Veterinary practices

Overview

A wide range of radiation sources are used in the veterinary sector for diagnostic and therapeutic applications.

A radiation management licence is a mandatory requirement for any company seeking to possess a veterinary radiation source. Multiple sources can be authorised on a single management licence and a separate authorisation on the licence is required for each source. In addition to authorising possession of the radiation source, the radiation management licence may also authorise other practices such as disposal or storage.

Applicants seeking a management licence for a veterinary practice must meet certain prerequisites prior to being issued with a management licence.

Prerequisites: what information do I include with my application?

The following documentation must be included with your application (electronic files can be attached with your application).

1. Establishment of identity and authorisation

A radiation Management Licence can only be issued to a legal entity. In most cases the legal entity will be a registered company or a person.

If you are applying for a management licence under a company name you must provide:

• A current Company Extract issued by the Australian Securities and Investments Commission (ASIC). The extract must display the ACN number and the name of the director(s) of the company. A registration of a business or ABN is not accepted as evidence of a legal entity.
• If you are not a director of the company, then you must provide a Letter of Authority signed by a director of the company. The director must be listed on the ASIC company extract. A template for the Letter of Authority can be found at sample Letter of Authorisation page. The Letter of Authority will authorise you to do the following on behalf of the company:
  • Apply for a new management licence.
  • Apply to vary an existing management licence.
  • Submit a notification of acquisition and/or disposal.
  • Discuss matters relating to the radiation management licence with the department.

If you are applying for a management licence under a person’s name:

• Proof of Identity (Drivers licence or passport showing current physical address) of the person applying to be the licence holder.
• If you are applying on behalf of another person, then you must provide a Letter of Authority from that person. A template for the Letter of Authority can be found at sample Letter of Authorisation page. The letter must be signed by the person that is proposed to be the licence holder. The Letter of Authority will authorise you to do the following on behalf of the proposed licence holder:
  • Apply for a new management licence.
  • Apply to vary an existing management licence
  • Submit a notification of acquisition and/or disposal.
  • discuss matters relating to the radiation management licence with the department

2. A Radiation Management Plan

From 6^th September 2021 a Radiation Management Plan (RMP) is now a mandatory prerequisite that must be submitted when undergoing any of the following activities:

• Applying for a new Radiation Management Licence
• Applying for a variation to an existing Radiation Management Licence
• Applying to transfer an existing Radiation Management Licence to another legal entity

The Radiation Management Plan page provides details on the minimum requirements that must be included in your RMP.

In addition to the minimum RMP requirements, you need to include the following information in your RMP:

1. The name of the dosimetry service provider (DSP) that you will use.
2. The centre number assigned to you by the DSP.

Additional RMP requirements for radioiodine therapy and nuclear medicine veterinary practices

For veterinary nuclear medicine practices, please also provide details regarding surface finishes, ventilation, drains in areas where radioactive material is to be used, and proposed arrangements for storage and disposal of any radioisotopes, radiopharmaceuticals or sealed sources. As a guide to good practice it is recommended that the principles contained in the following Standards be adopted for all laboratories in which radioactive substances are used or stored:

• AS 2243.4-1998 Safety in laboratories Part 4: Ionizing radiations, and
• AS/NZS 2982:2010 Laboratory design and construction.

3. Shielding assessment report

A management licence holder who is conducting a veterinary radiography practice must install sufficient shielding in the room where the radiography will be conducted to ensure that no person receives a radiation dose in excess of the relevant radiation protection limits specified in the Radiation Regulations 2017. A shielding assessment determines the minimum amount of shielding that is required in the walls, doors, floor and ceiling of the room in which the radiation source is will be installed to ensure that no person receives a radiation dose in excess of the relevant dose limits.

The following practices do not require a shielding assessment to be submitted with the application:

1. Practices that are only authorised for dental intra-oral apparatus do not require a shielding assessment provided the intra-oral apparatus is used in a separate room constructed of plasterboard or equivalent building materials.
2. Practices that are authorised to use mobile general x-ray units (i.e. general X-ray units that are used primarily out of the clinic environment (e.g. field radiography of horses).

For all other applications involving veterinary radiation sources a shielding assessment report must be submitted with your application.

The Department has developed an online Radiation Shielding Self-assessment to enable licence holders and applicants to conduct a simple shielding assessment for small animal veterinary radiography conducted in a room/area where:

1. the room/area contains only a general radiography X-ray unit and/or an intra-oral X-ray unit;
2. there is no occupiable space below the X-ray room;
3. the general radiography X-ray unit is used only for small animal Veterinary radiography; and
4. the primary X-ray beam of the general radiography X-ray unit is always directed down towards the floor.

This Radiation Shielding Self-assessment does not cover:

1. Large animal radiography (e.g. horses);
2. Radiotherapy units;
3. Computed Tomography (CT) units;
4. Fluoroscopy X-ray unit; and
5. Examinations where the primary X-ray beam is not directed down towards the floor.

The Radiation Shielding Self-assessment including further details regarding the assessment are available on-line at Radiation Shielding Self-assessment - Small Animal Veterinary Radiography.

If your practice is not covered by this self-assessment or the assessment indicates that the shielding is insufficient, then a detailed assessment must be performed in accordance with a relevant internationally recognised shielding calculation methodology adapted for the veterinary practice e.g. Calculation method using mAmin workload as per NCRP Report No. 147 – Structural Shielding Design For Medical X-Ray Imaging Facilities (2004), or ESD/KAP workload as described in “Radiation shielding for diagnostic radiology” BIR 2012.

The assessment report must include the following:

1. Floor plan showing the room in which the radiation source will be installed and surrounding rooms.
2. Occupancy factors and purpose of surrounding rooms.
3. Methodology/references used in the assessment.
4. Shielding required for the operator.
5. Radiation apparatus workloads used in the assessment.
6. Details (including thicknesses) of construction/shielding materials used in the walls, doors, floor, ceiling and windows of the room in which the radiation source is or will be installed.
7. The location of any related equipment e.g. X-ray equipment, tables, buckys, controls, protective screens, warning lights.
8. For premises with more than one radiation source/practice the assessment must address all sources/practices, and demonstrate that the total (aggregation) of doses from all sources/practices would not be expected to exceed the relevant radiation dose limit.
9. For radioiodine therapy and nuclear medicine practices - The shielding assessment must take into consideration exposures arising from all aspects of the proposed radiation practice (e.g. exposure from administered patients in holding pens, radioactive material in storage and waste products contaminated with radioactive material.

Conditions of licence

General and practice specific conditions of licence are mandatory requirements that apply to radiation management licence holders. It is important as a management licence holder that you understand and comply with all the conditions of licence that apply to your licence. Failure to comply with a condition of licence is an indictable offence under the Radiation Act 2005

General Conditions of licence

Two general conditions apply to all radiation management licence. The general conditions relate to the reporting of incidents and the acquisition and disposal of radiation sources. Further information on the general conditions can be found at Disposal of radioactive material and X-ray equipment page.

Practice specific conditions of licence relating to veterinary radiation sources

Compliance with the Code of Practice for Radiation Protection in Veterinary Medicine (2009) is a condition of management licence issued to veterinary practices and you must be familiar with its requirements.

Before lodging an application, we strongly recommend that you read the Safety Guide which is attached with the abovementioned Code of Practice.

Licence durations, licence fees, assessment process and timeframes

See the General information about management licences in Victoria page.

Do I need a use licence for veterinary radiation sources?

Any individual wishing to use veterinary radiation sources must hold a valid use licence.

The use of a radiation source without the required use licence is an offence under the Radiation Act 2005.

To apply for a use licence please visit the use licence section.

Apply for a management licence or apply to vary an existing licence

All of the department's forms for applications are on-line forms. The form is completed online and automatically emailed to the department upon submission. Please remember to check what mandatory documents must be included with your application.

Complete the online form: Application for a new management licence

Complete the online form: Application to vary a management licence