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Re: NRC Proposed Fine and Severity Level 1 Violation



To me, the principal lesson learned is that the RSO will take the fall in the

event of a violation, unless he takes specific actions to prevent this.  Would I

have done things any differently in those circumstances?  Maybe not.  However,

now that I'm aware of what happened, here's what I'd do.



1.  If not already in place, develop a written policy statement regarding

nuclear medicine patients who cannot be released under 10 CFR 35.75.  This would

include, as a minimum:   (1) the requirements of 10 CFR 35.315, (2) a policy on

visitors.  I would probably include a requirement to issue written instructions

to visitors, requiring consent to the instructions before allowing visits.

2.  In the event anyone, visitor or staff, violates the policy or instructions,

I would make every effort to put the enforcement responsibility on the hospital

administration.  This would, as minimum, include documented verbal communication

to my supervision of the violation and a reminder that it's the hospital

administration's responsibility to take whatever corrective actions are needed

to regain compliance with regulatory requirements.   This should be followed up

by a written communication.  I don't know to what extent coercive powers would

be used, eg, physically restraining the visitor.  However, I'd make sure that

it's not my decision.  (I doubt that the patient was in a position to "go

home.")

3.  In the event (which I doubt) that the hospital administration does not

correct the violation, I would feel an obligation to communicate directly with

the NRC.



Is this overly defensive?  Considering what actually happened, no.  Remember,

that when management asks you to be a "team player" in their chess game, it

usually means that you're a pawn.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



"Knapp, Steven J." wrote:



> What can be learned from this unfortunate situation?

>

> If family members choose to ignore the advise of the medical facility by

> sitting too close to a dying inpatient that is receiving radiopharmaceutical

> therapy, what should be done?  Should the facility have security staff

> remove the noncompliant visitors?  What level of control is required?

>

> Are medical facilities prepared to issue dosimeters (e.g. real-time

> read-out) to family members that may be noncompliant with visitor

> restrictions?  How is the medical facility going to enforce the radiation

> dose limits when family members are noncompliant?

>

> If a dying inpatient decided to go home, is the NRC going to site/fine the

> medical facility if the family members and patient do not follow the safety

> advise given to them?

>

> The level of control should proportionate with the risk to the family

> members and the public.  The wording may not be exact but the expert

> consultant concluded the radiation risk to the family members was

> insignificant during these unfortunate and tragic circumstances.

>

> Does the NRC consider any level of control to adequate that results in a

> family member or member of the public receiving a radiation dose in excess

> of the dose limits?

>

> Regards,

>

> Steve Knapp, Ph.D.

>

> -----Original Message-----

> From: Steven Dapra [mailto:sjd@swcp.com]

> Sent: Wednesday, May 14, 2003 10:51 PM

> To: radsafe@list.vanderbilt.edu

> Subject:

>

> May 14

>

> Jerry Cohen wrote:

>

>         "It seems to me that the comfort, warmth, and satisfaction of being

> near a

> dying loved one without the encumbrance of  shielding   might be well worth

> an added 3-15 rem. In any case, why shouldn't  the dose recipient [a

> daughter] be allowed to make an informed choice in the matter without NRC

> interference?"

>

>         A good, hearty AMEN to that.  It's a woman's right to choose, isn't

> it?

>

> Steven Dapra

> sjd@swcp.com

>

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