ML20052H030

Responds to Forwarding Rj Luchi Comments on Reg Guide 10.8 Re Proposed Training & Experience Criteria for Physicians Engaged in Nuclear Medicine Practice Licensed by Nrc.Comments Will Be Considered

ML20052H030
Person / Time
Issue date:	04/19/1982
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Jay Collins HOUSE OF REP.
References
FRN-47FR3228, RTR-REGGD-10.008 47FR3228-199, NUDOCS 8205190283
Download: ML20052H030 (2)

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h1 R.3220 El 4 g NN Og The Honorable James M. Collins to United States House of Represe,ntatives

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Washing *wn, D. C.

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Dear Congressman Collins:

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This is in response to your le'tter of March 18, 1982, whic smit'ad a letter from Dr. Luchi conceming the Nuclear Regulatory Cermission's proposed training and experience criteria for physicians who engage in nuclear medicine practice licensed by the Nuclear Regulatory Comission (NRC).

A Federal Reoister notice that the new criteria were t.nder 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 cade yet.

The revised criteria evolved f' rom preocsals initiated by the medical corc' unity 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 practice medicine in his or her medical specialty.

The proposed criteria are based on the reconmendations of the NRC's

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Advisory Comittee on Fedical.Uses of Isotopes. The Comittee is composed of recognized experts in nuclear medicine with specialties in areas such as internal medicine, diagnostic and ":erapeutic radiology, medical physics, etc. These specialized skills provide a broad rance of medical expertise focused on NRC policies and regulations pertainin; to nuclear i

medicine.

Selections of members of the Comittee are ordinarily based on recomendations or nominations fr= professional medical organizations.

For example, one present member of the Comittee was nominated by the l

American College of Cardiology.

The proposed training criteria' appear to have a substantial support in the medical com. unity. Thus far, the criteria have been encorsed by the American Board of Nuclear Fedicine, the American College of Suclear Physicians, the Society of Nuclear Fedicine, the American Osteopathic College of Radiology and the (ederated Council of Nuclear Fedicine Orcanizations.

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I Dr. Luchi's letter will be included with the coments received on the proposed criteria and will be considered in making a final decision on the criteria.

l Sincerely, W!rned T. A. RsimT William J. Dircks Executive Director for Operations l

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20515 March 18, 1982 Mr..Carlton C. Kammerer Room 1159 1717 H St.,

N.W.

Washington, D.C.

20555 Lear Mr. Kammerer:

Enclosed please find a copy of a letter sent to me by a constituent of mine, Dr. Robert J.

Luchi.

He is concerned about the Nuclear Regulatory Commission's draft revision of its training and experience requirements for nuclear medicine physicians.

I would appreciate it if you would note his comments and send me a full report.

Kindly address vour resconse to the attention of Ms. Stacey Lupton in my Wa'shington' office.

I thank you in advance, Mr. Kammerer,.for your time and assistance.

Sincerely, f

o,vid James M.

Collins, H.C.

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M:dic:l Csnter 2002 Holcombe Brulevard kS Houston, TX 77211 Veterans gp3 Administration

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Secretary of the Commission

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Washingtcn, D.C.

20555

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Attention:

Docketing and Service Branch

Dear Mr. Secretary:

I have read the Nuclear Regulatory Commissiens published draft revision of its training and experience requirements 'cr nuclear medicine physi-cians including nuclear cardiologists.

It is my judgement that this is an unnecessary increase in training'requirenents for physicians interested in nuclear cardiology who have come into the field through the standard '

cardiac fellowship training.

It is difficult for me to see how these-new requirements can be justified en the basis of radiatien safety or in fact other training requirements.

The impact of these proposed regulations en cardiologists interested in nuclear cardiology would be' severe. The intrusion of the Federal Government on the practice of medicine would be most unfortunate.

I urge that these revisions be withdrawn by t'.e Nuclear Regulatory

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Commission.

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.g ROBERT J. LUCHI, M.D.

Chief, Medica 1' Service and Vice-Chairman Department of Medicine Baylor College of Medicine O e h 5%ir Ader to:

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