Publication - Consultation analysis

Human Tissue (Authorisation) (Specified Type A Procedures) (Scotland) Regulations: consultation analysis

Published: 21 Feb 2020

Analysis of responses to a consultation held on the proposed content of the Human Tissue (Authorisation) (Specified Type A Procedures) (Scotland) Regulations.

Human Tissue (Authorisation) (Specified Type A Procedures) (Scotland) Regulations: consultation analysis
Additional procedures which should be listed (Q2)

Additional procedures which should be listed (Q2)

Question 2: If there is anything missing from the Type A procedures list, please comment here, giving reasons why.

53. The consultation paper asked if there were any medical procedures that may be missing from the proposed Type A list.

54. 13 out of 19 respondents provided an answer to Question 2. Of these, nine respondents (individual and organisational) provided a variety of suggestions for procedures to be included as Type A procedures that were not present on the consulted list. The remaining respondents either responded to indicate they had no comment (two) or that no procedure was missing and the list was comprehensive (two). Six respondents did not respond to this question.

55. As with Question 1, there was no clear distinction between either individual or organisational respondents in the theme or content of their responses. There was some crossover between different respondents in what procedures were suggested, which are highlighted below, but this was minimal.

56. One organisational respondent did not specifically highlight any missing procedures in their answer, but instead emphasised that the new statutory framework should, as far as possible, support appropriate clinical judgement within the parameters of the new regulatory framework.

Procedures should be added

Suggested procedures

57. In total, there were nine medical procedures suggested for inclusion in the Type A list, suggested by eight respondents. These respondents were either individuals, a representative organisation or NHS body. The following procedures were put forward for inclusion as appropriate to be categorised as a Type A procedure:

  • Administration of heparin;
  • Administration of steroids;
  • Bronchoscopy;
  • Oesophageal doppler;
  • Pulmonary artery floatation catheterisation (PAFC);
  • Taking of stool samples;
  • Transoesophageal echocardiogram (TOE);
  • Skin biopsy;
  • Swabbing or scraping of orifices other than inside of nose, mouth and ear

58. Generally, reasons provided for the inclusion of each of these procedures (where provided by the respondent) were to ensure that clinicians had the widest possible diagnostic options available to them under the new statutory framework. A number of respondents made this point in response to Question 4, rather than Question 2.

59. This point was drawn out further in direct engagement with clinical stakeholders who advised that in circumstances where a patient's condition did not permit a certain method (which may be as set out in the Type A list), other methods of obtaining that information could be inadvertently closed to them, which could mean donation would not proceed.

List is comprehensive

60. Two organisational respondents advised in their response that nothing was missing from the consulted list.