ICRP Publication ref 4839-3982-4649 May 6, 2011
Response from: The Society & College of Radiographers, 207 Providence Square, Mill Street,London SE1 2EW
The Society & College of Radiographers is the professional and representative body for radiography and the radiography workforce in the United Kingdom. We are pleased to be able to respond to the above consultation document and this response is the view of the United Kingdom Council of the Society of Radiographers.
There is a growing concern amongst interested professionals and members of the public on the impact of radiological examinations on the overall radiation dose to the population. The Society & College of Radiographers understands this concern and believes the publication of this document is opportune. Our body has considerable responsibility for ensuring that the radiography workforce is properly educated and trained, consistent with the needs of patients and clinical imaging and radiotherapy and oncology services. Radiation protection is a significant element of the required training.In responding to the consultation document, we wish to make the following comments:
It is well understood that the effective dose to the population has been steadily rising due mainly to the technological advancements in radiology, the increased demand for services from referrers and patient expectations. It could be argued that the trend will continue unless a more concerted effort is made in the difficult areas of demand management and education of the public on the efficacy of radiological examinations.Paragraph 19
Referrers have a pivotal role to play in ensuring the right patients receive the right radiological investigation and radiographers have an essential role to play in the justification process and in protection of patients from the medical use of ionising radiation. Radiation protection issues must remain a priority for all concerned and this has to be underpinned by appropriate refresher training. This section could be strengthened by stating that organisations should strive for improvements in the radiation protection culture in the workplace and to promote radiation protection as a core element in workplace training and continuous professional development.Section 3.1 Justification
The section needs to emphasise the importance for referrers and practitioners to maintain up to date radiation protection training records.
Individuals with the responsibility to request or to justify radiological examinations must have a thorough understanding of the potential benefit and detriment associated with the medical exposure under consideration.
Justification needs to be supported by appropriate and current radiation protection training for the practitioner. Similarly, referrers must be aware of the need to keep the exposure to ionising radiations as low as reasonably practicable and be aware of the dose implications of each examination they request.
There must also be an appreciation that some requests will not be justified by the practitioner. When this does occur it must not be perceived as interference in patient management but as an intervention in the interest of patient protection.
3.4 Quality criteria implementation and audit
This section seeks to demonstrate that radiology practices in paediatric specialist centres compares favourably to non-specialist centres. Whilst this is understandable the document should encourage sharing of good practice supported by continuing professional development. Sharing knowledge could improve patient outcomes much more widely.
The paper suggests that devices such as sponges and sandbags may be used as positioning aids in very small infants. The document needs to guide readers to refer to their local infection control policy which may provide guidance on the use of positioning aids.
The need for equipment to be able to deliver short exposure times and be generally ‘fit for purpose’ is welcome. All radiation protection advisors and inspectors should be aware of this and be prepared to give advice to organisations on the suitability of equipment and actions required.
The Society & College of Radiographers