Together with our counterpart regulators of the Ionising Radiation (Medical Exposure) Regulations in England, Northern Ireland and Scotland, we’ve published a response to the developing COVID-19 epidemic. Anyone involved in the use of medical ionising radiation equipment should read this.
For the attention of:
- Radiation employers
- Duty holders
- Service managers
- Governance managers
- Medical physics experts
- Radiation community
Update August 2020
We will be resuming inspection activity (both virtual and on-site) according to the risk of the service. These will be carried out following appropriate risk assessments to protect duty holders, patients and the enforcement authority inspection staff.
Update – 6 May
Administration of radioactive substances
We recognise that you may need to relocate certain procedures to alternative sites. Where you are planning to transfer services, you should:
- contact the ARSAC support unit for guidance on the employer’s licensing requirements for these services
- notify your regulator:
England: Care Quality Commission at COVID19IRMER@cqc.org.uk
Scotland: Healthcare Improvement Scotland at email@example.com – please also notify any changes to services that have already moved
Northern Ireland: Registration@rqia.org.uk
This information will also be shared with other relevant regulatory bodies to inform an appropriate regulatory response.
Any transfer of services needs careful consideration and risk assessment before you implement the changes, as there are other regulatory requirements that need to be satisfied as well as the employer’s licence.
In response to the developing COVID-19 situation, the inspectorates for the Ionising Radiation (Medical Exposure) Regulations (IR(ME)R) for the United Kingdom have worked with health boards, government, and professional bodies to create a temporary response. We have taken into account the new parliamentary bill and ongoing government advice. This will be in place for as long as required to respond to the situation and we will keep this under regular review.
We encourage flexibility within the legislative and regulatory requirements while ensuring that patient safety is not compromised. Our response is proportionate to the threat and aims to divert resources to the highest risk radiological activities. This response should be read in conjunction with any guidance published by other relevant regulatory bodies.
We understand at this time that staffing groups may be redeployed. It is important that you maintain training and supervision, particularly for high dose and complex procedures, for example radiotherapy, CT, nuclear medicine and interventional radiology/cardiology. We expect staff to work within the limits of their skills, knowledge, and experience at all times. Full training records and associated documentation may not be possible at this time, but we encourage the use of training matrices to support redeployment.
No staff should operate radiological equipment without training.
Alternative arrangements should be investigated to ensure essential applications training is delivered on all new equipment, including through video conferencing and e-learning.
Practice must be guided by local risk assessment and advice from your medical physics expert. You must prioritise essential and high dose equipment and consider its age and historical performance. Employers must ensure access to equipment for essential testing and maintenance whilst complying with local infection control policies. When purchasing new equipment, you should still perform essential commissioning and protocol set up.
Where regulators are allowing temporary registration of final year students and former registrants, these professionals may be entitled by their employer to act as duty holders under IR(ME)R within a defined scope of entitlement..
Any healthcare professional not registered by a body recognised by the Health Care Professions Act 2002 cannot be legally entitled under the regulations to act as a referrer or practitioner.
Services need to prioritise tasks that are essential and urgent, and postpone tasks that can tolerate delays with a lower risk to patients. Employers should take advice from their medical physics departments at this time, and discuss any changes to equipment location, adapted use and training.
Administration of Radioactive Substances
We recognise that it may be necessary to relocate certain procedures to alternative sites. Where this is planned, providers should contact the ARSAC support unit for guidance on employer licensing requirements for the transferred services. Any transfer of services should be considered carefully and risk assessed prior to implementation as there are other regulatory requirements that need to be satisfied aside of the employer license itself.
Significant Accidental or Unintended Exposures
We will not be making changes to our guidance, including timescales for reporting incidents. However, where employers face pressures we encourage you to give priority to high risk notifications (such as high dose or clinically significant). We will continue to investigate notifications following the graded approach. Where it is absolutely necessary, we may carry out our inspection functions to ensure patients are not at risk.
It is still important to maintain key safety checks before all exposures, including ID, pregnancy, exposure factors and modality/body part.
You can see further information from professional bodies and advisory committees: