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Submitted by Graciano Paulo / Vice President - EFRS, European Federation of Radiographer Societies
   Commenting on behalf of the organisation
Document Education and Training
 
EFRS COMMENTS
Draft Report for Consultation: Radiological Protection Education and Training for Healthcare Staff and Students

General comment:
• RP education and training received by radiographers at undergraduate level in several EU countries is appropriate and consistent. However, an argument could be made for periodic refresher training to be a mandatory part of continuing professional development (CPD) particularly when considering the pivotal role radiographers have in justification and dose optimisation.
• We recognise that other professions do not receive the same depth of RP training as radiographers and believe there is scope for improvement (other health professionals working in controlled area).
• Previously, the role of medical examination requesting has been the preserve of the medical profession. Some countries are changing this paradigm, with referrals received from regulated non-medical healthcare professionals as well as medical professionals. This has resulted in considerable benefits to patients and services with no adverse dose consequences. RP trainers in healthcare organisations, who are very often radiographers, should oversee the RP education and training of new referrers at induction.
• It should be specified that only properly trained and qualified professionals can use the radiological equipment.
• In general, those staff members are the radiographers (although there are remarkable differences in educational programs and in denominations at the international level).
• Spelling of ionizing varies throughout. American spelling ‘ionizing’ should be replaced by ‘ionising’ throughout document
• Other words vary similarly throughout document e.g. ‘utilize’ and ‘utilise’, ‘organization’ and ‘organisation’, ‘optimization’ and ‘optimisation’, ‘cognizant’ and ‘cognisant’, ‘specialized’ and ‘specialised’, ‘localized’ and ‘localised’, ‘fetus’ and ‘foetus’,
• Overall lack of consistency in relation to CT and dose implications.
• Is PET and PET/CT being grouped with nuclear medicine or diagnostic radiology?
• In terms of ‘diagnostic radiology’ CT and PET/CT as high dose examinations should be mentioned separately.
• Facilities (combined clinical / academic institutions) where small animal research is undertaken on PET/CT or SPECT systems could perhaps be considered. While ‘patient’ dose is less of an issue in these units, staff radiation protection training is equally important and many researchers will not have any background in radiological professions.
• We also feel that it is inappropriate to identify and attribute specific roles to specific named professions. These are matters best dealt with by individual countries and we strongly recommend that any such specific attributions should be removed; it is enough to refer to the need for the various roles to be carried out by statutorily regulated healthcare professionals.


Specific Comments:


104/...physicists and radiographers as part of the curriculum of undergraduate and postgraduate degrees. .../The knowledge referred in this paragraph is delivered to radiographers also in first cycle curriculum.

136/...professionals involved in use of ionising radiation for diagnostic (radiography, fluoroscopy computed tomography, nuclear medicine and PET/CT) and interventional (fluoroscopically guided) procedures./CT and PET/CT should be stated independently as high dose examinations. This is especially important in this paragraph as this defines ‘diagnostic’ procedures for the rest of this document.

160/Planned education and training programmes for the personnel involved are necessary sine qua non so as to ensure reasonable RP of patients and workers.

167/‘The present document makes recommendations on training in RP for medical practitioners, radiographers, physicists, dentists, and other health professionals who perform or provide support for diagnostic and interventional procedures utilising ionizing radiation.

184/For the medical professional in particular, it is essential that courses are perceived as relevant and necessary, and require only a limited commitment of time so that individuals can be persuaded of the advantages of attending. The use of e-learning structure would allow professionals to complete training at convenient times and to pace their learning according to their previous knowledge

193-196/A basic level of instruction should be given during medical, dental and other healthcare degree courses. Specific training in RP should be guaranteed in Radiographers education programme. More in-depth education...../At the end of their education program radiographers are entitled to perform diagnostic and therapeutic procedures, EFRS agrees that therefore they should have specific training in RP.

202/‘RP education and training for medical staff should be promoted by Regulatory and Health Authorities along with Professional Bodies.

221-224/Medical Physicists, Medical Specialists and Radiographers shall work closely in setting up and conducting effective training programmes.
/All the professionals in the radiological team should bring their specific knowledge in training programmes. Radiographers however are the end users of the equipment, responsible for the actual optimisation of the dose delivered to the patients and for all the practical aspects of the procedures.
It’s important to recognize the important role of radiographers in training and education. Universities across Europe have radiographers with PhD and master degrees, dedicated to RP teaching, and in hospitals daily practice these are the health professionals in the first line of radiation protection.

302/The radiologist and the radiographer should be aware of the possibilities …/Although there are different titles to identify the profession of Radiographer the denomination “CT scanner operator” is not one of them. CT exams should be carried out by a qualified radiographer.

306/…radiologists, cardiologists, medical physicists and radiographers understand the…/Although there are different titles identify the profession of Radiographer the denomination “CT scanner operator” is not one of them. Ct exams should be carried out by a qualified radiographer.

309/Radiographers should have an understanding of the reduction that can be …/Although there are different titles identify the profession of Radiographer the denomination “CT scanner operator” is not one of them. CT exams should be carried out by a qualified radiographer.

322/Industry should promote tools to inform radiologists, radiographers, and medical physicists about the recommended exposure parameters and the resultant patient doses associated with digital systems. Furthermore industry should cooperate closely with these three professions in order to develop procedures and protocol optimising the dose delivered to patients./There is a need of strong cooperation between the industry and the radiologists, radiographers, and medical physicists, in order to reduce the dose given to the patients.

365/The final responsibility for the radiation exposure lies with the physician, who should therefore be aware of the risks and benefits of the procedures involved.’/it also lies with the person exposing the patient to ionising radiation / performing the examination (most often somebody in the RDNM category or Radiologist) so this is a little misleading as currently worded.

468/Nuclear Medicine Specialists (NM): Physicians who are going to take up a career in which the major component involves the use of radiopharmaceuticals in nuclear medicine for diagnosis and treatment/is PET and PET/CT included in this category?


487/Radiographers, Nuclear Medicine Physicists and Medical Physics Technologists
/For EFRS the term “Radiographer” refers to a health professional that covers all fields (diagnostic radiology, radiation therapy and nuclear medicine)

494/Other Healthcare Professionals (HCP): Other professionals such as Podiatrists, Physiotherapists, Speech Therapists, and Chiropractors who may be involved in the use of radiology techniques to assess patients.

506/as stated in general comments, another category ‘researchers’ e.g. clinical research units could be added.

528/Training in RP given to interventional cardiologists in most countries is limited. The Commission considers that provision of more RP training for this group should be a priority/in this section and the paragraphs above cardiac CT should be mentioned as it can again be very high dose and may be performed under the direction of radiologists or cardiologists.

541/For these personnel, a combination of seminars and practical demonstrations is likely to be the best arrangement for their RP training/only specifying seminars and practicals is somewhat limiting. Multi-media rich e-learning content including sound, videos, etc. is an extremely useful method to deliver such content to these groups of professionals who are highly unlikely to be able to commit to taking several hours out of their busy schedules

565/Education in RP for future prescribers should be included in a dedicated short course.../The word should is stronger than could. We support that this should have a mandatory aspect

579-580/Radiographers will require a higher training in RP as this represents a core aspect of their work as well as specific knowledge in radiological techniques./Radiographers are the end users of the equipment responsible for the actual optimisation of the dose delivered to patients and all the practical aspects of the procedures, furthermore they are in the best position to reduce staff exposure.

702-704/The different groups of topics and the minimum level of training recommended for different categories of medically qualified staff and other healthcare professionals are included in Tables 1 and 2 respectively




713-714/‘The number of hours indicated in the table should be considered as an indication of the minimum amount of training.’

763-764 - table 2/…see the modify table below…/Radiographers are the end users of the equipment responsible for the actual optimisation of the dose delivered to patients and staff and also responsible for all the practical aspects of the procedures. They should have the highest level of education in some aspects of RP in order to fully understand the consequences of their professional behaviours and acts. In this there are also ethical and deontological issues.
In some countries they are responsible to carry out the QC and QA programs. The numbers of hours reflect the need of a robust education in this field.

781/practitioners will give much of the RP training, but healthcare professionals.../When describing generically the designation “healthcare professionals” should be used to avoid confusion with specific professions

791/In general the professions in categories 1 and 2 (Table 1), and 8 and 9 (Table 2) shall have formal education in RP and a formal examination system to test competency before the person is awarded a degree that entitles him/her to practice the profession/category 8 is MD and appears in table 1 rather than table 2.

793/…is awarded a degree that entitles him/her to practice the profession. Professionals in category 9 should have specific post graduated courses on RP. /Radiographers should have specific education in RP since they actually carry out the procedures and need also specific training in the use of the equipment.

866-872/The primary trainers in RP should normally be a team of professionals which knowledge encompass different aspects of RP. That means a team having knowledge about the clinical practice in the use of radiation, the nature of radiation, the way it is measured, how it interacts with the tissues, what kind of effects it can lead to, principles and philosophies of RP, and international and national guidelines./All the professionals in the radiological team should bring their specific knowledge in training.

1016-1018/A simple test of multiple-choice questions may be used to evaluate the knowledge of the attendants and score some of the key aspects to identify the possible weaknesses in the training programmes/it should be noted that while an MCQ can be used to assess knowledge it is not necessarily a good tool for assessing understanding and it is essential that radiation protection is understood by all

1046-1048/The involvement of the relevant medical, radiography, radiology, nuclear medicine and medical physics scientific societies is a key factor in attracting different clinicians to the training programmes.’/

1200/28) The primary trainers in RP should normally be a team of professionals which knowledge encompass different aspects of RP. That means a team having knowledge about the clinical practice in the use of radiation, the nature of radiation, the way it is measured, how it interacts with the tissues, what kind of effects it can lead to, principles and philosophies of RP, and international and national guidelines./All the professionals in the radiological team should bring their specific knowledge in training.


Training Area; 9 RDNM
Atomic structure, x-ray production and interaction of radiation ; M
Nuclear Structure and radioactivity ; M
Radiological quantities and units ; H
Physical characteristics of the x-ray machines; H
Fundamentals of radiation detection ; H
Fundamentals of radiobiology, biological effects of radiation ; H
Risks of cancer and hereditary disease and effective dose ; H
Risks of deterministic effects ; H
General principles of RP ; H
Operational RP ; H
Particular patient RP aspects ; H
Particular staff RP aspects ; H
Typical doses from diagnostic procedures ; H
Risks from foetal exposure ; H
Quality control and quality assurance ; H
National regulations and international standards ; H
Suggested number of training hours ; 120-150