Answer to Question #212 Submitted to "Ask the Experts"

Category: Policy, Guidelines, and Regulations

The following question was answered by an expert in the appropriate field:

Our hospital performs ¹²⁵I prostate seed implants in the operating room. Until now, we have been able to "flash" sterilize our radioactive seeds and seed applicator in the operating room, with the seeds under our direct supervision at all times. The hospital has informed us that flashing in the operating room is no longer permitted and we will need to have the seeds sterilized in the hospital's central processing department. Can you suggest the best method for assuring radioactive materials' security while this is being done? Our policy until now has been that all radioactive sources must be either locked up or under the direct supervision of an authorized Radiation Oncology staff member at all times. What are our safe and legal options for radioactive source security when sterilization is done in central processing? Thank you! (We are in an NRC state.)

The key regulation in this situation is § 20.1802 (a Nuclear Regulatory
Commission [NRC] regulation contained in Title 10, Code of Federal
Regulations, Part 20), "Control of material not in storage." "Licensees
shall control and maintain constant surveillance of licensed material
that is in a controlled or unrestricted areas and that is not in
storage." In this specific case, the licensee could institute controls
at the central processing department that would assure that the
material would be under constant surveillance. The licensee will also
need to consider whether the dose limits in § 20.1301,Dose limits for individual members of the public, or § 20.1302, Compliance with dose limits for individual members of the public,
apply to the individuals in central processing. Based on this
determination, the licensee will need to decide if monitoring (§
20.1502) or training (§ 19.12) is required. The licensee will also need
to consider some type of training for the individuals in central
processing on maintaining exposures ALARA, control/security of
material, and emergency response. Finally, the licensee should review
its license application and supporting documentation to be assured that
a license amendment is not needed prior to making this change. Note,
NRC will always have the option to inspect and determine compliance on
the basis of the regulations noted above and the licensee's
implementation of its radiation safety program.

Catherine Haney, NRC

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