Licensing of medical practitioners to use X-ray equipment.

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

diagnostic purposes.

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 protected])

Directorate: Radiation Control, Department of Health