Ten Year NIOSH Program Review
2010 marked the tenth anniversary of the passage of EEOICPA. Under EEOICPA, the President delegated to the Secretary of HHS the tasks of performing radiation dose reconstructions and evaluating petitions to add classes of employees to the SEC. As of December 31, 2010, NIOSH had completed 27,832 radiation dose reconstructions and had received for 182 SEC petitions to be considered for adding classes of employees to the SEC.
Given the passage of 10 years and the considerable amount of work that has been accomplished by NIOSH in support of EEOICPA, the Director of NIOSH commissioned a ten year retrospective review of NIOSH’s efforts.
The ten year review was conducted by NIOSH employees and CDC/NIOSH contractors who were familiar with NIOSH’s activities under EEOICPA, but not directly involved in the supervision of those activities. Draft reports were developed and public comments were received on the draft reports. Since that time, the five reports have been finalized and consideration given to the public comments received.
More information on the review such as Federal Register Notices, materials previously under consideration, and public comments on the review can be found on the NIOSH Docket 194.
The document below contains a list of the overall recommendations from the final reports on the five topic areas under consideration for the ten year review:
The document below contains a list of the action items NIOSH is currently working on in response to the ten year review recommendations:
Final Review Report on the Quality of Science
- Issues related to documentation
Action 1: DCAS will explore the use of tools (such as data base management tools) to minimize the possibility of inconsistencies between NIOSH Procedures.
Action 2: DCAS will develop a list of products it will submit to external peer review, consistent with the recommendation to make broader use of peer review within the program.
- Issues related to modification of the procedures data base
Action 1: DCAS will explore modifications of the Procedures database that would include information on the resolution of comments from all sources. DCAS will develop an estimate of the cost to implement such modification, and prioritize such an implementation relative to the implementation of other recommendations that result from the Program Review.
- Issues related to indirect exposure assessments
Action 1: DCAS will perform a trial run on one or two sites that will allow for the validation of the exposure assessment methodology used by DCAS in a completed program action. The Savannah River Site will be used for one of these trial runs.
- Issues related to “better” characterization of claimant favorability.
Action 1: DCAS will consider how best to undertake such a task and report back to NIOSH Leadership.
- Issues related to review of OTIB 0020
Action 1: DCAS will review as appropriate modify that OTIB.
- Issues related surrogate data
Action 1: DCAS will undertake a detailed review of the EPA methodology. Consistent with efforts to diversify the accomplishment of program tasks. DCAS will invite “other than Health Physicists” to join in the performance of such a review.
Final Review Report on the Timeliness of Task Accomplishments
- Issues related to higher priority to returns
Action 1: DCAS will continue its current efforts to give higher priority to returns.
Action 2: DCAS will share with the Program Review team its current targets for processing returns.
- Issues related to aggressive time limits for dose reconstructions
Action 1: DCAS will prepare cost estimates for the realization of more aggressive time limits for dose reconstructions and prioritize such efforts relative to the implementation of other Program Review recommendations.
- Issues related to aggressive time limits for the completion of the review of SEC petitions
Action 1: The DFO and the DCAS Director will discuss this issue with the Board Chair and explore strategies for realizing this recommendation while working in conjunction with the Board.
Action 2: DCAS will prepare a white paper that lays out a plan for realizing this recommendation. The white paper will be based upon NIOSH and the Board limiting their initial efforts in review of an SEC Petition to only those issues raised by the Petition. Should other issues arise that are worthy of consideration, these issues would be addressed through other means, such as 83.14 petitions.
Final Review Report on the Special Exposure Cohort
- Issues related to separating “policy” issues from “science” issues
Action 1: DCAS will prepare a draft of a Petition Evaluation Report that includes a section that identifies all important “decision points,” and provides the rational for the path chosen by DCAS in its report. NIOSH Leadership will review such a draft evaluation report to identify the “nature” of the decisions made. If those decision points are determined to be “policy” decision points, the appropriate level in the organization as to where such decisions should be made will be identified.
- Issues related to the definition of sufficient accuracy
Action 1: DCAS will develop a series of paragraphs that begin to define, to the degree possible, aspects of a definition of “sufficient accuracy.”
Action 2: NIOSH Leadership will review such paragraphs and provide feedback to DCAS.
- Issues related to a possible health physics bias
Action 1: In drafting the paragraphs related to the definition of sufficient accuracy, DCAS will consult with “other than Health Physicists.” In this way it can start to explore the contributions that can be made to the program by other disciplines.
Final Review Report on Dose Reconstruction
- Issues related to QA/QC
Action 1: DCAS/ORAU will provide documentation of current in place QA/QC efforts, including QA/QC plans and the results of several years of use of such plans.
Action 2: DCAS will work with the Subcommittee on Dose Reconstruction as they explore DCAS QA/QC efforts.
Action 3: DCAS will provide an answer to the question, “If the Board’s review has found an “error” in DCAS’s efforts, why was that error not found by the internal DCAS/ORAU QA/QC review?”
- Issues related to use of efficiency measures
Action 1: DCAS will review current communications to those filling claims, and where necessary make improvements in such communications.
Action 2: DCAS will perform a cost benefit analysis of the elimination of the use of overestimating dose reconstructions.
Action 3: DCAS will prioritize the elimination of overestimating dose reconstructions relative to their implementation of other Program Review recommendations.
Final Review Report
- Issues related to using customer supplied information
Action 1: DCAS will review current communications vehicles and where appropriate will make improvements in such vehicles.
- Issues related to understandability and quality of information
Action 1: DCAS will continue ongoing efforts to evaluate and improve the understandability and quality of DCAS communication vehicles.
- Issues related to access to information
Action 1: DFO and staff will continue efforts to see that Board and Work Group work products are posted on the website as soon as practical.
- Issues related to perceived burden on claimants and petitioners
Action 1: DCAS will consider its current communications strategies as they might present perceived burdens to claimants and petitioners, particularly in light of the real burden felt by those individuals through their interactions with the DOL.
- NIOSH Progress on Issues and Action Items from the Final Report
Federal Register Notices, final reports, materials under consideration, and public comments on the review can be found on the NIOSH Public Docket Website, Radiation Dose Reconstruction Review page.