After reviewing the consultation paper carefully at their meeting on 12 June 2017, the RACS WA State Committee formed the view that we do not support the suggested amendments to the legislation. The reasons for this decision are outlined below.
The case for change
The consultation paper lacks detail and does not adequately explain how the proposed changes will lead to improved outcomes or increased efficiencies. As an example, it is difficult to ascertain the purpose for changing the guidelines for the removal of heart valves. This is a procedure rarely performed in Western Australia given that there are no heart valve banks in the state, and transporting removed tissue to interstate facilities is rarely a viable option.
Throughout the document similar changes have been suggested, but it is not clear how these changes will lead to any improvements, and little explanation has been given as to the rationale behind this decision making.
Lack of coordination/sensitivity
Currently tissue removal is conducted by a trained medical professional with the appropriate skills to perform all of the required removals. This means that the deceased patient's body only needs to be accessed (for the purpose of tissue removal) once after death, and is then left undisturbed. If the proposed changes are introduced, in many cases the deceased body will be accessed multiple times by various retrieval teams.
Although each retrieval team may have the required skills to remove tissue from one area of the body, they often lack the expertise to remove tissue from other areas. Consequently, the proposed amendments will mean that tissue removal will require much greater coordination and oversight, and potentially become a much lengthier process. This only adds to the strain placed on loved ones in what is already a traumatic time. The Committee is concerned that this may have the unintended consequence of discouraging organ donation amongst the community.
Although tissue removal takes place in a highly sterilised environment, due to the nature of the procedure there will always be a level of inherent risk involved. By effectively relaxing the legislation this level of risk is unnecessarily exacerbated as more technicians become involved in the process, therefore increasing the risk of contamination. This also creates the undesirable situation where a technician trained specifically in harvesting an organ from one area of the body may inadvertently jeopardise the removal of tissue from another area, due to a lack of understanding of the interrelationship between the two procedures.
Furthermore, it is not clear in the proposed amendment whether multiple retrieval teams will be instructed to conduct their procedures simultaneously. If this is the case, the Committee strongly opposes this principle. Surgeons undertake several years of training operating in this environment and are well placed to deal with the challenges of tissue harvesting. When an adverse event occurs during tissue removal an organ can be lost very quickly, making it imperative that the medical team are all sufficiently trained and experienced to deal with this scenario. The Committee does not believe it is appropriate or fair that non-medical professionals be placed in a situation where they must interact with other non-medical professionals, in what is a highly stressful and time critical environment.
Read the complete response at the link below.