The American College of Radiology (ACR) submitted comments to the U.S. Nuclear Regulatory Commission (NRC) June 26 regarding patient release requirements in 10 CFR 35.75. The NRC requested public input on a series of questions to help the agency explore whether to revise the regulations.
The ACR expressed general support for the risk-informed, performance-based patient release criteria in 10 CFR 35.75. When combined with related guidance, guidelines and standards from the medical community, the ACR believes it appropriately protects public health and safety without infringing on the practice of patient-centered medicine. The College warned the agency that reverting to an activity-based regulation would require mandatory hospitalization of otherwise healthy and capable patients and would expose them to unnecessary risks and other negative consequences without adding substantive safety benefits.
We likewise expressed support for recommendations and risk analyses on this topic by the NRC’s Advisory Committee on the Medical Uses of Isotopes (ACMUI), a federal advisory panel of independent experts representing the agency’s medical stakeholder communities. The ACMUI has regularly advised NRC to not pursue further rulemaking on this topic.