DRAFT 

ADVISORY BOARD ON RADIATION AND WORKER HEALTH 

NATIONAL INSTITUTE FOR 

OCCUPATIONAL SAFETY AND HEALTH 

A REVIEW OF NIOSH’S PROGRAM EVALUATION REPORT 

OCAS-PER-014, “CONSTRUCTION TRADES WORKERS” 

Contract No. 200-2009-28555 

SCA-TR-PR2012-0014, Rev. 0 

Prepared by 

U. Hans Behling, PhD, MPH 

SC&A, Inc. 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

March 2012 

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: 

March 16, 2012

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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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Document No. 

SCA-TR-PR2012-0014 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Effective Date: 

Draft – March 16, 2012 

A REVIEW OF NIOSH’S PROGRAM 

EVALUATION REPORT OCAS-PER-014, 

“CONSTRUCTION TRADES WORKERS” 

Page 2 of 21 

Task Manager: 

________________________ Date: ___________ 

U. Hans Behling, PhD, MPH 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 03/16/2012 Initial issue 
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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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TABLE OF CONTENTS 

 

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

1.0 Statement of Purpose ...........................................................................................................5 

2.0

........................................................................................................................................7 

Subtask 1: Identify the Circumstances that Necessitated the Need for OCAS-PER014

2.1 Development of ORAUT-OTIB-0052, Revision 00................................................7 

2.2 Relevant Conclusions Presented in ORAUT-OTIB-0052 .......................................9 

2.3

...................10 

SC&A’s Comments, Observations, and Findings Pertaining to ORAUTOTIB-0052 as the Principal Support Document for OCAS-PER-014

2.3.1 External Penetrating Dose Adjustment Factor...........................................10 

2.3.2 External Shallow Dose...............................................................................11 

2.3.3 Internal Dose..............................................................................................12 

3.0 Subtask 2: Assess NIOSH’s Specific Methods for Corrective Action .............................13 

3.1 Critical Elements that Define OCAS-PER-014 .....................................................13 

3.2

........................................................14 

SC&A’s Comments Regarding Corrective Actions Taken by NIOSH for 

Identifying Potentially Eligible CTW Claims

4.0

..................................................15 

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

Dose Reconstructions Requiring Re-Evaluation of Dose

4.1 SC&A’s Comments Regarding NIOSH’s Approach.............................................16 

5.0 Subtask 4: Conduct Audits of a Sample Set of DRs Affected by OCAS-PER-014 .........18 

6.0 Summary Conclusions.......................................................................................................19 

7.0 References..........................................................................................................................20 
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ABBREVIATIONS AND ACRONYMS 

Advisory Board Advisory Board on Radiation and Worker Health 

AMWs All Monitored Workers 

CTW Construction Trade Worker 

DOE U.S. Department of Energy 

DR Dose reconstruction 

dpm disintegrations per minute 

GSD geometric standard deviation 

INL Idaho National Laboratory 

mrem millirem 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH OCAS Claims Tracking System 

OCAS Office of Compensation Analysis and Support [now known as the Division 

of Compensation Analysis and Support (DCAS)] 

ORAUT Oak Ridge Associated Universities Team 

OTIB ORAUT Technical Information Bulletin 

PEP Program Evaluation Plan 

PER Program Evaluation Report 

PFG Photofluorography

POC or PC Probability of Causation 

SC&A S. Cohen and Associates 

SRS Savannah River Site 

TBD Technical Basis Document 
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1.0 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 impacts of programmatic changes on previously completed 

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

and Program Evaluation Plans (OCAS 2006), Revision 2, dated December 6, 2006. This 

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

Evaluation Report (PER) and a Program Evaluation Plan (PEP). 

A PER provides a critical evaluation of the effect(s) that a given issue/programmatic change may 

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

potential impacts. Most important in this assessment is the potential impact on the Probability of 

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

As needed, a PEP may be issued that serves as a formal notification of an impending PER. The 

PEP provides a preliminary description of the issue(s) that will be addressed in the PER, and 

summarizes the likely scope of the effort required to complete the PER. 

During an Advisory Board meeting on October 22, 2009, SC&A was tasked by the Advisory 

Board to conduct a review of OCAS-PER-014, Construction Trades Workers (OCAS 2007). 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/characterization of the “issue” and its potential impacts 

on dose reconstruction. 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 document(s) (e.g., white papers, technical 

information bulletins, 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 re-evaluation. The second step may have important implications in instances 
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NOTICE:

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

NIOSH’s re-evaluation 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 for the completion of the PER. 

Subtask 4: Conduct audits of DRs affected by the PER under review. Based on information 

contained in Table 2 (and discussed in Section 3.1 below), 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 per PER will be made by the Advisory Board.) 

Subtask 5: Prepare a comprehensive written report that contains the results of the above-stated 

subtasks, along with our review conclusions. 
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2.0 SUBTASK 1: IDENTIFY THE CIRCUMSTANCES THAT 

NECESSITATED THE NEED FOR OCAS-PER-014 

For new facility construction, most construction trade workers (CTWs) were not monitored since 

no radioactive materials were present before the facility was completed and had become 

operational. Thereafter, facility modification(s) and/or maintenance of major systems that now 

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

however, were not monitored for external and/or internal exposure. Construction trade workers 

include (but are not limited to) laborers, mechanics, masons, carpenters, electricians, painters, 

pipe-fitters, boilermakers, millwrights, sheet-metal workers, iron-workers, insulators, etc. 

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

unmonitored, NIOSH issued ORAUT-OTIB-0052 (ORAUT 2006), Revision 00 (Technical 

Information Bulletin: Parameters to Consider When Processing Claims for Construction Trade 

Workers) on August 31, 2006, in order 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. 

2.1 DEVELOPMENT OF ORAUT-OTIB-0052, REVISION 00 

Because it was recognized that radiation exposures of CTWs may be different from other 

radiation workers and that the conventional use of assigning coworker dose(s) to unmonitored

CTWs may not be claimant favorable, NIOSH sought empirical data that would assess the ratio 

of external and internal doses received by monitored CTWs to all monitored workers (AMWs). 

External Dose Ratios. NIOSH identified seven major DOE sites [Savannah River Site (SRS), 

Rocky Flats, Y-12, K-25, X-10, Idaho National Laboratory (INL), and Hanford], where major 

construction activities took place and where exposures for monitored CTWs could be extracted 

from databases representing AMWs. Using the 95th percentile doses for CTWs and AMWs, dose 

and/or dose ratios (i.e., CTWs/AMWs) were derived by year for deep dose and shallow dose 

exposure for five of the seven sites, while for INL and Hanford, dose ratios were defined for 

average dose values. 

Internal Dose Ratios. As a rule, the inclusion of workers in a routine bioassay program is based 

on the likely potential for intake of radioactive material. Consequently, routine internal 

monitoring of workers is more selective and, therefore, involves fewer workers than those 

monitored for external exposures. Moreover, bioassays frequently focus on select radionuclides 

that may dominate concerns of internal exposure. 

To assess potential differences in internal exposures between CTWs and AMWs, NIOSH 

assessed urine bioassay data for uranium and plutonium. Annual ratios of excretion rates 

(defined in units of dpm/day at the 50th and 84th percentile) were derived for five of the seven 

sites (no data were available for INL and only limited data were available for SRS). 

Site-specific external and internal data that contrasted CTW and AMW exposures were presented 

in a series of figures. For those years during which the observed external deep dose ratios 
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(CTWs/AMWs) equaled or exceeded the value of 1.3, NIOSH provided a companion table that 

quantified the 95th percentile values for each group along with the total number of persons 

monitored with and without measurable dose. 

For illustration, Figure 5-2 of OTIB-0052, shown below as Exhibit #1, represents annual external 

deep dose exposure data for SRS between 1953 and 1999; and Table 5-1 of OTIB-0052 (Table 1 

below) identifies those years when the 95th percentile deep dose among CTWs exceeded those of 

AMWs by a factor greater than 1.2. 

Exhibit #1: 95th Percentile Penetrating Dose for Savannah River Site 

 Source: ORAUT-OTIB-0052, Figure 5-1

Table 1. Observed Ratios for SRS CTWs AMWs 

Year Number

monitored

Number with 

measurable dose

95th percentile 

dose (mrem)

Number

monitored

Number with 

measurable dose

95th percentile 

dose (mrem)

Observed ratios

(CTWs/AMWs)

1962 259 236 1696 3371 3101 1337 1.3 

1989 2408 1818 218 15517 8749 170 1.3 

1990 2440 1567 190 18494 8503 150 1.3 

1991 2202 1104 120 18630 6468 85 1.4 

1992 1902 792 95 17780 5016 70 1.4 

1997 949 317 83 11344 2410 55 1.5 

1998 870 280 71 10750 2210 54 1.3 

1999 785 240 62 10365 2159 49 1.3 

 Source: ORAUT-OTIB-0052, Table 5-1 
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2.2 RELEVANT CONCLUSIONS PRESENTED IN ORAUT-OTIB-0052 

On August 31, 2006, NIOSH issued ORAUT-OTIB-0052, Revision 00, for the purpose of 

providing the basis and guidance for performing DRs for unmonitored CTWs. 

On the basis of study data obtained in behalf of OTIB-0052, NIOSH stated the following 

conclusions and guidance, as given in Section 7.0 of OTIB-0052: 

 For External Deep Dose: 

. . . the dose received by monitored CTWs was usually bounded by the dose 

received by AMWs on the same site.

This relationship between the doses received by CTWs and AMWs can be 

combined with the premise that the nature of the construction work (e.g., 

carpentry, masonry, pipe-fitting, etc.) performed by unmonitored CTWs was not

significantly different (from a radiation protection perspective) than the 

construction work activity performed by monitored CTWs. Doses to monitored 

CTWs can therefore serve as an acceptable surrogate for doses to unmonitored 

CTWs. [Emphasis added.] 

 An analysis of the specific DOE sites identified specific years that CTWs’ [deep]

doses exceeded AMWs doses. To address these instances, an adjustment factor is 

needed. [Emphasis added.] 

The values for pre-1961 adjustment factors range from 1.3 to 1.4. 

The maximum value of 1.4 was selected as the prescribed favorable to claimant 

external dose adjustment factor (i.e., dose multiplier) for all DOE facilities for all 

years. [Emphasis added.] 

The application of the conclusions and adjustment factors derived in this 

document are limited to dose reconstructions for unmonitored construction 

workers at sites with applicable coworker data . . . [Emphasis added.] 

 For Non-penetrating Dose 

 

Based on the comparison of data that showed that CTWs doses were adequately bounded 

by AMWs’ doses, Section 8.3 of OTIB-0052 recommends the use of the 95th percentile 

non-penetrating dose of the site-specific coworker study: 

. . . for those CTWs whose dose history is either unavailable or incomplete unless 

there is compelling evidence to use another coworker percentile value. 

. . . Dose reconstuctors should not apply any adjustment factors for nonpenetrating dose. [Emphasis added.] 
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 For Internal Dose

 Section 8.4 of OTIB-0052 provides the following guidance for assigning internal dose to 

unmonitored CTWs: 

For Hanford dose reconstructions covered by this OTIB, the intake rates in the 

Hanford coworker document should be multiplied by a factor of two. 

For all other sites, the internal dose should be determined using the same method 

that is applied to all other workers. If coworker data studies are available for a 

site, the 50th percentile should be used with the appropriate GSD unless there is 

compelling evidence to use another coworker percentile value. 

 For Occupational Medical Dose

 Section 8.5 of OTIB-0052 provides the following guidance: 

If there are X-ray records in the file, the dose reconstructor should use the 

Technical Basis Document (TBD) for the site where the worker performed the 

work 

For sites where “X-ray records do not exist” is indicated and there are in fact no 

X-ray records in the file or for sites that are not currently including X-ray 

records, such as Y-12 and INL, the dose reconstructor should use the TBD for the 

site where the worker performed the work to assign the frequency or X-ray 

procedures that are clearly not a result of work-related injury. However, since 

these procedures may have been performed off-site, the assigned organ doses 

should come from Dose Reconstruction from Occupationally Related Diagnostic 

X-Ray Procedures (ORAUT 2005j). All X-ray procedures in this category should 

be assumed to be standard X-rays (not PFG) since PFG was an X-ray technique 

suitable to screening large groups of people at one time. Assuming the X-rays 

were performed off-site at a local clinic or hospital, it is unlikely that this 

screening occurred en masse with PFG. 

2.3 SC&A’S COMMENTS, OBSERVATIONS, AND FINDINGS PERTAINING TO 

ORAUT-OTIB-0052 AS THE PRINCIPAL SUPPORT DOCUMENT FOR OCASPER-014 

2.3.1 External Penetrating Dose Adjustment Factor 

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, site-specific coworker 

dose. Based on dose data that compared CTW to AMW doses for six DOE sites, NIOSH’s 

selection of the 1.4 adjustment factor for all DOE facilities and for all years appears to be 

conservative and claimant favorable. 
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At this time, SC&A has neither been given access to the original dose data nor an explanation 

that would indicate whether the annual doses for CTWs and AMWs were scaled to reflect 

exposure/employment duration in any given year. Unlike “all monitored workers” who mostly 

represent full-time employees/workers at a site, CTWs are more likely to be hired on an asneeded basis and for restrictive time periods that may represent a small fraction(s) of a given 

year. 

Finding #1 (Conditional): The Deep-Dose Adjustment Factor of 1.4 May Not be Claimant 

Favorable. In the event that annual doses for CTWs (and to a lesser extent for AMWs) were not 

adjusted to account for exposure/employment periods of less than a full year, the recommended 

deep-dose adjustment factor of 1.4 may not be claimant favorable. 

Finding #2 (Conditional): The Inclusion of CTWs Among AMWs May Obscure Dose 

Differences. As stated in Section 4.0 of OTIB-0052, “. . . Sometimes the AMW group includes

the CTWs and in others it did not.” However, the OTIB does not identify which data sets (i.e., 

external deep dose, shallow dose, and/or bioassay data sets) failed to separate CTW from AMW 

data. 

A review of external data contained in Tables 5-1, 5-2, 5-3, 5-4, and 6-1 of OTIB-0052 identifies 

the following: 

(1) The number of monitored CTWs relative to AMWs represents a substantial fraction of 

AMWs. 

(2) A ratio of “number monitored” to “number with measurable dose” among CTWs is 

consistently lower than those for AMWs. 

The inclusion of CTWs among AMWs, therefore, obscures the true ratios of CWTs/AMWs in 

instances where AMWs represent a combination of CTWs and non-CTWs. 

2.3.2 External Shallow Dose 

Only two of the eight DOE sites (i.e., SRS and Rocky Flats) provided annualized shallow dose 

data for deriving CTWs/AMWs dose ratios. According to NIOSH, these limited data, 

nevertheless, suggest that AMW doses consistently bounded CTW doses and obviate the need 

for an adjustment factor. 

Finding #3 (Conditional): A Shallow-Dose Adjustment Factor May be Required. Annual 

shallow doses (like penetrating doses) received by CTWs may, nevertheless, have been 

understated in the event that NIOSH failed to adjust CTW shallow doses to account for 

employment/exposure periods of less than 1 year as was cited in Findings 1 and 2 above for 

penetrating dose assessment. 

If Finding #1 holds and there are significant differences in exposure times between CTWs and 

AMWs in any given year, an adjustment factor may be required for the reconstruction of shallow 

dose for CTWs. 
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NOTICE:

2.3.3 Internal Dose 

Section 8.4 of OTIB-0052 provides guidance for internal DR in behalf of the following three 

conditions: 

(1) For Hanford DRs, coworker intake rates should be multiplied by a factor of two. 

(2) For all other sites, the internal dose should be determined using the same method that is 

applied to all other workers. 

(3) If coworker data studies are available for a site, the 50th percentile should be used with 

the appropriate geometric standard deviation (GSD). 

Finding #4: Guidance for Internal Dose. Guidance for the reconstruction of dose in behalf of 

Condition 2, as stated above, is incomplete/confusing. The Executive Summary of OTIB-0052 

states that “. . . This document provides guidance for performing DRs for unmonitored 

construction trade workers (CTWs).” In the absence of (1) internal monitoring data for the CTW 

and (2) coworker data, it is unclear what is meant by the recommendation “. . . the internal dose 

should be determined using the same method that is applied to all other workers.” 
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3.0 SUBTASK 2: ASSESS NIOSH’S SPECIFIC METHODS FOR 

CORRECTIVE ACTION 

3.1 CRITICAL ELEMENTS THAT DEFINE OCAS-PER-014 

OCAS-PER-014, Revision 0, was issued on November 28, 2007, and provides the following 

information and criteria in order to address DR of CTWs: 

 From Section 1.0: Description

. . . To address this issue, ORAUT-OTIB-0052 . . . was issued on 8/31/2006 to 

provide guidance on assessing exposure to CTWs with inadequate monitoring 

(either internal or external). [Emphasis added.] 

 From Section 2.0: Issue Evaluation

. . . This document [ORAUT-OTIB-0052] multiplies by 1.4 the external dose 

determined from a co-worker study. At Hanford, the internal dose is also 

adjusted by using a 2.0 multiplier on the monitored worker’s internal intakes. 

 . . . The sites that had external co-worker studies issued prior to 8/31/2006, and 

must be evaluated under this PER, are listed in the table below. [Emphasis 

added.] 

Table 2. DOE Sites with an External Coworker Model Issued Prior to August 31, 2006 that 

Must Be Evaluated Under PER-014 

First published coworker Site Date Document 

Hanford 3/23/2005 ORAUT-OTIB-0030 

Pacific Northwest National Laboratory 3/23/2005 ORAUT-OTIB-0030 

Kansas City Plant 5/31/2005 ORAUT-TKBS-0031 

Los Alamos National Laboratory 5/10/2005 ORAUT-TKBS-0010-6 

Pantex Plant 7/27/2006 ORAUT-TKBS-0013-6 

Portsmouth Gaseous Diffusion Plant 7/29/2005 ORAUT-OTIB-0040 

Savannah River Site 5/31/2005 ORAUT-OTIB-0032 

Weldon Spring Plant 6/24/2005 ORAUT-TKBS-0028-6 

Oak Ridge National Laboratory (X-10) 12/29/2004 ORAUT-OTIB-0021 

Y-12 Plant 9/9/2004 ORAUT-OTIB-0013 

 Source: OCAS-PER-014 
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NOTICE:

 From Section 3.0: Plan for Resolution or Corrective Action

A search of the claims from the sites in the table above was conducted to 

determine which claims may be those of Construction Trades Workers. The 

NOCTS Job Title, as well as the original dose reconstruction report, was 

searched for any of the key words listed in appendix A. . . . Only those claims 

with a probability of causation (PC) less than 50%, that are currently at the 

Department of Labor and whose dose reconstruction was approved prior to 

8/31/2007 were included. 

These search criteria resulted in 977 potentially affected claims being selected. 

[Emphasis added.] 

3.2 SC&A’S COMMENTS REGARDING CORRECTIVE ACTIONS TAKEN BY

NIOSH FOR IDENTIFYING POTENTIALLY ELIGIBLE CTW CLAIMS 

Critical to the successful implementation of OCAS-PER-014 is the accurate/complete 

identification of all workers that may have been exposed as a member of a construction trade. 

Search criteria for the NOCTS database and DR Reports, as cited in Attachment A of OCASPER-014, included 31 different construction trades. 

Given the types of facilities that define DOE sites, the spectrum of construction trades identified 

in Attachment A appear to be sufficiently inclusive/complete for the purpose of screening CTW 

claimants that may be affected by OCAS-PER-014. SC&A, therefore, agrees with the 

methodology used by NIOSH to identify the 977 potentially affected claims.
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4.0 SUBTASK 3: EVALUATE THE PER’S STATED APPROACH FOR 

IDENTIFYING THE NUMBER OF DOSE RECONSTRUCTIONS 

REQUIRING RE-EVALUATION OF DOSE 

The 977 potentially affected claims with POC values less than 50% will be evaluated by NIOSH 

in order to identify those claims for which the impact of OTIB-0052 will raise their POC value to 

a revised level that mandates a new DR. NIOSH intends to use the following criteria: 

 (1) Verify that the claim is a CTW since the “key word search method” (that identified the 

977 claims) could not verify the proper context of the key words and it is possible that 

some of the 977 claims should not have been included as a CTW claim. 

 (2) “Review the external dose of the claim. If no external coworker dose was assigned 

(and internal for Hanford), there is no OITB-0052 adjustment to be made and no 

need for further evaluation.” [Emphasis added.] 

 (3) Due to NIOSH’s existing policy that a POC ≥45% requires 30 IREP runs with 10,000 

iterations per run, the 977 potential claims will be screened based on the ability of OTIB0052 to raise the original POC value to a revised POC value of ≥45%. 

 (4) Given that OTIB-0052 would increase the external dose by a factor of 1.4 (and for 

Hanford, also increase the internal dose by 2.0 fold), it is clear that only a subset of the 

977 potentially affected claims will require a new DR using the equation PC = [ERR/(1 + 

ERR)]100. NIOSH determined that OTIB-0052 cannot raise the POC to 45% if the 

original POC was ≤36.8% for nine facilities in Table 2 above and ≤29.0% for Hanford. 

 (5) Identify the original POC value of the claim and determine if it meets the above-cited 

trigger value of 36.8% (or 29% for Hanford CTW claims). 

– For a POC value greater than or equal to the trigger value, a new DR is necessary. 

 – For a POC value less than the trigger value, determine if there are any other 

PERs that may affect the claim and assess the need for a new DR. 

Finding #5: OCAS-PER-014 is Incomplete. The extent to which NIOSH has screened and 

evaluated the universe of the 977 claims by means of the above-cited criteria was not discussed 

in OCAS-PER-014. As such, NIOSH has not identified the actual number of CTW claims (from 

among the 977 claims) that are eligible for the PER’s dose adjustment factor(s) and, therefore, a 

new DR. In Section 3.0 of OCAS-PER-014, NIOSH only provided the following information: 

NIOSH will provide DOL with the list of 977 claims, as well as a determination 

on each claim as to whether a new dose estimate is required. Documentation, 

that includes a dispositive statement which explains the basis as to why each 

claim was or was not determined to require a new dose reconstruction, will be 

provided to DOL and included in each case file. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

4.1 SC&A’S COMMENTS REGARDING NIOSH’S APPROACH 

SC&A believes that the key word search method (which identified a total of 977 claims) 

provides a valid starting point for defining the universe of CTW claims that potentially may be 

impacted by OTIB-0052. 

SC&A further agrees with the derived POC values of 38.6% and 29% as trigger values for 

selecting only those claims among the universe of 977 claims that have the potential of 

exceeding a POC value of 45% and must, therefore, be re-evaluated by means of a new DR. 

SC&A, however, has concerns regarding NIOSH’s screening criteria #1 of CTW claims, as 

stated on page 4 of PER-014 (and quoted herein on page 14 above): 

External Co-Worker dose assigned. If no external co-worker dose was assigned 

(also internal at Hanford), there is no OTIB-0052 adjustment to be made and the 

claim is not affected by OTIB-0052. [Emphasis added.] 

While the above stated criterion is consistent with the stated but limited objective defined in 

OTIB-0052 and PER-014, the requirement for a CTW claim to have an “assigned external 

coworker dose (also internal at Hanford),” may represent a potentially generic deficiency for 

CTWs that goes beyond the scope of OCAS-PER-014, as explained below. 

A review of Table 2 above identifies the dates-of-issue of the first published coworker data sets 

for each of the 10 DOE sites covered under PER-014. Issue dates of the coworker study data 

range from September 9, 2004 (for Y-12), to as recently as July 27, 2006 (for Pantex). SC&A’s 

concern involves those CTW claims with the following attributes: 

 Claims representing CTWs who were unmonitored or inadequately monitored and whose 

DR was adjudicated before the issue date of the site-specific external coworker (as well 

as the internal coworker) model. 

 For CTW claims completed/adjudicated before the issuance of a coworker model(s), DR 

for the unmonitored CTW would have been limited to environmental dose and possible 

medical dose with resultant POC values that would likely be well below the trigger PC 

values of 38.6% (and 29% for Hanford) and, therefore, be excluded from further 

consideration. 

 Even for those CTW claims that exceed the POC trigger value, the absence of an 

assigned coworker dose excludes the eligibility of these claims for a new DR. 

At the writing of this review, SC&A is neither aware of any past effort by NIOSH that would 

have identified and assigned coworker doses to those CTW claims that had been adjudicated 

before their respective site-specific coworker model had been issued in order to make them 

eligible for evaluation under OCAS-PER-014; nor is SC&A aware of a future effort to do so. 
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NOTICE:

If SC&A is correct in both assumptions, a potentially substantial number of the 977 will (1) have 

an incomplete DR and (2) be excluded from a revised DR, as provided by selection criteria cited 

in OCAS-PER-014. 

Finding #6 (Conditional): OCAS-PER-014, Revision 00, May Be Highly Restrictive in 

Addressing the Problem of Unmonitored Construction Trade Workers. At this time, there is 

uncertainty about the fate of CTW claims that had been adjudicated before the issuance of a 

coworker model. This conditional finding is based on the following statement in Section 2.0 of 

OCAS-PER-014: 

 A number of DOE sites did not yet have an external co-worker study published 

when OTIB-0052 was issued. Since dose reconstructions for claims at these sites 

completed prior to the issuance of OTIB-0052 could not have used external coworker values, there is no change to these claims as a result of the issuance of 

OTIB-0052. . . . [Emphasis added.] 
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5.0 SUBTASK 4: CONDUCT AUDITS OF A SAMPLE SET OF DRS 

AFFECTED BY OCAS-PER-014 

At the writing of this review, SC&A has not been provided any information as to whether 

NIOSH has even proceeded to evaluate the 977 claims in order to determine which of these 

claims are affected by OCAS-PER-014 and require a new dose estimate. 

Thus, the selection of a sample set of DRs for audit cannot proceed until NIOSH provides the 

Advisory Board’s DR Subcommittee with a list of DRs that were affected by OCAS-PER-014 

and for which new doses were derived. Once the aforementioned list of claims with 

reconstructed doses has been made available to the Subcommittee, SC&A recommends selection 

of 10 DRs (one DR from each of the 10 DOE sites listed in Table 2) for SC&A’s audit. 
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6.0 SUMMARY CONCLUSIONS 

In our review of OCAS-PER-014, SC&A identified a total of six findings, three of which are 

cited as “conditional.” These findings reflect a lack of or restrictive access to information; 

NIOSH’s failure to proceed with the evaluation of the 977 CTW claims; and most importantly, 

issues/findings related to ORAUT-OTIB-0052, Rev. 00, which to date remain unresolved. 

Since OTIB-0052 provides guidance for performing DRs for unmonitored CTWs and thereby 

serves as the technical basis for the implementation of OCAS-PER-014, the following historical 

facts should be noted: 

(1) Revision 00 of OTIB-0052 was first reviewed by SC&A in July 2007. A total of 16 

findings were identified and discussed in a series of Work Group meetings without full 

resolution. 

(2) On February 17, 2011, NIOSH issued Revision 01 of OTIB-0052 with changes that were 

to address the 16 findings. 

(3) Revision 01 of OTIB-0052 was again critically reviewed by SC&A in a report submitted 

in July 2011. In this report, SC&A identified (1) the status of the 16 findings against 

OTIB-0052 prior to Revision 01; (2) the recommended status of each finding following 

Revision 01 of OTIB-0052; and (3) the status of other OTIBs that support OTIB-0052. 

Table 3 provides a historical summary of findings associated with OTIB-0052. 

Table 3. Status of Historical Findings Associated with OTIB-0052 

Finding Status Prior to Revision 1 Recommended Status After Revision 1 

OTIB-0052-01: Transferred to Issue OTIB-0052-16 Transferred to ORAUT-OTIB-0020 

OTIB-0052-02: Closed Closed 

OTIB-0052-03: Closed Closed 

OTIB-0052-04: Closed Closed 

OTIB-0052-05: In Progress Closed 

OTIB-0052-06: Closed Closed 

OTIB-0052-07: Closed Closed 

OTIB-0052-08: Closed Closed 

OTIB-0052-09: In Progress Closed 

OTIB-0052-10: In Progress Closed 

OTIB-0052-11: In Progress Closed 

OTIB-0052-12: In Abeyance In Progress 

OTIB-0052-13: In Progress In Progress 

OTIB-0052-14: In Progress In Progress 

OTIB-0052-15: Transferred to ORAUT-OTIB-0020 Transferred to ORAUT-OTIB-0020 

OTIB-0052-16: Transferred to ORAUT-OTIB-0020 Transferred to ORAUT-OTIB-0020 

OTIB-0020: Not Applicable Not Applicable 

OTIB-0014-01: Transferred to ORAUT-OTIB-0052 Transferred to ORAUT-OTIB-0052 
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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.

7.0 REFERENCES 

OCAS 2006. Preparation of Program Evaluation Reports and Program Evaluation Plans, 

OCAS-PR-008, Revision 2, NIOSH’s Office of Compensation Analysis and Support, 

Cincinnati, Ohio. December 6, 2006 

OCAS 2007. Construction Trades Workers, OCAS-PER-014, Revision 0, NIOSH’s Office of 

Compensation Analysis and Support, Cincinnati, Ohio. November 28, 2007. 

ORAUT 2004a. Technical Information Bulletin: Individual Dose Adjustment Procedure for 

Y-12 Dose Reconstruction, ORAUT-OTIB-0013, Rev. 00, Oak Ridge Associated Universities 

Team: Cincinnati, Ohio. September 9, 2004. 

ORAUT 2004b. Technical Information Bulletin – External Coworker Dosimetry Data for the 

X-10 Site, ORAUT-OTIB-0021, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, 

Ohio. December 29, 2004. 

ORAUT 2005a. External Coworker Dosimetry Data for Hanford Site, ORAUT-OTIB-0030, 

Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. March 23, 2005. 

ORAUT 2005b. Los Alamos National Laboratory – Occupational External Dose, ORAUTTKBS-0010-6, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. May 10, 

2005. 

ORAUT 2005c. External Coworker Dosimetry Data for Savannah River Site, ORAUT-OTIB0032, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. May 31, 2005. 

ORAUT 2005d. Site Profile for the Kansas City Plant, ORAUT-TKBS-0031, Rev. 00, Oak 

Ridge Associated Universities Team: Cincinnati, Ohio. May 31, 2005. 

ORAUT 2005e. Weldon Spring Plant – Occupational External Dose, ORAUT-TKBS-0028-6, 

Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. June 24, 2005. 

ORAUT 2005f. External Coworker Dosimetry Data for the Portsmouth Gaseous Diffusion 

Plant, ORAUT-OTIB-0040, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, 

Ohio. July 29, 2005. 

ORAUT 2005g. Use of Coworker Dosimetry Data ForExternal Dose Assignment, ORAUTOTIB-0020, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. October 7, 

2005. 

ORAUT 2005h. Internal Coworker Dosimetry Data for Hanford Site, ORAUT-OTIB-0036, 

Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. October 28, 2005. 
Effective Date: 

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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.

NOTICE:

ORAUT 2005j. Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, ORAUT-OTIB-0006, Rev. 03 PC-1, Oak Ridge Associated Universities Team: 

Cincinnati, Ohio. December 21, 2005. 

ORAUT 2006a. Pantex Plant National Security Complex – Occupational External Dose, 

ORAUT-TKBS-0013-6, Rev. 00, Oak Ridge Associated Universities Team: Cincinnati, Ohio. 

July 27, 2006. 

ORAUT 2006b. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Revision 00, Oak Ridge Associated University Team: 

Cincinnati, Ohio. August 31, 2006.