British Institute of Radiology [BIR] & Royal College of Radiologists [RCR]
Comments on ICRP Draft ‘Radiological Protection in Fluoroscopically Guided Procedures Performed Outside the Imaging Department
The British Institute of Radiology [BIR and the Royal College of Radiologists [RCR] welcome the opportunity to comment on the ICRP consultation regarding protection of staff and patients during procedures performed outside the explicit control of an imaging department. As the draft highlights, these procedures are often undertaken without the knowledge and support of radiology professionals and, as such, this draft is a welcome addition to the advice on offer to such practices.
In general the draft represents a fair statement of good practice, with a thorough literature review. We should like to stress, however, that the message that radiologists and medical physicists are a key supporting resource to such practice needs to be put across more forcefully in explanations of systems within organisations. Interventional radiologists make excellent trainers of surgeons and physicians in the use of fluoroscopy and medical physicists are required to advise upon and support the development of radiation protection systems, especially concerning staff and patient dose monitoring and equipment management issues. All of this may need to be more forcefully put across than at present.
Below are specific points raised during our organisations’ deliberations on your document;
Line 77; Amend ‘are provided as also’ to ‘are provided as are also’
Line 193; misspelt ‘reviewers’
Table 1.1; Many of the procedures mentioned later do not appear in this table, e.g. EVARs. This should be remedied.
Lines 521/524; The use of terms ‘Tissue Reaction’ and ‘Deterministic requires consistency. Our view is that the term ‘tissue reaction’ should be used throughout.
Line 541; States that infertility has not been documented. If this is because it has not been investigated then that should be stated. If it is because it has been investigated but not found, then that should be stated.
Line 581; change ‘Publication’ to ‘ICRP Publication’
Lines 689-719; This section is poorly constructed. The basic principles of rp are justification, optimisation and dose limits and time/distance/shielding are practical methods for optimisation. The section requires re-ordering and clearer explanation.
Lines 721-724; This statement does not universally apply to all nations. It should be reworded to better reflect the general situation, where, if required by national authorities compliance is necessary.
Lines 721-735; This whole section explains what controls are in place in a very general way. The message to the reader should be, ‘these are the controls and you must ensure they are in place’
Lines 786-787; This is poorly written. Change to either, ‘is such that the requirement to know your equipment should not be compromised’ or, ‘is such that the principle of ‘know your equipment’ should not be compromised’
Line 800; This is incorrect. The dose is reduced not the imaging time.
Line 801; The use of the term ‘rather’ is not required. This whole passage is confusingly written and would benefit from review.
Figures 3.3 & 3.4; Both would benefit from the addition of a distance scale.
Line 974; The use of film for personal dosimetry is nearly obsolete due to its unavailability. It should be omitted.
Line 1001; The practice of fingers in primary beam should always be discouraged, even if unavoidable and this should always be stated. This statement seems to tacitly condone the practice.
Table 4.1 [and others]; Why has a reference dose of 35 mSv been chosen? Could this be explained?
Lines 1193-1212; The use of leaded surgical drapes is not mentioned. These have been shown to reduce finger dose significantly in cardiology. These devices should be mentioned.
Lines 1426-1429; The language used if far too emotive and detracts from an objective message. Please reword.
Line 1859; Missing ‘is’ before the word ‘somewhat’
Line 1963; Replace ‘owing to’ with ‘dependent on’
Section 4.5.2 Staff dose management; There needs to be something in this section regarding the risk in TIPPS when employing lateral projections for the physician/surgeon to ensure they work on the exit side of the body not the entrance side and keep their fingers as far from the beam as possible. The doserates in such entrance side beams are enough to exceed a dose limit in 1-2 procedures.
Lines 2604-2611; This part needs to specifically mention the need for optimised CT protocols for use when scanning children.
Line 2933’ Replace ‘trough’ with ‘through’
Secretary, Radiation Protection Committee [BIR]
On behalf of BIR & RCR