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REJOINDER: “My Personal Observation And Concerns On The Implementation Of ACT 857”

It is with much delight I write this rejoinder to a publication by Dr. K. Nsiah in the Friday, September 9, 2016 issue of THE PIONEER on page four with the title “My Personal Observation And Concerns On The Implementation Of ACT 857”.  Not only did I perceive mischief in the observation and concerns of individuals and a group with the sole aim of detracting the progress of medical laboratory practice in Ghana, but I also see a deliberate misrepresentation of facts in a context not applicable in post-ACT 857,2013 era by an expected intellect to appeal to the general public. I present this rejoinder to set some records straight and as a matter of fact address the concerns raised by the writer.

For the education of the general public and individuals who might have been misinformed, I respond to the issues raised in the publication as follows:

The writer claims that “ACT 857 was passed by Parliament of Ghana, to provide a legal framework to regulate the operation of clinical laboratories in the country.” It is of public knowledge that the Health Professions Regulatory Bodies ACT, 2013 (ACT 857) PASSED by Parliament and assented to by the President has FIVE PARTS, with PART ONE-ALLIED HEALTH PROFESSIONS COUNCIL (AHPC) responsible for the regulation of twelve (12) different professional groups including professionals of MEDICAL LABORATORY SCIENCE presented on pages 70 and 71. For the sake of precision and accuracy, it was my expectation that, the writer would have given a proper reference to the very foundation of his concerns and the mirage observations of the members of Medical Scientists Society of Ghana (MSSG).

It is well established that Medical Laboratory Science is an autonomous profession; characterized by its own body of knowledge and scope of practice; which certifies its own practitioners; and require of its practitioner’s impeccable competency in scientific, technical, managerial and scholarly principles, and high standards of performance and professional conduct. In Ghana, who qualifies to practice Medical Laboratory Science (MLS) is captured in the Schedule of Allied Health Professions in ACT 857. One becomes a professional Medical Laboratory Scientist (Biomedical Scientist) after demonstrating the requisite academic knowledge and skills with evidence of clinical laboratory training. Students of the medical laboratory profession undertake four or six years intensive theoretical and practical training (for the award of Bachelor or Doctor of MLS respectively), three years intensive theoretical and practical training (for Diploma in MLS) or two years intensive theoretical and practical training (for Certificate in MLS) in Clinical Haematology, Chemical Pathology, Histopathology (including cytology) and Clinical Microbiology (which includes parasitology, virology, mycology, bacteriology and medical entomology) in addition to the basic sciences just like students of dentistry, pharmacy, medicine, nursing, biochemistry, biology, chemistry, zoology (fisheries, herpetology, etc), botany, industrial laboratory, et cetera. After this scheduled training, graduates obtain a provisional professional license to undergo a mandatory one year internship in accredited health facilities before writing their professional exams to obtain their permanent license from the AHPC to practice.

The laboratory profession since its inception in Ghana in an unregulated environmental has seen many different cadre of certificate holders in practice. When the AHPC was initially registering professionals of Medical Laboratory Science in 2012-2013, about 25 different certificates were found to be submitted by applicants already in practice. No wonder the writer acknowledges the fact that “… a non-regulated situation would be inimical to the healthcare in the country,” and went further to appreciate “… the timeliness and appropriateness of the Law, …”.

Strangely enough, an erroneous impression was created by the writer as if the provisions in ACT 857, Part 1 were implemented in retrospect to throw out some of those already in practice from the clinical laboratories. The conclusion from his observations and reflections to assert that “… others are swept under the carpet.” is not true and a complete figment of the writer’s imagination.

I would not want to believe that by the statement, the writer is suggesting that everyone should be allowed into practicing MLS going forward once you have studied the basic sciences? Is that his explanation of how a regulated environment should be? “Definitely not!” What difference would it be when one compares to the pre-ACT 857 era? The group MSSG (of whom Dr K. Nsiah is a mentioned patron) which the writer mentioned in his article, petitioned the AHPC and were given a ruling which prescribed a way for upgrade to attain the level of body of knowledge accepted by the laws to practice in Ghana. This is not different from what happens in the UK and USA as the writer suggested we should go and learn best practices from. If the writer cares to know, those who followed the guidelines given by the AHPC after the petition and did the necessary upgrade have been licensed to practice the profession of medical laboratory science as we speak. I am therefore at sea what might have informed the purported observations and concerns of a law being applied “… to protect one group of professionals.” Was the writer suggesting a wholesale acceptance and license of anyone who wishes to work in the medical laboratory of hospitals? Was he suggesting that anyone, with whatever qualification and even a lecturer of students of MLS should be able to dot a “container” anywhere and be performing laboratory tests? No way in this era of regulation.

It is very difficult to comment on the “Hollow claim” presented by the writer giving an analogy of “John the Baptist and Jesus Christ” as in the Holy Book. The difficulty in responding is the inability of providing the reference to the claim. But just like all laws, ACT 857 was never applied in retrospect and provision was made to successfully recruit qualified and competent professionals to serve the medical laboratory needs of Ghanaians. My surprise is when the writer never proffered directions on how the ACT 857 should have been implemented to address his concerns but rather chose scenarios from UK and USA. Even with the scenarios cited, the facts were misapplied. Assuming, the ACT 857 was implemented wrongly, as claimed in the article, one would have wished countries close to Ghana (Nigeria, Egypt, Kenya, Tanzania and others in African) with good practices would have been cited. The choose and pick of practices across different cadre of professionals from UK and USA by the writer is problematic. With the clarity of the ACT 857, Part 1 on who can be a MLS professional, I cannot appreciate the submissions under the “Hollow Claim” of the writer. There are many professionals with qualifications other than Medical Laboratory Technology (MLT) registered with the AHPC once you have the required body of knowledge.

In the UK, before one can practice in the medical laboratory as a professional scientist, you need to provide academic qualification which shows the individual has undertaken;

  1. Core Subject areas: Biology: Primarily anatomy and physiology which should include cell biology, genetics, molecular biology and immunology. Biochemistry: Essentially the study of chemical processes which support life. Numeracy, Statistics and Computing. Instrumentation/Analytical Technique.
  2. Key subject areas: The programme should cover adequately the main traditional pathology specialisms: cellular pathology/cytology, clinical chemistry, clinical haematology, immunohaematology and transfusion science, medical microbiology/virology and clinical immunology.

In fact, a fundamental requirement of biomedical science degrees is an integration of the core science and the key/specialist subject areas through a study of a pathophysiology or biology of disease component, which should consider the human disorders and disease processes together with their investigation. The existence of these must be adequately demonstrated before one can satisfy the requirements of the Health and Care Professionals Council (HCPC) to register as a Biomedical Scientists in the UK (same as Medical Laboratory Scientists by the AHPC in Ghana). It is complete falsehood and throwing of dust into the eyes of the public that graduates of biochemistry, biological science, chemistry, zoology, and others are allowed to practice medical laboratory science straight from their institutions without top ups in accredited institutions. The IBMS offer Certificate of Competence to individual applicants before being accepted by the HCPC for license. There is no where on the websites of the IBMS and HCPC that graduates with the backgrounds mentioned by the writer are registered without top up except those with biomedical science degrees. Those who have Masters degree in the biomedical science specialty from recognized institutions are accepted for specialist registration as Chartered Scientists (IBMS 2016-2017). The UK example is exactly how the AHPC operates in Ghana and for that matter my surprise of the concerns raised by the writer.

To respond to the USA scenario, professionals of the MLS and Physicians are to be certified by the American Society of Clinical Pathologists (ASCP). There is an extension for international professionals who are given ASCPi certificate. It is very clear who qualifies to be able to take their exams before license just like in the UK. I have about five (5) of my colleagues who got into USA and had to write the exams for certification before qualifying for employment. The requirements are explicit just as by AHPC in Ghana. Once you satisfy the requirements of the law, no one, whether “… friends or foes …”, can misapply the law. Since “… Ghana does not learn from best practices but is doing something else”  and the writer refuses to describe the good ways the laws could have been implemented, I would add my voice to the fact that ACT 857, Part 1 is one of the best things to have happened to this country to get rid of quacks. This the writer does not refuse. On the concerns of implementation, since quality is a destination, I know we will get there because “Rome was not built in a day” and let no one think that the best laws only exist in the UK and USA.

The writer raises some “Concerns” and “Arguments” which are not founded as explained in earlier portions of this rejoinder. There are people who held biosciences certificates recognized by the law and those who have obtained biosciences certificate post-ACT 857 who followed requirements of the law and are equally accepted and registered. I wish the writer be informed of the happenings in the field of medical laboratory practice under the regulations of the AHPC rather than building on the unfounded concerns of MSSG. In certain parts of the world, chemist who mix compounds to develop drugs could be accepted to practice as Pharmacists. The laws of Ghana is against such practice. In the UK, MLS can rise through professional development to do tissue cut-up, prepare slides and do histological examination to report. Such individuals could be accepted by the Royal College of Pathologists.

It is high time all come to embrace the fact that the training and development of professionals of MLS is regulated with prescribed laws of Ghana. Anyone who prefers to be accepted as one should go through the required training to acquire the needed knowledge and skills to practice. The believe of “ability to do all things” as claimed by the article is the root of inefficiency and has been the woes of medical laboratory practice pre-ACT 857 in Ghana. Despite the challenges faced, I am sure of one thing, QUACKERY will forever be extinct and Ghanaians will enjoy quality medical laboratory services.

 

DENNIS ADU-GYASI
0207028698/0209097616