-----Original Message-----
From: Jose Julio Rozental [mailto:joseroze@netvision.net.il]
Sent: Thursday, May 15, 2003 12:27 PM
To: Knapp, Steven J.; radsafe@list.vanderbilt.edu
Subject: 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 RozentalIsrael
----- Original Message -----From: "Knapp, Steven J." <Steven.Knapp@MED.VA.GOV>Sent: Thursday, May 15, 2003 6:35 PMSubject: 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
>
>
>
> ************************************************************************
> You are currently subscribed to the Radsafe mailing list. To unsubscribe,
> send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
> radsafe" (no quote marks) in the body of the e-mail, with no subject line.
> You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/
> ************************************************************************
> You are currently subscribed to the Radsafe mailing list. To unsubscribe,
> send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
> radsafe" (no quote marks) in the body of the e-mail, with no subject line.
> You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/
>
>