ML20053C595

Responds to Transmitting RO Russell Comments on Proposed Reg Guide 10.8 Re Training & Experience Criteria for Physicians Engaging in Nuclear Medicine.Criteria Has Substantial Support from Medical Community

ML20053C595
Person / Time
Issue date:	05/05/1982
From:	Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To:	Shelby R HOUSE OF REP.
References
FRN-47FR3228, RTR-REGGD-10.008 47FR3228-229, NUDOCS 8206020362
Download: ML20053C595 (1)

Text

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The Honorable Richard Shelby M /?

United States House of Representatives k'ashington, D.C.

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Dear Congressman Shelby:

i This is in response to your letter of April 19, 1982, which transmitted a

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letter from Dr. Richard O. Russell, Jr., concerning the Nuclear Regulatory t

Comission's proposed training and experience criteria for physicians 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 coments were invited was published on January 22,1982 (47 FR 3228, copy enclosed).

A final decision on adoption of the i

. criteria has not been made yet.

i The resolved criteria evolved from proposals initiated by the medical i

community to reflect the training believed necessary for a physician to use i

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 j

practice medicine in his or her medical specialty.

i The proposed criteria are based on the recommendations of the NRC's Advisory Committee on Medical Uses of Isotopes.

The Committee is composed of recog-nized experts in nuclear medicine with specialties 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 members of the Comittee are ordinarily based on recomendations or nominations from.

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i professional medical organizations.

For example, one present member of-the' Comittee was nominated by the American College of Cardiology.

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i The proposed training criteria appear to have...substanNal support in the f

medical community.

Thus far, the criter.ia h~ ave been endorsed by the A'nerican i

Board of Nuclear Medicine, the -Anerican College of Nuclear Physicians, the Society of Nuclear Medicine, the American Osteopathic College of Radiology and the Federated ' Council of Nuclear Medicine Organizations.

I Dr. Russell's letter will be included with the coments received on the pro-posed criteria and will be considered in making a final decision on the i

criteria.

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lll StephenK. Kent 8206020362 820505 4DD' PDR REGGD Carlton Kammerer, Director g' ggAfgo 10.008 C PDR Office of Congressional Affairs yg

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Kammerer Congressional Liaison Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C.

20555

Dear Mr. Kammerer:

Enclosed is a letter I received from Dr. Richard O.

Russell, Jr., commenting on the Commission's proposal regarding nuclear medicine physicians.

I hope the Commission will give Dr. Russell's comments careful attention in any reconsideration of this proposal.

Thank you for your cooperation in this matter.

Sincerely, d

l Richard Shelby l

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Enclosure 4/27..To OCA for Direct Reply.. Suspense: May 17... docket. 82-0430 l '-

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March 8, 1982 Samuel J. Chilk, Secretary U.S. Nuclear RegulatoYy Commission Washington, D.C.

20555 e-Attention:

Docketing and Service Branch

Dear Mr. Chilk:

I am writing in regard to the publication in the Federal Register, Volume 4 7, No. 15, Friday, January 22, 1982 con-cerning the Notice of Proposed Training and Experience Cri-teria for Nuclear Medicine Physicians.

I am a practicing cardiologist who has had extensive acade ic experience in both clinical and research aspects of cardiology and while not a nuclear physician myself, am requesting nuclear card-iology testing with increasing frequency to help in the diagnosis and proposed therapy of my patients and those who--

I see in consultation.

I strongly reject the Notice of Proposed Training and Ex-perience Criteria for Nuclear Medicine Physicians, including nuclear cardiologists which would extend : heir training from 3 to 6 months.

The NRC has shown no reason why the current requirements have failed to protect either the professional or his or her patients and has presented no information as to how the new regulations, specifically the increased training period would enhance the radiation safety aspects of nuclear cardiology procedures either for consumers or providers of health care.

Cardiologists are already familiar with princi-ples of radiation exposure, having had extensive training in cardiac catheterization and angiography procedures.

I beli' eve this additional period of training would add unnecessarily to the indepth training which cardiologists bring to their practice.

It would delay individuals frcm finishing their training and proceeding into clinical or academic environ-ments.

Furthermore, the establishment of such s:andards would seem to invade the domain of the individual s:ates through their e

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CAR DIOVASCU LAR AS S OCI ATES. P. A.

Samuel J. Chilk, Secretary March 8, 1982 Page Two autonomous State boards of licensure and of the specialty boards whose purview is exactly what the NRC would usurp by these proposed changes.

I feel the role of the NRC should be to continue to assure safety in t'ne use of reactors and reactor generated isatopes.

I feel the revised training and experience criteria for nu-clear medicine will result in no benefit to the public or to health care professionals.

Sincerely yours,

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Richard O.

Russell, Jr., M.D.

RORjr/gid cc:

Senator Jeremiah Denton Congressman Tom Bevill Congressman Richard.C. Shelby -

William D. Coughlan, C.A.E.

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