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Re: Nuclear Medicine Patients and Homeland Security
This IN does not hold the licensee responsible if a patient refuses to follow the written instructions,
provided that the licensee has made a reasoned determination that the patient is "capable" of following these
instructions and has stressed the importance of following them. If a patient who alarms a detector states
that he had to sign some paperwork, but had no idea what it meant, then an inspector may be visiting the
licensee. However, if this patient states that he understands the instructions but chose not to follow them,
I don't think there's anything that the NRC can do.
I don't know whether the NRC has statutory authority to require the patient to follow instructions. It seems
that, unless specifically exempted by law, the NRC could write the regulations such that the patient is
granted a general license to receive the nuclear medicine treatment and the nuclear medicine administration
is considered a transfer to a general licensee. Then, one of the conditions of this general license would
require to patient to follow all written instructions from the specific licensee. I'm not sure that this is
worth it.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
John Jacobus wrote:
> While I understand the significants of informing
> patients about the relationship between administrated
> doses and presence of detection equipment, I do not
> know what can be done with patients that refuse or
> forget to follow release instructions? What is the
> licensee to do?
>
> --- William V Lipton <liptonw@DTEENERGY.COM> wrote:
> > Recalling an earlier Radsafe discussion on nuclear
> > medicine patients who
> > alarm radiation detectors placed in critical
> > infrastructure, the NRC has
> > issued Information Notice 2003-22, "Heightened
> > Awareness For Patients
> > Containing Detectable Amounts of Radiation From
> > Medicial
> > Administrations." This Notice describes an event in
> > which a nuclear
> > medicine patient, who had been released in
> > accordance with 10 CFR 35.75,
> > alarmed a detector in a tunnel while on a bus from
> > New York to Atlantic
> > City. The discussion notes that the patient had
> > disregarded the 10 CFR
> > 35.75 written instructions, which stated that the
> > patient should not use
> > public transportation for 2 days. Hence, the Notice
> > recommends that,
> > "...authorized users are expected to evaluate the
> > patient's capability
> > to follow recommended written instructions before
> > release, to determine
> > if release at that time is advisable, and stress the
> > importance to the
> > patient of following the written instructions."
> >
> > The report also notes that patients who are below
> > the threshold for
> > 10 CFR 35.75 written instructions could still alarm
> > radiation
> > detectors. The Notice thus "recommends" that
> > nuclear medicine
> > licensees: (1) "... provide all patients that still
> > contain delectable
> > [sic] amounts of radiation with an appropriate
> > explanation about the
> > potential of alarming radiation monitoring
> > equipment." (2)
> > "...consider providing the patient with the
> > licensee's business card and
> > written information for law enforcement use..."
> >
> > In the previous discussion, I suggested that
> > recommendation (1) should
> > be a regulation, and received many responses saying
> > that the medical
> > community doesn't need a regulation to do this.
> > Now's your chance.
> >
> > The opinions expressed are strictly mine.
> > It's not about dose, it's about trust.
> > Curies forever.
> >
> > Bill Lipton
> > liptonw@dteenergy.com
> >
> >
> >
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>
> =====
> +++++++++++++++++++
> "Those who deny freedom to others deserve it not themselves, and under a just God cannot long retain it."
> Abraham Lincoln
>
> -- John
> John Jacobus, MS
> Certified Health Physicist
> e-mail: crispy_bird@yahoo.com
>
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