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RE: NRC Proposed Fine and Severity Level 1 Violation
If the RSO follows your advise (CYA or pass the responsibility), this still
does not prevent the situation from developing nor does it prevent the
occurrence of a license violation. It looks like the RSO is going to take
the fall at the hands of either the facility or the NRC.
The question still remains, how much control over the patient and family is
required before the NRC determines the control is adequate?
I am not a lawyer, but I surmise patients have the right to terminate their
medical treatment and go home at any time unless they pose grave and
imminent danger to the public. If the patient goes home, the situation is
not monitored. Where is the consistency in mitigating the risk when the
patient is hospitalized versus the being at home? This appears to be a
regulatory problem, not a health risk problem.
Regards,
Steve Knapp, Ph.D.
-----Original Message-----
From: William V Lipton [mailto:liptonw@dteenergy.com]
Sent: Thursday, May 15, 2003 1:28 PM
To: Knapp, Steven J.
Cc: 'radsafe@list.vanderbilt.edu'
Subject: 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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