Compliance · The complete guide

NRCNuclear Regulatory Commission

TL;DR

The Nuclear Regulatory Commission (NRC) is the independent US federal agency that licenses and regulates the civilian use of byproduct, source and special nuclear materials under the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974. For radiopharmacy and nuclear-medicine operations, NRC's 10 CFR Parts 19, 20, 30 and 35 govern licensee responsibilities, occupational and public dose limits, byproduct-material licensing, and medical use of byproduct material. In 39 "Agreement States" the equivalent state programme regulates instead — but to NRC-equivalent standards.

Reviewed · By V5 Ultimate compliance team· 3,200 words · ~15 min read

01What NRC does

NRC is an independent US federal agency with five Commissioners appointed by the President and confirmed by the Senate. It does not regulate the medical use of radiation per se — only the use of byproduct material (radioisotopes produced as a byproduct of nuclear-reactor operation, plus accelerator-produced and naturally occurring radioactive material since the 2005 Energy Policy Act). The FDA regulates the radiopharmaceutical as a drug; NRC regulates the radioactive material itself. Both regimes apply simultaneously to a radiopharmacy.

02Agreement States

Under Section 274 of the Atomic Energy Act, NRC can transfer regulatory authority for byproduct material to a state that adopts a programme "compatible" with NRC's rules. As of 2025, 39 US states are Agreement States. In those states the state radiation-control programme — not NRC directly — issues materials licenses, conducts inspections and enforces 10 CFR 20-equivalent rules. The substantive controls are equivalent; the inspecting body differs.

03Dose limits (10 CFR 20 Subpart C + D)

  • Occupational annual TEDE — 5 rem (50 mSv).
  • Occupational organ dose (except eye lens) — 50 rem (500 mSv).
  • Lens of the eye — 15 rem (150 mSv).
  • Shallow-dose to skin or extremity — 50 rem (500 mSv).
  • Declared-pregnant worker — 0.5 rem (5 mSv) gestation-period total to the embryo / fetus.
  • Minor — 0.5 rem (5 mSv) annual.
  • Public — 0.1 rem (1 mSv) annual TEDE (10 CFR 20.1301).
  • Effluent limits — Appendix B air + water concentrations.

ALARA (10 CFR 20.1003) requires operating below these limits to the extent reasonably achievable — administrative investigation + action levels are typically set at 10 % / 30 % of the limit.

04Medical use (10 CFR Part 35)

Part 35 is the rulebook for medical use of byproduct material — diagnostic imaging, unsealed therapy, sealed-source brachytherapy. Key requirements:

  • Authorised User (AU) — physician with the specified training + experience for each use (35.290 imaging, 35.390 oral I-131 therapy, 35.490 brachytherapy, 35.590 manual brachy, 35.690 remote afterloader, 35.490 / 35.990 written-directive-required therapy).
  • Authorised Nuclear Pharmacist (ANP) — for licensees with in-house compounding.
  • Radiation Safety Officer (RSO) — single named individual responsible for the radiation-protection programme.
  • Written directive — required for any administration of I-131 sodium iodide > 30 µCi, parenteral therapy, sealed-source therapy. Verified at the bedside against the patient identification before administration.
  • Medical event reporting — administration outside the written directive (dose ≥ 20 % off plan, wrong patient, wrong radionuclide, leaking sealed source) reported to NRC within 24 hours by phone + 15 days in writing per 35.3045.

05Materials licensing

  • Specific license — issued for a named licensee + named uses; default for medical and radiopharmacy operations.
  • General license — granted by rule to broad categories (e.g. sealed sources in measuring instruments); does not require an individual application.
  • Application via NRC Form 313 + supporting documentation: radiation-protection programme, RSO qualifications, facility diagrams, dose-calibration procedure, security plan for quantities of concern.
  • Initial license duration typically 5–10 years; renewal application due ≥ 30 days before expiry.

06Security of radioactive sources

Following 9/11, NRC issued increasing-controls orders, then codified them in 10 CFR Part 37 ("Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material"). Quantities of concern include Co-60, Cs-137, Ir-192, Sr-90, Am-241 above category thresholds; medical / industrial sealed-source users must implement access controls, monitoring, transport security and trustworthiness reviews of authorised individuals.

07Inspections + enforcement

Routine NRC (or Agreement State) inspections occur on a frequency-by-priority basis — typically every 1–5 years depending on programme complexity. Enforcement actions are graded:

  • Non-cited violation — minor, corrected; recorded but no formal Notice of Violation.
  • Notice of Violation (NOV) — formal, requires written response with corrective action.
  • Civil penalty — escalated fine for significant or wilful violations.
  • Order — modify, suspend or revoke license; immediately effective in serious cases.

Trends are published in the Enforcement Action and Significant Enforcement Actions databases on nrc.gov.

08NRC vs FDA boundaries

Easy to confuse, but the boundary is clean:

  • NRC — the radioactive material (its source, possession, use, transfer, disposal); the radiation-safety programme; occupational + public dose.
  • FDA — the drug product (identity, strength, quality, purity, sterility, GMP). 21 CFR 212 (PET CGMP), 21 CFR 211 (compounded radiopharmaceuticals under the 503A/503B framework), 21 CFR 200 series for IND / NDA / ANDA submissions.
  • DOT / IATA — packaging + transport of radioactive material (49 CFR Parts 171–180; IATA DGR).

09Common mistakes

  • Treating NRC and FDA as alternatives — both apply simultaneously to a radiopharmacy.
  • Operating in an Agreement State without registering with the state programme.
  • Written directive missing for therapy administrations.
  • Medical-event report missed for a > 20 % dose deviation.
  • Quarterly RSO ALARA review absent or undocumented.
  • Sealed-source leak test not performed at the prescribed frequency (typically 6 months).
  • Decommissioning funding plan absent for facilities holding sources above threshold.
  • DOT shipping papers not completed for radwaste transport.

10How V5 Ultimate handles NRC

Frequently asked questions

Q.Is NRC the only US regulator for radiopharmacy?+

No — FDA regulates the radiopharmaceutical as a drug (21 CFR 212 + 211), DOT/IATA regulates transport (49 CFR), the state radiation-control programme may regulate via Agreement-State status, and OSHA regulates workplace safety more broadly. All apply simultaneously.

Q.What's the difference between NRC and an Agreement State?+

Substantive controls are equivalent — Agreement States adopt rules "compatible" with NRC. The inspecting and licensing body differs (state programme vs NRC regional office).

Q.Does NRC license accelerator-produced isotopes?+

Yes — since the 2005 Energy Policy Act broadened the definition of byproduct material to include accelerator-produced radioactive material. F-18, Ga-68 and most PET tracers fall under NRC (or Agreement-State) jurisdiction.

Q.Who is the RSO?+

A single named individual responsible for the radiation-protection programme at the licensee. Qualifications + responsibilities are codified at 10 CFR 35.50. The RSO sign-off appears on the ALARA review, the medical-event report and the licence amendment record.

Q.Does V5 replace the customer's NRC licence application?+

No — V5 is not a substitute for the customer's licensed radiation-safety programme. It is the GMP / Part 11 / QMS record layer alongside that programme.

Primary sources

Further reading

Explore this topic

NRC sits inside 2 overlapping topic clusters in our glossary. Every neighbour is one click away.

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