IC DR NRC FAQ
NRC Frequently Asked Questions
If a radiologist is not an Authorized User (AU) on an NRC license at an institution, what duties may he or she perform in the nuclear medicine laboratory of that facility?
The NRC recognizes that it is frequently necessary for an Authorized User (AU) to delegate to other individuals the specific tasks associated with preparing and administering byproduct material (radiopharmaceuticals) for medical uses in patients (10 CFR 35.27). These individuals include technologists, and other physicians who may not be AUs. If the policies and procedures of the institution holding an NRC radioactive materials license allow, the NRC regulations (10 CFR 35, subparts D* & E**) permit delegation of these duties, if the individuals performing the duties are properly instructed and supervised. The supervising AU does not need to be physically present for delegated use of byproduct material under subparts D & E. Further, there is no NRC requirement that diagnostic studies performed using byproduct material have to be interpreted by an AU. Thus, the NRC regulations do not restrict who can read and interpret diagnostic scans or the results of therapeutic procedures (i.e., radiologists who are not AUs may interpret such studies). However, it is strongly recommended that those radiologists practicing in NRC Agreement States consult the appropriate state regulatory agency to ensure that the state regulations allow for this delegation.
According to NRC regulations, only an AU can sign a written directive, including those necessary for therapeutic procedures involving unsealed byproduct material (e.g., treatment of hyperthyroidism, ablation of residual function thyroid tissue, or treatment of functioning thyroid metastases using 131I). However, administration of the therapeutic unsealed byproduct dose specified in the written directive may be delegated, if the individuals performing the administration are properly instructed in the written directive procedures and supervised accordingly.
*Subpart D- Unsealed Byproduct Material - Written Directive Not Required
- 35.100 - Use of unsealed byproduct material for uptake, dilution and excretion studies for which a written directive is not required
- 35.200 - Use of unsealed byproduct material for imaging and localization studies for which a written directive is not required
**Subpart E - Unsealed Byproduct Material - Written Directive Required
Radioisotope Safety Exam (RISE), also known as NRC Exam
1. What is the nature of the exam that is being given in March?
The exam is multiple-choice, single best answer.
2. How long is the exam?
The exam is 50 questions and is scheduled to last one hour.
3. What material does it cover?
There will be no image interpretations, but there may be some questions regarding specific radiopharmaceutical studies from a safety perspective. Questions on radiopharmaceuticals, including clinically relevant beta emitters, PET radioisotopes, and radioiodines should be anticipated. There will be considerable content on the safety and handling of radiopharmaceuticals.
4. Are there guidelines provided by the ABR to facilitate preparation?
The NRC website provides the general areas of training content under 10CFR35 sections 290, 392 and 394, which are pertinent to the examination.
The NRC web site also provides rules and regulations applicable to the safe use of radiopharmaceuticals and compliance issues that are included on the examination.
The candidate should be familiar with these.
5. If I choose to defer taking the exam, what options/dates will be available to me later?
If you defer this year but indicate to us that you want to take it in the future, you will be invited to next year's exam. The NRC exam is held annually in March.
6. What benefit/rights does the additional certification give me?
Being AU-eligible allows you to bypass some of the requirements set forth by the NRC to become a certified Authorized User. Otherwise, the ABR suggests contacting your institution/workplace for information regarding its particular nuclear medicine requirements.