Release of Patients

[Kent Lambert <lambert@allegheny.edu>]

I read the final rule re the release of patients administered
radioactive materials and had a couple of questions:

1.  Did I sleep through a change in 20.2101(a) which requires that
records be kept in units of curies, rads, and rems?  If not, why is this
rule written in terms of Sieverts?  I think that requiring one set of
units while the regulations are written in a separate set of units is a
mistake.

2.  In response to a comment that the dose-based release limit will
necessitate that many personal questions will need to be asked, the NRC
says, "nearly all patients will be released based on default assumptions
which do not require any personal information from the patient."  But in
response to a subsequent comment, the NRC says, "In special situations,
such as when a released patient would immediately board an airplane and
would therefore be in close contact with one or more individuals, it may
be necessary to base the release criteria on a more realistic
case-specific calculation."  

    So, how does one determine if a "special situation" exists if one
does not ask personal questions?  Or should we follow a "don't ask,
don't tell" philosophy?

3.  The rule explicitly addresses the dose to an infant or child that is
breastfeeding, where the mother is administered radioactive material,
but it does not address in utero exposure of the embryo or fetus.  Is
there a good reason why not?

So this is not considered NRC bashing, I think that a dose basis for
patient release with the guidance document (which provides default
release criteria is more rational than the existing rule, and I am
generally pleased with this change.

--
Kent N. Lambert, CHP
lambert@allegheny.edu

My employer takes no credit for opinions
expressed by this writer.