EBME Forums Forums Management Professional Issues Registration and Consultation

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 http://www.engc.org.uk/

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 http://www.medeng.net/IEE_Report.htm.

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: http://www.iee.org/Policy/ 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.

Interesting post. To pick up on a couple of points whilst cogitating on the rest, Amicus is MSF and I believe that the IEE are co-supporters of the VRCT.

Bravo Dr. Kevin! At long last we have some clues to the answers that have often been asked on this website, and in other forums. Many of us agree that we are engineers, not clinicians (we have, after all, engineering qualifications, not clinical ones). And yet some unseen hand (people I have met refer somewhat vaguely to new “government rules”) is bullying us into meekly resigning themselves to the fact that “registration is inevitable”.

So, what about the non-NHS service people? Some of these guys work for private companies resident in NHS hospitals. What about agency engineers working in EBME workshops – do have “have to” register in order to work, or are they classed as non-NHS?

Come on Brothers, if these people cannot answer the questions, let’s kick it out!

Is that the IEE or the IIE?

Thankyou Techman for the details regarding AMICUS. All our staff are members of UNISON, who were not represented at the meeting. I have updated my original post to reflect your point.

However, I talked to the staff of the IEE Policy Unit, personally, and they were unaware of the registration details, even if they had at some time been co-supporters as you suggest. The IEE will bring this up at the next Healthcare Technologies Network Executive Meeting.

I do think it is interesting to compare the IEE site with that of IPEM.

I also feel that it is vital we consider this concept of registration with the necessary rigour that would be required for any national and international registration process. There are legal and commercial implications for european and international companies etc.

Kevin

Well said Dr K, Who's idea was this anyway? I am already regulated as an engineer by the Engineering Council, I am not a 'Technologist'and do not match their job discription i'm a Medical Engineer ,What is this all about?,Do we just sit here and let it all happen with no input or consultation.

Hi Dr Kev and hopefully just answering Bob on his post.

The main reason I see that the IEE have never heard of this regulation is primarily because. The VRCT is adminstrated by the IPEM in partnership with the Association of Renal Technologists, and the wait for it Institution of Incorporated Engineers.(Yes read from the certificate I know.) Anyway so no wonder the IEE have never heard of it.

As I see it, the VRCT is good, growing and of beneficial to others. And not to be mocked by someone who Dr or not, a man of his level should have his credits right before quoting these words.

Dr Kev please dont take this the wrong way just an observation.

Regards and Huw keep up the good work.

Jeff T

Unless registration is mandatory I would have thought an external company’s decision to register employees would be if engineering degrees were still a permitted entry route or if not whether the clinical technologist degrees were approved by the likes of the IEE.

Question is what would happen if these courses were not compatible with engineering training programs. At the moment I can only see one clinical technologist degree and it seems to be a more of a physics degree rather than an engineering degree.

I’ve only come to the medical engineering sector recently but I doubt that companies in the medical sector don’t employ similarly and that minimum entry for all employees is a HNC/D or degree. In the previous company I worked for there was various levels of employee from those with just GCSE’s to OND/ONC up to HNC/HND and degree. For some tasks you don’t need a degree to perform them, let alone a HNC/D, while other duties with more responsibility need a higher qualified employee. Now if some do run like this where do you stop the registration? Do they have to have everybody that works on medical equipment registered or just the one’s that visit hospitals? It’s unlikely that all of them could register.

Also like were told on the ads for the beer that's not rushed, it's not ready yet! Comparing VRCT to engineering registration, VRCT doesn't seem to be well thought out. When I was first employed I was informed that something would have to be done about VRCT. Now the state registration is approaching it looks like there's still nothing I can do about it. I’ve ask if the training route is available but it doesn’t look likely there’s one implemented. I'm hoping that I can register in just over two years time, but I get the idea that when I can register someone will come along pull the rug out from under me by putting yet another obstacle in my path.

What would improve things would be if there was some sort of preliminary registration for those that don’t yet meet the experience required, like stage 1 of the engineering council registers. I feel that the both train programs and the education requirements should be fully laid down before the grandparenting provision is closed.

Kevin,
I totally agree with you that the stakeholder involvement appears flawed. Our technicians/engineers have registered (including myself) as we thought the hoops are easier to jump through earlier in the process. I don't think there has been enough 'joined up' thinking on how it will affect retention in the NHS. If manufacturers have to use registered technicians/engineers, where is the first place they will look?

Well put Kevin. Personally I am primarily an engineer - but one who is involved with medical equipment. Of course I need an understanding of the application and risks involved - but this is no different to any other application of engineering. Whilst I support and encourage professional registration and CPD with appropriate institutions but are those of us mainly involved with repair and maintenance really a unique profession of Clinical Technologists. I'd like to see the evidence which supports the basis that we are such a risk to patients that we need mandatory registration as Clinical Technologists.
Graham Barnes (CEng MIEE)