The American Society of Radiologic Technologists filed two comments to the U.S. Nuclear Regulatory Commission’s federal proposed rules Reforming and Modernizing the NRC’s Radiation Protection Framework and Reducing Barriers to Medical Use Licensing. ASRT addressed significant concerns about the impact of these proposed rules on patient safety.

The first proposed rule, Reforming and Modernizing the NRC’s Radiation Protection Framework, would streamline regulatory burden and remove subjective enforcement of federal radiation safety standards. It would also replace the agency’s longstanding ALARA, as low as reasonably achievable, standard with a new graded approach to dose management.

In its comments, ASRT stated that the rule, as written, will have unintended consequences on access to critical health care and to the safety of patients and health care workers. ASRT believes removing ALARA from the definitions within the federal regulations without a suitable vetted alternative will significantly and negatively affect the medical imaging and radiation therapy community, and ASRT is therefore opposed to the removal of ALARA when specifically discussing its use in health care. ASRT urged the NRC to clearly delineate between the nuclear power industry and health care.

The second proposed rule, Reducing Barriers to Medical Use Licensing, aims to reduce unnecessary regulatory burden in the licensing and reporting requirements for radiation and radiopharmaceuticals for medical uses.

In its comments, ASRT urged the NRC to maintain physician requirements for Authorized Users and provide consistent implementation of radiation safety best practices as supported by the independent medical imaging, radiation therapy and radiation protection experts for uniform protection for all patients, health care workers and the public.

If finalized, the proposed rules are anticipated to take effect in early 2027. For questions about ASRT’s comments contact [email protected].