Miss Kate E Gibson
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Allegation:(As amended on Day 1 of the hearing on 2 July 2018)
During the course of your employment as a Radiographer at Freeman Hospital, you:
1. Were at work whilst under the influence and/or smelling of alcohol on:
a) Wednesday 13 July 2016
b) Monday 25 July 2016
c) Tuesday 26 July 2016
2. On 6 June 2016, you:
a) Incorrectly positioned Patient A and/or the x-ray equipment
b) Took an x-ray of the wrong hip for Patient A
c) Exposed Patient A to a higher amount of radiation than was required.
3. On 17 June 2016, you:
a) Did not adjust the settings on the x-ray equipment before taking an x-ray of Patient B.
b) Did not take a diagnostic image of Patient B.
c) Exposed Patient B to a higher amount of radiation than was required.
4. On 26 July 2016, you:
a) Made numerous technical errors whilst x-raying Patient C in that you:
i) Did not line up the x-ray tube with the receptor
ii) Centred over the mid-femur instead of the hip joint
iii) Centred over the metal edge of the table rather than Patient C
b) Exposed Patient C to a higher amount of radiation than was required.
5. Your actions as described in paragraph 1 constitute misconduct
6. Your actions as described in paragraph 2 – 4 constitute misconduct and/or lack of competence
7. By reason of you misconduct and /or lack of competence, you fitness to practise is impaired
1. The Panel has seen a copy of the Notice of Hearing dated 5 April 2018 which contains all relevant information, the proof of posting of the same date, and a copy of the certificate of the Registrant’s registered address. The Panel determined that there was good service of the Notice of Hearing on the Registrant at her registered address in accordance with the provisions of rules 3 and 6(1) of The Health and Care Professions Council (Conduct and Competence Committee) (Procedure) Rules 2003, as amended (“the Rules”).
Proceeding in absence
2. The Panel heard a submission from Ms Ryan on behalf of the HCPC to proceed in the absence of the Registrant under Rule 11 of the Rules. The Registrant was not present or represented, nor sought an adjournment, but has sent written representations dated 5 March 2018 for this substantive hearing. Ms Ryan also referred the Panel to an HCPC file note dated 21 June 2018 which recorded the Registrant being encouraged to attend the hearing, but the Registrant again stated that she did not wish to attend at all. Ms Ryan also stated that witnesses were present today and would be inconvenienced if the matter were adjourned.
3. The Panel accepted the Legal Assessor’s advice to consider all the circumstances and take account of the guidance in the relevant HCPTS Practice Note on “Proceeding in the Absence of the Registrant” (March 2017), and that the Panel had a duty to test the HCPC’s evidence if proceeding in the Registrant’s absence.
4. The Panel noted that the Registrant had not applied for an adjournment and made it clear that she had decided not to attend the hearing. These were serious matters and the Panel took account of the public interest in final hearings being dealt with expeditiously. The correspondence and pre-hearing telephone calls with the Registrant meant that there was no reason to think that if the hearing was adjourned, the Registrant would then attend or be represented.
5. The Panel determined that the Registrant had exercised her choice not to attend or be represented at the hearing today and there was nothing to suggest that she would attend, or be represented, on a future date if this hearing was adjourned. It was accordingly fair, proportionate and in the public interest to proceed with this final hearing in her absence.
Application to conduct hearing in private
6. Ms Ryan applied for the hearing to be heard partly in private pursuant to rule 10(1) of the Rules. Ms Ryan submitted that there would be occasional reference during the hearing to health matters relating to the Registrant and privacy was required to protect the Registrant’s private life in relation to the specific health matters.
7. The Panel accepted the Legal Assessor’s advice and took account of the guidance in the HCPTS’s Practice Note
“Conducting Hearings in Private”. The Panel determined that it would be practicable to hold the hearing partly in private and therefore determined that the hearing should be heard in private at times when necessary to protect the Registrant’s private life.
Application to amend the particulars of the Allegation
8. Ms Ryan applied to amend the stem of paragraph 1, paragraph 2(a), paragraph 3(a) and the paragraph 4(a) of the Allegation in order to clarify the matters alleged. Those proposed amendments were notified to the Registrant by letter dated 21 December 2017, and the Registrant had not raised any objection.
9. The Panel accepted the Legal Assessor’s advice that the Panel could amend the particulars if it determined that there would be no particular prejudice to the Registrant that outweighed the public interest in having the case against the Registrant properly presented.
10. The Panel considered the circumstances and determined that the Registrant would not suffer any particular prejudice that outweighed the public interest in having the case properly presented, and therefore allowed the amendments sought to clarify the case against the Registrant.
11. The Registrant is a Band 5 Diagnostic Radiographer who had one year post-qualification experience at Sunderland Royal Hospital before moving to work at the Freeman Hospital within the Newcastle Upon Tyne NHS Foundation Trust (“the Hospital”). Three particular incidents of concern were recorded by staff concerning the Registrant’s practice, and concerns were also raised by staff regarding the Registrant attending work whilst under the influence of and/or smelling of alcohol on three occasions.
Decision on Facts
12. Witness 1 was a Band 5 Diagnostic Radiographer at the Hospital from October 2014. Witness 1 confirmed the contents of her witness statement signed on 24 January 2018. This detailed her concerns about the Registrant on 13 July 2016 (when she was working with the Registrant) and on 25 and 26 July 2016 when she smelt alcohol on the Registrant’s breath and observed inappropriate behaviour. When questioned about that assessment, Witness 1 stated that she had no special training, knowledge or experience about how the Registrant’s health condition may have affected her behaviour or breath.
13. Witness 2 was a Band 6 Senior Diagnostic Radiographer and had been at the Hospital since November 2010. Witness 2 confirmed the contents of his witness statement signed on 17 January 2018 which detailed concerns about the Registrant’s conduct of an x-ray for Patient A on 6 June 2016 whilst he was working with her. The Registrant was taking the lead during the day and he, as a mentor, was observing her practice. After the Registrant had x-rayed Patient A, Witness 2 checked the patient request card which detailed the required x-ray and noticed that she had x-rayed the wrong hip. Witness 2 therefore had to ask Patient A to come back from the outpatient department and have the correct hip x-rayed, which was an unnecessary extra exposure of radiation to the patient.
14. Witness 3 had been a Band 7 Superintendent Radiographer from 2004 and became a Breast Unit Manager in October 2010 at the Hospital. She confirmed the contents of her witness statement signed on 17 January 2018 which detailed the investigation she conducted on behalf of the Hospital into the concerns which are now the subject of the HCPC’s allegations against the Registrant. Witness 3 exhibited her investigation report and its appendices, which included notes of investigatory meetings she conducted with the Registrant and other Hospital staff on various dates during her investigation.
15. Witness 3 stated that she smelt alcohol on the Registrant’s breath when she held a suspension meeting with her on 26 July 2016, but did not inform the Registrant of this. Witness 3 also acknowledged that the Registrant had offered to be tested for alcohol at that meeting and again the Registrant maintained that the smell on her breath was caused by her health condition. No test for alcohol was performed on the Registrant.
16. Witness 4 was the Head of Diagnostic Radiology Physics at the Hospital from 2010. He confirmed the contents of his witness statement signed on 17 January 2018 in which he explained his analysis of the Datix incident involving Patient B on 17 June 2016. His conclusion was that the Registrant had exposed Patient B to radiation some thirteen times higher than was appropriate when she took the x-ray, being 0.25mSv rather than 0.02mSv. The risk to Patient B arising from this higher exposure was classed as very low risk. The overexposure was caused by the Registrant failing to manually adjust the settings from default to those corresponding to an AP chest x-ray.
17. Witness 5 was a Band 6 Senior Radiographer based at the Hospital from March 2015 and was working with the Registrant in the Musculoskeletal Unit on 26 July 2016. She confirmed the contents of her witness statement signed on 13 January 2018 and explained that the Registrant’s breath smelt that day. At the start of the day she was unsure whether the smell was alcohol from the night before or whether it was caused by the Registrant’s health condition. However, as the day progressed, the smell got stronger and the Registrant got more and more clumsy, and Witness 5 felt sure that the Registrant was under the influence of alcohol. Witness 5 was also concerned about the Registrant’s skills, in particular an incident when the Registrant centred the x-ray tube over the metal edge of the table rather than the patient’s hip. This led to the patient being exposed to a higher amount of radiation. This incorrect positioning was not, in her opinion, to be expected from a qualified radiographer. The Registrant refused to complete a Datix incident form, so Witness 5 had completed a Datix incident form.
18. Ms Ryan submitted that the HCPC had produced sufficient evidence for the Panel to find each particular of the Allegation proved on the balance of probabilities. She submitted that the evidence of the three HCPC witnesses was both credible and reliable, and supported by the exhibited documents in the hearing bundle.
19. The Registrant submitted in her written representations that the overexposure incidents had occurred because she was training on equipment which she was not used to, and that she had never consumed alcohol or be under the influence of alcohol whilst at work.
20. The Panel accepted the Legal Assessor’s advice that the burden of proof was upon the HCPC to prove each and every Particular in the Allegation, and the standard of proof required was that a fact had to be proved on the balance of probabilities.
21. The Panel carefully considered all the documentary and oral evidence, and the submissions made.
22. The Panel found all the HCPC witnesses to be credible, reliable and consistent in their evidence. All gave full and open answers to the questions put to them and their recollections of events were good. Without exception, the witnesses were fair and balanced in their evidence and the Panel detected no animosity towards the Registrant. All attested to the existence of a supportive and friendly environment in the workplace.
Particular 1(a) – found proved
23. The Panel found the evidence of Witness 1 to be compelling. She described how she had smelt alcohol on the breath of the Registrant and was fair and balanced in considering, and rejecting, other causes for that smell. She had personal experience of alcoholism in a close relative and knew what she had smelt. She described how the Registrant had difficulty in controlling equipment and began repeating herself and slurring her words. Witness 1 observed that the smell of alcohol became “very strong” by the end of the day.
24. The Panel rejects the Registrant’s assertion that she was not under the influence of alcohol on 13 July 2016, finding it to be implausible in the face of Witness 1’s evidence.
25. The Panel finds that the Registrant was both under the influence of alcohol and smelt of alcohol whilst at work on 13 July 2016.
Particular 1(b) – found proved in respect of smelling of alcohol
Found not proved in respect of being under the influence of alcohol
26. The Panel accepts the evidence of Witness 1 that when the Registrant returned from a break on 25 July 2016 she again smelt of alcohol. The Panel notes that this is consistent with the untested evidence of another colleague who had emailed her line manager on 26 July 2016 about the Registrant smelling of alcohol at lunchtime on 25 July 2016. The Panel finds that the Registrant smelt of alcohol whilst at work on 25 July 2016.
27. There is no evidence before the Panel to satisfy it on the balance of probabilities that the Registrant was under the influence of alcohol whilst at work on 25 July 2016.
Particular 1(c) – found proved
28. In her evidence, Witness 5 stated that the Registrant smelt of alcohol whilst at work on 26 July 2016 and that the smell intensified as the day progressed and particularly immediately after the Registrant returned from breaks. Witness 5 observed that the Registrant’s co-ordination and behaviour deteriorated through time. In answer to questions from the Panel, Witness 5 stated very clearly that she “had no doubt that Kate Gibson was under the influence of alcohol” whilst at work on 26 July 2016. Witness 5 had personal experience of alcoholism in a close relative and was certain that she was not mistaken in interpreting what she smelt and saw.
29. In their evidence, Witnesses 1 and 3 stated that they had smelt alcohol on the Registrant’s breath whilst she was at work on 26 July 2016.
30. The Panel rejects the Registrant’s claim that what was smelt was caused by her health condition.
31. The Panel finds that the Registrant smelt of alcohol and was under the influence of alcohol whilst at work on 26 July 2016.
Particular 2(a) – Found proved in respect of incorrectly positioning Patient A
Not proved in respect of incorrectly positioning the x-ray equipment
32. In his evidence, Witness 2, a Senior Diagnostic Radiographer, stated that the Registrant had x-rayed the wrong hip of Patient A. This necessitated a repeat x-ray of the correct hip. The Panel is, therefore, satisfied that the Registrant had initially incorrectly positioned Patient A.
33. There was no evidence that the x-ray equipment had been incorrectly positioned by the Registrant.
34. In her written submissions, the Registrant offers the generic remark that “I acknowledge my mistake”, although this is not specifically attributed to the events on 6 June 2016.
Particular 2(b) – found proved
35. For the same reasons as particular 2(a) above, the Panel finds that the Registrant took an x-ray of the wrong hip for Patient A on 6 June 2016.
Particular 2(c) – found proved
36. Under discussion of particular 2(a) above, the Panel accepted Witness 2’s evidence that the Registrant’s action in taking an x-ray of the wrong hip of Patient A on 6 June 2016, necessitated a second x-ray of the correct hip. This exposed Patient A to a higher amount of radiation than was required. Accordingly, this particular is found proved.
Particular 3(a) – found proved
37. The Registrant completed a Datix: Incident/Accident/Near Miss Investigation Form on 29 June 2016 in respect of an incident involving Patient B on 17 June 2016. In this she stated that “…I hadn’t realised that the setting needed to be changed on the console”. On the same Datix, the “Investigators” are recorded as observing that “…the settings on the equipment were not changed”.
38. The Panel accepts the Datix evidence and finds that the Registrant did not adjust the settings on the x-ray equipment before taking an x-ray of Patient B.
Particular 3(b) – found proved
39. In her evidence, Witness 3, the Investigating Officer, stated that the Registrant took an undiagnostic image of Patient B on 17 June 2016 due to her failure to adjust the x-ray settings, and “too much radiation was administered which in turn rendered the x-ray undiagnostic”.
40. The Panel accepts this evidence and finds the alleged particular proved.
Particular 3(c) – found proved
41. The Panel took account of Witness 3’s evidence outlined above in relation to particular 3(b) and accepts the evidence of Witness 4, Head of Diagnostic Radiology Physics, that “the actual dose was 13 times higher than the intended dose”.
Particulars 4(a)(i) – (iii) found proved
42. In her evidence Witness 5 described how the Registrant “centred the x-ray tube over the metal edge of the table rather than the patient’s hip” when taking an x-ray of Patient C on 26 July 2016. The associated Datix report observed a problem of “not lining up the x-ray tube with the receptor”. The same Datix stated that one of the errors was “centring over mid-femur instead of the hip joint”. This observation is also consistent with Witness 5’s oral evidence.
43. The Panel finds charges 4(a)(i), (ii) and (iii) to be proved.
Particular 4(b) – found proved
44. In her evidence, Witness 5 observed that the errors in particular 4(a) above meant that “the patient was exposed to a higher amount of radiation than was required”.
Decision on Grounds
45. Ms Ryan submitted that it was a matter for the professional judgement of the Panel as to whether any or all of the proven facts amounted to the ground of misconduct and/or impairment. She submitted, though, that the Panel could conclude that a ground of impairment was made out on the proven facts, and invited the Panel to consider standards 1 and 9 of the HCPC’s “Standards of conduct, performance and ethics” in force from January 2016.
46. The Panel accepted the Legal Assessor’s advice that the matters of misconduct and/or lack of competence were matters for the independent professional judgement of the Panel. The ground of lack of competence required a fair sample of the Registrant’s work to not meet the required standards. Misconduct, on the other hand, was a different ground and requires a serious departure from the proper professional standards. A single negligent act or omission was unlikely to amount to misconduct, but could do so if particularly serious. Further, multiple negligent acts or omissions were more likely to cross the threshold of misconduct. Serious misconduct has been described in legal cases as conduct which put service users at unwarranted risk of harm; conduct which brought the profession into disrepute; conduct which breached a fundamental tenet of the profession; and conduct which fellow professionals would regard as deplorable.
47. The Panel finds that the Registrant’s actions in being under the influence of alcohol and smelling of alcohol whilst at work falls far short of what would be proper in the circumstances. These were not individual or isolated incidents and represent a serious departure from the standards expected. Fellow practitioners would find this conduct deplorable.
48. The Registrant’s failings in respect of her professional duties in taking x-rays of Patients A, B and C also fall well short of what would be proper and expected from a radiographer of her experience. Witness 2 gave evidence that the Registrant had demonstrated the ability to correctly carry out x-rays and the Panel concludes that she failed to do so on the occasions found proved. The Registrant’s actions amount to serious misconduct.
49. The Panel finds the Registrant to be in breach of the following standards in the HCPC’s “Standards of conduct, performance and ethics” in force from January 2016:
“6 Manage risk
Identify and minimise risk
6.1 You must take all reasonable steps to reduce the risk of harm to service users, carers and colleagues as far as possible.
6.2 You must not do anything, or allow someone else to do anything, which could put the health or safety of a service user, carer or colleague at unacceptable risk.
9 Be honest and trustworthy
Personal and professional behaviour
9.1 You must make sure that your conduct justifies the public’s trust and confidence in you and your profession.”
50. The Panel also finds the Registrant to be in breach of the following standards in the HCPC’s “Standards of proficiency: Radiographers” (August 2013):
“ 3 be able to maintain fitness to practise
3.1 understand the need to maintain high standards of personal and professional conduct
14 be able to draw on appropriate knowledge and skills to inform practice
14.1 be able to conduct appropriate diagnostic or monitoring procedures, treatment, therapy or other actions safely and accurately.”
51. The Panel makes a finding of serious misconduct in respect of each and all proven particulars of the Allegation.
52. With regard to the ground of lack of competence in respect of the proven particulars 2 to 4, here is insufficient evidence before the Panel to represent a fair sample of the Registrant’s work and, therefore, the Panel makes no finding of lack of competence.
Decision on Impairment
53. Ms Ryan submitted that the question of current impairment by reason of the past proven misconduct was a matter for the independent judgement of the Panel, taking into account all the evidence before the Panel, including any evidence of insight, remediation and the risk of repetition.
54. The Panel accepted the Legal Assessor’s advice that the Panel had to consider whether that past misconduct leads to this Registrant’s fitness to practise being impaired now. There are two component parts of the test for impairment. First, there is what may be termed the personal component of this decision. The Panel considered the proven past misconduct or other ground, together with all the other evidence the Panel have in respect of the Registrant, (e.g. insight, any evidence of the remedying of the deficiencies, the risk of repetition, the risk to the public presented by any repetition of the misconduct). Second, the Panel must also consider what may be termed the public component, namely, what would be the effect of not finding impairment on the wider public interest. That wider public interest includes the maintenance of public confidence in the profession and its regulator, and the declaring and upholding of proper standards of conduct. Those components are dealt with in the HCPTS’s Practice Note “Finding that Fitness to Practise is ‘Impaired”‘ (March 2017).
55. Whilst the Panel notes the Registrant’s statement in her written submissions that “I acknowledge my mistake”, it does not find this amounts to meaningful insight into her proven misconduct. The Panel has identified no other significant evidence of insight and finds that the Registrant lacks insight in respect of her misconduct. Whilst the Panel considers the misconduct is capable of remediation, there is no evidence of remediation. The Panel therefore concluded that a real risk of repetition of the misconduct remains, and any repetition would put patients at risk of harm.
56. The Registrant’s actions of being under the influence of alcohol at work on two occasions, and serious failings in the execution of x-ray procedures on three patients over a short period of time, have brought her profession into disrepute. The proven breaches of published standards of conduct and of proficiency amount to a breach of fundamental tenets of the profession.
57. The Panel makes a finding of current impairment of fitness to practise both for public protection and in the wider public interest of declaring and upholding proper standards of conduct and behaviour, and of maintaining public confidence in the profession.
Decision on Sanction
58. Ms Ryan submitted that the Panel might wish to consider that there is a number of occasions when the misconduct occurred, there were two types of misconduct, and there was no evidence of remediation.
59. The Panel accepted the Legal Assessor’s advice that:
a) the appropriate sanction, if any, is a matter for the independent judgement of the Panel;
b) the Panel must at all times bear in mind that the purpose of imposing a sanction is to protect the public in accordance with the over-arching objective of the exercise of the HCPC’s powers set out in Art. 3(4) of the 2001 Order, as amended. This includes promoting and maintaining the public’s confidence in the profession and promoting and maintaining proper standards of conduct. The purpose of a sanction is not to rehabilitate the Registrant, nor to punish the Registrant, although a restriction on the Registrant’s registration may have a punitive effect;
c) The Panel should consider the impact of a particular sanction on the Registrant, but it is not the primary consideration;
d) the Panel must take account of the HCPC’s guidance in its published “Indicative Sanctions Policy” March 2017 (ISP), which includes the need for the Panel to exercise the principle of proportionality. This means that if a sanction is required, the sanction imposed should be the minimum appropriate sanction to achieve the over-arching objective. If the Panel deviates from the Policy, it should state clear and cogent reasons for so doing.
60. The Panel considered that there were the following aggravating features of this case: multiple acts of misconduct; the misconduct included being under the influence of alcohol on two occasions whilst dealing with vulnerable patients; there was an absence of meaningful insight; the misconduct involved the unwarranted risk of harm to patients by over-exposure to radiation.
61. On the other hand, there were the following mitigating factors: the Registrant’s health and personal issues outlined in her written representations; this is the first time the Registrant has been brought before her regulator; and the Registrant’s engagement with the regulatory process.
62. Balancing those features against each other, together with the seriousness of the misconduct and the real risk of repetition of the misconduct, the Panel determined that taking no action or issuing a caution would be wholly insufficient to achieve either protection of the public or to promote and maintain confidence in the profession or uphold and declare proper standards of conduct for the profession.
63. The Panel next considered a Conditions of Practice Order, but, apart from the absence of the Registrant’s willingness to comply, was unable to formulate workable conditions, especially in relation to alcohol, that would not be so restrictive as to amount to a suspension.
64. The Panel moved on to consider a Suspension Order. Paragraph 39 of the ISP suggests that a Suspension Order may be appropriate where “…where the allegation is of a serious nature but unlikely to be repeated and, thus, striking off is not merited.”
65. Paragraph 42 of the ISP also states that suspension “may be appropriate, in particular: where a less restrictive sanction would:
• be unlikely to provide adequate public protection;
• undermine public confidence; or
• be unlikely to have a deterrent effect upon the registrant concerned or the profession at large;…”
66. Throughout its deliberations the Panel kept in mind its findings in relation to the Registrant’s lack of meaningful insight and the real risk of repetition. The Panel also reminded itself of the need to achieve the over-riding objective whilst acting proportionately and taking into account the impact of a sanction upon the Registrant. The Panel concluded that a Suspension Order would not be sufficient or proportionate in the circumstances of this case. The Registrant had attended work, delivering radiological services to patients, whilst under the influence of alcohol on two occasions. In addition, she failed to perform x-rays correctly on three patients. She shows no meaningful insight and is in denial. She put patient at unwarranted risk of harm and both the profession and the informed public would be seriously concerned by her misconduct which would undermine public confidence in the profession. Proper standards of conduct must be upheld and declared to the profession and the public.
67. The Panel therefore went on to consider a Striking-Off Order. Paragraph 47 of the ISP states that “Striking off is a sanction of last resort for serious, deliberate or reckless acts involving abuse of trust such as sexual abuse, dishonesty or persistent failure.” The Panel finds that the Registrant’s misconduct was serious, deliberate and reckless.
68. The ISP goes on to state at paragraph 48 that “Striking off should be used where there is no other way to protect the public, for example, where there is a lack of insight, continuing problems or denial…” The Panel finds that lack of insight, denial and risk of repetition are key aspects of this case. Further, the Panel finds that any sanction less that a Striking-Off Order would be inadequate to send an unambiguous message to the profession at large that such behaviour will not be tolerated, or to meet the need to maintain public confidence in the profession and the regulatory process.
Order:The Registrar is directed to strike the name of Kate E Gibson from the Register on the date this order comes into effect
1. Ms Ryan applied for an interim Order on the grounds that it was necessary for the protection of the public and/or was otherwise in the public interest. These were serious matters that the Panel had determined had put patients at risk of harm and the only sufficient substantive order was Striking-Off.
2. The Panel accepted the advice of the Legal Assessor that the Panel should take into account the HCPTS Practice Note “Interim Orders” and could only make an Interim Order if it was of the view that an Interim Order was:
(i) necessary for the protection of members of the public;
(ii) is otherwise in the public interest; and/or
(iii) is in the interests of the Registrant.
3. The Panel took all the circumstances of this case into account, the submissions of Ms Ryan, and the contents of the HCPTS Practice Note “Interim Orders”.
4. The Panel determined, for the same reasons as it determined to make the substantive Striking-Off Order, to make an Interim Order of Suspension under Article 31(2) of the Health and Social Work Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest.
5. The Interim Order will be for 18 months because, if the Registrant appeals the substantive Striking-Off Order, it could take that period of time for the appropriate Court to determine any such appeal.
This order will expire:
(if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made;
(if an appeal is made against the Panel’s decision and Order) the final determination of that appeal, subject to a maximum period of 18 months.
History of Hearings for Miss Kate E Gibson
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