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.

MEMORANDUM

TO: Subcommittee on Procedures Review 

FROM: SC&A, Inc.

DATE: October 20, 2016 

SUBJECT: Y-12 ORAUT-OTIB-0013 and ORAUT-PROC-0042 Findings and Resolutions 

Introduction and Background 

NIOSH has issued the following four documents concerning coworker doses and adjustments to 

coworker doses for individual Y-12 workers: 

• ORAUT-OTIB-0013 (hereafter “OTIB-0013”), Individual Dose Adjustment Procedure for Y-12 

Dose Reconstruction (ORAUT 2004a) 

• ORAUT-PROC-0042 (hereafter “PROC-0042”), Accounting for Incomplete Personal 

Monitoring Data on Penetrating Gamma-Ray Doses to Workers in Radiation Areas at the Oak 

Ridge Y-12 Plant Prior to 1961 (ORAUT 2004b) 

• ORAUT-OTIB-0044 (hereafter “OTIB-0044”), Historical Evaluation of the Film Badge 

Dosimetry Program at the Y-12 Facility in Oak Ridge, Tennessee: Part 1 – Gamma Radiation

(ORAUT 2013a) 

• ORAUT-OTIB-0064 (hereafter “OTIB-0064”), Coworker External Dosimetry Data for the Y-12 

National Security Complex (ORAUT 2013b) 

OTIB-0044 of 2013 replaced OTIB-0013 of 2004 for individual workers’ dose adjustments, and 

OTIB-0064 of 2013 replaced PROC-0042 of 2004 for coworker dose assignments. 

Procedures Review Subcommittee Meeting – May 16, 2016 

During the Procedures Review Subcommittee (PRSC) Meeting of May 16, 2016, SC&A was tasked 

with determining if previous SC&A OTIB-0013 findings (SC&A 2007) had been addressed by the 

replacement document OTIB-0044, if the findings were no longer applicable, or if the findings were 

carried over to OTIB-0044. Additionally, SC&A was tasked with determining if previous SC&A 

PROC-0042 findings (SC&A 2007) had been addressed by the replacement document OTIB-0064, if the 

findings were no longer applicable, or if the findings were carried over to OTIB-0064. 
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 2 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

SC&A’s Evaluation of OTIB-0013 Findings and Their Resolutions

There were originally five SC&A findings for OTIB-0013 (referred to as “review objectives” in 

SC&A 2007). The following is a brief summary of these findings and their resolutions. (The text of the

findings is taken from the Board Review System [BRS 2016a].)

Finding 1 

There are areas where the data are not clearly defined or there are conflicts in the years 

stated: (1) It is not clear from the text why there are solid green dots representing 

measured doses in Figure 1 for the period 1956–1960. (2) It is not clear from the OTIB 

for what time period these dose adjustment factors are to be applied, due to conflicting 

statements in the document.

Resolution: Concerns with Figure 1 in OTIB-0013 have been addressed in Section 7.5 of OTIB-0044. 

Other areas have been clarified by previous responses, and some areas are no longer applicable because 

OTIB-0013 has been canceled, and the findings did not carry over into OTIB-0044. Based on SC&A’s 

review of OTIB-0044, we find that this issue has been adequately addressed and recommend closure.

Finding 2 

(1) Periods when most of the recorded dosimetry data were not available or not usable 

for deriving a dose distribution were not specifically mentioned in this OTIB to inform 

the dose reconstructor what data was and was not used to obtain the coworker dose 

distribution data. (2) An incorrect LOD value used when the worker's dose = 0, the 

laboratory minimum LOD of 40 mrem should at least be used in this analysis.

Resolution: (1) OTIB-0044 clarifies the use of data from 147 workers (page 9). (2) This item has been 

resolved, and the PRSC closed this finding during its May 16, 2016, meeting (BRS 2016).

Finding 3

The method for applying the estimated scaling factors is based on the assumption that the 

individual’s potential for exposure during the 1950s is similar to that from 1961 to 1965, 

and that the individual's doses differ from the coworker population dose by a constant 

factor both in the later years when data are available for comparison and in the earlier 

unmonitored years. However, no evidence is presented to support these assumptions. 

Moreover, under the proposed procedure the most uncertain scaling factors, estimated 

for the individuals with only five quarters of data, are then applied to the largest number 

of unmonitored quarters, compounding the effects of uncertainty. Despite the 

mathematically correct use of maximum likelihood methods for estimating the scaling 

factors, the constancy of the scaling factors over time and the application of such factors 

to possibly inappropriate distributions in the early years are not adequately addressed. 

Resolution: OTIB-0013 is no longer in use, and OTIB-0044 has replaced it. SC&A’s concern with the 

scaling factors has been addressed in OTIB-0044, Sections 7.4 and 7.5. Based on SC&A’s review of 

OTIB-0044, we find that this issue has been adequately addressed and recommend closure.
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 3 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Finding 4

OTIB-0013, Table 2, indicates a discontinuity in the dose assignment function at low and 

zero doses, i.e., in the 0–10 mrem range.

Resolution: NIOSH responded by stating that the scaling factor is to adjust upward the standard 

unmonitored dose for a worker; doses in the 0–10 mrem range would not be relevant for scaling. SC&A 

agreed with NIOSH’s response. The PRSC closed this issue on December 9, 2008.

Finding 5

Incorrect use of Scaling Factor terminology in Workbook, etc. There is a misuse of 

terminology that could result in incorrect dose assignment if the dose reconstructor is not 

familiar with the intent of both OTIB-0013 and PROC-0042. This stems from using the 

term “scaling factor” interchangeably for f and for exp(f).

Resolution: OTIB-0013 and its workbook are no longer in use; OTIB-0044 has replaced them. The 

OTIB-0064 coworker model for Y-12 is based on ORAUT-OTIB-0020, Technical Information Bulletin: 

Use of Coworker Dosimetry Data for External Dose Assignment, Revision 03 (ORAUT 2011), and not 

on scaling factors, such as those used in OTIB-0013. Based on SC&A’s review of OTIB-0044, we find 

that this issue has been adequately addressed and recommend closure.

SC&A’s Evaluation of PROC-0042 Findings and Their Resolutions

There were originally six SC&A findings for PROC-0042 (referred to as “review objectives” in 

SC&A 2007). The following is a brief summary of these findings and their resolutions. (The text of the 

findings is taken from the Board Review System [BRS 2016b].)

Finding 1

Generally, the OTIB was written in a fairly clear and logical manner. However, there are 

several areas that could be improved to assist the dose reconstructor in understanding 

the different stages of development of the dose reconstruction instructions. Additionally, 

some wording and errors contained in the text create confusion and require several 

rereads, and/or assumptions to be made, to clarify the issues. 

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to PROC-0042 

and, therefore, does not contain the same text errors and clarification issues identified by SC&A for 

PROC-0042. Additionally, the purpose and scope of using coworker data are outlined in Section 2.0, 

page 7, of OTIB-0064. 

SC&A recommends closing this issue.

Finding 2

The OTIB was generally written in a prescriptive manner. However, several areas could 

be improved. (1) In Section 5, page 4, the dose reconstructor is not provided with definite 

instructions on how to evaluate the monitoring data from the 1940s and 1950s. Reference 
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 4 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

to problems during this era and appropriate OTIBs would be helpful. (2) Section 6.3, 

page 9, instructs the dose reconstructor to use the “Microsoft® Excel® computer 

program and Crystal Ball®,” and Section 6.4, page 10, instructs the dose reconstructor 

to perform steps to calculate the scaled annual distributions for organ doses. Both 

instructions are without a definite reference to the name of the programs and/or 

workbooks to be used. This could cause incorrect dose reconstruction results if the wrong 

programs and/or workbooks were used, or inconsistencies between different dose 

reconstructors. 

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to 

PROC-0042, does not contain the same methodologies, and does not use the scaling factors for which 

SC&A identified issues in PROC-0042. Therefore, this finding is not applicable to OTIB-0064.

SC&A recommends closing this issue.

Finding 3

It is not stated in this document that the dose data for the years 1947–1956 (3rd quarter) 

in Table 5.1, page 5, are not actually from badged workers’ dose records. In fact, these 

values are inferred doses from regression analyses of 147 badged workers at Y-12 for the 

period of 1956–1965. ORAUT-RPRT-0032 [ORAUT 2005] must be analyzed to 

understand the development of this data. This may be an acceptable method to use in 

view of the lack of actual, reliable, recorded dose data for 1947–1956, but it should be 

clearly stated in the procedure that this is the case and not presented as actual dose of 

record. The second paragraph on page 4 of the procedure only refers to “the estimated 

parameters for lognormal distributions derived for each calendar quarter for July 1947 

to December 1965 (ORAUT-OTIB-0013),” but not to the origin of the dose data.

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to 

PROC-0042. Where data from the 147 badged workers at Y-12 are used, they are identified as such on 

pages 34 and 35 of OTIB-0064. Therefore, this finding is not applicable to OTIB-0064.

SC&A recommends closing this issue.

Finding 4

For this procedure to be considered claimant favorable in instances where claimants 

were not monitored, there are a number of assumptions/limitations that have to be 

accepted. These assumptions/limitations are not necessarily explicitly pointed out in 

detail in the procedure, and links/references to other documents must sometimes be 

followed to fully evaluate the applicability and technical soundness of this document.

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to 

PROC-0042. Assumptions, applications, and limitations are provided in OTIB-0064, such as on pages 7, 

8, 14, and 15. Therefore, this finding is not applicable to OTIB-0064.

SC&A recommends closing this issue.
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 5 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

Finding 5

Most of this procedure employed scientifically valid protocols for reconstructing doses. 

However, some technical errors were found in the text that could lead to errors in the 

assigned dose errors, if used as stated in the procedure. (1) The procedure appears to 

contain a technical error in applying the scaling factor. This error would not result in an 

underestimate of a worker’s dose, but could result in a worker that had average, or 

below average, recorded doses during 1961–1965 being assigned a higher dose during 

1947–1960 than another worker that has greater than average recorded doses during 

1961–1965. (2) Additionally, change the title of Section 6.2, page 8, from Use of 

calculated scaling factors greater than unity to Use of calculated scaling factors greater 

than zero. This is needed because the scaling factor appears in the exponent 

(GM* = eu+f) in calculating the scaled value of the geometric mean. Therefore, it must 

be zero to apply a multiplication factor of 1.0 to the dose. These paragraphs, and the 

associated errors, do not appear in the other related OTIBs and RPRT.

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to 

PROC-0042, does not contain the same methodologies, and does not use scaling factors for which 

SC&A identified issues in PROC-0042. Therefore, this finding is not applicable to OTIB-0064.

SC&A recommends closing this issue.

Finding 6

The procedure appears to contain a technical error in applying the scaling factor. This 

error would not result in an underestimate of a worker’s dose, but could result in a 

worker that had average, or below average, recorded doses during 1961–1965 being 

assigned a higher dose during 1947–1960 than another worker that has greater than 

average recorded doses during 1961–1965. To correct this error, the last paragraph on 

Page 6 should be changed from “...assume a scaling factor of unity (one) and use...” to 

“...assume a scaling factor of zero (0) and use....” Also, change the second paragraph 

on page 8 from: 

...assume a scaling factor of unity (one) and use the “population dose distributions for 

monitored workers” in Table 5.1 as a reasonable but necessary claimant favorable 

procedure to generate data for input to the NIOSH-IREP Program. If a scaling factor is 

assumed to be unity (one) or a scaling factor for a monitored worker is calculated to be 

equal to or less than unity (one),... 

to: 

...assume a scaling factor of zero (0) and use the “population dose distributions for 

monitored workers” in Table 5.1 as a reasonable but necessary claimant favorable 

procedure to generate data for input to the NIOSH-IREP Program. If a scaling factor is 

assumed to be zero (0) or a scaling factor for a monitored worker is calculated to be 

equal to or less than zero (0),... 

Additionally, change the title of Section 6.2, page 8, from: “Use of calculated scaling 

factors greater than unity” to: “Use of calculated scaling factors greater than zero”
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 6 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

This is needed because the scaling factor appears in the exponent (GM* = eu+f) in 

calculating the scaled value of the geometric mean. Therefore, it must be zero to apply a 

multiplication factor of 1.0 to the dose.

Resolution: OTIB-0064 is a complete rewrite of the Y-12 coworker procedure compared to 

PROC-0042, does not contain the same methodologies, and does not use scaling factors for which 

SC&A identified issues in PROC-0042. Therefore, this finding is not applicable to OTIB-0064.

SC&A recommends closing this issue.

Summary and Conclusions

In reviewing the original findings for OTIB-0013 and PROC-0042 in light of their replacement 

documents, OTIB-0044 and OTIB-0064, respectively, SC&A found that most of the previous findings 

are not applicable to the newer documents because of changes in methodology, application, and text.

The remaining areas have been resolved or are corrected in the new documents. Therefore, SC&A 

suggests that the findings for OTIB-0013 and PROC-0042 be closed. However, SC&A was tasked with 

only addressing the previous findings in OTIB-0013 and PROC-0042 to determine if they are present in 

the newer documents. SC&A did not perform a technical evaluation of the replacement documents 

OTIB-0044 and OTIB-0064 or their application and appropriateness to dose reconstruction, as that 

would require additional tasking by the PRSC. Because the methods of deriving the adjustment factors 

and coworker doses in OTIB-0044 and OTIB-0064 are substantially different from those used in 

OTIB-0013 and PROC-0042, SC&A recommends that a full technical review of OTIB-0044 and 

OTIB-0064 be performed, especially an evaluation of the statistical methodology and results obtained.

References

BRS 2016a. Rev. 00, Finding No and SC&A Page No: OTIB-0013-02 / 101–102, Board Review System,

Subcommittee on Procedures Review. May 16, 2016.

BRS 2016b. Rev. 00, Finding No and SC&A Page No: PROC-0042-01 / 262, Board Review System,

Subcommittee on Procedures Review. June 8, 2016.

ORAUT 2004a. Technical Information Bulletin: Individual Dose Adjustment Procedure for Y-12 Dose 

Reconstruction, ORAUT-OTIB-0013, Revision 00, Oak Ridge Associated Universities, Cincinnati, 

Ohio. September 9, 2004.

ORAUT 2004b. Accounting for Incomplete Personal Monitoring Data on Penetrating Gamma-Ray 

Doses to Workers in Radiation Areas at the Oak Ridge Y-12 Plant Prior to 1961, ORAUT-PROC-0042, 

Revision 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. September 9, 2004. 

ORAUT 2005. Technical Information Bulletin: Individual Dose Adjustment Procedure for Y-12 Dose 

Reconstruction, ORAUT-RPRT-0032, Revision 00, Oak Ridge Associated Universities, Cincinnati, 

Ohio. September 9, 2004.

ORAUT 2011. Technical Information Bulletin: Use of Coworker Dosimetry Data for External Dose 

Assignment, ORAUT-OTIB-0020, Revision 03, Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. November 14, 2011.
Memo – OTIB-13, PROC-42, OTIB-44, & OTIB-64 7 SC&A – October 20, 2016

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

Privacy Act 5 U.S.C. § 552a and has been cleared for distribution.

ORAUT 2013a. Historical Evaluation of the Film Badge Dosimetry Program at the Y-12 Facility in Oak 

Ridge, Tennessee: Part 1 – Gamma Radiation, ORAUT-OTIB-0044, Revision 01, Oak Ridge 

Associated Universities, Cincinnati, Ohio. April 29, 2013.

ORAUT 2013b. Coworker External Dosimetry Data for the Y-12 National Security Complex, ORAUTOTIB-0064, Revision 02, Oak Ridge Associated Universities, Cincinnati, Ohio. April 29, 2013.

SC&A 2007. Review of NIOSH/ORAUT Procedures and Methods Used for Dose Reconstruction, 

Review of the Third Set of Procedures (45 Procedure Reviews), SC&A, Inc., Vienna, Virginia, and 

Saliant, Inc., Maryland. October 29, 2007.