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Submitted by KY Cheung, IOMP
   Commenting on behalf of the organisation
Document Education and Training
1. General comment
This is a very important document with a clear structure and an outstanding comprehensive approach on the issue of education and training in Radiation Protection. ICRP Committee 3 should be congratulated for coming up with a comprehensive set of recommendations on education and training of medical professionals and supporting personnel on radiation safety and protection in diagnostic and interventional radiology. The document comes at the right time when the standard of practice in radiation safety, optimization of patient dose in particular, in diagnostic and interventional radiology is falling behind the advances in equipment technology and clinical practices. The document should be a valuable guide for those involved in education and training of medical professionals on radiation safety and protection and it should have a positive long term impact on dose reduction in radiology. IOMP welcomes the publication of the document.

2. Specific suggestions:
The report mainly deals with diagnostic imaging and interventional radiology. This should be indicated as such in the title of the report to avoid misleading. A suggested title is “Education and training on radiological protection in diagnostic imaging and interventional radiology for healthcare staff and students?

Page 18, lines 487-491, point 9.
The international terminology for Medical Physics should be respected. “Nuclear Medicine Physicists?is not a standard terminology and there is no need to use this term in this document. Also the term “Medical Physics Technologists?could be open to misrepresentation as it is not used in many countries. Again there is no need for this term in this document.

This document does not address the education and training requirements for Medical Physicists. This should be stated clearly at the beginning of point 2.2 in page 17, taking into account what is stressed in page 26, lines 716-722: “Medical physicists [experts in RP] should know all the training areas at the highest level, in addition to physics and all relevant aspects of quality assurance programmes, as they will play a major role in advising others on optimization of RP and delivering the training lectures. This group will need to maintain their competence to ensure that they keep up to date with the current knowledge of radiation hazards and risks, developments in techniques and equipment, and legislative requirements. They will require substantially more training than the other categories considered here.?

Medical Physicists are health professionals who are supposed to “have the highest level of training in RP as they have additional responsibilities as trainers in RP for most of the clinicians.?(lines 576-577 and final recommendation 17) lines 1164-1166). The requirements for their education and training in RP are addressed elsewhere. Please note that neither Table 1 nor Table 2 include the Medical Physicist category.

Having this in account, the professional category referred in point 9 should be stated as: “Radiographers, nuclear medicine technologists and x-ray technologists?in accordance with section 2.3.3., page 21, line 579. Also the RDNM category in Table 2, page 28 should be replaced by “RDNM - Radiographers, nuclear medicine technologists and x-ray technologists?(lines 765-766).

Page 36, lines 1011 and recommendations 5, page 39, line 1121 and 30, page 42, line 1209
According to the Terminology (section 5.1) “Accreditation?refers to the organization and “Certification?to the individuals. That’s why it is not so coherent to employ the term “certification of the training?in lines 1011 and 1209. Both the organizations and the courses (training included) can be accredited in order for individuals to get certification. This is in line with the expression used in line 1023 (“accrediting RP training programmes?. Also the “certification of the training?in lines 1121 and 1209 should be accordingly replaced by “accreditation of the training?

Summary of ICRP recommendations, pages 39 to 43
The Summary of ICRP recommendations, in pages 39 to 43, enunciates 38 recommendations without a proper organization. These recommendations should be grouped according to main themes like:
? General guidance for RP education and training (recommendations 1), 9), 10), 27), 32), 35), 36));
? Structure and organizational aspects of the training for physicians (recommendations 3), 4), 5), 8), 15), 23), 24), 26));
? Specifications for interventionists (recommendations 12), 13));
? Structure and organizational aspects of the training for other staff (recommendations 11), 16), 20), 21));
? Contents of the RP programs for physicians (recommendations 2), 6), 7), 14), 25));
? Contents of the RP programs for other staff (recommendations 18), 19));
? Trainers (recommendations 17), 28), 29));
? Evaluation of the training (recommendations 22), 30), 31));
? Accreditation and certification (recommendations 33), 34), 37), 38)).

The suggested groups above are just a possible way of structuring the 38 recommendations in order to highlight in a better way its global importance

3. Point suggestions:

Lines 93,170 and 1096. Add: medical institutions

Page 7, lines 177-179. The sentence "Other than aspects of nuclear medicine therapy, this document does not address radiation therapy, modalities which should only be prescribed by medical staff who have specialized in the relevant disciplines." is not clear. Which modalities should only be prescribed by medical staff who have specialized in the relevant disciplines? We would prefer: "This document does not address radiation therapy, except in what concerns some aspects of nuclear medicine therapy."

Page 9, line 227. Add: "Equipment manufacturers also have responsibility to develop and make available appropriate tools that are built into the radiological equipment to facilitate easy and convenient determination and recording of exposure dose with reasonable accuracy."

Page 12, line 334, "x-ray table" should be "patient table"

Page 16, line 417, "treatment" should be "clinical benefit"

Page 18, lines 484-5. Add: Paediatricians in particular should be emphasised in "Physicians who request examinations and procedures involving ionizing radiations ..."

Page 20, line 553. Add: particular emphasis on paediatrics should be given in sentence "prescribers of imaging techniques using ionizing radiation"

Page 22, line 617. "killing cells" should be "cell killing"

Page 22, line 620. "organs" should be "tissues"

Page 23, line 622. "frequency" should be "probability"

Page 25, Line 698. Add: 22) National and international legislation, guidelines and institutions. Also: A topic on principles and methods of protection of patients and staff in diagnostic and interventional radiology should be included in the course. A topic on knowledge and skills for counseling of patients on radiation risks before and after medical exposures should also be included in the course.

Page 26, line 716. Delete "experts in RP" from sentence "Medical physics experts in RP"

Page 29, line 791, "8 and 9" should be "9 and 10"

Page 29, line 792. Formal training on RP with proven professional competency through professional certification is needed in additional to education before he/she is qualified to practice the profession and teach others to practice.

Page 30, line 816. "the units used" should be "the quantities and units used"

Page 30, line 834. Principles and procedures for image quality and dose optimization should also be emphasized in training of engineers.

Page 32, line 899. Too much flexibility in the amount of training should be avoided as this could lead to variations in standard of training and hence standard of practice. A minimum requirement should be given.

Page 33, line 914. The amount of training provided according to level of radiation employed in the work should be avoided. This is because the nature and level of radiation work can change fairly quickly for any medical professionals (e.g. staff movement) and in any medical institutions (e.g. introduction of new services).

Page 33, lines 915-917. The example given "For example radiotherapy employs delivery of several gray of radiation per patient and a few tens of gray each day to groups of patients." is on radiotherapy. This document does not deal with RP in radiotherapy, so this example is not appropriate. Furthermore the end of the sentence is not clear (groups of patients??).

Page 34, line 962. The term “authorised body?should be defined.

Pages 35 & 42, Lines 988, 1203. Lecturers should be competent in RP which is best demonstrated by professional certification, state registration or an equivalent professional recognition system.

Page 36, line 1008, Section 5.3 Assessment. Only assessment of knowledge acquired is mentioned in this section. Assessment of competency and practical skills is also required at least for some categories of the medical professionals.

Page 37, line 1037. Add: Namely within Continuous Professional Development (CPD) programs.

Pafes 39 & 40, lines 1125-1126. "...more imaging tests being requested when other non-radiation tests could be performed...". Imaging tests cannot be opposed to non-radiation tests. Both radiation and non-radiation exams can be imaging tests.

Page 41, line1164, Recommendation 17: Add "For the stated reason, Medical Physicists should have proven knowledge and professional competency by way of professional certification or state registration before they are allowed to practice independently and to teach other medical professionals. They should also enter into a continual professional development scheme."

Page 41, line 1175. "enforcing" should be "regulatory"

Page 47, line 1328. Additional RP aspects for Therapeutic Nuclear Medicine procedure. Add "Safety measures in management of inpatients administered with therapeutic dose of radiopharmaceuticals".