Radiological Protection in Veterinary Practice

Line

Comment

Suggestion

94-96

The recommendation need more supporting material. 

Give examples of pros and cons of why the Commission recommends this with references.

94-98

The recommendations need more actual examples and more supporting material in some areas (for example stochastic effects for animals and possible radiological effects on the environment).  What risks exists today from veterinary nuclear medicine to the environment?

Give examples of radionuclides that might be a problem to the environment- what long-term and short-term effects exists?

99

"This report focuses primarily on justification and optimization in veterinary practice along with the underlying ethical values". Radiation protection with only an ethical value is not in line with the system of radiological protection.

Add science and experience in to the report.

101-103

This report seems more like a guideline than an introduction to issues within radiological protection in veterinary practice.  Hence, it includes recommendation of major measures. 

Rephrase the sentence so that it correspond with the content.

110-113

This main point seems more like a guideline for protection in veterinary practice than an introduction to related issues.  

Rephrase the sentence to "The objective of this publication is to provide an initial set of relevant observations, considerations, and general recommendations related to radiological protection in
veterinary practice."

114

This is indeed a practical general observation, perhaps not so surprising, but is supported to a lesser extent by the content of the report.

The main points need to be reviewed in light of the content of the report.

117

The report needs to present more scientific facts for this to be a main point of the report

The main point needs to be reviewed in light of the content of the report.

119

The publication gives no scientific facts to the results from exposure to radiation. The authors states there is potential tissue reactions and stochastic effects, which there probably is, but to what extent?

Remove the sentence or add facts into the publication.

121

This bullet point clearly states that the publication is based upon ethical values. It can thus not be used further to develop guides etc.

It has to be stated in the publication that to the next step is to use the results of this publication together with science and experience to end up with the final radiological protection in veterinary practice

125

Comparisons to medical and non-medical human exposure is true regarding the occupational exposure, and comforters and careers vs animal owner. Regarding the patient vs the animal there are large differences. In human medicine euthanasia is not used. The incidence of cancer due to irradiation is known for humans, less known for animals. 

Clarify the similarities regarding occupational exposure and animal owner.

125

The conclusion in the last bullet point is not supported by the content of the report.

The main points need to be reviewed in light of the content of the report.

127

It sounds as the three levels of justification already exists in veterinary practice, which they do not. If the authors want to introduce level 2 and 3 for veterinary practice this introduction is a separate bullet.

Introduction of justification level 2 and 3 as a separate bullet point.

131-187

The introductory part of the report, Chapter 2, contains goals, scope, background and motivation. The need for Chapter 1 is therefore limited. In addition, Chapter 1 does not contain substantiated facts with references and does not constitute direct support for the content of the report.

Delete the chapter or replace it with a summary.

145

Views or exposures?

This term is only used in chapter 1. In the rest of the document it is called "number of exposures" or "exposures" or "magnitude of exposure". 

147-149

To whom is radiation dose higher? And what does substantially higher means in terms of Sv/Gy?

Add reference or scientific data and clarify to whom the radiation dose is higher.

197 – 199

This section provides an overview of developments in veterinary medicine. The number of exposed persons - staff or the general public - and the number of animals have increased if the observation is correct. Unfortunately not supported by facts. The potential risks associated with radiation as such do not change with the volume of a business. In order to comment on whether the radiation risks is more diverse, a more detailed description of the exposure situation is needed.

Please amend including facts and reference

201-204

The target audience is diversified. “It is intended for a wide-ranging audience, including radiological protection professionals, veterinary staff, students, education and training providers, and members of the public as an introduction to the issues surrounding radiological protection in veterinary practice.”  However, assimilating the content requires both basic knowledge of the radiation protection system established by the ICRP, the application of the ICRP system in the planned occupational exposure situation covered by other ICRP publications and also knowledge of the introduction of animals into this environmental protection. the system. Furthermore, good prior knowledge of the specific exposure situation and radiation doses in connection with a veterinary activity as this is not reported. The intended target group is apparently too broad.

Please adjust the content according to the target group or the target group according to the content.

208-209

“These publications may provide inspiration for developing specific guidance and advice that can be applied in veterinary practice”. The ICRP publications are expected to provide a basis for the management of radiation risks and guide how this basis is applied in different exposure situations and different defined exposure types so that different organizations can set radiation protection requirements or practical guidelines for radiation protection in different practices. To be of Inspiration seems out of scope for ICRP publications. 

These publications can form the basis for developing specific guidance and advice that can be applied to veterinary practice.

211 – 212

“Both practices involve the need to protect professional workers.” Editorial change is suggested

Both practices involve the need to protect occupationally exposed workers.

218

Protection of the individual animal is a major change in radiological protection. This should be a separate bullet in the main points.

Make it a separate bullet point

330-333

Animal patient is referred to animals that need diagnostic/medical help. Young horses or horses for export that are healthy is not an animal patient.

Consistent terminology, animal patient or veterinary patient? What is the observation and consideration from Task group 110 about healthy animal that undergoes radiation exams?

341 – 343

In paragraph (20) it is stated “… various activities have been developed by a dedicated working group…” This is vague information and serves little purpose for the reader.

Please remove or develop and include the conclusion of the work and how this conclusion ties to the content of this report.

353 – 409

The content of “3.1 Dosimetric quantities” a well part of the content is well covered in the references in paragraph (22) and need not be repeated. The peculiarities in veterinary medicine need to be more in-depth included if these paragraphs serve a purpose in section 3.1.

Please Remove well-known concepts e.g. absorbed dose and equivalent dose and expand the part relating to veterinary activities specifically.

387 – 393

This paragraph addresses the animals' radiation sensitivity. The type of adverse health effects in the animal is not specified and no references are given. Furthermore, it is not clear which protective quantities are to be used for animals and it is not self-evident that the concept of effective dose is relevant at all. This must be investigated.

The relevance of the animals should be expanded and discussed in more detail.

464-540

In points (33) - (39) the content of certain parts refers to human studies, e.g. NRC 2006 and certain parts for animals. This makes the sections difficult to read and thus understand what results apply to humans, which applies to animals or both. The paragraphs also contain several references including rodents and dogs. Ideally, this should not only be referenced but also summarized.

Please re-work the paragraphs.

499

"Of interest to veterinary practice is the observation that dogs, as compared to other species studied, demonstrate a greater risk of developing cancer as a result of exposure to ionizing radiation, and for cancer prevention in dogs it has even been explicitly stated in the literature that dogs should be exposed to radiation only when the expected benefits will outweigh the risks (Kelsey et al., 1998), consistent with the principle of justification in radiological protection." This sentence is misleading. There is no reference for stating that dogs have a greater risk of develop cancer as a result of irradiation. The reference is misleading since the article is not about cancer from irradiation, but an epidemiological study of cancer all in all. The cited sentence is taken out of its context since dogs also should avoid tobacco smoke, flea repellent etc. Some breed of dogs have genetic defects which give them a higher risk for cancer, which is not due to radiation.

Delete the sentence

552-553

“In humans, for most properly conducted diagnostic radiology procedures, doses typically do not exceed 20 mGy… refer to absorbed dose to embryos fetus and please also insert a reference. The relevance of including this in this publication could be questioned

In humans, for most properly conducted diagnostic radiology procedures, absorbed doses to the embryo/fetus typically do not exceed 20 mGy, although interventional procedures involving the pelvis could be higher [add reference].

598-603

Paragraph (45) is unfounded since this has not been shown that this is the case in the report. The veterinary patient is in many cases not handled in the same way as humans. The report does not elaborate on this issue enough.  Furthermore, veterinary exposure is introduced. “Because veterinary practice appears to fall somewhere in between, or at the intersection of, the above exposure categories, local governments and regulatory agencies manage veterinary exposures in different ways.” The exposure categories mentioned in (45) is medical exposures, occupational exposure, and public exposure. One application seldom only include one categories and the exposure categories are not equivalent to an application, e.g. medical applications entail all three exposure categories. In this context veterinary practice, using present recommendations has included occupational exposure and public exposures. The exposure of the veterinary and the staff has most likely been regarded as occupational exposure and any exposure of other humans involved in the activities a public exposure and thus managed as such. If the latter is an issue this should be discussed. Furthermore, veterinary exposure is not specified but seems to be an important concept in this context. The argument that animals in veterinary medicine and animals in the environment cannot be included in the environmental exposure category is not pronounced. The argument for and specification of veterinary exposure needs to be included.

Elaborate on the term veterinary exposure if this is intended to be included in the radiation protection system, such as e.g. medical exposures.

643 -646

An” occupational medical exposure” is ambiguous. The example could be considered as an investigative action level and not an application of a dose constraint.

Remove the example.

663-

“These ideas should intuitively also apply to veterinary animal patients (Pentreath, 2016), although if and how these patients fit within the principle of optimization has not been explicitly defined.“ The basis for the application of optimization of radiological protection is not clear thus "should" is maybe a too strong statement? The end of this paragraph also states “Thus, clear delineation of the application of both justification and optimization for the patient in veterinary practice is warranted.”

Change to “These ideas could intuitively also…

682-685

This recommendation is not substantiated but could be one of the main outcomes of the report.

The motivation for this statement should be more substantiated in the report.

699-702

It's unclear of what a large-scale nuclear accident has to do with veterinary practices? Do you mean consideration of exposure to animals in a nuclear accident?

Explain this example more, what kind of doses and what type of concerns is there except large-scale nuclear accidents?

701-702

The application principles in veterinary practice including the exposed animals (veterinary exposure?) are not substantiated in the report. For example, in the figure justification principles for exposed animals as described in fig. 3.2 is not substantiated and is not applied today.

The motivation for this statement should be more substantiated in the report and today's system f radiological protection and suggested practice clearly separated.

703

Exemplify with relevant information about the different levels.

Exemplify with relevant situations

704

"Level 2 a procedure is justified for a specified objective if it does more good than harm to a group of exposed animals" This cannot be true if it means a higher exposure to the staff or pet owner….

More discussion about pros and cons when the authors introduce level 2.

704

"Level 3 the particular application should be judged to do more good than harm to the individual patient" This cannot be true if it means a higher exposure to the staff or pet owner…. It is neither truth if the exposure is due to economic aspects for the owner.

More discussion about pros and cons when the authors introduce level 3.

704

The authors clearly states that Diagnostic reference levels should be introduced. The publication lacks a discussion around this. What will this lead to when it is implemented? What are the benefits and what will it cost.

Introduce a discussion around pros and cons when applying DRL.

704

It is unclear, is it the authors intention to introduce dose limits for animals?

Clarify whether it is for humans or animals.

704

Figure 3.2 mixes humans and animals so it is difficult to understand

Clarify whether it is for humans or animals.

707-818

Subchapter 3.4 is very basic knowledge and practice-oriented if this is not assumed to be well known to the target audience then it is questionable if they could comprehend the content of the report as a whole. This subchapter does not provide any guidance on how the exposure of the animals should be included in the system of radiological protection.

Please consider removing this subchapter.

739

The abbreviation PPE is used in several places in the publication, but it is not a common used one.

Replace PPE with personal protective equipment

832-

ICRP 138 do address the environment as part of the ethical issues. In this context, it could sufficient to expand on this issue in the report.

Please consider expanding the reasoning.

879-883

Paragraph (71) specify some different types of animals. This should be addressed earlier in the report as this could be expected to have relevance on how to include exposure of animals in the system of radiological protection.

Please consider mention this earlier in the report.

962-973

Paragraph (77) is written as if it is obvious that the practical tool used in connection with medical exposure should also apply to the exposure of animals, for example DRL. This is not substantiated in the report.

Please elaborate and give an explanation. 

1022- 1024

The sentence “Consequence, radiological protection competent authorities may not automatically consider the diplomats (board-certified specialists) as sufficiently competent in radiological protection” is hard to understand the logic behind the statement.

Please elaborate.

1030-1042

Paragraph (81) is rather practice-oriented guidance.

Consider omitting.

1059-

The report does not state why the principles of human medical practice can be applied in veterinary medicine. This is presented as a recommendation and it is important to show an evidence base.

Please elaborate.

1061-1063

Justification is not taken as a given. More discussion about justification of pre-purchase exams is needed. There is a reference from FEEVA (FEEVA study/rapport reference)  https://feeva.fve.org/working_documents/joint-position-feeva-herca/). FEEVA considers that there is no evidence of a correlation between radiographic appearance of the dorsal spinous processes of the back and future risk of disease in asymptomatic horses.

More references and more discussion about justification. What is the observation and consideration of the task group 110 about pre-purchase examinations of healthy horses?

1068

The sections 5.1.1 and 5.1.2 does not exist. It should be 6.1.1 and 6.1.2?

Change to 6.1.1 and 6.1.2?

1069

Level 1. Proper use of radiation in most veterinary medicine is accepted..... Everything is not justified e.g. pre-purchase examination of healthy horses. Is proper use of radiation on healthy horses justified? Does medicine mean radiation examination of healthy animals?

Change text to "Proper use of radiation in most veterinary medicine is accepted as doing more good than harm to society."

1069

Level 2. Does veterinary patients include healthy animals?

Further discussion about pre-purchase examinations, and examination of healthy young horses need more observations and consideration. Thus, they are healthy.

1069

Level 2 and level 3 cannot be true if it means a higher exposure to the staff or owner.

Change the text with regard to the occupational exposure or the exposure of the animal owner.

1070-1085

The paragraph speculates whether tools applied in medicine also is applicable in veterinary medicine. For sure, this has not been tested out so this could be rather premature to suggest such practical solutions. (87) – (90) is in practice tools to avoid unnecessary radiation.

Consider omitting.

1084-1085

Put in an example to the sentence of self-presentation (e.g. presale examinations)

Similarly, in veterinary medicine ‘self’-presentation would then designate the situation in which an animal owner requests for a radiology procedure, without intervention of a veterinary clinician (e.g. presale examinations).

1095-1096

Rephrase the sentence. "...Could be considered a risk..." --> "...is considered a risk..."

Hence, financial incentives as
drivers for the use of radiological equipment are often present in veterinary medicine is
considered a risk factor for possible overuse.

1126-1131

In reality indicators such as insurance company and owners’ willingness of different type of examination due to the cost of the examination should also be mentioned.

Mention reality as a point of view with different indicators such as insurance company and owner’s willingness of different type of examination due to the cost of the examination.

1160

Needs a reference e.g. (FEEVA study/rapport reference)  https://feeva.fve.org/working_documents/joint-position-feeva-herca/

reference e.g (FEEVA study/rapport reference)  https://feeva.fve.org/working_documents/joint-position-feeva-herca/

1161-1164

For non-medical radiological procedures the three levels of justification (used for medical exposures) is not applicable and thus reference to level 2 justification is not doable. The meaning of screening is not clear.

Please clarify and elaborate.

1162

Give reference to the sentence "scientific evidence" and exemplify about studies that are used today for justification of non-medical radiological procedures.

If reference and examples does not exist, delete the sentence (93).

1170-1172

What is veterinary radiological societies? Exemplify.

Give example of what a veterinary radiological societies is.

1174-1177

In the context of radiological protection, the definition of benefits and risks is very important, e.g. in some cases, the net benefit should be considered and the “risk” includes radiation risks only. This should be clarified.

Please clarify.

1207-1215

There is no reference to the sentence in (93)--> 1207, 1210-1212, 1213-1215.

Give reference to the sentence or considered deleting (98).

1207- 1215

A quantitative assessment of the stochastic effect has not yet been presented in the report. It could be useful to show some numbers for exposed animals somewhere in the report. This could perhaps be the place.

Please amend with a quantitative assessment of the stochastic effect for animals.

1246 – 1248

The principle of optimization of protection is defined in ICRP 103: The likelihood of incurring exposure, the number of people exposed, and the magnitude of their doses should all be kept as low as reasonably achievable, taking into account economic and societal factors. In this report, this definition is altered and not elaborated why this was altered. It could also be noted that the definition of optimization is hard to apply to a deliberate exposure such as medical exposure.

Please elaborate and motivate this change of definition and also write optimization of radiological protection.

1262-1266

It is stated: “With the increase in prevalence and frequency of radiological exams, and the increased lifespan of companion animals, there is a corresponding increase in the risk of radiogenic effects in this population.”  This statement has to be clarified. The number of exams does not increase radiation risk as such. The use of term radiogenic effects is also first used here in the report. Improved optimization is also not self-evident related to the increased number.

Please elaborate on these causations. Please write optimization of radiological protection.

1267-1276

In paragraph (104) a value judgement of the societal value is stated. It is not clear what this conclusion is based on. It could be that in some cases in society and specific situations the animal value is judged as zero.

Please elaborate on the stated conclusion.

1273

However, since the specific risks induced by radiation exposure in animals are not yet quantified, currently no guidance is available related to, for instance, animal specific DRLs". The first step would be to quantify the specific risks induced by radiation exposure. Despite this ignorance the authors want to apply DRLs, without knowing the benefits of doing it.

Either: remove the intention of applying DRL. Or: add a section to clarify why DRL should apply. The benefits and the costs etc.

1274

It is not a part of the radiological system to only consider societal values alone. It has to be together with science and experience.

Remove the text or add science and experience to the arguments why optimization strategies should be valid for animal patients as well.

1277- 1582

The paragraphs (105) – (132) is practical guide to radiation protection.

Consider to omit.

1277- 1582

The paragraphs (105) – (132) is practical guide to radiation protection.

Consider to omit.

1277- 1582

The paragraphs (105) – (132) is practical guide to radiation protection.

Consider to omit.

1277- 1582

The paragraphs (105) – (132) is practical guide to radiation protection.

Consider to omit.

1306

Shouldn’t the procedure always be justified? 

Needs more explanation

1352

Change it to "delineating the designated are" instead of "delineating the controlled area"

Change it to "delineating the designated are" instead of "delineating the controlled area"

1360

"This is turn" to "This in turn"

Change is to in

1362

Why does the Task group 110 include comforters/carers when there is no such term in veterinary medicine?

Delete the term comforters, hence there is no such term in veterinary medicine.

1366

This part should be used in the entire report with only the terms owners and handlers. In the rest of the report following terms is also used: comforters, careers within Veterinary medicine.

Just use the terms owners and handlers in the rest of the report.

1592-1599

In paragraph (134) includes a recommendation. “Although thus far in veterinary medicine animals have not been legally recognized as ‘patients’ and thus the concept of a pet owner serving as a ‘carer’ has not been applicable, it is recommended that the concepts of patient and carer be tailored to be applicable within reason in veterinary practice.” Before issuing this recommendation, it may be useful to develop how the practice should fit into the radiation protection system. Veterinary exposure needs to be defined. A caregiver could be included in this concept. Pros and cons should be elaborated. For example, should exposures without a medical purpose should be included in veterinary exposure.

Please elaborate.

1601-1648

The paragraphs (135) – (141) is practical guide to radiation protection. Could be omitted from this recommendation.

Consider to omit.

1644-1649

A dosimeter is calibrated for different Hp for humans.  Is the aim to eventually monitoring every animal patient?

rephrase (141) to "Through systematic recording and follow-up of dose indicators to animals, staff, members of the public, and the environment, as applicable and inter comparisons with those registered by others in similar conditions, will contribute to optimization of procedures and will allow for the early detection of malfunctioning devices or the systematic performance of insufficiently optimized procedures."

Change "doses" in (141) to "dose indicators"

1671-1674

In paragraph (144) it is stated that “Despite some differences, the radiological protection concerns originating from the use of ionizing radiation in veterinary practice is to a very large extent  comparable to equivalent human medicine applications and non-medical human imaging.” The report does not to a satisfactory extent describe the similarities and differences, especially between medical exposure/non-medical exposures and the exposure of animals in different scenarios. Likewise, the report does not to a full extent show similarities and differences with the system of environmental protection.  The increased exposure level to staff is not quantified etc. It is therefore premature to draw give these types of recommendations.

Please consider amend the content.

1694-1695

Paragraph (147) states that the protection principles for justification, optimization and dose limits should apply in full to veterinary applications. The principles of radiation protection already apply to the veterinary application, but perhaps an exception, the specific exposure of the animals. The key question is how the exposure of the animals could fit into the radiation protection system. The report does not provide an in-depth basis for this and therefore provides no basis for the conclusion that it could be treated equally with medical exposures and applies the definition and use of justification. Paragraph (147) is written so that it is obvious that all statements in the paragraph are well founded.

Please consider clarifying this – this may affect the whole report.

1700

"It is recommended that scientific organizations and specialist professional societies provide guidelines that could assist clinicians in making appropriate choices" "Similar guidance would be particularly welcome when presale and insurability examinations on horses" Yes, this is true, but why hasn't this been discussed more in the publication.

Give these statements in the summary a section of its own in the publication.

1727

Does the commission recommends that one can apply LNT for animals?
This need further discussion before recommendation.

write that only after studies have been done in the field can one consider whether it is relevant to apply it.

2119 -

Responsibility and role are vague words and could perhaps be attributed to organizations and legal entities. However, when talking about the responsibility to perform tasks and oversee practices it becomes very unclear what the responsibilities and roles mean. It could also be confused with legal responsibility. This specific recommendation could clash with formal national legal requirements. For example 2171-2173, it is unclear from a legal point. It is not unlikely that in some legal framework it is the veterinary practice that should protect the public and have to take full responsibility.

Carefully consider re-phrasing the appendix

2120

(A1) has no connection to veterinary practice.

Consider deleting the part (A1)

2193

Annex B is a detailed guidance, which was not the intention of the publication.

Write about it, and write that only after studies have been done in the field can one consider whether it is relevant to apply it.

2193

It says "use third-parties (pet owners) to hold patient" both for horses and for small animal, yet, in 1357 the task group 110 writes that pet-owners should typically not be asked to help. It is also from a general routine in Switzerland.

Delete Annex B

2193-

This is a practice-oriented guidance that is not included in the scope of the report.

Please consider to omit.

2270-2275

This summary of the environmental protection does not give the whole picture of why it was included in the radiological protection system and needs to be reformulated.         "The Commission therefore acknowledged (ICRP, 2007) that, in contrast to human radiological protection, the objectives of environmental protection are both complex and difficult to articulate. It did however subscribe to the global needs and efforts required to maintain biological diversity, to ensure the conservation of species, and to protect the health and status of natural habitats, communities, and ecosystems. It therefore developed a framework in order to meet these objectives by way of a practical system..."

Suggest to change to: "the system for environment protection was developed to fill a conceptual gap in RP and to clarify how it can contribute to attainment of society's goal to protect the environment and how to demonstrate compliance with existing legislation."

2288

Since the publication is based on ethical values in veterinaray practice it is surprising that euthanasia is not mentioned, except for Annex C.

Include euthanasia in the ethical discussions  in the publication

2311

Consider deleting this part (C9). It's not relevant to the report with radiological protection in veterinary medicine.

Consider deleting the part (C9)

2320

Consider deleting this part (C10). It's not relevant to the report with radiological protection in veterinary medicine.

Consider deleting the part (C10)

2335

Consider deleting this part (C11). It's not relevant to the report with radiological protection in veterinary medicine.

Consider deleting the part (C11)

2340

Who is the client in this case? The animal or the owner?                                                                                                                                                                 

Consider deleting the part (C11)