RE: NRC Information Notice 2002-28/fluoroscopy

["Scott, Bob A" <bscott@rwmc.org>]

You wrote:



From: desegnac [mailto:desegnac@SWBELL.NET]

Sent: Monday, October 07, 2002 10:09 AM

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



Although I appreciate your response very much, I need to reiterate that I

addressed only the BUSINESS of an RSO in taking care of the OCCUPATIONAL

exposures, versus patients' exposure that is under an MD's treatment and C A

R E !



That we discuss patient's exposures with MD's administering a procedure or

using a certain treatment modality, is COMMENDABLE and, most probably,

DESIRABLE, but, according to our MANDATE (either implicit or explicit), it

is NOT our BUSINESS







RAS:

	In Rhode Island, it IS OUR BUSINESS to inform fluoroscopists of the

exposure rates being administered to patients; the regs say "Results of

these measurements shall be posted where any fluoroscopist may have ready

access to such results while using the fluoroscope and in the record

required in section .......  Results of the measurements shall include the

roentgens per minute, as well as the technique factors used to determine

such results.  The name of the (registered physicist) performing the

measurements and the date the measurements were performed shall be included

in the results."  This is so the MD will know what kind of a dose (s)he is

delivering to the patient.



	In Rhode Island, the licensee must inform patients who are released

from the licensee's control about the radiation dose that other persons

might receive from association with the patient if the patient has been

treated with certain radiopharmaceuticals or permanent implants.  These

kinds of responsibilities are properly handled by health physicists, and

this HP is also the RSO in this facility.  This is a MANDATE which I must

ensure is performed by someone if I don't do it, because this task has been

established by the Rad. Safety Comm. as the duty of the RSO.          RAS.









 (saying that, it does not mean at all, that we should

not DO something about it - your action is a fine, human and professional,

example).



COMPASSION, on the other hand, IS our PERSONAL business - I alluded to it in

the previous postings.



Furthermore, in the settings of our employment, it IS our business to

practice OCCUPATIONAL and GENERAL PUBLIC ALARA, but NOT the patients' - that

IS the MD's BUSINESS.



RAS:

	I must disagree, because of my points above.        RAS.





 Their compassion is, however, THEIR personal

business - whether we can do something about that is questionable, to say

the least. ALARA is NOT MANDATED for patients under any "radiation"

treatment (should it be and by whom?) - FOR OCCUPATIONAL and PUBLIC

EXPOSURE, it IS !



If the MD's, whom we are working along, accept our voice of concern, it is

superb. But not all, or, rather, seldom are MDs as receptive as your

colleagues, apparently, are, to suggestions from the "left fielders." Your

personal, professional, authority may be of help in your settings, but I

would be careful in approaching an MD and tell her or him that the patient

is being "fried."  







RAS:

	In Rhode Island, we have a regulatory requirement to give

instruction to non-radiologist fluoroscopists if those MD's wish to use

fluoroscopy.  This is a pro-active duty; because if we fail that, then the

registrant of the fluoro equipment is equally at fault with the MD if in

fact something does happen to cause the patient un-necessary harm.  And

because this is part of the Rhode Island Rules and Regulations of the

Radiation Control Agency, then that duty falls once again to the RSO (HP) to

either administer or perform.      RAS.



R. A. Scott, RSO

Roger Williams Medical Center

Providence, RI  

bscott@rwmc.org

 

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