The NRC revised 10 CFR Part 35 on 10/24/02 adding §35.290 which, in part, allows for some revisions of certain training requirements. A most significant change is the training required by an authorized user may be less than the 1200 hours that is currently required. The current training consists of 1000 hours of clinical experience and 200 hours of didactic training. The total training has been reduced to 700 hours without specifying how many hours must be didactic.

The new regulations apply to NRC regulated programs only. Currently there are 18 NRC regulated states: Alaska, Connecticut, Delaware, (District of Columbia is regulated by the NRC too), Hawaii, Idaho, Indiana, Michigan, Minnesota, Missouri, Montana, New Jersey, Pennsylvania, South Dakota, Vermont, Virginia, West Virginia, Wisconsin, and Wyoming. The NRC regulates byproduct radioactive materials only, e.g. Tc-99m. Usually these states have additional regulations at the state level to regulate NARM materials, e.g. Tl-201 or Co-57. The remaining 32 states are called Agreement States and regulate both byproduct and NARM.

Typically the new rules will not be adapted by the states and Agreement States, where they are not currently applicable, for up to several years. There are exceptions, however, and these should be investigated by the interested physician to determine the current requirements. All Agreement States must be in compliance with the minimum requirements of the new regulations within 3 years from 10/24/02.

From the ASNC web site at www.asnc.org can be found the following:

On September 28, the ASNC Board of Directors approved a new policy statement on the number of hours needed to fulfill the Nuclear Regulatory Commission's (NRC's) new rule on Training and Experience Requirements for nuclear cardiologists wishing to become authorized users of radioisotopes.

The ASNC policy establishes that a course of 50 hours (25 hours of Physics and Instrumentation and 25 hours of Radiation Pharmacy, Dosimetry and Radiation Waste Protection) meets the classroom and laboratory requirements published in 10 CFR Part 35.290. A total of 700 hours are required to apply for authorized user status in the 18 NRC states. The 32 Agreement States have three years to come into compliance with the Commission's new rule. Courses incorporating the 50 hour requirement are expected to be available in early 2003. For more information, visit the ASNC website at www.asnc.org.

Associates in Medical Physics has taken up the challenge to offer a quality course consisting of 50 hours to comply with ASNC policy recommendation. The course offering, which is oriented toward nuclear cardiologists, has precipitated the following points that should be considered.

1. A physician can become a named user on a license with 700 hours of training in any NRC regulated states for the use of byproduct material.
2. AMP has designed a 50 hour training program specifically to address the new regulations. It is based on recommendations made by ASNC in September of 2002.
3. The physician’s preceptor must consider the 50 hour training as acceptable didactic training.
4. The training is only acceptable for the NRC controlled programs.
5. The training is only appropriate for §35.190 (uptake dilution and excretion) and §35.290 (imaging) authorizations. Most cardiologists require only §35.290.
6. The training may be acceptable for state regulated radioactive material programs, but this should be confirmed.
7. An authorized user who becomes licensed through this method may be listed on most other licenses throughout the United States. This should be confirmed if intentions are pending for a physician to be licensed in one state with the plans to move to a different state.
8. Written Certification - the physician in training must submit written certification, signed by a preceptor authorized user who meets the requirements in §§35.290 or 35.390 or equivalent Agreement State requirements, that the individual has satisfactorily completed the requirements in paragraph (c)(1) of §35.290 and has achieved a level of competency sufficient to function independently as an authorized user for the medical uses authorized under§§ 35.100 and 35.200. The physician in training should confirm the written certification will be available from his/her preceptor before pursuing authorization under this regulation and before pursuing training offered by AMP. If the preceptor will not provide such certification, the licensing agency will not grant authorization.
9. The preceptor must be a named user on an existing license or be board certified by a board acceptable to the NRC. As of December 2002, the only board that meets this qualification is the CBNC. Other boards may be identified as acceptable by the NRC in the near future.
10. A letter from the preceptor, or Supplement A & B forms, available from the regulators, may be used to document training.