Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

DRAFT REVIEW OF ORAUT-OTIB-0079: 

GUIDANCE ON ASSIGNING OCCUPATIONAL X-RAY DOSE UNDER 

EEOICPA FOR X-RAYS ADMINISTERED OFF SITE 

Contract No. 200-2009-28555 

SCA-TR-PR2013-0079, Revision 0 

Prepared by 

Harry Pettengill, PhD 

Stephen F. Marschke 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

January 2013 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date:

January 25, 2013

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of NIOSH Dose 

Reconstruction Program

Document No. 

SCA-TR-PR2013-0079

Effective Date: 

Draft – January 25, 2013

Revision No.

0 – Draft

DRAFT REVIEW OF ORAUT-OTIB-0079: 

GUIDANCE ON ASSIGNING OCCUPATIONAL 

X-RAY DOSE UNDER EEOICPA FOR X-RAYS 

ADMINISTERED OFF SITE

Page 2 of 11

Task Manager:

________________________ Date: ___________

Stephen F. Marschke

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver

Reviewers:

 Stephen Marschke

 John Stiver

 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 01/25/2013 Initial issue.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

TABLE OF CONTENTS

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

1.0 Introduction..........................................................................................................................5

1.1 Purpose of Technical Information Bulletin..............................................................5

2.0 ORAUT-OTIB-0079 Review...............................................................................................6

2.1 ORAUT-OTIB-0079 Review Checklist ..................................................................6

3.0 Conclusions........................................................................................................................10

References......................................................................................................................................11
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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ABBREVIATIONS AND ACRONYMS

ABRWH Advisory Board on Radiation and Worker Health

AWE Atomic Weapons Employer

CFR Code of Federal Regulations

DCAS Division of Compensation Analysis and Support

DOE (U.S.) Department of Energy

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000

IG Implementation Guideline

NIOSH National Institute for Occupational Safety and Health

ORAUT Oak Ridge Associated Universities Team

OTIB ORAUT Technical Information Bulletin

PIC pocket ionization chamber

SC&A S. Cohen and Associates (SC&A, Inc.)

TLD thermoluminescent dosimeter
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

1.0 INTRODUCTION

This review of ORAUT-OTIB-0079, Guidance on Assigning Occupational X-Ray Dose under 

EEOICPA [Energy Employees Occupational Illness Compensation Program Act of 2000] for 

X-rays Administered Off Site, Revision 00, dated January 3, 2011, was prepared by Harry 

Pettengill and Stephen Marschke.

1.1 PURPOSE OF TECHNICAL INFORMATION BULLETIN

The purpose of ORAUT-OTIB-0079 is stated as: 

EEOICPA requires the assignment of external dose from medical X-ray examinations 

performed for occupational health screening and required as a condition of employment. 

Many DOE/AWE sites had their own medical clinics and equipment to perform medical 

X-ray screening of their workers. Sometimes, however, the DOE/AWE sites contracted 

with private physicians’ offices, clinics, or local community hospitals to provide this 

service to workers.

A recent NIOSH interpretation of the EEOICPA statute affects how X-ray dose should be 

assigned when the X-rays were taken at a site or location that is not defined under the 

statute as a covered facility. This includes the scenario in which X-rays were taken at 

off site locations such as private physicians’ offices, clinics, or local community 

hospitals. The NIOSH interpretation is that the statute defines covered radiation as the 

radiation received by a covered employee at a covered facility during a covered time 

period ([NIOSH 2010]). Except in limited circumstances concerning residual radiation, 

only radiation that the employee received while at a covered facility can be included in 

dose reconstruction. Any site profiles stating or suggesting that off site medical 

screening doses will be included will be revised.

The NIOSH interpretation of which sources of radiation are to be included in dose 

reconstructions performed under EEOICPA is provided in DCAS-IG-003, Radiation Exposures 

Covered for Dose Reconstructions under Part B of the Energy Employees Occupational Illness 

Compensation Program Act (NIOSH 2010). SC&A has not been charged with reviewing 

DCAS-IG-003.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

2.0 ORAUT-OTIB-0079 REVIEW

OTIB-0079 states:

If it is known that occupational medical X-ray dose was received at a location 

other than a covered facility (i.e., an offsite physician’s office, clinic, or local 

community hospital), it shall not be included in dose reconstruction.

The basis for this statement is given as DCAS-IG-003, Radiation Exposures Covered for Dose 

Reconstructions under Part B of the Energy Employees Occupational Illness Compensation 

Program Act (NIOSH 2010), which states the following regarding occupational medical x-ray 

exposure:

At many DOE [and AWE] facilities, physical examinations were required as a 

condition of employment. Some of these examinations included the use of medical 

screening x-rays. In accordance with 42 C.F.R. pt. 81, external doses received 

from occupational x-ray screening procedures, which were provided to the energy 

employee as a condition of employment and were performed at a covered facility, 

are included in dose reconstructions. X-rays performed for diagnostic or 

therapeutic reasons, however, are excluded. Screening x-rays are systematic 

examinations performed on asymptomatic people without history, complaint, 

physical findings, or physician evaluation. Diagnostic x-rays are examinations of 

people who already have suspicious signs or symptoms of a potential condition 

performed after physician evaluation. (NIOSH 2010, Section 2.3)

SC&A recognizes that in our role as the Advisory Board’s technical support contractor, we do 

not comment on DCAS’ interpretations of EEOICPA, which would require legal rather than 

technical expertise. Additionally, DCAS’ interpretation of EEOICPA is not contained within 

OTIB-0079, the subject of this review; rather it is contained within DCAS-IG-003, which SC&A 

has not been requested to review. Based on the DCAS-IG-003 interpretation of EEOICPA, as 

articulated in OTIB-0079, SC&A has no technical findings for OTIB-0079.

2.1 ORAUT-OTIB-0079 REVIEW CHECKLIST

The approach used to perform our review of OTIB-0079 follows the SC&A procedures provided 

in SC&A 2009. In brief, SC&A identified seven objectives (including 26 sub-objectives) in its 

protocol to the Advisory Board, which form the basis for conducting the review. OTIB-0079 

was rated as to how well it met each sub-objective using a rating system of 1 through 5, 

corresponding to the following answers: 1=No (or Never), 2=Infrequently, 3=Sometimes, 

4=Frequently, 5=Yes (or Always).

For our review of OTIB-0079, the completed review checklist is provided as Table 2.1-1. As 

Table 2.1-1 shows, SC&A has given OTIB-0079 the highest rating in each applicable category, 

and has no technical comments.
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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Review Objective 1.4

ORAUT-OTIB-0079 contains a list of sites with known occurrences of occupational x-rays 

administered at locations other than the covered facility (i.e., OTIB-0079, Table 1), as well as a 

list of covered facilities that administered occupational x-rays on site, or for which no evidence 

exists that x-rays were taken off site (i.e., OTIB-0079, Table 2).

In order to determine that OTIB-0079 is “consistent with all other procedures that are part of the 

hierarchy of procedures employed by NIOSH for dose reconstruction” (i.e., Review Objective 

1.4), SC&A reviewed and confirmed the information provided in OTIB-0079 Tables 1 and 2 

against the information provided in the reference source documents.

Table 2.1-1: ORAUT-OTIB-0079 Review Checklist

Document No.: ORAUT-OTIB-0079 Effective Date: 01/03/2011

Document Title: Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-Rays 

Administered Off Site

Reviewer: Harry J. Pettengill / Stephen F. Marschke

No. Description of Objective Rating

1-5

* Comments

1.0 Determine the degree to which the procedure supports a process that is expeditious and timely for 

dose reconstruction.

1.1 Is the procedure written in a style that is clear and unambiguous? 5

1.2 Is the procedure written in a manner that presents the data in a logical 

sequence? 

N/A

1.3 Is the procedure complete in terms of required data? N/A

1.4 Is the procedure consistent with all other procedures that are part of the 

hierarchy of procedures employed by NIOSH for dose reconstruction?

5 See comments.

1.5 Is the procedure sufficiently prescriptive in order to minimize the need 

for subjective decisions and data interpretation?

5

2.0 Determine whether the procedure provides adequate guidance to be efficient in instances where a 

more detailed approach to dose reconstruction would not affect the outcome. 

2.1 Does the procedure provide adequate guidance for identifying a 

potentially high probability of causation as part of an initial dose 

evaluation of a claim?

5

2.2 Conversely, for claims with suspected cumulative low doses, does the 

procedure provide clear guidance in defining worst-case assumptions?

N/A
Effective Date:

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Table 2.1-1: ORAUT-OTIB-0079 Review Checklist

Document No.: ORAUT-OTIB-0079 Effective Date: 01/03/2011

Document Title: Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-Rays 

Administered Off Site

Reviewer: Harry J. Pettengill / Stephen F. Marschke

No. Description of Objective Rating

1-5

* Comments

3.0 Assess the extent to which the procedure accounts for all potential exposures and ensures that 

resultant doses are complete and based on adequate data in instances where the POC is not evidently 

clear.

3.1 Assess quality of data sought via interview: ----

3.1.1 Is scope of information sufficiently comprehensive? 5

3.1.2 Is the interview process sufficiently flexible to permit unforeseen 

lines of inquiry?

N/A

3.1.3 Does the interview process demonstrate objectivity and is it free of 

bias?

N/A

3.1.4 Is the interview process sensitive to the claimant? N/A

3.1.5 Does the interview process protect information as required under 

the Privacy Act?

N/A

3.2 Assess whether the procedure adequately addresses generic as well as 

site-specific data pertaining to: ----

3.2.1 Personal dosimeters (e.g., film, TLD, PICs) N/A

3.2.2 In vivo/In vitro bioassays N/A

3.2.3 Missing dosimetry data N/A

3.2.4 Unmonitored periods of exposure 5

4.0 Assess procedure for providing a consistent approach to dose reconstruction regardless of claimants’ 

exposures by time and employment locations. 

4.1 Does the procedure support a prescriptive approach to dose 

reconstruction?

5

4.2 Does the procedure adhere to the hierarchical process as defined in 

42 CFR 82.2?

5

5.0 Evaluate procedure with regard to fairness and giving the benefit of the doubt to the claimant. 

5.1 Is the procedure claimant favorable in instances of missing data? 5

5.2 Is the procedure claimant favorable in instances of unknown parameters 

effecting dose estimates?

5

5.3 Is the procedure claimant favorable in instances where claimant was not 

monitored?

5

6.0 Evaluate procedure for its ability to adequately account for the uncertainty of dose estimates. 

6.1 Does the procedure provide adequate guidance for selecting the types of 

probability distributions (i.e., normal, lognormal)?

N/A

6.2 Does the procedure give appropriate guidance in the use of random 

sampling in developing a final distribution?

N/A
Effective Date:

January 25, 2013

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

Table 2.1-1: ORAUT-OTIB-0079 Review Checklist

Document No.: ORAUT-OTIB-0079 Effective Date: 01/03/2011

Document Title: Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-Rays 

Administered Off Site

Reviewer: Harry J. Pettengill / Stephen F. Marschke

No. Description of Objective Rating

1-5

* Comments

7.0 Assess procedure for striking a balance between the need for technical precision and process 

efficiency. 

7.1 Does the procedure require levels of detail that can reasonably be 

accounted for by the dose reconstructor? 

N/A

7.2 Does the procedure avoid levels of detail that have only limited 

significance to the final dose estimate and its POC?

N/A

7.3 Does the procedure employ scientifically valid protocols for 

reconstructing doses?

N/A

______________________

* Rating System of 1 through 5 correspond to the following: 1=No (Never), 2=Infrequently, 

3=Sometimes, 4=Frequently, 5=Yes (Always). N/A indicates not applicable 
Effective Date:

January 25, 2013

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

3.0 CONCLUSIONS

As requested by the Advisory Board (through its Subcommittee on Procedures Review), SC&A 

has performed a review of ORAUT-OTIB-0079 in accordance with our review protocol (SC&A 

2009) and has identified no findings.
Effective Date:

January 25, 2013

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution.

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82.

REFERENCES

42 CFR 81, 2002. Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal

Register/Vol. 67, No. 85/Thursday, May 2, 2002.

NIOSH 2010. Radiation Exposures Covered for Dose Reconstructions under Part B of the 

Energy Employees Occupational Illness Compensation Program Act, DCAS-IG-003, Rev. 01. 

National Institute for Occupational Safety and Health, Division of Compensation Analysis and 

Support, Cincinnati, Ohio. October 5, 2010.

ORAUT 2011. Guidance on Assigning Occupational X-Ray Dose under EEOICPA for X-rays 

Administered Off Site, ORAUT-OTIB-0079, Rev. 00. Oak Ridge Associated Universities Team, 

Oak Ridge, Tennessee. January 3, 2011.

SC&A 2009. A Protocol for the Review of Procedures and Methods Employed by NIOSH for 

Dose Reconstruction, SCA-TR-PR2009-0001, Rev. 3. SC&A, Inc., Vienna, Virginia. 

November 16, 2009.