Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

 

REVIEW OF OCAS-PR-012: 

WORKER OUTREACH PROGRAM 

 

Contract No. 200-2009-28555 

SCA-TR-PR2010-0002, Revision 0

 

 

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755 

April 2010 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42CFR82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 2 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Document No. 

SCA-TR-PR2009-0002 

Effective Date: 

April 9, 2010 

S. Cohen & Associates: Technical Support for the 

Advisory Board on Radiation & Worker Health 

Review of NIOSH Dose Reconstruction Program 

Revision No. 

0 

 

REVIEW OF OCAS-PR-012: 

WORKER OUTREACH PROGRAM 

 

Page 2 of 74 

 

Task Manager: 

________________________ Date: ___________ 

U. Hans Behling, PhD 

 

Project Manager: 

________________________ Date: ___________ 

John Mauro, PhD, CHP 

 

Supersedes: 

N/A 

 

 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 3 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

TABLE OF CONTENTS 

List of Abbreviations and Acronyms...............................................................................................5 

Executive Summary.........................................................................................................................7 

1 Overview of Procedure Used in the Conduct of the Worker Outreach Program...............11 

2 Status of ORAUT-PROC-0097 Findings/Observations....................................................15 

3 SC&A Evaluation of OCAS-PR-012.................................................................................17 

4 Procedure Checklist ...........................................................................................................32 

5 References..........................................................................................................................41 

Attachment 1: SC&A Meeting Minutes and Notes from the Weldon Spring Worker 

Outreach Meeting...............................................................................................................43 

Attachment 2: SC&A Summary from NIOSH Workshop on Dose Reconstruction and 

SEC Processes....................................................................................................................47 

Attachment 3: Worker Outreach Meetings/Events Conducted under OCAS-PR-012 .................53 

Attachment 4: Documentation Available in OTS for Closed Worker Outreach Events 

Conducted under OCAS-PR-012.......................................................................................60 

Attachment 5: Summary of Action Items for All Worker Outreach Meetings in the 

Outreach Tracking System through March 12, 2010.........................................................63 

Attachment 6: ORAUT-PROC-0097 Finding Disposition Recommendations............................66 

Attachment 7: Mission Statement and Draft Implementation Plan for the Worker Outreach 

Work Group .......................................................................................................................70 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 4 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

LIST OF TABLES 

Table 1: Summary of Issues........................................................................................................10 

Table 2: Summary of Meeting Types Occurring under PR-012. ................................................20 

Table 3: Primary Worker Outreach Meetings Described in PR-012...........................................21 

Table 4: Summary of OTS Documentation.................................................................................21 

Table 5: Other Outreach Venues Identified by NIOSH ..............................................................23 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 5 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

LIST OF ABBREVIATIONS AND ACRONYMS 

ABRWH, 

 Advisory Board, 

 or Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

ATL Advanced Technologies and Laboratories International, Inc. 

AWE Atomic Weapons Employer 

CATI Computer Assisted Telephone Interviews 

COI Close-out Interview 

CTW Construction Trades Worker 

DFO Designated Federal Official 

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

EEOICPA Energy Employees Occupational Illness Compensation Program Act 

FMPC Feed Materials Production Center 

FOIA Freedom of Information Act 

HHS Health and Human Services 

HP Health Physicist 

IAAP Iowa Army Ammunition Plant 

IAM International Association of Machinists 

IAMAW International Association of Machinists and Aerospace Workers 

ICWUC International Chemical Workers Union Council 

INEEL Idaho National Engineering and Environmental Laboratory 

INL Idaho National Laboratory 

IREP Interactive RadioEpidemiological Program 

KCBCTC Kansas City Building and Construction Trades 

KCP Kansas City Plant 

LANL Los Alamos National Laboratory 

NIOSH National Institute for Occupational Safety and Health 

NNSA National Nuclear Security Administration 

NOCTS NIOSH OCAS Claims Tracking System 

NTS Nevada Test Site 

NUMEC Nuclear Materials and Equipment Corporation 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 6 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

OCAS Office of Compensation and Analysis 

ORAUT Oak Ridge Associated Universities Team 

ORNL Oak Ridge National Laboratory 

OSC Outreach Support Contractor 

OTS Outreach Tracking System 

PDF Portable Document Format 

PHA Public Health Advisor 

POC Probability of Causation 

RFP Rocky Flats Plant 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SEC Special Exposure Cohort 

SME Subject Matter Expert 

SNLL Sandia National Laboratory – Livermore 

SOAR Steelworkers Organization of Active Retirees 

SPFPA Security Police and Fire Professionals of American 

SPSME Site Profile Subject Matter Expert 

SPTL Site Profile Technical Lead 

SRDB Site Research Data Base 

SRS Savannah River Site 

TBD Technical Basis Document 

UFCW United Food and Commercial Workers 

USW United Steelworkers of America 

VPP Voluntary Protection Program 

WISPR Worker Input to Site Profile Revision 

WOTL Worker Outreach Team Lead 

WOWG Worker Outreach Work Group 

WSP Weldon Spring Plant
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 7 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 

EXECUTIVE SUMMARY 

The Worker Outreach Program provides opportunities for current and former Department of 

Energy (DOE)/Atomic Weapons Employer (AWE) workers to obtain information and provide 

information relevant to site profiles, dose reconstruction, and the Special Exposure Cohort (SEC) 

program. SC&A has been tasked by the Worker Outreach Work Group (WOWG), and 

subsequently the Advisory Board on Radiation and Worker Health (Advisory Board), with 

conducting a review of Worker Outreach Program, OCAS-PR-012, Revision 0 (OCAS 2009a, 

hereafter referred to as PR-012). A previous SC&A review, conducted in 2007, evaluated 

Conduct of the Worker Outreach Program Procedure, ORAUT-PROC-0097, (ORAUT 2005a, 

hereafter referred to as PROC-0097). Findings and observations from the review of PROC-0097 

were presented to the Subcommittee on Procedures Review, but a resolution process was not 

completed. Findings from the PROC-0097 review that remain applicable to PR-012 are 

incorporated in this current review. 

SCOPE AND OBJECTIVES OF THIS REVIEW 

The scope of this review is as follows: 

(1) To evaluate the degree to which PR-012 provides direction to National Institute for 

Occupational Safety and Health (NIOSH) Office of Compensation and Analysis (OCAS) 

personnel and its contractors in a manner that helps to ensure that comprehensive 

technical information is acquired from a broad range of workers, site experts, petitioners, 

claimants, and other stakeholders 

(2) To evaluate the degree to which information obtained from the outreach program is 

documented in the Outreach Tracking System (OTS) as described in PR-012 

(3) To evaluate the procedural framework through which the technical information acquired 

under the outreach program is given appropriate consideration in OCAS work products, 

including site profiles and SEC petition evaluation reports 

This review is particularly interested in the degree to which PR-012 explicitly addresses the 

overall objectives of the Mission Statement and Objectives 1 through 4 of the draft 

Implementation Plan prepared by the WOWG.1

 The scope of this review does not include 

extensive evaluations of implementation; there are elements of each objective that could not be 

determined from reviewing PR-012 and the documentation available in the OTS. This report 

also does not include a review of recent site profiles or evaluation reports prepared by NIOSH to 

evaluate the degree to which NIOSH has, in fact, incorporated important information obtained 

from workers into their work products. SC&A will provide the work group with a separate 

proposed work plan to address these important aspects of the Implementation Plan. The primary 

focus of this review is to evaluate the process adopted and being implemented by NIOSH to 

1

 The Mission Statement and draft Implementation Plan for the Worker Outreach Work Group are 

provided in Attachment 7 to this report. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 8 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

gather worker input “for consideration and possible use in dose reconstructions, site profiles, and 

SEC petition evaluations.” 

REVIEW METHODOLOGY 

SC&A reviewed PR-012 (OCAS 2009a) in accordance with the generic approach outlined in 

SC&A’s review procedure, A Protocol for the Review of Procedures and Methods Employed by 

NIOSH for Dose Reconstruction (SC&A 2009). The review of PR-012 outlines the Worker 

Outreach Program and provides limited direction on implementation of this program. This 

procedure details the programmatic approach to worker outreach, and the policy of the agency in 

dealing with the public. This differs from a review of a technical procedure requiring a different 

approach to the procedure review from that detailed in SC&A 2009. During the February 2010 

meeting in Manhattan Beach, California, the WOWG implementation was presented to the 

Advisory Board. The objectives outlined in the implementation, and the purpose stated in PR012, serve as the basis for this review. The procedure checklist details the objectives and 

specific evaluation criteria. This varies from the standard procedure checklist, which specifically 

addresses dose reconstruction. Procedural compliance was evaluated to a limited extent where 

information was available from the OTS. 

Section 1 of this review provides an overview of the procedures used in the conduct of the 

Worker Outreach Program. Section 2 of this report outlines the status of findings from the 

review of ORAUT-PROC-0097 (ORAUT 2005a), which was replaced by PR-012 prior to 

comment resolution. 

 

Section 3 presents SC&A’s Findings and Observations. Section 4 presents a checklist of 

Implementation Plan objectives. The checklist has sections concerned with the following issues: 

 Determine whether OCAS is taking appropriate measures to solicit worker input into site 

profiles, SEC petition evaluations, and other technical documents 

 Determine whether OCAS is obtaining and documenting input from workers 

 Determine whether OCAS is giving thorough consideration to information received from 

workers through the worker outreach efforts, incorporating consideration of that material 

into its work products as appropriate, and adequately communicating the impact of 

substantive comments to workers 

In addition to reviewing PR-012, SC&A’s review of worker outreach was generally limited to 

worker outreach meetings that have occurred since the approval of PR-012. Of 118 meetings 

entered in the OTS at the time of review, 98 meetings pre-date the approval of PR-012, 

2 meetings were pending at the time of review, 9 meetings were invited forums sponsored by the 

U.S. Department of Labor (DOL), and 9 meetings were conducted by NIOSH from March 3, 

2009, through March 12, 2010. Additional invited forums were added to OTS during the week 

of March 15, 2010; however, this review did not consider these invited forums. SC&A 

representatives attended two worker outreach events; the Weldon Springs Plant Worker Outreach 

meeting on September 2, 2009, and the NIOSH Workshop on Dose Reconstruction and the 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 9 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Special Exposure Cohort on September 22–23, 2009. Review of the other seven NIOSH 

meetings was based primarily on documentation available in OTS. 

Documentation Reviewed: 

 Outreach Tracking System (OTS) content as of March 12, 2010 

 NIOSH/OCAS web site, Worker Outreach Activities by DOE/AWE site 

 Worker Outreach Program, OCAS-PR-012, Rev. 0, 3/04/09 (OCAS 2009a) 

 Classification of Worker Outreach Meetings (as defined at ABRWH Worker Outreach 

Work Group meeting, 6/16/2009) (OCAS 2009b)

 Types of NIOSH Meetings [Presented to the WOWG during the June 2009 meeting 

(OCAS 2009c)] 

 Review of ORAUT-PROC-0097, Conduct of the Worker Outreach Program Procedure, 

SCA-TR-TASK3-003, Addendum 1, Revision 1, November 2007 (SC&A 2007) 

 SC&A minutes of the Weldon Spring Worker Outreach meeting, September 2, 2009 

(Attachment 1) 

 SC&A Evaluation of the Weldon Spring Worker Outreach meeting (Attachment 1) 

 Workshop Evaluations from 24 participants at NIOSH Dose Reconstruction/SEC 

Workshop, September 22–23, 2009 (ATL 2009) 

 SC&A Evaluation of the NIOSH Dose Reconstruction Workshop, September 22–23, 

2009 (Attachment 2) 

The implementation of the Worker Outreach Program over time has not been subject to a 

comprehensive review by SC&A. The PROC-0097 review was limited, due to a lack of timely 

access to the Worker Input to Site Profile Revision (WISPR) database. The current review is 

limited to a single year (representing 18 of the 118 meetings recorded in OTS through March 12, 

2010). Some examples of concerns from meetings conducted prior to 2009 are included in this 

report for the purpose of evaluating the need for more thorough investigation of the program’s 

performance over time. SC&A will await direction from the Advisory Board as to the next steps, 

if any, to be taken in regard to the Worker Outreach Program. 

SUMMARY OF FINDINGS AND OBSERVATIONS 

SC&A’s detailed review of the PR-012 is presented in Section 3. The review produced 10 

Comments. SC&A divided these Comments into five Findings and five Observations, where the 

former represent deficiencies in the procedure that need to be corrected and which have the 

potential to impact the worker outreach program. Observations represent issues, which, if 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 10 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

addressed, would further improve the procedure, and may possibly reveal deficiencies that will 

need to be addressed in future revisions of the procedure. 

Table 1 summarizes the Comments, notes where in this document the full descriptions are found, 

and indicates whether each Comment is a Finding or an Observation. Our primary concern with 

this procedure is the lack of direction for evaluating and responding to worker comments, and 

incorporating substantive comments into technical work documents. Criteria for determining 

action items, and response to worker questions and comments, are based on subjective judgment 

with no procedural direction. Although an OTS exists, it does not track individual worker 

comments. A multi-track system exists for documentation and evaluation of worker comments. 

There is no accountability for validating the completeness and accuracy of meeting minutes with 

participants. 

This review found that PR-012 did not resolve a majority of the Findings raised in the review of 

its predecessor procedure, PROC-0097. In fact, PR-012 eliminated many of the positive 

elements of PROC-0097. For example, PR-012 makes accountability to workers less formal. 

Table 1: Summary of Issues 

Issue No. Summary Description 

Finding 1 The procedure does not provide direction for tracking, trending, evaluating, or responding to 

worker input. 

Finding 2 The procedure does not specify criteria for identifying Action Items or evaluating the 

adequacy and timeliness of response/resolution. 

Finding 3 The majority of expected documentation is not available in the OTS for meetings conducted 

within the effective period of PR-012. 

Finding 4 

The procedure fails to consider other venues of worker outreach. The multiple venues are not 

subjected to equivalent standards for documentation. Of particular concern is the two-track 

system for obtaining and documenting worker input that appears to give site expert interview 

records more weight than worker input obtained through outreach meetings. 

Finding 5 The procedure does not describe a process for assuring that worker feedback is accurately and 

completely documented. 

Observation 1 The procedure does not address the possibility that sensitive or classified information could be 

shared at a worker outreach meetings. 

Observation 2 

The procedure does not provide an opportunity for workers to discuss potentially classified 

information. Particularly at National Nuclear Security Administration (NNSA) sites, workers 

may be restricted from openly discussing site-specific information, due to security concerns. 

 Observation 3 There are no provisions for soliciting comments from workers who are unable to physically 

attend the meetings. 

 Observation 4 There is no requirement for disclosure of conflict of interest during worker outreach meetings. 

Observation 5 The Site Profile and Technical Basis Document Development, ORAUT-PROC-0031 (ORAUT 

2007a) procedure references PROC-0097, which has been replaced with PR-012. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 11 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

1 OVERVIEW OF PROCEDURE USED IN THE CONDUCT OF THE 

WORKER OUTREACH PROGRAM 

As a part of Task 3 authorization for procedures review during FY 2007, SC&A was charged 

with the review of ORAUT-PROC-0097, Conduct of the Worker Outreach Program (hereafter 

referred to as PROC-0097). A partial review was delivered to the Advisory Board on November 

27, 2007. The review was incomplete, due to a delay in getting access to the Worker Input to 

Site Profile Revision (WISPR) database, which was used at the time to track worker comments. 

There are outstanding findings associated with the review of this procedure that have not been 

resolved, and SC&A was not tasked with a follow-up review of the WISPR database when it did 

become available. On March 4, 2009, PROC-0097 was replaced with OCAS-PR-012, Worker 

Outreach Program (hereafter referred to as PR-012). Furthermore, WISPR was replaced with 

the Outreach Tracking System (OTS). In lieu of further evaluation of PROC-0097, SC&A was 

tasked with reviewing PR-012 to evaluate its effectiveness in accomplishing worker outreach 

objectives. This review considers the applicability of previous findings from the PROC-0097 

review to PR-012, as well as new findings and observations. An assessment of the 

documentation of the results of National Institute for Occupational Safety and Health (NIOSH) 

outreach is necessary, in order to assess the effectiveness of the procedure and its 

implementation. Because this key documentation is now compiled in the OTS database, a 

review of the OTS database is a critical component of this evaluation of PR-012. 

The change from an Oak Ridge Associated Universities Team (ORAUT) procedure (PROC0097) to a NIOSH Office of Compensation and Analysis (OCAS) procedure (PR-012) reflects a 

shift in responsibilities for worker outreach efforts. The NIOSH Worker Outreach Program was 

initially the responsibility of ORAUT. NIOSH now contracts directly with Advanced 

Technologies and Laboratories International, Inc. (ATL) to support its outreach activities. 

The two procedures are also influenced by changes in the scope of activities as the Energy 

Employees Occupational Illness Compensation Program Act (EEOICPA) has evolved. PROC0097 reflects a worker outreach program that was dominated by site profile development; the 

meetings conducted by NIOSH were designed to gather information for site profiles and to 

present the site profiles to affected populations. The current procedure reflects a different 

landscape, where the predominant activities relate to Special Exposure Cohort (SEC) petitions 

and site profile updates. It describes a variety of meeting types designed to gather worker input 

for site profiles and SEC evaluations, and to provide information about site profiles, dose 

reconstruction, and SEC petitions. 

During the June 16, 2009, Worker Outreach Work Group (WOWG) meeting, NIOSH provided 

the work group with Classification of Worker Outreach Meetings (OCAS 2009b) and Types of 

NIOSH Meetings (OCAS 2009c), which provided further details on the outreach venues. 

Outreach meetings were classified as information giving, information gathering, and information 

giving and gathering. An overview of each meeting type described its purpose, its audience, and 

the documentation likely to be produced. SC&A used these documents as supplements to PR012 in reviewing the meeting types and expected documentation. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 12 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NIOSH outreach meetings are flexibly structured; they are usually facilitated by a NIOSH 

member or by the Outreach Support Contractor (OSC). PR-012 describes four primary types of 

NIOSH Worker Outreach meetings, and outlines the responsibilities of various groups to plan 

and conduct the meetings. Although these meeting types are described in detail, structural 

flexibility is built into the procedure; “NIOSH can and will adjust the meeting format to meet the 

needs of the agency, the Board, and/or the public” (OCAS 2009a, pg. 4). In addition to the 

Worker Outreach meetings, NIOSH conducts dose reconstruction workshops and attends 

meetings sponsored by other groups, such as the U.S. Department of Energy (DOE) and the U.S. 

Department of Labor (DOL). 

The need for and timing of worker outreach efforts is guided by the following factors (OCAS 

2009a): 

 Substantive changes made to site profile 

 The need to identify and inform stakeholders of the SEC petition process or status 

 The need to gather additional information from stakeholders to address areas of interest 

for support of SEC evaluations and/or site profiles 

 Invitation from another agency for NIOSH participation 

 As otherwise deemed appropriate for an outreach effort 

As the OSC under PR-012, ATL identifies organizations (union, professional, retirement) 

affiliated with DOE or Atomic Weapons Employer (AWE) sites and works with these 

organizations to identify present and past workers interested in the outreach effort. They 

maintain ongoing communication with site representatives (labor, technical, and community 

leaders), support OCAS in developing meeting materials, coordinate and attend outreach 

meetings, serve as meeting leads and minute recorders, and maintain the outreach database in 

OTS. 

The meeting types most clearly oriented towards soliciting worker input are the Worker 

Outreach Focus Group meetings and the SEC Worker Outreach Focus Group meetings. 

Preparation activities for focus group meetings include identification of organizations affiliated 

with the DOE/AWE site, identification of potential participants, and notification/invitation of 

these individuals. Public notification is typically not required for a focus group, which targets a 

relatively small number of individuals whose experience is relevant to the issues of concern. The 

OCAS Health Physicist (HP), in collaboration with Site Profile Subject Matter Expert (SPSME) 

as needed, develops a presentation and questions for the focus group to discuss. The OSC team 

may assist with identifying potential participants; preparing and distributing meeting materials; 

arranging for an appropriate facility, supplies, and equipment; and uploading documentation into 

OTS. 

Worker Outreach Town Hall meetings are generally intended to provide information to workers, 

but may include opportunities to receive worker input, as well. Preparation activities for a 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 13 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Worker Outreach Town Hall meeting may require public notification and a larger venue, and the 

meeting materials are generally geared towards a large group presentation. The OCAS HP 

coordinates with the SPSME and/or OSC team, as needed, to determine areas of interest and 

develop the presentation materials. The presentation may provide a general overview of the dose 

reconstruction program, discuss what efforts have been initiated in the past to communicate and 

obtain feedback on the site profile, communicate changes that have been made to the site profile, 

and discuss the factors influencing the changes (e.g., document search, worker outreach 

feedback, oversight evaluation). As directed by the OCAS HP, the OSC Writer/Editor files the 

meeting materials into OTS and makes copies of the presentation and questions for distribution 

during the meeting. 

The purpose of an SEC Outreach Meeting is limited to discussion and informing individuals of 

the SEC process. These meetings are initiated by the SEC Petition Counselor and the NIOSH 

Ombudsman; the OSC Team may be asked to assist. Arrangements include venue selection, 

media notifications, development of meeting materials, and establishing points of contact (i.e., 

past/present DOE/AWE workers, unions, and professional organizations). The SEC Petition 

Counselor or the NIOSH Ombudsman typically notify and invite DOL for their information and 

support. Because these meetings focus on petition process education, meeting materials are 

relatively unchanged from meeting to meeting. Minor changes may include site-specific 

information or claim statistics. Meeting materials, handouts, and media notifications (if 

applicable) are filed in OTS. 

Minutes are “typically taken” at most types of worker outreach meetings, but are not required in 

all cases. They are generally not taken at SEC outreach meetings, where the focus is 

informational and NIOSH does not anticipate collection of worker input. When minutes are 

taken, their purpose is, “to assure pertinent information is captured for later use.” Recordings 

may be used, with appropriate notification and consent of participants. The recording is not 

available to the public under the Freedom of Information Act (FOIA) under the rationale that it is 

“not a deliverable product of the outreach contractor” (OCAS 2009a). Minutes are redacted of 

any Privacy Act-protected information prior to publication on the NIOSH/OCAS web site. 

Sign-in sheets are utilized for NIOSH outreach meetings, so that participants can be contacted, if 

needed, with follow-up information or questions. An example of the form is provided in 

Appendix C of PR-012. Sign-in sheets are protected by the Privacy Act and are not published on 

the NIOSH/OCAS web site. 

The NIOSH OTS is a database application accessible to NIOSH, the Advisory Board, ORAUT, 

and SC&A staff through the OCAS Staff tools. NIOSH defines the purpose of OTS as follows 

(OCAS 2009d): 

The OTS is designed to serve as a single repository for all available records 

related to Worker Outreach events, including a tracking function for site and 

meeting action items and their resolutions. 

The OTS allows authorized users to schedule worker outreach meetings and send out meeting 

notification e-mails to selected groups. Meeting information includes the meeting type; the time, 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 14 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

date, and location of the meeting; the sites covered by the meeting; the Point of Contact(s); the 

audience; and notes on the meeting. Following outreach meetings, the “Meeting Action Items” 

and “Meeting Files” are populated with applicable information. The “Meeting Action Items” 

section lists meeting-specific action items associated with the meeting. Information available on 

action items includes the action item description, owner entered date, commitment date, status, 

resolution description, and resolution date. The Meeting Files section of the OTS includes 

Portable Document Format (PDF) files of documentation associated with the outreach meeting, 

such as notifications, presentations, sign-in sheets, meeting minutes (draft and final), review 

requests, follow-up correspondence, or other documentation pertinent to the meeting. 

Action items arising from worker outreach meetings are identified by the OCAS HP or the SEC 

Counselor, who may input the details into OTS or coordinate with the Writer/Editor for 

uploading. As feedback is received on the status of an action item, the “Action Item Current 

Status” field is updated by the meeting owner. Upon closure of the action item, the “Action Item 

Resolution Detail” is completed by the meeting owner.
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 15 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

2 STATUS OF ORAUT-PROC-0097 FINDINGS/OBSERVATIONS 

This section lists the major findings identified in SC&A’s review of PROC-0097 (SC&A 2007) 

and describes their current status under PR-012. Each finding is identified with its page number 

from the report text and with related item number(s) in the Procedure Review Outline/Checklist 

(Table 1). 

PROC-0097 Finding 1: The procedure is deficient, because it does not require the audiotapes 

of the outreach meeting to be archived. In addition, the audiotapes are destroyed after the 

minutes of the outreach meeting are finalized. [Checklist items 1.4 and 7.3] 

Status: The substance of this finding has not been resolved in PR-012. Refer to Finding 5 of 

this review of PR-012. 

PROC-0097 Finding 2: The procedure does not address follow-up discussions with particular 

workers and how these are documented. [Checklist item 1.5, 3.1.2] 

Status: This finding has not been resolved. Refer to Finding 1 of this review of PR-012. 

PROC-0097 Finding 3: There are no provisions for soliciting comments from workers who are 

not able to physically attend meetings. [Checklist item 3.1.4] 

Status: This finding has not been resolved. Refer to Observation 3 of this review of PR-012. 

PROC-0097 Finding 4: The procedure seems to focus on outreach meetings with labor 

organizations, though the purpose of the meetings is to obtain worker input and inform all 

workers. [Checklist items 1.3, 3.1.3, 3.1.4] 

Status: The following changes have been made in PR-012 to expand the breadth of worker 

outreach: 

 PR-012 indicates that the OSC works with organizations other than unions (e.g., 

professional and retirement organizations) in its efforts to identify present and past 

workers interested in outreach activities. 

 Worker outreach has expanded to include a process for SEC petition input. 

 The Worker Outreach Program added opportunities for workers, advocates, and 

petitioners to obtain information about the dose reconstruction and SEC processes 

through workshops, SEC Worker Outreach meetings, invitation from organizations, and 

Town Hall meetings. 

 Worker outreach for the EEOICPA program has been more integrated, with NIOSH 

participating in outreach activities sponsored by other agencies, such as DOE and DOL. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 16 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

 Although not specifically described in the procedure, the following changes also increase 

interaction between NIOSH and workers: 

o An Ombudsman office was established to encourage workers to provide feedback on 

the process. The NIOSH Ombudsman closely communicates with the DOL 

Ombudsman Office to provide better overall support in the claims process. 

o A position of “SEC Counselor” was created to provide workers with information on 

the SEC petition process, and to assist petitioners with filing SEC petitions. SEC 

petitioners may also continue to request assistance through the SEC process. 

PROC-0097 Finding 5: A two-track system appears to exist for obtaining employee and site 

expert input. One track is formal, governed by ORAUT-PROC-0097, with documentation 

requirements, while the other track is informal and appears to be intended as a means to obtain 

information from site experts. [Checklist items 1.5, 7.4] 

Status: This finding has not been resolved. Refer to Finding 4 of this review of PR-012. 

For convenience, Attachment 6, “ORAUT-PROC-0097 Finding Disposition Recommendations,” 

presents the findings as they occur in the procedure tracking database. SC&A recommendations 

for disposition of PROC-0097 comments are provided for each of the nine findings identified.
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 17 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

3 SC&A EVALUATION OF OCAS-PR-012 

Finding 1: The procedure does not provide direction for tracking, trending, evaluating, or 

responding to worker input.

PR-012 does not provide clear direction regarding the disposition of worker input. PROC-0097 

described how comments were (1) captured and logged into WISPR, (2) evaluated to determine 

if a response was required, and (3) directed to the appropriate Site Profile Technical Lead 

(SPTL) for consideration. PROC-0097 specified a timeframe for responding to the workers and 

defined criteria for determining the adequacy of the response. None of these processes are 

addressed in PR-012. The current procedure does not discuss how comments provided by the 

workers will be evaluated to determine their potential impact on site profiles, dose 

reconstruction, and/or SEC evaluations, and how these comments will be resolved. The 

intentional responsiveness to worker input that characterized PROC-0097 receives passing 

mention in PR-012. Those practices that are retained (e.g., taking minutes) are not decisively 

required. 

Capturing worker input appears to be optional in PR-012, and no processes are described for 

tracking and utilizing the input received. The procedure states, “minutes are typically taken” for 

certain meeting types. It does not explicitly state that minutes are required for any particular 

type of meeting, and it does not indicate how worker input is captured at a meeting that is 

primarily intended for information giving (e.g., Town Hall, SEC worker outreach, workshops). 

PR-012 does not describe how NIOSH ensures that worker input useful for technical document 

preparation is captured at a venue in which such input is not anticipated. For meetings in which 

minutes are taken, the procedure instructs personnel to upload final meeting minutes to OTS. No 

other database or tracking system is identified for tracking comment resolution or trending 

recurrent issues. Although the procedure indicates that minutes are taken “to assure pertinent 

information is captured for later use,” no further explanation is provided in regard to extracting 

substantive comments for consideration in technical documents and/or dose reconstructions. 

In addition, PR-012 is a stand-alone procedure; it is not integrated or referenced in existing 

procedures for site profile development or SEC evaluations. PROC-0097 referenced the Worker 

Outreach Program Plan, ORAUT-PLAN-0010 (ORAUT 2004) and Site Profile and Technical 

Basis Document Development, ORAUT-PROC-0031 (ORAUT 2007a). Integration of these 

documents provided the procedural framework for considering worker comments in the 

development and revision of site profiles and technical basis documents (TBDs). In the current 

program, there is no plan or policy analogous to ORAUT-PLAN-0010. ORAUT-PROC-0031 

still references PROC-0097, rather than PR-012, in describing consideration of information 

derived from worker outreach. The reference error is not a simple matter of updating the 

document number and title, because PROC-0031 describes a functional interface that does not 

exist in PR-012 [between the Site Profile/TBD Document Owner and the Worker Outreach Team 

Lead (WOTL)]. The current procedure for the SEC program, Special Exposure Cohort (SEC), 

ORAUT-PROC-0044 (ORAUT 2005b), does not address the use of information obtained 

through worker outreach. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 18 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

During the review of PROC-0097, SC&A submitted questions to participants who attended 

worker outreach meetings. The questions and responses are available in Attachments 1 and 2 of 

the SC&A review (SC&A 2007). At this time, responses to questions indicate that many 

workers found the information portion of the meeting helpful. The workers, however, often felt 

that many of the comments provided in meetings were disregarded or misrepresented. Feedback 

from workers indicates that comments were not effectively resolved. For example, one worker 

provided the following impression of a worker outreach meeting (SC&A 2007). 

While attending the meeting in Cincinnati, Ohio, my recollection of the meetings 

were: they were designed to informationalize the workers that attended. Not a 

bad meeting in that respect. But, Larry Elliott tried his best to convince us that he 

was all for the workers while simultaneously ignoring what we were telling him 

about our exposures. I would say that everyone had time to speak, but as I said 

most of the information that was presented from the workers was ignored. 

Similar comments have been communicated to SC&A during site expert interviews conducted at 

various facilities. Substantive worker outreach comments, in some cases, have not been 

considered in critical decision-making processes, including SEC petition qualifications. For 

example, during Savannah River Site (SRS) SEC petition interviews, petitioners have indicated 

to SC&A that worker outreach comments from the May 22, 2008, worker outreach meeting in 

North Augusta, Georgia, were not considered during the request for administrative review of the 

SRS petition qualification. The original petition was submitted for all SRS workers, including 

production and construction trade workers (CTWs). The petition class was redefined to include 

only the CTWs. The review panel presented their findings to John Howard (HHS) on June 25, 

2008. The May 22, 2008, meeting minutes were not finalized at this time. The letter provided to 

the petitioner from Health and Human Services (HHS) indicated the panel reviewed the materials 

in the petition and the request for review. The final determination was, “...the petitioner did not 

provide sufficient information to extend the class beyond SRS employees classified as 

construction workers” (Howard 2008). The petitioners submitted a second request for review, 

citing that the panel had not considered the minutes from the May 2008 worker outreach 

meeting. Furthermore, the petitioners requested and received all materials considered by the 

panel, minus four pages of pre-decisional internal communications. This material did not 

include the meeting minutes from the May 2008 meeting. Information provided at this and other 

SRS worker outreach meetings discussed the interactions between SRS CTWs and production 

workers, and raised potential SEC issues applicable to both classes of workers. 

Individuals who offer public comments at Board meetings, as well as site experts interviewed by 

SC&A during technical document reviews, frequently express concern that worker comments are 

ignored. Many of these individuals describe specific examples of statements and documentation 

provided to NIOSH that have never received a response or resulted in changes to technical 

documents. Some advocates have stated that it is difficult to get participation at outreach 

meetings because of workers’ perception that their testimony is discounted (ABRWH 2008). 

This perception is only exacerbated by a worker outreach procedure that fails to establish an 

accountability process for dealing with the input received. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 19 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

This finding is the single greatest concern noted by SC&A in its review of PR-012. The 

opportunity for workers “to provide information for consideration and possible use in dose 

reconstructions, site profiles, and SEC petition evaluations” is identified as a primary objective 

of the Worker Outreach Program, but this procedure offers no mechanism for considering or 

using the comments provided by worker outreach participants. The absence of direction for 

effective documentation, evaluation, and response to worker comments indicates a failure of the 

procedure to fulfill a significant aspect of its intended purpose. The structure of this procedure 

minimizes the effectiveness of worker comments and their subsequent consideration in dose 

reconstructions, site profiles, SEC petition evaluations, and other technical work documents. 

Finding 2: The procedure does not specify criteria for identifying Action Items or for 

evaluating the adequacy and timeliness of response/resolution.

PROC-0097 described criteria for determining which worker comments required a response. It 

provided guidance on distribution of such comments to appropriate task personnel, specified that 

the Task Manager and/or Site Profile Team Lead (SPTL) must reply within 30 days, and 

provided criteria for the Worker Outreach Team Leader (WOTL) to evaluate each response. An 

acceptable response would address the comment, contain technically correct information, and 

either specify anticipated changes to the site profile (with a tentative schedule for completion) 

OR explain the reason for not revising the site profile. These activities were documented in the 

WISPR data base. 

In contrast, PR-012, Appendix D, “OTS Overview,” states that action items are identified by the 

OCAS Health Physics (HP) or SEC Counselor (OCAS 2009a, pg. 24). Action items are 

uploaded to OTS and updated as feedback is received. The procedure does not provide guidance 

to the meeting owners to determine what constitutes an action item, it does not indicate an 

appropriate timeframe for addressing or resolving the action item, and it does not specify a 

mechanism for evaluating the appropriateness of response. It also does not specify that a reason 

should be provided for rejecting a substantive comment. 

Whereas predecessor databases to OTS provided a repository for input by current and former 

employees of DOE and AWE facilities, OTS has does not provide a mechanism for the 

identification of substantive worker comments. PR-012 describes a separate documentation and 

tracking process for action items, rather than for all substantive worker comments. The 

appropriate determination of action items, therefore, becomes a critical part of being responsive 

to worker comments, and providing appropriate consideration of those comments in the dose 

reconstruction and SEC processes. The procedure leaves the determination of action items from 

a meeting open to the OCAS HP (who may not be present at the meeting), the SEC Counselor, or 

the Site Profile or SEC subject matter expert. While SC&A would agree that a substantial 

degree of technical judgment is required in considering and incorporating input from workers, as 

it is from historical documentation, the lack of specific criteria to guide the technical individuals 

in identifying action items is a significant concern, particularly in the context of other issues, 

such as the lack of a process to verify the accuracy of documentation of worker comments. Lack 

of specific criteria may lead to inconsistent determination of action items. Furthermore, in 

discarding the definitive requirements of PROC-0097, PR-012 appears to reduce NIOSH’s 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 20 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

accountability for identifying and resolving workers’ concerns. This has the potential for 

increasing workers’ perception that their comments are not being considered. 

Finding 3: The majority of expected documentation is not available in the Outreach 

Tracking System (OTS) for meetings conducted within the effective period of PR-012. 

As of March 12, 2010, OTS contained 118 meetings; 116 of those meetings were completed and 

2 meetings were scheduled for future dates. Completed meetings recorded in OTS dated from 

November 11, 2003, through December 8, 2009. Of the 116 closed meetings, 53 were held prior 

to implementation of PROC-0097, 45 were held during the effective period of PROC-0097, and 

18 were held after the approval of PR-012. Table 2 summarizes the numbers and types of 

meetings conducted by NIOSH within the effective period of PR-012. Attachment 3 lists all the 

worker outreach meetings scheduled, conducted, or attended under PR-012. 

Table 2: Summary of Meeting Types Occurring under PR-012. 

Information Giving Information Gathering 

Worker Outreach 

Town Hall SEC Outreach Workshop Invited Forum Worker Outreach Focus Group 

SEC 

Focus Group 

4 2 2 9 (DOL) 0 1 

SC&A representatives attended two worker outreach events; the Weldon Spring Plant (WSP) 

Worker Outreach meeting on September 2, 2009, and the NIOSH Workshop on Dose 

Reconstruction and the SEC on September 22–23, 2009. SC&A meeting minutes and an SC&A 

evaluation for the September 2, 2009, WSP meeting are provided in Attachment 1. SC&A notes 

collected during the observation of the workshop are available in Attachment 2. Review of the 

remaining outreach meetings conducted under PR-012 was based primarily on documentation 

available in OTS. 

As an indicator of procedure implementation, the reviewers sought to evaluate the completeness 

of documentation in OTS. Although PR-012 does not explicitly require minutes and other 

documents for specific meeting types, it does indicate that minutes are typically taken for worker 

outreach meetings, and it states that the documents produced for worker outreach meetings are 

uploaded to OTS. PR-012, supplemented by Classification of Worker Outreach Meetings

(OCAS 2009b), and Types of NIOSH Meetings (OCAS 2009c), provides a description of each 

primary meeting type, its purpose, its audience, and the documentation likely to be produced. 

SC&A referred to these documents to determine what documents would be expected to be 

produced and uploaded to OTS for each of the four primary meeting types described in PR-012. 

Table 3 summarizes the purpose, features, and expected documentation described by NIOSH for 

the primary worker outreach meetings. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 21 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Table 3: Primary Worker Outreach Meetings Described in PR-012. 

Worker Outreach Meetings 

Meeting Type Purpose & Features Expected Documents* 

Worker Outreach 

Focus Group 

“Site Profile / TBD 

Development” in OCAS 2009b 

 Information gathering 

 Small group of workers from specific site 

or operation 

 Discuss specific issue, process, questions, 

or site profile document 

 Letters of notification, 

possibly with questions 

 Sign-in sheet 

 Presentation materials 

 Action items 

 Minutes/summary 

SEC Worker Outreach 

Focus Group 

“SEC Evaluation Report Issues” 

in OCAS 2009b 

 Information gathering 

 Small group of workers 

 Discuss specific issues identified by 

OCAS/contractor during SEC Evaluation 

process 

 Letters of notification, 

possibly with questions 

 Sign-in sheets 

 Presentation materials 

 Action items 

 Minutes/summary 

Worker Outreach 

Town Hall Meeting 

“Town Hall” in OCAS 2009b 

 Information giving 

 General public meeting targeting affected 

and potential claimant population 

 Discuss program/policy issues, announce 

site profile revision, etc. 

 Comments/new information may be 

obtained 

 Media announcements 

 Sign-in sheets 

 Presentation materials 

 Action items, if applicable 

 Minutes 

SEC Outreach Meeting 

“SEC Petitioning Process 

Education” in OCAS 2009b 

 Information giving 

 Limited to SEC petition process 

 Current/former workers, claimants, 

potential claimants, and other interested 

parties 

 Media announcements 

 Letter notifications 

 Sign-in sheets 

 Presentation materials 

*As described in OCAS-PR-012 (OCAS 2009a) and/or the document titled Classification of Worker Outreach 

Meetings (OCAS 2009b). 

Attachment 4 itemizes the document files that were available in OTS on March 12, 2010, for the 

18 meetings that had been completed during the effective period of PR-012. Table 4 provides a 

summary of the presence or absence of expected documents. Some documents are not expected 

for certain types of meetings. Values in the table cells represent the number of meetings for 

which the specified document file was either present, expected but not present, or not expected. 

Table 4: Summary of OTS Documentation 

Document Status in OTS Notification of 

Meeting Sign-in Sheet Presentation File Final Meeting 

Minutes

Present in OTS 1 1 1 0* 

Expected, But Not Present 7 7 7 4 

Not Expected 10 10 10 13 

*A NIOSH representative’s personal meeting notes were available for one meeting in lieu of minutes. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 22 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Attachment 5 lists all of the action items currently contained in the OTS and the current status of 

each item. Although the action items are numbered up to 11, there are no action items numbered 

1, 2, 4, 5, or 6 in the OTS. SC&A was not able to determine if these item numbers were not 

assigned or if these numbers represent action items that are missing from OTS. For the 18 

meetings conducted between March 3, 2009, and March 12, 2010, there are two action items in 

OTS [Action Items #3 (Mound) and #11 (WSP)]. A response is provided for Action Item #11, 

and the item has been closed. The OTS indicates that Action Item #3 is open and past due. The 

lack of formal meeting minutes prevents SC&A from determining whether additional action 

items resulted from the meeting. During the observation of the September 22–23, 2009, 

workshop, SC&A identified two action items that are not currently included in the OTS. They 

are noted in Attachment 2. This illustrates that meetings designated as “information giving” can 

also result in action items. 

The remaining four action items in OTS are designated as legacy action items. These action 

items were from worker outreach meetings at Chapman Valve (February 14, 2005), Fernald 

(June 28, 2004), and Hanford (April 22, 2004). While a complete review of historical worker 

outreach events is outside the scope of this PR-012 review, several generic observations can be 

made regarding the completeness of action items in the OTS. 

(1) A brief review of the TopHats database indicates that NIOSH at one time documented 

substantive comments for Los Alamos National Laboratory (LANL), Linde, Pinellas 

Plant, Fernald, Oak Ridge National Laboratory (ORNL), Mound Laboratory, the Y-12 

Plant, the Rocky Flats Plant (RFP), and the SRS as of November 2005. Input available in 

TopHats for Fernald included comments on inadequate contamination controls, lack of or 

inadequacy in records, inadequate worker protection and monitoring, and specific 

exposure scenarios and incidents. The OTS action items for Fernald are limited to radon 

exposure. 

 

(2) A brief review of the WISPR report on staff tools indicates that additional comments are 

available for sites without action items in the OTS. 

(3) SC&A has attended meetings where actions were taken by NIOSH that are not reflected 

in the OTS. For example, during the April 22, 2008, meeting with the Security Police 

and Fire Professionals of American (SPFPA) Local 66 in Piketon, Ohio, the meeting 

minutes indicate that NIOSH accepted seven action items. No action items from this 

meeting are identified in the OTS. 

The six action items listed in the OTS do not represent the depth and breath of concerns raised by 

meeting participants for the 116 completed worker outreach meetings. 

The scarcity of documentation in OTS for meetings starting with the implementation of PR-012 

is indicative of the inadequacy of the procedure and/or its implementation regarding 

documentation of worker comments in OTS and generation of action items. Final meeting 

minutes are unavailable for four out of five meetings in which minutes would be expected. The 

meeting record for the fifth meeting is limited to two pages of notes for an information gathering 

meeting that lasted several hours. Given the scarcity of action items documented in OTS, it is 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 23 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

understandable that workers perceive that their input is often ignored or dismissed. There should 

be a more formalized process for identifying and resolving action items, and communicating 

resolutions of these action items to participants. 

Finding 4: The procedure fails to define processes or requirements for several venues of 

worker outreach. The multiple venues are not subject to equivalent standards for 

documentation. Of particular concern is the two-track system for obtaining and 

documenting worker input that appears to give site expert interview records more weight 

than worker input obtained through outreach meetings. 

Other Venues Identified by NIOSH 

PR-012 does not provide adequate information or establish documentation requirements for 

activities that NIOSH identifies as worker outreach (i.e., workshops, Board meetings, the 

website/docket, and invited forums). The information provided by NIOSH at the Board meeting 

includes a list of Other Outreach Venues—Work Shops, Board Meetings, Invited Forums, and 

the Website/Docket. All four venues are classified by NIOSH as information giving and 

gathering. Table 5 provides a brief description of each venue and documents associated with 

these activities. 

Table 5: Other Outreach Venues Identified by NIOSH 

Venue Description Associated Documents 

Workshops These meetings are held to educate the 

public about the dose reconstruction and 

SEC processes. Work shops involve 

formal presentations, classroom exercises, 

and open discussions with participants. 

 Presentations 

 Handout materials 

 Sign-in sheets 

Invited Forums (includes 

organized labor and 

worker/advocate forums) 

NIOSH role is typically to represent the 

agency and answer questions related to 

dose reconstruction. 

None listed in PR-012 

or in OCAS 2009b 

Other Outreach Venues (described in OCAS 2009b, but not in PR-012) 

Board Meetings The Advisory Board meets about every 3–

4 months to review program and science 

updates, SEC petition evaluations, and 

other matters of interest to the EEOICPA. 

The Board receives worker comments in 

the context of petitioner statements, public 

comment sessions, and at other times as 

authorized by the Chair. 

 Presentations 

 Public comments 

 Interactions 

 Public Health Advisor (PHA) 

interviews
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 24 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Venue Description 

Table 5: Other Outreach Venues Identified by NIOSH 

Associated Documents 

Website/Docket A “Docket” is a formal record of a federal 

government agency’s regulation 

development process. It includes copies 

of all public comments received by the 

agency in developing the regulation, 

copies of all references cited in the 

regulation, and other relevant information. 

The Docket is open to the public, which 

can view and obtain copies of any of its 

contents. According to OCAS 2009b, the 

NIOSH/OCAS Website/Docket provides 

for public display and tracking of 

documents related to EEOICPA. 

 Documentation of input/ 

comments on program 

documents 

 Public documents related to 

EEOICPA

*As described in OCAS-PR-012 (OCAS 2009a) and/or the document titled Classification of Worker Outreach 

Meetings (OCAS 2009b).

Each of these venues affords an opportunity for workers, advocates, and site experts to provide 

substantive comments for consideration in the dose reconstruction and SEC processes. There is 

no formalized process discussed in PR-012 for documenting, tracking, evaluating, and 

responding to comments provided from these venues. Little or no treatment is given to these 

venues in PR-012, although they appear to be important means of obtaining valuable input. At 

the present time, the responsibility for tracking of public comments has been given to the 

Designated Federal Official (DFO) and his staff, and the NIOSH OCAS role in this process is 

unclear to SC&A. PR-012 should include a discussion of these worker outreach venues. The 

procedure should specify what documents are required (or optional) in OTS, and describe how 

the comments provided by workers are made available for consideration in dose reconstructions, 

site profiles, and SEC petition evaluations. 

Other NIOSH Outreach Activities

Several activities conducted by NIOSH can provide substantive worker input consistent with the 

objectives of the Worker Outreach Program, but NIOSH does not acknowledge them as worker 

outreach activities. These unrecognized venues include, but are not limited to, Computer 

Assisted Telephone Interviews (CATIs), Close-out Interviews (COIs), general information 

provided by workers via e-mail or letters to NIOSH staff members, and site expert interviews. 

The CATI and COI processes are proceduralized, but the procedures do not provide a 

mechanism by which general site-specific information (as opposed to personal claimant-specific 

information) may be captured for consideration in technical work products. Some aspects of 

correspondence control are formalized in procedures, but they do not specify criteria for 

determining when NIOSH is required to respond to input that it receives via e-mail or letter. 

Because there is no single repository for worker comments gathered from multiple venues, it 

would be difficult for personnel involved in dose reconstructions, SEC evaluation reports, or site 

profiles to locate and utilize the information provided by the workers. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 25 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Two-Track System for Site Experts and Other Workers 

Of particular concern is an issue that was raised in the SC&A review of PROC-0097. SC&A 

noted what appeared to be a two-track system for gathering input from former and current 

workers. One track, a formalized process, solicited employee comments on the site profile 

through “worker outreach” meetings. A second track, which appears to be informal and at the 

discretion of the preparers of technical documents, solicited comments from site experts. Site 

expert interviews are a significant source of worker input for technical documents, but NIOSH 

has not established a formal process for selecting site experts, conducting interviews, assuring 

that the interviewees’ statements have been accurately expressed, or evaluating the information 

for use in technical work documents. Specifically, this form of worker input is not addressed in 

PR-012. 

PR-012 has implemented Worker Outreach Focus Group meetings, which allow NIOSH and 

ORAUT to solicit comments from HP personnel or employees with experience in specific job 

categories, depending on the need of site profile or SEC petition reviews. The Worker Outreach 

Focus Group described in PR-012 is typically a “small group of current and/or former workers 

from a specific facility or at a process-level operation within a facility.” The group of 10–12 

individuals provides feedback on a specific issue and/or set of questions, and/or the site profile 

document. An SEC Worker Outreach Focus Group meeting has a similar format, though it 

might involve more participants. These meetings are initiated by NIOSH when information is 

needed to complete an SEC petition evaluation report that is not available from other sources 

already obtained by NIOSH. 

In contrast to meetings for worker input organized under PR-012, site expert interviews are 

conducted by an informal process. ORAUT-PROC-0031 states that interviews are conducted 

with retirees or other long-term site personnel to obtain information about work performed on the 

site and the radiation protection program in place during the period of operation. These 

interviews are documented on ORAUT-FORM-0025, Documented Communication (ORAUT 

2007b). No equivalent instruction was located in ORAUT-PROC-0044 for the SEC Petition 

evaluation process. Documented Communication records are accessible in the Site Research 

Data Base (SRDB). 

A cursory review of Documented Communication records in the SRDB indicates that site expert 

interviews are commonly conducted one-on-one or in groups that are generally much smaller 

than the worker outreach meetings described in PR-012. In SC&A’s experience, it is very 

difficult for all attendees to provide detailed input in meetings larger than four people. A group 

of one to three persons works best for interviews in which very detailed information is expected. 

As compared to the methods described in PR-012 for worker outreach meetings, the approach 

used for gathering input from site experts is much more conducive to obtaining all the relevant 

information that a worker might have to provide. SC&A recognizes the value of conducting 

larger meetings at which worker input is obtained, since that increases the breadth of input with 

more modest resource commitments. In order to provide an equivalent opportunity for “worker 

outreach” comments to be explored and validated, PR-012 should describe a mechanism and 

criteria for determining when further follow-up with specific workers is indicated. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 26 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 

In addition to the advantage of one-on-one or small group interaction, site expert interviews 

appear to be initiated or carried out by personnel who are directly involved in producing 

technical documents. This increases the probability that the comments recorded in the interview 

notes will be taken into account. However, since there is no procedure for ensuring the accuracy 

of documentation of the interviews, SC&A has no way of verifying that all relevant points are 

actually included in the interview record. Furthermore, SC&A cannot verify whether document 

preparers send interview records to interviewees for verification and correction. This point was 

discussed at considerable length in the context of the resolution of SC&A’s comments in regard 

to the Nevada Test Site (NTS). A particular site expert provided extensive technical information 

to SC&A during an interview. Although NIOSH conducted several hours of interviews with this 

individual, only a very brief mention with a single relatively straightforward issue was 

incorporated into the interview record.2

NIOSH places significant weight on site expert interview records, to the point that some site 

expert interviews form the only basis for assumptions made in technical work documents. As 

such, an equivalent level of rigor should be applied to the documentation of information 

provided by site expert interviews as that for Worker Outreach Focus Groups and other 

information gathering venues. A review by the site expert, and subsequent sign-off, should be 

required for site expert interviews, particularly those used as a basis for assumptions in technical 

work documents. Substantiation of all worker comments should be conducted, regardless of the 

source of comments, including those provided by NIOSH site experts. 

Through the processes of worker outreach and site expert interviews, different perspectives on 

the same issue are apt to arise, including direct contradictions. For instance, SC&A interviewed 

two individuals for the Sandia National Laboratory - Livermore (SNLL) site profile review; a 

manager/engineer and an HP. When asked whether tritide operations were conducted at SNLL, 

the manager indicated the tritide work was done at Mound and SRS. An HP, who was directly 

involved in site operations, indicated that SNLL did conduct work with tritides. SNLL 

documentation supported the position of the HP. In order to evaluate multiple perspectives in 

developing technical documents, it is important to utilize consistent and effective processes to 

solicit, document, and substantiate worker input, regardless of the source of the comments. 

In summary, the concerns raised during SC&A’s review of PROC-0097 regarding inconsistent 

processes and unequal weighting of worker input have not been resolved, and PR-012 has 

intensified some concerns: 

 A two-track system tends to give less weight to the information provided by workers at 

outreach meetings than at site expert interviews. The latter appear to be conducted in 

small groups by personnel who are preparing technical documents. There is no assurance 

under PR-012 that the technical personnel preparing documents are aware of technical 

inputs provided at worker outreach meetings. 

2

 SC&A’s interview with this site expert is part of its NTS Profile Review (SC&A 2005). The 

NIOSH/ORAUT record of the interview with the same person is documented in Griffith 2004. Discussion of this 

issue occurred at various Work Group meetings. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 27 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 There is no systematic method described for documenting and resolving differences in 

important technical input that may arise from different settings in which different classes 

of workers are typically represented (outreach meetings and site expert meetings). 

 No process is described (for worker outreach minutes or site expert interview records) for 

verifying the accuracy and completeness of the official records, or for assuring that the 

information is considered for inclusion in technical documents. 

As noted, SC&A recognizes the importance of both small meetings (one to four people) and 

larger meetings for obtaining technical input from workers. However, there must be criteria for 

deciding when a broad meeting with many workers is to be held and when input is sought via 

one-on-one or in very small group settings. Both types also require a process for ensuring 

completeness and accuracy of the documented information and for ensuring appropriate 

consideration for inclusion in technical documents. 

Finding 5: The procedure does not describe a process for assuring that worker feedback is 

accurately and completely documented. 

PROC-0097 described a process for forwarding final draft meeting minutes to host 

organization(s) for review and comment. Following a 60-day review period, comments were to 

be evaluated and incorporated, as necessary. The minutes were to be finalized after 60 days, and 

the audiotapes would be destroyed, whether or not responses were received. In its review of 

PROC-0097, SC&A expressed concern that this procedure limited NIOSH’s ability to resolve 

concerns about potential misrepresentation of information provided. This deficiency is amplified 

in regard to PR-012; the current procedure does not indicate that participants’ input should be 

sought in regard to the accuracy of meeting minutes. In addition, the current procedure still 

indicates that audiotapes are destroyed after the minutes have been finalized. There are no 

requirements to archive these recordings, or to inform participants that recordings are not made 

available to them. PR-012 states (OCAS 2009a, pg. 4): 

Prior to the start of the meeting in which a recording may be used, the meeting 

facilitator will make an announcement stating that the meeting will be recorded 

and the recording is a tool for accurate preparation of the meeting minutes. (The 

recording is not a deliverable product of the outreach contractor and thus is not 

available to the public under FOIA.) 

Furthermore, on page 15, the procedure states the following: 

The OSC Team facilitator will generally facilitate the meeting and the OCAS HP 

and the SPSME will conduct the presentation and discussion. At the beginning of 

a meeting, when the meeting is to be electronically taped, the OCS Team 

Facilitator will make an announcement similar to the following: 

This meeting is being recorded. The purpose of the recording is to help prepare 

accurate meeting minutes. Thus, the recording is a tool and will be destroyed 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 28 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

once the minutes of this meeting have been finalized. Does anyone object to the 

use of the recording?” 

Note: If there are no objections, the meeting will be recorded. 

If there are objections, the OSC facilitator will resolve the issue. 

Possible Scenarios

If an individual(s) object to the recording, the individual (s) may leave and may 

give written comments through the NOCTS web application or letter, or may be 

given the opportunity to voice their comments after the meeting provided there is 

sufficient time or by phone at a later date. 

If there is an objection by majority, the meeting will not be recorded and written 

notes will be used to best capture the essence of the meeting discussions. 

If someone requests a copy of the recording, the OSC Team facilitator and/or 

OCAS staff representative will explain that copies are not available for public 

distribution. 

During an invited meeting with the SPFPA Local 66 in Piketon, Ohio on April 22, 2008, 

participants were prepared to audiotape the meeting for their own records. They were told at the 

time that a copy of the NIOSH recording would be provided to them (SC&A 2008), so they did 

not record it. Later, SPFPA was told the recording would not be provided to them, and were 

understandability upset that the NIOSH position had been reversed. This exemplifies why it is 

important to disclose up front as a part of the introductory remarks that copies of the audiotape 

are not available for public distribution. It is recommended that the procedure reflect inclusion 

of such a statement. 

PR-012 contains no requirements for providing meeting minutes to participants for review or for 

subsequent integration of comments received by workers. Furthermore, as noted above, the 

destruction of the audiotapes prevents any resolution of complaints that information provided 

was omitted or misrepresented. There is no required time period for the finalization of meeting 

minutes; this can result in long time periods for which draft meeting minutes are unavailable to 

the public. A reasonable time limit for finalizing meeting minutes and posting them to the 

NIOSH website should be incorporated into PR-012. If the practice of destroying audiotapes is 

continued, it is recommended that a process for verifying the accuracy of comments be 

completed in every case before the audiotape is destroyed. SC&A also recommends that the 

invitation letter should include a disclosure that tapes made by NIOSH and its contractor will be 

destroyed, so that participants can bring their own equipment, should they desire to record the 

proceedings. 

Without the final meeting minutes and audiotapes from the meetings conducted under PR-012, 

SC&A was unable to determine whether participant comments were adequately captured during 

applicable worker outreach meetings. While meeting notes were captured by SC&A at the WSP 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 29 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

outreach meeting (September 2, 2009), the official final meeting minutes are not available for 

comparison. 

The Mound Worker Outreach SEC Focus Group meeting on April 28, 2009, raises doubts about 

the completeness of the notes captured during the meeting. As previously mentioned, two pages 

of meeting notes were compiled in lieu of formal meeting minutes. The purpose of the meeting 

was to lay out NIOSH’s approach to determining neutron dose, and to solicit any comments or 

insights from invited workers (ABRWH 2009, pg. 8–10). A presentation was given to the 

participants, followed by a discussion of the proposed model. The outreach meeting lasted 

several hours, which has historically resulted in lengthy meeting minutes. 

At the present time, the procedure does not clearly indicate that worker input from “information 

giving” or combined “information giving and information gathering” meetings will be captured 

for consideration. Opportunities are provided for participants to ask questions and provide 

comments at work shops, at DOL- and DOE-sponsored meetings, and at NIOSH Town Hall 

meetings. Participants take these opportunities to provide comments on the information 

provided by presenters, as well as information about neighboring sites. Meeting minutes are 

typically taken for NIOSH Town Hall meetings, Worker Outreach Focus Groups, and SEC 

Focus Groups. There is presently no requirement to formally capture and track worker 

comments at workshops, DOE and DOL invited forums, or SEC Information Meetings. As a 

result, substantive comments may go unrecorded. At the WSP Worker Outreach Town Hall 

meeting and the workshop, SC&A made note of substantive comments provided by workers, 

which were relevant to technical work documents. For example, during the workshop, a 

participant from Oak Ridge provided information related to the enrichment process at the Oak 

Ridge Gaseous Diffusion Plant. He raised a concern related to the routine UF6 releases, which 

occurred from the cascades. Another participant verified his statement. NIOSH indicated that, if 

there were issues with UF6 releases into the work environment, it should be addressed in the site 

profile. The worker was told by NIOSH to submit this comment to the docket (see 

Attachment 2). PR-012 should contain direction on documentation and follow-up of participant 

input provided at information giving venues. It would be preferable to capture such comments 

from the worker outreach meeting, incorporate them in the OTS, and alert preparers of site 

profiles and SEC petition evaluation reports that new information is available. 

The fact that at least some workers believe their information was disregarded or misrepresented 

indicates gaps in the process of finalizing the minutes of the meetings. PR-012, unlike PROC0097, has eliminated the requirement to provide participants with an opportunity to review 

meeting minutes. The lack of a provision for an affirmative sign-off by meeting participants who 

provided input, along with the destruction of audiotapes, prevent the resolution of issues that 

arise regarding omissions or misrepresentation of meeting participant comments. SC&A 

recommends that a feedback meeting or loop be incorporated into the procedure, providing 

workers with an opportunity to correct inaccuracies or to insert information they feel was missed 

in the meeting minutes. Furthermore, the procedure should address how comments provided 

during information giving meetings are to be documented and resolved. This would generate 

confidence in the NIOSH approach to workers’ comments and alleviate stakeholder concerns. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 30 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Observations 

Observation 1: The procedure does not address the possibility that sensitive or classified 

information could be shared at worker outreach meetings. This is a particular concern at 

National Nuclear Security Administration (NNSA) sites. At a minimum, the procedure should 

alert worker outreach staff to submit recordings, minutes, or meeting notes for classification 

review if they have any doubt about the classification status of information shared at an outreach 

event. It is recommended that worker information captured for worker outreach activities 

involving NNSA sites be submitted for classification review prior to release to the public. This 

is consistent with the security plan requirements for submittal of site expert interview notes, 

white papers, and technical documents generated by NIOSH, the Advisory Board, and their 

contractors involving NNSA sites. 

Observation 2: There are no requirements in the procedure to notify participants that the 

meeting is designed to solicit unclassified information. A statement to this effect should be 

included in introductory remarks, particularly at worker outreach meetings involving NNSA 

sites. Furthermore, the procedure does not provide an opportunity for workers to discuss 

potentially classified information. Particularly at NNSA sites, workers may be restricted from 

openly discussing site-specific information, due to security concerns. When advising 

participants to refrain from sharing sensitive information at an outreach meeting, NIOSH should 

invite workers to request an alternate venue if they feel their concern or information cannot be 

shared in an open forum. 

Observation 3: There are no provisions for soliciting comments from workers who are not able 

to physically attend meetings. The people who attend the worker outreach meeting are only a 

fraction of the workers at the facilities. Many workers are aging and are not able to travel to 

outreach meetings. These individuals often represent the earliest years of operation at a site, and 

are sometimes the only workers still living for the covered periods of facilities. The procedure 

does not provide a mechanism for workers who cannot travel to worker outreach meetings to 

participate in meetings, nor does it provide direction on providing presentation material and 

soliciting comments from such individuals. One possible solution is to provide a call-in number 

for public outreach meetings. 

Observation 4: There is no requirement for disclosing conflict of interest during worker 

meetings. The Site Profile Subject Matter Expert (SPSME), the OCAS HP Supporting Outreach 

Efforts, and OCAS staff are responsible for identifying the need for worker outreach efforts at 

DOE/AWE sites; preparing presentations and developing questions for outreach discussions; 

identifying meeting action items; coordinating resolution of action items or other issues; 

verifying accuracy of meeting minutes; and identifying issues that are entered into the OTS. 

Participants should be informed of any actual or potential conflict of interest that could influence 

these individuals. 

NIOSH and NIOSH contractors are required to maintain conflict-of-interest plans to include real 

bias or the potential appearance of bias, including both organizational and individual conflict of 

interest. Currently, conflict of interest and bias disclosure statements for NIOSH and ORAUT 

are available through the NIOSH OCAS website. Although this information is available 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 31 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

electronically, not all individuals have access to this information. Conflict of interest and bias 

disclosure for organizations and individuals should be communicated to participants at the 

beginning of each NIOSH sponsored meeting. 

Observation 5: ORAUT-PROC-0031, Site Profile and Technical Basis Document 

Development, currently references PROC-0097, which has been replaced with PR-012. The 

interconnection between site profile development and worker outreach efforts no longer exists 

with PR-012. This and other procedures, plans, and policies that reference PROC-0097 should 

be updated to reflect the current worker outreach processes and procedures. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  32 of 74 

4 PROCEDURE CHECKLIST 

The checklist originally provided in A Protocol for the Review of Procedures and Methods Employed by NIOSH 

Reconstruction (SC&A 2009) was not appropriate for evaluation of the OCAS-PR-012. The procedure has been Objectives 1–4 defined in the Worker Outreach Implementation Plan (see Attachment 7) accepted by the Worke

Group and the Advisory Board. Since these evaluation criteria were developed to evaluate outreach meetings anobjectives are not applicable to the evaluation of the procedure and are so noted. 

No. Description of Objective Rating 1-5* Comments 

1.0 PLANNING FOR OUTREACH: Determine whether OCAS is taking appropriate measures to solicit worker input into 

petition evaluations, and other technical documents. 

1.1 Examine the procedures and processes by which OCAS solicits the involvement of workers by reviewing the following: 

1.1.1 How does OCAS determine whether an outreach meeting is to be 

conducted for a facility?

3 PR-012 Section 6 provides five non-bin

for determining the need for outreach e

relatively objective: o Substantive change to site profiles o Invitation by another agency The other three criteria are relatively vao The need to inform stakeholders o

status 

o The need to gather additional info

stakeholders to support SEC evalu

o As otherwise deemed appropriate Evaluation of actual OCAS determinatibeyond the scope of this review. 

1.1.2 How does OCAS identify and inform workers of the opportunities 

for input and follow-up to secure participation?

3 OSC identifies organizations (union, pr

affiliated with the site and works with tidentify present and past workers intereeffort. OSC develops and sends to interested inintroductory/confirmatory notices and icoordinated with OCAS HP. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  33 of 74 

No. Description of Objective Rating 1-5* Comments 

1.1.3 Is the Outreach Tracking System (OTS) scheduling and 

notification system adequate?

4 The scheduling and notification system 

notifies those individuals on a predetermoutreach events. There are situations wnotifications are not providing in a timeexample, notification of the Hanford ToMarch 16, 2010, was sent out on March 

1.1.4 Are participants in outreach meetings notified in a timely 

manner?

4 

1.1.5 Are arrangements made to participate for those interested but 

unable to travel to outreach meetings?

3 The procedure does not specify options 

who cannot travel to outreach meetingsnot available. 

1.2 Examine several examples of OCAS solicitations and follow-up associated with several particular work products to add

1.2.1 Were the procedures followed and effective in practice? See comment Actual notification and solicitation effo

evaluated, because none were found in conducted since PR-012 had been in effthe procedure what documentation is exmeeting (i.e., NIOSH attends a “non-pu

union’s request). 

1.2.2 Did OCAS make an appropriately extensive effort to elicit broad 

and substantial participation from workers?

3 NIOSH has improved efforts to solicit b

from workers. Specifically, outreach efbeyond union and labor organizations. include advocates, medical surveillance others. This is particularly true of inforand workshops. Worker Outreach (largely information goriented) is formalized with proceduresare regarded as a separate process and aonly “Worker Outreach” is considered, workers and professional employees are represented. The WSP worker outreach meeting was union meeting. The initial union membrepresentative of the site workers, becauof the original WSP workers available tSeven of the approximately 70 attendeethe covered period. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  34 of 74 

No. Description of Objective Rating 1-5* Comments 

1.2.3 Are there additional or improved methods for OCAS to consider? N/A Discussions with union organizers at th

that the meeting was scheduled sufficieinterested parties to attend. However, tannouncements or community outreacharrangements were made for those physto the meeting. 

2.0 CONDUCTING OUTREACH: Determine whether OCAS is obtaining and documenting input from workers. 2.1 Review all OCAS and contractor processes and procedures associated with obtaining and documenting worker input. 

2.1.1 How does OCAS document worker input from information 

gathering meetings and other venues? 

1 PR-012 indicates that meeting minutes 

capturing pertinent worker input for latavailable in OTS for review for any woconducted since the implementation of 

2.1.2 Does OCAS have a method for noting re-occurring issues 

associated with worker communication from various venues? 

1 The current procedure does not discuss 

tracking, or trending worker communic

2.2 Review a sampling of interviews and meetings where the above-referenced processes and procedures were implemented 

contractors to determine whether they were followed and effective in practice. 

2.2.1 Was the desired information obtained and documented? 1 No minutes are available in OTS for rev

outreach meetings conducted since the 012. SC&A attended an outreach meetSeptember 2, 2009, but cannot compare meeting against NIOSH’s documentatioworker input (meeting notes) from an SFocus Group meeting; however, these wby the Subject Matter Expert (SME), rameeting minutes. 

2.2.2 Is the documentation of participants’ comments accurate and 

complete?

1 SC&A attended an outreach meeting fo

final meeting minutes from this meeting comparison to notes and actions captureThe procedure requires destruction of inaudiotapes of meetings are destroyed afmeeting. Furthermore, the OSC Team 

staff representative is instructed to explaudiotape are not available for public dindividual requests a copy. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  35 of 74 

No. Description of Objective Rating 1-5* Comments 

2.2.3 Is the draft of the meeting record available for appropriate 

participant review?

2 Historically, meeting minutes have bee

sponsoring union organization for revieprovisions in PR-012 for submitting drameeting participants for review. Of the release of PR-012 requiring meeting mirequesting comments from the participa

2.2.4 Did the participants avail themselves of the opportunity to 

comment on the draft meeting record?

See comment There are no provisions in PR-012 for s

minutes to meeting participants for revi

2.2.5 Were comments incorporated into the final meeting record? See comment There are no provisions in PR-012 for s

minutes to meeting participants for revi

2.2.6 Was the finalized meeting record made available in a timely 

manner to participants requesting copies?

N/A SC&A cannot determine what informat

participants, but there is a significant abin the OTS. There are only five meetinare currently logged into OTS, and woumeeting minutes (i.e., not counting DOOutreach Meetings, or Workshops). Thplace between April and December of 2meetings do not have meeting minutes OTS. One meeting has a file containing representative’s meeting notes (not tradof these meetings is noted on the NIOSOutreach Activities. There is also no coOTS requesting a review of minutes or 

2.3 Evaluate the conduct of outreach meetings. 

2.3.1 Is technical staff present at information outreach meetings where 

appropriate? 

5 The procedure has provisions for the at

the SEC Petition Counselor, OSC staff, ombudsman. 

2.3.2 Were appropriate introductory statements made at the beginning 

of the meeting?

5 During the WSP meeting, appropriate i

regarding the audiotapes were made. Athere was a sign-in sheet, but it was useparticipants if needed. (See Attachmen

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  36 of 74 

No. Description of Objective Rating 1-5* Comments 

2.3.3 Was there an adequate time for presentations by OCAS? 4 The technical presentation at the WSP o

approximately 1 hour long, which was tand contained too many details in some of the information on Slides 10–16). Tthe slides were helpful, and would have if they could have been projected on a sfollow. At the September 22–23, 2010, workshthey would like to see more time spent “What You Can Do to Assist the Claim

2.3.4 Were participants allowed adequate opportunity to provide 

comments?

5 Based exclusively on the observation of 

2009, workshop, participants were provopportunity to provide comments and a

2.3.5 Are provisions made that are appropriate for interviews in a 

classified setting should the need arise?

2 The procedure does not provide an opti

meetings. For NNSA sites (e.g., Pantex worker outreach activities in public locpotential for inadvertent disclosure of cparticipants. In addition, the procedure instructions for classification review of accordance with the DOE Security Plan procedure, or by reference to an approp

2.3.6 Are presentations developed at the appropriate level for the 

participants of the meeting? 

4 The presentation at the WSP worker ou

level the participants could understand. At the workshop, participants found the although several mentioned the IREP pshortened and simplified, with an emphhome message.” 

2.3.7 Are sign-in sheets utilized for outreach meetings so that attendees 

can be contacted, if needed, with follow-up information or questions? 

2 Sign-in sheets are available for some ou

the implementation date of PR-012. Foconducted since the implementation of sign-in sheets available in the OTS. 

2.3.8 Are questions appropriate to solicit the desired information? N/A SC&A has not attended an information 

notes from the April 2009 Mound SEC include questions. No evaluation could 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  37 of 74 

No. Description of Objective Rating 1-5* Comments 

2.4 Evaluate the completeness and adequacy of the Outreach Tracking System (OTS). 

2.4.1 Does the OTS reflect the breadth and depth of the information 

provided by workers at the meetings?

See Comment Based on a review of the procedure and 

provided by workers is documented witAttendance at an information gathering subsequent review of meeting minutes ievaluation of this objective. 

2.4.2 Did OTS integrate action items accepted by OCAS or its 

contractors during the course of the meeting?

2 There are a total of six action items for 

OTS. Action items may be reflected in however, they are not documented and Item section of OTS. The minimal numdocumented and tracked indicates a lacworker comments in technical documenfollow-up with workers regarding questFurther evaluation of this objective requoutreach meeting. 

2.4.3 Were participant comments provided at information giving 

meetings included in OTS?

2 The procedure does not require that wo

during information giving meetings. As observed at the WSP outreach meetigenerated and put into OTS as a result oworker. An e-mail response was providDuring the workshop, several commentwere not captured in the minutes, nor wOTS. In one case, NIOSH acknowledgworker comment to the site profile, but submit his comment through the docketthe comment as an action item. 

2.4.4 Is OTS an adequate method for documenting and tracking worker 

comments?

2 The final meeting minutes for informati

are uploaded to OTS as part of the suppOTS does not have a capability for trac

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  38 of 74 

No. Description of Objective Rating 1-5* Comments 

2.5 Evaluate OCAS’s tracking system for identifying trends in worker comments. 

2.5.1 Has OCAS documented repetitive or reoccurring issues on a sitewide or program-wide basis? 1 There is no mechanism for evaluation o

comments. 

3.0 CONSIDERING WORKER INPUT: Determine whether OCAS is giving thorough consideration to information receiv

through the worker outreach efforts; incorporating consideration of that material into its work products, as appropriatcommunicating the impact of substantive comments to workers. 

3.1 Examine the process by which OCAS and its contractors evaluate worker input. 

3.1.1 How does OCAS catalog and consider worker input for inclusion 

into its technical documents such as site profiles and SEC evaluation reports?

1 Procedure does not describe a process f

considering worker input. This was remwas superseded by PR-012. 

3.1.2 What criteria are used to identify comments that deserve 

consideration for a response or action by NIOSH?

2 There are no criteria for identifying com

response or justify initiating an action i

3.1.3 Are the appropriate personnel evaluating the comments received? See Comment Rating 1- For evaluating comments (res

assigned in PR-012). Rating 3- For determining and assigninassigns responsibility to qualified indivaction items. The two action items recoassigned to individuals who were qualifissues. The action items listed in OTS tnot specify the personnel responsible fo

3.1.4 Were follow-up discussions held with participants providing 

substantive comments, when necessary?

2 For meetings conducted under PROC-0

submitted to organizations for review oSince implementation of PR-012, there to participants requesting reviews in OTexamples of follow-up correspondence related to action items. 

3.1.5 What processes and procedures are in place to ensure that 

NIOSH is following up on the response and action items?

2 Procedure does not specify a process. O

items recorded under PR-012 has been “in progress” 7 months beyond the due 

3.1.6 How is feedback provided to the workers in response to their 

comments?

See Comment General comment response cannot be e

not specify a process, and there is minimavailable for review. Rating 3 - Action Item response: The ofrom the PR-012 period has adequate dappropriate response. 

3.1.7 Did OCAS conduct research to evaluate substantive comments by 

participants and assess their impact on NIOSH documents, processes, and procedures?

N/A Cannot be determined by a review of th

limited documentation available in OTS

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  39 of 74 

No. Description of Objective Rating 1-5* Comments 

3.2 Conduct a systematic review of worker outreach database(s) (at a point in time) in relation to its impact on technical do

3.2.1 Select a sample of Site Profiles and SEC Evaluation Reports 

where worker outreach meetings have been done to document whether and how worker input has been considered and included, and evaluate if exclusions were appropriate.

See Comment This action is pending further direction 

3.2.2 Were the action items in OTS (or responses in WISPR and 

predecessor databases) appropriate to the comments received? 

2 There are provisions within the procedu

items in OTS. The procedure does not constitutes an action item. The only infprocedure is that action items will be idHP or the SEC Counselor and entered iItem” screen of OTS. Worker commencaptured and tracked in WISPR and pre

3.2.3 Were recurrent issues appropriately responded to? 1 The ability to track recurrent issues is n

Prior to the termination of TopHats and ability to identify recurrent issues. 

3.2.4 Are comments applicable to the DOL portion of the process 

forwarded to DOL for consideration?

1 There is no indication from material in 

been forwarded to DOL or DOE. In soare present at the meetings (i.e., Town HOutreach meetings, ABRWH meetings) 

themselves. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  40 of 74 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

No. Description of Objective Rating 1-5* 

NOTICE

wever, th

Comments 

4.0 INFORMATION GIVING: Determine whether OCAS is effectively informing workers in relation to its various respon

EEOICPA, including explaining dose reconstruction, the SEC petition process, etc. 

4.1 Examine the communication vehicles that OCAS has developed to communicate with workers, claimants, and petitione

representatives. 

4.1.1 Does OCAS communicate the information needed by claimants 

and petitioners?

4 The procedure outlines the responsibilit

distributing, and integrating informationpresentations) into OTS. In the case of the workshop presentatio23, 2009 workshop, the presentations wuseful in helping the participants underreconstruction and SEC processes. Thelectures and practical exercise. The sta

IREP was confusing to most participantsimplified into layman terms. Handoutprovided by NIOSH and DOL (who parwebsite and contact information, should arise. The appropriate subject matter expresentations. Cannot exclusively be determined by a Further evaluation requires attendance aoutreach meeting. 

4.1.2 Is this information communicated through appropriate means? 4 Cannot exclusively be determined by a 

4.2 Evaluate whether OCAS’s communications result in adequate understanding of dose reconstructions, the use of IREP, 

processes. 

4.2.1 Do the participants understand what to expect in the dose 

reconstruction and petition processes? 

N/A Cannot be determined by a review of th

4.2.2 Do the participants understand the requirements for submitting 

and qualifying an SEC petition? 

N/A Cannot be determined by a review of th

4.2.3 Do the participants understand the process for evaluating an SEC 

petition and how it may be approved or denied? 

N/A Cannot be determined by a review of th

4.2.4 Are claimants notified that an Ombudsman Office exists and what 

services it provides? 

N/A Cannot be determined by a review of th

4.2.5 Is the Ombudsman Office responding to worker communications 

and forwarding the comments received to appropriate subgroups of OCAS and its contractors?

N/A Cannot be determined by a review of th

* Rating system of 1 through 5 corresponds to the following: 1 = No (Never), 2 = Infrequently, 3 = Sometimes, 4 = Frequently, 5 = Yeindicates not applicable.
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 41 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

5 REFERENCES 

ABRWH (Advisory Board on Radiation and Worker Health) 2008. Transcript of the Worker 

Outreach Working Group Meeting of the Advisory Board on Radiation and Worker Health, 

February 1, 2008, pg 153. 

ABRWH (Advisory Board on Radiation and Worker Health) 2009. Transcript of the Mound 

Working Group Meeting of the Advisory Board on Radiation and Worker Health, May 28, 2009, 

pg. 8-10. 

ATL 2009. Participant Workshop Evaluations from the NIOSH Dose Reconstruction/SEC 

Workshop, September 22–23, 2009. 

Griffith, R.V. 2004. “Resolution of Question Regarding Quantities Used for Reporting the 

Measurement of Personal Exposures to Photons at the NTS, 1962 to 1987,” August 4, 2004, 

SRDB 13989. 

Howard, J., 2008. Letter from John Howard (NIOSH) to [SRS Petitioner], no subject, NIOSH, 

Washington, D.C., June 27, 2008. 

OCAS (Office of Compensation and Analysis) 2009a. Worker Outreach Program, OCAS-PR012, Rev. 0, National Institute for Occupational Safety and Health, OCAS, Cincinnati, Ohio, 

March 4, 2009. 

OCAS (Office of Compensation and Analysis) 2009b. Classification of Worker Outreach 

Meetings (as defined at ABRWH Worker Outreach Work Group meeting, 6/16/2009, National 

Institute for Occupational Safety and Health, OCAS, Cincinnati, Ohio, June 2009. 

OCAS (Office of Compensation and Analysis) 2009c. Types of NIOSH Meetings, National 

Institute for Occupational Safety and Health, OCAS, Cincinnati, Ohio, June 16, 2009. 

OCAS (Office of Compensation and Analysis) 2009d. NIOSH Outreach Tracking System (OTS),

Presented at the Worker Outreach Working Group Meeting June 2009, National Institute for 

Occupational Safety and Health, OCAS, Cincinnati, Ohio. 

ORAUT (Oak Ridge Associated Universities Team) 2004. Worker Outreach Program Plan, 

ORAUT-PLAN-0010, Oak Ridge, Tennessee, April 16, 2004. 

ORAUT (Oak Ridge Associated Universities Team) 2005a. Conduct of the Worker Outreach 

Program Procedure, ORAUT-PROC-0097, Oak Ridge, Tennessee, December 29, 2005. 

ORAUT (Oak Ridge Associated Universities Team) 2005b. Special Exposure Cohort (SEC), 

ORAUT-PROC-0044, Oak Ridge, Tennessee, October 7, 2005. 

ORAUT (Oak Ridge Associated Universities Team) 2007a. Site Profile and Technical Basis 

Document Development, ORAUT-PROC-0031, Oak Ridge, Tennessee, August 17, 2007. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 42 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

ORAUT (Oak Ridge Associated Universities Team) 2007b. Documented Communication, 

ORAUT-FORM-0025, Oak Ridge, Tennessee, May 17, 2007. 

SC&A (S. Cohen and Associates, Inc.) 2005. Review of the NIOSH Site Profile for the Nevada 

Test Site, SCA-TR-TASK1-0006, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, 

Maryland. December 13, 2005. 

SC&A (S. Cohen and Associates, Inc.) 2007. Review of ORAUT-PROC-0097, Conduct of the 

Worker Outreach Program Procedure, SCA-TR-TASK3-003, Addendum 1, Revision 1, SC&A, 

Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. November 2007. 

SC&A (S. Cohen and Associates, Inc.) 2008. Summary of Portsmouth Gaseous Diffusion Plant 

Meeting with SPFPA, SC&A, Inc., Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland, 

April 2008. 

SC&A (S. Cohen and Associates, Inc.) 2009. A Protocol for the Review of Procedures and 

Methods Employed by NIOSH for Dose Reconstruction, SCA-TR-PR2009-0001, SC&A, Inc., 

Vienna, Virginia, and Saliant, Inc., Jefferson, Maryland. November 2009. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 43 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 1: SC&A MEETING MINUTES AND NOTES FROM THE 

WELDON SPRING WORKER OUTREACH MEETING 

Weldon Spring Worker Outreach Meeting 

Laborers Local 660 Union Hall 

2633 West Clay Street 

St. Charles, MO 63301 

September 2, 2009, 7:00 pm

SC&A Meeting Minutes and Notes 

Participants: Mel Chew (ORAUT), Mark Lewis (ATL), Mary Elliot (ATL), Laurie Breyer 

(NIOSH), Stu Hinnefeld (OCAS), Denise Brock (CCI), Ron Buchanan (SC&A, Inc.), Karene 

Riley (SC&A, Inc.), and approximately 60 to 70 local union members. 

The Weldon Spring Worker Outreach Meeting began at approximately 7:20 pm CST following a 

monthly local union meeting which started at 7:00 pm. 

Introduction

Stu (OCAS) began the Weldon Spring Worker Outreach Meeting by explaining the purpose of 

the meeting and introducing the members of the NIOSH team including contractors. Stu 

explained that the purpose of the worker outreach meeting was to explain to workers that those 

who worked at the Weldon Spring Plant (WSP) site and have been diagnosed with cancer may be 

compensated for radiation exposure while working at the plant during a certain time period in 

accordance with the Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA). Stu also explained that former workers or their spouses or dependents can submit a 

claim under EEOICPA. Stu discussed the purpose of the site profile document and how it is 

developed through a records search and worker input on exposure history. He also explained 

that it is a living document that is updated as necessary and the need for worker input for 

updating the document. Workers were told that the minutes made from the meeting, as well as 

comments would be provided to NIOSH who will post it on the OCAS website and individual 

names would not be used. 

During the introduction, a question was posed by a member in the audience: Will this meeting 

only address cancer and not other diseases? 

 

Response from Stu: Stu stated that the meeting will only address cancer caused from radiation 

exposure at the WSP site which is under Part B of EEOICPA. He stated that other diseases are 

addressed under Part E of the program and handouts on claims information are provided on the 

table. 

Presentation: 

Mel Chew (ORAUT) gave a presentation which included explaining the role of the team, the 

purpose of the site profile and what the site profile means. He stated that an emphasis on worker 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 44 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

input is necessary for better dose reconstruction. A history of the Weldon Spring site and its uses 

since 1941 and the term “feed” was explained. Mel explained the timeframe that the U.S. 

Atomic Energy Commission (AEC) and the U.S. Department of Energy (DOE) held custody of 

the Weldon Spring Plant site and how these timeframes relate to worker claims submitted for this 

site. 

Two people [out of approximately 70 meeting attendees] raised their hands as having worked at 

the WSP site during the 1957–1966 timeframe. Five people [out of approximately 70 meeting 

attendees] raised their hands as having worked at the WSP site during the 1985–2002 

remediation timeframe. A couple of people in the audience began asking questions at this point 

in the presentation. The questions and responses are provided below. 

Worker Questions/Comments

1. Worker 1 Question: Worker 1 asked, “Why has the Department of the Army neglected the 

time period of 1968 to 1985”? This worker was upset and stated that the 1968 to 1985 time 

period appears to be taboo and no one is willing to talk about it. He stated that it was a 

forgotten era and feels there is a big cover-up going on. 

Response to Worker 1: Stu responded by stating that he does not know why the Dept. of the 

Army has not been responding to his inquiries and he can not speak for the Army, only for 

the DOE work-related timeframes. Stu referred this worker to the NIOSH website for 

information on e-mailing or writing to NIOSH in regards to the Dept. of the Army workrelated exposures and illnesses. 

2. Worker 2 Comment: Worker 2 stated he had two [relatives] who worked at the WSP site 

during the 1968 to 1985 timeframe and they were told that the “yellow cake” was fine and 

they got sick from it. He added that they were diagnosed with [cancer] and he can’t get a 

hold of the Army about his [relatives’] exposure cases. 

Return to Presentation

After these two questions/comments, Mel returned to the presentation and explained the types of 

material processed at the WSP site. He asked Worker 3 who previously stated that he worked at 

the WSP site during the 1957–1966 timeframe, if he thought approximately 50% of the workers 

worked with uranium and Worker 3 stated “yes, every bit of half.” Worker 3 also provided the 

following comments: 

3. Worker 3 Comment #1: Worker 3 stated that he was not sure if x-rays were provided when 

working at the plant. 

4. Worker 3 Comment #2: Worker 3 stated that during the remediation period of 1985 to 2002, 

a lot of material from the pipes that were being dismantled was released into the air. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 45 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

5. Worker 3 Comment #3: Worker 3 stated that during the plant’s operational period, no urine 

samples were taken from him. He also said that urine samples were only obtained when he 

started working and when he was laid him off and the plant closed. 

6. Worker 3 Comment #4: Worker 3 stated he did not have a whole-body count while working 

at the plant. 

7. Worker 3 Comment #5: Worker 3 stated that the workers did wear dosimeter badges and 

TLD badges later on. 

8. Worker 4 Question: This worker asked for information on getting individual records 

released. He also asked if descendents are able to claim for radiation exposure for deceased 

parents. 

Response: Mel and Stu responded to Worker 4 and told him “Yes, under Part B of 

EEOICPA, descendents can claim for their deceased parents. 

9. Worker 5 Question: This worker asked how he could obtain records for a deceased family 

member. He stated he was unable to obtain medical records from the hospital that the family 

member went to. 

Response: Stu responded to this worker’s question by referring him to the NIOSH website 

and telling him he can request the worker’s record if a claim had been submitted already. Stu 

said if a claim has been submitted, they can provide a copy of the records obtained from 

WSP. Stu also said he could talk to him more individually. Denise offered her assistance in 

helping him navigate the process of obtaining the family member medical record. 

10. Worker 6 Comment: This worker stated that he was told no thorium was at the site during 

decommissioning. 

Mel ended the presentation by re-iterating the importance of site worker input for developing a 

more relevant site profile. Stu asked if there were any additional questions or comments from 

the workers and thanked everyone for coming to the meeting. The Weldon Spring Worker 

Outreach Meeting ended at approximately 8:40 pm CST. 

SC&A’s Evaluation of the Meeting 

As required by OCAS-PR-012, Mary Elliot (ATL) explained that the meeting would be recorded 

as a tool to provide verification of the minutes of the meeting and would not be made public. 

There were no objections to the meeting being recorded. Mary also explained that the sign-in 

sheet would not be made public, but only used for contacting participants if needed. 

The Local 660 Union members had been invited to attend the meeting. SC&A’s discussion with 

the union organizer and several of the participants after the meeting indicated that the meeting 

was scheduled sufficiently in advance to allow the interested union members to be informed of 

the meeting and to attend it. Apparently this was accomplished by including it in the union 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 46 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

newspaper and by word of mouth. There was no public posting or community outreach 

concerning the meeting that anyone was aware of. There were no indications that arrangements 

were made for those that could not travel to the meeting. 

For this Weldon Spring worker outreach meeting, it was difficult to obtain worker input (and 

interest) because the site only operated during the period 1957–1966 and only two of the union 

members present had worked there during that time, and five had worked there during the 

remediation period of 1985–2005. Therefore, the younger workers started leaving the meeting 

and attendance went from approximately 70 union members at 7:15 pm to approximately 18 by 

8:30 pm. The initial union members present were not representative of the site workers because 

there are not many of the original Weldon Spring Site workers available to attend the meeting. 

In general, the meeting was at a level the participants could understand. However, the technical 

presentation was approximately one hour long, which was too long for this audience and 

contained too many details in some sections (such as some of the information on Slide #10-16). 

The handouts containing the slides were helpful, and would have been even more helpful if they 

could have been projected on a screen for the audience to follow. 

One very important point of controversy at the Weldon Spring Site that has plagued the site 

profile in the past, and this meeting also where one member was very vocal about the issue, is the 

period of 1967–1969 when the U.S. Army hired contractors to renovate the Weldon Spring Plant 

(WSP) for the anticipated use of producing herbicides (which was cancelled before any was 

produced at the WSP). Workers were potentially exposed to AEC-generated radioactive material 

in this renovation phase without the benefits of the EEOICPA, because the contractors were not 

AEC contractors. This issue needs to be addressed before any other meetings are held or Site 

Profile revisions are completed. 

The few workers present provided some information concerning bioassays, external badging, 

occupational medical X-rays, and personal protection equipment during and after the meeting. 

Various handouts and contact information was provided for the participants on a table along the 

wall. 

The meeting appeared to be conducted in a manner that followed proper protocol (e.g., OCASPR-012) and was informative. The main problem is that most of the work force is no longer 

available; in this case, it would have been better to have a more brief presentation. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 47 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 2: SC&A SUMMARY FROM NIOSH WORKSHOP ON 

DOSE RECONSTRUCTION AND SEC PROCESSES 

NIOSH Workshop on Dose Reconstruction and Special Exposure Cohort Processes 

Cincinnati, Ohio 

September 22–23, 2009

SC&A Summary from the Workshop 

Participants 

Participants invited to this workshop included personnel from the Former Worker Medical 

Screening program at the Pantex Plant, Cincinnati, Oak Ridge (Y-12, K-25, X-10), University of 

Iowa (IAAP and Ames), INEEL, and RFP, union representatives from Oak Ridge, Kansas City, 

and the Building Trades Council participated, petitioners, and personnel from the DOL.

Summary of Feedback from Participants 

 NIOSH did a good job at anticipating questions that have been previously raised and 

answering them. 

 Participants found the work shop presentations and handouts helpful and informative. 

 Participants indicated the information provided would be helpful in educating/helping the 

claimants understand what goes on when they file claims. 

 Several participants found the presentation on the website and the sample CATI very 

helpful. 

Summary of Recommendations from Participants 

 Focus on the new developments in EEOICPA. 

 Emphasize and allot more time for the portion of the work shop that provides advice on 

how to assist claimants. 

 Simplify and shorten the IREP presentation emphasizing the “take-home” message. 

 Include an exercise on dose reconstruction. 

 Provide a glossary of terms commonly used in the presentations and keep the subjects in 

layman terms. 

 Add the “take-home” message at the end of each presentation. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 48 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 Shorten the work shop to 1.5 days. Some individuals cannot afford to be away from 

work for four days (two days of travel, two days of workshop.) 

 Bring in a box lunch to facilitate discussions between participants. 

In general, the participants would recommend the workshop to others. 

 

Follow-up Actions for NIOSH/ATL 

(1) NIOSH took an action item to provide the Mound participant with additional information 

on whether plutonium was the only element for which Super S was considered. 

 

(2) NIOSH took an action item to determine why OTIB-62 and OTIB-63 were being 

referenced in LANL dose reconstruction when they were not yet available. 

Information Gathering Statements 

The workshop presents an opportunity for workers to provide comments on various sites which 

may benefit NIOSH technical documents or provide better understanding of processes and 

procedures at the sites. 

 When additional comments were solicited by the interviewer, the interviewee indicated 

that at ORNL, workers wore pocket ionization chambers, and if the unit went off scale, 

the average of the pencil dosimeter results for the area was assigned to the individual. 

The CATI interview volunteer said during the interview exercise that this was not 

reflective of the exposure all individuals in that area received. He indicated that he was 

told that 3 out of 10 PIC readings were bad. He also noted that in some areas they took 

away the dosimeter and gave them only PICs. [This is an example of comments 

communicated to NIOSH during the workshop that are pertinent to dose reconstruction of 

multiple workers, which should be captured, documented, and tracked in OTS and 

investigated further.] 

 An INEEL participant indicated that he carried two lunch boxes. One was a lunch box 

with the individual’s lunch, and the second was a lunch box for his bioassay sample. He 

indicated he had to take the sample lunch box home, collect the sample, and bring it back 

to the site. This was especially true after an event. [This is the kind of information that 

should be verified against information in the site profile to ensure the information is 

correct.] 

 A K-25 participant indicated that the enrichment process at K-25 and K-27 were wartime 

processes while the processes at K-29, K-31, and K-33 were used for peace time 

operation. He indicated that there were UF6 releases from the cascades, and was 

supported in this statement by other K-25 workers attending the workshop. NIOSH 

(Larry) indicated that if there were issues with UF6 releases into the work environment, it 

should be addressed in the site profile. The participant was told to submit his comment 

through the docket on the website. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 49 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Comments like those provided above add to the institutional knowledge being provided by 

workers. 

SC&A Observations from the Workshop 

Evaluation Objective #1: Determine whether OCAS is taking appropriate measures to 

solicit worker input into site profiles, SEC petition evaluations, and other technical 

documents. 

 Workshops are held a couple times a year to inform advocates, petitioners, union 

representatives, DOL personnel and other interested parties about topics such as the dose 

reconstruction process, telephone interviews, the OCAS website, the SEC process, the 

IREP model, and limited information on Part E benefits. The goal is to educate the 

attendees such that they can, in turn, assist claimants in either the DR or SEC process. 

Some information provided is purely information, such as suggestions on how to help the 

claimant to the fullest extent, or how to access and navigate the website and the IREP 

code. The other focus of the workshop seems to be an emphasis on demonstrating how 

claimant favorable the process is from the assumptions made in dose reconstruction, to 

the expanded evaluations of petitions beyond petitioner issues, to the favorability built 

into the IREP code. 

 In the case of the workshop observed, NIOSH and/or ATL personnel invited petitioners, 

union members, and worker surveillance personnel to attend. These workshops are in 

high demand by individuals wanting to attend and there is a waiting list. Letters were 

sent out to central contacts at union and worker surveillance programs so they could 

identify individuals they would like to attend. Attendance at these meetings is 

reimbursable by NIOSH, at least in the case of the September 22-23, 2009 Workshop. 

 The workshop along with presentations is included in OTS. Any phone calls made to 

individuals regarding the participation in the workshop are not documented in OTS. 

 There are no arrangements made for interested parties who would like to participate in 

the workshop who are either not physically able to attend, or who are unable to travel to 

workshops. There is no call-in number provided for workshops. 

 OCAS-PR-012 provides only generic guidance on how workshops are to be conducted, 

or the documentation is typically associated with workshops. Based on the vague 

direction provided by the procedure, it is difficult to evaluate whether the workshop 

complied with procedures. 

 Workshops are by invitation only. This was a somewhat targeting meeting primarily for 

individuals involved in the Worker Surveillance program. Attendees represented Oak 

Ridge National Laboratory, the Oak Ridge Gaseous Diffusion Plant, the Y-12 Plant, the 

Pantex Plant, IAAP, Idaho National Engineering Laboratory, the Kansas City Plant, Los 

Alamos National Laboratory (LANL), the Mound Plant, and the Cincinnati area worker 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 50 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

surveillance personnel. There is a waiting list for these workshops, but there are 

additional workshops planned in the future. 

Evaluation Objective #2: Determine whether OCAS is obtaining and documenting input 

from workers. 

 When workers had comments specific to their site, they were encouraged to enter these 

comments into the docket. NIOSH and ATL personnel were not taking notes on these 

comments being provided by the participants. There were a few questions, which 

NIOSH indicated they would follow-up on after the meeting. These action items are 

listed below. 

 The workshop is designated under “other forms of worker communication” in OCAS-PR012. The procedure is designated as an information giving meeting which for the most 

part is true. NIOSH encourages workers in ask questions during the presentations and 

exercises. The questions are in many cases related to the processes being explained. 

Clearly, former workshops have raised a number of questions, which were anticipated by 

NIOSH and answered at the beginning of the workshop. In our observation of the 

workshop, several generic and site-specific comments were provided by the workers. In 

one case, a worker who brought up information which was pertinent to the K-25 site, was 

told by NIOSH the item should be addressed in the site profile, and was told to submit his 

comments through the public docket. This is certainly one method for getting workerprovided documents recorded; however, NIOSH should be entering these comments into 

the docket and database on behalf of the workers so it can be tracked. 

 Although the workshop was primarily an information giving meeting, there were several 

comments provided by participants that were relevant to site profiles and dose 

reconstructions, and comments which required action be taken by NIOSH. The action 

items are listed later in this document. 

 There were no minutes taken at the workshop. The information was not formally 

documented. No audiotaped recordings were taken during the workshop. 

 NIOSH/ATL provided adequate opportunity to comment or ask questions. Participants 

were encouraged to ask questions and provide comments throughout the workshop. 

 The meeting was held in a union facility in Cincinnati, Ohio. There were participants 

there from NNSA sites or sites involving classified processes (e.g., Pantex, IAAP, LANL, 

Oak Ridge Gaseous Diffusion Plant, the Y-12 Plant). No statement was made up front 

regarding limiting comments and questions to unclassified information. Since 

documentation was not kept by NIOSH, it is not available for classification review. 

Evaluation Objective #3: Determine whether OCAS is giving thorough consideration to 

information received from workers through the worker outreach efforts, incorporating 

consideration of that material into its work products, as appropriate, and adequately 

communicating the impact of substantive comments to workers. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 51 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 Since no meeting minutes were taken during the workshop, it was difficult to determine 

whether adequate consideration was given to work comments. OTS identified no action 

items from this meeting. SC&A identified a few actions items taken by NIOSH in their 

own notes. These are specified in a separate section. 

Objective #4: Determine whether OCAS is effectively informing workers in relation to its 

various responsibilities related to the EEOICPA, including explaining dose reconstruction, 

the SEC petition process, etc. 

 In the case of the workshop, the participants were provided with a book of handouts 

including exercises and copies of the presentation. The handouts were put together by 

NIOSH. In the case of the interview demonstration, NIOSH failed to provide a list of the 

interview questions to be used in the demonstration. This made it more difficult to follow 

along with the interview/interviewer. In some cases, the presentation material was not 

written at the level of the audience. DOL also provided informative brochures and a 

handout for their Part E presentation. 

 There was an informative presentation on the NIOSH website and where to find 

information, followed by a hands-on exercise. 

 Based on observation, the participants understood the claim process, what to expect from 

the process, and the difference between Part B and Part E claims. NIOSH, in one of its 

presentations, addressed the turnaround time for dose reconstruction claims. The 

difference between the dose reconstruction process and the SEC process was explained 

effectively. 

 NIOSH provided a presentation which took the participant from the initiation of filing an 

SEC petition through final approval by Congress. 

 NIOSH explained that the 180-day limit is started from the time the petition is received 

and qualified. They indicated that typically they are able to meet this time limit, but that 

there are times they must request additional time from the petitioner. This is particularly 

true of large, complicated sites. 

 The Ombudsman Office provided a presentation in the workshop which included the 

purpose of the Ombudsman and the contact information. 

 The Ombudsman Office is responding to worker calls and communications within the 

limit of their capability. 

 The NIOSH Ombudsman staff is not large enough to handle all the incoming requests. 

General SC&A Comments 

 Representatives from the Department of Labor, who were attending the workshop, 

provided a brief presentation on Part E. The inclusion of a presentation on Part E was 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 52 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

beneficial. Many of the comments provided by workers include those associated with 

toxic substances, and having someone there to answer questions was helpful. In addition 

to the presentation, DOL representatives handed out information on Part E and provided 

contact information for the DOL Ombudsman Office. 

 In the discussion about Super S plutonium, it was not specified that this applied only to 

Pu-239 at the present time, and excluded other isotopes of plutonium. 

SC&A Recommendations 

 The CATI interview questions should be included in the booklet provided to the 

participants. 

 The dose reconstruction process was, in general, communicated in a way which was 

understandable to the participants. Numerous participants indicated in their Workshop 

Evaluation that they had difficulty understanding the discussion of the Probability of 

Causation (POC). The presentation should be simplified and possibly made more 

understandable with the use of a practical exercise in statistics. 

 The workshop should include a review of a dose reconstruction report, which is the 

primary documentation sent to the claimant at the end of the dose reconstruction process. 

 Offer up additional information such as TIBs for individuals that are more knowledgeable 

with their questions. For example, LANL worker was interested in the details of the 

Super S model. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  53 of 74 

ATTACHMENT 3: WORKER OUTREACH MEETINGS/EVENTS 

CONDUCTED UNDER OCAS-PR-012 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

37 Worker 

Outreach 

3/3/2009 NIOSH Workshop on 

Dose Reconstruction and the Special Exposure Cohort (multi-site representation), Health and Safety Training Center, International Chemical Workers Union (ICWU) Council/UFCW of Food and Commercial Workers Union, 329 Race Street, Cincinnati, OH 

Feed Materials Production Center (FMPC), Hanford, INL, KCP, LANL, NTS, ORNL (X-10), Pantex Plant, SNL, SRS, Y-12 Plant 

Invited attendees from multiple sites within the nuclear weapons complex learned about the EEOICPA dose reconstruction and SEC petitioning processes during this workshop. 

ATL Worker Outreach T(Vernon McDougall, MaLewis, Buck Cameron, MElliott) hosted the 12-howorkshop on Tuesday, M2009 and Wednesday, M2009. Participants inclurepresentatives from laborganizations at several sites, representatives froBuilding Trades MedicaScreening Programs, a representative from NIOand the Director of the NOffice of Nuclear WorkeAdvocacy. NIOSH: LaElliott, Laurie Breyer, GCalhoun, LaVon RutherDave Allen, and Denise presented information on EEOICPA Part B, dose reconstruction, and the Spetitioning process. Maand Buck Cameron led a group activity so the attecould apply what they hlearned. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  54 of 74 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

39 SEC 3/18/2009 Springville Townhall, 65 

Franklin St, Springville, NY 

West Valley Demonstration Project 

Members of International Association of Machinists and Aerospace Workers (IAM) Local Lodge 2401 

An informal non-public requested by IAM Local 2401 Association of Maand Aerospace Workers Lodge 2401. They asketo provide information aSpecial Exposure Cohorpetitioning process, and impact of adding a class SEC. No minutes. 

113 SEC 4/28/2009 Dayton, Ohio Mound Plant Former workers from the 

Mound site 

Meeting with a small focto gather information on dosimetry program in suMound SEC evaluation. NIOSH/ORAU Team: BUlsh, Tim Taulbee, Bob Karin Jessen. 

117 Worker 

Outreach 

8/11/2009 Greater Kansas City 

Building and Construction Trades (KCBCTC), Independence, MO 

Kansas City Plant 

KCBCTC leadership Buck Cameron will mak

informational presentatioEEOICPA to the KCBCduring their regular mee(This is not a traditional outreach meeting.) 

118 Non-NIOSH 8/11/2009 Receptions Conference 

Center 5975 Boymel Drive Fairfield, OH 45014 

Feed Materials Production Center (FMPC) 

This meeting is being held by the DOL Ombudsmans Office for former and current Fernald Workers. 

DOE Former Worker PrDOL Ombudsmans OffiDenise Brock, and DOL center will all be in atten

119 Non-NIOSH 8/11/2009 Receptions Conference 

Center, 5975 Boymel Drive, Fairfield, OH 45014 

Feed Materials Production Center (FMPC) 

This is a DOL Ombudsmans Office meeting for former and current workers at Fernald. 

DOE Former Worker PrDOL Ombudsmans OffiDenise Brock, and DOL center will all be in atten

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  55 of 74 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

120 Non-NIOSH 8/12/2009 Holiday Inn - Dayton 

Mall, 31 Prestige Plaza Drive, Miamisburg, OH 45342 

Mound Plant This is a DOL 

Ombudsmans Office meeting for Mound workers 

Will include individuals DOL Ombudsmans OffiFormer Worker ProgramBrock, and NIOSH, and Resource Center. 

121 Non-NIOSH 8/12/2009 Holiday Inn - Dayton 

Mall, 31 Prestige Plaza Drive, Miamisburg, OH 45342 

Mound Plant This is a DOL 

Ombudsmans Office meeting for former Mound workers 

Will include individuals DOL Ombudsmans OffiFormer Worker ProgramBrock, and NIOSH, and Resource Center. 

116 Worker 

Outreach 

8/13/2009 IAMAW Local Lodge 

778, 9404 Grandview Rd., Kansas City, MO 64132 

Kansas City Plant 

International Association of Machinists and Aerospace Workers (IAMAW) Local Lodge 778, Voluntary Protection Program (VPP) committee 

This is a non-public meethe request of the IAMALodge 778, which represworkers at the Kansas CThe NIOSH Team will pinformation on EEOICPand the Kansas City Planprofile to an audience coprimarily of the local unVPP committee and its occupational health and trainers. 

122 Worker 

Outreach 

9/2/2009 Laborers Local 660 

Union Hall, 2633 W Clay St, St Charles, MO 63301 

Weldon Spring Plant 

Member of Laborers Local 660. (This union supplied laborers and other trades workers to the Weldon Spring Plant during the operating period, as well as during the clean up period). 

This is a traditional workoutreach meeting to presWeldon Spring site profthe union''s regular monmeeting. NIOSH WorkeOutreach team: Stu HinMel Chew (ORAU), Maand Mary Elliott. Laurie may also attend. Mel Chgive the site profile pres

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  56 of 74 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

125 Non-NIOSH 9/16/2009 Shawnee State 

University, 740 Second Street, Sodexo Ballroom, Portsmouth, OH 45662 

Portsmouth Gaseous Diffusion Plant 

Individuals invited by the DOL Ombudsmans office 

This is a DOL Ombudsmmeeting. The purpose omeetings is to offer assiscurrent and former workPortsmouth Gaseous DifPlant with respect to the processing of Part E claito hear your grievances complaints concerning tprogram. 

126 Non-NIOSH 9/16/2009 Shawnee State 

University, 740 Second Street, Sodexo Ballroom, Portsmouth, OH 45662 

Portsmouth Gaseous Diffusion Plant 

Individuals invited by DOL Ombudsman 

This is a DOL Ombudsmmeeting. The purpose omeetings is to offer assiscurrent and former workPortsmouth Gaseous DifPlant with respect to the processing of Part E claito hear your grievances complaints concerning tprogram. 

127 Non-NIOSH 9/17/2009 Ohio University 

(Chillicothe Campus) 101 University Drive Bennett Hall Auditorium Chillicothe, OH 45601 

Portsmouth Gaseous Diffusion Plant 

Individuals invited by DOL Ombudsmans office 

This is a DOL Ombudsmmeeting. The purpose omeetings is to offer assiscurrent and former workPortsmouth Gaseous DifPlant with respect to the processing of Part E claito hear your grievances complaints concerning tprogram. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  57 of 74 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

128 Non-NIOSH 9/17/2009 Ohio University 

(Chillicothe Campus) 101 University Drive Bennett Hall Auditorium Chillicothe, OH 

Portsmouth Gaseous Diffusion Plant 

Individuals invited by DOL Ombudsmans office 

This is a DOL Ombudsmmeeting. The purpose omeetings is to offer assiscurrent and former workPortsmouth Gaseous DifPlant with respect to the processing of Part E claito hear your grievances complaints concerning tprogram. 

123 Worker 

Outreach 

9/22/2009 NIOSH Workshop on 

Dose Reconstruction and the Special Exposure Cohort (multi-site representation, others to be added as confirmed), Center for Worker Safety & Health Education, International Chemical Workers Union Council (ICWUC)/United Food and Commercia 

Oak Ridge National Laboratory (X10) 

Invited attendees from Former Worker Medical Screening Programs at DOE nuclear weapons facilities will learn about EEOICPA dose reconstruction and the SEC petitioning processes. 

The ATL Worker Outrewill host the 2-day workTuesday, September 22, Wednesday, September The NIOSH/OCAS Team present information on EPart B, dose reconstructithe SEC petitioning procATL team will conduct interactive exercises basOCAS presentations. 

124 Non-NIOSH 9/22/2009 The times and location 

of these meetings have not yet been determined. The OTS will be updated as the information becomes available. 

Area IV of the Santa Susana Field Laboratory 

DOL Ombudsmans Office meeting for workers from Santa Susana Field Laboratory. 

DOL meetings on Septeand 23, 2009 to provide information regarding thclass that was recently athe Santa Susana Field Laboratory. Stu Hinnefepossibly Lara Hughes wto represent NIOSH. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  58 of 74 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience Meeting Note 

129 Worker 

Outreach 

12/7/2009 USW Local 550 Union 

Hall, 2525 Cairo Rd., Paducah, KY 42001 

Paducah Gaseous Diffusion Plant 

United Steelworkers of America (USW) Local 550 members 

This is a non-public meeThe purpose of the meetdiscuss changes made to Paducah Site Profile sincORAU Worker Outreach met with the union in Fe2005. 

130 Worker 

Outreach 

12/8/2009 Western Kentucky 

Building Trades Council, 1930 N. 13th St. Paducah, KY 42001 

Paducah Gaseous Diffusion Plant 

Western Kentucky Building Trades Council affiliate members 

Non-public meeting to dthe changes made to the Paducah Site Profile sincNIOSH/ORAU team laswith the Council in Febr2005. 

Pending Meetings 

132 Worker 

Outreach 

3/23/2010 United Steelworkers of 

America (USW) Local 40 Union Hall, 712 Buffington St., Huntington, WV 25702 

Reduction Pilot Plant [Identified as Huntington Pilot Plant on NIOSH website] 

USW Local 40 Steelworkers Organization of Active Retirees (SOAR) 

This is an non-public mewith retirees, some of whave worked at the ReduPilot Plant, also known aHuntington Pilot Plant. will discuss the EEOICPwell as the Huntington PSite Profile. 

131 Worker 

Outreach 

4/20/2010 NIOSH Workshop on 

Dose Reconstruction and the Special Exposure Cohort (multi-site representation, others to be added as confirmed), International Chemical Workers Union Council (ICWUC)/United Food and Commercial Workers Union (UFCW) Center for Worker Safe 

Hanford, Reduction Pilot Plant 

Invited attendees from Former Worker Medical Screening Programs at DOE nuclear weapons facilities will learn about the EEOICPA dose reconstruction and SEC petitioning processes in a 2-day workshop. 

The ATL Worker Outrewill facilitate the 2-day won Tuesday, April 20, anWednesday, April 21, 20NIOSH/OCAS Team wiinformation on EEOICPdose reconstruction, and petitioning process. The Team will conduct interaexercises based on the Opresentations. At this timanticipates that attendeerepresenting workers froHanford, Iowa Ordnance 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  59 of 74 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ID Meeting 

Type 

Meeting 

Date 

Meeting Location 

Covered Site/s Meeting Audience 

NOTICE

wever, th

Meeting Note 

Paducah and Portsmouth Diffusion Plants, Mound and the Huntington Pilot may attend. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  60 of 74 

ATTACHMENT 4: DOCUMENTATION AVAILABLE IN OTS FOR CLOSED WORKE

EVENTS CONDUCTED UNDER OCAS-PR-012 

ID Meeting Type Date Action Items Assigned Notification of Meeting Sign-in Sheet File Presentation File Review Request Minutes Final Mee

O

37 

Worker Outreach 

(Workshop) 3/3/2009 No Yes Yes Yes NR 

39 SEC (SEC Outreach Meeting) 3/18/2009 No No No No No 

113 

SEC (SEC Worker 

Outreach Focus 

Group) 

4/28/2009 Action Item #3 No No No No 

There ar

notes" in 

than tradit

minutes

notice of 

was not 

SC&A or 

B

117 

Worker Outreach 

(SEC Outreach 

Meeting) 

8/11/2009 No No No No No 

118 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

8/11/2009 No NR NR NR NR 

119 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

8/11/2009 No NR NR NR NR 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  61 of 74 

ID Meeting Type Date Action Items Assigned Notification of Meeting Sign-in Sheet File Presentation File Review Request Minutes Final Mee

O

120 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

8/12/2009 No NR NR NR NR 

121 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

8/12/2009 No NR NR NR NR 

116 

Worker Outreach 

(Worker Outreach 

Town Hall) 

8/13/2009 No No No No No 

122 

Worker Outreach 

(Worker Outreach 

Town Hall) 

9/2/2009 Action Item #11 

There was no 

correspondence 

informing 

individuals of the 

meeting. 

No No No 

125 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

9/16/2009 No NR NR NR NR 

126 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

9/16/2009 No NR NR NR NR 

127 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

9/17/2009 No NR NR NR NR 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  62 of 74 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ID Meeting Type Date Action Items Assigned Notification of Meeting Sign-in Sheet File Presentation File Review Request Minutes 

NOTICE

wever, th

Final Mee

O

128 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

9/17/2009 No NR NR NR NR 

123 Worker Outreach (Workshop) 9/22/2009 No NR NR NR NR 124 

Non-NIOSH 

[Invited Forum 

(DOL Town Hall)] 

9/22/2009 No NR NR NR NR 

129 

Worker Outreach 

(Worker Outreach 

Town Hall) 

12/7/2009 No No No No No 

130 

Worker Outreach 

(Worker Outreach 

Town Hall) 

12/8/2009 No No No No No 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  63 of 74 

ATTACHMENT 5: SUMMARY OF ACTION ITEMS FOR ALL WORKER OUTREACH 

THE OUTREACH TRACKING SYSTEM THROUGH MARCH 12, 2010 

No. Facility Detail Commitment 

Date 

Current 

Status 

Resolution Detail Res

3 Mound Look into aqueous source term for 

polonium processing. 

8/28/2009 In process None 

7 Chapman 

Valve 

Former workers and their representatives provided NIOSH/ORAU with new/additional information: (1) date of fire; (2) existence/location of an incinerator used to burn uranium chips from lathing operations; (3) presence of enriched uranium (2.16%) on site; (4) questioned intake assumptions; (5) questioned upper bounds for internal exposure; (6) questioned air concentrations in comparison with other sites (NUMEC). 

2/14/2005 Legacy OCAS/ORAU revised the 

Chapman Valve Site Profile to include additional information based on worker input and data from the meeting and a subsequent e-mail from an attendee. 

10/

8 Fernald Meeting attendee commented that plant 

announcements were made concerning elevated radon levels following a project; stated that adding the information would be claimant favorable. 

6/28/2004 Legacy FMPC Site Profile Environmental 

Section revised (ORAUT-TKBS0017-4-Rev. 00 to Rev. 01): (1) Added totals to Tables 4.2a and 4.2b; (2) revised Tables 4.9a and 4.9b to include radon-222; (3) revised Table 4.10a to include intakes for uranium and nonuranium radionuclides; (4) revised table 4.10b to include site-wide intakes of radon-222; (5) added radon-222 concentrations to Table 4A in Appendix A. 

2

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  64 of 74 

No. Facility Detail Commitment 

Date 

Current 

Status 

Resolution Detail Res

9 Hanford Worker comments on Internal Dosimetry 

section of the Hanford Site Profile (ORAUT-TKBS-0006-5-Rev. 00): (1) Noted missing references for sources of data for calculations; (2) noted that Section 5.2.10 indicates that bioassay was considered "sufficient" and asked what NIOSH considers that to be; (3) ask how NIOSH determines exposures to isotopes such as neptunium that are harder to detect in bioassay (for unmonitored workers). A follow-up letter from the PACE local union provided more questions and additional information, as well as stating that the union disagrees with characterizations such as "strong radiation protection program" and "rigorous workplace monitoring." 

4/22/2004 Legacy Revision of Hanford Internal 

Dosimetry Section (ORAUTTKBS-0006-5 Rev00 to Rev. 01) revised to address worker input. Excerpt from Whisper: "discuss historical limits and tolerance dose; discuss separations plant (1944–1946) and 231-Z (1945–1946); clarify intakes in the 300 Area uranium fabrication and the laundry facilities; expand information on 241-Am and 241-Am MDAs for 1946 and 1967–6/1969; add section 5.2.4.1 on assignment of tritium doses; add Table 5.2.5-5 (MDAs for nonroutine uranium excreta analyses); revise Table 5.2.6-1 (Routine fission product analysis detection levels): add discussion of 214-Bi and 208-Tl in wholebody counting (section 5.3.1): expand section 5.7 on unmonitored workers; add tables and instruction to dose reconstructors for specific areas on the site; and include reference list that was inadvertently left out of the initial version.” 

11/

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  65 of 74 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

No. Facility Detail Commitment 

Date 

Current 

Status 

Resolution Detail Res

NOTICE

wever, th

10 Hanford Worker asked how information in the 

Site Description (ORAUT-TKBS-0006-2-Rev. 00) is validated. Stated that he worked in the B plant (during recovery operations) until Spring 1984. A subsequent letter from PACE local union concurs that the strontium and cesium recovery processes in 221-B operated until 1984, as well as pointing to conflicting information regarding dates for the operation. The letter also requests information on the ventilation problems in Building 303-J. 

4/22/2004 Legacy Revision of ORAUT-TKBS0006-2-Rev. 00 to Rev. 00 PC-1: 

A sentence was added on page 10 to reflect the fact that the 137-Cs and 90-Sr recovery operations at the B Plant were completed in September 1983 and February 1985, respectively. Also revised sentence on page 11 regarding the 137-Cs and 90-Sr recovery operations; changed the date from 1979 to 1978 on page 12; added one paragraph on page 14, section 2.3.5, discussing the ventilation problems in Building 303-L; deleted items on page 32. 

12/

11 Weldon 

Springs Plant 

[Redacted] worked during the initial cleanup. During the September 2 meeting, he stated that he was told during that time that there was not thorium in the disposal cell. Mel Chew responded that he would get back with [redacted] to let him know whether Th was present at the time. ([redacted] 

gave permission to be contacted, both in writing on the sign-in sheet and verbally to Mark Lewis). 

9/30/2009 Closed Mel Chew called [redacted] with 

the information regarding thorium at Weldon Spring during the initial cleanup period. See e-mail in Action Item File. 

10/
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  66 of 74 

ATTACHMENT 6: ORAUT-PROC-0097 FINDING DISPOSITION RECOMMEN

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-09 2 Conduct of Worker Outreach 11/9/07 SC&A Finding: There is a two-track process of interviews seeking site expert information. One is formal and relates m

subject of PROC-0097. The other is informal and appears to concern interviews with health physics personnel and otheras site experts. There is no formal documentation procedure for these interviews. 

4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 did not resolve this finding. Finding 4 of the OCAS-PR-012 procedure review includes a disc

track process for documenting and evaluating comments collected from outreach activities and site expert interviews. SC

finding be closed since it is duplicated under Finding 4 of the OCAS-PR-012 procedure review. 

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-08 1 Conduct of Worker Outreach 11/9/07 SC&A Finding: The procedure requires the audiotapes of the interviews to be destroyed after the minutes are finalized. 

without an affirmative sign-off from the interviewees or their representatives, though such a response is sought. 

4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 did not resolve this finding. Finding 5 of the OCAS-PR-012 procedure review includes discuaudiotapes. SC&A recommends this finding be closed, since it is duplicated under Finding 5 of the OCAS-PR-012 proc

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-07 4 Conduct of Worker Outreach 11/9/07 SC&A Finding: This procedure does not provide a mechanism for all stakeholders to provide comments. 4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 does not resolve this issue. Mechanisms such as the docket are available for submitting commformalized process for considering these comments. Improvement can be made in this area. SC&A recommends this fin

duplicated under Observation 4 of the OCAS-PR-012 procedure review. 

Date Procedure No. Finding No./Page No. Rating Procedure Title 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  67 of 74 

11/9/07 ORAUT-PROC-0097 PROC-0097-06 3 Conduct of Worker Outreach 11/9/07 SC&A Finding: This procedure clearly focuses on union and advocate organizations and does not define a method for e

other stakeholders (e.g., former and current non-union personnel). Also, although the procedure requires conflict of inteWOTL, these are not made available to participants either in writing or on the appropriate web site. 

4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 has expanded the opportunities for workers outside unions and organizations to provide input reconstruction and SEC process through workshops, SEC Worker Outreach meetings, invited forums, and town hall meeopportunities provide opportunities for participants to receive information from NIOSH. SC&A recommends that this aclosed. OCAS-PR-012 does not correct the issue associated with disclosure of conflict of interest at worker outreach meetings. finding be closed, since it is duplicated under Observation 4 of the OCAS-PR-012 procedure review. 

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-05 4 Conduct of Worker Outreach 11/9/07 SC&A Finding: Worker outreach meetings are specific to a particular site. In some cases, the location of the meeting so

facilities. NIOSH should make an effort to put the correct SPTL in contact with the participant. 

Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 has provisions for attendance of OCAS and ORAUT Health Physicists, the SEC Petition Coun

Support Contractor staff, and/or the SEC ombudsman. SC&A recommends closing this finding. 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  68 of 74 

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-04 4 Conduct of Worker Outreach 11/9/07 SC&A Finding: The procedure does not explicitly require worker outreach meetings for all sites where site profiles are 

refers to ORAUT-PLAN-0010, which has such a specification. 

Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. Under ORAUT-PROC-0097, the focus of outreach meetings was dominated by site profile development. ORprovided an implementation plan for ORAUT-PROC-0097 is also no longer effective. The current outreach program is activities related to SEC petitions and site profile updates, many of which are information giving meetings. Generic crit

to schedule and conduct outreach meetings in OCAS-PR-012. Legacy issues exist from the period of time when ORAU

effect. The lack of worker outreach meetings supporting site profile development, historically, has not been resolved an

to gaps in current site profiles. A specific example was addressed in the SC&A Sandia National Laboratory Livermore srecommends that a review of those site profiles, where no worker outreach was conducted be re-evaluated to determine wwould benefit from an information gathering meeting. 

4/1/10 

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-03 4 Conduct of Worker Outreach 11/9/07 SC&A Finding: Some guidance is provided in relation to which comments require a response. Also, there is some room 

as to who is included in the worker outreach program. A de facto two-track system—one governed by ORAUT-PROC-organizations and one for site experts, such as health physicists—appears to exist. However, the site expert track is not f

procedure. 

Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. ORAUT-PROC-0097 was canceled and replaced with OCAS-PR-012, Worker Outreach Program. OCAS-PR

eliminated any guidance in relation to comment response. Finding 1 and Finding 4 of the OCAS-PR-012 procedure dupfinding. SC&A recommends this finding be closed, since it is covered under Finding 1 and Finding 4 of the OCAS-PR-

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 9, 2010 

Revision No.  0 

Document No. 

SCA-TR-PR2010-0002 

Page No.  69 of 74 

: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

Ho is report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE

wever, th

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-02 3 Conduct of Worker Outreach 11/9/07 SC&A Finding: There is linkage between ORAUT-OTIB-0097 and ORAUT-PROC-0031 (Site Profile and Technical B

Development). Also, this is the only procedure that requires destruction of information, i.e., the audiotapes of the meetin

finalization of the minutes. 

4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 did not mitigate this finding. Finding 5 of the OCAS-PR-012 procedure review includes discu

audiotapes. SC&A recommends this finding be closed, since it is duplicated under Finding 5 of the OCAS-PR-012 proc

Date Procedure No. Finding No./Page No. Rating Procedure Title 

11/9/07 ORAUT-PROC-0097 PROC-0097-01 4 Conduct of Worker Outreach 11/9/07 SC&A Finding: The procedure emphasizes outreach to union representatives and should be expanded to include all wor

addition, there is no provision for classified interviews. 

4/1/10 Recommended Action to Procedures Working Group: ORAUT-PROC-0097 was canceled and replaced with OCAS-PR

Program. OCAS-PR-012 has expanded the opportunities for workers outside unions and organizations to provide input reconstruction and SEC process through workshops, SEC Worker Outreach meetings, invited forums, and town hall meeopportunities provide opportunities for participants to receive information from NIOSH. OCAS-PR-012 does not require that participants be told not to disclose classified or potentially classified information whThere are no requirements to notified participants that alternative arrangements can be made should they want to share c

classified information. SC&A recommends this finding be closed, since it is covered under Observations 1 and 2 of the review. 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 70 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 7: MISSION STATEMENT AND DRAFT 

IMPLEMENTATION PLAN FOR THE WORKER OUTREACH WORK 

GROUP 

The Advisory Board of Radiation and Worker Health 

Work Group on Worker Outreach 

Implementation Plan 

Presented to the Advisory Board February 11, 2010

Mission Statement 

The Worker Outreach Working Group defined the following mission statement. 

The mission of the Advisory Board on Radiation and Worker Health's Worker 

Outreach Work Group is to evaluate the effectiveness of NIOSH activities in 

obtaining and making use of information from current and former workers and 

their representatives. The mission also includes monitoring and evaluating the 

effectiveness of NIOSH sources of assistance to assure this information is 

available to as many potential EEOICPA claimants as possible. 

To supplement this mission statement, the Advisory Board requested an implementation plan 

from the working group for further definition of the tasks to be completed. Unless otherwise 

specified, the term “worker” in this document includes nuclear weapons workers, claimants, 

petitioners, as well as representatives of any of them. 

Scope of Worker Outreach Working Group 

The current worker outreach procedure, OCAS-PR-012, Worker Outreach Program, issued on 

March 2, 2009, redefines the scope of worker outreach (OCAS 2009a). The procedure identified 

four types of outreach meetings: Worker Outreach Focus Group meetings, SEC Worker 

Outreach Focus Group meetings, Worker Outreach Town Hall meetings, and SEC Outreach 

meetings. Other types of meetings mentioned in OCAS-PR-012 include dose reconstruction 

workshops, and participation in meetings held by the Department of Labor (DOL). Detailed 

descriptions of meeting types are available in OCAS-PR-012. Further clarification of the 

definition of worker outreach was requested by the working group on June 16, 2009. OCAS 

provided input to the working group on June 24, 2009 (OCAS 2009b). Based on the definition 

of worker outreach provided by NIOSH, there are two general types of outreach meetings; 

information gathering meetings and information giving meetings. Some types of meetings both 

provide as well as gather information from workers, petitioners, and advocates. OCAS outreach 

meetings specifically include the following: 

Information Gathering 

 SEC Petition Evaluation Report Issues 

 Site Profile/Technical Basis Document Development 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 71 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Information Giving/Gathering 

 SEC Petition Process Education 

 Town Hall Meetings to Educate about Changes in Site Profile/TBD 

Other Outreach Venues (information giving and gathering) 

 Dose Reconstruction Workshops 

 Advisory Board Meetings 

 Invited Forums 

 Website/Docket 

In addition to the worker and public outreach meetings, there are several sources of recurring 

information which should be collected and tracked for potential use in NIOSH technical work 

documents. Among those sources are Computer Assisted Telephone Interviews (CATIs), Public 

Health Advisor (PHA) meetings, Closeout Interviews (COIs), worker outreach databases (e.g., 

Top Hats, WISPR), and information letters. Reports from the NIOSH Ombudsman and SEC 

Petition Counselor should also be scanned for similar repetitive data. Tracking would focus on 

information provided by site operations, radiation protection, and incident reports, as 

distinguished from comments on individual cases. 

Objectives 

The evaluation will be conducted by the work group under the following framework. 

Evaluation Objective #1: Determine whether OCAS is taking appropriate measures to 

solicit worker input into site profiles, SEC petition evaluations, and other technical 

documents.

Examine the procedures and processes by which OCAS solicits the involvement of workers by 

reviewing the following: 

 How does OCAS determine whether an outreach meeting is to be conducted for a 

facility? 

 How does OCAS identify and inform workers of the opportunities for input and followup to secure participation? 

 Is the Outreach Tracking System (OTS) scheduling and notification system adequate? 

 Are participants in outreach meetings notified in a timely manner? 

 Are arrangements made to participate for those interested but unable to travel to outreach 

meetings? 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 72 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Examine several examples of OCAS solicitations and follow-up associated with several 

particular work products. 

 Were the procedures followed and effective in practice? 

 Did OCAS make an appropriately extensive effort to elicit broad and substantial 

participation from workers? 

 Are there additional or improved methods for OCAS to consider? 

Evaluation Objective #2: Determine whether OCAS is obtaining and documenting input 

from workers. 

Review all OCAS and contractor processes and procedures associated with obtaining and 

documenting worker input. 

 How does OCAS document worker input from information gathering meetings and other 

venues? 

 Does OCAS have a method for noting re-occurring issues associated with worker 

communication from various venues? 

Review a sampling of interviews and meetings where the above-referenced processes and 

procedures were implemented by OCAS and its contractors to determine whether they were 

followed and effective in practice. 

 Was the desired information obtained and documented? 

 Is the documentation of participants’ comments accurate and complete? 

 Is the draft of the meeting record available for appropriate participant review? 

 Did the participants avail themselves of the opportunity to comment on the draft meeting 

record? 

 Were comments incorporated into the final meeting record? 

 Was the finalized meeting record made available in a timely manner to participants 

requesting copies? 

 

Evaluate the conduct of outreach meetings. 

 Is technical staff present at information outreach meetings where appropriate? 

 Were appropriate introductory statements made at the beginning of the meeting? 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 73 of 74 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

 Was there adequate time for presentations by OCAS? 

 Were participants allowed adequate opportunity to provide comments? 

 Are provisions made that are appropriate for interviews in a classified setting should the 

need arise? 

 Are presentations developed at the appropriate level for the participants of the meeting? 

 Are sign-in sheets utilized for outreach meetings so that attendees can be contacted, if 

needed, with follow-up information or questions? 

 Are questions appropriate to solicit the desired information? 

Evaluate the completeness and adequacy of the Outreach Tracking System (OTS). 

 Does the OTS reflect the breadth and depth of the information provided by workers at the 

meetings? 

 Did OTS integrate action items accepted by OCAS or its contractors during the course of 

the meeting? 

 Were participant comments provided at information giving meetings included in OTS? 

 Is OTS an adequate method for documenting and tracking worker comments? 

Evaluate OCAS’s tracking system for identifying trends in worker comments. 

 Has OCAS documented repetitive or reoccurring issues on a site-wide or program-wide 

basis? 

Evaluation Objective #3: Determine whether OCAS is giving thorough consideration to 

information received from workers through the worker outreach efforts, incorporating 

consideration of that material into its work products, as appropriate, and adequately 

communicating the impact of substantive comments to workers. 

Examine the process by which OCAS and its contractors evaluate worker input. 

 How does OCAS catalog and consider worker input for inclusion into its technical 

documents such as site profiles and SEC evaluation reports? 

 What criteria are used to identify comments that deserve consideration for a response or 

action by NIOSH? 

 Are the appropriate personnel evaluating the comments received? 
Effective Date: 

April 9, 2010 

Revision No. 

 0 

Document No. 

SCA-TR-PR2010-0002 

Page No. 

 74 of 74 

 This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

 Were follow-up discussions held with participants providing substantive comments, when 

necessary? 

 What processes and procedures are place to ensure that NIOSH is following up on the 

response and action items? 

 How is feedback provided to the workers in response to their comments? 

 Did OCAS conduct research to evaluate substantive comments by participants and assess 

their impact on NIOSH documents, processes, and procedures? 

Conduct a systematic review of worker outreach database(s) (at a point in time) in relation to its 

impact on technical documents. 

 Select a sample of Site Profiles and SEC Evaluation Reports where worker outreach 

meetings have been done to document whether and how worker input has been 

considered and included and evaluate if exclusions were appropriate. 

 Were the action items in OTS (or responses in WISPR and predecessor databases) 

appropriate to the comments received? 

 Were recurrent issues appropriately responded to? 

 Are comments applicable to the DOL portion of the process forwarded to DOL for 

consideration? 

References 

ABRWH, 2007, Transcripts from Meeting 44 of the Advisory Board on Radiation and Worker 

Health, Volume IV, Day Three, Mason, Ohio, February 9, 2007. 

OCAS, 2009a, Worker Outreach Program, OCAS-PROC-012, Office of Compensation and 

Analysis, National Institute for Occupational Safety and Health, Cincinnati, Ohio, March 2, 

2009. 

OCAS, 2009b, Types of NIOSH Public Meetings, National Institute for Occupational Safety and 

Health, Cincinnati, Ohio, June 24, 2009.