DEVELOPMENT OF ASTM RADON MITIGATION STANDARDS
Marc Messing
Infiltec Radon Control, Inc
Falls Church, VA

ABSTRACT

The American Society for Testing and Materials (ASTM) is a non-governmental organization formed for
the development of independent standards on products, materials, systems and services. The Society operates
through a hierarchical structure of committees, subcommittees, and task groups, using a voluntary consensus process
to establish standards for methods and processes ranging from atmospheric chemistry to ocean floor drilling. In
1990 a Task Group on Radon Mitigation in Existing Residential Homes was established to develop standard
practices for installing radon control systems. The Environmental Protection Agency (EPA)'s radon mitigation
standards were used as the basis for the ASTM's first draft and the EPA effectively assumed the lead in developing
ASTM standards which would be compatible with its own. During the past five years substantial progress has been
made in the development of this standard; but the Task Group's difficulty in distinguishing between its technical
guidance and the EPA's policy guidance remains a serious obstacle to consensus and the promulgation of a standard.
INTRODUCTION

The American Society for Testing (ASTM) was incorporated in 1902 as an independent organization which
operates through "rigorous democratic procedures"' to ensure the development of consensus documents. These
procedures include meetings of task groups and committees, and a hierarchical sequence of balloting on proposed
standards before any such standards are submitted to ASTM for final balloting and approval.
Following the publication of the EPA's first citizen guides to radon in 1986, discussions began on the
subject of developing standards for the installation of radon control systems, and in 1990 an ASTM Task Group on
Radon Mitigation was formally estab~ished.~
Initial meetings of the task group in 1990 and 1991 failed to produce
any clear direction or working draft, and in 1992 the EPA offered both. In the previous year the EPA had published
their interim standards for radon mitigation: and it was working on a revised and expanded version of these
standards. Dave M. Murane, working for the EPA's Radon Policy Office, had recently completed development of
the EPA's new construction standards for radon prevention and was assuming responsibility for revision of the EPA
radon mitigation standards. Accordingly, Murane was asked to chair the ASTM task group in addition to his
responsibility at the EPA.

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1992 THE INITIAL EPAIASTM DRAFT

The ASTM task group met in October, 1992, reviewed the EPA draft mitigation standards, and directed
Murane to rewrite the draft as an ASTM Standard practice3*, and delete sections which referred to specific the EPA
policy requirements.4 A revised draft was circulated to the task group in December
Contrary to the task group's
directives, however, the expanded draft included new policy requirements from the EPA. In contrast to the the
EPA's interim standards of the previous December, which were barely four pages long and included only two
substantive technical requirements for the installation of radon control systems, the ASTM draft circulated in
December enumerated approximately one hundred requirements, many of which were, arguably, matters of policy
rather than technical guidance. For example, the draft required that contractors review test data with clients, advise
clients of health risks (referencing only the EPA documents), provide clients with Material Safety Data Sheets,
develop detailed building sketches, comply with federal laws, have suitable fire protection, et~.~"'**~

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1996 International Radon Symposium I11 - 8.1

When this draft was circulated to task group members in December, 1992, it was hoped that changes could
be made in time for a sub-committee ballot before the next committee meeting in March, 1993." This expression of
hope was ephemeral. The draft generated substantial criticism, both of the technical issues and of the EPA's policies.
1993 - INCREASING DISCUSSION AND DISSENSION
The Subcommittee met again in March, '93, in Atlanta, and in August a revised draft was submitted to
ASTM for balloting. Prior to submitting this draft, however, Murane not only made revisions to accommodate the
problems of the December. '92 ballot, but made additional changes to reconcile the ASTM draft standard with the
EPA draft standard which was under parallel de~elopment.""~ This new ASTM draft included two significant
changes. First, a section was added requiring back-drafting testsI2'. The EPA had issued an addendum to its interim
standards with this requirement, but the requirement was problematic for several reasons, including the fact that it
required mitigation contractors to perform time-consuming tests on houses prior to beginning, or even bidding work;
and there was no consensus standard which could be referenced for performing the necessary tests.I3 The second
change which was made was more far-reaching. Prior drafts had stipulated what "should" be done. In this draft, it
was explicitly stated that the standard was "not intended to represent either minimum or maximum acceptable
practices and should not be universally applied.I4 However, the word "shall" was inserted in the document more
than 100 times, thus effectively requiring virtually all of the practices be universally applied. In contrast, the word
"should" was retained in about a half dozen instances.
A variety of responses were received to this draft ranging from specific technical issues to the broader issue
of making all of the requirements
When the task group met again in October, '93, in Dallas, the
negative ballots were reviewed and it was decided that a revised draft would have to be circulated before being
resubmitted for balloting "because of the significant changes need to accommodate the ~omments"'~.It also was
noted in these comments that the document was out-dated because it failed to reference the Third Edition of the
EPA's Technical Guidance manual which had been released in the meantime.'* This draft was circulated in
~ o v e m b e r lbut
~ , apparently without significant change.
1994 - FUNDAMENTAL POLICY DIFFERENCES
By early 1994 it was clear that objections to the November draft were substantial, and this was underscored
by additional responses submitted in January in ~ e b r u a r ~ . 'Despite
~*
the task group's initial direction that the ASTM
standard should avoid policy and focus on issues of technical guidance, the draft was still significantly shaped by the
EPA policies it included. The EPA had decided to revise its Radon Mitigation Standard (RMS)~' in parallel with the
development of the ASTM standards, so that its policy could reference the technical guidance developed by ASTM.
Issues which were incompatible with the EPA policies apparently were not submitted to the Task Group for
consideration, regardless of the technical arguments which had been received from professional mitigators. Two
issues in particular clearly illustrate this problem: fan location and sump sealing.
Fan Locations
In 1991, when the EPA published its first standards for mitigation systems, it contained only two fundamental
technical requirements: 1) that fans be placed outside the building space, and 2) that the exhaust be vented away
from potential re-entry routes." The requirement that fans be placed outside the living space was based primarily on
the argument that this would create fail-safe systems because it eliminated the possibility of suddenly elevated levels
occurring as the result of leaks in the system.22 The EPA requirement was based on evidence of leakage in early,
unsealed, fans which had been mounted directly to pvc pipe in the mid-1980's. The problem of leakage from these
systems had been identified by late 1986 or early 1987, however, and by 1990 the common practice used factorysealed fans,mounted to solvent welded pipe with flexible couplings. Under these circumstances, it was argued, the
possibility of such leaks is small and there was no evidence that they were actually occurring.23

1996 International Radon Symposium 111 - 8.2

Although this issue appears to have been decided by the EPA as a matter of policy, there are technical
questions which are relevant to it: can fans designed for radon applications be "leak-proof;" are the flexible
couplings used in radon applications subject to deterioration; can systems be tested for positive pressure leaks; what
data is available regarding actual system failures from positive pressure leaks? In order to reach a sound technical
judgement, it would seem that answers to questions such as these should be the basis of an ASTM technical standard.
Sump Sealing
A second, similar issue regards the requirement to seal sumps. The July '93 draft included the requirement
to provide "a trapped drain@) with an automatic supply of priming water or with a check value to provide
protection... a high-tech, high-cost solution to a simple problem." If there was no requirement for sump sealing, then
the possibility of surface water drainage in the basement could be accommodated by simply drilling a I" hole in the
sump cover to allow drainage and design the system to accommodate the additional airflow.24 The additional airflow
would be insignificant, as a 1" hole at a pressure of 1" W.C. allows only 13 cfin of air flow and systems with sumps
and drainage fields would be expected to draw between 100 and 200 c h ; but the issue was problematic because it
questioned the more fundamental issue of requiring the sumps to be sealed. As with the questions raised about fan
locations, the decision about sump sealing should be made on the basis of technical evidence rather than by fiat..=
In May '94 a revised draft was again prepared without responding to these ~bjections?~
In October the
Standard was voted on again by the Sub-committee and nineteen votes were cast in the affirmative; two were cast in
the negative (although none of the professional mitigators who were engaged in the process at this time were part of
the formal balloting). In December, 1994, a new draft was proposed which included many minor editorial changes,
and which restructured the section on mitigation systems to reflect the organization of the Third Edition of the
Technical Guidance Manual which had been published by the E P A . ~ ~In~ 'March, 1995 the task group met again, a
revised draft was again circulated, and extensive comments were received, including the following comments on the
difference between "should" and
"The word 'should' is used throughout this document to indicate a general obligation, as distinct from an
absolute requirement, which is dictated by the word 'shall." There is a series of three questions which may be used to
determine the appropriate requirement, and therefore the appropriate word, in this document: 1) does the requirement
provide a measure of safety in most, if not all instances, 2) are there reasonably foreseeable situations in which the
requirement provides little or no measure of safety, and 3) are there reasonably foreseeable situations in which the
requirement would be counterproductive...If the requirement provides a measure of safety in all situations it is
appropriate to require it with the word 'shall'. If it does not provide a measure of safety in all situations, or it may be
counterproductive, then 'should' is more appropriate."30 These written comments led to further discussions of the
subject (at the EPA), but no changes. In October, 1995, the Task Group met in Orlando and in January, 1996,
another draft was circulated.
1996 - APPROACHING A STALEMATE
In January, 1996 a draft was circulated to members of the task group. "This informational draft," it was
noted in the cover letter, "includes all of the changes resulting from decisions made at the October 1995 meeting of
the E0641.3 (sic) Work Group as well as changes resulting from subsequent meetings and discussions with the EPA
Staff and ASTM members who submitted negative ballot ~ . . . " ~Unfortunately,
'
it neither addressed nor resolved the
various substantive technical objections cited in this review. Rather, it reiterated the EPA's position. "Reviewers
should be aware," the cover letter continues, "that...EPA intends to cite this ASTM Standard Practice as the primary
source of technical guidance to radon mitigation contractors. It will be a substitute for the technical portions of the
"
current EPA Radon Mitigation Standards (RMS).~~
Since 1992 the work of the task group has been dominated by the EPA - which has paid for the work of the
Chairman, first as an employee and later as a consultant - and sparsely attended by professional radon mitigators.
While considerable progress has been made, efforts by professional mitigators have been largely limited to written

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1996 International Radon Symposium I11 8.3

critiques of proposed drafts and substantive questions in conflict with EPA policies have been repeatedly dismissed.
Thus, after more than five years work and substantial progress, a consensus appears unlikely at this time.
Underlying this stalemate are several key issues. First of all, it is unclear whether the work of this task
group would be more appropriately spent on a Standard Guide, rather than a Standard Practice. The mandatory
nature of a "practice", which is a definitive procedure, may not be appropriate to the variety of structures and
circumstances found in retrofitting existing homes with radon mitigation systems. Secondly, a consensus must be
reached focussing on technical issues and leaving policy issues, as much as possible, aside. Thirdly, important
technical issues which have been raised during the past five years should be reviewed, and, to the extent possible,
resolved on their technical merits." To achieve these objectives, it would probably be desirable for the EPA to
relinquish the lead role it has assumed in this effort and allow ASTM to develop and independent technical standard.
Once that standard has been established, the EPA Radon Mitigation Standard could be revised on the basis of EPA's
policies for participation in the Radon Proficience Program, and the ASTM technical standard could be referenced
by the RMS where appropriate. The result would be a better process and a better product.

Regulations Governing ASTM Procedures, ASTM, 1992,

'The task group was created in the Committee on Performance of Buildings (E06) Subcommitteeon Infiltration in
Buildings (.41) Task Group on Air Infiltration (.09). Thus it was officially created as the Task-Group on Radon
Mitigation in Existing Residential Homes within the E06.41.09 Task Group.
EPA's Interim Radon Mitigation Standards had been developed and published pursuant to a congressional mandate
under the Indoor Radon Abatement Act of 1988
3a A "standard practice", in ASTM terminology is "a definitive procedure for performing one more specific
operations...", such as procedures for conducting interlaboratory testing programs, ASTM Regulations Governing
ASTM Technical Committees, July 1992
Memorandum from David M. Murane, dated 12101/92.
ASTM Draft Standard Practice for Installing Radon Mitigation Systems in Existing Homes, 1 1/18/92
ibid
6.3.1
ibid, 6.1.1; it was also noted in comments to this provision that the requirement was absurd and unconstitutional: "If
one want to argue that radon mitigation contractors should be experts in health risk analysis a notion akin to
requiring (hat plumbers be experts in sanitary engineering - then they should be familiar not only with EPA's
guidance on the health risks, but also the contrary opinions offered by the National Academy of Sciences, the World
Health Organization, federal agency and other countries which have offered different guidance." M. Messing,
comments dated December, 1992
D. Murane, Memorandum, op cit.
"raft dated 7/22/93
12 D.Murane, Correspondenceto Ms. Carolyn Thompson, ASTM, dated 2 August 93.
Draft dated 7/22/93, sec. 7.2.4
l3 The draft did reference other test procedures; however, the test procedures were complex and considered
unsatisfactory by ASTM task groups working on the problem of establishing back-drafting procedures.
l4 Draft dated 7/22/93, sec. 5.1
l5 Because ASTM welcomes all expert assistance in developing standards and the process is voluntary, there are no
ASTM membership requirements for participation in the various task groups and committees. It is unclear whether
any professional radon mitigators were members of either the task group or the parent committees in 1992; however,
extensive comments were submitted by J. Masson of Protech Environmental Services and M. Messing of Infiltec
Radon Control.
l6 Comments of J. Masson, Sept 19. 1993; , Comments of M.Messing, 1 Oct 1993
l7 Memorandum from D. Murane to Task Group, dated 3 Nov 93
l8 EPA, Radon Reduction Techniques for Existing Detached Houses; EPA/625/5-931019, 1993.

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1996 International Radon Symposium 111 - 8.4

Draft 1O/28/93
Comments of W.P.Brodhead, dated 21 January, 1994; comments of M. Messing, dated 20 Feb 94;
because these professional mitigators were, apparently, not formal members of the task group, they did
not received task force drafts directly, and responses were often out of synch with the group's progress.
20 The Interim Mitigation Standard had been supplanted by the RMS and was revised again in April, 1994; at this
time
21 "Depressurization system fans... shall not be installed in the conditioned (heatedkooled) space of a building, or in
any basement, crawlspace, or other interior location...(and) exhaust vents from depressurization system fans...shall
be discharged according to all of the following requirements: 1) the discharge point shall be ten feet or more above
ground level, 2) ...(away) from any window, door, or other openings ... 3) away from any private or public access,
and 4) ...(away) from any opening into an adjacent building." All the other requirements were essentially procedural.
EPA, Interim Radon Mitigation Standards, December 1991.
In all active soil depressurization systems -- which probably constituted more than 95% of all radon control
systems being installed by 1994 - the system between the soil and the fan is under a constant negative pressure as
soil gas is drawn into the fan. Any leakage in this part of the system, in the pipe or in the fan, is unlikely to cause
leakage of radon gas into the house because the system is under a negative pressure. Household air is more likely to
be drawn into the leak. The part of the system from the fan to the exhaust point, however, is under positive pressure,
and any leakage in this part of the system would force soil-gas borne radon out of the system and into the
surrounding area. If that area is in the house, and if the soil concentrations of radon are sufficiently high, the result
would be sharp increases in the indoor radon levels. This scenario of an undetected positive pressure leak inside the
building space is the only "catastrophic" failure mode that has been identified with radon systems. If systems shut
down, radon levels would be expected to rise no higher than pre-existing levels; if leaks occur in the negative side of
the system, no increases would occur (except through secondary system degradation); but leaks in the positive side of
the system could results in radon levels far higher than any pre-existing levels, and, in the absence of radon
measurements, there would be no way to detect such severe and sudden increases. Requiring the placement of fans
outside the building envelope therefore eliminates the only catastrophic failure mode associated with radon control
s stems. This was well understood by the late 1980's and therefore part of the first interim standards.
"J. Masson, Comments dated .... It was also argued that interior fan locations would entail simpler wiring, longer
fan life, easier detection of failure, fewer chances for damages, lower installation costs and enhanced aesthetics..
24 M. Messing, op cit
Following the lack of a response to these questions, the argument was carried forward in an article in the Indoor
Air Quality Journal", October, 1995: "The leakage area around the circumference of a 24" inch sump yields less
than 1/10 the leakage area around half the perimeter of a 30' x 40' basement (assuming comparable leakage
around the sump and the perimeter). If suction were applied to the swap it is conceivable that this leakage could
short-circuit the system and prevent an effective pressure-field. But if suction is applied away from the sump, a
covered - but unsealed - sump yields no more leakage area than that accepted at floor wall joints behind
inaccessible walls. And if pressure were to be applied to the sump and the pressure-field extension were found to
be in adequate, it would be trivial to seal the sump. The important issue here is that EPA protocols require sumps
to be sealed in all cases: despite the fact that it is technically unnecessary, it adds some additional expense, and it
creates justified consumer anxiety about sump repairs.
'These issues also relate to the attendant requirement that sump covers be fitted with water traps or
mechanical traps. These also add to consumer costs, provide no additional benefits, and are unnecessary if the
sump cover is left unsealed. (In some instances it also might be desirable to seal the sump for stability and drill a
1" drainage hole in the cover rather than fit it with a mechanical trap.) In low-pressurehigh flow systems such as
sump pump depressurization, the air leakage from an unsealed sump cover or a 1" drainage hole is generally
insignificant, both in terms of maintaining pressure field extension and in terms of energy losses.
"Ironically, while there is no downside to the removing the requirement to seal sumps, there is a very
serious potential danger to EPA's current requirement to seal the sumps; namely the potential for flooding. Even
though the protocols require a trapped drain to provide drainage, malfunction ofthe drain could cause flooding,
and flooding creates the possibility of both property damage, and, in the worst case, electrocution."
26 Draft, 5/ 15/94
l9
19'

"

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I996 International Radon Symposium I11 - 8.5

"some confusion surrounds the origin of this draft. It was David Saum's understanding, as Chairmen of the Task
Group on Radon Mitigation, that Dave Murane had resigned as Chairman of the Task Group following the October
ballot because he was retiring and leaving EPAZ Accordingly, M. Messing and D. Saum revised this draft on the
basis of the comments received to the October ballot and restructured the section on mitigation along the lines of
EPA9sTechnical Guidance manual. The draft, dated 12/15/94 was then reviewed by D. Murane and D. Saum before
being submitted for balloting in January, 1995
The structure defined seven categories of active soil depressurization systems and addressed the requirements of
each of them specifically: Active Soil Depressurization, Sump Pump Depressurization, Drain Tile Depressurization,
Sub-Membrane Depressurization, Block Wall Depressurization, Crawl Space Depressurization, and Pressurization.
29 The distinction between "should" and "shall" may, in fact, be subordinate to the distinction in ASTM terminology
between standard practices and guides: "whereas a practice prescribes a general usage principle, a guide only
suggests an approach. The purpose of a guide is to offer guidance, based on a consensus of viewpoints, but not to
establish a fixed procedure. A guide is intended to increase the awareness of the user to available techniques in a
given subject area and to provide information from which subsequent evaluation and standardization can be
derived." Op Cit.
30 M. Messing, comments dated 4/14/95. Because of confusion regarding the Chairmanship of the Task Group
during this period, it is unclear which was the "official" draft at this time, or whether these comments were read in
response to the draft to which they responded.
" D. Murane, letter dated January 3 1,1996
ibid
EPA has, apparently, circulated a more recent draft to EPA reviewers. This issue, dated 8/9/96, was
not received in time for review in this paper.

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1996 International Radon Symposium I11 8.6