RE: Shipping Question

Ed and fellow Radsafers,

As a HP for a nuclear pharmacy company that sometimes deals with outside couriers and transportation events I would like to put my two cents in.

1. First, you would have to determine the types and amount of material(s) in the shipment. A return shipment doesn't necessarily mean empty(as defined by DOT regulations) or limited quantity shipment. The customer might have been returning some material for credit to their account. (Some hospitals order bulk Tc-99m for contingency purposes, but sometimes never use it.) Once you determine what's in the shipment, you can determine what the reporting requirements are (immediate, 24 hour, 30 day etc.). As the RSO of the pharmacy or hospital involved, I would definitely report the event to the appropriate regulatory authority. (If you don't, chances are they'll call you.) I would also make ! myself available to any first responders that might appear (regulators, haz mat, police etc.). Given the recent public attention given to "dirty bombs" and the resultant scrutiny put on regulatory agencies, a knowledgeabl! e person should be on hand to prevent things from being taken out of context. You wouldn't want the name of your hospital or pharmacy mentioned in a story with the headline "Lost Nukes Found in Parking Lot". As outrageous as that may sound, we've had to deal that type of press.

2. Determining the responsible party is a little more difficult. You would have to check the license of the pharmacy to determine if there were specific references to the courier company used and their level of involvement. For instance, if their license application (or subsequent correspondence) reads "We will use XYZ Shipping for all transport of radioactive materials and will train its drivers pursuant to the re! quirements of 49 CFR and (insert state regulation here)." I would say that the licensee bears some responsibility (item of concern, Severity Level IV violation, etc.). At the very least, it should be the responsibility of the pharmacy to take some steps, albeit rather limited, to prevent a recurrence of the event (report the driver to a manager, change couriers, remind staff members about materials accountability and security, etc.).

The above suggestions are mine and mine alone and do not represent the opinions of my employer or anybody else.

Toli Mikell

--- On Tue 06/25, Ed Stroud < ed.stroud@state.co.us > wrote: