Reducing Barriers to Medical Use Licensing

September 9, 2026 [Submitted electronically via: Regulations.gov, Irene.Wu@nrc.gov and Katherine.Tapp@nrc.gov] U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Docket ID: NRC-2025-1237 Re: Reducing Barriers to Medical Use Licensing; Proposed Rule and Guidance; Request for Comment (NRC-2025-1237) (RIN 3150-AL50) On behalf of the American Pharmacists Association (APhA) Radiopharmaceuticals Community, representing Authorized Nuclear Pharmacists (ANPs), Board Certified Nuclear Pharmacists (BCNPs), and other radiopharmaceutical professionals dedicated to the safe management, preparation, handling, dispensing, and distribution of radioactive drugs for patient care, we appreciate the opportunity to comment on the U.S. Nuclear Regulatory Commission's (NRC) proposed rule and guidance, Reducing Barriers to Medical Use Licensing. The proposed rule includes important changes that would modernize medical-use licensing requirements, reduce unnecessary administrative burden, and improve flexibility while maintaining patient and radiation safety protections. At the same time, we encourage the NRC to carefully reevaluate and readdress several proposed physician qualifications and operational changes to ensure that reductions in regulatory requirements do not inadvertently weaken patient safety and radiation safety oversight. See, attached PDF for full comments. Thank you for the opportunity to comment on this important proposed rule. APhA's Radiopharmaceuticals Community stands ready to work collaboratively with the NRC, Agreement States, physicians, nuclear pharmacies, and health care facilities to ensure modernization efforts continue to support patient safety, innovation, regulatory compliance, and patient access to radiopharmaceutical services. If you have any questions or would like to meet with our nation's nuclear pharmacists in APhA's Radiopharmaceuticals Community, please contact mbaxter@aphanet.org. Sincerely, APhA Radiopharmaceuticals Community