Advisory note

X-ray baggage machine with a conveyor belt


  • Between June 2016 and July 2017, ARPANSA undertook 28 inspections of baggage X-ray units.
  • The units inspected are used for a range of screening scenarios including: public access to court buildings and diplomatic posts; mail and parcels; arriving passengers within the customs controlled areas of international airports.  
  • The five broad ‘Areas for Improvement’ (AFIs) were broken down into sub-categories to better highlight the AFI.
  • Inspections are generally based on regulatory priority (RP) where RP1 is the highest priority and RP6 the lowest. The RP of a source is based on its hazard level. Section 1.7 of the

    contains details about how RP is determined.  

  • Baggage X-ray units are considered low hazard and are assigned RP6. For certain low hazard sources (RP5 or RP6) ARPANSA may adopt a simplified approach to regulatory oversight that may not require physical or e-inspection. For most baggage x-ray units this may mean that they are not inspected unless specific circumstances warrant the need.
  • Licence holders who deal only with baggage X-ray units may be required to report on compliance twice a year instead of annually. In these cases, the licence condition for reporting will be amended accordingly.  

Standard used for inspection

ARPANSA conducts inspections of cabinet x-ray units against Radiation Health Series 21 (RHS 21) Statement on cabinet X-ray equipment for examination of letters, packages, baggage, freight and other articles for security, quality control and other purposes.

Cabinet X-ray equipment means an X-ray unit in a shielded enclosure (cabinet) into which articles, products or other materials may be placed, or through which they may pass, for fluoroscopic or radiographic imaging.

RHS 21 sets out requirements and safety standards for shielding, external radiation, safety interlocks, maintenance ports, item examination access, controls which initiate and terminate the generation of X-rays, lighting, signage, monitoring, training and maintenance.  

Conformance with RHS 21 and compliance of X-ray equipment with the requirements of ‘the Statement’ will ensure that the operators of the equipment and the general public will be exposed to negligible doses of ionizing radiation.

Areas for improvement

AFI primary classifications of X-ray baggage units

Identified AFIs for X-ray baggage units

Figures relate to findings from inspections of baggage X-ray units between June 2016 and July 2017

Analysis of inspection findings

Analysis of the inspection findings for baggage x-ray systems grouped the AFIs into five categories:

  1. Documentation
  2. Equipment and technology
  3. Record keeping
  4. Training
  5. Other

Documentation: Licence holder’s documents not reviewed in accordance with plans and arrangements or reporting requirements.  Some documentation was out of date and had not been updated to reflect current internal procedures, plans and arrangements.

Equipment and technology: related primarily to compliance with technical aspects of the standard with many licence holders failing to adhere to requirements for access control of entry/exit ports of the X-ray machine and use of correct signage.

Record keeping: included incorrect and superseded lists of authorised staff, inaccurate inventory of apparatus and source inventory workbooks as well as access to and availability of maintenance records and accurate staff training records.

Training: included a number of licence holders failing to train staff in accordance with their plans and arrangements and in one case, a staff member occupying the position of Radiation Safety Officer (RSO) without having completed the required RSO training. 

Other: included access control issues which are not within the scope of RHS 21.


  • Analysis of inspection data confirms the low hazard category of baggage X-ray units classified by ARPANSA as RP6.
  • Unless specific circumstances warrant, ARPANSA may not conduct inspections of baggage inspection X-ray units. In such cases, licence holders will be required to apply their own internal controls and audit processes to ensure they continue to meet their licence conditions and the requirements of RHS 21.
  • Licence holders who deal only with low hazard sources such as baggage X-ray units may be required to report their compliance twice a year instead of annually. In such cases the licence will be reissued with the amended licence condition.


Australian Radiation Protection and Nuclear Safety Regulations 2018

Radiation Health Series 21 Statement on cabinet X-ray equipment for examination of letters, packages, baggage, freight and other articles for security, quality control and other purposes (1987)

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