During its deliberations, the committee reviewed information from a variety of sources, including commissioned papers, literature reviews, site visits, official presentations by NRC personnel, a public hearing, and interviews with radiation safety officers. The lack of data for comparing byproduct material, naturally occurring and accelerator-produced radioactive materials (NARM), and machine-produced radiation limited the scientific basis of the committee's findings. This section enumerates the findings the committee generally agreed upon given the existing data, as presented in Chapters 2, 3, and 4. The issues are summarized in terms of risks and benefits, regulations, the regulated community, and private and voluntary involvement in radiation safety.
The use of ionizing radiation in medicine offers tremendous benefits to patients but also carries a nontrivial potential for harm.
Compared to the regulatory systems in place for the other 90 percent of medical use of ionizing radiation, the more detailed reporting and enforcement systems required for byproduct materials do not seem to result in even a marginal decrease in risk to providers, patients, or members of the public.
Equal treatment of all ionizing radiation in medicine would be a sensible national policy insofar as the risks of reactor-generated byproduct material and other forms of radiation are equal. However, because data on adverse events in the use of ionizing radiation are limited, it is difficult to compare risks involving byproduct material with risks involving machine-produced radiation, or to compare overall risks of the use of ionizing radiation in medicine with those of other medical modalities.
The fragmented regulation of the use of ionizing radiation in medicine—namely, its division into (a) the NRC's exclusive regulation of reactor-generated byproduct material, and (b) state regulation of NARM and machine-produced radiation—is a historical artifact. This has resulted in appreciable variation in the intensity and nature of regulatory control of various forms of radiation that have roughly equivalent risks.
Regulation of reactor-generated byproducts exceeds in intensity and burden that of all other aspects of ionizing radiation in medicine. The regulation of reactor-generated byproduct material is also more vigorous than that of any other aspect of high-risk health care. It greatly exceeds the regulation of chemotherapy, surgery, anesthesia, and the use of general pharmaceuticals except for controlled substances, all of which are unregulated at the federal level.