NIOSH Dose Reconstruction
By: Kevin Tran
By: Kevin Tran
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Dose Reconstruction Overview
The NIOSH Dose Reconstruction Program was a time intensive and harrowing process that held a reputation for dose reconstruction cases that took several years or more to complete. The United States Department of Labor started accepting claim applications on July 31, 2001, and sent the first batch of cases to NIOSH on October 11, 2001, for dose reconstruction. However, the responsibilities given to NIOSH for this compensation program were new to the agency at that time. These cases were being sent to NIOSH before the necessary infrastructure, rules and regulations, technical documents, and other processes and procedures required for dose reconstruction were in place. (cdc.gov/niosh/ocas/ocasdose). As cases were being sent before rules and technicalities were put properly in place, many cases were either handled improperly or put off for an extended period of time.
The NIOSH Dose Reconstruction Program was a time intensive and harrowing process that held a reputation for dose reconstruction cases that took several years or more to complete. The United States Department of Labor started accepting claim applications on July 31, 2001, and sent the first batch of cases to NIOSH on October 11, 2001, for dose reconstruction. However, the responsibilities given to NIOSH for this compensation program were new to the agency at that time. These cases were being sent to NIOSH before the necessary infrastructure, rules and regulations, technical documents, and other processes and procedures required for dose reconstruction were in place. (cdc.gov/niosh/ocas/ocasdose). As cases were being sent before rules and technicalities were put properly in place, many cases were either handled improperly or put off for an extended period of time.
What is Dose Reconstruction?: The process of estimating radiation doses that were received by individuals or populations in the past as a result of particular exposure situations of concern. The basic principle of radiation dose reconstruction is to characterize the radiation environment to which individuals have been exposed using available information. In cases where radiation exposures can not be fully characterized based on available data, default values based on reasonable scientific assumptions can be used as substitutes. The extent to which the default values are used depends on the purpose of the reconstruction(s) being undertaken (Wikipedia).
Methods for Radiation Dose Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act of 2000; Final Rule
Under the Department of Health and Human Services, the Final Ruling "implements select provisions of the Energy Employees Occupational Illness Compensation Program Act of 2000 (‘‘EEOICPA’’ or ‘‘Act’’). The Act requires the promulgation of methods, in the form of regulations, for estimating the dose levels of ionizing radiation incurred by workers in the performance of duty for nuclear weapons production programs of the Department of Energy and its predecessor agencies" (cdc.gov/niosh/ocas/pdfs/42cfr82/42cfr82).
These dose reconstruction methods are then applied by NIOSH which reproduces the radiation dose estimates that the DOL uses in determining certain claims of cancer under the Act. However, these are still estimates and workers that have been working at the plant for many years and have left and/or died may not remember certain details about working conditions, radiation levels in the area, or are available to report such conditions; and they may have much higher doses than procured by the agency.
Regulation for Implementing the Energy Employees Compensation Program: Methods for Radiation Dose Reconstruction
It was stated that the methodology proposed by CDC/NIOSH is appropriate and errs on the worker's side, and it also puts a high burden on the worker to prove his or her case. As the regulations were written, the burden is on workers to prove that he or she was injured and that the work was unsafe. If data is not available to assess internal and external doses, under theses regulations, this information will be passed to DOL who will deny compensation regardless of exposure level.
Furthermore, a commentator states, "This is unfair and a major defect in the proposed regulations. It is hard for us to imagine a situation where a rough approximation of radiation dose, at least a bonding dose, could not be calculated" (cdc.gov/niosh/ocas/pdfs/81and82/resnikoff110801).
There are a number of discrepancies that provide numbers far from the actual dosage, and gaps between book-keepings create inconsistencies in records. Also, there is still a delay between requests and processing, leading to more wait time, frustration, and injustice relating to the Act.
Furthermore, a commentator states, "This is unfair and a major defect in the proposed regulations. It is hard for us to imagine a situation where a rough approximation of radiation dose, at least a bonding dose, could not be calculated" (cdc.gov/niosh/ocas/pdfs/81and82/resnikoff110801).
There are a number of discrepancies that provide numbers far from the actual dosage, and gaps between book-keepings create inconsistencies in records. Also, there is still a delay between requests and processing, leading to more wait time, frustration, and injustice relating to the Act.
Contemporary Reconstruction and Case Attention
Reconstruction and case attention are improved in the modern day versus years ago. However, not all cases have been brought to justice, and much work is still needed to be done in order to correct and give compensation to those affected by the events that unraveled at Rocky Flats.
1. Centers for Disease Control and Prevention. Centers for Disease Control and Prevention, n.d. Web. 13 June 2014.
<http://www.cdc.gov/niosh/ocas/ocasdose.html>.
2. "Radiation Dose Reconstruction." Wikipedia. Wikimedia Foundation, 06 Feb. 2014. Web. 1 June 2014.
<http://en.wikipedia.org/wiki/Radiation_dose_reconstruction>.
3. Federal Register/ Vol. 67, No. 85 / Thursday, May 2, 2002 / Rules and Regulations. N.p.: n.p., n.d. N. pag. Web. 1 June 2014.
<http://www.cdc.gov/niosh/ocas/pdfs/42cfr82/42cfr82.pdf>.
4. "Comments on Regulations to Implement the Energy Employees Compensation Program: Methods for Radiation Dose Reconstruction,
and Guidelines for Determining the Probability of Causation." (n.d.): n. pag. Www.cdc.gov. Web. 1 June 2014.
<http://www.cdc.gov/niosh/ocas/pdfs/81and82/resnikoff110801.pdf>.
<http://www.cdc.gov/niosh/ocas/ocasdose.html>.
2. "Radiation Dose Reconstruction." Wikipedia. Wikimedia Foundation, 06 Feb. 2014. Web. 1 June 2014.
<http://en.wikipedia.org/wiki/Radiation_dose_reconstruction>.
3. Federal Register/ Vol. 67, No. 85 / Thursday, May 2, 2002 / Rules and Regulations. N.p.: n.p., n.d. N. pag. Web. 1 June 2014.
<http://www.cdc.gov/niosh/ocas/pdfs/42cfr82/42cfr82.pdf>.
4. "Comments on Regulations to Implement the Energy Employees Compensation Program: Methods for Radiation Dose Reconstruction,
and Guidelines for Determining the Probability of Causation." (n.d.): n. pag. Www.cdc.gov. Web. 1 June 2014.
<http://www.cdc.gov/niosh/ocas/pdfs/81and82/resnikoff110801.pdf>.