ML20053A939
| ML20053A939 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1982 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Melcher J SENATE |
| References | |
| FRN-47FR3228, RTR-REGGD-10.008 47FR3228-36, NUDOCS 8205270475 | |
| Download: ML20053A939 (2) | |
Text
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f[ga ng-k-UNITED STATES y 7, s ( 3 g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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l Cd The Honorable John Melcher
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United States Senate
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Washington, D.C.
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Dear Senator Melcher:
This is in response,to your letter of April 12, 1982, which transmitted a letter from Dr. Weeks concerning the Nuclear Regulatory Comission's proposed training and experience criteria for physicans who engage in nuclear medicine practice licensed by the Nuclear Regulatory Comission (NRC).
A Federal Register notice that the new criteria were under consideration and that public comments were invited was published on January 22,1982 (47 FR 3228, copy encl osed).
A final decision on adoption of the criteria has not been made yet.
The revised criteria evolved from proposals initiated by the medical community to re flect the training believed necessary for a physican to use licensed material safely for protection of workers, the public and patients.
These criteria are in addition to any clinical skills a physican must have to prac-tice medicine in his or her medical speciality.
The proposed criteria are based on the recomendstions of the NRC's Advisory Comittee on Medical Uses of Isotopes.
The Committee is compose'd of recog-nized experts in nuclear medicine with specialities in areas such as internal medicine, diagnostic and therapeutic radiology, medical physics, etc.
These specialized skills provide a broad range of medical expertise focused on NRC policies and regulations pertaining to nuclear medicine.
Selections of mem-bers of the Comittee are ordinarily based on recommendations or nominations from professional medical organizations.
For example, one present member of the Comittee was nominated by the Anerican College of Cardiology.
The proposed training criteria appear to have a substantial support in the medical community.
Thus far, the criteria have been endorsed by the American Board of Nuclear Medicine, the Anerican College of Nuclear Physicians, the Society of Nuclear Medicine, the Anerican Osteopathic College of Radiology and the Federated Council of Nuclear Medicine Organizations.
Dr. Weeks' letter will be included with the coments received on the proposed criteria and will be considered in making a final decision on the criteria.
Sincerely, f
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th f, 'f Carlt6n Kam%m r, Dir ctor ADP:
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Office 's/ Congr al Affairs g
Enclosure:
pgt)tgpico Federal Register Notice 394*1I 47 FR 3228 "3
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JIHN MELCHER
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?JCnifeb Sfales Senafe April 12, 1982 Keith R. Weeks, M.D.
Montana Heart Institute 1231 North 29th Street #312/#315 Billings, Montana 59101
Dear Keith:
Thanks for your letter and the material on the change in the regulations concerning nuclear medicine training.
Since existing practioners are grandfathered in,those in training will not be affected and training programs will be allowed time to change those programs.
The matter of people not receiving proper training is another matter.
I'm not sure that is the purpose of the NRC guidelines, but I have inquired of the NRC and Mr. Del Medico tells me they are still considering comments.
When I hear from the NRC, I'll get back to you.
Best regards.
Sincerely, 253 RusstLt. BUILDING CORNER or 1sT & C NE.
WASHINGTON. D.C.
20510 (202) 224-2644
MUNTANA
.1231 NORTH 29TH STREET * #312/#315
ROSEAT E D PC aussau s.n $ U I.
c TIMOTMY A. DERNSACM. KD.
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HEART INSTITUTE February 8, 1982 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20005 ATTENTION: Docketing and Service Branch
Dear Sirs:
This is in comment to your proposed changes concerning cardiology and nuclear medicine as published in the Federal Register of January 21, 1982.
I wish to comment on your acceptable training experience for medical uses of a by product material, specifically Category 5, Training for Diagnostic
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Procedures.
I would use as reference your own supplemental information which
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states, "by way of background NRC's objective is to ensure that authorized physician users have sufficient training experience to handle safely the by product material used in nuclear medicine." To my way of thinking, this background information states that the NRC's responsibility is to ensure that physicians who use the material have training in the handling and safe use of by product material. This certainly is the objective of the " training for basic radioisotope handling techniques, which is 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />,"
if the categories refer to training in the actual handling and to training in the interpretation.
One could not quibble with the fact that training is needed in the handling.
What is training becomes a question.
Is training observation of a technique and drawing up material and watching that material being given, or is it the actual drawing up of material by the physician, measuring the doses and then t
giving it himself.
I think it can clearly be stated in most institutions that l
the technician will do most of the work.
A physician may observe these in his training program, but he is not going to observe 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> worth.
I believe the above can be stated unequivocally and does not warrant further l
comen t.
In other words, I believe that the 500 hour0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> requirement is much too j
long for adequate learning, specifically in view of the fact that the physician j
has had adequate training with the initial 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of basic.
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The second category of training under supervision of a skilled practitioner I
who will teach the physician how to interpret films, certainly is outside of the limi ts. of what you have stated as your own objective.
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Secretary of the Commission February 8, 1982 However, if you are to take that as your responsibility to ensure that physicians know what they are reading, then I would think that you would want to ensure that they know something about cardiology. Nowhere in your rules is there any provisal for a cardiology fellowship which would be be necessary to interpret isotope examinations at the time that they are being done. This would include physiology, pharmacology and anatomy.
None of the physician groups that you have included as being acceptable for safe handling of by-product material are trained or have knowledge of the above.
Therefore, I suggest that all of your regulations be rethought and put before a nonpartisan group. Your ACHUl group certainly has its own axe to grind and certainly is trying to exclude everyone who might be a competitor.
I would note that this is a standard procedure of a business which wishes to inhibit competition.
I would note also that this is a standard way by which businesses do not grow. The history of nuclear medicine would tend to agree with this, e
it has been unnecessarily stunted and now it is fated to die a slow death because of this committee. Other techniques will take over and much of nucleas medicine as it pertains to cardiology will be lost.
I believe this is an inappropriatethingasnuclearmedicinehasmuch5ooffer for cardiology and for many other fields.
It needs skilled physiologists to interpret them and most of those people are not found in training disciplines which emphasize anatomy.
I strongly believe that the whole field needs to be opened up for strong competition and then there will be a real possibility that nuclear medicine will survive.
Thank you for your attention.
Yours truly,
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Keith R. Weeks, M.D.
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