medical misadministrations

[William V Lipton <liptonw@dteenergy.com>]

I received the attached response to my original posting by private
e-mail, and am posting it to RADSAFE with the author's permission.  I
removed the author's name at her/his request.  Although I don't agree
with all of it, I think that this response provides a lot of insight
into the recent "epidemic" of misadministrations.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com


 Bill,
>
> In response to your e-mail this morning regarding another medical
> misadministration, I would like to say that you are probably
preaching to
> the wrong people.  I do not know your background, but I do know that
you
> currently or at one time worked at a NPP.  I also do not know if you
are
> familiar with 10 CFR Part 35 "Medical Use of Byproduct Material."
>
> I agree with you that the rates of these types of events are to high.
The
> reason I think is simple.  Most nuclear medicine programs across the
country
> do not have a "professional" HP on staff.  (The exception would be
most
> teaching hospitals with research.)  The reason for this is found in
35.900
> that addresses the training and experience for RSO's in medical
facilities.
> This section allows almost any "certified" physician (35.900(a)) and
any
> authorized user (35.900(c)) to be an RSO, regardless of training
and/or
> experience.  I would suggest that you do a survey of the hospitals in
your
> area, including hospitals of all sizes and find out how many actually
have
a
> "professional" HP as RSO.  I think that you would be surprised.
> Unfortunately the NRC needs to have this rule since there are not
enough
HPs
> to go around.  I which I think you know.  In the revised rules that
were
> recently sent to the NRC commissioners they proposed a small step in
the
> right direction, a very small step. Authorized users that wish to
become
> RSOs will need "experience with the radiation safety aspects of
similar
> types of use."
>
> It is my impression that you, and many other "professional" HPs on
RADSAFE,
> would not think that I am qualified to be a "professional" HP.  I
qualified
> to be a RSO by fulfilling the requirements of 35.900(b).  I have a
4-year
> physics degree and my initial experience under a very competent HP,
who is
> now a CHP.  I am also in the initial stages of pursuing certification
at
> this time.
>
> Another problem for "professional" HPs in medical facilities is
staffing.
> The NRC does not or can not dictate staffing levels. (I am not sure
if
they
> can at NPP either.)  Back in 1986, after a NRC inspection (before I
was
> here), the inspection report stated that the NRC thought that the
staffing
> at this facility was not adequate.  The director of the facility sent
a
> letter back basically stating that the NRC cannot determine for him
what
the
> staffing levels should be.  (I have a copy of the letter if you would
like
> to see it.)  The NRC stopped pushing the issue at that time and there
is
> still only one HP at this facility.
>
> If you really think that this is a big problem I encourage you to
petition
> the NRC with a rulemaking on the issue of qualifications for RSOs.  I
am
> sure that you would have the support of many HPs, including myself.
>
> I once went to a talk and the main thing that I come out with was "No
> problems, without solutions."  It is hard to do.  I find myself
failing at
> it all the time.  What is the solution to this one?  I don't know
yet.
But
> the comments in your e-mail don't help.  What are your "solutions"?
>
> Thanks for your time.
>

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