RE: licensing in medical institution

[Sharyn.Baker@UCHSC.edu]

Hi Peter, 
yes, your message went to everyone as did my reply. And no, the details were
not particularly important. I was just saying heelo to you and clarifying
the program. I forget that Radsafe is set up so that all replies go to
everyone. Some listserves are not set up this way and I do not care for this
approach and wish they would change. If one wants to simply reply to someone
one must create a new email and copy their address from the one sent by
Radsafe. Then it will just go to the person intended.

Cheers
Sharyn

> ----------
> From: 	Vernig, Peter G.
> Reply To: 	radsafe@romulus.ehs.uiuc.edu
> Sent: 	Monday, March 1, 1999 12:15 PM
> To: 	Multiple recipients of list
> Subject: 	RE: licensing in medical institution
> 
> Sharyn,
> I was a little uncertain and felt it wasn't important to be absolutely
> correct.  What I don't understand is how you got the message.  I thought I
> had sent to the person asking.  I keep thinking I have master the internet
> and e-mail and keep finding out I have not.  I would imagine your message
> &
> this response also went out to everybody.  I will try and be more accurate
> and methodical in my use of e-mail.
> 
> -----Original Message-----
> From: Sharyn.Baker@UCHSC.edu [mailto:Sharyn.Baker@UCHSC.edu]
> Sent: Monday, March 01, 1999 10:15 AM
> To: Multiple recipients of list
> Subject: RE: licensing in medical institution
> 
> 
> 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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information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html