New NRC Reg Guide for patient release

[ehsnet!hps (HPS)]

Reply-to: Wes.Dunn@p2.f13.n233.z1.fidonet.org (Wes Dunn)
Fido-To: dale boyce

In a message of <19 Jul 94  11:56:59>, Dale Boyce writes:

 >Time to get the soapbox back out.  I have received a copy of the
 >draft reg guide on release of patients dosed with radiopharmaceuticals.
 >It indicates that written instructions must be given to patients and
 >records kept of that instruction at levels significantly lower than
 >before.  My read of it would say that written instructions and records
 >would be required for all I-131 patients that have 6.5 mRem or more
 >remaining or a dose rate of 1 mRem per hour.  I don't know how this
 >affects other institutions, but my office does not even see patients
 >that receive less than 30 mCi of I-131.  Other isotopes are listed
 >with different limits, but none of the other common nuc med isotopes,
 >except Tc99m are listed.
 >
 >OMB Paperwork Reduction Act strikes again!

Assuming this is the Reg Guide that goes with the proposed change to 
10CFR35 on medical patient release (I haven't reviewed the Guide yet,
but just finished reviewing the rule):

I think (hope) you have either mis-read the R.G., or there are some 
"minor errors" included.  My understanding is the R.G. is supposed to
help users implement the new rule, which clarifies that patient releases
are not held to the 100 mrem dose to the public in 10CFR20, but the 500
mrem dose listed in 10CFR35.  However, patient instructions are required
if the dose could exceed 100 mrem.  However, they do not appear to require
written instructions, but documentation (NRC example includes notation 
on the patient record) of the instructions.  Note that the new criteria is
based solely on estimated dose to the public (NCRP 37), and the 30 mCi
or 5 mR/hr standards are out.  If the RG (supposed to be published at the
same time as the final rule) is halfway decent, I don't see a problem
conceptually.  30 mCi or 5 mR/hr was nice and convenient, but has no basis
in reality for anything but I-131.  Do the new calcs, work out patient
instruction options, train the staff, and go.  (Note the NRC doesn't do
accelerator produced stuff, so Tl-201, etc..., won't be in the RG.  Also,
the Agreement States may be a bit behind in implementation, unless NRC
pulls another 10CFR20 "everyone together" fiasco).

Last, if you have comments on this, put em here.  I'll be reviewing the RG
and putting my comments together in the next week or so.  See next note for
further rational.

Wes Dunn
Token Revenuer


--- msged 1.99S ZTC
--- eecp 1.45 LM2 

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