Office of Compensation Analysis and Support (OCAS)

Public Docket for 42 CFR 82 (Dose Reconstruction)

Please note that the Public Comments listed on this page are arranged in the order they were received. The most recent item received is at the top of the list. The Meeting Reports, Stakeholder Correspondence, and References are listed in chronological or alphabetical order.

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Public Comments on Changes to the Dose Reconstruction Target Organ Selection for Lymphoma Request for Comments Published on January 19, 2006

• Comments from Private Citizen, 1 pg. Received on February 6, 2006.
  PDF 18 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on February 6, 2006.
  PDF 18 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on February 6, 2006.
  PDF 23 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on February 3, 2006.
  PDF 32 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 31, 2006.
  PDF 40 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 31, 2006.
  PDF 15 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 31, 2006.
  PDF 38 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 31, 2006.
  PDF 42 KB (1 page)
  
  
• Comments from Private Citizen, 8 pp. Received on January 30, 2006.
  PDF 738 KB (8 pages)
  
  
• Comments from Private Citizen, 2 pp. Received on January 30, 2006.
  PDF 54 KB (2 pages)
  
  
• Comments from Private Citizen, 1 pg. Received on January 27, 2006.
  PDF 30 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 27, 2006.
  PDF 58 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 27, 2006.
  PDF 25 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 27, 2006.
  PDF 41 KB (1 page)
  
  
• Comments from Private Citizen, 1 pg. Received on January 25, 2006.
  PDF 50 KB (1 page)
  

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Public Comments on Interim Final Rule with Request for Comments Published on October 5, 2001

• Comments from the Advisory Board on Radiation and Worker Health. Recommendations and Comments from of the the Advisory Board on Radiation and Worker Health, 6 pp. Received on March 6, 2002.
  PDF 150 KB (6 pages)
  
  
• Comments from Paul Ruhter. 42 CFR Part 82, 4 pp. Received on March 2, 2002.
  PDF 141 KB (4 pages)
  
  
• Comments from Rhonda Bogard. NIOSH Comments, 3 pp. Received on March 1, 2002.
  PDF 123 KB (3 pages)
  
  
• Comments from Private Citizen. Public Comment, 1 pg. Received on February 23, 2002.
  PDF 18 KB (1 page)
  
  
• Comments from Private Citizen. Dose Reconstruction Comments, 4 pp. Received on February 22, 2002.
  PDF 189 KB (4 pages)
  
  
• Comments from Tom H. Foulds. Comments on Proposed 42 CFR 82, 2 pp. Received on February 21, 2002.
  PDF 67 KB (2 pages)
  
  
• Comments from Louis Clark, Executive Director, Government Accountability Project. Comments of the Government Accountability Project on the Department of Health and Human Services' Proposed Rule: "Methods for Dose Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act of 2000 (42 CFR Part 82)," 9 pp. Received on January 23, 2002.
  PDF 434 KB (9 pages)
  
  
• Comments from Private Citizen. Comments on 42 CFR 81 and 82, 2 pp. Received on January 23, 2002.
  PDF 19 KB (2 pages)
  
  
• Comments from Private Citizen. Dose Reconstruction, 1 pg. Received on January 17, 2002.
  PDF 19 KB (1 page)
  
  
• Comments from Kenneth W. Crase, Technical Advisor, Health Physics Technology, Westinghouse Savannah River Company, Savannah River Site. Comments on 42 CFR 81 and 82, 2 pp. Received on December 4, 2001.
  PDF 70 KB (2 pages)
  
  
• Comments from James F. Koonce, Executive Director of Operations, University of California. University of California Comments, 3 pp. Received on December 4, 2001.
  PDF 102 KB (3 pages)
  
  
• Comments from Theresa Parker. Comments Regarding the Energy Employees Compensation Act of 2000, 2 pp. Received on November 8, 2001.
  PDF 98 KB (2 pages)
  
  
• Comments from Beat Hintermann and Marvin Resnikoff, Radioactive Waste Management Associates. Comments on Proposed 42 CFR Parts 81 and 82, 5 pp. Received on November 8, 2001.
  PDF 171 KB (5 pages)
  
  
• Comments from Marylia Kelley, Executive Director, Tri-Valley CAREs. Tri-Valley CAREs Comments on EEOICPA Dose Reconstruction, 3 pp. Received on November 6, 2001.
  PDF 141 KB (3 pages)
  
  
• Comments from Sylvia Kieding. PACE Comments on NIOSH Proposed Rules on Dose Reconstruction, 8 pp. Received on November 5, 2001.
  PDF 354 KB (8 pages)
  
  
• Additional Comments from Robert Bistline, Program Manager, Oversite of Radiation Protection Program, U.S. Department of Energy, Rocky Flats Field Office. Comments on 42CFR82, 3 pp. Received on November 5, 2001.
  PDF 79 KB (3 pages)
  
  
• Comments from George Anastas, President, Health Physics Society. HPS Comments on 42CFR82, 12 pp. Received on November 5, 2001.
  PDF 529 KB (12 pages)
  
  
• Comments from Dianne Lentz. Compensation Payments, 1 page. Received on November 5, 2001.
  PDF 21 KB (1 pages
  
  
• Comments from Carter K. Kirk. Comments on 42CRF82.doc, 1 page. Received on November 5, 2001.
  PDF 54 KB (1 page)
  
  
• Comments from Louis Clark, Executive Director, Government Accountability Project. Comments of the Government Accountability Project on the Department of Health and Human Services' Proposed Rules, 9 pp. Received on November 5, 2001.
  PDF 390 KB (9 pages)
  
  
• Comments from Tim K. Takaro, Washington University. Comments on Radiation Dose Reconstruction, 3 pp. Received on November 5, 2001.
  PDF 93 KB (3 pages)
  
  
• Comments from E. Vincent Holahan, Senior Level Technical Advisor, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission. Comments on 42 CFR Part 82, 5 pp. Received on November 5, 2001.
  PDF 246 KB (5 pages)
  
  
• Comments from Alan Fellman, Radiation Safety Academy. Comments on 42 CFR Part 82, 2 pp. Received on November 5, 2001.
  PDF 39 KB (2 pages)
  
  
• Comments from Steven Cary, Acting Assistant Secretary, Office of Environment, Safety, and Health. Comments on 49CFR, Part 82, 5 pp. Received on November 2, 2001.
  PDF 169 KB (5 pages)
  
  
• Comments from Dennis Schaeffer, Program Manager/Senior Health Physicist, Nuclear Test Personnel Review Program, Technology Development Directorate, Defense Threat Reduction Agency. Comments on 42 CFR Part 82, 4 pp. Received on November 1, 2001.
  PDF 194 KB (4 pages)
  
  
• Comments from Craig Anderson, Comments - Dose Reconstruction Interim Rule, 5 pp. Received on October 30, 2001.
  PDF 148 KB (5 pages)
  
  
• Comments from Janet McKirahan. Public Opinion, 1 page. Received on October 29, 2001.
  PDF 19 KB (1 page)
  
  
• Comments from Laurence Fuortes, Project Director, University of Iowa. Comments on 42 CFR Part 82, 3 pp. Received on October 29, 2001.
  PDF 133 KB (3 pages)
  
  
• Comments from Marguerite Love and Marilyn Love. Public Comment on Interim Final Rule on Dose Reconstruction, 1 page. Received on October 27, 2001.
  PDF 18 KB (1 page)
  
  
• Comments from Linda Love Yeiser. Comments on 42 CFR Part 81, 42 CFR Part 82, and the Collection of Information Requirements, 2 pp. Received on October 23, 2001.
  PDF 98 KB (2 pages)
  
  
• Comments from Robert Bistline, Program Manager, Oversite of Radiation Protection Program, U.S. Department of Energy, Rocky Flats Field Office. Comments to NIOSH Interim Final Rule 42CFR82 "Methods for Radiation Dose Reconstruction Program Act of 2000, 2 pp. Received on October 22, 2001.
  PDF 60 KB (2 pages)
  
  
• Comments from Lauretta Herrick. Procedures for Filing Form for My Deceased Husband DOE Employee, 1 pg. Received on October 18, 2001.
  PDF 21 KB (1 page)
  
  
• Comments from James P. Thomas, Paralegal, Short Cressman & Burgess PLLC. Proposed Rules--42 CFR Part 82--"Methods for Dose Reconstruction Under the Energy Employees Occupational Illness Compensation Program Act of 2000; Interim Final Rule with Requests for Comments," 2 pp. Received on October 18, 2001.
  PDF 62 KB (2 pages)
  
  
• Comments from Glenn Bell, Y-12 Machinist, Beryllium Victims Alliance, Y-12 Beryllium Support Group, Coalition for a Healthy Environment, DOE Chronic Beryllium Disease Protection Program Member, DOE Risk Analysis Committee Worker Representative. Re: Public Comments, 42 CRF Part 82, 3 pp. Received on October 15, 2001.
  PDF 128 KB (3 pages)
  
  
• Comments from Candace Elizabeth Benson Peyer-Bellows. Work Related Radiation Exposure, 2 pp. Received on October 12, 2001.
  PDF 99 KB (2 pages)
  
  
• Comments from Mindy Newby, Compensation for Nuclear Workers, 1 pg. Received on October 07, 2001.
  PDF 33 KB (1 page)
  
  
• Comments from Private Citizen. Compensation for Direct Workers of Nuclear Energy Materials, 1 pg. Received on October 5, 2001.
  PDF 18 KB (1 page)
  

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Meeting Reports

• OCAS Trip/Meeting Report; Washington, D.C.; 04/02/2001. Meeting of the National Academy of Sciences committee that is reviewing the dose reconstruction program of the Defense Threat Reduction Agency (DTRA), 3 pp.
  PDF 121 KB (3 pages)
  
  
• OCAS Meeting Report; Cincinnati, Ohio; 05/08/2001. Presentation and discussion with ACJ and Associates on the Integrated Modules for Bioassay Analysis Software (IMBA), 24 pp.
  PDF 739 KB (24 pages)
  
  
• OCAS Trip/Meeting Report; Washington, D.C.; 05/16/2001. Discussion with AFL/CIO representatives of NIOSH role and plans for EEOICPA, 28 pp.
  PDF 790 KB (28 pages)
  
  
• OCAS Meeting Report; Cincinnati, Ohio; 07/19/2001. Discussion with MJW Corporation regarding lessons learned from the Mound internal dose reconstruction project, 41 pp.
  PDF 754 KB (41 pages)
  

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Stakeholder Correspondence

• Letter from LJ Elliott to Stakeholders requesting input into the development of a new occupational illness compensation program (01/01/2001), 3 pp.
  PDF 90 KB (3 pages)
  
  
• Comments from JJ Fix (04/17/2001), 2 pp.
  PDF 80 KB (2 pages)
  
  
• Comments with enclosure from G Bell (04/17/2001), 5 pp.
  PDF 208 KB (5 pages)

  [Enclosure, 36 pp.]
  PDF 1.3 MB (11 pages)

• Comments from AC Upton of the Consortium for Risk Evaluation with Stakeholder Participation (04/17/2001), 1 pg.
  PDF 38 KB (1 pages)
  
  
• Comments with enclosure from WJ Klemm (04/25/2001), 9 pp.
  PDF 436 KB (9 pages)

  [Enclosure, 11 pp.]
  PDF 720 KB (11 pages)

• Comments from DO Stram of the University of Southern California (04/26/2001), 3 pp.
  PDF 167 KB (3 pages)
  
  
• Comments from PL Ziemer of Purdue University (04/30/2001), 4 pp.
  PDF 157 KB (4 pages)
  
  
• Comments from WK Sinclair of NCRP (05/01/2001), 2 pp.
  PDF 57 KB (2 pages)
  
  
• Comments from K Ringen of the Center to Protect Workers' Rights (05/01/2001), 4 pp.
  PDF 168 KB (4 pages)
  
  
• Comments from PS Rohwer of the Health Physics Society (05/02/2001), 17 pp.
  PDF 760 KB (17 pages)
  
  
• Comments from JE Till of the Risk Assessment Corporation (05/07/2001), 2 pp.
  PDF 105 KB (2 pages)
  
  
• Comments from R Wilson of Harvard University (05/24/2001), 10 pp.
  PDF 79 KB (10 pages)
  
  
• Comments from AC Thadani of the Nuclear Regulatory Commission (05/31/2001), 4 pp.
  PDF 171 KB (4 pages)
  
  
• Comments from R Miller of the Government Accountability Project (06/17/2001), 19 pp.
  PDF 1.01 MB (19 pages)
  
  
• Memo to the file from LJ Elliott regarding the public comments on the development of rules on individual dose reconstruction and probability of causation (09/25/2001), 3 pp.
  PDF 78 KB (3 pages)
  

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References

• Akritas MG, et al. (1994). Statistical Analysis of Censored Environmental Data. Handbook of Statistics, Volume 12. Elsevier Science, pp. 221-242.
  
  
• Beyea J and Greenland S (1999). The Importance of Specifying the Underlying Biologic Model in Estimating the Probability of Causation. Health Phys 76(3):269-274.
  
  
• Clinton WJ (2000). Providing Compensation to America's Nuclear Weapons Workers. Executive Order, 7 pp.
  PDF 311 KB (7 pages)
  
  
• Congress (2000). Title XXXVI--Energy Employees Occupational Illness Compensation Program Act of 2000. 31 pp.
  PDF 1.2 MB (31 pages)
  
  
• Congress (2000). 1957 Acts: Section Enacted by Section 4 of the Price-Anderson Act and Also as the Atomic Energy Damages Act. Findings Regarding 2000 Amendments. 13 pp.
  PDF 666 KB (13 pages)
  
  
• Congress (1974). 38 FR 34530. Federal Register, 9 pp.
  PDF 500 KB (9 pages)
  
  
• Cox LA, Jr (1986). Technical and Policy Issues in Assigned Share Calculations: A Comment on Lagakos and Mosteller. Risk Analysis 6(3):373-375.
  
  
• Cox LA, Jr (1984). Probability of Causation and the Attributable Proportion of Risk. Risk Analysis 4(3):221-230.
  
  
• Eheman CR and Tolbert PE (1999). Estimating Occupational Radiation Doses When Individual Dosimetry Information is not Available: A Job Exposure Matrix. Am J Ind Med 36:348-359.
  
  
• Federal Register (2001). Energy Employees Occupational Illness Compensation Act of 2000. List of Covered Facilities. FR Notice, 14 pp.
  PDF 446 KB (14 pages)
  
  
• Finkelstein MM and Verma DK (2001). Exposure Estimation in the Presence of Nondetectable Values: Another Look. AIHAJ 62:195-198.
  
  
• Foulds, TH (2001). In response to letter to Secretary Bill Richardson (DOE) dated 12/13/2000, 110 pp.
  PDF 3.75 MB (110 pages)
  
  
• Gilbert ES (1998). Accounting for Errors in Dose Estimates Used in Studies of Workers Exposed to External Radiation. Health Phys 74(1):22-29.
  
  
• Gilbert ES and Fix JJ (1995). Accounting for Bias in Dose Estimates in Analyses of Data from Nuclear Worker Mortality Studies. Health Phys 68(5):650-660.
  
  
• Gilbert ES, et al. (1996). An Approach to Evaluating Bias and Uncertainty in Estimates of External Dose Obtained from Personal Dosimeters. Health Phys 70(3):336-345.
  
  
• Greenland S and Robbins JM (1988). Reviews and Commentary: Conceptual Problems in the Definition and Interpretation of Attributable Fractions. Am J Epidmiol 128(6):1185-1197.
  
  
• Hattis, D (1995). Radiation-induced Cancers in DOE and Contractor Employees--Prospects for the Individual Ascertainment of Causation. Contract No. DE-AC01-94EH89501, 106 pp.
  PDF 3.59 MB (106 pages)
  
  
• HCRA (2000). Compensating Government Workers Exposed to Radiation. Harvard Center for Risk Analysis 8(7):1-4.
  
  
• Hornung RW and Reed LD (1990). Estimation of Average Concentration in the Presence of Nondetectable Values. Appl Occup Environ Hyg 5(1):46-51.
  
  
• Hui TE, et al. (1997). The Second Internal Dosimetry Intercomparison Study of the U.S. Department of Energy. Radiation Protection Dosimetry 72(2):131-138.
  
  
• Hui TE, et al. (1994). An Internal Dosimetry Intercomparison Study. Health Phys 67(3):217-225.
  
  
• ICRP Task Group (1995). Age-dependent Doses to Members of the Public from Intake of Radionuclides: Part 3. International Commission on Radiological Protection (ICRP) Publication 69. Annals of the ICRP 25(1):80 pp.
  
  
• ICRP Task Group (1994). Human Respiratory Tract Model for Radiological Protection. International Commission on Radiological Protection (ICRP) Publication 66. Annals of the ICRP 24(1-3):497 pp.
  
  
• ICRP Task Group (1989). Age-dependent Doses to Members of the Public from Intake of Radionuclides: Part I. International Commission on Radiological Protection (ICRP) Publication 56. Annals of the ICRP 20(2):123 pp.
  
  
• Lagakos SW and Mosteller F (1986). Response to Comments on "Assigned Shares in Compensation for Radiation-related Cancers." Risk Analysis 6(3):377-380.
  
  
• Lagakos SW and Mosteller F (1986). Assigned Shares in Compensation for Radiation-related Cancers. Risk Analysis 6(3):345-357.
  
  
• Lave LB (1986). Who Needs Causation Probabilities? Risk Analysis 6(3):359-361.
  
  
• Miller G and Inkret WC (1995). Bayesian Maximum Posterior Probability Method for Interpreting Plutonium Urinalysis Data. Nuclear Technology Publishing, 7 pp.
  
  
• Mitchell TJ, et al. (1997). A Method for Estimating Occupational Radiation Dose to Individuals, Using Weekly Dosimetry Data. Radiation Research 147:195-207.
  
  
• National Research Council (2000). A Review of the Draft Report of the NCI-CDC Working Group to Revise the 1985 Radioepidemiological Tables. 85 pp.
  PDF 2.74 MB (85 pages)
  
  
• NCI-CDC Working Group (2000). Draft Report of the NCI-CDC Working Group to Revise the 1985 NIH Radioepidemiological Tables. 81 pp.
  PDF 3.66 MB (81 pages)
  
  
• NIOSH (1997). Tables: "Populations of Workers at DOE Nuclear Facilities Included in Health Studies" and "Summary of Years of Latency and Percent Dead by Year of Vital Status Follow-up Among Health Studies Conducted at DOE Facilities." Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, 5 pp.
  PDF 155 KB (5 pages)
  
  
• NIOSH (1993). NIOSH Research Issues Workshop: Epidemiologic Use of Nondetectable Values in Radiation Exposure Measurements. Cincinnati, OH. September 9-10, 1993. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, 30 pp.
  PDF 1.73 MB (30 pages)
  
  
• Richardson B and Herman AM (2001). Letter to Dennis J. Hastert Regarding the Proposed Legislation to Implement the Energy Employees Occupational Illness Compensation Program Act of 2000. House of Representatives, 52 pp.
  PDF 1.66 MB (52 pages)
  
  
• Richardson D, et al. (2000). Evaluation of Annual External Radiation Doses at Values Near Minimum Detection Levels of Dosimeters at the Hanford Nuclear Facility. J Exp Anal Environ Epidemiol 10:27-35.
  
  
• Richardson D et al. (1999). Missing Annual External Radiation Dosimetry Data Among Hanford Workers. J Exp Anal Environ Epidemiol 9:575-585.
  
  
• Robins J and Greenland S (1989). The Probability of Causation Under a Stochastic Model for Individual Risk. Biometrics 45:1125-1138.
  
  
• Rosenberg D (1986). The Uncertainties of Assigned Shares Tort Compensation: What We Don't Know Can Hurt Us. Risk Analysis 6(3):363-369.
  
  
• Scott BR, et al. (1997). On Evaluating Respiratory Tract Intake of High Specific Activity Alpha Emitting Particles for Brief Occupational Exposure. Radiation Protection Dosimetry 69(1):43-50.
  
  
• Seiler FA (1986). Assigned Shares and Combined Insults. Risk Analysis 6(3):371-372.
  
  
• Smith TJ, et al. (1991). Exposure Assessment for Epidemiology: Characteristics of Exposure. Appl Occup Environ Hyg 6(6):441-447.
  
  
• Stewart PA, et al. (1991). Collection of Exposure Data for Retrospective Occupational Epidemiologic Studies. Appl Occup Environ Hyg 6(4):280-289.
  
  
• Stockwell H (2001). Modified Tables of 1/6/2001 Tables. Contain doses and probability of causation values for an individual exposed to low-LET radiation who later developed leukemia. Department of Energy, 4 pp.
  PDF 76 KB (4 pages)
  
  
• Strom DJ (1986). Estimating Individual and Collective Doses to Groups with "Less Than Detectable" Doses: A Method for Use in Epidemiologic Studies. Health Phys 51(4):437-445.
  
  
• Strom DJ, et al. (1996). Doses to Workers in the United States Nuclear Weapons Program Due to External Irradiation at the Dawn of the Atomic Era (1940-1960). Health Phys 71(1):50-57.
  
  
• Wakeford R, et al. (1998). A Review of Probability of Causation and Its Use in a Compensation Scheme for Nuclear Industry Workers in the United Kingdom. Health Phys 74(1):1-9.
  
  
• Watson JE, et al. (1994). Estimation of Radiation Doses for Workers Without Monitoring Data for Retrospective Epidemiologic Studies. Health Phys 67(4):402-405.
  
  
• Ziemer PL (1999). Radiation Protection Information: Can You Trust the Government's Risks or Risk the Government's Trust? From the 1997 G. William Morgan Lecture. Health Phys 77(1):9-15.
  

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