Office of Compensation Analysis and Support 

Document Number: 

OCAS-PR-003 

Effective Date: (9/24/02) 

Revision No. 0 

Performing and Reporting Dose Reconstructions Page 1 of 20 

Approval: Signature on File Date: 9/24/02

 J.W. Neton, OCAS Health Science Administrator 

Concurrence: Sinature on File Date: 9/24/02 

L. J. Elliott, OCAS Director 

Supersedes:

 None 

Subject Expert: Grady Calhoun x4377 

TABLE OF CONTENTS 

SECTION TITLE PAGE 

1.0 PURPOSE ......................................................... 3 

2.0 SCOPE ............................................................ 3 

3.0 REFERENCES ..................................................... 3 

4.0 RESPONSIBILITIES ................................................. 3 

5.0 GENERAL .......................................................... 3 

6.0 PROCEDURE 

6.1 Claim Receipt ........................................... 5 

6.2 Evaluate Available Data/Information ....................... 6 

6.3 Claimant Interview ....................................... 9 

6.4 Document Claimant Interview ............................. 9 

6.5 Provide Interview Report to Claimant ....................... 9 

6.6 Claim Evaluation ...................................... 10 

6.7 Internal Dose Calculation Methodology ................... 10 

6.8 External Dose Calculation Methodology .................. 11 

6.9 Initial Dose Evaluation ................................. 11 

6.10 Secondary Dose Evaluation ............................ 12 

6.11 Refining Dose Reconstruction ........................... 12 

6.12 Report Preparation .................................... 12 

6.13 Dose Reconstructions that Cannot Be Completed .......... 13 

6.14 Report Review ........................................ 14 

6.15 Draft Report Distribution ................................ 15 

6.16 Closing Interview with Claimant .......................... 15 

6.17 Preparation of Administrative Record ..................... 15 

6.18 Final Report Distribution ................................ 16 

6.19 Claim Closing ......................................... 16 

6.20 Review of Completed Dose Reconstructions .............. 17 

7.0 RECORDS ....................................................... 17 

 

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8.0 DEFINITIONS ...................................................... 17 

RECORD OF ISSUE/REVISIONS 

ISSUE 

AUTHORIZATION 

DATE 

EFFECTIVE 

DATE 

REV. 

NO. 

DESCRIPTION 

9/24/02 9/24/02 0 New document to establish program guidelines 

for performing dose reconstruction. Initiated by 

Grady Calhoun. 
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1.0	 PURPOSE 

The purpose of this procedure is to provide guidance for the Office of Compensation Analysis and 

Support (OCAS) staff and its technical support contractors in the performance, review, and 

documentation of dose reconstructions for covered employees with cancer per the requirements of 42 

CFR 82, “Methods for Radiation Dose Reconstruction Under the Energy Employees Occupational 

Illness Compensation Program Act of 2000.” 

2.0	 SCOPE 

This procedure applies to OCAS personnel and its technical support contractors involved in 

performing dose reconstructions for covered employees. 

3.0	 REFERENCES 

3.1	 OCAS-IG-001, “External Dose Reconstruction Implementation Guide” 

3.2	 OCAS-IG-002, “Internal Dose Reconstruction Implementation Guide” 

3.3	 Energy Employees Occupational Illness Compensation Program Act (EEOICPA) 

3.4	 42 CFR 82, “Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000: Interim Final Rule With Request for 

Comments.” 

3.5	 20 CFR 30, “Performance of Functions Under This Chapter; Claims for Compensation Under 

the Energy Employees Occupational Illness Compensation Program; Final Rule.” 

4.0	 RESPONSIBILITIES 

Records Management Team Leader - Oversees the receipt and maintenance of data provided by the 

Department of Labor and the Department of Energy, processes requests for additional information, 

and maintains records of all correspondence associated with dose reconstructions. 

Health Physicist - Performs and reviews dose reconstructions. 

OCAS Health Science Administrator - Oversees the dose reconstruction process. 

5.0	 GENERAL 

The Energy Employees Occupational Illness Compensation Program Act (EEOICPA), provides for the 

payment of compensation benefits to covered employees and, where applicable, survivors of such 

employees, of the United States Department of Energy, its predecessor agencies and certain of its 

contractors and subcontractors. Among the types of illnesses for which compensation may be 

provided are cancers. As provided below, there are two categories of covered employees with cancer 

under EEOICPA for whom compensation may be provided. This procedure applies only to the 

category of employees described under 5.1. 

5.1	 Employees with cancer for whom a dose reconstruction must be conducted, as required under 

20 CFR 30.115. 

5.2	 Members of the Special Exposure Cohort seeking compensation for a specified cancer, as 
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defined under EEOICPA. The U.S. Department of Labor (DOL) which has primary authority for 

implementing EEOICPA, has promulgated regulations at 20 CFR 30.210 and 30.213 that identify 

current members of the Special Exposure Cohort and requirements for compensation. 

Dose reconstructions are to be conducted for the following covered employees with cancer seeking 

compensation under EEOICPA: An employee who was not monitored for exposure to radiation at 

DOE or Atomic Weapons Employer (AWE) facilities; an employee who was monitored inadequately 

for exposure to radiation at such facilities; or an employee whose records of exposure to radiation at 

such facility are missing or incomplete. Technical limitations of radiation monitoring technology and 

procedures will require evaluations of each employee's recorded dose. In most, if not all cases, 

monitoring limitations will result in possibly undetected or unrecorded doses, which are estimated 

using commonly practiced dose reconstruction methods and would have to be added to the dose 

record. 

NIOSH will conduct a dose reconstruction for each claim determined by DOL to be a claim for a 

covered employee with cancer under DOL regulations at 20 CFR 30.210(b), subject to the limitations 

of available data. 

The procedures and level of effort involved in dose reconstructions depend in part on the quantity and 

quality of available dose monitoring information, the conditions under which radiation exposure arose, 

and the forms of radiation to which the individual was exposed. If individuals for whom dose estimates 

are needed were monitored using present day technology and received only external radiation doses, 

dose reconstruction could be very simple. It might only require summing the radiation doses recorded 

from radiation badges and adding estimated potential "missed" doses resulting from the limits of 

detection of monitoring badges. 

Dose reconstruction can require extensive research and analysis. Such work is required if radiation 

doses were not monitored or there is uncertainty about the monitoring methods involved; if there was 

potential for internal doses through the ingestion, inhalation or absorption of radioactive materials; or if 

the processes and circumstances involved in the radiation exposures were complex. For the most 

complex dose reconstructions, research and analyses may include determining or assuming specific 

characteristics of the monitoring procedures; identifying events or processes that were unmonitored; 

identifying the types and quantities of radioactive materials involved; evaluating production processes 

and safety procedures employed; identifying the locations and activities of exposed persons; 

identifying comparable exposure circumstances for which data is available to make assumptions; and 

conducting a variety of complex analyses to interpret the data compiled or estimated. 

As necessary, NIOSH will characterize the internal and external exposure environments for 

parameters known to influence the dose. For internal exposures, examples of these parameters 

include the mode of intake, the composition of the source term (i.e., the radionuclide type and 

quantity), the particle size distribution and the absorption type. When it is not possible to characterize 

these parameters, NIOSH may use default values, when they can be established reasonably, fairly, 

and based on relevant science. 

For external exposures, the radiation type (gamma, x-ray, neutron, beta, or other charged particle) and 

radiation energy spectrum will be evaluated. When possible, the effect of non- uniformity and 

geometry of the radiation exposure will be assessed. 

For each dose reconstruction, records relevant to internal and external exposures to ionizing radiation, 

including exposures from medical screening x rays that were required as a condition of employment 

will be included. 

Dose reconstructions will be performed in a conservative manner such that uncertainties concerning 

data quality or dose are handled in a manner favorable to the claimant. 
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The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed and to then place each worker in time and space within this exposure 

environment. Then methods are applied to translate exposure to radiation into quantified radiation 

doses at the specific organs or tissues relevant to the types of cancer occurring among the workers. 

A hierarchy of methods is used in a dose reconstruction, depending on the nature of the exposure 

conditions and the type, quality, and completeness of data available to characterize the environment 

If found to be complete and adequate, individual worker monitoring data, such as dosimeter readings 

and bioassay sample results, are given the highest priority in assessing exposure. These monitoring 

data are interpreted using additional data characterizing the workplace radiation exposures. If radiation 

exposures in the workplace environment cannot be fully characterized based on available data, default 

values based on reasonable and scientific assumptions may be used as substitutes. For dose 

reconstructions conducted in occupational illness compensation programs, this practice may include 

use of assumptions that represent the worst case conditions. For example, if the solubility 

classification of an inhaled material can not be determined, the dose reconstruction would use the 

classification that results in the largest dose to the organ or tissue relevant to the cancer and that is 

possible given existing knowledge of the material and process. 

If individual monitoring data are not available or adequate, dose reconstructions may use monitoring 

results for groups of workers with comparable activities and relationships to the radiation environment. 

Alternatively, workplace area monitoring data may be used to estimate the dose. As with individual 

worker monitoring data, workplace exposure characteristics are used in combination with workplace 

monitoring data to estimate dose. 

If neither adequate worker nor workplace monitoring data are available, the dose reconstruction may 

rely substantially on process description information to analytically develop an exposure model. For 

internal exposures, this model includes such factors as the quantity and composition of the radioactive 

substance (the source term), the chemical form, particle size distribution, the level of containment, 

and the likelihood of dispersion. 

An iterative process is used to expedite the processing of claims to ensure that dose reconstructions 

are completed in a claimant-friendly manner. If using an individual’s minimum realistic exposure, or a 

portion of an individual’s exposure (internal, external, or internal and external combined) results in a 

high probability of causation, then no further evaluation will be performed. Conversely, if the worstcase exposure (internal plus external) scenario results in a low probability of causation, then no further 

evaluation will be performed. Detailed dose reconstructions will be performed on those cases where 

the probability of causation is not evidently clear. Attachment 1, “Dose Reconstruction Flow Process” 

illustrates the decision logic used during the dose reconstruction process. 

6.0 PROCEDURE 

6.1 Claim Receipt 

Records Management Team 

6.1.1 Receive, process and maintain the claims provided by the DOL in accordance with OCASPR-002, “Processing Compensation Claims.” 

6.1.2 Request records from the DOE on radiation dose monitoring and radiation exposures
 

associated with the employment history of the covered employee.
 

6.1.3 Notify OCAS Health Science Administrator or designee when personnel exposure information 

is received. 

Health Physicist 
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6.2 Evaluate Available Data/Information 

6.2.1 Information provided by the claimant will be accepted and used for dose reconstruction, 

providing it is reasonable, supported by substantial evidence, and is not refuted by other 

evidence. In assessing whether the information provided by the claimant is supported by 

substantial evidence, consider: 

6.2.1.1	 Consistency of the information with other information in the possession of NIOSH, from 

radiation safety programs, research, medical screening programs, labor union 

documents, worksite investigations, dose reconstructions conducted by NIOSH under 

EEOICPA, or other reports relating to the circumstances at issue 

6.2.1.2	 Consistency of the information with medical records provided by the claimant; 

6.2.1.3	 Consistency of the information with practices or exposures demonstrated by the dose 

reconstruction record developed for the claimant 

6.2.1.4	 Confirmation of information by co-workers or other witnesses 

6.2.2 Attempt to confirm information provided by the claimant through review of available records 

and records requested from DOE. 

6.2.3 As necessary, request additional records from DOE to characterize processes and tasks 

potentially involving radiation exposure for which dose and exposure monitoring data is 

incomplete or insufficient for dose reconstruction. 

6.2.4 Compile any data, and information from NIOSH records that may contribute to the dose
 

reconstruction.
 

6.2.5 Evaluate the initial radiation exposure record compiled to: Reconcile the exposure record with 

the reported employment history, as necessary; complete preliminary calculations of dose, 

based upon this initial record, and prepare to consult with the claimant. 

6.2.6 Any discrepancies in the employment history information will be reconciled with the
 

assistance of DOE, as necessary. 

6.2.7 Use the following sources of information for dose reconstructions, as necessary: 

6.2.7.1	 DOE and its contractors, including Atomic Weapons Employers and the Former 

Worker Medical Screening Program 

6.2.7.2	 NIOSH and other records from health research on DOE worker populations 

6.2.7.3	 Interviews and records provided by claimants 

6.2.7.4	 Co-workers of covered employees, or others with information relevant to the covered 

employee's exposure, that the claimant identified during the initial interview with NIOSH 

6.2.7.5	 Labor union records from unions representing employees at covered facilities of DOE 

or AWEs 

6.2.7.6	 Any other relevant information 

6.2.8 Obtain the types of information described in this section for dose reconstructions, as
 

necessary and available: 
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6.2.8.1 Subject and employment information, including: 

(A)	 Gender 

(B)	 Date of birth 

(C)	 DOE and/or AWE employment history, including: job title held by year, and work 

location(s): Including site name(s), building number(s), technical area(s), and duration 

of relevant employment or tasks. 

6.2.8.2 Worker monitoring data, including: 

(A)	 External dosimetry data, including external dosimeter readings (film badge, TLD,
 

neutron dosimeters)
 

(B)	 Pocket ionization chamber data 

6.2.8.3 Internal dosimetry data, including: 

(A)	 Urinalysis results 

(B)	 Fecal sample results 

(C)	 In Vivo measurement results 

(D)	 Incident investigation reports 

(E)	 Breath radon and/or thoron results 

(F)	 Nasal smear results 

(G)	 External contamination measurements 

(H)	 Other measurement results applicable to internal dosimetry 

6.2.8.4 Monitoring program data, including: 

(A)	 Analytical methods used for bioassay analyses 

(B)	 Performance characteristics of dosimeters for different radiation types 

(C)	 Historical detection limits for bioassay samples and dosimeter badges 

(D)	 Bioassay sample and dosimeter collection/exchange frequencies 

(E)	 Documentation of record keeping practices used to record data and/or administratively 

assign dose (F)	 Other information to characterize the monitoring program procedures and evaluate
 

monitoring results.
 

6.2.8.5 Workplace monitoring data, including: 

(A)	 Surface contamination surveys 

(B)	 General area air sampling results 

(C)	 Breathing zone air sampling results 

(D)	 Radon and/or thoron monitoring results 

(E)	 Area radiation survey measurements (beta, gamma and neutron) 

(F)	 Fixed location dosimeter results (beta, gamma and neutron) 

(G)	 Other workplace monitoring results 

6.2.8.6 Workplace characterization data, including: 

(A)	 Information on the external exposure environment, including: Radiation type (gamma, xray, neutron, beta, other charged particle); radiation energy spectrum; uniformity of 

exposure (whole body vs partial body exposure) 

(B)	 Information on work-required medical screening x-rays 

(C)	 Other information useful for characterizing workplace radiation exposures 

6.2.8.7 Information characterizing internal exposures, including: 
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(A)	 Radionuclide(s) and associated chemical forms 

(B)	 Results of particle size distribution studies 

(C)	 Respiratory protection practices 

(D)	 Other information useful for characterizing internal exposures 

6.2.8.8	 Process descriptions for each work location, including: 

(A)	 General description of the process 

(B)	 Characterization of the source term (i.e., the radionuclide and its quantity) 

(C)	 Extent of encapsulation 

(D)	 Methods of containment 

(E)	 Other information to assess potential irradiation by source or potential for airborne 

radioactive material 

6.2.9 Evaluate the completeness of an individual's monitoring data provided by DOE through one 

or more possible measures including, but not limited to: 

6.2.9.1	 Comparisons with information provided by claimants, co-workers, and other witnesses 

6.2.9.2	 Comparisons with available information on area monitoring, production processes, and 

radiologic protection programs 

6.2.9.3	 Comparisons with information documented in the records of unions representing
 

covered employees
 

6.2.9.4	 Comparisons with data available on co-workers 

6.2.9.5	 Reviews of DOE contractor record systems. 

6.2.10	 As appropriate, evaluate the instruments and procedures used to collect individual 

monitoring data to determine whether they adequately characterized the radiation 

environments in which the covered employee worked (adequately for the purpose of dose 

reconstruction), based on present-day scientific understanding. 

6.2.10.1For external dosimeter measurements, this includes an evaluation of the dosimeter 

response to the radiation types (gamma, x-ray, neutron, beta, or other charged particle) 

and the associated energy spectrum. 

6.2.10.2For internal exposure, the methods used to analyze bioassay samples will be reviewed 

to determine their ability to detect the radionuclides present in the work environment. 

6.2.10.3An analysis of the monitoring, or exchange frequencies for the monitoring program(s), 

will also be conducted to determine the potential for undetected dose. 

6.2.11	 For external dosimeter results that are incomplete due to historical record keeping 

practices, use commonly practiced techniques to estimate the missing component of 

dose and to add this to the total dose estimate. 

6.2.12	 For monitoring periods where external dosimetry data are missing from the records, 

estimate a claimant's dose based on interpolation, using available monitoring results from 

other time periods close to the period in question, or based on monitoring data on other 

workers engaged in similar tasks. 

6.2.13	 Review historical bioassay sample detection limits and monitoring frequencies to 

determine, when possible, the minimum detectable dose for routine internal dose 

monitoring programs. This "missed dose" will establish the upper limit of internal dose that 
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a worker could have received for periods when bioassay sample analysis results were 

below the detection limit. 

6.2.14	 Using ICRP biokinetic models, estimate the internal dose and include an associated 

uncertainty distribution. 

6.2.15	 The following types of information can be used to supplement or substitute individual 

monitoring data: 

6.2.15.1Monitoring data from co-workers, if it is determined they had a common relationship to 

the radiation environment 

6.2.15.2A quantitative characterization of the radiation environment in which the covered 

employee worked, based on an analysis of historical workplace monitoring information 

such as area dosimeter readings, general area radiation survey results, air sampling 

data 

6.2.15.3A quantitative characterization of the radiation environment in which the employee 

worked, based on analysis of data describing processes involving radioactive 

materials, the source materials, occupational tasks and locations, and radiation safety 

practices 

6.3 Claimant Interview 

NIOSH Interviewer 

6.3.1 Interview the claimant. The interview may be conducted in one or more sessions. The
 

purpose of the interview is to: 

6.3.1.1	 Explain the dose reconstruction process 

6.3.1.2	 Confirm elements of the employment history transmitted to NIOSH by DOL 

6.3.1.3	 Identify any relevant information on employment history that may have been omitted 

6.3.1.4	 Confirm or supplement monitoring information included in the initial radiation exposure 

record 

6.3.1.5	 Develop detailed information on work tasks, production processes, radiologic 

protection and monitoring practices, and incidents that may have resulted in 

undocumented radiation exposures, as necessary 

6.3.1.6	 Identify co-workers and other witnesses with information relevant to the radiation 

exposures of the covered worker to supplement or confirm information on work 

experiences, as necessary. 

6.4	 Document Claimant Interview 

6.4.1 Document the claimant interview on the “NIOSH Claimant Interview under EEOICPA.” 

6.5	 Provide Interview Report to Claimant 

6.5.1 Provide a report to the claimant summarizing the findings of the interview, titled: "NIOSH 

Claimant Interview under EEOICPA.” 

6.5.2 Notify the claimant, in the report, of the opportunity to contact NIOSH if necessary, by a 
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specified date, to make any written corrections or additions to information provided by the 

claimant during the interview process. 

6.6 Claim Evaluation 

OCAS Health Science Administrator (or designee) 

6.6.1 Assigns claim to Health Physicist for evaluation. 

Health Physicist 

6.6.2 Ensure that all the following criteria have been met: 

6.6.2.1 The claimant meets the definition of covered employee and the Department of 

Labor has verified the covered employment period for the claimant. 

6.6.2.2 Documentation exists stating that the claimant has or has had a covered cancer. 

6.6.3 If either of the previous criteria are not met, then additional information is required prior to 

performing a dose reconstruction. Notify OCAS Health Science Administrator. 

6.7 Internal Dose Calculation Methodology 

6.7.1 In accordance with the guidance provided in the NIOSH Implementation Guide for Internal 

Dosimetry, calculate the dose to the organ or tissue of concern using the appropriate current 

metabolic models published by ICRP. Using data available to NIOSH, the models will be 

based on exposure conditions representative of the work environment. 

6.7.2 When exposure conditions cannot be established with sufficient specificity, the dose
 

calculation will assume exposure conditions that maximize the dose to the organ under
 

consideration.
 

6.7.3 Internal doses will be calculated for each year of exposure from the date of initial exposure to 

the date of cancer diagnosis. 

6.7.4 The calculation of dose from ingested, inhaled or absorbed radioactivity involves the 

determination of the types and quantities of radionuclides that entered the body. Use the 

results of all available bioassay monitoring information as appropriate, based on assessment 

of the technical characteristics of the monitoring program. 

6.7.5 If bioassay monitoring data are unavailable, the dose reconstruction will rely on the results of 

air sampling measurements, radiation sources, work processes and practices, and incidents 

involving radiation contamination, as necessary. 

6.7.6 When the cancer covered by a claim is in a tissue not covered by existing ICRP models, use 

the ICRP model that best approximates the model needed, while giving the benefit of the 

doubt to the claimant. 

6.7.7 For internal exposures, select the highest dose estimate from among the modeled organs or 

tissues that do not concentrate the radionuclide 

6.8 External Dose Calculation Methodology 

6.8.1 In accordance with the guidance provided in the NIOSH Implementation Guide for External 

Dosimetry, calculate the dose to the organ or tissue of concern. Using data available to 

NIOSH, the dose will be based on exposure conditions representative of the work 
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environment. 

6.8.2 When exposure conditions cannot be established with sufficient specificity, the dose
 

calculation will assume exposure conditions that maximize the dose to the organ under
 

consideration.
 

6.8.3 External doses will be calculated for each year of exposure from the date of initial exposure 

to the date of cancer diagnosis. 

6.8.4 The calculation of external dose involves the determination of the types and energies of 

radiation present as well as the direction from which the radiation entered the body. Use the 

results of all available external monitoring information as appropriate, based on assessment 

of the technical characteristics of the monitoring program. 

6.9 Initial Dose Evaluation 

The first step in performing an initial dose evaluation is to review the available exposure data and the 

specified primary cancer(s). For cases in which only a secondary cancer is listed, the dose to all 

possible primary cancer sites, as listed in Table 1 of 42 CFR 81, must be calculated. A judgement 

must then be made whether internal or external sources contributed the larger dose to the specified 

organ(s). This information will be used to determine which portion of the dose reconstruction will be 

performed first. The work activity and the types and sources of radiation to which an individual was 

potentially exposed must be evaluated. For example, external radiation would be the primary concern 

for an individual working with encapsulated radioactive material such as cladded fuel parts or radiation 

sources. Internal exposure would be the primary concern if an individual worked with un-encapsulated 

radioactive material, worked in airborne radioactivity areas, or worked with un-contained chemical 

operations. 

In addition to the radioactive material or radiation encountered in the workplace, the affected organ(s) 

and the potential routes of exposure to the organ(s) must be evaluated. For example, internal 

exposure is probably the highest contributor of dose to the lung for individuals working with uranium or 

transuranic elements with a relatively small emission of penetrating radiation. Conversely, an organ 

such as the prostate gland has very little likelihood of receiving significant dose from internal 

deposition of actinides because it is not an organ of significant accumulation. 

Once the most probable source of irradiation is determined, an evaluation of the potential dose is 

performed. Guidelines for performing internal and external dose reconstructions are found in OCASIG-001, “External Dose Reconstruction Implementation Guide” and OCAS-IG-002, “Internal Dose 

Reconstruction Implementation Guide.” During this initial evaluation, worst-case assumptions will be 

used to provide an overestimate of the dose. Probability of causation calculations will be performed to 

determine if this overestimated radiation dose will result in a high or low probability of causation. 

6.9.1 If the overestimated dose results in an estimated probability of causation less than 50%, then 

perform a similar assessment for the other source of irradiation. For example, if the internal 

exposure evaluation was performed first, complete an external exposure evaluation. 

6.9.1.1 If the sum of the internal and external doses results in a probability of causation of less 

than 50%, then the evaluation is complete. A report must be written per the 

requirements of step 6.12. 

6.9.1.2	 If the sum of the internal and external doses results in a probability of causation above 

50%, then the dose reconstruction must be further refined. 

6.10 Secondary Dose Evaluation 

Using the route of exposure (internal or external) resulting in the highest dose to the specified 
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organ(s), perform a secondary dose evaluation. The secondary evaluation uses an underestimated 

dose or even a partial dose to the organ or tissue of interest. 

6.10.1	 If the underestimated dose results in a high probability of causation (i.e., >50%), then no 

further evaluation is necessary. Prepare a report per step 6.12. 

6.10.2	 If the dose results in an estimated probability of causation less than 50%, then perform a 

similar assessment for the other source of irradiation. For example, if the internal 

exposure evaluation was performed first, complete an external exposure evaluation. 

6.10.2.1If the sum of the internal and external doses results in a probability of causation greater 

than 50%, then the evaluation is complete. A report must be written per the 

requirements of step 6.12. 

6.10.2.2If the sum of the internal and external doses results in a probability of causation of less 

than 50%, then the dose reconstruction must be further refined. 

6.11 Refining Dose Reconstruction 

The dose reconstruction process is an iterative one. Successive reconstructions will contain 

increasing detail. This process will continue until the dose clearly results in an estimated high or low 

probability of causation OR all relevant, available data has been used in the calculation. 

At any point during the dose reconstruction, NIOSH may determine that sufficient research and 

analysis has been conducted to complete the dose reconstruction. Research and analysis will be 

determined sufficient if one of the following three conditions is met: 

6.11.1	 From acquired experience, it is evident the estimated cumulative dose is sufficient to 

qualify the claimant for compensation (i.e., the dose produces a probability of causation of 

50% or greater); 

6.11.2	 Dose is determined using worst-case assumptions related to radiation exposure and
 

intake, to substitute for further research and analyses; or,
 

6.11.3	 All available data has been used. 

Worst-case assumptions will be employed under condition in step 6.11.2 of this section to limit further 

research and analysis only for claims for which it is evident that further research and analysis will not 

produce a compensable level of radiation dose (a dose producing a probability of causation of 50% or 

greater), because using worst-case assumptions it can be determined that the employee could not 

have incurred a compensable level of radiation dose. 

6.12 Report Preparation 

6.12.1	 An overview of the dose reconstruction must be included in the, “NIOSH Report of Dose 

Reconstruction under the Energy Employees Occupational Illness Compensation 

Program Act (EEOICPA). 

6.12.2	 The report will include the following information, as relevant: 

6.12.2.1Annual dose estimates (or a fraction thereof) related to covered employment for each 

year from the date of initial radiation exposure at a covered facility to the date of cancer 

diagnosis 

6.12.2.2Separate dose estimates for acute and chronic exposures, different types of ionizing 

radiation, and internal and external doses, providing dose information for the organ or 
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tissue relevant to the primary cancer site(s) established in the claim 

6.12.2.3Uncertainty distributions associated with each dose estimated, as necessary 

6.12.2.4Explanation of each type of dose estimate included in terms of its relevance for 

estimating probability of causation 

6.12.2.5Identification of any information provided by the claimant relevant to dose estimation 

that was omitted from the basis for dose reconstruction, justification for the decision, 

and if possible, a quantitative estimate of the effect of the omission on the dose 

reconstruction results 

6.12.2.6A summary and explanation of information and methods applied to produce the dose 

reconstruction estimates, including any factual findings and the evidence upon which 

those findings are based 

6.12.2.7For all claims in which worst-case assumptions are employed under the conditions of 

6.11.2, the reasoning that resulted in the determination to limit further research and 

analysis will be clearly described in the dose reconstruction results reported to the 

claimant and the DOL. 

6.12.2.8The estimate of each annual dose will be characterized with a probability distribution 

that accounts for the uncertainty of the estimate. 

6.12.3	 Once the resulting data set is complete, construct an occupational exposure matrix, 

using the general hierarchical approach discussed in step 5.0. 

6.12.3.1This matrix will contain the estimated annual equivalent dose(s) to the relevant 

organ(s) or tissue(s), for the period from the initial date of potential exposure at a 

covered facility until the date the cancer was diagnosed. 

6.12.3.2The equivalent dose(s) will be calculated using the current, standard radiation 

weighting factors from the International Commission on Radiological Protection. 

Note:	 All dose reconstructions must be reviewed and approved by an OCAS Health 

Physicist. 

6.12.4	 If the dose reconstruction was completed by a contract Health Physicist then the report 

must be forwarded to an OCAS Health Physicist for review. If the dose reconstruction 

was completed by an OCAS Health Physicist, then it must be forwarded to an OCAS 

Health Physicist other than the one performing the dose reconstruction. 

6.13 Dose Reconstructions that Cannot Be Completed 

6.13.1	 Notify in writing any claimants for whom a dose reconstruction cannot be completed once 

that determination is made, as well as in the closing interview provided for under step 

6.16. 

6.13.2	 Notification will describe the basis for finding a dose reconstruction cannot be completed, 

including the following: 

6.13.2.1A summary of the information obtained from DOE and other sources; and, 

6.13.2.2A summary of necessary information found to be unavailable from DOE and other 

sources. 
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6.13.3	 Notify DOL when it is not possible to complete a dose reconstruction for the claimant. 

6.13.4	 Provide the claimant with any information and forms that HHS provides to classes of 

employees seeking to petition to be added to the Special Exposure Cohort. 

6.14 Report Review 

OCAS Reviewing Health Physicist 

6.14.1	 Review the dose reconstruction report for technical accuracy and to ensure that the 

requirements of 6.12.2 are included. 

6.14.2	 Designate approval by signing the “Dose Reconstruction Reviewed by” block of the 

“NIOSH Report of Dose Reconstruction under the Energy Employees Occupational 

Illness Compensation Program Act (EEOICPA).” 

6.14.3	 Return reports not meeting appropriate requirements to the Health Physicist who 

performed the dose reconstruction. 
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Administrative Support 

6.15 Draft Report Distribution 

6.15.1	 Provide the claimant with a copy of the draft dose reconstruction report to be provided to 

DOL. 

Health Physicist 

6.16 Closing Interview with Claimant 

6.16.1	 Conduct a closing interview with the claimant to review the dose reconstruction results 

and the basis upon which the results were calculated. This will be the final opportunity 

during the dose reconstruction process for the claimant to provide additional relevant 

information that may affect the dose reconstruction. The closing interview may require 

multiple sessions, if the claimant requires time to obtain and provide additional 

information, and allow NIOSH time to integrate the new information into a new draft of the 

dose reconstruction report 

6.16.2	 Grant requests for time to provide additional information, based on whether the requests 

are reasonable and the claimant is actively seeking the information specified 

6.16.3	 Subject to any additional information provided by the claimant and revision to the dose 

reconstruction report, the claimant is required to return form OCAS-1 to NIOSH, certifying 

that he/she has completed providing information and that the record for dose 

reconstruction should be closed. Upon receipt of the form, forward a final dose 

reconstruction report to DOL, DOE, and to the claimant. The report itself will not provide 

information on probability of causation, which DOL must calculate to determine a 

recommended decision on the claim. 

Records Management Team/Health Physicist 

6.17 Preparation of Administrative Record 

The information to be included in the Administrative Record, as applicable, is as follows: 

6.17.1	 Acknowledgment Letter to Claimant (Letter #1) 

6.17.2	 DOE Request Form (2 page) 

6.17.3	 DOE Request Sent Letter to Claimant (Letter #2) 

6.17.4	 60 Days Overdue Letter to DOE 

6.17.5	 DOE Receipt 

6.17.6	 Letter to Claimant Preparing them for the CATI (Includes Script) (Letter #3) 

6.17.7	 Letter to Claimant with completed CATI Draft Report 

6.17.8	 Letter to Claimant with completed CATI Update Report 

6.17.9	 Letter to Claimant with completed Dose Reconstruction Draft Report 

6.17.10 Letter to Claimant with completed Dose Reconstruction Final Report 
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6.17.11 Internal Correspondence (Correspondence Initiated by OCAS Staff)
 

6.17.12 External Correspondence (Correspondence Initiated by Outside Entity)
 

6.17.13 DOL Supplemental Information (Category non-specific)
 

6.17.14 DOL Supplemental Information (Employment Verification) 

6.17.15 DOL Supplemental Information (Racial Ethnic Identification) 

6.17.16 DOL Supplemental Information (Medical Information)
 

6.17.17 DOL Supplemental Information (Smoking Information)
 

6.17.18 DOL Amended NIOSH Referral Summary Document
 

6.17.19 DOL Supplemental Information (Dose Information)
 

6.17.20 DOE Response
 

6.17.21 Phone Conversation Report
 

6.17.22 OCAS-1 Form
 

6.17.23 Authorization Forms from Claimant Contacts (i.e. forms, letters, or documentation)
 

6.17.24 Supporting documentation for final dose calculations which may include:
 

6.17.24.1 Spreadsheets containing calculations used for final dose estimates
 

6.17.24.2 Applicable portions of environmental reports used
 

6.17.24.3 Reports from dose calculation programs showing final results of dose estimates
 

6.17.24.3 Any other documentation used in final dose estimate
 

6.17.25 Excel Spreadsheet for input into IREP
 

6.17.26 Printout of IREP run performed by NIOSH
 

Administrative Support 

6.18 Final Report Distribution
 

6.18.1 Forward a final dose reconstruction report to the claimant and DOE.
 

6.18.2 Forward administrative record to DOL.
 

Note: Do not forward the dose reconstruction report to DOL for adjudication without receipt 

of form OCAS-1 signed by the claimant or a representative of the claimant authorized 

pursuant to 20 CFR 30.600. If the claimant or the authorized representative of the claimant 

fails to sign and return form OCAS-1 within 60 days, or 60 days following the claimant’s final 

provision of additional information and receipt of a revised draft dose reconstruction report, 

whichever occurs last, after notifying the claimant or the authorized representative, NIOSH 

may administratively close the dose reconstruction and notify DOL of this action. Upon 

receiving this notification by NIOSH, DOL may administratively close the claim. 
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6.19	 Claim Closing 

6.19.1	 Once actions under section 6.16.2 are completed, the record for dose reconstruction
 

shall be closed unless reopened at the request of DOL under 20 CFR part 30.
 

6.20	 Review of Completed Dose Reconstructions 

6.20.1	 Completed dose reconstructions may be reviewed with the assistance of DOL to identify 

denied claims when either of the following circumstanced arise: 

6.20.1.1Additional records or information are obtained pertaining to radiation exposures of DOE 

or AWE employees that could substantially increase the level of radiation doses 

estimated in the completed dose reconstructions 

6.20.1.2A scientific element underlying dose reconstructions is changed according to the 

provisions of Subpart E of this rule and the change could substantially increase the 

level of radiation doses estimated in the completed dose reconstructions 

6.20.2	 When a review of a dose reconstruction is completed, provide a report describing the 

basis for the review, the methods employed in the review, and the review findings to the 

claimant, DOL and DOE. 

7.0	 RECORDS 

The following records are generated as applicable. 

7.1	 NIOSH Report of Dose Reconstruction under the Energy Employees Occupational Illness 

Compensation Program Act (EEOICPA) 

8.0	 DEFINITIONS 

8.1	 Atomic Weapons Employer - an entity, other than the United States, that-­

8.1.1 processed or produced, for use by the United States, material that emitted radiation and was 

used in the production of an atomic weapon, excluding uranium mining and milling; and, 

8.1.2 is designated by the Secretary of Energy as an atomic weapons employer for purposes of 

the compensation program. 

8.2	 Bioassay - the determination of the kinds, quantities, or concentrations, and (in some cases), 

locations of radioactive material in the human body, whether by direct measurement or by 

analysis and evaluation of radioactive material excreted or eliminated by the body. 

8.3	 Claimant - the individual who has filed with the Department of Labor for compensation under 

EEOICPA. 

8.4	 Covered Employee - An individual with cancer specified below if, and only if, that individual is 

determined to have sustained that cancer in the performance of duty in accordance with section 

3623(b) of EEOICPA. 

8.4.1 A Department of Energy employee who contracted that cancer after beginning employment 

at a Department of Energy facility. 

8.4.2 A Department of Energy contractor employee who contracted that cancer after beginning 

employment at a Department of Energy facility. 
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8.4.3 An atomic weapons employee who contracted that cancer after beginning employment at an 

atomic weapons employer facility. 

8.4.4 An individual with cancer specified in steps (9.4.1), (9.4.2), or (9.4.3) shall be determined to 

have sustained that cancer in the performance of duty for purposes of the compensation 

program if, and only if, the cancer specified was at least as likely as not related to 

employment at the facility, as determined in accordance with the guidelines established in 42 

CFR 81. 

8.5	 Covered Facility - any building, structure, or premises, including the grounds upon which such 

building, structure, or premise is located: 

8.5.1 In which operations are, or have been, conducted by, or on behalf of, the DOE (except for 

buildings, structures, premises, grounds, or operations covered by Executive Order 12344, 

dated February 1, 1982, pertaining to the Naval Nuclear Propulsion Program); and, 

8.5.2 With regard to which the DOE has or had: 

8.5.2.1	 A proprietary interest; or, 

8.5.2.2	 Entered into a contract with an entity to provide management and operation, 

management and integration, environmental remediation services, construction, or 

maintenance services; or 

8.5.3 A facility owned by an entity designated by the Secretary of Energy as an atomic weapons 

employer for purposes of EEOICPA that is or was used to process or produce, for use by 

the United States, material that emitted radiation and was used in the production of an atomic 

weapon, excluding uranium mining or milling. 

8.6	 DOE means the U.S. Department of Energy, and includes predecessor agencies of DOE, 

including the Manhattan Engineering District. 

8.7	 Department of Energy contractor employee - means any of the following: 

8.7.1 An individual who is or was in residence at a Department of Energy facility as a researcher 

for one or more periods aggregating at least 24 months. 

8.7.2 An individual who is or was employed at a Department of Energy facility by--

8.7.2.1	 an entity that contracted with the Department of Energy to provide management and 

operating, management and integration, or environmental remediation at the facility; or, 

8.7.2.2	 a contractor or subcontractor that provided services, including construction and 

maintenance, at the facility. 

8.8	 Department of Energy facility - means any building, structure, or premise, including the grounds 

upon which such building, structure, or premise is located. Refer to 9.5, “Covered Facility.” 

8.9	 DOL - The U.S. Department of Labor 

8.10 Dose Reconstruction - the process by which the radiation dose received by an individual is 

estimated. The result of a dose reconstruction is not intended to replace the dose of record or 

be the absolute dose which the individual received. 

8.11	 EEOICPA means the Energy Employees Occupational Illness Compensation Program Act of 

2000, 42 U.S.C. 7384-7385 [1994, supp. 2001]. 
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8.12	 Equivalent dose - the absorbed dose in a tissue multiplied by a radiation weighting factor to 

account for differences in the effectiveness of the radiation in inducing cancer. 

8.13	 External dose - that portion of the equivalent dose that is received from radiation sources 

outside of the body. 

8.14 Internal dose - that portion of the equivalent dose that is received from radioactive materials 

taken into the body. 

8.15 NIOSH - the National Institute for Occupational Safety and Health, Centers for Disease Control 

and Prevention, U.S. Department of Health and Human Services. 

8.16 Primary cancer - a cancer defined by the original body site at which the cancer was incurred, 

prior to any spread (metastasis) resulting in tumors at other sites in the body. 

8.17 Probability of causation - the probability or likelihood that a cancer was caused by radiation 

exposure incurred by a covered employee in the performance of duty. In statistical terms, it is 

the cancer risk attributable to radiation exposure divided by the sum of the baseline cancer risk 

(the risk to the general population) plus the cancer risk attributable to the radiation exposure. 

This concept is further explained under 42 CFR part 81, which provides guidelines by which 

DOL will determine probability of causation under EEOICPA. 

8.18	 Radiation - ionizing radiation, including alpha particles, beta particles, gamma rays, x rays, 

neutrons, protons and other particles capable of producing ions in the body. For purposes of 

this rule, radiation does not include sources of non-ionizing radiation such as radio-frequency 

radiation, microwaves, visible light, and infrared or ultraviolet light radiation. 

8.19	 Specified cancer - a term defined in section 3621(17) of EEOICPA and 20 CFR part 30.5(dd) 

that specifies types of cancer that, pursuant to 20 CFR part 30, may qualify a member of the 

Special Exposure Cohort for compensation. It includes leukemia (other than chronic 

lymphocytic leukemia), multiple myeloma, non-Hodgkin's lymphoma, and cancers of the lung 

(other than carcinoma in situ diagnosed at autopsy), thyroid, male breast, female breast, 

esophagus, stomach, pharynx, small intestine, pancreas, bile ducts, gall bladder, salivary gland, 

urinary bladder, brain, colon, ovary, liver (not associated with cirrhosis or hepatitis), and bone. 

Pursuant to section 2403 of Public Law 107-20, this definition will include renal cancer. 

8.20	 Uncertainty distribution - a statistical term meaning a range of discrete or continuous values 

arrayed around a central estimate, where each value is assigned a probability of being correct. 

8.21	 Worst Case -a term used to describe a type of assumption used in certain instances for certain 

dose reconstructions conducted under this rule. It assigns the highest reasonably possible 

value, based on reliable science, documented experience, and relevant data, to a radiation dose 

of a covered employee. 
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ATTACHMENT 1
 

Dose Reconstruction Flow Process (Page 1 of 1)