Re: 10CFR35.315 + your comment

[carol marcus <csmarcus@ucla.edu>]

At 05:39 PM 1/13/00 -0600, you wrote:
>At 07:12 13.01.2000 -0600, you wrote:
>>Dear Radsafers,
>>
>>I have a question concerning the release of hospital rooms that have been
>>used by Iodine-131 patients (for therapeutic treatment) that I hope you can
>>help me with.
>>
>>10 CFR 35.315, paragraph (7) states "Survey the patient's or the human
>>research subject's room and private sanitary facility for removable
>>contamination with a radiation detection survey instrument before assigning
>>another patient or human research subject to the room.  The room must not
>>be reassigned until removable contamination is less than 200
>>disintegrations per minute per 100 square centimeter". 
>>
>>My interpretation of the above is that the limit of the removable
>>contamination must be met even thus if the next patient who will be
>>assigned the room is also an iodine patient undergoing therapeutic
>>treatment.  Is this correct?
>>
>
>I wonder whether for your hospital US regulations are compulsary. I also
>wonder whether lebanese regulations exist. In the first case you probably
>cannot avoid to follow these regulations, though they do not make in this
>case any sense, as several other RADSAFERs pointed out. I suppose that no
>specific lebanese regulations exist, leaving the decision to the person
>responsible for radiation protection. If US regulations are not compulsary
>I would recommend that you treat this case on the basis of radiation
>protection principles and common sense, which clearly indicate also to the
>opinion of other RADSAFERs that such extensive cleaning is not necessary. 
>
>
>
>
>>I also would like to get your comment on the following:
>>
>>The hospital administration is thinking of dedicating a hospital room for
>>only iodine patient.  Moreover, this room is in the middle of the hallway.
>>I guess their thinking is that if the room is dedicated only to iodine
>>patients, then they do not have to worry much about contamination levels
>>and any special preparation for the room such as using absorbent papers to
>>cover ….
>>Do you think this is appropriate?  
>
>No, it is not appropriate. If regulations on decontamination should be
>followed closely though they do not make sense then it is more than
>inappropriate to neclect much more important principles of radiation
>protection. I suppose that the US regulations would also prescribe a
>separate sewage system and collection of urine and faeces - has this been
>taken care of? I do not know your position, but I think that such plans
>have to be evaluated in very close cooperation with the radiation
>protection officer and his demands have to be followed closely.
>
>
>Franz
>
>
>Franz Schoenhofer
>Habicherg. 31/7
>A-1160 Vienna
>Austria
>Tel.: +43-1-495 53 08
>Fax.: same number
>mobile phone: +43-664-338 0 333
>e-mail: schoenho@via.at
>
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Dear Franz:

I follow California regulations, not NRC's, and the California regulators
are much more sensible than NRC.  As far as dedicated sewage systems for
urine and stool contaminated with I-131, I think it's ridiculous, NRC has
always exempted human excrement, and if you think there is a safety problem,
you need to do a scientific analysis to demonstrate why.  None exists.  I
think we should exempt pet excrement too---why save cat urine but let human
urine down the sewer?  As there is no hazard, all of it should go down the
sewer.

As far as a dedicated room and therefore less draconian cleanup, I think it
is reasonable but the NRC hasn't got the capacity to understand the
difference.  I don't think its staff and management understand how to use
specific gamma ray constants, complete with shielding considerations, to
perforn absorbed dose calculations.  So, they keep groping for silly
numbers, which is something they can understand.

I don't know whether Lebanese radiation safety regulations exist; do they
have any or do they use IAEA guidelines?

Ciao, Carol

<csmarcus@ucla.edu>

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