Update on changes to radiation safety for veterinarians
New licencing requirements
Organisations that manage and control radiation sources must be in possession of a source licence according to the new Radiation Safety Act 2016 that came into force on 07 March 2017. The Office of Radiation Safety (ORS) administers the Act.
Practitioners who use radioactive material (for example Tc-99m for diagnostic purposes or I-131 for treatment of thyroid conditions) must hold a use licence issued under the new Act. However, veterinarians who use only X-ray equipment are exempt from the need to obtain a use licence (Schedule 3 of the Regulations).
Check: are you compliant?
We believe that many practices and veterinarians are compliant with these requirements.
Practices that are not in possession of their source licence are in breach of the Act and have to urgently make contact with ORS at orsenquiries@health.govt.nz to become compliant with the legislation.
Information about how to apply and corresponding annual fees can be found on the Radiation Safety Office website (https://www.health.govt.nz/our-work/ionising-radiation-safety).
If an existing clinic is sold to a new owner, the source licence issued to the previous owner cannot be transferred to a new owner. The new owner becomes a managing entity for the clinic, and therefore the new owner must apply for their own source licence for the existing clinic.
About the Act and Codes of Practice
The new Radiation Safety Act authorises the making of regulations and the issuing of codes of practice. The new structure of legal documents is:
Initially ORS intended to issue only four codes that would be general in nature. In response to public submissions it was decided that there needed to be more codes that were targeted at specific radiation practices and included more prescriptive requirements.
It has been decided to issue 12 codes structured according to this table:
Six of these codes have already been issued (C1-4, C6-7).
C5 is well-advanced with the expectation that it will be issued later in 2019. The remaining codes have been drafted but because they contain more detail than was in the initial consultation document, ORS has decided to consult a second time so that affected parties can have their say on the new detail.
Next steps
Importantly for the profession this includes C9 which relates to the use of X-rays and radioactive material for veterinary purposes. We expect that this second public consultation period will commence later in 2019. When that consultation is complete there will be a period of review and re-drafting before the code is finally issued.
After the implementation of the final Codes of Practice issued under the new Act, ORS will engage with the sectors to gauge the necessity of developing specific compliance guides.