ating claims but noted that the program had no independent review process. In December 2000, the National Research Council formed a committee in response to a charge by Congress that directed it to evaluate randomly sampled dose reconstructions and address these four issues:
Whether or not the reconstruction of the sample doses is accurate.
Whether or not the reconstructed doses are accurately reported.
Whether or not the assumptions made regarding radiation exposure based on the sampled doses are credible.
Whether or not the data from nuclear tests used by DTRA as part of the reconstruction of the sampled doses are accurate.
The committee was also asked to recommend whether there should be a permanent system of review for the dose reconstruction program.
A number of laws and regulations apply to the dose reconstruction program. In particular, under 38 CFR 3.309, veterans who are confirmed participants and have any of 21 cancers are eligible for compensation regardless of their radiation exposures; this is often called the presumptive regulation. The list of cancers considered “presumptive” has been added to over the years. A different regulation, 38 CFR 3.311, applies to other diseases; this is the “nonpresumptive” regulation. For them, a dose assessment is used to help evaluate whether a veteran’s disease is at least as likely as not to have been caused by radiation exposure during atomic testing. Furthermore, the veteran is to be given the benefit of the doubt in evaluating a claim for a nonpresumptive disease if his participation cannot be definitely confirmed. He is also to be given the benefit of the doubt in estimating his dose. Dose reconstruction involves estimating the most likely dose that a veteran received and also a higher number called an upper-bound dose, which is the dose to be considered in deciding compensation. For skin, eye, and inhalation exposures, only an upper bound is estimated. A stated goal of the dose reconstruction program is that there not be more than a 5% chance that the reported upper bound is lower than the actual dose the veteran received.
Radiation dose reconstruction can be tedious and complicated. Often historical information is lacking about individual activities that would help in estimating a dose. The committee recognized the difficulties that would face any agency or organization that took on this challenge. In addition, the science involved in dose reconstruction has changed in the last 25 years. For all those reasons, independent review of the process is important.
On the basis of its review of 99 individual dose reconstructions and other program documents, the committee reached these conclusions:
Although the methods used to estimate average doses to participants in various units are generally valid, many participants did not wear film badges all the times that they might have been exposed, so individual doses are often highly uncertain.