U.S. Nuclear Regulatory Commission
Burial of Patients With Permanent Implants
Title: Burial of Patients With Permanent Implants
See the memorandum from L. B. Higginbotham to A. B. Davis
dated April 3, 1980. It references NCRP Report No. 37,
"Precautions in the Management of Patients Who Have
Received Therapeutic Amounts of Radionuclides," regarding
burial of patients with permanent implants. This NCRP
report gives levels of radioactivity below which no
precautions are needed.
A hospital requested guidance on the disposition of a
deceased patient with a permanent implant of 20 mCi of
I-125 seeds. They were advised by IE:HQ that, since there
were no regulatory requirements, the conservative approach
would be to remove the implants, if practicable. It was
also suggested that a policy might be needed on this issue
to provide guidance.
As a general rule, any licensee who requests guidance
should be told that he is obligated to adhere to all
regulatory requirements, and if no regulatory requirements
exist, he may take any action he deems appropriate.
Regional offices may inform licensees where to obtain
guidance by suggesting generally accepted documents such as
NCRP reports, ICRP committee reports, regulatory guides,
and ANSI standards.
If the licensee requests more specificity and doesn't have
certain reports and time is essential, regional personnel
may summarize applicable guidance sections (if available in
the region) for the licensee, making it clear that the
licensee is not obligated to use regional suggestions to
prevent the licensee from believing that NRC is imposing
new requirements on him.
In this particular case, the implants would not have to be
removed since permanent implants are not intended to be
removed. The guidance in NCRP Report No. 37 that deals
with management of patients with therapeutic amounts of
radionuclides establishes levels of radioactivity below
which no precautions are necessary. The deceased patient
also contained materials below precautionary concerns, and
NCRP reports are generally accepted as appropriate guidance
for use in the absence of regulatory requirements.
For patients who die, there are precautions in NCRP Report
No. 37 to be taken for physicians performing autopsies and
precautions for handling the deceased when no autopsies are
performed. There are also precautions for cremating,
including total millicurie amounts per year that can be
handled safely by a single crematorium, with some
exceptions for Ta-182 and Ir-192 that have been shown to
significantly contaminate crematoriums. There appears to
be no restrictions or precautions on burial except in
preparing the deceased for burial.
The guidance in NCRP Report No. 37 is considered to cover
this situation adequately, and it is not believed a policy
statement is needed on this issue.
Regulatory references: NCRP Report No. 37
Subject codes: 9.0, 9.4, 12.8
Applicability: Byproduct Material