From: [EMAIL PROTECTED]

NSW branch held a meeting on Saturday at which Len Potapof 
presented on 
behalf of the EPA. This question was well covered.The 'direct 
supervision" clause on the student's license indicates that the student 
MUST be supervised AT ALL TIMES, otherwise insurance may well be 
null 
and void and the practice leaves iteself open to prosecution. This is 
regardless of whether the student is deemed competent or not by the 
practice.The fact is, the student remains unlicensed. With regards to 
exemptions, you are correct in saying that the chief Radiographer has 
to 
issue an exemption to the student. The Chief radiographer can only do 
this if their license contains a clause permitting the exemptions to be 
granted and they are then accepting responsibility for ensuring all the 
conditions of licensing are met by the students, ie direct supervision 
etc. This exemption certificate is to be handed to the student to carry 
at all times,and also posted in view wherever the student is working.
My personal view is that this is a ruling which appears sensible for the 
safety of the patient. We are screaming about the prospect of a tiered 
profession,considered by most to be "unsafe", yet are willing to allow 
students to work unsupervised on patients. It appears a contradiction to 
me- what exactly do we want?

Rita Richter wrote:

> 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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