NSW Radiation Regulation Review: The AVA advocates for practical, veterinary-focused reforms

The AVA has lodged a detailed submission to the NSW Environment Protection Authority (EPA) in response to the Proposed Protection from Harmful Radiation Regulation 2025. The draft regulation represents a significant shift in how radiation safety is managed in NSW, aiming to modernise, simplify, and align regulation with actual risk.

The frequent use of diagnostic radiography in veterinary clinical and ambulatory settings makes this review highly relevant to the profession.

Key Points from the AVA Submission

• Support for Supervised Licence Exemptions - The AVA welcomed the proposed licence exemptions for veterinary nurses, technologists, and students working under the supervision of registered veterinarians. However, clarification was sought on the definitions of these roles to ensure consistent application.
• Radiation Management Plans (RMPs) - The AVA supports mandatory RMPs and has requested the EPA provide templates and training to ease implementation. The submission also questioned how compliance would be monitored if RMPs are not reviewed by the EPA.
• Personal Monitoring Devices (PMDs) - While supporting clear safety protocols, the AVA raised concerns about ambiguity in who must wear PMDs, particularly for laypeople like animal owners assisting in radiography. Further clarification and a risk-based approach has been requested.
• Veterinary-Specific CPD - Recognising the unique nature of veterinary radiation use, the AVA strongly encouraged the development of tailored training and CPD programs co-designed with veterinary experts.
• Inspections and Compliance Audits - The AVA supports equipment inspections but cautioned against duplication across regulators.

It recommended leveraging existing Veterinary Practitioners Board inspections and sought further detail on the frequency and scope of the EPA’s “enhanced compliance audit program”.

• Penalties and Fees - While not opposing updates to fees and penalties, the AVA emphasised the need for transparency, clarity, and a focus on education rather than punitive enforcement for veterinary practices making good-faith efforts to comply.

The AVA remains committed to working with the EPA to ensure final regulations are practical, proportionate, and support the continued safe use of vital diagnostic tools in veterinary settings.

The AVA submission can be viewed in full here.