Safer for all: the importance of radiation protection in modern healthcare

The UK’s Ionising Radiation Regulations are a vital component of maintaining patient safety. Synergy explores findings from the most recent Care Quality Commission annual report

By Will Phillips

By Will Phillips

Ionising radiation is an essential part of modern healthcare. But its risks are ever present and, in the case of significant accidental or unintended exposures (SAUE), learning from previous events helps healthcare professionals prevent them from happening again. 

Each year, the Care Quality Commission (CQC) publishes an in-depth Ionising Radiation (Medical Exposure) Regulations (IR(ME)R) report that provides a breakdown of the total number and the type of exposure notifications from the previous 12 months. As an important part of the report, the CQC also provides examples of errors and actions that were taken to prevent repeat occurrences. 

The IR(ME)R 2024 provides a framework to safeguard individuals from the harmful effects of ionising radiation during imaging, treatment or research. Where procedures or training strategies are inadequate, patients can receive unintentional or accidental doses of radiation.

In the most recent report, published on 30 September, the CQC revealed that it had received 842 SAUE notifications in 2024-25, an increase of 3 per cent in incidents from the previous year (there were 819 notifications in 2023-24). These notifications represent clinically noteworthy incidents of patients being exposed to ionising radiation.

How, then, can radiographers make the best use of the CQC’s reports and what are the most important takeaways? Synergy sought to find out more about the report, how it is made and how it is used, and what can be done to ensure radiographers are making the most of its important lessons.

By Will Phillips

By Will Phillips

Ionising radiation is an essential part of modern healthcare. But its risks are ever present and, in the case of significant accidental or unintended exposures (SAUE), learning from previous events helps healthcare professionals prevent them from happening again. 

Each year, the Care Quality Commission (CQC) publishes an in-depth Ionising Radiation (Medical Exposure) Regulations (IR(ME)R) report that provides a breakdown of the total number and the type of exposure notifications from the previous 12 months. As an important part of the report, the CQC also provides examples of errors and actions that were taken to prevent repeat occurrences. 

The IR(ME)R 2024 provides a framework to safeguard individuals from the harmful effects of ionising radiation during imaging, treatment or research. Where procedures or training strategies are inadequate, patients can receive unintentional or accidental doses of radiation.

In the most recent report, published on 30 September, the CQC revealed that it had received 842 SAUE notifications in 2024-25, an increase of 3 per cent in incidents from the previous year (there were 819 notifications in 2023-24). These notifications represent clinically noteworthy incidents of patients being exposed to ionising radiation.

How, then, can radiographers make the best use of the CQC’s reports and what are the most important takeaways? Synergy sought to find out more about the report, how it is made and how it is used, and what can be done to ensure radiographers are making the most of its important lessons.

Embedding a culture 

Reports are made by the CQC with the input of radiographers, clinical departments, professional bodies and societies from across the country. The 2024-25 report collates these inputs to provide valuable evidence in driving the development of resources aimed at addressing the key points, contextualised against a background of extensive pressures and stretched workforce capacity.

It is important to note that there is minimal risk of a notifiable SAUE taking place, in relation to the number of individual medical ionising radiation exposures being undertaken per year. 

Tracy Bradshaw, the CQC’s IR(ME)R lead, and Caroline Berry, a radiotherapy inspector, have been with the CQC since 2023 and 2019, respectively. As team lead, Tracy’s role is to manage the different aspects of developing the report, while Caroline is responsible for collating the data, ensuring the different members of the radiotherapy modality see the important pieces, and performing analysis on the information they receive.

Tracy Bradshaw

Tracy Bradshaw

They explain that the CQC reviews investigation reports into SAUE incidents from around the country and identifies what learning outcomes can be made. The CQC’s IR(ME)R team, which deals with incident investigations, regulatory enforcement and the creation of the annual report, is divided into three modalities: diagnostic imaging, radiotherapy and nuclear medicine.

While Tracy and Caroline agree that, overall, hospital radiology teams are excellent at ensuring investigations are carried out and the results are sent to the CQC in a timely and efficient fashion, there are year-on-year recurrent and persistent themes. There are always, for example, a significant percentage of notifiable incidents that happen in the referral space; a referral is made for the incorrect patient, or there is a failure to cancel a referral when it is no longer needed.

Embedding a culture 

Reports are made by the CQC with the input of radiographers, clinical departments, professional bodies and societies from across the country. The 2024-25 report collates these inputs to provide valuable evidence in driving the development of resources aimed at addressing the key points, contextualised against a background of extensive pressures and stretched workforce capacity.

It is important to note that there is minimal risk of a notifiable SAUE taking place, in relation to the number of individual medical ionising radiation exposures being undertaken per year. 

Tracy Bradshaw, the CQC’s IR(ME)R lead, and Caroline Berry, a radiotherapy inspector, have been with the CQC since 2023 and 2019, respectively. As team lead, Tracy’s role is to manage the different aspects of developing the report, while Caroline is responsible for collating the data, ensuring the different members of the radiotherapy modality see the important pieces, and performing analysis on the information they receive.

Tracy Bradshaw

Tracy Bradshaw

They explain that the CQC reviews investigation reports into SAUE incidents from around the country and identifies what learning outcomes can be made. The CQC’s IR(ME)R team, which deals with incident investigations, regulatory enforcement and the creation of the annual report, is divided into three modalities: diagnostic imaging, radiotherapy and nuclear medicine.

While Tracy and Caroline agree that, overall, hospital radiology teams are excellent at ensuring investigations are carried out and the results are sent to the CQC in a timely and efficient fashion, there are year-on-year recurrent and persistent themes. There are always, for example, a significant percentage of notifiable incidents that happen in the referral space; a referral is made for the incorrect patient, or there is a failure to cancel a referral when it is no longer needed.

Were in new and uncharted territory

This is where the ‘paused and checked’ referrers and operators checklist system is vital. ‘Paused and checked’ is a safety methodology widely used in healthcare and particularly in radiology. By running through the paused and checked prompts, referrers can ensure they are referring the correct patient, and operators can confirm the right patient is having the correct test.  

“We’re in new and uncharted territory. We’ve got radiographer shortages. We’ve got practitioner and radiologist shortages. Medical physics experts are short on the ground. We’ve got an annual increase in the number of referrals being made,” Tracy explains.

“We are diverging away from traditional models of radiography delivery, where you’ve got a radiology department and a cohort of referrers who are medical doctors. Everything is moving so quickly in the clinical space.”

Human factors are, of course, inevitable in modern healthcare. Whether because of pressures in the volume of appointments, demand and staff shortages, or the culture in the department itself, it is entirely possible for staff to not take the time to undertake paused and checked procedures, or to not carry out the pre-exposure checks they should. Caroline adds that because imaging is such a significant component of healthcare in general, there’s a greater risk of error. Many incidents can be traced back to staffing availability.

This is where the ‘paused and checked’ referrers and operators checklist system is vital. ‘Paused and checked’ is a safety methodology widely used in healthcare and particularly in radiology. By running through the paused and checked prompts, referrers can ensure they are referring the correct patient, and operators can confirm the right patient is having the correct test.  

“We’re in new and uncharted territory. We’ve got radiographer shortages. We’ve got practitioner and radiologist shortages. Medical physics experts are short on the ground. We’ve got an annual increase in the number of referrals being made,” Tracy explains.

“We are diverging away from traditional models of radiography delivery, where you’ve got a radiology department and a cohort of referrers who are medical doctors. Everything is moving so quickly in the clinical space.”

Human factors are, of course, inevitable in modern healthcare. Whether because of pressures in the volume of appointments, demand and staff shortages, or the culture in the department itself, it is entirely possible for staff to not take the time to undertake paused and checked procedures, or to not carry out the pre-exposure checks they should. Caroline adds that because imaging is such a significant component of healthcare in general, there’s a greater risk of error. Many incidents can be traced back to staffing availability.

Competing priorities 

The CQC report found that, over the past year, there has also been an increase in equipment faults. Tracy says many radiology departments face the challenge of competing priorities for individual, hospital, location, provider and trust-level budgets. Creating a business case for the replacement of equipment can be challenging, particularly when what is needed is a full capital replacement plan.

But the 2024-25 report also gave examples of successful changes that had been introduced. In fact, a couple of years ago, the team saw a number of errors emerge during radiotherapy, when the contouring system would identify a patient as being out of position when it was simply normal variation of positioning; Therapeutic Radiographers found themselves overriding this system almost automatically, with the assumption that the out-of-alignment notification was always wrong. The CQC suggested in its 2022-23 report that, instead of a blanket override, the system would make site-specific notifications for when it saw that the patient was out of position. In doing so, the team saw a “significant” drop-off in these types of exposures.

Theres this continual drive to move away from the culture of fear of reporting and to move towards learning

Building a culture of learning

Julie Stevens, a clinical specialist in radiation protection at Derriford Hospital, works to understand the information gained during investigations into exposure incidents. By liaising between her department, clinical areas, and national bodies, she supports work that ensures these incidents are properly learned from.

Julie Stevens

Julie Stevens

After having been involved with the UK Health Security Agency’s national taxonomy for the incident learning in clinical imaging, MRI and nuclear medicine working group, which developed a system to extract relevant incident data from existing systems, Julie trialled the framework at her own trust and brought the feedback to the UK Health Security Agency.

The SoR has helped to create the national taxonomy framework, which uses a coding system of abbreviations related to incident type, modality and failure type, which allows for nationwide analysis of the data. This coding breaks down the incident by steps in the patient pathway. Rather than pointing the finger at a person, now it looks at where in the system the error first occurred, and what the contributory factors were. The result is a string of code that breaks down the details and conclusions of each incident, which are picked up by Medical Exposures Group, a national data analysis body that sits under the UK Health Security Agency.

As a clinical radiographer for 20 years, Julie took the opportunity her current role presented to enhance radiation protection measures across the hospital. Her work now involves reviewing incident data, auditing different areas of the hospital and collaborating with various staff groups and departments to champion radiation protection culture.

Working with both this national taxonomy framework and the CQC IR(ME)R reports has helped her to identify trends in her own hospital, compare them to the national data and ‘through collaboration with clinical colleagues to contribute to’ identifying solutions to underlying issues. “Incidents are complex, and there’s many moving parts,” she says. “People don’t come to work to make a mistake – there’s no intention of that. Being able to break down and look at incident reports section by section [through the national taxonomy framework], we can see that our data matches.”

With those conclusions in hand, Julie has – for example – helped to develop a safety bulletin to reach referrers, tried to make incidents headline news to catch attention and made resources such as the the ‘paused and checked’ screensavers, which act as a reminder of the procedure. 

CQC reports are nonetheless “incredibly helpful”, she adds, identifying and circulating the key things to look out for during inspections. Discussing the reports in radiation safety committees, or in imaging departments more generally, teams can help to understand how to apply the report’s conclusions and what lessons are most useful. “The whole system is about improving and learning,” Julie continues. “Radiation safety is more recognised now; it’s becoming more embedded. There’s this continual drive to move away from the culture of fear of reporting and to move towards learning. Improving that learning culture protects the patient and protects the staff. That’s the key thing because, if those incidents aren’t reported, then nobody’s aware, and that change can’t happen.”

Building a culture of learning

Julie Stevens, a clinical specialist in radiation protection at Derriford Hospital, works to understand the information gained during investigations into exposure incidents. By liaising between her department, clinical areas, and national bodies, she supports work that ensures these incidents are properly learned from.

Julie Stevens

Julie Stevens

After having been involved with the UK Health Security Agency’s national taxonomy for the incident learning in clinical imaging, MRI and nuclear medicine working group, which developed a system to extract relevant incident data from existing systems, Julie trialled the framework at her own trust and brought the feedback to the UK Health Security Agency.

The SoR has helped to create the national taxonomy framework, which uses a coding system of abbreviations related to incident type, modality and failure type, which allows for nationwide analysis of the data. This coding breaks down the incident by steps in the patient pathway. Rather than pointing the finger at a person, now it looks at where in the system the error first occurred, and what the contributory factors were. The result is a string of code that breaks down the details and conclusions of each incident, which are picked up by Medical Exposures Group, a national data analysis body that sits under the UK Health Security Agency.

As a clinical radiographer for 20 years, Julie took the opportunity her current role presented to enhance radiation protection measures across the hospital. Her work now involves reviewing incident data, auditing different areas of the hospital and collaborating with various staff groups and departments to champion radiation protection culture.

Working with both this national taxonomy framework and the CQC IR(ME)R reports has helped her to identify trends in her own hospital, compare them to the national data and ‘through collaboration with clinical colleagues to contribute to’ identifying solutions to underlying issues. “Incidents are complex, and there’s many moving parts,” she says. “People don’t come to work to make a mistake – there’s no intention of that. Being able to break down and look at incident reports section by section [through the national taxonomy framework], we can see that our data matches.”

With those conclusions in hand, Julie has – for example – helped to develop a safety bulletin to reach referrers, tried to make incidents headline news to catch attention and made resources such as the the ‘paused and checked’ screensavers, which act as a reminder of the procedure. 

CQC reports are nonetheless “incredibly helpful”, she adds, identifying and circulating the key things to look out for during inspections. Discussing the reports in radiation safety committees, or in imaging departments more generally, teams can help to understand how to apply the report’s conclusions and what lessons are most useful. “The whole system is about improving and learning,” Julie continues. “Radiation safety is more recognised now; it’s becoming more embedded. There’s this continual drive to move away from the culture of fear of reporting and to move towards learning. Improving that learning culture protects the patient and protects the staff. That’s the key thing because, if those incidents aren’t reported, then nobody’s aware, and that change can’t happen.”

The future of incident reporting

Lynda Johnson, professional officer for clinical imaging and radiation protection at the SoR, highlights the importance of building a comprehensive reporting culture into departments. Not only does it inform the educational resources that the SoR develops, such as its webinar series, it informs its work with other radiological societies as well – the British Institute of Radiology and the Royal College of Radiologists, for example.

Lynda Johnson

Lynda Johnson

But the reporting of ionising radiation exposure needs to go further, argues Lynda. Local incident reporting can sometimes be frustrating, she explains, because it can be rare for teams to get feedback on what happened and what went wrong specifically. This lack of response means that staff may be discouraged from reporting non-SAUE incidents in the future.

Non-SAUE incidents include any kind of incident of accidental or unintended exposure that doesn’t meet minimum thresholds. These lead to a local incident investigation process – if it qualifies as a SAUE, it legally needs to be reported to the CQC and, if not, an incident analysis is conducted, a report is made and the learning is fed back to the department. However, Lynda warns, “often that doesn’t happen”. 

She adds: “They might breathe a huge sigh of relief and say ‘oh, it’s not a SAUE – that’s the end of it, we’ve investigated it’ or they might look to blame one person, but we now know the risks to patients and staff development with that approach. You need to understand where the system failure was, and that’s where the really rich learning lies.

“We want to encourage services to use the coding so that we can start really understanding the data and learning where the cracks are before something falls apart.”

CQC SAUE notifications must meet a minimum dose threshold for reporting. That means, Lynda explains, there could be many incidents sitting under the dose threshold that must nonetheless be investigated locally.

The SoR supports the national strategy for departments to adopt the national taxonomy for incident learning in clinical imaging, MRI and nuclear medicine, and expects the benefits of doing so will be realised by future shared learning from thematic analysis of this potentially large-scale data. “Neglecting near misses or inadequately investigating perceived low or no harm incidents can lead to the degradation of attitudes to patient safety and create cultures where poor standards become normalised,” Lynda adds. 

“No healthcare professional should be asked to provide care under these conditions; patients deserve better healthcare experiences. It may seem counterintuitive to focus on a governance framework. It can be perceived as an added layer of complexity that slows down decision making and execution. 

“However, in healthcare, the reality is that operating without a structured governance framework can lead to inefficiencies, increased risks and potential errors that ultimately waste more time in the long run.”

The future of incident reporting

Lynda Johnson, professional officer for clinical imaging and radiation protection at the SoR, highlights the importance of building a comprehensive reporting culture into departments. Not only does it inform the educational resources that the SoR develops, such as its webinar series, it informs its work with other radiological societies as well – the British Institute of Radiology and the Royal College of Radiologists, for example.

Lynda Johnson

Lynda Johnson

But the reporting of ionising radiation exposure needs to go further, argues Lynda. Local incident reporting can sometimes be frustrating, she explains, because it can be rare for teams to get feedback on what happened and what went wrong specifically. This lack of response means that staff may be discouraged from reporting non-SAUE incidents in the future.

Non-SAUE incidents include any kind of incident of accidental or unintended exposure that doesn’t meet minimum thresholds. These lead to a local incident investigation process – if it qualifies as a SAUE, it legally needs to be reported to the CQC and, if not, an incident analysis is conducted, a report is made and the learning is fed back to the department. However, Lynda warns, “often that doesn’t happen”. 

She adds: “They might breathe a huge sigh of relief and say ‘oh, it’s not a SAUE – that’s the end of it, we’ve investigated it’ or they might look to blame one person, but we now know the risks to patients and staff development with that approach. You need to understand where the system failure was, and that’s where the really rich learning lies.

“We want to encourage services to use the coding so that we can start really understanding the data and learning where the cracks are before something falls apart.”

CQC SAUE notifications must meet a minimum dose threshold for reporting. That means, Lynda explains, there could be many incidents sitting under the dose threshold that must nonetheless be investigated locally.

The SoR supports the national strategy for departments to adopt the national taxonomy for incident learning in clinical imaging, MRI and nuclear medicine, and expects the benefits of doing so will be realised by future shared learning from thematic analysis of this potentially large-scale data. “Neglecting near misses or inadequately investigating perceived low or no harm incidents can lead to the degradation of attitudes to patient safety and create cultures where poor standards become normalised,” Lynda adds. 

“No healthcare professional should be asked to provide care under these conditions; patients deserve better healthcare experiences. It may seem counterintuitive to focus on a governance framework. It can be perceived as an added layer of complexity that slows down decision making and execution. 

“However, in healthcare, the reality is that operating without a structured governance framework can lead to inefficiencies, increased risks and potential errors that ultimately waste more time in the long run.”

Find out more about the Care Quality Commission IR(ME)R report

The CQC is the relevant enforcing authority of the IR(ME)R in England. It enforces regulations through onsite inspections and by reviewing statutory notifications from healthcare services about significant accidental or unintended exposures in patients. 

Find out more about the key themes and actions for employers in the report here. 

Find out more about the National Taxonomy Framework for Incident Learning

In order to minimise the burden on clinical departments, the Medical Exposures Group (MEG) plans to extract relevant incident data from existing systems such as Learning from Patient Safety Events (LFPSE) NHS England and Once for Wales Concerns Management System NHS Wales Shared Services Partnership. Anonymised incident data will be analysed by MEG. Results and learning will be published in regular reports.

Find out more online here.

Image credit: Getty Images

Read more