To all regarding registration of ‘Clinical Technologists’

I have very grave concerns about the proposed registration scheme. There is clear political agenda to register healthcare workers. However, those staff who maintain, repair and service medical devices are basically engineering staff - with engineering qualifications. They are not healthcare workers as more usually considered by the Healthcare Professions Council (HPC).

Engineers already have a registration scheme under the Engineering Council take a look at there web site

Be absolutely clear the Institute of Physics and Engineering in Medicine (IPEM) are responsible for this registration process proceeding as a result of a petition they have made to the HPC (I have been unable to get copy despite a promise by the HPC to send me copy). I personally feel that IPEM do not have the engineering credentials to be placing such a scheme forward and that the Institute of Electrical Engineers (IEE) should be involved as they understand all the issues involved as they are more commonly involved in national and international standards! Prior to 1992, IPEM were the Hospital Physicists Association, they then renamed themselves to the Institute of Physics and Science in Medicine and then in the mid nineties again named themselves to IPEM. I also believe the HPC do not understand the engineering (specifically commercial) issues as they are only used to dealing with healthcare workers.

It is important to remember that only 722 people voted for this on IPEM’s voluntary register to go ahead (only 51% on the register voted at all). Most of our staff knew nothing about this voluntary register. Few appear to understand the wider implications, questions and personal cost, as this debate has not happened. This number of people must represent a tiny proportion of the staff in the NHS and commercial sector involved in the maintenance, repair and service of medical devices.

I have made a wide range of comments and asked numerous questions regarding this process directly to the Chief Scientific Officer, Professor Sue Hill (whose background I believe is in Pulmonary Physiology). I have yet to get satisfactory answers and have had to resort to contacting my MP. For those that are interested I suggest they take a look the document I have prepared for the IEE

My chief concern is that there has not been sufficient consultation with all the various stakeholders. Regarding the meeting on the 26th of November which IPEM mention on their web site regarding consultation and agreeing a minimum qualification: Only one union was represented (AMICUS), and not UNISON i.e. the main union that usually represent our EBME staff. Although a member of AIME claimed to represent the IEE I have confirmed with the IEE policy unit that this person was not capable of representing the IEE when it came to matters of policy and registration issues etc.

See: and

I have contacted Professor Sue Hill office to inform her of this situation. The meeting to discuss all the issues with all the stakeholders was only given approximately 1 hour and I have been unable to get the minutes!

There are many commercial companies providing maintenance service both in house and as manufacturers and suppliers. Yet that has been no consultation with the commercial sector! Where occupations are regulated by the HPC the same staff in industry must also be regulated – This is how it works!

My department directly competes with these companies. It is untenable that our staff will have to be registered and yet externally companies would have to have no qualifications whatsoever.

Also I feel the requirement for a new registration scheme has not yet been addressed sufficiently. The IPEM suggest that because engineers work on medical devices that they can cause harm to the patient. The same argument would apply to electricians and plumbers in the NHS, where does this argument stop. Almost all medical devices demand the user carries out checks before the equipment is used and the equipment is designed to rigorous international standards to ensure that user can ascertain whether the equipment functions correctly. I would like to see the statistical evidence (not hearsay) to show that EBME staffs have directly caused harm to patients as a result of poor maintenance. To date none has been presented by IPEM or the DoH. If there is evidence it should be available through the much more complete adverse incident reporting that is now demanded by the DoH. This registration has a potential to be an expensive exercise for no purpose.

Apart from the existing Engineering Council registration scheme many EBME departments have invested heavily in externally audited quality systems such as ISO9000. Staff competency is an essential element of these systems.

Again as many have highlighted, this is not a criticism of any individual but about concerns over a process that appears very poorly defined. In my opinion this is not an issue with IPEM as they do not represent many EBME staff, especially on employment issues. It would be unthinkable to bring in a new registration for nurses, for example, without consulting the nurses unions. I am deeply concerned that this registration could have a negative effect on the service our department delivers and the ability to get good and suitable staff. I am concerned that we may create some administrative and expensive monster that actually prevents in-house services competing with external companies. This is a very political issue whether we like it or not.

This registration process must go through public consultation; it is not yet set in stone. This is a fundamental part of the process of HPC registering a new occupation. If you feel you have any issues or comments my advice is to engage in the process and contact the DoH and HPC, the Engineering Council, your union or the IEE or any other body you may be a member of and make them aware of any concerns you have. You could copy the comments made here and forward them on.

I hope that you find these points useful and that you all enjoy and join the debate directly and get involved in the consultation with the HPC and DoH and contact your representative organisations such as unions etc. This is a very challenging issue.

Dr K R Haylett PhD,CEng,MIEE

Principal Clinical Scientist
Contract& IT Manager
Medical Engineering
Manchester Royal Infirmary
Oxford Road
M13 9WL