U.S. Nuclear Regulatory Commission

Burial of Patients With Permanent Implants

HPPOS-030 PDR-9111210152

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