The following is supplemental information for our October 2002 Reduced Training Requirement.

The NRC revised 10 CFR Part 35 on 10/24/02 adding §35.290 which, in part, reduced the training requirements from 1200 hours of which 200 hours had to be didactic training to 700 hours without specifying how many hours must be didactic. The remaining training consisted of clinical experience as described in the regulations.

The new regulations applied initially to NRC regulated programs only. Ultimately, the Agreement States must adopt certain portions of the revised regulations, of which the training requirements for authorized users is a required part. As of this writing on 12/11/03, there are 17 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, and Wyoming. All others are Agreement States to include Wisconsin which became an Agreement State in August 2003.

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. This is because it takes time to adopt the new rules through the legislation process of the regulatory agencies and applying codification to fit the state’s requirements. There are exceptions, however, and the status of any state should be investigated by the interested physician to determine the current requirements at their location of interest. All Agreement States must be in compliance with the minimum requirements of the new regulations for training, at least, within 3 years from 10/24/02.

Some Agreement States have already adopted part or all of the training requirement changes at this point in time. To confirm their status, the regulatory agency should be contacted and questioned. A directory of phone numbers is available on the web at http://www.hsrd.ornl.gov/nrc/home.html. The phone numbers are usually pretty current. Click on any state for contact information and even links to the regulations.

Pertinent questions to ask the regulator would be:

Has the state adopted the revised federal code for physician training yet. If not does the regulator know when that might take effect?

Will the regulations and licensing apply to the use of both byproduct material (Tc-99m for cardiologists) and NARM (Tl-201 and Co-57 reference sources) or are these separate issues?

Is the recentness of training that can be submitted going to be the same as the NRC? Recentness of training varies a little from state to state and is either 5 years or 7 years. The NRC allows 7 years.

Can the clinical experience be acquired in a clinic setting or must it be obtained in a hospital based program? Some regulators are very strict on this interpretation.

If the old standards of 1000 hours of clinical training apply, can the two 500 hour segments (supervised work experience vs. supervised clinical experience) be obtained concurrently, rather than sequentially? Some states allow this and what would look like a six month training requirement can be completed in a three month interval. Refer to your state’s regulations for a more complete definition of these terms.

Visit other links on our web site for courses offered in 2005 to comply with the didactic training requirements.