EEOICPA CIRCULAR NO. 11-03 April 22, 2011
SUBJECT: Calculating aggregate work days for employees residing at a Department of Energy (DOE) facility.
The purpose of this Circular is to clarify for all Division of Energy Employees Occupational Illness Compensation (DEEOIC) staff the method by which an employee residing at a DOE facility may be credited with work day(s) for purposes of inclusion in the Special Exposure Cohort (SEC).
Guidance issued by the DEEOIC has defined a work day as the equivalent of an 8 hour work shift. This facilitates assessment of total work days based on hourly, daily or, monthly work-shift tallies. In addition, allowance has been granted in policy directives for individuals residing at atomic weapon test sites, such as the Nevada Test Site (NTS) and the Pacific Proving Grounds (PPG) to be credited with the equivalent of three (8-hour) work days for each calendar day spent working and residing at the test site.
NTS and PPG are unique DOE facilities that were the site of above-ground nuclear weapons testing. As part of weapons testing activities at these locations, employees were often required to live onsite in remote locations in circumstances that tended to blur the line between work and residency. Additionally, the danger inherent in weapons testing, particularly atmospheric testing, and resuspension of radioactive particles, further distinguishes these facilities from all others. Although it is recognized that employees lived on the premises of other DOE facilities, the circumstances of such residency do not include the uniqueness, the remoteness, nor the risks and dangers inherent in living at NTS and PPG.
For this reason, the allowance for considering each 24-hour day spent in residence or employment at a Department of Energy facility as three separate work shifts is exclusive to employees at the NTS and PPG. It does not apply to individuals residing at other DOE facilities that are linked to atomic weapons production or processing. For purposes of inclusion into the SEC, the assessment of work days for these other employees must be derived from evidence of employment during the course of a normal work-shift, and does not include credit for three (8-hour) shifts for every 24-hour period spent in residence at the facility.
RACHEL P. LEITON
Director, Division of Energy Employees
Occupational Illness Compensation
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