Radiological Protection in Veterinary Practice

Draft document: Radiological Protection in Veterinary Practice

Submitted by Timo Helasvuo, Radiation and Nuclear Safety Authority Finland � STUK
Commenting on behalf of the organisation

Dear Colleagues in ICRP

These comments have been gathered from a group of subject matter and legal matter experts with working titles as inspectors, senior inspectors and senior advisors in Radiation and Nuclear Safety Authority Finland – STUK. They represent a coherent understanding on radiation use in veterinary practices and the regulations that are empowered in Finnish Radiation Act 859/2018 and how this draft relates to current national situation in Finland. The comments include examples on what certain implementations would require from the end user and regulatory bodies looking to enforce these kinds of recommendations with the focus on concentrating on the graded approach on these veterinary applications. The current radiation act has quite significantly taken veterinary medicine into consideration during the legislative process already.

STUK wants to remind that in general we should investigate ways to make veterinary x-ray examinations, treatments and procedures as safe as possible to all attending individuals and while doing that the animals will benefit in the process.

Row(s)	Content / Chapter being commented	Comment
594-597	Statement in brackets "apart from …. Natural background" means that exposure to natural background would not fall under any category of exposure meaning that it would fall out from the whole system of protection. This is wrong, as high exposures to natural background are certainly covered by the system of protection.	Delete words "and natural background".
601-603	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 definition of veterinary exposure is missing. How it should be compared to other exposures defined in the ICRP 103?
616-618	The principle of optimisation of protection and safety specifies that doses should be as low as reasonably achievable (ALARA), considering economic and societal factors as well as other relevant aspects of the prevailing618 circumstances (see section 6.2).	The involvement of economic and societal factors should be further discussed in the light of targeting available resources in the society, for example between different approaches to protect animals and between radiation safety of humans and animals for example within the radiation protection authority.
643	A very confusing term "occupational medical exposure" is used.	Should this read "occupational exposure in medical use of radiation"?
678	Emphasis is therefore placed on the justification of the procedures in the first place, on the optimization of protection in relation to the source and, for diagnostic procedures, on the use of DRLs, which are not seen as limits, but instead indicate if a dose received from an imaging procedure is unusually high or low to guide the optimization process and thus help manage patient exposures. The Commission recommends that an approach analogous to that applied for human medical exposures be developed and applied for veterinary exposures which includes a quality dose management program that allows for periodic audits, continuous peer learning, and use of incident reporting systems that capture incidents and near misses.	DRLs in veterinary x-ray exposures are not practical tools for optimization for following reasons: Conventional x-ray equipment for veterinary use usually does not include dose displays and requiring such would be against graded approach. Even with x-ray equipment with dose displays (for example CT) establishing and using DRLs would be complicated. Either simple DRLs could be established as a function of animal weight or such for different projections, but these would be very approximate to a point of being useless. Alternatively, there should be a large quantity of DRLs established for different sizes and shapes of animals and for different projections, which would require a lot of data, effort and time. Such DRLs would not be simple to use for the end user and would require a long period to cumulate enough dose data of similar kind. Instead using an exposure parameter chart for different kinds of animals and projections or using built-in protocols with adjustments if needed, would enable for sufficient level for optimization.
682	The Commission recommends that an approach analogous to that applied for human medical exposures be developed and applied for veterinary exposures which includes a quality dose management program that allows for periodic audits, continuous peer learning, and use of incident reporting systems that capture incidents and near misses	This sentence can be interpreted as meaning that the aim of the ICRP is to develop a system of radiation protection completely analogous to that already available in human medical exposures. In our opinion, this is not in line with the principle of graded approach and, for example, audits and the setting of reference levels for veterinary X-ray examinations are not necessary. The general optimization principle is sufficient for such low-risk operations.
704, Fig. 3.2 and 1069 Table 1 and related texts.	Level 2 justification of a specific procedure is problematic because it considers the issue only from the animal’s perspective. As rightly written in lines 1048 - 1053 of the document, a specific procedure may cause also significant human exposure.	It should be emphasized more clearly that even if a specific procedure would be justified in the meaning of Level 2 justification (as it is now defined in the document), the procedure may be unjustified when also the risks to humans are taken into account.
707	3.4. Potential exposure pathways and practical protection strategies	Was surprising to see the very basics” time, distance, shielding" and the inverse-square law explained as part of this document. Is all this really needed in this document or could some of the material be placed in an Annex? Could we not assume that the reader has at least the very basic knowledge?
1105-1106	6.1.1. Justification of medical procedures	There is no indication whether this chapter concerns Level 2 or 3 justification or both. Please indicate somehow in the text which parts are relevant to which level of justification.
1173	6.1.3. Benefit and risk of radiological procedures	This chapter rightly discusses risks and benefits to be considered in the justification from many different aspects, including human exposure. But the levels of justifications L1 -L3 are defined through the harms and benefit to the animal. So, it is somehow left open how e.g. risks to human should be brought into the justification assessment, especially in case of L2 level? So, in addition to L2 assessment, an overall assessment considering also human exposure should be done separately (see also above my previous comment on the related subject).
1228-1230	The assistance of laypersons in radiological procedures is currently a subject of debate and will be further discussed in the following section (see section 6.2.1).	The term layperson is new. How it should be compared to members of public or workers in the ICRP 103?
1243	6.2. Optimisation	Surprisingly this chapter does not address the establishment of dose constraints for workers or members of the public despite dose constraints are discussed in chapter 3.3.2 as the basic tools for optimization. For example, it could be noted the need to set a dose constraint for pet owners taking their pet home after nuclear medicine procedure or treatment.
General comment	Regarding the justification and optimization ideology	The narrative on the guide about justification and optimization is strongly suggesting on implementation of these systematic approaches on a single animal, but then again is overlooking the equine prepurchase and general breeding related x-ray examinations as standard and acceptable procedures. These kinds of safety culture inheritances should also be looked through the justification and optimization procedures without giving “special approaches” to certain use cases of radiation in veterinary medicine.
General comment	Lack of scientific evidence	The draft report is missing the scientific evidence, particularly on stochastic effects of radiation on animals. The LNT model is mentioned, but the use of it has not been justified by scientific evidence. Moreover, the report is based on very limited amount of experience. There should be a solid bases of science, experience and ethics before giving recommendations.
General comment	Purpose	It is not clear if the purpose of the draft document is to give recommendations on radiation protection of veterinary medicine on the level of introducing how to apply the ICRP 103 on veterinary medicine, to create a new basic recommendation for radiation protection of animals or to give practical guidelines based on existing recommendations. IAEA has already published a Safety Report 104 Radiation Protection and Safety in Veterinary Medicine.

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