AERB registration for clinic and dental X-ray machines

If your clinic has an X-ray machine of any kind, including a dental unit, you need consent from the Atomic Energy Regulatory Board (AERB) before you use it. Under the Atomic Energy (Radiation Protection) Rules 2004, it is mandatory for every user of X-ray equipment to obtain the requisite consent from AERB, and all of it now runs through one online portal called eLORA.

The trigger is the radiation source, not your specialty. A radiology centre, a busy multi-specialty clinic with an in-house X-ray, and a single-chair dental practice with an intra-oral unit are all in scope.

Why a separate regulator exists for X-ray

X-ray, CT, and other radiation-producing equipment carry an occupational and patient safety risk that ordinary clinical licensing does not address. AERB is the national authority that regulates that radiation safety. Its job is to make sure the machine is a type-approved model, the room is shielded so staff and neighbours are not exposed, a named person is accountable for safety, and the equipment is tested on a schedule.

This is a genuinely distinct regime from the other registrations on your setup list. Your clinical establishment registration says you may run a clinic. Your AERB consent says you may run the radiation source inside it. One does not cover the other.

AERB is not PCPNDT, and you may need both

This is the single most common confusion, so it is worth settling early. AERB and PCPNDT are two different laws, two different authorities, and two different machines.

• AERB governs radiation safety for X-ray, CT, mammography, dental X-ray, and similar radiation equipment.
• PCPNDT governs ultrasound and other pre-natal diagnostic equipment, to prevent sex selection.

An ultrasound machine needs PCPNDT registration and has nothing to do with AERB, because ultrasound uses sound waves, not ionising radiation. An X-ray needs AERB and has nothing to do with PCPNDT. A diagnostic centre that runs both an ultrasound and an X-ray or CT needs both registrations, applied for separately with the two authorities. Keep the two files apart in your head and on your shelf.

Who needs AERB consent

Assume you are in scope if you own or are about to install any of these:

Equipment	Typical setting	AERB applies
Intra-oral / RVG dental X-ray	Dental clinic	Yes
OPG / panoramic, dental CBCT	Dental clinic, ortho	Yes
General radiography (chest, limb)	Clinic, hospital	Yes
CT scanner	Diagnostic centre, hospital	Yes
Mammography, C-arm, fluoroscopy	Imaging centre, OT	Yes
Ultrasound	Any	No (this is PCPNDT)

Dental clinics sometimes assume the rules are only for big imaging centres. They are not. A dental intra-oral unit is a radiation source and falls squarely under AERB, even though its exposure is small. The category and exact consent may be lighter than for a CT, but the duty to apply is the same.

The eLORA portal: where it all happens

AERB requires all X-ray institutions to obtain their consents through eLORA, short for e-Licensing of Radiation Applications. It is a web-based system, so there is no paper counter to visit. You create an account for your institution, then work through the steps online.

In broad terms, the process moves through these stages, though the exact screens and order can change as AERB updates the portal:

1. Register the institute. Create the facility profile with the institution's details and the people responsible.
2. Get the room layout approved. Submit the X-ray room plan. Appropriate structural shielding has to be provided for walls, doors, ceiling, and floor so that dose limits are met. AERB publishes sample layout plans for different equipment types to work from.
3. Procure approved equipment with permission. Buy a type-approved or NOC-validated machine from an authorised supplier, after obtaining procurement permission from the Competent Authority. AERB requires suppliers to sell only type-approved models, so confirm the model's approval before you order.
4. Register each machine. Record every X-ray unit at the centre on the portal, including any portable or hand-held one, which is easy to overlook.
5. Apply for the consent to operate. No diagnostic X-ray equipment may be operated for patient diagnosis until the consent for operation is obtained from the Competent Authority.

Whether your particular machine is granted as a lighter registration or a fuller licence depends on its category, and AERB sets that mapping. Smaller, lower-risk units such as dental intra-oral systems generally sit at the lighter end, while CT and interventional equipment sit at the heavier end. Treat the labels as AERB's call, not something to guess, and confirm your machine's category on the portal.

The Radiation Safety Officer

An upcoming radiology facility must have a Radiation Safety Officer (RSO) approved by the Competent Authority. The RSO is the named person responsible for making sure the installation meets its radiation safety obligations day to day.

The RSO may be the owner-doctor or an employee to whom the duty is delegated, and the minimum qualification and training are set by AERB. The bar rises with the category of equipment. For a simple X-ray, an owner who completes the prescribed radiation safety training may be able to act as RSO. For higher categories such as CT or interventional work, expect a more demanding qualification. Confirm what your specific category requires before you build a hiring plan around it.

The duties that continue after you go live

AERB consent is not a one-time event. Two duties run for as long as the machine is in use:

• Quality assurance testing. Periodic QA of the equipment must be carried out by AERB-authorised agencies. AERB's guidance points to a minimum interval (commonly cited as every two years), but confirm the current interval for your equipment, as this is the kind of figure that gets revised.
• Personnel monitoring. Radiation workers must be provided with personnel monitoring, typically a TLD or OSL badge, so individual exposure is tracked.

There is also a tail at the end of the machine's life. When you replace or retire an X-ray unit, AERB expects the old one to be decommissioned and disposed of through approved channels rather than quietly sold on. Plan for that when you upgrade.

Fees, timelines, and the honest caveats

Fees and processing times for AERB consents vary by equipment category and change over time, so this guide deliberately does not quote a rupee figure or a number of weeks. The portal shows the current fee for your application, and the realistic timeline depends on how clean your layout submission and documents are. Build the application into your fit-out schedule early, because you cannot lawfully scan a patient until the consent to operate is in hand.

If your setup is more than a single dental unit, or you are installing CT or interventional equipment, it is worth engaging a radiation safety consultant or a qualified medical physicist to prepare the layout and shielding submission. A clean first application saves more time than it costs.

Where AERB sits in your wider compliance map

AERB is one specialised regime among several. It is separate from your clinical establishment registration, separate from PCPNDT for ultrasound, and separate from biomedical waste rules. The specialty compliance guide maps how these machine-triggered and specialty-triggered regimes fit together, and the full list of licences to open a clinic shows where AERB lands in the overall sequence. To get a quick read on which of these apply to your setup, the clinic licence checker walks through the common ones.

Where Avinya Plus fits

Be clear about the boundary here. Avinya Plus is an EMR, billing, and scheduling system. It does not handle your AERB registration, it does not generate radiation safety records, and it does not manage your eLORA consents. Those remain a separate statutory duty you carry out with AERB.

What the software does help with is the clinical record that sits around the imaging. It keeps structured patient records with a chronological timeline that can include imaging entries, and an audit trail logging who viewed, created, or changed a record. That record discipline is useful for the clinic generally, but it is not a substitute for the AERB consent, the layout approval, the RSO, or the QA schedule, all of which live outside any practice management software.

This is general information, not legal advice. AERB registration is administered centrally with category-specific requirements that change over time. Confirm the current rules, fees, and timelines on the eLORA portal or with a qualified radiation safety consultant before you procure equipment or apply.