advanced procedures for non HCP

3

3leadecg

Full Registered User
Hi folks.
About a month ago, I emailed the MHRA asking them about:- well, you will see.
I'm not asking to be chased, but I thought a bit of clarity for some folk, may help.
Am happy to provide the original if you PM me.

Please read ORIGINAL MESSAGE first and Dear Mr 3leadecg second.

Dear Mr 3leadecg,

Thank you for your recent enquiry to the MHRA.

We are sorry for the delay in responding to your enquiry. We are not aware of any legislation covering procedures. Medicines legislation addresses the sale, supply and administration of medicines. If any of these procedures involve the use of medicines, then the legislation will apply. In particular, the general rule is that injectable medicines such as saline, may only be administered in accordance with the patient-specific directions of an independent prescriber. They could not be administered by a first aider on their own initiative even if someone has signed them off as competent.*

There are certain injectables that can be administered by anyone for the purpose of saving life in an emergency and other POMs could also be administered in certain circumstances but this relies on an organisation being able to legitimately obtain stocks of the medicines.*

We are sorry we are unable to comment on liability issues as this is outside of our remit.

Please contact us again if you need further assistance with this, or any other queries.
* *
* *
Kind Regards,

Ronke
Central Enquiry Point
Information Services
Medicines and Healthcare products Regulatory Agency
Tel: 020 3080 6000

Your views matter. Tell us what you think of the service you have received from us by following the link below:
https://www.surveymonkey.com/s/CentralEnquiryPointFeedback


***************************************

-----Original Message-----
From:ainttellin @googlemail.com [mailto:ainttellin@googlemail.com]
Sent: 08 February 2012 17:58
To: MHRA Central Enquiry Point
Subject: Legislation

Dear MHRA.

Blah blah blah.....

It is accepted that those who are qualified health care professionals, are able-if trained-to:(list 1) cannulate.
Intubate.
Use supraglottic airways(LMA).
Draw blood.
Needle chest decompression.
Surgical airway(ie mini trach device).

Those who work outside of the NHS, may have a medical director sign them off as competent to carry out these procedures.
Other people, may not have a medical director to do this, yet are prepared to apply these skills in an emergency.

Example;
It is commonplace for those working in the security industry(for the UK and in foreign lands for UK based companies) to undertake the IHCD First Person on Scene-intermediate(FPoS-I) course.
This is essentially an advanced first aid course.
With AED/02 C-spine immobilisation techniques.
The training providers have latched onto the fact that those working in hostile/remote environments are asking to be trained in advanced procedures as listed above In list 1.

My questions are;
1)what legislation covers the use of advanced procedures as listed? *

2)by performing any of those procedures(consent is assumed)in the UK, in an emergency, by a non healthcare professional, without being signed off/under supervision of the medical director for the company, by someone who is trained to carry out such procedures, does this person commit an offence?

3)a non healthcare professional, trained as per list 1. If legislation is permissive, what procedures would the medical director have to follow to sign this person off as competent to carry out these skills? If that is appropriate.

I ask these questions, as I work in the security industry *as a medic. I'm not a health care professional, but I'm alarmed at the number of "5day medics" coming into the system who wouldn't know their scaphoid from their talus, but are running around with POM(saline for IV) and intubation equipment and such like

Please excuse the long email, but in the interests of clarity, I feel it needed to be so.

Thanks in advance for your help.

Kind regards
3leadecg

******************************************
I'm not getting at any of the training providers, nor am I meaning to show any dis respect to the professional medics, with or without a pin number.
Just for info or health discussion.

3l
 
I think the key here is that outside of a national service, medics and so called medics MUST have the following:

1. Appropriate training
2. Appropriate patient contact/experience
3. Depending upon their level; be registered with the relevent body
4. Carry the right equipment to allow them to work within their scope of practice
5. Operate under medical direction, whether is be offline by virtue of a set of standing orders from a physician or online via telemedicine
6. Have appropriate insurance

The securiry company who provide medical services to a large international oil company in Basra have signed up to all of the above and whilst not perfect, it is light years ahead of most private security companies/individuals who really don´t understand medicine, education, scope of practice, legislation, the need for CPD etc etc and won´t listen to any advice...because it will cost them money.

There are numerous companies who expect their paramedics (hired as CPOs, paid less but expected to perform both roles) to deliver paramedic standard services if the wheel comes off yet aren´t willing to provide a medical director, guidelines (bearing in mind this is a multi national enviroment with medics from US, UK, SA, OZ etc) equipment and medications.

As an individual;

How do you get the drugs into country?
Do you trust locally manufactured medications?
Who will approve you to adminster them?
What happens when the client dies following your drug adminsitration? Legal cases, insurance....legs to stand on....

and that´s a paramedic following his own national guidelines.

Imagine someone who has recently attended an ´Advanced Tactical Trauma for Close Protection´ course over 3 days and attempts to put a needle in a chest or starts slicing throats open (I am sure that´s how they´d describe the procedure, afterall, how much can you learn and retain in 3-5 days)

Not sure that´s any help 3leadecg but its certainly worth a thought.

M4MED
 
All valid points M4MED.
not being an HCP and not working for a company that holds a PGD, the most invasive kit I carry is igel airways and my CBG lances.

I'm all for medics of all grades being allowed to work to the limit of their training, confidence and competence.
I recently worked with a guy, who told me that he was an "advanced tactical FPOS." which was fantastic for the HDU transfers we were doing.
I had my obs bag with me, he had a camo STOMP type medic bag in the truck, packed with mini Trach devices and items for blunt dissection!
I did barts and Batls years ago, and wouldn't be confident carrying out some the procedures now.

This guy was a Walt, and that's what encouraged me to email the MRHA.

But it looks like any one can cut into someone, and as long as you not injecting stuff, you are in the clear(even cannulating is sweet if you use pre filled flush).

Standing by for incoming.
 
3leadecg,

You raise an important and relevant issue to the practise of medicine by those who are commercially (and militarily) 'medic trained'. ******************************************************



Rich H
 
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So where does someone stand legally if they improvise a chest seal in appropriate circumstances? Or how about if you come across a serious accident with a number of casualties and you stick a torniquet on whats left of a limb because its the only way you can stop the bleeding quick enough and resussitate another casualty. How about if you resussitate a drowned kiddie even if you're not trained in peadiatric first aid? I'm not talking about the possibilities of being sued, are there any specific charges that could be brought against someone?
 
LW,

I think the question cannot be answered in such a clear cut way. Each situation would be viewed with its own merits. However, it must be understood that the medical assistance provided must be within the skill set of the one administering.

I don't believe any court would find a 'helper' in conflict to the provision and reasoning of their assistance and if the casualty died then it would most likely remain a case that the casualty died of their injuries and not as a result of any invasive techniques.

******************************* is one of the issue of 'disclaimer' that a colleague of mine brought up during pre-deployment training. It was in relation to chest drains, a procedure that was widely accepted was beyond the team members expertise, yet, we were being shown how to do one.



Rich H
 
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I have been told on here before that to do anything medical that goes beyond the scope of FAAW or FPOS would be illegal if you were not a qualified paramedic or nurse etc. However, I can't find what legislation would cover this. There are people practising all sorts of alternative therapies with no legal requirement to register with anyone (although most do register with a professional body and have insurance) and then there's people doing all sorts of strange body piercing stuff.
 
This is potentially a huge discussion, taking into consideration, scope of training, scope of practice, medical direction, consent, currency, good samaritan laws, accepted practice, insurance, guidelines, training records, portfolios, legislation....

Keep it simple.

If you are a first responder or first aider - act within the parameters of your training in the right circumstances and you´ll be fine.

Healthcare professionals obviously have a lot more to think about and they already know what they need to know so no need to preech to them on here.

However, first aiders attempting invasive procedures that they learnt in someone´s garden shed.....standby!
 
I certainly wasn't suggesting people start doing anything invasive but FAAW is dumnbed down and assumes help is going to be close by, which won't necessarily be the case.
There's a couple of issues surrounding the dumning down of FAAW. Firstly compressions first unless its drowning is taught, but what about other forms of asphixiation? You're told to raise any bleeding bit, but what about a stab wound to the chest, isn't it meant to be injured side down?
 
I´m a big fan of teaching compression only CPR to the lay person because most people don´t carry CPR face shields / barriers and in this day and age no one wants to help anyway, let alone put their mouth on a strangers (who is probably vomitting and could have a whole host of diseases). At least this way the lay rescuer is more likely to get involved and get the blood moving.

As for stab wounds to the chest, it really depends on location, depth, breathing ok, difficulty breathing, conscious, unconscious....generally for any breathing and conscious patient with chest or breathing problems, I get them to sit or lie back in the most comfortable position for them. If it has perforated the chest wall then a pneumothorax may ensue which may cause a tension and subsequent unconsciousness. In this case LW you´re absoloutely correct at FAW level, fashion a chest seal, manage the airway (the recovery position) with chest injured side down.

All the best,

M4MED
 
M4MED said:
As for stab wounds to the chest, it really depends on location, depth, breathing ok, difficulty breathing, conscious, unconscious....generally for any breathing and conscious patient with chest or breathing problems, I get them to sit or lie back in the most comfortable position for them. If it has perforated the chest wall then a pneumothorax may ensue which may cause a tension and subsequent unconsciousness. In this case LW you´re absoloutely correct at FAW level, fashion a chest seal, manage the airway (the recovery position) with chest injured side down.

All the best,

M4MED
Click to expand...
What I'm getting at is that FAW doesn't teach chest seals and teaches you to put the bleeding side upwards, so if you do put the bleeding side downwards or use a chest seal, even if it is the right thing to do, can you be prosecuted because it goes against your training?
 
As far as I'm aware, almost all medical devices come with a caveat that "this is only for use by or on the directions of a physician", and the caveat is usually packaged in with the device. I've certainly seen it on ETTs and chest drains, among others.

It's a shame that confidence isn't the same as competence. HDU transfers with this guy? I don't envy you. Sometimes it's better to be on your own than with someone like that.
 
In the case of this guy its certainly not. Confidence in this case is dangerous!!! FPOS HDU transfers!!!

Or what we call in the training world unconscious incompetence. He´s not aware how dangerous he is and in his mind he firmly believes that a person can learn a serious invasive technique, the anatomy and physiology, the indications, contraindications, complications....and exactly what to do when it goes wrong....and have a plan B ready and be slick enough to employ it...after a 5 day course crammed with other things and no patient contact (oh and about 30 seconds on that particular skill station....).

I like to think our students genuinely leave confident in their ability through competence derived from repeated skills workshops, scenario based training and real supervised clinicals at the right level.

Ref kit you´re bang on Seagdog.... the use of kit or any invasive intervention should be by a qualified healthcare professional under medical direction, written into standing orders, guidelines or instructions given in online medical direction over the phone or radio..

M4MED
 
So true - one of the big things is to get people enough training to move them from unconscious incompetence to conscious incompetence, where at least they realise that there's a whole world out there that they know very little about: that tends to make people safer practitioners, and willing to say "I need help with this" when required. Doing the basics well and calling for help early save more patients than anything else.

Sometimes it's not just a plan B required, but plans A/B/C/D! There was an article recently which raised concerns about the number of pre-hospital intubators who didn't have a pre-planned "difficult airway" strategy, and another about whether consultants in critical care are necessarily the right people to do transfers if they haven't been keeping their skills up in the transfer environment. If people who have trained for at least 10 years in dealing with the sickest patients around can recognise that they may no longer possess a given skill-set, why would someone with only an FPOS be thought ideal??
 
littlewoman said:
What I'm getting at is that FAW doesn't teach chest seals and teaches you to put the bleeding side upwards, so if you do put the bleeding side downwards or use a chest seal, even if it is the right thing to do, can you be prosecuted because it goes against your training?
Click to expand...

I fear for the FAAW training you have either done!! or heard about LW, certainly on our courses,,chest injuries are very differently taught. I promise you!

Macca
 
littlewoman said:
What I'm getting at is that FAW doesn't teach chest seals and teaches you to put the bleeding side upwards, so if you do put the bleeding side downwards or use a chest seal, even if it is the right thing to do, can you be prosecuted because it goes against your training?
Click to expand...

It's always been injured side down.



Rich H
 
Its not that they specifically say "penetrating chest wound - put injured side up" its just that they say all bleeding should be raised and if the patient needs to lie down the injured side must be uppermost. When I have specifically asked about chest injuries they say that all bleeding bits go upwards and chest injuries are no different. Its just dumbing down and not wanting to confuse the message.

However, I have just found in the "First Aid manual" authorized by St John Ambulance and Red Cross that it does say that for a penetrating chest injury the patient should be encouraged to lean towards the injured side and does show how to improvise a chest seal. So thats me covered to do the right thing should the need arrive!

I've got my peadiatric First Aid in a few weeks, I'll ask to instructor what he's teaching on the adult course.
 
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