United States Nuclear Regulatory Commission - Protecting People and the Environment

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

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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