ARPANSA fully supports the direction and outcomes for improving the training in radiation protection of appropriate healthcare professionals. After careful review of the document we have the following queries, comments and suggestions. General 1) There is no recognition of the degree of training variation required where; a) the physician/surgeon is working without a radiographer present as sole operator responsible for equipment operation, patient care and radiation safety, or b) the physician/surgeon is operating the equipment with a radiographer nearby, e.g. a cardiac cath lab or a surgeon operating equipment in theatre with a radiographer in the department but not actually present, or c) the physician/surgeon is performing the procedure with the equipment being operated by the radiographer. 2) There needs to be clearer defined requirements of the breakdown of training time for theory and practice. 3) Is this a one off education course or is it envisaged that further updating of theory and practice is required via refresher courses? 4) The document does not clearly define medical physicists working in radiology and nuclear medicine. It is suggested that the term ‘diagnostic imaging medical physicists’ be used to cover both disciplines. 5) The document does not reflect the ‘Australian’ situation where we have ‘rural and remote’ operators, e.g. general practitioners and nurses, of radiographic equipment who are at significant distances from specialist support, e.g. radiographers, radiologists and tertiary medical units. 6) There is an assumption throughout the document that a high degree of RP knowledge is automatically translated into a natural ability to be able to ‘teach’ the topic. There should also be some requirements/ assessment of an individual’s ability to be able to teach. 7) The Annexes go beyond RP training into some quite specific clinical decision making and applications, e.g. line 1299 and 1453-1456 Specific Comment per line number line comment 193 Could training be required/provided as part of an employee’s induction training program rather than at undergraduate or postgraduate level This education could also be provided via web based courses provided by regulators, institutions outside of any undergraduate or postgraduate program provided by academic institutions 195 Undergraduate training of radiographers/nuclear medicine technologists should adequately cover RP education and training 199 A broader definition of ‘practical skills’ 384 Who evaluates the training and how is it assessed – employer, professional society, regulator? 392 General RP education could be provided at employment induction and specific equipment training should be provided by the department where the practice is performed 456 In Australia the term ‘authorised’ is more generally used than ‘certified’ 487 Suggest the term ‘diagnostic imaging medical physicists’ 667 Local requirements could and should include ‘licensing’ and ‘authorisation’ 712 Add ‘regulatory requirements’ Table 1 No indication of time for theory and practical Definitions of low, medium and high CD & MDX should have a higher dose knowledge requirement, medium to high All foetal dose exposure knowledge should be medium to high Table 2 RDNM training hours have a very large spread – why? – 80 - 100 765 Suggest the term ‘diagnostic imaging medical physicists’ 772 Knowledge of diagnostic and foetal doses should be high 791 Clarify category references in Tables 1165 Specialist knowledge does not equate to teaching ability