Open consultation

Using dual energy x-ray absorptiometry (DEXA) scans for non-medical purposes as a justified practice

Updated 30 March 2026

Introduction

Under The Justification of Practices Involving Ionising Radiation Regulations 2004 (JoPIIRR), any practice involving the deliberate exposure of individuals to ionising radiation must be justified before it can be lawfully introduced. Dual energy x-ray absorptiometry (known as DXA or DEXA) is an imaging technique that uses ionising radiation to measure bone mineral density. It’s a medical tool used widely to diagnose and monitor osteoporosis and osteopenia, and to assess an individual’s risk of bone fracture. DEXA can also be used to assess body composition, providing information on the relative proportions of fat, bone and lean muscle within a medical pathway.

The medical application of DEXA offers clear clinical benefit that outweighs the risks associated with low-dose radiation. As such, the medical use of DEXA is permissible under JoPIIRR. All medical exposures involving ionising radiation are regulated under The Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R) and The Northern Ireland Ionising Radiation (Medical Exposure) Regulations 2018 (NI IR(ME)R).

Issues and risks

While DEXA is well‑established as a safe medical practice, its use for sports and general wellness purposes requires careful consideration. The UK government is aware that some businesses currently offer, and others wish to offer, DEXA scans commercially for non-medical body composition monitoring, tracking changes in the proportion and distribution of lean muscle and fat tissue. Some elite athletes and professional sports organisations are also using DEXA to monitor and guide training programmes.

The use of non-medical DEXA for sports and general wellness purposes is prohibited as it is not justified under JoPIIRR. However, as confirmed in JoPIIRR guidance, DEXA examinations undertaken for insurance or legal purposes, where there is no medical indication, is permissible. For the purpose of this consultation, ‘non-medical DEXA’ refers specifically to DEXA scans provided for sports and wellness purposes.

Significant risks associated with non-medical DEXA use for sports and wellness purposes may include:

Repeated exposure and cumulative dosing

Although DEXA uses a relatively low dose of radiation, compared to other imaging techniques, repeated exposure may contribute to a small increased cancer risk over time.  

Greater impact on higher risk groups

Evidence from higher dose radiation exposure indicates that cancer risks from radiation are higher in young children and developing foetuses.

Lack of follow-up for incidental findings

Non-medical DEXA services for sports and general wellness purposes may detect incidental abnormalities, for example metastatic lesions, vertebral fractures and vessel calcifications. Without oversight from appropriate healthcare professionals, there is a risk that such findings may be missed or not followed up appropriately.

Variable service quality and safety

There are increased risks associated with commercial providers of non-medical DEXA scans who will not currently be licensed with an appropriate regulator as the practice is not a justified use of ionising radiation. Without oversight from a regulator, non-medical DEXA use for sports and wellness purposes creates potential risks relating to operator training, equipment maintenance and the accuracy of interpretations. These risks may lead to misleading information to users, potentially prompting misguided lifestyle or training decisions.

Expert advice

In 2019, the government sought independent expert advice on non‑medical DEXA use. In response, the Committee on Medical Aspects of Radiation in the Environment (COMARE) published Issues for sports performance assessment using DXA scans.

COMARE advised that:

• DEXA for assessing body composition in sport could be justified but should only be considered as part of a recognised training programme
• non-medical DEXA use should incorporate limits on scan frequency and minimum intervals between scans, with particular caution for children
• non-medical DEXA should not knowingly be used during pregnancy - while foetal risk is very low, the results would be of limited value due to physiological changes during pregnancy
• non-medical DEXA consent procedures would need to specify how incidental findings would be handled, including referral of images and results to a medical doctor

Justification

Before any new class or type of practice involving ionising radiation can be introduced in the UK, the government must first assess whether the potential individual or societal benefit outweighs the health detriment it may cause. This process is called justification.

As explained in JoPIIRR: guidance on their application and administration, a ‘practice’ is defined in legislation as a ‘human activity that can increase the exposure of individuals to radiation from a radiation source’. This includes a wide range of activities from nuclear power generation to the use of ionising radiation for medical and dental diagnosis and treatment.

Justifying a practice

For a practice to be justified, it must demonstrate an overall benefit with consideration of:

• its purpose and expected outcomes
• potential risks
• the population affected
• the availability of alternative approaches

If non-medical DEXA use for sports and wellness purposes was recognised as a justified practice, businesses wishing to offer non-medical services would need to register with the relevant regulator who would regulate them under IR(ME)R. IR(ME)R imposes specific obligations for ‘non-medical imaging using medical radiological equipment’. Obligations under IR(ME)R include:

• clear roles for duty holders (employer, referrer, practitioner, operator)
• adequate training and competence for all duty holders
• well-maintained radiological equipment
• exposures to be optimised and kept as low as reasonably practicable

Rationale for consultation

Building on COMARE’s 2019 findings and recognising the increasing interest in non‑medical DEXA use from sports bodies, fitness clubs and health centres, the government now considers it necessary to seek wider views on whether non-medical DEXA use should be recognised as a justified and legal practice.

Since the publication of the 2019 COMARE report, the Care Quality Commission (CQC) and other regulators have reported a growing demand to use DEXA for purposes such as general body composition assessment and to support optimisation of sports performance. To inform a justification decision, the government must first weigh the potential health risks against the potential benefits. To do this, the government aims to gather a broad range of perspectives, including those of service providers, users and scientific experts.

How to respond

Please respond through our online survey.

Do not provide personal data when responding to free-text survey questions. Any personal data included will be removed before analysis of these responses and will therefore not be considered in the consultation outcome.

The consultation is open for 9 weeks and will close at 11:59pm on 1 June 2026. If you respond after this date, your response will not be considered.

If you have any queries on this consultation, email environmental.hazards@dhsc.gov.uk. Do not send your consultation answers or any personal information to this email address.

Consultation questions

About you

Questions for everyone

In what capacity are you responding to this consultation?

• An individual sharing my personal views and experiences
• An individual sharing my professional views
• On behalf of an organisation

Questions for individuals sharing their personal or professional views

What is your age?

• Under 16
• 16 to 24
• 25 to 34
• 35 to 44
• 45 to 54
• 55 to 64
• 65 to 74
• 75 to 84
• 85 or above
• Prefer not to say

Are you a medical or healthcare professional?

• Yes
• No

Where do you live in the UK?

• England
• Scotland
• Wales
• Northern Ireland
• I live outside the UK
• Prefer not to say

If you said ‘England’, which area of England do you live in?

• North East England
• North West England
• Yorkshire and the Humber
• East of England
• East Midlands
• West Midlands
• London
• South East England
• South West England
• Prefer not to say

Question for all respondents

Do you have expertise in medical uses of ionising radiation? If you are responding on behalf of an organisation, please refer to the expertise of your organisation.

• Yes
• No

Questions for people responding on behalf of an organisation

What type of organisation are you responding on behalf of? Select all that apply.

• Business (for example, health and wellness facilities, gyms)
• Clinical and professional health body
• Elite sports performance provider
• Not for profit organisation
• Patient group
• Regulator within the health and social care sector
• Research and/or academic institution
• Trade association
• Other, please specify

Where does your organisation operate or provide services? Select all that apply.

• England
• Scotland
• Wales
• Northern Ireland
• Outside of the UK
• Prefer not to say

If you said ‘England’, where in England does your organisation operate or provide services? Select all that apply.

• North East England
• North West England
• Yorkshire and the Humber
• East of England
• East Midlands
• West Midlands
• London
• South East England
• South West England
• Whole of England
• Prefer not to say

Your use of DEXA scans for non-medical sports and wellness purposes

The next questions are about whether you have provided DEXA scans for non-medical sports and wellness purposes. This could include:

• sports performance assessments
• physical health monitoring including non-medical weight loss and body composition assessment
• general fitness purposes

Have you provided DEXA scans to individuals for non-medical sports and wellness purposes? (If you are responding on behalf of an organisation, does your organisation or business offer DEXA scans to individuals for non-medical sports and wellness purposes?)

• Yes
• No
• Prefer not to say
• Not applicable

If you said ‘no’ or ‘prefer not to say’, are you (or is your organisation or business) interested in offering DEXA scans to individuals for non-medical sports and wellness purposes? For example, for sports performance assessments or body composition assessments.

• Yes
• No
• Prefer not to say

If you said you provide DEXA scans for non-medical sports and wellness purposes, what do you provide non-medical DEXA scans for? Select all that apply.

• Sports performance assessment
• Physical health monitoring, including non-medical weight loss
• General fitness purposes
• Research
• Prefer not to say
• Other, please specify

The next question is about whether you personally have had DEXA scans for non-medical sports and wellness purposes. This could include:

• sports performance assessments
• physical health monitoring including non-medical weight loss and body composition assessment
• general fitness purposes

Have you had DEXA scans for non-medical sports and wellness purposes?

• Yes
• No
• Prefer not to say
• Not applicable

If you said ‘no’ or ‘prefer not to say’, are you interested in having DEXA scans for non-medical sports and wellness purposes?

• Yes
• No
• Prefer not to say

If you have had DEXA scans for non-medical sports and wellness purposes, what have you had non-medical DEXA scans for? Select all that apply.

• Sports performance assessment
• Physical health monitoring, including non-medical weight loss
• General fitness purposes
• Research
• Prefer not to say
• Other, please specify

If you have had DEXA scans for non-medical sports and wellness purposes, approximately how many non-medical DEXA scans have you had in the last 3 years?

• No scans
• 1 to 2 scans
• 3 to 5 scans
• 6 to 10 scans
• More than 10 scans
• Prefer not to say

Your views on DEXA scans for non-medical sports and wellness purposes

To what extent do you agree or disagree with the following statements?

DEXA scans for non-medical sports and wellness purposes should be allowed for elite athletes, for example to support their training programme. By elite athlete, we mean an individual who derives a living from competing in a sport, is a senior representative nominated by a relevant sporting body, is a member of the senior training squad for a relevant sporting body or is aged 16 or above and on an elite development pathway.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Prefer not to say

DEXA scans should be allowed for any non-medical sports and wellness purposes. This includes monitoring body composition for non-medical weight loss, general fitness or as part of sporting programmes.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Prefer not to say

Should there be age restrictions on DEXA scans for non-medical sports and wellness purposes?

• Yes
• No
• Don’t know

If you said ‘yes’, who should DEXA scans for non-medical purposes sports and wellness purposes be restricted to?

• People aged 16 years and older
• People aged 18 years and older
• Don’t know
• Other, please specify

To what extent do you agree or disagree with the following statements?

Non-medical DEXA scans for sports and wellness purposes should exclude individuals known to be pregnant.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Prefer not to say

There should be a limit on the number of non-medical DEXA scans for sports and wellness purposes that an individual can have each year.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Prefer not to say

If you have any further thoughts on the use of DEXA scans for non-medical sports and wellness purposes that you wish to share, including any potential restrictions not already discussed, please set them out here. (Optional, maximum 200 words)

Privacy notice

We will not be collecting the names and addresses of individual respondents, however we will ask you to identify which category of respondent you are, for example, a business providing DEXA scans, a regulator or a user of DEXA for sports performance assessment services. We will also be asking the region in which you live. A summary of the responses to this consultation will be published.

Responses to this consultation may be subject to release under the Freedom of Information Act 2000.

There may be occasions when DHSC will share the information you provide in response to the consultation with external analysts. This is for the purposes of consultation response analysis and provision of a report of the summary of responses only. Any quotes from responses included in the government response to the consultation will be anonymised.

For more information about how DHSC processes personal data, please see our privacy notice.

Glossary

Body composition

The percentages of fat, bone, water and lean muscle in the body.

Bone mineral density

The bone mass in a defined area divided by the bone area in the same region, for example, the femoral neck.

Consent

A process where a person gives permission before they receive any type of treatment, test or examination.

Dose

A measure of the amount of radiation received.

Elite athlete

As defined in the Health Protection (Coronavirus, Restrictions) (England) (Amendment) (No. 3) Regulations 2020, an elite athlete is:

an individual who (1) derives a living from competing in a sport, (2) is a senior representative nominated by a relevant sporting body, (3) is a member of the senior training squad for a relevant sport body, or (4) is on an elite development pathway.

Incidental finding

A finding that has potentially significant health or reproductive importance about which the individual is unaware, which is discovered in the course of an examination undertaken for a completely different purpose.

Ionising radiation

Radiation that is sufficiently energetic to remove electrons from atoms in its path. In human or animal exposures ionising radiation can result in the formation of highly reactive particles in the body which can cause damage to individual components of living cells and tissues.

Justification

Consideration that a medical exposure shall show a sufficient net benefit, weighing the total potential diagnostic or therapeutic benefits it produces, including the direct health benefits to an individual and the benefits to society, against the individual detriment that the exposure might cause, taking into account the efficacy, benefits and risks of available alternative techniques having the same objective but involving no or less exposure to ionising radiation.

Non-medical

A deliberate exposure of an individual to ionising radiation using medical equipment where the primary intention is not to bring a health benefit to the individual. 

Osteoporosis

A medical condition in which the bones become brittle and fragile from loss of tissue, typically as a result of hormonal changes, or deficiency of calcium or vitamin D.

Physiological

Pertaining to physiology. The functions of cells, tissues, organs and systems, and how they interact to maintain life and a stable internal state.

Practice

A human activity that can increase the exposure of individuals to radiation from a radiation source and is managed as a planned exposure situation.

Referrer

A registered health care professional who is entitled in accordance with the employer’s procedures to refer individuals for medical exposure to a practitioner.

Registered healthcare professional

A person who is a member of a profession regulated by a body mentioned in section 25(3) of the National Health Service Reform and Health Care Professions Act 2004 - for example, the General Medical Council, Nursing and Midwifery Council, and the Health and Care Professions Council.