As of this writing numerous Agreement states have proceeded to adopt the new training requirements for physicians that were implemented in October 2002. All states are supposed to have the changes in place by October 2005. For a brief history of the progress of these changes please review the articles for 2002 and 2003 above.

All NRC regulated states follow the new regulations but not all Agreement States have been able to adopt the regulations at this point in time. This is generally attributed to the fact that the state usually must go through a regulation change procedure that requires legislative or committee review. The new regulations must be proposed and often published for public comment. Then they must be codified and issued. This process varies by the state and is sometimes easy or sometimes labor intensive. Each state can be contacted and queried as to its current status. For a listing of the phone numbers please go to the web at http://www.hsrd.ornl.gov/nrc/home.html. Click on your state for a listing of contacts or look to the menu on the left for other references.

In fact, it would behoove any interested physician who wants to become licensed in a particular state to check with that state to see what the status is today, or at least check to see the possible status when the individual plans on becoming a licensed user in that state (e.g., if you plan on moving to a different state).

A noteworthy side bar discussing is as follows:

There are two types of radioactive materials, determined by how they are produced. One is called (1) Byproduct Material, from a reactor, and the other is called (2) NARM (Naturally occurring or Accelerator produced Radioactive Material) and is produced from an accelerator (unless it is Naturally Occurring). Both are radioactive, both are handled in similar ways and both have similar effects on the environment. It is just that at the time regulatory bodies were evolving Byproduct was around and NARM was yet to gain its popularity. The regulatory bodies had a different focus in the past at the time regulations were evolving.

In order to use these materials medically, a physician has to be named on an appropriate license as an Authorized User (AU). There are several licensing situations of which the physician wishing to become an authorized user should be aware.

States are regulated by one of three regulatory configurations. (1) The NRC (17 of them) governs only the use of Byproduct Material (notably Tc-99m and Cs-137). (2) States may have their own licensing requirement to regulate NARM materials or they might just have a Registration for use of this material (notably Tl-201 and Co-57). (3) Agreement States (a situation where the state has agreed with the NRC to regulated Byproduct Materials) typically regulates both Byproduct and NARM materials.

In order to become an authorized user on a license in your state, you should be aware of what type of state you live in. This can be gleaned from the web site mention above (http://www.hsrd.ornl.gov/nrc/home.html). If it is NRC regulated and you have questions, then call the NRC regional office that covers your state, which can be determined at http://www.nrc.gov/who-we-are/locations.html. Otherwise, you should contact the state and ask the following questions.

1. Does the state use the training requirements at this time as adopted by the NRC in October 2002. If so then 650 hours of clinical and 50 hours of didactic is acceptable if your preceptor agrees with this specific training and experience.
   
2. If not, is the didactic training 200 hours or something different. And then, what is the clinical requirement.
   
3. Is the clinical training made up of 6 months or 3 months of experience in the required topics.
   
4. Does the state accept training and experience received within the past 5 years or the past 7 years.
   
5. Does the state require that the clinical and/or didactic training be received from an (1) ACGME accredited training program (a university based graduate medical education program - usually associated with residency programs), an (2) ACCME accredited program or (3) any program they find acceptable.
   
6. Can the clinical training received in a clinic setting be used for evidence of training and experience (as opposed to hospital based).
   
7. Will the state accept as evidence of qualifications a license from another state or the NRC on which you are listed as a named user.
   
8. Are there other specific requirements to become a licensed user.
   

Usually, once a physician is named on an NRC or Agreement State license he/she can use this as a reference to show evidence of proper training and experience for the purpose of becoming named on another license in a different state. But this is not always true. There might be situations where the State will not accept this form of documentation because their standards are “higher” and simply being on a license from another state is not adequate. These situations are few but worth checking into before making a move.

Remember, if you go to an NRC regulated state you might also have to apply for a State license to use NARM. Confirm training is compatible for both licenses.

All Agreement States are supposed to accept the guidelines of training established at the Federal level by October 2005. Hopefully, by that time the requirements will all be standardized throughout all of the states. BUT, do not ASSUME.