Re: Disposal of clinical wastes containing radio-isotopes

[Paul Lavely <lavelyp@uclink4.berkeley.edu>]

Did I misread one of the replies on this topic or is the author 
advocating the circumvention of the directions of the RSO. I am not 
sure which of these (or all of them) applied; however, I am concerned 
that anyone on radsafe may believe that ANY such circumvention is 
acceptable.

The statements that I refer to are:

"If you are dealing with outpatients, and somebody tells you you have to
decay out the diapers, give the ziploc bags to the patients and tell them to
throw them out themselves when they get home!  For that matter, take them
home yourself and throw them out.  If the hospital trash is monitored for
radioactivity and your RSO doesn't want anything radioactive in there, just
see to it that they're thrown out somewhere else.   It's not as 
though we're talking about a safety issue. "


As I read this, it appears that the author advocates that the medical 
staff should not follow the RSO's direction. That is, the statement 
that "If you are dealing with outpatients, and somebody tells you you 
have to decay out the diapers, give the ziploc bags to the patients 
and tell them to throw them out themselves when they get home!" While 
it is not clear who the "someone" is, I assume that it is someone who 
had the authority to make that decision and give that direction. This 
statement says to ignore that direction and to do something other 
than what has been determined to be the institution's requirement 
("you have to decay out the diapers").

Another was the statement that  "just see to it that they're thrown 
out somewhere" other than hospital trash because the RSO has said "do 
not put them in hospital trash."  That is, staff should do something 
to circumvent RSO policy (or license requirements) by seeing  "to it 
that they're thrown out somewhere else" even if it means that staff 
"take them home yourself and throw them out." I can not envision a 
situation under which I would allow STAFF to take licensed 
institutional radioactive materials HOME for disposal. In fact, if I 
found that STAFF were taking home (or to other non-authorized 
location) institutional rad waste (whether it came from a patient or 
not) for disposal I would have to determine if I needed to report it.

Finally, as I understand California law, the intentional improper, 
unauthorized disposal of radioactive waste can be charged as a 
felony. Why chance it? The real answer here seems to be to discuss 
issues such as this with your regulator. If you get an answer that 
supports what you want to do, document what the regulator said (amend 
your license if needed) and the issue is settled. If the answer is 
not what you want, appeal it.

Paul Lavely
RSO and Director UC Berkeley
lavelyp@uclink4.berkeley.edu
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