From: "Rita Richter" <[EMAIL PROTECTED]>
Hi all
I may behind the 8-ball here, but what are other practices doing
regarding
the requirement of direct supervision of students by a licensed
radiographer
whilst the student operates x-ray equipment. I have enclosed
excerpts from
the NSW EPA Radiation Control Regulation and Act that relate to
this.
My interpretation of this is that a qualified and licensed radiographer
must
supervise students at all times whilst they are taking an x-ray.
Someone on
site must also be given the authority by EPA to give the approval
for
exemption for students. I have heard other interpretations such as
direct
supervision is only required for examinations for which the student
has not
gained competency. Once the student has gained competency in a
procedure,
they only require general supervision, eg. check the films at the
end. EPA
advise that students should be directly supervised at all times for all
examinations, and general supervision for when they are doing non-
radiation
tasks such as processing.
I am sure there are many practices that would not be able to
function
without allowing a student to at least take x-rays that they are
competent
in without having someone supervising them directly. Let alone the
demoralising effect this would have on students.
What do others think of this?
Rita Richter
San Radiology
Sydney Adventist Hospital
185 Fox Valley Rd
Wahroonga NSW 2067
Ph: 9487 9838
Fax: 9487 9845
Email: [EMAIL PROTECTED]
RADIATION CONTROL REGULATION 1993 - SECT 8
Exemptions from sec. 6 licensing requirements for certain persons
8. (1) The following persons are exempt from the licensing
requirements of
section 6 of the Act in relation to the use of radioactive substances
and
ionising radiation apparatus:
(a) a person who is a medical registrar at a hospital and is
training in
nuclear medicine, diagnostic radiology, radiation oncology,
ophthalmology, dermatology, rheumatology or in a medical
discipline
which uses fluoroscopy;
(b) a person who is a student in medical radiation technology and
is a
trainee technologist in nuclear medicine, diagnostic radiology
or
radiation oncology;
(c) a person who is an assistant to an industrial radiographer;
(d) an undergraduate student in a university or other educational
institution who is undertaking course work or research;
2) This exemption does not have effect with respect to a person
unless the
person:
(a) is the subject of an approval under this clause; and
(b) is complying with the conditions to which the approval is
subject.
(3) A person who holds a licence may give approvals for the
purposes of this
clause, but only if the conditions of the licence so allow.
(4) An approval:
(a) must be in writing; and
(b) must specify the radioactive substances or radiation
apparatus to
which it relates; and
(c) must set out any conditions to which it is subject; and
(d) must identify each person, or class of persons, to whom it
relates;
and
(e) must identify the person or persons who are to supervise each
person,
or class of persons, to whom it relates.
(5) A person who gives an approval for the purposes of this clause
must
ensure
that a copy of the approval:
(a) is given to each person to whom it relates; or
(b) is conspicuously displayed at each place in which the
radioactive
substances or ionising radiation apparatus to which the
approval
relates are proposed to be used.
Maximum penalty: 15 penalty units.
(6) A person who grants an approval must ensure that each person
so approved
is supervised by a qualified person as follows:
(a) a person referred to in subclause (1) (a) must be subject to:
(i) immediate supervision at all times during the first 6 months of
the
person's training; and
(ii) general supervision after that period;
(b) a person referred to in subclause (1) (b) must be subject to:
(i) immediate supervision at all times while the person is using
the
radioactive substances or radiation apparatus to which the
approval
relates during clinical experience in the course of training; and
(ii) general supervision at all other times;
(c) a person referred to in subclause (1) (c) must be subject to
immediate supervision at all times;
(d) a person referred to in subclause (1) (d) must be subject to:
(i) immediate supervision at all times while the person is using
the
radioactive substances or radiation apparatus to which the
approval
relates in any clinical situation; and
(ii) general supervision at all other times;
Maximum penalty: 15 penalty units.
(7) In this clause:
"general supervision" means supervision by a qualified supervisor
who
oversees
the person being supervised and ensures that the person follows
safe
radiation
work practices in relation to the use of radioactive substances or
radiation
apparatus;
"immediate supervision" means supervision by a qualified
supervisor who is
present at all times during, and is observing and directing, the use
by the
person being supervised of radioactive substances or radiation
apparatus;
"qualified person", in relation to supervision for a particular
radioactive
substance or item of radiation apparatus, means a person who is
the holder
of
a licence which allows the person to provide supervision with
respect to
that
substance or item.
RADIATION CONTROL ACT 1990 - SECT 6
Restrictions on possession, use and sale etc of radioactive
substances and
certain radiation apparatus
6 Restrictions on possession, use and sale etc of radioactive
substances and
certain radiation apparatus
(1) This section applies to the following:
(a) all radioactive substances,
(b) all ionising radiation apparatus,
(c) non-ionising radiation apparatus prescribed as apparatus to
which this
section applies.
(2) A person must not possess, use, sell or give away anything to
which this
section applies unless the person is the holder of a licence under
this
section and does so in compliance with any conditions to which the
licence
is subject.
Maximum penalty: 1,500 penalty units in the case of a corporation
or 250
penalty units or imprisonment for 2 years, or both, in any other
case.
(3) A person must not sell or give away anything to which this
section
applies except to a person who holds a licence under this section
authorising the possession, use or sale of that thing.
Maximum penalty: 1,500 penalty units in the case of a corporation
or 250
penalty units or imprisonment for 2 years, or both, in any other
case.
(4) The Authority may, on application in the approved form and
payment of
the prescribed fee, grant a licence.
(5) The Authority is not to grant a licence authorising a person to
use
anything to which this section applies unless it is satisfied:
(a) that the applicant is a natural person and is a fit and proper
person to
hold the licence, and
(b) that the applicant has appropriate knowledge of the principles
and
practices of radiation safety and protection applicable to the
activities
proposed to be carried on by the applicant pursuant to the licence,
and
(c) that the applicant meets any relevant requirements for licensing
for use
of the substance or apparatus set out in a document forming part of
the
National Directory and adopted by the Authority under section 37.
(6) A licence is subject to such conditions as may be imposed by
the
Authority.
Rita
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