Office of Compensation Analysis and Support

Document Number: OCAS-PR-010 

Effective Date: 1/23/2009 

Revision No. 0

Data Access and Interview Procedures Page 1 of 14 

Approval: Signature on file 1/22/2009 

Signature Date 

Stu Hinnefeld, Health Science Administrator 

Name 

Concurrence: Signature on file 1/22/2009 

 

Signature Date 

Larry Elliott, OCAS Director 

Name 

1.0 PURPOSE.......................................................................................................................2 

2.0 SCOPE ............................................................................................................................2 

3.0 REFERENCES ...............................................................................................................2

4.0 GENERAL......................................................................................................................2 

5.0 PROCEDURE.................................................................................................................4 

6.0 RECORDS ......................................................................................................................11 

7.0 APPLICABLE DOCUMENTS (FORMS) .....................................................................11 

8.0 DEFINITIONS................................................................................................................11 

RECORD OF ISSUE/REVISIONS

ISSUE 

AUTHORIZATION 

DATE

EFFECTIVE 

DATE

REV. 

NO.

 DESCRIPTION

1/23/2009 1/23/2009 0 

Initial version of procedure describing the 

coordination and submission of data requests to the 

Department of Energy 
Effective Date: 1/23/2009 Revision No. 0 Procedure No. OCAS-PR-010 Page 2 of 14 

 

1.0 PURPOSE

The purpose of this procedure is to outline the steps required to coordinate and submit data 

requests to the Department of Energy in support of Dose Reconstruction (42 C.F.R. pt. 82) and 

Special Exposure Cohort Evaluations (42 C.F.R. pt. 83) under the energy Employees 

Occupational Illness Compensation Program Act (EEOICPA) of 2000. 

Additionally, interviews with current and former workers are sometimes necessary to understand 

work practices and radiation monitoring in support of the Dose Reconstruction and Special 

Exposure Cohort evaluations. This procedure also outlines the steps to conduct these interviews 

and ensure the review of information in a manner that protects sensitive information. The steps 

outlined in this procedure are required for all data requests at all DOE and AWE sites. 

2.0 SCOPE

This procedure applies to all NIOSH personnel, including special government employees (i.e. the 

Advisory Board on Radiation and Worker Health (ABRWH)) and all NIOSH contractors 

(including subcontractors working on behalf of the ABRWH), who are working on the 

EEOICPA project. 

3.0 REFERENCES

3.1. 42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule; May 

2, 2002; SRDB Ref ID: 19392 

3.2. 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the 

Special Exposure Cohort Under the Energy Employees Occupational Illness 

Compensation Program Act of 2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

3.3. 10 C.F.R. pt. 1017 Identification and Protection of Unclassified Controlled Nuclear 

Information

4.0 GENERAL

This procedure must be used by all NIOSH personnel including special government employees 

(i.e. the Advisory Board on Radiation and Worker Health (ABRWH)) and all NIOSH contractors 

and subcontractors (including those working on behalf of the ABRWH), who work under the 

EEOICPA project. Specific responsibilities for key personnel are outlined below. 
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NIOSH Site Point of Contact (POC) or (designee)

The NIOSH Site Point of Contact is responsible for the overall implementation of this procedure. 

The NIOSH Site POC receives, coordinates, and submits all data requests to DOE, and ensures 

that the information captured is properly protected and uploaded to the Site Research Database 

(SRDB). The NIOSH Site POC is also responsible for coordinating any sensitive interviews 

with current or former workers to be conducted with the site. The NIOSH Site POC may 

designate in writing an authorized representative to act in their place for all responsibilities 

outlined below including submittal of requests and coordination with the DOE Site POC. 

DOE Site Point of Contact

The DOE Site Point of Contact is responsible for coordinating with the NIOSH Site POC to 

provide site access for data review, coordinate onsite classification reviews, and submit reviewed 

and requested information to NIOSH. The DOE Site POC may also designate an authorized 

representative to act in their place for all responsibilities outlined below, including coordination 

of all aspects with the NIOSH Site POC. 

DOE Headquarters Point of Contact

The DOE Headquarters Point of Contact is responsible for coordinating and providing funding to 

the DOE Site to support NIOSH requests for information. The DOE Headquarters Point of 

Contact is responsible for coordinating the transmittal of appropriate clearance information to 

enable NIOSH and their contractor’s access to sensitive information. The DOE Headquarters 

Point of Contact is responsible for confirming NIOSH’s “need to know” as established by 

EEOICPA and should provide the DOE Site POCs with the “confirmation” that NIOSH has an 

established “need to know” with the DOE Site POCs. 

NIOSH Contractor Site Point of Contact

The NIOSH Contractor Site Point of Contact is responsible for coordinating their team’s data 

requests including the conduct of sensitive interviews. All requests for information and sensitive 

interviews are to be submitted through the NIOSH Site Point of Contact. 

 
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5.0 PROCEDURE

5.1. Requesting Information

During Site Profile development and/or review in support of Dose Reconstruction, 

Special Exposure Cohort petition evaluations, or for other reasons, additional information 

from the Department of Energy is generally necessary to address scientific issues related 

to the estimation of worker radiation dose. In these instances, it becomes necessary for 

NIOSH to formally request the additional information from the Department of Energy. 

Before any request is submitted, the NIOSH Site POC is responsible for checking the Site 

Research Database to ensure the information has not already been obtained from the site 

or is publicly available from other DOE resources such as the Office of Science, 

Technology and Information (OSTI) OpenNet / Information Bridge. Once the NIOSH 

site POC has determined that this information is not in any NIOSH records holdings, a 

formal request can be made. 

5.1.1. Initial Contact 

NIOSH Site POC shall contact the DOE Headquarters Point of Contact to open 

dialog regarding the nature of the information needed and whether the request is 

singular or will be part of a larger ongoing request such as an SEC evaluation, 

Site Profile development, or Site Profile review. The purpose of this initial 

contact is to provide advanced notice to DOE-Headquarters so that they can 

provide some basic support for the site especially for large requests where the site 

may require additional funds. 

5.1.2. Submittal of Formal Request 

The NIOSH site POC prepares and submits a formal written request for 

information (letter) to the DOE Site POC. This request should describe in as 

much detail as possible the information needed and the purpose for which the 

information is being requested (i.e. Site Profile development, Site Profile review, 

or SEC petition evaluation). 

There are basically two methods by which DOE may respond to the request for 

information. The first, following the submittal of a formal request from the 

NIOSH Site POC to the DOE Site POC, is for DOE to provide the information 

with no additional involvement from NIOSH or its contractors. In this instance, 

the Department of Energy ensures that all of the documents have been reviewed 

for sensitive information, are clearly marked, and then formally transmitted to 

NIOSH. 
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The second method, while far more complicated, is often the most efficient use of 

both NIOSH and DOE resources. This method involves extensive coordination 

between the NIOSH Site POC and the DOE Site POC. For very large requests, 

that involve DOE retrieving records from onsite repositories or from Federal 

Records Centers (FRC), it is often beneficial for NIOSH or its contractors to 

review the information before data capture to ensure the information is useful and 

pertinent to the Site Profile development, review, or the SEC Petition evaluation. 

In most instances this review requires an onsite visit, typically by Q-cleared 

individuals. DOE site access, the conduct of the data review, and the data capture 

steps are outlined in sections 5.1.3 through 5.1.5 below. 

5.1.3. Site Access for NIOSH Personnel and NIOSH Contractors 

In this section the typical steps and responsibilities to enable NIOSH and its 

contractor’s access to the site are described. 

5.1.3.1. Establishing Date of Visit to Site 

The NIOSH Site POC will coordinate with the DOE Site POC to arrange 

an agreed upon date that NIOSH or its contractors can visit the site to 

conduct the review. 

5.1.3.2. Participating Individuals 

The NIOSH Site POC will submit a list of individuals that will be 

participating in the data review to the DOE Site POC. When necessary, 

the NIOSH Site POC will provide completed “Request for Visit or Access 

Approval” forms (DOE Form 5631.20) to the DOE Headquarters POC for 

all NIOSH personnel or contractors requesting DOE site access. The 

NIOSH Site POC (or designee) will coordinate with the DOE Site POC 

site access for all NIOSH contractors, subcontractors, the ABRWH, and 

the ABRWH contractors. The NIOSH Site POC is also responsible for 

transferring special access requests to the DOE Headquarters POC. 

5.1.3.3. Site Badging and Training 

The DOE Site POC will coordinate with the DOE Headquarters POC and 

with the site security personnel to ensure appropriate badging (including 

sigmas if necessary, to enable site access. In addition, the DOE Site POC 

is responsible for determining if an additional training is required to 

facilitate and complete access. 

Note if any onsite training is required, the DOE Site POC will coordinate 

with the NIOSH Site POC to ensure adequate time is allowed for the 

training before the data review is conducted.
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5.1.4. Data Review 

In this section, the actual conduct of the review is discussed including the 

identification of records to be captured and necessary data logging information. 

5.1.4.1. Site Classification Overview and Introduction 

NIOSH staff and contract reviewers will meet with NNSA/DOE site 

classification office for brief overview of site sensitivities. This 

introduction will serve to familiarize the NIOSH Site POC with subject 

area and keyword indicators that may contain restricted data or other 

controlled information. 

5.1.4.2. Retrieval of Information 

The DOE Site POC will coordinate with site personnel to retrieve the 

information requested in step 5.1.2 and provide a space/location for 

NIOSH and/or its contractors to conduct their review. 

5.1.4.3. Communication of Information 

The NIOSH Site POC (or designee) will coordinate and communicate with 

the data capture team the information (data / records) to be technically 

reviewed, and will coordinate the conduct of the technical review. 

5.1.4.4. Documentation of the Review 

During the technical review of information, each reviewer should fill out 

OCAS-FORM-003, “Data Tracking Log Sheet” (Appendix A), identifying 

the information reviewed. This is not a requirement, but is a good records 

review practice. 

5.1.4.5. Documentation for Capture and Coding 

For data that is to be requested/captured, the reviewer will fill out OCASFORM-004, “Document Review Request Form” (Appendix B) describing 

the information, where it was found and for which purpose it was 

originally being requested. Each NIOSH contractor may develop their 

own form that complies with the intent of OCAS-FORM-004, as long as 

all of the pertinent information is recorded such that the information can 

be entered into the Site Research Database (SRDB). 

5.1.4.6. Classification Review of Identified Information 

Once the information to be captured has been identified, the DOE Site 

POC will coordinate with the site classification officer to review the 

information and provide the appropriate security markings (e.g. UCNI, 

OUO, or Unclassified: Approved for Public Release) as necessary on each 

document or data set before it is captured. 
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5.1.5. Data Capture 

For the data capture, some coordination between the NIOSH Site POC and the 

DOE Site POC is necessary. As with the initial request, there are two basic 

methods for which the reviewed data can be captured. The first is that DOE 

provides either a hardcopy of the appropriately marked information and NIOSH 

and/or its contractors scans/captures the information. The second is that Site 

Personnel scan the requested and security marked information and provide an 

electronic copy to the NIOSH Site POC. 

5.1.5.1. NIOSH or its Contractors Conduct Scanning 

When NIOSH or its contractors conduct the scanning, the DOE Site POC is 

responsible for providing adequate space to conduct the scanning and for 

ensuring that all documentation is appropriately marked before the 

scanning is conducted. 

5.1.5.2. DOE Conducts Scanning 

When DOE agrees to conduct the scanning, the NIOSH Site POC and the 

DOE Site POC will coordinate an appropriate schedule to ensure the 

scanning is conducted in a time frame that meets NIOSH’s needs and 

DOE’s resource limitations. 

5.2. Interviews 

In support of Site Profile development and review or in support of Special Exposure 

Cohort Evaluations, interviews with current or former workers are often beneficial to 

understanding site operations and radiation monitoring practices. These interviews differ 

from the Computer Assisted Telephone Interview (CATI) in that the interview is nonclaimant specific. The material discussed during these interviews generally involves 

more process information as well as site radiological monitoring practices. 

The only difference between the conduct of an interview with a former worker and a 

current worker is if the current worker requests that the interview be conducted during 

work hours. In this instance, the NIOSH Site POC must coordinate with the DOE site 

POC to establish a time and location for the interview to be conducted such that the 

interviewee is not penalized for his/her participation. Regardless of whether the 

interview is with a former or current worker, the steps outlined below describe how the 

interviews are to be conducted and documented. 

5.2.1. Interviews with Workers 

When conducting interviews with workers at any DOE or AWE sites caution must 

be employed to ensure sensitive or controlled information is not inadvertently 

included in the notes of the interview if conducted outside a limited access area. At 

the initiation of the interview, the following text shall be read to the interviewee. 
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“This interview is being conducted as part of the (Site Profile development / Site 

Profile Review / SEC Petition Evaluation) for the ______ site. You have been 

selected as an individual with intimate knowledge of the (operations / radiation 

monitoring practices) at ____ (site). Please note this interview and your responses 

are not a formal affidavit, or legal document, but a tool to assist NIOSH and/or its 

contractors in understanding the (sites operations / radiation monitoring practices). 

Since this site was part of the DOE Nuclear Weapons complex there are certain 

restrictions as to what can be discussed here today in an uncontrolled area. We ask 

that you not disclose any sensitive or potentially sensitive information with us 

today. If you believe this type of information is necessary to our understanding of 

the (site operations / radiation monitoring practices) we will be happy to arrange a 

follow-up interview with you at a secure federal facility where you will be allowed 

to discuss sensitive information. Do you have any questions? Do you wish to 

continue or do you request we conduct this interview in a secure Federal facility?” 

5.2.1.1. Concurrence Not to Disclose Sensitive Information 

If the interviewee agrees to continue, the interview may be conducted. 

5.2.1.2. Request for Interview in Secure Federal Facility 

If the interviewee wishes to conduct the interview in a secure federal 

facility, the NIOSH Site POC will coordinate with the DOE Site POC to 

schedule an interview in an approved secure location. In addition, the 

DOE site POC will provide a written disclosure letter to the interviewee 

authorizing them to be interviewed by the appropriately cleared NIOSH 

personnel and / or their contractors and to authorize the disclosure of 

sensitive or controlled information. 

5.2.2. Documentation of the Interview 

Upon completion of the interview, a transcript of the questions and responses will 

be documented using OCAS-FORM-005, “Documented Communication” 

(Appendix C) for entry into the Site Research Database (SRDB). Before entry 

into the SRDB, a classification review must be conducted by the DOE Site 

Classification Officer. 

5.2.2.1. Classification Review for Non-Secure Facility Interview 

For interviews conducted in non-secure locations, OCAS-FORM-005 and 

the typed notes will be submitted to the DOE Site POC to coordinate the 

classification review of the interview. For DOE sites that are no longer 

operational, NIOSH will coordinate such reviews with the EEOICPA POC 

at DOE Headquarters. The NIOSH Site POC will maintain 

documentation of the submittal date, subject matter, and will be 

responsible for tracking requests for DOE review. 
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5.2.2.2. Classification Review from Secure Federal Facility Interview 

If the interview is conducted on the DOE site of interest or at a secure 

federal facility, the OCAS-FORM-005 and the raw interview notes (nontyped) shall be placed in an envelope and delivered to the DOE Site 

Classification Officer for review. The interview notes shall not be 

removed from the facility, typed into an electronic system, or disseminated 

by any other means until the classification review has been completed, and 

the document has been marked appropriately. (Note: care must be taken 

either during or following the interview to explicitly record the exact 

language that will appear in a final version before the notes are submitted 

to the DOE Classification Officer for review. Any changes to the 

interview transcripts after a classification review has been completed will 

require another classification review.)

5.2.2.3. Final Documentation 

Once the interview notes are reviewed, marked unclassified, and obtained 

from the DOE Classification Officer, the interview notes should be 

provided to the interviewee to ensure concurrence with the statements 

within the interview. (Note: this is not an opportunity to elicit additional 

information especially from interviews conducted in secure federal 

facilities, but to give the interviewee a chance to review and ensure that 

the information as recorded is accurate and factual. If additional 

information is volunteered, another interview should be scheduled in a 

secure facility, and the procedures described in 5.2.2.2. followed.) 

5.2.2.4. Submittal to the SRDB 

Unclassified interview notes, which contain neither Unclassified 

Controlled Nuclear Information (UCNI) nor Export Controlled 

Information (ECI), will then be submitted, along with Form OCAS-5, to 

the custodians of the Site Research Database for entry and formal 

documentation of the interview. Notes containing UCNI shall be kept in 

hardcopy form only, and shall be stored in a locked receptacle to prevent 

unauthorized disclosure, as described in 10 C.F.R. 1017. A Form OCAS-5 

can be submitted to the SRDB as a placeholder for the full document. 

Classified interview notes and documentation will be kept in secure 

storage for NIOSH by the DOE site POC or by the DOE Headquarters 

EEOICPA Point of Contact. Unclassified interview notes should be 

provided to NIOSH whenever possible. 

 
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5.2.3 Review of Documents Received During Interviews 

Occasionally, an interviewee has possession of additional documentation useful to 

NIOSH. Sometimes, this documentation does not contain any classification 

markings (OUO, UCNI, ECI, other), thus the disposition of the documents is not 

actually known. Some interviewees have been and are willing to provide a hard 

copy of these documents upon the condition that the originals will be returned. 

Since the disposition of unmarked documents is not known, the steps outlined 

below describe the process for retrieving and controlling this type of information 

until appropriate markings have been provided. 

5.2.3.1 Copying Unmarked Documents

Upon receipt of unmarked documentation from an interviewee, the 

NIOSH Site POC or designee shall have the original documents copied

(not scanned) thus creating a second hard copy of the originals. Upon 

copying, the original documents shall be returned to the interviewee. (The 

goal for copying not scanning the documents is to prevent the inadvertent 

inclusion of unmarked documentation into the SRDB). 

5.2.3.2 Submittal of Unmarked Documents for Classification Review

The NIOSH Site POC or designee shall submit the copied documents to 

the DOE Site POC for classification review. 

5.2.3.3 Review of Unmarked Documents

The DOE Site POC shall coordinate the classification review and ensure 

that all of the documents are appropriately marked (OUO, UCNI, ECI, 

Unclassified: Approved for Public Release or other). The DOE Site POC 

shall provide the marked hard copy documents to the NIOSH Site POC for 

inclusion into the SRDB. 

5.2.3.4 Submittal to the SRDB

Documents which do not contain Unclassified Controlled Nuclear 

Information (UCNI) or Export Controlled Information (ECI) will then be 

submitted, along with Form OCAS-4, to the custodians of the Site 

Research Database for entry and formal documentation. Documents 

containing UCNI shall be kept in hardcopy form only, and shall be stored 

in a locked receptacle to prevent unauthorized disclosure, as described in 

10 C.F.R. pt.1017. Form OCAS-4 can be submitted to the SRDB as a 

placeholder for the full document. 

If the documents are determined to contain sensitive information, the 

documents will be kept in secure storage for NIOSH by the DOE site POC 

or by the DOE Headquarters EEOICPA Point of Contact. 
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6.0 RECORDS 

The following records are generated as applicable. 

7.0 APPLICABLE DOCUMENTS

7.1. OCAS-FORM-003, “Data Tracking Log Sheet” 

7.2. OCAS-FORM-004, “Document Review / Request Form” 

7.3. OCAS-FORM-005, “Documented Communication” 

8.0 DEFINITIONS

8.1. None 
Appendix A, OCAS-FORM-003 - Data Tracking Log Sheet 

Date : _______

Box Number Requested 

Document Number Yes No Document or Folder Title and description of contents 

OCAS-FORM-003 Rev 0 – 09/01/2008
Appendix B, OCAS-FORM-004 – Document Review Request Form 

DOCUMENT REVIEW REQUEST FORM OCAS-FORM-004 REV 0 

The attached document may contain Privacy Act data. This information is protected by the Privacy 

Act, 5 U.S.C. §552a; disclosure to any third party without written consent of the individual to whom 

the information pertains is strictly prohibited. 

Complete all information that applies to the data/document being submitted for uploading to the Site 

Research Database (SRDB), attach this form to the front of the document

OCAS-FORM-004 REV 0 
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Appendix C, OCAS-FORM-005 Documented Communication