For those physicians who are interested in becoming an Authorized User (AU) there may be a potential problem if, for example, they are applying for their own clinic license. The NRC mandates, in part, that all licenses issued for medical use must have an Authorized User (AU) and a Radiation Safety Officer (RSO). If one or more individuals cannot serve as an AU and/or RSO, a license will not be issued. Usually in a small clinic the AU is also the RSO, and therein lies the problem.

The NRC recently discussed this issue in June 2006 in a publication known as the NMSS Quarterly Review. They reviewed the interpretation of the regulations and applicability to a physician who was applying for a new license to be the AU and RSO. Basically, they concluded the new license applicant could not serve as the RSO on his application because to become an RSO he must first already be an AU. For a new applicant, the very point in submitting the application is to become an AU. This is a sort of catch 22. Someone else would have to serve as RSO to get the license started. The license could then be amended to allow the AU to become the RSO. Finding someone to fill this short- term role may prove difficult in some cases.

Specifically the NRC stated:

Although the physician applying to be both a new AU and RSO had experience with the radiation safety aspects of similar types of use of byproduct material for which the individual would have Radiation Safety Officer responsibilities, the physician would not meet the other requirement in 10 CFR 35.-50 (c)(2), because the individual was not yet an AU. In addition, a preceptor RSO could not attest that the person was either an AU or met the training and experience requirements in any of the other pathways specified in 10 CFR. 35.350. The applicant was requested to identify another individual as the RSO, and provide documentation that the person met the requirements in 10 CFR 35.50. Applicants for new licenses should be aware of the current requirements.

If this is an issue, there are alternative ways to address the problem. The specifics of each circumstance may vary. If you are considering attending a course we offer to become an AU and RSO, you may want to contact our office to discuss this issue.