APPENDIX 11
Memorandum from the Institute of Physics
and Engineering in Medicine
The Institute welcomes the inquiry of the House
of Commons Select Committee on Science and Technology into the
"Scientific Advice, Risk and Evidence: How Government Handles
Them". The Institute is pleased that the Select Committee
has chosen the circumstances surrounding the use of MRI equipment
and the EU Physical Agents (Electromagnetic Fields) Directive
as one of the case studies. The Institute supports the submission
compiled by Dr Stephen Keevil on behalf of this Institute, and
the British Institute of Radiology, Institute of Physics, Royal
College of Radiologists and the British Chapter of the International
Society for Magnetic Resonance in Medicine. The submission places
in context the various communications made to government agencies
and departments about the concerns of the scientific and medical
community in relation to the adverse impact on healthcare programmes.
On behalf of the Institute I should like to
make more general comment.
The EU Physical Agents (Electromagnetic Fields)
Directive encompasses many industries. The commissioning of the
Directive is unlikely to have been promoted as a major benefit
for the "healthcare industry". Hence it is possibly
not surprising that the passage of the Directive has seemingly
bypassed the healthcare industry, and in particular the problems
that will occur with the use of magnetic resonance imaging for
medical procedures that require intervention from a health professional.
There may indeed be other concerns that have not yet surfaced
with other techniques used in hospitals.
It is perhaps surprising that government agencies
have apparently not consulted adequately with scientific professional
bodies given that the membership is most likely to consist of
the expertise able to give good advice on such matters. The reasons
for this could be the lack of awareness of the professional expertise
available to government through professional organisations or
a fundamental lack of knowledge of the potential implications.
Such circumstances have not occurred previously when the EC Council
Directive 96/29/Euratom and EC Council Directive 96/43/Euratom
were being developed. Indeed, with the formation of these Directives,
subsequent UK legislation and guidance, the Institute's members
seemed to be actively engaged. It might be interesting to understand
better why the above EC council Directives enjoyed greater involvement
and acceptance by the scientific healthcare community.
One of the probable reasons is that the biological
effects, hazards and risks of ionising radiations are better understood
than those associated with electromagnetic fields. It was probable
also that government bodies and agencies were aware of the expertise
available through scientific and professional bodies on such matters
involving ionising radiations. There was also probably an incentive
for wide and rigorous consultation relating to these directives
given public perceptions associated with "radiation".
However, professional organisations and the scientific community
must take responsibility for not promoting sooner the need for
definitive research into the biological effects and potential
risks of electromagnetic fields. Some will argue that the case
was made at an appropriate stage, but this then prompts the question
as to whether the communication channels to government on such
matters are well understood. It appears with the restrictions
associated with this legislation (ie the Directive), that the
MRI scientific community has awakened to the needfor such research.
However, it is of considerable concern that legislation will be
enacted without reasonable evidence of the need for such restrictions.
To the medical community such legislation will seem to follow
an "over precautionary" principle. Indeed how should
government respond without available scientific evidence?
In summary, it should be very helpful if the
Inquiry might examine also the role and mechanisms of scientific
professional bodies in providing advice and evidence to Government.
The scientific community must take responsibility for not bringing
matters to government attention in a timely way, and perhaps government
needs to examine whether routes of communication are well understood
and effective. Where the scientific community believes government
agencies and departments are not addressing concerns, there maybe
hestitation also in bringing matters to the attention of ministers.
The Institute should welcome contributing to the Inquiry as required.
January 2006
| 
