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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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