RE: Dose Rates from Patients

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Kathi,

10CFR20.1903(b) clearly states that posting of patient rooms is not
required ONLY if the patient could be released from confinement
pursuant to 10CFR35.75.  [20.1903(a) also allows the room not to be
posted if (1) material is in the room less than 8 hours; (2) the room
is under constant surviellance; and (3) the licensee controls the
room].

A conflict between Parts 20 and 35?  Oh my!  Then it is up to the NRC
to determine precedence.  The NRC has historically chosen Part 20
[RE: public dose limits vs patient release limits].

However, posting requirements are separate from dosimetry
requirements.

Wes


> Date:          Wed, 10 Jul 96 14:52:26 -0500
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          Kathi Elliott <KELLIOTT@WPO.IUPUI.EDU>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       RE:  Dose Rates from Patients

> I don't believe it is appropriate to post a patient room as a "radiation
> area" or "high radiation area" (at least according to an NRC inspector).
>  10CFR35.315 states to post a radiopharmaceutical (and 35.415 for
> implant patients) patient's room with a "Radioactive Materials" sign.
> No mention of "radiation area."  Maybe the part of the definition of
> "radiation area" that states "...accessible to individuals" exempts
> hospital rooms (i.e., the room is posted that all visitors must report
> to nurses station before entering the room).  Therefore, it is assumed
> that there is some controlled access(???).  But we all know how that is!
>  I know that really sounds like a stretch...any other thoughts?
>
> Kathi Elliott
> Indiana University Medical Center
> kelliott@wpo.iupui.edu
>
>
*********************************************************************
Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************