Re: Related issue - patient

["Kent N. Lambert" <lambert@allegheny.edu>]

BLHamrick@aol.com wrote:

> 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. 

True, but the licensee has no control of what the patient does when 
s/he leaves the facility.  Compliance with instructions is may or may 
not occur.  No regulations have been violated if the instructions are 
not followed.

> 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 respectfully  disagree.  10 CFR 20.1501 applies to licensed 
material.  Once the patient is released from confinement (for the 
purposes of controlling the radiological hazards present) any 
contamination from the patient is not licensed radioactive material.  
Therefore, 10 CFR 20 does not apply.


--
Kent N. Lambert, M.S., C.H.P.
mailto:lambert@allegheny.edu