Professional Scientists Australia submission to the review to the RTAC Code of Practice

Professional Scientists Australia represent several thousand members in labs around Australia, including Embryology. In February of 2020, we submitted a review to the FSA regarding the RTAC Code of Practice raising issues that are of high importance to our members and patient safety.

Professional Scientists Australia are disappointed and concerned that the FSA has taken no steps to address the issues raised in our survey. There has been no acknowledgement of embryologist’s concerns, no investigation, no feedback and no consultation.

As a reminder of the seriousness of this issue, we refer to our original submission in which we found that of our survey respondents,

  • 74.5 per cent of respondents reported working more hours in an average week than they are contracted to perform, 
  • 72.5 per cent had had a request for recreation/annual leave refused,
  • 66.7 per cent of respondents said they thought staffing was not adequate to safely support the annual EPU case load, 
  • 76.5 per cent said that workload had led to increased stress and fatigue,
  • 56.9 per cent said that workload had harmed their mental health,
  • 72.5 per cent said workload had increased to possibility of human errors occurring (in the laboratory), 
  • 93.6 per cent of respondents said the Code needed to include provisions to protect against too few fertility scientists, 
  • 89.4 per cent of respondents said that the Code should include explicit provisions for adequate staff ratios.

These are serious issues and anecdotally there has been no improvement in the year and a half since the survey was conducted.

The new code includes the additional statement under 1.5 Stakeholder feedback (Critical Criterion 3) “Stakeholders must be provided with avenues that allow the escalation of a complaint to persons or organisations outside of the ART Unit”. There is a failure by the Fertility Society Australia to consider the gaps that have allowed workers as key stakeholders limited avenue of complaint, and no process exists for workers to make a direct complaint to the FSA as the peak regulatory body.

Self-regulation of ART was formed in the absence of government regulation in its inception. Since then, IVF has rapidly evolved into a highly competitive industry worth over half a billion dollars a year in Australia, and it is increasingly evident that the costs of competition have put the health and safety of staff and patients at risk.

The FSA as self-regulator of an industry that receives significant government funding through Medicare, have a duty in the public interest to investigate and report upon any submissions made as part of the review process.

Can the FSA provide evidence that there has been any investigation into the issues or recommendations made in our submission? We are aware a group of SIRT volunteers began an investigation and reporting process which was essentially grounded due to scheduling difficulties, independently highlighting how time poor embryologists are. No report was ultimately commissioned.

None of the recommendations of Professional Scientists Australia have been met, or addressed, nor is it apparent they have been considered. It is the view of Professional Scientists Australia that the FSA continue to enable high levels of unmanaged risk and that there must be urgent inclusions into the Code of Practice before its release specifically addressing staffing.

We look forward to correspondence specifically addressing our concerns, and furthermore are available via telephone, to meet separately to the report back zoom, and will be present at the report back zoom, Monday 2-4pm.
Read full letter here
(Adobe PDF File)