Re: Related issue - patient

[BLHamrick@aol.com]

In a message dated 97-05-27 09:02:28 EDT, Kent Lambert wrote:

<< NRC regulations (I can't talk about CA regs) implicitly permit
 radioactive waste in the public landfills.  Patients may be released
 from confinement based on specific criteria (which changes later this
 week).  So I can administer 29 mCi of I-131 (or other isotope such as
 Tc-99m) and release the patient.  Once the patient is released, he/she
 is no longer under the licensee's control.  So, the patient is
 incontinent.  Disposable products are used to clean up.  Cleaning
 materials are placed in the trash ...  What regulation has been
 violated? >>

You're absolutely right to some extent.  Tc-99m can "legally" end up at
landfills from patients who have been released.  However, this waste rarely
makes it to a landfill before decaying, because residential trash pick up is
usually only once per week.  I-131 patients released cause some additional
problems which are addressed in a variety of ways.  One thing many facilities
do is instruct patients to rinse the disposable dishes, etc. that they use at
home before disposing of them in the trash. 

 However simply because a patient is releasable does not relieve a facility
from controlling the radioactive waste generated.  If that were the case,
diagnostic programs would not be required to decay waste in storage - they
could simply dispose of their syringes directly to medical waste processors
without holding or surveying it.  Also, simply because there has been no
specific commitment to control a specific type of waste (e.g., dialysis
filters contaminated with gallium), the facility is not relieved from
"performing adequate surveys to determine..." the extent of contamination or
radiological hazards present (10 CFR 20.1501), and handling it as they would
any other contamination they might identify at their facility.

I'd be delighted to see some kind of BRC (Below Regulatory Concern)
regulation re-introduced.  And, we should include solid waste handlers in
these discussions because many states have regulations prohibiting landfills
from receiving ANY radioactive materials, which is patently absurd.

Barbara L. Hamrick
BLHamrick@aol.com