Dear MPC Client:
The NRC has issued a request for comment on proposed revisions to the patient release program. The NRC has directed staff to revise Regulatory Guide 8.39 Release of Patients Administered Radioactive Materials. Prior to 1997, hospitalization was required for all patients treated with more than 30 mCi of NaI‐131. The dose‐based release criteria was implemented in 1997 and we, as a Nuclear Medicine Community, began calculating the highest likely dose to an individual from each therapy patient in order to show compliance with the new 500 mrem dose‐based threshold. A return to an activity‐based release criteria will require additional staff hours and patient inconvenience.
Jim Carey, President of MPC, has written a response to the NRC based upon his extensive experience. It is important that affected licensee’s respond to this request for comment. A lack of response from licensees involved in radiopharmaceutical therapies may allow a few individuals without practical experience to push through unwarranted regulatory changes.
Therefore, MPC asks that you and as many individuals at your facility as possible submit either a response in support of MPC’s comments or a personalized response to the request for comment. Responses from NMTs, authorized users, referring physicians, nurses, and administrators will all be valuable. Please feel free to use all or parts of the MPC response.
Below are instructions for submitting comments. If you support the MPC comment you can cut and paste the template below.
Cindy Bladey, Office of Administration
RE: Response to NRC Request for Comment NRC Docket ID NRC‐2017‐0094
I am a ____________________________(Nuclear Medicine Technologist, Physician, Authorized User,
Radiologist, Administrator, Manager, Nurse) at a medical facility licensed by
__________________(USNRC, State of ___________).
I am submitting this letter in support of the Comment Response Letter submitted by James Carey, Medical Physics
Consultants, Inc. dated June 9, 2017. I have reviewed this response letter and agree with the contents.
Please accept my response to the request for comments NRC Docket ID NRC‐2017‐0094.
Thank you for the opportunity to participate in this process.
Steps for submitting comments:
- Copy the template or create your own response
- Click on https://www.regulations.gov/comment?D=NRC-2017-0094-0004
- Paste the template into the Comment box, type your own comments, or upload your own file.
- If using template modify the blank areas(date, etc).
- Provide name if desired or leave blank to submit anonymously.
- Click on “Continue” and follow any instructions.
Thank you for taking the time to provide a response. If you have questions, please feel free to contact Tracy King, firstname.lastname@example.org or your MPC consultant.