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Welcome to the IRS Newsletter for December 2011. As the festive period draws ever closer IRS would like to extend our warmest season's greetings to all of our customers and wish you all the best for 2012.

IRS will be closing at 3pm on Friday 23rd December for Christmas and will reopen on Wednesday 28th. We will then close for New Year at 3pm on Friday 30th December before reopening on Tuesday 3rd January 2012. During this time emergency calls will be redirected to one of our RPAs.

In the meantime, if you have any comments on our newsletter forward them to admin@irs-limited.com

See you in the New Year,

The IRS Team

Contents

IRR99 & IR(ME)R 2000 Issues

Young Persons Working with Ionising Radiation

The following guidance in respect of allowing young persons under the age of 16 to undertake any form of work placement/work experience has been provided by the HSE contained in a letter responding to a query from Dr Alexandra Mackie:

Following your query regarding whether there is an age below which it would be illegal to permit work experience in areas involving exposure to ionising radiation irrespective of the assessed risk, I have consulted my colleagues in both FOD Radiation Team and Policy Division. 

The legislation relevant to under 16s is:

  • IRR99 Regulation 11(1) and thus Schedule 4, Part I:  “..the limit on effective dose for any person other than an employee or trainee, including any person below the age of 16, shall be 1mSv in any calendar year.”
  • Management of Health and Safety at Work Regulations 1999, Regulation 19(2):  “..no employer shall employ a young person for work …involving harmful exposure to radiation; and in determining whether work will involve harm or risks for the purposes of this paragraph, regard shall be had to the results of the assessment.”  A ‘young person’ is persons under the age of 18, and includes those under 16.

The wording of reg 19(2) does not absolutely prohibit under 16s from working with ionising radiation, so long as the employer can prove that they have carried out a suitable and sufficient risk assessment showing that the work would not “involve harm”. 

A future development that you should also be made aware of is that HSE intend to implement Article 7.2 of the International Labour Office Convention 1960 (No. 115) that prohibits any under 16 year-old working with ionising radiation via the IRR99 Amendment Regulations.

The link to ILO C115 is http://www.itcilo.it/actrav/actrav-english/telearn/osh/legis/c115.htm

The link to the items to be included in the IRR99 revision is http://www.hse.gov.uk/radiation/ionising/rpa/rpa24.htm#irr99

My understanding of the ILO Conventions is that they are produced by the International Labour Office and have no standing in individual countries unless and until those countries choose to implement them within national legislation.  Therefore, the mechanism for implementation of ILO C115 within the UK would be via HSE-enforced radiation protection legislation.  HSE Policy Division remain unable to provide a definitive date when the IRR99 amendments will be implemented, therefore at the moment the only legal requirements specifically relating to under 16s are those of IRR99 Reg 11(1), Schedule 4, Part I and MHSWR99 Reg 19(2). 

So in answer to your question, until such times as the amendment regulations or ILO Convention 115 are implemented, if it is considered necessary for under 16s to be engaged in work experience with ionising radiations, their employer should ensure that radiation exposures of those persons are restricted so far as reasonably practicable in accordance with IRR99 Regulation 8 and should definitely not exceed the “other persons” dose limit of 1mSv per calendar year.  A suitable and sufficient risk assessment must also be carried out in accordance with MHSWR99 Reg 3 and 19(2) and IRR99 Reg 7. 

As you rightly advised, INDG364 is misleading as it does state that children below the MSLA must never do work involving ionising radiation.  HSE will therefore consider whether it should be revised.

I hope this answers your query, however if you do have any other questions or wish to discuss it in any more detail please give me a call.

Yours Sincerely
Alexandra Elizabeth Mackie
HM Inspector of Health and Safety (Radiation)

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Handover of X-ray Equipment and Controlled Areas

Following recent radiation protection audits undertaken by IRS RPAs we have become aware that some departments are not formally handing over the equipment and the associated controlled area to the service and maintenance company.

The HSE recommend that the host employer formally hands the equipment and controlled area over to the service and maintenance company prior to all types of work including routine maintenance visits and repairs. Formal handover procedures and documents are required to facilitate this.

If handover procedures have not yet been implemented you may wish to use a form developed by HSE and AxREM (Association of X-ray Equipment Engineers and Manufacturer’s). This form is deemed to be appropriate for all types diagnostic imaging x-ray equipment including CT.

The original AxREM form can be accessed from the link below, which also provides some background information as to why handover and handback documentation is required. 

www.axrem.org.uk/radiation_safety.html

HSE have also provided guidance on their position in Radiation Protection News. Please clink on the link below and scroll down to the article called – ‘Work on ionising radiation equipment in hospitals’

http://www.hse.gov.uk/radiation/rpnews/rpnews220908.htm

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Care Quality Commission 2010 Annual Report

The report on Regulatory activity undertaken by the Care Quality Commission during 2010 was published in April 2011. It may be downloaded from the following hyperlink

http://www.cqc.org.uk/sites/default/files/media/documents/irmer_ar_2010.pdf

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Care Quality Commission Circular

The following CQC circular was sent to NHS Chief Executives earlier this year in respect of the need to ensure that all x-ray examinations are clinically evaluated. The full letter is provided below:

Ionising Radiation (Medical Exposure) Regulations (IR(ME)R) 2000: Important information on compliance with IR(ME)R

Dear colleague,

We are writing to the chief executives of all NHS trusts in relation to their trust's compliance with IR(ME)R. We have contacted you at this time as it is important for the new intake of trainee doctors arriving in August to understand their role in relation to this issue. Last year, a radiology department in an NHS trust carried out an internal clinical audit of patients' notes, which showed that around 50% of the radiographs that were provided to referring clinicians for their interpretation had no clinical evaluation report recorded in the patients' notes.

It is a statutory requirement of IR(ME)R that all examinations involving ionising radiation are evaluated in the clinical record, either in the form of a report by a radiologist or an opinion by another clinician. This is a quality issue for the management of patients, as it ensures that all examinations are seen.

The trust has since developed a plan to improve compliance in this area by raising awareness of the requirement, training staff and carrying out a re-audit. While we applaud the trust for undertaking the audit, it has highlighted that the requirement may be difficult to implement in practice.

In relation to IR(ME)R, CQC expects you to:

  1. Know the degree of compliance with this requirement locally through a clinical audit
  2. Have agreed initiatives to improve compliance and have a timescale for implementation.

We encourage you to undertake your own audit of how well you comply with the Regulations. However, we recognise that obtaining and searching clinical notes is time-consuming and we certainly don't expect you to monitor compliance continuously.

If we inspect your trust's radiology department in our 2011 programme, it would help to assure us if you could refer to an audit of notes, indicating what percentage of exposures had been evaluated. We would also expect you to plan how to improve this percentage. You may find it useful when planning your workforce to distinguish whether examinations were reported by radiologists, radiographers or non-radiologist medical practitioners.

Please ensure that you forward this important information to the relevant team in your trust, as it is essential that they are aware of their requirements under the Regulations.

For more information please visit our website. If you have any queries, please email them directly to IRMER@cqc.org.uk and we will respond accordingly.

Yours faithfully,
Dr Nick Bishop, Senior Medical Advisor - Care Quality Commission
Cliff Double Lead IR(ME)R Inspector - Care Quality Commission

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IRMER Amendment Regulations 2011 (Reg 3)

The Ionising Radiation (Medical Exposure) (Amendment) Regulations of 2011came into force on 25th July 2011. These add at the end of regulation 3(a) the following:

“These Regulations shall apply to the following medical exposures:

(a) the exposure of patients as part of their own medical diagnosis or treatment including any exposure of an asymptomatic individual;”

The purpose of this amendment is to ensure that persons who undergo any form of screening examination including CT, are covered by the Regulations

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Radiation Protection Training

IRS held a number of successful courses during 2011 as part of its regular training programme. These were:

  • Annual Laser Protection - January 2011
  • QA in Digital Mammography - February 2011
  • RPS Course - March 2011
  • RPS Refresher - December 2011

IRS also undertook or was involved in a number of miscellaneous training activities. These were:

  • NHSBSP Regional Digital Mammography Workshop
  • Lectures given as part of the University of Liverpool new Modernising Scientific Careers training course in Medical Physics
  • Chester RPS Update
  • Macclesfield SNLB safety training
  • Liverpool Community Health Dental Radiation Protection
  • Calderdale and Huddersfield Trust IRMER Training
  • Nobles Isle of Man -Theatres
  • RLUH St Paul’s -Theatres & 9Y
  • Warrington Laser -Theatres

IRS has the following courses planned for 2012:

  • Annual Laser Protection - 16th January 2012 – Some places still available
  • RPS Course - 27th - 29thMarch 2012
  • Digital Quality Assurance & Patient Dose/DRLs TBC

For further details or to book a place on any of the courses please visit our website http://www.irs-limited.com/book-courses-online.html.  Alternatively, please contact Tracy Barlow at tracybarlow@irs-limited.com.

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Quality Control Matters

Full Field Digital Mammography

IRS continues to support our symptomatic and breast screening programmes in adapting to the QA requirements for Full Field Digital Mammography. We have rolled out spreadsheets for recording and analysing the results of digital mammography QA tests and have provided training at each of our breast screening programmes and many of our symptomatic mammography units. Further development has included the ability to export QA data to IRS at the click of a button and an on-line review and analysis facility. These new developments are currently undergoing testing and will be fully available early in 2012.

In addition, and to support the coordination of medical physics support to the North West NHS Breast Screening Programme, in conjunction with our breast screening colleagues in the Manchester half of the region we held a regional workshop on digital mammography quality assurance. This workshop was well received by all who attended and it is hoped to repeat the exercise during 2012.

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Personnel Monitoring

IRS is currently evaluating the latest dosemeter product from Mirion Technologies. The product known as Instadose (www.instadose.com) is at the very forefront of personal dosemeter technology. Currently monitoring of radiation workers in healthcare is provided with passive dosemeters such as film and TLD. A drawback of both these technologies is that they require returning to a processing facility so the dosemeters can be read and reported to the end user. Typically the dose summary reports are issued 5-6 weeks after the end of the user wear period.

Instadose allows users to have the flexibility to view their radiation dose at any time from any computer with internet access. Readings via a PC are enabled by a USB compatible detector (see image below).

When a user wishes to obtain a reading they simply log-in to their account, plug in instadose to a USB port and log in to their. The accumulated dose stored on instadose is processed through a proprietary algorithm. Once complete a graphical representation of the current dose will load on the screen. Users can also view their cumulative dose level by clicking "View Cumulative Dose”(see image below).

Instadose from Mirion

Instadose from Mirion

Currently IRS is evaluating this technology as part of a project being undertaken at the Liverpool Heart and Chest Hospital and believes this technology will revolutionise personnel monitoring in the healthcare sector. Staff groups where Instadose would provide an immediate benefit are higher risk workers such as Interventional Radiologists and Cardiologists where more frequent dose readings are easily obtainable. In addition Instadose can provide reassurance for employers and pregnant workers that fetal dose limits are not being exceeded.

For more information on Instadose, please contact Alex McCaffrey at IRS.

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Presentations Given

IRS were once again involved in a number of posters and presentations at various relevant meetings.

In January, Paul Charnock was asked to give a presentation at a national, IPEM organised Radiographer QA course.A pdf of the presentation can be viewed here

In the summer, work on audit of data through radiology information systems (RIS) performed by two short term student placements, Antonia Pike and Simon Graham, was presented as a poster at UKRC. The poster was titled “Large scale dose audits using RIS in the North West”, and can be viewed here

October saw a few meetings; as part of his regular membership of CTUG, Paul Charnock gave a presentation entitled “Noise & HU measurements during routine level B QA in CT”. This can be viewed here

October also saw the 2011 Neuroradiographers Conference with IRS involved with both a stand and a presentation on “radiation dose considerations in neuro CT” and can be viewed here 

Also in October Mike Moores and Ryan Wilde attended a meeting in Stockholm that was organised by the Nordic Association of clinical Physicists. The meeting was concerned with DICOM patient dose and quality control (QC) - data collection, processing and visualization. The meeting was attended by approximately 60 persons mainly from the Nordic countries but some from other parts of Europe.

This meeting was amongst the first specifically aimed at presenting and discussing results obtained from the use of electronic patient x-ray examination records that could be applied to the field of radiation protection and QC.

The Liverpool contingent presented results of patient dose audits that employ examination records obtained from RIS together with tube calibration data established as part of routine x-ray equipment testing. We also presented a review of the technical and IT requirements necessary for this type of approach.

The meeting was held at a college campus just outside Stockholm. This provided a very warm and friendly environment for the interesting and wide ranging discussions that resulted from the scientific presentations. It was very obvious that this will be a very fruitful and worthwhile area for future development with the potential to impact directly on radiation protection and QC support in diagnostic radiology, particularly in the area of automated processes.

Finally, also in October, most of the RPA pool all gave lectures on quality assurance for the new Liverpool University MSC course for physics trainees.

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Conference News

David Hughes, Mike Moores and Paul Connolly have all had abstracts accepted for IRPA 13, which is being held in Glasgow in May 2012.

Abstract titles are as follows:

Estimation of whole body effective dose in the cardiac catheter laboratory: An intercomparison of currently recommended monitoring strategies - David Hughes

Managing The Workload And Workflow Of A Radiation Protection Advisor In Medicine - Paul Connolly

Patient dose audits in diagnostic radiology employing electronic examination records - Mike Moores

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Company and Staff News

IRS News

  • David Hughes was promoted in July 2011 to the role of Lead Radiation Protection Adviser and now has management responsibility for service management, policy development and strategic direction in RPA.
  • IRS were awarded the Best Practice in Professional Development Award in recognition of IRSs commitment to and provision of high quality training provided to Physicists working in a small to medium enterprise (SME).  Elaine Highton and Paul Connolly were in attendance to receive the award (pictured below)
  • Paul Connolly and Paul Charnock have been awarded the status of Clinical Scientist by the HPC.

Paul and Elaine at the IOP Awards

Paul(left) and Elaine accept The Best Practice in Professional Development Award from Professor Sir Peter L. Knight

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Staff Changes

IRS have appointed 3 new full time members of staff in the last 12 months:

  • Wadah Yasean - Systems Analyst
  • Alex McCaffrey – Personnel Monitoring and Admin Officer
  • Tom Couch – Technical Officer

Congratulations to Paul Charnock on the arrival of his little boy, Daniel.

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Friends of IRS

  • Congratulations to Hilary Moore for winning the North West Radiographer of the Year award and to Mid Yorkshire Hospital for the five trainee consultant radiographers who have achieved national recognition for developing and improving clinical practice and services.
  • Pam Black, Radiology Manager at Aintree Hospitals NHS Trust is now the Vice President for the Society of Radiographers.
  • Well done to Superintendent Radiographer Ali Guest who yet again did an abseil off the Royal Liverpool University Hospital in aid of the Linda McCartney Centre.

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IRS Contact Details

RPA Enquiries/Finance - Ms Sue Hird susanhird@irs-limited.com

Survey Enquiries/Personnel Monitoring - Miss Alex McCaffrey alexmccaffrey@irs-limited.com

General Enquiries - admin@irs-limited.com

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