A large and growing number of clinics in the UK now work with high power lasers or intense pulsed light (IPL) systems, and are required by law to employ the services of a laser protection advisor (LPA) as an external consultant to oversee laser safety.1 Those performing aesthetic treatments, such as hair and tattoo removal, will presumably be operating a class 3B/4 laser or IPL system, which, without professional LPA support, would be in violation of the Control of Artificial Optical Radiation (AOR) at Work Regulations 2010.1 Consequently, their business would be exposed to the potential for significant financial and commercial damage. This could be through the loss of their treatment licence, a claim as result of an adverse incident that could have been avoided, or a fine.1
The role of the LPA is to provide advice on matters relating to the evaluation of optical radiation equipment hazards, and have responsibility for advising on their control. This includes guiding on laser safety training, the suitability of personal protective equipment, and producing a risk assessment with a corresponding document outlining day-to-day laser safety management and procedures know as the ‘Local Rules’.2
As the legal responsibility for ensuring compliance with AOR regulations ultimately lies with the business owner or manager,1 an elemental knowledge of the level of competency and service to expect from an LPA is essential.
LPA competency and certification
The employment of a certified LPA to oversee laser safety is now a mandatory requirement of local authorities.3 It is also a condition of the special treatment licence that many local authorities have implemented and now issue to compliant businesses operating laser and IPL systems for aesthetic and therapeutic applications.
Guidelines published by the Medicines and Healthcare Products Regulatory Agency (MHRA) give no defined criteria for LPA competence, but instruct that it is for the employer to judge what level of competency they require.4 However, a scope of essential LPA duties is provided by the MHRA, accompanied by details of LPA certification schemes. One such scheme is run by the Association of Laser Safety Professionals (ALSP); a member-based organisation of laser safety professionals. Nationally recognised LPA certification is awarded by the ALSP to those who demonstrate the necessary standard of knowledge and expertise in laser safety through relevant qualifications, evidence of practical experience, and an assessment interview. A similar scheme is run by RPA 2000, which awards LPA certification and is also recognised and listed within the MHRA guidelines.
The LPA would examine whether controls and protocols were correctly adhered to and, if so, decide where new controls should be implemented to avoid a repeat incident
Considering that there is no defined criteria for competence, but instead a seemingly common-sense guide to the LPA role and duties, one may question the need for certification and associated schemes. However, the expertise of a certified LPA in areas such as the current legislative framework and optical radiation exposure evaluation is unique and certainly invaluable in the event of an adverse incident. In such circumstances, the LPA would be informed of the adverse incident and proceed to oversee a thorough and objective investigation into the incident and the surrounding conditions that may have enabled it. The LPA would examine whether controls and protocols were correctly adhered to and, if so, decide where new controls should be implemented to avoid a repeat incident.2
Of course, the knowledge of the LPA often extends much further, with members of certification schemes holding relevant qualifications in the fields of physics, medical science, or biomedical engineering.
Level of service
- The role and responsibilities of the LPA are outlined in the MHRA guidelines,4 which identifies the LPA’s key duties, and includes:
- Undertaking a risk assessment to identify potential hazards associated with the laser/IPL system and the area in which it is to be used.
- Producing suitable Local Rules of working practices, which implement controls to eliminate and/or minimise the identified hazards of the corresponding risk assessment.
- Ensuring that the laser/IPL equipment, room, and personal protective equipment are fit for purpose and compliant with relevant standards.
- Delivering expert advice on safety training of relevant personnel.
- Designating a Laser Protection Supervisor (LPS) within the business to ensure safe working practices are being consistently adhered to, and to liaise with the LPA in the event of an adverse incident, or when reviewing proposed changes to current protocols.
- Investigating any adverse incidents, and reporting the incident to the employer and appropriate external body if necessary.
Beyond these elementary duties, there are some lesser-known requirements of the LPA, such as evidence to demonstrate the LPA has carried out an initial on-site visit and inspection as part of the practical risk assessment procedure for each laser/ IPL system in use. This practical obligation is outlined in the British Medical Laser Association (BMLA) essential standards document, which was produced in May 2017 with the intention of providing a comprehensive set of industry standards to be implemented across the entire aesthetic laser/IPL sector.5 The BMLA is a scientific society for medical and aesthetic lasers, and promotes safe operation of laser and light-based technology throughout the industry.
From my knowledge, local authorities have subsequently adopted the BMLA essential standards and its noted practical inspection requirement into their respective licensing conditions, thus making it crucial that the licensee/employer ensures that a practical inspection is carried out by any perspective or currently employed LPA. As an exception, some class 3b lasers designed for low level laser therapy (LLLT) may not require an on-site visit or restriction to a controlled area, depending on the laser’s intended purpose and technical specification.
The means by which an employer is able to contact their LPA may vary between services of individual LPAs. For some employers, an email-only support service is preferred, whereas others may offer direct phone support in the event of an adverse incident, such as accidental exposure of the eye to the laser beam.
Laser safety training
The national minimum requirement, as set by the MHRA, for operating a higher power laser or IPL system is the laser safety ‘Core of Knowledge’ course. This attendance-based course defines the minimum competency level for a laser operator.2
A course delivered by an LPA with the discrepancy to decline inappropriate course completion, enables a degree of regulation of the award’s representative level of competency
Although there is no statutory approval body for Core of Knowledge courses, the MHRA has defined a course syllabus, and instructs that the course should be delivered by an individual – with a high level of knowledge and understanding of different optical radiation devices, optical radiation safety and the hazards associated with the equipment – such as a certified LPA, to ensure quality and consistency.4
In many cases, local authorities now require that before being registered as authorised users; laser operators attend a Core of Knowledge course that is delivered specifically by a certified LPA. With course completion awarded primarily on the basis of attendance, an online course that might easily be ‘flicked through’ to attain the certificate without involvement or retention may not be accepted. A course delivered by an LPA with the discrepancy to decline inappropriate course completion, enables a degree of regulation of the award’s representative level of competency.
Most LPAs offer the Core of Knowledge course as an additional element to their support services, which may be required at the time of employment, or later when new untrained staff are taken on.
Key requirements
Subsequent to making the sizeable investment in laser or IPL equipment, it is understandable that a business may be price-focused when it comes to the additional, but necessary expense of employing an LPA. However, when determining value for money and a service that best meets the needs or the employer, the following points should be considered:
- Certification: Make sure the LPA is certified by an official organisation such as the ALSP or RPA 2000. A certified LPA will be glad to provide a copy of their certification upon request.
- Industry expertise: Be sure to find an LPA with expertise and certification in medical and aesthetic applications. Some LPAs hold certification for industrial laser applications not suited to aesthetic lasers.
- Pricing structure: Some LPAs will charge per laser device in use, whereas others charge per clinic. The latter option generally being the cheaper option.
- Means of contact: Find out the means by which the LPA can be contacted, and what kind of response times you should expect.
- On-site visits: Ensure the LPA will perform an initial on-site visit and inspection of the laser room, and that this is included in their fee.
- Training: If you require Core of Knowledge training, find an LPA that offers this service. This optional extra may be offered at a discount when purchased with LPA support services.
Summary
The employment of a certified LPA and implementation of their laser safety guidance is a mandatory practice to ensure regulatory compliance and safe working procedures; protecting patients, employees, equipment, and the respective business. Accordingly, as the employer maintains ultimate responsibility for regulatory compliance, an elemental knowledge of the key requirements of the LPA is essential in assuring an appropriate level of competence and service.
Disclosure: Rob Knowles is a member of the Association of Laser Safety Professionals (ALSP), which offers LPA certification.
