Royal decree on medical exposure
Technical Reglements published March 2020
Technical Reglements Department medical physics
See FANC/AFCN website for detailed information.
Feedback from community:
In November 2020 FANC has asked BHPA to give feedback on the new legislation on medical exposure in the form of necessary clarifications amendments.
Two meeting have since then been held:
- 30/10/2020 with the RT-24 work group
- 16/12/2020 with the RX, NM and RT working groups.
We gathered feedback from the different disciplines.
In January 2021 a follow-up meeting will be organised.
Nuclear medicine:
Q1: Within the framework of the "basins de soins/ziekenhuisnetwerken" and the grouping of hospitals, what are the objective and quantitative criteria to define the scope of the work of the head of medical physics and how many institutions can he/she oversee ?
E.g.
- the number of devices on the different sites?
- the distance between the sites?
- the number of radiophysicists available on the sites?
Q2: How much FTE time does the head of medical physics has to devote to per discipline in case the head has multiple recognitions?
Q3: in the context of multi-site departments, can the local MPE be taken over under the aegis of the local medical director? In short, can the site MPE have the site medical director as N + 1?
Q4: It seems that the medical profession wants to keep the radiophysicist under its control and simply wants him to play an administrative role vis-à-vis the AFCN. Do you have a legal aid section?
Q5: Need for MPA for NM
--> Consult Claire Bernard for more info
Radiotherapy:
Q1: Clinical audits (art30):
This was introduced by college as good practice, based on peer review and voluntary basis. If mandatory, open spirit and mutual trust will be lost.
What if college does not support audits anymore?
External certified auditors: Who will certify, based on what criteria, reimbursement (centres support auditor-time, because return of investment currently)?
Internal audit team: minimum of 1 certified internal auditor (same issues as previous)?
Why only for radiotherapy (art30, §5)?
Q2: Dosimetry audits:
This was introduced by BHPA/college as good practice.
External dosimetry audit every 5 year.
Good practice for every introduction of new equipment --> Suggestion to have mandatory basic dosimetry audit before every machine is put into clinical practice for every used energy (photons and electrons)
Problem is continuity: BELdART (currently funded by college), ROC, … should be available.
What about RX/NM?
Reference dosimetry needs to be calibrated every 2 year, traceable to primary standard. What if VSL, SCK, … can/will not provide service?
Q3:
Why different measures for different disciplines?
Art 36, §3: MPE RT needs to be physically present during treatments. Will require more MPE RT (compensation overtime, hollidays, satellites, illness, …)
Art 57: Proactive analysis of RT actions (ie FMEA). Again, this is a lot of work, and again why only RT?
Art 60: Deviations of 10%, 20%, … Not specified if this refers to PTV, GTV, OAR (critical OAR …), global-local … and again … why only RT?
Q4:
The head medical physics is Always male …
Art 87 - 96
Q5: MPE:
Clinical internship, what if academic supervisors are not available?
New core curriculum MP and MPE, what if internship 2 years (payment, attractive for future candidates, what if no candidates?)
MPA:
"Credits" for RTT’s, "hours" for RTT (gemachtigden)?
Training program does not exist (20 SP?)
Tasks and training specific for RT, what about RX/NM?
What about ICT (scripting, SW upgrades, network issues, … and technical support (in-house engineers)?
Q6:
Add list of exemptions for secondary mandatory dose verification (Article 8§2-§4)
IORT, including IOERT and kV-based techniques
prostate LDR brachytherapy, PDR HDR
kV contact therapy,
Ru-106 eye plaques.
Remove mandatory presence of MPE during Eye plaques treatment
Q7: Delegation of tasks to MPA: What about e.g. invivo dosimetry? Everybody that does it is MPA? Then every RTT is MPA…
--> Consult Frederik Vanhoutte and Jan Vandecateele for more info.
Radiology:
Q1: Two optimisation projects per annum - responsabilities not clear in that respect (per department, per modality, e.g. C arm in pain clinic?)
Q2: technical reglement of fluroscopy has al lot of errors.
Q3: Training MPE: fixed sequence of academic and private center internship?
Q4; need for MPA for Radiology
--> Consult prof Hilde Bosmans en prof Klaus Bacher for more details
Royal decree on medical exposure
Technical Reglements published March 2020
See FANC/AFCN website for detailed information.
