A dispute over the safe use of dental radiography has developed between the island’s dentists and the entity that regulates their operations.

The matter gained traction last week when Jamaica Association of Public Dental Surgeons (JAPDENS) and Jamaica Dental Association (JDA) issued a joint news release responding to concerns raised recently by Hazardous Substances Regulatory Authority (HSRA) Director General Dr Cliff Riley regarding the safety of radiographic equipment used in dental practices.

According to the dentists, “the HSRA’s position reflects a misunderstanding of dental X-rays and threatens access to essential care in an already underserved environment”.

The dentists explained that dental radiography, including intraoral X-rays, is legally recognised as a fundamental part of dental practice under the Dental Act of Jamaica.

“These X-rays are essential for diagnosing and treating oral health issues, preventing complications, and improving patient outcomes. The Dental Act, which regulates all aspects of dental practice, clearly authorises the use of X-rays as part of regulated dental care,” they said.

However, they argued that the Nuclear Safety and Radiation Protection (NSRP) Act — though important in many settings — does not and should not supersede the provisions of the Dental Act.

“Dental professionals, as indubitable major stakeholders, were neither consulted nor involved in drafting this legislation nor was the regulatory body for dentistry in Jamaica, the Dental Council, given a voice in the process,” the dentists said.

“This lack of consultation has led to provisions within the Act that attempt to govern areas outside HSRA’s expertise. For example, the Act presumes to evaluate whether a dentist is ‘fit and proper’ to own an X-ray unit. Unfortunately, the HSRA lacks the clinical expertise to determine if and when dental X-rays are indicated for patient care and thereby regulate dental X-rays, and is encroaching on the professional autonomy of dentists, disregarding our training and ethical responsibilities,” both associations argued.

However HSRA, in response, said it has been in discussions with JDA and JAPDEN since November 2019 and has participated in consultations and exchanged several correspondences regarding the requirements and stipulations of the Nuclear Safety and Radiation Protection Act, 2015 and attendant Regulations (2019).

The regulator said that in its last written correspondence to the associations, in October 2023, “it was made very clear that all facilities, including dental facilities utilising X-ray units with energy levels above 5 keV (Kilo Electron Volts), must be authorised as per the law”.

But the dentists’ associations pointed out that, contrary to common misconceptions, dental X-rays use very minimal radiation.

“A standard intraoral X-ray exposes a patient to just 0.005 mSv — equivalent to a single day of natural background radiation, the kind we all experience just from being outdoors or living in our homes,” they said.

To highlight their point the dentists pointed out that a computed tomography, or CT scan, exposes a patient to between 1 and 10 mSv — up to 2,000 times more radiation than a dental X-ray.

An mSv (millisievert) is a unit of measurement of the amount of radiation absorbed by the body, also known as the effective dose.

According to the dentists, a chest X-ray is 20 times higher, at 0.1 mSv, which they said is about 10 days of natural radiation.

“In fact, the radiation from a dental X-ray is similar to the exposure you would get from walking outside on a sunny day for just 10 minutes. It’s minimal, well below any risk threshold, and far less than many other common activities, for example a short airline flight at high altitude or medical procedures we routinely undertake,” the dentists said.

In response, the regulator said that while it appreciates the purported internal radiation safety controls highlighted by JDA and JAPDENS, it must note that sole reliance on internal verification by the facility owners or other staff, who are dental professionals, is not best practice and contravenes the existing NSRP Act.

“Like all other health services, it is mandatory for there to be independent validation of safety protocols and practices such as radiation shielding, radiation measurements and dose monitoring, radiation-emitting equipment maintenance and proper functioning, to ensure fitness for clinical use,” HSRA said.

The regulator acknowledged that dental operations generally fall within the lower end of the radiation risk spectrum. However, it insisted that self-verification and validation are only one step in the process as an independent assessment must be undertaken, by law, by a qualified expert who is a trained medical physicist.

However, the associations said that Jamaican dentists adhere to strict safety protocols — including the use of lead aprons and digital radiography — to minimise radiation exposure.

They said that by painting the profession as “non-compliant” and imposing an unnecessarily heavy regulatory hand, HSRA misrepresents the safety standards already upheld within the field of dentistry and undermines the profession’s reputation.

“We urge the HSRA to adopt a more balanced, evidence-based, risk-adjusted framework that reflects the low-risk nature of dental X-rays,” the dentists said.

They also encouraged the regulator to work with Dental Council of Jamaica and the profession to:

“Implement annual inspections of dental practices to ensure safety standards are met, rather than imposing high-cost licensing fees.

“Partner with dental organisations to provide affordable training programmes on radiation safety for dental professionals; and

“Adopt graduated compliance requirements — a differentiated approach where facilities with higher radiation output, such as hospitals or imaging centres, are subject to more rigorous compliance measures, while low-output, dental radiographic facilities face simplified regulatory requirements.”