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Re: Nuclear Medicine Patients and Homeland Security
Sorry, Bill. But apparently the NRC does not think
there is any need to further restrict the use of
radioactive material in medicine. As I pointed out
before, . . .
"With regarding to compliance of instructions when a
patient is released, consider the following from NUREG
1556, Vol 9, Appendix U, "Model Procedure for Release
of Patients or Human Research Subjects
Administered Radioactive Materials" at
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v9/
"U.2.1 Activities and Dose Rates Requiring
Instructions
Based on 10 CFR 35.75(b), for some administrations the
released patients must be given instructions,
including written instructions, on how to maintain
doses to other individuals ALARA after the patients
are released.(Footnote 1) . . ."
"(Footnote 1)NRC does not intend to enforce patient
compliance with the instructions nor is it the
licensee’s responsibility to do so."
Maybe they feel that the medical uses do more good
than harm, and that the exposures to the public are
trivial.
--- William V Lipton <liptonw@DTEENERGY.COM> wrote:
> First of all, the NRC, not a specific licensee,
> issues a general license, see
> 10 CFR 30.31. Thus, issuing a general license to
> nuclear medicine patients would require
> rulemaking.
>
> To clear up any misunderstandings, once more with
> feeling:
>
> Let me repeat: I am not saying that this should be
> > done; I'm only responding to questions
> > regarding how it would be done, if required.
>
> Let's put this issue in perspective. The NRC
> criteria for unrestricted site release is 25
> mrem/year to an average member of the critical
> group. (10 CFR 20.1402) The EPA criteria for
> exposure of a member of the public from the uranium
> fuel cycle is 25 mrem/yr whole body, 75
> mrem/yr thyroid, and 25 mrem/yr any other organ. (40
> CFR 190.10) Defacto criteria for
> obtaining NRC approval for alternate waste disposal
> under 10 CFR 20.2002 is 1 mrem/yr. NRC
> "guidance" for nuclear power plants for exposure to
> the general public is 3 mrem/yr whole body
> and 10 mrem/yr to any organ from liquid effluents;
> and 10 mrads/yr gamma and 20 mrads/yr beta
> site boundary air dose from atmospheric releases (10
> CFR 50, Appendix I) The NRC is
> developing guidance for the unrestricted release of
> materials from restricted areas. It
> appears that the criteria will be 1 mrem/yr to the
> public from all waste streams.
>
> In contrast to this, a medical licensee is allowed
> to release a nuclear medicine patient if
> the dose to the public will not exceed 500 mrem per
> patient! (10 CFR 35.75) It seems that
> there should be some reasonable assurance that even
> this very generous criterion will not be
> exceeded.
>
> 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:
>
> > I think the NRC would take a dim view of a
> licensee
> > issuing a general license to an individual. Or
> are
> > you suggesting that new regulations be written to
> > allow medical licensees to do this? At what cost?
> To
> > whose advantage?
> >
> > --- William V Lipton <liptonw@DTEENERGY.COM>
> wrote:
> > > The general license would be "issued"
> automatically
> > > when the patient is released. The
> > > specific licensee would have the responsibility
> of
> > > informing those who are "issued" the
> > > general license of the applicable conditions,
> i.e.
> > > following the instructions.
> > >
> > > Let me repeat: I am not saying that this should
> be
> > > done; I'm only responding to questions
> > > regarding how it would be done, if required.
> > >
> > > 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:
> > >
> > > > Are you serious? Do you know how many nuclear
> > > > medicine therapies are done a year? And you
> want
> > > > everyone of them to be issued a general
> license?
> > > Who
> > > > would issue these licenses?
> > > >
> > > > --- William V Lipton <liptonw@DTEENERGY.COM>
> > > wrote:
> > > > > As I stated in a previous posting, the
> patient
> > > > > instructions could be enforced
> > > > > through the general licensing provisions of
> > > current
> > > > > regulations. The patient
> > > > > would be granted a general license to
> receive
> > > the
> > > > > material under the conditions
> > > > > of this license. One of these conditions
> would
> > > be
> > > > > to follow the instructions
> > > > > provided by the administering specific
> licensee.
> > > > >
> > > > . . .
> > > >
> > > > =====
> > > > +++++++++++++++++++
> > > > "There's no trick to being a humorist when you
> > > have the whole government working for you."
> > > > Will Rogers
> > > >
> > > > -- John
> > > > John Jacobus, MS
> > > > Certified Health Physicist
> > > > e-mail: crispy_bird@yahoo.com
> > > >
> > > > __________________________________
> > > > Do you Yahoo!?
> > > > Find out what made the Top Yahoo! Searches of
> 2003
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> > >
> >
>
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> > =====
> > +++++++++++++++++++
> > "There's no trick to being a humorist when you
> have the whole government working for you."
> > Will Rogers
> >
> > -- John
> > John Jacobus, MS
> > Certified Health Physicist
> > e-mail: crispy_bird@yahoo.com
> >
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=====
+++++++++++++++++++
"There's no trick to being a humorist when you have the whole government working for you."
Will Rogers
-- John
John Jacobus, MS
Certified Health Physicist
e-mail: crispy_bird@yahoo.com
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