ICRP Draft Report on ‘Radiological protection education and training for healthcare staff and students’ Comments from the British Institute of Radiology The comments below represent the collective response of the Radiation Protection Committee of the British Institute of Radiology. In case of query or follow-up information, please contact the Committee Secretary on rpc@bir.org.uk . General Issues Implementation The presentation of approximate hours for training of different staff categories will aid course developers. However, there is a continual drive towards shorter training courses in the name of both relevance and efficiency. In the UK this is an especially strong force. Therefore, evaluation becomes all the more important as the harmoniser and guarantor of standards – it is essential therefore those national authorities create a framework in which this can be delivered. It is also important to stress the role practical, supervised training plays in embedding sound rp practice by healthcare individuals, especially in dose reduction techniques for doctors performing fluoroscopy. Clarification As specifically mentioned below, the use of terms ‘prescriber’ and ‘requester’ requires consistent use throughout this document. In the UK the role of the requester is subservient to the clinical justifier and so this document may cause confusion. Continuing Education & Training This is a very important aspect of maintenance of standards and should receive a more thorough discussion within your report. Following addition of such a discussion, a summary of such requirements may be added to tables 1&2. Radiation Treatments The inclusion of nuclear medicine therapy whist excluding brachytherapy and external beam therapy seems arbitrary. Specific Points Lines 162 – 166: It would be helpful for the assertions in this paragraph to be referenced with peer-reviewed evidence. In the UK, the role of requesting physicians is somewhat restricted and so training requirements consequently lessened. If the training requirements changed without a change to the role, it would be difficult to justify. Line 175 [& elsewhere]: The role of the prescriber in the UK it not well defined. In the lines mentioned above, those who ‘request’ or ‘perform’ are mentioned. Clarity is required between the use of these terms. Section 1.3.2: This seems like a long list to give as examples – maybe this section could be more concise? Lines 401 – 410: We welcome the inclusion of image interpretation as an area requiring training. However, the statement in lines 407 – 410 requires clarification – it is surely the knowledge regarding the potential information from an image that informs justification, rather than the actual information that is interpreted from an image. Section 2.2: Why exclude the rp medical physicist and MPE from the list? Lines 528 – 529: The Institute strongly supports the flagging of the importance of rp training for cardiologists. Section 2.3.3: As well as maintenance engineers, clinical applications specialists have a crucial role in rp when they train the users. Can this group be added? Lines 605 – 608: The recognition of the importance of the relevance of training to clinicians is extremely important if the training is to be seen as an integral part of their overall training, and thus important. We support the inclusion of this statement. Tables 1&2: Not sure why maintenance engineers require 3x the amount of rp training than someone associated with procedures leading to an exposure of a patient? There was also a feeling amongst some on our committee that the number of hours for a few other categories seemed excessive and certainly more than currently delivered. Is there evidence of the need for such levels? Alternative suggestions are MDA 2-5 hours; HCP 5-10 hours; NU 2-5 hours; DN 5-10 hours. Add ‘Clinical Applications Specialists’. Lines 828 – 832: The use of other learning methods is to be supported. Maybe there is a role for centrally commissioned material at a regional or national level, as quality is vitally important in this area? Lines 833 – 835: The need to train maintenance engineers in the implications for patient safety is to be applauded but the implementation will probably require, at the minimum, national coordination and authority. Lines 873 – 891: Whilst the aspirations contained in this section are very important, is it essential to realise the importance of ensuring the opportunity for rp trainers to keep up-to-date in emerging clinical techniques/new technologies. Often clinical applications training is limited and rp trainers may find themselves at the back of the ‘training queue’. It may be useful to point out the need for rp trainers to be continually trained themselves? Lines 900 – 913: The Institute supports the Commission viewpoint on the importance of evaluation. However, we feel that evaluation should have a national element to ensure consistency of standards. Can this be added? Lines 924 – 928: We agree that interventional cardiology deserves the same degree of rp training as interventional radiology. However, it should be made clear that this relates only to the interventional element of radiology training – an interventional cardiologist would not necessarily require [although it may be useful] the entire radiation training of a radiologist. Line 1235: The Institute especially supports recommendation 36 as key in maintaining standards as new technologies are introduced. Line 1472: What does this statement mean? Should it read ‘To note the importance of periodic dose assessment’? Line 1531: Would the word ‘checking’ be better than ‘control’? Line 1537: Remove the word ‘different’. It is unlikely that training in one country would deliver the rp national requirements in a variety of other countries.