The problem is not only the ABNM/SNM
(who did nothing to stop radiology from stepping in our toes) but the Nuclear Regulatory Commission (NRC)
, who allowed radiologist with 4 months of nuclear medicine training to perform all nuclear medicine diagnostic studies and treatments since 2004 (as explained below). The ABNM and SNM board of directors from 2004 to the present ARE responsable for not fighting back!
http://theabr.org/ic/ic_dr/ic_dr_nuc_train.html
Nuclear Training
Please watch for an update of this statement.
Date: March 12, 2004
RE: Nuclear Medicine Training
Several years ago the Nuclear Regulatory Commission (NRC) proposed changes in the rules that govern training and experience required to use the types of radioactive materials commonly employed in clinical nuclear medicine. Controversies surrounding the proposed regulations delayed implementation, but the publication of a revised final version now seems near. In the past the NRC has accepted board certification by the ABR as evidence that a practitioner is properly trained to safely and effectively use radioactive materials in Nuclear Medicine. The ABR wishes to retain this status for diplomates when the new regulations are finalized and, accordingly, is preparing to match the length of training and the materials on which it examines to the final NRC regulations.
We know that radiology residents, nuclear medicine chiefs and radiology chairs are anxious for the ABR to clarify its new requirements and indicate when they will take effect. The latest NRC public comment period ended February 24, 2004, and a delay of several months is anticipated before the final regulations are published in the Federal Register. Accordingly, the dates and content listed below are SUBJECT TO CHANGE based on the final decisions of the NRC. The ABR also will attempt to remain consistent with the requirements of the Radiology RRC, which are being revised at this time.
The length of the clinical nuclear medicine experience required for compliance with NRC regulations appears likely to decrease from the current 1100 hours (six months) to 700 hours (four months). ABR will amend its training and experience requirements accordingly. If the final rule is published on or before the NRC's own chosen "final" implementation date of October 24, 2004, the ABR will admit for the oral examination of June 2005 candidates with 700 or more hours of training and experience in nuclear medicine. The ABR will require that four months be spent on clinical nuclear medicine. Classroom education in nuclear medicine is to be in addition to the four months of clinical nuclear medicine experience.
LEAVE OF ABSENCE
Leaves of absence and vacation may be granted to residents at the discretion of the program director in accordance with local rules. Within the required period(s) of graduate medical education, the total such leave and vacation time may not exceed SIX CALENDAR WEEKS (30 working days) for residents in a program for one year, TWELVE CALENDAR WEEKS (60 working days) for residents in a program for two years, EIGHTEEN CALENDAR WEEKS (90 working days) for residents in a program for three years, or TWENTY FOUR CALENDAR WEEKS (120 working days) for residents in a program for four years. If a longer leave of absence is granted, the required period of graduate medical education must be extended accordingly.
This total training and experience must include all NRC-required items related to the safe handling, administration and quality control of the radionuclide doses used in clinical nuclear medicine. The Federal Register provides a comprehensive list of these items, which will not be repeated here. ABR testing will cover selections from subjects such as safe elution and quality control (QC) of radionuclide generator systems, calibration and QC of survey meters and dose calibrators, safe handling and administration of therapeutic doses of unsealed radionuclide sources (e.g., I-131), responses to radiation spills and accidents, radiation signage and related materials. Such items will be tested in both the written and oral exams.
In order to comply with the sections of the NRC regulations and expected new RRC guidelines related to I-131 therapy with unsealed sources, residents will have to participate with a preceptor in three therapies in each of two NRC categories for I-131 therapy--3 low dose ( < 33 mCi) and 3 high dose ( > 33 mCi). The specific dates on which these experiences occur should be kept in a log book by each resident in a format similar to the following:
Resident Name _______________ Program ________________
Date Disorder Dose
Administered Preceptor
Initials
1. 2-1-05 Plummer Disease ____ mCi 131I ______
2. _______ ______________ _____________ ______
3. _______ ______________ _____________ ______
4. _______ ______________ _____________ ______
5. _______ ______________ _____________ ______
Because of HIPAA concerns, no data that might identify a patient are to be included in the log book. This log is to be submitted by the program director along with the other materials that attest to the residents oral exam eligibility.
Our colleagues in Radiation Oncology are dealing with similar concerns about the therapy-related sections of the new NRC regulations. The ABR will be writing to Radiation Oncology training program directors in a separate memo to encourage new training content and to indicate ABRs intention to include new NRC-related materials in future examinations.
To license an individual as an authorized user of radionuclides the NRC will require that another authorized user/preceptor typically this would be the Nuclear Medicine Chief attest to the successful completion of the training in Nuclear Medicine. The attestation of the Residency Program Director will not be accepted by the NRC unless the Program Director also is an authorized user. For admittance to the ABR exam, however, Residency Program Director attestation will suffice.
The ABR recommends that all residency programs re-evaluate their training in nuclear medicine and add the content elements outlined in this communication. In this way, all residents will be prepared and qualified to sit for the nuclear medicine portion of the ABR oral exam as early as June, 2005, and also will be better able to provide nuclear medicine services safely and effectively. Nuclear Medicine training should not be shortened, however, until the NRC has made its final ruling. To do so prematurely runs the risk of disenfranchising entire candidate classes of the ABR.