If Medical Engineering services are outsourced by an organisation, anyone employed as a Medical Engineering Technologist will require to be registered.
I think the point that's being made in earlier postings is that 3rd parties are unlikely to employ individuals with a protected title unless they are obliged to. The NHS, once its employers are required to employ Medical Engineering Technologists regulated by the HPC, under the legislation that exists, will have to employ some under the protected title "Medical Engineering Technologists" carrying out jobs defined by the scope of practice.
The only way around the possibility of a discrepancy, between the requirements placed on 3rd parties and those employed in the NHS, that I can see working, is that the NHS as a customer could specify that only registered Medical Engineering Technologists are employed by external contractors to work on medical devices on NHS sites - since the NHS would be legally obliged to ensure that anyone working within the scope of practice on behalf of their organisation is regulated.
Isn't the whole point of regulation to protect the patient from harm and the employer (or purchaser of technical services, e.g. NHS Trusts) from financial risk and reduce the associated liabilities? This is meant to be achieved by ensuring that those employed as Medical Engineering Technologists working within the scope of practice have appropriate Education, Experience and Training before they are allowed to work on medical devices, as Jim Methven states.
If external providers of technical services, i.e. 3rd parties, are not regulated and continue to be allowed to work unregulated on medical devices that are used on patients, within the NHS, then HPC regulation is a non-starter in my opinion since it leaves a loophole that works to the disadvantage of existing NHS employees and employers plus it makes a mockery of the notion that HPC regulation protects patients and reduces liabilities for healthcare providers.
Finally, can I re-iterate that the VRCT comprises representatives from the IET, ART and IPEM. It is not an organisation run by IPEM or Medical Physicists. It is a standalone regulator which uses IPEM staff to perform administative functions.
I think this is important - anyone, in any of these organisations or others, who's eligible, are entitled to join the VRCT. Membership of IPEM, IET, ART is not the issue - the fact that regulation is likely, is the issue, so individuals need to decide what they're going to do about it, i.e. find out more about the facts, join, ignore it, whatever. It is voluntary but my personal view is that whoever administers a VRCT will most probably have to transfer it over to the HPC who will almost certainly regulate those working in the NHS.
