ML23254A377

Presentation for Public Meeting on 9-12-2023 - Termination of Us NRC Recognition of the American Board of Radiologys Certification Processes

ML23254A377
Person / Time
Issue date:	09/12/2023
From:	Maryann Ayoade NRC/NMSS/DMSST/MSEB
To:
References
Download: ML23254A377 (23)

Text

Termination of U.S. NRC Recognition of the ABRs Certification Processes Presentation by:

Maryann Ayoade - Medical Radiation Safety Team Member Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission September 12, 2023

• Background

- How to Become an Authorized Individual

- ABR Recognition Timeline

- ABR Discontinues NRC Recognition (When?

What? Why?)

• What This Means For Individuals and Authorizations

• Where to Find Information

• How to Become an Authorized Individual -

Alternate T&E Pathway

• Current Status and Next Steps 2

AGENDA Presentation Outline

How to Become an Authorized Individual

• Individuals must complete T&E criteria in 10 CFR Part 35:

- To be authorized for the medical use of byproduct material;

- To independently fulfill the radiation safety-related duties of an authorized individual; and

- To be listed on a license as an Authorized Individual (e.g., AU, RSO/ARSO, AMP).

3 BACKGROUND

Three main pathways:

1.

Board certification pathway

• Is the individual certified by an NRC-recognized medical specialty board?

• Has the necessary additional T&E been completed?

2.

Alternate T&E pathway

• Has all required T&E (classroom & lab; supervised work experience, including case work; and device-specific training) been successfully completed?

• Was a written attestation submitted?

3.

Authorized Individual listed on a license

• Is the individual already listed on an NRC or Agreement State license for equivalent types of use?

• Has the necessary additional T&E been completed?

4 How to Become an Authorized Individual BACKGROUND

5 How to Become an Authorized Individual BACKGROUND Board Certification Pathway Alternate T&E Pathway Complete all required T&E.

Essentially same requirements depending on the type of use.

For certain types of use, T&E must be acquired via a residency training program.

Complete all required T&E.

Essentially same requirements depending on the type of use.

Pass examination administered by specialty board that assesses knowledge and competency in areas that include radiation safety.

Obtain preceptor attestation of satisfactory completion of required T&E, and ability to independently fulfill the radiation safety-related duties for each type of use or device.*

• Note that preceptor attestations are not required for most individuals certified by recognized specialty boards. The attestation in 10 CFR 35.396(b)(3) is required for both board-certified individuals and individuals using the alternate T&E pathway 10 CFR 35.396(b)(1) and (b)(2).

ABR Recognition 6

2005 ABR becomes an NRC-recognized specialty board In March 2005 (70 FR 16335), NRC published a final rule, providing, among other things-updated criteria that specialty boards must meet to be recognized by the NRC or the Agreement States.

March/April 2022 ABR notified NRC and submitted letter of intent to discontinue maintaining NRC recognition of certification processes (ML22091A272)

December 31, 2023 ABR will discontinue including AU/AMP/RSO-Eligible designations on issued certificates BACKGROUND

ABR Discontinues NRC Recognition - WHEN?

7 2005 ABR becomes an NRC-recognized specialty board

- In March 2005 (70 FR 16335), NRC published a final rule, providing, among other things-updated criteria that specialty boards must meet to be recognized by the NRC or the Agreement States.

March/April 2022 ABR notified NRC and submitted letter of intent to discontinue maintaining NRC recognition of certification processes (ML22091A272)

December 31, 2023 ABR will discontinue including AU/AMP/RSO-Eligible designations on issued certificates BACKGROUND

ABR Discontinues NRC Recognition - WHAT?

8 BACKGROUND

• All NRC-recognized ABR specialty areas are impacted NRC-Recognized Specialty Boards Webpage: https://www.nrc.gov/materials/miau/med-use-toolkit/spec-board-cert.html Specialty Areas NRC Regulations Authorization Diagnostic Radiology 10 CFR 35.290 10 CFR 35.392, 35.394 Authorized Users Interventional Radiology /

Diagnostic Radiology 10 CFR 35.290 10 CFR 35.394 Authorized Users Radiation Oncology 10 CFR 35.390, 35.392, 35.394 10 CFR 35.490 10 CFR 35.690 Authorized Users Diagnostic Medical Physics 10 CFR 35.50 RSOs and Associate RSOs Nuclear Medical Physics 10 CFR 35.50 RSOs and Associate RSOs Therapeutic Medical Physics 10 CFR 35.51 Authorized Medical Physicists

ABR Discontinues NRC Recognition - WHY?

9 BACKGROUND

• Outside the focus of ABR mission.

• Diverts resources from fundamental objectives (exams &

customer service).

• No specific correlation between being board certified &

having the AU/AMP/RSO-Eligible status.

• A direct pathway exists with NRC and Agreement States.

• ABR information webinar, direct link, and FAQs:

https://www.theabr.org/blogs/authorized-user-eligibility-webinar-recording-and-faqs-available https://www.youtube.com/watch?v=hkRc9JzP2oA https://www.theabr.org/diagnostic-radiology/initial-certification/nrc-compliance#faqs

Prior to December 31, 2023 ABR complies with applicable NRC regulations and maintains existing NRC recognition.

ABR may issue NRC-recognized certificates with AU/AMP/RSO-Eligible designations.

NRC-recognized certificates (issued prior to December 31st) remain valid for use via the NRC Board Certification Pathway.

7-yr. Recentness of Training requirement (10 CFR 35.59) applies.

Individuals may obtain certification from a different NRC-recognized specialty board.

Alternate T&E pathway remains an option.

Submit documentation of all required T&E and written preceptor attestation directly to NRC or Agreement States via the licensing process.

10 WHAT THIS MEANS

After December 31, 2023 ABR will not maintain NRC-recognition and certification processes will not be recognized by the NRC.

ABR will not issue NRC-recognized certificates with AU/AMP/RSO - designations.

NRC-recognized certificates (issued prior to December 31st) remain valid for use via the NRC Board Certification Pathway.

7-yr. Recentness of Training requirement (10 CFR 35.59) applies.

Individuals may obtain certification from a different NRC-recognized specialty board.

Alternate T&E pathway remains an option.

Submit documentation of all required T&E and written preceptor attestation directly to NRC or Agreement States via the licensing process.

11 WHAT THIS MEANS

Where to Find Information Other useful links on the NRCs Medical Uses Licensee Toolkit web page:

• The NRC's ACMUI Subcommittee Reports

• Subcommittee on Training and Experience for All Modalities, Final Report

• FAQs About Licensing Medical Uses of Byproduct Material Under 10 CFR Part 35

• NRC Medical List Server NRCs Medical Uses Licensee Toolkit:

• Public Meeting Announcement and ABR 2022 Decision Letter

• Specialty Board Certifications Recognized by NRC Under 10 CFR Part 35

• How to Become Authorized

• Procedures for Recognizing, Monitoring, and Terminating the Certification Process of Specialty Boards

• 2022 Evaluation of NRC Recognized Specialty Boards

How to become an Authorized Individual - Alternate T&E Pathway

• Licensee submits request to NRC or Agreement State program.

• All applicable T&E documentation should be included.

• May use NRC 313A series forms

- Detailed instructions in NRC guidance - NUREG-1556, Vol. 9, Rev. 3 (Section 8.7 and Appendix C, D, and E).

NOTE: NRC does not issue licenses to individuals, but rather to licensees. NRC authorizes individuals to be listed on a license.

13

Sample NRC Form 313A (AUS)

Page 1 of 6 10 CFR 35.490 - Training for use of manual brachytherapy sources 10 CFR 35.491 - Training for ophthalmic use of strontium-90 10 CFR 35.690 - Training for use of remote afterloader units, teletherapy units, and gamma stereotactic radiosurgery units 14

Sample NRC Form 313A (AUS)

Page 2 of 6 15

Sample NRC Form 313A (AUS)

Page 3 of 6 16

Sample NRC Form 313A (AUS)

Page 4 of 6 17

Sample NRC Form 313A (AUS)

Page 5 of 6 18

Sample NRC Form 313A (AUS)

Page 6 of 6 19

Prior to December 31, 2023 After December 31, 2023 ABR complies with applicable NRC regulations and maintains existing NRC recognition.

ABR will not maintain NRC-recognition and certification processes will not be recognized by the NRC.

ABR may issue NRC-recognized certificates with AU/AMP/RSO-Eligible designations.

ABR will not issue NRC-recognized certificates with AU/AMP/RSO -

designations..

NRC-recognized certificates (issued prior to December 31st) remain valid for use via the NRC Board Certification Pathway.

7-yr. Recentness of Training requirement (10 CFR 35.59) applies.

May obtain certification from a different NRC-recognized specialty board.

Alternate T&E pathway remains an option.

20 Remember!

Current Status / Next Steps

• Discontinuation of ABRs recognition with NRC is to occur on December 31, 2023.

• Licensees and Current/Potential Authorized Individuals:

Keep track of T&E documentation.

Complete NRC 313A series forms early.

Get familiar with NRC Part 35 T&E requirements.

Reach out to your friendly regulators.

• NRC will staff will:

Conduct a public meeting to share information.

Inform/notify stakeholders when discontinuation is finalized via the NRC Medical List Server.

Abbreviations

• ABR - American Board of Radiology

• ACMUI - The Advisory Committee on the Medical Uses of Isotopes

• AU - Authorized User

• AMP - Authorized Medical Physicist

• ARSO - Associate Radiation Safety Officer

• CFR - Code of Federal Regulations

• RSO - Radiation Safety Officer

• T&E - Training and Experience 22

Questions?

• Contact Us:

medicalquestions.resource@nrc.gov

• Medical Uses Licensee Toolkit 23