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Sonographers as referrers for ionising radiation examinations

17 October, 2019

Author: Maria Murray, SCoR Professional Officer for Scotland and UK Radiation Protection Lead, and Lynda Johnson, SCoR Professional Officer Clinical Imaging

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The Ionising Radiation (Medical Exposure) Regulations 2017 (IR(ME)R) and IR(ME)R NI 2018 recognises four duty holders: employer, referrer, practitioner, and operator. The employer must entitle someone before they can act as referrer, operator or practitioner.

‘Sonographer’ is not a protected title and a person does not currently need to be a statutorily registered healthcare professional to undertake sonography examinations. However, sonographers should be educated, trained and qualified to enable them to perform a range of diagnostic medical ultrasound examinations, which may include screening and interventional procedures. If they are not using ionising radiation to acquire images, they do not need to be entitled as operators under IR(ME)R to undertake their sonography role.

Sonographers are well placed to refer patients to another healthcare professional for additional investigations, or ongoing care as required. Further imaging involving ionising radiation, for example an x-ray or CT scan, may be considered appropriate.

There are, however, statutory requirements that govern who can do this.

Under IR(ME)R, 'referrer' means a registered health care professional who is entitled in accordance with the employer’s procedures to refer individuals for exposure to a practitioner. A registered health care professional means a person who is a member of a profession regulated by a body mentioned in section 25(3) of the National Health Service Reform and Health Care Professions Act 2002.

This includes the General Medical Council, the General Dental Council, the General Optical Council, the General Osteopathic Council, the General Chiropractic Council, the General Pharmaceutical Council, the Pharmaceutical Society of Northern Ireland, the Nursing and Midwifery Council, the Health and Care Professions Council (HCPC), and any other regulatory body (within the meaning of Schedule 3 to the 1999 Act) established by an Order in Council under section 60 of that Act.

Sonographers who are not registered with one of these regulators, for example as a diagnostic or therapeutic radiographer, physiotherapist, midwife or nurse, cannot therefore legally act as a referrer for examinations involving ionising radiation.

Currently, the majority of sonographers are statutorily registered as radiographers, nurses, midwives, or physiotherapists. They will be registered with either the Health and Care Professions Council (HCPC) or the Nursing and Midwifery Council (NMC). However, overseas recruitment and the development of new educational pathways means that for a significant number of sonographers, statutory registration is not available to them and they therefore cannot act as referrers for ionising radiation examinations.

Being voluntarily registered with, for example, the Public Voluntary Register of Sonographers is not sufficient to act as a referrer for examinations utilising ionising radiation.

If statutorily registered, it is worth noting that there is no requirement under IR(ME)R for referrers to be adequately trained. They must, however, be aware of their statutory responsibilities as a referrer under regulation 10 (5) to supply the practitioner with sufficient medical data (such as previous diagnostic information or medical records) relevant to the exposure requested. This is necessary to enable the practitioner to decide whether there is a sufficient net benefit as required by regulation 11(1)(b) which is concerned with justification of individual exposures.

For this reason, referrers who are not medically trained usually have a scope of entitlement which relates to their professional scope of practice and the role they are undertaking. For example, a sonographer who is statutorily registered with the HCPC as a radiographer and who is trained to perform medical ultrasound examinations of the abdomen, may be entitled by the employer to refer patients above the age of 18 (or as otherwise stated) for an x-ray or CT scan of the abdomen within a specified set of clinical criteria. This should be recorded in a written procedure as part of the overarching local clinical governance framework.

There is a requirement for the employer to have a written procedure to identify individuals entitled to act as referrer within a specified scope of practice (schedule 2 1(b)).

Employers must take steps to ensure that written procedures are complied with by the referrer, practitioner and operator. While tasks may be delegated, responsibility for compliance with IR(ME)R lies with the employer.

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