for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has 

been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Use of Surrogate Data Work Group

Monday, August 12, 2019 

The Subcommittee convened via teleconference, at 

1:30 p.m., Eastern Daylight Time, Paul Ziemer, 

Chair, presiding.
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that this transcript is for information only and is subject to change.

2 

Members Present: 

Paul Ziemer, Chair

Josie Beach, Member

James E. Lockey, Member

Loretta R. Valerio, Member

Also Present: 

Ted Katz, Designated Federal Official

Dave Allen, NIOSH ORAU

Robert Anigstein, SC&A

Kathy Behling, SC&A

Grady Calhoun, NIOSH ORAU

Rose Gogliotti, SC&A

John Mauro, SC&A

Dan McKeel

Jenny Naylor, HHS OGC

Jim Neton, NIOSH ORAU

John Stiver, SC&A

Tim Taulbee, NIOSH ORAU
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that this transcript is for information only and is subject to change.

3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Use of Surrogate Data 

Work Group Monday, August 12, 2019 1

Roll Call/Welcome, by Ted Katz 4

Brief Review of Surrogate Data Criteria, by 

Paul Ziemer, WG Chair 5

NIOSH Approach to Estimating Radon 

Exposure, by Dave Allen 10

SC&A Comments on NIOSH Approach 21

By John Mauro 21

By Bob Anigstein 28

Work Group Discussion and Recommendations

32

Future Follow-Up 38

Adjourn 39
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4

Proceedings

(1:32 p.m.)

Roll Call/Welcome, by Ted Katz

Mr. Katz: So welcome, everyone. This is the Advisory 

Board on Radiation and Worker Health. It's the Use 

of Surrogate Data Work Group, and today we're 

discussing Surrogate Data matters related to -- just 

drawing a blank -- Allied Chemical Plant, and the 

materials for today, the agenda and the background 

readings for today, are posted on the NIOSH website 

under the Board section, our scheduled meetings, 

today's date.

So you can go there and see the basic materials and 

the agenda. And this work group has four Board 

members. Paul Ziemer. Dr. Ziemer is the Chair, and 

he's here, and as well as all -- well two of the other 

members. Loretta Valerio and Josie Beach, and we're 

waiting for Jim Lockey, but I know --

Member Lockey: Hey, Ted, I'm here.

Mr. Katz: Oh, great. Okay, and we have Jim, so we 

have the whole work group which is great. None of 

the members have conflict or they wouldn't be on the 

work group, but let's for the rest of the people as I 

go through roll call, please address conflict of 

interest.

(Roll call.)

Mr. Katz: Okay. Welcome, Dan. All right. And with no 

further ado, then, Paul, it's your meeting.

Chair Ziemer: Very good.

Mr. Katz: And just to remind everyone to mute your 

phones except when you're addressing the group. 

Press Star 6 to mute your phone and Star 6 to turn 

off of mute. Thanks.
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5

Brief Review of Surrogate Data Criteria, by Paul 

Ziemer, WG Chair

Chair Ziemer: Okay, thank you, Ted, and welcome, 

everybody. You have the agenda before you. The 

main documents for consideration are on the 

website. Also, if you look at the agenda you'll notice 

that I've put in, for Item 2, a brief review of surrogate 

data criteria and I want to go through that very 

briefly.

The dose reconstructions for this site originally were 

based almost completely on surrogate data, although 

since the early days of the dose reconstructions for 

the site there's been additional data which will be 

mentioned. But I did want to do a brief review of the 

surrogate data. I'm not going to spend a lot of time 

on it.

I'll just reference you to the final draft of the criteria 

for use of surrogate data was dated May 14th, 2010. 

So if it's convenient for you to pull that up, you might 

go ahead and do that, but I'm just going to briefly 

review the criteria.

To a large extent it's going to be sort of a hybrid now 

because there's -- new data has become available in 

the last couple years so that the issue of using 

surrogate data completely for this site is critical and 

will continue to be used.

Just to recall, there actually are two types of 

surrogate data. One is the type of surrogate data 

that's simply used completely to substitute for the 

site in question because of the lack of data.

The Type 2 surrogate data is a situation where you're 

using surrogate data to develop parameters for dose 

reconstruction and not completely as a substitute for 

the site data.

Criteria that are the ones that are used to establish 
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that this transcript is for information only and is subject to change.

6

the validity of using criteria data. The first is called 

the Hierarchy of Data and basically that says that we 

first must go through the full hierarchy which is 

individual worker monitoring data, co-worker data 

and on through the complete look of the site. So you 

should only use data in this image over data for 

image if they are available for --

Mr. Katz: Paul. Paul, I don't know, Paul?

Chair Ziemer: Yes?

Mr. Katz: Paul, I don't know if you know you're 

having problems but your voice is breaking up at 

times on the --

(Simultaneous speaking.)

Chair Ziemer: You know what, what I'm going to do 

I'm going to -- I'm on a cell phone so I'm going to 

move to a different location and I'll see if that helps 

any.

Mr. Katz: Thank you.

Chair Ziemer: Should I repeat what I was saying or?

Mr. Katz: I think, I mean the last couple sentences I 

couldn't follow.

Chair Ziemer: Oh, okay. I'm actually going to move 

out to my patio which will eliminate the blockage of 

doors and windows and other parts of the building 

here. Is this better?

Mr. Katz: Yeah. You sound good right now. Thanks.

Chair Ziemer: Okay. Let's try this. One which is 

where you are using the surrogate data completely 

to substitute for the other, for the site of interest 

simply because of lack of data.

The other is where the surrogate data is used to help 
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7

develop parameters to use in assisting in the dose 

reconstruction for a site that may have some data but 

perhaps not adequate.

There are five criteria to use. One is the Hierarchy of 

Data. You first have to establish that, well you have, 

there's the criteria saying that you must go through 

the availability of, first, the monitoring data, 

personnel monitoring data, then the process data, 

source data. And the surrogate data is only to be 

used to replace data where you have some 

advantage in doing so that made a big advantage 

over available data.

Effectiveness criteria is called exclusivity constraints. 

This surrogate data is used with this available data. 

You have to establish the --

Court Reporter: Sorry, this is the court reporter. I'm 

not able to follow this.

Chair Ziemer: Still breaking, still breaking up?

Court Reporter: Yes, I'm sorry.

Mr. Katz: Yes, just at the very end, Paul, you started 

breaking up again and so, just the last sentence or 

two. Do you have earbuds with a mic because that 

usually works better for me?

Chair Ziemer: I don't have earbuds at the time. I'm 

just shooting this as is.

Mr. Katz: Okay, yes.

Chair Ziemer: So, in the exclusivity constraints, the 

surrogate data is used to supplement available 

monitoring data. You use it -- it's data that's available 

and you're relying on evaluating the quality and the 

completeness of the surrogate data as it might apply.

The third one is site or process similarities. That's 

similarities to the sites, the surrogate data has to be 
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8

similar to the site's situation or the process has to be 

similar. So there's issues of having the data reflect 

the types of processes and work practices at the site 

from which you're doing the evaluation.

There are temporal considerations. You have to take 

a look at the period in question and ask whether 

working conditions and processes are similar time 

wise to the surrogate data site and the site under 

evaluation.

And the last criteria has to do with plausibility. The 

manner in which the surrogate data is to be used 

must be plausible in terms of reasonableness of the 

assumptions made. And there we're talking about 

both scientific plausibility -- is it scientifically 

appropriate -- and work place plausibility -- is it 

plausible for the facility in question.

So, those are the criteria. And in the case that we're 

going to be talking about today, I believe I'm correct 

and NIOSH folks can help me here if I'm wrong, but 

I believe that the original approach was completely 

use the surrogate data. Is that not correct, David?

Dr. Mauro: Paul, I'm sorry to interrupt you in the 

middle of your discussion but let me apologize. This 

is John Mauro. Let me apologize --

Chair Ziemer: Yes, John.

Dr. Mauro: -- for being 10, 15 minutes late. I find 

myself sidetracked on another conference call that 

stretched on, so I apologize to everyone for 

interrupting. I'm online and I'm available to help out 

at any time --

Chair Ziemer: Yes. Very good. Dr. Mauro: -- for your 

people. Okay, thank you.

Chair Ziemer: Yes, appreciate you letting us know. 

We're just reviewing the surrogate data criteria.
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9

Dr. Mauro: Yes.

Chair Ziemer: What we've decided to do in terms of 

this particular situation, which is, was really the blind 

dose reconstruction for the site, and originally SC&A 

had comments early on and the -- I think that was in 

2015, and you'll have a chance to talk about those if 

you wish next, or in a moment.

But we have now NIOSH's approach for estimating 

the radon exposure which was the case, the situation 

here for Allied Chemical, which they developed in 

2017 or at least the paper came out in February 

2017. And that's the approach that they have 

proposed and they were challenging -- that's that. 

That is the most recent paper.

SC&A may wish to then respond to that but you also 

may have some background information relative to 

your earlier review, which was for the June 2015 

review.

But let's go ahead with the NIOSH approach now and 

--

Dr. Mauro: Yes, Paul, just to let you know we, myself 

and others from SC&A on the phone have read the 

reports, the most recent one and --

Chair Ziemer: Yes, I assumed that you did. Right.

Dr. Mauro: Yes. So we're prepared to give the 

background and also to comment on the current one, 

the 2017 report --

Chair Ziemer: Very good.

Dr. Mauro: -- by Dave Allen, yes. Thank you.

Chair Ziemer: Very good. So, let's proceed with the 

latest NIOSH approach, which is actually a couple of 

years old by now. But, Dave, you want to go ahead?
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10

NIOSH Approach to Estimating Radon Exposure, by 

Dave Allen

Mr. Allen: Yes. This is Dave Allen. Just enough 

background to know where we're at, this was, like 

you said, a blind DR. The point of contention that's 

still outstanding was the radon exposure.

SC&A did a blind DR and did radon exposure a couple 

different ways. We did one for the DR and they didn't 

match up well, which is not too unexpected.

But after some discussions, it was decided at one 

point that SC&A should see what the radon exposure 

would be if they used the same model used in 

Blockson. And they did that in 2015, I believe, and 

came up with something a little closer to what we 

had. And then at some point I think the, I may be 

speaking out of school but I believe the dose 

reconstruction subcommittee was ready to close this 

out saying it was, you know, everybody agreed it 

was, what we did was a bounding estimate.

But then Dr. Melius stepped in and said he wanted to 

review it based on the surrogate data criteria, and 

that's kind of why we're here for this particular issue.

After that time, to muddy the waters more, after that 

time, Jim Neton managed to find some more 

definitive documentation on the research they were 

doing, which was something we were lacking. We 

only knew that the kind of quantities they worked 

with and it was very small quantities.

Since then, he found this information that the two 

main studies they were doing was on leech zone 

filtration and on uranium extraction from phosphoric 

acid. And we judged that the phosphoric acid came 

to the laboratory, it would have already been 

chemically processed and the radium would have 

been gone from that, so it wasn't really a source of 

radon.
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11

It would have been the leech field studies, the leech 

zone filtration studies that would have been the 

source of radon.

This documentation that he found mentioned that 

they worked with 150-gram samples, and at another 

point in there it mentioned that they thought they 

would need 45 more batches of those samples to run 

all the analyses they wanted to to verify the analysis 

they had already run.

So what we did was came up with a rough estimate 

assuming 150 grams in the laboratory to the point 

where it just stayed there all the time and reached 

an equilibrium. And by that, I mean all the radon that 

would emanate from 150 grams of phosphate ore 

minus the radioactive decay and minus the air 

exchanges in the room, in a small room. And we 

came up with an estimate of what the radon levels 

would be in the room based on that.

We then turned around and did the same thing with 

the full 45 batches or basically 45 150-gram samples, 

and obviously that ended up being 45 times higher.

And towards the end of my paper there's a table that 

mentions five different estimates that have been 

done on this site as far as the radon goes.

The first two are the estimates that were done that I 

just mentioned, the first one being the 150-gram, 

you know, one sample; the second one being 45 

samples all contained in a room at the same time. 

The third one was a little lower and that was the one 

from SC&A based on the Blockson model for radon 

emanating from phosphate ores. The fourth one is 

what we actually used in the dose reconstruction. 

That was we used a 10 percent of the OTIB-43 value, 

the 95 percentile OTIB-43 value, which was OTIB put 

together based on exposures at Phosphate-4, or at 

Phosphate-9.
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12

The last one Jim Neton put in there was, he 

mentioned some samples that were collected at 

Blockson and simply took 10 percent of the largest 

sample, and it ended up being right in line with many 

of these others.

And if you look at the table, you can see that 

everything is pretty close, or several of them are 

pretty close in line. There are -- none of them are 

way outside the others. The largest one being the one 

we had used in the dose reconstruction, which was 

10 percent of the phosphate ore value. But it's only 

a little more than double what we got with a couple 

of these other estimates.

And the white paper concluded with it seems based 

on that the estimate we did was reasonable. Not, it 

was bounding but not unduly bounding and we were, 

at least at this point, planning on sticking with that 

estimate. Did you want anything else on that, Paul, 

or?

Chair Ziemer: No, that's fine. Let me, and actually 

I'm back in my office now, so I'm wondering if you 

can still hear me okay?

Ms. Beach: Better, yes.

Mr. Katz: Yes, you sound much better, Paul.

Chair Ziemer: Okay. So, what you're proposing is 

basically the surrogate data approach, but it turns 

out that its estimate is about double what you get 

from using the X? Do I understand that correctly?

Mr. Allen: About double from what you get with one 

of those estimates, yes, or a couple of those 

estimates.

Chair Ziemer: Yes. Yes, well, your 45 sample 

estimate comes out 00042 and your OTIB-43 

estimate comes out 00093, so it's complete 
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13

surrogate. It's higher value and it seems to me it was 

logical to say okay, that's on me. You're not really 

using in the sense the --

Mr. Katz: Sorry, Paul, we couldn't hear that. You're 

not using the what?

Chair Ziemer: You're still proposing to use the 

surrogate data, which gives you the 00093 value. It's 

OTIB-43 right?

Mr. Allen: Yes, that's what we stated at the end --

Chair Ziemer: That's what you used before and that's 

what you're proposing to continue to use. And I'm 

saying it appears that it's about double what you get 

if you used the actual data for 45 samples.

Mr. Allen: Yes.

Ms. Beach: So, Paul, let me -- can I ask a question?

Participant: Excuse me.

Ms. Beach: Paul, this is Josie.

Participant: This is --

Chair Ziemer: Somebody's asking a question? Josie?

Ms. Beach: Yes, this is Josie, Paul. I wanted to ask, 

so if you're going to go with the 043 OTIB, that data 

is in, was gathered in the late 80s and 90s, so it 

doesn't really fit the criteria as the same time frame 

either. So, and I don't think we ever settled the 

surrogate data question. Is that correct?

Chair Ziemer: Yes. Well, that's correct. At least that 

was Dr. Melius' question, I think. One of the 

questions on the time frame is not that has to be the 

same time frame. The question is whether or not the 

methodology or either the approach is different in 

different time frames.
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14

A lot of this is just based on radon emanation and 

some basic types of extraction and I think that they 

were assuming, and, I guess, Dave, you should speak 

to this, that that part of it has not changed in time.

Mr. Allen: Right. Well, I mean our estimate in this 

white paper is based on the idea if you have 

phosphate or with some percentage of uranium in it, 

which is essentially the same radon source you would 

get in the phosphates mines. It's just a heck of a lot 

more quantity in the mines.

The assumption then is that the laws of physics didn't 

change from the 50s to the 80s and you end up with 

a similar --

Chair Ziemer: Right.

Ms. Beach: Except the facilities are, one's in the south 

and one's up further north isn't it?

Mr. Allen: Right. That was a big question, was the 

phosphate mines are essentially open pits mines in 

Florida; whereas Blockson, if you noticed on there, is 

a building in the Chicago area, essentially in Illinois.

Ms. Beach: Right.

Mr. Allen: And you end up where, as Jim pointed in 

this white paper, the maximum or the values you get 

for radon measurements at the Blockson were fairly 

similar to what you would get at the phosphate mine. 

That essentially is that factor of two difference so, it 

seems like though that might make a difference, it 

seems like it really didn't between Blockson and the 

phosphates mines.

Dr. Mauro: Can you --

Ms. Beach: But we're also talking -- go ahead, John.

Dr. Mauro: Yes, I just got -- clarification, I thought 

the work that was in OTIB-43 is not the mine data 
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15

but you looked at all of the data from FIPR, you know, 

the Florida research work.

And there's a lot of different categories of where 

radon was measured -- everything from the mines to 

the processing plants to the stacks, outdoor stacks. 

And the most applicable set of data would be the 

processing plants.

And that there was an issue at one time, and we're 

prepared to talk a little bit about this, is that the 

phosphate processing plants, which is the most 

analogous to places like Blockson and Allied Chemical 

where they're, as you said, the chemistry, the wet 

chemistry phosphate process, really hasn't changed, 

sort of the same thing they've been doing forever.

But I think you're, correct me if I'm wrong, but the 

measurements that you used as your, the foundation 

is really the radon measurements in the processing 

plant as opposed to the mines. Correct me if I'm 

wrong.

Mr. Allen: I really don't have that information. You're 

talking about OTIB-43 right?

Dr. Mauro: Yes. Yes. I'm going back to OTIB-43 and, 

which draws, you know, has your surrogate data. And 

what I'm saying is I believe your surrogate data is 

based not so much on the mines but on processing 

plants.

Because, you know, when you go to looking at other 

processing plants up north where they have a closed 

building, where you'd want to, where they're doing 

the same process, the wet, the sulfuric acid digestion, 

you know, the whole thing that we're familiar with.

The analogous circumstance would be the processing 

plants that were used in Florida. We have tons of 

measured radon data for different aspects of the 

whole life cycle. The most important and most 
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16

relevant of which of course, is the processing plant 

itself as opposed to the rock mines. And I just wanted 

to bring that up because that was my understanding 

of OTIB-43.

Mr. Allen: I, as you say that, John, I believe you are 

correct. I didn't look that up off the top of my head. 

I don't remember off the top of my head, but that 

does sound correct.

Dr. Mauro: Yes, and I have a --

Mr. Allen: John, say this is --

Dr. Mauro: Later on I have a lot to say about that but 

I wanted to give a little clarification to that. It's 

important.

Chair Ziemer: Well, you're right, John. If you look at 

OTIB-43, you'll see that there's a compilation of a lot 

of different studies and it has everything from the 

tunnels into the processing plants and so on.

Dr. Mauro: Yes.

(Simultaneous speaking.)

Mr. Allen: Okay, this is Dave Allen.

Chair Ziemer: Somebody else was -- yes, Dave, go 

ahead.

Mr. Allen: I'm sorry, I just wanted to say something 

else about the surrogate data and the criteria. When 

we were looking through this and trying to prepare 

for this meeting several years ago, actually, when Jim 

found this stuff, it occurred to us that it's not clear 

any, you know, a bounding estimate would ever 

actually pass the surrogate data criteria. It's not clear 

if it was intended to apply to a bounding estimate 

because the criteria requires the equivalent of 

working conditions, source terms, processes. And it's 

hard to come up with a bounding estimate that's 
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that this transcript is for information only and is subject to change.

17

equivalent to what the surrogate data was, so to us 

it wasn't clear if this criteria actually applied to 

something that everyone agreed was bounding.

Chair Ziemer: Yes, okay. Other comments or 

questions for NIOSH?

Mr. Anigstein: This is Bob Anigstein. I just wanted to 

make a clarification or perhaps I didn't understand. 

Paul, you referred to that sample, to that study using 

the 45 150-gram samples of data. It was actually a 

model, correct me if I'm wrong, if I'm misinterpreting 

it, Dave, a model of what is the maximum you could 

possibly expect by using extremely conservative, 

extremely limiting and not -- this is not a pejorative 

scene, but not realistic parameters like 100 percent 

emanation from the ore of radon, a very small room, 

so --

Chair Ziemer: All right, well --

Mr. Anigstein: At least the reason was --

Chair Ziemer: Yes, you're correct, Bob. It's not that, 

it is that they had source term information, the 150 

grams. That is, in a sense data.

Mr. Anigstein: It is. But the radon concentration --

(Simultaneous speaking.)

Chair Ziemer: In other words, it was the 45 runs were 

actually made, but they made the assumption that 

perhaps they all weren't made and therefore they 

would, the source term would be 45 times that. 

That's my understanding of it.

Mr. Anigstein: Yes, that's my understanding also. But 

the actual radon level were not measured.

Chair Ziemer: You're very correct. But knowing the 

source term and making some assumptions, I should 

think they're, as I understand what they did, the 
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that this transcript is for information only and is subject to change.

18

effort using the room size that they did, which was 

rather small, would maximize the concentration.

Mr. Anigstein: Yes.

Chair Ziemer: A lot of assumptions there of course, 

yes. Other questions or comments?

Mr. Anigstein: But excuse me, if I could point out in 

contrast, where to show the variability depending on 

further variability of the model, of the modeling. The 

model, which is, Dave, perhaps I'm jumping ahead, 

out of turn, so stop me, somebody stop me if I'm 

wrong, if I'm out of place.

Incidentally I just wanted to notify everyone, I have 

to, I was brought into this after the date and time 

were chosen, so I have to leave at 2:30. I have an 

appointment.

Chair Ziemer: Okay.

Mr. Anigstein: I have to get my sitting in time. 

Because in contrast to the Dave Allen's model of our 

work in regulatory meetings, we were asked back in 

2015 by the DR subcommittee to, or we volunteered 

-- anyway we were directed to use the source term 

information available then in conjunction with the 

model we had developed for Blockson to come up 

with a concentration.

And the source term, we didn't have 150-gram 

samples --

Chair Ziemer: Right. That was before that was 

available. Right.

Mr. Anigstein: Yes. So the source term we used was 

an estimate from an interview of a former worker 

who said, well, it's not more than two to ten pounds 

of uranium -- not ore. Two to ten pounds of uranium 

were extracted and that translates, based on the 
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19

concentrations of radium -- of uranium in the ore, 

that translates to approximately, if you assume this 

is an annual amount, to approximately 50 tons of 

uranium as opposed to 150 grams times 45 at that 

time.

Chair Ziemer: Right.

Mr. Anigstein: And nevertheless, by using the 

ventilation rate, using the detailed model developed 

for Blockson with the emanation coefficient, the 

processing, the size of the building and the 

ventilation rate, we came up with about 30 times 

lower than the estimate for the 150-gram samples.

So it just shows the variability, depending on what 

assumptions you make about the site of the building. 

I was using the Blockson building with a 20,000 cubic 

meters --

Chair Ziemer: Right.

Mr. Anigstein: -- as opposed to maybe 20 cubic 

meters, so it's ten by ten by eight feet and also, 

however, a higher ventilation rate based on some 

industrial buildings, data on industrial buildings.

So I'm just throwing this in to show the range of 

parameters. And also I'd like to make one other 

comment to supplement what Dave said about the -

- I just changed screens here -- about the 

measurements as Blockson.

There were two other measurements, two other sets 

of measurements that are mentioned in the updated 

-- the Blockson TBD was updated since the original 

work was done on Blockson.

And one statement is that the FUSRAP measured 

.0061 working levels, so it's a little higher than the 

.0042 that was measured by the Owens Survey, and 

by one, almost one and a half times higher.
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20

And then also the assumption made in the TBD for 

doing, for modeling radon during the residual period 

assumes that in 1960, which was the last year of the 

operational period, the value, the radon value was 

.0083 working levels. So we basically have three 

numbers from Blockson --

Chair Ziemer: Yes.

Mr. Anigstein: -- .0042, .0061, .0083. So all of these 

are pretty much, this is what -- I'm speaking for 

SC&A, mainly it's myself and John Mauro -- all of 

these are pretty much in the range of the .0093 from 

the OTIB-43. So --

Dr. Mauro: Is that .00 -- is that -- I think it's three 

zeroes there? Is that right?

Chair Ziemer: It's three zeroes, triple zero.

Mr. Anigstein: Right. Yes.

Chair Ziemer: Yes. Well --

Mr. Anigstein: Actually, excuse me. It's two zeroes 

was the 95th percentile and then they divided by ten 

to account for the much smaller source term.

Chair Ziemer: Yes.

Dr. Mauro: Thanks. Thank you.

Chair Ziemer: Well, actually, Bob has a presentation 

for the SC&A, so let's go ahead and flesh that out a 

little. First, Kathy, were you going to do some, give 

us some background information before the others 

got into the details? Is Kathy there?

Dr. Mauro: I was speaking -- this is John -- I was 

speaking to Kathy before the meeting. I'm not sure if 

she's able to be on the line or not.

Chair Ziemer: She was on the line earlier.
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21

Dr. Mauro: Oh, she was. Oh, okay. Well if she's there 

certainly, but one of the things we talked about --

Chair Ziemer: I don't know if she's still there. Kathy, 

are you there? She must not be there now. But I did 

get an email from her that she would be on the line. 

Is she there?

Ms. Behling: This is Kathy. I'm on. Yes, I am.

Chair Ziemer: Oh, okay. Yes.

Ms. Behling: Actually I came back between David 

Allen and Bob Anigstein. They have provided the 

background information that I was prepared to speak 

on.

I just want to touch on making the subcommittee 

aware that obviously this is work that was done 

initially on a blind dose reconstruction and --

Chair Ziemer: Right.

Ms. Behling: -- there were several methods used, so 

everything I think that I was going to tell you has 

been talked about. But thank you for asking if I had 

anything else to contribute.

(Simultaneous speaking.)

Chair Ziemer: Yes. John and Bob, then, do you want 

to specifically respond to the cited paper by NIOSH?

Dr. Mauro: Yes, this is John. I mean, I'm be glad --

Bob and I did have a chance to talk --

Mr. Anigstein: Go ahead John.

SC&A Comments on NIOSH Approach

By John Mauro

Dr. Mauro: -- thanks Bob. Yes, let me, I think to go 

to Josie's the heart of the question. Surrogate data. 
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22

We all understand the background now. And you 

have to ask yourself the question, all right what we're 

doing is we have data from FIPR for processing 

plants, which is basically OTIB-43.

Now interestingly enough, we have data from 

Blockson and there is parity in that measurements 

are Blockson and the measurements for the 

processing plants at FIPR.

And the measurements are, quite frankly, from 

Blockson and from FIPR were in the same decade, I 

believe. So in terms of the, so in a funny sort of way 

what we have is, even though the processing plants 

at, and this was an issue way back when, the folks 

have been around for a while remember.

One of the issues I brought up originally when I was 

concerned about using FIPR as a surrogate for 

Blockson had to do with -- well, one building is 

opened. The building's in Florida. These are 

processing plants. These are open buildings.

And here we have a situation with Blockson and also 

Allied Chemical which are close. Boom. We have 

ourselves a potential surrogate data issue.

And the other potential surrogate data issue is the 

Allied Chemical building was clearly smaller than the 

Blockson building and it was decades earlier when the 

operations took place compared to when the 

measurements were made, both at Blockson and at 

FIPR.

Okay, so that is the essence of the surrogate data 

issue, and now I'm going to give you my conclusion 

and then I'm going to tell you why. I don't think it's 

an issue, okay.

I think what was done by the use of OTIB-54, the use 

of the factor of ten and, in fact, is acceptable, 

notwithstanding the surrogate data issues that we 
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23

always tried to test. And let me explain why.

Ms. Beach: Hey, John?

Dr. Mauro: Yes?

Ms. Beach: Before you do that, you just brought up 

OTIB-54. Is that --

Dr. Mauro: No, that should be then 43.

Chair Ziemer: You meant 43, I assume.

Ms. Beach: I want to make sure. Thank you.

Dr. Mauro: Oh, no, I apologize. If I said 54, it's just 

a slip. It's 43.

Ms. Beach: No worries. Okay. Thanks.

Dr. Mauro: Yes. Good. Okay. What we have here is 

something that's, first of all is very important. The 

issue before, the original issue, that open building 

closed building was an issue.

That issue has now been resolved and that, holy 

mackerel, look at this, the measurements made in 

the open buildings, processing buildings in Florida are 

coming up with concentrations of radon and progeny 

that are in parity with Blockson.

So all of a sudden we see that. So, oh, okay. So all 

of a sudden that original issue that was of great 

concern, now we have data, we have information, the 

measurements made at Blockson at about the same 

time.

And timing, by the way is, in my opinion not an issue 

because the wet processing of phosphate which is all 

we're really talking about, has been the same 

forever, you know, the way in which you process 

phosphate ore, it's been going on forever.
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24

Now, which brings us to timing. Okay, so the first 

thing I want to point out is the issue, surrogate issue 

related to open versus closed just went away, okay. 

Because we now have demonstrated that in theory 

originally we were worried about it but now with the 

Blockson data we could say, that's not a really 

important issue because they appear to be and they 

were all pretty low, by the way.

We're talking about concentrations of radon and 

progeny that are background. I mean, that's where 

we are, which is interesting. But that's the truth.

Ms. Beach: So John -- John, this is Josie.

Dr. Mauro: Yes?

Mr. Beach: Can I stop you for just a quick sec? Where 

does the Blockson data come into O-43?

Dr. Mauro: No. I'm only bringing up a point of one of 

the issues had to do with surrogate data from the 

OTIB-43 --

Ms. Beach: Right.

Dr. Mauro: -- the measured data for open buildings.

Ms. Beach: Okay. So, that was your original --

Dr. Mauro: That was original-original and, by the way 

--

Ms. Beach: Okay.

Dr. Mauro: -- that's also an issue as applied to Allied 

Chemical. That's a closed building too. So what I'm 

trying to say is --

Chair Ziemer: Yes, it's pretty --

Dr. Mauro: -- what --

Chair Ziemer: The 43 is pretty much Florida stuff.
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25

Dr. Mauro: Yes. I think -- yes?

(Simultaneous speaking.)

Ms. Beach: Okay. I -- going back and forth between 

the 2015 and then the O-43 is just, I want to make 

sure I understand. Thanks.

Dr. Mauro: Yes, I want to, please stop me at any 

point because I think, in my head, conceptually, I've 

come, I'm at a point where I'm comfortable and I'm 

trying to explain why. And one had to do with the 

open facility in Florida, processing plants and closed 

buildings elsewhere such as Allied Chemical and 

Blockson.

And that was originally the starting point for one of 

the surrogate data concerns. I believe that that issue 

has gone away now simply because we're seeing that 

the measured, the measured values in the open 

buildings in Florida, OTIB-43 and the closed building, 

in this case Blockson, their numbers are comparable 

and they're very low.

And now what's the other issue? The other issue is 

timing. We're talking about measurements made 

both at Blockson and at FIPR, Florida. And well, one 

were made, I guess, decades later.

In other words, both measurements are made -- you 

folks -- I remembered that they're relatively recent 

compared to when Allied Chemical operated, which I 

believe was in the 50s. There's your timing issue.

Well I would argue that when it comes to phosphate 

ore processing, timing is a non-issue because there's 

nothing about the nature of the processing that is, 

that really changes over history.

The same digestive mechanisms are at play. So, I 

think that timing in terms of things may have 

changed substantially, doesn't apply.
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26

And then it brings us to one last issue. It has to do 

with the size of the building and the amount of 

material. The size of the building at Allied, smaller. 

The amount of material is orders of magnitude less 

by way of throughput of ore, maybe a 1,000 times 

smaller. You folks have the numbers on your 

fingertips, probably, right there.

Now so, in my mind, using concentrations as your 

starting point, which is surrogate, which you're are 

either FIPR, which is OTIB-43, in other words, OTIB43, its foundation is FIPR data.

It has been validated. Now that yep, you can apply 

FIPR data open buildings to closed buildings.

Ms. Behling: It seems like they're saying on the right, 

and then it's on the left?

(Simultaneous speaking.)

Dr. Mauro: I'm sorry?

Chair Ziemer: Kathy, I think you're off mute because 

and we're hearing you.

Ms. Behling: Okay, sorry. Sorry. Go ahead.

Dr. Mauro: Okay. Now so, what is then you say to 

yourself, okay notwithstanding the model that, I'm 

sort of putting it in the parking lot right now, the 

model that David Allen used to try to cut the deal to 

come to say well listen, let's make this little room, 

put all the activity in the room and let it, I mean, to 

me that's a very, very bounding, unrealistically highbounding analysis to make such an assumption.

So, let's just put that apart. I'm saying something 

different. I'm saying you could take either the FIPR 

data or the Blockson data and say to yourself, do I 

want to use that for Allied Chemical.

And I said, it would be really, really an overestimate, 
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27

and the reason being the throughput of ore is, you 

know, you have the numbers there, but if I recall 

we're talking a thousand times smaller. So what do 

you do?

You say, listen, let's just, you know, and we realize 

the building is smaller also. And here's where a little 

bit of what I call let's not over-analyze the problem. 

They divide it by ten, they said.

And to me they could have divided by a thousand. 

But they divide it by ten because of the throughput 

difference and they're still coming -- now stay with 

me. Now what I believe that does is it gives you a 

working level or a radon concentration in Allied 

Chemical that's probably overestimated by at least a 

factor of ten.

In other words -- but they just divided by ten and 

here's a very important point. So what they've come 

up with is what I believe to be an unrealistic 

overestimate of what the concentrations might have 

been in Allied and, still, you're below doses that are 

compensable. I mean, that's where I come out.

I say see, in my world when you use an efficiency 

approach or a bounding approach or an overestimate 

approach, that's always okay as long, because it's an 

efficiency method and, certainly correct me because 

my recollection of some of these things goes back a 

lot of years and a lot of, you know, water has flown 

under the bridge, you know.

But I believe it's okay to do that, overestimate, when 

in the end you still are not compensating. If this was 

compensated, I would say we've got a problem. I 

mean, you just can't throw a big number, but you can 

throw a big number at something that everyone 

would agree is a big number and you're still not 

compensating? Well, problem solved.

So, that's my take away on, yes, there are surrogate 
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28

data issues that are at play here, all of which I believe 

can be reconciled. And I just went through my story 

of why I've come to a comfortable place. Why 

NIOSH's approach is fine.

By Bob Anigstein

Chair Ziemer: Thank you, John. Bob, do you have 

additional comments on the SC&A's position? Is Bob 

still there? Not hearing him.

Dr. Mauro: By the way, Bob is not, I mean, he may 

have left I'm not sure or maybe he's on mute. We, 

Bob and I --

Mr. Anigstein: I'm here.

Dr. Mauro: Oh, okay. Bob, you're back. Good. Yes. 

Bob, there was --

Mr. Anigstein: Yeah, I'm here. What's the question?

Chair Ziemer: Did you have additional comments, do 

you have what John -- I take it that SC&A's position 

is that you are comfortable with NIOSH's approach?

Mr. Anigstein: Yes.

Chair Ziemer: Even though --

Mr. Anigstein: I would simply take a slightly different 

take on it than John did, and that is the three 

measurements, three sets of measurements at 

Blockson would probably be a better surrogate than 

the FIPR data.

But since it's, they're consistent within a factor of 

two, I think the FIPR data the way it was used was 

the 95th percentile, so obviously it should be higher. 

If it was consistent with Blockson it should also be 

higher because we don't have 20 measurements.

So I think the surrogate data isn't quite clear, 
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29

whether that's the exact correct number but 

certainly, in this instance, it's certainly bounding. It's 

unlikely that the radon exposures at Allied were 

higher because quite frankly they were much lower.

And as John said, for the purpose of denial of the 

claim, it's accepted. The denial for quote is 

acceptable. I mean it's a difficult, do to discuss your 

data it's a difficult problem. I think NIOSH did the 

best that could be done with it.

Chair Ziemer: Yes. Remind me, Dave Allen, what, 

with the NIOSH concentration values, what would an 

annual exposure turn out to be for the worker? 

Wasn't in a couple millirem range?

Mr. Allen: Well, these working level, the working level 

values are actually put into IREP as an exposure 

model when it comes to lung cancers.

Chair Ziemer: Yes.

Mr. Allen: So it's actually put in as working levels and 

we produce a POC. We don't actually get any dose.

Chair Ziemer: Yes. So you don't actually produce a -

-

Mr. Anigstein: Paul, I believe that NIOSH is using the 

UNSCR approach, which is, for radon, they use the 

data on incidence of lung cancer and relate it to radon 

concentrations and they skip the dose calculations. 

So we go directly from working levels to --

(Simultaneous speaking.)

Chair Ziemer: Yes. Yes, I was trying to get a feel for 

how it would compare to a significant lung dose if you 

were to go to, say a millirem value. But I guess you 

don't have a specific number that that would 

translate to.

But these concentrations compared to normal 
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30

backgrounds in homes, which are in a few working 

level months' value are really low.

Mr. Anigstein: Well, there is a little light cast on it 

because John Mauro, earlier on, back in 2015 did, in 

fact -- and probably Kathy helped, was also involved 

-- in doing a IREP run based strictly on four picocuries 

per liter, which would --

Chair Ziemer: Yes, which was the Environmental 

Protection Agency value recommended for upper 

limit for homes before you could --

Mr. Anigstein: Right. And that corresponded to 

something like a 60 percent POC. Chair Ziemer: Yes.

Mr. Anigstein: Ignoring all other source terms or 

other sources of dose to the lungs.

Chair Ziemer: Yes.

Dr. Mauro: You make -- yes, I think it's important to 

point out that when I did that, back then, we were in 

a funny place. Said, listen, John, he asked me, you 

know, what kind of levels might be there?

I said, well, you know, we don't know and I said, well 

one thing I know is that my basement has one 

picocurie per liter. Where I'm sitting right now.

And I know that EPA set a limit and people are fixing 

homes all over the country. Got data from all over 

the country that's on the order of one to four 

picocuries per liter. Occasionally you have a higher -

- buildings.

So I went down that road and then unfortunately, 

interesting enough, and this was brought out by 

Dave, and he was right, is that well, you know, yes, 

we did, but you know, the radon levels in these 

buildings from the ore processing doesn't approach 

that. And he was right.
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31

And so I went down a road that was at the time I 

thought was reasonable, but it turns out it's not a 

good approach. The right approach is to say, wait a 

minute, no, no, no, let's look at what the measured 

values are in real operating plants. And it's an 

interesting observation.

Now I would be the first to say that those 

measurements that they made in FIPR, that might 

very well be background, you know, I mean, so that's 

where we're operating at.

We're operating at background levels that everyone 

-- you sitting right where you are, where you are 

right now, it's probably what you're getting, you 

know.

So what I'm getting at is that notwithstanding a lot 

of the struggling we're going through is to say, well 

how do we deal with the surrogate issue. And I 

explained to you my rationale why I think the 

surrogate issue has been taken care of.

But at the same time, Paul, we're talking about levels 

that are comparable to the levels that we're all 

exposed to all the time indoors and that has to be 

kept in mind. You can't lose sight of that perspective, 

so, on both levels.

And, by the way, interestingly enough you're coming 

up with POCs that are pretty high. It goes to show 

you radon is, it doesn't take very much to be a 

problem.

We're all living our lives in the level of radon 

concentration that's -- now I'm being a little 

speculative -- knocking on the door of a level that 

could theoretically be argued can cause lung cancer 

at a, exceed a POC of .5 and we're all living at that.

And so radon, it doesn't take very much radon to be 

a problem. But I think in this case we're showing that, 
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32

you know, they put an upper bound, a reasonable 

upper bound and we're still coming in with a POC 

that's below .5, and I think that's where the story 

ends.

Chair Ziemer: Yes. Well, I think, is it fair to say the 

bottom line for SC&A is that you accept NIOSH's 

approach? Is that a fair statement?

Dr. Mauro: Well, I think speaking for SC&A the 

answer is yes.

Work Group Discussion and Recommendations

Chair Ziemer: Okay. Thank you. Let me ask the work 

group. Jim Lockey and Ms. Valerio, Ms. Beach, any 

questions for SC&A or for NIOSH? Further clarity or -

- go ahead.

Member Lockey: When I was looking at the levels and 

sort of doing what John did, is these levels that we're 

talking about really are not of, I would say of clinical 

significance from a physician point of view. In other 

words, I would not consider this an injurious 

exposure at those levels.

Chair Ziemer: I want to ask Ted -- Ted, does this 

subcommittee need to make a specific 

recommendation as to whether or not surrogate data 

criteria are met or do we simply need to make a 

decision on whether we endorse or accept NIOSH's 

approach for using OTIB-43 in the dose 

reconstructions for this site?

Mr. Katz: Yes, I think, Paul, you just need to make 

the general recommendation that there's not a 

surrogate data issue here, if that's what I'm hearing 

correctly and the methodology is fine. And that then 

settles matters generally and then it also allows the 

dose reconstruction subcommittee to close out its 

case.
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33

So, it would be a, and your recommendation really is 

a, I mean your finding I would say not a 

recommendation, is just a finding that you then send 

back to the DR subcommittee.

But it would also, it would also stand for, you know, 

this work group's position, should this ever come up, 

I don't see that it necessarily will but if there's a site 

profile review for this for the Board to consider then 

that would --

Chair Ziemer: Yeah.

Mr. Katz: -- that would just be included in that site 

profile would be for your recommendation to the 

Board. Yes.

Chair Ziemer: Thank you.

Ms. Beach: So this is Josie. It would seem to me that 

we would need some kind of a write-up. I know we've 

had this discussion and maybe the transcript will be 

write-up enough on the surrogate data issue and the 

parameters of the Board's surrogate data issues 

being met to follow along with this. Is that not true 

or --

Mr. Katz: Yes. I think and then just a fairly brief 

memo referencing the transcript and just the most 

salient points, like a very brief paragraph from this 

work group would be adequate.

Chair Ziemer: Well, Ted, I would like something on 

that.

Mr. Katz: I'm sorry, Paul, I couldn't hear you.

Chair Ziemer: I would like to see something written 

from SC&A that identifies what John has told us, John 

and Bob have told us. And we could have that in the 

record as well as in the transcript, but, you know, a 

brief white paper or memo indicating I think basically 
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34

what John summarized for us.

And then we could maybe close this out well, would 

we need to do that in-person or I mean, by phone or 

can we do it, just, agree to do it after we get that?

Mr. Katz: So I don't, I think you can, I mean if you 

all conclude this is your conclusion, I don't think you 

have to wait for that. I think you can have, 

absolutely, and I think it's a good idea for John to 

write a summary memo that references this call as 

well and what was discussed and what SC&A's ending 

recommendation was.

But I think that the work group can act on it. You 

don't need another work group meeting to act on it 

because you already all concluded it.

Ms. Beach: Well --

Mr. Anigstein: This is Bob. Can we, can we wait for 

that until we get the, at least a rough draft of the 

transcript because it's a lot easier working from the 

transcript than just working from memory?

Mr. Katz: Yes, yes. There's no reason why you can't. 

Yes.

Ms. Beach: Well --

Mr. Anigstein: Okay. Paul, could you --

Chair Ziemer: Another question?

Ms. Beach: Yes, this is Josie. I do have one more 

comment. But I can wait for Bob.

Chair Ziemer: Yes, go ahead.

Ms. Beach: Well, Dave said something earlier on, 

Dave Allen, about how, about the surrogate data and 

how it's supposed to be met.
for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has 

been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

35

And so it, and I don't want to put words into Dave's 

mouth but, that it was, something about it being 

impossible to meet this criteria. Dave, do you 

remember what you, exactly, said? I think it's 

important --

Mr. Allen: I'm sure I don't remember my exact words 

but what I was trying to say was some of that criteria 

says you need equivalent source term processes, 

conditions. And that just doesn't seem to apply to a 

bounding estimate.

I think John and most others have come to that 

conclusion, that this is a bounding estimate. But I'm 

not sure how you judge this against that criteria 

unless maybe you substitute the word bounding for 

equivalent. It just doesn't seem like that criteria will 

work well for a bounding estimate.

Chair Ziemer: One of the things about bounding is 

that it makes assumptions that are sometimes 

unrealistic which takes you, in a sense, that says 

you're not really going one for one as a surrogate but 

you're doing, you're overestimating.

A lot of overestimating is, you know, we've always 

agreed is usually a little unrealistic but I think --

(Simultaneous speaking.)

Dr. Mauro: I think, yes --

Mr. Katz: Paul, this is Ted. I'm sorry.

Dr. Mauro: I'm sorry, Ted.

Mr. Katz: It's okay and you can follow me, but I was 

just going to say I think there's a difference between 

saying the surrogate data criteria were met and 

saying that the surrogate data are not an issue here 

with this dose reconstruction approach. But go 

ahead, John.
for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has 

been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

36

Dr. Mauro: Oh, you used up the wind out of my sails.

Mr. Katz: I'm sorry.

Dr. Mauro: I think that, that this is, when you're in 

the place where you're not, if you're trying to do a 

realistic dose reconstruction, certainly surrogate data 

becomes essential.

In this mode whereby we're trying to place a 

bounding, all of a sudden surrogate data -- and you 

certainly need to say something intelligent about it, 

hopefully we did.

But you're right, you really, the surrogate data 

criteria may not be explicitly met when you're in this 

mode of placing an upper bound on an exposure --

and you demonstrate that there's still no 

compensation. If there was compensation here, we'd 

be having a whole different conversation.

Mr. Katz: Let me just add, I mean, so thank you John, 

let me just add, the other thing just for the board 

members to keep in mind, well everybody, I guess, 

is it's somewhat comparable to what we've already 

said with co-worker modeling as well, which is when 

we're talking about levels of dose that are 

exceptionally low and inconsequential, it's a different 

matter and we're not applying criteria the way we 

would when we have substantial doses and we're 

trying to estimate reasonably. So, and that's a 

position the board took related to co-worker 

modeling as well.

Chair Ziemer: So the wording that we would need to 

agree on would be along the lines of, well, I'm trying 

to recall the wording you said, Ted, not that the 

criteria were met but that what?

Mr. Katz: That surrogate data, it's not really a matter 

of surrogate data being applicable in this case 

because this is a bounding estimate and because 
for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has 

been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

37

these are not consequential levels of exposure.

Chair Ziemer: The surrogate data issue is dealt with? 

That's different than saying it's met. Is that, I'm 

trying to find the --

(Simultaneous speaking.)

Chair Ziemer: What?

Mr. Katz: I was saying they're not really applicable in 

this circumstance but --

Dr. Taulbee: Hey, can I offer a word here, this is Tim. 

How about that there is no surrogate data issue with 

the approach that's used for this dose reconstruction?

Chair Ziemer: That's the wording. That's the wording.

Yes. Data issue.

Ms. Beach: Well, the surrogate data issue actually 

came up with the 2015, what we were doing early on, 

right? So this new --

Chair Ziemer: Right. Right. And it was raised by SC&A 

originally, was it not?

Dr. Mauro: Yes. Yes. Yes.

Mr. Katz: But, I mean, the subcommittee actually 

came to the same conclusion earlier on before Dr. 

Melius wanted to have more examination of the 

questions. So it's actually pretty consistent with 

where the subcommittee went with this.

Chair Ziemer: Okay. Well, let me ask if individual 

members of the work group are comfortable or 

satisfied with that as our position. Let me ask you 

individually. Josie, are okay with that?

Ms. Beach: Yes. Yes, I am.

Member Lockey: Yes, Jim Lockey, I'm okay with that.
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been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

38

Member Valerio: Loretta Valerio, I'm okay with that. 

And I also have one quick comment on John Mauro's 

--

Chair Ziemer: Oh sure, yes.

Member Valerio: -- regarding what John Mauro said. 

My question was on the open versus closed buildings. 

And when he explained it and how it was resolved, 

that made it much clearer for me so thank you, John, 

for that.

Chair Ziemer: Yes.

Dr. Mauro: You're welcome.

Chair Ziemer: And you're okay then going ahead, 

Loretta?

Member Valerio: Yes, sir.

Chair Ziemer: Okay. And I'm agreeable and so, Ted, 

I think we have the final conclusion.

Mr. Katz: Right.

Future Follow-Up

Chair Ziemer: And we'll have SC&A back their 

comments up at the appropriate time when they get 

the transcripts. Is that good?

Mr. Katz: Yes, so that's good. And then, Paul, but 

then, and the final act would just be for you to send 

the memo to the DR subcommittee and you can just 

attend to it in the SC&A report.

(Simultaneous speaking.)

Chair Ziemer: Yes. Very good.

Mr. Katz: And that would be a nice way to wrap this 

up.
for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information has 

been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Surrogate Data Work Group for accuracy at this time. The reader should be cautioned 

that this transcript is for information only and is subject to change.

39

Adjourn

Chair Ziemer: Okay. Thank you very much, 

everybody. I appreciate everybody's work on this and 

that concludes our meeting. We'll see everybody in a 

couple of weeks or a week and a half or whenever it 

is, coming soon.

Mr. Katz: Bye-bye. A week from now, yes.

Member Valerio: Thank you.

Ms. Beach: A week from today.

Chair Ziemer: We are adjourned now.

(Whereupon, the above-entitled matter went off the 

record at 2:39 p.m.)