EPA - Acknowledgement of Proficiency Progs
EPA - Acknowledgement of Proficiency Progs
Proficiency Programs
Since the close of EPA’s National Radon Proficiency Program (RPP) in 1998, there have been a number of requests that
EPA offer some form of recognition of non-Federal radon proficiency programs. EPA has offered a one-time
acknowledgment, based on meeting set recognition criteria (following this document), to any non-Federal radon
proficiency program that lists or certifies radon measurement, mitigation service providers and/or analytical service
providers. EPA believes that it is appropriate to develop recognition criteria that call for a non-Federal radon proficiency
program to incorporate, at a minimum, program elements that comprised EPA’s former voluntary RPP. EPA continues to
encourage States, industry and consumers to work together to identify those elements that would improve non-Federal
radon proficiency programs and go beyond EPA’s former voluntary RPP. These improved elements should then be
adopted as standards of practice.
Both of the existing non-Federal national radon proficiency programs (The National Radon Safety Board (NRSB) and The
National Environmental Health Association’s (NEHA) National Radon Proficiency Program) participated in the evaluation.
On March 30, 2001, EPA issued letters to both organizations stating the following:
The Environmental Protection Agency (EPA) has completed its review of the (NRSB’s or NEHA’s
NRPP’s) application submitted for EPA’s evaluation of Non-federal National Radon Proficiency
Programs. Based solely on its review of the materials submitted, EPA finds that the following categories
(listed here by program) successfully satisfy EPA’s minimum criteria for operation of a non-federal
National Radon Proficiency Program (as established and implemented as described in the applications
submitted to EPA on March 1, 2001).
Former EPA RPP Program Name NEHA NRPP Equivalent Program Name
Analytical Service Provider Analytical Laboratories
Radon Measurement Provider Offering Standard
Residential Radon Measurement Provider
Services
Analytical Service Provider AND Residential Radon Residential Measurement Provider Offering Standard
Measurement Provider and Analytical Services (RMPSAS)
Residential Radon Mitigation Provider Residential Mitigation Provider
Because of expected changes in the radon industry, this acknowledgment is only valid through
December 31, 2002, at which time this determination will expire. There will be no extensions of this
determination. This determination is not applicable if changes are made to the program(s) as submitted
to EPA, or if it is not implemented as described to EPA. To avoid misleading the public, you may not
make public reference to this EPA determination after December 31, 2002.
Any references to EPA’s determination in advertisements should avoid misleading consumers in this
regard. We recommend that you use the following description:
For NRSB: “EPA has reviewed NRSB’s description of its Accredited Radon Laboratory
program; Radon Measurement Specialist; and, Radon Mitigation Specialist categories
and has determined that they are consistent with EPA’s former program categories
Analytical Service Provider; Residential Radon Measurement Provider; and, Residential
Radon Mitigation Provider, respectively. EPA has not reviewed the actual operations of
NRSB’s Board, operation of its day-to-day operations, nor performed any audits of its
quality assurance program, examinations, or device evaluation program.”
For NEHA’s NRPP: “EPA has reviewed NEHA’s NRPP’s description of its Analytical
Laboratories program; Residential Measurement Provider Offering Standard and
Analytical Services (RMPSAS) program; Residential Measurement Provider Offering
Standard Services program; and, Residential Mitigation Provider program and has
determined that they are consistent with EPA’s former program categories Analytical
Service Provider, Residential Radon Measurement Provider and Residential Mitigation
Provider, respectively. EPA has not reviewed the actual operation of NEHA’s NRPP
Board, operation of its day-to-day operations, nor performed any audits of its quality
assurance program, examinations, or device evaluation program.”
If you have questions or comments on this recognition process, you can contact James Long at (202) 564-9433, or via e-
mail at [email protected].
For more information on how to contact either of the Non-federal National Radon Proficiency Programs (listed here
alphabetically):
The National Environmental Health Association (NEHA) The National Radon Safety Board (NRSB)
National Radon Proficiency Program P.O. Box 426
Administrative Offices Putnam Valley, NY 10579
525 East Fountain Boulevard, Suite 201 1-866-329-3474
Colorado Springs, CO 80903 (914) 345-8862 (fax)
(719) 227-7518 http://www.nrsb.org
(719) 632-9607 (fax) e-mail: [email protected]
http://www.radongas.org/
e-mail: [email protected]
(Reference herein to any specific commercial products, process, or service by trade name, trademark, manufacturer,
or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United
States Government.)
October 20, 2000
I. Introduction .......................................................................................... 1
-i-
Criteria for EPA Evaluation of Non-Federal National Radon Proficiency Programs
I. Introduction
In 1988, Congress enacted the Indoor Radon Abatement Act (IRAA), which established a
long-term national goal to reduce indoor radon levels to the point that air within buildings is as
free of radon as the air outside. Under 15 USC 2665, §305(a)(2), “Technical Assistance to
States for Radon Programs,” IRAA provided EPA authority to develop and implement activities
designed to assist State radon programs, including operation of a voluntary program to rate the
effectiveness of radon measurement devices and methods, the effectiveness of radon mitigation
devices and methods, and the effectiveness of private firms and individuals offering radon-
related services.
Prior to closing its RPP, EPA began investigating the feasibility of privatizing the RPP and
worked with stakeholders, and, in particular, the Conference of Radiation Control Program
Directors, Inc. (CRCPD) and the American Association of Radon Scientists and Technologists
(AARST), to this end.
Currently, there are two privately-run National Radon Proficiency Programs, one run by the
National Environmental Health Association (NEHA) and one run by the National Radon Safety
Board (NRSB). Since the close of EPA’s RPP, there have been a number of requests that EPA
offer some form of recognition of these non-Federal programs. In response to these requests,
on May 22, 2000, EPA issued draft criteria that would be used in evaluating these non-Federal
radon proficiency programs. The draft criteria were posted on EPA’s web site, and sent to key
stakeholders representing States, consumers, industry, and the two current non-Federal radon
proficiency programs. EPA received fourteen individual and joint comments on the draft criteria
from a wide range of stakeholders and these comments have informed EPA’s development of
the final criteria.
A. Recognition
1. Development of Criteria
In its 5/22/00 draft criteria, EPA proposed that it would recognize/re-evaluate private
proficiency programs every three years. This periodic review process would have
EPA play a substantial continuing role in overseeing any recognized proficiency
program which a number of commenters did not support. Moreover, some of the
commenters wanted EPA to develop criteria that would require non-Federal
proficiency programs to comply with standards well in excess of EPA’s former
voluntary National Radon Proficiency Program (RPP). In consideration of these
comments, and to further encourage States, industry, and consumers to be involved
in ensuring that non-Federal programs meet their needs, EPA has decided that it will
offer a one-time process to recognize those programs that apply within a specified
period of time.
EPA believes that it is appropriate to develop recognition criteria that call for a non-
Federal radon proficiency program to incorporate, at a minimum, program elements
that comprised EPA’s former voluntary RPP. EPA continues to encourage States,
industry and consumers to work together to identify those elements that would
improve non-Federal radon proficiency programs and go beyond EPA’s former
voluntary RPP. These improved elements should then be adopted as standards of
practice.
2. Application Process
EPA will issue a letter of recognition for each program (residential measurement
service provider program, residential mitigation service provider program, and/or
analytical service provider program) that satisfies EPA criteria. This will be based
solely on the information contained in the program’s application(s). A copy of these
recognition letters will also be posted (see Appendix B and C for samples of each
type of letter) on http://www.epa.gov/radonpro/index.html. If an applicant does not
meet the established criteria, EPA will issue a letter to this effect, and will post this
determination on its web site.
An application for EPA’s recognition should be submitted to the following address so that
it will be received by EPA no later than March 1, 2001.
Applicants can submit one application for recognition for one or more program elements
(measurement, mitigation and/or analytical), but must fully address the criteria for each
of these recognitions in sufficient detail in separate sections of their application. Policy or
procedural manuals should be submitted in support of the application. The applicant
should highlight any deviation from the criteria in Section III below, and provide a detailed
explanation as to why the applicant’s program element still remains equivalent to that of
EPA’s former voluntary National Radon Proficiency Program.
EPA encourages all applicants to make public the contents of their application. However,
in accordance with established EPA procedures contained in the Code of Federal
Regulations, an applicant may assert a business confidentiality claim that covers part or
all of their application. If an applicant chooses to assert such a claim, it must do so at
the time of application. Information covered by such a claim will be disclosed by EPA
only to the extent, and by means of, the procedures set forth in 40 CFR Part 2, Subpart
B.
Should EPA find that an application is deficient, EPA will give the applicant notice of the
deficiencies and give the applicant 30 calendar days from the date of receipt of the notice
to remedy them. Failure by the applicant to remedy the deficiencies within the 30-day
period will result in a determination that the applicant has not shown that its program
element meets EPA’s criteria, and such a determination will be posted on EPA’s web
site.
III. Evaluation Criteria for Analytical Service Provider Programs, and Residential
Measurement and Mitigation Service Provider Programs
An analytical service provider program shall require a device performance test for
each radon test device or method listed by participants in its program. An analytical
service provider program shall require participants to provide measurement results
that are within at least what EPA’s former RPP required, ±25% of the chamber target
value. A more detailed discussion of what EPA required in its device performance
test is contained in, “U.S. EPA National Radon Proficiency Program Handbook, EPA
402-R-95-013, July 1996 which is available on the EPA website at:
http://www.epa.gov/radonpro/.
An analytical service provider program should develop criteria for a quality assurance
program and the program should require participants to adopt these criteria as they
develop their own quality assurance plan(s). An analytical service provider program
should also require participants in the program to operate by, and maintain their
quality assurance plan throughout their participation for each device listed in the
subject analytical service provider plan(s). The program should require that the
participant’s plan be updated whenever the program participant wishes to add a
device to a listing or certification in the program. Also, EPA’s guidance on quality
assurance (Radon Measurement Proficiency Program: Guidance on Quality
Assurance, EPA document 402-R-95-012) recommends that quality assurance
program criteria provide details, practices, and procedures unique to each device
used by a radon measurement service provider. An analytical service provider
program should adopt criteria for a quality assurance plan that address all four of the
following elements.
Additional guidance for analytical service provider programs in developing criteria for
quality assurance plans available under EPA Order 5360.1 A2, Policy and Program
Requirements for the Mandatory Agency-wide Quality System (May 5, 2000), which
reaffirms the policy defined under EPA Order 5360/1 (April 1984), and the EPA Order
5360 (2000), EPA Quality Manual for Environmental Programs. More information on
EPA’s quality program are available at: http://www.epa.gov/quality/index.html.
3. Adhere to Protocols
1. Examinations
S The results of the radon test, including an explanation of what the test result
means in reference to established benchmarks for concern, including EPA’s
radon action level of 4 pCi/L (picoCurries per liter);
S If the radon test exceeds established benchmarks (such as EPA’s action level
of 4 pCi/L), information about possible re-testing and information on how to
obtain mitigation services (such as is provided in EPA’s “Consumer's Guide
to Radon Reduction How to Reduce Radon Levels in Your Home...” EPA
Document Number 402-K-92-003).
1. Training
2. Examinations
A residential mitigation service provider program must be able to demonstrate how its
continuing education program is designed to maintain a participant’s relevant
knowledge in the radon field. A residential mitigation service provider program should
require participants to submit documentation showing their completion of, at least,
sixteen hours of continuing education. Under its former voluntary RPP, EPA required
that at least half of these credits come from completion of program-evaluated or
approved courses, with the other half of the continuing education requirements
coming from a variety of informal radon-related activities and experience. EPA will
consider this approach acceptable for a residential measurement service provider
program. Each formal course should include an evaluation mechanism built into the
lesson plan to ensure that attendees demonstrate attainment of the learning
outcomes with a certificate of successful completion awarded upon completion of the
course requirements.
A Citizen's Guide to Radon (second edition) The guide to protecting yourself and your family
from radon. EPA Document Number 402-K-92-001, September 1994.
Consumer's Guide to Radon Reduction How to Reduce Radon Levels in Your Home... EPA
Document Number 402-K-92-003.
Home Buyer's and Seller's Guide to Radon. EPA Document Number: 402-R-93-003, March
1993. (Note: A newly revised version of the Guide is about to be released - 402-K-00-008, July
2000).
Model Standards and Techniques for Control of Radon in New Residential Buildings.
EPA Document Number 402-R-94-009, March 1994.
Radon Mitigation Standards. EPA Document Number 402-R-93-078, October 1993 (Revised
April 1994).
Technical Support Document for the 1992 Citizen's Guide to Radon. EPA Document
Number 400-R-92-011, May 1992.
Indoor Radon and Radon Decay Product Measurement Device Protocols. EPA
Document Number 402-R-92-004, July 1992.
Protocols for Radon and Radon Decay Product Measurements in Homes. EPA Document
Number 402-R-93-003, June 1993.
U.S. EPA National Radon Proficiency Program Handbook, EPA 402-R-95-013, July 1996
EPA Order 5360.1 A2, “Policy and Program Requirements for the Mandatory Agency-wide
Quality System,” May 5, 2000 (http://www.epa.gov/quality)
RE: EPA’s Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or
Residential Mitigation Service Provider Program or Analytical Service Provider Programs]
Dear Sir/Madam:
EPA has completed its review of your program’s application dated __/__/__. Based solely
on its review of the materials submitted, EPA finds [the subject program’s] residential
measurement service provider program [or residential mitigation service provider program, or
analytical service provider program] successfully satisfies EPA criteria for operation of a non-
Federal national radon proficiency program if established and implemented as described in your
application. Because of expected changes in the radon industry, this acknowledgment is only
valid through December 31, 2002, at which time this determination will expire. There will be no
extensions of this determination. This determination is not applicable if changes are made to the
program as submitted to EPA, or if it is not implemented as described to EPA. To avoid
misleading the public, you may not make public reference to this EPA determination after
December 31, 2002.
“EPA has reviewed [your organization’s] description of its [your program name] and
has determined that the description of [your program’s name] is consistent with EPA’s
criteria for operation of a non-Federal residential measurement service provider program
[or a residential mitigation service provider program or an analytical service provider
program]. EPA has not reviewed the actual operation of [your program’s name].”
We will post the results of our determination on our web site at:
http://www.epa.gov/radonpro. If you have any questions concerning this letter, you may contact
James Long of my staff at (202) 564-9433 or [email protected].
Sincerely yours,
RE: EPA Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or
Residential Mitigation Service Provider Program or Analytical Service Provider Programs]
Dear Sir/Madam:
Based on EPA’s review of your submission dated __/__/00, we can not find that your
residential measurement service provider program [or residential mitigation service provider
program, or analytical service provider program] meets EPA’s criteria for a non-Federal national
radon proficiency program. You have 30 calendar days from the date of your receipt of this letter
to address the concerns described in the attachment. If you fail to successfully address these
concerns within the time frame allocated, no more consideration will be given to your
submission and EPA will issue you a formal denial of your application and post the results of our
If you have any questions concerning this determination, you may contact James Long of my
Sincerely yours,