Well I was just guessing about the regional thing. In fact in retrospect that seems a bit daft, Ascii values might be reassigned but scancodes should stay the same for different regions. Maybe the docs are just wrong, or Blitz is just translating the scancode incorrectly. So maybe it was always meant to be 197 as per the docs but somewhere along the line it was mixed up with the code for Numlock. Mark is always fiddling with things so this could have occured since the docs were written.
In fact I seem to remember the function of Print Scrn being changed at some point. My guess is this is when the code for Pause was inadvertently changed. Apparently these keys are a bit "special".
http://www.win.tue.nl/~aeb/linux/kbd/scancodes-1.html#ss1.1Just a brief glance at that document suggests that scancode translation is a nasty business.
So I would use 69, unless you get indication that some people do have the Pause key returning a scancode of 197 in which case it would be time to think again. I have changed my docs to suit.