Stop discriminating between Medicals and Non-medicals in Diagnostic Laboratory Sciences
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To, Date: 23/06/2017
Shri Jagat Prakash Nadda,
Hon’ble Cabinet Minister,
Ministry of Health and Family Welfare,
Government of India, Room No. 508, D Wing,
Nirman Bhavan, New Delhi – 110011
Kind attention: The Principal Secretary, MOHFW, Union Government of India, New Delhi.
Subject: The proposed draft amendment to the Clinical Establishments (Central Government) Rules, 2012, circulated by the Ministry of Health and Family Welfare in their draft Notification [G.S.R.441(E)] dated May 5, 2017, Gazette of India, Extra Ordinary [Part-II, Sec 3(i)] proposed to be incorporated in the Gazette of India: Extraordinary minimum standards requirement-human resource..
Reference: Regd.No.D.L.33004/99, dated May5, 2017; Government of India Gazette Notification by MOHFW, New Delhi.
The Association of Clinical Biochemist and Microbiologist (ACBM), Registration No. 1394/2014, www.acbmindia.com and Association of Clinical Microbiologist and Biochemist (ACMB), Registered under societies registration act XXI, 1860, Established in 2007, www.acmbindia.org ; together, hereby file the following representation for your kind consideration. The representation is categorized under the following headings:
· MAIN OBJECTION
· BACKGROUND OF THIS PROBLEM
· OUR JUSTIFICATION
· THE SOPHISTRY - ARGUMENT OF MBBS LOBBY
· DAMAGES THIS CEA NOTIFICATION CAN CAUSE
· NATIONAL OPINION OF IMPORTANT PERSONALITIES ON THIS NOTIFICATION
We are into Diagnostic Healthcare Profession as a Medical Laboratory Scientist (MLS). In our fraternity of MLS we have minimum qualifications of M.Sc. or MPhil or MSc., PhD in Biochemistry, Microbiology, Molecular biology, Genetics and other biological sciences specialties. We are highly qualified professionals engaged in practice of providing Diagnostic Services in India since the very beginning of Diagnostics in our country both in Medical Colleges as well as in Stand Out Diagnostics Centers in Hospitals and in Independent Diagnostics Laboratories. Our members and fraternity persons are Professors, Teachers, Medical-Examiners, Accreditation inspectors/Assessors, as also Research Guides to students of
(i) MBBS/DCP/MD (Medical)
(ii) B.Sc./M.Sc./Ph.D. (Science)
(iii) DMLT/MLT/B.Sc.-MLT (Paramedical)
We have been very successfully working in the medical diagnostic field as Lab Directors/Diagnostic Professionals and are called as MEDICAL LABORATORY SCIENTISTS (MLS) (https://en.wikipedia.org/wiki/Medical_laboratory_scientist Biochemist, Microbiologist or Biomedical Scientist (BMS) (https://en.wikipedia.org/wiki/Biomedical_scientist Medical Laboratory Technologist in government, semi-government and corporate organizations in India and worldwide. Some of us are also self-employed in the medical diagnostic field since many years and are successfully heading these organizations. Our job responsibilities are the same as our MD counterparts.
We are in Medical-Diagnostics and Teaching Basic Medical Sciences from the time Basic Medical Sciences were introduced in Medical Education System in our country and in International Medical Education System. The teachers, both as professors and laboratory personnel, were in subjects like Biochemistry, Microbiology, Serology, Immunology, Toxicology, Molecular biology, Genetics etc. These subjects are taught to Medical students in there undergraduate (MBBS) and Post-Graduate curricula for giving them the basic understanding of human life processes, its deviations and inter related systems. We have an elaborate appreciation of overall human diagnostics services.
Our qualifications of M.Sc./ MSc,PhD are most respected and well recognized for the post of Laboratory Directors at all the international forums, accreditation boards and in all the advanced nations of the world. Our contribution to the improvement of human health and life is quite significant.
Ph.D. is the highest degree accorded in medical or any other education system in our country as well as in other countries. It ranks higher than MD. In fact, technically MD is equivalent to M.Sc. Many MDs are aspiring and enroll for Ph.D degree and get them as well just as post M.Sc. In fact, earlier in the area of Medical Sciences in Medical Colleges the postgraduate degree awarded to MBBS in preclinical subjects used to be M.Sc.
· MAIN OBJECTION:
The draft Gazette Notification under reference, makes us unauthorized signatories on lab reports and labels us as lab technicians alongside DMLT qualifications; because of this our members and the whole diagnostic scientific community/ Professionals are disheartened, despaired and sadden. This gazette notification is also against the policy of our Honorable Prime Minister of India who wants that every part of the community should develop equally and simultaneously it is outlined in govt. slogan of “Sabka Saath and Sabka Vikas”!
THE REAL PROBLEM and the reasons are adduced hereunder:
(A) OBJECTION-1: The referred gazette notification
In this notification (page13-14) under the section of `Human resource', it has removed us from becoming “LAB DIRECTORS/ AUTHORISED SIGNATORIES”. Also, it has put us alongside the DMLT (under graduate, technician’s course) as Laboratory Technicians. This therefore proposes to bring us under our own students of MBBS/MD streams, whom we taught and trained for the job/ subjects as their Teachers, Examiners and, eventually, guided them to get their MD degrees.
(B) OBJECTION-2: In The NABL 112, 2016 document
In the human resource section of the revised version of NABL 112, 2016 (National Accreditation Board for Testing and Calibration Laboratories), draft guidelines, although our qualifications are rightly designated as Authorized Signatories (pg 7-9); however, a proposal has been referred to Medical Council of India regarding qualification norms for authorized signatories in its annexure-II (b).
(C) OBJECTION-3: No data to prove our INCOMPETENCE.
I would like to share with you that no data is available with the government or any other agency to even judge the competence of MDs and M.Sc, Ph.D. in their jobs. Contrary, there are numerous data available across the world proving our COMPETENCY in this field, which was grossly ignored.
(D) OBJECTION-4: No representation by our fraternity in drafting the CEA guideline.
Among the 20 committee members constituted to draft this CEA guideline, none represented us professionals, even though we are and have been rendering our services in healthcare sector even before the time of inception of the MCI.
· BACKGROUND OF THIS PROBLEM
a) The conspicuous absence of our fraternity member in any of the councils, boards and committees involved in clinical establishment Act envisaged total disregard of our contribution in diagnostic laboratory services.
b) We were having 100 percent presence in biochemistry department of all medical colleges, after we started guiding students in MD Biochemistry, our presence was reduced to 50% and furthered snatched the post of HOD from the teachers and awarded it to their students of MD biochemistry; all because of lobbying of MBBS degree holders.
c) DGHS and his subordinate medical Officers have been constantly pressurizing NABL for changing the human resource guidelines to suit the misplaced aspirations of the MBBS/MD fraternity. By lobbying in this regard, such personnel are forgetting their primary duty; Patients Care and Disease Control at the level of Primary Health Care.
d) This has been done at the instance of a Coterie holding MBBS degrees who are lobbying through the present DGHS.
e) Hundreds of representations as objections to human resource requirements in CEA-026 document were sent to the appellant authorities, yet to utter disregard of objections, no change was made in this gazette notification.
f) In total disregard to democratic setup of the country, no appointment was given to us to present our case although dozens of such written applications and oral requests were made to the concerned authorities.
· OUR JUSTIFICATION
1.1 Our qualifications were always considered as optimum and we were practicing laboratory diagnostic services among other duties and responsibilities in government – private as authorized signatories. This notification proposes to deprive us of the age old established practice conferring upon us the recognition/ responsibility of Authorized Signatories in Lab Diagnostics since independence and before. Thus threatening to make directly ~50,000 families without jobs and many more to indirectly affect families, causing crises of livelihood for all.
1.2 The professionals holding doctorates in Biochemistry (in various forms such as Medical, Clinical etc) and Microbiology have been present in Laboratory Medicine, Medical Diagnostic Laboratories, Medical Colleges and Hospitals since the very establishment of these Institutions. They have effectively contributed to the quest for improvement in healthy life through Research, Education, Diagnostics and Bio-Technological Development. These being the relatively newer branches of science have been studied always along with other related branches and are more or less are inter-disciplinary.
1.3 Our presence in the healthcare has always been considered as a bliss, since we did not encourage physician to pathologist nexus damaging for patients, worked in rural areas in large number providing healthcare diagnostic services with quality, timely and in competitive charges.
1.4 We based the concept of quality control in India, by ACBI-CMC-EQAS quality control program since 1982. And a large number of our fraternity members are participants among ~3000 labs in this program.
1.5 To the best of my knowledge NO charges were ever proved against any of our members, whereas the MBBS,MD persons are routinely accused in petitions filed against them in consumer courts.
1.6 Among the many outstanding Scientists and Technologists working in inter-disciplinary fields, a good example can be cited of our “Indian born noble laureate, Dr.HarGobind Khorana, who did his studies taking biology and chemistry in B.Sc (1943), Chemistry in M.Sc from University of Punjab (1945), researched on Insecticides for his Ph.D work in UK (1948). Later, he pursued his research in biochemistry (proteins and nucleic acid) from US and finally was acclaimed to be decorated with Noble prize in Physiology and Medicine, involving genetics in 1968”. The various disciplines of Science do not have rigid boundaries; it is, rather, porous and inter-related, complementing each other for optimum beneficial impact especially in the area of improving the health and related services to the humans at large.
1.7 Biochemists/Microbiologists/Geneticists with degrees in Basic Sciences viz; M.Sc., Ph.D. are Lab-Directors, Institute-Directors, Lab-Assessors (Inspectors) for NABL-India, CAP of US (College of American Pathologists) and ISO (International Organization of Standards) for Awarding Accreditation to Appellant Labs. Then how can these personnel be classified as Lab-Technicians and can be prevented from holding positions of Head of the Labs/Depts, it is beyond our imagination?
1.8 Dr.TEDROS A. GHEBREYESUS, has been elected as the next DIRECTOR-GENERAL of the World Health Organization (WHO) from July1,2017. Dr.Tedros has done his B.Sc in Biology, M.Sc in Immunology, and Ph.D in community Medicine (http://www.who.int/dg/election/cv-tedros-en.pdf?ua=1 (https://en.wikipedia.org/wiki/Tedros_Adhanom So, a non-medical doctor is going to lead the UN health agency, (http://www.who.int/mediacentre/news/releases/2017/director-general-elect/en/ whereas in India we consider the same qualification not good enough to sign lab reports and head the department being a professor! The healthcare is a symbiotic effort of all biological sciences and not only medical science; hence concerted collective efforts can only bring good to India and to the World.
1.9 Under the present dispersions, Clinical laboratories managed by science graduates can be awarded ISO-15189/NABL Accreditation, CAP Accreditation and for CLIA’88 (Clinical Laboratory Improvement Amendments, US). These Accreditation Boards are the most prestigious boards for accreditation of medical/clinical laboratory across the globe. (https://www.gpo.gov/fdsys/pkg/CFR-2011-title42-vol5/pdf/CFR-2011-title42-vol5-part493.pdf see page no. 600 -605 of this CLIA 1988 document.
· THE SOPHISTRY - ARGUMENT OF MBBS LOBBY
The argument, rather, sophistry, that the MBBS lobby (and a very influential lobby, even at policy making level of the nation) put forth to reserve all rights exclusively for them to be the Signatories on Laboratory Diagnostic Reports rests on:
(I) Biochemistry and Microbiology are Medico/Clinical subjects.
(II) All Diagnostic Reports require Clinical Interpretation and Patient Interaction which can be done only by Medicos’.
2.1.1 The above two arguments are manipulative and prejudiced.
Of the two arguments (sophistry) above, the first one is absolutely incorrect. Biochemistry and Microbiology are basic medical/science subjects all over the world.
As for the second one (again a sophistry), I would submit that the Ph.D. and M.Sc. degree holders in the discipline are competent to interpret the diagnostic reports. The reason being, the Doctorate/M.Sc. degree holders in the relevant disciplines are the Teachers for the MBBS/MD students. They teach the subject, including as to how to derive the clinical interpretations.
In support of my counter-argument, I quote below the definitions of Biochemistry and Microbiology from various English Dictionaries.
British Dictionary says: “The branch of science concerned with the chemical and physico-chemical processes and substances which occur within living organisms”.
Merriam-Webster Dictionary: (a) Chemistry that deals with the chemical compounds and processes occurring in organisms. (b) The chemical characteristics and reactions of a particular living organism or biological substances. (https://en.wikipedia.org/wiki/Biochemistry
The branch of biology dealing with the structure, function, uses and modes of existence of microscopic organisms.
Oxford dictionary: The branch of science that deals with micro-organisms.
Merriam-Webster Dictionary: a branch of biology dealing with microscopic forms of life. (https://en.wikipedia.org/wiki/Microbiology
Therefore, we say Biochemistry and Microbiology are the subjects of biology and chemistry. That is why, world over these subjects are recognized as Science subjects; at the best they could be in the realm of Basic Medical Sciences.
2.1.2 BASIC SCIENCE SUBJECTS: These basic medical science subjects are taught by us in Medical Colleges in MBBS, DNB and MD streams, in Science colleges to B.Sc and M.Sc students, in Paramedical Colleges to DMLT, MLT, B.Sc.-Nursing students and in Ayurvedic and Homeopathic medical college to BAMS, BHMS students.
Hence, it is obvious that Biochemistry and Microbiology are in the main stream of science subjects and these two subjects have its own exclusivity, and, thus, could not be narrowed down to bring it in the domain of medical practitioners.
2.1.3 MBBS WITH NO EXPERIENCE ARE NON-COMPETENT: In fact, MBBS students are not competent to independently handle a diagnostic laboratory since they study biochemistry and microbiology only for one year in their four year course time. The number of hours a medical student studies biochemistry or microbiology is less than 1/20th of one M.Sc, Ph.D. student studies. And to substantiate this, I have the curricula of recognized universities of India which could be presented as and when called for.
2.1.4 MD GUIDES: The MD degree in Biochemistry and Microbiology started late in India and world-over. Prior to that, only M.Sc. and Ph.D. degree holders were teaching these subjects in all the Medical Colleges. Still today, more than 50% of MDs in Biochemistry are guided by the M.Sc. and Ph.D. degree holders.
2.1.5 NON-CLINICAL BRANCHES: The MCI and the other similar organizations the world over have placed MD in Biochemistry and Microbiology in non-clinical branches. It is obvious that having been the products of non-clinical branches, they are surely not better placed than M.Sc. and Ph.D. degree holders in the relevant fields. The persons with MBBS and MD biochemistry are not considered clinically acceptable and are not given the clinical postings and jobs abroad.
2.1.6 HISTORY: Moreover, since independence in 1947 till date, professors with MD or M.Sc. /Ph.D. qualifications have been performing similar duties and responsibilities including signing of billions of test reports in government and private hospitals, clinics and institutions.
Then what is the new development now?
Why is this sudden requirement of amendment?
It is premature, prejudicial and uncalled for to initiate a doctrine which has widespread repercussion on the career prospects of lakhs of educated employed personnel. Therefore, it is our sincere hope that the proposed act will be declared null and void.
2.3 DIVERSE CORRICULUM, YET SAME COMPETENCY: MD, DNB and DCP in pathology, biochemistry and microbiology, all have the different curriculum and different duration, yet all of them are awarded with the authorization to work in all the branches. When all of them have a diverse curriculum due to diverse specialization, when MCI has atleast three different branches and three different curriculums, (http://muhs.ac.in/showpdf.aspx?src1=http://intranet.muhs.ac.in/syllabus.aspx then how can all of them have the same expertise in all the fields? In MCI run medical colleges in India no person with MD Biochemistry can work in pathology or microbiology department or vice-versa and they are never allowed to work in tandem within departments, then how is it that their competence in enhanced while drafting this contentious notification? We demand that they should not be allowed to work for other specialization branches. This is what is done across the world too, and only on exhibition of practical knowledge and certification of working in other branches that they are recognized to sign reports for other branches, same concept should be applied here too. The current draft instead of emphasizing on the COMPETENCY of the individual, is giving prime importance to qualification.
2.4 DEROGATORY EQUALIZATION OF A SCIENTIST to a LAB TECHNICIAN: Science doctorates and M.Sc. holders in various Biological-Technological Branches are working as Scientists/ Biochemists/Microbiologists (Class-I post) and as institute directors and laboratory in-charge in one and all premier institutes of the country associated with life and medical sciences including ICMR’s institutes; It’s not only demeaning, but also a gross violation of accepted norms of propriety, denying them the right to serve in clinical laboratories practice in Government and Private Centers and bringing them down to the level of laboratory technicians (Class-III post).
2.5 IN GOVT JOBS: There are hundreds of advertisements in different Government post which has been advertised in favor of MSc/PhD as Biochemists, Microbiologists, Teachers, Scientists, and Specialists in medical field which includes signing lab reports included in their duties and responsibilities.
· DAMAGES THIS CEA NOTIFICATION CAN CAUSE:
The contentious references as in human resource requirements first the draft of Gazette Notification, second CEA-026 and latest NABL-112 annexure-II (b) can cause severe damages, and repercussions, as it is:
a) Totally against the fundamental right guaranteed under Indian Constitution, more specifically Article 21 and 16.
b) This draft notification is against the principles of Human rights of India and international committees to which India is cosignatory.
c) This is also against the principles of healthy competition for which competition commission of India is formed.
d) More than 50,000 health care professional will be thrown out of jobs, inflicting upon them and their families a mortal blow that would affect lakhs of persons associated with it.
e) The loans, liabilities along with social/family responsibilities, all will be severely affected.
f) The Govt. is concerned with plummeted physicians to Patient ratio; however, by this draft it will further remove many more clinicians/physicians to work as non-physicians (this being a non-clinical job); further decreasing Dr to Patient ratio.
g) It will increase corrupt practices in healthcare. This will encourage corrupt practices between referring doctors and diagnostic centers, since it will eliminate us, non-medicos, hindrance to their possible nefarious activities.
h) It will cause great inconvenience to patients. This notification if adopted will lead to closing of thousands of diagnostic centers, causing hardships to patients, who will have to go for centers much away from them, may be lesser trustworthy, and will definitely pay more with less-competitive options along with delayed treatment.
i) On one hand government wants to encourage pure sciences, skilled labor, self-employment, but with this single draft notification, all such goodwill of the govt. will be mocked!
j) This will eventually be the only case in the history of mankind where a skilled person with the qualification of doctorate, self-employed and providing jobs to many more skilled and unskilled persons will be asked to stop practicing what he/she has graduated in and has done all his/her life. This also damages the Right to work enshrined under our honorable constitution of India.
k) In India, pursuance of study by women is encouraged. Women are very much there in good numbers in the pursuit of biological sciences. There are a good number of women who have attained highest qualification in the medical-diagnostic sector. Women presently in jobs, self-employed entrepreneurs and those presently pursuing studies for making carrier in this field, all of them will be severely affected by this proposed gazette notification which, in turn, would reduce the slogan `Beti Bachao Beti Padhao’ in just mere a ‘slogan’, devoid of its connotations.
l) Govt. is taking up lot of social means to uplift the backward communities of India. In our profession a large number of persons from backward communities have taken up these diagnostic sciences as a carrier option. They are either in jobs or in pursuance of jobs while pursuing the education in these subjects. Along with this there are many self-employed persons from SC,ST and OBC category who had taken large loans and have started their diagnostic services/ practices, especially in rural areas. All my members are sadden and devastated on notification of this gazette. Hence, besides encroaching on the means of livelihood of all of them it will also cause a lot of inconvenience with money and time if such rural diagnostic centers are closed down.
Without prejudice to the legal rights of all the affected persons, this association humbly requests that, at first, in no case, the existing professionals and employees can be disturbed with the present rule, which might be enforced but not retrospectively; as the existing professional and employees were given livelihood when no such basis of requisite qualifications for the required post were there and in addition they have acquired huge knowledge on the basis of their practical work experience of the post that is from the date of employment/practice to the date of present rules and laws.
· NATIONAL OPINION OF IMPORTANT PERSONALITIES ON THIS NOTIFICATION:
1. Dr Thuppil Venkatesh M.Sc,PhD (Biochemistry)
(Professor emeritus and Lead Assessor NABL and Guide to MD biochemistry students for over three decades, CAHO (Consortium of Accredited Healthcare Organization) Lifetime Achievement Award 2017)
“As a senior professor and HOD of biochemistry and currently the professor emeritus from St John's Medical College and principal adviser QCI strongly feel that the CEA draft version released as gazette notification is totally biased and favoring only medical graduates in India who presume that they are the custodians of medical testing laboratories and have sidelined the non-medical clinical biochemist that taught them and guided them to get even their post-graduate qualification in MD degree. After getting their basic and post graduate qualification unfortunately they have disregarded their own teachers and have banned them from taking any responsibilities including being authorized signatories. Under these circumstances I strongly recommend that all those who were trained and got MBBS and MD degree in biochemistry shall be disqualified with immediate effect.”
“All non-medical biochemist with MSc and PhD shall be considered with immediate effect as responsible persons in the medical testing laboratories in the area where they are working. Their decisions are important in patient care and shall be signing and taking responsibilities for the work they are supervising and carrying out. India is the only country where such an shameful act of differentiating professionals just because of some people with vested interest who are responsible in drafting and misguiding the authorities who sent the draft CEA and this gazette notification. This is highly condemnable. If not this I will be taken up at International bodies, as Human Rights are violated in the world's largest democracy. I am bound to return all my awards to government if this notification is not withdrawn”
-Dr Thuppil Venkatesh
2. Dr.Kanagsabapathy M.Sc,PhD
(Ex-Professor CMC, Vellore; First president of NABL council of India, Lead Assessor and guide to MD Biochemistry students; Founder of First clinical chemistry’s external quality control program ACBI-CMC-EQAS since 1982; wrote quality control manual for WHO, gave talk in India and abroad and arranged seminars, scientific seasons on quality control application in clinical labs on more than 1300 occasions; nick named father of quality control in clinical chemistry)
“Gross injustice is made through this gazette notification and it has already caused irreparable damage to the reputation of diagnostic laboratory scientist community with M.Sc, PhD qualifications. Our fraternity has contributed much more to the clinical chemistry science then MBBS,MDs. Infact we are and we were their teachers and guides to this subject. MBBS only is infact not competent to head a laboratory unless sufficient training is imparted to them. All over the world much emphasis is given to practical training and continuous training, and they are never discriminating between MD and MSc,PhD qualifications. I must say that the first document of NABL-112 can be best reference in preparing our human resource guidelines. MCI has nothing to do with the laboratory practice, they are responsible for only medical college curriculum and teaching. On one hand our prime minister is laud efforts for upliftment of technical, paramedical and allied health science personnel in our country and on the darker side of it such gazette notifications are just going to kill the entrepreneurs in this profession, prospects of students perusing carrier in this, and encourage brain drain from the country. I must say this draft gazette notification is prepared by the prejudiced persons without application of mind. I strongly demand withdrawal of this notification forthwith.”
3. Dr. Sadanand S. Naik, M.Sc., Ph.D. (Med. Biochemistry)
(Ex. HOD Clinical Biochemistry, K.E.M.Hopsital, Pune; Sr. Consultant Biochemist, Head, Clinical Biochemistry, Deenanath Mangeshkar Hospsital, Pune, A recognized teacher (Pune University) for M.Sc. and Ph.D. in Medical Biochemistry and (Symbiosis International University) for Ph.D. in Health Science, author to several peer reviewed International Journals, Editorial member, International Journal of Nutrition,President, Association of Clinical Biochemists and Microbiologists, Pune, India.)
"Nonmedical Biochemists and Microbiologists fare much better in practice and theoretical work than medical MDs. They study the subject for more duration, have wider outlook on research problems than MDs. This is the reason world over they have more share of research work than others. Unfortunately, today because of the discriminatory Clinical Establishment Act we are compelled to prove ourselves that in clinical biochemistry, medical graduates have limited exposure to practical aspects as compared nonmedical biochemists.
I hope we retain the status we deserve and government should right away withdraw this gazette notification and invite ACBM to discuss on this and other related matters."
- Dr. Sadanand S. Naik.
4. Mr.Jiju Janardhan
(President, Association of Clinical Microbiologist and Biochemist, kerala, India)
“My association has more than 5000 members with minimum of M.Sc qualifications in lab medicine subjects. Thousands of our members are also working all over the world as authorized laboratory personnel. There are many thousands perusing the education with an eye on making a profession for them. This notification is against all the principles enshrined in our constitution. This is also against the fundamental human rights of the civilized society of any part of the world. According to this notification our students who have graduated and post-graduated with lab science subjects’ qualifications will have no acceptance in their own country, then how can it be respected in the world? The government is unable to provide jobs to so many science PGs and when they are earning their bread and butter while serving the society through their profession in remote areas of the country, the government wants to starve them? This notification and the CEA-026 are totally against our members and the fraternity and I deplore it. I demand the withdrawal of this notification forthwith along with invitation to us for further discussions on this topic. I along with my thousands of members demand immediate withdrawal of this notification.”
-Mr. Jiju Janardhan
5. Prof. Kshama Hiremath, CEO & Chief Biochemist,Trident Diagnostics, Bengaluru.
(A women entrepreneur; having over a decade of experience in teaching and diagnostic domains. She has tutored, guided, mentored and assisted students in the field of Paramedics, MBBS and BDS at various reputed institutions. In the field of Diagnostics, she has played an instrumental role in key designations including being Lab in Charge, Consultant Biochemist and Deputy Quality Manager in reputed diagnostic centres. She currently renders her valuable professional expertise at Trident Diagnostics.)
“Before taking such an inconsiderate step, one should contemplate on the fact that these post graduates and MDs share a lot in common. Healthcare in India is already on a disturbed equilibrium and the act if enforced into action will definitely disrupt it further. The government and the concerned decision boards should understand that it is practically impossible for MDs to function as signatories considering the country’s current doctor to patient ratio of 1:1,700 (which is worse than Vietnam, Algeria & Pakistan) and way below WHO stated guideline. While MDs should concentrate on clinical side more and to the wellbeing of the patient. By deeming MSc graduates as incompetent, we are making mockery of our own education system. Logically, we should make best use of this trained and qualified pool of resource to manage the labs.
When countries like USA, Nepal, Sri Lanka, Saudi Arabia etc can authorize M.Sc degree holders to be signatories or consultants in clinical diagnostic laboratories, why should we manipulate and exploit the laws? You cannot term a profession that has proved its competency for decades together to be incompetent all of a sudden. You will find competent and incompetent professional in every field, so it’s imperative to consider their COMPETETIVENESS and individual track records, dedication and contribution. Callous decision like this will simply be risking thousands of professionals to either get demoted or even render them as unemployable.”
- Prof. Kshama Hiremath
1. In view of the submissions made above, the draft gazette notification Regd.No.D.L.33004/99, dated May5, 2017; Government of India Gazette Notification by MOHFW, New Delhi, threatens multifarious damaging impact on the scientific community and their livelihoods, and, hence, needs to be quashed and withdrawn forthwith.
2. The CEA-026 should be suitably amended to accommodate us. Among the 20 committee members formed to draft this CEA guideline, none represented us professionals. [Ref: Operational guidelines for CEA, p:11-12]
3. The NABL under QCI need be advised that they should not seek directions from MCI on matters pertaining to scientific pursuit in Clinical Establishment, as also on matters of private practice undertaken by qualified individuals, because these are not encompassed in their domain.
4. We seek representation from our National Association body, ACBM (ACMB being a joint partner), to have your audience and allowing us to present our case to you along with all the accompanying documents to substantiate our point as soon as possible.
5. The present rule which you have now formed, nowhere gives preference to work experience of M.Sc. / Ph.D. health professionals which deserves to be mentioned in the present CEA act which is mandatory requirement of natural law and should be included.
6. Our representative should always be part of any council/ board or committee where our future is to be decided.
7. Provide us with necessary registration number under a council as rightfully envisaged in the objectives of the CEA.
8. Any other relief as you deem fit.
Dr. Ajay Soni
On behalf of the Presidents of ACBM & ACMB
1. Regd.No.D.L.33004/99, dated May5, 2017; Government of India Gazette Notification by MOHFW, New Delhi. ( http://clinicalestablishments.nic.in/NEWS/1041.aspx
2. CEA-026 minimum standards document. (http://clinicalestablishmentstraining.nic.in/WriteReadData/669.pdf
3. Operational guidelines for CEA (www.clinicalestablishments.nic.in/WriteReadData/497.pdf )
4. NABL-112, 2016 issue, page 7-9; and annexure –II (b). (www.nabl-india.org/nabl/file_download.php?filename=201210170522-NABL-112 )
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