Submitted by Louise Fraser, Administration of Radioactive Substances Advisory Committee (ARSAC) UK Commenting on behalf of the organisation
Line 1917 - Update reference to the ARSAC Notes for Guidance 2023 https://www.gov.uk/government/publications/arsac-notes-for-guidance
Line 2832 - Update reference to the ARSAC DRL’s to the 2023 Notes for Guidance as above
Line 2832 - Recommend adding that the ARSAC Notes for Guidance are reviewed and updated annually - next publication due February 2024.
Line 2951 - Update reference to the ARSAC Notes for Guidance 2023 as above
Para 270 (from Line 2790) - This paragraph describes the approach to setting DRLs. In the UK, this methodology is used for setting DRLs in CT only. In nuclear medicine, a different approach is used and DRLs may be set based on the product marketing authorisation Summary of Product Characteristics (SmPC), on expert advice, published references or surveys. Recommend updating paragraph 270 to be clear that this refers to CT only.
Table 6.4 includes a copy of the values from Table 5.2 in the 2023 ARSAC Notes for guidance. There are now 2 additional procedures included by ARSAC – 18F-choline for parathyroid imaging and 18F- PSMA for prostate cancer imaging and it may be appropriate to include these here.
Radionuclide
Chemical form
Investigation
Route
of admin
DRL (MBq)
Activity by weight
(MBq/kg)
ED
(mSv)
Dose to uterus (mGy)
18F
PSMA
prostate cancer imaging
IV
280
4.0
6.2
N/A
18F
choline
parathyroid imaging
IV
300
3.0
6.0
4.5
Paragraph 276 (lines 2836-2845) talks about CT DRLs and includes values from France. The UK has a DRL for hybrid CT in PET as follows that may be appropriate to reference (https://www.gov.uk/government/publications/diagnostic-radiology-national-diagnostic-reference-levels-ndrls/ndrl#national-drls-for-computed-tomography)
Examination
Clinical indication
Scan region / technique
CTDIvol per sequence (mGy)
DLP per complete examination (mGy cm)
PET half body
attenuation correction and localisation of the nuclear medicine signal