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ICRP: Free the Annals!

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Submitted by Paul Marks, ARPANSA
   Commenting on behalf of the organisation
Document Diagnostic Reference Levels in Medical Imaging
 

Topic

Section

Page No.

Paragraph

Line number

Comment

Executive Summary

1.Introduction

9

a

6

ICRP (2001) -> ICRP Supporting Guidance 2 (2001)

 

 

9

b

11

Should DRLs apply to imaging that takes places during radiotherapy procedures?

 

2.DRLs

10

g

3

‘Standard sized patient’ needs to be defined in the Glossary

 

2.DRLs

10

h

16

What does image quality evaluation mean?

 

2.DRLs

10

i

20-24

Is the median value the one to use?

 

3 DRL quantities

11

m

1-3

What does this statement mean?

Glossary

 

 

 

 

Should be expanded to cover topics such as image quality, patient size

 

 

 

 

 

All acronyms used in the document need to be defined somewhere.

 

DRL quantity

14

 

19-28

No mention of administered activity as a DRL quantity

Introduction

 

19

 

31

“of” missing after word Values

 

 

24

22-24

 

Stratification of exams types is complicated by lack of common protocol naming convention masking it difficult to compare protocols

 

Image quality must not be neglected

24

26

 

Image quality need to be defined

 

 

25

27

 

This implies appropriate diagnostic information from insufficient image quality.

 

Rationale for this report

26

35

 

Assumption is DRL survey has produced diagnostic quality image

 

 

27

 

 

see stratification comment

Considerations in conducting surveys to establish DRLs

Introduction

32

 

8

Need for a set of common procedures internationally

 

 

33

43

28

supplements to a professional judgement -> supplements to professional judgement

 

 

33

44

31

Ka,e/Ka,i/Ka,r no subscript throughout?

 

 

34

46

 

Do national DRLs have precedents over ones establish in States?

 

 

34

48

 

Need a clear definition for DRLs in nuc med. 75% or 50%

 

 

36

Table 2.1

 

Nuclear Medicine surveys?

Survey Considerations

Responsibility for conducting surveys and establishing DRLs

37

66

 

Titles should comply with those in GSR-3

 

Patients

41

88

12

At least 20 patients contradicts page 121 para 33 line 5

 

 

41

88

19

Breast size throughout doc compared with compressed breast thickness. ??

 

Examinations & DRL quantities

41

89

 

What do all groups of operators mean?

Determining DRL values

Distribution of DRL quantities

45

102

21

Minimal effect or none?

 

 

46

102

2-4

Definition of outliers?

 

Image Quality

51

19

14

radiologists agree with to produce -> radiologists agree produce

 

 

51

122

 

needs to be expanded and further addressed

Radiography & Diagnostic Fluoroscopy

Mammography

 

 

 

Whole section lacks depths and no guidance on what should be measured. Stratification of metrics?

 

 

61

149

36

Minimal  compressed breast thickness should be used

 

 

 

 

 

 

Interventional Procedures

Introduction

67

165

17-18

there is a variation in dose with angulation that must be taken into account

 

Complexity analyses

67

167

32

Typo “patients”

Digital Radiography, CT, Nuclear Medicine & Multimodality Procedures

 

78

185

40

Delete comma after “Bedside”

 

Considerations for DRL surveys in CT

83

211

 

Inconsistent numbers in CT DRL surveys

 

DRLs in planar and SPECT NM imaging

85

221

 

Is ICRP indorsing this approach? Rec max act a DRL?

 

Considerations for DRL surveys for NM

86

226

 

Is this developing DRLs or applying DRLs?

Paediatrics

Paediatric DRLs for radiography, NM and interventional procedures

98

266

 

Is it  suggested to use EANM or USA information as a start for local DRLs in nuc med

Application of DRLs in Clinical Practice

 

101

 

5

Definition of clinical audits

 

 

102

 

3

Where is the evidence?

 

Setting up an audit program in healthcare facility

104

271

21

What does necessary mean in this case

 

 

105

275

 

Should be Fig 7.1

 

Factors to consider if a DRL value is exceeded

107

287

10

should be investigated

 

7.5.2 CT protocols

113

318

8

into account how the interaction -> into account the interaction

 

7.8 Outcome of the investigation

115

331

33

a risk -> a significant risk (??)

Summary of the Commission’s Recommendations

DRL quantities

119

16

18

New metric (5cm) not reference anywhere else in document

 

DRL surveys

121

33

4

Issues associated patient numbers

 

Setting DRL values

122

44

1

Does this apply to nuclear medicine?