Re: Brachy Misadministrations

[carol marcus <csmarcus@ucla.edu>]

At 11:55 AM 3/4/99 -0600, you wrote:
>I was recently asked a question by a physician in a radiation 
>oncology department concerning the Quality Management Program's 
>definition of "misadministration" and "recordable event". The 
>question basically was 'how much time do you have to get the 
>brachy source in place before it is considered a misadministration?' 
>In other words, suppose there was a temporary obstruction while 
>trying to place the source in the site to be treated. Surrounding 
>tissue is being irradiated at this time. What length of time is there 
>to get this source in place before it's a misadministration, or 
>recordable event. The GA regs simply talk about when the administered 
>dose is >10% (rec. event) or >20%(misadmin.) of the prescribed dose. 
>The prescribed dose is usually for the treatment site only. The regs 
>do not give a rec.event/misadmin. threshold limit to other parts of 
>the body.
>Any thoughts? Suggestions? References?
>Your help is appreciated.
>
>Steve Grimm
>Sr. HP
>Radiation Safety Office
>(404)727-3525; pgr. 742-7902
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Dear Steve and other Radsafers:

The NRC doesn't know enough about medicine to have ever even considered that
question.  It was never raised during the entire NRC nitwit nonsense that
surrounded the whole Misadministration Rule rulemaking process.  NRC lied
and created false data to support the rulemaking, but never cared about
whether or not it made sense in medical practice.  It has no one there that
understands medical practice except for its Visiting Medical Fellow, who is
not allowed to work on the "Medical Program".

There is the ACMUI, of course, but they unanimously trashed the
Misadministration Rule when it first came up, and trashed it again a few
years later.  One of the NRC Commissioners (Curtis) even threatened to
disband the ACMUI (it is not required by the Atomic Energy Act), but NMSS
management prevailed, and that, of course, did not happen.

The Misadministration Rule should be abandoned.  It is pointless, stupid,
and vicious.  NRC did a study on its effects and found that it did nothing
to decrease errors, which was its ill-conceived aim. However, the Chairman
isn't smart enough to discard Admiral Carr's misguided junk and that's why
it's still here.  Even though all the participants in the Chicago meeting of
the NRC public meetings on the new Part 35 unanimously trashed the
Misadministration Rule, we are all being ignored by an NRC that is incapable
of being educated, let alone being honest. At the All-Agreement States
meeting preceding these public meetings, there was a unanimous vote to trash
the rule as well, although the Chairman doesn't care about that, either.

Ciao, Carol

Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu>

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