Report | June 10, 2020

Audit of the Safety and Security of Radioactive Materials at Department of Defense Medical Treatment Facilities (DODIG-2020-088)

Audit

Publicly Released: June 12, 2020

 

Objective

The objective of this audit was to determine whether DoD and military medical treatment facility (medical facility) management properly trained personnel, conducted inspections and program reviews, and accounted for inventory levels for the safety and security of radioactive materials. In addition, Defense Health Agency (DHA) management officials requested that we identify any best practices for their consideration as they assume administration and management responsibility of all medical facilities within the DoD.

We reviewed the safety and security of radioactive materials in the Nuclear Medicine Departments at eight nonstatistically selected DoD medical facilities across the Military Services and National Capital Region-Medical Directorate.

 

Background

On October 1, 2019, the DHA assumed administration and management responsibilities from the Army, Navy, and Air Force for all military hospitals and clinics. The DHA will oversee facilities through a direct support relationship with the Military Medical Departments. The DHA will relieve the Departments of their support during a transition period in which responsibility for specific health care and administrative functions fully transfer to the DHA. The DHA transition has a target completion of September 2021.

About one-third of all patients admitted to hospitals are diagnosed or treated with radiation or radioactive materials, which are referred to as radiopharmaceuticals. This branch of medicine is called nuclear medicine. The most common types of procedures performed by nuclear medicine technicians include brachytherapy, iodine treatment for overactive thyroid, and bone mineral analysis. There are 32 medical facilities and 1 medical training facility within the DoD that have radioactive materials.

The Nuclear Regulatory Commission (NRC) regulates the use of radioactive materials for diagnosing and treating illnesses, and in medical research. The NRC is responsible for ensuring that medical facilities use the materials properly and in a way that protects patients, medical workers, the public, and the environment from radiation contamination and exposure. Furthermore, the NRC oversees medical uses of radioactive materials, issues medical use licenses to medical facilities, authorizes physician users, and develops guidance and regulations for use by licensees.

 

Finding

DoD medical facility management properly trained personnel, conducted inspections and program reviews, and accounted for inventory levels for the safety and security of radioactive materials at the eight facilities visited. Specifically, DoD management at each medical facility:

• trained Radiation Safety Officers and authorized users regarding the safe use of radioactive materials;

• complied with Federal and DoD  requirements  for periodic reviews of facility radiation safety programs, ensuring reviews were conducted at least annually, and took corrective actions to address deficiencies identified by the periodic reviews; and

• received, secured, accounted for, and disposed of radioactive materials, and took measures such as conducting surveys and monitoring occupational exposure to ensure patient and employee safety.

We identified multiple best practices such as sharing process improvements identified through external audits, improved procedures for survey instrument testing and calibration, and potential cost savings and efficiencies over dosimetry processing for the DHA to consider implementing as it assumes administration and management responsibility of all medical facilities within the DoD. These best practices could help the DHA strengthen controls over the safety and security of radioactive materials and gain potential cost savings.

 

Recommendations

We recommend that the DHA Director:

• coordinate with Radiation Safety Officers to conduct external audits of other medical facility radiation safety programs to expedite the sharing of best practices across the Military Services and medical facilities,

• implement supplemental guidance to instruct the medical facilities on appropriate steps to take after a failed quality control test,

• conduct a study to determine the benefits and feasibility of directly connecting the medical facilities' nuclear medicine information systems to survey instruments,

• review and revise, as necessary, the dosimetry processing procedures that record and measure radiation exposure to occupational employees, and

• review and revise, as necessary, the occupational dosimetry program to limit monitoring to only those individuals likely to be exposed to radiation.

Management Comments and Our Response

The DHA Director agreed with all recommendations and provided comments that address the specifics for four of the five recommendations. The four recommendations are resolved but will remain open until the DHA Director submits adequate documentation showing that all agreed-upon actions have been completed. However, the DHA Director did not provide comments that addressed the specifics for the recommendation to determine the benefits and feasibility of directly connecting the nuclear medicine information system to survey instruments at the medical facilities. Therefore, the recommendation is unresolved. We request that the DHA Director provide additional comments in response to the final report that resolve the recommendation.

 

This report is the product of Proj. No. D2019-D000AX-0183.000