DISCLAIMER: This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for Occupational Safety and 

Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its Working Groups or 

Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working documents are 

not final NIOSH or ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

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

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Presentation Handout

Findings and Discussions of Document Reviews Presented to the 

Advisory Board on Radiation and Worker Health

Meeting of the Advisory Board on Radiation and Worker Health

August 18, 2021

This presentation handout gives details about documents reviewed by the Subcommittee for 

Procedure Reviews (SCPR) that have previously been presented to the Advisory Board on 

Radiation and Worker Health (ABRWH, Board) but have not been formally approved/closed. 

The following documents are discussed in this handout.

March 12, 2013, ABRWH Meeting

• ORAUT-OTIB-0070, “Dose Reconstruction During Residual Radioactivity Periods at 

Atomic Weapons Employer Facilities”

• OCAS-IG-001, “External Dose Reconstruction Implementation Guideline” 

July 17, 2013, ABRWH Meeting

• OCAS-TIB-0010, “Best Estimate External Dose Reconstruction for Glovebox Workers” 

• ORAUT-OTIB-0023, “Assignment of Missed Neutron Doses Based on Dosimeter 

Records”

October 17, 2013, ABRWH Meeting

• ORAUT-OTIB-0010, “A Standard Complex-Wide Correction Factor for Overestimating 

External Doses Measured with Film Badge Dosimeters”

• OCAS-PER-012, “Evaluation of Highly Insoluble Plutonium Compounds” 

April 11, 2018, ABRWH Meeting (closeout deferred awaiting National Institute for 

Occupational Safety and Health (NIOSH) followup)

• NIOSH-OVER-0009, “Skin Exposure” 

• ORAUT-OTIB-0017, “Interpretation of Dosimetry Data for Assignment of Shallow 

Dose”
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ORAUT-OTIB-0070, Rev. 0, “Dose Reconstruction During Residual Radioactivity 

Periods at Atomic Weapons Employer Facilities”

SC&A reviewed revision 0 of ORAUT-OTIB-0070 (OTIB-0070) in August 2008. The findings 

and resolutions of findings were presented to the ABRWH at the March 12, 2013, meeting. 

Summary: This technical information bulletin provides guidance for (1) estimating dose to 

workers at Atomic Weapons Employer (AWE) facilities when NIOSH determines “significant 

residual contamination” and (2) reconstruction of internal doses due to the resuspension of 

particulate surface contamination.

Table 1. Fifteen total findings for ORAUT-OTIB-0070, revision 0

# OTIB-0070 finding Resolution

1 Inconsistent use of the resuspension 

factor (RF) – The default source term 

depletion value of 1% per day implies 

an RF of 8e-05 per meter, which is 

nearly 2 orders of magnitude higher 

than NIOSH’s recommended RF of 

10-6 m-1

Closed on July 31, 2012. 

OTIB-0070, revision 1, changed the source term 

depletion rate from 1% day-1 to 0.00067 day-1, which 

is consistent with an RF of 10-6 m-1. 

2 OTIB-0070, section 2.5, references 

refer to outdoor soil contamination, 

which involves conditions with little 

resemblance to building surfaces, 

building uses, room heights, and 

ventilation rates.

Closed on July 31, 2012. 

OTIB-0070, revision 1, recalculated the default 

source-term depletion rate during the residual 

radiation periods based actual data from four AWE 

sites (Blockson, Dow Madison, General Atomics, and 

Simonds Saw) rather than being based on literature 

sources where outdoor measurements were 

preponderant.

3 Implicit in deriving the source term 

depletion rate (λ, Section 2.6) is that 

airborne contaminants are (1) 

uniformly distributed throughout the 

interior volume and (2) removed with 

100% efficiency. Neither assumption is 

likely to exist.

Closed on July 31, 2012 

OTIB-0070, Revision 1, Section 4.1 recalculated the 

default source-term depletion rate during the residual 

radiation periods based on averaging observed 

depletion rates at four AWE sites.

4 Battelle-TBD-6000 and TBD-6001 

identified relatively large job-specific air 

concentrations during facility 

operations. In contrast, OTIB-0070, 

attachment B, identifies a single value 

for each of three thorium sites that 

excludes process air sampling data.

Closed on January 5, 2011. 

Air samples were selected to be indicative of general 

area conditions within the facilities at the start of the 

residual period and not potential exposure during the 

operational period.

5 Attachment B cites survey data for 

three thorium facilities but provides no 

further guidance on how these data 

sets are to be used.

Closed on January 5, 2011. 

Since it has never been used for dose reconstruction 

(DR), attachment B has been deemed unnecessary 

for the purpose of OTIB-0070 and has been removed 

from revision 1. 
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# OTIB-0070 finding Resolution

6 Use of attachment B Horizons 

summary survey data as a default 

value for operational air concentration 

at a thorium-refining facility is 

inappropriate and not claimant 

favorable.

Closed on January 5, 2011. 

Since it has never been used for DR, attachment B 

has been deemed unnecessary for the purpose of 

OTIB-0070 and has been removed from revision 1. 

7 It is unclear how the attachment B 

Horizons geometric mean value of 

4.8 disintegrations per minute per 

cubic meter (dpm/m3) was derived from 

the Atomic Energy Commission data. 

Closed on January 5, 2011.

Since it has never been used for DR, attachment B 

has been deemed unnecessary for the purpose of 

OTIB-0070 and has been removed from revision 1.

8 The derivation of attachment B air 

concentration values (i.e., a geometric 

mean of 1.2 dpm/m3 and a geometric 

standard deviation of 3.9 dpm/m3) for 

Nuclear Metals was not adequately 

explained.

Closed on January 5, 2011. 

Since it has never been used for DR, attachment B 

has been deemed unnecessary for the purpose of 

OTIB-0070 and has been removed from revision 1.

9 The derivation of the attachment B 

Lindsey air concentration values was 

not adequately explained, and the 

values do not appear to correspond to 

those reported in the survey.

Closed on July 31, 2012. 

Since it has never been used for DR, attachment B 

has been deemed unnecessary for the purpose of 

OTIB-0070 and has been removed from revision 1.

10 NIOSH’s recommended RF of 10-6 m-1

is inappropriate. The scientific literature 

indicates RF values of 10-4 to 10-3 m-1

for indoor activities involving 

substantial industrial activities.

Closed on July 31, 2012. 

A footnote added to table 5-1 indicates that a site-bysite analysis should be conducted to establish the RF 

at sites where no postoperational clean-up has been 

performed, rather than simply accepting an RF of 10-6

m-1. 

11 Use of NUREG-1400 is inappropriate 

and technically not feasible since the 

total absence of data precludes a 

quantitative assignment to the source 

term that reflects residual 

contamination.

Closed on July 31, 2012. 

Consideration of NUREG-1400 as a possible method 

for estimating residual contamination has been 

deleted from OTIB-0070, revision 1 (refer to table 5 of 

OTIB-0070).

12 Use of Battelle-TBD-6000 for assigning 

operational air concentration values 

may not be claimant favorable. 

This finding is being addressed in Battelle-TBD-6000, 

issue 4 as of July 26, 2010. 

This finding will be closed when documentation from 

the TBD-6000 Work Group is received indicating that 

TBD-6000, issue 4, has been closed.

13 It is not possible to judge whether the 

basic approach to developing 

inhalation doses in TBD-6001 is 

claimant favorable.

Closed on July 31, 2012. 

Since TBD-6001 has been cancelled, all references to 

and data from TBD-6001 have been removed from 

OTIB-0070, revision 1.

14 Use of Battelle-TBD-6001 for 

determining inhalation doses may not 

be claimant favorable.

Closed on July 31, 2012. 

Since TBD-6001 has been cancelled, all references to 

and data from TBD-6001 have been removed from 

OTIB-0070, revision 1. 
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# OTIB-0070 finding Resolution

15 Many of the assumptions that form the 

basis of the OCAS-TIB-009 ingestion 

model are too restrictive and may yield 

low ingestion estimates.

Closed on February 5, 2013. 

Since finding TIB-009-01 has been resolved and 

closed, finding OTIB-0070-15 has also been closed.

Board Discussions

There was some discussion about the use of a default RF of 10-6 m-1 (pp. 149–157 of the March 

12, 2013, transcript). 

• Question: Is the default RF appropriate for outdoor settings? 

Response: OTIB-0070 recommends use of the default RF for indoor activities at 

facilities where postoperational decontamination has been performed. 

• Question: Is the default RF applicable at all AWE sites?

Response: OTIB-0070 also states that a site-by-site analysis should be conducted to 

establish an appropriate RF at sites where no postoperational cleanup has been 

performed, rather than simply accepting an RF of 10-6 m-1. 

This explanation satisfied the Board members, and no further discussion was held regarding the 

review of OTIB-0070. 
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OCAS-IG-001, Revisions 1, 2, and 3, “External Dose Reconstruction 

Implementation Guideline”

SC&A reviewed revision 1 of OCAS-IG-001 (IG-001) in January 2005 and revision 2 in October 

2007. SC&A was tasked to perform a focused review of revision 3 the ensure all remaining 

findings were appropriately addressed. The results of these reviews were presented to the 

ABRWH at the March 12, 2013, meeting. 

Summary: IG-001 provides general (not specific) guidance on the components, standards, and 

methods to be used to reconstruct external radiation dose for probability of causation (POC) 

calculations.

Table 2. Twenty-four total findings (17 findings from review of revision 1 and 7 findings 

from review of revision 2) for OCAS-IG-001

# IG-001 finding Resolution

1 Deficiencies with procedure layout 

include (1) fragmented structure, 

(2) excessive amount of useless data 

and/or historical background in main 

body, and (3) critical data for DR found 

in appendices rather that main body.

Closed on July 31, 2012. 

The SCPR determined that this finding is closed. 

Concerns raised by this issue are covered in 

finding 19.

2 Guidance for deriving (1) film and 

thermoluminescent dosimeter (TLD) 

uncertainty, (2) neutron dose from 

source term, and (3) occupational 

medical dose using x-ray machine 

operating parameters requires data 

and resources that are not available to 

the dose reconstructor.

Closed on November 1, 2012. 

IG-001 provides general principles, not specific 

guidance. Detailed implementation guidance and 

related information are found in other documents and 

procedures.

3 IG-001 provides inadequate guidance 

for classifying a case as potentially 

<50% POC or >50% POC and should 

identify the role of Task 2 personnel.

Closed on October 29, 2007. 

Revision 2 of IG-001 eliminated recommending 

inappropriate methods for TLD uncertainty and 

includes guidance that directs the dose reconstructor 

to site-specific documentation, when available.

4 IG-001 recommends inappropriate 

methods for estimating TLD 

uncertainty.

Closed on October 29, 2007. 

Revision 2 of IG-001 eliminated recommending 

inappropriate methods for TLD uncertainty and 

includes guidance that directs the dose reconstructor 

to site-specific documentation, when available.

5 IG-001 recommends a range of limit of 

detection (LOD) values for 1956–1960 

that the reviewer considers too low for 

the period.

Closed on October 29, 2007. 

In revision 2, table 2.1 that referenced LOD values for 

the 1956–1960 period has been modified to remove 

any date-specific LOD values.
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# IG-001 finding Resolution

6 Guidance implies that LOD for deep 

dose from gamma may also be applied 

to electron dose, which is inconsistent 

with historical data that show 

uncertainty for shallow dose is 

considerably higher than for deep 

dose.

Closed on October 29, 2007. 

Revision 2 of IG-001 removes the example that 

implies LOD for deep dose from gamma is also 

appropriate for electron dose.

7 IG-001 assumes nuclear track 

emulsion, type A (NTA) film dosimeters 

were insensitive to neutron below 

500 kiloelectron volts (keV); however, 

the reviewer contends that the 

dosimeter is insensitive to neutron. 

Closed on October 29, 2007. 

Revision 2 indicates that a variety of energy 

thresholds for NTA film dosimeters are cited in the 

literature and recommends reviewing site-specific 

information for determining actual threshold values.

8 Methods for reconstruction of neutron 

doses from survey data or source term 

data do not appear practical, 

achievable, and defensible.

Closed on July 31, 2012. 

Revision 3 has included the use of more practical 

methods, such as employing neutron-to-photon ratios.

9 IG-001 does not acknowledge the 

likely use of neutron/photon ratio 

methods in neutron DR and erroneous 

states that “at most facilities, neutron 

exposures were generally less than 

20% of the photon exposures.”

Closed on October 29, 2007. 

Revision 2 modified section 2.2.2 to eliminate the 

inaccurate statement and introduced a statement 

acknowledging the use of site-specific neutron-tophoton ratios.

10 IG-001, appendix B, dose conversion 

factors (DCFs) for bone surface and 

red marrow are underestimated.

Closed on October 29, 2007. 

Revision 2 recommends applying a correction factor 

to the rotational and isotropic DCFs for bone surface 

and red marrow (as well as esophagus and lung).

11 IG-001 does not account for additional 

laboratory uncertainty for film badge 

readings associated with exposure less 

than 200 millirem (mrem). 

Closed on October 29, 2007. 

Revision 2 added guidance to section 2.1.1.3 

indicating that site-specific dosimetry data may be 

available in the site profile. 

12 IG-001, appendix B, posterior-anterior 

(PA) geometry DCFs are in error and 

underestimate dose (i.e., assume the 

dosimeter is worn on the posterior).

Closed on February 5, 2013. 

PA DCFs are not routinely used in DRs. However, 

since PA DCFs could prove useful in some special 

exposure scenarios (if used correctly), the PA DCFs 

should be kept in appendix B.

13 IG-001, appendix B, rotational and 

isotropic geometry DCFs are in error 

and underestimate dose.

Closed on October 29, 2007. 

Revision 2 has introduced a discussion and table of 

correction factors to be applied to rotational and 

isotropic DCFs for bone (surface), bone (red marrow), 

esophagus, and lung.

14 Angular sensitivity not accounted for in 

correcting measured film or TLD 

values.

Closed on October 29, 2007. 

Revision 2 added a discussion on the angular 

response of dosimeters to section 4 and guidance that 

directs the dose reconstructor to site-specific 

documentation.
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# IG-001 finding Resolution

15 No correction recommended for 

backscatter; may be significant factor 

for pre-1984 when calibrations were 

done “in air” as opposed to “onphantom.” 

Closed on July 27, 2006. 

No correction for backscatter only makes the reported 

film dose higher, building some conservativeness in 

early years.

16 Environmental uncertainty (i.e., heat, 

humidity, light, etc.) was not addressed 

in IG-001. 

Closed on February 5, 2013. 

IG-001 contains general guidance information but 

does not provide specific instructions to follow during 

DR. Specific instructions are provided in site-specific 

or issue-specific technical documents and workbooks.

17 Guidance for the selection of 

uncertainty distributions for total organ 

dose raises question of consistency 

and requires professional judgment.

Closed on February 5, 2013. 

IG-001 contains general guidance information but 

does not provide specific instructions to follow during 

DR. Specific instructions are provided in site-specific 

or issue-specific technical documents and workbooks.

18 SC&A’s review of IG-001, revision 1, 

identified several deficiencies 

regarding the clarity and structure of 

the document.

Closed on July 31, 2012. 

Revisions 2 & 3 eliminated much of the excessive 

data and generally improved the clarity of the 

document.

19 A deficiency (finding 1) identified under 

the revision 1 review was the 

fragmented structure and illogical 

sequencing of information.

Closed on November 1, 2012. 

What constitutes the logical, versus illogical, 

sequencing of information is a fairly subjective 

determination. Importantly, the sequence of 

information within the document is not a key factor in 

providing adequate guidance.

20 Guidance was not provided regarding 

the methodology for the assessment of 

neutron doses using source term data.

Closed on November 1, 2012. 

IG-001 provides general principles, not specific 

guidance. Detailed implementation guidance and 

related information is found in other documents and 

procedures.

21 IG-001 does not consistently direct the 

dose reconstructor to technical and 

site-specific documents.

Closed on July 31, 2012. 

This finding is virtually identical to finding 22.

22 OCAS-IG-001 should (but does not) 

direct the dose reconstructor to 

technical and site-specific 

documentation, where the dose 

reconstructor can find more specific 

guidance.

Closed on November 1, 2012. 

IG-001 provides general principles, not specific 

guidance. Detailed implementation guidance and 

related information is found in other documents and 

procedures.

23 No discussion added to this revision 

regarding neutron-to-photon ratios.

Closed on July 31, 2012. 

Revision 3 added a discussion to section 2.2.2.2.1 to 

clarify the evaluation of missed neutron data, by 

recommending the use of site-specific neutron-tophoton dose ratios.
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# IG-001 finding Resolution

24 (1) All DCFs associated with PA 

geometries in appendix B are in error 

and underestimate dose. 

(2) Environmental uncertainty 

associated with dosimeters is not 

addressed. (3) Guidance for selection 

of uncertainty distributions raises 

questions of consistency and required 

professional judgment.

Closed on February 5, 2013. 

PA DCFs are not routinely used in DRs. However, 

since PA DCFs could prove useful in some special 

exposure scenarios (if used correctly), the PA DCFs 

should be kept in appendix B. 

IG-001 contains general guidance information but 

does not provide specific instructions to follow during 

DR. Specific instructions are provided in site-specific 

or issue-specific technical documents and workbooks.

Board Discussions

Board members posed the following questions about the review of IG-001 (pp. 171–181 of the 

March 12, 2013, transcript): 

• Question: Would information provided in IG-001, such as differences in film badges and 

their limitations, be used simply as guidance and site-specific data used for details, such 

as limits of detection, etc.?

Response: This guidance document essentially predates virtually every other procedure 

currently in use. It presents the principles of external dosimetry. At the time it was 

written, there was not a well-defined process for how the technical documentation was 

going to be defined. As the program progressed, it was recognized that there was a need 

for far more site-specific and issue-specific distinction to provide some consistent 

guidance. Therefore, IG-001 is a very general document. It is almost a primer on what 

DR consists. At this point, site-specific documents would be used to provide details of the 

external dosimetry program in use.

• Question: To what extent did this review use the experience in the individual DRs? 

Response: SC&A’s review of IG-001 did not consider the experience of DR, because 

the review was performed very early in the program. At the time of the original review, 

there was not a significant amount of specific DR review experience available. 

This explanation satisfied the Board members, and no further discussion was held regarding the 

review of IG-001. 
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OCAS-TIB-0010, Revision 2, “Best Estimate External Dose Reconstruction for 

Glovebox Workers”

SC&A reviewed revision 2 of OCAS-TIB-0010 (TIB-0010) in June 2006. The findings and 

resolution of findings were presented to the ABRWH at the July 17, 2013, meeting. 

Summary: This procedure provides correction factors for best-estimate DR to organs located in 

the lower torso from photons emanating from gloveboxes when a dosimeter is worn on the lapel. 

NIOSH calculated the gamma flux at 30 points covering the chest and at 30 points covering the 

abdomen and then determined the ratio of each abdomen flux to each chest flux. The mean ratio 

was then selected as the correction factor.

Table 3. Nine total findings for OCAS-TIB-0010

# TIB-0010 finding Resolution

1 The TIB lacks transparency. The 

radioactive source is not identified; 

neither its exact dimensions nor 

location are given, nor is the thickness 

of the walls presented.

Closed on March 22, 2011. 

The requested information was provided in appendix 

B, rev. 03.

2 Lower torso organs not specified. Closed on April 11, 2012. 

The phrase “other cancers that appear in the region of 

those organs” (i.e., stomach, liver, bladder, prostate, 

ovaries, testes, genitalia) was added to section 2.0 to 

allow for cancers such as sarcomas, Hodgkin’s 

lymphomas, or other cancers that might occur 

anywhere but would only require the adjustment if 

they occurred in the region defined by the specified 

organs.

3 Correction factors do not represent 

worst-case assumptions.

Closed on October 14, 2008. 

The SCPR is of the opinion that this is a NIOSH policy 

decision and has been handled appropriately.

4 Analysis is needlessly complex. Closed on October 14, 2008. 

This was more of an observation than a finding.

5 SC&A questions the design of the 

analysis that compares the particle flux 

over locations on the torso, rather than 

modeling the variation of dosimeter 

response with location.

Status changed to in abeyance on February 5, 2013. 

The SSCPR agrees with the use of the 95th percentile 

instead of the mean for the correction factor.

6 SC&A questions the assumptions 

made concerning the glovebox model, 

e.g., wall thickness, Lexan window, 

etc.

Status changed to in abeyance on February 5, 2013. 

The SCPR agrees with the use of the 95th percentile 

instead of the mean for the correction factor.
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# TIB-0010 finding Resolution

7 SC&A questions the use of an 

anatomical illustration of a human torso 

rather than the International 

Commission on Radiological Protection 

(ICRP) Reference Man based 

anthropomorphic phantoms developed 

by Oak Ridge National Laboratory.

Closed on October 14, 2008. 

Since the SC&A-calculated correction factor based on 

the Hp(10) dose rate was the same as the correction 

factor calculated using the anatomical illustration, the 

additional work to model the ICRP Reference Man is 

not warranted. 

8 The use of the Attila software is 

questioned.

Status changed to in abeyance on February 5, 2013. 

The SCPR agrees with the use of the 95th percentile, 

instead of the mean, for the correction factor.

9 The use of Rocky Flats to validate the 

model is questionable; Rocky Flats 

data are for glovebox and nonglovebox workers, information is 

lacking regarding the radiation 

sources, etc.

Closed on October 14, 2008. 

Rocky Flats Plant (RFP) data were used only as a 

proof of principle; they were not used in the 

justification of the glovebox factor. The RFP data have

been removed from DCAS-TIB-0010.

Board Discussions

Board members raised the following questions (pp. 31–45 of the July 17, 2013, transcript): 

• Question: When this model was developed, were there specific designs of gloveboxes 

that were used?

Response: NIOSH stated that, because of the myriad designs even at a given facility, it 

was decided not to make adjustments based on design and rely strictly on a geometric 

consideration without accounting for other shielding. SC&A added that they ran MCNP 

calculations for a number of different glovebox designs and found that the different 

glovebox designs evaluated did not have a significant effect on the correction factor. 

• Question: At Hanford, they put shielding on the front of the glovebox but nothing 

underneath. If a person is backed up against another, you are getting scatter radiation 

from underneath the glovebox. Was this scenario considered? 

Response: TIB-0010 contains a generic calculation that is bounding for the geometries 

considered. NIOSH stated that the math in TIB-0010 is adequate to describe the variance 

in the two measurements described therein. But if there are other special situations, they 

would need to be incorporated outside of the realm of TIB-0010. In addition, shielding 

did not come into play; it is a geometric correction factor. 

• Question: Since this is a geometric issue, did the model take into account the height of 

the workers? 

Response: Yes, height of the worker was discussed, and it was decided to use the height 

of the Reference Man. However, since the model uses the 95th percentile of the dose 

ratio distributions, in reality it is taking the ratio of what the badge would read to 

probably the lowest organ. 
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• Question: Is the model adjusted for workers who wore lead aprons? 

Response: The lead apron would not be a question for the glovebox adjustment. It 

would be a question for the interpretation of the badge and was the badge worn under the 

apron or over the apron. 

• Question: So, in summary, this is just to correct the geometric means of the dose that 

does not consider shielding, the manufacturing, etc.? And this is used as a best estimate?

Response: OTIB-0010 is used for best estimates to organs located in the lower torso and 

is a geometric correction factor only.

These explanations satisfied the Board members, and no further discussion was held regarding 

the review of TIB-0010. 

Update: During the preparation of this handout, SC&A reviewed revision 04 of TIB-0010 and 

determined that section 3.2 and section 5.0, table 1, still recommend applying the geometric 

mean values, rather than the 95th percentile values agreed upon in findings 5, 6, and 8. 
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ORAUT-OTIB-0023, Revision 00, “Assignment of Missed Neutron Doses Based on 

Dosimeter Records”

SC&A reviewed revision 0 of ORAUT-OTIB-0023 (OTIB-0023) in June 2006. The findings and 

resolution of findings were presented to the ABRWH at the July 17, 2013, meeting. 

Summary: The purpose of OTIB-0023 is to provide information to allow dose reconstructors to 

determine when it is appropriate to assign missed neutron doses at U.S. Department of Energy 

sites using the neutron missed dose central estimate (nLOD/2) method or an “alternative” 

method. The alternative method should be applied when the nLOD/2 exceeds 75 percent of the 

assigned photon dose (i.e., from recorded dosimeter dose + missed dose). 

Table 4. Eight total findings for ORAUT-OTIB-0023

# OTIB-0023 finding Resolution

1 The procedure lacks clarity by failing to 

provide clear definitions and is 

inconsistent in its terminology.

Closed on June 24, 2008. 

OTIB-0023, revision 1, addressed this finding.

2 For the alternative method, detailed 

information is required that will not be 

readily available to the dose 

reconstructor.

Closed on June 24, 2008. 

Revision. 00, Section 6, Condition #1 was eliminated 

by Rev. 01, which resolves Finding 2.

3 References OCAS-IG-001 as the basis 

for its guidance; however, guidance 

contained in OTIB-0023 and OCAS-IG001 is inconsistent. 

Review objective 1.4: “Is the procedure 

consistent with all other procedures 

that are part of the hierarchy of 

procedures employed by NIOSH for 

dose reconstruction?”

Closed on January 7, 2008. 

OTIB-0023, revision 1 (and IG-001, rev. 3), corrected 

the inconsistencies between IG-001, section 2.2.2.2.1 

and OTIB-0023, section 6.

4 It is questionable whether dose 

reconstructors are in a position or have 

the information to make the potentially 

subjective decisions required.

Closed on June 24, 2008. 

Revision 00, section 6, condition 1, was eliminated by 

revision 01, which resolves finding 4.

5 Refer to finding OTIB-0023-03 for 

review objective 1.4. 

Review objective 4.2: “Does the 

procedure adhere to the hierarchical 

process as defined in 42 CFR 82.2?”

Closed on January 7, 2008. 

The SCPR indicated that issue OTIB-0023-03 was 

closed. Since this issue refers to issue OTIB-0023-03, 

it has also been closed.

6 The reconstruction of missed neutron 

doses from “numerous neutron 

measurements and accurate time 

information” is unrealistic.

Closed on June 24, 2008. 

Revision 00, section 6, condition 1, was eliminated by 

revision 01, thus rendering finding 6 moot.

7 The regulatory recommendation for 

“striking a balance between the need 

for technical precision and process 

efficiency” has been ignored.

Closed on June 24, 2008. 

Revision 00, section 6, condition 1, was eliminated by 

revision 01, thus rendering finding 7 moot.
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# OTIB-0023 finding Resolution

8 The generic assumption of a neutronto-photon ratio of 0.75:1 as a limiting 

value for the application of nLOD/2 is 

neither technically defensible nor 

claimant favorable.

Closed on June 24, 2008. 

Revision 00, section 6, condition 1, was eliminated by 

revision 01, thus rendering finding 8 moot.

Board Discussions 

Board members had no questions or comments regarding the review and finding resolution 

process of OTIB-0023. 
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ORAUT-OTIB-0010, Revision 00, “A Standard Complex-Wide Correction Factor for 

Overestimating External Doses Measured with Film Badge Dosimeters” 

SC&A reviewed revision 00 of ORAUT-OTIB-oo10 (ORIB-0010) in January 2005. The findings 

and resolution of findings were presented to the ABRWH at the October 17, 2013, meeting. 

Summary: The objectives of this document are (1) evaluate the degree of standardization of 

typical U.S. Department of Energy film dosimeters and (2) develop a standard methodology for 

use by the dose reconstructor to assign a dose that will result in a reasonable overestimate of the 

organ dose. Since this is an overestimating approach for a quick evaluation of the potential for 

compensability, OTIB-0010 is used only for claims that are judged to be likely noncompensable. 

Table 5. Ten total findings for ORAUT-OTIB-0010

# OTIB-0010 finding Resolution

1 Guidance is lacking for how to treat 

missed dosimetry data in which the 

number of zero readings is fewer than 

12 cycles.

Closed on June 24, 2008. 

Revision 01 provides guidance on how to handle 

missed (or zero) dosimetry data.

2 Guidance fails to acknowledge that 

missed dose based on LOD (as 

opposed to LOD/2) represents 95th 

percentile and requires no uncertainty.

Closed on June 24, 2008. 

Revision 01 new table 2-1 provides specific 

instructions to the dose reconstructor regarding how 

the recorded and missed dose should be calculated 

and entered into the Interactive RadioEpidemiological 

Program (IREP). 

3 Document contains too much upfront 

background information and does not 

provide DR with guidance for 

maximizing external dose until page 8.

Closed on June 24, 2008. 

In revision 01, relevant background and technical 

basis information has been moved to the end of the 

document and incorporated into new attachment A.

4 Upfront background information not 

relevant to implementation of 

procedure.

Closed on June 24, 2008. 

In revision 01, relevant background and technical 

basis information has been moved to the end of the 

document and incorporated into new attachment A.

5 Guidance does not address how to use 

the standard correction factor when 

recorded dosimeter dose is greater 

than zero but less the LOD 

(i.e., 40 mrem).

Closed on June 24, 2008. 

Revision 01 specifies the use of 40 mrem as a 

reasonable default LOD.

6 Guidance fails to acknowledge that the 

use of the standard correction factor 

eliminates the need for uncertainty. 

Closed on June 24, 2008. 

Revision 01 new table 2-1 provides very specific 

instructions to the dose reconstructor on calculating 

uncertainty and how the dose data should be entered 

into IREP.
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# OTIB-0010 finding Resolution

7 Guidance in OTIB-0010 differs from 

instructions in section 5.0 of ORAUTPROC-0006. (ORAUT-PROC-006 

does not employ a standard correction 

factor to dosimeter dose but does 

apply uncertainty; OTIB-0010 uses a 

standard correction factor with no 

uncertainty.)

Closed on June 24, 2008. 

ORAUT-PROC-0006 was completely revised June 5, 

2006, and no longer contains guidance that is 

inconsistent with OTIB-0010.

8 OTIB-0010 does not identify its 

hierarchical position among competing 

procedures; for example, does the 

dose reconstructor have the option to 

use either OTIB-0010 or attachment 

D-2 of ORAUT-PROC-0006? 

Closed on June 24, 2008. 

ORAUT-PROC-0006, attachment D-2, has been 

eliminated and ORAUT-PROC-0006, section 5.1.1, 

refers the dose reconstructor to OTIB-0010, when 

appropriate.

9 A standard correction factor of 2, which 

is described as encompassing a great 

deal of errors, does not actually appear 

to be excessively conservative based 

on the 1989 National Research Council 

report, “Film Badge Dosimetry in 

Atmospheric Nuclear Tests.”

Closed on July 26, 2006. 

A standard correction factor of 2 for every recorded 

dose is considered to be sufficiently conservative.

10 The use of a default LOD value of 

40 milliroentgen (mR) should be 

considered a typical value as opposed 

to a highly conservative one.

Closed on July 26, 2006. 

An assumed LOD of 40 mR for gamma radiation is a 

reasonably claimant favorable assumption and, when 

combined with the assumed monthly zeros, ensures 

missed dose is overestimated.

Board Discussions 

Board members raised the following questions (pp. 37–47 of the October 17, 2013, transcript): 

• Question: Is this OTIB currently in use, since the Board member was under the 

impression that the use of the overestimate approach was not being continued? 

Response: NIOSH stated that the OTIB was still active; however, it is rarely used. They 

also indicated that there are some overestimating methods that have stopped. However, 

when you talk about eliminating overestimates in general, it makes DR much more time 

consuming and expensive. Therefore, NIOSH did not feel they could completely 

eliminate the overestimating approach.

• Question: Given that facilities use film badges, some of which are more sensitive than 

others, and now TLDs are commonly used, how comfortable is NIOSH with the value of 

40 mR as the LOD? 

Response: NIOSH stated that 40 mR is a good value to use for this procedure because 

the guidance is not just using 40 mR as the LOD; it also recommends maximizing the 

number of zero readings. Therefore, the DR not only overestimates the number of zeros, 
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it also uses the LOD instead of the LOD/2, which is considered a more precise estimate 

of the missed dose. 

• Question: On finding 9, what does the standard correction factor of 2 correct for?

Response: NIOSH indicated that they had not reviewed the OTIB recently, but there are 

several factors that influence the uncertainty of the film badges, and there were estimates 

of how large that uncertainty could be. When you sum these uncertainties, it comes to 

about 2. However, it was determined that the Board member would review the OTIB and 

attempt to answer his own question and, if necessary, get back to NIOSH with any 

additional questions. 

• Question: How do you handle missed dose as compared to records where you see zeros 

or less than detectable or blank cycles?

Response: For this OTIB, if you have a recorded dose in a year, you assume that 

occurred in one badge cycle. Then, the missed doses are calculated for all other cycles 

within the year, based on 40 mR per cycle. This is NIOSH’s definition of maximizing 

zeros.

These explanations satisfied the Board members, and no further discussion was held regarding 

the review of OTIB-0010. 
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OCAS-PER-012, Revision 0, “Evaluation of Highly Insoluble Plutonium 

Compounds” 

SC&A reviewed revision 0 in March 2010. SC&A submitted a review of nine DRs affected by 

OCAS-PER-012 (a Subtask 4 report under SC&A’s contract) in July 2012. The findings for the 

program evaluation report (PER) and Subtask 4 reviews were presented to the ABRWH at the 

October 17, 2013, meeting. 

Summary: Internal DR considers solubility types F, M, and S of a given radionuclide. Under 

unique circumstances, plutonium (Pu) exists in highly insoluble forms, referred to as type 

Super S (type SS). Inhaled, this highly insoluble form of Pu has extended residence time in the 

lung, proportionately increasing dose to that tissue. The impact of type SS Pu target tissue dose 

was assessed in ORAUT-OTIB-0049, “Estimating Doses for Plutonium Strongly Retained in the 

Lung” (OTIB-0049). That assessment prompted the issuance of OCAS-PER-012 (PER-012). 

Table 6. Summary evaluation of PER-012 review

Review subtask Action taken Finding/recommendation 

Subtask 1: Assess 

circumstances that 

necessitated the 

PER

• In development of the RFP technical 

basis document (TBD), NIOSH noted 

highly insoluble type S Pu and needed 

to assess its impact on internal dose. 

• 42 CFR 82 require dose to be 

calculated using current ICRP 

metabolic models, which do not 

address highly insoluble forms of Pu 

(type SS). 

• To account for longer retention and 

increased organ doses from type SS 

Pu, NIOSH developed and issued 

ORAUT-OTIB-0049 on 2/6/2007.

• ORAUT-OTIB-0049 specifies “dose 

adjustment factors” (generally a factor 

of 4) developed from cases of RFP and 

Hanford workers exposed to type SS 

Pu for four target organs and intakes

based on lung counts, air 

concentrations, urinalysis, and fecal 

analysis.

SC&A’s review of OTIB-0049, 

OCAS-PEP-012, and OCAS-PER012 found that NIOSH properly 

characterized the significance of 

highly insoluble Pu and complied 

with OCAS-PR-008 in evaluating 

impact of the programmatic 

changes on previously completed 

DRs.

SC&A had no findings under 

Subtask 1 of the review.
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Review subtask Action taken Finding/recommendation 

Subtask 2: Assess 

specific methods for 

corrective action

• When a PER involves a technical issue 

supported by documents such as white 

papers, OTIBs, or procedures that 

have not yet been formally reviewed by 

SC&A, Subtask 2 assesses the 

scientific basis to ensure credibility of 

the corrective action. 

• OCAS-PER-012 was prompted by 

ORAUT-OTIB-0049 issuance, critically 

reviewed by SC&A on October 29, 

2007. 

• SC&A was in full agreement with 

NIOSH’s approach for dose modeling 

of Pu type SS. 

• Subtask 2 was reduced to a brief 

summary of key technical elements 

defining ORAUT-OTIB-0049.

SC&A had no findings under 

Subtask 2 of the review.

Subtask 3: Evaluate 

approach for 

identifying the 

number of DRs 

requiring 

reevaluation

• To determine the total population of 

DRs potentially affected by OTIB-0049, 

PER-012 cited three criteria: (1) DR 

had been completed on or before 

2/6/2007, (2) DR involved facilities with 

exposure to type SS Pu, and (3) POC 

was <50%. This identified 4,865 

potential cases. 

• OTIB-0049 has two additional 

screening criteria: (1) POC >16.97% 

for cancers other than lung and 

thoracic lymph node (LNTH) and (2) no 

Pu dose was assigned, or Pu intake 

was based on air monitoring. This 

reduced potential cases to 1,757.

SC&A agreed with the 

methodology used to identify and 

quantify claims potentially affected 

by OTIB-0049 and had no findings 

under Subtask 3 of the review.

Subtask 4: 

Recommend a 

sample of affected 

DRs for evaluation

• PER-012 indicates the need for dose 

reevaluation for four groupings of 

target tissues: (1) lungs and LNTH, 

(2) extrathoracic tissues of respiratory 

tract, (3) tissues of gastrointestinal (GI) 

tract, and (4) other systemic organs. 

• Reevaluation of dose for these four 

groupings is dictated by one of four

monitoring methods employed in 

original DR: (1) air sampling, 

(2) urinalysis, (3) in vivo lung counting, 

and (4) fecal analysis.

SC&A recommended a minimum 

of 1 case be selected from 10 

permutations (1) lung/LNTH

evaluated using urinalysis, lung 

count, fecal, and air sampling and 

(2) extrathoracic, GI tract, and 

systemic organs evaluated using 

urinalysis and fecal sampling.

The Board selected nine

applicable cases.
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Review subtask Action taken Finding/recommendation 

Subtask 4: Review of 

sample set of DRs 

affected by PER-012

Audit of the selected nine DRs was 

limited to evaluating methods/corrective 

actions in the DRs that relate only to 

issues addressed in OCAS-PER-012. 

Audit focused on determining whether 

internal doses associated with potential 

exposure to type SS Pu were performed 

accurately and in accordance with 

guidance in ORAUT-OTIB-0049.

• SC&A’s audit concurred with 

NIOSH’s approach and 

assumptions in calculating 

internal doses from exposure to 

highly insoluble Pu for all nine

cases. 

• SC&A found that NIOSH 

reevaluated each of these DRs 

using methodology consistent 

with guidance in ORAUT-OTIB0049. The review had no 

findings. 

• SC&A found development of the

OTIB-0049 Workbook, which 

assists dose reconstructors in 

(1) entering appropriate data, 

(2) calculating fitted and missed 

organ doses and making 

comparisons of these data, and 

(3) generating IREP input, was 

very instrumental in successful 

implementation of PER-012.

Board Discussions 

Board members had no questions or comments regarding the review of PER-012 and the 

evaluation of nine impacted cases.
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NIOSH-OVER-0009, “Skin Exposure” 

NIOSH-OVER-0009 (OVER-0009) is a categorization of observations and findings that arise 

during reviews of DRs or technical guidance documents that will impact many. The findings and 

resolution of findings were presented to the Advisory Board at the April 11, 2018, meeting. 

Summary: NIOSH-OVER-0009 specifically addresses SC&A’s concerns about the modeling of 

fine and large particle deposition on the skin. 

Table 7. Three total concerns for NIOSH-OVER-0009

# OVER-0009 concerns Resolution

1 SC&A’s concern involved a derived 

dose of 16 mrem/year to bare skin that 

is based on unsupported and 

unrealistic assumptions, which include: 

1. daily skin contaminations for each of 

the 250 workdays per year that only 

persist for 8 hours 

2. implication that after 8 hours, each 

skin contamination is 100% 

removed by a standard daily shower 

3. only bare skin is subject to 

contamination and resultant 

radiation exposure

Closed February 18, 2015, based on the following.

NIOSH discussed its approach for addressing fine 

particle deposition to the satisfaction of SC&A, except 

for assumptions about the ease with which uranium 

could be removed from skin and clothing. 

NIOSH prepared a white paper (February 2015), 

which assessed the literature that qualitatively and 

quantitatively supported the removal of uranium by 

washing with soap and water.

2 SC&A’s concern involved the 

relationship between the derived dose 

and how IREP uses this dose to derive 

a POC, given that the skin dose only 

occurs to a small area.

Closed April 16, 2014, based on following NIOSH 

actions:

• Explained the relationship between derived dose 

and IREP to determine a POC. 

• Identified that specific guidance for dealing with 

nonuniform exposure to the skin has been 

incorporated into ORAUT-OTIB-0017 (OTIB-0017). 

• Consulted with SENES Oak Ridge to confirm 

OTIB-0017 guidance was appropriate.

3 SC&A had the same basic questions 

as described in concern 1, but for 

deriving doses for the skin deposition 

of large uranium flakes.

Closed April 16, 2014, based on following SC&A 

recommendation.

SC&A recommended using OTIB-0017 protocols, 

where the skin exposure under a hypothetical flake is 

averaged over the entire surface area of the body.

Board Discussions 

April 11, 2018, Board meeting: Board members raised the following questions (pp. 63–73 of 

the April 11, 2018, transcript): 

• Question: Are there any data to show that all facilities required daily showers and 

workers, in fact, actually took a standard daily shower in winter and summer? 
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Response: NIOSH stated that they did not look in tremendous detail at how we know 

that everyone took a daily shower. However, it was their experience that, in many of 

these facilities that they were familiar with, showering was part of their activity, 

especially when workers were involved in messy operations, such as rolling.

Response Followup: It might be worth taking a look at the frequency with which people 

really do take showers, not the efficacy of the soap and water.

• Question: How is this averaging (i.e., small particles versus large particles versus whole 

body) being resolved by IREP?

Response: NIOSH stated that if you do not know where the contamination occurred, 

then this is not an IREP issue; it is an issue with input into IREP. NIOSH assigns a 

lognormal distribution that accounts for the various possible scenarios of how large an 

area could have been contaminated.

• Question: We know that a skin cancer occurred on the bare skin. We do not know where 

the contamination occurred, but we're generating a bare skin estimate and then averaging 

it over the entire body. Is that claimant favorable or not?

Response: NIOSH stated that all we have is a value. We know there was maybe 5,000 

dpm per 100 square centimeters (cm2) but we have no idea where it was. Therefore, we 

have to have some accommodation to account for the unknown nature of where the 

contamination occurred. Was it over the tumor? Was it not over the tumor? How large an 

area? That is basically what this lognormal distribution accounts for.

Due to the lengthy discussions and the Board’s inability to get all their questions answered to 

their satisfaction, it was determined that the Board would postpone action on approving the 

review of NIOSH-OVER-0009. The Board requested that NIOSH prepare additional information 

to clarify these issues and present those data at a future Board meeting.

August 22, 2018, Board meeting: As requested, NIOSH provided the Board with additional 

information regarding the resolution of concerns about assessing dose to contaminated areas of 

the skin under NIOSH-OVER-0009 (pp. 81–92 of the August 22, 2018, transcript). In summary, 

• The issue is as follows: Assuming there is a probability of a hot particle depositing on the 

skin of a worker that was never measured, and you have a skin cancer, what is the risk 

associated with that?

• In this situation where you do not know if the skin was irradiated over the tumor or not, it 

falls into the realm of binomial distribution.

• Since there is currently no binomial distribution in IREP, SENES developed a lognormal 

approximation of the binomial distribution that was incorporated into OTIB-0017 that is 

considered claimant favorable. NIOSH stated that they are very confident it is claimant 

favorable because this lognormal approximation significantly overestimates the upper 

dose.
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• Since this issue was raised, NIOSH has communicated with SENES, and they are in the 

process now of producing a binomial distribution test model for NIOSH to use in IREP to 

determine if what NIOSH is doing is definitely claimant favorable and whether or not 

NIOSH might want to move forward in the future and have the true binomial distribution 

for this situation.

• NIOSH stated that they are reopening OTIB-0017, and a couple issues are going to be 

refined for better detail.

• The Designated Federal Officer requested that SC&A perform a focused review of the 

revised OTIB-0017 to determine how these issues were handled.

To date, OTIB-0017 has not been revised since 2005. Therefore, the NIOSH-OVER-0009 

concerns cannot be formally closed by the Board. 
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ORAUT-OTIB-0017, Revision 01, “Interpretation of Dosimetry Data for Assignment 

of Shallow Dose” 

SC&A reviewed revision 01 in June 2006. The findings and resolution of findings were 

presented to the Advisory Board at the April 11, 2018, meeting. 

Summary: OTIB-0017 provides guidance for assigning shallow doses to the skin, testes, and 

breast from nonpenetrating radiation, including beta exposures and exposures to low-energy 

photons. 

Table 8. Fifteen total findings for ORAUT-OTIB-0017

# OTIB-0017 finding Resolution

1 OTIB-0017 suggested that the dose 

reconstructor check whether the site 

was reporting dose due to electrons or 

photons, and whether the dosimetry 

system had been calibrated for that 

type of radiation. It needs to provide 

additional guidance on how to interpret 

film badge data with respect to beta vs. 

low-energy photon exposure for the 

purpose of reconstructing shallow 

doses.

Closed October 2, 2007, based on following NIOSH 

response.

NIOSH explained that this OTIB is to be used together 

with the site profile and other OTIBs on a case-bycase basis.

2 The protective clothing used for each 

case was known in the majority of 

cases. Clothing-specific transmission 

factors should be used.

Closed October 2, 2007, based on following NIOSH 

response.

NIOSH explained that there is language in the OTIB 

that allows the dose reconstructor to choose the 

appropriate clothing shielding factors based on 

whether a minimizing, maximizing, or a realistic 

analysis of beta dose is being performed.

3 It is SC&A’s opinion that individual 

monitoring for beta particles only works 

on a “yes/no” basis. SC&A’s main 

concern is the potential for direct 

deposition of a hot particle on the 

worker’s skin that is not detected, or 

localized undetected beta exposure.

Closed October 14, 2008: It should be noted that 

many of SC&A’s concerns were ultimately addressed 

to SC&A’s and the SCPR’s satisfaction under 

overarching issues (NIOSH-OVER-0009).

NIOSH explained that whether such exposures might 

have occurred is determined based on frisking data 

(for hot particles) and knowledge of the working 

conditions at the facility.

SC&A recommends that finding 3 be closed, not 

because everything is resolved, but because OTIB0017 cannot be improved much further. SC&A 

suggests the following: 

• When the cancer site is on the hands, lower arm, or 

face, consider workplace monitoring data. 

• When the cancer site is on the thorax, use individual 

monitoring data. 

• When the cancer site is on the lower legs or feet, 

consider both.
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# OTIB-0017 finding Resolution

4 It is possible to state definitely where 

the cancer site is, but not where the 

contamination was.

Closed October 2, 2007: The SCPR transferred this 

item to overarching issues, because it is being 

addressed and ultimately closed under finding 3.

Discussion about finding 3 applies to this issue.

5 A skin dose due to hot particle 

exposure will not be detected because 

of the localized nature of the exposure.

Closed October 2, 2007: The SCPR transferred this 

item overarching issues, because it is being 

addressed and ultimately closed under finding 3.

Discussion about finding 3 applies to this issue.

6 If dosimetry recorded an LOD, then 

this value should be used as the basis 

for the missed dose calculation.

Closed December 11, 2007, based on the following 

agreement between NIOSH and SC&A.

If it is known that the film badge dosimeter overstated 

the dose from low-energy photons, and if it can be 

further ascertained that the LOD was expressed in 

terms of this overstated dose rather than the corrected 

dose, then we agree that it is appropriate to apply a 

correction factor to the LOD in assigning a missed 

dose from low-energy photons.

7 It is not claimant favorable to consider 

that the employee had 4 millimeters 

(mm) of clothing thickness. 

Closed October 2, 2007, based on following NIOSH 

response.

Due to the location of the organ of concern, the 4-mm

assumption was made for pants and an 

undergarment, not a lab coat.

8 Attachment A provides a correction 

factor for the breast, penis, and testicle 

using a source that was modeled as a 

10-cm2 infinitely thin disc source 

located 2 cm away from the skin. This 

is appropriate for the breast area; 

however, if the source was near the 

testicles, the film dosimeter would not 

measure anything.

Closed October 2, 2007: The SCPR concluded that 

the guidance in OTIB-0017 for this issue is adequate 

based on following.

There was extensive discussion about other 

documents that address this issue. NIOSH explained 

that it relies on quality assurance and training to 

ensure that the full array of guidance documents are 

being correctly employed in individual DRs.

9 Tables A-1 and A-2 list correction 

factors for nonpenetrating doses based 

on radionuclide. In nearly all real 

cases, it is not possible to state the 

radionuclides that are responsible for 

the beta dose.

Closed November 7, 2007, based on following NIOSH 

response.

The table provides benchmark correction factors for a 

range of beta energies. Site profile documents will 

typically provide information that will help the dose 

reconstructor determine the proper energy range to 

use. In addition, the OTIB itself provides guidance 

with respect to uranium daughter products.

10 For low-energy beta radiation, the 

dosimeters were likely incapable of 

furnishing accurate doses.

Closed November 7, 2007, based on following NIOSH 

response.

DR staff would have to consider this on a case-bycase basis. The OTIB purpose is to provide general 

information for the DR staff to use along with other 

sources of information. If necessary, the hierarchy of 

data sources listed in IG-001 (table 1.1) and ORAUTPROC-0006 (table 5.2) includes the use of source 

term modeling.
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# OTIB-0017 finding Resolution

11 It is not clear why the two tables 

providing examples of skin dose 

assignments on pages 21 and 24 give 

the recommendation to assign 30–

250 keV for missed dose to the skin for 

0 “OW reading” and 0 “S reading.”

Closed November 7, 2007, based on following NIOSH 

response.

This radiation type and energy range was chosen 

because it is, in fact, claimant favorable compared to 

assigning the dose as electron dose (refer to IREP 

technical document).

12 The logical order of the information in 

chapter 3, “General Approach,” could 

be improved.

In abeyance as of November 11, 2007, awaiting a 

revision to OTIB-0017.

NIOSH agreed with SC&A’s finding and will revise 

OTIB-0017 in the future.

13 The OTIB does not identify any cases 

where a possibly high POC can be 

determined early in the investigation.

Closed November 7, 2007, based on following NIOSH 

response.

ORAUT-PROC-0006, not OTIB-0017, is the document 

that would be used by DR staff to quickly triage a 

claim to determine the potential for high POC. It is 

important to consider the use of OTIB-0017 in the 

overall context of the DR process. OTIB-0017 does 

give guidance on the topic of low/high POC potential 

on page 6, items a, b, and c.

14 The OTIB is not claimant favorable in 

instances of unknown parameters 

affecting dose estimates. (Typically, 

the dosimeter location has no 

relationship to skin dose at the point of 

cancer incidence.)

Closed November 7, 2007, based on following NIOSH 

response.

The Division of Compensation Analysis and Support

(DCAS) and Oak Ridge Associated Universities Team 

(ORAUT) disagree with this position. Consideration of 

geometry issues is discussed in the OTIB and is 

addressed on a case-by-case basis. In addition, the 

OTIB makes a recommendation (i.e., DCF = 1) to 

accommodate potential inaccuracies due to exposure 

geometry. The OTIB is claimant favorable in its 

recommendations regarding DCF, LOD, attenuation, 

and radiation type/energy range.
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# OTIB-0017 finding Resolution

15 The OTIB does not employ 

scientifically valid protocols for 

reconstruction of doses regarding 

(a) assignment of nonpenetrating dose, 

(b) assumption of 4 mm clothing 

thickness, and (c) treatment of hot 

particles. 

Closed November 7, 2007: The SCPR concurred with 

the following NIOSH response. It should be noted that 

the nonuniform dose was ultimately adequately 

addressed under NIOSH-OVER-0009.

DCAS and ORAUT disagreed with this position and 

provided the following discussion: 

a. The guidance is given in order to assign the 

nonpenetrating dose as electrons or low-energy 

photons as necessary to complete a valid DR using 

IREP. Dose is often given as “OW” and “S” or 

“shallow” and “deep,” not beta and gamma. 

b. Since the organ discussed in this section of the 

OTIB is the penis, the 4-mm assumption was made 

for pants and an undergarment, not a lab coat 

(although that could have been added), sweater, or 

shirt as recommended in the general comments 

section. 

c. The dose reconstructor can consider nonuniform 

dose using the guidance in the OTIB along with 

tools such as VARSKIN and guidance from site 

profile documents regarding the potential for hot 

particle exposure.

Board Discussions 

April 11, 2018, Board meeting: Board members raised the following questions (pp. 74–80 of 

the April 11, 2018, transcript): 

• Question: For finding 12 of the OTIB, it appears that NIOSH, SC&A, and the 

Subcommittee are all in agreement, but the revision has been in abeyance since 2007, 

which is a very long time. Is there any indication of when the OTIB will be revised?

Response: Dr. Neton responded that “this procedure is currently undergoing revision for 

other items and I made sure that this would be incorporated into that revision that's being 

worked on right now.” 

• Question: Finding 7 relates to the assumption of 4 mm of clothing. The question is about 

how that is operationalized or what that means in terms of the shielding from 4 mm of 

clothing and what assumptions are implicit in that. Sometimes when you incorporate 

clothing as an additional barrier, there are various ways of implementing it. One of them 

is that you assume it's impermeable or nonporous. For the underpants, that would seem a 

stretch, as they are designed to breathe.

Response: NIOSH indicated that they did not know the answer to the question and 

would have to do additional research. NIOSH stated, however, that the thicknesses were 

derived based upon the guidance within VARSKIN and clothing thicknesses. 
SC&A, Inc.

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Since several OTIB-0017 findings were associated with resolution of NIOSH-OVER-0009 and 

NIOSH’s inability to answer all Board questions regarding other OTIB-0017 findings, it was 

determined that the Board would postpone action on approving the review of OTIB-0017. 

Therefore, the Board passed a motion to “defer action and to report back the clarification matters 

for those findings that deal with the skin dose and the undershorts and other garments.”

August 22, 2018, Board meeting: As requested, NIOSH provided the Board with additional 

information regarding the resolution of concerns about assessing dose to contaminated areas of 

skin and the calculation of shielding from clothing (undergarments) under OTIB-0017 and 

NIOSH-OVER-0009 (pp. 81–92 of the August 22, 2018, transcript).

• For the discussion of skin contamination, please see the NIOSH-OVER-0009 section on 

the August 22, 2018, Board meeting in this handout.

• Regarding the question on OTIB-0017, finding 7:

– NIOSH stated that they looked at three different sets of clothing and performed 

attenuation measurements that ranged from 1 to 5 mm, and the density around 

1.5 grams per cubic centimeter for both the undergarments and the protective 

outer clothing is based on the fact that these are cotton garments.

– NIOSH re-ran the calculations using the mean of the distribution of the values 

that were measured, which resulted in very similar values for strontium-90 and 

yttrium-91.

– For rhodium, ruthenium, rhodium, ruthenium-106, and rhodium-106, the results 

differed by about a factor of 2. The attenuation factor was calculated to be 0.5, not 

0.2 as reported in OTIB-0017.

– NIOSH indicated that they are in the process of revising OTIB-0017 and will 

revise table A1 based on their new results. 

– NIOSH also recommended that this finding should not be closed at this time and 

that, when the revised OTIB-0017 is published, the SCPR should consider 

performing another review of the revision.

• Dr. Richardson stated that his question on finding 7 was in regard to “the permeability of 

the undergarment, not just the thickness but the assumption that you had a perfectly 

impermeable undergarment.”

– Dr. Neton stated, “I apologize if we misinterpreted your question then, but it's a 

good time because we're going to go back and revise it anyway, so we can take 

that issue up at that time.”

To date, OTIB-0017 has not been revised since 2005. Therefore, the OTIB-0017 findings cannot 

be formally closed by the Board.