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 firstname.lastname@example.org.
Insight written by George Hanger