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Re: Passing of prostate seeds



Federal and State regulations hold that: "No licensee shall discharge
radioactive material to the sanitary sewerage system unless: (a) it is
readily soluble or it is biological material that is readily dispersable in
water." Patient excreta are exempt from the limits on concentrations, but it
is assumed that they meet the above criteria. Sealed sources, regardless of
the obvious arguments one might raise, bearing on their high integrity, or
the small amount of material contained, e.g., 560 uCi in a typical 350 uCi
seed, or 3.6 mCi in the typical 1 mCi Pd seed (compared to the many dozens of
mCi [I131] that go down the drain from a patient under treatment for thyroid
Ca, in an entirely free form) are not accepted as patient excreta in any
regulatory venue of which I'm aware.
My understanding of the intent of the regs is that we are obliged to give the
patients instructions to control the seeds, as if they were, in fact, still
on our premises (license). The issue of what instructions (and equipment, if
necessary, e.g., strainers, containers to void into, shielded containers,
etc.) to give them, so as to effect this policy, is normally handled
("negotiated" might be a more apt term) in the course of the application for
licensure. Note that there are other sorts of issues involving the radiation
protection of persons and the environment that need to be addressed, notably
the death and autopsy of a patient within a few (less than seven?) half-lives
of implantation.

chris alston
ccja@aol.com