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RAM Licensing & Regulatory

General requirements

Standing up an Ac-225 program is an exciting step that brings real operational obligations. Meeting the licensing, safety, facility, and staffing requirements is what makes the program safe for patients and staff — and what makes it auditable when the regulator visits.

Minimum requirements

To establish and operate a targeted alpha therapy program, an institution typically needs to meet baseline requirements across three pillars:

Licenses & protocols

  • Obtain (or amend) a specific RAM license for medical use covering Ac-225
  • Develop written procedures for receipt, handling, administration, decay, and waste
  • Document a written-directive workflow and recordkeeping per 10 CFR Part 35

Space & equipment

  • Designated hot lab, administration room, and post-administration restroom that meet regulatory standards
  • Alpha-capable survey instruments (ZnS scintillation) and a low-background alpha counter for wipes
  • Shielded transport, vial, and syringe equipment sized for daughter gammas (Bi-213)

Staff & training

  • Authorized User (AU) meeting NRC §35.390 (or alternate pathway) for parenteral administration with written directive
  • Authorized Medical Physicist (AMP) and qualified Radiation Safety Officer (RSO)
  • Trained nuclear medicine technologists, nursing, and patient-navigation support
Tip

Licensing tends to be the longest lead item. It can help to sequence the regulatory work first — in parallel with site selection — so a hot lab build doesn't outpace the license amendment.

The information in this section is intended to help practitioners build appropriate care pathways for patients receiving alpha-emitting radiopharmaceuticals. It does not establish a legal standard of care; institutions are responsible for complying with all applicable federal, state, and local requirements by establishing their own policies, procedures, and guidance.

Escalation

When to escalate on licensing & regulatory items

Regulatory decisions move slowly — but ambiguity should be surfaced early. Escalate the following without waiting for the next scheduled review.

  • Uncertainty on whether an amendment vs. new application is requiredRSO + regulatory counsel
  • Key-individual (AU / AMP / RSO / ANP) departure or long absenceRSO + department leadership
  • Notice of inspection, deficiency, or violation from NRC / Agreement StateRSO + institutional compliance
  • Scope-of-practice question on AU privileging for Ac-225AU + medical staff office