The Employer has a responsibility to ensure that all entitled practitioners and operators are adequately trained to perform the tasks in their defined scope of practice (Regulation 4(4a) and (4b)) and consequently, practitioners and operators shall not carry out a medical exposure or any practical aspect without having been adequately trained (Regulation 11(1)).
Practitioners and operators shall have successfully completed training, including theoretical knowledge and practical experience as detailed in Schedule 2 which is divided into 2 sections:
- subjects that are relevant to the individuals’ functions as practitioner or operator
- subjects that are relevant to specific areas of their scope of practice:
diagnostic radiology, radiotherapy and nuclear medicine (SI 2000 No 1059).
a) Training Records for Practitioners and Operators
IR(ME)R Regulation 11(4) states:
‘‘The Employer shall keep, and have available for inspection by the appropriate authority, an up-to-date record of all practitioners and operators engaged by him to carry out medical exposures or any practical aspect of such exposures or, where the Employer is concurrently practitioner or operator, of his own training, showing the date or dates on which training qualifying as adequate training was completed and the nature of the training’’ (SI 2000 No 1059).
SCoR Guidance
Adequate training to achieve and maintain professional registration for non-medical staff is determined by the relevant regulatory body as defined in the National Health Service Reform and Healthcare Professions Act 2002. The Society and College of Radiographers recognises that the pre-registration radiography education programmes it approves, and which are approved by the Health Professions Council (HPC) to give eligibility for registration as a radiographer, address the requirements of Schedule 2 of IR(ME)R. Hence, these may be used as the benchmark by which the Employer defines ‘adequate training’.
For all practitioners and operators, this initial training and education should only be considered as a starting point rather than an endpoint in demonstrating adequate training within a local department. Responsibility for ensuring that adequate and up-to-date local training is delivered and recorded rests with the Employer and must be consistent with the scope of practice and tasks the individual is entitled to carry out. Training records need to reflect continuous development and local department-specific training, as well as that achieved through additional external qualifications and courses.
Training records for radiographers could include:
- Professional Registration Details – for radiographers their HPC number and period of registration
- Details of academic qualifications – DCR/BSc/MSc/Post-graduate certificates etc.
- Individual training profiles for each radiographer outlining which particular x-ray/radiotherapy equipment and techniques that they have been trained to use and by whom they were trained or declared as competent.
- A competency matrix of all radiographers may be useful to see a complete overview of all radiographers’ training.
- Radiographers must also keep their own training file/portfolio containing evidence of ongoing continuing professional development (CPD).
- Evidence of CPD may include certificates of attendance, reflective reports, learning of new techniques etc.
b) Agency Staff
Regulation 11(5) states: ‘‘Where the Employer enters into a contract with another to engage a practitioner or operator otherwise employed by that other, the latter shall be responsible for keeping the records and shall supply such records to the Employer forthwith upon request’’ (SI 2000 No 1059).
It is essential that companies supplying radiography agency staff provide their HPC registration and relevant training details to allow Employers to entitle them as an IR(ME)R duty holder.
c) Induction of new staff
It is always important for Employers to provide induction for new staff within clinical imaging/radiotherapy departments to aid the entitlement process and to ensure that new staff are adequately trained.
SCoR Guidance
All new staff should complete an induction programme that should include training on local equipment and tasks related to their specific role and that which provides an opportunity for staff sign-off as competence is reached. Before moving onto a new post in another department, it is advisable for staff to obtain copies of their own training record from their Employer. This should provide, for the new Employer, a foundation to establish what an individual is trained to do and what additional training might be required to allow the new Employer to entitle them forthwith.
The following points should typically be included in an induction checklist even though many of them go beyond IR(ME)R matters. It is equally important that the checklist meets the needs and expectations of the RPS as they have a wider safety role:
General
- Read local rules
- Read IRMER Employer’s Procedures
Examination rooms/treatment/simulator units
- Read Work Instruction Files (standard operating procedures) relevant to unit and activities associated with unit
- Switching on and off procedures
- Machine QA
- Contingency procedures
- Use of equipment
- Techniques relevant to unit
- Use of radiology information system / record and verify system
- Staff organisation
- Consent process
- The request card / treatment prescription
- QA procedures
Patient care
- Review clinics
- Patient information
- Departmental skin care
- Support services, nursing, dietician, Macmillan staff
- Post treatment follow up clinics
Additional
- Appointment booking system
- Hospital transport
- Telephone procedure/ bleep system
- Doctors clinics
- Private patient procedures
Radiation protection
- Staff monitoring procedures
- Departmental contingency plans
- IR(ME)R procedures
- Incident reporting procedures and documentation
Health and safety
- Departmental procedures
- COSHH
- Emergency/crash procedure