The Alliance of Nuclear Worker Advocacy Groups (ANWAG) has been involved with the
Energy Employee Occupational Illness Compensation Program Act (EEOICPA) since its
inception. Our members have monitored the implementation of the law by the responsible
agencies, attended and spoke at public meetings, and have offered our concerns to those
agencies, Congress, the Part E Ombudsman, and the press.
We have recently reviewed the July 2008 edition of the Health Physics Radiation Journal which is dedicated to the National Institute of Occupational Safety and Health Office of Compensation Analysis Support’s (NIOSH) scientific papers on their dose reconstruction program and wish to offer a few observations.
ANWAG finds it odd that the Journal did not present any opposing views, as one would expect to find. At the very least, you might have recruited a guest editorialist, as many other journals do in a similar situation, to balance the opposing points of view of NIOSH and its critics with respect to dose reconstruction methodology. That editorialist could have reviewed other systems of dose reconstruction such as those employed the Defense Threat Reduction Agency (DTRA) for the Atomic Veterans since the early 1990s. ORAU is the major contractor for both NIOSH and DTRA dose reconstruction programs [REF 1a]. Yet, NIOSH and DTRA have had major issues with each other scientific methodology [REF 1b,c] and your readers would benefit from knowing about that major interagency controversy within our government. Instead, your portrayal of the NIOSH dose reconstruction program is very one-sided.
One misconception we also see is that NIOSH and its contractor Oak Ridge Associated Universities (ORAU) developed the methodology alone. The authors of the papers recognized that they had input from the interested stakeholders and advocates, yet the submissions to your journal appear that NIOSH and ORAU alone were responsible for the procedures. This portrayal is not quite accurate. While Dr. Paul Zeimer, Chairman of the Advisory Board on Radiation and Worker Health (the Board), acknowledged that the Board has a contractor to assist them, ANWAG feels it is important to note the invaluable contribution made by that contractor, Sanford Cohen and Associates (SC & A). At the direction of the Board, SC & A reviewed the site profiles NIOSH and their contractor issued and reported several deficiencies. In fact, SC & A found and reported in their November 10, 2006 report 33 deficiencies in the Feed Materials Production Center (Fernald) site profile.
We have recently reviewed the July 2008 edition of the Health Physics Radiation Journal which is dedicated to the National Institute of Occupational Safety and Health Office of Compensation Analysis Support’s (NIOSH) scientific papers on their dose reconstruction program and wish to offer a few observations.
ANWAG finds it odd that the Journal did not present any opposing views, as one would expect to find. At the very least, you might have recruited a guest editorialist, as many other journals do in a similar situation, to balance the opposing points of view of NIOSH and its critics with respect to dose reconstruction methodology. That editorialist could have reviewed other systems of dose reconstruction such as those employed the Defense Threat Reduction Agency (DTRA) for the Atomic Veterans since the early 1990s. ORAU is the major contractor for both NIOSH and DTRA dose reconstruction programs [REF 1a]. Yet, NIOSH and DTRA have had major issues with each other scientific methodology [REF 1b,c] and your readers would benefit from knowing about that major interagency controversy within our government. Instead, your portrayal of the NIOSH dose reconstruction program is very one-sided.
One misconception we also see is that NIOSH and its contractor Oak Ridge Associated Universities (ORAU) developed the methodology alone. The authors of the papers recognized that they had input from the interested stakeholders and advocates, yet the submissions to your journal appear that NIOSH and ORAU alone were responsible for the procedures. This portrayal is not quite accurate. While Dr. Paul Zeimer, Chairman of the Advisory Board on Radiation and Worker Health (the Board), acknowledged that the Board has a contractor to assist them, ANWAG feels it is important to note the invaluable contribution made by that contractor, Sanford Cohen and Associates (SC & A). At the direction of the Board, SC & A reviewed the site profiles NIOSH and their contractor issued and reported several deficiencies. In fact, SC & A found and reported in their November 10, 2006 report 33 deficiencies in the Feed Materials Production Center (Fernald) site profile.
SC & A also made significant contributions to many of the scientific methodologies published and used by NIOSH. At the direction of the Board, SC & A would work with NIOSH and their contractor, ORAU, in developing the scientific calculations necessary to reconstruct dose.
The advocates and claimants often do not agree with the assumptions. However, we do feel it is necessary that SC & A be acknowledged for their participation.
The process of developing the site profiles and scientific methodology has been long and arduous and too long for the stakeholders. We have seen a protracted battle to have NIOSH accept documentation or oral histories from the workers and advocates. A case in point is the Special Exposure cohort petition for the Rocky Flats facility. A petitioner stated in the petition that NIOSH was using an incorrect particle size for plutonium. NIOSH, after two years of debate with the petitioners, the Board and the Board’s contractor, SC & A, finally agreed that the petitioners’ claim was correct and revised their methodology, as evidenced in their technical bulletin, ORAUT-OTIB-0049.
Another example of the length of time it takes NIOSH and its contractor to agree to a stakeholder’s assertion is the conflict of interest policy. The paper written by Judson L. Kenoyer, Edward D. Scalsky and Timothy D. Taulbee, employees of ORAU contractor, Dade Moeller and Associates, states, “However, care must be exercised to avoid selecting a Document Owner – or any other team member – who has worked at the specific site in the past; otherwise he or she will be considered by third-party reviewers as having a potential conflict of interest.” For the Rocky Flats facility, NIOSH and the Board were advised of the conflict with the author of the site profile by claimants and advocates in 2003. The author was not removed as an author until 2006. A similar conflict was presented to the Board and NIOSH concerning the Neutron Dose Reconstruction Project for the Rocky Flats plant. Unfortunately, that concern of the advocates with this conflict was ignored.
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