IR(ME)R 2017 in Dental Notes: Radiograph Justification and Clinical Evaluation

Referrer, practitioner and operator

Regulation 2 defines three roles. A "practitioner" is a registered health care professional "entitled in accordance with the employer's procedures to take responsibility for an individual exposure". An "operator" is a person entitled under those procedures to carry out the practical aspects. A "referrer" is a registered health care professional entitled under those procedures to refer individuals for exposure to a practitioner.

One person can hold more than one role. Regulation 6 requires the employer to have written procedures and to "take steps to ensure that any written procedures are complied with by the referrer, practitioner and operator", so the first thing to know is which role you hold under your practice's procedures.

Justification (regulation 11)

Regulation 11(1) says a person "must not carry out an exposure unless" it "has been justified by the practitioner as showing a sufficient net benefit giving appropriate weight to the matters set out in paragraph (2)" and "has been authorised by the practitioner or, where paragraph (5) applies, the operator". The matters in paragraph (2) are:

• the specific objectives of the exposure and the characteristics of the individual involved;
• the total potential diagnostic or therapeutic benefits, including the direct health benefits to the individual and the benefits to society;
• the individual detriment that the exposure may cause; and
• the efficacy, benefits and risk of available alternative techniques having the same objective but involving no or less exposure to ionising radiation.

For an individual of childbearing potential, regulation 11(1)(f) also requires that the person "has enquired whether that individual is pregnant or breastfeeding, if relevant".

The Regulations do not say what form the justification takes in the notes. Nosht's suggestion is a short entry for each radiograph that names the clinical question (the specific objective), the individual factors you weighed and the alternative you considered, rather than "film taken". The CGDent guideline Selection Criteria for Dental Radiography (3rd edition) is the dental guidance on when radiographs are indicated; CGDent notes that the CQC expects dental practices in England to comply with its recommendations.

Clinical evaluation (regulation 12(9))

Regulation 12(9) says: "The employer must take steps to ensure that a clinical evaluation of the outcome of each exposure, other than where the person subject to the exposure is a carer or a comforter, is recorded in accordance with the employer's procedures including, where appropriate, factors relevant to patient dose." In a dental record this is the entry that says what the radiograph showed and what follows from it.

Regulation 12(1) and (3) add that doses must be kept "as low as reasonably practicable consistent with the intended purpose", with the operator selecting equipment and methods to achieve this. Whether and how you record dose-related factors is for your employer's procedures.

A note that covers both duties

This is Nosht's suggested layout, not wording taken from the Regulations. Adapt it to your practice's procedures:

• Referrer and practitioner (names or initials) and who took the image.
• Justification: the clinical question, the individual factors considered, why no or lower-dose alternatives were not enough.
• Pregnancy or breastfeeding enquiry, where relevant.
• Clinical evaluation: what the image showed, including the negative findings, and the resulting plan.
• Any factors relevant to dose that your procedures require.

Sources

• The Ionising Radiation (Medical Exposure) Regulations 2017 (SI 2017/1322) (accessed 18 October 2026)
• CGDent: Selection Criteria for Dental Radiography (3rd edition) (accessed 18 October 2026)