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Submitted by Donna Newman , ISRRT
   Commenting on behalf of the organisation
Document Occupational Radiological Protection in Interventional Procedures
 



Dear ICRP,


The ISRRT welcomes the opportunity to comment and give feedback on "The draft ICRP report Occupational Radiological Protection in Interventional Procedures”.


The following is a summary of the comments received by the ISRRT as the global member society representing over 500,000 radiographers.


As an organization, we believe the core elements of protection practices, as confirmed in the report relate strongly to the evolution of technology and procedures, having the proper protective devices and education of staff engaging in the procedures. Setting proper dose thresholds, is important and evidence based as outlined by the committee’s effective dose reduction to the lens of the eye, however, at the core, proper use of protective devices, and ongoing education are critical to reducing and maintaining occupational exposures to a minimum.


 


 As a global stakeholder representing the radiographer/technologist voice we believe that radiographers play a vital role in ensuring quality radiation protection is met through high quality standards of practice to the patient dose, occupational dose and public dose.


The ISRRT reached out to its member societies and asked the experts in their fields to read the document and validate the evidence based information for accuracy relating to the radiographers’ practice. We also as requested our experts to review the draft to look for trends and gaps that may need to be added or amended. The following are a summary of the information we received from radiographers/technologists that reviewed the document.


 


Over all the responses from our member societies summarized that the entire document was well written and contained crucial information. The overall responses also supported that the draft was based on evidence based practices. Finally, there was an overwhelming response that indicated that the information would be useful and should be implemented in the radiological profession.


The following are a summary of the suggestions for the draft document.


Suggestion one is that the globally accepted terminology used to describe the professional is radiographer and this terminology should be used throughout the paper when discussing the personnel. There are some spots where technologist is used instead of radiographer.
Suggestion two came from several comments that were received that stated although the recommendation of two dosimeters may give the most information about occupational dosimetry it will be quite expensive for the hospitals to implement.  This could be problematic depending on the country you are working in. 


  Suggestion three came from several comments that were received that there were several different terms used to describe the same person: interventionalist, operator, physician, interventional clinician the suggestion was to use one accepted global term such as interventionalist to be consistent throughout the paper.


 Fourth suggestion was from a comment that was submitted that the Radiation Protection Officer is responsible for the staff protection according to Directive 2013.


 Suggestion five came from several comments that were submitted that stated that some references are quite old and asking if there are newer supporting evidence based research to reference instead.


Among the information received from our member societies were several questions and points to consider further examination and more specific information:



  • Identification of how non-medical radiation staff (nurses, specialists etc.) working with radiation should be trained and educated and what level of training is required?

  • Identification of how medical staff who have formal training in radiation (MRTs, radiologists etc.) should be continually educated and to what level?

  • What educational mediums should be used and how it should be monitored, consistent with evolution of technology and practice (annual education/testing?)

  • Should there be an evaluation system to measure the results of a program/ education?


  • The ISRRT believes this draft on occupations radiological protection is essential to good practice for radiographers working with Interventional procedures. We thank the ICRP for the opportunity to comment on the ICRP Occupational Radiological Protection in Interventional Procedures document.


     


     


    Sincerely,


    Donna Newman


    Director of Professional Practice International Society of Radiographers and radiological Technologists  ISRRT