|The American College of Radiology (ACR)—a U.S. based professional organization representing more than 36,000 radiologists, radiation oncologists, interventional radiologists, nuclear medicine physicians, and medical physicists—appreciates the opportunity to provide comments on the International Commission on Radiation Protection’s (ICRP) draft report for consultation, Radiological Protection Education and Training for Healthcare Staff and Students.
It should be noted that several of the following comments were previously submitted by Donald L. Miller, MD, FACR, who serves ICRP on Committee 3.
Line 103: Add “certain other medical practitioners” after “radiologists.”
Line 143: Delete “even.”
Line 160: Change “necessary sine qua non” to “essential.”
Line 332: Change “avoid” to “reduce.”
Lines 461-505: Physicians should be categorized according to what they do, and not according to specialty. We suggest a classification of radiologists (DR), interventionalists of any specialty (MDI), nuclear medicine practitioners of any specialty (MDN), and the existing classes of MDX, MDA, and MD. A physician may be a member of more than one classification and therefore would meet the requirements for each class—understanding there will be common elements in the curricula for these classifications, and it should not always be necessary to repeat common elements during training.
Lines 484-486: Because emergency department physicians heavily prescribe imaging exams, we suggest specifically mentioning them as an example: “8. Medical Prescribers (MD): Physicians (for example, emergency department physicians) who request examinations and procedures involving ionizing radiations and medical students who may prescribe examinations in the future.”
Lines 487: Instead of “Medical Physics Technologists,” the U.S. uses the terminology “Diagnostic Medical Physicists.”
Lines 487-491: Because the roles of radiographers are significantly different from those of medical physicists, we suggest breaking item #9 into two—one category for radiographers and the other category for medical physicists.
Lines 494-495: Clarify if item #11 (Other Healthcare Professionals) include physician extenders such as nurse practitioners and physician assistants. In the US, we are finding more physician extenders performing or supervising procedures utilizing ionizing radiation. Few of these have the necessary training in radiation protection. If you include the individuals in this category, we suggest mentioning them by name. If you did not intend for this category to address these individuals, we suggest creating a new category to include physician extenders such as nurse practitioners and physician assistants.
Line 568: In some countries, nurse practitioners are permitted to practice independently and prescribe medical exposures. These individuals should be required to have the same training and certifications as individuals in class MD.
Lines 962, 965: Please change “authorized” to “authorizing.” It would also be helpful to state the criteria for an authorizing body.
Lines 1177-1179: Certification does not entitle a person to practice an activity. Certification only demonstrates an adequate knowledge of a specific subject. Privileges to practice the activity are granted by the facility on the basis of certification and the demonstration that the individual is competent clinically. You are confusing certification (also called credentialing) with the granting of clinical privileges. The two are not the same.
Lines 1291-1296: In addition to the EU guidance, the ACR Appropriateness Criteria also provide excellent guidance on justification. These criteria are constantly updated and readily available on the web, at no charge. They should be cited and referenced.
Annexes A.2, A.3: The requirements for all interventionalists should be the same.
Line 1734: The site listed as Office of Radiation Protection (Division of Environmental Health, USA) is in fact the Washington State Department of Health, USA. This web site belongs to the State of Washington, one of the 50 states in the U.S., not to the US federal government.
Lines 1763-1766: For this reference, please use this citation: Klein LW, Miller DL, Balter S, Laskey W, Haines D, Norbash A, Mauro MA, Goldstein JA. Occupational health hazards in the interventional laboratory: time for a safer environment. J Vasc Interv Radiol 2009; 20:147-52. This is the reference for the journal that holds the copyright (JVIR); the author list follows the bibliographic data in PubMed.