NSW Radiation Law Reform: What AVA members need to know

The NSW Environment Protection Authority (EPA) has released a draft Regulatory Impact Statement (RIS) and Proposed Protection from Harmful Radiation Regulation 2025 for public consultation as the current Regulation (2013) is due for automatic repeal in September 2025.

The proposed Regulation retains the core framework but introduces updates aimed at enhancing safety, simplifying compliance, and aligning with national standards. These changes are significant for professionals using radiation in veterinary practice.

Key proposed changes relevant to veterinary practice

• Expanded Licence Exemptions: Veterinary nurses and technologists may be exempt from radiation user licences if they meet training, supervision, and safety criteria.
• Mandatory Radiation Management Plans: All holders of radiation management licences must develop or adopt a compliant plan within 12 months of the Regulation's commencement.
• Work Health and Safety: Improved radiation incident reporting, dose monitoring, and clear responsibilities for occupational safety.
• Increased Penalties and Updated Fees: Fines will be updated to reflect current standards, and fees will be indexed to the consumer price index from 2026.

Why this matters

The changes promote a risk-based, proportionate regulatory approach that aims to protect people and the environment without overburdening low-risk users. For veterinarians, the focus is on better compliance with fewer licensing hurdles—especially in team-based clinical environments.

How to provide feedback for the AVA submission:

• Please review the EPA NSW information through this link which provides details on the proposed regulations.
• Due to a tight consultation timeframe from EPA NSW, and to allow time for drafting and internal review and approval, we ask that you provide your feedback via email to robyn.whitaker@ava.com.au by 9am Monday 16 June 2025.

Key questions supplied by EPA NSW you may consider as part of your review/feedback: 

• When thinking about licence exemptions what are your views on the updated licensing exemptions and new offences related to exemptions in the proposed Regulation?
• Considering radiation management plans please tell us your views on the requirement in the proposed Regulation for all radiation management licensees to prepare or adopt a radiation management plan?
• Please tell us your views on the provisions in the proposed Regulation relating to occupational exposure monitoring and exposure dose limits, including clarifying which occupationally exposed persons must be issued with a personal monitoring device by employers?
• Thinking about radiation incidents please share your views on the provisions in the proposed Regulation defining what occurrences are taken to be radiation incidents, including the thresholds and requirements for reporting them?
• Do you have any feedback about fees payable for radiation licences, accreditations and other purposes in the proposed Regulation, including adjusting fees annually in line with the consumer price index?
• Do you have any feedback on the updated maximum penalties and penalty notice amounts prescribed in the proposed Regulation?

More information for the EPA NSW consultation can be found on their website here.

Please direct any questions to Senior Advocacy Officer, Dr Robyn Whitaker, who is leading this consultation for the AVA. robyn.whitaker@ava.com.au

We greatly appreciate your time in reviewing this information and providing input to inform the AVA’s submission.