Dr. Tony Holohan:

I thank the Chairman and the members for their questions. I will work my way through the questions one by one if that is in order. I am happy for colleagues from the faculty to interject as they see fit in terms of what I say and some of the questions that would have been referenced to them. I always have the challenge of reading my writing with respect to the questions raised.

First, regarding the lack of evidence that Deputy O'Reilly raised around appropriate training, the reality is that we have no understanding of training arrangements for chiropractors in this country. They are not part of either the formal healthcare system or, to my knowledge, the formal education system. We are reliant on the statements they have made in that we have no means, or otherwise, of validating it. The reality is that they have not been part of our healthcare system. We have no issue at all with chiropractors, either as individuals or as a collective, but it has never been the case in our healthcare system that they have formed part of what we might call our formal healthcare system. We understand that we differ in that respect from the UK. I cannot honestly advise what the policy basis was for the decision to include them in the UK. I simply know that what was said is true in regard to its standing in the UK. That is not the case throughout most of Europe and most other European countries are in line with the situation here. Many of the points made and the questions raised here, and some of the evidence that was given earlier, to my mind relates as much to the existential nature of chiropracty as part of a formal healthcare system as much as to the specific question to which the committee is giving consideration. During the length of time I have sat on the management team of the Department of Health, which has been quite a number of years at this stage, this question has never arisen.

There was some consideration in the very early 2000s, of which some members may be aware, to the broad question of the inclusion, or otherwise, of a variety of different practitioners, who are not part of the formal healthcare system of regulation. Nothing was advanced in that regard. I cannot honestly recall what the nature of the consideration was around that question. The members might recall that it was part of a commitment, if I remember rightly and I have not read it in recent days, in Quality and Fairness, a health strategy that was published in 2001, but nothing was done to advance that case in specific terms to broaden the system of regulation. Our regulatory function in the Department has been focused on two broad areas in more recent times. One is strengthening the basis of regulation of a variety of practitioners who were already regulated.

The latter include the medical profession, the nursing profession, pharmacy and others where a number of different reforms including lay majorities and others have been introduced, with more public hearings, more differentiation between fitness to practice and poor performance and a range of things of that nature. There is a second strategic intention, which is to broaden the number of practitioners who would be the subject of regulation and those who are part of a formal healthcare system. That is the work which is under way under the Health and Social Care Professionals Council, CORU. The council is working its way through 14 different groupings, each of which would be the subject of a separate system of regulation and specification. None of that architecture or apparatus exists as part of our healthcare system. While I am not saying that we would not, we do not have any plan or proposal to look at that with regard to chiropractic. That is a statement of policy as is in the Department.

I have no knowledge of the iRefer guidelines to which Deputy O'Reilly referred. That is the first I have heard of such a thing. I am not in any sense casting any aspersion on those guidelines. I have never heard of them and do not know what they are. We will be back in touch on the matter and will respond to the correspondence shortly. The Deputy asked a question about the nature of the radiation safety committee. It will stay in existence until the directive comes into force and new arrangements apply. The HSE has, de facto, been carrying out competent authority functions which it is not effectively empowered to carry out and there is not an appropriate separation of powers between provider and regulator. The committee may be aware of this being a finding of the inspection done by the International Atomic Energy Agency in 2015 when it made some negative findings about arrangements here, including that, that there was not separation between the provider and regulatory function. We set out the plan that we had at this point to transpose this directive. We are doing this in our system of licensing, which members may be aware will be before them for pre-legislative scrutiny in the near future. We published the heads of that before Christmas. Each of these might provide a mechanism for us to strengthen the oversight and regulation that would apply in this area. The International Atomic Energy Agency endorsed that strategic direction for how we would propose to respond to the negative findings made at that time. This work is part of us finalising some of our obligations in that regard.

On Deputy Durkan's question about where this originated, it is a process of strengthening and consolidating a set of regulations and updating those that were previously in existence. That is my best understanding, as opposed to it being something that had a specific origin in a specific member state. It is part of a set of obligations that we now have, shared with the rest of Europe. We did not have any different role other than that we may have participated, as a number of experts from this country do, in the development of that kind of knowledge and capacity at a European level. That is what it would have emerged from. On the question of complaints, I am not aware that we have ever received a complaint about a chiropractor or, indeed, a GP regarding the conduct of an X-ray. I am open to correction on that but I do not recall ever hearing of one. The Department is not a complaint-----