Comment on FR Doc # 2026-09877, NRC-2025-1205-0001, from American Pharmacists Association (APhA) Radiopharmaceuticals Community
American Pharmacists Association (APhA) Radiopharmaceuticals CommunitySupportAdvocacy
Summary: The American Pharmacists Association (APhA) Radiopharmaceuticals Community supports the NRC's proposed rule to modernize byproduct material regulations, noting that the changes align with advances in nuclear medicine and reduce unnecessary regulatory burdens. They specifically advocate for the formal recognition of Authorized Nuclear Pharmacists (ANPs) as integral members of interprofessional nuclear medicine teams to enhance safety and efficiency.
On behalf of the American Pharmacists Association (APhA) Radiopharmaceuticals Community, representing nuclear pharmacists and radiopharmaceutical professionals dedicated to the safe management, preparation, handling, 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, "Modernizing NRC Regulations for Byproduct Material Use.”
By way of background, APhA began the process of identifying and recognizing specialty practices of pharmacy in 1971. This resulted in the formation of the APhA Board of Pharmaceutical Specialties (BPS). Nuclear pharmacy was recognized as the first specialty in 1978, as the BPS offered recognition of the Board Certified Nuclear Pharmacist (BCNP).
APhA’s Radiopharmaceuticals Community strongly supports the NRC's efforts to modernize regulations governing byproduct material while maintaining the agency's commitment to public health, radiation safety, and regulatory oversight. We recognize that many of the proposed changes are appropriate given the advances in nuclear medicine, radiopharmaceutical manufacturing, and pharmacy practice since the regulations were first developed.
See, attached .PDF for full comments.