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Probability of Causation (PC) News & Updates
- Increasing the Accuracy and Precision of Probability of Causation
- New Procedure for Resolving Cases Close to 50% PC
- Technical Amendments to the Guidelines for Determining the Probability of Causation
- Dependence of Cancer Risk on Dose and Dose Rate of Low-LET Radiation
- Revision of Guidelines on Non-Radiogenic Cancers
- Changes to the NIOSH-IREP Lung Cancer Risk Model
- Radiogenicity of Specific Cancers
- Changes to the Dose Reconstruction Target Organ Selection for Lymphoma
- Revision to 1985 NIH Radioepidemiological Tables
Increasing the Accuracy and Precision of Probability of Causation
August 2024
NIOSH has been evaluating the accuracy and precision of the 99th percentile Probability of Causation (PC) calculations. This is important when the PC value is close to the 50.0% compensation threshold. We found that we need larger sample sizes when cases are near the 50.0% compensation threshold.
Starting in June 2006, NIOSH processed claims with PC between 45% – 52% using a different methodology. The claims were processed on the IREP Enterprise Edition, using the following steps:
- Increase the sample size from 2,000 to 10,000 iterations.
- Re-run the simulation 30 more times with new random seed values.
- The Average of PC values from all 30 runs determines the claim outcome.
For cases with PC outside the 45% – 52% interval, the calculations used a sample size of 2,000 iterations.
We chose the original sample size of 2,000 to balance the precision and speed of the calculations. This ensured accurate results while keeping the calculation time of the PC reasonable. During the evaluations, NIOSH found a small negative bias at the 99th percentile of the PC; this was more pronounced when using a small sample size of 2,000 iterations. We found out that the bias becomes less significant as the sample size increases.
Therefore, NIOSH recommends increasing the number of iterations from 2,000 to 20,000 iterations in IREP for all cases. With modern computing power, this implementation should have a minimal programmatic impact on the PC calculation time. For most cases, the IREP computation time will increase from a few seconds to less than a minute. Using a larger sample size will reduce the bias to an insignificant level, and it will increase the PC precision.
Since June 2006, we have used the Average PC value from 30 runs with 10,000 iterations to determine a claim outcome; this method was used to increase the precision for claims with PC between 45% and 52%. The methodology has worked well for the past 18 years. It also continues to be an important part of the PC determination. At 10,000 iterations, the bias noted above is much smaller (when compared to 2,000 iterations), but it is still present. Therefore, NIOSH recommends using 30 runs with 20,000 iterations for claims in the 45% – 52% range.
For certain claims very near the compensation threshold, the uncertainty around the Average PC can still be greater than desired. Such claims include large dose uncertainty and/or many exposures. NIOSH recommends a change in the analysis methodology; the following two-step process will be used only for cases with PC between 49.5% to 50.5%:
- First, IREP will perform a rapid calculation to predict the sample size needed to achieve the desired margin of error of 0.1% for the Average PC.
- Next, IREP will use 300 runs with the sample size predicted in the previous step to calculate the Average PC value. A minimum sample size of 20,000 iterations will be used. The Average PC values will determine the claim outcome.
We will apply this new procedure only to a very small number of cases. NIOSH determined that we need this new procedure only for cases that are very close to the compensation threshold of 50.0%.
We announced these proposed changes, and the Advisory Board approved them during their meeting in August 2023.
The extensive research conducted by NIOSH on the accuracy and precision of the PC calculations is described in four papers which we listed as references below.
Soon, NIOSH will develop a program evaluation report reviewing all past claims in the 45% to 52% range. If the new methods described above will indicate a change in PC that may affect the compensation decision, NIOSH will request those claims back from DOL for re-evaluation.
Please note: We are committed to ensuring that all our content is accessible to everyone. Fully accessible versions of the documents below are being prepared and will be available soon. Thank you for your patience and understanding. If you need immediate assistance with these documents, please contact our Website Coordinator.
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NIOSH/DCAS: Increasing the Accuracy of the 99th Percentile of PC White Paper [10 MB (79 pages)]
July 2022 -
NIOSH/DCAS: Effect of Alternative Percentile Definition on PC Values White Paper [2 MB (45 pages)]
October 2021 -
NIOSH/DCAS: Comparison of Several Percentile Definitions [2 MB (66 pages)]
December 2019
New Procedure for Resolving Cases Close to 50% PC
August 2024
NIOSH updated its procedure for resolving cases close to the 50% compensation threshold.
Key points:
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More precise calculations performed for claims near the 50% threshold.
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Multiple simulations used to ensure accurate results.
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Optimized sample sizes used to enhance precision and minimize running time.
Background
Original Method (used at the beginning of the program starting in 2002)
All cases were run with the following procedure:
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Used a single simulation (or run) with sample size of 2,000.
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Used a random seed value of 99.
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PC obtained with these simulation settings determined the claim outcome.
Improved Method (used from 2004)
If the PC from the original method fell between 45% and 50%:
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Increased sample size from 2,000 to 10,000.
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Re-ran the simulation with a new random seed value.
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PC obtained with these simulation settings determined the claim outcome.
Multiple Runs Method (used from June 2006)
If the PC from the original method fell between 45% and 52%:
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Increased sample size from 2,000 to 10,000.
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Re-ran the simulation 30 more times with new random seed values.
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The Average of PC values from all 30 runs determined the claim outcome.
New Methodology as of August 1, 2024
NIOSH’s most recent method builds on the previous ones. The new method ensures that calculations are precise and reliable, with a focus on claims that are close to the 50% cutoff point for compensation.
Presentation and Approval:
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The new method was presented to the Advisory Board on August 16, 2023.
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The Board approved the method.
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The new method was implemented and became operational on August 1, 2024.
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The NIOSH-IREP User’s Guide was revised to reflect the updates.
Main changes introduced by the new method (starting August 2024)
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The default sample size is increased to 20,000 for all claims.
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If the PC falls between 45% and 52%:
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30 more simulations are run with new random seed values.
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If the PC falls between 49.5% and 50.5%:
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300 additional simulations are run with new random seed values.
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Processing Claims with One Primary Cancer
Initial Review
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All claims are first run with a sample size of 20,000 and a random seed of 99.
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The PC obtained determines the claim outcome (unless this value is between 45% and 52%).
Increased Precision (if needed)
If the PC obtained based on one run falls between 45% and 52%:
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Use 30 additional runs of sample size 20,000, and each run will use a new random seed value.
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The Average PC from the 30 runs will determine the claim outcome (unless this average is between 49.5% and 50.5%).
Enhanced Precision (if needed)
If the average of the PC values from the 30 samples falls between 49.5% and 50.5%:
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The IREP Predictive Tool will be used by NIOSH to determine the sample size needed for enhanced precision.
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If the sample size estimated by the IREP Predictive Tool is less than 20,000, a sample size of 20,000 will be used for the 300 runs.
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Run 300 simulations with the recommended sample size.
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Calculate the Average PC value from the 300 runs.
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The average PC value from the 300 runs determines the claim outcome.
Processing Claims with Multiple Primary Cancers
Initial Review
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Each cancer for a claim with multiple primary cancers is first processed using one run with a sample size of 20,000, and a random seed value of 99.
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The PC values from all cancers are combined in IREP using the Multiple Primary Cancers Equation.
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The Combined PC obtained using the Multiple Primary Cancers Equation determines the claim outcome (unless this value is between 45% and 52%).
Increased Precision (if needed)
If the Combined PC obtained from the initial review falls between 45% and 52%:
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Use 30 additional runs of 20,000 for each cancer, and each run will use new random seed values.
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The Average PC from the 30 runs for each cancer are calculated.
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The Average PC values from all cancers are combined in IREP using the Multiple Primary Cancers Equation.
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The Combined PC value obtained using the Multiple Primary Cancers Equation determines the claim outcome (unless this value is between 49.5% and 50.5%).
Enhanced Precision (if needed)
If the Combined PC obtained from the 30 runs falls between 49.5% and 50.5%:
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The IREP Predictive Tool will be used by NIOSH for each cancer to determine the sample size needed for an enhanced precision.
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The maximum value of all the sample sizes suggested by the IREP Predictive Tool for each cancer will be used as the new sample size for all cancers in the next re-run.
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If the maximum value of all the sample sizes is less than 20,000, use a sample size of 20,000 for the 300 runs.
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For each cancer, run 300 more simulations with the maximum sample size previously determined.
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For each cancer, calculate the Average PC value from the 300 runs.
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The Average PC values from all cancers are combined in IREP using the Multiple Primary Cancers Equation.
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The Combined PC value obtained using the Multiple Primary Cancers Equation determines the claim outcome.
IREP Predictive Tool: Ensuring Precise Results
NIOSH developed a special tool to determine the optimal number of iterations needed for accurate results when the PC is very close to 50% (between 49.5% and 50.5%).
Key points:
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The tool ensures precise results by adjusting the number of samples used in a simulation.
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PC precision increases with increasing number of samples in a simulation.
How it works:
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Run 300 simulations with a sample size of 1,000.
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Using a prediction formula, the IREP Predictive Tool estimates the number of samples needed to achieve a very high precision for the PC value (0.1% margin of error).
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If the sample size estimated by the IREP Predictive Tool is less than 20,000, then a minimum sample size of 20,000 will be used to run the 300 additional IREP runs, either for claims with a single primary cancer or for claims with multiple primary cancers.
When is it used?
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Only for claims with PC values between 49.5% and 50.5%.
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For both single and multiple primary cancer claims.
Output:
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The tool provides an estimate of the sample size needed for very accurate results.
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NIOSH includes this information in the dose reconstruction input file sent to DOL.
The following Program Evaluation Report details the effect of this new procedure on previous non-compensable cases.
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Document Number: OCAS-PER-0016 Rev-00
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About this Document: New document to evaluate the effect of implementing a new IREP procedure on previously completed claims.
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Approved: September 25, 2007
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Summary: A total of 109 previously non-compensable claims with PC values of 45% or greater were evaluated. The average PC value remained below the 50% compensation threshold for each of the 109 claims. An itemized list of claims was provided to DOL containing the final evaluation result for each of the 109 claims.
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Technical Amendments to the Guidelines for Determining the Probability of Causation
August 2019
On August 1, 2019, the Department of Health and Human Services (HHS) is revising its regulations to update references to the International Classification of Disease (ICD) codes from ICD–9–CM to ICD–10– CM, and remove outdated references to chronic lymphocytic leukemia from Energy Employees Occupational Illness Compensation Program regulations. These technical amendments have no effect on the cancer eligibility requirement under the Program because all cancer types are eligible to receive a dose reconstruction from NIOSH. Thus, no eligible claimant will be adversely impacted by this rulemaking.
Dependence of Cancer Risk on Dose and Dose Rate of Low-LET Radiation
June 2017
This report describes a study for the National Institute for Occupational Safety and Health (NIOSH) to re-evaluate dose and dose-rate effectiveness factors (DDREFs) for low-LET radiation (photons and electrons) that are incorporated in cancer risk models in the Interactive RadioEpidemiological Program (IREP). The objective of this study was to develop recommendations that provide unbiased representations of the current state of knowledge of DDREFs for low-LET radiation.
Revision of Guidelines on Non-Radiogenic Cancers
March 2012
On March 21, 2011, the Department of Health and Human Services (HHS) proposed to treat chronic lymphocytic leukemia (CLL) as a radiogenic cancer under the Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA or the Act) (76 FR 15268).
CLL is now treated as being potentially caused by radiation and as potentially compensable under the Act. This reverses the earlier decision by HHS to exclude this cancer from consideration. The final rule was published on February 6, 2012. This change became effective on March 7, 2012.
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Notice of Proposed Rulemaking:
Please Note: The Final Rule does not add CLL to the list of “specified cancers” or qualifying cancers for the Special Exposure Cohort.
Public comment on this rulemaking closed on June 20, 2011. A complete electronic docket containing reviews of CLL radiogenicity and the CLL Risk Model and public comments can be found on the NIOSH Docket page, under Docket Number 209: PC – Non-radiogenic Cancer Reconsideration.
Changes to the NIOSH-IREP Lung Cancer Risk Model
December 2010
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Document Number: SCA-TR-PR2010-0008, Rev. 0
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About this Document: Review of OCAS-PER-008
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Approved: December 15, 2010
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Document Number: OCAS-PER-0008 Rev-00
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About this Document: Reports the impact of the NIOSH-IREP lung cancer model on non-compensable cases completed before February 28, 2006.
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Approved: April 12, 2007
The combined lung cancer risk model was introduced on 02/28/06 via the release of NIOSH-IREP Version 5.5, followed by v5.5.1 on 05/16/06. The combined lung model is programmed with two different lung cancer risk models: the NIOSH-IREP model, plus an alternative risk model created by the National Cancer Institute for use in NIH-IREP, another version of IREP (referred to hereafter as the “NIH” model). For each cancer of the lung, trachea, or bronchus, NIOSH-IREP now calculates separately the probability of causation (PC) produced by each of the two risk models and reports the higher PC at the upper 99th percentile credibility limit as the PC value of record for the claim. NIOSH-IREP v5.5 and v5.5.1 also incorporate a bias correction factor for random errors in dosimetry for “never smokers” exposed to radon. Due to a programming oversight, this correction had been omitted for “never smokers”” and was applied only to smokers in earlier versions of NIOSH-IREP. NIOSH-IREP v5.5 corrected this error.
This “combined” lung cancer risk model was endorsed by the Advisory Board on Radiation and Worker Health, and can result in no lower PC value for the same set of claim inputs than had been calculated under previous versions of NIOSH-IREP (versions 5.4 and earlier).
For a more detailed description of the new combined model, including the background of and rationale for the modification, please refer to OCAS-PEP-008 below.
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Document Number: OCAS-PEP-008 Rev-00
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About this Document: New document to evaluate the modification of the NIOSH-IREP lung cancer model on previously competed cases.
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Approved: December 7, 2006
NIOSH-IREP Version 5.5 was installed on February 28, 2006, replacing NIOSH-IREP v5.4. This updated version of NIOSH-IREP incorporates modifications to the lung cancer risk model for calculating PC for cancers of the lung, trachea, or bronchus. Specifically, NIOSH-IREP v5.5 is programmed with two alternative lung cancer risk models. NIOSH-IREP v5.5 calculates separately the PC produced under each risk model for each cancer of the lung, trachea, or bronchus, and reports the higher PC of the two models as the PC of record for the case. This risk model change was endorsed by the Advisory Board on Radiation and Worker Health, with the provision that NIOSH revisit the issue in approximately one year to determine if new evidence might warrant consideration of a single lung cancer risk model. Further details regarding this change, including copies of all relevant documents provided to the Advisory Board on Radiation and Worker Health, can be accessed below.
NIOSH-IREP v5.5 also incorporates a bias correction factor for random errors in dosimetry for “never smokers” who were exposed to radon. Due to a programming oversight, this correction had been inadvertently omitted for “never smokers” and was applied only to smokers in earlier versions of NIOSH-IREP. NIOSH-IREP v5.5 corrects this error.
The modifications incorporated in NIOSH-IREP v5.5 pertain only to the “Lung (162)” risk model and apply only to cancers of the lung, trachea, or bronchus. In conjunction with these revisions, NIOSH will review all relevant previously completed cases that have not been compensated to identify those for which the changes are applicable, and will re-evaluate the cases using the new guidelines. NIOSH will also apply the new guidelines to all currently active cases and any future cases. This may result in the Department of Labor calculating higher PC determinations for select lung, trachea, or bronchus cases among previously decided and current EEOICPA cancer claims. (Note: It will not result in lower PC determinations for any case.)
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Background Information: Proposed Modification of NIOSH-IREP Lung Cancer Risk Model (October 2005)
NIOSH proposes to install the NIH-IREP lung cancer risk model into NIOSH-IREP, but to retain the current NIOSH-IREP lung model as well. Under this proposal, EEOICPA lung cancer cases would be processed by running each case under both IREP models, separately, but NIOSH-IREP would report only the set of results associated with the higher PC at the upper 99th percentile credibility limit. Thus, the higher of the two values at the upper 99th percentile would determine compensability. Should this NIOSH-IREP change be implemented, all previously completed non-compensable EEOICPA lung cancer cases would be re-evaluated.
This proposal is based in part on recommendations obtained from four outside experts who agreed to review the IREP lung models. NIOSH concludes that the points raised by reviewers warrant erring on the side of EEOICPA claimants by adopting the methodology described above.
A letter announcing this proposed change, along with eight supporting documents including the four expert opinions, was delivered to ABRWH members in late September 2005. These documents, taken together, provide a detailed explanation and chronology of the factors leading to this proposal. Links to the nine documents are provided below:
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Changes to the NIOSH-IREP Lung Cancer Risk Model: Request for comments regarding a change to a scientific element underlying the determination of PC under EEOICPA
NIOSH has changed a guideline for determining the PC under the EEOICPA for energy employees with cancers of the lung, trachea, or bronchus. The change affects only the NIOSH-IREP cancer risk model termed “Lung (162).” The new guideline, which became effective on February 28, 2006, with the introduction of NIOSH-IREP Version 5.5, requires the use of both a National Institutes of Health (NIH)-IREP lung model implemented by NIH in 2003 and the original NIOSH-IREP lung model implemented by NIOSH in 2002. NIOSH-IREP Version 5.5 calculates separately the PC produced under each model for each cancer of the lung, trachea, or bronchus. The result from the model that produces the higher PC at the upper 99th percentile credibility limit is reported as the PC result of record for the case. NIOSH-IREP Version 5.5 also incorporates a bias correction factor for random errors in dosimetry for those energy workers who had not smoked cigarettes (“never smokers”) and who were exposed to radon. This correction was previously applied to smokers, but had been inadvertently omitted for never smokers. These changes may result in DOL calculating higher PC determinations for select cases of cancer of the lung, trachea, or bronchus among previously decided and current EEOICPA cancer claims. The changes cannot result in any lower PC determinations. Although this change to the NIOSH-IREP lung cancer risk model took effect February 28, 2006, NIOSH will fully consider all comments received regarding this change and may reconsider this change or consider further revisions to the lung cancer risk model based on public comment.
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Radiogenicity of Specific Cancers
December 2009
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About this Document: In response to Senate Report (S. Rep.) 109-103 (2005), NIOSH examined the evidence for the radiogenicity1 of 11 “non-presumptive cancers,” which were not included in the list of 22 “specified cancers” referenced in the Energy Employees Occupational Illness Compensation Program Act of 2000 as Amended (EEOICPA)
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Sent to Congress: December 17, 2009
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Summary: Review of the evidence of radiogenicity of specific cancers indicates that there is strong epidemiologic evidence for the radiogenicity of basal cell carcinoma and insufficient evidence for larynx, CLL, lymphoma (Hodgkin’s), male genitalia, oral cavity, prostate, skin (squamous cell), uterus, and malignant melanoma.
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About this Document: In response to Senate Report (S. Rep.) 109-103 (2005), NIOSH examined the evidence for the radiogenicity1 of 11 “non-presumptive cancers,” which were not included in the list of 22 “specified cancers” referenced in the Energy Employees Occupational Illness Compensation Program Act of 2000 as Amended (EEOICPA)
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Sent to Congress: June 2007
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Summary: Review of the evidence of radiogenicity of specific cancers indicates that there is strong epidemiologic evidence for the radiogenicity of basal cell carcinoma and insufficient evidence for larynx, CLL, lymphoma (Hodgkin’s), male genitalia, oral cavity, prostate, skin (squamous cell), uterus, and malignant melanoma.
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Changes to the Dose Reconstruction Target Organ Selection for Lymphoma
March 2007
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Target Organs for Lymphoma[17 KB (2 pages)]
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Document Number: OCAS-PER-009 Rev-00
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About this Document: New document to change target organs for lymphoma.
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Approved: March 8, 2007
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Summary: In February, 2006, OCAS determined that the internal and external dosimetry target organs used for several forms of lymphoma should be changed. The detailed rationale for this decision is described in OCAS-TIB-012. The change resulted from a detailed investigation by OCAS of the etiology of lymphoma.
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Document Number: Federal Register / Vol. 71, No. 31, page 7969
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Published: February 15, 2006
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About this Document: Announced that NIOSH changed the selection of target organs used in dose reconstructions. The change responds to an evaluation by NIOSH of current scientific data on lymphoma, which revealed that the site of the radiation injury can differ from the site of the tumor or cancer origin documented in the medical files of a lymphoma cancer patient. The new process for selecting dose reconstruction target organs for energy employees with lymphoma cancers includes selecting the target organ that would have received the highest radiation dose from among relevant, possibly irradiated organs, as determined through the dose reconstruction process, when the identity of the target organ is in question. This change may result in the Department of Labor calculating higher probability of causation determinations for select lymphoma cases among previously decided and current EEOICPA cases.
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Document Number: OCAS-TIB- 0012, Rev. 1
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Approved: February 10, 2006
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About this Document: Re-evaluates target organ selection for lymphatic/hematopoietic cancers.
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Summary of NIOSH’s Re-examination of Lymphoma Target Organ Selection[17 KB (2 pages)]
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Approved: October 31, 2005
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About this Document: NIOSH proposed to modify the selection of target organs so that the dose to the highest plausible organ is used in the dose reconstruction.
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Revision 1985 NIH Radioepidemiological Tables
September 2003
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Report of the NCI-CDC Working Group to Revise the 1985 NIH Radioepidemiological Tables
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Document Number: NIH Publication No. 03-5387
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About this Document: This updated report uses epidemiological dose-response data and uncertainty analyses in providing a scientific basis for quantifying radiation-related cancer risks. The tabular version is an interactive radio-epidemiological computer program known as “NIH-IREP” and corresponds to the report. NIH-IREP can be accessed Online at http://www.irep.nci.nih.gov/.
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Published: September 2003
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