13th April 2019

To,
Dr AnilKumar
Addl. DDG, Dte. GHS
Ministry of Health and Family Welfare,
Government of India,
Room No. 560-A
Nirman Bhawan,
New Delhi – 110011

Email: help.ceact2010@nic.in

Sub:

Objections/ Suggestions invited by G.S.R._E, dated 15/3/2019 on draft

of certain rules further to amend the Clinical Establishments (Central
Government) Rules, 2012, which the Central Government proposes to
make in exercise of the powers conferred by section 52 of the Clinical
Establishments (Registration and Regulation) Act, 2010 (23 of 2010).

Ref:

Notification dated 15/3/2019, the Gazette of India, Extraordinary, Part II,

Section 3, Sub Section (1), Ministry of. HFW, Gov. of India, G.S.R_ (E) dated
15/3/2019.

Respected Sir,

With reference to the above, we the members of the Association of self

employed owners of private pathology laboratory of Gujarat
(West zone) , a representative organization of the Medical Laboratory
Technologists in Gujarat (West zone) , since last 25 years, do hereby
submit our objections and suggestions invited by you ….

Kindly refer to the following statement in the Schedule Table

1. S. No I :

“At the end, the following notes shall be inserted namely”:

“Medical tests should normally be undertaken on the advice

of a doctor”

OBJECTION / SUGGESTION : NO OBJECTION

It is a normal practice of Basic composite laboratory.
(Here we understand that it is not compulsory.
2. S.No II-
 Human Resource, Column 2:

“The Authorised Signatory will be liable for authentication

of laboratory test report only”

OBJECTION / SUGGESTION : NO OBJECTION

Justification: “They (Lab Technologist) are also responsible for

confirming the accuracy of test results, and reporting laboratory
findings.” .. But the responsibility is for their report ONLY.

3. S.No III-

Human Resource Column 3:

“ **Wherever interpretation of lab results or opinion there on are

required registered Bachelor of Medicine and Bachelor of surgery
(MBBS) medical practitioner is essential”. Above shall be substituted
with following words: “ *

* Interpretation of lab results or opinion there on when required,

registered Bachelor of Medicine and Bachelor of surgery (MBBS)
medical practitioner is essential”.

OBJECTION / SUGGESTION : NO OBJECTION

In old rules , the word “ Wherever “ is substituted with “When

required“ .

THIS CORRECTION IS GRAMETICALLY A WONDERFUL

CORRECTION.

We request you to strongly consider all the above mentioned comments

and suggestion to implement in the Clinical Establishments Act for a
better healthcare delivery system in India,

Thanking you,

Yours sincerely

Hemant Amrutiya

ASEOPPLOG – (Rajkot-west Zone )