EBME Forums Forums Management Professional Issues Agenda For Change Voluntary Register ?

Not as sad as me, obviously! But well written, all the same.

No Kevin, I disagree generally with your statements, I think it's about time the NHS sorted its own staff out before trying to solve the worlds problems. The NHS and HPC is not, and will probably never be, in a position to regulate the Manufacturers and 3rd party service agents in the same way that regulation of a profession can be applied to NHS employees. At the moment the NHS is leaving junior and middle managers in EBME and Medical Physics to essentially dictate the level of service, staff qualifications, skills, experience, training, CPD, etc, etc, at the local level and I think this is not good enough.

This carries across to discrepancies in gradings and the work carried out by individuals as well. It's a job-role, qualification, experience, skills lottery for individuals working on similar grades at the moment - a free for all, dog eat dog, dead mens shoes setup - what's needed is a modicum of order and some uniformity in the provision of basic services provided so that customers in any NHS hospital, whether its a large teaching trust or a cottage hospital, have an idea what EBME and Medical Physics Technologists do and what they are capable of at a certain grade or level. Of course regulation should not be intended to interfere with the requirements of local organisations or with local management decisions but it might go some way to ensuring that most of the technicians have a core background of knowledge, level of skills that's been assesssed and the same chance of progressing based on ability into appropriate grades by performance based on assesment hence attainment rather than patronage.

Manufacturers standards, European Directives and Quality Systems are mandatory and already in place for Medical Device manufacturers to comply with I believe. This includes equipment servicing, QA, etc, etc. This is an attempt to ensure that the devices are designed, manufactured and even serviced to the appropriate standards. Thats the idea of MDD, ISO and all of these other organisations that we all should be aware of.

I don't believe anthing like this currently exists for Medical Physics or EBME, currently relying on staff attempting to follow sketchy guidelines, etc, etc, without adequate guidance and support via professional networks, etc, etc, and if it does (in larger Medical Physics Departments) then it's not being applied across the workforce (what about EBME?). Hopefully a uniform curriculum for student technologists would provide the knowledge based aspects of the job, including legislative, device regulatory, management, etc, etc. I see professional regulation and the baggage that comes along with it as the only means of working towards achieving that aim, applied across the workforce.

Having said this I do think the 3rd party organisations need to be regulated in soe way to match the levels proposed in the NHS rather than hiding behind Quality Systems that are, in my experience, generally tailored to pass the external audits and little else in practice - otherwise the system of regulation in the NHS, setup to protect patients when all's said and done, is circumvented as I've said before. It's about time managers in EBME/Medical Physics departments were forced to sit down and think harder about what qualifications, experience, skills and whatever training is required, what the job is all about and what services they could and should be providing; rather than just consider qualfications, training and CPD a personal issue for individuals to beg for or weigh it up against the demand for "bodies" justifying a "bums on seat" attitude irrespective of candidates suitability.

Yes we need the support of Manufacturers training but that is CPD and support materiels, just like tools required to do the job and not required to become fully qualified as a professional - it is not the be-all and end-all. The core competencies and hands-on skills are with technologists forever - the manufacturers courses are only useful for the life of the equipement. Sometimes I think we all place disproportionate value on manufacturers courses; some departments even make the quantity of manufacturers courses attended by individuals the key issue when considering grading - shameful. Recognised vocational training is what we need with a level of qualification and skills that allows us to contribute at the same level as other staff in healthcare. Otherwise the skills are not going to be recognised.

The provision of core skills and ongoing CPD should not be a lottery based on the whims of an EBME manager at the local level. If there were mandatory basic requirements then every technician would be starting from the same point and continuing to develop into whatever role they're working in. It's alright for those having been in a position to develop their careers and lever meaningful, recognised, qualifications and training and status primarily because they manage to attain a grade that ensures they can manipulate the system and get what they want - what about the career prospects of the majority who don't wish to rely on a lottery but want a system setup that ensures everybody a decent career?

Frankly, Richard, the whole of engineering services in the NHS is in need of a massive overhaul! But especially medical engineering services (which I will now label MES), which, as we all know, have simply evolved, with hardly ever any real planning input.

What I believe is needed is a complete re-think of the whole scene. I would like to see an NHS-wide MES philosophy of “giving the customer the service she actually wants”. The clinical staff need a Total Technical Service (TTS). They needn't care where it comes from, or who provides it, as long as it is there at their beck and call. It should all-embracing (ie, including information services, repair and maintenance services, asset management, the supply of equipment “consumables” such as cuffs ECG paper, training etc. etc. – yes, the whole nine-yards). A one-stop-shop for all the users' equipment needs and problems.

Only when the customer's needs are totally met can people start talking about a “quality service” (after all, that's what it means). At the moment all NHS nurses get is a service which, shall we say, varies greatly from hospital to hospital (ie, from rag-bag to excellent – why is that the case, by the way, in our National Health Service?). Step 1 – set up a Directorate at national level, give it a mandate, give it some “teeth”, and then set it some targets (I think all this is called “management”, isn't it?).

But it will never happen. Why not? Because it would mean at least a doubling of technical manpower, plus a load of proper training, and funding for all that will never be available. And that is why we will still need to continue to “muddle through”, doing our best, and all the rest of it, in the time-honoured British manner. Stiff upper lip, don't you know, Old Chap.

MES to TTS? Not in our lifetime, Mate!

Qualified techs / engineers delivering a quality service. I think this is happening across the NHS already. Uniformity is a good idea Geoff (as in the forces) but how do we do it? Through state registration? Maybe it will help.
A handbook on How to do it? How many corporate [NHS Exec] instructions and policies get implemented at a local level? Some do. Institute lead change. ??

My personal feeling is that the voluntary register will happen within 5 yrs. Will it help? Only time will tell. Did i have a say - NO! Not Until i reported it to the IIE about 4/5 yrs ago and we requested that IPEM consult our members. Even then i don't think enough stakeholders were consulted.

Did you have your say? Probably not.

Was there sufficient stakeholder input, probably not.

Can we still influence and change the process? Yes - we as a website community have the lobbying power to influence change. If someone in our EBME community wants to take up the mantle, I am happy to arrange a meeting with a voluntary register representative from AIME. Any volunteers?

Lots of Graemlins in play there, John!

Of course they are many good people about delivering (and many more or trying to deliver) a quality service. But there are some not-so-good ones as well. Yes, lack of uniformity.

But I can't see that “registration” is bound to improve things at all. To me, all that is missing the point by, oh, a league or two at least. Institute-lead change? Doubtful.

A handbook? Why not? Any “quality” department should already have a Policies and Procedures Manual, surely? Basic stuff, I would have thought (… yet I know some don't have them). A handbook issued by the Directorate could help, if it had any weight behind it.

Yes, this very website could make a difference (I believe it already does), if only more of the blighters would say their piece instead of just lurking!

So, how do we make it happen? I reckon that if our beloved modern government set targets for the completion of hospital equipment PM, that would be a start.

Frankly, and I know that this will “stir the pot” a little (and why not?), the only way for change on the scale required is privatisation (oh my, the dreaded word)! When you have a contractor, you can make him perform to the letter of his contract (and, the skill on the part of the hospital trust is in the precise drafting of the contract).

Witness the success of PFI – at least we are now seeing some new infrastructure, fresh designs and some new equipment. On the other hand, it's sometimes difficult to “motivate” NHS staff to implement change from within, or so it would seem. Too much invested there in the “status quo”.

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.

I understand the point of basic core competencies and Mr Ling feels registration is the way forward. However, I feel that a good case has not yet been made and that there has been no consultation. I am unconvinced by the arguments presented to date. 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. All systems are only as good at the people and their motivation, and that has a lot to do with the quality of local management and leadership. I do agree that a well defined career path may be a good thing. But what is this career? Is it not different from Trust to Trust, and company to company?

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. The HPC is not NHS specific. This is why I do not feel it is an appropriate model. So unless the statutory instrument is changed all unsupervised medical engineers in the private sector and NHS will have to be registered. I again ask how many medical engineers on the VRCT were from the private sector and hence how valid was the vote?

Another point is that CPD is the registrant’s responsibility and not that of the organisation or even the NHS. It the registrant’s responsibility to define there own CPD requirements! The HPC have made this absolutely clear at all the CPD consultation events I have attended. A registrant can use a recommended CPD scheme (e.g. by a department or institution) but does not have to! It is up to the registrant. So it is unlikely that there will be some uniform CPD and therefore competency, if you feel that CPD will relate to competency. Only a sample of registrants will be randomly selected each year and asked to present their CPD portfolio.

What is the role of the manufacturer in deciding what maintenance should be carried out? What is our role as medical engineers? This is interesting and debatable. For example, in the case of deciding how many service visits to be carried out. Should we have to follow the manufacturer’s guidelines or do we use our own knowledge and skills and risk assessment? This is was one of my main points i.e. that it is extremely important that lines of responsibility are essential and the legal position is well defined. I am sure that in any legal case device specific training would be a very important issue.

I feel that Geoff makes some very useful points and would like to thank John for the offer regarding contacting a representative on the VR. I am unsure this is the right direction for me to take at the moment. My main concerns are with the DoH and the HPC, as most of my questions so far are about the process that the HPC was supposed to go through. I feel they have not followed many of their own guidelines.

Sadly, I have to go now as I am quite busy. Hopefully, I will be able to pop online now and then follow the thoughts of those individuals concerning this debate. I am looking forward to the consultation phase as promised by the DoH that has to take place through the regular NHS lines of communication such as SHAs, the MHRA, Trust Executives, HR, and Unions etc. Hopefully, we will then have an opportunity to put our points forward and get some real answers to some very important questions.

Best regards to all

Kevin

Sealed with a sigh…..

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:

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”.

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.


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.

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”.

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.

Mornin’ Richard,

Another fine piece, I see!

Whilst not wishing to spend too much time on this issue on such a fine Sunday morning, I’d better just mention that my own views on registration, voluntary or not, are in fact quite plain.

I regard the whole issue as one of the most appalling bureaucratic “red tape”, that will have absolutely no positive bearing on the real issues of developing or promoting our “profession”.

To go a little further, I fear it may even make matters worse by actually driving out the very people which I believe are in fact most needed (and for which I, personally, have the highest regard), videlicet, the “hands-on fixit technicians working in healthcare”!

I realize that all of us in “modern Britain” have been conditioned to believe that we need to be regulated incessantly for our own good, but I do not accept such things with just a shrug of the shoulders myself. Old School, I’m afraid, Old Chap. Ex-Arborfield Boy, don’t you know?

And as I have stated publicly before, my own stance is when I am prevented from working by not having some meaningless piece of paper will be the day that I shall stop working in this “sector” all together (to be honest, I often wonder these days why I didn’t get out years ago).

We are not, by the way, “Clinical Technologists” (well, most of us, anyway), but are nevertheless proud simply to be engineering technicians who happen to work, for the most part, in hospitals. And what’s wrong with that? Is that not good enough for you?

Lastly, I see little point in adding further to the buckets of megabytes already wasted on this topic, and therefore rest my case. Hmmph!

Hi Goeff,

Somehow I get the impression you think I and others of similar dispositions are "hands-off" technicians, if you do then you're wrong, you're barking up the wrong tree with that one. I've always worked on the bench, "hands-on" as it were. However, for my sins I do have a genuine interest in the really technical aspects of electronic engineering, physics, clinical aspects of the job and I'm always available for the clinical staff if they have issues - backed with formal education and knowledge, of course, if anyone asks.

Actually there is a need for something more than a "fixit" technician - there always has been - if you haven't noticed the changes then you've been out of it too long elsewhere in the nether-regions.

I guess I was one of those earnest young technicians you were talking about a while back the ones that are motivated and interested and I've never even worn khaki undies. However you can't expect everybody to be inclined that way so I guess the employer has to set minimum standards and if that's not satisfactory then the state does.

I certainly don't see having to develop in a job role or give evidence that I know what I'm doing as red-tape. It's a necesary and responsible attitude in this sort of job. I don't actually think it will have a massive impact on me. Hopefully I will meet the requirements and the new starters will progress through the system until they attain registration. What it does mean is that others currently in the job will have to do the equivalent of meeting the requirements of the VRCT as well, whether they like it or not, if they're employed in a role with a protected job title.

I must say that the impression you give is of one of those individuals, nearer the end of their career than the beginning, that doesn't want to pull the system into a cohesive, effective, service - a maverick perhaps, out on their own. Some individuals like to see a bit of chaos around them so they can make opportunities for themselves I suppose. My interests are with the NHS Clinical Technologists, whatever their background, coming together as a group with a career ahead of them if they want it.

If regulation is about getting a decent slice of training, some status within the NHS, a protected job-role that prevents those that are not up to it spoiling my day, eventually influences salary and I'm already eligible as are many others with similar backgrounds then I'm all for it (subject to any consultation and committee of course).

Oh, Richard, if only you knew me better! Then you’d have to grudgingly admit that few have laboured so hard to create order from the chaos.

And, yes, as I am one of the few, I expect, who actually wade through all of your missives, I do recall that you have often stressed your “hands-on” approach. That’s the reason I bother responding to you, Old Thing!

Perhaps you could glance at my own dispatches occasionally. Then you would see that we’re more or less “on the same page”, as it were, you and I (but someone has to play Devil’s Advocate, you know).

Pity you were never at Arborfield, though (your loss, I’m afraid). I would have enjoyed beasting you around the square!

A maverick, perhaps, but a benevolent one I dare say.