[ RadSafe ] Re: Who can read nuclear medicine studies?

Douglas Simpkin dsimpkin at wi.rr.com
Fri Nov 10 15:20:28 CST 2006

On the MedPhys list, Dean Broga wrote:

>It has been my experience that most hospitals only allow authorized users to
>read their nuclear medicine studies. However, I am also aware of a number of
>outpatient setting where there is only one authorized user named on the
>license and yet many of the physicians in the group read studies. The NRC
>(and I'll assume most agreement states) don't control the actually practice
>of medicine and therefore do not restrict which physicians can actually read
>studies. Within the hospital privileging limits who can and cannot read
>studies. This raises a number of questions.
>It has been my contention that all studies ultimately are the responsibility
>of an authorized user and if no authorized user is identified the
>responsibility would fall to the RSO/AU if the facility has one or to the
>most senior AU (i.e., the chair of the department). As a parallel consider
>CT, the physician reading the CT is tied to the study in that all x-ray is
>under the direction of a physician. So this begs the question, who is
>responsible for physicians reading nuclear medicine studies that are not AU.
>I would content that these physicians need to be under the supervision of an
>AU and that the supervision be clearly delineated in writing. If supervision
>is not delineated than that responsibility would fall to the RSO/AU if the
>facility has one or to the most senior AU (i.e., the chair of the
>I'd appreciate any comments on this opinion that you have since it is
>becoming a notable issue in a number of community hospitals.
>  DWB

Rephrasing Dean's question, has NRC Policy Guidance Doc 3-16 (PG 
3-16) been updated?

That 1995 document (confirmed by regulators and discussed on the 
RadSafe forum in 1999) contains the following:

There is no NRC REQUIREMENT that an authorized user must render an 
interpretation of a diagnostic image or results of a therapeutic 
procedure. NRC recognizes that the authorized user may or may not be 
the physician who interprets such studies. Additionally, NRC 
regulations do not restrict who can read and interpret diagnostic 
scans or the results of therapeutic procedures involving the 
administration of byproduct material to individuals. The images and 
test results may be made available to any physician upon request.

Reg. Guide 10.8 rev. 2, page 8, item 7, indicates that the authorized 
user retains responsibility for the interpretation of diagnostic 
images and results of therapeutic procedures. Item 7 also indicates 
that this responsibility may be delegated to a physician who is under 
the supervision of an authorized user. The purpose of having the 
authorized user or supervised physician retain this responsibility is 
to ensure that licensed material is used safely and that the patient 
receives the intended study or procedure, and dosage or dose.

In summary, there is no regulatory requirement that an authorized 
user, or a physician under the supervision of an authorized user, 
make an interpretation of a diagnostic image or therapeutic procedure 
involving the administration of byproduct material, but only a 
recommendation for the purposes stated above.

Quidquid latine dictum sit, altum sonatur.

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