[ RadSafe ] Recycling Urine Containing I-131; Emergency License Amendment Request 4/1/98

[Carol Marcus]

April 1, 2014

Dear Radsafers:

In the spirit of April Fool's Day, I am reprinting an emergency license 
amendment request to Edgar Bailey, then Chief of the California 
Radiologic Health Branch.  It was sent April 1, 1998.  At the time, I 
was Assoc. Chief of Nuclear Medicine at Harbor-UCLA Medical Center, and 
in charge of all the therapies.

April 1, 1998

Dear Ed:

As we start the 38th month contesting our license renewal, I though I 
might as well request an additional license condition for when you guys 
finally give up and give me what I need.

We would like to collect the urine from thyroid cancer patients who 
receive 100-400 mCi NaI-131 and recycle it.  As only 1% at the most goes 
to thyroid remnant or thyroid cancer, we at Harbor-UCLA feel that it is 
a waste of money to let all that good I-131 go down the sewer to amuse 
the EPA.  Why not recycle it for other patients?  As we already have a 
lyophilizer for compounding designer drugs that FDA has never approved, 
we can simply remove most of the water and produce a radioactive 
"cocktail" worthy of the name.

I-131 thus obtained has several advantages:

1) There are considerable cost savings when reusing it for hyperthyroid 
or other thyroid cancer patients.  As you know, L.A. County Department 
of Health Services is broke, and our effort will certainly help for cost 
containment.

2) By offering our impoverished patients a modest fee for their urine, 
they might carefully urinate in containers and not splash hot urine all 
over the toilet.  This would cut down on our cleanup time, and also 
thwart Rad Health inspectors on their evil rounds.

3) The "cocktail" would probably be more effective than ordinary NaI-131 
in solution.  Ordinary NaI-131 has no taste, the patient's assume it's 
rather benign, and it's really hard to impress them.  On the other hand, 
the "cocktail" would have a strong odor and taste, and it is a 
well-known medical fact that the worse a medicine tastes, the stronger 
the patient thinks it is, and the more likely it is to cure the 
patient's illness.

4) People who have a hysterical fear of radiation could smell the 
patient coming, and run like Hell.  This "early warning system" would be 
very popular with antinukes and their political supporters, such as 
those nuclear cognoscenti, Barbara Boxer and John Garamendi.  Can you 
imagine Barbara and John supporting ME?

5) There is a considerable radiation safety advantage here, because 
radioactive urine from these patients is actually an exempt quantity.  
ANYONE, including unlicensed individuals who have NOT PAID USER FEES 
(the ultimate sin), could collect radioactive urine and treat patients 
with it.  By recycling the urine ourselves, we cut off their supply and 
"keep it off the street", so to speak.

6) You should have no fear of the drug quality of our recycled I-131 
"cocktail".  It will most assuredly meet the strict standards of the 
U.S. Pee.

Ciao, Carol


Carol S. Marcus, Ph.D., M.D.
Prof. of Radiation Oncology, of Nuclear Medicine, and of Radiological 
Sciences at the David Geffen School of Medicine, at UCLA