U.S. Nuclear Regulatory Commission
Applicability of 10 CFR 20.303 (d) to Disposable Diapers Contaminated with T c-99m.
Title: Applicability of 10 CFR 20.303 (d) to Disposable
Diapers Contaminated with Tc-99m.
See the memorandum from J. R. Mapes to J. R. Metzger dated
January 6, 1979, the memorandum from J. R. Metzer to A. B.
Davis dated January 18, 1979, and the incoming request of
A. B. Davis dated December 13, 1978. It is an OELD opinion
that the exemption in 10 CFR Part 20.303 (d) for excreta
applies only to excreta discharged to a sanitary sewer and
does not apply to excreta remaining on disposable diapers
placed in trash cans or disposed of otherwise. The health
physics position was written in the context of 10 CFR
20.301 and 20.303, but it also applies to the "new" 10 CFR
Part 20, Sections 20.2001 and 20.2003.
During a Region III inspection of a children's hospital, an
inspector found an infant's disposable diaper contaminated
with Tc-99m in a trash can that was not labeled to indicate
the presence of radioactive material and that in fact was a
normal cold trash can. The hospital had given diagnostic
doses of Tc-99m to infants. Diapers soiled with feces were
rinsed in the toilet and then placed in the cold trash
(i.e., non-radioactive trash).
In response to citations for failure to survey diapers
prior to disposal, and disposal of radioactive material by
a means not authorized by 10 CFR 20.301 [or 10 CFR
20.2001], the licensee stated they called several
children's hospitals across the country and determined that
they all use the same method of diaper handling. They also
point out that 10 CFR 20.303 (d) [or 10 CFR 20.2003 (b)]
states that "excreta from individuals undergoing medical
diagnosis or therapy with radioactive material shall be
exempt from any limitations contained in this section," and
that this should exempt their diapers.
Region I was contacted and they stated that they have never
looked into diaper disposal at medical institutions.
Several HPs in both Regions I and III who have worked at
medical institutions have stated that persons receiving
diagnostic doses of radioactive material are not considered
radioactive and are not segregated from other patients and
no special handling is given to their bed clothes, bed
pans, or excreta. Special handling is reserved for
patients under therapy.
Diapers from both children and excreta from incontinent
adults undergoing nuclear diagnosis would be considered not
radioactive. On the other hand, 10 CFR 20.303 [or 10 CFR
20.2003] addresses disposal by release into the sanitary
sewer. The exception in 10 CFR 20.303 (d) [or 10 CFR
20.2003 (b)] applies to excreta that enters the sewer where
it is held and diluted before release to an unrestricted
area. The citation was not for the feces washed into the
sewer but for material remaining on the diapers in normal
cold trash that was disposed of by normal trash methods.
There appears to be no exemption for material excreted and
not disposed via the sanitary sewer.
The OELD opinion agrees with the Region III opinion (i.e.,
diapers are not exempt from the requirements of 10 CFR
20.303 [or 10 CFR 20.2003] because they contain excreta
residue, and therefore, must be labeled as contaminated
waste). The exemption only applies to material actually
released to the sanitary sewer. Hospitals ordinarily hold
contaminated waste for about seven half lives or until
there is no detectable contamination and then dispose of
the material via normal trash channels. This would be
particularly simple for Tc-99m with a half life of 6 hr.
Of course, waste destined for normal trash disposal must be
placed in a suitable holding area as contaminated waste
until the radioactivity has decayed to nondetectable levels.
Regulatory references: 10 CFR 20.303, 10 CFR 20.2003
Subject codes: 9.0, 9.3, 9.7
Applicability: Byproduct material