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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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