Inspection report  
Licence holder

Department of Climate Change, Energy, the Environment and Water, Australian Antarctic Division, Polar Medicine Unit (AAD-PMU)

Location inspected Kingston, Tasmania
Licence number  S0008
Date of inspection 7 June 2023
Report number R23/04566

This inspection was conducted as part of ARPANSA’s source inspection program to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 2018 (the Regulations), and conditions of source licence S0008.

The scope of the inspection included an assessment of performance at the AAD Kingston premises against the Source Performance Objectives and Criteria (SPOC).  The inspection consisted of a review of records, interviews, and a physical inspection of sources.


AAD-PMU, part of the Department of Climate Change, Energy, the Environment and Water, is authorised to deal with controlled apparatus under section 33 of the Act.

AAD-PMU uses mobile medical and dental X-ray equipment (controlled apparatus) to provide medical and dental care at Casey, Davis and Mawson stations on Antarctica, the subantarctic station at Macquarie Island, and supply ships.  Each group of Antarctic expeditioners is isolated from usual medical facilities through Antarctica's remoteness.  Each station and ship therefore requires on-site Antarctic medical practitioners (AMPs) who provide surgical, medical and dental care to these isolated groups of people.  The AMPs are, in turn, supported by full-time medical practitioners located at the AAD-PMU's headquarters in Kingston, Tasmania.  Medical diagnostic and dental radiography are part of the services these AMPs provide.

The AAD-PMU medical and dental equipment are regularly rotated through the stations and ships back to the headquarters at Kingston.  Once the equipment arrives at Kingston, it is sent for testing and servicing by appropriately licensed personnel from the private sector.

The main codes and standards applicable to this licence are:


In general, the management of radiation safety at the AAD Kingston premises in relation to controlled apparatus was found to be sound.

Effective control

Management commitment

AAD-PMU has demonstrated a commitment to radiation protection by establishing a policy to facilitate the safe and effective use, storage and disposal of controlled apparatus at its Kingston premises and its remote bases and ships.  This is supported by a comprehensive Radiation Management Plan (RMP), their Plans and Arrangements, to achieve and maintain best practice and compliance with radiation legislation and ARPANSA licence conditions.  The RMP is, in turn, supported by procedural documents relating to radiation protection and X-ray safety management.  It should be noted that this particular inspection focusses mainly on the Kingston premises with Antarctic and Southern Ocean bases and the ships being inspected electronically at other times.

Statutory & regulatory compliance

The RMP has been written to ensure compliance with the Act, the Regulations and the conditions of licence S0008.


The Radiation Safety Officer coordinates information for quarterly reports combining that from Kingston with input from each Antarctic base.  Once collected, this information is consolidated into a single final report to ARPANSA.  AAD quarterly reports have been submitted to ARPANSA in a timely manner in recent years, and contain relevant information, including details of compliance with the Act and Regulations.

Safety management

Safety management for the licence is outlined in a separate document to the RMP and includes topics such as:

  • the promotion of safety culture within the organisation,
  • training of relevant staff,
  • incident reporting,
  • record keeping, and
  • regular audits and quality assurance programs for the equipment.

Of those controlled apparatus seen during the inspection, all matched the internal designations assigned to those apparatus and listed in the SIW. 

Training & education

All personnel who operate the X-ray equipment are required to undertake training relevant to the equipment’s use before being permitted to carry out medical or dental radiography.  Training records for AMPs for use of the equipment were verified by the ARPANSA inspectors for each person who had completed the training.

AAD-PMU has developed a remote radiography training course in conjunction with the University of Tasmania and the Tasmanian Department of Health radiation regulator for rural and remote medical X‑ray operators through its Centre for Antarctic, Remote and Maritime Medicine.  A pass in this course is required for all operators at the Antarctic and Southern Ocean bases and the ships.  AAD-PMU keeps the training records electronically and these were viewed during the inspection.  This is considered an example of a good practice.

It was noted that only the AMPs on the bases had received the radiography training.  In the unlikely event of the AMP becoming incapacitated and in need of an X-ray for diagnostic purposes, the task would fall on an ‘untrained’ person, albeit under supervision of the AAD-PMU medical practitioners at Kingston.  For this reason, AAD-PMU should consider including a radiation safety component into the monthly on-station training program.

Radiation protection

All radiation protection provisions of RPS C-5 and RPS 10 were seen to be used including, but not limited to:

  • the availability of patient protection (lead aprons and thyroid shields)
  • relevant warning labelling on X-ray equipment,
  • the adoption of the justification principle when determining the need for an X-ray, and
  • the adoption of optimisation for all procedures (e.g. limitation of field size, the use of exposure charts, correct patient positioning, frequent equipment quality assurance checks etc).

These provisions are outlined in the radiation protection procedural document.  It should be noted that any deficiencies will be identified and reported on by the nominated Radiation Medical Practitioner, a consultant radiologist at Royal Hobart Hospital.

Radioactive Waste

No radioactive waste is generated during any procedure.


The use of controlled apparatus only does not invoke the requirements of the Code of Practice for the Security of Radioactive Sources (2019) (RPS11).

Emergency plans

Event Protection and Emergency Preparedness and Response were handled under the broader AAD policy and work health and safety plans and was not assessed during the inspection. 


The licence holder was found to comply with the requirements of the Act, the Regulations, and licence conditions.

The inspection revealed the following good practice:

The development of a rural and remote X-ray operator training course in conjunction with the University of Tasmania and the Tasmanian radiation regulator.

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