3

Site Exposure Matrix Database

The Department of Labor’s (DOL’s) Site Exposure Matrix (SEM) database (www.sem.dol.gov) is an important tool in the claims adjudication process for workers and contactors covered by the Energy Employees Occupational Illness Compensation Program Act (EEOICPA) Part E and the Radiation Exposure Compensation Act (RECA). SEM is a Web-accessible database of site-specific information, including a list of toxic substances that have been identified at Department of Energy (DOE) and RECA facilities and covered by EEOICPA Part E. In order to facilitate consolidation of information on DOE facilities, the DOL worked with a contractor to develop a database to store site-specific data, such as a list of DOE EEOICPA-covered facilities, an inventory of toxic substances present at each facility, job descriptions, and production processes. As of October 2012, there were 13,697 toxic substances listed in SEM (DOL, 2012e).

In this chapter, the committee discusses the development, content, structure, and updating of SEM, as well as its strengths and weaknesses. The committee recognizes that the database might be more accurately described as a “hazardous substance” rather than an “exposure” database. Exposure information—that is, the potential of a toxic substance to enter the body and cause harm—includes route (inhalation, dermal, oral), intensity (concentration, dose), duration, and frequency. Such information is not included in the database.

Although the majority of recommendations for improving SEM are provided in Chapter 4, specific suggestions are made in this chapter that could address some of the criticisms DOL has received from the Government Accountability Office (GAO), the DOL ombudsman, and the public. In accordance with its charge, the committee focused on the links between toxic substances and associ-



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3 Site Exposure Matrix Database T he Department of Labor’s (DOL’s) Site Exposure Matrix (SEM) database (www.sem.dol.gov) is an important tool in the claims adjudication process for workers and contactors covered by the Energy Employees Occupa- tional Illness Compensation Program Act (EEOICPA) Part E and the Radiation Exposure Compensation Act (RECA). SEM is a Web-accessible database of site- specific information, including a list of toxic substances that have been identified at Department of Energy (DOE) and RECA facilities and covered by EEOICPA Part E. In order to facilitate consolidation of information on DOE facilities, the DOL worked with a contractor to develop a database to store site-specific data, such as a list of DOE EEOICPA-covered facilities, an inventory of toxic sub- stances present at each facility, job descriptions, and production processes. As of October 2012, there were 13,697 toxic substances listed in SEM (DOL, 2012e). In this chapter, the committee discusses the development, content, structure, and updating of SEM, as well as its strengths and weaknesses. The committee recognizes that the database might be more accurately described as a “hazardous substance” rather than an “exposure” database. Exposure information—that is, the potential of a toxic substance to enter the body and cause harm—includes route (inhalation, dermal, oral), intensity (concentration, dose), duration, and frequency. Such information is not included in the database.  Although the majority of recommendations for improving SEM are provided in Chapter 4, specific suggestions are made in this chapter that could address some of the criticisms DOL has received from the Government Accountability Office (GAO), the DOL ombudsman, and the public. In accordance with its charge, the committee focused on the links between toxic substances and associ- 51

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52 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE ated occupational diseases found in SEM. These links are imported solely from the “Diseases” field in the Haz-Map database (see Chapter 2). USE OF SEM IN THE EEOICPA CLAIMS PROCESS For context on how SEM is used, DOL provided the committee with an overview of the EEOICP claims process (see Figure 3-1). Each pathway shows that information in the database is not the final determinant of either an expo- sure pathway (Figure 3-1a) or a toxic substance–disease link (Figure 3-1b). For example, a claims examiner uses the claimant’s employment history to verify that the claimant was potentially exposed to a toxic substance based on location, job category, or process (Figure 3-1a). Based on a claimant’s employment his- tory and medical information, a claims examiner can also check to see whether a causal link between the claimant’s disease and any toxic substance exists in SEM (Figure 3-1b). DOL appears to use “Exposure Pathway” to indicate the presence or absence of a substance at a DOE site. If a causal link is found in the data- base, the claims examiner can recommend that the claim be accepted if a well- rationalized link between the claimant’s diagnosis and occupational exposure to a toxic substance is supplied by the treating physician and an exposure pathway is evident (Figure 3-1). If a link between a claimant’s disease and exposure to a toxic substance is not given in the database, the claimant may provide additional supporting information and statements from the treating physician regarding the etiology of his or her disease. The claims examiner may further refer the claim to a toxicologist, a district medical consultant, or an industrial hygienist for further evaluation before a decision is made to accept or deny the claim (DOL, 2012e). SEM is periodically updated. As the introductory website states: The exposure and diagnosed illness information provided on this website is not complete. Toxic substance use at each facility is continuously evaluated and new substances are added as their presence is discovered. DOL places SEM data on the Internet in an ongoing effort to obtain and organize exposure and disease in- formation for all covered Part E facilities. The website was developed to support DOL Part E claims adjudication. The information presented is not an attempt to provide a complete history of any DOE or RECA facility. (http://www.sem.dol. gov; accessed January 24, 2013) DOL states that “SEM represents the most current, accurate, and comprehensive information regarding toxic substances and their known health effects, and is updated regularly” (DOL, 2008). The current version of the database used by claims examiners and the version available to the public on the Internet contain the same information, although initially there were differences in the available information due to DOE security concerns. DOL asserts that the security con- cerns have been resolved and that there are no longer differences between the content of the public and the internal SEM databases (Anders, 2012a).

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SITE EXPOSURE MATRIX DATABASE 53 Yes IH Referral Question as to Yes } Exposure Level? No Accept EE 1/2 Exposure EE 3 Does SEM Show Yes OHQ Exposure Pathway? Review DAR Claimant Records No FWP No RD to Deny Exposure Pathway Found? (a) Exposure Figure 3-1a RD to Accept Yes Did treating physician provide Yes a well-rationalized link between Dx No DMC } and toxin? EE 1/2 Medical SEM Records Show Link? Dx DMC or Treating Toxicologist Physician Yes No Literature showing link provided? No RD to Deny and/or Either RD to Accept, or to Yes Did treating Treating Physician physician provide or DMC some rationale for a causative link requiring further (b) Medical review? No RD to Deny FIGURE 3-1  The DEEOIC claims process for determining (a) exposure and (b) medical information. This flow diagram was created by DEEOIC staff to describe the use of SEM in the claims process. NOTE: DAR = document acquisition request; DMC = district medical consultant; Dx = diagnosis; EE 1/2 = employee’s claim form and survivor’s claim form; EE 3 = employment history form; FWP = former Figure 3-1b IH = industrial hygiene; OHQ = occupa- worker program; tional health questionnaire; RD = recommended decision; SEM = site exposure matrix. SOURCE: Anders, 2012b.

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54 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE Any judgment regarding whether exposure to a toxic substance causes a specific health effect requires a clear definition of the exposure of interest. SEM provides a set of indicators showing which exposures are presumed to occur in which occupations. The entries in the database indicate whether a worker in a specific job is considered potentially exposed to a given substance, but they con- tain no information on the probability of exposure, or the intensity, duration, or route of exposure. In order to assess the validity of links between an occupational exposure and disease, the committee recognized the need to consider the range of exposure scenarios involving concentrations, duration, and route of exposure to a toxic substance. DEVELOPMENT OF SEM Development of SEM began in early 2005 with database design criteria and a pilot project. It continues to expand as new information becomes available. DOL’s goal is to identify all possible toxic substances that had been used at DOE sites. The database was populated with data from more than 11,000 documents collected from DOE sites and archives (Stalnaker, 2012). According to the DOL SEM contractor, sources of information included the following: • worker and site interviews; • record gathering on the substances used at major DOE facilities (e.g., work procedures, industrial hygiene reports, safety analysis reports, job hazard analyses); • federal and state agencies (e.g., U.S. Environmental Protection Agency [EPA], State of Colorado); • National Institute for Occupational Safety and Health (NIOSH) profiles; • textbooks; • former Worker Program documents; and • other credible sources (as cited by the DOL contractor). SEM does not indicate the actual source of any of the site-specific informa- tion. Therefore, the user is unable to ascertain whether all potential sources of information have been identified and used to develop the list of toxic substances present at a particular site. However, the public, including former workers, may submit both site-related and disease-related information directly to DOL on the database website (see discussion of external submissions to SEM) (http://www. sem.dol.gov/ComposeSubmittal.cfm). Creating and updating SEM requires DOE cooperation because it must approve the declassification of any site information, including inventories of toxic substances. The database also contains information about occupational diseases that are associated with each toxic substance found at a site. DOL determined that an appropriate source for such associations was Haz-Map,which is published

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SITE EXPOSURE MATRIX DATABASE 55 online by the National Library of Medicine (NLM), and contains a variety of information about occupational exposures and diseases for more than 7,000 toxic substances (see Chapter 2). The committee used the publicly available SEM database (http://www.sem. dol.gov/expanded; DOL, 2012e) for its review. The review is based on many hours of accessing the database and an overview of the database by its developer at the committee’s first open session. The committee was not given specific infor- mation on the architecture of the database, although its structure affects how the database functions, including its search capabilities. An online user’s guide is available for SEM that explains the database content, how to search for specific toxic chemicals, and how to filter the results (http://www.sem.dol.gov/expanded/ help.cfm; DOL, 2012c). CONTENT AND STRUCTURE OF SEM SEM is a site exposure–driven database. To access information on toxic substances, the user must first choose a specific DOE site. Although this feature assists users by taking them immediately to a chosen site, the system may be cumbersome for those who worked at more than one site because each site must be searched independently and results cannot be electronically combined. The database contains information in two general categories: site-specific exposure information for DOE facilities and universal information (all toxic substances and associated health effects) (see Figure 3-2). Each DOE site may be searched for information on site history, labor categories, processes that used toxic substances, areas and buildings where toxic substances were present, and incidents involving toxic substances. For example, a health physics technician at the Alba Craft site may have worked in four different buildings and performed concrete cutting, debris reduction operations, decontamination activities, decon- tamination and demolition activities, excavation and backfilling activities, and site waste packaging and shipment activities (see Figure 3-3). This worker may have been exposed to cement, diesel exhaust, gasoline, Hantavirus, Histoplasma capsulatum, kerosene, petroleum mid-distillate, and uranium. Magnifying glass icons next to substances, buildings, and processes indicate that more information is available. In this example, by clicking on the icon next to kerosene, the user can view chemical information and properties for kerosene, the buildings, processes, and labor categories potentially exposed to kerosene at Alba Craft and specific health effects from the Haz-Map database (see Figure 3-3). Specific Health Effects in SEM DOL and its contractor control and choose what information from Haz-Map is used in SEM. The “Specific Health Effects” field for each toxic substance in SEM is populated directly from the Haz-Map “Diseases” field (see Chapter 2 and

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56 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE FIGURE 3-2  SEM search options for a specific DOE site. The Clarksville Facility is shown in this example. SOURCE: DOL, 2012e. Figure 3-3). The “Specific Health Effects” field contains health effects informa- tion based solely on “established relationships between toxic substance expo- sures and occupational diseases as reported by the National Library of Medicine (NLM) on its Haz-Map website (http://Haz-Map.nlm.nih.gov)” (DOL, 2012c). Although DOL relies on the NLM Haz-Map database for toxic substance–occu- pational disease links, NLM does not establish those causal associations as might be implied from that statement. As stated on the NLM website, “the views and opinions of authors expressed on NLM Web sites do not necessarily state or reflect those of the U.S. Government” (NLM, 2012). No other health effects information from a Haz-Map toxic substance profile (see Chapter 2 for all the database fields) is included in SEM (Stalnaker, 2012). For example, in the kerosene profile, Haz-Map lists “CNS solvent syndrome” and “secondary hepatoxin” as adverse effects and “chronic solvent encephalopathy” and “solvents, acute toxic effect” as the occupational diseases that may result

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SITE EXPOSURE MATRIX DATABASE 57 FIGURE 3-3  Example of SEM record for a health physics technician at the Alba Craft Facility. SOURCE: DOL, 2012e.

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58 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE FIGURE 3-4  Example of SEM record for kerosene found at the Alba Craft site. SEM database queried on October 2, 2012. from exposure to kerosene (see Box 2-1), but, only the latter two health effects are included in SEM (see Figure 3-4). Furthermore, SEM does not include any health effects that are not covered under Part E (e.g., birth defects), even if that health effect is included in Haz-Map, that is, it includes only those health effects that may be compensable under EEOICPA.

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SITE EXPOSURE MATRIX DATABASE 59 While more comprehensive information about the health effects associated with a toxic substance is available from Haz-Map (for example, skin designa- tions), the DOL explicitly instructs its claims examiners to use only Haz-Map information that is included in SEM. The Claims Examiner Manual states: The occupational disease links in SEM are imported from the widely accepted and well rationalized medical science database called Haz-Map, a database of the National Library of Medicine (NLM). While the NLM database, Haz-Map, is often utilized in other circumstances as a resource, the claims examiner must never use Haz-Map as a development or adjudicatory tool. Only SEM is accept- able for use in case file development and adjudication. It is unacceptable to base a decision, particularly a remand order, on any information contained in Haz- Map beyond the established links populated directly into SEM. Haz-Map serves many purposes for the public and medical professional fields and will often cite suggestive research that it has not accepted as a basis for finding a demonstrable link between a given substance and an occupational illness. (DOL, 2012b) Haz-Map, as noted in Chapter 2, contains more than 7,000 agents and 235 occupational diseases (Brown, 2012, 2013), whereas SEM contains 13,697 toxic substances as of October 2012 (DOL, 2012d) and more than 120 occu- pational diseases (Stalnaker, 2012). Many toxic substances in SEM, such as 1,5-cyclooctadiene platinum II chloride, are not included in Haz-Map and there- fore, will have no health effects information available. DOL has developed its own internal guidance on a few occupational disease associations, such as DOL Bulletin No. 08-15, Adjudication of Part E Claims for the Conditions of Par- kinsonism and Parkinson’s Disease, May 30, 2008, but these bulletins are not included in SEM. SEM also contains many commercial products, mixtures, and compounds (e.g., 1 Shot Graphic Coat Enamel) that are or have been used at DOE sites, but these substances are not included in Haz-Map. Some substances in Haz-Map are not in SEM because they have not been identified or confirmed as being used at any DOE site, such as carob bean gum; however, these sub- stances are included in Haz-Map because they have been found in other occu- pational settings. It should also be noted that not every toxic substance listed in Haz-Map has adverse health effects information. This may be because the agent has not been tested for toxicity or it may not be identified with any adverse effects, occupational or otherwise, in the medical, epidemiological, or industrial hygiene literature. Neither Haz-Map nor SEM, however, distinguishes between substance–disease links for which there is no evidence and those where the evi- dence that does not support a causal relationship between the substance and a disease. The committee believes this lack of clarity about the reason for no link may be confusing if the absence of a link in SEM is always interpreted to mean that the evidence does not support a link.

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60 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE Updating SEM Content Updating the SEM is a continuous process. Although there is no formal schedule for reviewing any specific components (Paragon Technical Services, 2012), DOL indicates that updates are made approximately every 6 months (Karoline Anders, DOL DEEOIC, personal communication, October 9, 2012). According to the DOL and its contractor, the SEM can be updated in three ways: external submissions from the public of site-related or disease-related informa- tion; incorporation of Haz-Map updates for health effects links; and receipt of new information from DOE. In the following sections, the committee discusses updates to the SEM based on external submissions of information and on revi- sions to Haz-Map. Because DOE does not provide health effects information to SEM, nor was the committee asked to comment on DOE activities with regard to it, updates to the database based on DOE information are not discussed further in this report. Regardless of the source of new information for SEM, for security reasons, DOE must approve all updates before they are publicly released. Although a SEM record indicates when it was last updated, there is no indication as to what specific information or field was updated, added to, or revised. This lack of this information makes it extremely difficult for the user to know if the most current information has been incorporated. For example, the record for o-toluidine was last updated on November 14, 2011, according to the “Record History” field; however, the “Specific Health Effects” field states that “No diseases were listed in NLM Haz-Map (i.e., NLM had not identified any occupational disease related to exposure to this substance) as of June 5, 2012” and “Diseases currently associated with this substance in the Haz-Map database may differ from those associated with it when this page was updated on June 5, 2012,” suggesting that the page had indeed been reviewed as of June 5, 2012 (accessed December 3, 2012). There is no explanation of why the review occurred or what information was being considered. Statements such as these can be con- fusing to the user. The committee recognizes that the periodic updating of both Haz-Map and SEM as new information on toxic substances and occupations disease links become available is essential to assisting claimants and claims examiners. The committee encourages these ongoing updates to both Haz-Map and SEM and, therefore, has indicated in its report the dates a link was evaluated, recognizing that since then a link may have been added, revised, or deleted. The committee expects that between the time this report was written and when it is published, there may be additional changes to both databases and, thus, the committee’s statements about a specific link may no longer be accurate. In fact, the committee was told that many revisions were made to SEM in December 2012 (Karoline Anders, DOL DEEOIC, personal communication, January 2, 2013); however, the committee was unable to review these revisions for its report.

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SITE EXPOSURE MATRIX DATABASE 61 External Submission of Content External submissions may come directly from claimants, from their repre- sentatives or advocates, and from the general public (Stalnaker, 2012). On the SEM homepage, DOL provides a mechanism for public submission of site-related and disease-related information to be considered for addition to the database (see Figure 3-5) (http://www.sem.dol.gov). The SEM homepage states that “comments and documentation regarding the use of toxic substances at covered Part E facili- ties and documentation of established occupational illness links are welcome.” The DOL contractor told the committee that there is a structured internal process for reviewing submitted information, but no formal external review process. Another button on the SEM homepage labeled “Status of disease-related input” allows users to view the toxic substance–disease links that have been submitted and indicates whether the proposed link has been accepted by DOL and, therefore, is in the queue to be added to the SEM (see Figure 3-6). Before a toxic substance–disease link is added to SEM it is reviewed by the Haz-Map FIGURE 3-5  Screen capture of SEM homepage indicating highlights for public input. SOURCE: DOL, 2012d (accessed January 23, 2013).

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84 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE TABLE 3-4 Selected Missing Toxic Substance–Noncancer Disease Links Based on Evaluations by Authoritative Organizationsa SEM Substance Human Disease/Illness Authoritative Organization Antimony Cardiovascular ACGIH, 2001; ATSDR, (deaths; increased blood 1992; NIOSH, 1978 pressure; EKG changes from occupational exposures) Carbon Disulfide Cardiovascular Cal/EPA, 2002 (increase in mortality due to ischemic heart disease in several occupational studies) Carbon Monoxide Cardiovascular ACGIH, 2001; Cal/EPA, (workers at significantly 1999 increased risk of death from atherosclerotic disease; deaths of workers with existing cardiovascular disease) Chromium VI Male Reproduction Cal/EPA, 2009 (infertility, decreased fecundability, other effects in exposed workers) Dibutyl Phthalate Male Reproduction Cal/EPA, 2007 (decreased testosterone levels in occupationally exposed men) 2,4- and 2,6-Dinitrotoluene Cardiovascular ACGIH, 2001; ATSDR, 1998 (significant increase in heart disease mortality in occupational cohort study) Hydrogen Cyanide Central Nervous System ACGIH, 2001; Cal/EPA, Endocrine System 2000 (nervous system effects and thyroid enlargement in workers chronically exposed to low levels) Methylene Chloride Cardiovascular Cal/EPA, 1999; DOL, 1997 (Dichloromethane) (OSHA standard based in part on protecting against effects on the heart) Rotenone Peripheral Nervous System EPA, 2007b (a few reported cases of peripheral neuropathy) Tetrachloroethylene Central Nervous System EPA, 2012; NRC, 2010 (Perchloroethylene) (visual changes, increased reaction time, decrements in cognition from low level occupational exposures)

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SITE EXPOSURE MATRIX DATABASE 85 TABLE 3-4 Continued SEM Substance Human Disease/Illness Authoritative Organization Toluene Central Nervous System EPA, 2005b (altered color vision; decreased performance in neurobehavioral tests from low level occupational exposures) Welding Fumes Metal Fume Feverb DOL, 1989; IARC, 1990; NIOSH, 1988 aThe process the committee used to identify the toxic substance–disease links and the definition of authoritative organizations are provided in the text. bBased on the complex mixture. Metal fume fever is also listed in SEM; however, it is listed as a potential disease link based on one of the 43 chemical constituents of welding fumes. NOTE: EKG = electrocardiogram; OSHA = Occupational Safety and Health Administration. epidemiological studies (EPA, 2011). EPA’s criteria for “carcinogenic in humans” (EPA, 2005a) are not substantially different from IARC’s criteria for “sufficient evidence of cancer in humans” (IARC, 2006). Since the IARC evaluation was published in 1995, IARC’s classification of trichloroethylene as a Group 2A or probable carcinogen does not take into account the more recent cancer evidence for trichloroethylene in the EPA meta-analysis. From a scientific perspective, the committee does not believe that the omission of the trichloroethylene-kidney cancer link from SEM is valid. Some of the links in Table 3-2 (formaldehyde and leukemia, o-toluidine and bladder cancer, 1,3-butadiene and cancer of the hematolymphatic organs) are in Haz-Map but not in SEM presumably due to a time lag in importing the Haz-Map links into SEM (i.e., the links are currently in the former, but have not yet been added to the latter). This is described further in the section on updating SEM. Additionally, the lung cancer links for diesel exhaust and coal tar pitch volatiles presumably also will be added to SEM, although the links are not in Haz-Map. As a part of the revisions to Haz-Map, based on the 2012 IARC cancer evaluation (Cogliano et al., 2011; IARC, 2012), the lung cancer links for diesel exhaust and coal tar pitch volatiles are scheduled to be added to it by the end of 2012 (http://www.haz-map.com/cancer.htm). DOL has also concluded that the diesel exhaust cancer link could be verified and would be added to SEM (http:// www.sem.dol.gov/StatusD.cfm). SEM does not include links between radioactive substances and cancers. The reason for not including cancer links for the six radioactive substances (iodide-131, plutonium, radium, radon, strontium-90, and thorium) in Table 3-2 is not clear. It may be because DOL does not evaluate claims involving radiation and cancer under Part E. Radiogenic cancers, including thyroid, bone, liver, lung, leukemia, and gall bladder cancers, are covered under Part B which does not use

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86 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE SEM. According to the SEM website, SEM does not address the relationship between radiation and cancer. For purposes of EEOICP, the relationship between radiation and cancer is evaluated by the NIOSH (http://www.sem.dol.gov). How- ever, if this is the reason, it does not appear to be consistent with information in the SEM profiles for the substances. They state that “no diseases were listed in NLM Haz-Map (i.e., NLM had not identified any occupational disease related to exposure to this substance) as of June 5, 2012.” The statement, which is used generically in the database when there is no disease information, implies that if or when disease information for the radioactive substances is added to Haz-Map, it will be subsequently added to SEM. The committee found this generic language misleading for radioactive substances. Regardless of SEM’s inclusion or exclusion of radiogenic cancers, the com- mittee found discrepancies in the cancers linked to radioactive substances in the Haz-Map and SEM databases. As shown in Table 3-2, cancer links for plutonium, radon, and radium are currently in Haz-Map. Since some information for these substances is listed in SEM, it is not clear if the Haz-Map cancer links eventually will be added to SEM. Currently, Haz-Map does not have links for iodine-131 and thyroid cancer; plutonium and liver cancer; strontium and leukemia and solid cancers; thorium and bile duct, gall bladder, or leukemia; and radium and the mastoid process (see Table 3-2). It is unclear if they will be added to Haz-Map (and eventually to SEM), even though they are IARC Group 1 carcinogens. These cancer links are not scheduled to be added to Haz-Map, although they are in the 2012 IARC cancer monograph (http://www.haz-map.com/cancer.htm). The DOL notation of “could not be verified” (http://www.sem.dol.gov/StatusD.cfm) for the publicly submitted link between iodine-131 and thyroid cancer suggests that the cancer link will not be added to SEM. It also suggests that additional criteria (other than the IARC designation of sufficient evidence of cancer in humans) are used to identify cancer links for radioactive substances. Given these inconsisten- cies and the lack of transparency, DOL should clarify whether Haz-Map cancer links for radioactive substances are included in specific SEM substance profiles. If the cancer links are included in SEM, DOL should provide the complete cri- teria that are used to identify which cancer links are imported into the database. To assess how criteria for substance–disease links may affect SEM, the com- mittee looked for cancers associated with substances in SEM using a less strict criterion than the IARC Group 1 classification currently used by Haz-Map. Table 3-3 shows cancer links for 23 substances that are not in SEM because the epide- miological studies on which the links are based are classified by IARC as “lim- ited” evidence of cancer in humans (Group 2) rather than “sufficient” (Cogliano et al., 2011; IARC, 2012). As a result, the links do not meet the Haz-Map criteria for cancer causality and are not included in either Haz-Map or SEM. The toxic substance–cancer links include 11 cancers—prostate, colorectum, pharynx, mul- tiple myeloma, breast, digestive tract, salivary gland, hepatobiliary tract, cervix, esophagus, and pancreas—that were not listed in Haz-Map.

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SITE EXPOSURE MATRIX DATABASE 87 Deciding whether only the IARC classification of sufficient evidence of cancer in humans or whether the IARC classifications of both sufficient and limited evidence of cancer in humans most appropriately reflect the intent of EEOICPA is a DOL policy decision on the application of scientific information, not a scientific decision. Noncancer Links Table 3-4 shows 13 substances for which noncancer disease links are not in SEM. Diseases or health effects identified include cardiovascular, male repro- ductive, central and peripheral nervous system, and endocrine effects. All of the disease links are based on human case reports or epidemiological studies. As a result, according to the limited information available in Haz-Map, the links appear to be consistent with its criteria for determining noncancer disease causal- ity. Regarding noncancer disease links, Haz-Map states that “for chronic diseases, linkage between an agent and a disease means that a causal relationship has been determined based on human case reports or epidemiological studies” (www.haz- map.com; accessed January 22, 2013). Some authoritative organizations, for example, OSHA and EPA, also use disease or health effect endpoints to derive exposure limits for regulatory or preventative purposes. Such use indicates that the toxic substance–disease asso- ciations are strong, and that the disease is the most sensitive health endpoint for the toxic substance. EPA and Cal/EPA prioritize human studies of sufficient quality over animal studies (EPA, 2002). The diseases in Table 3-4 are all based on occupational health studies. Effects on the cardiovascular system resulting from occupational exposures were identified as the most sensitive health endpoint and are the basis for the NIOSH recommended exposure limit for antimony (NIOSH, 1978), the Cal/EPA acute reference exposure level for carbon monoxide (Cal/EPA, 1999), and the Cal/EPA chronic noncancer reference exposure level for methylene chloride (Cal/EPA, 1999) (see Table 3-4). Cardiovascular effects are also the basis for the OSHA methylene chloride standard, due to metabolism of methylene chlo- ride to carboxyhemoglobin (DOL, 1997). The OSHA standard includes medical surveillance requirements that are intended to provide specific protections for workers with existing cardiovascular disease. As of October 1, 2012, however, cardiovascular disease is not included in Haz-Map as an occupational disease, and is listed in the “More Research Needed” category (http://hazmap.nlm.nih.gov). The criteria used to determine whether cardiovascular disease is an occupational disease and the basis for adding toxic substance–cardiovascular links to SEM, are not clear in Haz-Map. To ensure transparency, these criteria should be made available to SEM users. Chronic central nervous system (CNS) effects are linked to tetrachloroeth- ylene and toluene (see Table 3-4) on the basis of chronic low-level, occupational

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88 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE exposures resulting in such effects such as visual deficits (EPA, 2012). These CNS effects are different from “encephalopathy, chronic solvent,” which is found in both Haz-Map and SEM databases, and is caused by chronic high exposures to solvents. This health effect is listed for all organic solvents used in paints and varnishes in both databases (www.haz-map.com/overview.htm; accessed January 22, 2013). These CNS effects at low exposures are the basis for EPA’s reference concentrations for tetrachloroethylene (EPA, 2011) and toluene (EPA, 2005b), but neither are in either database. Since the EPA IRIS database is one of the informa- tion sources Haz-Map identifies in its references, it is not clear why the disease links for tetrachloroethylene and toluene are not in Haz-Map or SEM. Male reproductive effects have been associated with chromium VI and dibu- tyl phthalate (Cal/EPA, 2007, 2009) but these associations are not listed in either the SEM or Haz-Map. Furthermore, neither database has a chemical profile for chromium VI alone, but rather include it with other forms of chromium in a profile for “Chromium and Chromium Compounds.” The Haz-Map profile for chromium and compounds is a mix of data pertaining to chromium III, a rela- tively benign compound and essential nutrient, and chromium VI, a highly-toxic substance known to cause lung cancer (ATSDR, 2012b). Because the toxicity of chromium III and chromium VI differ substantially, the distinction between the two chemicals should be made clear in both databases. A further complication is that the CAS (or Chemical Astract Service) registry number used for chromium and chromium compounds in both databases is 7440-47-3, the number usually associated with chromium metal. The CAS number used typically for chromium VI is 18540-29-9. However, the occupational diseases listed for the CAS number 7440-47-3 are specific to chromium IV (ATSDR, 2012b), which is included in chromium compounds in both databases. This method of combining substance profiles may lead to inaccurate conclusions; in this case, that chromium III causes lung cancer. Despite this flaw, the substance–disease links for chromium and compounds (if interpreted as being chromium VI) are correct except for the lack of male reproductive effects. In cases where the effects of a specific form of a compound differ greatly from the group of compounds, a separate profile or distinct notation should reflect the differences in toxicity among them. The link between welding fumes and metal fume fever is captured in SEM, but it is missing in the Haz-Map database. This is because SEM lists toxic substance–disease links for the constituents of mixtures as opposed to the mixture as a whole. Metal fume fever can result from exposure to welding fumes (DOL, 1989; IARC, 1990; NIOSH, 1988) and should be captured in SEM. However, this link in SEM is based on the diseases associated with the two of the constituents of welding fumes, zinc and copper, both of which are linked to metal fume fever in Haz-Map. In Haz-Map, welding fumes are linked to toxic pneumonitis and chronic obstructive pulmonary disease. In summary, the committee determined that there are missing links between substances potentially present at DOE sites and cancers and noncancer diseases in

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SITE EXPOSURE MATRIX DATABASE 89 SEM as of October 1, 2012. Links may be missing due to human error, ambigu- ous criteria for establishing links in Haz-Map, lack of consistency between the “Diseases” field in Haz-Map and the “Specific Health Effects” field in SEM, or because of delays in updating both databases. SUMMARY SEM provides a key function in the EEOICPA Part E compensation system and is one tool by which claims examiners assess whether occupational exposure to a toxic substance at a DOE facility is associated with an occupational disease. In its evaluation of this database, the committee identified several strengths, including its development with consultation from DOE experts and former work- ers and its attempt to comprehensively list all toxic substances used at DOE facili- ties. However, the committee also identified several major weaknesses in SEM, specifically the difficulty in accessing some information in the database, lack of detailed exposure information; inability to handle complex exposures, including exposure to mixtures, chemical compounds, and radioactive substances; ambigu- ity in why certain links are not listed; incomplete or inconsistent exposure profiles based on location and job; disregard of epidemiologic studies in DOE workers; and the sole use of Haz-Map for substance–disease links. In particular, the sole use of Haz-Map for disease causation was problematic for several reasons, and the committee conducted an exercise that illustrated examples of toxic substance–disease links that are not currently in SEM. The exercise was extensive, but not comprehensive. However, based on it, the com- mittee identified cancer links that are missing in SEM that have been categorized by IARC as having sufficient evidence in humans (see Table 3-2) or limited evidence in humans (see Table 3-3), as well as missing links in the database for noncancer diseases based on evaluations by other authoritative organizations (see Table 3-4). The exercise also identified noncancer disease links that are missing from SEM. Overall, the committee noted that links may be missing due to human error, ambiguous criteria for determining or excluding links in Haz-Map, lack of exposure information in SEM, or because of delays in updating links in both databases. To address the weaknesses in SEM, and particularly to strengthen the toxic substance–disease links in SEM, the committee proposes a number of recommendations to DOL. These recommendations are discussed in detail in the next chapter. REFERENCES ACGIH (American Conference of Governmental Industrial Hygienists). 2001. Documentation of the Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs): Antimony and Compounds.

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90 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE Anders, K. 2012a. Energy Employees Occupational Illness Compensation Program Overview. Pre- sentation at the First Committee Meeting, January 23, Washington, DC. Anders, K. 2012b. DEEOIC Claims Process Flow Charts for the Committee on Review of the Depart- ment of Labor’s Site Exposure Matrix (SEM) Database. March 15, 2012. ATSDR (Agency for Toxic Substances and Disease Registry). 1992. Toxicological Profile for Anti- mony and Compounds. Washington, DC: U.S. Public Health Service. http://www.atsdr.cdc.gov/ toxprofiles/tp23.pdf (accessed December 11, 2012). ATSDR. 1998. Toxicological Profile for 2,4- and 2,6-Dinitrotoluene. Washington, DC: U.S. Public Health Service. http://www.atsdr.cdc.gov/toxprofiles/tp109.pdf (accessed December 11, 2012). ATSDR. 2001. Toxicological Profile for Asbestos. Washington, DC: U.S. Public Health Service. http://www.atsdr.cdc.gov/ToxProfiles/tp61.pdf (accessed January 23, 2013). ATSDR. 2004a. Guidance Manual for the Assessment of Joint Toxic Action of Chemical Mixtures. Washington, DC: U.S. Public Health Service Division of Toxicology. http://www.atsdr.cdc.gov/ interactionprofiles/IP-ga/ipga-p.pdf (accessed December 11, 2012). ATSDR. 2004b. Interaction Profile for: Arsenic, Cadmium, Chromium, and Lead. Washington, DC: U.S. Public Health Service. http://www.atsdr.cdc.gov/interactionprofiles/IP-metals1/ip04.pdf (accessed January 23, 2013). ATSDR. 2012a. About the Chemical Mixtures Program. Division of Toxicology and Environmental Medicine. http://www.atsdr.cdc.gov/mixtures/index.html (accessed December 11, 2012). ATSDR. 2012b. Toxicological Profile for Chromium. Washington, DC: U.S. Public Health Service. http://www.atsdr.cdc.gov/toxprofiles/tp7.pdf (accessed January 23, 2013). Blanc, P. D., M. D. Eisner, G. Earnest, L. Trupin, J. R. Balmes, E. H. Yelin, S. E. Gregorich, and P. P. Katz. 2009. Further exploration of the links between occupational exposure and chronic obstruc- tive pulmonary disease. Journal of Occupational and Environmental Medicine 51(7):804-810. Brown, J. A. 2012. Haz-Map: A Process to Map Occupational Toxicology Information into a Rela- tional Database. Presentation at First Committee Meeting, January 23, Washington, DC. Brown, J. A. 2013. What’s New? Web Changes and Database Updates. http://www.haz-map.com/ wotsnu.htm (accessed January 23, 2013). Caldwell, J. C., N. Keshava, and M. V. Evans. 2008. Difficulty of mode of action determination for trichloroethylene: An example of complex interactions of metabolites and other chemical expo- sures. Environmental and Molecular Mutagenesis 49(2):142-154. Cal/EPA (California Environmental Protection Agency). 1999. Air Toxics Hot Spots Program Risk Assessment Guidelines. Part 1: The Determination of Acute Reference Exposure Levels for Air- borne Toxicants. http://oehha.ca.gov/air/pdf/acuterel.pdf (accessed January 23, 2013). Cal/EPA. 2000. Chronic Toxicity Summary: Hydrogen Cyanide. CAS Registry Number 74-90-8. In Ap- pendix D.3, Chronic RELs and Toxicity Summaries Using the Previous Version of the Hot Spots Risk Assessment Guidelines. Pp. 313-320. http://oehha.ca.gov/air/hot_spots/2008/AppendixD3_ final.pdf#page=313 (accessed January 23, 2013). Cal/EPA. 2002. Chronic Toxicity Summary: Carbon Disulfide. CAS Registry Number 75-15-0. http:// www.oehha.org/air/chronic_rels/pdf/sum111401.pdf (accessed January 23, 2013). Cal/EPA. 2007. Proposition 65 Maximum Allowable Dose Level (MADL) for Reproductive Toxicity for Di(n-butyl)phthalate (DBP). Office of Environmental Health Hazard Assessment (OEHHA) Reproductive and Cancer Hazard Assessment Section. http://oehha.ca.gov/prop65/law/pdf_zip/ DBP%20MADL%20062907.pdf (accessed January 23, 2013). Cal/EPA. 2009. Evidence on the Developmental and Reproductive Toxicity of Chromium (Hexavalent Compounds). Office of Environmental Health Hazard Assessment Reproductive and Cancer Hazard Assessment Section. http://oehha.ca.gov/prop65/hazard_ident/pdf_zip/chrome0908.pdf (accessed January 23, 2013). Carpenter, A. V., W. D. Flanders, E. L. Frome, W. G. Tankersley, and S. A. Fry. 1988. Chemical ex- posures and central nervous-system cancers. A case-control study among workers at 2 nuclear- facilities. American Journal of Industrial Medicine 13(3):351-362.

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SITE EXPOSURE MATRIX DATABASE 91 Chan, C., T. S. Hughes, S. Muldoon, T. Aldrich, C. Rice, R. Hornung, G. Brion, and D. J. Tollerud. 2010. Mortality patterns among Paducah gaseous diffusion plant workers. Journal of Occupa- tional and Environmental Medicine 52(7):725-732. Chen, W.-c. G., and T. E. McKone. 2001. Chronic health risks from aggregate exposures to ion- izing radiation and chemicals: Scientific basis for an assessment framework. Risk Analysis 21(1):25-42. Cogliano, V. J., R. Baan, K. Straif, Y. Grosse, B. Lauby-Secretan, F. El Ghissassi, V. Bouvard, L. Benbrahim-Tallaa, N. Guha, C. Freeman, L. Galichet, and C. P. Wild. 2011. Prevent- able exposures associated with human cancers. Journal of the National Cancer Institute 103(24):1827-1839. Dement, J. M., L. Welch, E. Bingham, B. Cameron, C. Rice, P. Quinn, and K. Ringen. 2003. Surveil- lance of respiratory diseases among construction and trade workers at Department of Energy nuclear sites. American Journal of Industrial Medicine 43(6):559-573. DOE (Department of Energy). 2012. Find Facilities. http://www.hss.doe.gov/healthsafety/fwsp/ advocacy/faclist/findfacility.cfm (accessed October 6, 2012). Office of Health, Safety, and Se- curity. http://www.hss.doe.gov/healthsafety/fwsp/advocacy/faclist/findfacility.cfm. DOL (Department of Labor). 1989. Occupational Safety and Health Guideline for Welding Fumes. http://www.osha.gov/SLTC/healthguidelines/weldingfumes/recognition.html (accessed October 6, 2012). DOL. 1997. Occupational Exposure to Methylene Chloride. RIN 1218-AA98. http://www.osha.gov/ pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=998 (accessed January 23, 2013). DOL. 2008. EEOICPA Bulletin No. 08-38 (replacing Bulletin Nos. 06-10 and 06-14). http://www. dol.gov/owcp/energy/regs/compliance/PolicyandProcedures/finalbulletinshtml/EEOICPA Bulletin08-38.htm (accessed January 23, 2013). DOL. 2010. Presolicitation for Site Exposure Matrices for DOL/DEEOIC. Solicitation Number DOL011RP20896. https://www.fbo.gov/index?s=opportunity&mode=form&id=c70989c92ca 49c5679ad783067dbbe97&tab=core&_cview=1 (accessed January 23, 2013). DOL. 2011. US Department of Labor Completes Expansion of Site Exposure Matrices Website. http:// www.dol.gov/opa/media/press/OWCP/OWCP20110041.htm (accessed September 10, 2012). DOL. 2012a. 116 DOE Fcilities available on Public SEM. Division of Energy Employees Occu- pational Illness Compensation (DEEOIC). http://www.dol.gov/owcp/energy/regs/compliance/ DOEPublicSEM_list.htm (accessed October 9, 2012). DOL. 2012b. Establishing Toxic Substance Exposure. In The Federal (EEOICPA) Procedural Man- ual. http://www.dol.gov/owcp/energy/regs/compliance/PolicyandProcedures/UnifiedProcedure Manual.htm (accessed February 6, 2013). DOL. 2012c. Site Exposure Matrices Website Help Guide. http://www.sem.dol.gov/expanded/help. cfm (accessed January 16, 2012). DOL. 2012d. EEOICP Site Exposure Matrices Website—Homepage, DOE facilities and RECA Sites Data. Updated June 5, 2012. http://www.sem.dol.gov/index.cfm (accessed February 6, 2013). DOL. 2012e. Office of Workers’ Compensation Program Site Exposure Matrix (SEM) Expanded. http://www.sem.dol.gov/expanded (accessed February 6, 2012). DOL. 2012f. Questions posed by IOM committee and subsequent answers from DOL. Committee on Review of the Department of Labor’s Site Exposure Matrix (SEM) Database. Eaton, D. L., and S. G. Gilbert. 2007. Principles of toxicology. In Casarett and Doull’s Toxicology: The Basic Science of Poisons. 7th ed, Klaasen, C. New York: McGraw-Hill Publishers. Pp. 11-44. EPA (Environmental Protection Agency). 1986. Guidelines for the Health Risk Assessment of Chemi- cal Mixtures. Federal Register 51(185):34014-34025. EPA/630/R-98/002. Washington, DC: EPA Risk Assessment Forum. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=22567 (ac- cessed February 9, 2012).

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92 REVIEW OF THE DOL’S SITE EXPOSURE MATRIX DATABASE EPA. 2000. Supplementary Guidance for Conducting Health Risk Assessment of Chemical Mixtures. EPA/630/R-00/002. Washington, DC: Risk Assessment Forum, EPA. http://cfpub.epa.gov/ncea/ cfm/recordisplay.cfm?deid=20533 (accessed February 9, 2012). EPA. 2002. A Review of the Reference Dose and Reference Concentration Processes. EPA/630/ P-02/002F. Washington, DC: EPA Risk Assessment Forum. http://www.epa.gov/raf/publications/ pdfs/rfd-final.pdf (accessed February 9, 2012). EPA. 2005a. Guidelines for Carcinogenic Risk Assessment. EPA/630/P-03/001F. Washington, DC: EPA Risk Assessment Forum. http://www.epa.gov/raf/publications/pdfs/CANCER_ GUIDELINES_FINAL_3-25-05.PDF (accessed February 9, 2012). EPA. 2005b. Toxicological Review of Toluene (CAS No. 108-88-3). EPA/635/R-05/004. Washington, DC: EPA. http://www.epa.gov/iris/toxreviews/0118tr.pdf (accessed February 6, 2012). EPA. 2007a. Concepts, Methods, and Data Sources for Cumulative Health Risk Assessment of Multiple Chemicals, Exposures and Effects: A Resource Document (Final Report). Cincin- nati, OH: Office of Research and Development, National Center for Environmental Assess- ment. EPA/600/R-06/013f. Washington, DC: EPA. http://cfpub.epa.gov/ncea/cfm/recordisplay. cfm?deid=190187 (accessed February 6, 2013). EPA. 2007b. Reregistration Eligibility Decision for Rotenone, List A, Case No. 0255. EPA 738-R- 07-005. Washington, DC: EPA. http://www.epa.gov/oppsrrd1/REDs/rotenone_red.pdf (accessed February 9, 2012). EPA. 2011. Trichloroethylene Toxicological Review and Appendices. http://www.epa.gov/iris/ supdocs/0199index.html (accessed February 9, 2012). EPA. 2012. Toxicological Review of Tetrachloroethylene (Prchloroethylene), CAS No. 127-18-4). EPA/635/R-080/011F. Washington, DC: EPA. http://www.epa.gov/iris/toxreviews/0106tr.pdf (accessed February 9, 2012). Erren, T. C., M. Jacobsen, and C. Piekarski. 1999. Synergy between asbestos and smoking on lung cancer risks. Epidemiology 10(4):405-411. European Commission. 2012. Toxicity and Assessment of Chemical Mixtures. http://ec.europa.eu/ health/scientific_committees/environmental_risks/docs/scher_o_155.pdf (accessed January 23, 2013). Frost, G., A. Darnton, and A–H. Harding. 2011. The effect of smoking on the risk of lung cancer mortality for asbestos workers in Great Britain (1971-2005). Annals of Occupational Hygiene 55(3):239-247. GAO (Government Accountability Office). 2010. Energy Employees Compensation: Additional In- dependent Oversight and Transparency Would Improve Program’s Credibility. GAO 10-302. Washington, DC. http://www.gao.gov/assets/310/302183.pdf (accessed January 23, 2013). Godbold, J. H., and E. A. Tompkins. 1979. A long-term mortality study of workers occupationally exposed to metallic nickel at the Oak Ridge Gaseous Diffusion Plant. Journal of Occupational and Environmental Medicine 21(12):799-806. Guha, N., D. Loomis, Y. Grosse, B. Lauby-Secretan, F. El Ghissassi, V. Bouvard, L. Benbrahim-Tallaa, R. Baan, H. Mattock, and K. Straif, on behalf of the International Agency for Research on Can- cer Monograph Working Group. 2012. Carcinogenicity of trichloroethylene, tetrachloroethylene, some other chlorinated solvents, and their metabolites. The Lancet Oncology 13(12):1192-1193. Hertz-Picciotto, I., A. H. Smith, D. Holtzman, M. Lipsett, and G. Alexeeff. 1992. Synergism between occupational arsenic exposure and smoking in the induction of lung cancer. Epidemiology 3(1):23-31. HSDB (Hazardous Substances Data Bank). 2012. TOXNET (Toxicology Data Network) Hazardous Substances Data Bank (HSDB). Bethesda, MD: Division of Specialized Information Services, National Library of Medicine. http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB (accessed January 23, 2013).

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