Does every dental radiograph need a written report?

Yes. The law requires a recorded clinical evaluation of every dental exposure, except an exposure of a carer or comforter. In Great Britain the duty is regulation 12(9) of IR(ME)R 2017; Northern Ireland's regulations, as made in 2018, use the same words. The dental Guidance Notes ask for a record that shows each image was evaluated and can be audited later.

What does IR(ME)R require after every dental exposure?

Regulation 12(9) of the Ionising Radiation (Medical Exposure) Regulations 2017 reads: "The employer must take steps to ensure that a clinical evaluation of the outcome of each exposure, other than where the person subject to the exposure is a carer or a comforter, is recorded in accordance with the employer's procedures including, where appropriate, factors relevant to patient dose." [1]

That is the law, and the duty sits with the employer. It covers each exposure, so every bitewing, periapical and panoramic radiograph you take needs one. Carers and comforters are the only exception the regulation makes [1].

The regulation's term is clinical evaluation, and the Guidance Notes call the written record a clinical evaluation report [8]. Regulation 2(1) defines it as "interpretation of the information resulting from an exposure, including the outcome and implications" [2]. That definition came into force on 1 October 2024 [5].

Regulation 12(9) leaves the detail to the employer's procedures. Schedule 2 paragraph 1(j) requires the employer's written procedures to include one "for the carrying out and recording of a clinical evaluation for each exposure" [3]. Regulation 10(1) requires the practitioner, the operator and the referrer to comply with those procedures [4]. The 2024 amending regulations changed Schedule 2's "an evaluation" to "a clinical evaluation" and left regulation 12(9) as it was [5].

IR(ME)R 2017 extends to England, Wales and Scotland [1]. Northern Ireland has its own regulations, IR(ME)R (Northern Ireland) 2018, and their regulation 12(9), in the text as made, carries the same duty word for word [6].

Guidance fills in detail the regulation leaves out. The Department of Health and Social Care (DHSC) recommends that the evaluation be accurate and timely, so that it contributes to the person's care, and says that in practice it might include the diagnostic findings [7].

The dental Guidance Notes use "must" for a legal requirement and "should" for a recommendation [8]. They say the clinical evaluation must cover the whole image, including any regions outside the area of interest [8]. That is the Guidance Notes' reading of the duty; the words "whole image" do not appear in regulation 12(9) [1]. Covering the whole image is the job of a radiographic search pattern.

What should the record of a clinical evaluation hold?

The regulation itself names one item for the record: factors relevant to patient dose, where appropriate [1]. The rest comes from guidance, and the table below marks which is which.

The Guidance Notes say the term clinical evaluation covers both interpreting the image and documenting the findings, and that it is a separate process from image quality rating [8]. The record does not need to be a full radiology report. It should show that each image has been clinically evaluated, with enough recorded for a later audit [8].

The findings in the Guidance Notes are examples. Their template procedure D8 is a model for each practice to edit as required, so its list is a recommendation [8].

On dose, the DHSC guidance says the relevant factors should go in the record where appropriate, because they might let the person's effective dose be estimated later [7]. The Guidance Notes' template D9 records off-protocol settings, the total number of exposures and the reason for any repeat exposure [8].

Timing is guidance too. The regulation sets no deadline [1]. The Guidance Notes say the evaluation should be made on the same day as the exposure where possible, and recorded as soon as possible after [8].

Planning treatment from the image is itself evidence of a clinical evaluation, the Guidance Notes say, provided the records show which images were used and who did the planning [8]. When more than one person reports on an image, each must record an evaluation [8]. For the practice's own patients, the Guidance Notes say the record should be made in the patient's notes [8].

The record also feeds audit. The employer's procedures must include one for clinical audit [3], and the Guidance Notes say the audit should include the clinical evaluation of radiographs [8].

Who is allowed to write the clinical evaluation?

In law, clinical evaluation is one of the practical aspects of an exposure [2]. A person who carries out practical aspects is an operator: anyone the employer's procedures entitle to do so [2]. The law sets no professional registration for the operator; the practitioner, who takes responsibility for justifying the exposure, must be a registered health care professional [2].

The operator must be adequately trained, is responsible for each practical aspect they carry out, and must follow the employer's procedures [4]. Those procedures must identify who is entitled to act as operator within a specified scope of practice [3]. So the employer names who may write the clinical evaluation.

In a dental practice one dentist commonly acts as referrer, IR(ME)R practitioner and operator [8]. The DHSC guidance gives some dental practitioners as its example of one person holding more than one of these roles [7]. The Guidance Notes call operators who clinically evaluate images "operators (reporting)" [8].

Two guidance documents of different dates say which roles can do this. They agree on every role but one.

The two documents disagree on clinical dental technicians. The Guidance Notes, published in 2020, say they do not clinically evaluate radiographs [8]. The GDC's Guidance on Scope of Practice, effective from 1 November 2025, says they can interpret radiographs within their scope and competence [9]. The GDC document is the later of the two. Neither is the law; under IR(ME)R, the employer's procedures name who is entitled to act as operator [3].

For dental CBCT, the Guidance Notes say the operator (reporting) role should sit only with dentists who have had additional training [8].

A referred patient's images have two routes. The practice that took the images may send a report to the referring clinician, or return the images without one under an arrangement for the referrer to carry out and record the clinical evaluation [8]. The referring dentist then becomes an operator (reporting) and should be adequately trained for the interpretation [8]. The Guidance Notes add that an exposure should not be justified or authorised unless the IR(ME)R practitioner knows who will write the clinical evaluation [8].

Since the 2024 amendments, software that directly assists an operator in carrying out a clinical evaluation counts as equipment under IR(ME)R [2]. The DHSC guidance says such software may support clinical evaluation and cannot be used autonomously [7].

What if the radiograph cannot be evaluated?

Regulation 12(9) covers each exposure, and its only exception is a carer or comforter [1]. Neither the regulation, the DHSC guidance nor the Guidance Notes sets out how to record the clinical evaluation of an image that cannot be read.

What the Guidance Notes do cover is image quality rating, which they keep separate from clinical evaluation [8]. They recommend rating each image diagnostically acceptable (A) or not acceptable (N) [8]. For each N image, the practice should record the date, the nature of the deficiency, its known or suspected cause, and the number of repeat images taken [8]. That record feeds reject analysis. Whether to take a repeat is covered in when to retake a dental radiograph.

The Guidance Notes also say that if no clinical evaluation takes place, this indicates the radiograph was not justified, and the exposure should not have taken place [8].

The sources on this page were checked on 23 September 2026.

A clinical evaluation is only as good as the reading behind it. The two-minute reading test shows what you catch on real radiographs and what you miss.