What IR(ME)R training does a dentist need?

In Great Britain, IR(ME)R 2017 says a dentist who justifies, takes or clinically evaluates radiographs must be adequately trained: theory and practical experience in the Schedule 3 subjects relevant to that role [1][2][3]. The employer must take steps to ensure this happens and continues, and keep a dated record [4][1]. The law sets no refresher interval or hours [4][1].

IR(ME)R, often written IRMER, is the Ionising Radiation (Medical Exposure) Regulations 2017 (SI 2017/1322). It covers England, Wales and Scotland [1]. It was last amended by SI 2024/896, in force on 1 October 2024 [5]. On 23 September 2026, legislation.gov.uk listed no outstanding changes to it [6].

This page keeps two kinds of rule apart. What the law requires comes from the regulations. What is recommended comes from the Department of Health and Social Care (DHSC), the General Dental Council (GDC) and the 2020 Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment. DHSC says its guidance is not binding [7]. The Guidance Notes use "must" for a legal requirement and "should" for a recommendation [8].

What does regulation 17 of IR(ME)R 2017 require?

Regulation 17 is the training rule. A practitioner or operator must not carry out any exposure, or any practical aspect of one, without having been adequately trained [1]. "Adequate training" means training that satisfies Schedule 3 [3], and regulation 17(6) points there for the detail [1].

The rest of regulation 17 does four things [1]:

• A certificate from an institute or person competent to award degrees or diplomas, or to provide other evidence of adequate training, is sufficient proof of adequate training if the certificate says so (17(2)).
• A trainee may take part in practical aspects as part of practical training, under the supervision of an adequately trained person (17(3)).
• The employer must keep an up-to-date record of the training of every practitioner and operator it engages (17(4)).
• Where another employer supplies the practitioner or operator, that other employer keeps the records and must supply them immediately on request (17(5)).

DHSC's guidance says the nature and extent of supervision depends on the task and on the trainee's existing training and experience [7]. A trainee who works without the direct supervision of an adequately trained person counts as an operator [3].

The 2024 amendments replaced the Schedule 3 tables and left the wording of regulation 17 as it was in 2018 [1][2].

Northern Ireland

Northern Ireland has its own regulations, the Ionising Radiation (Medical Exposure) Regulations (Northern Ireland) 2018 (SR 2018/17) [9]. The training rule there is also regulation 17. The 2024 amendments extend to England, Wales and Scotland only [5]. legislation.gov.uk holds the Northern Ireland regulations only in their original 2018 form, with the original Schedule 3 tables [9].

What training does Schedule 3 list for practitioners and operators?

Schedule 3 says practitioners and operators must have successfully completed training, including theoretical knowledge and practical experience, in two sets of subjects [2]:

• the subjects in Table 1 that are relevant to their function as practitioner or operator
• the subjects in Table 2 that are relevant to their specific area of practice

Both tables were replaced on 1 October 2024 by SI 2024/896 [2][5].

Table 1 covers radiation production, radiation protection and statutory obligations [2]. Its groups are:

• Physics of radiation: excitation and ionisation, attenuation, scattering and absorption.
• Radiation hazards and dosimetry: biological effects, risks and benefits, and the dose quantities and their units.
• Special attention areas: pregnancy and potential pregnancy, breastfeeding, infants and children, carers and comforters, asymptomatic individuals, and others.
• Justification and authorisation: justification of the individual exposure, use of existing radiological information, and alternative techniques.
• Radiation protection: diagnostic reference levels, dose optimisation, dose recording and dose audit, quality assurance for written procedures and protocols, quality control of equipment, risk communication, protection devices, and others.
• Statutory requirements: the regulations, non-statutory guidance, local procedures, individual responsibilities, clinical audit, and accidental or unintended exposures.

Table 2 covers diagnostic radiology, radiotherapy and nuclear medicine [2]. Its "All Modalities" and "Diagnostic radiology" headings include:

• All modalities, general: radiological anatomy, factors affecting radiation dose, dosimetry, clinical evaluation, identifying the individual being exposed, and equipment specification.
• Diagnostic radiology, general: principles of radiological techniques and production of X-rays.
• Diagnostic radiology, practical aspects: patient positioning, equipment selection and use, protocol selection, optimisation of image quality and radiation dose, dose assessment and recording, and image acquisition, artefacts, processing, display and storage.

The rest of Table 2 covers contrast media, CT, interventional procedures, hybrid imaging, radiotherapy and nuclear medicine [2].

What the guidance says about which subjects apply

DHSC's guidance says not every Schedule 3 subject has to be covered. What is needed depends on the exposures and modalities the practitioner or operator works with [7].

The 2020 Guidance Notes say that for general dental practice only the "General" and "Diagnostic radiology" sections under the "All Modalities" heading in Table 2 are relevant [8]. That pointer was written in 2020, before Table 2 was replaced in 2024. The College of General Dentistry still presents the 2020 second edition [10].

The Guidance Notes also recommend what a verifiable CPD course in radiation protection should cover [8]. For practitioners and operators alike, that is the principles of radiation physics, the risks of ionising radiation, radiation doses in dental radiography, the factors affecting those doses, the principles of radiation protection, statutory requirements and quality assurance. Selection criteria are added for practitioners only.

Who is responsible for making sure the training happens?

The employer. Regulation 6(3) requires the employer to take steps to ensure that every practitioner and operator it engages is adequately trained under regulation 17(1) [4]. The same regulation requires the employer to take steps to ensure they undertake continuing education and training after qualification, including training on new techniques and their radiation protection requirements [4].

DHSC's guidance reads this as a duty to take steps so that the training is undertaken. It says the employer is under no duty to provide continuing education and training itself [7].

The employer's written procedures must identify who is entitled to act as referrer, practitioner or operator, within a specified scope of practice [11]. The Guidance Notes add that the employer must define this in writing and make sure everyone entitled is trained and competent for the role [8].

Under regulation 2(2), a person who holds more than one role carries the duties of each [3]. DHSC gives some dental practitioners as an example of one person acting as several duty holders [7]. Where the employer is also practitioner or operator, DHSC says the employer must make sure their own continuing education and training is undertaken, and must keep training records [7]. A practice owner who refers, justifies and takes radiographs answers for their own training record as well as the team's.

What the law sets and what is recommended

IR(ME)R sets no interval and no number of hours. Regulation 6(3) asks for continuing education and training after qualification and attaches no figure to it [4]. Neither regulation 17 nor Schedule 3 adds one [1][2].

The five-year figures in dental guidance are recommendations. The GDC recommends at least five hours of radiography and radiation protection CPD in each five-year CPD cycle for anyone who undertakes radiography [12][13]. The Guidance Notes repeat that recommendation [8].

The Guidance Notes' checklist for the Ionising Radiations Regulations 2017 (IRR17) says radiation-safety training should be refreshed at least every five years, or when the work changes [8]. IRR17 protects workers. That training is a separate duty from IR(ME)R's adequate training.

How do the referrer, practitioner and operator roles differ in a dental practice?

The regulations define each role by what it does [3][14]:

• The referrer is a registered health care professional entitled, under the employer's procedures, to refer individuals to a practitioner for exposure. The referrer must give the practitioner enough medical data to decide whether the exposure has a sufficient net benefit.
• The practitioner is a registered health care professional entitled to take responsibility for justifying an individual exposure.
• The operator is anyone entitled to carry out practical aspects of the exposure.

All three must follow the employer's procedures [14].

Practical aspects include clinical evaluation [3]. The Guidance Notes list the dental ones: patient identification; positioning the image receptor, the patient and the tube head; setting the exposure parameters; pressing the exposure button; processing phosphor plates or films; clinical evaluation of radiographs; and exposing test objects for quality assurance [8]. So the person who reports a bitewing or a periapical radiograph is acting as an operator for that step [3][8].

Regulation 17 and Schedule 3 apply to practitioners and operators [1][2]. The regulations do not require the referrer to be adequately trained. DHSC says referrers must still understand their regulation 10 duties and follow the employer's procedures [7]. The Guidance Notes strongly recommend training for anyone who refers for dental CBCT [8].

In general dental practice one dentist commonly acts as referrer, practitioner and operator. Nurses, hygienists, therapists and other dental care professionals commonly carry out some or all of the operator's functions [8].

The Guidance Notes go further on hygienists and therapists. They say that GDC-registered dentists, and hygienists and therapists who qualified after 2013, are adequately trained to justify intraoral, panoramic and cephalometric radiographs [8]. Hygienists and therapists should not normally be expected to justify cephalometric radiography or dental CBCT [8]. Whatever their date of qualification, the employer should make sure their skills are adequate and up to date for every role they perform [8].

Where the 2020 guidance has aged

The Guidance Notes' role table (their Table 3.1) rests on the GDC's 2013 Scope of Practice. The GDC has since published Guidance on Scope of Practice, effective from 1 November 2025 [15]. Read the 2020 table as the Guidance Notes' view at the time.

The 2025 GDC guidance lists prescribing, taking and interpreting radiographs within scope and competence among the tasks of dental hygienists and dental therapists [15]. It says clinical dental technicians can prescribe, undertake and interpret radiographs within their scope and competence [15]. For dental nurses, it says taking radiographs needs specific training and certification set by other regulatory bodies [15]. The GDC also says other legislation can set training requirements that registrants must follow [15].

What training records does the practice need to keep?

Regulation 17(4) requires the employer to keep an up-to-date record of all relevant training of every practitioner and operator it engages [1]. The record must show:

• the date or dates on which adequate training was completed
• the nature of the training

The record must be available for inspection by the relevant enforcing authority [1]. In England that is the Care Quality Commission [3]. In Scotland and Wales the regulations name the Scottish Ministers and the Welsh Ministers, and DHSC says these are Healthcare Improvement Scotland and Healthcare Inspectorate Wales [3][7]. In Northern Ireland it is the Department [9].

Where another employer supplies a practitioner or operator, such as an agency, that employer keeps the records and must supply them immediately on request [1][7]. The Northern Ireland wording is "forthwith" [9].

The Guidance Notes point out that IR(ME)R sets no retention period for its records [8].

What the guidance recommends

DHSC recommends that the record include practical training on specific equipment or functions, such as dose-saving devices, where they differ significantly from the usual [7]. It suggests induction on the employer's procedures and protocols may count as training [7]. It says records should be stored so they can be produced for inspection, for example separately from personnel files [7].

The Guidance Notes include a template procedure for entitlement and training [8]. It keeps an up-to-date record of qualifications, evidence of training and CPD for each entitled person, held by the practice, or by each duty holder with an annual assessment. The template form asks for:

• name and job title
• qualifications and the dates they were obtained
• GDC registration number and the date it was last checked
• who holds the training records
• each task the person is assigned, signed off as competent with the date and the initials of the duty holder and the assessor

Under the template, training on induction and on any new X-ray equipment or software is documented in each duty holder's training record [8].

On retention, the Guidance Notes advise keeping records of qualifications throughout employment. They advise keeping training records in radiology and radiation protection for at least five years after the end of the CPD cycle they relate to [8].

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

Take the two-minute reading test to see what you catch on real radiographs and what you miss.