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Submitted by Chris Wood, Institute of Physics and Engineering in Medicine
   Commenting on behalf of the organisation
Document Radiological Protection in Fluoroscopically Guided Procedures Performed outside the Imaging Department

The Institute of Physics and Engineering in Medicine (IPEM) welcomes this document and is grateful for the opportunity to comment on the draft.


General comments

In general, IPEM would like to see emphasis on the involvement of the Radiation Protection Adviser in staff dose issues, particularly on which staff need to undertake dose monitoring and what the most appropriate method to use.


There is also the need to mention the involvement of the Medical Physics Expert in patient dose optimization and audit, particularly for higher dose procedures.


IPEM hopes that the inclusion of the RPA and MPE in this report would help to raise the awareness of medical physics support to clinical staff outside the radiology department.


The document appears to use the terms ‘deterministic effects’ and ‘tissue reactions’ interchangeably where just one should be used.


Specific comments

Paragraph 31 - Registration of individual x-ray machines is not currently required under UK legislation.


Paragraph 37, lines 799-800 – Reducing SID does not reduce imaging time.


Paragraph 57 – recommend that the advice of a Radiation Protection Adviser is sought with regard to who should undertake individual monitoring.


Paragraph 58 - should state that fingers should not be placed in the primary beam and that finger dose should be monitored for staff groups based on the advice of an RPA.


Paragraph 59 – staff dose monitoring in the UK tends to be based on risk assessment and as such not all staff working in the fluoroscopy room are monitored 100% of the time.