Thank you for the opportunity to comment on a draft publication on Ethics in Radiological Protection for Medical Diagnosis and Treatment. I wish to submit the following comments.
Medical ethics is a mature disipline as outlined in the draft publication. The missing element, in my experience is relevant, usefull information related to radioation effects and risk.
I note the main point (Lines 149 to 161) that "Risks should be explicitly defined as those that we know with certainty, those that are potential, and those where there is uncertainty in the scientific community or that we do not yet fully understand." (Emphasis added)
Table 2.4 and lines 574, 575 seem to inflate the importance of the LNT model. The LNT model has been implemented as a prudent measure in the absensce of full knowledge of the scope and consepquences of [low radiation dose is not known]. The LNT model provides a prudent estimate of radiation risk at low doses to compensate for an absence of scientific knowledge. The LNT model simply provides an estimate of the risk of radiation exposure in the absence of "full knowledge of the scope and consequences" of that radiation exposure, on a hypothetical basis. This estimate of risk is only an input into the Principals of Justification and Optimistation. LNT does not prompt action, the full elements of the System for Radiological Protection prompt action. We reduce exposure of medical imaging consistent with good clinical practice on the basis of Optimisation
I submit that LNT is NOT a prompt for action to reduce doses in medical use of radiation. LNT is just part of the the justification process for Beneficence and Non-Malificence. The draft publication seems to overstate the role of the LNT model. I think this is a serious defect in the draft publication.
The draft publication does not seem to consider the ethical aspects of excessive concern about radiation risk. For example, the, not uncommon, occurrence of a pregant patient who discharges against medical advice to undergo computed tomogrpahy imaging to query pulmonary embolism in order to avoid the radiation risk to their foetus.The risk of pulmonary embolism vastly outweighs the risk of the radiaiton exposure to the foetus.
Case study 6.5: This case study should mention that the expected radiation dose for the foetus from the imaging is well below the threshold to cause an effect. A significant element of this case staudy seems to be related to the poor information provided by the clinician. In practice limited, or non-existent, knowledge of radiation risk in clinicians who are informing patients can be a significant issue.
Case study 7.4: This case study seems to have an implied criticism of the clinician in providing full information to the parents/patient (both in the document and in the webinar). This case study might be more informative if it also included an ethical compliance evaluation of the case where the clinicain did not inform the parents about the option of proton therapy. In laymen's terms the question that arises: Is it worse to tell the patents about an option that they may not be able to afford, or should they be fully informed?