[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
RE: licensing in medical institution
Malik,
While I suspect we are smaller, sounds like we have a similar situation. VA
Medical Center, Denver has about 6 medical authorized users and about 18
research authorized users. "Radioactive material will be used by OR UNDER
THE SUPERVISION" of authorized users, is the phrase that is on specific
licenses. We have in the past been a hybrid [although the NRC has disavowed
that term] broad scope licensee. Our RSC appoints authorized users for
medical use according to training requirements in 10 CFR 35. Basically
medical AUs are physicians who have met training requirements set forth in
various subparts of part 35 Sub D, Uptake, Dilution, Excretion; Sub E,
Imaging and Localization; Sub F Radiopharmaceuticals for Therapy; Sub G,
Sources for Brachytherapy; Sub H, Sealed Sources for Diagnosis; and Sub I
Teletherapy. A physician may be an AU for several subparts, if s/he meets
the training requirements. Most training documentation is in the form of
board certifications. We have one staff NM Physician who is qualified for
D, E, F, & H. We have some staff radiologists that are AUs for D, E, & H.
We have associated University [of Colorado Med. Center] MD's for
brachytherapy. We very rarely do that, like every ten years. We are not
authorized and do not do teletherapy. External beam [accelerator] therapy
is done for us on contract by the University.
Research Authorized Users are appointed according to a schedule of training
we made up and the NRC approved. It involves Training and Experience. Due
to the grant and investigator, principal investigator system our research
authorized users are always much more qualified than our criteria.
Radioactive materials are handled by radiation workers that are supervised
by the authorized users. In the medical part, they are Nuclear Medicine
Technologists that must have passed a registry exam. In the research arena
they are lab technicians and research assistants and graduate students.
There is no criteria for research radiation workers and some may start with
out any experience. Usually they have some and not infrequently they have a
lot. We document that and they are given a very brief orientation by
Radiation Safety [that's me]. The authorized user is responsible for doing
the bulk of the training. We have a small program so this works. The
University has a much larger program and they have a more rigorous and
formalized training program handled by the Radiation Safety Office. It is 4
modules that may take 1/2 to 1 day each, with tests for each module.
Now the short answer to your question is that the authorizations issued to
the Authorized Research Users list the radiation workers that have received
orientation. The appointment of medical authorized users is all on one
document and the Nuclear Medicine Technologists are not listed on them or a
document but the procedures for the NM Section require, as I said, that they
be certified or certifiable in one year from hire and if they were hired and
failed they would have to be let go.
Other thing that RSC and Authorizes Users should realize is that the
authorized user is the responsible person and if a radiation worker, working
under an AU messes up, it is the responsibility of the AU as much or more
than the individual that caused the problem. At USC the County of Los
Angeles inspected and issued 10 criminal warrants for flagrant violations of
radiation safety regulations to the authorized users at the institution.
Action under criminal statues is VERY RARE thankfully. But administrative
law sanctions are, unfortunately not so rare. In cases of failure to follow
radiation safety regulations the RSC must inform the Authorized User and
require him or her to take action. They can warn or use sanctions. The
ultimate sanction, is of course, revocation of authority to use radioactive
materials.
Hope that wasn't too long winded and is helpful. Hopefully my signature
block will be added, just in case not...Regards from:
Peter G. Vernig, VA Med Center, Denver, CO, USA
peter.vernig@med.va.gov
-----Original Message-----
From: Malek Chatila [mailto:mc02@aub.edu.lb]
Sent: Monday, March 01, 1999 5:58 AM
To: Multiple recipients of list
Subject: licensing in medical institution
Hello everyone,
We, at the American University of Beirut, are about to begin licensing
users of radioactive materials for research purposes. Our institution
consists of a university and a medical center. I was hopping that someone
might assist me with the following questions. What is the work practice in
the states concerning the licensing of personnel who uses radioactive
materials at a medical center? Is it similar to the University settings,
i.e. does everyone who possess or uses radioactive material above the
exempt levels need to be licensed from the Radiation Safety Committee. For
example, will the nuclear medicine department in a hospital need to be
licensed by the RSC to possess and use radioactive materials? Where do the
NRC stands concerning this matter?
Thanks in advance for your assistance.
Sincerely,
Malek Chatila, Ph.D. candidate
Health Physicist, Assistant RSO
American University of Beirut
Email: mc02@aub.edu.lb
Fax: 961-1-749-198
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html