Inspectors of the Department of Health (DOH) have confirmed the
concerns of the Medical and Dental Professions Board (MDB) regarding a
lack of knowledge pertaining to the impact of ionising radiation on the
public, over-exposure, misdiagnosis and inappropriate treatment of
patients by general medical practitioners (GPs) using X-ray equipment
In the early 1980s the DOH questioned the training of GPs to
perform diagnostic X-ray examinations. This was not resolved and the DOH
continued issuing licences to GPs for the use of X-ray equipment for
The scope of medical practitioners is wide and overlaps with the
scopes of other professions, including radiography. Recent reports
confirmed that owing to the limited course content in respect of
radiography in their undergraduate education and training, medical
practitioners (non-radiologists) could not perform specific professional
acts that fell within the scope of radiography, except in an emergency.
These include the taking and interpretation of X-ray films. Further
education and training in radiography, to be developed and approved by
the Professional Board for Radiography and Clinical Technology (PBR CT), in collaboration with the MDB, is required.
In December 2003 the Executive Committee of the MDB confirmed that
only practitioners with adequate education, training and experience in
the field of radiography/radiology should be allowed to own and/or use
X-ray equipment. The Department of Radiation Control has therefore
adopted the following position since 1 June 2004:
Any practitioner or person wishing to use and/or own
medical X-ray equipment must have received proper,
accredited education and training in the correct and safe
use of such equipment as determined by the MDB and the
These professional boards are currently working on principles to
inter alia define adequate education, training and experience.
Implementation of this policy relating to further education and training
to be completed by non-radiologists currently in possession of licences
to use X-ray equipment will only be effected once the course has been
finalised, and guidelines pertaining to the use and ownership have been
refined and approved by the Health Professions Council of South Africa
(HPCSA). Such licence holders will be allowed to complete the course
within a given time.
In terms of current legislation the Directorate: Radiation Control
(DRC) is authorised to withdraw licences and seal equipment if
practitioners fail to meet the licence conditions.
In terms of the Regulations Relating to the Control of Electronic
Products, prospective users of X-ray equipment are also required to
submit applications for user licences at least 90 days before the
intended commissioning date. Suppliers may not install X-ray equipment
unless the client is in possession of a valid licence for the use
thereof. Licences are required for the possession (installation,
storage, etc.) of X-ray equipment, irrespective of whether such
equipment is being used or not.
The DRC does not anticipate any problems in this regard since
prospective users would have received sufficient notice of unsuccessful
Since a licence is issued to a specific person or hospital for a
specific machine (make, model and serial number) to be used at a
specific location, it may not be transferred from one party to another
without the formal approval of the DRC.
Any person acting in contravention of the stipulations above could
be prosecuted in terms of the relevant legislation.
Please feel free to contact the DRC or the HPCSA for further
Department of Health
Directorate: Radiation Control
Private Bag X62
Tel. 021 948-6162
Fax: 021 946-1589
E-mail: Susan Nel
Corresponding author: S Nel (email@example.com)
Directorate: Radiation Control, Department of Health