Queensland veterinarians should be aware of important changes that came into effect on 1 October 2025 regarding the use of diagnostic X-ray equipment under Queensland radiation safety legislation.
These changes affect whether a radiation use licence is required and apply specifically to veterinarians who use plain diagnostic imaging X-ray apparatus for small animals.
What has changed?
From 1 October 2025, veterinary surgeons who are registered with the Veterinary Surgeons Board of Queensland (VSB QLD) are now considered prescribed licensees for the purposes of radiation safety legislation.
This means that registration with the VSB QLD now authorises certain X-ray use, without the need to hold an individual radiation use licence, provided the use falls within the prescribed scope.
Importantly, this is not an exemption from licensing, but rather a different mechanism for authorisation under the legislation.
What X-ray use is covered by prescribed licensee status?
Prescribed licensee status applies to:
- Plain diagnostic imaging X-ray apparatus
- Used for plain diagnostic imaging of small animals
This includes:
- Plain dental radiography of small animals, which is considered a subset of plain radiography and is therefore covered.
Veterinarians whose X-ray use is limited to this scope are authorised to use the equipment on the basis of their VSB QLD registration alone.
What if you previously held a radiation use licence?
If your licence only covered plain radiography of small animals
Veterinarians who held a licence prior to 1 October 2025 that only authorised plain diagnostic imaging of small animals:
- No longer need to renew that licence
- Are now authorised under the prescribed licensee arrangements
If your licence covered additional imaging or equipment
If your previous (or current) licence authorises any broader scope, such as:
- Imaging of animals outside the “small animal” category
- Use of different or more advanced equipment (e.g. CT, fluoroscopy)
- Other radiation practices beyond plain diagnostic imaging
Then:
- You must continue to hold a separate radiation use licence
- That licence remains in force for the additional authorities
- It must continue to be renewed in line with the expiry date shown on the licence
Important clarification required: “small animal” vs “large animal”
A key issue that remains unresolved is the definition and interpretation of “small animal” for the purposes of these prescribed licensee arrangements.
- The legislation and current guidance rely on the term “small animal”
- This terminology does not align cleanly with contemporary veterinary practice, where imaging may be performed across species, sizes, or practice types
- The AVA has formally raised this issue with the Queensland Radiation Health Unit (RHU)
- The Veterinary Surgeons Board of Queensland has also requested clarification, so they can appropriately advise registered practitioners
Further guidance from the Department of Health is required to ensure veterinarians clearly understand:
- Whether their specific radiology practices fall within prescribed licensee status, or
- Whether a radiation use licence is still required
At the time of writing, this clarification is still pending.
What should Queensland veterinarians do now?
All practitioners are strongly advised to:
- Review the type of radiology you use, including:
- The type of imaging equipment used
- Check whether your practice falls entirely within:
- Plain diagnostic imaging of small animals
- Apply for or renew a radiation use licence if:
- You believe your imaging activities fall outside the prescribed licensee scope
- Seek advice if you are unsure
Who to contact for advice
If you are uncertain whether you require a radiation use licence under the new arrangements, you are encouraged to contact the Queensland Radiation Health Unit directly: Applicants, licensees and certificate holders enquiry form | Queensland Health