RPA Update Meeting 2010
Elizabeth Larkin (Queen Elizabeth Hospital Birmingham)
UCL INSTITUTE OF CHILD HEALTH, LONDON, 22nd June 2010
UPDATE FROM THE ENVIRONMENT AGENCY: ENVIRONMENTAL PERMITTING REGULATIONS 2010 AND THE REVIEW OF RAS EXEMPTION ORDERS
The Environmental Permitting Regulations 2010 (EPR 2010) came into force on 6 April 2010 and have largely replaced the Radioactive Substances Act 1993 (RSA 93) in England and Wales; RSA 93 is still active in Scotland and Northern Ireland. Kate Griffith (Environment Agency) advised that RSA93 authorisations and registrations automatically became ''environmental permits'' and that there were no major changes in the scope or nature of the radioactive substances legislation. Whilst there are no regulator changes, changes in the scope of regulation or standards for environmental protection, the following changes will occur: full or partial transfer of an environmental permit is now allowed, the process for new applications is subject to public consultation, a site plan is required for applications and the requirement to display sealed source certificates is no longer required. The key benefits include consistent regulatory approach across environmental regulation, improved procedural arrangements, e.g. inter-site transfers, and staged regulation for repositories. The principal aims of RSA 93 Exemption Order review are to rationalise and standardise, to reduce burden on users and regulators, to achieve a risk informed basis for exemption, to align with the BSS Directive and EC guidance, and to be flexible enough to deal with change.
Further information is available at:
SURVEYING DOSE LEVELS FOR COMPUTED RADIOGRPHY IN THE UK
There remains a general feeling that while set-up, technique and doses in Computed Radiography (CR) may vary, there is limited published evidence. Jonathan Cole (King's College Hospital) presented the results of a project initiated by the Department of Health. Data collected for PA Chest and AP Abdomen examinations from participating departments included local standard operating protocols (SOPs), entrance surface air kerma (ESAK) measured ''free in air'' with an ionisation chamber and detector dose measured using an Unfors Mult-o-meter in a modified cassette and corrected for ratio of ESAKs; distances, half value layers, kVp and measured data were used to calculate effective dose (E) using the Monte Carlo programme PCXMX. Results: The wide range of SOPs, detector air kerma (DAK) and E obtained suggested substantially different optimisation methods; DAK varied from 2.4 to 7.8μGy and from 4.6 to 19μGy for AP Abdomen and PA Chest examinations respectively. No evidence has been found for differences between CR supplier or technique.
Further information can be found at: http://www.kcare.co.uk.
Steve Evans (Northampton General Hospital) described e-IRMER as a joint project between the Institute of Physics and Engineering in Medicine (IPEM) and e-Learning for Healthcare (Department of Health). It uses an e-learning approach to satisfy the core training required under the Ionising Radiation (Medical Exposure) Regulations 2000 (amended 2006) (IR(ME)R). The principal groups requiring this training are referrers, practitioner and operators who are involved in the use of ionising radiation for the diagnosis and treatment of patients. Each module contains a number of e-learning training sessions that are designed to be engaging, validate prior knowledge and deliver relevant content that the learner is expected to remember; each session contains interactive content that will deliver the educational objectives using a variety of techniques such as animation and video. Further information can be found at http://www.e-IRMER.org.uk.
And Finally ...
IS THE INSTANTANEOUS DOSE RATE RELEVANT AS A DETERMINANT OF SHIELDING THICKNESS IN RADIOTHERAPY?
Philip Mayles indicated that dose rates from modern linear accelerators can be as high as 30Gy/min. This makes primary barriers, designed to instantaneous dose rates (IDR) of 7.5μSv/h, un-necessarily large. A realistic assessment of the TADR2000 could be around 0.1mSv even with an IDR of 20μSv/h because the total dose to the isocentre may not be affected by the peak dose rate. The ACOP suggests that if the IDR exceeds 7.5μSv/h in an area accessible to workers, the area should be controlled, whereas the Medical and Dental Guidance Notes suggest that TADR2000 is more important. NB. IRR Regulations 8 and 16 - nothing in the regulations regarding IDR.
ISSUES REGARDING THE DE-REGULATION OF SOME COSMETIC LASER USERS
On 1 October 2010 the Health and Social Care Act 2008 (Regulated Activities) Regulations 2010 come into force. Stan Batchelor reported that many cosmetic laser users will no longer come under the regulation enforced by the Care Quality Commission (CQC), i.e. they will no longer have to be registered with them. Users may choose not to employ the services of a certificated Laser Protection Adviser (LPA) and may well cut out the LPA service altogether. Whilst users still need to comply with the Health and Safety at Work Act, there will not be the same degree of monitoring/inspection process which would help maintain standards and assure public safety. A group has met with the Department of Health in an endeavour to remediate this potentially disastrous situation. The group hopes to put regulation back in the hands of local authorities who will licence premises as some used to prior to NCSC/HC/CQC days. Councils without these existing statutes will not be in a position to do this by 1 October.
AN UPDATE ON THE GUIDANCE DOCUMENT FOR THE NHS ON RADIATION EMERGENCY PREPAREDNESS
Ian Chell reported that the latest version of the radiation guidance for the NHS should be published this summer, once the new Minister has agreed publication. The ambulance guidance was published earlier in the year and rolled out to Ambulance Trusts; the Health Protection Agency (HPA) are now providing a 24/7 radiation protection advisory service for on-duty Trust supervisors and a comprehensive training programme.
PRIVATE FINANCE INITIATIVE CONTRACTS AND THE HOSPITAL RADIATION PROTECTION ADVISER
For a traditional hospital build, the appointed Radiation Protection Adviser (RPA) takes full responsibility for specification of radiation protection and critical examination of the finished facility. In a Private Finance Initiative (PFI) contract, there may be other parties involved. For example, the PFI contractor may appoint a RPA to specify radiation protection requirements. Ultimately, the hospital RPA assures statutory compliance and takes responsibility for the design. It is possible that the two RPAs disagree on the specification. There may be a question over who is legally responsible if there is a problem with the protection. Mark Knight advised RPAs to check their contractual obligations prior to signing any contract.
The meeting was sponsored by e-Learning for Healthcare, Imaging Equipment, MediScientific, Mirion Technologies, Panasonic Industrial Europe, PTW-UK Ltd, Qados and Wardray Premise Ltd.
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