AARST_Radon_Reporter_July_2023

THE RADON REPORTER | 27 POLICY requirement of 24 CFR 58.5(i)(2)(iv) to use current techniques by qualified professionals to undertake investigations. A few of the more obvious cautionary notes are: • Subsidizing do-it-yourself testing limited to tenants and owner-occupants is a good first step for their own benefit. It should not be tied to refinancing, real estate transactions, or federal program determination of need for mitigation. • If allowed in multifamily properties, the use of test kits by owners must test 100% of the ground contact units • Suggesting that state- and SIRG-funded test kits be used to test residence is not viable: kits are for occupants’ self-protective action. • An occupant self-test cannot be used to exempt the unit from program action • Recommending kit purchase sources is inappropriate for a policy • Citizen’s guide contains insufficient guidance for third party testing – delete • Legitimate third-party test devices are approved by proficiency program Testing in Remote Areas. The need for greater capacity that exists in few areas of the country will be met as demand grows. It is important that HUD support programs and agencies in such areas with relevant, timely, and health-protective guidance consistent with the mandate to use current techniques and qualified professionals. Local government staff, and others involved in HUD programs, can fulfill capacity gaps in measurement (and mitigation) by getting staff trained and credentialed through a private proficiency program and, as applicable, state credentialing program. They can also use the state, NRPP and NRSB listings to identify qualified providers. There are radon professionals who will drive more than an hour to meet a need. For HUD programs testing properties to determine the need for mitigation, consumer monitoring devices are not a substitute for devices that have been approved by the EPA-recognized certification programs. The applicable regulation at 24 CFR 58.1(d) allows the Assistant Secretary for Community Planning and Development to, for good cause and with appropriate conditions, approve waivers and exceptions. Responsible parties and programs that can document inability to comply should be able to submit a request for a waiver or exception. HUD should establish criteria for granting a variance so that the building does get tested and public health is not compromised. Such exceptions should be rooted in specific types of circumstances proposed by the requestor, such as testing will be done using a specific equipment/person to do the work. Scientific Data Review. Testing is the only way to determine if a building has a high radon level: scientific data cannot be used to determine “whether the project site is located in an area identified as having a high potential for high radon levels.” This criterion is flawed, since any risk potential is the only legitimate threshold to define whether an area is impacted by high radon levels. The mischaracterization of radon-induced lung cancer risk is a longstanding health equity problem. The historic EPA radon zone maps classified 3,000 plus counties as having high, medium, or low risk, based on 5,694 radon tests and some geologic and ambient air data. For thirty years, the resultant EPA maps have effectively steered consumer testing decisions and public resources toward the many places labeled high risk and away from Texas, California, and numerous southern states deemed low risk. The EPA Map’s mean radon levels mask measurements above the action level. Millions of additional measurements have occurred since this point-in-time study. Geological studies should not be used to define whether an area is impacted by high radon levels. While certain geologic formations increase the potential for greater levels of uranium, radon has been found in buildings in many areas that lack these formations. The most thorough EPHT test data results above the action level and maximum radon level can be useful indicators of an area’s risk potential. Mean and median radon levels should not be used to define whether an area is impacted by high radon levels since they mask measurements above the action level. Mitigation. The mitigation plan must be developed under the supervision of a certified or licensed radon mitigation professional. The mitigation plan, when implemented, shall be implemented by or under the supervision of a certified or licensed radon mitigation professional in accordance with the applicable ANSI/AARST mitigation standard. Post-mitigation clearance must indicate that the radon level is below 4 picocuries per liter. HUD must ensure that all HUD programs test for and mitigate radon consistent with industry standards and insist that the disparate treatment of HUD program recipients ends. “ “