ML20052H023
| ML20052H023 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Broyhill J HOUSE OF REP. |
| References | |
| FRN-47FR3228, RTR-REGGD-10.008 47FR3228-228, NUDOCS 8205190275 | |
| Download: ML20052H023 (2) | |
Text
f
~u g$
f 1
g e
/
amm
~: ad ::ULE IS(
e c4ir i~
- 1sn q,
REcylVED.
shy 7196A 9 6
The Honorable James T. Broyhill sagen United States House of Represe.ntatives noc
=
y 9
Washington, D. C.
20515 N
Dear Congressman Broyhill:
This is in response to your le'tter of March 26, 1982, which transmitted a letter from Dr. Whalen concerning the Nuclear Regulatory Comission's
-proposed training and experien.'ce criteria for physicians who engage in nuclear medicine practice licensed by the Nuclear Regulatory Comission (NRC).
A Federal Recister not' ice that the new criteria were under consideration and that public 'coments were invited was published on January 22,1982 (47 FR 3228, ' copy enclosed).
A final decision on adoption of the criteria has n,'ot been made yet.
The revised criteria evolved f' rom proposals initiated by the medical comunity to reflect the training believed necessary for a physician to use licensed materials safely.for protection of workers., the public and patients. These criteria are in addition to any clinical skills a physician must have to practic;e medicine in his or her medical specialty.
The proposed criteria are basdd on the recomendations of the URC's Advisory Comittee on Pedical Uses of Isotopes.
The Corm:ittee is composed of recognized experts in nucle'.ar medicine with specialties in areas such as internal medicine, diagnostic and therapeutic radiology, cedical physics, etc. These specialized skills provide a broad range of medical exoertise focused on HRC policies and regulations pertaining to nuclear medicine. Selections of members of the Comittee are ordinarily based on reccmendations or nominations frem professional medical organizations.
For example, one present membe'r of the Comittee was nominated by the American College of Cardiology,.
The proposed training criteria ^ appear to have a substantial support in the medical comunity. Thus far, the criteria have been endorsed by the Faerican Board of Nuclear Medi' cine, the American College of Nuclear Physicians, the Society of Huclear Medicine, the American Osteopathic
()
College of Radiology and the F,ederated Council of Huclear Fedicine
/
Crganizations.
,g'.
l fI W
G S 6:
I k$0MjD 820419
/
10 008 C peg
"">..1.....
.g...................
~ "%.
................l.......
x
\\.>..............
.)
- Han:rable James T. Broyhill - -
Dr. lihalen's letter will be included with the coments received on the proposed criteria and will be considered in caking a final decision on the criteria.
~
Sincerely, A
734nNO T. A. Rshm
~
William J. Dircks Executive Direct.or for Operations
Enclosure:
47FP3228
~
~
d i
4
(' Yli JAMES T. a',CYHILL
- "*'ev qices.
g 3m sa =iverry 103H Distancv. >+o=vw cm w
Gasman,+.onv= camou a 2e332 cunu.u hvuu== Howes omca muotoismo (ConDnregg of f c I!Initch dbtates
~~--.
~ ~ = = - ="'
Loon. P.oev= canow.e4 2ssa5
- .;,2 21b217E 0;,4)7344147 auge of Representatibts u~
,vm.
Roems 133
=~c;;;~aco;~;;cc maseingron, n.c. 20 sis n, o=v=::"',2 o,
Ou) 23 4719 M C M BEJ' March 26, 1982, Mr. Carlton Kammerer, Director Office of Ccngressional Affairs Nuclear Regulatory Con:nission 1717 H Street, NW Washington, D.C.
20555
Dear Mr. Kammerer:
Enclosed is a copy of the correspondence which I~recently received from Mr. P.obert E. Whalen, ':.D., Prof essor of 1:e dicine at Duke University Medical Center, Box 3393, Durh am, North Carolina 27710.
As you will note, Dr. Whale opposes)the draft revision of the NRC's requirements for nuclear rieTicine physicians, as he believes the proposed three month extension of the training program is unnecessary and may contribute to increased heal:h care costs.
I believe you will find his letter to be self-explan at ory.
Due to the concern this matter has caused Dr. Whalen, I would appreciate your review of this situation and your coments ir this regard.
i t h ~ e: regards, 4
Jam s T. Eh ill "e.. o/r of. Conrress JTS:gm enclosure galG2R g
g/
h
.. m
)
o a. gg ouxs usivsasirv uso1 cit cesrea
)
Deparornens of Medicine Dwision of Marcb 5,1982 Cardavascular Disease Honorable James T. Broyhill U. S. House of Representatives Washington, D. C. 20515
Dear Representative Broyhill:
I am writing to you as a constituent, as a member of the Gevs:nmental Relations Committee of the American College of Cardiology, and as the lirector of Cardio-vascular Disease Service at Duke University Medical Center.
I am writing specifically to protest the draf t revision of the Nuclear Replatory Commission requirements for nuclear medicine physicians, including nuclear cardiologists who are requesting authorization to use reactor produced radi: isotopes for nuclear medicine procedures including nuclear cardiology.
Once again this seems a clear example of regulatery overkill, particularly in l
the case of cardiology.
In essence, what the NRC is doing :.s doubling the time l
it requires for training in a very narrow area because of pc:intial perceived I
hazards which have never been documented despite years of ex;arience with using isotopes in the clinical situation they are trying to regula:s.
The NRC has essentially proposed that the amount of training to use certain liaited isotopes be increased from three months to six months despite the f ac: that nothing in our past experience indicates a need for this, particularly f:: trained cardio-logists.
Much of the three months of additional time the NRC wnpid re:. ire would be to attempt to teach clinicalcardiology to cardiologists who have already gone through extensive training programs.
Thus, the NRC has prrp: sed three months ex-tension of a training progra= to attempt to provide something which the candidate going through the training program elready has in abundance.
s I hope you and your administrative staff will review the testimony given by the American Heart Association and the American College of Cardic"ogy concerning these organizations' objections.
These objections have been sent to Mr. Samuel J. Chilk, Secretary of the U.S. Regulatory Co= mission.
Aside from the' inappropriateness of the charge in the regula: ions I think it is worth recognizing that this is how we build new health :are costs into the system in a sub,tle way.
If you increase the length of t4-= ' training pro-grams this will be di,r,ectly reflected back into the health care cost of this country and will further increase the charges the patients will eventually pay.
6 ] n tir l ' tyj (y Box 3393
- Durham, North Carolina 27710
- Telephone (919) 68 t-H:5
(
'L e #
A
,r' s
Honorable James T. Broyhill 2-March 5, 1982 I think m.,ch of the health care cost increases that have occurred can be traced back to these seemingly minor changes in regulations and I hope you will take this opportunity to at least intervene in this issue.
Sincerely, 6Y bv Robert E. Whalen, M.D.
Professor of Medicine Director, Cardiovascular Disease Service REW/w CC:
Mr. Samuel J. Chilk Mr. William D. Coughlan i
j i
1 2
'?
4 W
l t
^
i 1
e
-y
- - ~<
ws --
+ w -
.,w,-
w
--