Reporting Nuclear Medicine Injection Extravasations as Medical Events

The American Pharmacists Association (APhA) is pleased to submit these comments on behalf of the American Pharmacists Association-Academy of Pharmacy Practice and Management (APhA-APPM) Nuclear Pharmacy Practice Special Interest Group (SIG) in response to the Petition for rulemaking; notification of docketing and request for comment [Docket ID NRC-2020-0141]. Please, see, attached .PDF for full comments. APhA is the largest association of pharmacists in the United States and the only organization advancing the entire pharmacy profession. APhA represents pharmacists in all practice settings, including community pharmacies, hospitals, long-term care facilities, physician offices, clinics, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. Within APhA, the Nuclear Pharmacy Practice SIG represents over 3,100 APhA members involved in the specialty practice of nuclear pharmacy. In summary, we do not support the need of additional rulemaking for reporting nuclear medicine injection extravasations as medical events. Such matters are best managed locally at an institutional/hospital level of the facility practice as a quality improvement process. Thank you for the opportunity to comment. The APhA-APPM Nuclear Pharmacy Practice SIG looks forward to working with the NRC. If you have any questions or require additional information, please contact Michael Baxter, Senior Director of Regulatory Policy, at mbaxter@aphanet.org.

Filed on regulations.gov — full text not in the inline record.