Memorandum by the Royal College of Physicians
of Edinburgh
1. The Royal College of Physicians of Edinburgh
(RCPE) has been a full partner in much of the analytical work
undertaken by sister Colleges in the Academy of Medical Royal
Colleges and Faculties of the UK, in particular the Federation
of Royal College of Physicians of the UK. The RCPE has not therefore
repeated the excellent summary of facts and challenges included
within the evidence offered by the Royal College of Physicians
of London (RCPL) but supports their conclusions and seeks to emphasise
the main areas of concern.
2. The College welcomes the principles underpinning
the EWTD and we are collaborating with other Colleges and the
Departments of Health across the UK to explore new models of care
to reduce the long working hours undertaken by many doctors. However,
it is important that continuity and quality of care are maintained
for patients and that the training of young doctors is not disadvantaged
by the organisational changes required to achieve the required
reduction in hours. Therefore, our reservations are in relation
to the detailed application of the Directive within the NHS and
the speed of introduction.
In particular, the College has concerns about:
3. The SiMAP and Jaeger judgments
in relation to the definition of "working time": These
present a significant challenge and push the NHS in the direction
of full shift working for all resident clinical staff. The current
supply of doctors is inadequate to provide a safe level of care
in all hospitals. The RCPE supports the call for increased flexibility
in the interpretation of "working time".
4. Remote and Rural Medicine: The EWTD,
and SiMAP/Jaeger in particular, is a serious threat
to hospitals serving rural populations. Rural hospitals are staffed
to meet the needs of smaller populations, and the EWTD could make
the provision of emergency medicine by those hospitals impossible.
5. The impact on recruitment of doctors
to general medicine: Not only are there insufficient doctors to
staff the required rotas in many hospitals, but the Directive
will affect the availability of key staff (consultants and trainees)
during the main working hours. The surveys cited by RCPL demonstrate
that the resulting work patterns are unattractive to many doctors,
particularly those with young families. This is direct opposition
to one of the key aims of the EWTD, to address work/life imbalance.
6. The August 2004 deadline for implementation:
Many of the organisational changes that will be required to support
patient care with reduced medical time out-of-hours have yet to
be evaluated fully and widely disseminated. For example, skill
mix changes require shifting the balance of some out-of-hours
work to nursing, a profession with its own recruitment problems.
7. The impact on education and training:
The requirement to work full shifts will reduce the scope and
scale of clinical experience for young doctors and their time
with appropriate senior staff for training and assessment. The
overall limitation on hours will pose a significant challenge
for continuing professional development for all grades of staff.
20 February 2004
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