Re: NRC Information Notice 2002-28

[Gary Isenhower <garyi@bcm.tmc.edu>]

The following comments apply to the clinical/medical setting, not to the

industrial/reactor setting.



There are two seperate issues here: nuclear medicine and interventional

fluoroscopy.  In either case, the RSO is largely a figurehead and

occasionally a scapegoat.  In clinical medical settings, the RSO usually

knows less about the doses and their effects than the technologists who

administer them.  But this is certainly better than the converse, where

the RSO has adequate training but the technologists do not.  I don't

know about you, but I want the person holding the syringe to be the

expert.



Interventional fluoroscopy proceedures have produced a few patients with

large doses and on rare occasions bad skin burns.  On the other hand,

those patients all had serious, often life threatening, cardiac problems

and the neccessary treatment is difficult and complicated.  It is true

that some overexposures occur due to lack of experience in the physician

performing the procedure.  But more often, patients get large doses

because it takes a lot of beam-on time to treat the life-threatening

condition.



Overexposures resulting in real harm to patients are rare in fluoroscopy

and more rare in nuclear medicine.  So, I would not characterize this as

a reprehensible situation, or one that should elicit outrage or

disbelief.  In the case of nuclear medicine, radiation safety is best

improved by better training for the technologist.  For fluoroscopy,

better training for the physicians in needed.  Either way, the RSO plays

a secondary role in this process.  He should ensure that there is time

and money for good training and continuing education and that the

facility is in compliance with the terms of its license/registration. 

These are largely administrative funcitons, not physics functions.



If every hospital and clinic were forced to hire a full time on-site

competent physicist, then there would be that much less money for

training the physicians and technologists actually doing the

procedures.  Of course, it is wrong for a facility to appoint an RSO

without telling that person about it. :)





"Michael G. Stabin" wrote:

> 

> > Notice, the NRC notes that, "Several recent NRC inspections have

> > identified cases involving medical licensees who appointed an RSO

> > [Radiation Safety Officer] or AU [Authorized User] without this

> > individual's knowledge or consent.  As a result licensed activities were

> > performed without the oversight of an RSO and dosages were administered

> > to human patients without the supervision of an AU."

> > This would be funny if it weren't so sad.

> 

> Perhaps it does not need to be said, but I could not agree more with Bill on

> this. I have heard of this before, anecdotally, so I won't cite particulars,

> but this is a recurring theme, and it represents a reprehensible situation

> that can only be viewed with outrage and disbelief. This is the worst kind

> of irresponsibility, and in a setting in which serious safety issues may be

> in play.

> 

> Some argue that a lot of health physics involves spending too much time and

> money worrying over nanosievert doses when attention could be better spent

> elsewhere. I think the issue of patient overexposures during fluroscopy and

> the issue addressed above are serious, and should get high priority by us as

> a society for attention and prevention. I am not saying that anything else

> should be forgotten or given zero priority. I am just saying that these

> areas are quite serious and need attention, and that we should be taking the

> lead in saying so and proposing reasonable solutions, or we ain't doin' our

> jobs.

> 

    _______________________________________________



	Gary Isenhower

	713-798-8353

	garyi@bcm.tmc.edu