November 30, 2017 

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 report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

ISSUES RESOLUTION MATRIX FOR ORAUT-OTIB-0020, 

“USE OF COWORKER DOSIMETRY DATA FOR EXTERNAL DOSE ASSIGNMENT” 

Finding 

Number Finding Description NIOSH Response Finding Resolution

1 The applicability of OTIB-0020 lacks clarity 

and prescriptive guidance. 

08/29/07: The context of OTIB-0020 must be 

taken into account as part of the overall 

procedures review process. This OTIB is a 

general use document describing the 

methodologies and technical considerations for 

subsequent OTIB documents addressing specific 

coworker data sets for a wide variety of DOE 

sites. Prescriptive guidance is found in the sitespecific coworker OTIBs. Regarding clarity, the 

purpose of the OTIB is stated clearly in 

Section 1.0: “This TIB is to be used in 

conjunction with separate TIBs or other 

approved documents that provide site-specific 

coworker data.” 

09/17/07: Each site-specific coworker TIB states 

the methods and results used to confirm that the 

coworker data (i.e., from a database) match the 

data found in hardcopy form (i.e., EEOICPA 

claimant records). Because of the wide variety of 

data formats and recordkeeping practices 

encountered from site to site, it would seem 

sensible to maintain the current approach of 

providing a description of data validation for 

each site TIB rather than formulating a general 

approach in OTIB-0020 that might prove 

unworkable for individual sites. 

10/02/07: SC&A and the SCPR found this 

explanation acceptable, and the SCPR closed 

the finding. 
Issues Resolution Matrix for OTIB-0020 2 SC&A – November 30, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Finding 

Number Finding Description NIOSH Response Finding Resolution

2 Side-stepping the use of OTIB-0020 and 

coworker data requires the dose reconstructor 

to make a quantitative determination of what 

corresponds to “reasonable” upper exposures 

that the unmonitored person may have 

received. 

08/29/07: Again, the context of the use of 

OTIB-0020 is critical. Use of coworker data is 

part of the hierarchy of data sources listed in 

IG-001 (Table 1.1) and PROC-0006 (Table 5.2). 

As a claim is processed using PROC-0006 (see 

Summary Figure 5.2), data other than coworker 

data may be needed to complete the claim. These 

types of data may be found in site profile 

documents or in documents available through the 

SRDB system. Use of these types of data to 

complete a claim with a POC <45% would entail 

a description in the DR report of the nature of 

the data with respect to the “reasonable upper 

limit” criteria. 

10/02/07: SC&A and the SCPR concurred 

with NIOSH’s explanation, and the SCPR 

closed the finding. 

3 The OTIB stipulates that site-specific 

coworker data may not be necessary for dose 

reconstruction and the dose reconstructor may 

select “reasonable upper limits, provided POC 

is less than 45%.” This places an unreasonable 

judgement decision on the dose reconstructor 

and may lead to inconsistencies.

08/29/07: NIOSH’s response was the same as for 

Finding 1, which, in summary, states that 

OTIB-0020 is a general use document and refers 

the dose reconstructor to prescriptive guidance 

found in the site-specific coworker OTIBs. 

10/02/07: SC&A and the SCPR concurred 

with NIOSH’s explanation, and the SCPR 

closed the finding. 
Issues Resolution Matrix for OTIB-0020 3 SC&A – November 30, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Finding 

Number Finding Description NIOSH Response Finding Resolution

4 The dose reconstructor is placed into a 

situation where “professional judgment” must 

be made, i.e., 50th or 90th percentile dose. It is 

SC&A’s opinion that data needed for these 

decisions are unlikely to be available to the 

dose reconstructor. 

08/29/07: Again, the context of the dose 

reconstruction process must be considered. Dose 

reconstruction staffs do not work in a vacuum. 

First, the DR staff will use PROC-0006 to 

evaluate the claim. Professional judgment used 

during claim processing is supported by 

information from the site profile documents (and 

authors), the coworker OTIBs, the available 

records from the site, SRDB documents, 

discussions with site lead DR staff, and 

interaction with the project principal 

dosimetrists. In addition, assumptions made 

regarding the choice of 50th or 95th percentile 

values must be peer reviewed by other DR staff 

as well as staff from OCAS. 

10/02/07: SC&A and the SCPR found this 

explanation acceptable, and the SCPR closed 

the finding. 

5 SC&A considers the 50th percentile constant 

value as one that is without scientific basis and 

not claimant favorable. 

08/29/07: The 50th percentile value is claimant 

favorable for certain types of energy employees 

as described in OTIB-0020. In addition to using 

the 50th percentile of measured dose, a claimantfavorable quantity of missed dose is also added 

to the 50th percentile dose (see Sections 6.0 and 

7.0 of OTIB-0020). It should be noted that a 

comparison of 50th percentile values for a given 

site (K-25) was conducted against values 

calculated using a maximum likelihood method. 

The results, as seen in Table 7-1 of OTIB-0020, 

show that the 50th percentile values consistently 

exceeded the maximum likelihood geometric 

mean values and generally exceeded the 

maximum likelihood 95th percentile values as 

well. 

10/02/07: SC&A and the SCPR found this 

explanation acceptable, and the SCPR closed 

the finding. 
Issues Resolution Matrix for OTIB-0020 4 SC&A – November 30, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Finding 

Number Finding Description NIOSH Response Finding Resolution

6 There are multiple elements described in the 

guidance/use of this OTIB that require the dose 

reconstructor to make subjective decisions or 

require information that is not likely to be 

available. 

08/29/07: The reviewer presupposes that 

information will not be available to make 

informed decisions. The variety of sources of 

information available to DR staff has been 

discussed in the previous responses. The 

assertion that DR staff cannot resolve complex 

issues in a consistent manner is not true. The 

project has additional staff resources, as 

described previously, to assist the DR staff with 

respect to judgments on individual DR claims. 

10/02/07: SC&A and the SCPR concurred 

with NIOSH’s explanation, and the SCPR 

closed the finding. 

PreReview 

of OTIB0020, 

Rev. 03

Because OTIB-0020 has been revised more 

than once since SC&A performed its original 

review, the Advisory Board at the July 31, 

2012, meeting tasked SC&A to perform a prereview to determine whether there were 

sufficient technical changes to OTIB-0020 to 

warrant a full review. On January 25, 2013, 

SC&A responded to the Subcommittee 

indicating that NIOSH has introduced two 

changes in the revisions to OTIB-0020: (1) the 

K-25 example coworker doses, which had been 

provided in Table 7-1, have been removed in 

response to a Quality of Science (10-year 

review) comment, and (2) the second 

paragraph of Section 3 was modified as agreed 

upon by the Subcommittee, NIOSH, and 

SC&A to address a finding made by SC&A’s 

review of ORAUT-OTIB-0052, Revision 00 

(i.e., Finding OTIB-0052-16). Neither of these 

changes are of a technical nature; thus, a full 

re-review is not required. 

N/A 07/18/13: The SCPR agreed with SC&A’s 

recommendation that a full review of 

OTIB-0020, Revision 03, was not warranted. 

The SCPR added a finding to the BRS 

indicating this decision and closed the 

finding. 

BRS = Board Review System; DOE = U.S. Department of Energy; DR = dose reconstruction; EEOICPA = Energy Employees Occupational Illness Compensation Program Act; 

OTIB, TIB = technical information bulletin; POC = probability of causation; SCPR = Subcommittee for Procedure Reviews; SRDB = Site Research Database