Answer to Question #10542 Submitted to "Ask the Experts"
The following question was answered by an expert in the appropriate field:
Our company is considering getting PET/SPECT (positron emission tomography/single-photon emission computed tomography) equipment for animal research. We have a Nuclear Regulatory Commission (NRC) Type B broad scope license. Since I don't have any background in nuclear medicine as a radiation safety officer, do I need to take training to be qualified? For the following radioactive materials that we will be using (57Co, 68Ge, 22Na, 18F, 99Mo/99mTc, 153Gd, 111In, and 201Tl), what kind of amendment do I need to submit to the NRC?
The answer to this question is partially driven by what your current license allows. If your current license authorizes you to use similar radionuclides (e.g., negatron, positron, and/or x-ray and gamma-ray emitting radionuclides) in similar quantities, then it would seem that little additional information or training would be required. On the other hand, if your current license only authorizes a limited number and/or type of radionuclide (e.g., low-energy beta emitters such as 3H and 14C) and you as the radiation safety officer haven't had any training or experience using positron and or x/gamma-ray emitters, you may want to obtain some additional training, as those tend to present more significant external radiation issues. Likewise, the NRC will most likely want some additional information regarding the radiation safety procedures that will be used if the radionuclides currently authorized under your license are dissimilar to those listed in your question.
The actual use will be important as well. If your current license already permits animal research with radioactive materials, you will simply need to review what was originally submitted to the NRC regarding the use of radioactive materials in animals and possibly modify that, depending upon the scope of that use.
Finally, the amounts of the various radionuclides compared to your currently licensed amounts will also affect both the necessary training and what the NRC might expect in the license amendment (e.g., increasing your activity use). Higher quantities sometimes require more stringent procedures.
Probably the best advice is to simply contact the NRC, explain what you want to do, and then follow he NRC's advice. If you know someone in your NRC region who is familiar with your license, I would suggest contacting that individual. He or she should be able to guide you with respect to training and what is necessary to amend your license for what you wish to do. You could also solicit the advice and assistance from a consulting health physicist who might be able to provide you training and assistance in preparing the NRC license amendment.
Mack L. Richard, MS, CHP