I felt like titling this article "Multi-Society Miracle on NRC Recommendations." The Federal Register, in Volume 83, No. 209, Monday, October 29, 2018 asked for comments from stakeholders about a request they received to create a Limited-Use, Authorized-User category for physicians wanting to perform radiopharmaceutical therapy with only specific agents and requiring much reduced training and experience requirements. Such a category raises the possibility of having unqualified practitioners performing radionuclide therapy. The proposed policy could also expand to other forms radiation use and could apply to those providing physics support. Over the course of several national meetings and discussions with leaders of other professional organizations, it became clear that there was broad opposition to the proposal among our sister societies. Some of us wondered if we could make a stronger impression by voicing our opinions together?
AAPM contacted some societies that might have interest in the issue, in alphabetical order: the American Brachytherapy Society (ABS), the American College of Radiology (ACR), the American Society for Radiation Oncology (ASTRO), the Health Physics Society (HPS) and the Society for Nuclear Medicine and Molecular Imaging (SNMMI), all of which had interest in such a joint letter. While not professional societies and not intending to sign on to a joint letter, the Conference of Radiation Control Program Directors (CRCPD) and the International Atomic Energy Agency (IAEA) participated in the discussion. AAPM provided an e-mail alias for the group and started a dialogue. Comments to the NRC were due in three months, by January 29. The discussion was lively and, while it was clear that all involved shared the same goal, there were several, incompatible ideas on the pathway to get there—starting with what the letter should look like and what should be included.
Many drafts were circulated with comments shared. While there were some contentious issues that held the potential to scuttle the project, the group managed compromises and cooperation. A draft that seemed agreeable to all of the writing panel was reached on January 23, or so we thought. As a couple of societies took the draft for approval, one last, serious issue was noticed. That was worked out over the next day, and the letter went to the six societies for approval. This was only five days before the submission deadlines! One by one the notices of approval came in (along with several messages noting typographical errors to be corrected).
In AAPM, the letter was reviewed by the Government and Regulatory Affairs Committee, the Radiation Protection Subcommittee, the CRCPD Subcommittee, in addition to EXCOM. Contrary to the impression some have about the AAPM approval process, approval of the letter came through in time and the letter was submitted and received by the NRC.
AAPM thanks all the representatives of all the organizations for their commitment to the project, the creative ideas and thorough analyses provided, and the level of cooperation exhibited. It was an exhilarating experience to see this all in action.
For CRCPD (Ex Official – non-voting)
We have noticed that you have an ad blocker enabled which restricts ads served on this site.
Please disable it to continue reading AAPM Newsletter