Lesson 5.1 · 6 min
Licence, radiation protection officer, an inspection every four years
Open in the coursewith narrated slides, a checklist to tick off and a quiz
At a glance
- X-ray needs a licence. Dental X-ray is an activity that needs a licence. It is only granted with a named radiation protection officer.
- In the licence. The licence sets conditions for radiation protection. Breaking one is an administrative offence.
- At least every four years. The authority inspects dental X-ray units at least every four years, and can inspect at any time in addition.
- Report without delay. If the radiation protection officer changes, the authority must be told without delay, with proof of training.
- First a deadline, then a report. For a breach the authority sets a deadline first. Only when it passes, or at once for serious breaches, does a penalty report follow.
In detail
The licence
Dental X-ray is an activity (Tätigkeit) under the Radiation Protection Act, and such activities need a licence § 15(1) StrSchG 2020. A licence to carry out the activity may only be granted if, among other things, a demonstrably appointed radiation protection officer has been named to the authority § 17(1) no. 3 StrSchG 2020. The authority writes into the licence the conditions needed for radiation protection § 17(2) StrSchG 2020. These licensing rules apply accordingly to any change relevant to radiation protection in the activity or in the structural radiation protection measures § 18 StrSchG 2020. Whether a new unit or a building change counts, check with the authority beforehand.
Dental X-ray units without a remote exposure function may be operated outside a dedicated radiation room, but third parties must be protected by suitable measures § 27(2) MedStrSchV. Panoramic units with an intraoral X-ray tube are not allowed § 27(8) MedStrSchV.
The inspection
The licensing authority inspects dental X-ray units at least every four years § 61(1) no. 2(a) StrSchG 2020, and may inspect at any time § 61(3) StrSchG 2020. It checks compliance with the act, the administrative acts issued under it, such as your licence, and directly applicable EU law § 61(4) StrSchG 2020.
When the radiation protection officer changes
A change must be reported to the authority without delay, naming the new person and attaching their training certificates. If they don't meet the requirements, the authority prohibits the activity § 65 StrSchG 2020.
What a breach costs
When the authority finds a breach, it first asks for compliance to be restored within a reasonable deadline. Only if that doesn't happen does it report the breach for penalty proceedings; for serious breaches it reports at once § 62 StrSchG 2020.
| Breach | Fine up to | |
|---|---|---|
| X-ray without a licence, intentionally circumventing the licensing rules | €50,000, or €75,000 if repeated | § 152(1) no. 1 |
| X-ray without a licence in all other cases | €7,500, or €11,250 if repeated | § 152(2) no. 4 |
| A change relevant to radiation protection made without a licence | €7,500, or €11,250 if repeated | § 152(2) no. 6 |
| A licence condition not met | €1,500, or €2,250 if repeated | § 152(3) no. 1 |
| A change of radiation protection officer not reported | €1,500, or €2,250 if repeated | § 152(3) no. 11 |
| Other breaches of the act, of administrative acts issued under it or of directly applicable EU law | €1,500, or €2,250 if repeated | § 152(3) no. 30 |
On one quality assurance sample visit, the door contact switch on the X-ray unit was missing (quality report 2017–2021). The MedStrSchV itself only requires opening the door to interrupt the radiation in certain radiotherapy rooms § 26(2) no. 2 MedStrSchV. Which technical and structural conditions apply to your X-ray unit is set out in your licence.
Checklist
- The licence is kept in the practice, and we know its conditions.
- The radiation protection officer has been named to the authority and knows it.
- If that person changes, we report the new one at once, with certificates.
- We know when the last official inspection was, and expect the next within four years.
- Before a new unit or a building change, we check with the authority whether a licence is needed.
Quiz
How often, at least, must the authority inspect a dental X-ray unit?
- Every three years
- Every four years
- Every year
- Only when licensing
Show the answer
The answer is B: Every four years. Inspections of dental X-ray units must take place at least every four years (§ 61(1) no. 2(a) StrSchG 2020); they can also happen at any time (para. 3).
Sources
This lesson's statements rest on:
- Radiation Protection Act 2020 (StrSchG 2020) § 15, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 17, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 18, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 61, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 62, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 65, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Radiation Protection Act 2020 (StrSchG 2020) § 152, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Medical Radiation Protection Regulation (MedStrSchV) § 26, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Medical Radiation Protection Regulation (MedStrSchV) § 27, Federal Legal Information System (RIS), in German, version of 7 October 2026
- Quality report 2017–2021 under § 10 of the chamber's Quality Assurance Regulation, the chamber's PDF, in German
Not legal advice. What counts is the acts and regulations in the Federal Legal Information System and the Austrian Dental Chamber's regulations (read on 7 October 2026). The health minister's regulation with the criteria from 2028 (§ 9b(2) GQG) had not been issued on that day. Not covered are insurer contracts, billing, data protection in detail and the employer's duties under the Worker Protection Act in detail; there is a separate course on those at aschg.globalapps.top. Not an offer of the Austrian Dental Chamber, a regional dental chamber, the BIQG or the Chamber of Commerce.