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Re: NRC Proposed Fine and Severity Level 1 Violation
Please look at http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/materials/ea02248.html
It is clear the reasons for the enforcement
- The individual received the exposure as a result
of not following prescribed radiation safety instructions, including staying
behind the shielding.
- Hospital staff frequently noted the individual
sitting at the patient's bedside where a shield was not located. When this was
observed, the hospital staff reminded the individual to position herself on
the other side of the bed behind shielding.
- While the member of the public disregarded
radiation safety instructions provided by hospital staff, the radiation safety
officer failed to implement corrective actions as necessary to minimize the
individual's exposure, once the extent of the potential exposure was
identified.
- During the predecisional enforcement conference,
you stated that you did not take more proactive steps to limit the dose to
visitors or to contact the patient's relatives to more accurately determine
their dose because of your concern for the patient's rights and for compassion
toward the patient and family members. The NRC staff understands that the case
involved unusual circumstances and that you did not want to appear
uncompassionate toward the patient or her family.
- However, you could easily have implemented a
number of actions in response to the daughter not following instructions, such
as: (1) explaining to the daughter that staying an arm's length from the
patient would significantly reduce the exposure (radiation levels at one meter
were approximately one-tenth those at the bedside); (2) using additional
shielding, including shielding the catheter bag; (3) minimizing the daughter's
time at the bedside; and (4) providing a digital dosimeter for the daughter to
self-monitor her exposure, which you had available. Therefore, the NRC has
determined that your staff's performance was deficient such that enforcement
action is warranted.
This case is very important for training
:
a) What should be discussed is the level of the
enforcement and responsible parties.
b) What is important to discuss is the lessons to be
learned to avoid recurrence
c) What is important to discuss also is the
responsible parties? - The Radiation Safety Officer could advice the
Director of the Hospital to inform the Regulatory Authority about the
dose to visitors because of his concern for the patient's rights and
for compassion toward the patient and family members.
Jose Julio Rozental
Israel
----- Original Message -----
Sent: Thursday, May 15, 2003 6:35 PM
Subject: NRC Proposed Fine and Severity Level 1
Violation
> 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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