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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 imminent danger to the
public. If a patient goes home, the situation is not monitored.
Where is the consistency in mitigating the radiation risk when the patient is
hospitalized versus being at home? This appears to be a regulatory
problem, not a health risk problem. The NRC consultant stated the
radiation health risk to family members was insignificant.
The
questions still remains, how much control over the patient and family is
required before the NRC determines the control is adequate? Would the
NRC have a similar conclusion if an RSO completed the procedures listed in the
NRC letter to St. Joseph Mercy Hospital and a noncompliant and informed family
member exceeded the radiation dose limit?
It is
obvious the RSO could have done things to lessen the opportunity for the NRC to
find fault, but even if he did, would that have been enough?
Steve
Knapp, Ph.D.
ge-----
From:
John Johnson [mailto:idias@interchange.ubc.ca]
Sent: Friday, May 16,
2003 3:01 PM
To: radsafe@list.vanderbilt.edu
Subject: Re:
NRC PROPOSES $6,000 FINE AGAINST ST. JOSEPH MERCY HOSPITAL IN MICHIGAN FOR
OVEREXPOSURE TO A MEMBER OF THE PUBLIC
Radsafers
I think you all should join me in thanking John
for this.
Hopefully it (the subject) will now decay
away:-).
John
----- Original Message -----
Sent: Friday, May 16, 2003 10:06
AM
Subject: Re: NRC PROPOSES $6,000 FINE
AGAINST ST. JOSEPH MERCY HOSPITAL IN MICHIGAN FOR OVEREXPOSURE TO A MEMBER
OF THE PUBLIC
With regard to exposure rate values, these are in the report:0
| B. |
10 CFR 20.1301(a)(2) requires that each licensee
conduct operations so that the dose in any unrestricted area from
external sources, with exceptions not applicable here, does not exceed
2 millirem in any one hour.
Contrary to the above, the licensee
conducted operations so that the dose in unrestricted areas exceeded 2
millirem in any one hour. Specifically, licensee operations on July 1,
2002, resulted in a dose of 10 millirem in one hour in an emergency
exit stairway, and a dose of 17millirem in one hour outside the ground
floor window of a patient's room. Licensee operations continued
through July 7, 2002, when the resultant doses were 4 millirem in one
hour and 8 millirem in one hour, respectively.
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It should be noted that these values are outside of the patents
room. I assume next to the bed the dose rates would be significantly
higher.
Also, NCRP 37 provides recommendations. The NRC grants a license
under which the licensee agrees to operate. You cannot pick the
regulations you like to follow.
Carol Marcus <csmarcus@ucla.edu> wrote:
.
. .
So, where does 3 to 15 rem come from? Nowhere credible.
As I see it, the member of the family elected to get a radiation dose that
is judged safe for radiation workers, in order to be with a dying
relative. Seems reasonable to me.
It may be reasonable to
point out that 10 CFR Part 20 includes the last sentence of 20.1001:
"However, nothing in this part shall be construed as limiting actions that
may be necessary to protect health and safety." I would sincerely
argue that the mental health of the member of the family comes under this
clause, and that the standards need not apply. The care and peace of
mind of the dying patient should be considered as well. While I
would go to great lengths to prevent a member of the family from receiving
a dose that I know to be harmful, I don't see any reason to become
hysterical about a dose that is a! bout what a radiation worker may
receive in a year, or significantly less. In NCRP no. 37, it is
recommended that family members over 45 not receive more than 5 rads from
the patient. I don't know how old the family member in question was,
but clearly there are standards that would support much higher radiation
doses than the NRC seems prepared to permit in extreme
circumstances.
-- John
John Jacobus,
MS
Certified Health Physicist
e-mail: crispy_bird@yahoo.com
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