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-0052, 

“PARAMETERS TO CONSIDER WHEN PROCESSING CLAIMS FOR CONSTRUCTION TRADE WORKERS” 

Finding 

Number

Finding Description

(originally for Revision 00) NIOSH Response Finding Resolution

1 OTIB-0052 does not address differences in 

doses received by different construction 

occupations. 

08/29/07: NIOSH believes that the goal of 

favorable treatment for construction trade 

workers who were unmonitored or were 

monitored but are deficient in some portion of 

their records for a period of time has been 

achieved. Any refinement in the model with 

respect to different construction occupations is 

unnecessary. 

04/11/12: Because this issue is essentially 

the same as Finding 16, the SCPR changed 

the status to “Addressed in OTIB-0052-16.” 

The SCPR transferred Finding 16 (and, by 

extension, Finding 1) to OTIB-0020. 

On November 14, 2011, NIOSH issued 

OTIB-0020, Revision 03, with the requested 

change to address the OTIB-0052 findings. 

Therefore, the SCPR closed Finding 1 along 

with Finding 16. 

2 The dose databases used are lacking significant 

data for the early operational years. 

08/29/07: NIOSH concurs with SC&A’s July 30, 

2007, report, which postulates on page 77 a 

reason for relatively low CTW exposure during 

the early years of site operations. In the early 

years of any site, the task of construction trade 

workers would more likely be involved with 

initial facility construction rather than retrofits 

and would therefore involve less radiation dose 

potential. Any deficiency in data during early 

operational years would apply to all monitored 

workers, not just construction trade workers, and 

would therefore tend to be an unbiased source of 

uncertainty. 

06/24/08: The SCPR was satisfied with this 

response and closed the finding. 
Issues Resolution Matrix for OTIB-0052 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

(originally for Revision 00) NIOSH Response Finding Resolution

3 The dose databases do not always identify who 

were CTWs, and for CTWs, what were their 

occupations. 

08/29/07: The dose databases constitute the best 

available source of information for a large 

population (more than 179,000 bioassay values 

and 216,000 external dose data values for CTWs 

were included in the analysis). The criteria used 

to identify CTWs were either set at the time the 

record was created by site personnel or were

identified in the OTIB in a description of the 

database query.

06/24/08: SC&A and the SCPR agree with 

the NIOSH response, and the SCPR closed 

the finding. 

4 NIOSH did not make modifications to the 

internal dose calculation methodology as they 

indicated to CPWR that they would. 

08/29/07: When NIOSH attempted to make the 

CPWR agreed-upon modifications (i.e., increase 

the GSD), the result was “implausibly large 

values.” At that point, NIOSH decided to use

existing internal dosimetry bioassay data, which 

also eliminated issues about breathing rates, 

oronasal breathing, number of hours worked per 

week, etc. NIOSH determined that a better 

course of action was available based on actual 

CTW bioassay data rather than assumed intakes 

based on air concentration. NIOSH believes that 

the resulting method provides a more sitespecific-based approach to dose reconstruction 

that is favorable to the claimant. 

06/24/08: SC&A and the SCPR were 

satisfied with NIOSH’s response, and the 

SCPR closed the finding. 
Issues Resolution Matrix for OTIB-0052 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

(originally for Revision 00) NIOSH Response Finding Resolution

5 Plutonium and/or uranium were used to 

compare internal CTW to all monitored 

workers (AMW) doses. What about other 

radionuclides? 

SC&A Follow-up: It is not whether a 

comparison between groups for less prominent 

radionuclides is “feasible,” but whether such a 

comparison in “necessary.” For example, do 

the plutonium/uranium doses always dominate 

the AMW doses, or do other radionuclides 

sometimes dominate? Also, do the AMW 

doses from other radionuclides “follow” the 

plutonium/uranium doses in any predictable 

fashion? When AMW have bioassay data for 

other radionuclides, why were these data 

collected? Was there any systematic reason?

08/29/07: The underlying assumption for 

internal dose comparison is that the internal dose 

hazard for a site is closely tied to the 

radionuclide being handled in greatest quantity 

at the site. The vast majority of bioassay data in 

the DOE complex are for plutonium and 

uranium. Data on other radionuclides are limited 

in timeframe and number of results. 

Consequently, meaningful comparisons between 

the groups for less prominent radionuclides were 

not judged to be feasible. 

NIOSH Follow-up: NIOSH added Section 3.1, 

“Limits and Exceptions,” which refers 

OTIB-0052 users to the site TBD for information 

on intakes of less common radionuclides.

07/14/11: Based on the change made by 

NIOSH in Revision 01 regarding this issue 

and SC&A’s concurrence, the Subcommittee 

closed this finding. 

6 OTIB-0052 does not address how to determine 

CTW doses at sites that do not have a 

coworker model. 

08/29/07: For sites lacking coworker studies, the 

dose for unmonitored CTWs is reconstructed in 

the same way as for other unmonitored workers 

with a potential for exposure or intakes (see 

Section 8.1 in OTIB-0052). The site TBD 

provides direction on how to assign external and 

internal doses, and then the appropriate 

adjustment factor defined in OTIB-0052 is 

applied. 

06/24/08: SC&A agreed with NIOSH’s 

response, and the SCPR closed this finding. 
Issues Resolution Matrix for OTIB-0052 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

(originally for Revision 00) NIOSH Response Finding Resolution

7 OTIB-0052 does not address how to determine 

neutron CTW doses. 

08/29/07: External doses were not intentionally 

differentiated according to gamma or neutron 

doses, so no inherent bias in reconstruction of 

neutron dose is likely. Note that neutron dose is 

normally associated with access to special 

nuclear materials, which requires a security 

clearance or security escort. Workers with 

security clearances were known and likely to be 

monitored. Consequently, it is reasonable to 

assume that the neutron dose would be higher in 

the group of all monitored workers than in the 

somewhat more transient CTW group. 

06/24/08: SC&A and the SCPR agreed with 

NIOSH’s response, and the SCPR closed this

finding. 

8 All SRS external doses are from the HPAREH.

There needs to be an evaluation of other dose 

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

08/29/07: No additional value is gained in this 

case by expending resources to study the 

contents of other, less complete, databases. 

Quoting from the SC&A report dated July 30, 

2007, page 33, “Based on this analysis, there is 

no reason to believe that including the 

Fayerweather database in the ORAUT-OTIB0052 analysis would change the results of that 

study for the SRS or for the ratio of 1.4 to be 

applied to external coworker models. The 

limitations of the above comparison should be 

kept in mind, particularly the fact that 22% of 

the data presented in Fayerweather lack 

exposure and/or dosimetry information.” 

08/21/08: SC&A and the SCPR agreed with 

NIOSH’s response, and the SCPR closed this

finding. 

9 Evaluation is based on DOE annual exposure 

report. Needs to address the Master Update 

Dump (MUD) dose database for INL. 

08/29/07: The MUD database covers the time 

period prior to 1986. The data in the Annual 

Reports are equivalent (because the Annual 

Report was created from the MUD data) for the 

overlapping time periods. However, NIOSH 

agreed to modify the OTIB to explain why it did 

not use the MUD dose database. 

07/14/11: Based on the change made by 

NIOSH in Revision 01 regarding this issue 

and SC&A’s concurrence, the Subcommittee 

closed this finding. 
Issues Resolution Matrix for OTIB-0052 5 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

(originally for Revision 00) NIOSH Response Finding Resolution

10 For post-1974, the ratio of penetrating doses 

experienced by CTWs to other workers in 

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. 

SC&A Follow-up: NIOSH 2005, Table 2-7, 

indicates 30,604 construction workers out of a 

total worker population of 112,304, or 27% 

construction workers. Also, NIOSH 2005, 

Figure 3-12 (reproduced as Figure 3.14-1 of 

the SC&A review of OTIB-0052, 

Revision 00), indicates that the number of 

unmonitored construction workers compared to 

monitored non-construction workers is larger 

prior to 1960, about the same from 1960 to 

1964, and less after 1964. SC&A does not see 

the basis for the statement “the CTW 

population is effectively all radiation 

workers,” would like to see more information 

on this subject from NIOSH, and recommends 

keeping the status of the issue “In Progress.”

08/29/07: The two worker populations are not 

equivalent in that the CTW population is 

effectively all radiation workers, while the “other 

workers” population includes administrative 

workers and engineers who are not radiation 

workers and tend to dilute the average exposure 

for “other workers,” which would artificially 

raise the correction factor. The unmonitored 

CTW at INL would not have worked in a 

radiation area, so assigning the CTW a dose 

equal to 1.4 times the non-CTW dose would be 

very claimant favorable.

06/24/08 NIOSH Follow-up: NIOSH added a 

new paragraph to Section 5.13 that explains that 

the NIOSH 2005 data were not used because the 

service workers are grouped with CTWs, a 

practice that is inconsistent with the definition of 

CTW used in OTIB-0052. 

07/14/11: Based on the change made by 

NIOSH in Revision 01 regarding this issue 

and SC&A’s concurrence, the Subcommittee 

closed this finding. 
Issues Resolution Matrix for OTIB-0052 6 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

(originally for Revision 00) NIOSH Response Finding Resolution

11 The claimant favorability of the OTIB-0052 

approach for INL early period internal dose (to 

1965) cannot be determined. 

SC&A Follow-up: OTIB-0052, Section 5.14, 

states: “Data for internal exposures for 

workers at the INL was not available.” Also, 

NIOSH 2005 states: “Until about 1965 

construction and service workers had 

relatively higher percentages of internal dose 

than non-construction/non-service workers.” 

Both of these statements lead SC&A to believe 

that the INL pre-1965 internal dose is not well 

known or documented. 

08/29/07: Internal exposures are well known and 

documented. 

06/24/08 NIOSH Follow-up: NIOSH modified 

the second paragraph of Section 5.14 to address 

SC&A’s concern and provide clarity to the dose 

reconstructors. NIOSH explained that the reason 

pipefitters at SRS received higher doses during 

the 1960s was the major modifications taking 

place in the F and H Canyons. Since these are 

classified areas, all workers would have been 

monitored, and any unmonitored CTWs (the 

subjects of OTIB-0052) would have received 

lower exposures. 

07/14/11: Based on the change made by 

NIOSH in Revision 01 regarding this issue 

and SC&A’s concurrence, the Subcommittee 

closed this 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 OTIB-0052. 

08/29/07: The data used for the Hanford analysis 

were extracted by the site expert from the REX 

database and provided to the OTIB-0052 team as 

spreadsheet files. The text of OTIB-0052 did not 

communicate the identity of the source database. 

Any subsequent revision will correct this 

oversight. In summary, NIOSH believes that the 

analysis of Hanford penetrating dose presented 

in OTIB-0052 is valid and need not be 

reevaluated.

06/24/08 NIOSH Follow-up: NIOSH added the 

following statement to Section 6 of OTIB-0054: 

“Electronic access to the REX database was not 

available when this bulletin was drafted. 

However the data in REMS was derived from the 

data in REX and is judged to adequately 

represent the ratio of CTW and AMW doses.” 

11/25/14: Based on the change made by 

NIOSH in Revision 01 regarding this issue 

and SC&A’s concurrence, the Subcommittee 

closed this finding. 
Issues Resolution Matrix for OTIB-0052 7 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

(originally for Revision 00) NIOSH Response Finding Resolution

13 The CTW doses need to be compared 

consistently to either AMW or non-CTWs. 

Currently different sections perform different 

comparisons. 

04/10/12 SC&A Follow-up: SC&A examined

the SRS HPAREH average penetrating data 

(excluding zero measurements) from 1953 to 

1999 and found that the ratio of (CTW to nonCTW) and (CTW to AMW) ranged from 

89.7% to 104.1%. When the ratio is greater 

than 100%, the average CTW dose is greater 

than the average non-CTW dose.

Likewise, SC&A examined the SRS HPAREH 

90th percentile penetrating data (excluding 

zero measurements) from 1953 to 1999 and 

found that the ratio of (CTW to non-CTW) and

(CTW to AMW) ranged from 85.9% to 

101.0%. When the ratio is greater than 100%, 

the average CTW dose is greater than the 

average non-CTW dose.

SC&A recommended changing the status to 

closed. 

08/29/07: Methods differ in the details because 

of data availability. Because CTW doses are 

similar to or higher than AMW doses, the 

calculated ratios, which are used to form an 

adjustment factor, tend to be similar or higher 

when non-CTW is used in the denominator 

instead of AMW. The baseline method is to use 

AMW in the denominator, but the ratio would 

tend to be more favorable to the CTW 

population when non-CTW data are used in the 

denominator. 

12/19/11 NIOSH Follow-up: Regardless of 

comparison method, the outcome would be 

favorable to CTWs because the correction is 

typically applied to doses in a site-specific 

coworker model that is based on data for all 

monitored workers. When CTW are removed 

from the comparison population, the ratio favors 

the CTW if the CTW doses are in fact elevated. 

In addition, the 20% threshold criteria for 

adjustment falls inside the margin of uncertainty 

(~ 30%) for dosimetry programs during the film 

era as well as modern programs covered by 

DOELAP. 

04/11/12: The SCPR agreed with SC&A’s 

recommendation and closed this finding. 
Issues Resolution Matrix for OTIB-0052 8 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

(originally for Revision 00) NIOSH Response Finding Resolution

14 The handling of “missing dose” needs to be 

consistent. Currently, some sections include 

“missing dose” while others do not. 

08/29/07: The external dose data used in the 

Rocky Flats analysis had been prepared for a 

coworker study by others on the ORAU Team. 

In the process, “missed dose” was added as 

necessary to each record according to the normal 

dose reconstruction practice, then the data were

reviewed and approved. For Rocky Flats, the 

comparison of CTWs to the coworker population 

used these data. For all other sites studied, 

missed dose adjustments to the data were not 

available. Regardless of how missed dose was 

treated, the site-specific comparison between 

CTWs and AMW was fair because missed dose 

was handled consistently for both groups within 

each site.

12/19/11 NIOSH Follow-up: NIOSH added the 

following paragraph to Section 4.0: 

The quality, usability, and accessibility of the data 

varied, making a standardized comparison among 

sites difficult. For example, some data are available 

in a modern database as official records while others 

are available only as summaries in centralized 

compilations. Some data have rigorously 

characterized parametric descriptions, while others 

are described only by a mean value. At some sites, the 

AMW group includes the CTWs and at others it does 

not. Some site comparisons are made using data that 

have been corrected for external missed dose, while 

others are made without that correction. The analysis 

method was appropriately adapted to the differences 

in data, but in all cases the comparisons are 

consistent for each site. The outcome of a specific 

comparison might have been affected by these 

differences, but only negligibly in the context of the

threshold for adjustment described in Section 4.2 [2].

07/31/12: SC&A agreed with NIOSH’s 

modification, and the SCPR closed this

finding. 
Issues Resolution Matrix for OTIB-0052 9 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

(originally for Revision 00) NIOSH Response Finding Resolution

15 OTIB-0052 does not give instructions for what 

to do if high or low cumulative exposures are 

suspected.

SC&A Follow-up: OTIB-0020 does give 

guidance on what to do for individuals who 

were unlikely to have been exposed to low 

doses. OTIB-0020 also states that for 

individuals who were encouraged or instructed 

not to wear their badges (dosimeters), the dose 

reconstructor should “modify the dose 

reconstruction and/or perform additional 

research.” Issue OTIB-0020-06 questions 

whether the dose reconstructor would be able 

to carry out the required reconstructions. Also, 

there is nothing in OTIB-0020 to instruct the 

dose reconstructor to modify the dose 

reconstruction and/or perform additional 

research when other circumstances arise 

(e.g., a traditional high-dose construction 

trade).

08/29/07: The normal assessment methods 

defined in OTIB-0020 for these types of 

exposures apply. The method in OTIB-0052 

does not change when either low or high 

cumulative exposures are suspected. 

Consequently, no additional clarification on this 

topic is needed. 

04/11/12: The SCPR and NIOSH agreed that 

the finding should be transferred to ORAUTOTIB-0020. On November 14, 2011, NIOSH 

issued OTIB-0020, Revision 03, with the 

requested change to address the OTIB-0052 

finding, and the SCPR closed the finding. 
Issues Resolution Matrix for OTIB-0052 10 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

(originally for Revision 00) NIOSH Response Finding Resolution

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.

SC&A Follow-up: SC&A recommended that 

this issue be transferred to OTIB-0020, with a 

statement alerting the dose reconstructor that 

certain construction trades (e.g., pipefitters) 

may have received higher exposures than the 

CTW as a whole, and therefore, additional 

conservatism should be included in the dose 

reconstruction when the claimant belongs to 

one of these trades.

08/29/07: NIOSH believes that the goal of 

favorable treatment for construction trade 

workers who were unmonitored, or who were 

monitored but are deficient in some portion of 

their records for a period of time, has been 

achieved by assigning doses that are among the 

highest observed on any site. Any refinement in 

the model with respect to subgroups of 

construction occupations is not necessary. 

04/11/12: The SCPR and NIOSH agreed that 

the finding should be transferred to ORAUTOTIB-0020. On November 14, 2011, NIOSH 

issued OTIB-0020, Revision 03, with the 

requested change to address the OTIB-0052 

finding, and the SCPR closed the finding. 

AMW = all monitored workers; CPWR = Center to Protect Workers’ Rights; CTW = construction trade worker; DOE = U.S. Department of Energy; DOELAP = Department of Energy 

Laboratory Accreditation Program; GSD = geometric standard deviation; HPAREH = Health Protection Annual Radiation Exposure History Database; INL = Idaho National Laboratory;

MUD = Master Update Dump; OTIB = technical information bulletin; REMS = Radiation Exposure Monitoring System; REX = Radiological Exposure (database); SCPR = Subcommittee 

for Procedure Reviews; SRS = Savannah River Site; SRS-ABST = SRS Abstract Database; TBD = technical basis document