Medical Events Reporting

["Shackford, Hobart W" <hshackford@rwmc.org>]

For you folks that have worked with the new 10CFR Part 35 for a while I have a question.



Our state has just published their regulations revisions, revised to comply with the NRC regs., for review. In their zeal to minimize paperwork the NRC has produced the following paragraph in the definition of a reportable medical event that I find rather confusing:



(3) A dose to the skin or an organ or tissue other than the treatment site that exceeds by 0.5 Sv (50 rem) to an organ or tissue and 50 percent or more of the dose expected from the administration defined in the written directive (excluding, for permanent implants, seeds that were implanted in the correct site but migrated outside the treatment site).



Would I be correct in interpreting the above in the following way? 



(3) A dose to the skin or an organ or tissue, other than the treatment site, that exceeds by 0.5 Sv (50 rem) the dose expected from the administration defined in the written directive and that exceeds the dose expected from the administration defined in the written directive by 50 percent or more (excluding, for permanent implants, seeds that were implanted in the correct site but migrated outside the treatment site).



I was also surprised to see the new ALARA "constraint" of <10 mrem/yr for airborne emissions (from 10CFR Part 20). Could someone explain the difference between a "constraint" and a limit? If we exceed the constraint level we have to report it "and promptly take appropriate corrective action to ensure against recurrence." What is that phase? If it looks like a duck, sounds like a duck....



Hobie Shackford, RSO

Roger Williams Hospital

Providence, RI  

401-456-2471

hshackford@rwmc.org





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