The Health Information and Quality Authority (HIQA) has published 11 inspection reports assessing compliance with medical exposure to ionising radiation regulations. Medical exposure to ionising radiation is when radiation is used as part of diagnosis such as an X-ray or CT scan, for medical research purposes or the use of radiotherapy as part of cancer treatment at a hospital. It also includes radiation received by carers and comforters while attending to a patient.

Inspections were carried out between May 2021 and September 2021 of: 

• Bon Secours Hospital, Dublin

• Dexascan & Bone Health Unit, Dundalk, Louth

• Dr John A Lordan at Northbrook Clinic, Dublin

• Gorey Family Chiropractic Clinic, Wexford

• Hermitage Medical Clinic, Dublin

• Human Body Composition Laboratory, University of Limerick, Limerick

• Kilcreene Regional Orthopaedic Hospital, Kilkenny

• Monaghan Dental Centre, Monaghan

• Ormond Orthodontics - Kylemore Clinic, Kilkenny

• The James Clinic, Enfield, Meath

• UPMC Bon Secours, Cork.

Of the inspection reports published today, good levels of compliance or substantial compliance with the regulations were found in the majority of services. Full compliance with regulations was found in Monaghan Dental Care on the day of inspection. Gorey Family Chiropractic Clinic demonstrated full compliance and Kilcreene Regional Orthopaedic Hospital showed noticeable improvements following findings of non-compliance for both services on previous inspections. Some examples of good or novel practice seen on inspection included:

• The Bon Secours Hospital utilised radiation safety committees to highlight potential regulatory non-compliances, formulate actions and subsequently monitor ongoing compliance levels. This ability to review practice and address potential regulatory shortcomings was seen as an effective use of governance structures by the hospital.
• On the day of inspection, it was found that UPMC Bon Secours used technology to enhance the risks and benefits discussion for patients. Inspectors were informed that an audio recording of the consultation was made available to patients. Family members were also permitted to virtually attend these consultations should a patient wish.
• At Ormond Orthodontics - Kylemore Clinic, a radiation safety committee was in place at the dental practice. Issues such as clinical protocols, radiation safety procedures and incident management were discussed. The presence of a radiation safety committee was seen as a positive additional assurance mechanism for undertakings to strengthen their governance, management and oversight arrangements for medical exposures, especially where undertakings have more than one dental practice.
• At Monaghan Dental Care, information relating to patient exposure formed part of the report of the dental radiological procedure. The proactive identification of this area for improvement and the implementation of corrective actions to achieve compliance was seen as an example of good practice.
• At the Hermitage Medical Clinic, inspectors were provided with evidence that an extensive and in-depth analysis and optimisation study was conducted when the local diagnostic reference levels (DRLs) were found to be greater than the national DRLs. This facilitated the undertaking to implement new optimised protocols with the assurance that the dose reduction had not affected the quality of the images. 

Inspectors found evidence of non-compliance in The James Clinic, Dr John A Lordan at Northbrook Clinic, Dexascan & Bone Health Unit, and the Human Body Composition Laboratory. 

In The James Clinic, the undertaking had been conducting medical exposures to ionising radiation for a considerable period of time without notifying HIQA as required by the regulations. At Dr John A Lordan’s practice at Northbrook Clinic, written protocols for every type of standard dental radiological procedure were not available on the day of inspection. In addition, the inspector reviewed patient reports and was subsequently informed that information relating to the patient exposure did not routinely form part of the report. 

An urgent compliance plan was issued to the Dexascan & Bone Health Unit relating to the absence of medical physics involvement in the service and deficits in oversight for maintenance of a quality assurance programme for equipment. There were further issues identified in the absence of key personnel required in the referral and justification of medical exposures. An urgent compliance plan was also issued to the Human Body Composition Laboratory as the service had not allocated responsibilities appropriately in line with the regulations. It was found that registered referrers and practitioners were not sufficiently involved in justification and medical exposures were carried out by individuals that were not entitled to do so under the regulations. 

HIQA continues to engage with these services to ensure compliance with the regulations. 

Read all 11 inspection reports at www.hiqa.ie. 

Notes to Editor:

• HIQA is the competent authority for patient protection in relation to medical exposure to ionising radiation in Ireland after the EU’s Council Basic Safety Standards (BSS) Directive of 2013 was transposed into Irish law in 2019. These inspections were carried out between August and November 2020.
• The Environmental Protection Agency (EPA) continues, under separate ionising radiation regulations, to be the competent authority for the protection of workers and members of the public. HIQA and the EPA work together to carry out their separate but parallel functions under the relevant legislation.
• An undertaking is a person or body who has the legal responsibility for carrying out, or engaging others to carry out, a medical radiological practice, or the practical aspects of a medical radiological procedure, as defined by the regulations.
• A practitioner is a registered doctor, dentist, radiographer or radiation therapist who can take clinical responsibility for an individual medical exposure.
• Medical physics expert is a person who has the knowledge, training and experience to advise on matters relating to radiation physics applied to medical exposure procedures. 
• Diagnostic reference levels (DRLs) are estimates of representative radiation dose levels for typical X-ray examinations.