Summary – OCAS-PR-003, Rev. 0 1 SC&A – January 20, 2011

Overview of

PERFORMING AND REPORTING DOSE RECONSTRUCTION

(OCAS-PR-003, Rev. 0) 

This procedure, Performing and Reporting Dose Reconstruction (OCAS-PR-003), deals with the 

administrative process for dose reconstruction for claimants. In addition, it establishes that 

uncertainties concerning data quality or dose be handled in a claimant-favorable manner, and sets 

thresholds for when a sufficient level of analysis is achieved and when additional effort is 

warranted. The National Institute for Occupational Safety and Health (NIOSH) staff and its 

technical support contractors use this procedure in the performance, review, and documentation 

of dose reconstructions for covered employees with cancer. 

The procedure lays out the steps required in collecting information, provides guidance for the 

calculation methods, and discusses what information is relevant for the preparation of dose 

reconstruction reports. The procedure also addresses notification protocol in the event the dose 

reconstruction cannot be completed with the information in hand, and lists the letters and record 

management requirements for each case. 

SUMMARY OF FINDINGS RESULTING FROM THE TECHNICAL REVIEW

Review of this procedure by the technical contractor for the Advisory Board on Radiation and 

Worker Health (the Board) produced the 11 findings summarized below: 

Finding #1: The document is ambiguous in identifying individuals who are responsible for 

various steps of the dose reconstruction process. 

Finding #2: Some of the subsections could be organized in a more logical, clear manner. 

Finding #3: Reference should be made to all relevant procedures and documents that are directly 

applicable to the dose reconstruction process. 

Finding #4: The procedure contains a few inconsistencies and lacks the level of detailed 

guidance provided in some other procedures. 

Finding #5: The guidance is limited regarding conducting dose assessments for potential low or 

high Probabilities of Causation (POCs). 

Finding #6: The guidance given for claimant interviews is very brief.

Finding #7: The guidance given for “best estimate” dose reconstructions is inadequate. 

Finding #8: The procedure does not discuss prioritizing data used in dose reconstruction in a 

hierarchical manner, as prescribed in regulations. 

Finding #9: The procedure does not draw a strong distinction between instances where worst-
Summary – OCAS-PR-003, Rev. 0 2 SC&A – January 20, 2011

case assumptions are selected for process efficiency as opposed to being selected because of 

unknowns. 

Finding #10: The procedure provides no guidance regarding dose estimate uncertainty.

Finding #11: An extensive list of potential sources of data is provided, but restrictions on the use 

of the data sources minimizes their value.

RESOLUTION OF FINDINGS

In response to the findings identified above, NIOSH did three things: 

(1) Agreed with all findings 

(2) Developed more specific procedural guidance in the period since this procedure was 

prepared

(3) Cancelled this procedure 

The Board recognized that the document has been replaced with more specific procedural 

guidance elsewhere and, accordingly, closed all issues associated with it.