HPPOS-030 PDR-9111210152

Burial of Patients With Permanent Implants

See the memorandum from L. B. Higginbotham to A. B. Davis dated April 3, 1980. It references NCRP Report No. 37, “Precautions in the Management of Patients Who Have Received Therapeutic Amounts of Radionuclides,” regarding burial of patients with permanent implants. This NCRP report gives levels of radioactivity below which no precautions are needed.

A hospital requested guidance on the disposition of a deceased patient with a permanent implant of 20 mCi of I-125 seeds. They were advised by IE:HQ that, since there were no regulatory requirements, the conservative approach would be to remove the implants, if practicable. It was also suggested that a policy might be needed on this issue to provide guidance.

As a general rule, any licensee who requests guidance should be told that he is obligated to adhere to all regulatory requirements, and if no regulatory requirements exist, he may take any action he deems appropriate. Regional offices may inform licensees where to obtain guidance by suggesting generally accepted documents such as NCRP reports, ICRP committee reports, regulatory guides, and ANSI standards.

If the licensee requests more specificity and doesn’t have certain reports and time is essential, regional personnel may summarize applicable guidance sections (if available in the region) for the licensee, making it clear that the licensee is not obligated to use regional suggestions to prevent the licensee from believing that NRC is imposing new requirements on him.

In this particular case, the implants would not have to be removed since permanent implants are not intended to be removed. The guidance in NCRP Report No. 37 that deals with management of patients with therapeutic amounts of radionuclides establishes levels of radioactivity below which no precautions are necessary. The deceased patient also contained materials below precautionary concerns, and NCRP reports are generally accepted as appropriate guidance for use in the absence of regulatory requirements. For patients who die, there are precautions in NCRP Report No. 37 to be taken for physicians performing autopsies and precautions for handling the deceased when no autopsies are performed. There are also precautions for cremating, including total millicurie amounts per year that can be handled safely by a single crematorium, with some exceptions for Ta-182 and Ir-192 that have been shown to significantly contaminate crematoriums. There appears to be no restrictions or precautions on burial except in preparing the deceased for burial.

The guidance in NCRP Report No. 37 is considered to cover this situation adequately, and it is not believed a policy statement is needed on this issue.

Regulatory references: NCRP Report No. 37

Subject codes: 9.0, 9.4, 12.8

Applicability: Byproduct Material