I send this comment on behalf of the Associazione Italiana di Fisica Medica e Sanitaria (AIFM-Italian Association of Medical Physics). The AIFM represents more than 1300 medical physics experts working in Italy in public and private hospitals. I thank ICRP for writing the document "Optimization of radiological protection in digital radiology techniques for medical imaging". In general, we agree with the content of the document, which addresses many important points that can help strengthen the application of the optimization principle in the hospital settings (for example, the issue of providing adequate staffing levels to ensure safe and optimized use of X-ray systems).
We send one comment that we hope will help improve the effectiveness of the radiation protection system in the hospital setting.
Comment
Actions that ensure the radiation protection of workers and members of the public are often strongly interconnected with those dedicated to the radiation protection of patients. This point is also addressed in the ICRP document currently open for consultation (lines 136-137, page 4 "The radiation dose levels that patients receive also have implications for doses to staff”).
The actions undertaken to protect staff and the public from the harmful effects of ionising radiation may not be aligned with those to protect the patient. In practice, in many hospitals in Italy medical physics experts assume the responsibilities for the physical aspects of radiation protection in hospital settings, including patients, working staff, members of the public and visitors. In these cases, radiation protection management, which includes all the actions necessary to ensure radiation protection for all, is simplified, less expensive and more effective. Moreover, in this way the responsibilities are clearly defined.
In light of the above, we suggest the following text modification.
Line 418, page 12: to add another subsection between subsection (8) and (9) with the following content.
“Actions that ensure the radiation protection of workers and members of the public are often strongly interconnected with those dedicated to the radiation protection of patients, including optimization. To ensure a more effective and simplified radiation protection for all, in the optimal scenario the medical physics experts should be the healthcare professionals to supervise and assume the responsibilities for the physical aspects of radiation protection in hospital settings, including patients, working staff, members of the public and visitors. In the case of large hospital settings, these duties can be carried out by unit/department of medical physics”.