Radiation exposure is a significant concern during medical and dental treatments, with computed tomography (CT) scans and X-rays being major contributors. In fact, evidence suggests that a single CT scan or X-ray accounts for 16% of the average annual radiation dose in the UK. To protect patients and avoid litigation, medical and dental professionals must ensure that the benefits of these procedures outweigh the risks. Fortunately, the introduction of IRMER 2017 guidelines has improved patient care and safety. In this article, we will provide an overview of IRMER 2017 and discuss important updates in 2023 to help you protect your patients and avoid legal issues.
IRMER 2017 – An Overview:
IRMER, the Ionising Radiation (Medical Exposure) Regulations, was implemented in 2017 to regulate the use of radiation in medical treatments, including CT scanning and X-rays. It replaced the previous Ionising Radiations Regulations (IRR) of 1999, derived from the European Council’s Medical Exposures Directive under Section 15 of the Health And Safety At Work Act of 1974. The regulations cover various aspects, such as optimal radiation doses, equipment quality assurance, and radiation safety training. According to IRMER 2017, employers are directly responsible for implementing these regulations. They must adhere to the following points:
- Notifying HSE
Under IRMER 2017, employers need to notify the Health and Safety Executive (HSE) of any changes in their radiation operations. Dental radiography falls into the “intermediate risk” category, requiring employers to register with the HSE and pay a one-off fee. This registration applies to all clinics owned by the employer.
Medical Physics Expert (MPE)
Every medical and dental establishment must have access to a Medical Physics Expert (MPE). The MPE is appointed by the clinic and serves as a point of contact for advising clinicians on radiation protection and equipment performance. They play a crucial role in ensuring compliance with IRMER 2017 regulations.
Optimisation of Protection
Efforts should be made to minimise patient radiation exposure while achieving the desired diagnostic or therapeutic outcomes. This involves selecting appropriate imaging techniques and protocols. Patients must be informed of potential risks, provide written consent, and all doses must be recorded.
Medical exposure involving ionising radiation should only be performed when clinically necessary for the patient’s diagnosis and treatment.
- Equipment and Quality Assurance
Radiology equipment and radiation therapy devices must meet specific quality standards. Regular calibration, testing, and maintenance should be conducted and documented.
- Training and Education
All individuals involved in the use of ionising radiation must receive appropriate training and education to ensure competency in radiation safety. This includes radiologists, radiographers, and dental professionals.
IRMER 2017 Update in 2023
As of April 19, 2023, the Care Quality Commission (CQC) updated information related to clinically significant, accidental, or unintended exposures (CSAUE). In the case of unintended or accidental radiation exposure deemed clinically significant, providers must thoroughly investigate the incident and report their findings to the UK IRMER enforcing authority. Failure to comply may result in enforcement actions against the provider. This update aims to address concerns about regulatory compliance and promote incident reporting.
So why is this update necessary?
Investigations previously carried out by the CQC found some key concerns around regulation compliance. For example, in the year ending 2022, the CQC reported 611 statutory notifications of significant accidental and unintended radiation exposures. These notifications were up from 499 in 2021.
Common errors included:
- Patients receiving scans intended for other patients
- General operating errors
- Inadequate or incorrect preparation
- Inadequate training leading to radiation overexposure and
- Poor or faulty equipment.
The CQC hopes to bring these figures down by ensuring that the correct training and education protocols are in place. But more importantly, when something goes wrong, all incidents must be investigated, documented and reported in a timely manner.
Finally, the relevant duty of candour for accidental or unintended exposures should also be considered.
Key Takeaway – IRMER 2017 Guidelines
IRMER provides a crucial framework to protect patients and operators during ionising radiation administration. The recent updates emphasise thorough investigation and reporting of clinically significant incidents. Compliance with these guidelines is essential for safeguarding employers, staff, and ensuring optimal patient care.
If you have any questions about your legal responsibilities surrounding IRMER, talk to our Dental Defence Society team. In addition to providing tailored indemnity packages, we have a knowledgeable dento-legal team who can help you navigate the pitfalls of ionising radiation. We’re here to help, so get in touch today.