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Submitted by Dr Richard Smart, St George Hospital
   Commenting as an individual
Document Education and Training
Line 136 insert CT to become (radiography, fluoroscopy, CT and nuclear medicine)

Lines 150/1 change wording to “requires that awareness is raised both about the benefits and risks of such procedures among those clinicians who request the procedures.”

Lines 211/5 It is suggested that a “referrer” is not involved in the justification of the procedure. That is incorrect, in the way that referrer is usually meant. The justification step should be performed by the requesting doctor (where possible, in consultation with the radiation specialist) before the patient is referred for the procedure. The requesting doctor has full knowledge of the patient’s clinical history and is the best person to assess the benefit (or otherwise) of the radiation procedure. Lines 297-301 support the role of the referring physician in the justification process.

Line 487 Change “Nuclear Medicine Physicists” to “Nuclear Medicine Technologists” and add “Medical Physicists” as a separate category especially as (see line 576) they require “the highest level of training in RP”

Line 489 add “injecting radiopharmaceuticals”. This is commonly performed by the nuclear medicine technologist.

Line 498 suggest deleting “injecting radiopharmaceuticals” as this is not usually performed by nurses.

Table 1 The training requirements in RP should be the same for radiologists and nuclear medicine specialists. NM need to know about the characteristics of x-ray machines (eg SPECT/CT) and DR need to know about radioactivity (eg intra-arterial administration of radiopharmaceuticals for therapy via angiography).

Line 716 and Table 2
Line 716 states that “Medical physics experts should know all training areas at the highest level. However RDNM, in Table 2, supposedly includes medical physicists. Suggest changing RDNM (line 765) to be radiographers, nuclear medicine technologists, medical physics technologists, and adding a new column to Table 2, headed MP, medical physicist, with high level of knowledge.

Table 2. RDNM need the same level of RP training as nuclear medicine specialists.

Table 2. One group of health professionals not specifically addressed are the radiochemists / radiopharmacists. These are now usually referred to as Radiopharmaceutical Scientists (RPS). While their training requirements will in many ways be similar to the Radionuclide Laboratory Staff (RL), the RPS will usually be using activity levels many orders of magnitude larger than used for laboratory tests. In addition, an RPS should know the doses from diagnostic procedures, which is marked – for the RL.

Line 1164 add “nuclear medicine” to become "working in RP, nuclear medicine or radiology...,"