
Yes. The General Dental Council's Scope of Practice, in force across the UK since 1 November 2025, lists prescribing, taking and interpreting radiographs among the tasks dental hygienists and dental therapists generally undertake after registration. Each must be trained, competent and indemnified or insured for it. Under IR(ME)R, the employer decides which roles each person is entitled to perform.
What does the GDC's Scope of Practice say hygienists and therapists may do with radiographs?
The version in force is the GDC's Guidance on Scope of Practice, effective from 1 November 2025 [1]. The GDC published it on 16 September 2025 [2]. It replaced the 2013 Scope of Practice, which the GDC says "is no longer in use but is available for reference purpose only" [3]. The GDC's Scope of Practice page addresses anyone who works "in the UK as a registered dental professional" [6].
For both titles, radiography sits in the list of tasks the role "will generally undertake following registration" [1]. Here are the 2025 lines beside the 2013 ones:
| Title | Scope of Practice 2025, in force | Scope of Practice 2013, superseded |
|---|---|---|
| Dental hygienist | "Appropriately prescribing taking and interpreting radiographs within scope and competence." (p11) [1] | "prescribe radiographs" and "take, process and interpret various film views used in general dental practice" (p7) [4] |
| Dental therapist | "Appropriately prescribing, taking, and interpreting radiographs within scope and competence." (p15) [1] | "prescribe radiographs" and "take, process and interpret various film views used in general dental practice" (p8) [4] |
Read side by side, the 2025 wording drops "process" and "film views used in general dental practice", and adds "within scope and competence". The GDC says the revision "has not changed the scope of practice for any of the seven dental professional titles" and gives "greater clarity on existing title boundaries" [2][3][5].
A task listed for your title marks what the title allows. Your own scope depends on your training. The guidance says "just because a task is mentioned in relation to a professional group, it does not always mean that an individual will be trained, competent and indemnified or insured to undertake that task" [1]. The GDC's Scope of Practice page puts it in terms of the individual: if your title permits a procedure and you lack the training, experience or confidence to do it safely and competently, "it is outside your personal scope of practice" [6].
Which of those are part of training on qualification, and which are additional skills?
Radiography is part of the core role for both titles. The 2025 guidance lists it among the tasks hygienists and therapists "will generally undertake following registration" [1]. The 2013 version listed it among what they could undertake if trained, competent and indemnified, and neither role's list of additional skills mentioned radiography [4].
The guidance says your core scope "is largely defined by the learning outcomes and behaviours in the Safe Practitioner framework" for your title [1]. The Safe Practitioner frameworks for dental hygienists and for dental therapists carry the same three outcomes that bear on radiography [7][8]:
- C 1.15: "Explain the scientific principles of medical ionizing radiation and statutory regulations, and how these are applied to clinical practice"
- C 2.1.4: "Appropriately prescribe and/or interpret the findings of clinical investigations"
- C 2.1.5: "Undertake relevant special investigations and diagnostic procedures, including radiography"
These outcomes cover UK education programmes leading to GDC registration. They took effect on 1 August 2025, and the GDC expects all education providers to be mapped against the framework by the academic year 2030/31 [9].
The 2025 guidance gives no list of additional skills for hygienists or therapists. For each title it says that, "with additional training and experience", they "can provide additional services within their professional boundaries" [1]. To add a skill within your title's boundary, you "will need to undertake further training", and that training "must be sufficient to make you competent in the task" [1]. A skill you hold can lapse. The guidance says you may become "no longer competent to carry out a particular task or activity and require additional training to restore competence" [1].
When you qualified can matter, and the two primary sources on it give different years:
- The Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment (2020) say the scope of hygienists and therapists "was extended in 2013" to cover prescribing radiographs. Those who qualified before then "will not necessarily have acquired the necessary skills and abilities" for the referrer and IR(ME)R practitioner roles, or for clinical evaluation [10].
- The GDC's Direct Access page, updated 1 November 2025, says hygienists and therapists "who qualified after 2002 in the UK should have covered the full scope of practice in their training", while those who trained before 2002 or overseas may not have covered everything [11].
The Guidance Notes speak to the radiography roles under IR(ME)R. The GDC line speaks to the full scope in general. If you qualified in the UK between 2002 and 2013, the two sources read differently for you.
How does IR(ME)R entitlement fit with the Scope of Practice?
The nations differ here. The Ionising Radiation (Medical Exposure) Regulations 2017, IR(ME)R, cover Great Britain: England, Wales and Scotland [12]. Northern Ireland has its own regulations, the Ionising Radiation (Medical Exposure) Regulations (Northern Ireland) 2018 [13]. The DHSC's guidance to IR(ME)R 2017 does not apply in Northern Ireland [14]. The Guidance Notes say their references to IR(ME)R 2017 also apply to the Northern Ireland regulations [10]. The regulation text quoted below is the Great Britain version as amended.
The Scope of Practice points to rules like these. It says other regulations and legislation can "limit or permit" tasks and set their own training requirements, which "are not set by the GDC, but as a registered dental professional you are required to follow them" [1].
IR(ME)R names three duty holders for an exposure [12][15]:
- The referrer is a registered health care professional entitled to refer individuals for exposure to a practitioner.
- The practitioner is a registered health care professional entitled to take responsibility for the justification of an individual exposure.
- The operator is any person entitled to carry out practical aspects of an exposure, and practical aspects include clinical evaluation.
Since 1 October 2024, IR(ME)R has defined clinical evaluation as "interpretation of the information resulting from an exposure, including the outcome and implications" [12]. Interpreting a bitewing or a periapical radiograph is clinical evaluation. In Great Britain, that makes interpreting an operator task [12].
Entitlement is the employer's decision. The employer's written procedures must identify who may act as referrer, practitioner or operator "within a specified scope of practice" [16][17]. IR(ME)R uses "scope of practice" in its own sense here: DHSC guidance describes it as "the range of tasks that may be undertaken by them", and says "Entitlement and scope of practice should be supported by education and training" [14].
The GDC's words and IR(ME)R's words do not line up. The Guidance Notes, written in 2020 against the 2013 Scope of Practice, give a mapping they say "has been confirmed with the GDC and should be taken as the definitive interpretation" [10]:
| Scope of Practice wording | IR(ME)R role |
|---|---|
| Prescribing | Referrer and IR(ME)R practitioner |
| Taking | Operator |
| Interpreting | Operator, carrying out clinical evaluation |
Under that mapping, hygienists and therapists take these roles "if appropriately trained, competent and indemnified to do so", and "within their scope" [10].
The Guidance Notes also set limits by type of radiograph. As an example, they say a hygienist's or therapist's scope "might be expected to include" intraoral and possibly panoramic radiography, and never cephalometric radiography or dental cone-beam CT (CBCT) [10]. For those two, hygienists and therapists should not be expected to act as IR(ME)R practitioner or as operator (reporting), the Guidance Notes' term for the operator who carries out clinical evaluation [10]. They can clinically evaluate only images within their own scope of practice or experience [10].
Under direct access, hygienists and therapists can carry out their full scope of practice, except tooth whitening, without referral from a dentist [11]. The GDC says referral arrangements should make sure a dentist is available to "report" on aspects of a radiograph that are out of scope of the dental care professional (DCP) [11].
What training does each role need before taking or interpreting radiographs?
Training for registration follows the GDC's Safe Practitioner outcomes, which include radiography for both hygienists and therapists [7][8].
In Great Britain, IR(ME)R adds its own requirement. A practitioner or operator "must not carry out any exposure or any practical aspect without having been adequately trained" [18]. Schedule 3 defines adequate training as theoretical knowledge and practical experience in the listed subjects relevant to your functions and your area of practice [19]. The Guidance Notes, written in 2020 against IR(ME)R as first made, say that for general dental practice only the "General" and "Diagnostic radiology" sections under the "All Modalities" heading of Table 2 are relevant [10]. Table 2 has since been substituted, from 1 October 2024 [19]. IR(ME)R does not require the referrer to be adequately trained [14].
The Guidance Notes say hygienists and therapists who qualified after 2013 and are registered with the GDC are adequately trained to justify intraoral and panoramic radiographs [10]. The GDC's Direct Access page uses 2002 as its year for having covered the full scope in training [11].
IR(ME)R accepts a certificate from an institute or person competent to award degrees or diplomas as sufficient proof of adequate training, if the certificate says so [18]. The sources on this page name no particular certificate that hygienists or therapists must hold before taking or interpreting intraoral radiographs. A trainee can take part in practical aspects under the supervision of an adequately trained person [18]. The employer must keep an up-to-date record of the relevant training of every practitioner and operator it engages [18].
Training continues after qualification. The employer must take steps to ensure every practitioner and operator undertakes continuing education and training, including training in any new technique they use [10][16]. The GDC lists radiography and radiation protection among its highly recommended CPD topics: "if you undertake radiography, we recommend at least five hours in each cycle" [20].
Dental CBCT needs further training beyond qualification [10]. The Guidance Notes intend Level 1 core CBCT training for hygienists and therapists who are already adequately trained to take 2D radiographs, and Level 2 operator training for those who act as operators undertaking dental CBCT examinations [10]. The CBCT training for justification and interpretation is not for them, since the IR(ME)R practitioner and operator (reporting) roles are not relevant to their practice in CBCT [10].
The sources on this page were checked on 23 September 2026.
Interpreting a radiograph is a reading skill. The two-minute reading test shows what you catch on real radiographs and what you miss.
References
- General Dental Council. Guidance on Scope of Practice. Effective from 1 November 2025. Source (accessed 23 September 2026).
- General Dental Council. GDC publishes revised Scope of Practice guidance. News, 16 September 2025. Source (accessed 23 September 2026).
- General Dental Council. Review of the Scope of Practice guidance. No date shown on page. Source (accessed 23 September 2026).
- General Dental Council. Scope of Practice. Effective from 30 September 2013; superseded 1 November 2025. Internet Archive copy (25 May 2025) of the GDC's file at Source: Source (accessed 23 September 2026).
- General Dental Council. Revisions to the Scope of Practice guidance: consultation outcome report. Published September 2025. Source (accessed 23 September 2026).
- General Dental Council. Scope of Practice guidance (web page). No date shown on page. Source (accessed 23 September 2026).
- General Dental Council. The Safe Practitioner: A framework of behaviours and outcomes for dental professional education. Dental Hygienist. November 2023. Source (accessed 23 September 2026).
- General Dental Council. The Safe Practitioner: A framework of behaviours and outcomes for dental professional education. Dental Therapist. November 2023. Source (accessed 23 September 2026).
- General Dental Council. Learning outcomes and behaviours. No date shown on page. Source (accessed 23 September 2026).
- Public Health England and Faculty of General Dental Practice (UK). Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment. 2nd edition, 2020. Hosted by the College of General Dentistry. Source (accessed 23 September 2026).
- General Dental Council. Direct access. Updated 1 November 2025. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 2 (Interpretation). UK legislation, published by The National Archives on legislation.gov.uk; latest revised version, as amended by SI 2024/896 from 1 October 2024; extent Great Britain. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations (Northern Ireland) 2018, SR 2018/17, regulation 2. Northern Ireland legislation, published by The National Archives on legislation.gov.uk; as made. Source (accessed 23 September 2026).
- Department of Health and Social Care. Guidance to the Ionising Radiation (Medical Exposure) Regulations 2017. Updated 4 September 2024. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 10 (Duties of the practitioner, operator and referrer). UK legislation, legislation.gov.uk; latest revised version, as amended by SI 2024/896. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 6 (Employer's duties). UK legislation, legislation.gov.uk; latest revised version. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, Schedule 2 (Employer's Procedures). UK legislation, legislation.gov.uk; latest revised version, as amended by SI 2024/896. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, regulation 17 (Training). UK legislation, legislation.gov.uk; latest revised version. Source (accessed 23 September 2026).
- The Ionising Radiation (Medical Exposure) Regulations 2017, SI 2017/1322, Schedule 3 (Adequate Training). UK legislation, legislation.gov.uk; latest revised version. Source (accessed 23 September 2026).
- General Dental Council. Recommended CPD topics (Enhanced CPD scheme 2018). No date shown on page. Source (accessed 23 September 2026).
Dr. Wael Mansour
Papilla helps dental students, dentists, and dental hygienists learn to read radiographs, one real case at a time, against outlines drawn by expert annotators.