[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
RE: incontinent patient dosed with ~100 mCi of I-131
Well the last try came up as gibberish - lets see if I fixed the
problem.
According to the DOT the radioactive material is not regulated as long
as it is in/on the patient. Once it has been removed (the diaper
changed) and is transported it would then be covered by DOT
regulations. This type material setting off the monitors at landfills
is the reason DOT issued exemption DOT11406 back around 1982. This
allows the cognizant regulatory authority to issue an exemption to
transport the material to a facility that can properly handle it
(hospital, waste broker etc)without having to go through all the
requirements for a DOT shipment of radioactive material or they can
allow they truck to just sit and decay. The max allowable dose rate on
the vehicle is 50 mr/hr. This is very similar to the DOT exemption for
scrap metal (DOT10656).
This has been a topic of discussion at CRCPD meetings. Additional info
can be obtained from (according to DOT) Kathleen McCallister with the
state of MA at 617-727-6214 etx 2013 or from Dr. Jerry Devine with the
CRCPD in Frankfurt, KY 502-227-4543
-----Original Message-----
From: dave@uic.edu [mailto:dave@uic.edu]
Sent: Tuesday, June 20, 2000 3:37 PM
To: radsafe@romulus.ehs.uiuc.edu
Cc: dave@uic.edu
Subject: Re: incontinent patient dosed with ~100 mCi of I-131
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
> >
>
>***********************************************************************
*
>The RADSAFE Frequently Asked Questions list, archives and subscription
>information can be accessed at
http://www.ehs.uiuc.edu/~rad/radsafe.html
Dave Derenzo, RSO (dave@uic.edu)
UIC Radiation Safety Section, M/C 932
Phones: Voice (312) 996-1177 Fax: (312) 996-8776
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html