Nuclear Regulatory Commission (NRC)
U.S. federal regulator of byproduct nuclear material — relevant to medical imaging and radiation oncology for PET tracers, Tc-99m generators, I-131 therapy, Y-90 brachytherapy and radioembolization, Ir-192 HDR brachy sources, Co-60 Gamma Knife sources, and theranostic Lu-177 / Ac-225 programs. The NRC's medical-use framework is one of the load-bearing regulatory documents for any program handling unsealed or sealed radioactive material.
What NRC regulates in imaging and therapy
- 10 CFR Part 35 — medical use of byproduct material. Defines authorized users (Part 35.290 nuclear medicine, 35.300 unsealed therapy, 35.400 sealed-source brachytherapy, 35.500 sealed-source diagnostics, 35.600 Gamma Knife / sealed-source teletherapy), required training, written directives, safety precautions, and incident reporting.
- 10 CFR Part 20 — occupational and public dose limits, ALARA program, dose-record retention.
- 10 CFR Part 30 — licensing of byproduct material generally; license types and amendment procedures.
- 10 CFR Part 71 — packaging and transportation of radioactive material; impacts radiopharmaceutical delivery and waste shipment.
- 10 CFR Part 19 — notices, instructions, and reports to workers.
Authorized User pathways (Part 35)
- 35.290 — imaging and localization studies (Tc-99m, F-18 FDG, Ga-67, Tl-201, In-111, etc.).
- 35.300 — unsealed-source therapy (I-131 thyroid, Lu-177 PSMA / DOTATATE, Y-90 microspheres, Ra-223).
- 35.400 — manual brachytherapy (LDR seeds, HDR afterloader operations).
- 35.500 — sealed-source diagnostics (well counters, calibration sources).
- 35.600 — sealed-source teletherapy / Gamma Knife (Co-60).
Each pathway has its own training, mentorship, and written-directive requirements. AU credentialing is non-transferable by program — staff changes require license amendments.
Agreement States
37 U.S. states have Agreement State status with the NRC — they regulate byproduct material themselves under programs the NRC has determined are compatible. In Agreement States, the state radiation-control program issues licenses rather than the NRC. Federal facilities (VA, DoD, IHS) and non-Agreement-State facilities are licensed directly by the NRC.
Agreement-state regulations sometimes go beyond NRC minimums (more stringent dose limits, additional training requirements, more frequent surveys). Programs operating across state lines navigate two regulators.
Required program elements
- Radioactive Materials License — facility-level, with named Authorized Users, listed isotopes, possession limits, and authorized activities.
- Radiation Safety Officer — on file, with documented qualifications and authority. Some Agreement States require a deputy RSO and/or a Radiation Safety Committee.
- Documented radiation safety program — surveys, dose records, written procedures, ALARA goals.
- Dose calibrator + survey meter + area monitoring — equipment with documented calibration and daily / weekly QC.
- Waste disposal + regulated transport — decay-in-storage, licensed-broker disposal, manifests, source-return chain of custody.
- Incident reporting — misadministration, lost / stolen sources, contamination above thresholds.
Why it matters to buyers
- License transferability is NOT automatic in used-equipment purchases. PET / CT, SPECT, Gamma Knife, brachy afterloaders all carry program-level license obligations that travel with the program, not the box.
- License amendment timelines — 30 to 120+ days depending on jurisdiction and complexity. Build into install schedule.
- Authorized User credentialing — physicians and physicists must be individually named on the license; staff changes are amendment events.
- Inspection cycle — typically every 1–5 years depending on license type and inspection history.
- Decommissioning has its own license-amendment pathway (final survey, inventory reconciliation, RSO sign-off, closeout inspection in some jurisdictions).
Relevant clinical applications
- Brachytherapy (HDR, LDR)
- FDG PET Oncology
- Cardiac Rubidium-82 PET
- Tc-99m MDP bone scan
- Cardiac SPECT
- Y-90 radioembolization
Related
- NRC Licensing (operational guide)
- State Radiation Registration (X-ray equipment, separate framework)
- AAPM TG-142 (linac QA, distinct framework)
- MQSA (mammography, distinct framework)
- Radiation Safety Officer
- Nuclear Medicine Technologist
- Rad Onc Physicist
- Nuclear Medicine Decommissioning
- PET / CT Decommissioning
- Linac Decommissioning