Mr Emmanuel Krishnan

Profession: Radiographer

Registration Number: RA47164

Hearing Type: Final Hearing

Date and Time of hearing: 10:00 10/12/2018 End: 17:00 18/12/2018

Location: Health and Care Professions Tribunal Service (HCPTS), 405 Kennington Road, London, SE11 4PT

Panel: Conduct and Competence Committee
Outcome: Conditions of Practice

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During the course of your employment as a Band 6 Radiographer with the Royal Surrey

County Hospital NHS Foundation Trust, between 3 March 2015 and 20 April 2015, you:

1. Did not demonstrate appropriate knowledge of radiotherapy principles, in that you:

a) could not define and/or explain ‘Isocentre’

b) could not define ‘Prostatectomy’ and/or explain the clinical implications of this;

c) on a number of occasions:

i) did not apply the correct imaging tolerance

(ii) were unable to provide correct imaging tolerances.

2. Did not demonstrate basic ALARA and/or radiation safety principles in that you:

a) attempted to irradiate a patient unnecessarily

b) triggered the ‘last man out’ safety interlock whilst a colleague was still in the treatment room.

3. On a number of occasions when setting up patients for treatment, you:

a) did not set the laser height and/or couch height correctly

b) were unable to correct the laser height and/or couch height without prompting by a colleague

4. Did not account for pitch and/or rotation when moving patients into position.

5. On a number of occasions you:

a) when moving the isocentre:

(i) did not demonstrate appropriate knowledge of which direction corresponds with adding and subtracting

(ii) moved the treatment couch in the wrong direction

(b) were inaccurate and/or inconsistent with your mathematics

6. The matters set out in paragraphs 1 –5 constitute lack of competence.

7. By reason of your lack of competence you fitness to practise is impaired.


Preliminary matters:

Composition of the Panel

1.The Registrant Panellist member Mrs Dickie informed the Registrant and Mr Ferson that during the period 2010 to 2012 she knew one of the witnesses, NR. Mrs Dickie knew NR as a student at the University of Portsmouth and was one of her lecturers. NR was a “friend” of Mrs Dickie on Facebook at this time. Mrs Dickie confirmed that she has not had contact with NR since 2012 and was no longer a “friend” of NR on Facebook.

2.Mr Ferson and the Registrant were given the opportunity to comment. They did not object to Mrs Dickie continuing as the Registrant Panellist member.

3.The Panel accepted the advice of the Legal Assessor.

4.Taking into account the time that has elapsed since 2012 and the lack of contact since 2012 between Mrs Dickie and NR, the Panel decided that a fair minded and informed observer would not consider that there was a real possibility that Mrs Dickie was biased. Therefore, the Panel should not recuse itself and the hearing should proceed.

Hearing in private

5.The Panel decided that it was appropriate to hear parts of the hearing in private. This decision was limited to the evidence relating to the health and private life of the Registrant and of the witness NR.


6.Following a telephone interview, the Registrant commenced work as a Band 6 Senior Radiographer at the Royal Surrey County Hospital NHS Trust (the Trust) on 3 March 2015. The Registrant had previously worked in a Band 6 Role for the NHS in Poole. There was a lengthy gap of almost two years between the Registrant’s last employment as a Radiographer and the start of his employment by the Trust. In the interim period the Registrant was in India for personal reasons. Given that the Registrant had not worked as a Radiographer for some time, he was required to complete the competencies for a Band 5 radiographer.

7.The Registrant was based at the Trust’s Redhill satellite site in Redhill. During his induction period he was also required to visit the Guildford site for training and clinical sessions in order to become proficient in all treatment areas.

8.The Registrant was allocated a mentor, MK, who was an Advanced Practitioner Treatment Radiographer. The Registrant met regularly with MK and HN, who was a Practice Educator and Band 7 Radiographer. Concerns about the Registrant’s performance as a Band 6 Radiographer were raised immediately, and it was decided that the Registrant would spend time in a supernumerary role, and that he would follow the probation policy and work under the guidance of a preceptorship competency framework. Regular review meetings took place in which MK and HN raised concerns about the Registrant’s lack of progress. In the meetings the Registrant stated that he believed he was making progress. The Registrant also had access to training resources which were available to him through the Trust’s electronic systems. He did not ask for further support or training.

9.At the Redhill site the Registrant worked (at the time in question) with a team of Radiographers including LF, a Band 5 Radiographer, KM a Band 7 Lead Radiographer, AD a Band 7 Advanced Practitioner Treatment Radiographer and NR Senior Radiographer. As part of his induction the Registrant also attended clinical sessions at Guildford with JN, Senior Therapy Radiographer.

10.The Registrant’s employment with the Trust ended on 20 April 2015.

Decision on Facts:

11.The Panel carefully read the HCPC bundle of exhibits and the Registrant’s written response to the HCPC Allegation dated 11 May 2016.

12.The Panel heard evidence from MK, HN, LF, KM, AD, NR and JN. The Panel found that the witnesses were generally credible. There were some differences between the witnesses and the Panel considered that these differences were due to the witnesses describing their genuine but differing perceptions and feelings.

13.The Panel had some reservations about the evidence of the witnesses due to the passage of time since the events in 2015. The Panel also considered that there had been some discussion between some of the HCPC witnesses about the matters alleged. The Panel noted that the contemporaneous statements made by the witnesses, which were all written in the period from 24 April 2015 to 28 April 2015, used very similar terminology. The contemporaneous statements included references to incidents where the Radiographer did not directly witness the event described. An example is that a Radiographer JT described the Registrant triggering the “last man out” safety interlock, even though he was not a witness to that event.

14.The Panel heard evidence from the Registrant. The Panel found that the Registrant was strong in his beliefs and has remained consistent between his statement to the Investigating Committee in May 2016 and his evidence to the Panel. The Panel considered that the Registrant has tried to be as honest as he can be, describing the events as he remembers them.

15.In respect of the background matters KM described a bullying culture by other members of the radiography team in Redhill, whereas JN’s perception was that KM was a bully. Given these differing perceptions, the Panel considered that there were communication or personality issues within the Redhill team in March-April 2015. At the Redhill satellite site there was a tightknit group (excluding KM) of predominantly female staff who had developed successful working relationships and confidence in each other. Initially the team was positive about the Registrant’s arrival, but as difficulties arose and continued the Registrant became socially excluded from the team. This had a negative impact on his morale which was already low due to an unfortunate chain of events.

16.The Registrant had not practised as a Radiographer for one year and nine months. At his telephone interview he expressed his concerns that he was “rusty” and would need support. When he began work the Registrant was not able to fully focus on the tasks because there were problems with his accommodation and he was spending time and energy resolving these issues. He had some health concerns but was unable to access a GP. Although he was provided with a mentor, he did not have access on a daily basis to a manager to speak about the issues he was experiencing. There was some contact with a manager, but this only took place in some of the meetings to review his progress against the competencies.

17.Although the team at Redhill was a tightknit group and there were inevitably discussions between members of the team about the Registrant, there was no agreed strategy to damage the Registrant or play with his emotions. The HCPC witnesses appeared genuinely hurt or felt insulted that the Registrant had made this suggestion. The Panel can understand that, to some extent, the Registrant may have felt isolated and unsupported, but the extent of his criticism of the Radiographers was not justified.

Particular 1(a)

18.The Panel found particular 1(a) not proved. Although the Registrant failed to explain the term “isocentre” on at least one occasion, this was because he declined do so. The HCPC has not proved that he could not do so.

19.The Radiographers asked the Registrant many questions and continued to do so because they were assessing his level of competence and he had not demonstrated to them the level of knowledge and skill they would expect of a Band 6 Radiographer. The Registrant was “rusty” in some areas and he was unfamiliar with some of the machines and processes.

20.The Registrant became upset and frustrated by the questioning, particularly where the questions related to basic principles. His perception was that he was being treated unfairly and therefore did not provide an answer when he was asked about an isocentre. The Registrant recalls that this was on only one occasion.


21.The Registrant gave the impression to the Radiographers that he did not know what an isocentre was because he declined to answer their questions.

22. The Registrant had over twenty years of experience as a Radiographer and had worked successfully as a Radiographer for eight years at Poole Hospitals NHS Trust from 2005 to 2013. He was able to explain “isocentre” in his evidence to the Panel.

23.The Panel decided that it was not likely that the Registrant as an experienced Radiographer could not define “isocentre” and that it was more likely that the Radiographers perceived the Registrant’s refusal to respond to the question as an inability to respond.

Particular 1(b)

24.The Panel found particular 1(b) not proved. The Registrant remembers only one instance when he was asked about a prostatectomy by JT, a Radiographer and that he declined to answer for the same reasons he declined to answer the question about an “isocentre”. The HCPC relied on evidence of two occasions on which the Registrant appeared to the Radiographers to be unaware of what a prostatectomy was.

25.The Panel concluded that it was more likely that the Registrant failed to answer the question or questions because he was upset by the questioning. The Registrant was very clear in his evidence that he knew what a prostatectomy was and that this was basic knowledge. Again, as with the term “isocentre”, the Panel decided that there had been a miscommunication between the Registrant and the HCPC witnesses. The HCPC has not proved that the Registrant “could not” define the term.

26.The Panel also found that the HCPC has not proved that the Registrant could not explain the clinical implications of a prostatectomy. There was no evidence that the Registrant was asked a question specifically about the clinical implications of a prostatectomy. As with the definition of a an isocentre and a prostatectomy, the clinical implications of a prostatectomy is basic knowledge that a Radiographer with over twenty years of experience would know.

27.The Registrant was unfamiliar with the use of fiducial markers in relation to patients with a prostatectomy. At the Trust small gold fiducial markers were implanted into the patient’s prostate to assist in matching images. The Registrant had no previous experience of the use of these markers when he worked at Poole. The Panel decided that the Registrant’s lack of knowledge relating to gold fiducial markers was not a lack of understanding of the clinical implications of a prostatectomy.

Particular 1(c)

28.The Panel found particular 1(c)(i) not proved because the HCPC has not proved that there was a failure on a number of occasions.
29.The HCPC evidence to support this particular is the evidence of JN. The Registrant recollected that he always worked at Guildford in a supernumerary role with two radiographers and that all his work was directly supervised. JN did not have a specific recollection of the Registrant working in a supernumerary position and she was unable to say whether or not another Radiographer was present at all times.

30.In her witness statement JN described a process of matching online images when making treatment decisions. This pre-treatment process, as described by JN, does not involve the application of imaging tolerances. The application of imaging tolerances occurs later, at the point of clinical treatment.

31.Later in her witness statement JN described the application of imaging tolerances when she referred to the loading of the treatment fields ready for treatment delivery. In her oral evidence JN explained that when the treatment fields were loaded there were occasions when the machine would load the fields automatically. There was no evidence to confirm whether the Registrant had loaded the fields or the machine had loaded the fields or the number of occasions on which the Registrant had himself loaded the fields incorrectly. There was therefore no evidence that a failure to apply the correct imaging tolerances had occurred on a number of occasions.

32.The Panel found particular 1(c)(ii) proved. The Registrant admitted this sub-particular.

33.The imaging tolerance is required to ensure that therapy is provided to the same area on every occasion in accordance with the treatment plan. The specific tolerances differ for different areas of treatment; for example the tolerance for a pelvis patient was 0.2cm, and for a breast patient 0.5 cm. The tolerances vary between cancer centres and the Registrant was expected to check the tolerances in use at the Trust which were documented and available to him electronically.

34.The Panel found this sub-particular proved by the evidence of MK, LF, AD and JN who described a number of occasions when the Registrant was unable to provide the correct imaging tolerances when he was asked.

Particular 2(a)

35.The Panel found particular 2(a) not proved.

36.The Panel accepted NR’s evidence that the Registrant had his hand over the console and that her perception was that the Registrant was about to press the “beam on” button which would have irradiated the patient unnecessarily. The Panel considered that her description of this incident as one of the “more scary days” that she had worked was an overstatement. In her written contemporaneous account she described it as “almost an incident” and did not emphasise any particular seriousness. No written report was made of the incident as a “near miss”.

37.The Panel did not consider that the evidence of AD added to NR’s evidence concerning this incident because AD’s description was vague and lacking in detail.

38.The Panel accepted the Registrant’s account of the incident. He was clear and consistent in stating that he knew that he should not irradiate the patient until the gantry had been moved to the second field and that he would not do this. He acknowledged that he had his hand over the console, but that this was to move the gantry, not to irradiate the patient. He was also clear in stating that he removed his hand when told to do so.

39.The Panel gave greater weight to the Registrant’s evidence as to his state of mind at the relevant time than, to NR’s perceptions of his intentions.

Particular 2(b)

40.The Panel found particular 2(b) not proved.

41.The HCPC witnesses explained that the last man out safety interlock is a safety system whereby the machine will only operate and deliver radiation to the patient if the room is safe for treatment and all staff have left the area. The staff exit the room through a corridor. The last member of staff to leave the room presses a button (the “last man out” button) and closes a wooden door which sends a signal to the machine. The interlock is not set until both the button is pressed and the door is closed. The closing of the door is one stage of the process of triggering the safety interlock, but the whole safety process requires both the “last man out” button to be pressed and the door to be closed.

42.On one occasion the Registrant was working with two Radiographers, KM and LF. The Registrant and KM left the room and were sitting at the computer outside the treatment room. When LF left the treatment room to join the Registrant and KM she found that the door was closed. There was no evidence from either HCPC witness that the “last man out” button was pressed by the Registrant or that it was pressed at all until it was activated by KM herself when she left the room.

43.Although it was likely that the Registrant closed the door, and he admitted this, the HCPC has not proved that the “last man out” safety interlock was triggered because this is a safety process requiring two steps of pressing the “last man out” button and closing the door.


Particular 3(a)

44.The Panel found particular 3(a) not proved.

45.On one occasion the Registrant was unable to set the couch height. This incident was described by JN. The Registrant volunteered to set the laser height, but this was out of tolerance. He required direction from JN in order to rectify the situation.

46.A failure to set the laser height or couch height was not identified by any other HCPC witness. Therefore, the HCPC has not proved that the Registrant failed in this task on a number of occasions.

Particular 3(b)

47.The Panel found particular 3(b) to the extent that there were two occasions when the Registrant was unable to correct the laser height or couch height.

48.In the incident described by JN, the Registrant was unable to correct the laser height that he had set up incorrectly. He required guidance to set it up correctly. Another occasion was described by AD. She and another Radiographer had purposely set the couch height 3 cm out of tolerance. The Registrant was questioned on three occasions as to whether he was happy with the couch height and he replied that he was happy.

Particular 4

49.The Panel found particular 4 proved. The Registrant agreed that during the first few weeks of his employment he was not able to account for pitch and rotation when moving patients. He stated that this was being remedied towards the end of the period of his employment.

50.The HCPC witnesses, MK, LF, AD and NR described incidents when the Registrant failed to account for pitch or rotation when moving patients into position. Patients were given a number of small tattoos which assisted the Radiographer to align the lasers prior to delivery of radiation treatment. For pelvis patients the alignment of the tattoos may be incorrect if the pelvis is not correctly tilted in one or more directions. If this occurred the Radiographer asked the patient to tilt their pelvis to correct the pitch or rotation to ensure that the tattoos aligned. These adjustments were necessary to ensure that the treatment was delivered to the correct location.

Particular 5(a)

51.The Panel found particular 5 (a)(i) proved.

52.JN explained that in order to position the patient correctly to the correct isocentre (location for the delivery of treatment), the couch must be moved laterally, longitudinally, and vertically by a set amount. The Radiographer moves the bed in the opposite direction to the one calculated. When undertaking the calculations prior to moving patients the Registrant was not always aware of which direction corresponded with adding or subtracting. LF and MF described the same difficulty. LF explained that the Registrant struggled with maths in terms of knowing which direction was to add or subtract. Even after repeated prompting he was inconsistent and often inaccurate. LF noticed the error on multiple occasions.

53.The Panel found particular 5(a)(ii) proved by the witness statement and oral evidence of JN who described a number of occasions when the Registrant moved the couch in the wrong direction when preparing and positioning the patient for treatment.

Particular 5(b)

54.The Panel found particular 5(b) proved. The Registrant admitted that he was inaccurate or inconsistent with his mathematics.

55.MK confirmed that the Registrant struggled with mathematics and that she made a suggestion that he should buy a pocket calculator. Occasions when the Registrant was inaccurate or inconsistent were described by LF, AD and JN. AD referred to the Registrant frequently making mistakes. She acknowledged that mistakes do happen, but with the Registrant the mistakes were frequent even when she pointed out what the Registrant was required to do.
Decision on Grounds:

56.The Panel was satisfied that the proved particulars represent a fair sample of the Registrant’s work. Taking into account mandatory training days, the Registrant worked as a Radiographer for a short period of time. Nevertheless, within those days of work there were examples of the same error or failure being repeated on several occasions.

57.In considering whether the proved particulars constituted a lack of competence the Panel applied the standard applicable to the post to which the Registrant had been appointed, a Band 6 Radiographer.

58.While the environment in which the Registrant was working could have been more supportive, in the Panel’s judgment the errors made by the Registrant related to basic areas of knowledge and skill for a Radiographer relating to the task of moving patients into the correct position and the mathematical calculations required when moving the treatment couch. It is also part of basic knowledge and skill to either learn the correct imaging tolerances or be able to find this information quickly. The Registrant had not satisfactorily reached the level of skill and knowledge expected of a Band 5 Radiographer and certainly not the competency required of a Band 6 Radiographer who would be expected to guide others.

59.The Panel considered that the Registrant was in breach of the HCPC Standards of Conduct, Performance and Ethics:

•5. “You must keep your professional knowledge and skills up to date”.

60.The Panel also considered that the Registrant was in breach of the Standards of Proficiency for Radiographers in particular:

•1. “be able to practise safely and effectively within their scope of practice”;

•3.3. “understand both the need to keep skills and knowledge up to date and the importance of life-long learning”;

•4. “be able to practise as an autonomous professional, exercising their own professional judgment”;

•11. “be able to reflect on and review practice”;

•13. “understand the key concepts of the knowledge base relevant to their profession”;

•13.9. “understand and be able to apply the physical principles of ionising radiation production, interaction with matter, beam modification and radiation protection for diagnostic imaging or radiotherapy treatment”;

•14. “be able to draw on appropriate knowledge and skills to inform practice”;

•14.9. “be able to interrogate and process data and information gathered accurately in order to conduct the imaging procedure or radiotherapy most appropriate to the service user’s needs”;

•14.10 “to be able appraise image information for clinical manifestations and technical accuracy, and take further action as required”.

•14.18. “be able to operate radiotherapy or diagnostic imaging equipment safely and accurately”;

•14.24. “be able to position and immobilise service users correctly for safe and accurate imaging examinations or radiotherapy treatments;

•14.39. “be able to perform the full range of radiotherapy processes and techniques accurately and safely”.

61.When he treated patients the Registrant worked in a supernumerary role and was supervised by other Radiographers. In this environment there was no harm to patients, nor was there a risk of harm. However, if the Registrant had been working as a Band 6 Radiographer, there was the potential for harm to a service user. In particular there was a risk that patients might be subject to irradiation incorrectly due to incorrect positioning, or that the radiation was not correctly directed to treat the tumour requiring treatment.

62.In the Panel’s judgment the proved particulars demonstrated a standard of work which was unacceptably low and constituted a lack of competence.
Decision on Impairment:

63.The Panel accepted the advice of the Legal Assessor and had regard to the HCPTS Practice Note “Finding that Fitness to Practise is Impaired”. The Panel considered the Registrant’s fitness to practise at today’s date.

64.The Registrant has not worked as a Radiographer since April 2015. He returned to India and has worked in a position in hospital administration. He has not undertaken training relevant to his clinical practice as a registered Radiographer.

65.The Panel considered that the Registrant has demonstrated some insight. He made some admissions at the outset of the hearing and he informed the Panel that after self-reflection he has decided that in future he would apply for a band 5 position. He described to the Panel some of the lessons he has learned from his experiences.

66.The Panel did not consider that the Registrant has full insight. The Panel was concerned that he failed to demonstrate that he took personal responsibility for his own learning and development. He demonstrated a passive approach, expecting the Panel to direct him on the appropriate course of action. He did not demonstrate that he now understands his personal responsibility to ensure that he maintains his fitness to practise through education and training.

67.The Panel was also concerned that the Registrant blames others for his lack of competence. The focus in his written submissions and his oral evidence was on his belief that members of the team had a strategy to hurt him emotionally. While the Panel recognise that he may be describing how he genuinely felt at the time of the events, his focus on other members of the team distracted him from fully recognising his own responsibility and the actions he needed to take to remedy his lack of competence.

68.In the Panel’s judgment the Registrant’s lack of competence is remediable, but it has not yet been remedied. There is no evidence to demonstrate that the lack of competence has been addressed. The Registrant himself stated in evidence that he does not feel competent at present to return to unrestricted practise as a Radiographer.

69.The Panel was concerned that if the Registrant was free to practise as a Radiographer without restriction, there is a risk of repetition of the failures and errors found proved by the Panel. The Panel therefore concluded that the Registrant’s fitness to practice is impaired on the basis of the personal component.

70.The Panel next considered the wider public policy considerations including the need to protect service users, uphold standards of conduct and behaviour and maintain public confidence in the profession and the regulatory process.


71.The Panel noted that there was the potential for harm to patients if the Registrant’s errors and failures were repeated in an environment where he was not working under supervision. The nature of the risk would be a concern for members of the public because there is general public awareness of the need for patient exposure to radiation to be minimised and directed to the correct area. Members of the public would also have concerns about the Registrant’s passive approach, his failure to take full responsibility and the ongoing risk of repetition.

72.Therefore, in the Panel’s judgment public confidence in the profession and the regulatory process would be undermined if the Registrant was free to practise without restriction. The Panel concluded that the Registrant’s fitness to practise is impaired on the basis of the public component.

Decision on Sanction:

73.The Panel heard submissions from Mr Ferson and from the Registrant.

74.The Registrant thanked the Panel and all the participants in the Hearing for having heard his case fairly and transparently. He apologised in respect of the matters which the Panel found proved and told the Panel that he took full responsibility for his actions. He suggested that the maximum Order the Panel should impose was a Caution Order.

75.The Registrant told the Panel that he is due to commence work on 3 January 2019 at Bangalore Baptist Missionary Hospital. He will be working in administrative position and not employed as a Radiographer. His employer is not currently aware of the HCPC proceedings. The Registrant expects that he will be able to take time during the week to engage in clinical practice at the Hospital under the supervision of a Radiographer. He hopes to gain knowledge and skills and receive written confirmation of his competency which he could provide to the HCPC over the course of approximately six months.

76.The Registrant’s future career plan is that he intends to return to the UK to work as a Radiographer. This is not an immediate plan, but he is looking forward to returning to the UK once he has refreshed his knowledge and skills in India.

77.In considering which, if any, sanction to impose the Panel had regard to the HCPC Indicative Sanctions Policy (ISP) and the advice of the Legal Assessor.

78.The Panel reminded itself that the purpose of imposing a sanction is not to punish the practitioner, but to protect the public and the wider public interest. The Panel ensured that it acted proportionately, and in particular it sought to balance the interests of the public with those of the Registrant, and imposed the sanction which was the least restrictive in the circumstances commensurate with its duty of protection.

79.The Panel decided that the aggravating features were:

•the Registrant made fundamental errors relating to basic principles of radiography despite his lengthy experience;

•no evidence that he has addressed the shortcomings.

80.The Panel decided that the mitigating features were:

•the Registrant’s previous good character;

•the context of the workplace, in particular the lack of a clear management structure;

•issues in the Registrant’s private life

•the absence of harm or risk of harm to patients

81.The Panel considered the option of taking no action or mediation, but decided that they were not appropriate because of the seriousness of the concerns and the ongoing risk of repetition.

82.The Panel next considered a Caution Order. The Panel did not consider that the guidance in the ISP for Caution Orders applied. Although the Registrant has stated that he will complete competencies in India the Panel has no information on how those competencies relate to the competencies required for a Radiographer in the UK or the deficiencies in the Registrant’s practice the Panel has identified. The Panel was not sufficiently confident that the Registrant will take the necessary steps if he is not subject to a reviewable restriction on his practice.

83.The Panel next considered a Conditions of Practice Order. The Panel considered that the Registrant has a sufficient level of insight for conditions of practice to be considered. The Panel also had sufficient confidence that the Registrant would comply with conditions of practice. The Panel considered that the risk of repetition in this case could be addressed by conditions of practice.

84.The Panel decided that a condition requiring the Registrant to limit the scope of his practice to a Band 5 Radiographer role was necessary. This ensured that the Registrant would not be employed in a senior position with responsibility for leading others. A condition requiring the Registrant to notify his employer of the conditions was also necessary so that future employers are aware of the HCPC proceedings and the Panel’s concerns about particular areas of lack of competence. It was also necessary for the Registrant to have in place a workplace supervisor. The supervisor will monitor the Registrant’s progress and ensure that he is practising safely. These conditions will apply if the Registrant works as a Radiographer in the UK.

85.The Panel also decided that the Registrant should be required to provide to formulate a personal development plan and provide it to the HCPC within three months from today. The development plan should set out the steps the Registrant plans to take to address the deficiencies in his practice. This gives the Registrant flexibility to consider a number of possible options including training courses or clinical practice under supervision. This ensures that the Registrant will be pro-active in taking remedial action to reduce the risk of repetition.

86.The Panel considered the wider public interest considerations and was satisfied that a Conditions of Practice Order was sufficient. The conditions of practice reassure members of the public and protect the reputation of the profession because they address the ongoing risk of repetition. A Conditions of Practice Order was a sufficiently severe sanction to deter other Registrants.

87.The Panel considered the more restrictive option of a Suspension Order. The Panel decided that this was not necessary or proportionate. The conditions of practice the Panel has formulated address the risk of repetition and therefore protect the public. A Conditions of Practice Order permits a rehabilitation process and gives the Registrant an opportunity to demonstrate to a future Review Panel that he is fit to practise as a Radiographer.

88.The Panel decided that the appropriate length of time for the Conditions of Practice Order was twelve months. This period struck an appropriate balance between the Registrant’s interests and the public interest. It allowed a realistic time period for the Registrant to comply with the Conditions of Practice and prepare evidence for a Review Hearing.

89.The Panel therefore decided that the appropriate and proportionate Order is a Conditions of Practice Order for a period of twelve months.

90.The Conditions of Practice Order will be reviewed before it expires. A future Reviewing Panel may be assisted by:

(a) evidence of compliance with the Conditions of Practice Order;

(b)  a report from the Registrant’s workplace supervisor (alternatively, if the Registrant has not been employed as a Radiographer, references or testimonials from any employer);

 (c) a reflective piece on the Panel’s findings including the impact of the Registrant’s lack of competence on colleagues and potential impact on patients;

(d) evidence that the Registrant has kept his continuing professional development (CPD) up to date.


The Panel decided to impose a Conditions of Practice Order.


No notes available

Hearing History

History of Hearings for Mr Emmanuel Krishnan

Date Panel Hearing type Outcomes / Status
10/12/2018 Conduct and Competence Committee Final Hearing Conditions of Practice