RE: licensing in medical institution

[Sharyn.Baker@UCHSC.edu]

Hi Peter,

Our Rad Trng program is modular but all but one module is completed simply
by self-study and sucessfully completing a challenge exam. There are 4
required modules for workers, 5 for P.I.s.
Module 2 is a mandatory 2 hour class. So far there is no required refresher
but we have yet to get all the "old" researchers to comply with the new and
mandatory program.

It is no big deal that your email suggests otherwise but I thought you'd be
interested in knowing the real format. It is certainly much more rigorous
than existed here before and no exceptions are made exempting personnel from
training. Even God would have to complete the training before woriking with
isotopes.

Our experience is that there are often people coming here to work who have
little or no formal training. To think they will get rigourous and
disciplined training by P.I.s is just not reality. Some are very disciplined
and others not so. In fact, it is some of the P.I.s who create problems or
do not handle isotopes appropriately. 

regards,
sharyn baker
instructor - health and safety divsion
UCHSC

> ----------
> From: 	Vernig, Peter G.
> Reply To: 	radsafe@romulus.ehs.uiuc.edu
> Sent: 	Monday, March 1, 1999 9:37 AM
> To: 	Multiple recipients of list
> Subject: 	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
> 
> 
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