Re: NRC Information Notice 2002-28/fluoroscopy

["Michael G. Stabin" <michael.g.stabin@vanderbilt.edu>]

> Re: NRC-fluoroscopy-overexposure

>

> If I am not mistaken, we are missing the target. OCCUPATIONAL EXPOSURES is

> an NRC-Agreement State business, thus RSO's domain, while exposure of

> patients is exempted from regulations, thus irrelevant



OK, the first issue was raised in the context of an NRC action, I agree. I

was speaking in the broader context of health physics - what are we as

health physicists responsible for? The safe use of radiation. These are two

issues that may involve reasonably serious situations, and should be given

some attention. I was not suggesting that the fluoro situation involves a

regulatory issue, but it is something that HPs should be actively involved

in helping hospitals to do better. Poor assignment of RSO duties in a big

hospital may also involve situations that are really of concern to health

and safety. I accept Dr. Marcus' point that the kind of managerial

misconduct in assigning RSOs may be rare, but, again, I have heard of this

more than once, so I think it is not an isolated event.



I think perhaps Dr. Marcus' point about small hospitals is a bit overstated

("the non-medical job of an RSO in a community hospital that does some

nuclear medicine is largely secretarial, and has no safety significance at

all."). I would not say there are no safety concerns at all. If radiation

safety is not done well, there may not be dire consequences for individuals

in terms of dangerous doses, but there could be unnecessary overexposures,

unrecorded exposures, mishandling of licensure and rad waste, etc. All of

these could have negative consequences for the hospital during an

inspection, and the former two may or may not be "have safety significance",

depending on your views of doses within the regulatory limits.



Mike





Michael G. Stabin, PhD, CHP

Assistant Professor of Radiology and Radiological Sciences

Department of Radiology and Radiological Sciences

Vanderbilt University

1161 21st Avenue South

Nashville, TN 37232-2675

Phone (615) 343-0068

Fax   (615) 322-3764

e-mail     michael.g.stabin@vanderbilt.edu

internet   www.doseinfo-radar.com







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