A recent NSW EPA audit found dental practices operating in breach of radiography licensing laws. Since 1 December 2025, the rules on who can legally activate imaging equipment are precise — and so is the risk of getting it wrong.
Dental assistants routinely place sensors and film, position equipment, and activate intraoral and extraoral X-ray apparatus, including OPG machines. Whenever a DA operates that equipment, the law requires the correct legislative credentials — the relevant approved course units — however routine the task has become. Unqualified staff who activate X-ray apparatus, even just pressing the exposure button on a practitioner's instruction, are doing so illegally.
It's a common workaround: practitioners step away from the patient to avoid radiation exposure, then have an untrained DA press the activation button in their place. This doesn't change the legal position. The solution isn't to find a way around the gap — it's to train the DA to competently manage the whole process, from positioning to producing the finished image. That removes the risk and builds a genuinely more capable team member.
What the licensing rules require and the training required
Under NSW arrangements from 1 December 2025, a DA who completes an EPA-approved course is not required to hold an IA20 radiation user licence.
The Dental Assistants Professional Association (DAPA) delivers nationally recognised HLTSS00072 Dental Radiography Skill Set (HLTDEN021, HLTDEN022, HLTDEN023) within the HLT45021 Certificate IV in Dental Assisting . All staff who enrol in the Certificate IV in Dental Assisting with DAPA will undertake the Dental Radiography Skill Set, which will underpin practice compliance. To enrol in the Certificate IV, DAs must hold a Certificate III in Dental Assisting (HLT35021) or an equivalent qualification.
DAPA (RTO 90424) is one of only three providers currently listed by the NSW EPA for approved Certificate IV radiography training. Training is delivered online, in practice, in a classroom, or in a blended format, all assessed to the same national standard.
Note: IA20 exemption doesn't cover CBCT, which still needs a separate IA24 licence.
What's at stake
For managers and practitioners, closing this gap avoids serious penalties, fully recognises a team member's skills, and frees up practitioners' time. For patients, it means every image is captured by someone properly trained and legally authorised to do so.
At a glance
● NSW EPA audits have found practices in breach of radiography licensing laws
● Legal position: unqualified staff cannot lawfully activate X-ray apparatus — even just pressing the button
● Qualification: HLTSS00072 Dental Radiography Skill Set (3 units, HLT45021 Cert IV)
● Doesn't cover CBCT — a separate IA24 licence is still required
● Delivery: online, in-practice, classroom, or blended
Don't wait for an audit to find the gap.
Register your EOI here: https://dapa.readystudent.io/apply_to_course/2607_dt
Talk to DAPA today about the training model that fits your practice. Call Mark, Marty or Barb on
02 9569 3220.