Re: Medical Events Reporting

[John Jacobus <crispy_bird@YAHOO.COM>]

I would read the first statement as (1) the dose

delivered exceeded the prescribed dose by more that

50% which resulted in a dose to the skin or organ than

the treatment exceeded 50 rem.  Consider the situation

where the teletherapy dose was more than 50% higher

than the prescribed dose.  If the dose to the

overlying skin exceeded 50 rem, you have a reportable

medical event.  But both factors, the excess delivered

dose and dose to the skin must exist.



A "constraint" is an action level for ALARA response. 

If you exceed it, you need to ensure that it does not

happen again to be in compliance with ALARA practices.



--- "Shackford, Hobart W" <hshackford@rwmc.org> wrote:

> 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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=====

+++++++++++++++++++

""A fanatic is one who cannot change his mind and won't change the subject."  Winston Churchill



-- John

John Jacobus, MS

Certified Health Physicist

e-mail:  crispy_bird@yahoo.com



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