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how much control over the
patient and family is required before the NRC determines the control is
adequate?
Considering International Recommendation as in the
IAEA Basic Safety Standards, Safety Series 115, 1996, the
GUIDANCE LEVEL OF ACTIVITY FOR DISCHARGE
FROM HOSPITAL (page 284)
TABLE III-VI. GUIDANCE LEVEL FOR MAXIMUM
ACTIVITY FOR
PATIENTS IN THERAPY ON DISCHARGE FROM
HOSPITAL
Iodine-131 1100 MBq - In some countries a level of 400
MBq
is used as an example of good practice.
About Control (page 58)
CONTROL OF VISITORS
III.5. Registrants and licensees, in
co-operation with employers when appropriate,
shall:
(a) ensure that visitors be accompanied in any controlled area
by a person
knowledgeable about the protection and safety measures for that
area;
(b) provide adequate information and
instruction to visitors before they enter a
controlled area so as to ensure
appropriate protection of the visitors and of
other individuals who could be affected by their actions;
and
(c) ensure that adequate control
over entry of visitors to a supervised area be maintained
and that appropriate signs be posted in
such areas.
LESSON TO BE LEARNED BY
LICENSEE:
Minimize misunderstanding, and
as result mismanagement, in case of doubt, ask to Regulatory Authority to
clarify.
Example of a possible
misunderstanding - What does (when appropriate)
means
Jose Julio Rozental
Israel
----- Original Message -----
Sent: Monday, May 19, 2003 3:30 PM
Subject: RE: NRC PROPOSES $6,000 FINE
AGAINST ST. JOSEPH MERCY HOSPITAL IN MICHIGAN FOR OVEREXPOSURE TO A MEMBER OF
THE PUBLIC
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.
|
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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