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Rules applying to unlicensed users working under the supervision and instructions of a licensed dentist
The following rules are set out by the National Radiation Laboratory.
- A registered dentist cannot work under the supervision or instructions of another dentist and must hold
his or her own licence.
- Instructions relate to the situation where the user works remotely from the licensed dentist. In order to
satisfy the requirements for instruction the user must:
- be working under a written system of work including rules setting out the circumstances in which x-rays
can or cannot be taken; and
- comply with the provisions of the Radiation Protection Regulations 1982 and any conditions to which the
instructing dentist's licence is subject; and
- understand the radiation hazards of his or her work and the precautions to be taken in relation
thereto; and
- have received suitable training. In the case of therapists and hygienists this involves the training
required for registration in one of the additional scopes of practice (1) Radiography in Dental Therapy
Practice, (2) Diagnostic Radiography in Dental Therapy Practice, (3) Intra Oral Radiography in Dental
Hygiene, Dental Auxillary and Orthodontic Auxillary Practice or (4) Extra Oral Radiography in Dental
Hygiene, Dental Auxillary and Orthodontic Auxillary Practice. However there are also circumstances where
a student in the final stages of training can take x-rays under instructions because s/he has received
sufficient training to enable the safe taking of x-rays without the immediate oversight of a supervising
licensee.
- Supervision relates to the situation where a licensed dentist is physically present. In order to meet the
requirements for supervision the licensee must:
- be physically present; and
- be able to intervene if required; and
- issue specific directives and the unlicensed user must be carrying out those specific directives.
The overriding consideration is the safe use of the radiation. If the supervisee is inexperienced then the
physical presence and ability to intervene require direct visual contact and oversight. However with more
experienced supervisees, who can recognise abnormalities when they occur, these terms require that the licensee is
within hearing range and sufficiently close that s/he can take remedial action within a very short period of time
(i.e. this may not require that the supervising licensee is present in the same room with direct visual
contact).
This explanation of the term 'supervision' applies only to that used in the Radiation Protection Act and not to
that used in any other legislation with which practitioners may be required to comply.
In either case (i.e. supervision or instructions) the unlicensed user must know the identity of the licensee s/he
is working under, and the licensee remains responsible for the overall safety of the procedure.
These rules are applied to actual circumstances as follows:
- Registered dentists - must have their own licence
- Therapists and hygienists - can operate under instructions if they are registered in an additional scope of
practice relating to the taking of x-rays. Otherwise they can only operate under the supervision of a licensed
dentist.
- Oral health students - initially students must act under supervision. However later in their training they
can operate under instructions assuming sufficient training has been received. Note that there is nothing to
stop a person operating under supervision one day, instructions the next and then back to supervision the
next.
- Dental assistants - it is most unlikely that dental assistants will ever have enough training to be able to
operate under instructions and therefore they can only operate under supervision.
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