What does a radiation protection supervisor do in a dental practice?

A radiation protection supervisor (RPS) supervises dental radiography so that staff follow the practice's local rules. The Ionising Radiations Regulations 2017, and Northern Ireland's matching regulations, require the employer to appoint one or more suitable RPSs, name them in the local rules and give them the means to do the role. Legal responsibility stays with the employer.

What does IRR17 require of a radiation protection supervisor?

Regulation 18(5) of the Ionising Radiations Regulations 2017 (IRR17) puts three duties on the employer. It must appoint one or more suitable radiation protection supervisors "for the purpose of securing compliance with these Regulations in respect of work carried out in any area made subject to local rules". It must set down their names in the local rules. And it must provide the means they need to perform their role.

IRR17 covers England, Wales and Scotland, and came into force on 1 January 2018. Northern Ireland has its own Ionising Radiations Regulations (Northern Ireland) 2017, in operation from the same date. Its regulation 18(5) sets the same three duties in matching words, with "shall" in place of "must".

The duty attaches to areas under local rules. IRR17 requires written local rules for every controlled area. The dental Guidance Notes say that people taking dental radiographs generally have to follow special procedures to restrict significant exposure, so a controlled area will need to be designated under regulation 17. Whenever a controlled area is designated, they say, the employer must appoint an RPS.

IRR17 does not define a radiation protection supervisor, and it does not define "suitable". Regulation 2, the interpretation regulation, defines the radiation protection adviser and has no entry for the supervisor. What makes someone suitable comes from guidance.

Two guidance documents fill that gap, and each says how much weight it carries. HSE's L121 is the Approved Code of Practice and guidance to IRR17. Its code text has special legal status. Its guidance text is not compulsory, though following it will normally be enough to comply with the law. Every L121 paragraph on the RPS, 345 to 352, is guidance text. The dental Guidance Notes, published in 2020 by Public Health England and FGDP(UK), use "must" only where the law or the code requires something, and "should" for recommendations.

L121 is written for Great Britain. HSENI's ionising radiation page links to it, and the sources name no separate Northern Ireland code. The Guidance Notes read their references to IRR17 as covering the Northern Ireland regulations too.

Both documents make the same point about responsibility. The RPS helps make sure the employer's arrangements are followed, and the legal responsibility stays with the employer. It cannot be delegated to the RPS.

The regulation puts the RPS's name in writing, in the local rules. It does not ask for an appointment letter. L121 guidance says the role "should be confirmed in writing so there is no confusion about the work expected of them". The Guidance Notes say the appointment should be confirmed in writing, and the employer should confirm in writing what is expected of the RPS. Both are recommendations. The radiation protection adviser is handled differently: IRR17 requires that appointment in writing, with the scope of the advice.

Northern Ireland's regulations carry the same legal duties at the same regulation numbers.

What does an RPS do day to day in a dental practice?

The job is supervision. The Guidance Notes give the RPS's key function as supervising the work with ionising radiation "with the aim of ensuring that employees adhere to the requirements of the local rules". L121 guidance describes the same role: supervising the arrangements set out in the local rules.

None of the sources on this page gives a full list of daily duties. The Guidance Notes describe tasks that employers commonly hand to the RPS on top of supervision:

• administering personal dosimetry
• arranging testing and maintenance of the X-ray equipment
• keeping records
• liaising with the radiation protection adviser

These are common practice. The Guidance Notes do not require them of the RPS, and handing them over leaves legal responsibility with the employer.

The RPS is the named contact. The local rules carry the RPS's name. Staff who are not directly involved in radiography, such as receptionists and cleaners, should be trained in the local rules, including the RPS's name and contact details in case of emergency.

Equipment problems reach the RPS as well. The Guidance Notes say every operator should check the X-ray equipment's safety and warning features daily and bring problems directly to the RPS or the employer. The results of these checks should be formally recorded at intervals not exceeding once every six months.

L121 guidance says it may not always be necessary for an RPS to be present all the time.

Visiting engineers fall under their own employer's arrangements. When an outside employer's staff work on the equipment, the Guidance Notes say the practice's RPS will not have been suitably trained to supervise that work, and the practice's local rules will not cover it. Among the duties of the engineers' employers, the Guidance Notes list appointing suitable staff as RPSs and training them.

Who can be appointed RPS, and what training do the sources say they need?

L121 guidance sets out what an appointed RPS should be able to do. An RPS should:

• know and understand the requirements of the Regulations and the local rules relevant to the work
• command enough authority from the people doing the work to supervise its radiation protection aspects
• understand the precautions to be taken and how far they restrict exposure
• be given enough time and resources to carry out the role
• know what to do in an emergency

The dental Guidance Notes repeat these points for dental radiography.

L121 guidance says an RPS will generally be an employee of the employer, usually in a line-management position close to the work, so they can exercise supervisory authority. It adds that a radiation protection unit set up by the employer, or a radiation protection adviser, may carry out the role. The Guidance Notes say that ideally the RPS is an employee who works at the practice and is closely involved in dental radiography.

Both documents bring in the radiation protection adviser here. L121 says employers should consider the need for the adviser's advice on the suitability of RPS appointments. The Guidance Notes say the adviser should be consulted on who in the practice would be a suitable candidate.

The regulations, L121 and the Guidance Notes describe the person and name no profession. Scotland's SDCEP Practice Support Manual is the one source that does. For practices in Scotland, it says the RPS "can be a dentist or a dental care professional (DCP) who has had the appropriate training", and that evidence of relevant training should be available.

On numbers, L121 guidance says employers need to weigh the range and complexity of the work and the number of different locations to be covered. It adds that "the number of RPSs must be sufficient to make sure that the work is adequately supervised". The Guidance Notes say that unless the practice is particularly large, one or two RPSs will generally be sufficient to supervise the work and give continuity of cover. None of the sources sets a rule of one RPS per site.

The legal training duty is general. IRR17 regulation 15 requires the employer to give employees who work with ionising radiation appropriate training in radiation protection, repeated at appropriate intervals and documented. It names no RPS training and sets no hours, course or interval. Northern Ireland's regulation 15 carries the same duty.

L121 guidance says RPSs should receive appropriate training under regulation 15, reflecting the complexity of the work. It should include periodic refresher training, and training when the local rules change.

The dental Guidance Notes say more about content and timing. RPS training, including refreshers, should cover these subjects as they apply to dental radiography:

• radiation protection principles and procedures
• the requirements of IRR17
• the arrangements in the local rules and contingency plans

The training can be a formal course, or a presentation by a suitable person such as the radiation protection adviser. The Guidance Notes give "a period of no longer than five years" as a suitable interval for refresher training for RPSs in dental radiography.

Here the sources differ. L121 asks for periodic refreshers and sets no interval. The five-year interval is the Guidance Notes' recommendation, and it does not appear in IRR17 or L121.

IR(ME)R update training does not count by default. The Guidance Notes say update courses for dentists and dental care professionals under IR(ME)R 2017 are adequate as RPS training only if they also cover the RPS subjects above.

None of the sources on this page names an RPS course or sets a minimum length or number of hours.

How does the RPS differ from the radiation protection adviser?

The adviser advises the employer, and the supervisor supervises the work. Under IRR17 regulation 14, the employer must consult suitable radiation protection advisers on observing the Regulations, and in any event on the matters in Schedule 4:

• controlled and supervised areas
• examining plans for installations, and accepting new or modified sources of ionising radiation into service
• regular calibration of equipment that monitors ionising radiation
• periodic examination and testing of engineering controls, safety features and warning devices, and regular checking of systems of work

The employer must appoint the adviser in writing, with the scope of the advice the adviser is to give. The supervisor is appointed under regulation 18 to secure compliance in the areas under local rules. Northern Ireland's regulation 14 sets the same duties.

The law sets a competence scheme for the adviser and none for the supervisor. IRR17 defines a radiation protection adviser as an individual or body meeting criteria of competence specified in writing by HSE. In Northern Ireland those criteria can come from HSENI or from HSE. HSE considers an individual to meet the core competence requirements if they hold a certificate from an HSE-recognised assessing body or a Radiological Protection Level 4 National or Scottish Vocational Qualification (N/SVQ). Certificates are normally reassessed every five years. HSE's adviser page adds that the N/SVQ must have been issued within the last five years. Holding either does not, by itself, make someone a suitable adviser for a particular employer. For the RPS, regulation 18 says only "suitable".

For dentistry, the Guidance Notes say a suitable adviser meets HSE's core competence criteria and has specific knowledge and experience of radiation protection in dental diagnostic radiology. They recommend appointing the adviser on an ongoing basis, and getting advice on the substantive requirements of IRR17 in writing.

The sources do not require the adviser to come from outside the practice. L121 guidance says advisers can be part-time or full-time employees or consultants. An adviser appointed on a continuing basis need not be present every time work with ionising radiation takes place. The difference the sources draw is in the job: advice for the adviser, supervision for the RPS.

The two roles meet at the local rules. The Guidance Notes say the local rules must be drafted after consulting the adviser. The adviser should be consulted on suitable RPS candidates, and can deliver RPS training. Liaison with the adviser is one of the tasks employers commonly give the RPS.

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

The supervisor makes sure the local rules are followed when radiographs are taken. Take the two-minute reading test to see what you catch on a radiograph, what you miss and what to work on first.