The NRC changed their regulations on March 30, 2005, with an effective date of April 29, 2005 regarding training. This deals with the didactic training requirements for those doctors who want to become named as an authorized user on an NRC license. This would apply to Cardiologists and even full service nuclear medicine physicians. Cardiologists would normally be listed for uses identified under the Federal regulations in 10 CFR 35.290 and full service physicians listed in 10 CFR 35.290 and 35.390. Note the didactic training has changed from that which would have been approved by the preceptor (50 hours was assumed acceptable under specific circumstances) to 80 hours for 35.290 and 200 hours for 35.390. There is still a requirement for total training to be 700 hours of clinical experience, work experience and didactic. This article discusses only the didactic portion of the training.

The Agreement States, who were supposed to implement the “50 hr” training by October of 2005 have been given a reprieve and do not have to implement the new “80 hr” requirement for three years. This means that if they were currently requiring “200 hrs” they may continue to do so for another three years before they have to accept the “80 hrs”. We have no way of knowing what will happen at that point in time. Some Agreement States may also have adopted the “50 hr” training “early” and may continue to accept this until April 2008, but we think this will not be common.

In the interim, we have been advised that the CBNC will accept the “50 hr” training for the Fall certification test of 2005 if all other application criteria have been met. However, the CBNC must re-apply to the NRC for re-acceptance of their Board after October 2005 and it must be based, in part, on the new “80 hr” training requirement. Qualifications for CBNC testing eligibility will change.

It is critical that you check with your licensing agency and the CBNC to get the current facts of how this whole process will be handled at the point in time when you intend to submit an application. We are getting conflicting explanations at the time this article was authored (May 2005) and do not feel we can offer accurate advice that is acceptable for all individual circumstances.

AMP has considered how to best handle this sudden change. We may offer another 30 hours of didactic training in Cleveland, Ohio, on Aug 1-3 of 2005, to those who received 50 hours didactic training from our courses earlier. This will “make you whole”, so to speak, and allow you to continue with your plans of becoming an authorized user on a license if the 80 hours impacts you. The “extension course”, if there is sufficient interest, will be offered at a proportioned additional fee, if you bring your books as initially issued to you at the time of your attendance. If these are no longer available there will be an additional fee to replace them.

In the Fall, AMP will re-instate a 200 hour program and will create an 80 hour program. The program dates are as follows:
(1) “80 hr” Sep 9-16 (10hr/day for 8 days)
(2) “200 hr” Sep 9-18 (10hr/day for 10 days) and Oct 14-23 (10hr/day for 10 days)
Please contact our office ASAP to advise us whether or not you plan to attend any of our offerings. The 200 hour course tuition will be $4500 with timely registration. The 80 hour course tuition will be $3500 with timely registration. Both courses will be conducted in Cleveland, Ohio.

You may need 80 hours or 200 hours of didactic training by the time you plan to be named on a license if that has not already been accomplished.
See previous articles on this web page that may still be posted for background discussions on the evolution of the training requirements.

For reference, the Summary of the notice from the Federal Register reads as follows. The bold, italicized, underlined statements are emphasis put into the notice by AMP as well as the “...” to drop out some of the “legalize”.

SUMMARY: The Nuclear Regulatory Commission (NRC) is amending its regulations governing the medical use of
byproduct material to change its requirements for ... authorized users. The final rule also revises the requirements for demonstrating the adequacy of training and experience for pathways other than the board certification pathway. This final rule grants, in part, a petition for rulemaking submitted by the Organization of Agreement States
(PRM–35–17) and completes action on the petition.

DATES: Effective Date: This final rule is effective on April 29, 2005.

FOR FURTHER INFORMATION CONTACT:
Roger W. Broseus, Office of Nuclear
Material Safety and Safeguards, U.S.
Nuclear Regulatory Commission,
Washington, DC 20555–0001; telephone
(301) 415–7608, e-mail rwb@nrc.gov.

The body of the notice reads, in part, as follows for 35.290 and 35.390. The “*****” indicates the remaining verbiage in the current regulations stays in place. Only the changes are published here.
§ 35.290 Training for imaging and localization studies.
* * * * *
...
(c)(1) Has completed 700 hours of training and experience, including a minimum of 80 hours of classroom and laboratory training, in basic radionuclide handling techniques
applicable to the medical use of unsealed byproduct material for imaging and localization studies.
...
§ 35.390 Training for use of unsealed byproduct material for which a written directive is required.
* * * * *
...
(b)(1) Has completed 700 hours of training and experience, including a minimum of 200 hours of classroom and laboratory training, in basic radionuclide handling techniques
applicable to the medical use of unsealed byproduct material requiring a written directive.