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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
> >
>
>***********************************************************************
*
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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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