ML20126A990
| ML20126A990 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1979 |
| From: | Dircks W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Slaggie E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20126A980 | List: |
| References | |
| NUDOCS 8002290024 | |
| Download: ML20126A990 (2) | |
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wm f DEC 3 : 1 79 MEMORANDUM FORi E. Leo Slaggie Office of the General Counsel FROM: William J. Dircks, Director Office of Nuclear Material Safety and Safeguards s
SUEJECT: H.R. 5934, " CONSUMER-PATIENT FADI ATION HEALTH AND ,'
SAFETY ACT OF 1979" This c ffice has reviewed the above bill forwarced by ycur menorandum of De:erber 5,1979, and has the following comments:
- 1. Section 104(4) [page 6, line 13] " radiation" is defined, for pur;oses of the Act, to incle"^ "na tural adiation." We believe
- c: na tural radiation s F" ' -
be included, because it is not amena bl e to regul ni ~ - :~ rol .
- 2. Se:: ion 104/~' ~ - defines " radiologic technoicgist," for cur::ses of ' -
. as "an;. Derscn. othe- than a nedical or den al practitioner, wno actinisters radiation ;c censumer-patients,"
and fur;her e .umerates several Ca:scories of radiolociC *eChnolo0ists.
F-E vently in radiation the a;y, a raciation physicist acting on's trescrittion by a physician dire::iy sucervises the admir.istra; ion of ra:ia:icn to the patient by tre radiatie- techn:legist, but cces nt:
"itsel f administer it. We te.lieve it is acoropriate to insert on
- n y-6rl.ine--l 6, foll owi ng :ne wo rd "a dm i ni s ters ," the word s "or directly supervises the acministra:icn of,' to ;rovide fer :ne cualificatien of such persons.
- 3. Sec; ion 121(b;M] enumerates ca e; cries of criteria and guidelines to be promulgated by the Secre:ary (HEW). Diagnostic nuclear medicine is not included. We believe that ie-s hould be, a nd t ha t the categories in Section"12i(b) should be changed to read as follows: i
"(1 ) the application of diagnostic X-rays c censumer-catients; (2) the administration of radioactive drugs for diagnostic purposes to consumer-pa tients ;
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.', 4 E, Leo Slaggie .2-(3) the therapeutic external application of beam radiation to consumer-patients for treatment of disease; and (4 )' the therapeutic internal application of radiation to consumer-patients for treatment of disease, such as Jerapeutic nuclear medicine applications,"
4 Iction 131(a)Mrequires the Secretary to promulgate voluntary minimum standards for the accreditation of educational
' institutions conductino education programs in radiologic services.
Section 132(a) [+d requires the Secretary to promulgate voluntary minimum standards for licensure of radiologic technologists.
Sec tion 141_MrTmakes compliance with all such standards mandatory on all Federal agencies.
Inese standards are likely to substantially affect a large number ,qL <- ,
NRC licensees and r.any Federal agencies, Hence we believe itjT5sintial I to include in -t : t 11 a regt.irement tha t vy standards developed t
i pursuant to 5'ections 131 or 132 shall be promulgated only af ter prior I consulta' inn W coordinatinn with the Nuclear Deculatory Commission.
- 5. Page S, line 25, should be cnanced tc read: " orca nizations will adnere (and are continuing to adhere).' " in the interest of parillelism.
- 6. Pa ge 9, line 7, should be changed to read: " organizations are ccr.:inuing to adhere to such standarci." The word "no " should be
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!:ricken. Otherwise, the provisc as oresently written rakes no sense. l
< . , N if ll
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f "Willier
(. 4 .~%cb J. e.cks, Director l
Office of Nuclear Material Safety I anc Safeguard a,