Radiological Protection in Therapy with Radiopharmaceuticals


Draft document: Radiological Protection in Therapy with Radiopharmaceuticals
Submitted by Medical Exposure Group - Louise Fraser, Public Health England
Commenting on behalf of the organisation

The report largely summarises the current state of dosimetry in a range of unsealed source therapies, although novel therapies labelled with 227Th are not included. Recommendations are primarily advocating for further research and application of dosimetry to all therapies, and encouraging better collection of data that would improve modelling and dosimetry assumptions. Previous ICRP reports had not been specifically focussed on this area and so there appears to be little likely to contradict or amend previous ICRP statements or recommendations.

Specifc comments are listed below:

L67: A definition of “Dose Constraint” should be added.

Section 2: Some of the information presented could be reviewed for consistency e.g. finger dose estimates to staff are presented for 90Y and 177Lu DOTATATE but not for other therapies listed in this section

Pg 12: Footnote 1 includes a typo ‘Molecular Radiotherapy’

Para 7: The target audience might also include radiographers.

Para 21: reference to section 5.3.4 Breastfeeding could be added here.

L440 & L599: it may be useful to refer to the periods of time to avoid conception included in section 5.3.6

L449: is there a reference for the 2% mortality figure quoted?

L468: The term “iodine negativity” is not defined, could this be clarified?

L673 & L1037: include information on contraindications of pregnancy and breastfeeding, with reference to section 5.3.6

L699-700: statement that the physical half-lives and biological retention “do not cause unnecessary hospitalisation” contradicts the statement in L731 that “patients are typically hospitalised for one or two nights”. This could be made clearer.

L701: it would be useful to state what the “usual precautions” are for these procedures.

Para 75: An individual risk assessment may be required to determine any restrictions on close contact with friends and family when the patient returns home.

L940: it would be useful to clarify what “concerns of protection” are being referred to here.

Para 100: While staff working in theatres may be familiar with radiation protection requirements around x-ray equipment, additional training may be required to cover the administration of radioactive materials.

Para109: references to “sensible” precautions and “acceptable limits” could be clarified.

L1614: the phrase “optimisation of staff exposures include consideration of” could be replaced with “staff exposures should be kept ALARA by considering”

Para 183: suggest that patient life expectancy should be taken into consideration when making the decision to treat with radiopharmaceuticals.

Para 185: Consider replacing references to females and women with the phrase “individuals of childbearing potential”

Para 187: It may be useful to refer to the further medical management of the infant when born.

Table 5.2: includes periods to avoid pregnancy following the administration of 32P-phosphate for myeloproliferative disorders, however, L523 states that this treatment is not recommended for women of childbearing potential.

Section 5.3.7: This section might usefully include an explicit recommendation on L1796 that all services should develop and adopt minimum criteria for checking of safety critical steps in the referral, planning, optimisation and delivery of nuclear medicine therapy. These criteria should be checked by an independent operator using primary source data and a separate methodology where possible.  This section might also include a recommendation that procedures should differentiate between checking something is in place, it is consistent or it is correct.

L2040-2041: higher dose constraints may be appropriate for parents of very sick children. Monitoring of doses to ensure the dose constraint is not exceeded may be appropriate.

L2049-2051: if an individual is not occupationally exposed and they knowingly and willingly provide care to the patient, they should be classified as a comforter and carer. It may be useful to refer to section 5.5 here.

Section 6: The summary of recommendations should reflect at least one recommendation related to the prevention of medical errors with radiopharmaceuticals

L2199: radiation protection precautions should be provided in writing
















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