The hidden risks in dental radiography - A compliance case study

By Sofia Mendes

Radiography is routine in dental practice. We take X rays every day. Bitewings, periapicals, OPGs. The process feels clinical, efficient, normal.

But from a regulatory perspective, every single exposure is a legal event.

Under IRMER, ionising radiation is tightly controlled. The expectation is not just safe clinical care, but clear governance, defined responsibilities, and auditable systems. And this is where many otherwise well run practices become vulnerable.

Let me share a recent mock inspection scenario.

The practice

A busy mixed practice. Modern digital sensors. An up to date OPG machine. Experienced clinicians. No patient complaints. No known safety incidents.

When asked about radiography compliance, the team confidently produced their radiation protection file.

On the surface, everything appeared to be there.

But once we started reviewing the detail, the gaps became clear.

The findings

Local rules were present but had not been reviewed in over two years.

Employer procedures existed, but there was no clear evidence that individual IRMER roles had been formally allocated. Staff assumed they knew who was responsible as referrer, practitioner and operator, but nothing was documented.

The most recent RPA report was filed away, but there was no documented evidence that recommendations had been reviewed, actioned, or signed off.

Radiograph grading was being completed sporadically. Some clinicians graded consistently. Others did not. There was no structured audit cycle, no trend analysis, and no governance discussion recorded in meeting minutes.

Quality assurance testing for the X ray equipment had been completed, but the records were not easily accessible and had not been referenced during internal reviews.

None of this meant patients were unsafe.

But it did mean the practice was exposed from a compliance perspective.

The risk

• Under IRMER, the employer has clear legal responsibilities. CQC will expect to see:

• Defined and documented roles

• Employer procedures that reflect actual practice

• Regular radiograph audits with evidence of learning

• Up to date RPA involvement

• Clear QA testing records

• Oversight at governance level.

If documentation is fragmented, outdated, or not linked to governance, inspectors may conclude that systems are not robust, even if clinical care appears sound.

In today’s regulatory environment, intent is not enough. Evidence is everything.

The fix

We approached this in a structured way.

First, we reviewed and updated the radiation protection file so it reflected current equipment, current staff, and current practice.

Second, we formally documented IRMER roles. Each clinician and relevant team member had their responsibilities clearly allocated and recorded.

Third, we implemented a six monthly radiograph audit cycle. Grading became consistent. Results were collated. Trends were analysed.

Fourth, RPA recommendations were reviewed line by line. Actions were documented, signed off, and referenced in governance meeting minutes.

Finally, radiography compliance became a standing agenda item at clinical governance meetings. Learning points were discussed and recorded. 

The difference was not dramatic. It was structured.

And structure is what inspectors look for.

Why this matters

Radiography compliance is not about owning modern equipment. It is about demonstrating control.

Every exposure must be justified.

Every image must be graded. 

Every audit must lead to reflection.

Every recommendation must be actioned.

If you cannot show that loop clearly, your governance is incomplete.

IRMER compliance sits firmly within the Safe and Well Led domains. It reflects how seriously a practice takes legal responsibility, risk management, and continuous improvement.

Final thought

Radiographs are taken in seconds.

But the compliance surrounding them is ongoing.

If you are unsure whether your radiography systems would withstand scrutiny, start by asking one simple question: If an inspector asked to see our radiography audit trail today, could we produce it confidently and coherently?

If the answer is hesitation rather than certainty, that is where the work begins.

Need support with compliance in your dental practice?

Compliance can feel straightforward in day-to-day practice, but as this case study shows, it is often the detail behind the systems that determines how well a practice would stand up to inspection.

Over time, even well-managed practices can find that documentation, audit cycles, or governance processes are not as clear or joined up as they could be. A fresh set of eyes can often help bring reassurance, clarity, and structure.

If you are unsure whether your current processes are fully up to date, or simply want to sense-check your compliance systems, why not get in touch and see how we can help? Call us 0330 088 2275, or email info@buxtoncoates.com