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EPA Acknowledgement of Non-Federal National Radon

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 NRSB Equivalent Program Name


Analytical Service Provider Accredited Radon Laboratories
Residential Radon Measurement Provider Radon Measurement Specialist
Residential Radon Mitigation Provider Radon Mitigation Specialist

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

Criteria for EPA Evaluation of


Non-Federal National Radon Proficiency Programs

U.S. Environmental Protection Agency


Office of Air and Radiation
Office of Radiation and Indoor Air
Indoor Environments Division (6609J)

1200 Pennsylvania Avenue, N.W.


Washington, DC 20460
Table of Contents

I. Introduction .......................................................................................... 1

II. EPA’s Recognition of Non-Federal Radon Proficiency Programs ............ 2


A. Recognition .................................................................................... 2
1. Development of Criteria ............................................................. 2
2. Application Process ................................................................... 2
B. Application for Recognition ............................................................. 3

III. Evaluation Criteria for Analytical Service Provider Programs, and


Residential Measurement and Mitigation Service Provider Programs ..... 3
A. Criteria for Recognition of an Analytical Service Provider Program ... 3
1. Device Performance Test ....................................................... 4
2. Develop and Implement a Quality Assurance Plan ...................... 4
3. Adhere to Protocols .................................................................. 5
4. Reassessment of Qualifications on a Biennial Basis ................... 6
5. Compliance with Program Requirements .................................... 6
B. Criteria for Recognition of a Residential Measurement Service
Provider Program ............................................................................. 6
1. Examinations ............................................................................. 6
2. Adhere to Protocols ................................................................. 7
3. Develop and Implement a Quality Assurance Plan ..................... 7
4. Reassessment of Qualifications on a Biennial Basis .................. 7
5. Provide Lists of Certified/Proficient Individuals ........................ 8
6. Compliance with Program Requirements ................................... 8
7. Consumer Information ........................................................... 9
C. Criteria for Recognition of a Residential Mitigation Service
Provider Program ............................................................................ 9
1. Training .................................................................................. 9
2. Examinations ............................................................................ 9
3. Adhere to EPA Radon Mitigation Standards .............................. 10
4. Reassessment of Qualifications on a Biennial Basis ................. 10
5. Provide Lists of Certified/Proficient Individuals ....................... 10
6. Compliance with Program Requirements .................................. 11

Appendix A - List of Resources ................................................................ 12


Appendix B - Sample Acknowledgment Letter to Successful Applicants .... 13
Appendix C - Sample Letter to Applicants Who are Denied
Acknowledgment ............................................................... 14

-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.

In response to this authorization, EPA established the Radon Measurement Proficiency


(RMP) Program to assist consumers in identifying organizations capable of providing reliable
radon measurement services. The Radon Contractor Proficiency (RCP) Program was
established in 1989 to evaluate the proficiency of radon mitigators in residences and provide
information to the public on proficient mitigators. In 1991, EPA expanded the RMP Program,
adding a component to evaluate the proficiency of individuals who provide radon measurement
services in the home. In 1995, these Programs were consolidated to form the National Radon
Proficiency Program (RPP). A number of factors contributed to EPA’s closing down its RPP on
September 30, 1998. In addition to EPA’s budgetary constraints, the radon industry itself had
matured and appeared willing and capable of running their own proficiency program.

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.

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 1 of 14
II. EPA’s Recognition of Non-Federal Radon Proficiency Programs

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

Upon successful application, a non-Federal proficiency program will be recognized


as meeting EPA’s minimum criteria for a residential measurement service provider
program or a residential mitigation service provider program or an analytical service
provider program. To achieve this recognition, the non-Federal program will have to
prove that it contains at least all of the components (or their equivalent) of the
applicable portion of EPA’s former voluntary National Radon Proficiency Program.
These are outlined in further detail in Section III below.

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.

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 2 of 14
B. Application for Recognition

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.

Mr. James W. Long


U.S. Environmental Protection Agency
Indoor Environments Division (6609J)
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

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

A. Criteria for Recognition of an Analytical Service Provider Program

Analytical measurement services are defined as radon measurement services or


activities that include the capability to extract, read, analyze, or manipulate the data from
radon measurement device(s), and calculate the final concentration for the client test
report. These capabilities include, but are not limited to, reading and recording initial and
final voltages, printing data tapes, recording concentrations from a data window, or
downloading the data to a some form of device/system for test report generation. An
analytical service provider program shall require its participants to adhere to quality

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 3 of 14
assurance/quality control (QA/QC) principles and appropriate radon measurement
protocols.

1. Device Performance Test

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/.

2. Develop and Implement a Quality Assurance Plan

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.

• Chain of Custody: A quality assurance plan should demonstrate custody


procedures for tracking specific measurement devices. All radon
measurement tests performed should have supporting documentation, which
provides complete chain-of-custody information. All certified or listed devices
in an analytical service provider program should carry a unique identifier, such
as a serial number. Analytical service provider programs should require
participants in their program to keep a record of the residential measurement
service providers whose devices they analyze and be specific to the devices
analyzed.

• Calibration: An analytical service provider program must require its


participants to be able to describe the process, in writing, of how devices
used by participants are calibrated. EPA recommends that an analytical
service provider program should require participants in the program to have
their devices calibrated at least biennially. Calibration ensures that results of
analyses are accurate within acceptable limits. An analytical service provider
Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs
October 20, 2000
Page 4 of 14
program should require that all continuous radon and continuous working level
measurement devices display calibration information. This calibration “label”
should list the calibration facility, the calibration date, and the calibration
expiration date. An analytical service provider program should require
participants to maintain records of calibration certificates and/or logs for all
devices listed by the participant in the program.

• Checks for Background: A quality assurance plan should also include


instructions on how to assess the effect of background radiation on
measurement results.

• Spiked, Blank and Duplicate Samples: Depending on the measurement


device or method, criteria for a quality assurance plan should require that
participants regularly use of one or more of the following checks for bias and
precision.

S Spikes are samples that are exposed to a known radon concentration.


S Blanks are unexposed samples.
S Duplicates are two or more measurements with identical equipment
exposed over the same time interval at the same location.

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

An analytical service provider program shall require participants in its program to


agree to adhere to the EPA’s Measurement Device and Homes Protocols, that are
referenced in Appendix A, or some equivalent or better device and homes protocols.
There are many Federal, State, university, and private organizations who perform
radon measurements, therefore, it is important that an analytical service provider
program follow consistent procedures to assure accurate and reproducible
measurements, and to enable valid intercomparison of measurement results.

S Indoor Radon and Radon Decay Product Measurement Device Protocols.


EPA Document Number 402-R-92-004, July 1992.

These protocols provide method-specific technological guidance that can be


used as the basis for standard operating procedures. In keeping with good
laboratory practices, each program participant should develop its own detailed
instrument-specific procedures that incorporate recommendations found in
this and other radon-related protocol and guidance documents.

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 5 of 14
S Protocols for Radon and Radon Decay Product Measurements in Homes.
EPA Document Number 402-R-93-003, June 1993.

4. Reassessment of Qualifications on a Biennial Basis

An analytical service provider program should require participants to remain abreast


of new developments in the radon industry and to continue to hone their skills. The
analytical service provider program should require participants to fulfill biennial
listing/certification requirements. The biennial requirements may include device
performance tests, review of the participant’s quality assurance procedures, and/or a
review of the participant’s quality control (QC) measurement data during the previous
listing/certification period, etc.

5. Compliance with Program Requirements

An analytical service provider program shall have a compliance component and a


process for evaluating complaints, including fair procedures that afford opportunities
for providers and complainants to present their views to an impartial party (to be
determined by the analytical service provider program). EPA suggests that
consequences (e.g., delisting/decertification for incompetence, inappropriate
practices or fraud) of program non-compliance should be clearly stated in
informational materials provided by the analytical service provider program and
should be implemented when appropriate.

B. Criteria for Recognition of a Residential Measurement Service Provider Program

A residential measurement service provider program should evaluate participants on


their knowledge in providing reliable radon measurement services in the home. EPA
considers the following components necessary elements for a residential measurement
service provider program to assess the qualifications of participants so as to ensure that
consumers receive reliable, quality measurement services.

1. Examinations

A residential measurement service provider program shall require participants to


demonstrate knowledge sufficient to provide reliable radon measurement services in
a residential setting. EPA considers the preferred method to demonstrate this
knowledge to be passing a written or, for example, a computer-based exam, as a
condition to being initially listed or certified. The exam should be designed to evaluate
an individual’s knowledge necessary to ensure valid radon measurements and
effective consumer communication. EPA continues to offer an extensive list of
resources to assist in the development of an exam and as a study aid for participants
to prepare for the exam(s) (see Appendix A).

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 6 of 14
2. Adhere to Protocols

A residential measurement service provider program shall require participants in its


program to agree to adhere to EPA’s Measurement Device and Homes Protocols,
that are referenced in Appendix A, or some equivalent or better device and homes
protocols. There are many Federal, State, university, and private organizations who
perform radon measurements, therefore, it is important for that a residential
measurement service provider program follow consistent procedures to assure
accurate and reproducible measurements, and to enable valid intercomparison of
measurement results.

S Indoor Radon and Radon Decay Product Measurement Device Protocols.


EPA Document Number 402-R-92-004, July 1992.

These protocols provide method-specific technological guidance that can be


used as the basis for standard operating procedures. In keeping with good
laboratory practices, each program participant should develop its own detailed
instrument-specific procedures that incorporate recommendations found in
this and other radon-related protocol and guidance documents.

S Protocols for Radon and Radon Decay Product Measurements in Homes.


EPA Document Number 402-R-93-003, June 1993.

3. Develop and Implement a Quality Assurance Plan

A residential measurement service provider program shall develop criteria for a


quality assurance program and the program should require participants to adapt this
criteria as they develop their own quality assurance plan(s). A residential
measurement service provider 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 a quality assurance plan provide details, practices,
and procedures unique to each device used by a radon measurement service
provider. (See III.A.2. above for further EPA guidance regarding development of
quality programs.) The elements of the guidance are designed to provide a
framework for quality assurance practices that can be modified, and added to,
according to the specific needs of the measurement program.

4. Reassessment of Qualifications on a Biennial Basis

A residential measurement service provider program should require participants to


remain abreast of new developments in the radon industry and to continue to hone
their skills. The program shall require participants to fulfill a biennial re-listing/re-
certification requirement. This requirement could be achieved by completing
continuing education requirements. A residential measurement service provider
program should demonstrate how continuing education course work is approved and
Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs
October 20, 2000
Page 7 of 14
how participants document their completion of continuing education credits. A
residential measurement service provider program that approves course providers
should require these providers to update their course materials on a regular basis to
ensure that as new technical information is developed this information is incorporated
into the course material. As part of its former continuing education program, EPA
developed course evaluation criteria that can be used as guidance in developing a
continuing education program (see Appendix A).

A residential measurement 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 measurement 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 non-Federal 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.

5. Provide Lists of Certified/Proficient Individuals

Consumers seeking the services of a radon measurement service professional need


a resource they can use to find qualified service professionals. EPA recommends
that consumers contact their State Radon Contact to determine what are the, or
whether there are, requirements associated with providing radon measurement in a
particular State. Some States maintain lists of contractors available in their state or
they have proficiency programs or requirements of their own. EPA recommends that
a residential measurement service provider program offer convenient ways for
consumers and other groups to search for their listed radon professionals in an
easily accessible media (e.g., the world wide web).

6. Compliance with Program Requirements

A residential measurement service provider program shall have a compliance


component and a process for evaluating complaints, including fair procedures that
afford opportunities for providers and complainants to present their views to an
impartial party (to be determined by the residential measurement service provider
program). EPA suggests that consequences (e.g., delisting/decertification for
incompetence, inappropriate practices or fraud) of program non-compliance should
be clearly stated in informational materials provided by the residential measurement
service provider program and should be implemented when appropriate.

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 8 of 14
7. Consumer Information

In addition, a residential measurement service provider program shall require


participants to provide all customers the following information:

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).

C. Criteria for Recognition of a Residential Mitigation Service Provider Program

A residential mitigation service provider program should evaluate participants on their


knowledge in providing reliable radon mitigation services in the home. EPA considers the
following components necessary elements for a residential mitigation service provider
program to be able to assess the qualifications of participants so as to ensure that
consumers receive reliable, quality services.

1. Training

A residential mitigation service provider program shall incorporate requirements that


participants complete at least 16 hours of hands-on training. A residential mitigation
service provider program should be able to prove that training courses, at a
minimum, contain the guidance in EPA’s “Radon Mitigation Standards.” EPA
Document Number 402-R-93-078, October 1993 (Revised April 1994), or equivalent
information. The EPA Radon Mitigation Standards set a base level of performance
for all residential mitigation service providers.

2. Examinations

A residential mitigation service provider program should require participants to


demonstrate knowledge sufficient to provide reliable radon mitigation services in a
residential setting. EPA considers the preferred method to demonstrate this
knowledge to be passing a written or, for example, a computer-based exam, as a
condition to being initially listed or certified. The exam should be designed to evaluate
an individual’s knowledge necessary to ensure valid radon mitigations and effective
consumer communication. EPA continues to offer an extensive list of resources to
assist in the development of an exam and as a study aid for participants to prepare
for the exam(s) (see Appendix A).

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 9 of 14
3. Adhere to Radon Mitigation Standards

A residential mitigation service provider program shall require participants in its


program to agree to adhere to appropriate standards and protocols, such as those
found in EPA’s “Radon Mitigation Standards.” EPA Document Number
402-R-93-078, October 1993 (Revised April 1994), or similar document.

EPA’s Radon Mitigation Standards provide uniform standards that residential


mitigation service provider programs can use to ensure quality and effectiveness in
the design, installation, and evaluation of radon mitigation systems.

4. Reassessment of Qualifications on a Biennial Basis

A residential mitigation service provider program should require participants to


remain abreast of new developments in the radon industry and to continue to hone
their skills. The program shall require participants to fulfill a biennial re-listing/re-
certification requirement. This requirement could be achieved by completing
continuing education requirements. A residential mitigation service provider program
should demonstrate how continuing education course work is approved and how
participants document their completion of continuing education credits. A residential
mitigation service provider program that approves course providers should require
these providers to update their course materials on a regular basis to ensure that as
new technical information is developed this information is incorporated into the
course material. As part of its former continuing education program, EPA developed
course evaluation criteria that can be used as guidance in developing a continuing
education program (see Appendix A).

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.

5. Provide Lists of Certified/Proficient Individuals

Consumers seeking the services of a radon mitigation service professional need a


resource they can use to find qualified service professionals. EPA recommends that
consumers contact their State Radon Contact to determine what are the, or whether
there are, requirements associated with providing radon mitigation in a particular
Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs
October 20, 2000
Page 10 of 14
State. Some States maintain lists of contractors available in their state or they have
proficiency programs or requirements of their own. EPA recommends that a
residential mitigation service provider program offer convenient ways for consumers
and other groups to search for their listed radon professionals in an easily accessible
media (e.g., the world wide web).

6. Compliance with Program Requirements

A residential mitigation service provider program shall have a compliance component


and a process for evaluating complaints, including fair procedures that afford
opportunities for providers and complainants to present their views to an impartial
party (to be determined by the residential mitigation service provider program). EPA
suggests that consequences (e.g., delisting/decertification for incompetence,
inappropriate practices or fraud) of program non-compliance should be clearly stated
in informational materials provided by the residential mitigation service provider
program and should be implemented when appropriate.

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 11 of 14
Appendix A
List of Resources

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.

El Radón Guía para su protección y la de su familia Documento de la Agencia de los Estados


Unidos para la Protección Ambiental Número 402-K-93-005, septiembre del 1993.

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.

Radon Measurement Proficiency Program: Guidance on Quality Assurance, EPA


document 402-R-95-012

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)

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 12 of 14
Appendix B
Sample Acknowledgment Letter to Successful Applicants

[Organization’s Name] [Date]


[Organization’s Representative]
[Address]
[City, State, Zip]

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.

Any references to EPA’s determination in advertisements should avoid misleading


consumers. We recommend that you use the following description:

“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,

Mary T. Smith, Director


Indoor Environments Division

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 13 of 14
Appendix C
Sample Letter to Applicants Who are Denied Acknowledgment

[Organization’s Name] [Date]


[Organization’s Representative]
[Address]
[City, State, Zip]

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

determination on the EPA website at: http://www.epa.gov/radonpro/.

If you have any questions concerning this determination, you may contact James Long of my

staff at (202) 564-9433 or [email protected].

Sincerely yours,

Mary T. Smith, Director


Indoor Environments Division
Attachment

Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs


October 20, 2000
Page 14 of 14

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