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
- Comments from Rhonda Bogard. NIOSH Comments, 3 pp. Received on March 1, 2002.
PDF 123 KB (3 pages)
- Comments from the Advisory Board on Radiation and Worker Health, 5 pp. Received on February 7, 2002.
PDF 207 KB (5 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: "Guidelines for Determining the Probability of Causation Under the Energy Employees Occupational Illness Compensation Program Act of 2000 (42 CFR Part 81)," 8 pp. Received on January 23, 2002.
PDF 390 KB (8 pages)
- Comments from Private Citizen. Causation, 1 pg. Received on January 23, 2002.
PDF 12 KB (1 page)
- Comments from Private Citizen. Comments on 42 CFR 81 and 82, 2 pp. Received on January 23, 2002.
PDF 69 KB (2 pages)
- Comments from Private Citizen. Energy Employees Occupational Illness Compensation Program of 2000, 4 pp. Received on December 5, 2001.
PDF 103 KB (4 pages)
- Comments from Michael Schaeffer, Program Manager/Seniro Health Physicist, Nuclear Test Personnel Review, Technology Development Directorate, Defense Threat Reduction Agency. Comments on 42 CFR 81 from Department of Defense, 3 pp. Received on December 5, 2001.
PDF 95 KB (3 pages)
- Comments from Mark Griffon, PACE HP Consultant. PC Comments, 6 pp. Received on December 5, 2001.
PDF 305 KB (6 pages)
- Comments from William
Slattery, President, Atlantic Legal Foundation. Comments on Proposed 42CFR81, 3 pp. Received on December 4, 2001.
PDF 76 KB (3 pages)
- Comments from Frank M. Roddy. Comments on 42CFR81, 2 pp. Received on December 4, 2001.
PDF 67 KB (2 pages)
- Comments from Marylia Kelley, Executive Director, Tri-Valley CAREs. EEOICPA: Probability of Causation Comments, 10 pp. Received on December 4, 2001.
PDF 449 KB (10 pages)
- Comments from Timothy K. Takaro, William C. Griffith, and John Abbotts of the University of Washington. Comments, Guidelines for Probability of Causation, 4 pp. Received on December 4, 2001.
PDF 182 KB (4 pages)
- Comments from Sheryl Burrows. Comments on Proposed 42CFR Part 81, 2 pp. Received on December 4, 2001.
PDF 56 KB (2 pages)
- Comments from The Building Construction Trade Department, AFL-CIO. Comments on Guidelines for Determining Causation Under EEOICPA, 8 pp. Received on December 4, 2001.
PDF 363 KB (8 pages)
- Comments from George Anastas, President, Health Physics Society. HPS Comments on 42CFR81, 11 pp. Received on December 4, 2001.
PDF 449 KB (11 pages)
- 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 Private Citizen, 3 pp. Received on December 3, 2001.
PDF 77 KB (3 pages)
- Comments from Dorothy C. Clayton. Proposed Rulemaking on Probability of Causation, 56 pp. Received on December 3, 2001.
PDF 2 MB (56 pages)
- Comments from Charles Land, NCI. IREP, 2 pp. Received on November 26, 2001.
PDF 110 KB (2 pages)
- Comments from Chauncey Starr, President Emeritus, Electric Power Research Institute. NIOSH-IREP, 1 pg. Received on November 26, 2001.
PDF 20 KB (1 page)
- Comments from Richard Wilson. IREP, 2 pp. Received on November 25, 2001.
PDF 100 2KB (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 Dianne Lentz. Compensation Payments, 1 page. Received on November 5, 2001.
PDF 21 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 Craig Anderson. Comments on Probability of Causation, 5 pp. Received on November 4, 2001.
PDF 168 KB (5 pages)
- Comments from Roger Shaw. Information Request, 1 pg. Received on November 2, 2001.
PDF 27 KB (1 page)
- Comments from Alexandre Klementiev. Comments on Probability of Causation, 2 pp. Received on October 29, 2001.
PDF 42 KB (2 pages)
- 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 Carter K. Kirk, URS Corporation. NOPRM Comments 42 CFR Part 81, 1 page. Received on October 22, 2001.
PDF 43 KB (1 page)
- Comments from Charles B. Meinhold, President, National Council on Radiation Protection and Measurement. Comments on "Guidelines for Determining the Probability of Causation," 1 page. Received on October 19, 2001.
PDF 25 KB (1 page)
- 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 Sander Greenland, Professor of Epidemiology and Statistics, University of California, Los Angeles. Guidelines for Determining the Probability of Causation, 1 page. Received on October 16, 2001.
PDF 31 KB (1 page)
- 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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Subject Matter Expert Reviews of NIOSH-IREP
- Comments from David G. Hoel, Ph.D., University Professor, Medical University of South Carolina, 6 pp.
PDF 157 KB (6 pages)
- Comments from Richard Hornung, University of Cincinnati, 4 pp.
PDF 157 KB (4 pages)
- Comments from David Richardson, Department of Epidemiology, School of Public Health, University of North Carolina, 6 pp.
PDF 52 KB (6 pages) (revised on 2/11/02)
- Comments from Roy E. Shore, Ph.D., Dr. P.H., Professor, Department of Environmental Medicine, Director, Division of Epidemiology and Biostatistics, New York University, School of Medicine, 4 pp.
PDF 164 KB (4 pages)
- Comments from Daniel O. Stram, Ph.D., Associate Professor, Keck School of Medicine, Department of Preventive Medicine, Division of Biostatistics, University of Southern California, 5 pp.
PDF 439 KB (5 pages)
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Subject Matter Expert Reviews of Proposed Radiation Weighting Factors
- Comments from David J. Brenner, Ph.D., D. Sc., Director, Radiological Research Accelerator Facility, Professor of Radiation Oncology and Public Health, Columbia University, 4 pp.
PDF 134 KB (4 pages)
- Comments from Robert L. Ullrich, Professor, Department of Radiological Health Sciences, Colorado State University, 2 pp.
PDF 70 KB (2 pages)
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Meeting Reports
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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), 4 pp.
PDF 79 KB (4 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
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Reappraisal of Brain Tumor Risk Among U.S. Nuclear Workers:
A 10-year Review. In: Occupational Medicine: State of
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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.
- Cardis E, et al. (1995). Effects of Low Doses and Low Dose Rates of External Ionizing Radiation: Cancer Mortality Among Nuclear Industry Workers in Three Countries. Radiat Res 142:117-132.
- 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)
- Correa P (NO DATE). Morphology and Natural History of Cancer Precursors. Cancer Precursors:45-64.
- 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.
- Curtis RE, et al. (1994). Relationship of Leukemia Risk to Radiation Dose Following Cancer of the Uterine Corpus. JNCI 86(17):1315-1324.
- Darby SC, et al. (1987). Long Term Mortality After a Single Treatment Course with X-rays in Patients Treated for Ankylosing Spondylitis. Br J Cancer 55:179-190.
- Federal Register (2001). Energy Employees Occupational Illness Compensation Act of 2000. List of Covered Facilities. FR Notice, 14 pp.
PDF 446 KB (14 pages)
- Foulds, TH (2001). In response to letter to Secretary Bill Richardson (DOE) dated 12/13/2000, 110 pp.
PDF 3.75 MB (110 pages)
- Gore, Honorable Albert, Jr (2001). Proposed Legislation to Implement the Energy Employees Occupational Illness Compensation Program Act of 2000. Senate, 52 pp.
PDF 1.66 MB (52 pages)
- Greenland S (1999). Relation of Probability of Causation to Relative Risk and Doubling Dose: A Methodologic Error that has Become a Social Problem. Am J Publ Health 89(8):1166-1169.
- 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.
- Grippo PJ and Sandgren EP (2000). Highly Invasive Transitional Cell Carcinoma of the Bladder in a Simian Virus 40 T-antigen Transgenic Mouse Model. Am J Pathol 157(3):805-813.
- Grogan HA, et al. (2001). Risks of Fatal Cancer from Inhalation of 239,240Plutonium by Humans: A Combined Four-method Approach with Uncertainty Evaluation. Health Phys 80(5):447-461.
- Hall EJ (1994). The Deposition of Radiant Energy. In: Radiobiology for the Radiologist, 4th Edition. Philadelphia, PA: JB Lippincott Company, 12 pp.
- Hall EJ and Brenner DJ (1992). The Biological Effectiveness of Neutrons: Implications for Radiation Protection. Radiation Protection Dosimetry 44(1/4):1-9.
- Hall EJ, et al. (1991). Neoplastic
Transformation and the Inverse Dose-rate Effect for Neutrons.
Radiat Res 128:S75-S80.
- 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 Meinhardt TJ (1987). Quantitative Risk Assessment of Lung Cancer in U.S. Uranium Miners. Health Phys 52(4):417-430.
- IARC (no date). IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. Release 1.1. Volumes 1-20, 37, 38, 43-78, Suppl. 7. Lyon, France: International Agency for Research on Cancer.
- ICRP/ICRU (1986). The Quality Factor in Radiation Protection. Bethesda, MD: International Commission on Radiation, ICRU Report No. 40, 30 pp.
- Kerlikowske K, et al. (1997). Comparison of Risk Factors for Ductal Carcinoma in Situ and Invasive Breast Cancer. JNCI 89(1):76-82.
- 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.
- Lubin JH, et al. (1997). Lung Cancer Risk from Residential Radon: Meta-analysis of Eight Epidemiologic Studies. JNCI 89(1):49-57.
- Lubin JH, et al. (1995). Radon-exposed Underground Miners and Inverse Dose-rate (Protraction Enhancement) Effects. Health Phys 69(4):494-500.
- Luebeck EG, et al. (1996). Two-stage Model of Radon-induced Malignant Lung Tumors in Rats: Effects of Cell Killing. Radiat Res 145:163-173.
- Mays CW and Spiess H (1984). Bone Sarcomas in Patients Given Radium-224. In: Radiation Carcinogenesis: Epidemiology and Biological Significance. New York, NY: Raven Press, 12 pp.
- Muirhead CR, et al. (1999). Occupational Radiation Exposure and Mortality: Second Analysis of the National Registry for Radiation Workers. J Radiol Prot 19(1):3-26.
- 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)
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PDF 3.66 MB (81 pages)
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PDF 13.9 MB (370 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/HERB (2001). Table: Secondary Cancer by Gender. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, 35 pp.
PDF 1.82 MB (35 pages)
- Pierce DA, et al. (2000). Radiation-related Cancer Risks at Low Doses Among Atomic Bomb Survivors. Radiat Res 154:178-186.
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- RECA Committee (1996). Final Report on the Radiation Exposure Compensation Act Committee Submitted to the Human Radiation Interagency Working Group. RECA Committee, 31 pp.
PDF 2.29 MB (31 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)
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- Rosenberg D (1986). The Uncertainties of Assigned Shares Tort Compensation: What We Don't Know Can Hurt Us. Risk Analysis 6(3):363-369.
- Seiler FA (1986). Assigned Shares and Combined Insults. Risk Analysis 6(3):371-372.
- 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)
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Page last updated: April 12, 2007
Page last reviewed: May 30, 2008
Content Source: National Institute for Occupational Safety and Health (NIOSH)
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