Who can justify a dental radiograph under IR(ME)R?

Under IR(ME)R 2017, which covers Great Britain, only an IR(ME)R practitioner can justify a dental radiograph: a registered health care professional, such as a GDC registrant, whom the employer's written procedures entitle to do it. Dentists commonly hold the role, and trained, entitled hygienists and therapists can too. No exposure may be carried out until it is justified.

The Ionising Radiation (Medical Exposure) Regulations 2017 apply in England, Wales and Scotland, and were amended from 1 October 2024 [1][2]. Northern Ireland has its own regulations, made in 2018, and the Department of Health and Social Care (DHSC) guidance to IR(ME)R does not apply to them [3][8]. This page reads the Great Britain rules. It says IR(ME)R practitioner in full, because the role is separate from being a dental practitioner.

What is justification, and what happens if it is skipped?

Justification is the decision that an exposure's benefit to the patient outweighs its harm. The regulations say no one may carry out an exposure unless an IR(ME)R practitioner has justified it as showing a sufficient net benefit [1]. The practitioner weighs four matters:

• the specific objectives of the exposure and the characteristics of the patient
• the total potential diagnostic or therapeutic benefit, to the patient and to society
• the detriment the exposure may cause the patient
• alternative techniques with the same objective and less or no ionising radiation

The practitioner must also take account of the clinical data the referrer supplies, and consider it in order to avoid unnecessary exposure [1]. The regulations define radiodiagnostic to include dental radiology, so the rule applies to every exposure from a single bitewing to a dental CBCT scan [1].

The Guidance Notes for Dental Practitioners on the Safe Use of X-ray Equipment (2020), called the Guidance Notes below, put the same test in chairside terms. Before the exposure, the IR(ME)R practitioner decides whether the benefit of the diagnostic information will outweigh the detriment of the exposure, and the radiograph would normally be expected to aid or change the patient's management or prognosis [4]. They draw two consequences. There is no justification for routine radiographs of new patients without a thorough clinical examination. Where the referrer's information is incomplete, the practitioner should not justify and authorise the exposure until it has been provided [4].

Authorisation is a separate step. It is the record that shows justification took place, and the employer sets the method [1][3][4]. The Guidance Notes say the reasoning behind a justified exposure need not be written down. A rejected request is recorded with its reasoning, and the referrer is told [4].

An exposure carried out without justification contravenes regulation 11(1). IR(ME)R is enforced as if it were health and safety regulations under the Health and Safety at Work etc. Act 1974, and contravening such regulations is an offence under section 33(1)(c) of that Act [1][7]. A person charged has a defence if they show they took all reasonable steps and exercised all due diligence to avoid the offence [1]. The enforcing authority in England is the Care Quality Commission. The regulations name the Scottish and Welsh Ministers, and the DHSC guidance says these are Healthcare Improvement Scotland and Healthcare Inspectorate Wales [1][3]. The GDC adds that a dental professional who does not comply with relevant legislation puts their registration at risk [5].

Who may refer a patient for a dental radiograph, and who may justify it?

Regulation 2 defines both roles [1].

• A referrer is a registered health care professional entitled under the employer's procedures to refer patients to an IR(ME)R practitioner.
• An IR(ME)R practitioner is a registered health care professional entitled under the employer's procedures to take responsibility for the justification of an individual exposure.

The referrer supplies the practitioner with enough medical data, such as previous diagnostic information or records, for the practitioner to decide on net benefit [1]. The DHSC guidance says the referrer does not usually justify, except where they are also entitled as practitioner [3]. The practitioner is responsible for justification and, under regulation 17(1), must be adequately trained [1].

Both definitions set two conditions. The first is registration. A registered health care professional is a member of a profession regulated by a body listed in section 25(3) of the National Health Service Reform and Health Care Professions Act 2002, and that list includes the General Dental Council [1][6]. The GDC registers dental professionals under seven titles [5]. Read together, those texts mean every GDC registrant meets the first condition. The second is entitlement: the employer's written procedures must identify who is entitled to act in that role, within a specified scope of practice [1][3].

One person can hold more than one role, and carries the duties of each [1]. The Guidance Notes say it is common in general dental practice for the dentist to be referrer, IR(ME)R practitioner and operator [4]. When the referrer and the practitioner are the same person, no formal exchange of clinical information is needed, and a referral is still considered to have occurred [4].

The 2024 amendment reworded these roles in Great Britain. The practitioner's responsibility, once "for an individual exposure", now reads "for the justification of an individual exposure", and the referrer now carries the regulation 10(1) duty to comply with the employer's procedures [1][2]. Northern Ireland's regulations, in the original 2018 version that legislation.gov.uk holds, keep the older practitioner wording [8].

Authorising can sit with someone else. Where it is not practicable for the practitioner to authorise an exposure, regulation 11(5) lets the operator authorise it under guidelines the practitioner issues [1]. The Guidance Notes do not describe that route. They describe one exception to authorising in advance: the practitioner who justified the exposure is in the room while it is taken, and authorises it as soon as possible within the same episode of care [4].

Since 1 October 2024, where two or more employers are involved in the same patient's exposure, referral or justification, regulation 6A requires them to co-operate and exchange information so each can comply [1][2].

Can a dental hygienist, therapist or nurse justify a radiograph?

A hygienist or therapist can, when trained, competent, indemnified and entitled by the employer. The Guidance Notes say a dental nurse does not take the role [4]. IR(ME)R itself names no dental profession, so the line is drawn by scope of practice and by the employer's entitlement [1].

Hygienists and therapists. The Guidance Notes say that dental hygienists and dental therapists who are appropriately trained, competent and indemnified can refer a patient for a radiograph and take responsibility for it as IR(ME)R practitioner, within their scope [4]. Those who qualified after 2013 and are registered with the GDC are adequately trained to justify intraoral, panoramic and cephalometric radiographs. Those who qualified before 2013 will not necessarily have the skills for the referrer and practitioner roles [4]. The employer must make sure everyone it entitles is suitably trained and competent for the role [4].

The Guidance Notes state the limits in two ways. Section 3.2.2 says hygienists and therapists should not normally be expected to justify cephalometric radiographs or dental CBCT. Section 3.3.6 says their scope might be expected to include intraoral and possibly panoramic radiography, "but never cephalometric radiography or dental cone-beam CT" [4]. For dental CBCT, the IR(ME)R practitioner must be a dentist, after additional training [4].

The GDC's Scope of Practice, effective from 1 November 2025, lists appropriately prescribing, taking and interpreting radiographs within scope and competence for both hygienists and therapists [5]. The Guidance Notes read the GDC's "prescription" as the referrer and IR(ME)R practitioner roles, a reading they say was confirmed with the GDC against its 2013 Scope of Practice [4]. No source checked for this page says whether that reading has been confirmed against the 2025 Scope.

Dental nurses. The Guidance Notes say dental nurses do not refer patients for radiographs, act as IR(ME)R practitioner or clinically evaluate radiographs [4]. The GDC's 2025 Scope says dental nurses do not diagnose disease or plan treatment, and work under prescription from, or the direction or delegation of, a dentist or other registered professional [5]. It adds that skills relating to taking radiographs need specific training and certification set by other regulatory bodies [5].

Other registrants. The two documents part on clinical dental technicians. The 2020 Guidance Notes say they may act as referrer or IR(ME)R practitioner only after developing additional skills and completing additional training [4]. The GDC's 2025 Scope says clinical dental technicians can prescribe, undertake and interpret radiographs within their scope and competence [5]. The Guidance Notes were published in 2020, before the 2024 amendment, and the College of General Dentistry offers that edition [4][9]. The Guidance Notes say orthodontic therapists and dental technicians do not have the skills to act as referrer or IR(ME)R practitioner, and do not have the scope to train for it [4].

What must the practice's written procedures say?

The employer must have written procedures covering at least the matters in Schedule 2, and must take steps to make sure referrers, practitioners and operators comply with them [1]. The DHSC guidance calls the Schedule 2 list the minimum expected of employers [3]. The items that bear on who justifies are:

• (a) identifying correctly the patient to be exposed
• (b) identifying who is entitled to act as referrer, IR(ME)R practitioner or operator, within a specified scope of practice
• (j) carrying out and recording a clinical evaluation for each exposure
• (o) carrying out clinical audit
• (p) making, amending and cancelling referrals

Items (o) and (p) were added from 1 October 2024 [2]. The employer must also set recommendations on referral guidelines and make them available to referrers, under regulation 6(5)(a) [1].

Entitlement has no definition of its own in regulation 2. It sits inside the definitions of referrer, practitioner and operator, as being "entitled in accordance with the employer's procedures" [1]. The DHSC guidance says the employer determines entitlement, and that it includes each person's scope of practice, meaning the range of tasks they may undertake [3]. The procedures can identify people by profession, grade or individual name. Where one person holds more than one role, the procedures must document that, with the scope of practice for each [3].

The Guidance Notes turn this into a practice template [4]:

• The employer defines in writing who is entitled as referrer, IR(ME)R practitioner and operator, and ensures each is suitably trained and competent for the role.
• A named entitler records each person's permitted duties on behalf of the employer.
• The justification procedure makes an entitled dentist, hygienist or therapist responsible for justifying each individual exposure.
• When the referrer is also the entitled practitioner, the referral signature in the clinical notes shows the exposure is also justified. For dental CBCT the practitioner must be a dentist.

The DHSC guidance recommends that the procedures also specify the method of authorisation used locally [3]. To know who may justify a radiograph in your practice, read its entitlement record. It names the person, their profession or their grade as IR(ME)R practitioner, within a stated scope [1][3].

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

Justification decides whether a radiograph is taken. Once it is, take the two-minute reading test to see what you catch, what you miss, and what to work on first.