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4. IR(ME)R Regulations and enforcement

4.1 IR(ME)R Regulation 11 refers to training and prohibits any practitioner or operator from carrying out a medical exposure or any practical aspect without having been adequately trained. An exception is made for trainees  where they participate in practical aspects under the supervision of someone who is adequately trained. Adequate training is training that satisfies the requirements of IR(ME)R Schedule 2.

4.2 Responsibilities of practitioners and operators with regard to any contravention of the IR(ME)R regulations are laid out in Regulation13 which states:

“ In any proceedings against any person for an offence consisting of the contravention of the IRMER Regulations it shall be a defence for that person to show that he took all reasonable steps and exercised all due diligence to avoid committing the offence” .

Due diligence is shown by adherence to the procedures laid down by the employing authority in relation to legal compliance3.  In addition radiographers have a professional and ethical duty to challenge any ‘procedures’ they may deem unsafe or unfit for purpose4.

4.3
Students/ trainees undertaking any exposures should not be classified as IR(ME)R operators, this entitlement remaining the responsibility of the supervising radiographer7.

4.4 There may be circumstances, however, where an employer may entitle students/trainees to be operators provided there is a robust local entitlement process within the clinical department that satisfies the relevant sections of IR(ME)R Schedule27 .

4.5 The practitioner role under IR(ME)R regulations2,5 remains the responsibility of the supervising radiographer. The practitioner is responsible for the justification of an individual exposure in terms of net benefit to the patient. This requires the practitioner to have full knowledge of the potential benefit and detriment associated with the procedure under consideration.

4.6 In order for a student to eventually undertake the role of IR(ME)R operator once qualified, s/he will undergone a period of education related to the role and will be trained under the direct supervision of the registered radiographer.The IR(ME)R enforcing authority “expect(s) to see close collaboration between the training institution and the department providing the clinical placement”6.

4.7
In addition, the HCC identified that in relation to students “We are seeing increasing evidence of a breakdown in IR(ME)R procedures when the responsibilities in team working are not clearly identified, particularly where trainees or students are involved. Although it is common practice for these groups to have no entitlement in the employer’s written procedures, which require all operator tasks to be carried out under supervision, these arrangements may sometimes lack clarity”6.

4.8 IR(ME)R regulation 7(7[b]) states that the practitioner and the operator shall pay special attention to medical exposure of children. SCoR has issued advice specific to children18,19.

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