procedures, or administer radiation therapy. The standards and requirements for training prescribed by Illinois' statute and regulation are certainly equal to, and in most cases exceed, those standards suggested by the Act" (Illinois). The Illinois respondent went on to explain that "there are still 21 states, with regard to medical radiography, that have made no progress during the past 13 years in implementing the minimum standards for training and education described in the Act. In addition, there are still 35 states which have no requirements for technologists who use radioactive materials and perform nuclear medicine procedures. While the Act describes minimum standards, there has been little guidance provided to the states on implementation of these standards."

Question 10 (N = 24)

What, if any, Federal agency should be responsible for establishing educational standards for accreditation regarding the medical use of ionizing radiation? NRC? FDA? Other? How should the quality of the education programs be judged? What criteria should be applied?

In response to this question we received 24 replies: 16 from professional associations, societies, and industry; 5 from states; and 3 from miscellaneous sources. On this question, there was no consensus. Answers typically fell into one of two categories: (1) There should be no federal involvement in this issue. (2) Federal involvement is appropriate but determining which agency is no simple task.

Most of the professional associations offered the first response. In place of federal oversight, they argued instead for industry self-regulation. "There is already a complete working mechanism for the review, accreditation and periodic re-review of education programs for radiological technologists, and radiation therapists. All that would be necessary is to require all individuals using ionizing radiation for medical uses to either be a licensed health care professional or a graduate of an accredited program" (AAPM). "Government agencies should not have responsibility for developing educational standards, standards for accreditation of training programs, or certification of qualifications (competence) to practice medicine using ionizing radiation. This should be the responsibility of professional organizations" (ABNM). "We do not think that any Federal agency should be directly responsible for establishing educational standards for accreditation regarding the medical use of ionizing radiation. This should be the assumed responsibility of established professional/educational/scientific organizations. … Educational programs should be evaluated by accreditation bodies which may operate under the auspices of a Federal agency" (ACMP). "No Federal agency should be involved with this. … Professional accrediting organizations exist to accredit programs, and this all that is needed. … For those who do not possess certification by an acceptable professional group, the State can offer an examination, as is done in California" (ACNP). "Neither agency [FDA or NRC] is well-equipped to make this type medical decision and neither should be



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