Re: saftey of being in the proximity of someone on RAI therapy

[BLHamrick@AOL.COM]

This little topic has stirred up quite a bit of interest.  I'm sure I  will 

not have the last word, but I would like to clarify a few things.   Some of 

what I have to say has already been pointed out, but I'd like to put it  all in 

one place for future reference.

 

First of all, many landfills have been "required" by state law or by  their 

permitting agency to install radiation detectors.  In general, these  are not 

requirements imposed by the radiation health agencies, but by the waste  

management agencies, who usually do not have health physics expertise on  staff.

 

In California, most of the installed monitors are sodium iodide detectors,  

connected to a meter that provides a readout in kilo-counts per minute, and  

without any ancillary equipment that would provide isotopic  identification.  As 

someone else pointed out, the meters are usually set to  alarm anywhere 

between 2 and 10 times the average background count-rate.

 

In an informal review I performed of landfill alarms that are voluntarily  

reported by some states to the NRC's NMED system, over 98% of the alarms (from  

the states that report) were from patient waste resulting from a recent 

nuclear  medicine procedure.  The states most commonly see I-131 in the waste, but  

have also found Tc-99m in surprising amounts, as well as Tl-201, and other 

odds  and ends.  In some cases (especially early on when these detectors were  

first installed), the regulatory agencies would often sort through the waste,  

and a patient identification could be made from the waste surrounding the "hot" 

 trash (now there is less inclination to sort through the trash if it can be  

identified as a short-lived nuclear medicine isotope, since most inspectors 

now  carry a portable gamma-spec system).

 

As another poster pointed out, when a "hot" apple core is found in the same  

trash bag as 48 pieces of mail addressed to Ms. Jane Doe at 123 Plum Street, 

one  can pretty much assume that Ms. Doe recently had some type of nuclear 

medicine  treatment.  In one case I know of, this was confirmed, because an 

inspector  drove by 123 Plum Street on the next "trash day" with a detector out the 

car  window, and, sure enough, the trash was again "hot."  Thus no medical  

entity has to provide any "privacy" information, although, just FYI, HIPPA does  

provide some exemptions from the privacy requirements for regulatory  

agencies.  

 

The question is, what to do about this situation, as (at least in  

California) these landfill alarm responses are unfunded activities that are very  

time-consuming, and rather nasty (due to the trash aspect) as well.   They cannot 

simply be ignored, because there actually have been incidents where  relatively 

significant sources have been identified.  A very recent  case involved the 

disposal of old therapeutic radium needles at a public  landfill.  The radiation 

health agencies, in most states (PA may be an  exception) do not have the 

authority to require the landfills to purchase  gamma-spec systems, and there is 

considerable concern that even if they could,  the reported results would not 

be reliable without implementing some type of  appropriate training and 

re-training requirement for the landfill  operators.

 

In addition, even when these wastes are identified as short-lived nuclear  

medicine isotopes, the landfills are under no obligation to take them.   Indeed, 

most landfills in California carry a prohibition in their permit that  does 

not allow them to accept any radioactive materials.  The practicality  of the 

situation has been worked out with some landfills on a case-by-case  basis, 

such that they will hold the waste load for decay, then bury it, or even  bury it 

directly upon receipt of written "permission" from the radiation health  

agency, but this varies, literally from landfill to landfill, not just state to  

state.

 

This is a serious concern for many state agencies, as the number of these  

monitors are increasing, and the response to the alarms is not generally  

funded.  In states with large land areas (California, Texas, and Florida,  e.g.), 

the problem is compounded, because the travel time usually well exceeds  the 

response time, and is generally not justified by the end health and safety  

impact of the "event."

 

As an aside, someone on the list noted that only licensees are responsible  

for compliance with the regulations.  This is not the case in  California.  

California regulations require "users" of radioactive  materials to comply with 

the regulations, and the definition of "user" embraces  anyone with a 

licensable source of radiation.  If it is not expressly  exempt, it is licensable, and 

subject to regulation (irrespective of whether or  not it is, in fact, 

licensed), though I am not aware of any attempt to enforce  regulations upon a 

patient that has disposed of their own excreta-contaminated  waste to a solid waste 

facility.

 

So, this is an issue that should be taken up by the nuclear medicine and  

waste management communities, in conjunction with the radiation health agencies,  

so that a reasonable solution may be found.  We are wasting an enormous  

amount of money, nationwide, chasing "hot" diapers, yet we must be cognizant of  

the fact that occasionally (though extremely rarely) these monitors do identify 

 relatively more significant sources.  The question on the table should be  

do those very rare occasions justify the other 98%+ of the responses.   I.e., 

if a radium needle or two makes it into a landfill somewhere in the  country 

every 5 to 10 years, does that justify the millions wasted by the 50  states' 

radiation health agencies chasing "hot" diapers on a daily basis?

 

Barbara L. Hamrick, CHP, JD