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RE: NRC Information Notice 2002-28/fluoroscopy
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu
[mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of Scott, Bob A
Sent: Tuesday, October 08, 2002 8:50 AM
To: radsafe@list.vanderbilt.edu
Subject: RE: NRC Information Notice 2002-28/fluoroscopy
Thanks for the reply and the comments.
You wrote:
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.
That in Rhode Island you have such a program as described above is, indeed,
COMMENDABLE, but it is only mandated by your RSC.
Furthermore, you did not provide information concerning any LIMITS of
exposure that the MDs ought to observe, but only the necessity to RECORD the
administered exposures. However, that is not what I have been trying to say,
which is that MDs are NOT bound by some regulatory limits of exposure in
their quest for correct diagnosis or successful therapy. That they observe
some common sense - professional levels of patients' exposures does not mean
that that level is MANDATED, even if they are informed of the exposures they
impair on their patients.
(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.
Your reply - points above - is a fine example of your collective, but local
level of compassion and professional concern that results in a better
treatment for the patients under your, collective, care. What I have been
trying to say is that your application of ALARA principles to the exposures
of patients is not mandated to an HP/RSO. Instead it is the business -
mandate of the practicing MDs. That you - med. physicist - can help an MD in
that endeavor, in the way you describe, is commendable local mandate that
does not say to an MD: "THOU SHALL NOT EXCEED ... ."
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.
I completely agree with you that you are applying "pro-active" service to
the MDs. But, again, that is only local - voluntary, since, I would think
that, the MD attempting to use some radiation equipment and/or isotope,
OUGHT to be an "AUTORIZED USER," trained in radiation safety and the
application (only subjective) of the ALARA principles. If not, then you are,
indeed, performing a fine professional and compassionate service.
Again, what I am trying to say is that an RSO/HP, however locally mandated,
is not, as is an MD, in treating her or his patient, in a professional
position to determine the ratio of harm versus benefits of the level of
exposure she or he is administering. It is up to that MD, NOT the RSC, or an
RSO, or med. physicist, or regulators of any kind, to determine what is
"good" or "bad" (in terms of radiation) and how much of either is desirable
and/or achievable. That is the position of the entire med profession, as I
understand it. That is why I am saying that MDs are NOT bound by regulatory
limits and hardly could be ordered - mandated to practice ALARA as it is CFR
mandated to RSC/RSO/HP for radiation protection of general public (release
of patients, for example) and occupational workers.
Sincerely Dusan Radosavljevic
Austin, TX
desegnac@swbell.net
R. A. Scott, RSO
Roger Williams Medical Center
Providence, RI
bscott@rwmc.org
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