Dr. Niall Sheehy:

I thank the committee for inviting us to attend. The faculty of radiologists is the professional training body responsible for the training of radiologists and radiation oncologists in Ireland. Our members are medical doctors who have pursued specialist training of at least five years' duration following their medical degrees, are deemed competent via a series of examinations and assessments and are ultimately included on the specialist register of the Medical Council.

We are concerned with the safe and appropriate use of radiation in medicine to accurately diagnose and treat patients. We hold positions on national and European committees that are concerned with radiation protection. We stay abreast of technological developments to ensure we are practising to current international standards to deliver the safest care to patients in Ireland. We must participate in continuing professional development, quality improvement and audit to maintain our registration with the Medical Council.

Radiologists and radiation oncologists meet the definition of "practitioner" in the new basic safety standards legislation and oversee approximately 2 million examinations per year in this country. We work alongside non-radiologist doctors, radiographers, medical physicists and nurses to ensure that radiation doses delivered to patients are as low as possible. This is known as optimisation. Patients are sent to us for radiologic investigation by medical doctors or nurse referrers for radiologic investigation. These are known as referrers. We perform the study if we believe the request to be necessary and appropriate on the basis of referral criteria. This is known as justification. In some cases, we may decide that the risk to the patient does not justify the exposure to radiation and we suggest an alternative investigation. Even at low doses, radiation carries with it a theoretical risk of inducing cancer. All the professionals we have described are registered members of organisations in this State that demonstrate commitment to training and accreditation. They participate with radiologists in hospital radiation safety committees and in research and audit. The recent development of the nurse referrer role is an appropriate model for how to incorporate a new regulated allied health professional into the radiology process. The training of nurse referrers includes the principles of radiation safety and referral. Their practice is audited by local implementation groups.

The committee is focusing its attention on whether chiropractors should be included in the legislation as referrers or practitioners. When compared with the trained and regulated healthcare professionals previously described, we have found no substantive evidence of appropriate training, referral criteria, audit or accountability in published literature from the Irish chiropractic community. We have no knowledge that the criteria and standards set out as basic in the directive by the European Commission are being met. We would not regard the self-audit of 2011 as evidence of such. While we are aware that some chiropractors are practising in a manner that is comparable to referrers and practitioners, this practice is outside the current legislation. There is no current legal basis for chiropractors to act as practitioners. This practice has only been maintained because the current legislation has no enforcement provision. Some radiology departments have performed radiology examinations on chiropractor patients. In such cases, radiologists have judged that the clinical circumstances for radiographic exposure are appropriate and have taken on the onus of becoming the patients' referrer, which is allowed for under the current law. It is important to understand that the chiropractor is not being considered to be a referrer. The radiologist is obliged to follow up the patient if significant findings are detected and further medical treatment is required.

The faculty of radiologists is of the opinion that when people operate outside the law, they make it difficult for those of us who operate within the law to compete for radiation safety resources and equipment, to motivate training of workers and to promote best practices. The faculty of radiologists regards the oversight of a regulated medical or dental practitioner as essential in ensuring patient safety. We regard any system of radiation protection as incomplete without clinical governance structures, appropriate training and audit. We fully support the Minister's position that such basic safety standards are available for Irish patients, as demanded by EU Council Directive 2013/59/EURATOM. These standards were first incorporated after the directive in 1997 and legislated for in 2002. The new directive raises the bar on such requirements. People who did not meet the standards and operated outside the law in 2002 are not likely to meet the higher standards of the new legislation. We regard the provision for enforcement by the independent regulator, HIQA, as the major difference in the new legislation, which the faculty of radiologists wholeheartedly welcomes.