Public Docket for 42 CFR 81 (Probability of Causation)

Public Comments – In Order of Received

• Comments from Rhonda Bogard. NIOSH Comments, 3 pp. Received on March 1, 2002. [123 KB (3 pages)]
• Comments from the Advisory Board on Radiation and Worker Health, 5 pp. Received on February 7, 2002. [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. [390 KB (8 pages)]
• Comments from Private Citizen. Causation, 1 pg. Received on January 23, 2002.[12 KB (1 page)]
• Comments from Private Citizen. Comments on 42 CFR 81 and 82, 2 pp. Received on January 23, 2002. [69 KB (2 pages)]
• Comments from Private Citizen. Energy Employees Occupational Illness Compensation Program of 2000, 4 pp. Received on December 5, 2001. [103 KB (4 pages)]
• Comments from Michael Schaeffer, Program Manager/Senior 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. [95 KB (3 pages)]
• Comments from Mark Griffon, PACE HP Consultant. PC Comments, 6 pp. Received on December 5, 2001. [305 KB (6 pages)]
• Comments from William Slattery, President, Atlantic Legal Foundation. Comments on Proposed 42CFR81, 3 pp. Received on December 4, 2001.[76 KB (3 pages)]
• Comments from Frank M. Roddy. Comments on 42CFR81, 2 pp. Received on December 4, 2001.[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.[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.[182 KB (4 pages)]
• Comments from Sheryl Burrows. Comments on Proposed 42CFR Part 81, 2 pp. Received on December 4, 2001.[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.[363 KB (8 pages)]
• Comments from George Anastas, President, Health Physics Society. HPS Comments on 42CFR81, 11 pp. Received on December 4, 2001.[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.[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.[102 KB (3 pages)]
• Comments from Private Citizen, 3 pp. Received on December 3, 2001.[77 KB (3 pages)]
• Comments from Dorothy C. Clayton. Proposed Rulemaking on Probability of Causation, 56 pp. Received on December 3, 2001.[2 MB (56 pages)]
• Comments from Charles Land, NCI. IREP, 2 pp. Received on November 26, 2001.[110 KB (2 pages)]
• Comments from Chauncey Starr, President Emeritus, Electric Power Research Institute. NIOSH-IREP, 1 pg. Received on November 26, 2001.[20 KB (1 page)]
• Comments from Richard Wilson. IREP, 2 pp. Received on November 25, 2001.[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.[171 KB (5 pages)]
• Comments from Dianne Lentz. Compensation Payments, 1 page. Received on November 5, 2001.[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.[460 KB (9 pages)]
• Comments from Craig Anderson. Comments on Probability of Causation, 5 pp. Received on November 4, 2001.[168 KB (5 pages)]
• Comments from Roger Shaw. Information Request, 1 pg. Received on November 2, 2001.[27 KB (1 page)]
• Comments from Alexandre Klementiev. Comments on Probability of Causation, 2 pp. Received on October 29, 2001.[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.[98 KB (2 pages)]
• Comments from Carter K. Kirk, URS Corporation. NOPRM Comments 42 CFR Part 81, 1 page. Received on October 22, 2001.[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.[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.[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.[31 KB (1 page)]
• Comments from Candace Elizabeth Benson Peyer-Bellows. Work Related Radiation Exposure, 2 pp. Received on October 12, 2001.[99 KB (2 pages)]
• Comments from Mindy Newby, Compensation for Nuclear Workers, 1 pg. Received on October 07, 2001.[33 KB (1 page)]
• Comments from Private Citizen. Compensation for Direct Workers of Nuclear Energy Materials, 1 pg. Received on October 5, 2001.[18 KB (1 page)]

Subject Matter Expert Reviews of NIOSH-IREP

• Comments from David G. Hoel, Ph.D., University Professor, Medical University of South Carolina, 6 pp.[157 KB (6 pages)]
• Comments from Richard Hornung, University of Cincinnati, 4 pp.[157 KB (4 pages)]
• Comments from David Richardson, Department of Epidemiology, School of Public Health, University of North Carolina, 6 pp.[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.[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.[439 KB (5 pages)]

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.[134 KB (4 pages)]
• Comments from Robert L. Ullrich, Professor, Department of Radiological Health Sciences, Colorado State University, 2 pp.[70 KB (2 pages)]

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.[121 KB (3 pages)]
• OCAS Trip/Meeting Report; Washington, D.C.; 04/03/2001. Discussion with Administrator of Veteran’s Administration “Atomic Workers” Compensation Program, 3 pp.[176 KB (3 pages)]
• OCAS Meeting Report; Cincinnati, Ohio; 04/10/2001. Discussion and demonstration of IREP, 4 pp.[184 KB (4 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.[790 KB (28 pages)]

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.[90 KB (3 pages)]
• Comments from JJ Fix (04/17/2001), 2 pp.[80 KB (2 pages)]
• Comments with enclosure from G Bell (04/17/2001), 5 pp.[208 KB (5 pages)]
  • Enclosure, 36 pp.[1.3 MB (36 pages)]
• Comments from AC Upton of the Consortium for Risk Evaluation with Stakeholder Participation (04/17/2001), 1 pg.[38 KB (1 pages)]
• Comments with enclosure from WJ Klemm (04/25/2001), 9 pp.[436 KB (9 pages)]
  • Enclosure, 11 pp.[720 KB (11 pages)]
• Comments from DO Stram of the University of Southern California (04/26/2001), 3 pp.[167 KB (3 pages)]
• Comments from PL Ziemer of Purdue University (04/30/2001), 4 pp.[157 KB (4 pages)]
• Comments from WK Sinclair of NCRP (05/01/2001), 2 pp.[57 KB (2 pages)]
• Comments from K Ringen of the Center to Protect Workers’ Rights (05/01/2001), 4 pp.[168 KB (4 pages)]
• Comments from PS Rohwer of the Health Physics Society (05/02/2001), 17 pp.[760 KB (17 pages)]
• Comments from JE Till of the Risk Assessment Corporation (05/07/2001), 2 pp.[105 KB (2 pages)]
• Comments from R Wilson of Harvard University (05/24/2001), 4 pp.[79 KB (4 pages)]
• Comments from AC Thadani of the Nuclear Regulatory Commission (05/31/2001), 4 pp.[171 KB (4 pages)]
• Comments from R Miller of the Government Accountability Project (06/17/2001), 19 pp.[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.[78 KB (3 pages)]

References

• Alexander V and DiMarco JH (2001). Reappraisal of Brain Tumor Risk Among U.S. Nuclear Workers: A 10-year Review. In: Occupational Medicine: State of the Art Reviews. Philadelphia, PA: Hanley and Belfus, Inc., 27 pp.
• Anderson M, et al. (1993). Leukemia and Other Related Hematological Disorders Among Danish Patients Exposed to Thorotrast. Radiat Res 134:224-233.
• 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.[311 KB (7 pages)]
• Congress (2000). Title XXXVI–Energy Employees Occupational Illness Compensation Program Act of 2000. 31 pp.[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.[666 KB (13 pages)]
• Congress (1974). 38 FR 34530. Federal Register, 9 pp.[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.[446 KB (14 pages)]
• Foulds, TH (2001). In response to letter to Secretary Bill Richardson (DOE) dated 12/13/2000, 110 pp.[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.[1.7 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.[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.[2.8 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.[3.66 MB (81 pages)]
• NIH (1985). Report of the National Institutes of Health Ad Hoc Working Group to Develop Radioepidemiological Tables. Responding to the Congressional Mandate Uncer Section 7(b) of the Orphan Drg Act of January 4, 1983 (PL 97-414). National Institutes of Health, 370 pp.[14 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.[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.[1.9 MB (35 pages)]
• Pierce DA, et al. (2000). Radiation-related Cancer Risks at Low Doses Among Atomic Bomb Survivors. Radiat Res 154:178-186.
• Preston DL, et al. (1994). Cancer Incidence in Atomic Bomb Survivors. Part III: Leukemia, Lymphoma, and Multiple Myeloma, 1950-1987. Radiat Res 137:S68-S97.
• RECA Committee (1996). Final Report on the Radiation Exposure Compensation Act Committee Submitted to the Human Radiation Interagency Working Group. RECA Committee, 31 pp.[2.3 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.[1.66 MB (52 pages)]
• Robins J and Greenland S (1989). The Probability of Causation Under a Stochastic Model for Individual Risk. Biometrics 45:1125-1138.
• Ron E, et al. (1998). Skin Tumor Risk Among Atomic-bomb Survivors in Japan. Cancer Causes and Control 9:393-401.
• Ron E, et al. (1995). Thyroid Cancer After Exposure to External Radiation: A Pooled Analysis of Seven Studies. Radiat Res 141:259-277.
• 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.[76 KB (4 pages)]
• Thompson DE, et al. (1994). Cancer Incidence in Atomic Bomb Survivors. Part II: Solid Tumors, 1958-1987. Radiat Res 137:S17-S67.
• 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.
• WHO (1977). Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death. Volume 1. Geneva: World Health Organization.
• WHO (1977). Manual of the International Statistical Classification of Diseases, Injuries, and Causes of Death. Volume 2. Geneva: World Health Organization.
• 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.