From:	Pomije, Brian D. (LCDR)
Sent:	Friday, July 29, 2005 4:12 PM
To:	Burke, Gerald; Casey, Richard W. LCDR; Clark, Dorothy M. (CIV); Ely, Karen D. (CIV); Fairchild Gregory R LT; Giel, Daniel T. (CIV); Hecht, Sheila C , LCDR; Herrera, Mark E; Hope, Lawanda P. HM1; Johnson, Gabrielle M.; Kennemur, Lisa K LCDR; LaFontaine, Richard L CT; Loscocco, Michele F (CDR); Maher, John M CDR; Ozeroglu, Muhammed A  LT; Pomije, Brian D. (LCDR); Ruiz, Steven LCDR; Saylor, Tillman K (NNMC Contractor); Scott, John H., CIV.; Simays, Andrew E., CDR; Solanki, Haresh P; Swilley, Eugene A. (LT); Tu, Victor LT; Van Way, Rick L (LCDR); Younes, Georges  E LCDR
Cc:	Pomije, Brian D. (LCDR); Ely, Karen D. (CIV); Clark, Dorothy M. (CIV); Earles, Marvin R LCDR ; Glennon, Brendan K. CDR BUMED; Lino CDR Fragoso (E-mail) (Lino.Fragoso@navy.mil)
Subject:	NRMP - Approval of a Medical RSO, AU, AMP or ANP
Approval of a Medical RSO, AU, AMP or ANP

To all Medical Radiation Safety Officers and NRMP Permittees:

Based on the 30 March 2005 revision to 10 CFR Part 35, there are three authorized pathways for individuals to satisfy training and experience requirements to be approved as a Radiation Safety Officer (RSO), Authorized User (AU), Authorized Medical Physicist (AMP) or an Authorized Nuclear Pharmacist (ANP).  These pathways are as follows:

1.  Approval of an individual who is certified by a specialty board, whose certification process has been recognized by the NRC or an Agreement State as meeting NRC's requirements for training and experience;

2.  Approval based on an evaluation of an individual's training and experience; or

3.  Identification of an individual's approval on an existing NRC license, Agreement State license, or on a Permit issued under a Master Materials License (MML).

Because of the 3rd alternate pathway listed above, it is highly advisable that all RSOs, AUs, AMPs and ANPs be approved and added to Naval Radioactive Materials Permits (NRMPs) via formal amendments, prior to 24 October 2005.  The reason that this date is so critical is that the old regulatory requirements in Subpart J of 10 CFR Part 35 will officially be removed from the regulations on 24 October 2005, and that after midnight on that date, everyone must comply with the new Part 35 requirements.

It is also important to realize that most physician AUs have been previously approved based on their board certifications.  As of today, essentially none of these certification boards have been approved by the NRC, including the American Board of Radiology (ABR) and the American Board of Nuclear Medicine (ABNM).  It is also important to know that there are currently no certification boards approved for RSOs.  This is why it is highly advisable to approve individuals and have them listed on NRMPs prior to 24 October 2005.  If they are listed on a Permit, then they can essentially be "grandfathered", and will not need to comply with the initial requirements in the "new" Part 35 regulations.

Very Respectfully,

LCDR Pomije

Brian D. Pomije, MS, DABR
Lieutenant Commander, Medical Service Corps, USN
Radiation Health Team Leader
Navy Environmental Health Center
620 John Paul Jones Circle (Suite 1100)
Portsmouth, VA 23708-2103

W: (757) 953-0766; DSN: 377-0766
Cell: (757) 651-2814
Fax: (757) 953-0685