United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Technical Assistance Request on Whether a Cardiologist Must be Authorized by NRC to Interpret Nuclear Medicine Patient Scans, DePaul Hospital, Cheyenne, WY

HPPOS-313 PDR-9306250172

Title: Technical Assistance Request on Whether a

Cardiologist Must be Authorized by NRC to Interpret Nuclear

Medicine Patient Scans, DePaul Hospital, Cheyenne, WY

See the memorandum from J. E. Glenn to W. E. Fisher dated

February 14, 1991. This memorandum responds to the

technical assistance request dated December 7, 1990,

wherein DePaul Hospital in Cheyenne, Wyoming requests

clarification as to whether a cardiologist must be

authorized by NRC license to interpret nuclear medicine

patient scans. The request, described in a letter dated

November 14, 1990, submitted by the licensee, has been

reviewed and the following directions are given. HPPOS-156

contains a related topic.

In the practice of medicine it is common to secure a second

opinion or interpretation of diagnostic test results in

order to arrive at a consensus for the diagnosis and

treatment of each patient. In order to facilitate this

process, we believe that the raw data contained in the

nuclear medicine scan images may be made available for

interpretation by any physician that is involved with the

care of the patient. 10 CFR Part 35 does not prevent any

physician from viewing, interpreting, or acting upon an

interpretation of a nuclear medicine scan in the process of

exercising medical judgement.

However, as described in Regulatory Guide 10.8, Rev. 2, it

is the licensee's responsibility to ensure that at least

one interpretation of nuclear medicine scans is performed

by an authorized user or a physician under the supervision

of an authorized user. The licensee must meet their

obligation to ensure that a responsible party, i.e., an

authorized user or physician under the supervision of an

authorized user, performs an interpretation of the scan and

reviews all aspects of the patient study to assure that

appropriate procedures were followed and adequate results

obtained. Failure of the licensee to meet this obligation

may result in a violation of 10 CFR 35.25 (a) for failure

to supervise, or 10 CFR 35.13 (b) for use of radioactive

material by an individual not authorized on the license.

Regulatory references: 10 CFR 35, Regulatory Guide 10.8,

License Conditions

Subject codes: 1.3, 11.5

Applicability: Byproduct Material

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