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 document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Memorandum

To: Subcommittee for Procedure Reviews

From: Robert Anigstein, SC&A, Inc. 

Date: June 7, 2023

Subject: Reply to NIOSH Response to SC&A Review Comments on PER-073

At the September 29, 2022, teleconference meeting of the Subcommittee for Procedure Reviews 

(SPR), the National Institute for Occupational Safety and Health (NIOSH) presented its response 

(NIOSH, 2022) to finding 1 of the SC&A review (SC&A, 2018) of DCAS-PER-073, “Birdsboro 

Steel and Foundry Company” (NIOSH, 2016). The SPR requested SC&A to reply to the NIOSH 

response at its next meeting (ABRWH, 2022, p. 56).

SC&A Reply to NIOSH Comments on Finding 1 

Finding 1: NIOSH neglected the external exposure to documented radiographic 

sources in assigning photon doses to Birdsboro workers [SC&A, 2018] 

SC&A (2018, p. 17), citing the Steel Founders’ Society of America (1961), stated that 

“Birdsboro had nondestructive test facilities comprising a 24-MV betatron, a 300-kVp x-ray 

machine, 200 mCi of 60Co, and 500 mg of radium in 1961.” NIOSH (2022, p. 3), citing the 

results of records searches, stated: “none of the records identified the presence of these sources 

or X-ray machines during the AEC covered time period in 1951 or 1952.” 

SC&A concedes that the 24-mega-electron volt (MeV) betatron apparatus and the Andrex x-ray 

unit were located in the Birdsboro Armorcast facility (Birdsboro, n.d.), which was 500 yards 

from the main Birdsboro plant (NLRB, 1953, p. 23). Furthermore, we agree that there is no 

conclusive information that Birdsboro employees who might have been exposed to the uranium 

metal handled at the Birdsboro steel foundry worked at the Armorcast facility during the covered 

period. 

However, a much greater source of exposure to external radiation of Birdsboro employees was 

the use of sources of radium (226Ra)1

1 The element radium comprises a number of radioactive isotopes. In common, nonscientific usage, the term 

“radium” is understood to mean 226Ra.

 for the radiography of steel castings at the main Birdsboro 

plant. There are several sources of information regarding the use of radium sources during the 

time that spans the covered period. First are 
Robert Anigstein, SC&A, Inc.

Reply to NIOSH, page 2 June 7, 2023 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

records of telephone interviews with the survivors of one energy employee (EE) 

. . . According to the interview report: “[the EE was exposed to] radium . . . from 

a bucket lifting out a source with a pole from the bucket. There is a radioactive 

sign next to it.” [SC&A, 2018, p. 16] 

This

information is entirely consistent with the information on radiographic operations 

at GSI [General Steel Industries, Inc.]. Since the greatest source of external 

photon exposure at GSI was the use of 226Ra employing the fishpole technique, a 

strong case can be made for using the external exposure scenarios developed for 

GSI as surrogate data for Birdsboro. [SC&A, 2018, p. 17] 

The EE was employed during the covered period. It is therefore plausible and claimant favorable 

to assume that this EE and some of the EE’s coworkers were exposed to 226Ra radiographic 

sources during the covered period. 

Further information about this EE’s occupational exposure is provided by the U.S. Department 

of Labor (DOL, 2001). The EE’s survivors filled out and signed a copy of this DOL form. In the 

form field labeled “Describe all factor(s) believed to have contributed to the development of the 

claimed illness,” they each entered: “Chronic acute exposure to radiation from capsules of 

radium & cobalt 60 during . . . employment at Birdsboro Steel Corp.” This further indicates that 

the EE had been exposed to 226Ra radiographic sources during the covered period. 

Further information regarding the possible use of 226Ra sources during the covered period at a 

steel foundry such as Birdsboro is provided by ASTM International.2

2 Formerly known as “American Society for Testing and Materials,” ASTM International is a developer of 

international voluntary consensus standards. 

ASTM E446-10 describes 

the “Significance and Use” of 

graded reference radiographs [that] are intended to provide a guide enabling 

recognition of specific casting discontinuity types and relative severity levels that 

may be encountered during typical fabrication processes. . . These reference 

radiographs are intended as a basis from which manufacturers and purchasers 

may, by mutual agreement, select particular discontinuity classes to serve as 

standards representing minimum levels of acceptability. [Reprinted from ASTM 

E446-10, “Standard Reference Radiographs for Steel Castings up to 2 in. 

(50.8 mm) in Thickness,” copyright ASTM International, www.astm.org.] 

If a steel foundry such as Birdsboro adopted such a standard, it would have performed 

radiographs of their castings and compared the resulting films to reference radiographs 

purchased from ASTM to establish the acceptability of its products. 

Further information that is relevant to radiographic standards in use during the covered period is 

provided by ASTM International (2014): “Note 2—Reference radiographs previously used for 

this thickness range carried the designation E71, but included a now rarely used gamma source, 
Robert Anigstein, SC&A, Inc.

Reply to NIOSH, page 3 June 7, 2023 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

that is, radium.”3

3 Reprinted from ASTM E446-10, “Standard Reference Radiographs for Steel Castings up to 2 in. (50.8 mm) in 

Thickness,” copyright ASTM International, www.astm.org. 

 The ASTM E71 standard was first published in 1947, with subsequent editions 

issued in 1952 and on August 31, 1964 (Accuris, n.d.). Consequently, this standard might have 

been employed by the Birdsboro Steel Foundry during the covered period. 

SC&A therefore concludes that it is plausible that Birdsboro used 226Ra sources to radiograph the 

castings it produced during this period to conform to the ASTM E71 standard in order to satisfy 

the requirements of its customers. Exposures to such sources should be included in dose 

reconstructions of workers who might have plausibly been exposed to such sources during the 

covered period. 
Robert Anigstein, SC&A, Inc.

Reply to NIOSH, page 4 June 7, 2023 

NOTICE: This document has been reviewed to identify and redact any information that is protected by the 

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

References

Accuris. (n.d.). ASTM E71 1964 edition, August 31, 1964. Standards Store by Accuris. 

https://global.ihs.com/doc_detail.cfm?document_name=ASTM%20E71&item_s_key=00020220 

Advisory Board on Radiation and Worker Health, Subcommittee for Procedure Reviews. (2022). 

Thursday, September 29, 2022 [Transcript of teleconference meeting].

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2022/sctr092922-508.pdf

ASTM International. (2014). ASTM E446-10: Standard reference radiographs for steel castings 

up to 2 in. (50.8 mm) in thickness. https://www.astm.org/e0446-10.html

Birdsboro Corporation. (n.d.). X-ray operators safety manual. SRDB Ref. ID 193501 

National Institute for Occupational Safety and Health. (2003). Energy Employees Occupational 

Illness Compensation Program Act (EEOICPA) dose reconstruction telephone interview, NIOSH 

claimant ID [redacted] [Computer-assisted telephone interview in NIOSH OCAS Claims 

Tracking System]. 

National Institute for Occupational Safety and Health. (2016). Birdsboro Steel and Foundry 

Company (DCAS-PER-073, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/pers/dc-per73-r0.pdf 

National Institute for Occupational Safety and Health. (2022, September 2). NIOSH DCAS 

response to SC&A review of DCAS-PER-073 “Birdsboro Steel and Foundry Company” 

finding 1. [Memorandum from Mark Rolfes to Subcommittee for Procedure Reviews].

https://www.cdc.gov/niosh/ocas/pdfs/dps/dc-per73-092222-508.pdf 

National Labor Relations Board. (1953). Decisions and orders of the National Labor Relations 

Board, 101, 22–25. https://casetext.com/admin-law/birdsboro-armorcast-inc 

SC&A, Inc. (2018). A review of NIOSH’s program evaluation report DCAS-PER-073, 

“Birdsboro Steel and Foundry Company” [redacted] (SCA-TR-2018-PR003, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-per73-r0-508.pdf

Steel Founders’ Society of America. 1961. Directory of steel foundries in the United States, 

Canada, and Mexico: 1961–62. 

https://babel.hathitrust.org/cgi/pt?id=coo.31924004418764;view=1up;seq=7

U.S. Department of Labor, Employment Standards Administration, Office of Workers 

Compensation Programs. (2001). Initial case file for Claimant [redacted] [NIOSH OCAS Claims 

Tracking System].