Procedures Review Finalization 

& Approval Process 

Meeting of the Advisory Board on Radiation and Worker 

Health

April 14, 2021

Josie Beach, Chair, Subcommittee for Procedure Reviews/ 

Kathy Behling, SC&A, Inc.
Current status of SCPR activities

• 35 active technical guidance documents:

• Reviewed by SC&A

• Discussed at SCPR meetings

• Findings/observations resolved and closed by SCPR

• Technical guidance documents not included in the 35 active 

documents:

• Documents reviewed but have since been cancelled

• Documents reviewed but have revisions that may need an 

additional review

• Document reviews with no findings

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Document finalization process

• Since 2018, document review finalization to include full Board 

approval

• Therefore, full Board review of 35 technical guidance 

documents is needed

• Current approach – SCPR makes a presentation to the Board 

summarizing:

• Document review findings/observations

• SCPR discussions

• Resolution of issues

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Alternative approach to finalizing document 

reviews

• SCPR will prepare an issue resolution matrix like those used 

by other Board work groups

• Matrix will include:

• Summary description of document reviewed

• Description of document review findings/observations

• Chronology of NIOSH, SC&A, and SCPR discussion to resolve issue

• Summary of final finding/observation resolution

• Matrix approach only for less complex documents with few 

findings/observations

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Issue resolution matrix for ORAUT-PROC-0022, 

rev. 00, “Supplemental requests for DOE 

information” 

• Procedure outlines method for requesting supplemental 

information about an energy employee from U.S. 

Department of Energy (DOE) sites

• Revision 00 issued 3/15/2005

• Revision 01 issued 8/24/2017

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Issue resolution matrix for ORAUT-PROC-0022, rev. 00, finding 1

Finding number 

(date)

Finding description NIOSH response Finding resolution

Finding 1

(6/8/2006)

Title and PROC 

number for Privacy 

Act procedure 

needs to be correct 

and consistent.

8/24/2007. Procedure is currently 

being revised. In the revision, the 

Privacy Act reference (ORAUTPROC-0079, “Protecting Personally 

Identifying Information (PII)”) will 

be fixed so that it is correct and 

consistent throughout the 

document.

10/31/2017. NIOSH revised this 

procedure and published rev. 01 

on 8/24/2017. References were 

corrected throughout the 

procedure.

11/20/2017. SCPR 

agreed to close 

finding.

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Issue resolution matrix for ORAUT-PROC-0022, rev. 00, finding 2

Finding number 

(date)

Finding description NIOSH response Finding resolution

Finding 2

(6/8/2006)

Procedure states 

that information 

should be 

requested from 

task 2, task 4, and 

task 5 and assumes 

that the reader is 

familiar with each 

task without 

providing the task 

function or 

description.

8/24/2007. Procedure is currently 

being revised. In the revision, 

references to various tasks within 

the ORAUT project organizational 

chart will be removed. 

10/31/2017. NIOSH published 

rev. 01 on 8/24/2017. All 

references to specific ORAUT 

project tasks were removed, as 

NIOSH and any ORAUT group can 

identify claims that need 

additional information and ask for 

supplemental request letters. 

11/20/2017. SCPR 

agreed to close 

finding.

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Issue resolution matrix for DCAS-PER-081, 

“Hooker Electrochemical”

• Program evaluation report (PER) determines effect of rev. 03 

to DCAS-TKBS-0009, the Hooker Electrochemical technical 

basis document (TBD)

• Hooker Electrochemical TBD, rev. 03 reviewed separately

• This review performed under SC&A’s subtask 4 protocols 

(case reviews)

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Issue resolution matrix for DCAS-PER-081, “Hooker 

Electrochemical,” observation 1

Observation 

number 

(date)

Observation 

description

NIOSH response Observation 

resolution

Observation 1

(10/9/2018)

In the original and 

reworked DR, NIOSH 

used the exposure 

skin dose conversion 

factors (DCFs) from 

OCAS-IG-001, rev. 3, 

instead of a skin DCF 

of 1.000 from ORAUTOTIB-0017

2/13/2019. During SCPR meeting, 

NIOSH explained that as Hooker 

external doses are based on 

MNCP modeled calculations, 

OCAS-IG-001 DCFs are used. If 

doses were based on film badge 

data, it is unclear whether the 

dose is from beta or some lowenergy photon. Therefore, the 

favorable approach is to apply 

OTIB-0017 DCFs.

11/20/2017. NIOSH’s 

explanation clarified 

SC&A’s concern, and 

the SCPR closed the 

observation.

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Issue resolution matrix for DCAS-PER-081, “Hooker 

Electrochemical,” observation 2

Observation 

number 

(date)

Observation 

description

NIOSH response Observation 

resolution

Observation 2

(10/9/2018)

Reworked internal 

dose assignment 

increased for the 

lymphatic tissue (as 

expected) but 

decreased slightly for 

the skin cancer sites.

2/13/2019. During SCPR meeting, 

NIOSH explained that the original 

DR was performed using 

overestimating assumptions and 

assessed lymphatic internal dose 

from type S solubility and skin 

dose using type M. The rework 

used best estimate protocol and 

used type S for all cancers.

11/20/2017. SC&A 

agreed with NIOSH’s 

explanation, and the 

SCPR closed the 

observation.

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Board followup to issue resolution matrix

• SCPR will distribute the issue resolution matrix to the Board 

members prior to full Board meeting

• Relevant documentation (e.g., SC&A’s review report, white 

papers, etc.) will be attached to document in Board Review 

System (BRS)

• Board members will have an opportunity to discuss closure 

of technical guidance documents included in matrix or 

request additional information at a full Board meeting

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Additional document finalization discussions: 

Presentations with no formal closeout

March 12, 2013

• ORAUT-OTIB-0052 

• ORAUT-OTIB-0070

• OCAS-IG-001 

July 17, 2013

• OCAS-TIB-0010

• ORAUT-OTIB-0023

October 17, 2013

• OCAS-PER-012

• ORAUT-OTIB-0010

November 6, 2014

• OCAS-PER-014

December 13, 2017

• ORAUT-OTIB-0020

• ORAUT-OTIB-0052

April 11, 2018 (closeout deferred 

awaiting NIOSH followup)

• ORAUT-OTIB-0017

• NIOSH-OVER-0009

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Summary discussions

• Does the Board agree with the matrix approach for closing 

out some SCPR-approved technical guidance documents?

• Does the matrix include sufficient information for the Board 

to act on approving review or opening additional issues?

• How do we handle closure of those documents previously 

presented to the Board that were not formally closed?

• Does the Board need to be provided an overview of 

documents reviewed by the SCPR with no findings 

identified?

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