18^th January 2013

To: Sarah Sargent, Deputy Clerk, Health and Social Committee, National Assembly for Wales

Consultation on the Human Transplantation (Wales) Bill

The Royal College of General Practitioners is the largest membership organisation in the United Kingdom solely for GPs. It aims to encourage and maintain the highest standards of general medical practice and to act as the ‘voice’ of GPs on issues concerned with education, training, research, and clinical standards. Founded in 1952, the RCGP has over 46,000 members, 1,862 in Wales, who are committed to improving patient care, developing their own skills and promoting general practice as a discipline.

The Royal College of General Practitioners (Wales) welcomes the opportunity to respond to the consultation letter of 6^th December 2012.

The Bill, as set out, promotes the ideal of donation. It will potentially increase the number of transplants and improve the care of those requiring transplants.

Although General Practitioners on the whole would be supportive of the improvement in the numbers of donor organs for the benefit of those in need, we do not feel that they can be expected to counsel patients about opting out or in of donations.

The system of opting out of transplant will need to be carefully promoted to the public of Wales as there could be much lack of understanding. Patients whose first language is not English or Welsh will need special consideration as they may not understand the implications and special consideration needs to be given to those whose religious or cultural beliefs prevent removal of tissue and organs after death.

There were suggestions that this process would occur at registration at the GP. However, as we are sure you are aware, the work load of general practice has increased considerably over the past few years and additional work outwith general medical service provision would be difficult to contemplate. There would likely be considerable burdens on ensuring that the details of individuals were recorded accurately at the time of registration and for individuals to be made aware and to be informed about consent as well as training requirements for practice staff to ensure they were competent to take such consent.

We note that there is nothing in the bill about the fact that patients have to register to opt out of being donors or how they will be enabled to opt out; the opting out process was commented on in our previous consultation response, and the details of implementation are also not included in the Bill. 

If you have any queries about this response, please do not hesitate to contact us, by emailing Carl Turner at cturner@rcgp.org.uk