RE: NRRPT Petition for Rule Making

[VERNIG.PETER@FORUM.VA.GOV]

I think I'm in the minority here but, I favor the reduction of the
OJT to 3 months.
 
First, there's experience and experience.  I had experience at two places
that manufactured a device I-125 seeds (tm) and pharmaceuticals I-123,
neither would have counted but both were applicable IMHO.
 
I heartily agree with the gentleman/woman ctr from NRC these are minimums
we're talking here.
 
The year or 3 months now only applies to those using the 200 hours to be
qualified.  They do not apply to 35.900(a) CHP and all the other boards.
Would a CHP with 10 years of power plant experience be qualified?  No
offense all you CHPs.  Actually, depending on the circumstances I would
say maybe they would.  But I think somebody with the 200 hours in the
form of a bachelor's or MS in HP and 3 months of hospital experience
would be more qualified thatn a CHP with only a lot of power plant exper-
ience.  I'm not knocking power plant types either.  Just a different
environment.
 
The ARSO experience does not apply to 35.900(c) either.  An authorized
user might be, worst case, a first year resident, with only 8 hours of
training 35.950 for use of sealed sources in diagnostic studies.
 
Any doctors out there, I beg your pardon also.  I work a lot with doctors
most of the ones I work with would probably refuse an RSO designation if
they could because the realize they can't know everything and appreciate
their own limitations.  But there are a few who think because they are 
experts in a field of medicine, they are experts in everything they know
anything at all about.  Those can be dangerous.
 
I guess generally my position is non-interventionist.  I rather see more
guidance on what the NRC or powers that be consider acceptable quals
than rules about it.  I'd like to see a reg guide breaking down 
type of medical programs and suggested training and experience and give
the hospitals more flexibility to say hire somebody who might not have
experience with high dose rate brachytherapy [whether or not they had 
1 year or 3 months of hospital ARSO experience] and cover that with their
medical physicist or by hiring a consultant.  I have 6 years + as a
hospital RSO and have no experience with high dose rate brachy or 
teletherapy.  If I went to another facilty doing either, I would be 
qualified by reg but I would want to understudy somebody.
 
Almost forgot the grandfathers, 35.901 anybody who was an RSO befor
10/1/86.
 
Anyway, I support the reduction to 3 months and think it should be
applied to CHPs, Authorized Users, Grandfathers, and NRRPTs.  Don't
know the make up of all the medical boards listed maybe it should be
added to some of them.
 
These are my own opinions and do not reflect those of the Denver VA, 
The Dept. of Veterans Affairs, or any agency of or the U.S. Government.
 
Peter G. Vernig, vernig.peter@forum.va.gov