RE: NRC Information Notice 2002-28/fluoroscopy

[desegnac <desegnac@swbell.net>]

As "radsafers" we need to be, indeed, concerned about overexposures, but

that is where the buck stops. If, not being an MD, we even advise a patient

of our concerns, we will "practice medicine" - kind of - and we will be in a

heap of trouble. We may voice our concern, like we are doing it here, or on

some other more relevant occasions, with some reliable statistics, thus spur

the NM MDs to think in a little different ways. I doubt that anything,

barring a lawsuit for malpractice involving overexposure, would wake up

their community and press them into some more thoughtful action. But, again,

I might be very wrong in these matters.



NRC, again, is mandated (thus the RSO structure) to take care of limiting

occupational and exposure of the general public - the patients are concern

of the FDA - it approves procedures - and a doctor practicing NM. An RSO in

a hospital/clinic ought to be focused on the NRC mandate and, if not a

doctor or a medical physicist, any of RSO's concern about an unfortunate

patient(s) level of exposure is, simply, not her or his business, but the

matter of heart.



Indeed, as you said, hospital admins and NM MDs ought to be concerned about

jeopardizing their license, which stipulates that they shall observe the NRC

rules and regulations concerning possession and safe handling of radioactive

material/radiation producing machines, and not exceed occupational and gen.

public dose levels. The structure of an RSO is a part and parcel of that

license and need not be, ever, treated as a second class function. In a NM

department, she or he could help a lot in, among other things, maintaining

very healthy relations with NRC, but more importantly, with the public.



Dusan Radosavljevic



Austin, TX



desegnac@swbell.net





-----Original Message-----

From: Michael G. Stabin [mailto:michael.g.stabin@vanderbilt.edu]

Sent: Friday, October 04, 2002 5:28 PM

To: desegnac; 'RadSafe'

Subject: Re: NRC Information Notice 2002-28/fluoroscopy





> 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