ML20141E904
| ML20141E904 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| NUDOCS 9707010203 | |
| Download: ML20141E904 (13) | |
Text
.
PDP MEDICAL REGULATORY REVISIONS PART 35 0
W O
c, e
m CD tm Pt*,
h, tift Division ofIndustrial and Medical h
Nuclear Safety 5s U.S. Nuclear Regulatory Commission lg Washington, D.C. 20555
- l D vv:*
u_4_., pr3r hvA cJ uu -..
@g
/
-o R
RE q H 2 3' OKb
j.
l l
l i
PROCESS i
Public Participation in Process NRC / State Working Group Proposeo Rulemaking Final Rulemaking i
2 i
l l
COMMISSION DIRECTION Continue ongoing program with l
l Improvements i
Capture not only Relevant Safety -
l Significan;: Events, aut also Precursor Events Consult with ACMCI and Medical Communify E se ofProfessional Standards and Guidance
.___.._......,.._........,.._.._._.....s s_.
l COMMISSION DIRECTION (Continued)
E tilize Risk-Informed Performance-Based Approach Higher Risk Activities Should be Primary Focus of Efforts and Resources Decrease Oversight of Low-Risk Activities with Continued Emphasis of High-Risk Activities
e SRM ITEMS Focus Part 35 on Procedures that Pose Highest Risk Oversight Alternatives for Diagnostic Procedures Consistent with Risk Capturing of Relevant Safety Issues and Precursors Change " Misadministration" to " Medical Event"
l SRM ITEMS l
(Continued)
I
\\
l Redesign Part 35 to Allow for Timely Incorporation of New Modalities Revise to Focus on Patient Safety 1
E se of Available Industry Guidance and i
Standards i
ACMLI VIEWS AXD RECOMMENDATIONS 4
Concurred with Commissions' Position to:
i j
- Continue the Ongoing Medical Program, with-l Improvements l
- Decrease Oversig at of Lew Risk Activities; and
- Continue Emphasis in High Risk Areas Supported use of Professiona:L Medical l
j Organizations and Societies l
i j.
i ACMCI VIEWS AXD
\\
~
i RECOMMEXDATIONS (Continued) j Recommended " Quality Improvement
)
Approach" vs " Quality Management l
Approach" Believed that the NRC Should not Intrude l
~
Into Medical Judgments i
)
i m..
m
- m. ---
s.
, w ~
wT-e - 51N
-'*-TN4 v w-+ v s
~'NM'*
iw
l-
~
ACMUI MEDICAL POLICY l
STATEMENT #2 PROPOSAL l
i l
- Tae NRC will regulate the rac iation sa:Pety of patients only where justified by the risk to the patients, and only where voluntary standarc s or comphance with these l
standards are i'nadequate.
i Assessment of the risks justifying such regulations
]
will reference comparable risks and comparable modes of regulation for other types of medical practice.
i i
I
e l
l ACMEI MEDICAL POLICY l
l STATEMENT #3 PROPOSAL The NRC will { minimize intrusion} not intrude l
into medicaljudgments affecting patients and mto other areas traditionally considered to be a l
part of the practice of medicine.
I l
1
.______.__.____..___..____________.___________________.___.,-~-v-..--4v,-~,._,,---
ISSUES i
l QM Requirements Misadministration vs Medical Event i
Training and Experience l
l Capturing Emerging Technologies Accreditation Process I
4 i
I
.,-,.-.c.-%,
m v-
,c,--..-.,-.,,~o,.,.
,,.,.., mp.,
.c.,.
,,.w.%
,wy..
,..,,,,v._,.y.,
w,,,.
,.,%,.y e-
--2.w
[
ISSUES 4
l Medical Judgment Sophistication of Practice i
i
" Bad Apple" Factor Authorized User i
I l
I
i i
l MODALITY APPROACH i
j i
i Who Licensed?
i i
Technical Issues: (e.g., surveys, access contro_s)
\\
l Training and Experience l
Licensee Event Reports: CMisadministrations, etc.)
i l
- Quality Management I
Records Organization / Internal QA L -
.----