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Submitted by Celso Osimani , International Committee of Italian Radiation Protection Association (IC-AIRP)
   Commenting on behalf of the organisation
Document Accidental exposures in modern radiotherapy
 
The International Committee of Italian Radiation Protection Association (AIRP-IC), representing also the Italian Medical Radiation Protection Association (AIRM) and Italian Medical Physics Association (AIFM), appreciated the document, which was considered an excellent piece of work, also beyond the technical aspects and the deriving benefits. From this document it emerges the contribution given by the radioprotection field and the derived culture to the technological society on the whole. In particular the ten main points at the beginning of the document are themselves of high educational level.

Some comments:

1) It seems that there are two titles given to the drafted document:
a- "Preventing accidental exposures from new external beam therapy radiation technologies", as reported on the front page;
b-"Minimizing the risk of radiation unintended exposure from newer therapy technologies", as reported on top of each page.
It is advised to take into account that the second title does not limit the attention to external beams explicitly and therefore, in principle, it does not exclude the radio-pharmaceutical therapy, which is not within the scope of the document. Also, please not the typographical error: “technologie” for "technologies" on top of the even pages.


2) Although the content of the document was considered excellent by AIRP-IC, the text of the document seems not to privilege the uniformity of language with other ICRP documents, such as the most recent recommendations. The fresh and practical approach of the document is appreciated but it is suggested to use, where possible, the already well known terms in the radio-protection community, also with the aim of having a greater link between the management of programmed medical exposures of various nature, since from the radio-protection point of view is they all stem from the same RP culture. Two examples are reported in the following:

a- Considering that the "unintended exposures" mainly involve the same individuals that are subject to programmed exposures during a therapy with radiations, that the caused damage is a risk for the health of the direct exposed persons, and that such exposures can be introduced as a result of potentially unsafe conditions, AIRP-IC would like to suggest to refer to these exposures in the text as "potential exposures" whenever it is possible.

b- The text of the drafted document often refers to "optimization of the dose distribution", to "quality assurance", and "directions of hundreds of minibeams", but it never cites the process or the principle of optimization.
It should be clarified, for example, whether "the need for proactive, structured, and systematic approaches to the identification of system weaknesses and the anticipation of failure modes", "the strategy for the user to systematically deal with risks from complex procedures”, and “the need for the design of proper warnings self-test capabilities, self-explanatory user interfaces and internal safety interlocks to prevent improper use that may lead to an accidental exposure” should be considered as part of the optimization process of the protection.
AIRP-IC would like to suggest recalling explicitly the optimization process at least in some points of the document.


3) From this document in draft it emerges a particular attention towards education and training already in the first of the ten main points and moreover an entire paragraph is dedicated to this topic. AIRP-IC particularly appreciated the recommendations (in paragraph 18) to governments, before embarking on radiation therapy programme, to consider a system of education and training of the staff. Regarding the medical physicist, two points should be considered carefully:

a- By considering that medical physicists have unique competences and a range of responsibilities, AIRP-IC suggests as comprehensive as possible when referring to the responsibilities of this professional figure (e.g. in paragraph 17) or in the case, like in the context of the draft, when the necessity of immediacy and simplicity of the text prevails, suggests to use the expression “medical physicists, responsible for example for …” in order to avoid the list of such responsibilities of the medical physicists to be considered exhaustive.

b- In consideration of the fact that to acquire and to maintain a good competence level for the management of the therapy with radiations, in particular in new technologies, it is necessary both a good initial education and continuous bringing up to date, AIRP-IC would like to suggest to give weight, in the document in draft, not only to the bringing up to date, but also to the necessity of a good initial level in the formation of the staff. The publication of this ICRP document could also be an occasion to support a harmonization and refinement of the curricula of medical physicists across various countries, if not globally at least in each area (meaning at the level of the European area, the American area, the Australian area etc.), remembering as an example that such efforts are taking place within the community (e.g. the work of the group ESTRO/EFOMP ref).