[Intl_DxMedPhys] NRC rule changes

Thu Jul 30 11:30:38 EDT 2026

I support many of the changes, but a few issues I noticed at first glance:

  *   The patient or caregiver consent requirement for patient release is going to be very problematic, at least as currently written it appears to require patient consent for release for any radiopharmaceutical exam. This will be a massive increase in recordkeeping and brings up of potential issues such as are we required to then hospitalize any patient who refuses consent.

  *   The 7-year recentness of training requirement is being replaced with continuing education and experience, again requiring a massive increase in recordkeeping requirements, as well as a lack of clarity because acceptable education and experience is not defined in the regulation or guidance.

  *   Changing the permissible exposure to the caregiver and public from per treatment to per regimen is a huge change.  It will require longitudinal recordkeeping which is not currently required.  It is also problematic because a regimen in clinical practice is not always as clearly defined as indicated in the rule.  In addition, although the permissible dose to the caregiver from a released patient is increased, it is not changed for members of the public.  With the change to per regimen, the limit is thus greatly decreased for members of the public such as non-caregiver household members.

Mary Ellen Jafari, MS, DABR (D,N), MRSE, MRSO, FACR, FAAPM, CIIP
Chief Physicist and Regional Radiation Safety Officer

Kaiser Permanente Southern California
Southern California Permanente Medical Group
Medical Imaging Technology and Informatics
199 S. Los Robles Ave.,Ste. 600B, Pasadena CA 91101
626-430-1231 (office mobile)
Maryellen.Jafari at kp.org<mailto:Maryellen.Jafari at kp.org>

From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+maryellen.jafari=kp.org at lists.osu.edu> On Behalf Of Steiner, Joseph [BSD] via Intl_dxmedphys_wd_osu_list
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To: Adam Springer <adam at klsphysics.com>; kenharper14 via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu>; Lemieux, Bryan P. <bryan.lemieux at uky.edu>
Subject: Re: [Intl_DxMedPhys] NRC rule changes

Adam is right, the summary is very positive (is there a catch??). Some things that caught my eye: 3. Eliminating the requirement for license amendments to add authorized users for diagnostic uses, allowing licensees to approve and document these

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Adam is right, the summary is very positive (is there a catch??). Some things that caught my eye:

3. Eliminating the requirement for license amendments to add authorized users for diagnostic uses, allowing licensees to approve and document these users internally due to the lower risk of these non-therapeutic uses.

9. Removing the written directive requirement for diagnostic administrations of sodium iodide I-131, aligning regulatory oversight with current clinical practice and other diagnostic administrations with comparable risk.

12. Expanding decay-in-storage eligibility by increasing the allowable half-life from 120 to 275 days, enabling safe, cost-effective onsite disposal of longer-lived materials like lutetium-177 metastable (Lu-177m) and cobalt-57 (Co-57).

Joe

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To: Adam Springer <adam at klsphysics.com<mailto:adam at klsphysics.com>>; kenharper14 via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Subject: [EXTERNAL] Re: [Intl_DxMedPhys] NRC rule changes

For those who have not been following all this, one is a revision to Part 20 and one is a revision to Part 35. There is also a revision in a separate rule making about licensing to permit General Licenses for simple diagnostic nuclear med. There
For those who have not been following all this, one is a revision to Part 20 and one is a revision to Part 35. There is also a revision in a separate rule making about licensing to permit General Licenses for simple diagnostic nuclear med. There

For those who have not been following all this, one is a revision to Part 20 and one is a revision to Part 35.  There is also a revision in a separate rule making about licensing to permit General Licenses for simple diagnostic nuclear med.  There are also 3 new regulatory guides, and some older ones referenced…… around 450 pages of new stuff and coming.

Some highlights for you all…

  *   As Adam mentioned – traditional ALARA is dead – long live… Alara V 2.0?  Now with built in cost benefit analysis and $$$ / Person-Rem avoided justification guidance once you hit some of those stepwise trigger levels….
  *   Updated dose guidance to allow alternate schema than ICRP 26/30 for occupational dose and NRC compliance without having to ask for special permission – lots of new stuff will be pre-approved for general use – and doses may be used interchangeably – which will cause great angst for some people.
  *   Public dose remains at 100 mrem/yr; proposed to drop 2 mrem in an hour restriction on uncontrolled areas.
     *   Dose constraints apply here – cost benefit proposed if going over 25 mrem / yr according to narrative.
     *   See also new regulatory guide proposed for control of dose at medical institutions.
  *   Occupational dose limits remain “mostly” the same – we get a new special limit if we want to use it for Planned Occupational Dose Limit Extension  which allows occupational workers to exceed the annual limit but ties back to a “budget” of accrued dose/risk allowance over rolling 5 year preceding period.
  *   Patient release limits change
     *   Now per treatment Course; still 500 mrem to general public
     *   New Caregiver limit (if consenting) 5000 mrem – separate from any dose below.
     *   As written any patient release requires consent of the patient regardless of dose to others.
  *   In-patient care limits change.
     *   Instead of needing a license amendment, caregivers can get 2 rem during a hospital admission built into the regs….
     *   Added rules for safety instructions on care of some other classes of patients.
  *   AU training is revised.
  *   New record keeping requirements proposed to replace the 7 year Recentness of Training provisions.
  *   Lots of cleanup on requirements for medical uses, bringing Y-90 into Part 35, updating gamma knife rules etc….; close loophole on computer based treatment planning and acceptance testing.

This will of course all trickle out to the agreement states, most is pretty high compatibility class – and once it hits the AS especially it will probably affect all of your x-ray and other machine produced sources as well since most states have unified rules.  Keep all that in mind while reviewing these and how it will affect your practices and programs generally when looking to comment.

Regards,

Bryan Lemieux, MS CHP DABMP

Associate Chief - Radiation Safety

Radiation Safety Officer

UK HealthCare

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Sent: Thursday, 30 July 2026 07:21:19
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Subject: [Intl_DxMedPhys] NRC rule changes

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Forgive me if someone has posted on this already. The executive order for the NRC is resulting in regulatory changes for medical use of RAM. See the proposed rules and a way to give feedback at the link below. The summary makes them sound good. 

Forgive me if someone has posted on this already.

The executive order for the NRC is resulting in regulatory changes for medical use of RAM.  See the proposed rules and a way to give feedback at the link below. The summary makes them sound good.

https://urldefense.com/v3/__https://www.regulations.gov/document/NRC-2025-1237-0001__;!!KGKeukY!yySj_9m9BzrnztX4XMciWHAjNlY0b6divytR0IjEwSAwscnMV9ttHYfLSY_QQ1ecOpiXUVqFD3EEH5rSvR1E6C0YqyezepbGRQCNHlzl3oX19CU$ <https://urldefense.com/v3/__https:/www.regulations.gov/document/NRC-2025-1237-0001__;!!KGKeukY!wYrr9HpiPIDFbIQL6GdB0Y95nj01gFH4PzbfcLU8SbJ5_d4UvYc837ORULrHxriRDym71iUb4_OyLYLLaSy8lvUh4xYqswqYxc1aUA$>

Another version is below with details about replacing ALARA with “determinate” levels. It’s very long so I haven’t compared the two yet.

https://urldefense.com/v3/__https://www.govinfo.gov/content/pkg/FR-2026-07-15/pdf/2026-14208.pdf?utm_campaign=subscription*mailing*list&utm_medium=email&utm_source=federalregister.gov__;Kys!!KGKeukY!yySj_9m9BzrnztX4XMciWHAjNlY0b6divytR0IjEwSAwscnMV9ttHYfLSY_QQ1ecOpiXUVqFD3EEH5rSvR1E6C0YqyezepbGRQCNHlzllQF5EnI$ <https://urldefense.com/v3/__https:/www.govinfo.gov/content/pkg/FR-2026-07-15/pdf/2026-14208.pdf?utm_campaign=subscription*mailing*list&utm_medium=email&utm_source=federalregister.gov__;Kys!!KGKeukY!wYrr9HpiPIDFbIQL6GdB0Y95nj01gFH4PzbfcLU8SbJ5_d4UvYc837ORULrHxriRDym71iUb4_OyLYLLaSy8lvUh4xYqswo21poyxA$>

I assumed it would be awhile before agreement states followed suit, but one of my local regulators informed me that the states have been asked to expedite adoption of the NRC’s updates.

-Adam

================================
Adam C. Springer, MS, DABR®<https://urldefense.com/v3/__https:/myabr.theabr.org/*/certificate-public-reporting/P5911__;Iw!!KGKeukY!wYrr9HpiPIDFbIQL6GdB0Y95nj01gFH4PzbfcLU8SbJ5_d4UvYc837ORULrHxriRDym71iUb4_OyLYLLaSy8lvUh4xYqswoPuc4bHA$>, DABSNM<https://urldefense.com/v3/__https:/www.absnm.org/certification-verification.html*/certificate-public-reporting/ABSNM-2026-09__;Iw!!KGKeukY!wYrr9HpiPIDFbIQL6GdB0Y95nj01gFH4PzbfcLU8SbJ5_d4UvYc837ORULrHxriRDym71iUb4_OyLYLLaSy8lvUh4xYqswp3Ozs_xg$>, MRSE<https://urldefense.com/v3/__https:/ibmrs.org/abmrs-credential-search-global/__;!!KGKeukY!wYrr9HpiPIDFbIQL6GdB0Y95nj01gFH4PzbfcLU8SbJ5_d4UvYc837ORULrHxriRDym71iUb4_OyLYLLaSy8lvUh4xYqswraWDXtkg$> (MRSC™)
Medical Physicist & CEO

KLS Physics Group, LLC
PO Box 700
Ruston, LA 71273
Office: 318-255-5033
Mobile: 318-272-8292

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