Re: incontinent patient dosed with ~100 mCi of I-131

[Dave Derenzo <dave@uic.edu>]

Once upon a time, before Illinois was an agreement state, the NRC 
regulators in Region III indicated that while radioactive material was in a 
patient it was not regulated.  However, if one were to collect a urine 
sample, the sample was once again regulated.  This was conceptually applied 
to diapers also.  As part of a Haz Mat DOT surveillance program, Illinois 
state troopers found their largest readings from I-131 patients, but never 
cited them for DOT violations.  (They had 2x2 NaI crystals with alarm rate 
meters permanently mounted in their cars.)  However, the problem of finding 
a bag of contaminated diapers in the trunk never came up to my knowledge.

I think that the concepts of what is and what is not regulated is not set 
in stone, rather it changes from place to place and time to time depending 
on the mind sets of the regulators.  My advice is to check with your local 
and/or national authorities and not to rely entirely on logic.  The right 
answer for me might be the wrong answer for you.

Dave Derenzo

At 01:18 PM 06/20/2000 -0500, you wrote:
>Many thanx for you thoughtful response.  However, I do not see valid 
>regulatory
>basis.  It is important to keep in mind that DOT and NRC regulations, 
>although they
>interface in many areas, are separate.  Often, material which is exempt from
>licensing requirements is still considered "radioactive material" for
>transportation.  Likewise, waste material that is below the DOT threshold for
>"radioactive material" (i.e., < 2 nCi/g) may still be considered 
>"radioactive waste"
>by the NRC.  Thus, I'd have to disagree with the reasoning in your statement:
>
>"Once the patient is released from confinement, the radioactive material is
>unregulated.  The patient does not need a "license", and while counseled to
>take certain precautions, cannot be forced to do so.  The patient can carry
>contaminated diapers in their car without a DOT license, and can carry
>themselves in their car without a DOT license as well."
>
>You're correct in stating that a patient does not need an NRC license to 
>possess his
>contaminated diaper.  However, the diaper may still be within the DOT 
>definition of
>"radioactive material," and, hence subject to DOT regulation.  BTW, there 
>is no such
>thing as a "DOT license."
>
>In addition, the licensee, under 10CFR35.75, is required to: "... provide the
>released individual with instructions, including written instructions, on 
>actions
>recommended to maintain doses to other individuals as low as reasonably 
>achievable
>if the total effective dose equivalent to any other individual is likely 
>to exceed 1
>millisievert (0.1 rem)...."  These instructions must:  (1) be effective, 
>and (2) not
>instruct to patient to violate any regulations.
>
>The opinions expressed are strictly mine.
>It's not about dose, it's about trust.
>
>Bill Lipton
>liptonw@dteenergy.com
>
> > >carol marcus wrote:
> > >
> > >> Dear Radsafers:
> > >
> > Dear Radsafers:
> >
> > Once the patient is released from confinement, the radioactive material is
> > unregulated.  The patient does not need a "license", and while counseled to
> > take certain precautions, cannot be forced to do so.  The patient can carry
> > contaminated diapers in their car without a DOT license, and can carry
> > themselves in their car without a DOT license as well.  They can throw
> > contaminated kleenexes in any garbage can or waste basket they like.  Once
> > the material is deregulated, it is no longer labeled "radioactive", and I
> > believe that it is illogical to assume that if it touches that hands of
> > someone on a license that it is suddenly reregulated.  This point was 
> raised
> > with some radiation control program directors a couple of years ago, who
> > agreed that once patients are released from confinement, their contaminated
> > articles are permanently deregulated in terms of NRC or Agreement State
> > radiation requirements.
> >
> > I have always treated it as such, with no directive from anyone otherwise
> > (e.g. a radiation regulator or my RSO).  The point is that no member of the
> > public can get more than 500 mrem from the patient or his/her diapers
> > because if someone reasonably could, the physician should have kept the
> > patient in the hospital in the first place.  Why make a big deal about an
><significant hazard?
> >
> > If you can show that a physician is letting someone out of the hospital 
> in a
> > situation where it is reasonable to expect a member of the public to get
> > more than 500 mrem, I would (1) like to see your analysis and (2) suggest
> > that you should get that physician off the license.
> >
> > Ciao, Carol
> >
>
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Dave Derenzo, RSO (dave@uic.edu)
UIC Radiation Safety Section, M/C 932
Phones: Voice (312) 996-1177  Fax: (312) 996-8776

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