Radiation is a form of energy that travels from one place to another, either as waves or particles. We are exposed to radiation daily from various natural and artificial sources. Natural sources include cosmic rays and the sun, while familiar artificial sources range from microwave ovens and radios (generally harmless) to equipment used in medical and industrial settings and may present greater risks.
As the use of radiation sources may pose risks to both people and the environment, the Government of Western Australia has established a legislative framework that includes safety standards, licensing requirements and source registration to manage and regulate these risks. The activities and equipment that generate radiation and present risks to people or the environment may need to be registered, and the people handling, operating or using them will need an authorisation or a licence.
In WA, operating or possessing radiation equipment without the proper registration or a licence is illegal. For example, a dentist who uses an X-ray machine needs a licence and equipment registration. An industrial company using radiation gauges will require possession registration and licensed personnel registration.
So, when will registration or a licence be required? What requirements and information are necessary to support the application? What government agency may authorise or grant a permit or a licence? When can someone be exempt from having to register or hold a licence? Let’s discuss further.
Legislation
Since 1975, the government of WA has regulated the use and possession of radiation sources under the Radiation Safety Act and its regulations. These provide a legal framework and guidance to concerned users and owners. This Act also established the Radiological Council as the regulatory body – the independent authority executing the licensing and registration scheme.
The Radiation Safety Act applies to radioactive substances, irradiating devices and electronic products unless an exemption is granted, and establishes two types of authorisations: Registration of Premises and User Licences. A Registration authorises the possession and management of radiation sources and their premises. Registration is required for:
- The ownership or possession of regulated radiation equipment or substances, such as fixed radiation gauges,
- Facilities that use, store or dispose of radiation sources, such as mining sites, laboratories, clinical or veterinary practices, or
- Entities that import, sell, or service radiation-emitting devices or radioactive substances.
This authorisation is referred to as Registration of Premises or Possession, which differs from an individual User Licence.
Under the Radiation Safety Act, the Council may grant a User Licence authorising:
- Use or handling of specific radiation sources such as X-ray equipment, lasers used for medical or cosmetic purposes, radioactive substances (for example, in nuclear medicine or industry), radiation gauges, and analytical X-ray units or,
- Operations or supervised procedures involving radiation, such as radiotherapy and diagnostic imaging.
Both are User Licences specific to the person’s role and training.
Exploring Registration Requirements
Registration is the approval of the premises where any radioactive substances, X-ray equipment, electronic products occur or facilities where radiation is produced, handled, used, and stored. This Registration ensures that the possession and management meet the required safety standards. A registrant is responsible for ensuring compliance with the Act, regulations and any requirement imposed by the Radiological Council (Radiological Council, 2024b).
If someone owns both the premises and the irradiating apparatus inside, they can apply to register them together in a single application.
The registrant must ensure compliance with the requirements outlined in the Registration, such as appointing a radiation safety officer (RSO) and a radiation safety committee (if necessary), completing any notifications, training and ensuring that radiation workers have the correct Licence or exemption (Radiological Council, 2019).
The Act requires the ‘owner’ of the facility or equipment to make the application for any Registration. For the purposes of the Act, the ‘owner’ can be the hirer, lessee, borrower, manager, a foreman, supervisor or any person in charge or having control or management of the location of the radiation source or unit (Government of WA, 1983).
Understanding Licence Requirements and Their Various Types
In WA, any person using or possessing a source of radiation regulated under the Radiation Safety Act must hold a Licence (Radiological Council, 2022a).
This Licence can be issued to an individual or organisation, permitting the use or possession of the radiation source. It authorises professionals or workers to use, handle or possess radiation sources. Two types of Licences exist:
- Use Licence – issued to a user, authorising individuals to use or handle radiation sources; and
- Possession Licence – authorising individuals or entities to possess, store or deal with radiation sources (Radiological Council, 2024a).
Depending on the intended use of a radiation source, the Radiological Council requires licence applicants to meet specific prerequisites. To obtain a Radiation Use Licence, applicants must hold a relevant degree or demonstrate adequate qualifications and experience related to the proposed activity. Additionally, the Radiological Council may require applicants to complete specific training aligned with the intended use and successfully pass its examinations (Radiological Council, 2024a).
Regarding the Radiation Possession Licence (which involves registering any radiation source); the applicant must specify the intended purpose of the Licence and provide detailed information about the nature of the radiation source. This Licence grants the legal right to own, store and take responsibility for the radiation source (Government of WA, 1983).
An important distinction is that a Licence can be held independently from a Registration. For example, a radiographer working in a hospital may operate an X-ray machine under a Use Licence, but does not personally own the equipment – the hospital holds the Possession Licence. Conversely, a company may hold a Possession Licence to register and store radioactive material, but may engage a separately licensed operator to handle or use the material under a Use Licence. Notably, the required licence depends on the specific role. If the owner is also the operator, both a Possession Licence and a Use Licence will be required by the same individual (DoH WA, 2017).
The forms and prerequisite information needed for applications for licences, exemptions and registrations can be found in the Radiation Safety (General) Regulations 1983 and on the Radiological Council website.
Use of Radiation and Exemptions
The Radiological Council may exempt an activity from authorisation requirements if no danger to the life or health of any person is caused, and by doing this, it responds to the general interest of the public (Government of WA, 1975). An exemption from authorisation requirements may be granted by regulation or a case-by-case basis by the Council applying discretionary decision-making.
Under the Radiation Safety (General) Regulations 1983, certain radioactive substances and electronic products are also exempt from the provisions of the Radiation Safety Act if they meet specific criteria, such as activity limits or design standards. Examples of exempt items include microwave ovens, smoke detectors, luminous watches or clocks, self-luminous safety devices, like exit signs, and radiation-emitting electronics such as older TVs and monitors.
Additionally, radiation sources regulated under the Radiation Safety Act may also include equipment used in industrial radiography, which – while similar in principle to medical X-ray – serves non-medical purposes such as imaging the internal structure of materials. Examples of regulated industrial radiation sources include: nuclear density or thickness gauges, which use radioactive material to measure thickness, density, or fill levels during manufacturing, and X-ray ore sorting equipment, which uses high energy X-ray to separate valuable ore from waste rock based on material composition, improving mineral processing efficiency (The Australian Mining Review, 2023).
Consequently, the issue of radiation and radiation authorisation requirements can be complicated and if you need help navigating radiation licensing and compliance, ISPL has extensive experienced supporting businesses with applications for radiation use authorisations and source registrations under Western Australia’s regulatory framework.
Whether you are applying for a new licence or need guidance on reporting requirements, ISPL offers expert advice to ensure your application is accurate, complete, and compliant; contact ISPL at enquiries@integratesustainability.co.au or call us at 08 9468 0338.
ISPL- Regulation Tools Under The Radiation Safety Standard- PDF
References
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DoH WA. (2017). How safe are medical x-rays? Retrieved May 22, 2025, from Department of Health: https://www.healthywa.wa.gov.au/Articles/U_Z/X-ray-radiation-safety
Government of WA. (1975, September 18). Radiation Safety Act. Retrieved April 3, 2025, from Department of Justice Parliamentary Counsil’s office: https://www.legislation.wa.gov.au/legislation/statutes.nsf/main_mrtitle_784_homepage.html
Government of WA. (1983, February 21). Radiation Safety (General) Regulations 1983 . Retrieved April 3, 2025, from Department of Justice Parliamentary Counsel’s Office: https://www.legislation.wa.gov.au/legislation/statutes.nsf/law_s4730.html
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Radiological Council. (2019, March 1). Responsibilities of the Registrant. Retrieved April 2, 2025, from Government of Western Australia Radiological Council: https://www.radiologicalcouncil.wa.gov.au/~/media/RadiologicalCouncil/Documents/PDFs/responsibilities-registrant.pdf
Radiological Council. (2022a, July 1). Licences. Retrieved Apil 2, 2025, from Government of Western Australia Radiological Council: https://www.radiologicalcouncil.wa.gov.au/Licences
Radiological Council. (2022b, February 24). Forms. Retrieved April 3, 2025, from Government of Western Australia Radiological Council: https://www.radiologicalcouncil.wa.gov.au/Forms
Radiological Council. (2024a, April 4). Licence Prerequisites. Retrieved Apil 2, 2025, from Government of WA Radiological Council: https://www.radiologicalcouncil.wa.gov.au/Licences/Licence-Prerequisites
Radiological Council. (2024b, April 4). Registrations. Retrieved Apil 2, 2025, from Government of Western Australia Radiological Council: https://www.radiologicalcouncil.wa.gov.au/Registrations
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