Draft

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH

National Institute for Occupational Safety and Health

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

DCAS-PER-062, “ORAUT-OTIB-0052” 

Contract No. 211-2014-58081 

SCA-TR-2018-PR002, Revision 0 

Prepared by 

Kathleen Behling 

SC&A, Inc.

2200 Wilson Boulevard, Suite 300 

Arlington, VA 22201-3324 

Saliant, Inc.

5579 Catholic Church Road 

Jefferson, Maryland 21755 

May 2018 

DISCLAIMER 

This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical 

support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, 

draft or working documents are not final NIOSH or ABRWH products or positions, unless specifically 

marked as such. This document prepared by SC&A represents its preliminary evaluation on technical 

issues.

NOTICE: This document has been reviewed to identify and redact any information that is protected by 

the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 
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SC&A, INC.: Technical Support for the Advisory Board on Radiation and 

Worker Health Review of NIOSH Dose Reconstruction Program

DOCUMENT TITLE: A Review of NIOSH’s Program Evaluation Report DCAS-PER062, “ORAUT-OTIB-0052”

DOCUMENT NUMBER/

DESCRIPTION:

SCA-TR-2018-PR002 

REVISION NO.: 0 (Draft)

SUPERSEDES: N/A

EFFECTIVE DATE: May 31, 2018

TASK MANAGER Kathleen Behling [signature on file]

PROJECT MANAGER: John Stiver, MS, CHP [signature on file]

DOCUMENT 

REVIEWER(S): John Stiver, MS, CHP [signature on file]

Record of Revisions

Revision 

Number

Effective 

Date

Description of Revision

0 (Draft) 5/31/2018 Initial issue
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TABLE OF CONTENTS

Abbreviations and Acronyms ......................................................................................................... 4

1 Statement of Purpose ................................................................................................................ 5

2 Subtask 1: Identify the Circumstances that Necessitated DCAS-PER-062, “ORAUT-OTIB0052” ......................................................................................................................................... 7

2.1 Chronology of Events ...................................................................................................... 7

2.2 SC&A Comments ............................................................................................................ 9

3 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action ................................... 10

3.1 SC&A’s Comments and Findings .................................................................................. 11

4 Subtask 3: Evaluate the PER’s Stated Approach for Identifying the Number of Dose 

Reconstructions Requiring Reevaluation of Dose .................................................................. 12

4.2 SC&A’s Comments and Findings .................................................................................. 12

5 Subtask 4: Conduct Audits of a Sample Set of Dose Reconstructions Affected by 

DCAS-PER-062 ...................................................................................................................... 14

6 References ............................................................................................................................... 15
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ABBREVIATIONS AND ACRONYMS

Advisory Board or 

ABRWH Advisory Board on Radiation and Worker Health 

AMW all monitored workers 

CPWR Center to Protect Workers’ Rights

CTW construction trade worker

DCAS Department of Compensation Analysis and Support 

DOE U.S. Department of Energy 

DR dose reconstruction 

EE energy employee 

HPAREH Health Protection Annual Radiation Exposure History 

INL Idaho National Laboratory

MUD Master Update Dump

NIOSH National Institute for Occupational Safety and Health

NOCTS NIOSH OCAS Claimant Tracking System

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT technical information bulletin

PER program evaluation report 

POC probability of causation

REX Radiological Exposure (database)

SRS Savannah River Site 

TIB technical information bulletin
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1 STATEMENT OF PURPOSE

To support dose reconstruction (DR), the National Institute for Occupational Safety and Health 

(NIOSH) and the Oak Ridge Associated Universities Team (ORAUT) have assembled a large 

body of guidance documents, workbooks, computer codes, and tools. In recognition of the fact 

that all of these supporting elements in DR may be subject to revisions, provisions exist for 

evaluating the effect of such programmatic revisions on the outcome of previously completed 

DRs. Such revisions may be prompted by document revisions due to new information, 

misinterpretation of guidance, changes in policy, and/or programmatic improvements. 

The process for evaluating potential effects of programmatic changes on previously completed 

DRs has been proceduralized in OCAS-PR-008, Revision 2, Preparation of Program Evaluation 

Reports and Program Evaluation Plans, dated December 6, 2006 (NIOSH 2006b). This 

procedure describes the format and methodology to be employed in preparing a program 

evaluation report (PER) and a program evaluation plan. 

A PER provides a critical evaluation of the effects that a given issue or programmatic change 

may have on previously completed DRs. This includes a qualitative and quantitative assessment 

of potential effects. Most important in this assessment is the potential effect on the probability of 

causation (POC) of previously completed DRs with POCs <50%. 

During an Advisory Board on Radiation and Worker Health meeting on December 14, 2017, the 

Advisory Board tasked SC&A to conduct reviews of several PERs. Included among these PERs 

is DCAS-PER-062, ORAUT-OTIB-0052 (NIOSH 2017; hereafter “PER-062”). In conducting a 

PER review, SC&A is committed to perform the following five subtasks, each of which is 

discussed in this report:

• Subtask 1: Assess NIOSH’s evaluation and characterization of the “issue” and its 

potential effects on DR. Our assessment intends to ensure that the issue was fully 

understood and characterized in the PER.

• Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the 

PER involves a technical issue that is supported by documents (e.g., white papers, 

technical information bulletins [TIBs], procedures) that have not yet been subjected to a 

formal SC&A review, Subtask 2 will include a review of the scientific basis and/or 

sources of information to ensure the credibility of the corrective action and its 

consistency with current/consensus science. Conversely, if such technical documentation 

has been formalized and previously subjected to a review by SC&A, Subtask 2 will 

simply provide a brief summary conclusion of this review process.

• Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs, and assess the criteria by which a subset of potentially affected DRs was 

selected for reevaluation. The second step may have important implications in instances 

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s reevaluation is confined to a subset of DRs that, based on their scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness of the completion of the PER. 
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• Subtask 4: Conduct audits of DRs affected by the PER under review. The number of DRs 

selected for audit for a given PER will vary. (It is assumed that the selection of the DRs 

and the total number of DR audits for each PER will be made by the Advisory Board.) 

• Subtask 5: Prepare a written report that contains the results of the Subtask 4 DR audit, 

along with our review conclusions. 
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2 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED DCAS-PER-062, “ORAUT-OTIB-0052”

Construction trade workers (CTWs) who worked on new facility construction were not 

monitored because no radioactive materials were present before the facility was completed and 

had become operational. Thereafter, facility modifications and/or maintenance of major systems 

that now contained radioactive materials/contamination may have exposed CTWs, some of 

whom were not monitored for external and/or internal exposure. CTWs include (but are not 

limited to) laborers, mechanics, masons, carpenters, electricians, painters, pipefitters, 

boilermakers, millwrights, sheet-metal workers, ironworkers, insulators, etc.

To address the fact that some CTWs at various U.S. Department of Energy (DOE) sites were 

unmonitored, NIOSH issued ORAUT-OTIB-0052, Revision 00, Parameters to Consider When 

Processing Claims for Construction Trade Workers, on August 31, 2006 (NIOSH 2006a). The 

purpose of this TIB was to provide guidance for the reconstruction of exposure by means of 

“adjusted” site-specific coworker data to those CTWs who were either unmonitored or 

inadequately monitored. Guidance for the reconstruction of external penetrating dose for 

unmonitored CTWs involves the use of a 1.4 adjustment factor (i.e., multiplier) and the 95th

percentile of site-specific coworker dose, which was derived using dose data that compared 

CTW to all monitored workers (AMW) doses for six DOE sites.

2.1 CHRONOLOGY OF EVENTS

ORAUT-OTIB-0052, Revision 00 PC-1: On January 16, 2007, Sections 8.2 (guidance on the 

determination of penetrating dose for unmonitored CTWs), 8.3 (guidance on the determination of 

nonpenetrating dose for unmonitored CTWs), and 8.4 (guidance on the determination of internal

dose) were revised to provide consistent guidance for DR (NIOSH 2007a). 

SC&A Draft Review of ORAUT-OTIB-0052, Revision 00: At the September 19–21, 2006, 

Advisory Board meeting, SC&A was tasked with performing a review of ORAUT-OTIB-0052. 

SC&A’s review was submitted July 3, 2007 (SC&A 2007). As a result of this review, SC&A 

identified the following 16 findings (SC&A 2011): 

• Finding 1: ORAUT-OTIB-0052 does not address differences in doses received by 

different construction occupations. 

• Finding 2: The dose databases used are lacking significant data for the early operational 

years.

• Finding 3: The dose databases do not always identify who were CTWs, and for CTWs, 

what were their occupations. 

• Finding 4: NIOSH did not make modifications to the internal dose calculation 

methodology as they indicated to the Center to Protect Workers’ Rights (CPWR) that 

they would. 
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• Finding 5: Plutonium and/or uranium were used to compare internal CTW to AMW 

doses. What about other radionuclides?

• Finding 6: ORAUT-OTIB-0052 does not address how to determine CTW doses at sites 

that do not have a coworker model. 

• Finding 7: ORAUT-OTIB-0052 does not address how to determine neutron CTW doses. 

• Finding 8: All Savannah River Site (SRS) external doses are from the Health Protection 

Annual Radiation Exposure History (HPAREH). There needs to be an evaluation of other 

dose databases, e.g., Fayerweather, SRS-ABST.

• Finding 9: Evaluation is based on DOE annual exposure report. Needs to address the 

Master Update Dump (MUD) dose database for Idaho National Laboratory (INL). 

• Finding 10: For post-1974, the ratio of penetrating doses experienced by CTWs to other 

workers in ORAUT-OTIB-0052 does not agree with the INL epidemiologic study 

(NIOSH 2005), which indicates a correction factor closer to 2, and perhaps greater for 

some job types. 

• Finding 11: The claimant favorability of the ORAUT-OTIB-0052 approach for INL early 

period internal dose (to 1965) cannot be determined. 

• Finding 12: The Radiological Exposure (REX) dose database was not used. NIOSH 

needs to compare results based on the REX database to those given in ORAUT-OTIB0052. 

• Finding 13: The CTW doses need to be compared consistently to either AMW or 

non-CTWs. Currently, different sections perform different comparisons.

• Finding 14: The handling of “missing dose” needs to be consistent. Currently, some 

sections include “missing dose” while others do not. 

• Finding 15: ORAUT-OTIB-0052 does not give instructions for what to do if high or low 

cumulative exposures are suspected.

• Finding 16: Some construction occupations (e.g., pipefitters) receive exposures larger 

than the average CTW exposure. The average member of such groups may consistently 

receive external exposures above the 95th percentile, but possibly not by much. 

Occupational details in the data are not plentiful enough to define percentile value. 

OCAS-PER-014, Revision 0: NIOSH issued OCAS-PER-014, Revision 0, Construction Trades 

Workers, on November 28, 2007 (NIOSH 2007b), to evaluate CTW claims that had been 

adjudicated at DOE sites with existing external coworker studies prior to the issuance of 

ORAUT-OTIB-0052. As a result of this PER, 977 potentially affected claims were identified, 

which were reviewed to determine if they were affected by ORAUT-OTIB-0052 guidance. 
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ORAUT-OTIB-0052, Revision 01: On February 17, 2011, NIOSH issued Revision 01 of

ORAUT-OTIB-0052 (NIOSH 2011) to address five of the findings from SC&A’s review of 

Revision 00 PC-1. These changes provided clarification for the basis of certain assumptions and 

cautions regarding limitations of the data. 

SC&A’s Draft Review of ORAUT-OTIB-0052, Revision 01: SC&A’s review of ORAUT-OTIB0052, Revision 01, was issued on July 11, 2011 (SC&A 2011). As a result of many 

Subcommittee for Procedure Reviews meetings, 6 of the 16 findings identified in the review of 

ORAUT-OTIB-0052, Revision 00, were closed, 3 findings were transferred to the ORAUTOTIB-0020 review, 1 finding was in abeyance, and 6 findings remained in progress. The purpose 

of the report was to determine which of SC&A’s findings were addressed by ORAUT-OTIB0052, Revision 01, and to provide recommendations to the Subcommittee on the status of the 

remaining findings.

SC&A’s Draft Review of OCAS-PER-014, Revision 0: On March 16, 2012, SC&A issued its 

review of OCAS-PER-014 (SC&A 2012). The review of OCAS-PER-014 resulted in the 

identification of six findings. Three of the findings were identified as “conditional” because 

SC&A was unable to confirm data due to the lack of or restrictive access to information. One 

finding identified NIOSH’s failure to proceed with the evaluation of the 977 potentially affected

claims, and two findings related to unresolved issues from SC&A’s review of ORAUT-OTIB0052, Revision 00 (SC&A 2007).

ORAUT-OTIB-0052, Revision 02: NIOSH issued Revision 02 of ORAUT-OTIB-0052 on 

July 24, 2014, to add language to the Purpose, Scope, Section 7.0, and Section 8.0 to clarify 

applicability of the TIB to CTWs who could have worked for prime Management and Operations

contractors and DOE sites (NIOSH 2014).

DCAS-PER-062, Revision 0: NIOSH issued PER-062 on November 2, 2017 (NIOSH 2017), in 

response to the issuance of Revisions 01 and 02 of ORAUT-OTIB-0052 (NIOSH 2011, 2014). 

Both revisions to ORAUT-OTIB-0052 added language to clarify guidance for the DR of CTWs,

hence the need for this PER.

2.2 SC&A COMMENTS

SC&A reviewed each of the documents leading up to changes incorporated in Revision 01 and 

Revision 02 of ORAUT-OTIB-0052 (NIOSH 2011, 2014). Although no values were changed in 

the two revisions to ORAUT-OTIB-0052, guidance was added to clarify assumptions and 

provide more detail about who qualified as a CTW, as well as to add information about 

limitations of the data. SC&A agrees with NIOSH regarding these changes and their effects on 

CTWs that mandate the need for PER-062 (NIOSH 2017).

There are no findings pertaining to Subtask 1.
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3 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION

NIOSH’s plan for corrective action involved a two-step process, which included the 

identification of applicable sites and the assessment of the total population of potentially 

applicable cases, as discussed below. 

Establishing a List of Applicable Sites: NIOSH first identified a list of sites for which coworker 

data had been developed using monitored site workers (see Table 3-1). Those sites where a sitespecific PER is planned or where a PER had already been issued were excluded from 

consideration in PER-062. Sites that were included in this PER are identified as “Yes” in 

column 2 of Table 3-1. 

Table 3-1. NIOSH Applicable Site List

Site Included in PER-062

Ames Laboratory PER forthcoming

Albany Research Center PER forthcoming

Area IV – Santa Susana Field Laboratory PER forthcoming

Bridgeport Brass Company PER-061

Brookhaven National Laboratory PER forthcoming

Canoga Avenue Facility PER forthcoming

Clinton Engineering Works Yes

De Soto Avenue Facility PER forthcoming

Downey Facility PER forthcoming

Electro Metallurgical Company PER-068

Energy Technology Engineering Center (ETEC) PER forthcoming

Feed Materials Production Center (Fernald) PER forthcoming

Hanford PER forthcoming

K-25 (Oak Ridge Gaseous Diffusion Plant) PER forthcoming

Kansas City Plant Yes

Lake Ontario Ordnance Works Yes

Los Alamos National Laboratory PER forthcoming

X-10 (Oak Ridge National Laboratory) PER forthcoming

Paducah Gaseous Diffusion Plant PER-049

Portsmouth Gaseous Diffusion Plant PER forthcoming

Rocky Flats Plant PER forthcoming

Sandia National Laboratories – Albuquerque, NM Yes

Savannah River Site PER forthcoming

Y-12 Plant PER forthcoming

Extrusion Plant Yes

Nevada Test Site (1945-1957) Yes

Pacific Proving Grounds Yes

Pantex Plant PER forthcoming

Pinellas Plant PER forthcoming

United Nuclear Corp. PER forthcoming

Weldon Spring Plant Yes
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Determination of the Population of Claims: As shown in Table 3-1, eight sites were evaluated 

under PER-062. An assessment of claims from these eight sites resulted in NIOSH identifying a 

total of 2,486 cases that potentially required reevaluation using ORAUT-OTIB-052, Revision 02,

guidance.

3.1 SC&A’S COMMENTS AND FINDINGS

SC&A’s assessment of NIOSH’s methods for corrective action included a process to verify 

(1) all sites that have coworker models, (2) the total number of cases associated with the eight 

sites that are the subject of PER-062, and (3) the PERs listed in Table 3-1 were issued after 

Revision 02 of ORAUT-OTIB-0052 and included reevaluation of all claims less than 50% POC.

Coworker Models: SC&A reviewed the entire list of sites with covered employment under the 

Energy Employees Occupational Illness Compensation Program Act of 2000 to determine if a 

coworker model had been developed for the site. The SC&A-developed list was compared to 

those sites identified in Table 3-1. SC&A determined that NIOSH accurately captured all sites 

where coworker models have been developed using site-specific data. However, SC&A does 

have one observation regarding Table 3-1.

Observation 1: SC&A could not find documentation indicating that a coworker model is being 

developed or that a PER is forthcoming for Albany Research Center, which is listed in Table 3-1.

Total Number of Cases: Using the NIOSH OCAS Claimant Tracking System (NOCTS), SC&A 

was able to approximate NIOSH’s 2,486 total number of cases associated with the eight sites that 

are being reevaluated under PER-062.

PERs: SC&A reviewed the three PERs associated with Bridgeport Brass Company, Electro 

Metallurgical Company, and Paducah Gaseous Diffusion Plant listed in Table 3-1. Our review 

confirmed that the PERs had been issued after the ORAUT-OTIB-0052, Revision 02, effective 

date of July 24, 2014. Since the three PERs required the reevaluation of all cases with POCs 

<50%, the reworks would have included the most current ORAUT-OTIB-0052 guidance.

However, since SC&A cannot presently assess the forthcoming PERs for sites listed in 

Table 3-1, we recommend a follow-up action, as discussed in Observation 2.

Observation 2: To ensure that appropriate ORAUT-OTIB-0052 guidance is applied to all cases 

evaluated under planned PERs for the 20 sites listed in Table 3-1, SC&A should (1) maintain a 

list of these sites, (2) be informed when the PER is issued, and (3) review the PER to assess

whether the selection of reworked cases will adequately capture all potential CTWs.

SC&A has no findings about the methodology used by NIOSH for corrective action.

However, our review of NIOSH’s corrective actions did identify two observations.
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4 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DOSE RECONSTRUCTIONS 

REQUIRING REEVALUATION OF DOSE

As discussed in Subtask 2, NIOSH calculated a total population of 2,486 cases associated with 

eight sites. To determine if the energy employee (EE) from that population should have been 

classified as a CTW, NIOSH developed the following list of keywords: craft, iron, teamster, 

plast, maint, crane, boil, skill, pipe f, equip, engineer, radiographer, asbestos, rigger, sheet, metal, 

linem, ship, plumb, construction, machinist, insulator, weld, mason, tile, black, millw, heavy, 

electric, operating, cement, truck, paint, brick, laborer, pipef, and carp. NIOSH used these 

keywords to query the DR Reports and the NOCTS database to identify cases where any of the 

keywords were found. This process resulted in the identification of 1,438 cases that met the 

search criteria.

In addition, NIOSH conducted a text search on the DR Reports for all cases from all sites, except 

those already reworked under a separate PER as identified in Table 3-1, to determine if the site 

names for any the eight sites considered under PER-062 were mentioned. This search identified 

an additional 754 cases. Using the keywords above, NIOSH conducted a query on these 754 

cases. This query eliminated 223 cases, which brought the total population of CTW cases 

potentially requiring additional evaluation to 1,969 (1,438 + 531). 

Additional Reductions to the Population of CTW Claims: NIOSH then considered the following 

factors, which further reduced the number of CTW cases: 

• Duplicate cases (EE was listed at one site but another site on the list was mentioned) = 

169 cases

• POC greater than 50% = 260 cases 

• Cases in the process of a DR, which would use the current version of ORAUT-OTIB0052 = 23 cases 

• Cases compensated under a Special Exposure Cohort = 163 cases

• Nevada Test Site cases with employment starting after 1957 = 267 cases

• Clinton Engineering Works employment that did not include years 1948 or 1949 = 

22 cases

Considering these factors, the CTW population of 1,969 was reduced by 970 cases, leaving a 

total of 1,006 cases remaining that needed further evaluation. 

4.2 SC&A’S COMMENTS AND FINDINGS

SC&A reviewed the list of keywords used to define an EE as a CTW. SC&A determined that this 

list was thorough and adequately served to identify workers as CTWs.

SC&A does not have the ability to perform queries on the DR Reports. Based on personal

communications with David Allen of NIOSH, these queries were performed by the NIOSH 
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Information Technology Group and required 3 days to complete. Therefore, SC&A is not able to 

verify the final total number of cases that were subject to dose reevaluation. 

Therefore, SC&A’s assessment is limited to the methodology and criteria employed by NIOSH 

to identify those cases that are or were potentially affected by PER-062. Based on this restrictive 

assessment, SC&A concludes that the screening criteria used to identify potentially affected

claims are scientifically sound.

SC&A has no findings pertaining to the identification of claims that were affected by 

PER-062.
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5 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DOSE 

RECONSTRUCTIONS AFFECTED BY DCAS-PER-062

NIOSH evaluated the 1,006 cases to determine (1) if coworker doses were assigned, and (2) if 

so, whether the EE should have been considered a CTW. For those cases meeting both of these 

criteria, the DR was reviewed to assess whether the ORAUT-OTIB-0052 external dose 

correction factor 1.4 had been applied. If not, the dose was recalculated using Revision 02 of 

ORAUT-OTIB-0052, as well as other current revision of applicable documents.

Of the 1,006 cases, 1 case resulted in a recalculated POC greater than 52%, 992 had POCs below 

45% or no change, and 1 case resulted in a POC between 45% and 50%. Among the pool of 

1,006 DRs that are subject to audit, SC&A recommends the selection of the one case that 

resulted in a POC between 45% and 50% to satisfy its commitment under Subtask 4. 
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6 REFERENCES

NIOSH 2005. An Epidemiologic Study of Mortality and Radiation-Related Risk of Cancer 

Among Workers at the Idaho National Engineering and Environmental Laboratory, a U.S. 

Department of Energy Facility, M.K. Schubauer-Berigan, G.V. Macievic, D.F. Utterback, 

C.Y. Tseng, and J.T. Flora, U.S. Department of Health and Human Services, National Institute 

for Occupational Safety and Health, HHS (NIOSH) Publication No. 2005-131. January 2005.

NIOSH 2006a. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Revision 00, National Institute for Occupational Safety and 

Health, Cincinnati, OH. August 31, 2006.

NIOSH 2006b. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Revision 2, National Institute for Occupational Safety and Health, Cincinnati, 

OH. December 6, 2006.

NIOSH 2007a. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Revision 00 PC-1, National Institute for Occupational Safety and 

Health, Cincinnati, OH. January 16, 2007.

NIOSH 2007b. Construction Trades Workers, OCAS-PER-014, Revision 0, National Institute 

for Occupational Safety and Health, Cincinnati, OH. November 28, 2007.

NIOSH 2011. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Revision 01, National Institute for Occupational Safety and 

Health, Cincinnati, OH. February 17, 2011.

NIOSH 2014. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Revision 02, National Institute for Occupational Safety and 

Health, Cincinnati, OH. July 24, 2014.

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