Does a dental practice need to register X-ray equipment with the HSE?

Yes. Under the Ionising Radiations Regulations 2017 (IRR17), a dental practice in Great Britain must hold a registration from the Health and Safety Executive (HSE) before it uses X-ray equipment [1][2]. Registration is the middle of three grades [3]. Dental X-ray work does not need consent, the highest [2]. Northern Ireland has its own regulations and registers through HSENI [4][5].

The rules below come from two kinds of source. The law is IRR17, the fees regulations that go with it, and Northern Ireland's own regulations. The guidance is HSE's and HSENI's web pages, HSE's L121 guidance on IRR17, and the Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment (2nd edition, 2020). Each rule names the one it comes from.

Which grade of HSE authorisation does dental radiography need?

IRR17 sorts work with ionising radiation into three grades by risk. Low-risk work is notified to HSE, medium-risk work needs a registration, and high-risk work needs consent [3]. The regulations set these out as notification in regulation 5, registration in regulation 6 and consent in regulation 7 [6][1][7].

Dental X-ray equipment sits in the middle grade. HSE's guidance says a dentist or dental practice using X-rays needs a registration for radiation generators, and that consent does not apply [2]. HSE's list of work that needs registration names "X-ray devices used by dentists, vets, chiropractors and NHS trusts" [8][9].

In law, regulation 6(3) of IRR17 says an employer must not carry out a registrable practice until it has applied for, and been issued with, a registration [1]. Away from nuclear premises, the authority that issues it is HSE [1]. IRR17 covers England, Wales and Scotland [1].

HSE's L121 guidance tells employers to apply through the online system before carrying out the work [10]. The Guidance Notes tell the employer to register before use of the X-ray equipment begins [11]. They call working with X-ray generators without a registration an offence [11].

Consent covers a list of specified practices in regulation 7 of IRR17, such as operating an accelerator, industrial radiography and industrial irradiation [7]. None of them names dental imaging [7].

Northern Ireland runs under the Ionising Radiations Regulations (Northern Ireland) 2017 (IRRNI17), with the Health and Safety Executive for Northern Ireland (HSENI) as the authority [4][5]. Its regulation 6(3) carries the same bar on working before a registration is issued [5]. HSENI lists x-ray devices used by dentists under registration [12]. The Guidance Notes put it for the whole UK: every dental practice registers its work with a radiation generator, with HSE in Great Britain or HSENI in Northern Ireland [11].

What does a practice submit, and what does it cost?

Applications go through RADAN, HSE's online service [2]. HSENI takes its applications through the same platform [13]. You can save a part-finished application and come back to it [2].

An authorised employee submits it [2]. HSE says this will usually be someone directly involved in the work, such as the radiation protection supervisor (RPS), or someone with the same level of knowledge and training [2]. A radiation protection adviser (RPA) who is an employee of the practice can submit if authorised [2]. An outside RPA, or any other third party, can advise but cannot submit [2]. HSENI sets the same rule [13]. The Guidance Notes say an RPA may help, and is not allowed to complete the registration for the employer [11].

HSE asks for the extent and purpose of the work, including the approximate number of X-ray generators and the premises where they are used [2]. HSENI says you register once, however many sites you have [4]. HSE's pages carry no such sentence for Great Britain.

The Guidance Notes describe the form as it stood in 2020. It asked for basic details such as the name, address and number of premises, and for declarations that certain IRR17 requirements are in place [11]. The declarations they list are [11]:

• a risk assessment has been completed
• doses to employees have been estimated and appropriate steps taken
• the actions the risk assessment identified to restrict exposures have been taken
• contingency plans cover all reasonably foreseeable radiation accidents
• a suitable RPA has been appointed and consulted
• employees and other people have had training, information and instruction
• controlled and/or supervised areas are designated and marked out
• local rules are drawn up, and radiation protection supervisors appointed where required

The Guidance Notes flag one wrong turn on the form. A question about staff "expected dose", or about the Radiation (Emergency Preparedness and Public Information) Regulations 2019, means a consent category was picked by mistake [11]. A dental practice selects "work with a radiation generator" only, unless it is working in an atmosphere containing radon above a certain level [11]. The Guidance Notes describe the 2020 form, and HSE now takes applications through RADAN, so the wording on screen may differ [11][2].

In law, the Health and Safety and Nuclear (Fees) Regulations 2022 charge a fee on each application for registration [14]. The fee is £27, in force since 1 April 2024 [14][15]. It was £26 from 1 April 2023 [18]. HSE's fees page, updated on 1 April 2026, gives the same £27 [19]. The inspectors' fee charged on other applications does not apply to a registration [14]. These fees rules cover Great Britain [15].

Northern Ireland currently charges no fee for notification, registration or consent [13]. HSENI says that position remains under review and may change [13].

When an application succeeds, HSE issues a certificate based on the information submitted, with conditions attached [3]. The Guidance Notes advise downloading the certificate of registration and the summary details, and keeping both at the practice [11].

When does the registration need updating?

In law, HSE can issue a registration with conditions, which may include a time limit, and can revoke it in writing at any time [1]. The employer must notify HSE immediately if the practice stops, or if a material change affects the details given at registration [1]. Northern Ireland's regulations carry the same duty to HSENI [5].

HSE's guidance says a registration does not need renewing unless there is a material change to the information given [16]. HSENI says the same [17]. A certificate's conditions can still carry a time limit, so read them [1].

HSE's examples of changes to report include [16]:

• a change of employer name: tell HSE the work has stopped under the old name, and register under the new one
• a change of employer address
• adding or removing categories of work in a registration
• a change in the use of portable radiation sources at sites other than the employer's

Report a change through HSE's ionising radiation contact form [16]. HSE's L121 guidance says employers must tell HSE of a significant change to the details submitted, or when the registered work has stopped for good [10].

In Northern Ireland, HSENI lists the same kinds of change [17]. It says a registration may no longer be valid if a significant change goes unreported [17].

Moving premises or changing address

The sources differ here. The 2020 Guidance Notes say a change of practice name or address means cancelling the original registration and making a new application [11]. HSE's current page lists a change of employer address as a change to report through the contact form, and keeps the new-registration route for a change of employer name [16]. HSE's page is the current one. L121 also gives an employer's change of address as its example of a significant change [10].

The Guidance Notes add that work at new premises needs registering where those premises are not covered by an existing registration made by the same employer [11].

Changing owner

Neither HSE page uses the word owner. HSE covers the change as a change of employer name, which means a new registration under the new name [16]. The Guidance Notes list a change of practice name or ownership as notifiable [11]. A new registration is an application, and the fees regulations charge on each application [14].

Only the Guidance Notes speak to a fee for a change. They say that only a material change involves paying another fee [11]. HSE's current pages send changes through the contact form and name no fee for reporting one [16].

Registrations from before October 2023

Registrations granted before 1 October 2023 continue to apply in Great Britain [3]. HSE said it would contact those holders before April 2024 for more information about the extent and purpose of their work, and that holders need do nothing until it does [3]. In Northern Ireland the same terms cover registrations granted before 4 December 2023 [13]. Neither page sets the holder a deadline.

Do CBCT or hand-held units change what is needed?

The regulations speak only in general terms.

IRR17 defines a radiation generator as a device capable of generating ionising radiation such as X-rays [7]. HSE lists X-ray devices used by dentists under registration [8]. The consent list in regulation 7 does not name dental or CBCT imaging [7]. Read against those definitions, a CBCT unit or a hand-held intra-oral unit is an X-ray device, in the registration grade with the practice's other sets. That reading comes from the definitions. No source here states it for CBCT or hand-held units.

The Guidance Notes give the one dental line on equipment. Buying a new type of dental X-ray set that the practice has not used before is not a material change [11]. Starting radiography at care homes with mobile X-ray equipment is one [11].

Where a unit is used is the change the sources name. HSE lists a change in the use of portable radiation sources at sites other than the employer's as a change to report [16]. The Guidance Notes say the registration form asks whether the employer works with portable sources at sites belonging to other employers [11]. A practice that takes its own X-ray equipment to care homes or other establishments answers yes [11]. HSENI lists the same change for Northern Ireland [17].

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

Registration covers the equipment. The two-minute reading test shows what you catch, and what you miss, on the radiographs it takes.