Frequently asked Questions about Radiation Protection
Last reviewed 28.11.2024
Yes, in some cases LDRLs may be higher than NDRLs. This can happen when equipment is reaching end of life or when exposures are not effectively optimised or staff are not adequately trained in optimisation. Local dose audits and the use of Image Optimisation Teams should seek to identify why and recommend measures to bring LDRLs closer to NDRLs. If you are undertaking novel techniques or research, your procedure and therefore your LDRL may vary from the standard procedure from which the NDRL was calculated.
The requirement in IR(ME)R schedule 2 is for the employer to have a written procedure for making enquiries of individuals of childbearing potential to establish whether the individual is or may be pregnant or breastfeeding. Where breastfeeding is relevant to the benefit and risk decision it should be discussed. This is most often applicable to examinations involving radiopharmaceuticals. It is advised to work with your MPE to develop procedures for checking breastfeeding status. It's always best to avoid asking questions if they are not relevant.
Please see the .gov website for how NDRLs are calculated and please speak to your MPE about specific LDRLs.
This is for the Employer to decide before they entitle the individual to act as an IR(ME)R operator or practitioner.
We have contacted the HCPC and can share their response:
The international route to HCPC registration assesses applicants based on their comparability to the Standards of Proficiency (SOPs). The requirement to assess comparability is set out for HCPC in Article 12 of the Health and Care Professions Order 2001.
In this context, our international registration assessors (two registrants from relevant part of the Register who work together to assess an international application for registration) are required to establish an applicant’s comparability to the SOPs based on qualifications and professional experience the applicant gained outside the UK.
As part of this process the assessors assess whether the applicant has developed knowledge, skills and experience in the country they trained and practised which is comparable to the requirements set out by the SOPs.
There will be elements of the SOPs where comparability of an applicant in effect equates to what you would expect a UK graduate to have demonstrated (even though equivalence isn't what the assessors are looking for (the assessment is one of comparability as set out in our legislation). For example, this is usually the case in relation to the core foundational knowledge required for practice in a specific profession. There will be other elements identified where comparability (as opposed to equivalence) to the SOPs has been established. In relation to the requirements of ionising radiations legislations registration must:
An individual accepted to the Register will have provided evidence through their qualifications and professional experience that they have the knowledge and ability to apply relevant legislation, as was required in the country where they trained and practised. The assessors will be satisfied on this basis that this establishes comparability to relevant SOPs. However, that individual may still need to undertake further continuing professional development (CPD) to manage their scope of practice effectively in the UK once registered with us. As with any registrant, we expect the individual to be capable of managing this as a registered professional.
For these reasons, it is important that transition, induction, and preceptorship processes are understood for internationally qualified applicants - their needs may be different to UK graduates as they are transitioning to working in a new healthcare system.
The HCPC deliver introductory sessions for all new registrants joining the HCPC via the international route which are intended in part to discuss areas of the standards and practising within a UK context. These sessions are not profession specific, so a registrant would need to consider any further continuing professional development they need as one of the learning points out of this session.
This depends on several things. A risk based approach is recommended, ensuring your highest dose and most commonly performed procedures are audited more frequently than lower dose pocedures. If equipment is changed new LDRLs should be developed, or as a minimum, doses reviewed against existing LDRLs. When techniques change, or specialist views are added, this will impact your LDRL. If trend changes are identified it is good practice to review optimisation and training alongside LDRLs. Guidance is available through IPEM report 91 which is currently being updated.
It is always best to discuss dose metrics with your MPE. The metrics we record do not represent the actual absorbed patient dose and further calculations are required if the patient wants to know the dose they received. We recommend weight based dose data collection for paediatrics, perhaps with the exception of children above a certain age where head circumference is likely to be similar to adult head size. This is a good example of a discussion to have in your image optimision teams where image quality will be a key factor.
We would encourage students to take all opportunities for learning. Working with your MPE and helping to develop LDRLs is an excellent learning expereince.
Data are collected from all makes and models of equipment across all modalities. Please see the slides for this information and go to the .gov website.
It’s easy to join. Just email [email protected] or [email protected]
For examinations of the trunk, weight is the preferred indicator of size but for the paediatric head, age may be a more accurate metric to record. Weight should be used instead of age for paediatric body exposures as size varies considerably among children of similar ages. This variation continues throughout childhood to adulthood.
Diagnostic Reference Levels (DRLs) in paediatric radiology | IAEA
To begin with NDRLs can be used as your reference but as your work increases LDRLs can be developed for the most commonly undertaken examinations. Individual doses should not be compared to the DRL as long as you understand why there might be a big difference.
An upward trend of dose should always be investigated to identify the cause. If this is related to aging/failing equipment it can be valuable evidence to support the case for replacement alongside image quality and the risk to your patient cohort.
Yes we recorded an IR(ME)R webinar in 2019 and it can be found here alongside our other radiation protection webinars. We have 8 and will be adding to them in 2024. Please be aware that IR(ME)R is currently being revised and we will be sharing the changes and implcations for practice once the new regulations are published in 2024.
NDRLs are separated in this way because they relate to specific exposure factors and therefore different dose measurements. If you combine the two and there is a shift over time, you may not be able to easily identify if the issue is with the AP exposure or the lateral exposure. If you wish to make your LDRL relevant to the whole procedure, you could collect dose data for all projections and make a LDRL for the combined test. When using complete exams, it’s important that everyone is clear what projections the DRL refers to in case there are variations. An example of this might be where oblique or flexion extension views are included.
Q: At our hospital, we have a brand new DR room and its giving way too high a dose for all HBL hips, and too high mas,on the central wall AEC chamber, so the team leader has asked people to set their own manual exposures for now, and record dose etc. on a paper sheet. What other actions should my dept be taking?
A: This would be a wonderful opportunity for an optimisation team including the MPE to get to the bottom of the issue. It is often reported that when new equpiment is installed and manufacturers preset parameters are used, doses can be high if optimisation is not undertaken. It would be valuable to use the dose data you are collecting and compare this to the NDRL as evidence for further investigation. Also consider the image quality, is it good enough, is there room for optimisation where doses can be reduced without impacting image quality?
Doses will vary across equipment and your MPE can advise if the differences are significant enough to require different LDRLs.
The most important thing is to have the DRLs in an easily accessed format where everyone can find them and know how to use them. Having LDRLs alongside associated NDRLs where they exist is very useful. You may wish to reference LDRLs for other centres using the same equipment as you for specilaist exposures such as paediatric examinations if you do them infrequently and there are no NDRLs. Any recognised benchmark is helpful as an indicator for your optimisation processes.
Please watch the follow up webinar The Art of Optimisation. The COMARE 16 report provides background and useful information about the need for Image Optimisation Teams .
Please note we weren't sure if this question relates to exposures that are out of tolerance during routine quality control checks or to significant accidental and unintended exposures, so we will answer both:
If during your routine QC checks you are recording exposures that are outside your local tolerance levels there should be a local procedure that details who to notify and what action to take. Acceptable percentages outside of tolerances should be indicated in your QC procedures and anything that is below or above this should not be ignored. It is not acceptable to simply record out of tolerance exposures and do nothing. Out of tolerance exposure levels recorded as part of your QC may indicate a fault, that something physically affecting the exposure has been changed or it may be a feature of ageing equipment. Both of these differ from DRLs. SAUEs relate to an individual exposure which DRLs do not.
Significant accidental and unintended exposures (SAUE) are those exposures that meet the threshold for notication to the IR(ME)R regulator. Unlike DRLs, these apply to individual exposures. Read more about information on threshold doses for investigation
This refers to the relationship between Kvp and mAs, we used to use the 10kvp rule. This link to Digital Radiographic Exposure: Principles & Practice chapter 16 explains both the 15% rule and the 10kVp rule of thumb with "test yourself" sections to assess understanding.
This depends on your authorisation guidelines. Consider whether they include lateral and oblique views. If not they will require additional justification. The topic is appropriate for discussion within the MDT or the IOT. There are requirements to provide lateral and oblique views but they should be done with careful forethought for the consequences to both overall dose and skin dose. As with all exposures, the practitioner must consider how benefit outweighs risk.
It's important to think about the patient as an individual and to recognise that an adult weighing 30kg is not a standard sized adult and using a standard adult protocol may not appropriate. What you do differently will depend on the body part being scanned, the clinical indications and the intended outcome, the person's muscle/body fat ratio etc. Knowing the data that was used to inform your adult and paediatric LDRLs will be helpful to understand which protocol is most appropriate. In CT, automatic exposure devices may be less effective for very thin people especially if the patient is not in the isocentre of the gantry. Consider if a lower kvP or a manual mA is appropriate.
It is not generally advisable to use adult protcols when delivering ionising radiation exposures to children. Whatever the technique or equipment you are using you need to be sure the exposure is optimised and the individual exposure is ALARP.
The National Breast Screening programme offers guidance on the mammographic aspects (both clinical and technical) of breast screening QA and the quality control of radiographic procedures. For all services the creation of an Image Optimisation Team would be beneficial, enabling radiographers, reporting radiologists and radiographers, assistant practitioners and medical physics expers to develop robust optimisation processes.
Breast screening: guidance for breast screening mammographers - GOV.UK (www.gov.uk)
Creeden A and Curtis M (2020). Optimising default radiographic exposure factors using Deviation Index. Radiography, 26(4), pp308-313.
An American study on paediatric circumference as dose reduction Reid, J., et al. (2010). Optimisation of kVp and mAs for Paediatric low-dose simulated abdominal CT: is it best to base parameter selection on object circumference? American Journal of Roentgenology, 195(4) https://doi.org/10.2214/AJR.09.3862. Another interesting study on AP Pelvis which could be construed as circumference was Alzoud, K., et al. (2019). Impact of body part thickness on AP pelvis radiographic image quality and effective dose. Radiography, 25(1) pp. e11-e17.
A. The CQC provides detailed information on when to report an IRMER incident.
On this page you will find a link to an online incident report form. Once the form is submitted, you will receive an automatically generated email acknowledgement, including an IRMER notification reference number. This number has to be used in all subsequent dialogue with the CQC. You are advised to contact the CQC if you do not receive this confirmation email.
If you have any difficulties, please contact the IRMER desk on 020 7448 9039 or via email at [email protected].
An example of the normal sequence of events when a radiation incident (IR(ME)R) notification has been made to CQC (England):
A: There is an epidemiological research article (free of charge) in the British Journal of Cancer entitled: Bunch KJ, Muirhead CR, Draper GJ, Hunter N, Kendall GM, O'Hagan JA, Phillipson MA, Vincent TJ, Zhang W. Cancer in the offspring of female radiation workers: a record linkage study. British Journal of Cancer (2009), Volume 100, Issue 1, pages 213-218. available for download here.
Although the radiation worker subjects involved in this research study are from the nuclear, research and industry sectors (who tend to be classified radiation workers) and NOT in healthcare (NOT radiographers), the conclusion that there is no evidence of an increased risk of childhood cancer associated with maternal preconception radiation work is heartening. However, there does seem to be limited evidence of a weak association between maternal radiation exposure during pregnancy and childhood cancer in offspring. A similar study that did involve radiographers found NO such evidence of excess cancer in the radiographers' offspring - see Roman E, Doyle P, Ansell P, Bull D, Beral V (1996) Health of children born to medical radiographers.
Occup Environ Med 53: 73-79 Many female radiographers have contacted the Society & College of Radiographers to express concerns regarding anxieties of occupational radiation exposure during pregnancy which has prompted information about working whilst pregnant to be posted on the SoR website. The SCoR also wishes to report that a new publication entitled "Pregnancy and work in Diagnostic Imaging" from the British Institute of Radiology" (to which SCoR had input) will be available shortly.
HSE have produced a useful publication which is available here PDF
This should be read in conjunction with the SoR Pregnant staff handbook – available under the Health and Safety section of this website.
The International Committee of Radiological Protection (ICRP) has produced a very useful (and free) PowerPoint presentation relating to information surrounding exposure to ionising radiation and pregnancy (for staff and patients).PowerPoint
As explained in the guidance your written procedure should to apply to yourlocal risk group.This is the age at which it is considered there is potential for pregnancy. For example 12-55, meaning it would not apply to a 6-year-old or an 80-year-old person.
Work with your MPE to define the exposures or the range of exposures that may result in a dose that could be harmful to a fetus. So for example, it would not apply to a finger exposure. Apply the procedure to everyone in the defined risk group. This does not mean ask everyone in the risk group if they are pregnant. It means follow a procedure that enables you to ensure all patients in the risk group have the appropriate information to enable individuals with childbearing potential to identify themselves.
People aren’t all the same and unless we ask them, we can’t be sure everyone gets the same opportunity to receive safe care. The objective of the guidance is to support services to deliver inclusive care. This means no person should be at risk of being irradiated during pregnancy.
The guidance and the IPS form serve to ensure no person who may be pregnant is excluded. You may wish to continue with an existing procedure. As recommended in the guidance, the procedure should not discriminate an individual or group of individuals with protected characterstics.
The recommendations in the guidance are to ensure the way we practice and the care we give is equal for everyone. Equity means ensuring there is opportunity for all individuals to access the same level of care. We do not believe the recommendations disadvantage any group. The pilot studies did not report that patients felt disadvantaged or offended by being asked about the possibility of pregnancy where it was appropriate to do so.
Yes. An employer can choose to use any written procedure if the procedure and the way it is appliedensures that trans or non-binary individuals can be assured of safe, effective and equitable care. Any professional can use their judgement and they must work in line with their employer’s procedures. The same procedure should be applied to everyone in the same risk group.
Yes. Trans and non-binary (TNBI) people are represented in all communities not just large cities. It may be necessary to work with local TNBI groups to understand what the needs or barriers are to healthcare in your local area. Training should be tailored to meet the local need.
Q: What else can we do?
A: Speak to your MPE and the person who has the named legally responsibility, as the Employer, for IR(ME)R compliance in your organisation. Document the areas where you feel improvement needs to be made to achieve compliance. Use the guidance to support the case for change. The IR(ME)R regulators are often happy to give advice.
It is important that healthcare professionals know what data is being shared and what the sex data field indicates in their organisation.
There is legislation and guidance around this which may inform your local discussions.
Article 6: Lawfulness of processing (gdpr.org)
Article 7: Conditions for consent (gdpr.org)
Article 9: Processing of special categories of personal data (gdpr.org)
Patient experience in adult NHS services (nice.org.uk)
Patients have a right to choose what information they disclose and this right must be respected. However, it is a requirement for employers to have written procedures to provide the individual to be exposed with adequate information relating to the benefits and risks of the exposure. If we do not provide this information, where it is practicable to do so, it may not be possible to gain valid informed consent.
Do not assume the patient knows the risks. They may not know how to ask the question or may be fearful of disclosing the information. Radiographers should be trained and competent to ensure the patient is making a fully informed decision. As long as a radiographer has followed the employer’s written procedure and this procedure meets the requirements of IR(ME)R then a patient’s decision should be respected.
If adequate information has been shared and the patient has been informed of the benefits and risks of the exposure, the exmaination may be justified even if the patient does not consent to this information being stored or shared. This is a decision for the IR(ME)R practitioner considering the patient’s wishes. Alternatively the examintion may be postponed if it is in the best interests of the patient and with their agreement.
The procedure can be followed and the outcome documented as long as no personal information is stored or shared without the consent of the patient.
Please note regulation 19 of IR(ME)R - Defence of due diligence. All reasoned decisions should be documented. All patient responses should be documented where it is appropriate to do so.
The benefit and risk conversation needs to be managed sensitively in this age group and the language chosen may differ. The number of children identifying as trans is increasing and so this is an important consideration. Children may give informed consent as long as the information is communicated appropriately. For more information, please see Obtaining consent: a clinical guideline for the diagnostic imaging and radiotherapy workforce updated_22_jan_2020_131117_002.pdf_2 (sor.org)
This will depend on your local procedure, who is trained to undertake the test and deliver the information, and how relevant the result is in the context of justifying the dose you are delivering.
The pilot studies were all undertaken in large cities. If you feel you work in an area where the demographic is likely to be very different you may wish to run a local pilot and adapt your procedure accordingly. Please be aware that you will still need to meet the legal requirements.
The requirements of IR(ME)R came into effect on 6th February 2018. Some employers will have already adopted these measures and have been compliant since this date. The guidance helps with compliance for those who are finding it challenging to meet the requirements or who have been advised that their existing procedures are not compliant.
This will vary depending on the demographic of your team. It is recommended that you assess the gaps in knowledge and the skill mix in your local workforce and address any specific learning needs. During the pilot studies, it was found that explaining the meaning of the terms used in the guidance glossary gave employees more confidence communicating with Trans, Non-Binary and Intersex (TNBI) people. Key points were around not being afraid to ask, listening and understanding the needs of the patient, not making assumptions, not asking questions that are inappropriate or not relevant to their care, and apologising and moving on if you get things wrong.
This is a good question and applies to all patients regardless of their sex or gender identity. Consent is generally considered to apply to a single episode of care and the guidance recommends applying secure measures to ensure any disclosed information about gender is not shared without the consent of the patient. In the case of multiple events on the same day you should have a local procedure for how this information is stored and shared This should be communicated to the patient in order to gain their consent. Wherever possible, avoid repeating personal questions where that information is already available and the patient has given their consent for it to be stored and shared.
Please feel free to adapt the forms to your local needs but we do ask that the SoR is acknowledged as the original source for clarity.
Unfortunately, translation into all the languages spoken in the UK is prohibitively complex and very costly for a member funded organisation. The SoR is happy for anyone to translate the documents as long as the SoR is acknowledged as the original source for clarity.
The SoR is not able to mandate practice. It serves an advisory role and supports members to meet professional standards.
As explained in the guidance, the referrer may not lawfully share information without the patient's consent.
There is a legal process in England for changing gender in medical records. Please refer to the guidance for more information. Please note that a trans male may have a male gender marker and therefore automatic gender based clinical alerts may not always be appropriate.
Q: Quite a few departments now offer text reminder services, has there been consideration to provide an electronic link to this information so that these individuals are pre informed before hospital visits that they may be more inclined to offer the information up freely?
The more opportunity patients have to read and understand the information related to their safe care the better. An electronic link to the form could be helpful if the accompanying information about why the questions are being asked is available. You must also consider how you record the response and who has access to it. It is important to maintain confidentiality and to remember the patient may only be consenting to this information being shared for a single episode of care.
The IPS form has been designed to be used as part of a written procedure that safeguards every patient within your identified local risk group. Please see the guidance for more information. Please note that if you amend the form, for example by removing the option for the patient to share their sex assigned/registered at birth, it may no longer be appropriate to give the form to all patients.
We considered writing example employers’ procedures but after wide consultation it was acknowledged that services vary and what might be appropriate for one would not suit another. Instead, the guidance includes important considerations to include in your local written procedures (appendix 1 and 2).
The guidance is aimed at everyone in the radiographic workforce, and we would hope that educators and radiographers work together with students to ensure inclusivity becomes part of our everyday practice and behaviour. It is important to open a conversation if you feel this is not happening.
All registered healthcare professionals must meet the standards set by their regulator. This is the Health and Care Professions Council for radiographers and other allied health professions. It is your responsbility to raise your concerns in line with your employer's procedure. If you do not feel safe to do so please speak to your local SoR accredited representative, SoR Equalise LGBTQI+ group or contact [email protected].
Please note the standards of conduct, performance and ethics are changing. From 1 September 2024, every professional on the HCPC Register will need to meet the revised standards.
Yes. It is recognised that many religions and cultures are represented in our healthcare staff and patient populations. We believe radiographers are trained to communicate in a way that is appropriate and relevant to the individual in their care. This applies to all aspects of radiography and radiotherapy and is not unique to making pregnancy enquiries.
Radiographers are reminded of their duty to take action to ensure that your personal values, biases and beliefs do not lead you to discriminate against service users, carers or colleagues. Your personal values, biases and beliefs must not detrimentally impact the care, treatment or other services that you provide HCPC standards of conduct performance and ethics.
This seems like a straightforward question and in most cases individuals will understand the reason why they are being asked and will be able to answer confidently either yes or no. However, please consider those groups of patients for whom a more sensitive approach is required. These include, but are not limited to children, transgendered males, people with variations of sex charactestics, people who have experienced trauma due to abuse, medical conditions or treatment affecting their fertility or child loss. It is important to provide appropriate information leading up to enquiries about pregnancy to minimise the impact on the individual and to assist them to provide only information that is relevant to their care. Don't assume all individuals understand the risk of ionising radiation exposures in pregnancy or that everyon'e attitude to risk is the same. Some people may have previousy been given poor advice about the posibility of becoming pregnant. The burden of understanding the impact of answering yes or no should not lie soley with the patient.
The age range is part of your local risk group definition and will be agreed in collaboration with your Medical Physics Expert (MPE). Your local risk group defines the examinations and population demographics to which your local procedures should be applied. It is important to know what these are in your own organisation.
At the request of a member, SoR produced an alternative IPS questionnaire for use in radiotherapy using an age range of 10-55.
To support you to deliver inclusive care, our recorded Inclusive Practice Training Webinars will help you feel confident in your interactions with trans people. They’re delivered by a topic expert and have been designed in consultation with professionals working in clinical practice, ensuring the content reflects the duties and responsibilities of the radiographic workforce and the specific challenges around working with ionising radiation and making clinical evaluations. Watch them here.
You can also download the Q&A from the series.
A: There is a very useful power-point presentation about avoiding radiation injuries in interventional radiology. Available at: www.icrp.org
A:Yes. This is detailed in the publication L121 "Work with ionising radiation. Ionising Radiations Regulations 2017. Approved Code of Practice and guidance"
Essential content: Local rules must contain the following information:
A: Again, this is available in the same publication.
Optional content: Local rules may also contain a brief summary of the general arrangements of the following information:
A: Radiation employers (ie, employers who in the course of a trade, business or other undertaking carry out work with ionising radiation) are required, under IRR17, to designate as classified persons those employees who are aged 18 years or over and are likely to receive an effective dose in excess of 6mSv per year or an equivalent dose in excess of 15mSv per year for the lens of the eye or geater than 150 mSv per year for the skin or the extremities. (IRR regulation 21)
Where this is the case, employees will be informed that they have been classified and must be certified by a relevant doctor as fit for the work they are undertaking with ionising radiation
They must have their doses appropriately assessed and recorded. (IRR regulation 22).
A:For the protection of patients, the Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R) requires any IR(ME)R 'Operator' to undergo 'adequate education and training' to fulfil their (medical exposure) role – this would also apply to the ODP that is mentioned.
To undertake education and training to act as an 'Operator' would be to have demonstrable recorded evidence which would satisfy Schedule 3 of the IR(ME)R. It is theoretically correct that any individual can be given education and training (that includes both theory and practical training) to be able to be 'entitled' by an IRMER Employer as an 'Operator' (this is still necessary for even doing the fluoroscopic tasks in theatre). Radiographers, by virtue of their undergraduate training, already have this demonstrable evidence of training.
The other issue is, before each fluoroscopy procedure (exposure) is undertaken, it must first be 'justified' by the IRMER Practitioner – therefore in the theatre, it must be clear who would be providing this justification. Justification is the responsibility of the IRMER 'Practitioner' and the training for this may be greater. Again, Radiographers (usually more senior), have this demonstrable evidence of training. If the 'Practitioner' is to be the Surgeon, then the IR(ME)R Employer must ensure that the surgeon has also received the education and training necessary (to also satisfy Schedule 3 of IRMER) and will hold a record of those entitled to act as “Practitioner”.'
The ODP could act as an 'Operator', alongside the 'Practitioner', but they must take legal responsibility for monitoring and minimising radiation dose to the patient (ie, keeping within DAP “best practice' levels etc). Both the ODP and the surgeon must be made aware that these are legal roles – on the statute books under the Health and Safety at Work Act – and, as such, must take responsibility for the exposure to the patient. An important point to consider is that the surgeon is normally 'busy' dealing with the clinical requirements of the patient in theatre and does not always have the time to think about the technical and dosimetric elements of the radiation exposure procedure and, as such, would perhaps not be fulfilling the legal requirements of the IR(ME)R Practitioner role – something to think about with this proposal.
Additionally, the other Regulations that also come into force in this theatre scenario are the Ionising Radiations Regulations (IRR) 2017, in terms of protecting the radiation exposure to the staff involved in the theatre session; the QA of the equipment being used and also in taking responsibility for the controlled and supervised areas – there is a need to have the adequate training to fulfil these Regulations too. Again, a Radiographer does by virtue of their undergraduate training and education.
Q: This HEI is reviewing the radiography degree educational programme and one of the questions that had come up, from an admissions point of view, is if students still have to be 18 years old to go out on clinical placement.
Do you know of any reasons why radiography students cannot start at 17 years?
A: SCoR are not aware of any age restrictions for entry into radiography education programmes, there used to be with the old DCR but SCoR have not imposed any now.
Radiography students and radiographers are not being 'classified' as radiation workers under IRR 2017, but there may be some differences within different clinical departments from their Local Rules point of view, please check with each clinical placement site that they agree with you about sending under 18 year olds on clinical placement — the RPS/RPA for each department will be able to help.
IR(ME)R is only about patients and does not affect potential doses to students/staff.
A: Radiation protection RPS (for IRR 2017) courses are available at:
A: SCoR do know of other (registered) staff groups being trained to use image intensifiers, although in cardiac work they are static units. Mobile units potentially present a greater radiation hazard. We cannot prevent this, however, we do remind people that the person must be adequately trained as an 'Operator' under IR(ME)R.
There is an issue around who is the 'Practitioner' under IR(ME)R, ie, who provides the justification for the exposure. A radiographer by virtue of their qualifications and HCPC registration can do this. Many medics will claim that they are the IR(ME)R Practitioner, likewise they must be trained in this role. We make the observation that it is difficult to be operating on someone and monitor the radiation dose to the patient and all staff at the same time.
SCoR advises that the theatre staff should work with the radiography department to ensure that there is adequate back-up and advice available.
There are programmes that are looking at 'generic' working in cardiac catheter labs, but the system of supervision and availability of expert advice is fundamental to these developments. Also, the nurses or electro physiologists involved generally only take on the role of Operator as the cardiologist is the Practitioner.
A: This is an important point that relates to the concept of asymptomatic screening or Individual Health Assessment.
The Department of Health has published a working party report entitled ‘Justification of Computed Tomography (CT) for Individual Health Assessment’. https://www.gov.uk/government/publications/use-of-ct-scanning-to-carry-out-individual-health-assessments
The report recommends circumstances when it may be justified to use CT scanning on individuals with no symptoms and outside of national screening programmes.
The working party that produced the report was recruited by the Royal College of Radiologists and the Royal College of Physicians.
SCoR Director of Professional Policy Charlotte Beardmore welcomed the report.
She said: “The SCoR has been concerned about self-referral and life-style screening for some time. We welcome these recommendations which discourage scans on people who are unlikely to benefit and encourage clear care pathways.
"However, we believe that self-referral for diagnostic imaging outside a nationally regulated health screening programme is inappropriate and unnecessary.”
We would not expect newly qualified radiographers to be entitled to act as IR(ME)R Practitioners so you would be an IR(ME)R Operator, authorising exposures using guidelines issued by the IR(ME)R Practitioner who may be a radiologist or a more experienced trained and entitled radiographer. This is because schedule 3 of IR(ME)R requires that practitioners and operators must have successfully completed training, including theoretical knowledge and practical experience. A newly qualified radiographer will not have the knowledge base or practical experience to make those decisions required to justify an exposure. Please see our guidance The Diagnostic Radiographer as the entitled IR(ME)R Practitioner for more information. It can be found in the https://www.sor.org/learning-advice/professional-body-guidance-and-publications/documents-and-publications/policy-guidance-document-library
We would not expect newly qualified radiographers to be entitled to act as IR(ME)R Practitioners so you would be an IR(ME)R Operator, authorising exposures using guidelines issued by the IR(ME)R Practitioner who may be a radiologist or a more experienced trained and entitled radiographer. This is because schedule 3 of IR(ME)R requires that practitioners and operators must have successfully completed training, including theoretical knowledge and practical experience. A newly qualified radiographer will not have the knowledge base or practical experience to make those decisions required to justify an exposure. Please see our guidance The Diagnostic Radiographer as the entitled IR(ME)R Practitioner for more information. It can be found in our document library.
We would not expect newly qualified radiographers to be entitled to act as IR(ME)R Practitioners so you would be an IR(ME)R Operator, authorising exposures using guidelines issued by the IR(ME)R Practitioner who may be a radiologist or a more experienced trained and entitled radiographer. This is because schedule 3 of IR(ME)R requires that practitioners and operators must have successfully completed training, including theoretical knowledge and practical experience.
A newly qualified radiographer will not have the knowledge base or practical experience to make those decisions required to justify an exposure. Please see our guidance The Diagnostic Radiographer as the entitled IR(ME)R Practitioner for more information.
If a radiographer is trained and entitled to act as an IR(ME)R Practitioner then they may justify and protocol the examination. The protocol is part of the justification process as it determines the appropriate exposure.
Your employer's procedures must include a process for escalation when an IR(ME)R Practitioner is not available. This is where authorisation guidelines are most helpful. Without the legal framework in place you would be acting unlawfully. If it is challenging within your organisation to find radiologists, it would be helpful to consider training and entitling your radiographers.
There is no requirement for the referrer to have physically seen the patient. Their responsibility is to supply the practitioner with sufficient medical data (such as previous diagnostic information or medical records) relevant to the exposure requested by the referrer to enable the practitioner to decide whether there is a sufficient net benefit.
There is nothing within IR(ME)R that prevents a student from authorising using guidelines, however, to do so they must be trained and entitled as an IR(ME)R Operator and be working under the employer's procedures to a defined scope of practice. They must have this scope of entitlement in writing. Logistically, this would be extremely onerous to manage as the scope would be continually changing. For this reason we do not advise that students are entitled as IR(ME)R operators. Learners who are apprentices are employees and it may be that as they near completion of their studies they might be trained and assessed as competent in a limited scope of practice, however this would need to be closely managed as their scope expands.
You would need to know this before working in theatre and it might be different between employers or across sites within a single employer. We believe more common practice is for there to be authorisation guidelines, and radiographers act as IR(ME)R operators authorising the exposure. There is nothing to prevent a surgeon from becoming an IR(ME)R Practitioner if they are trained and entitled by the employer having met the requirements of schedule 3 for their area of practice. Remember that if you are an assistant practitioner you cannot legally justify the exposure.
Please see the SoR guidance The Diagnostic Radiographer as the entitled IR(ME)R Practitioner for more information (it can be found in our document library). Once trained and assessed it is important to get a written scope of entitlement from your employer.
You are working as the Operator when you undertake any practical aspect of the exposure such as taking the exposure or making the clinical evalution. As the Operator you may authorise exposures using guidelines issued by the IR(ME)R Practitioner. You can only justify the exposures in A&E if you are trained and entitled as an IR(ME)R Practitioner.There are no guidelines involved when you act as the Practitioner. You are making that reasoned decision based on your expertise and practical experience, taking into account the individual benefit and risk to that patient. We advise that you have this additional scope of entitlement in writing from your employer.
Please follow your university procedures for doing this and take advice from your lecturers and programme lead. As a student radiographer, your university will have policies to support you with raising concerns. There will be a process in place with the employer for raising concerns. Sometimes a person may have made a decision based on knowledge and expertise that is not immediatley apparent to you and it is valuable learning to enquire why something has happened or a person has made a decision you don't understand or don't agree with. Try and avoid confrontation, as you say, be diplomatic. You will learn the skills to challenge people in a professional manner as you develop your career but it is a requirement of professional registration to do so. As healthcare professionals, we are judged by both our actions and inactions.
Yes absolutely. Wrong laterality is very common. Discuss with the patient, contact the referrer if that is practicable and ask them to amend the referral. If not discuss with a senior colleague who is an IR(ME)R Practitioner so that the exmaination continues appropriately.
Not necessarily. Pay is related to your level of practice (radiographer practitioner (practice level NOT IR(ME)R Practitioner) , enhanced, advanced, consultant practitioner) and your post registration training and education.
Q: We have ‘delegation of authorisation’ from our lead radiologist, who is the practitioner. The protocols are from them, so we just make sure the referrals meet the protocols to authorise. Is this standard practice? Ps I’m a student
A: Yes this is common practice except delegated authority is an old term and is no longer recognised by The Ionising Radiation (Medical Exposure) Regulations 2017 or The Ionising Radiation (Medical Exposure) (Amendment) Regulations 2024. You are in effect authorising under guidelines issued by the IR(ME)R Practitioner. As a student, it is your supervising radiographer who is acting as the IR(ME)R Operator and not you as an individual. As part of your training you will quickly learn to understand how the radiographer decides if a referral fits within the authorisation guidelines and what to do if not.
Q: For documentation of authorisation, can this be done as a signature in a specified area on a form for instance (outlined in SOP), or does it have to be written as authorised by with signature on a page or screen?
A: This can be decided at organisational level and written into your employers procedures. IR(ME)R reguires exposures to be authorised by the practitioner or, where it is not practicable for the practitioner to authorise an exposure, the operator must do so in accordance with guidelines issued by the practitioner. Authorisation is the documented evidence that justification has taken place. How that is recorded is up to your employer and operators and practitioners should know and follow the procedure.
Q: As I am currently an apprentice radiographer I had to do a clinical exam and had to discuss IRMER justification with two senior radiographers and explain why I feel that this is justified. Can I discuss the justification process as long as I am with someone who is IRMER practioner trained?
A: Yes absolutely. An important part of your learning is to discuss the reasons why an exposure may or may not be justified and to understand the legal mechanism for operators to undertake the exposure. For every exposure you make, as the operator you should know why it has been justified by the practitioner as showing a sufficient net benefit. Students can always challenge a decision if someone else has told you something different but try and do this respectfully and from a position of learning. Please remember too that as a student radiographer you can speak to the university as they will have policies to support you with raising concerns.
Occupational exposures are not covered by IR(ME)R, they fall under The Ionising Radiations Regulations 2017. Everyone must know their obligations as ionising radiation workers, including adhering to the local rules for theatres.
Theatres can be a stressful place to work, especially during emergency procedures. This is why good governance and consistent practice are so important. If any member of staff in any radiation environment you are working in does not follow the local rules or is putting another person at risk, you MUST NOT make the exposure without advising them of their responsibilities to keep themselvs and others safe.
There will be a Radiation Protection Supervisor allocated for theatres that you can raise your concerns with if there are persistent offenders or ongoing non compliances. People sometimes use 'the patient will suffer' as a reason for you to bend the rules. If you put your registration at risk, many more patients will potentially suffer as there will be one less radiographer to provide the service.
Yes all employers are required to undertake audit of their written procedures. This is covered in IR(ME)R schedule 2 which states: The employer’s written procedures for exposures must include procedures; (d) to ensure that quality assurance programmes in respect of written procedures, written protocols, and equipment are followed.
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