Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

PRE-REVIEWS OF REVISED DOCUMENTS 

ORAUT-OTIB-0005, ORAUT-PROC-0031, 

ORAUT-PROC-0061, AND ORAUT-OTIB-0020

Contract No. 200-2009-28555 

Prepared by 

Joyce Lipsztein

Stephen Ostrow 

Harry Pettengill 

Stephen Marschke 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

January 2013 

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 42 CFR 82. 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:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

2 of 10

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.

S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of NIOSH 

Dose Reconstruction Program

Document No. 

Pre-Review of Revised Documents

Effective Date: 

Draft – January 25, 2013

PRE-REVIEWS OF REVISED DOCUMENTS 

ORAUT-OTIB-0005, ORAUT-PROC-0031, 

ORAUT-PROC-0061, AND ORAUT-OTIB-0020

Page 2 of 10

Task Manager:

________________________ Date: ___________

Stephen F. Marschke

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewers:

 John Stiver

 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 01/25/2013 Initial issue.
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

3 of 10

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

Acronyms and Abbreviations ..........................................................................................................4

1.0 Introduction..........................................................................................................................5

2.0 Documents Previously Reviewed by SC&A .......................................................................6

2.1 ORAUT-OTIB-0005 – Internal Dosimetry Organ, External Dosimetry 

Organ, and IREP Model Selection by ICD-9 Code .................................................6

2.1.1 Purpose of the Technical Information Bulletin............................................6

2.1.2 Pre-Review Conclusions..............................................................................6

2.2 ORAUT-PROC-0031 – Site Profile and Technical Basis Document 

Development............................................................................................................6

2.2.1 Purpose of the Procedure .............................................................................7

2.2.2 Pre-Review Conclusions..............................................................................7

2.3 ORAUT-PROC-0061 – Occupational Medical X-Ray Dose Reconstruction 

for DOE Sites...........................................................................................................7

2.3.1 Purpose of the Procedure .............................................................................7

2.3.2 Pre-Review Conclusions..............................................................................8

2.4 ORAUT-OTIB-0020 – Use of Coworker Dosimetry Data for External Dose 

Assignment ..............................................................................................................8

2.4.1 Purpose of the Procedure .............................................................................8

2.4.2 Pre-Review Conclusions..............................................................................9

3.0 Documents Previously Reviewed by SC&A .....................................................................10
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

4 of 10

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.

ACRONYMS AND ABBREVIATIONS

Advisory Board

 or Board Advisory Board on Radiation and Worker Health

DCAS Division of Compensation Analysis and Support

DOE (U.S.) Department of Energy

EEOICPA Energy Employee Occupational Illness Compensation Program Act of 2000

ET extrathoracic region

ICD International Classification of Diseases

ICRP International Commission on Radiological Protection

IREP Interactive RadioEpidemiological Program

NIOSH National Institute for Occupational Safety and Health

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

PROC Procedure

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

SP Site Profile

TBD Technical Basis Document

TIB Technical Information Bulletin

WHO World Health Organization
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

5 of 10

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.

1.0 INTRODUCTION

As the technical contractor to the National Institute for Occupational Safety and Health 

(NIOSH), Division of Compensation Analysis and Support (DCAS), the Oak Ridge Associated 

Universities Team (ORAUT) performs dose reconstructions under the Energy Employee 

Occupational Illness Compensation Program Act of 2000 (EEOICPA). As technical support 

contractor to the Advisory Board on Radiation and Worker Health (Advisory Board), S. Cohen 

& Associates (SC&A) performs (at the Advisory Board’s direction) technical reviews of the 

work performed by both DCAS and ORAUT. As part of that responsibility, the Advisory Board 

recently had SC&A review the ORAUT list of approved procedures and other documents to 

determine if any were candidates for review. SC&A identified five previously reviewed 

documents that had been revised by ORAUT two or more times since the SC&A review, and 

thus, could be considered as candidates for re-review. The five identified ORAUT documents 

are:

(1) ORAUT-OTIB-0005, Internal Dosimetry Organ, External Dosimetry Organ, and 

IREP Model Selection by ICD-9 Code (ORAUT 2011a)

(2) ORAUT-PROC-0031, Site Profile and Technical Basis Document Development

(ORAUT 2011b)

(3) ORAUT-PROC-0061, Occupational Medical X-Ray Dose Reconstruction for 

DOE Sites (ORAUT 2010)

(4) ORAUT-OTIB-0020, Use of Coworker Dosimetry Data for External Dose 

Assignment (ORAUT 2011c)

(5) ORAUT-PROC-0066, Quality Assurance Records Management (ORAUT 2009)

During its June 20, 2012, meeting, the Board discussed what to do with these five documents. 

Since ORAUT-PROC-0066 was not a “technical” document, the Advisory Board felt that it did 

not merit an additional review. The Board tentatively tasked SC&A to re-review the other four 

documents, but indicated that a final decision on approval would be provided by the Procedures 

Subcommittee, after the Subcommittee discussed the merits of re-reviewing each document.

At its July 31, 2012, meeting, the Procedures Subcommittee expressed concern that the changes 

to each of the four documents being considered for re-review may not warrant the expenditure of 

effort that is required to prepare for, perform, and document a full review. With this in mind, it 

was decided that SC&A should perform a pre-review to determine the nature and extent of the 

changes that were made to each document in question since originally reviewed. This report 

presents the results of those four pre-reviews.
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

6 of 10

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.

2.0 DOCUMENTS PREVIOUSLY REVIEWED BY SC&A

2.1 ORAUT-OTIB-0005 – INTERNAL DOSIMETRY ORGAN, EXTERNAL 

DOSIMETRY ORGAN, AND IREP MODEL SELECTION BY ICD-9 CODE

This pre-review of ORAUT-OTIB-0005, Internal Dosimetry Organ, External Dosimetry Organ, 

and IREP Model Selection by ICD-9 Code, Revision 4, dated April 18, 2011, was prepared by 

Joyce Lipsztein, PhD. In January 2005, Dr Lipsztein performed SC&A’s original review of 

OTIB-0005, Revision 1, dated January 23, 2004. Three findings were identified in the original 

review; all three findings have been addressed by the Subcommittee and closed.

2.1.1 Purpose of the Technical Information Bulletin

The stated purpose of OTIB-0005 is to provide guidance:

... on selection of (1) the appropriate International Commission on Radiological 

Protection (ICRP) organ or tissue model to estimate the internal dose for specific 

codes from the World Health Organization’s (WHO) International Classification 

of Diseases, Ninth Revision (ICD-9; WHO 1977), (2) the appropriate organs or 

tissues to estimate external dose, and (3) the appropriate model in the Interactive 

RadioEpidemiological Program (IREP). This TIB also provides information for 

selecting and assessing likely primary cancers for secondary cancers.

2.1.2 Pre-Review Conclusions

It was determined that a full re-review of ORAUT-OTIB-0005 is not needed. The previous issue 

with OTIB-0005 was that it did not reflect the fact that International Commission on 

Radiological Protection (ICRP) Publication 66 recommended that the oral cavity should be part 

of the extrathoracic region 2 (ET2). The new ICRP Publication 103 (ICRP 2007) does not 

recommend the inclusion of the oral cavity as part of ET2. Instead, the oral mucosa is now part 

of the remainder. Thus, a re-review is not needed and OTIB-0005, Revision 4, may be accepted 

without further comments.

2.2 ORAUT-PROC-0031 – SITE PROFILE AND TECHNICAL BASIS DOCUMENT

DEVELOPMENT

This pre-review of ORAUT-PROC-0031, Site Profile and Technical Basis Document 

Development, Revision 3, dated November 14, 2011, was prepared by Stephen Ostrow, PhD. In 

August 2007, Dr. Ostrow performed SC&A’s original review of PROC-0031, Revision 1, dated 

December 15, 2005. Two findings were identified in the original review; both findings have 

been addressed by the Subcommittee and closed.
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

7 of 10

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.

2.2.1 Purpose of the Procedure

The stated purpose of ORAUT-PROC-0031 is to provide guidance:

...for establishing SP/TBD [Site Profile/Technical Basis Document] Teams to 

develop and revise SPs/TBDs, and it defines the structure and content of 

SPs/TBDs.

2.2.2 Pre-Review Conclusions

SC&A’s pre-review of PROC-0031, Revision 3 (November 14, 2011), found that there are no 

material technical changes to the document from Revision 1, which was originally reviewed. 

Additionally, PROC-0031 is a procedural, rather than technical, document. Hence, a full rereview is not required and PROC-0031, Revision 3, may be accepted without further comments.

SC&A’s general impression is that PROC-0031, Revision 3, is a substantial improvement over 

the earlier version, in that it is clearer and more detailed as to the steps and considerations 

involved in producing an SP/TBD. However, SC&A did not check the accuracy of the many 

references to other documents made in PROC-0031.

2.3 ORAUT-PROC-0061 – OCCUPATIONAL MEDICAL X-RAY DOSE 

RECONSTRUCTION FOR DOE SITES

The pre-review of ORAUT-PROC-0061, Occupational Medical X-Ray Dose Reconstruction for 

DOE Sites, Revision 3, dated March 3, 2010, was prepared by Harry Pettengill, PhD. In August 

2007, Dr. Pettengill performed SC&A’s original review of PROC-0061, Revision 0, dated 

December 1, 2004. Four findings were identified in the original review; three of the findings 

have been addressed by the Subcommittee and closed. The fourth finding (PROC-0061-04), 

whose resolution remains in progress, is:

The dose reconstructor is not advised to make corrections for retakes or 

additional exposures due to poor technique or processing—the estimated 

“maximizing” dose may not be claimant favorable.

2.3.1 Purpose of the Procedure

The stated purpose of ORAUT-PROC-0061 is to provide direction:

...on reconstruction of doses from occupational medical X-rays for the Oak Ridge 

Associated Universities (ORAU) Team Dose Reconstruction Project for the 

National Institute for Occupational Safety and Health (NIOSH). The Energy 

Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA)

requires the assignment of external dose from medical X-ray examinations that 

were performed for occupational health screening and required as a condition of 

employment. This procedure relies on information in site technical basis 

documents (TBDs), and it supersedes some of the instructions for X-ray dose 

reconstruction in ORAUT-PROC-0006 Rev. 01, External Dose Reconstruction.
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

8 of 10

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.

2.3.2 Pre-Review Conclusions

The conclusions from SC&A’s pre-review of ORAUT-PROC-0061, Revision 3, are as follows:

(1) As stated above, SC&A originally had four concerns regarding PROC-0061, Revision 0; 

the first three were adequately addressed, have since been closed, and have been 

incorporated in PROC-0061, Revision 2.

(2) The one “In Progress” finding is not addressed directly in Revision 3, but is handled in 

the other documents that the dose reconstructors are directed to consider. Finding PROC0061-04 dealt with the impact on dose due to x-ray retakes. SC&A’s concern was that 

PROC-0061 stated that the impact of retakes was less than 3% and referenced the Trout 

black lung study (Trout et al. 1973). SC&A believed that 3% was too low. In 

Revision 3, ORAUT has moved the reference table for x-ray dose assignments to the “O” 

drive, thereby ensuring that the latest versions from the TBD, updated TIBs, etc., are used 

by dose reconstructors. It also transfers the 3% retake issue from PROC-0061 into the 

realm of SP/TBD reviews. SC&A believes that these steps adequately address our 

remaining concern with PROC-0061, and recommends that the status of Finding PROC0061-04 be changed to “Closed.”

(3) The Revision 3 changes to PROC-0061 are essentially editorial or administrative. For 

example, the document originally listed three approaches to dose reconstruction 

(Maximizing, Best Estimate, and Minimizing); in Revision 3 the “Maximizing” category 

was changed to “Overestimate.”

(4) Additionally, the PROC-0061 Revision 3 list of references has been generalized, with no 

specific citations given. Since Revision 3 directs the use of the “O” drive, this will 

ensure that the dose reconstructors use the latest version.

Hence, a full re-review is not required and PROC-0061, Revision 3, may be accepted without 

further comments.

2.4 ORAUT-OTIB-0020 – USE OF COWORKER DOSIMETRY DATA FOR 

EXTERNAL DOSE ASSIGNMENT

The pre-review of ORAUT-OTIB-0020, Use of Coworker Dosimetry Data for External Dose 

Assignment, Revision 3, dated November 14, 2011, was prepared by Stephen Marschke. In 

August 2007, Hans Behling, PhD, MPH, performed SC&A’s original review of OTIB-0020, 

Revision 1, dated October 7, 2005. Five findings were identified in the original review; all five 

findings have been addressed by the Subcommittee and closed.

2.4.1 Purpose of the Procedure

The stated purpose of ORAUT-OTIB-0020 is to provide:

...general information to allow Oak Ridge Associated Universities (ORAU) Team 

dose reconstructors to assign doses based on site coworker external dosimetry 

data to workers at DOE sites who have little or no individual monitoring data. 
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

9 of 10

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 TIB is to be used in conjunction with separate TIBs or other approved 

documents that provide site-specific coworker data.

2.4.2 Pre-Review Conclusions

Since SC&A’s original review of OTIB-0020, there have been two changes to the document: 

(1) the K-25 example coworker doses, which had been provided in Table 7-1, have been 

removed in response to a Quality of Science (10-year review) comment, and (2) the second 

paragraph of Section 3 was modified as agreed upon by the Subcommittee, NIOSH, and SC&A 

in order to address a finding made by SC&A on ORAUT-OTIB-0052, Revision 00 (ORAUT 

2006) (i.e., Finding OTIB-0052-16).

Neither of these changes to OTIB-0020 is of a technical nature; thus, a full re-review is not 

required and OTIB-0020, Revision 3, may be accepted without further comments.
Effective Date:

January 25, 2013

Revision No.

Draft – 0

Document No.

Pre-Review of Revised Documents

Page No.

10 of 10

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.

3.0 DOCUMENTS PREVIOUSLY REVIEWED BY SC&A

ICRP 1994. Human Respiratory Tract Model for Radiological Protection, International 

Commission on Radiological Protection, Publication 66, Ann. ICRP 24 (1-3).

ICRP 2007. The 2007 Recommendations of the International Commission on Radiological 

Protection, International Commission on Radiological Protection, Publication 103, Ann. ICRP 

37 (2-4).

ORAUT 2006a. Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUTPROC-0060, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 28, 

2006.

ORAUT 2006. Parameters to Consider When Processing Claims for Construction Trade 

Workers, ORAUT-OTIB-0052, Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. August 31, 2006.

ORAUT 2008. Occupational X-ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, 

Rev. 01, Oak Ridge Associated Universities Team, Cincinnati, Ohio. January 2, 2008.

ORAUT 2009. Quality Assurance Records Management, ORAUT-PROC-0066, Rev. 02. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. September 15, 2009.

ORAUT 2010. Occupational Medical X-Ray Dose Reconstruction for DOE Sites, ORAUTPROC-0061, Rev. 03. Oak Ridge Associated Universities Team, Cincinnati, Ohio. March 3, 

2010.

ORAUT 2011a. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 04. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. April 18, 2011.

ORAUT 2011b. Site Profile and Technical Basis Document Development, ORAUT-PROC0031, Rev. 03. Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 14, 

2011.

ORAUT 2011c. Use of Coworker Dosimetry Data for External Dose Assignment, ORAUTOTIB-0020, Rev. 03. Oak Ridge Associated Universities Team, Cincinnati, Ohio. November 

14, 2011.

Trout, E.D., G. Jacobson, R.T. Moore, and E.P. Shoub, 1973. “Analysis of the Rejection Rate of 

Chest Radiographs Obtained During the Coal Mine ‘Black Lung’ Program.” Radiology 109:25-

27.

WHO 1977. International Classification of Diseases, Ninth Revision, World Health 

Organization, World Health Assembly, Geneva, Switzerland.