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Submitted by Donald Frush, Image Gently Alliance
   Commenting on behalf of the organisation
Document Occupational Radiological Protection in Interventional Procedures

L149:      What about operators in this list?


L185:      Not always physicians but other licensed healthcare providers such as PAs (e.g. L238 as well)


L229:      “Document lesion” not always. For example, in line placement there is no lesion. “Both normal and abnormal conditions and outcome of diagnosis or treatment” consider as substitute.


L244-248: Long, redundant (e.g. effectiveness and what comes subsequently)


L318:      Not using assigned dosimetry


L338:      Use of lead best for describing aprons? Since the other materials: should apron be substituted for by radioprotective garment?


L382:      All professionals: Why use this term? Why not all staff/operators?


L389:      Increased protection by increase (add) distance


L393:      Is mSv correct unit for conceptus dose?


L424:      What if medical physicists is responsible for creating and maintaining? As stated, says “or” rather than “and”. And what is role of PhD radiographer (i.e. European model)


L487:      Fluoroscopy intervention mentioned but CT intervention excluded.


L503:      Mentioned dental: How much of this is relevant to the document? e.g. Image guided dental procedures? This doesn’t seem to come up again so consider eliminating.


L504:      Diagnosis, surveillance and treatment (add surveillance).


L591:      “By employer” redundant since say “employed” earlier


L596:      “open” surgery? Is this a standard and understood term? Is there “closed surgery”?


L634:      Misplaced modifier “their”; say “these interventions” for “their”.


L700-06: Only talk about “external” ionizing radiation but mentioned SIRT above


L768:      CT also used for spine work (e.g. pain control)


L864:      When used “ED received” implies that they get this rather than exposed to or subject to…please clarify


L892:      Anesthetists/anesthesiologist “clarify terminology, e.g. CRNA in definition.


L1294:    “alters the radiation exposure”: what does this mean? Increasing or providing exposure?


L1725-28: Smaller font was used. Please correct.

L2074:  Section 5.1 Current wording: All professionals in the room should wear protective aprons;

Suggested change: All professionals in the room should wear wrap-around protective aprons;Reasoning: most staff in an IR environment are moving throughout the whole procedure and are not always facing the patient/x-ray tube during fluoro time;  wrap-around aprons are fairly standard these days to maximize effectiveness for staff safety around



L2103:    This goes without saying. One should be familiar with this already. Consider changing to something such as “familiarity should include both patient and occupational dose management”


L2116:    Consider adding as a reference (is open source)


L2227:    All interventional radiology lead then?


L 2340:  Section 5.6.1

Current wording: glasses can be quantified in terms of DRFs

Suggested change: glasses can be quantified in terms of dose reduction factor (DRF)

Reasoning: DRF was originally defined in section 4.4.3 line 1996, but should be redefined here (section 5) so readers can read each section independently.


L2752:    Incident versus accident difference? Need clarification



  • Role of including anesthesiologist who frequently are present for pediatric and commonly for adult procedures.

  • Discuss use of other modalities, either in place of or supplement to such as ultrasound especially in children where field of view may be more amenable for dose reduction.

  • Education and training should emphasize the spectrum of ages in some unique considerations in children.

  • Section 5.13: dose recording in additional to badges. Reporting confidentiality?

  • Recording:  Including medical record? What about the procedural record or only related to occupational exposure?

  • It seems that many of the sections are repetitive and redundant. Overall this report could be more concise.

  • Many of the assertions describing common practices are lacking references.

  • There seems to be an unusually large, unbalanced emphasis on the dose to the eyes for a report that encompasses all elements of radiation protection in interventional procedures. The NRCP recently published Commentary 26 (Guidance on Radiation Dose Limits for the Lens of the Eye). Which is listed in the references but not actually referenced within the work (?). They suggest a dose limit of 50 mSv rather than 20 mSv. Not sure why there is a difference in the dose limit, and there was no discussion of the difference within the report. There are significant costs associated with protection measures that may be overly conservative.

  • Not sure why section 3.5 isn't in section 5 

  • Surprising to learn that the ICRP recommends <1 mSv additional dose after the declaration of pregnancy. The NRC limit is 5 mSv for the gestational term and 0.5 mSv/month (vs 0.2 mSv per the ICRP). Why are these limits different? How is the risk to the fetus different?