Western Health and Social Services Council

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The Future of Pathology Services in Northern Ireland

DEPARTMENT OF HEALTH, SOCIAL SERVICES & PUBLIC SAFETY
The Future of Pathology Services in Northern Ireland

CONSULTATION RESPONSE DOCUMENT
November 2006

CONSULTATION RESPONSE QUESTIONNAIRE
You can respond to the consultation document by e-mail, letter or fax.
Before you submit your response, please read the section in the Executive Summary
on the confidentiality of the consultation responses. This gives guidance on the legal
position about any information given by you in response to this consultation.
Responses should be sent to:
e-mail: dreena.evans@dhsspsni.gov.uk
Written: Secondary Care Directorate
Room 1, Annexe 1
Castle Buildings
Stormont
Belfast BT4 3SG
Fax: (028) 9052 3303
Responses must be received no later than 28 February 2007.

I am responding: as an individual on behalf of an organisation
(please tick a box)
Name: Ms Maggie Reilly
Job Title: Chief Officer
Organisation: Western Health and Social Services Council
Address: Hilltop, Tyrone and Fermanagh Hospital, Omagh,
Co Tyrone, BT79 0NS
Tel: 028 82252555
Fax: 028 82252544
e-mail: maggie.reilly@whssc.n-i.nhs.uk or info@whssc.n-i.nhs.uk
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc

Management and corporate governance
Q1. Do you agree with recommendation 1, development of a single, managed
pathology network? If not, please state the reasons why.
Yes No ?
Response:
The Western Health and Social Services Council does not support the view that
there should be one single network for Northern Ireland. Such a proposal would
inevitably lead to a Belfast centric model and with it the control of resources. Rather
the Council suggests that a better model would be to have two networks operating
under the same standards, regulation and governance. One network could provide
for the Belfast and surrounding area population whilst a second network could
operate within the North and South West of Northern Ireland.
(Causeway, Altnagelvin and South West hospital’s patient community).
Q2. Do you agree with recommendation 2, establishment of a working group to
explore formalising links between the proposed pathology network and the Northern
Ireland Blood Transfusion Service? If not, please state the reasons why.
Yes ? No
Response:
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Workforce
Q3. Do you agree with recommendations 3 and 4, that the DHSSPS workforce
plans in relation to (a) consultant pathologists and (b) Technical and Scientific staff
should be reconsidered in light of any new reconfiguration of services? Do you
agree that future requirements for administrative and clerical staffing should also be
examined as part of the process? If not, please state the reasons why.
Yes ? No
Response:
Q4. Do you agree with recommendation 5, that the current voluntary
arrangements for the provision of out-of-hours services should be replaced by more
sustainable and appropriate arrangements by 2008? Do you consider the target
date appropriate? If not, please state the reasons why.
Yes ? No
Response:
The Western Health and Social Services Council supports the view that voluntary
arrangements for providing out-of-hours services is neither desirable nor sustainable
in the long term. However given all of the major changes currently underway
especially with the merger of old Trusts into the New Trusts and the impact on all
staff, we believe the target date of 2008 may prove to be somewhat ambitious.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Q5. Do you agree with recommendation 6, that DHSSPS and Queen’s
University should consider joint initiatives to strengthen academic pathology? If not,
please state the reasons why.
Yes No ?
Response:
The Western Health and Social Services Council is at a loss to understand why the
University of Ulster has been excluded from this recommendation. It is the Council’s
understanding that there are advantages to developing both Universities i.e. Queen’s
University Belfast and University of Ulster with regard to medical education and that
currently both provide training across the pathology service requirement.
It would seem reasonable that both Universities should develop a solid research
foundation.
The University of Ulster is located within the N West and has established links with
the HPSS and local providers. It seems to the Council that these arrangements
should be strengthened and sustained rather than developing a single University to
provide academic pathology.
It is also the view that the DHSSPS would want to explore and develop research and
academic links throughout the island of Ireland and the UK.
Clinical and advisory services
Q6. Do you agree with recommendation 7, that the proposed pathology network
should ensure that all clinical needs are met in all health and social care settings,
irrespective of their distance from the nearest laboratory? If not, please state the
reasons why.
Yes No
Response:
It is the Council’s view that the single network is iniquitous in its conception and
would not meet the needs of the whole population most particularly those patients
outside the Belfast based network.
The Council would subscribe to the recommendations were there to be two
networks as proposed by the Western Health and Social Services Council (see Q1).
Then clearly the networks role would be to ensure that all clinical needs were met
across all the health and social care settings irrespective of their distance from the
nearest laboratory.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Clinical governance, audit, accreditation and benchmarking
Q7. Do you support recommendations 8 (audit and clinical governance), 9 (CPA
accreditation) and 10 (benchmarking) as a means of further improving quality,
effectiveness and responsiveness in pathology services? Do you consider the target
date for enrolment in the CPA accreditation scheme appropriate? If not, please state
the reasons why.
Yes ? No
Response:
The Western Health and Social Services Council fully supports all measures
proposed for improving quality, effectiveness and responsiveness and notes that
Altnagelvin already holds full accreditation across a range of disciplines within
pathology.
Resources
Q8. Do you agree with recommendation 11, that the resources currently
allocated for pathology services be retained and re-invested across an integrated
pathology network? If not, please state the reasons why.
Yes No
Response:
Altnagelvin Trust has under PFI arrangements a new first class Laboratory facility
which is designed to serve the needs of it’s Western population and patients beyond
its own boundaries including cross-border work.
This very valuable asset would under the current proposal be stripped of its Cancer
pathology services and reconfigured within the new single Network. The Western
Health and Social Services Council strongly opposes such a move and is against
any proposal which would asset strip the Western Area in favour of supporting a
Belfast based Cancer pathology service providing for Northern Ireland.
We note that the Review document does not fully take account of the valuable new
estate asset (in fact fails to mention it) the fully accredited histopathology and
cytology service in Altnagelvin and the human asset of expertise and experience.
Pathology services in Northern Ireland will most likely require additional investment
in its estate, human resource science technology and ICT.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Technological capacity and equipment replacement
Q9. Do you support recommendations 12 (regional procurement and
maintenance in relation to new and replacement laboratory equipment) and 13
(considering buying services from the private sector or universities when expensive,
infrequently-used equipment is required). If not, please state the reasons why.
Yes ? No
Response:
Point of Care Testing
Q10. Do you agree with recommendation 14, that Point of Care Testing (POCT)
should be managed under a regional framework? If not, please state the reasons
why.
Yes ? No
Response:
Point of Care Testing should be subject to high quality standards across all of
Northern Ireland which can be achieved through a regional framework.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
ICT
Q11. Do you agree with recommendation 15, that work on a regional pathology
ICT system should be progressed with a view to commissioning a new system by the
end of 2009? Do you consider the target date appropriate? If not, please state the
reasons why.
Yes ? No
Response:
Whilst agreeing the importance of achieving a regional system, ICT systems within
health and social care have been problematic in the past not least the inability of ICT
to integrate across the HPSS e.g. secondary to primary care sector.
Sample Transportation
Q12. Do you agree with recommendation 16, that sample transport and
management should be reviewed? If not, please state the reasons why.
Yes ? No
Response:
The western Health and Social Services Council fully supports such a review being
especially mindful of the very many concerns regarding the generally poor transport
infrastructure in rural areas.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Future Configuration of Laboratory Services
Q13. Do you agree with recommendation 17, that regional pathology services
should remain in Belfast and be managed by the new pathology network? If not,
please state the reasons why. Where should they be located and who should
manage them?
Yes No ?
Response:
It is the Council’s understanding that some of the ‘super regional’ pathology service,
especially the more specialist areas and low volume work, can be provided by other
UK laboratories and that this might represent better VFM.
Otherwise were 2 Networks to be in place in Northern Ireland it should not be
assumed that the regional work could only be carried out in Belfast.
Q14. Do you agree with recommendation 18, that laboratory services in Belfast
should be provided from a single facility on a 24-hour daily basis, with the
development of essential diagnostic facilities to support specific clinical needs at
other Belfast locations? If not, please state the reasons why.
Yes ? No
Response:
The Council supports this recommendation in the context of its original proposal (Q1)
that there be 2 networks which is predicated on their being a 24/7 laboratory facility
at Altnagelvin serving the needs of the North West. This second facility would also
include histopathology and cytology services.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Q15. Do you agree with the proposals in recommendation 19 for pathology
services at the large acute hospitals (Altnagelvin, Antrim, Craigavon and the Ulster),
that:
· integrated clinical biochemistry and haematology should be provided on a 24-
hour basis at all four hospitals
· microbiology should be provided on a 24-hour basis at Altnagelvin and a 12-
hour basis at the other three hospitals
· histopathology and cytopathology services should be provided from the
Belfast facility (recommendation 18 refers), with small facilities at the large
hospitals for urgent diagnostic work, and a permanent consultant pathologist
team at Altnagelvin?
If not, please state the reasons why.
Yes No ?
Response:
The Western Health and Social Services Council does not agree with this
recommendation. The Council’s view is that Altnagelvin has a new PFI laboratory
facility planned, built, funded and designed to specifications which would see this
laboratory provide the full range of pathology services i.e. Haematology,
Biochemistry, Microbiology, Blood Transfusion, Histopathology and Cytopathology.
The Trust and its Cancer and Pathology Clinicians have shown foresight and
innovation in recognising the present and future needs of the sub-region. They have
already managed to secure additional revenue to the service through the provision of
smear testing for patients in the Republic of Ireland and Breast pathology service to
Causeway.
This review does not even mention or take any of this into account in it’s overview of
existing laboratories.
It seems remarkable that many millions have already been committed now and into
the future (through the PFI) of public monies into this state of the art building and that
a strategic review would countenance such waste through the less than optimal use
of the new facilities.
The Western area has a valuable resource of scientific staff providing Cancer diagnostic services and screening in Altnagelvin and has extended its screening
service beyond Northern Ireland. Altnagelvin’s Cancer service has the potential to
grow in the future with a regrettably predicted 56% increase in Cancer diagnoses
over the next twenty years.
Cancer patients in this area not only want to secure the retention of the current
Cancer service but will also want it to be developed further so that more patients
receive more care closer to their own area.
If Histopathology and Cytology services were removed from Altnagelvin patients in
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.docthis area would inevitably receive a lesser service and a lesser quality of service than
their counterparts elsewhere.
Such a move as proposed in this recommendation goes well beyond the capacity of
other centralised laboratories in the UK/Europe.
It is the Council’s understanding that a Belfast Laboratory would be dealing with over
90,000 patients predicted to double in ten years and would be the largest in Europe.
The Council does not share the confidence of the reviewers that this is either
desirable, safer or manageable (even if ICT and transport infrastructure could be
improved).
Q16. Do you agree with the proposals in recommendation 20 for pathology
services in the smaller acute hospitals (Causeway, Daisy Hill and the new South
West hospitals), that integrated clinical biochemistry and haematology should be
provided on a 12-hour basis and all out of hours urgent samples transferred to the
nearest large acute hospital laboratory? If not, please state the reasons why.
Yes No ?
Response:
The Western Health and Social Services Council is extremely concerned with this
proposal and most particularly that integrated clinical biochemistry and haematology
should only be provided on a 12 hour basis at the new South West Hospital.
The Sperrin Lakeland area which will have an acute and local hospital has witnessed
a hugely divisive argument within and between its communities in Fermanagh and
Tyrone. Both communities have legitimately wanted to secure safe and sustainable
services for their respective populations. The final decision to locate the acute
hospital in the South West continues to dominate the health debate.
This argument continues and the Western Health and Social Services Council has
highlighted throughout that the focus of concern should be on what services will be
provided across the two areas and how accessible they will be to patients.
This recommendation has therefore stunned the members of the Western Health and
Social Services Council. The implications of such a proposal would be to downgrade
the new South West Hospital before it is even built from a small acute hospital to a
local hospital.
This Council knows the value placed by the DHSSPS on any recommendations or
advice of the Royal Colleges about safe and sustainable services. Indeed previous
Royal College recommendations have been cited to justify the urgent reconfiguration
of current acute service provision across the Erne and Tyrone County
Hospital sites.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
The New South West Hospital is planned to provide acute surgery, medicine,
obstetrics and A & E. This service could not be sustained if it only had a 12 hour
biochemistry and haematology laboratory provision. Even with elective intakes
emergencies occur.
Such a proposal if it were adopted would mean that the New South West Hospital
had built into the seeds of unsustainability and unsafe service provision; a point that
will not be lost on patients, clinicians or Royal Colleges.
Patients and Clinicians cannot wait for 2-5 hours for the results of laboratory tests in
order to treat or maintain life.
This review does not appear to have taken on board the lessons which should have
been learnt from recent Clinical Governance Reviews, Royal Colleges
recommendations or the findings from Coroners’ cases.
Q17. Do you agree with the proposals in recommendations 21 and 22 that there
should be no laboratory facilities at local and enhanced hospitals and that pathology
services for local hospitals, primary and community care should be provided by the
nearest laboratory? If not, please state the reasons why.
Yes No ?
Response:
The Council has a concern that the Tyrone County Hospital which provides renal
dialysis services should maintain its skilled ‘hot’ laboratory facility in order to ensure
the maintenance of the dialysis service.
Q18. Do you agree with recommendation 23, that development of the new
laboratory and mortuary infrastructure associated with the new configuration of
services? If not, please state the reasons why.
Yes No
Response:
It is the Council’s understanding that Altnagelvin may in the future provide for
Coroners post mortems and this will require additional infrastructure support.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Equality implications
Q19. Are the proposals likely to have an adverse impact on any group of people in
terms of the nine equality groups identified under Section 75 of the Northern Ireland
Act 1998? If yes, please state the group or groups and the adverse impact(s) that
you feel the proposals are likely to have on them.
Yes No
Response:
Recommendation 19 (contained within Q15) would adversely affect Cancer patients
in the North West in relation to equitable access and quality of service provision.
Recommendation 20 (contained within Q16) would adversely affect patients in the
Sperrin Lakeland catchment area in that they inherently call into question the viability
and long-term sustainability of acute service provision for the area. There is no
evidence of rural proofing any of the proposals.
Q.20 Are you aware of any evidence, qualitative or quantitative, that the proposals
may have an adverse impact on equality of opportunity or on good relations? If yes,
please give details and comment on what you think should be added or removed to
alleviate the adverse impact.
Yes ? No
Response:
Anecdotal evidence would suggest that the implementation of recommendations 19
and 20 will have an adverse impact on the equality of opportunity for patients, carers
and families with regard to service provision.
Clinicians and health professionals will be adversely impacted upon in terms of
opportunities to work and develop within the Western geography.
Again anecodotally
Good relations between already divided and polarised communities may suffer
further as a result of implementing recommendation 20.
20070319_consultationreviewpathologyservices_response_questionnaire_mrkl.doc
Q.21 Could the proposals better promote equality of opportunity or good relations?
If yes, please give details as to how.
Yes No ?
Response:
See Q20.
Q22. Do you have any other comments on the recommendations or any suggestions that
you would like to make to improve the promotion of equality of opportunity and/or good
relations or human rights?
Yes No ?
Response:
THANK YOU FOR YOUR COMMENTS.

Western Health and Social Services Council
‘Hilltop’
Tyrone and Fermanagh Hospital
Omagh
Co Tyrone
BT79 0NS
Freephone: 0800 917 0222
Tel: 028 8225 2555
Fax: 028 8225 2544
Minicom: 028 8224 8389
Email: info@whssc.n-i.nhs.uk
Website: www.whssc.org

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