Geoff, John, Kevin,
From your comments I’m not certain whether any of you actually have any straightforward views on regulation, or at least opinions of it, whether it has the potential to be good or bad for the Clinical Technologist profession that’s being proposed based on how other NHS professionals are regulated. The discussion should be about how we can contribute to the standards that are to be set - academic qualifications are now out of our hands since the HPC has made that decision. However the way that training, experience and CPD is attained is still up for discussion perhaps. Regulation is likely to come into effect in the NHS, sooner rather than later, irrespective of all the talk of committees and consultation. That's the way of the NHS, for good or bad, and the HPC has the cooperation of the NHS in this matter I believe.
My response to comments made are that before getting into the debate and flinging provocative statements or expressing their views I think it would be useful if individuals declared their interests with regard to whether they’re working as employees of the NHS, whether they have associations and interests that lie in the private sector, or whether they currently provide services that could be adversely affected by regulation. Then we know where they’re coming from, so to speak. I have been quite clear in my views taken from my perspective working as a direct employee as a Technician the NHS who meets the requirements of VRCT. I have my reservations and I've mentioned them previously. Considering Kevin's valuable contribution to the discussion:
“Regarding registration, I am not sure that one size can fit all. Local managers will probably always need a role to be flexible at some level and have different views of what is required for their local Trust. The histories of most medical engineering departments are quite different as are the services they provide.”
Yes, but if that's the case then perhaps minimum standards, assessed within an independent framework of regulation, ensure the level of education, training and skills of technicians that managers have to work with. Beyond that registration of individuals should convey to potential employers, colleagues and the public at large, that the registrant has been assessed as fully qualified. Though perhaps you consider the requirements inappropriate. There is no doubt that, currently, the process of assessment of individuals’ status, whether they’re fully qualified, is quite subjective and made at the local level, to local standards. In my opinion there has to be a minimum standard set by the employer across the workforce, nationally. The workforce is more mobile than it has ever been, exactly because there are contractors, private sector staff, OEM representatives, etc, etc, I think there needs to be a minimum standard applied by an independent organisation affiliated to the professional institutes that cooperates with employers to ensure that there’s evidence to prove that all are capable before they should be allowed to practice in an occupation within which individuals purportedly “have the capability to do harm”.
“The HPC role is to regulate people (not companies or organisations) and includes all individuals in the NHS and private sector in the same occupation.”
Yes that is probably the intention and what I’ve said is that, in my opinion, the HPC is in a position to regulate the NHS workforce in a way that it’s not likely to be able to regulate the private sector; it’s more likely that the NHS will cooperate fully. The HPC is only concerned with regulating people in the same occupation with protected titles; what I’ve suggested is that the NHS will probably be inclined to use regulation hence use protected titles for individuals working in certain areas of medical equipment maintenance whether we like it or not. This is likely to place the obligation on NHS departments to employ individuals with the relevant education, training, skills and experiences in responsible positions in a job-role with protected titles; as is the case with other regulated professions. I can only take my views from my own experience, the experiences of other regulated professions in healthcare and knowledge from the perspective of a technician working within the NHS.
“If the current quality systems are something to hide behind, as Mr Ling suggests, I am in no doubt that registration will sit neatly in line – and right in front.”
In the context of personal training, skills and experience I have no doubt that quality systems are as good as any other system in recording facts. However the point I’m making is that quality systems are not required to set standards or perform objective assessments of individuals’ level of skills and competence and I don’t believe that the intention of Quality Systems, in this respect, is equivalent to regulation. In fact they cannot be equivalent due to the fragmented nature of Quality System implementation and the inconsistencies in how they’re implemented across the NHS organisation at the moment.
“What is the role of the manufacturer in deciding what maintenance should be carried out?”
They are the originators of the equipment hence they determine that maintenance requirements as required by MDD legislation, guidelines, quality systems and manufacturing standards. If the manufacturer is unable to provide the information on servicing or it is unsatisfactory then, in my view, it is even more important that technicians in the NHS, in particular, have the core skills generic training and experience to recognise what’s good and bad practice and act on it. My view differs from others in that I believe all Technicians should have the core knowledge to contribute to or actually make these decisions once they’re fully qualified, not just an “elite”.
“I am sure that in any legal case device specific training would be a very important issue.”
The point is that the manufacturers course itself does not necessarily confer the basic skills to do the job (these can only be assumed by the manufacturer giving the training) and the attendees attainment of knowledge and skills obviously needs to be assessed appropriately by trainers who are themselves recognised as being fully qualified. A similar argument would obviously apply to the level of skills and generic training plus experience that an individual has. If an individual had attended a service course for servicing, high-risk, possibly life-support equipment, a ventilator for example, and subsequently there was an incident involving a ventilator serviced by that individual then I have no doubt that questions would be asked concerning the abilities of the individual, irrespective of the manufacturer’s course. Evidence would be required in a legal setting.
If, under regulation, that individual was then found to have inappropriate technical qualifications, insufficient experience, training or a lack of evidence of attainment of skills under supervision of fully qualified trainers, when compared to the standards for registration in the industry, then I’m certain this would become an important issue for the employer as well, irrespective of device specific training by the manufacturer. In fact, for critical devices, such as those involved in life-support or anaesthetics, more reputable manufacturers do actually specify certain levels of experience and qualifications before individuals can attend courses (perhaps this is not well known or rigorously enforced by manufacturers) also, as far as I’m aware, Manufacturers generally have requirements in the front of their service manuals for the minimum standard of qualifications for those servicing equipment. No one actually regulates this but I’m certain in a legal setting then this would become apparent.
It would be remiss of an employer to allow an individual without a defined level skills, training and qualifications, i.e. not fully qualified to the minimum requirements, to be expected to work on equipment without any supervision from fully qualified staff. The problem we have at the moment is deciding what the minimum standards should be. I am certain there are discrepancies nationally in managers’ opinions on this. The problem being, currently, that each department sets its own requirements for core skills, competencies and the amount of manufacturers training, if there is any at all. This leads to inconsistency in core-abilities and a lack of uniformity in the workforce minimum standards.
I think I’ve exhausted my own hopes and fears regarding professional regulation with respect to standards of training and assessment of competence – it would be more interesting to hear others’ views on regulation in the context of the original thread i.e. how it might affect those of us that are not registered in future or can’t give evidence required by organisations that are regulated of our competence.
