SNMMI-ACNM Submit Comments on NRC Proposed Changes to Training and Experience Requirements

July 5, 2019

The Society of Nuclear Medicine and Molecular Imaging (SNMMI) and the American College of Nuclear Medicine (ACNM) submitted joint comments to the Nuclear Regulatory Commission (NRC) on the proposed changes to the training and experience currently required to administer radiopharmaceuticals for which a written directive is required.

SNMMI-ACNM's comments highlight the importance of patient and public safety, while ensuring access to quality care. 

  • Any reduction in current requirements will compromise the safety of patients, their caregivers, and family members. 
  • Parenteral radionuclide therapy can be administered safely only by personnel with an extensive understanding of radiation physics, radiopharmacy, pharmacokinetics, dosimetry, and radiation biology, as well as the principles and practices of radiation safety.
  • There is no identified shortage of authorized users, so there is no reason for a change in the current requirements.

As previously reported, the NRC published a Federal Register notice in May 2019, requesting feedback from the public. The NRC also held several public meetings to gain input on several topic areas outlined below. 

SNMMI has previously submitted comments to the NRC on this issue. You can read SNMMI's comments from 2018 here. Many other stakeholders submitted comments to NRC as well, including the American Board of Nuclear Medicine. ABNM's comments can be viewed here

You can find general information on the NRC's training and experience evaluation here.