November 29, 2017 

DISCLAIMER: This is a working document provided by the Centers for Disease Control and Prevention (CDC) technical support contractor, SC&A, for use in 

discussions with the National Institute for Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker Health (ABRWH), including its 

Working Groups or Subcommittees. Documents produced by SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or ABRWH 

products or positions, unless specifically marked as such. This document prepared by SC&A represents its preliminary evaluation on technical issues.

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

ISSUES RESOLUTION MATRIX FOR ORAUT-OTIB-0017, REVISION 01,

“INTERPRETATION OF DOSIMETRY DATA FOR ASSIGNMENT OF SHALLOW DOSE” 

Finding 

Number Finding Description NIOSH Response Finding Resolution 

1 The OTIB needs to provide additional 

guidance regarding how to interpret film badge 

data with respect to beta vs. low-energy photon 

exposure for the purpose of reconstructing 

shallow doses. 

It is suggested that the dose reconstructor 

check whether the site was reporting dose due 

to electrons or photons, and whether the 

dosimetry system had been calibrated for that 

type of radiation. 

DR staff has access to that type of information in 

the site profile documents and other supporting 

documentation such as TIBs. For example, an 

SRS claim would make use of Attachment B to

ORAUT-OTIB-0017 (Attachment B, “Skin Dose 

Assignment for Savannah River Site Cases”), 

OCAS-TIB-0006 (Section 3, “Shallow Dose 

Interpretation”), and the site profile document. In 

addition, there is evidence of over-response of 

film dosimeters to low-energy photons (as 

discussed on page 9 of ORAUT-OTIB-0017). 

The Subcommittee for Procedure Reviews

(SCPR) found NIOSH’s response acceptable 

and closed this finding. 

2 The OTIB assumes that the protective clothing 

used for each case was known in the majority 

of cases and the appropriate clothing-specific 

transmission factors can be selected. 

NIOSH explained that there is language in the 

OTIB that allows the dose reconstructor to 

choose the appropriate clothing shielding factors 

based on whether a minimizing, maximizing, or 

a realistic analysis of beta dose is being 

performed. SC&A concurs with this response. 

The SCPR found NIOSH’s response 

acceptable and closed this finding. 
Issues Resolution Matrix for OTIB-0017 2 SC&A – November 29, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution 

3 It is SC&A’s opinion that individual 

monitoring for beta particles only works on a 

“yes/no” basis. The main concern is that a 

person may experience direct deposition of a 

hot particle on the skin or localized undetected 

beta exposure, and it is not detected, and the 

worker develops skin cancer later in his life. 

SC&A Follow-up: To improve the dose-to-theskin reconstruction, the following should be 

considered: 

– When the cancer site is on the hands, lower 

arm or face? Use workplace monitoring data. 

– When the cancer site is on the thorax? Use 

individual monitoring data. 

– When the cancer site is on the lower legs or 

feet? Use both.

OCAS and ORAUT disagree with this position. 

Consideration of geometry issues is discussed in 

the OTIB in the “Exposure Geometry” section,

and it is discussed in the DR reports on a caseby-case basis. It is incumbent on the DR staff to 

analyze and discuss the potential for 

overestimating or underestimating electron dose 

with respect to the cancer location. In addition, 

ORAUT-OTIB-0017 recommends a claimantfavorable dose conversion factor of 1.0 for 

application of measured electron dose to the 

skin. 

SC&A recommended that Finding 3 be 

closed, not because everything is resolved, 

but because OTIB-0017 cannot be improved 

much further. The SCPR agreed with 

SC&A’s recommendation and closed 

Finding 3 with an outstanding Action Item 

on how to handle the hot particle issue. 

It should be noted that as a result of these 

discussions, the skin exposure concern

became an overarching issue and was 

addressed in NIOSH-OVER-0009. 

4 It is possible to state definitely where the 

cancer site is, but not where the contamination 

was. 

Other data can be available to DR staff, such as 

claimant interview information and 

contamination incident reports. In addition, some 

work tasks involved partial body irradiation to 

specific locations of the body that will be 

apparent to DR staff familiar with the site 

operations through the use of the site profile and 

other supporting documentation. In situations 

where the location of the partial-body exposure 

is not known, guidance in the section titled 

“Non-Uniform Exposure of the Skin of OTIB0017” regarding the development of a lognormal 

distribution of dose due to potential skin 

contamination can be used. 

Because Finding 4 also relates to the 

resolution of Finding 3, the SCPR transferred 

this finding to Finding 3 and closed it

according to the resolution of Finding 3. 
Issues Resolution Matrix for OTIB-0017 3 SC&A – November 29, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution 

5 A skin dose due to hot particle exposure will 

not be detected because of the localized nature 

of the exposure. 

Non-uniform dose can be considered by the DR 

using the guidance in the OTIB along with tools 

such as VARSKIN and guidance from site 

profile documents regarding the potential for hot 

particle exposure. As shown in the literature (see

the Merwin and Moeller reference in the OTIB), 

hot particle dose can be extremely variable, thus 

making it difficult to establish a reference hot 

particle skin dose. If this were possible, codes 

such as VARSKIN would not exist. 

Because Finding 5 also relates to the 

resolution of Finding 3, the SCPR transferred 

this finding to Finding 3and closed it

according to the resolution of Finding 3. 

6 SC&A questions why an adjustment is needed 

to an LOD value. If the dosimeter result was 

reported as an LOD value, then this value 

should be used as the basis for the missed dose 

calculation. 

Follow-up: There were lengthy discussions 

about the calibration of dosimeters for low- vs. 

high-energy photons and what values should 

be assigned to a worker who was exposed to 

low-energy photons but the dosimeter was 

calibrated for high-energy photons. SC&A 

prepared a white paper on this issue that

concluded the following: “If it is known that 

the film badge dosimeter overstated the dose 

from low-energy photons, and if it can be 

further ascertained that the LOD was 

expressed in terms of this overstated dose 

rather than the corrected dose, then we agree 

that it is appropriate to apply a correction 

factor to the LOD in assigning a missed dose 

from low-energy photons.” 

An adjustment to LOD is needed for the 

technical reasons stated in this section 

(over-response of film to low-energy photons). 

Based on SC&A’s white paper on 

OTIB-0017, NIOSH and SC&A concluded 

that they were in agreement. The SCPR 

concurred with this resolution and closed 

Finding 6. 
Issues Resolution Matrix for OTIB-0017 4 SC&A – November 29, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution 

7 In Attachment A, “Non-Penetrating Doses to 

Organs Other Than the Skin,” it is not claimant 

favorable to consider that the employee had 

4 mm of clothing thickness over the penis. 

Since the organ discussed in this section is the 

penis, the 4-mm assumption was made for pants 

and an undergarment – not a lab coat (although 

that could have been added), sweater, or shirt. 

The 4 mm measurement was confirmed a second 

time for this response.

SC&A and the SCPR found this explanation 

acceptable, and the SCPR closed Finding 7. 

8 Attachment A provides a correction factor for 

the breast, penis, and testicle using a source 

that was modeled as a 10-cm2 infinitely thin 

disc source located 2 cm away from the skin.

For the breast area, the film dosimeter would 

give a reasonable dose estimate. However, if 

the source was near the testicles, the film 

dosimeter would not measure anything. 

The comment is not relevant to the discussion in 

this section, which is related to modeling that 

was performed to determine appropriate 

correction factors for a range of beta energies. A 

discussion of dosimeter exposure geometry is 

provided on page 7 of the OTIB. 

There was extensive discussion about other 

documents that address this issue and whether 

this document should cross-reference those 

documents. It was agreed that such a crossreferencing would be burdensome, given the 

evolving nature of the guidance documents. 

NIOSH explained that it currently relies on QA 

and training to ensure that the full array of 

guidance documents are being correctly 

employed in individual dose reconstructions. 

NIOSH also pointed out that the workbooks are 

designed to integrate the guidance contained in 

multiple documents, which also helps to prevent

this problem from arising.

The SCPR concluded that the guidance in the 

OTIB with respect to this issue is adequate 

and closed Finding 8. 

9 Tables A-1 and A-2 list correction factors for 

non-penetrating doses based on radionuclide. 

However, in nearly all cases, it is not possible 

to state the radionuclides that are responsible 

for the beta dose. 

The table provides benchmark correction factors 

for a range of beta energies. Site profile 

documents will typically provide information 

that will help the DR determine the proper 

energy range to use. In addition, the OTIB itself 

provides guidance with respect to uranium 

daughter products. 

SC&A and the SCPR agreed with NIOSH’s

response, and the SCPR closed Finding 9. 
Issues Resolution Matrix for OTIB-0017 5 SC&A – November 29, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution 

10 OTIB-0017 states that correction factors for lip 

dose are most notable for low-energy beta 

sources with maximum energies <500 keV. 

However, for low-energy beta radiation, the 

dosimeters were likely incapable of furnishing 

accurate doses.

DR staff would have to consider this on a caseby-case basis. The purpose of the OTIB is to 

provide general information for the DR staff to 

use along with other sources of information. If 

necessary, the hierarchy of data sources listed in 

IG-001 (Table 1.1) and PROC-0006 (Table 5.2) 

includes the use of source term modeling. 

SC&A and the SCPR agreed with NIOSH’s

response, and the SCPR closed Finding 10. 

11 It is not clear why the two tables providing 

examples of skin dose assignments on pages 

21 and 24 give the recommendation to assign 

30–250 keV for missed dose to the skin for 

0 “OW reading” and 0 “S reading.”

This radiation type and energy range was chosen 

because it is, in fact, claimant favorable 

compared to assigning the dose as electron dose 

(see IREP Technical Document).

SC&A and the SCPR agreed with NIOSH’s

response, and the SCPR closed Finding 11. 

12 The logical order of the information in 

Chapter 3, “General Approach,” could be 

improved. 

NIOSH agrees with SC&A’s finding. OTIB 

documents are revised for clarity as project time 

and resources allows. NIOSH will revise 

OTIB-0017 accordingly in the future. 

The SCPR agreed, and the finding was 

placed In Abeyance until NIOSH has the 

opportunity to revise the OTIB. 

13 The OTIB does not identify any cases where a 

possibly high POC can be determined early in 

the investigation.

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

that would be used by DR staff to quickly triage 

a claim to determine the potential for high POC. 

It is important to consider the use of OTIB-0017 

in the overall context of the DR process. In 

addition, OTIB-0017 does give guidance on the 

topic of low/high POC potential on page 6, 

items a, b, and c. 

SC&A and the SCPR agreed with NIOSH’s

response. No further action is required, and 

the SCPR closed Finding 13. 

14 The OTIB is not claimant favorable in 

instances of unknown parameters affecting 

dose estimates.

OCAS and ORAUT disagree with this position. 

Consideration of geometry issues is discussed in 

the OTIB and is addressed on a case-by-case 

basis. In addition, the OTIB makes a 

recommendation (i.e., DCF = 1) to accommodate 

potential inaccuracies due to exposure geometry. 

The OTIB is claimant favorable in its 

recommendations regarding DCF, LOD, 

attenuation, and radiation type/energy range. 

SC&A and the SCPR agreed with NIOSH’s

response. No further action is required, and 

the SCPR closed Finding 14. 
Issues Resolution Matrix for OTIB-0017 6 SC&A – November 29, 2017

NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Finding 

Number Finding Description NIOSH Response Finding Resolution 

15 The OTIB does not employ scientifically valid 

protocols for reconstruction of doses: 

(a) Page 6, item 3, of the OTIB states, “Assign 

the non-penetrating dose as electrons 

>15 keV...or photons < 30 keV if the 

employee worked in a plutonium facility.” 

Either the dose was originally calculated as 

being due to electrons for betas or the 

equivalent calculation was made for 

photons. 

(b)The assumption of 4 mm thickness of 

clothing for beta radiation shielding is not 

claimant favorable.

(c) The treatment of hot spots is not adequate. 

OCAS and ORAUT disagree with this position. 

Regarding item (a):

The guidance is given in order to assign the nonpenetrating dose as electrons or low-energy 

photons as necessary to complete a valid dose 

reconstruction using IREP. Dose is often given 

as “OW” and “S” or “shallow” and “deep” – not 

beta and gamma (although that condition does 

occur and DR staff will use that information in 

their analysis). 

Regarding item (b): 

Since the organ discussed in this section of the 

OTIB is the penis, the 4-mm assumption was 

made for pants and an undergarment – not a lab 

coat (although that could have been added), 

sweater, or shirt as recommended in the general 

comments section of the SC&A review. The 

4-mm measurement for pants and an 

undergarment was confirmed a second time for 

this response. The selection of this clothing for 

this organ is appropriate. 

Regarding item (c):

Non-uniform dose can be considered by the DR 

using the guidance in the OTIB along with tools 

such as VARSKIN and guidance from site 

profile documents regarding the potential for hot 

particle exposure. Additional information can be 

gained by analyzing claimant records and 

interviews.

SC&A and the SCPR agreed with NIOSH’s

response. No further action is required, and 

the SCPR closed Finding 15. 

DCF = dose conversion factor; DR = dose reconstruction; IREP = Interactive RadioEpidemniological Program; LOD = limit of detection; OTIB, TIB = technical information bulletin;

POC = probability of causation; QA = quality assurance; SCPR = Subcommittee for Procedure Reviews; SRS = Savannah River Site