ML20203N669

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Forwards NMSS 861118 Review of Authorized User Provisions of License Conditions for Veterans Admin Hosps.Apparent Conflict W/Interpretive Guide of 791001 Discussed.Further Clarification of Provision Necessary
ML20203N669
Person / Time
Issue date: 12/23/1981
From: Higginbotham L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Gibson A, Greger L, Joyner J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20203N671 List:
References
REF-SSINS, REF-SSINS-SSINS 6920, NUDOCS 8610170052
Download: ML20203N669 (2)


Text

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SSINS; 6920 TERA DEC 2 31981 MEMORANDUM FOR:

J. H. Joyner, Chief, TI Branch, Region I A. F. Gibson, Chief, TI Branch, Region II L. R. Greger, Chief, TI Branch, Region III G. D. Brown, Chief, TI Branch, Region IV H.-E. Book, Chief, RS Branch, Region V FROM:

Le'o B. Higginbotham, Chief, Radiological Safety Branch, IE

SUBJECT:

AUTHORIZED USERS' SUPERVISION OF MEDICAL PROGRAMS Enclosed is a copy of a recent. response by NMSS to our earlier request for a review of the " authorized user" provisions of license conditions of VA hospitals and an apparent conflict therein with our related Interpretive Guide of October 1, 1979.

A question on that matter had been raised by Region IV.

In our sub-sequent discussions with NMSS, they agreed to try to clarify their overall philosophy on " authorized users." As indicated in their letter, however, they are currently reexamining their position on the VA Hospital license condition, which clearly has been an exception to their general philosophy. We shall keep you informed of their final conclusions on that matter.

In their " general discussion," NMSS does shed some further light on how they apply the terms " licensed material shall be used by

" and " licensed material shall be used by, or under the supervision of It is fairly clear that in the latter case, they make a distinction that the person being supervised must be a physician, whereas in the former case, he is not.

We feel that the discussion by NMSS is generally helpful, but certainly does not solve our overall problems in distinguishing between compliance and non-compliance situations on matters relating to authorized users and their supervision in medical programs.

We have considered issuing a revision of our Interpretive Guide, but have decided to hold off until after the completion of the current work by the NMSS Task Force on the Part 35 revision, which, as indicated by NMSS, will address and clarify the authorized user license conditions.

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2 In the interim, if you have any comments on this matter, particularly the NMSS letter, please send them to us.

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Leo B. Higgin ham, Chief Radiological Safety Branch, IE

Enclosure:

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FCMSS Staff CONTACT:

A. W. Grella 49-28119 I

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