Radiation Protection Training for Healthcare Staff in Ireland: Who Regulates It

Radiation protection training for healthcare staff in Ireland sits under two different regulators because the law protects two different groups of people. One set of rules concerns patients who receive medical exposures, and the other concerns workers and the public. This guide explains who regulates what, what the pages we opened say about training and competence, and how an employer can organise the evidence. It is a regulatory and workforce guide only; it contains no clinical content and no dose limits. If you are preparing for a regulator visit more broadly, our guide to HIQA inspections and staff training in Ireland covers the wider inspection picture.

Two regulators, two sets of rules

According to a HIQA news update dated 6 February 2020, HIQA regulates medical exposure to ionising radiation in Ireland, while the Environmental Protection Agency (EPA) is responsible for occupational and public exposure. Both agencies oversee public and private radiological, radiotherapy, nuclear medicine and dental facilities, and the update describes a memorandum of understanding formalising their cooperation.

The update names the legislation for each. For HIQA it is S.I. No. 256 of 2018, which transposes the EU Basic Safety Standards Directive into Irish law. For the EPA it is the Radiological Protection Act 1991, as amended, and the regulations made under it. The EPA's guidance adds that S.I. No. 30 of 2019, the Ionising Radiation Regulations 2019 (often shortened to IRR19), covers the protection of workers and members of the public, while patient protection during medical exposures is covered separately by S.I. 256 of 2018.

HIQA: medical exposure

HIQA's page on the regulation of medical exposure to ionising radiation (the page shows no date) says HIQA is the competent authority, inspecting and enforcing the rules against service providers, called undertakings, in public and private settings that deliver medical and dental radiological services. The obligations it lists for undertakings include:

• ensuring local diagnostic reference levels are established, regularly reviewed and used by staff performing radiological procedures;
• carrying out clinical audit in line with HIQA's national procedures;
• reporting significant events, including accidental and unintended exposures, to HIQA.

On training, the page does not list specific training or education requirements, but it says that during inspections conversations with management and staff concentrate on their understanding, experience and training. That is a useful signal. Even where a page does not prescribe a course, an inspector can ask for evidence of competence.

HIQA's guide to the inspection of medical services providing medical exposure to ionising radiation (version 3.0, updated September 2023) adds workforce detail. Facilities submit governance documentation, including an organogram showing lines of responsibility, along with professional recognition and training documentation for practitioners, medical physics experts and others who are delegated practical tasks. The guide's self-assessment topics include that referrals are accepted only from registered healthcare professionals, that practical tasks are delegated only to individuals who have completed a course in radiation safety, and that practitioners and delegated staff have adequate education, training and radiation protection competence and continue training after qualification. The guide also says ten working days' notice is given for standard announced inspections.

EPA: workers and the public

The EPA's IRR19 guidance (published June 2022, and expressly guidance on what typically constitutes compliance rather than a legal interpretation) says the EPA is the competent authority for IRR19. It authorises practices through registration or licensing, carries out inspections, takes enforcement action, publishes guidance and approves and registers radiation protection advisers. The main duty holder is the undertaking, and legal responsibility stays with the undertaking and cannot be delegated.

On training, the guidance says undertakings must ensure staff are adequately trained and follow radiation safety procedures. The Irish Statute Book page for S.I. No. 30 of 2019 lists a regulation titled "Radiation Protection Education, Training and Information" (Regulation 35). According to that page, it requires undertakings, and employers of outside workers, to give exposed workers, apprentices and students appropriate education, training and information in the field of radiation protection, and it covers repeating and documenting training at appropriate intervals. We did not read the whole instrument, so please read Regulation 35 itself before relying on our summary. The EPA's IRR19 overview page does not itself list training requirements.

The EPA guidance also explains two roles. Undertakings must consult an approved radiation protection adviser in specified situations, and must designate a radiation protection officer, an individual or unit with operational responsibility for radiation protection. The guidance says radiation protection officers are responsible for giving new workers an introduction to radiation safety procedures and for liaising on training for exposed workers.

What this means for employers

Put simply, the same hospital, clinic or dental practice may be answerable to HIQA for how patients are exposed and to the EPA for how staff and the public are protected. Training evidence may be asked for by either. The pages do not say that one qualification satisfies both, so do not assume it.

Practical suggestions for keeping the evidence

Our suggestion: these are our own ideas, not regulatory requirements.

• Map roles to regulators. List who is a practitioner, a medical physics expert, a delegated operator, a referrer and an exposed worker, and note which regulator's framework each role falls under.
• Hold the paperwork in one place. HIQA's inspection guide asks for professional recognition and training documentation. Our guide to a training records matrix for healthcare employers shows one way to organise it.
• Date everything. Because Regulation 35 refers to training being repeated and documented at appropriate intervals, record when each person was trained and when review falls due, and decide the interval with your radiation protection adviser.
• Brief locums, agency and visiting staff. The EPA guidance refers to outside workers and says their employers have responsibilities too, so include them in your induction and records.
• Fit radiation training into your wider plan. Our overview of mandatory training for healthcare staff in Ireland can help you see where it sits alongside other recurring training. These rules are national, so Dublin employers follow the same framework as everyone else.

What we could not confirm

We did not open the full text of S.I. 256 of 2018 or all of S.I. 30 of 2019, so we give no regulation numbers beyond those named on the pages we read, and we state no dose limits, qualification titles or training intervals. HIQA's and the EPA's own pages should be checked for current requirements.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Who regulates radiation protection in Irish healthcare?

According to HIQA (update dated 6 February 2020), HIQA regulates medical exposure and the EPA is responsible for occupational and public exposure.

Does HIQA set a specific radiation training course?

Its medical exposure page lists no specific training or education requirements, but says inspection conversations with management and staff concentrate on their understanding, experience and training.

What does IRR19 say about training?

The Irish Statute Book page lists Regulation 35, which requires appropriate education, training and information for exposed workers, apprentices and students. Read the regulation itself for the detail.

Does the undertaking or the individual hold legal responsibility?

The EPA's IRR19 guidance says legal responsibility stays with the undertaking and cannot be delegated.

Knowing which regulator asks for which evidence is the first step to keeping radiation protection training in good order.