The Society & College of Radiographers (SCoR) welcomes the opportunity to comment on this draft report. A compelling case is made for the need to improve radiation protection (RP) education and training of medical staff and healthcare professionals and we fully support the report’s objectives.
We believe the RP education and training received by radiographers at undergraduate level in the UK is appropriate and consistent. The education and training of assistant practitioners is also satisfactory. 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.
Previously, the role of medical examination requesting has been the preserve of the medical profession. This has now changed in the UK 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.
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.
Comments on Specific Sections
We would support an audit of the medical exposure doses received by patients in different centres. We would also encourage closer scrutiny of paediatric doses.
148 - 151
There are recognised general difficulties regarding junior doctors and their perception of justification. A refusal to justify a request is often interpreted as interference in patient management. It is imperative that doctors and other healthcare professionals that request imaging examinations understand the procedure for requesting an examination, the need for justification, alternative imaging methods and dose optimisation.
155 – 156
As stated above, periodic refresher RP training should be introduced so that medical and non-medical healthcare practitioners stay alert to the hazards of radiation. Staff must be cognisant of the need for dose optimisation whilst maintaining adequate image quality for the purpose of the investigation.
182 – 184
Whilst the SCoR understands the statement (“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”) we feel that RP education and training should be mandatory and its significance should be emphasized. Medical practitioners and non-medical healthcare practitioners referring patients for medical imaging examinations must appreciate the need for justification and understand the roles played by other healthcare professionals.
194 – 196
SCoR believes that comprehensive RP education should be included in the training of radiologists, medical physicists and radiographers. This must be completed by the time they qualify in their professional speciality. Refresher education and training should also be delivered annually within the CPD programme.
201 – 207
The SCoR agrees with this section but believes that professional bodies should have a major role to play in the delivery of consistent education and training. In the UK, the relevant medical and non-medical professional bodies have, to date, provided high quality, external quality assurance of radiation protection education and training.
Whilst the SCoR agrees that RP education should be effectively delivered in medical and dental schools, there is a belief that there is insufficient time available in the medical training programme to deliver it. An alternative mechanism would be for mandatory training to be delivered before individuals are allowed to refer patients for medical imaging examinations.
216 – 220
SCoR strongly agrees that RP education and training should occur throughout an individual’s professional life.
565 - 567
The educational requirements for referrers are described. The SCoR believes that in addition to this, further mandatory training should be given by employers at induction so that local practices are understood and before they are allowed to refer patients for imaging examinations.
575 – 580
The SCoR agrees with this section but also believes that RP training should be a mandatory within the CPD programme and that radiographers could be a resource to help deliver training.
Table 1 and 2 Recommended RP Training
SCoR agrees with the detail in the tables.
819 – 823
The SCoR agrees that continuing RP education for referrers is imperative. The standard of education needs to be consistent and preferably delivered by an appropriate accredited body.
The SCoR believes professional bodies have a role to play in delivering targeted, accredited refresher training to their members and an obligation to provide access to other clinical groups if required.
989 – 990
RP training has to be given by an individual with the right skills and knowledge, and is not a role exclusively for medical physicists. In the UK, medical physicists lack the specialist knowledge of radiographic technique and image interpretation.
Summary of ICRP Recommendations
The SCoR agrees with all of the recommendations but has comments to make on the following:
3) In the UK the final responsibility for the radiation exposure may not be a physician and the wording of the recommendation should reflect this. We suggest the word ‘physician’ be replaced with ‘statutorily regulated healthcare practitioner.’
8) Whilst the SCoR understands the statement we feel that RP education and training should be mandatory and its significance should be emphasized. Those referring patients for medical imaging examinations must appreciate the need for justification and understand the roles played by other healthcare professionals.
9) There is a need to ensure consistency in the quality and delivery of RP education and training.
10) The SCoR strongly supports this recommendation.
11) The SCoR strongly supports this recommendation.
17) RP training has to be given by an individual with the right skills and knowledge, and is not a role exclusively for medical physicists.
22) The training described is part of the radiographer undergraduate and the assistant practitioner programmes in the UK.
28) As stated above, the designation of the primary trainer is unimportant. The trainer needs to be competent and possess the knowledge to deliver the training.
31) Whilst the SCoR agrees in principle, we believe a project of this magnitude would need to be targeted to specific groups and it could only be delivered if centrally driven and funded.
37) It has to be recognised that there are no significant training budgets for many clinical groups. Also, the time allocated to undertake formal training and CPD is often severely limited or nonexistent.