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New Radiation Management Plan requirements for practices operating radiation sources

Under the Victorian Radiation Act 2005 (Vic), a person or entity that conducts a radiation practice must hold a valid radiation management licence.

From 6 September 2021, those parties must now also submit a Radiation Management Plan to the Department of Health in certain circumstances that relate to their radiation management licence.

What is a radiation management licence?

A radiation management licence is a licence that permits an organisation, individual or business to conduct a radiation practice. A radiation practice includes activities like:

  • the possession of a radiation source; and / or
  • the disposal of a radiation source.

This means that any practice, for example, that utilises an x-ray unit must hold a valid management licence before it conducts any radiation activities. The may include dental, veterinary and medical practices.

A radiation management licence will include:

  • a description of the radiation practice that is permitted under the licence.
  • a list of the sites at which the radiation practice can be conducted.
  • restriction on how the radiation practice can be conducted.
  • conditions to which the licence is subject.

A radiation management licence is separate and different to a use licence, which is held by and permits an individual practitioner to use specified types of radiation sources for a specified purpose.

When does a Radiation Management Plan need to be submitted?

A party must submit a Radiation Management Plan to the Department of Health when it is applying:

  • for a new radiation management licence (e.g. starting a new practice);
  • to vary its existing radiation management licence (e.g. when relocating to a new premises); or
  • to transfer an existing radiation management licence from another legal entity into its name (e.g. when purchasing a practice).

What is a Radiation Management Plan?

A Radiation Management Plan sets out safety information for anyone using or working around radiation sources at the practice.

The following, amongst other things, need to be included in a Radiation Management Plan:

  • Details in relation to the licence holder, Radiation Safety Officer and any representatives who are authorised to communicate with the Department of Heath.
  • A list of each site at which the radiation practices will be conducted including details of each source that will be used at each site and a floorplan of each site with the location of the radiation source identified.
  • Details of the radiation safety training requirements for persons using or working around the radiation sources and a list of those persons and their respective training and qualifications to use the radiation sources.
  • Details regarding the radiation safety equipment available at the practice.
  • Practice procedures for acquiring and disposing of radiation sources in accordance with the requirements of the Radiation Act 2005 and Radiation Regulations 2017.
  • Practice procedures for how the radiation sources and radioactive material will be stored safely at the premises when not being used.
  • Details in relation to what constitutes a ‘radiation incident’ and the reporting processes for those incidents.
  • Appropriate practice procedures to be followed in the event of a radiation related emergency.

It is important that practices are aware of the new Radiation Management Plan requirements because the time needed for the preparation of a Radiation Management Plan and the assessment by the Department of Health must be considered when a person or entity intends to start a new practice, vary an existing licence or purchase a practice.

If you would like to discuss any aspect of the above or any other aspect of your practice, please do not hesitate to contact a member of our Commercial Division, experts in medical, health and life sciences industry clients, on (03) 9822 8588 or


Insight written by George Hanger


Meghan Warren


Meghan Warren

LL.B GAICD B.Bus (FinPlan)
Meghan is one of the few lawyers in Australia admitted in the State (Victoria) and Federal jurisdictions of Australia, and as an Attorney at Law to the New York State Bar in the United States.

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Kristy Muhlhan

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Special Counsel

Elizabeth Ong

Special Counsel
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