Register and run X-ray equipment in a chiropractic clinic

This applies if a chiropractor in your clinic will take X-rays, or if you are adding an X-ray machine. If your clinic does not take X-rays, it does not apply to you.

Taking X-rays is a diagnostic and screening procedure. In England it normally needs registration with the Care Quality Commission (CQC). Schedule 1 to the 2014 Regulations excepts X-rays taken by a chiropractor registered with the General Chiropractic Council (GCC). That exception covers chiropractors only. If a physiotherapist or an osteopath will take X-rays, follow Physiotherapy, osteopathy and chiropractic clinic registration first.

The exception removes CQC registration. It does not remove your duties under the radiation regulations. These rules apply in Great Britain:

• the Ionising Radiations Regulations 2017 (IRR 2017), which protect your staff and the public
• the Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R 2017), which protect patients

You must meet these regulations before the first X-ray. Allow time for the HSE application when you plan your opening date.

Steps to take before your first X-ray

Duties and who enforces them

The summary below sets out the main duties and the regulation each comes from. The HSE guidance on IRR 2017 is approved code of practice and guidance L121. Read it with your radiation protection adviser.

Enforcement by nation

The HSE enforces IRR 2017 across Great Britain. Who enforces IR(ME)R 2017 depends on where your clinic is. The CQC does so in England, even though it does not register your clinic for X-rays.

Wales follows the same pattern as Scotland, with its own Ministers and inspectorate.

Northern Ireland has its own X-ray regulations.

Inspections and common problems

Expect inspection. The GCC reports that the HSE has run a rolling programme of inspections under IRR 2017 that was to include chiropractic clinics. The GCC also states that all practices with X-ray facilities are always subject to inspection. In England the CQC can inspect your X-ray facilities against IR(ME)R 2017 even though you do not register with it.

If you are not sure whether an activity needs registration or falls within the rules, ask before you start:

• ask your radiation protection adviser about risk assessments, local rules and the registration application
• ask the HSE about registration through RADAN
• ask the CQC, Healthcare Improvement Scotland, HIW or the RQIA about medical exposure and whether an exception applies

Asking does not commit you to anything.

What to do next

Add X-ray safety to your wider health and safety arrangements, and keep the risk assessment, local rules and procedures where an inspector can see them. For the rest of the set-up path, follow Start a physiotherapy, osteopathy or chiropractic clinic. Review your procedures each time you change equipment or staff.