vvEPA
United States
Environmental Protection
Agency
Air And Radiation
(ANR-464)
22A-5000
January 1992
Strategy On Federal/State
Cooperation For
Radon Certification Program
Development
Printed on Recycled Paper
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STRATEGY ON FEDERAL/STATE COOPERATION FOR RADON
CERTIFICATION PROGRAM DEVELOPMENT
Prepared by:
John Hoornbeek
Jed Harrison
Stacy Greendlinger
Barbara Zakheim
U.S. Environmental Protection Agency
Office of Radiation Program
Washington, D.C. 20460
Endorsed by the Executive Board Conference of Radiation Control Program Directors
January, 1992
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ACKNOWLEDGEMENTS
EPA would like to acknowledge the valuable input and direction provided by State
Radon Officials through CRCPD's E-22 Committee on Radon Program Implementation,
and E-21 Radon Public Awareness Committee. In particular the Agency would like to
recognize the important contributions made by Marcie Matthews (E-22 Committee
Chairperson), Jeana Phelps (E-21 Committee Chairperson), and William Dornsife
(CRCPD Executive Board).
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TABLE OF CONTENTS
EXECUTIVE SUMMARY iv
I. INTRODUCTION
A. Background 1
B. Purpose and Structure 1
II. FEDERAL AND STATE ROLES
A. Types of Radon Service Evaluation Activities 3
B. Radon Industry Sectors 3
C. Summary of Federal and State Roles 4
III. FEDERAL RADON QUALITY ASSURANCE ACTIVITIES
A. Current EPA Programs 6
1. Radon Measurement Proficiency (RMP) Program 6
2. Radon Contractor Proficiency (RCP) Program 8
3. Regional Radon Training Centers (RRTCs) 9
B. How the Federal Role is Fulfilled 10
1. Device Manufacturers 10
2. Commercial Calibration Facilities 10
3. Measurement Laboratories 11
4. Measurement Operators 11
5. Mitigation Contractors 11
IV. STATE CERTIFICATION PROGRAM OPTIONS 12
A. Consumer Information Option 13
B. Mandatory Federal Program Option 13
C. Mandatory Federal Program — Plus 14
1. Measurement Laboratories 15
2. Radon Measurement Operators 16
3. Mitigation Contractors 17
D. Summary of State Options 19
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TABLE OF CONTENTS (CONTINUED)
V. STATE FUNDING OPTIONS AND RECIPROCITY
A. Funding Options 21
1. State Appropriations 21
2. Fees 21
3. EPA State Indoor Radon Grants (SIRG) 22
B. Reciprocity Among States 22
VI. RECOMMENDATIONS 24
Appendix A Summary of State Programs 25
Appendix B Description of Federal & State Roles 41
Appendix C List of State Contacts 48
List of Four Radon Regional Training Centers 52
List of Regional Offices 53
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EXECUTIVE SUMMARY
STRATEGY ON FEDERAIVSTATE COOPERATION FOR RADON CERTIFICATION
This strategy was developed with and for State radon program officials. It
provides a plan for coordinating Federal and State efforts to ensure that the public
receives quality radon services. The strategy specifies Federal and State roles in radon
quality assurance and makes recommendations for State radon programs. It also
furnishes information to assist State officials who are developing radon certification
programs.
The Federal government's major role in radon quality assurance is to set minimum
standards and requirements for radon professionals. The United States Environmental
Protection Agency (EPA) fulfills this role — in cooperation with States and the private
sector — through its Radon Measurement Proficiency (RMP) and Radon Contractor
Proficiency (RCP) Programs. The State role in radon quality assurance is to supplement
these standards and ensure that radon professionals adhere to applicable requirements
when providing services to consumers. To date, fifteen States require some form of
certification, registration, or licensing of radon professionals.
The U.S. EPA and the Conference of Radiation Control Program Directors
(CRCPD) make four major recommendations for State Radon Programs. These
recommendations are based on a desire to assure that consumers receive quality radon
services. They also seek to minimize burdens on radon service providers. The
recommendations are as follows.
First,- States should require that radon professionals in their State participate
successfully in EPA's RMP and RCP Programs. By mandating these Federal programs,
States insure that consumers receive services from capable radon professionals.
Second, States should implement monitoring and enforcement activities to ensure
that Federal and State standards actually lead to delivery of quality radon services.
These activities could include on-site office and laboratory audits, paperwork reviews,
and/or mitigation installation inspections.
Third, States should supplement EPA's quality assurance programs with any
additional requirements that are necessary to address unique environmental conditions or
construction practices in their State(s). These requirements might focus on State specific
concerns and state or local building codes.
And fourth, States should establish reciprocal agreements among themselves, using
the RMP and RCP Programs as a base. These agreements should aim to minimize
burdens on radon service providers without reducing the level of assurance consumers
have in State certified radon firms and operators.
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While the Strategy suggests that .States adopt the above recommendations, it also
recognizes the need for State flexibility in tailoring radon certification programs to meet
State specific needs and resource levels. Some States may not yet be ready to implement
aggressive radon quality assurance programs. The Strategy offers these States less
aggressive quality assurance approaches which can be used until such time as they are
ready to implement full scale certification programs. These less aggressive approaches
may include providing radon information to consumers, responding to consumer
complaints about radon service providers, and requiring RMP and RCP listing without
adopting full scale monitoring and enforcement programs.
EPA and State Radiation officials are working to assist consumers in obtaining
quality radon services. This strategy provides a solid framework for further coordinating
and accelerating these quality assurance efforts.
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I. INTRODUCTION
A. Background
Radon is a colorless, odorless gas formed by the decay of radium and uranium.
Based on current data, radon is the second leading cause of lung cancer in the United
States. The Environmental Protection Agency (EPA) established the Radon Action
Program (RAP) in 1985 to address this serious public health problem.
The RAP was designed to assess the magnitude of the radon problem, develop
strategies for reducing indoor radon levels, build State and private sector radon
assessment and reduction capabilities, and provide the public with information on the
health risks of radon. In 1986, the Congress passed the Superfund Amendments and
Reauthorization Act (SARA), provisions of which authorized the EPA to take the
leading role in the national effort to reduce indoor radon levels. The Indoor Radon
Abatement Act of 1988 (IRAA) authorized the EPA to assist State radon abatement
programs.
The IRAA and subsequent appropriations legislation directed the EPA to develop
voluntary proficiency programs to evaluate the effectiveness of radon devices,
organizations, and operators. The EPA developed two major proficiency programs to
implement this directive: the Radon Measurement Proficiency (RMP) Program and the
Radon Contractor Proficiency (RCP) Program. These program assist states and
consumers in identifying capable radon service providers. The Agency also established
four Regional Radon Training Centers (RRTCs). These Centers provide radon
measurement and mitigation training for individuals and organizations seeking to enter
the radon measurement and mitigation businesses. In addition they assist States by
tailoring training programs to meet specific state needs.
States play a critical role in evaluating radon service providers and ensuring that
consumers receive quality radon services. They provide consumers with information and
advice on selecting radon service providers, and respond to consumer complaints about
inadequate services or fraudulent business practices. Some States operate certification
programs and others are considering developing such programs.
B. Purpose and Structure
The purpose of the guidance is to assist States in developing radon certification
programs. This document provides guidance to States on possible elements of State
Radon Certification Programs. It builds upon existing EPA proficiency programs,
encourages consistency and reciprocity among State certification programs, and provides
a framework for strengthening the State/Federal system for ensuring that quality radon
services are provided to the public. This document offers States a variety of certification
program options, and provides specific recommendations on certification program
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elements. In so doing, it recognizes a need for State flexibility in determining optimal
radon consumer information and protection activities.
The guidance integrates current Federal and State radon quality assurance
activities with options for future State program activities. It consists of the following
sections:
o Federal and State Roles
Specifies Federal and State roles in ensuring quality radon services.
o Federal Radon Quality Assurance Activities
Description of Federal radon quality assurance activities and how they fulfill
Federal roles.
o Options for State Radon Certification Programs
Provides options for State radon certification program elements for
measurement laboratories, measurement operators, and mitigation contractors.
o State Funding and Reciprocity
Furnishes alternatives for funding of State programs and information on
reciprocity arrangements among States.
o EPA Recommendations
Offers recommendations on optimal State certification program elements.
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II. FEDERAL AND STATE ROLES
This section identifies Federal and State roles in radon quality assurance. The
first two sub-sections summarize possible types of radon service evaluation activities, and
the radon industry sectors which might be affected by them. The last subsection
summarizes Federal and State roles in terms of the type of evaluation activity
undertaken, and the industry sectors to which they apply.
A. Types of Radon Service Evaluation Activities
Federal and State governments (and potentially other organizations) undertake
different types of activities to ensure that consumers receive quality radon services. They
set standards or requirements for how radon services should be provided. They may also
monitor and enforce compliance with standards and requirements. Specific definitions of
these two types of activities are provided below:
Standards
Activities that set up standards for radon service providers to follow and/or
require or recommend radon service providers to carry out various operations, e.g.
register or list with Federal or State authorities, participate in training etc.
Monitoring
Activities that monitor and/or enforce compliance with standards or requirements.
B. Radon Industry Sectors
Radon service providers vary considerably in the types of services they provide to
consumers. Federal and State authorities may address these types of radon services
differently to ensure quality service is provided. This document divides radon service
providers into five categories, each of which provides services that affect the overall
quality of radon service provided to the public. These provider categories, the types of
services they provide, and how they impact the quality of services provided to consumers
are described below:
Measurement Device Manufacturers
Manufacture measurement devices in the marketplace e.g. charcoal canisters,
alpha-track devices, electret ion chambers, continuous radon monitors, and other
devices. The effectiveness of measurement devices produced by manufacturers
directly affects the accuracy of radon measurement results provided to consumers.
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Commercial Calibration Facilities
Calibrate measurement devices for other radon service providers. The quality of
calibrations conducted for radon service providers affects the accuracy of radon
measurement results provided to consumers.
Measurement Laboratories
Offer radon measurement analysis and other services for devices requiring a
laboratory (e.g. analyses of charcoal adsorption and alpha track devices). Radon
measurement results provided to consumers are only as accurate as the analyses
conducted by these laboratories.
Radon Measurement Operators
Operators of on-site reading devices (e.g. continuous radon monitors), operators
who place and retrieve measurement devices, or individuals who provide radon
consultation services. Consumers make decisions on the need for mitigation based
on the results and advice provided by radon measurement operators.
Mitigation contractors
Providers of radon mitigation services. Consumers depend upon mitigation
contractors to reduce elevated radon levels in their buildings.
C. Summary of Federal and State Roles
Table 2-1 outlines Federal and State roles in radon quality assurance according to
the type of evaluation activity conducted and radon industry sector. We do not suggest
specific ways in which Federal and State governments should fulfill their roles - this
decision is left to the governmental units involved. Designation of a role does not
necessarily mean that specific Federal or State programs are needed to address the
radon service sector in question. Wherever possible, Federal and State governments
should take advantage of market mechanisms, non-governmental talent, and private
sector initiatives to assist them in fulfilling their respective roles.
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Table 2-1: FEDERAL AND STATE ROLES
Service
Provider
Standards/*
Requirements
Monitoring/**
Enforcement
Device
Manufacturers
Calibration
Facilities
Measurement
Laboratories
Radon Measurement
Operators
Mitigation
Contractors
Federal
Federal
Federal/
State
Federal/
State
Federal/
State
Federal/
State
Federal/
State
Federal/
State
State
State
* Mixed (Federal/State) roles for standards activities suggest that the Federal government will set
minimum standards which may be supplemented by States.
** Mixed roles for monitoring activities suggest that it might be appropriate for both Federal and State
governments to monitor activities of these industry sectors.
In general, the Federal government's role in radon quality assurance is to set
minimum standards and requirements for radon professionals. The States should
supplement these standards, as appropriate, for radon measurement laboratories, radon
measurement operators, and mitigation contractors. They should also ensure that radon
professionals adhere to applicable requirements when providing services to consumers.
More detailed descriptions of these roles may be found in Appendix B.
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IH. FEDERAL RADON QUALITY ASSURANCE ACTIVITIES
The EPA currently operates three major programs which help to ensure the
availability of quality radon services. They are as follows:
o Radon Measurement Proficiency (RMP) Program
o Radon Contractor Proficiency (RCP) Program
o Regional Radon Training Centers (RRTCs).
This section summarizes these programs and describes how they fulfill the roles
defined in the previous section. These programs provide a base that States can use in
building their own radon measurement and mitigation certification programs. The
descriptions included are accurate as of January 1992. However, program requirements
and activities may change over time. Consequently, States should work with EPA
Regional Offices to ensure that they plan their activities based on current information.
A. Current EPA Programs
1. Radon Measurement Proficiency (RMP) Program
The primary goal of the RMP Program is to provide consumers with a way of
selecting radon measurement organizations that meet minimum indoor radon
measurement proficiency requirements. The program assists States by (1) helping them
disseminate information to the public on radon measurement service providers and (2)
providing a criterion for making certification decisions. Organizations and individuals
participate in the program on a voluntary basis, and may submit applications at any time.
The EPA believes that most radon measurement organizations participate in the RMP.
Participants in the program are classified according to the type(s) of measurement
services they provide. The RMP Program currently recognizes two general types of
radon measurement services:
Primary Radon Measurement Services
A participant that analyzes or reads radon measurement devices is defined as a
"primary" for that device. This category includes radon measurement laboratories
and those radon measurement operators that provide reading or analysis services.
Secondary Radon Measurement Services
A participant that offers a radon measurement service, but relies on another party
for the analysis of the device used, is defined as a "secondary" service operator.
This type of service may include consulting with the consumer, placing and
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retrieving measurement devices, and/or reporting measurement results. It does
not include simple retail sale of measurement devices.
Both categories of participants are required to comply with all applicable program
requirements. The requirements provide a minimum level of assurance that
organizations and individuals passing the RMP Program will provide accurate radon
and/or radon decay product measurements to consumers. Participants that violate
program requirements are subject to delisting. States may bring evidence of significant
non-compliance to the attention of EPA Regional authorities. The EPA is developing
procedures for delisting firms that fail to meet program requirements. Some of the
major requirements of the program are outlined below.
Quality Assurance Plan (QAP)
All participants are required to develop, operate by, and maintain a QAP for each
primary device or measurement method for which they are listed. QAPs
developed by participants address chain of custody and calibration procedures,
background radon checks, and spiked, blank, and replicate samples.
Radon Measurement Protocols
All participants must follow applicable EPA Radon Measurement Method
Protocols.
EPA Guidelines on Measurement Reporting
All participants must report radon measurement results to the consumer in a
consistent and timely manner.
Consumer Information
All primary and secondary participants must provide printed mitigation
information together with the measurement results they provide to the consumer.
Use of RMP Listed Services
All secondary participants must use a listed primary participant for the analysis of
the radon measurement device(s) they use.
Passing of a Radon Measurement Test
All primary participants must pass a radon measurement test to obtain and
maintain their listing. During a radon measurement test, participant measurement
devices are exposed to known radon concentrations in EPA radon chamber
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facilities. Radon measurement tests are conducted at the time participants enter
the program and periodically thereafter.
Individuals who provide on-site, residential radon measurement services must pass
a written examination to obtain individual RMP listing status. The EPA
developed the measurement examination in cooperation with state officials, expert
radon measurement contractors, and a professional examination development
firm. The examination sets a national baseline measure of proficiency by
evaluating contractor knowledge of radon and radon measurement methods in a
residential environment.
The National RMP Program Radon Measurement Proficiency Exam is comprised
of 150 multiple-choice questions covering six major areas of measurement
practice. It is offered at many locations around the country. Additionally, testers
are required to pass a re-examination every two years to maintain their individual
RMP program listing. This examination includes new industry practices and
technology, as well as review of radon measurement fundamentals.
Advertising of RMP Listing
Participants may only advertise their EPA listing using the phrase "Meets EPA
Requirements."
The EPA notifies participants if they have met program requirements. These
listed participants may use this notification to represent themselves to States and the
public. The EPA also publishes Proficiency Reports on a periodic basis. These reports
include current lists of successful RMP Program participants. States may verify a
participant's current status by contacting the RMP Program Information Service (RIS) at
(919) 541-7131. '
2. Radon Contractor Proficiency (RCP} Program
The EPA established the Radon Contractor Proficiency (RCP) Program to
evaluate and provide information on capable radon reduction contractors. The program
is directed toward individual radon mitigators who evaluate buildings with elevated radon
levels, do radon diagnostics, and develop radon mitigation plans. These individuals hold
the highest level of responsibility within their companies. The RCP Program includes
several requirements that facilitate the proficiency of radon mitigation contractors.
Examination
The National RCP Program Radon Mitigation Proficiency Exam is the primary
means by which EPA measures radon mitigation proficiency. Mitigators who
participate in the program must pass the examination to obtain an RCP Program
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listing. This exam was developed using the same process as that used for the
RMP Measurement Exam. The exam sets a national baseline measure of
knowledge for proficiency in radon mitigation practices. The mitigation exam has
a structure and length similar to that of the measurement exam, and both exams
are administered nationally and often at the same locations. Contractors are also
required to pass a re-examination every two years. This exam is on radon
reduction fundamentals and changes in mitigation practices and technology.
Training
The EPA requires hands-on radon mitigation training for all RCP listed
contractors. EPA-developed courses are offered at the Regional Radon Training
Centers and similar courses are offered by State and private organizations. The
EPA approves courses which provide this training. Participating radon mitigators
must take their training from EPA-approved training providers. Courses generally
cover health effects, building investigation, radon measurement and other
diagnostic procedures, mitigation system design, installation techniques, and system
evaluation.
Mitigation Standards and Protocols
RCP listed contractors must adhere to current EPA Radon Mitigation Standards
and Protocols in performing mitigation work.
Continuing Education
The EPA recommends that RCP listed contractors undergo continuing education
of not less than 8 hours a year in areas such as new mitigation technology, worker
health and safety, and HVAC and radon mitigation. This training will assist RCP
listed mitigators in preparing for their biennial reexamination.
The RCP Program Proficiency Report lists mitigators who have successfully
completed RCP program requirements. The report is updated periodically to reflect
additions and deletions from the program. Contractors may be delisted due to failure to
meet RCP program requirements. States may bring evidence of non-compliance with
program requirements to the attention of Regional authorities. The EPA has procedures
for delisting RCP listed radon mitigation contractors who violate program requirements.
3. Regional Radon Training Centers (RRTCs)
The 1988 Indoor Radon Abatement Act (IRAA) gave the EPA the authority to
establish Regional Radon Training Centers (RRTC). The purpose of these centers is to
provide information and training on radon to Federal and State officials, radon service
providers, school administrators, building and home inspectors, code officials, and others.
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Based on the results of competitive solicitations, the EPA awarded grants to four
institutions to host an RRTC:
o Western Regional Radon Training Center at Colorado State University.
o Midwest University Radon Consortium (MURC -- Universities of Minnesota
and Michigan and Kansas State University).
o Eastern Regional Radon Training Center at Rutgers University.
o Southern Regional Radon Training Center at Auburn University (also includes
Texas A & M, and the University of Tulsa).
The RRTCs provide up-to-date training in radon mitigation, measurement, and
radon resistant new construction. They may similarly provide specialized courses for real
estate agents, State and local officials, health professionals, and other audiences. In
addition, the RRTCs administer written examinations associated with the RCP and RMP
Programs. The Centers are available to provide specialized expertise in radon
measurement and mitigation and work closely with State officials to meet State radon
training needs. They are a valuable resource for States that are developing radon
certification programs.
B. How the Federal Role is Fulfilled
The previous subsection discussed the EPA's three major radon quality assurance
programs. This subsection defines how these programs and other Federal activities fulfill
the Federal roles defined in Section 2. The EPA evaluates and improves its radon
quality assurance activities on an ongoing basis.
1. Device Manufacturers
Federal authorities have published a set of environmental conditions that are
typical of real world exposures. The EPA conducts measurement tests in the RMP
Program under these conditions to help ensure that the devices can provide accurate
results in "real-world" conditions.
2. Commercial Calibration Facilities
The current RMP program requires calibration for primary laboratories and other
primary operators. The EPA allows for inter-comparison of commercial calibration
facilities to the EPA laboratories. The EPA collects information on the quality of
calibrations through the RMP Program. When issued, the RMP Program's QA/QC
Guidance will provide more specific information on calibration.
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3. Measurement Laboratories
The RMP program requires measurement tests for measurement laboratories and
other primary providers to determine their capability to make accurate radon
measurements. In the monitoring and enforcement area, the RMP Program carries out
blind tests and may conduct QA reviews to help assure compliance with RMP program
requirements. Efforts are being made to coordinate more closely with States on these
monitoring activities.
4. Measurement Operators
Operators of devices that have an analysis capability are evaluated through
performance tests similar to those required of measurement laboratories. The RMP
program requires all listed measurement operators to use EPA measurement protocols
and standard operating procedures. Measurement operators also have to pass a written
examination. Monitoring activities are limited to responding to complaints from States
about listed measurement operators.
5. Mitigation Contractors
The RCP program requires that mitigation contractors pass a written examination
to become RCP-listed and in addition requires participation in a hands-on training
program. Furthermore, contractors are required to adhere to EPA standards in their
mitigation work. Monitoring activities are currently limited to responding to complaints
from States about RCP listed contractors.
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IV. STATE CERTIFICATION PROGRAM OPTIONS
This section presents options for State radon quality assurance programs. These
options describe possible ways States may fulfill their roles in ensuring quality services
from measurement laboratories, measurement operators, and mitigation contractors. The
options presented are not all-inclusive. They are presented to provide State authorities
with a structure to help them determine optimal program elements for their State.
Wherever possible, States should take advantage of market mechanisms, non-
governmental talent and private sector initiatives to assist them in ensuring quality radon
services.
There is no universally preferable structure for State radon quality assurance
programs. States have many options. Their choices regarding radon certification
program elements may depend on the extent of their concern about the radon problem,
their resources, and their activities to date. This strategy addresses three basic options
available to State radon authorities that build upon EPA's existing programs. States
may administer these potential programs themselves or they may work with private sector
organization(s) to administer them. These programs suggest an increasingly more
comprehensive approach to radon service quality assurance and control.
Consumer Information Option
Improving the quality of radon service providers by offering advice and responding
to citizens' complaints about radon service providers.
Mandatory Federal Programs Option
Ensuring the quality of radon services by mandating adherence to Federal
programs (RMP/RCP listing), providing consumer information, and responding to
citizen complaints about radon service providers.
Mandatory Federal Programs -- Plus
Ensuring the quality of radon services by providing consumer information,
mandating adherence to Federal programs, and supplementing Federal programs
with additional State activities.
The following subsection describes these options in greater detail.
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A. Consumer Information Option
This option preserves the status quo for most States. States use EPA's RMP and
RCP Programs to advise consumers on capable radon measurement laboratories,
measurement operators, and mitigation contractors. In addition, they caution consumers
about the unknown accuracy of non-proficient radon measurement devices and the
unknown capabilities of non-proficient organizations. States use EPA public information
brochures, mitigation standards, measurement protocols, and technical guidance to
educate the public on how to obtain quality radon services.
States also play a critical role in addressing problems relating to the quality of
radon services that have already been provided. They may use EPA documents to help
consumers and service providers resolve questions and conflicts. States should conjointly
use their consumer protection authorities (Attorney General's office, consumer fraud
statutes, etc.) to assist consumers in obtaining corrective action in cases where the
services provided have not met applicable requirements.
Furthermore, States may initiate delisting actions against EPA listed service
providers that violate proficiency program requirements. States should contact their
Regional EPA office if they feel EPA delisting actions may be warranted. In addition,
States may bring cases to the attention of the EPA that prompt changes in the RMP or
RCP standards and requirements.
Advantages:
o Educates radon service consumers.
o Places a minimum burden on radon service providers.
Disadvantages:
o Minimizes State control.
o Provides least protection to consumers.
B. Mandatory Federal Program Option
This option includes the consumer information activities discussed above, but
further mandates that all radon service providers in the State meet the standards and
requirements of EPA's Proficiency Programs. States may mandate adherence to EPA
Proficiency Program standards and requirements by legislative enactment or, in some
cases, by use of existing statutory authorities.
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Advantages:
o Protects consumers by eliminating services of unproven providers.
o Offers the least costly mandatory option.
o Allows enforcement of program requirements.
Disadvantages:
o Relies solely on consumer complaints to ensure adherence to standards and
requirements. No monitoring activities.
o Minimizes State control.
C. Mandatory Federal Program - Plus
This option offers States a variety of different standards and monitoring activities
that build upon the Mandatory Program option described above. The options provided
may or may not be desirable for particular States. In implementing this option, State
authorities may also conduct standards and monitoring activities in other areas of
particular concern, such as mitigation activities affecting building codes particular to their
jurisdictions.
Advantages:
o Provides greatest assurance of quality radon services
o Allows States to implement activities as needed.
Disadvantages:
o Increases use of State resources.
o Increases burdens on radon service providers.
The following discussion provides specific activities that States may want to apply
to measurement laboratories, radon measurement operators, and mitigation contractors.
The options provided are not all inclusive and may or may not be desirable for particular
States.
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1. Measurement Laboratories
Standards Activities:
Registration/Listing
State authorities can require that primary laboratories obtain State registration
before commencing operation, Such registration allows States to be aware of
service providers in their States.
Educational Requirements/Measurement Experience
States may require that laboratory supervisors and/or personnel attain some
minimum level of education (e.g. undergraduate degree) or serve an
apprenticeship to gain measurement experience.
Monitoring Activities:
General Monitoring
State authorities may review phone books and other radon service advertising to
ensure that organizations and individuals providing services within their boundaries
are RMP listed and meet any applicable State registration requirements. States
may also check consumer complaints regarding service providers against current
RMP and State registration lists. This will ensure swift response to citizens'
complaints and expose non-certified operators.
Blind Testing
States may initiate and conduct their own blind tests of radon measurement
laboratories. EPA laboratories may assist States by providing device exposures to
the extent possible within the constraints of other workload demands.
Laboratories which perform poorly on blind tests may be de-certified by the State
or referred to the EPA for blind testing under the RMP Program.
Records Reviews
State authorities can require that measurement laboratories mail in calibration
reports showing how their equipment has been calibrated. They can additionally
request a copy of laboratories' QA/QC plans to ensure that such a plan exists and
that it meets both EPA and any State requirements. State authorities may be able
to review quality assurance plans on a more comprehensive basis than the EPA.
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On-Site Audits
State authorities may perform announced and unannounced audits of
measurement laboratories. States should provide State certified laboratories with
information on laboratory audit procedures to make them aware of what to expect
and to encourage compliance with applicable requirements. Audits may include
review of QA/QC programs, calibration records, control charts, measurement
result reports, laboratory staff, and other records.
2. Radon Measurement Operators
Standards Activities:
Registration/Listing
States can require that measurement operators obtain State registration before
commencing operation. Such registration or listing allows States to be aware of
service providers in their States.
Examinations
States can supplement the RMP examination for radon measurement operators
with their own examination questions. Such questions may cover specialty topics
that have particular application to the State. States may also wish to sponsor
future measurement operator examination offerings in their State in cooperation
with the EPA and the Regional Radon Training Centers.
Educational Requirements/Measurement Experience
States may require that measurement operators attain some minimum level of
education (e.g. undergraduate degree) or serve an apprenticeship to gain
measurement experience. Likewise, States may require operators to obtain
training in radon measurement. This training might include instruction on
operating specific radon measurement devices, environmental factors affecting
device selection, and/or procedures specific to operation in their State or region.
States may additionally want to evaluate and approve qualified training providers.
Record Keeping and Information Submittal
States may wish to institute specific record keeping requirements for measurement
operators. These requirements might include records relating to calibration,
quality assurance/quality control programs, measurements provided to consumers
and zip code information relating to those measurements. States may use these
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records to monitor compliance with program requirements and to conduct
analyses of trends in radon measurement work.
Monitoring Activities:
General Monitoring
State authorities may review phone books and other radon service advertising to
ensure that organizations and individuals providing services within their boundaries
are RMP listed and meet any applicable State registration requirements. States
may similarly check consumer complaints regarding service providers against
current RMP and State registration lists. This will ensure swift responses to
citizens' complaints and expose non-certified operators.
Records Reviews
State authorities may review calibration records, quality assurance/quality control
plans, standard operating procedures, measurement report results, and other
required records for compliance with State and EPA requirements. These reviews
may be conducted during office audits. Moreover, States may request that
measurement operators mail copies of these records for review on a periodic
basis.
Blind Reviews
States may evaluate the extent to which measurement operators place devices
according to EPA protocols and/or operate their devices properly. They may
conduct these reviews by posing as consumers who request the services of
measurement operators at specific buildings. They could then evaluate the
services they receive. States which conduct this activity need to develop and
publicize criteria for successful services well in advance of conducting these
evaluations. These criteria should be consistent with applicable EPA and State
requirements.
3. Mitigation Contractors
Standards Activities:
Registration/Listing
States can require that mitigation contractors obtain State registration before .
commencing operation. Such registration allows States to be aware of mitigators
in their States.
17
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Examinations
States can supplement the RCP examination with their own examination
questions. Such questions may cover specialty topics that have particular
application to their State. Furthermore, States may wish to sponsor RCP
examination offerings in their State in cooperation with the EPA and the Regional
Radon Training Centers.
Educational Requirements/Mitigation Experience
States may require that mitigation contractors attain some minimum level of
education or experience (e.g. undergraduate degree or building experience) or
serve an apprenticeship to gain mitigation experience. States may also require
mitigators to obtain specific training on the building stock and building codes in
their States. Additionally, States may want to evaluate and approve qualified
training providers.
Mitigation Protocols/Guidelines
States may supplement RCP guidelines and protocols with more specific or
stringent requirements that apply to their particular State.
QA Plan
States may require that mitigation contractors prepare and submit a QA Plan
prior to obtaining certification.
Building Codes
State and/or local authorities can amend existing building codes to ensure that new
construction practices deter the entry and concentration of radon gas. [Building
codes can also be amended to incorporate mitigation standards for existing
buildings.] These codes may be based on EPA standards or other State or local
standards adapted to local construction practices and/or geologic circumstances.
Record Keeping and Information Submittal
States may wish to institute specific record keeping requirements for mitigation
contractors. These record keeping requirements might include records of before
and after measurements, mitigation plans, diagnostic and mitigation techniques
used, zip codes, and other information relevant to the installation.
18
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Monitoring and Enforcement Programs:
General Monitoring
State authorities may review phone books and other radon service advertising to
ensure that organizations and individuals providing mitigation services within their
boundaries are RCP listed and meet any applicable State requirements. In
addition, States may check consumer complaints regarding service providers
against current RCP and State registration lists. This will ensure swift responses
to citizens' complaints and expose non-certified operators.
Records Reviews
State authorities may review records on mitigation contractors and installations,
and other required records for compliance with State and EPA requirements.
These reviews may be conducted during office audits. Similarly, they may request
that mitigation contractors mail copies of these records for review on a periodic
basis.
Installation Inspections
States may inspect mitigation installations to review mitigation practices and
conformance to mitigation protocols, guidelines and standards, building codes, and
other State requirements. In this way, they can expose poor mitigation practices,
decertify the offending parties, and, if necessary, advise the EPA of potential
delisting action.
D. Summary of State Options
These three optional program packages offer States a variety of possible State
certification program elements. Combined, they provide a flexible approach to managing
State radon quality assurance responsibilities and ensuring that there is a suitable
program for each State. The ultimate choice of option(s) obviously rests with the
individual State authorities. Tables 4-1 and 4-2 summarize activities that States could
undertake for measurement laboratories, measurement operators, and mitigation
contractors. As shown, not all activities apply to all categories of service providers, and
activities may vary as applied to different provider groups.
19
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Table 4-1: STATE STANDARDS ACTIVITIES
Program
Element
Radon
Measurement Measurement Mitigation
Laboratories Operators Contractors
Registration/
Listing
Educational/
Experience Requirements
X
X
X
X
X
X
Record Keeping
Examination
Protocols/
Guidelines
Building
Codes
X
X
X
X
X
X
X
Table 4-2: STATE MONITORING ACTIVITIES
Program
Element
Radon
Measurement Measurement Mitigation
Laboratories Operators Contractors
General
Monitoring
Record Keeping
Reviews
X
X
X
X
X
X
On-Site
Audits
Blind
Evaluntion(s)
Mitigation
Installation
Inspections
X
X
X
X
X
X
20
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V. STATE FUNDING OPTIONS AND RECIPROCITY
This section overviews options for funding State radon certification programs, and
discusses reciprocity among State certification programs.
A. Funding Options
There are three major options for funding State radon certification programs: (1)
State appropriations; (2) fees; (3) EPA State Indoor Radon Grants (SIRG). Each of
these options is briefly discussed below.
1. State Appropriations
States authorities can work with their State Legislatures to appropriate funds for
radon certification programs. State Legislatures may be more responsive to requests for
such appropriations if they are provided with evidence of radon quality assurance
problems, data on the extent of the State's radon problem, and information t>n other
funding sources such as fees and EPA SIRG Grants. Likewise, State Legislators may be
interested in radon certification program funding levels in comparable States. State
authorities maximize the effectiveness of their efforts by presenting their
recommendations to State Legislators clearly and concisely.
2. Fees
States may also fund their radon certification programs through fees levied on
radon service providers. States may levy fees on applications submitted by service
providers, or for achievement of licensing or certification status. In the latter case, the
fees would be levied against service providers that have met certification requirements.
In addition there are other options that States have proposed for generating
revenues for their programs. Among these are:
o A special home improvement contractors' fund, which is financed by the
registration of home improvement contractors. It could be used for program
administration and covering consumer costs in cases of bad mitigation (was
proposed in the State of Connecticut).
o
A surcharge on every new square foot of construction, irrespective of whether
it has radon resistant features, which may be used for program administration
or as a trust fund for correcting improperly installed radon mitigation systems
(was proposed in the State of Rhode Island).
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3. EPA State Indoor Radon Grants (SIRG)
Section 306 of the Indoor Radon Abatement Act (IRAA) authorizes the EPA to
provide States with grant funds to assist them in developing and implementing programs
for the "assessment and mitigation of radon." Most States currently receive SIRG
funding. This program is now in its third year of operation. Detailed information on
the SIRG Program can be found in EPA's Third Year Guidance for the State Indoor
Radon Grants Program. EPA Office of Radiation Programs, October 1991, and is
available through EPA's Regional Offices.
B. Reciprocity Among States
Reciprocity agreements among States are desirable in cases where radon
organizations and/or individuals provide identical or very similar services in different
States. States may enter into different kinds of reciprocal arrangements with one
another. The agreements can recognize and accept other States' complete certification
programs, or they can accept only particular features of another State's program
(training, passage of an exam, etc.).
Reciprocity arrangements minimize economic burdens on radon service providers
who have to comply with differing State certification requirements and fees. Additionally,
they may reduce the costs of radon services because service providers pass the costs of
complying with State requirements on to their customers. Reciprocity arrangements may
also reduce the operating costs of State certification programs by minimizing the number
of organizations and individuals who have to be processed and tracked through the
programs' different steps and requirements.
There are currently no specific reciprocity agreements among States in existence.
State requirements vary among the States that have some form of certification, licensing,
or registration program. While these differences in program requirements may be
appropriate, they present obstacles to development of reciprocity agreements among
States.
There are steps States can take to overcome these obstacles to reciprocity. These
steps are easier to implement for States whose programs are still developing, but they
can be implemented in States whose programs are in place. They are summarized
below.
o Legislative Authority
Reciprocity can only be achieved if States have the legislative authority to do
so. Many States are currently unable to consider reciprocal agreements with
other States due to the lack of authority. Legislative authority for reciprocity
agreements may be a useful addition to certification statutes.
22
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o Minimum Requirements
States that adopt uniform minimum requirements for radon service providers
make reciprocal arrangements easier to implement. In these cases, out-of-
State radon service providers can be granted complete or partial certification
status based on meeting or surpassing minimum standards. States can require
RMP and/or RCP listing for service providers. This requirement provides a
minimum standard which can serve as a basis for reciprocity agreements.
o Flexibility
The more flexible the features of a radon certification program, the more
likely the program will be suitable for reciprocal arrangements with other
States. For example, if only one option for educational background is
stipulated by a program, it becomes less likely that providers certified in other
States will be able to meet the requirement. However, if a number of options
for educational background are stipulated, then there is a better chance that
providers certified in other States may meet the requirement. Of course,
flexibility should not be built into program requirements in a way that
compromises the assurance of quality services provided to consumers.
States entering into reciprocity agreements may adopt equivalent certification
requirements (perhaps based on the RMP and RCP Programs), and make office audits,
laboratory inspections, and/or records reviews the responsibility of the "primary" State in
which the service provider has its office. Loss of certification in the "primary" State
would result in such loss in the reciprocal State. States that have entered into reciprocity
agreements have the option of charging higher fees in the "primary" State to account for
the increased costs associated with that service provider's certification.
This type of approach will minimize costs and may allow States to reduce any fees
charged to outside firms. Of course, it still may be desirable for States to inspect
mitigation installations and/or radon measurement services that are provided within their
State by outside service providers. This type of service could still require the imposition
of fees.
23
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VI. RECOMMENDATIONS
Four recommendations can be made based on the goal of ensuring that consumers
receive quality radon services. These recommendations also recognize State sovereignty
in implementing radon certification programs and industry concerns about conflicting
State program requirements.
o States should mandate the RMP/RCP programs: By mandating the Federal
RMP/RCP programs. States ensure that their consumers receive service only
from EPA-listed operators and thus provide a minimum level of quality
assurance within their States. In addition, State required RMP/RCP listing
provides a base of common requirements which can be used in developing
State reciprocity agreements.
o States should supplement these mandatory programs with active monitoring
and enforcement programs. Monitoring and enforcement programs ensure
that Federal and State standards actually lead to the delivery of quality radon
services.
o States should supplement the mandatory RMP and RCP programs with any
additional standards and requirements that are necessary to ensure quality
radon services in their particular State.
o States should establish reciprocal agreements among themselves, using the
RCP and RMP programs as a base. These agreements should minimize
burdens of conflicting requirements on radon service providers to the extent
possible without reducing the level of assurance consumers can have in State
certified radon firms and operators.
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APPENDIX A
SUMMARY OF STATE PROGRAMS
The following information relates to State programs and regulations that were in
place as of December, 1991. Twelve States have some form of regulations relating to
radon measurement and mitigation service operators, either fully promulgated or in the
draft or interim stage. Two States, Maryland and Virginia, require that organizations
only meet Federal proficiency requirements. Kentucky has a voluntary registration
program dependent upon Federal proficiency requirements. There is a notation for
States where the regulations are not final.
CALIFORNIA
Certification, Registration or Licensing
Radon measurement laboratories, radon testing & consulting specialists, and
radon mitigation contractors are required to be certified by the State.
Certifications are renewable biennially.
Federal and/or State Measurement Proficiency Requirement
Certification is dependent upon RMP-listed status.
Federal and/or State Mitigation Proficiency Requirement
Certification is dependent upon RCP-listed status.
QA Plan
QA plans in accordance with the RMP Program are required.
Education and/or Experience
Radon testing & consulting specialists are required to have a college degree with a
major in physical, biological or engineering science.
Training and/or Examination Requirement
Radon testing & consulting specialists are required to have 16 hours of classroom
training.
Audits (Office and/or Site)
None are required.
User Fees
Fees are $300 for radon measurement laboratories, $200 for mitigation
contractors, and $100 for testing & consulting specialists.
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CONNECTICUT
Certification. Registration or Licensing
Measurement laboratories, diagnostic specialists, and mitigation contractors are
required to be registered with the State.
Federal and/or State Measurement Proficiency Requirement
Registration is dependent upon RMP-listed status.
Federal and/or State Mitigation Proficiency Requirement
Registration is dependent upon RCP-listed status.
OA Plan
The regulations refer to the RCP guidelines for quality assurance of mitigation
contractors.
Education and/or Experience
There are no requirements except for the training qualifications outlined below.
Training and/or Examination Requirement
Diagnostic specialists must complete an RMP related training program and
mitigation contractors must have a minimum of a 2-3 day approved training
program.
Audits (Office and/or Site)
The Department of Consumer Protection can investigate measurement operators.
The Department of Health Services investigates mitigation contractors.
User Fees
There are no fees for the registration program. However, mitigation contractors
are charged by another State agency for doing business in the State.
DELAWARE
Certification. Registration or Licensing
Radon measurement and mitigation firms are required to register with the State.
Registration must be renewed on an annual basis.
Federal and/or State Measurement Proficiency Requirement
Registration is dependent upon RMP-listed status and/or source of testing devices.
Federal and/or State Mitigation Proficiency Requirement
Registration is dependent upon RCP-listed status.
26
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QA Plan
There are QA guidelines for radon measurement and mitigation firms.
Education and/or Experience
Prerequisites are dependent upon sampling procedures and QA plan.
Training and/or Examination Requirement
Training prerequisites are dependent upon sampling procedures and QA plan.
Audits (Office and/or Site)
The State performs site audits on mitigation companies. The State reserves the
right to perform office and/or site audits on all measurement and mitigation
companies operating within the State of Delaware.
User Fees
At present there are no user fees.
FLORIDA
Certification, Registration or Licensing
The State requires the separate certification of businesses and individuals involved
in radon measurement and mitigation services.
Federal and/or State Measurement Proficiency Requirement
The State requires RMP-listing and the use of RMP-listed devices.
Federal and/or State Mitigation Proficiency Requirement
Participation in the RCP program is currently voluntary.
QA Plan
The State requires submission of a QA plan, which is approved on an individual
basis. The State will accept the RMP QA plan. For passive devices, the State
requires QA blanks and duplicates. Monitoring and enforcement programs
include State review of QA plans and annual on-site QA audits. On-site
inspections apply only to firms located within the State.
Education and/or Experience
Measurement specialists require 4 years of radiological experience of which 3
years may be substituted by relevant college education. Measurement technicians
require no previous experience or education. Mitigation specialists require 4 years
experience in the construction industry of which 3 years may be substituted by
relevant college education. A State contractor's license also meets this
requirement. Mitigation technicians require 2 years of construction experience.
27
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FLORIDA (Cont)
Training and/or Examination Requirement
Florida has training requirements which exceed those of the RMP/RCP programs.
Training is provided by approved RMP/RCP vendors. The State administers its
certification training examination a minimum of 3 times per year to qualified
applicants.
Audits (Office and/or Site)
Measurement and mitigation businesses are inspected annually for proper
maintenance of required records and adherence to measurement and mitigation
rules and guidelines.
User Fees
A $200 certification fee for both businesses and individuals covers application,
examination and a one-year certification.
ILLINOIS
Certification, Registration or Licensing
Registration is required only for radon measurement deployment consultants.
Measurement laboratories are exempt from registration, unless they also deploy
devices directly into homes.
Federal and/or State Measurement Proficiency Requirement
None
Federal and/or State Mitigation Proficiency Requirement
None
OA Plan
There are no requirements.
Education and/or Experience
Deployment consultants must have either a bachelor's degree in science or an
associates degree with 2 years related experience, or 4 years related experience.
An approved radon measurement course can also be accepted as a qualification.
RCP is an accepted form of education/experience. RMP is an accepted form of
education/experience only for secondary organizations.
Training and/or Examination Requirement
There is a minimum training requirement, which is met if an individual is RMP
listed. There is no examination requirement.
28
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ILLINOIS (Cont.)
Audits (Office and/or Site)
The State has the authority to perform audits.
User Fees
$100 per individual and $125 for firms.
INDIANA (Final rule expected March 1992)
Certification, Registration or Licensing
Certification is required for primary and secondary testers, measurement
laboratories, and mitigation contractors.
Federal and/or State Measurement Proficiency Requirement
Certification is dependent on RMP listing or equivalent proficiency program and
submission of a sworn affidavit that the individual has read and agrees to the
EPA's "Indoor Radon and Radon Decay Product Measurement Protocols".
Federal and/or State Mitigation Proficiency Requirement
Certification is dependent on RCP listing or equivalent proficiency program.
OA Plan
There is no State requirement for a QA Plan.
Education and/or Experience
There is no level of formal education that secondary testers, primary testers, or
mitigators must achieve. However, at least one individual employed by a radon
laboratory must have either a Bachelor's degree from an accredited university or
college in the physical sciences or engineering or in a related field approved by
the commissioner, or a minimum of two years full-time experience, or equivalent,
as determined by the commissioner, in radiation measurement.
Continuing education involves all categories of certification and must be from a
course approved by the commissioner and must be at least six contact hours.
Written confirmation of attendance, signed by the course instructor, or its
designee, must be submitted at the time of application for recertification.
However, full-time employment by the certified individual for the prior two years
may substitute for the continuing education requirement provided written
confirmation of full-time employment, signed by the business owner or chief
executive officer of the business which employed the certified individual, has been
submitted along with the application for recertification.
29
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INDIANA (Cont.)
Training and/or Examination Requirement
There are no State-administered examinations or State-administered training
programs.
Audits (Office and/or Site)
The commissioner, his or her agents, and his or her employees have the right to
enter at all reasonable times in or upon any public or private property upon
presentation of appropriate credentials, to inspect any equipment or records
pertaining to radon-222 testing, mitigation or analysis, to conduct radon-222
testing, to inspect radon-222 testing laboratories, or to inspect radon-222
mitigation facilities or equipment that has been, or is to be, installed.
User Fees
Fees are levied for two years at the following rates: secondary tester $150,
primary tester $300, radon laboratory $300, and mitigators $250.
IOWA
Certification. Registration or Licensing
Iowa has an extensive certification program for both measurement laboratories
and measurement specialists. It also has an extensive accreditation program for
mitigation contractors.
Federal and/or State Measurement Proficiency Requirement
Measurement laboratories must be RMP listed.
Federal and/or State Mitigation Proficiency Requirement
Mitigation contractors must be RCP listed.
OA Plan
Iowa requires QA plans for all radon service operators, which are based on the
EPA guidance.
Education and/or Experience
Measurement and Mitigation specialists are required to be at least 18 years old
and have three years of relevant experience; college courses in areas such as
energy, natural sciences or engineering (can be substituted for experience in both
certifications). However, one year of relevant practical experience is required to
be certified as a mitigation specialist.
30
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IOWA (Cont.)
Training and/or Examination Requirement
Measurement specialists must successfully complete a state approved training
course and examination or be certified by another state with the same
requirements. Mitigation specialists must pass the RCP examination.
Audits (Office and/or Site^
Iowa performs on-site audits on measurement laboratories, measurement
operators, and mitigation contractors. Although there is no regulated frequency of
audits, the goal is to audit once a year.
User Fees
Iowa imposes fees for both certification applicants and for annual State
accreditation. Application fees for both measurement and mitigation service
operators are $25.00 for residents and $100.00 for non-residents. Annual
certification fees are $250 for measurement specialists, and $500 for measurement
laboratories. Mitigation contractors must pay an initial annual fee of $150 and
$40 per installation, for installations over $200 in value, thereafter.
KENTUCKY
Certification. Registration or Licensing
The State manages a voluntary registration program for measurement and
mitigation companies. Amendments to the State radiation control act to institute
a mandatory certification program for laboratories, testers, and mitigators have
been submitted to the Kentucky legislature for consideration in the 1992 session
Federal and/or State Measurement Proficiency Requirement
Registration is dependent upon RMP-listed status.
Federal and/or State Mitigation Proficiency Requirement
Registration is dependent upon RCP-listed status.
31
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MAINE (Final rule expected mid-1992)
Certification. Registration or Licensing
The State requires registration of all testing, measurement and mitigation
companies doing business in the State, including those based outside the State.
Federal and/or State Measurement Proficiency Requirement
Registration is dependent upon RMP-listed status.
Federal and/or State Mitigation Proficiency Requirement
Registration is dependent upon RCP-listed status.
OA Plan
There will be a requirement for a QA plan. This is currently in draft stage.
Education and/or Experience
Although there are no educational prerequisites besides those necessary for the
RMP/RCP listing, there is a requirement for continuing education.
Training and/or Examination Requirement
The State requires RMP/RCP training or the equivalent for initial registration, as
well as continuing education.
Audits (Office and/or Site)
The State has the right to perform audits.
User Fees
The registration fee has not yet been determined.
MARYLAND
Federal and/or State Measurement Proficiency Requirement
All operators performing radon measurement testing must be RMP-listed.
NEBRASKA (Additional rules instituting licensing are being formulated)
Certification. Registration or Licensing
The State manages a registration program for measurement and mitigation
companies.
Federal and/or State Measurement Proficiency Requirement
Registration is dependent upon RMP listing.
32
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NEBRASKA (Cont.)
Federal and/or State Mitigation Proficiency Requirement
None
QA Plan
There is no QA requirement.
Education and/or Experience
Registered measurement and mitigation companies must have on staff an
individual with a minimum of: a Bachelor's degree in nuclear science, health
physics, environmental health, physical sciences, biological sciences, or a related
discipline; one year's experience in radiation related matters and radioactivity
measurement; and completed training in an agency approved course on
radon/radon decay product measurements and/or radon remedial services.
Technicians placing radon measurement devices must have as a minimum course
work in physics, mathematics, chemistry, health physics equivalent to a 40 hour
basic radiological health training program and have completed training in an
agency approved course.
Training and/or Examination Requirement
At least a one-week course in radon measurement and/or mitigation is required.
The RRTC course is approved.
Audits (Office and/or Site)
None
User Fees
There are no fees currently, although some may be instituted in 1992.
NEW JERSEY
Certification, Registration or Licensing
State certification is required for all radon measurement and mitigation businesses
and their employees involved in testing and/or mitigation activities, and radon
laboratories.
Federal and/or State Measurement Proficiency Requirement
Radon measurement businesses and laboratories must provide proof of successful
completion of the EPA RMP or an authorized State RMPP.
33
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NEW JERSEY (Cont.)
Federal and/or State Mitigation Proficiency Requirement
New Jersey regulations established two classifications of mitigation personnel: a
radon mitigation specialist and radon mitigation technician. Both must pass New
Jersey radon certification examinations. The EPA RCP program is not required
and does not substitute for the New Jersey examination.
OA Plan
QA plans are required for all radon service operators in accordance with EPA
and State guidelines.
Education and/or Experience
Radon Measurement Specialist: A Bachelor's degree in a natural science, one year
radiation work experience, 6 months radon measurement experience. A certified
Health Physicist meets the degree and radiation work experience requirement.
Radon Measurement Technician: 6 months radon measurement work experience.
Radon Mitigation Specialist: Any combination of 5 years of college education
(curriculum in architecture, engineering, or HVAC studies) or work experience
(the design, construction, and renovation of buildings, and associated HVAC
systems, or design and installation of radon mitigation systems).
Radon Mitigation Technician: Two years experience in the building or
construction trades, including the HVAC trade.
Training and/or Examination Requirement
Radon Measurement Specialist: Complete a Department-approved course
consisting of at least 24 hours.
Radon Measurement Technician: Complete a Department-approved course
consisting of at least 16 hours.
Radon Mitigation Specialist: Complete a Department-approved course consisting
of at least 24 hours.
Training and/or Examination Requirement (Cont.)
Radon Mitigation Technician: Complete a Department-approved course consisting
of at least 16 hours.
Audits (Office and/or Site)
On-site audits are to be performed on a rotating basis every one to two years at
the radon measurement or mitigation location. In addition, there is inspection of
radon mitigation systems. On-site audits of radon laboratories are required for
laboratory certification.
34
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NEW JERSEY (Cont.)
User Fees
Besides application, examination, and annual certification fees, New Jersey has a
unique system of fees based on a sliding scale for the number of measurement
devices placed or the number of mitigations performed over a six-month period.
The following Tables A, B, and C provide details of these fees.
35
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OHIO (Licensing Program to be enacted January 1992)
Certification, Registration or Licensing
The State requires licenses for all radon testers, radon mitigation contractors, and
radon mitigation specialists. The State has the ability to approve laboratories and
training. Licenses are for two-year periods.
Federal and/or State Measurement Proficiency Requirement
The licensing program requires RMP-listing.
Federal and/or State Mitigation Proficiency Requirement
The licensing program requires RCP-listing.
QA Plan
A QA plan must be submitted with the provider's application for licensing or
certification.
Education and/or Experience
The State has a continuing education requirement.
Training and/or Examination Requirement
Testers, mitigation contractors, and mitigation specialists must complete an
approved training course and pass examination.
Audits (Office and/or Site)
The State may examine the records of measurement and mitigation operators to
determine compliance with State requirements.
User Fees
Fees are $800 for mitigation contractors and $600 for mitigation specialists.
PENNSYLVANIA
Certification, Registration or Licensing
A full certification program is in effect for all radon measurement and mitigation
operators and firms. All radon measurement firms, laboratories, and radon
mitigation firms must have at least one certified individual to obtain certification.
Federal and/or State Measurement Proficiency Requirement
Measurement laboratories and measurement operators must be RMP-listed.
Federal and/or State Mitigation Proficiency Requirement
There is a State measurement proficiency requirement.
39
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PENNSYLVANIA (Cont.)
OA Plan
Measurement operators and laboratories are required to have a QA program.
Measurement and mitigation personnel are also required to follow EPA protocols
and guidelines in carrying out their respective activities.
Education and/or Experience
In addition to training and examination (see below), one year of professional
experience in their respective areas is required of all operators. For radon
mitigators this experience can be substituted for. three years of experience in
related professions, such as architecture, engineering or plumbing. Laboratory
staff can substitute this experience with a Health Physics certification, but must
also have a degree (or experience equivalent to a degree) in physical science or
engineering.
Training and/or Examination Requirement
Measurement laboratory staff, measurement operators and mitigation contractors
are required to take a State-approved course in order to become certified.
Measurement operators and mitigation contractors must also pass a State-
approved examination. State approval is given to the RCP examination, and the
examinations set by the States of Florida and New Jersey.
Audits (Office and/or Site)
The State may audit all certified individuals and firms to enforce compliance with
State requirements.
User Fees
All applicants whether measurement operators, laboratories, or mitigators must
pay an application fee for certification. This is set at $200 for individual testers
and mitigators, $250 for laboratory staff, and $500 for all firms.
VIRGINIA
Federal and/or State Measurement Proficiency Requirement
All firms must be RMP-listed.
Federal and/or State Mitigation Proficiency Requirement
All firms must be RCP-listed.
40
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APPENDIX B
FEDERAL AND STATE ROLES
A. Principles for Determining Federal/State Roles
The appropriate roles for Federal or State governments in ensuring quality radon
services can be determined by four principles. These principles recognize the need to
maintain currently effective program activities. They also direct future activities toward
ensuring that radon quality assurance activities use resources cost effectively, treat radon
service providers consistently and responsively, and set standards and requirements that
ensure quality delivery of different kinds of radon services.
All four principles apply to each of the five sectors of the radon industry
(measurement device manufacturers, commercial calibration facilities, measurement
d1fferen0tnerinci les ^UT&mGnt °Perators> a*d ^don mitigation contractors). However,
monitoring and enforcing existing requirements. DescriptionsTn7aP^ Or
principles to standards and monitoring activities are presented below.
Preservation of Effective Programs
Current radon quality assurance programs provide valuable information and
protection to consumers. This information and protection should not be
eliminated as a result of this guidance. EPA recommendations on Federal and
nmL^T ™k t0.presTerver^^e Federal and State radon quality assurance
programs. The principle of preserving effective programs applies to both
standards and monitoring activities.
Effective radon quality assurance programs ensure provision of quality radon
services without unnecessarily burdening radon service providers. This document
n™!*0* att!?P! ^ detf™e the effectiveness of existing radon quality assurance
programs - this task is left to the governmental units involved. Federal and State
governments should evaluate the effectiveness of their programs on a continuing
basis to assure provision of quality radon services and eliminate unnecessary
burdens on radon service providers.
Ease and Cost of Implementation
This principle encourages efficient use of Federal and State resources for ensuring
quality radon services. Quality assurance activities should be conducted at the
level o± government where they are easiest and least costly to implement For
example, economies of scale (efficiency resulting from the implementation of
41
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activities over a wide area) or extensive technical capability implies a Federal role
in areas that are not variable from State to State or region to region. For
example, tests that cover material or procedures that are applicable on a
nationwide basis may be less expensive to develop at the ^°™l™\,^fc
monitoring and enforcement may be performed less expensive^ at the State evel
due to close proximity to particular service providers. This principle applies to
both standards and monitoring activities.
Geographic- Scope of the Radon Service Provider
This principle is important for ensuring consistency and responsiveness in the
treatment of radon service providers. A very wide scope of provider operation
suggests a Federal role to ensure consistency and minimize burdens on service
providers. A narrow scope of service provider operation suggests a strong State
role States can combine consistent treatment of local service providers with
responsiveness to the concerns of both providers and local consumers. This
principle applies to both standards and monitoring activities.
Geographic Variability of the Radnn Service Provided
This principle ensures that consumer information and protection activities are
effective in assuring the quality provision of different kinds of radon services.
Radon services that are similar nationwide suggest a strong Federal role, while
variability in the nature of a particular type of service nationwide implies a
stronger State role. This variability may apply to either a particular type of
service or to the appropriate steps taken to provide that service. For example,
radon mitigation services are provided nationwide, but appropriate mitigation
techniques and procedures might vary geographically. Consequently, a Federal
role in radon mitigation may be appropriate, along with a State role relating to
the techniques and procedures that are specific to that State or region.
This principle is important for standards activities, since the effectiveness of
particular standards depend on the nature of the service being provided. This
principle is not as important for monitoring activities because the appropriate
level of government to conduct monitoring and enforcement does not necessarily
depend on the nature of the standard or the governmental unit that set it For
example, it is relatively easy for States to monitor and enforce similar standards
and requirements; it is difficult for Federal authorities to monitor and enforce
varying standards and requirements in fifty States.
42
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B. Analysis and Determination of Federal and State Roles
We can determine recommended roles for Federal and State governments by
applying the principles outlined above to the five sectors of the radon service industry
and different types of radon quality assurance activities. In some cases, all appropriate
principles suggest a clear role for Federal or State governments. In other cases, the
principles suggest a mix of Federal and State roles. The nature of this mixed role
depends on the radon service sector, the type of radon quality assurance activity being
conducted, and the principles involved.
The following analysis applies the appropriate principles to each of the five
categories of providers for both standards and monitoring activities. The first table
applies the principles to standards activities directed toward the five radon service
sectors. The second table applies appropriate principles to monitoring activities for the
five radon service sectors.
STANDARDS ACTIVITIES
PRINCIPLE
Preserving
Effective
Programs
Device
Manufacturers
Federal
Calibration
Facilities
Federal
Measurement
Laboratories
Federal/State
Radon
Measurement
Operators
Federal/State
Mitigation
Contractors
Federal/State
Ease of Program Federal
Implementation
Geographic Federal
Scope of Provider
Similarity/
Variability of
Service Provided
Federal
Federal
Federal
Federal
Federal/State Federal/State Federal/State
Federal
Federal
State
State
Federal/State Federal/State
43
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MONITORING ACTIVITIES
Device Calibration
PRINCIPLE Mannfactureis Facilities
Preserving Federal Federal
Effective
Programs
Measurement
Laboratories
Federal/State
Radon
Measurement
Operators
State
Mitigation
Contractors
State
Ease of Program Federal/State
Implementation
Geographic Federal
Scope of Provider
Similarity/
Variability of
Service Provided
Federal/State
Federal/State
Federal
Federal/State
FederaVState State
Federal/State State
Federal/State State
State
State
State
1. Device Manufacturers
The principles suggest a dominant Federal role relating to standards for the
manufacture of radon measurement devices. Manufacturers of radon measurement
devices generally sell them nationwide and the devices operate similarly throughout the
country. In addition, the EPA's RMP Program is the major existing program that
currently sets standards for or monitors the effectiveness of radon measurement devices.
If a program specifically directed toward device manufacturers were to be developed, it
would require extensive technical capability and would benefit from economies of scale.
To the extent that device manufacturers should be monitored to enforce national
standards, these activities could be carried out at either the Federal or State level.
2. Calibration Facilities
Applicable principles suggest a dominant Federal role for standards activities relating
to radon calibration facilities. Commercial calibration facilities provide similar services
on a nationwide basis. The EPA's Guidance on Quality Assurance will establish basic
procedures for calibration. Inter-facility comparison programs for commercial calibration
facilities, which assist in ensuring equivalent calibrations from different facilities also
require extensive technical capability and large capital investments to finance radon
chamber facilities. Both Federal and State authorities may have a role in monitoring
commercial calibration facilities for compliance with national standards.
44
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3. Measurement Laboratories
The principles suggest a mixed role for Federal and State governments in assuring
quality radon measurement laboratory services. An analysis of these mixed roles for
standards and monitoring activities is provided below.
Standards and Requirements
The geographic scope of the provider and geographic variability of the service
provided principles suggest a clear role for Federal authorities in setting standards for
radon measurement laboratories. Radon measurement laboratories generally provide
similar services to customers all around the country. By contrast, the principles of
preserving effective programs and ease of implementation suggest a mixed role Both
federal and State governments currently set standards for radon measurement
laboratories and both of them can set these standards with similar ease and efficiency
Future standard development for measurement laboratories should be focused at the
Federal level. If a State has more stringent requirements than those of the Federal
government or other States, laboratories may choose to operate in those States with
less stringent requirements. Therefore, States should limit their standard setting for
measurement laboratories to those areas where they feel it is absolutely necessary to
ensure provision of quality measurement services in their State.
Monitoring and Enforcement
The principle of geographic scope of provider suggests a clear role for Federal
authorities However, the principles relating to preservation of effective programs and
ease of implementation suggest a mixed role.
Both Federal and State governments conduct activities to monitor radon measurement
laboratories, and both of them can implement these monitoring activities relatively
easily and cost effectively. They can both conduct blind tests of radon measurement
laboratories and audits of their facilities. States may be able to conduct the audit
function more easily and inexpensively because they are generally in reasonably close
geographic proximity to the facilities in their State. The EPA and States need to work
together closely to ensure maximum effectiveness of radon measurement laboratory
monitoring: activities. States engaging in monitoring measurement laboratories should
work with their EPA Regional Office to coordinate their monitoring activities with
Federal monitoring activities.
There is a strong role for Federal authorities in ensuring the quality of radon
measurement laboratory services. However, States may want to supplement this role
with their own standard setting and monitoring activities. Additional State standards
could improve the quality of services provided, but at increased costs to radon
measurement laboratories which would have to adhere to differing standards throughout
45
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the country. These increased costs may be passed on to consumers. Additional State
mon'Sand enforcement of Federal standards could improve the quality of services
prodded but without substantial additional costs to competent measurement laboratories
and consumers.
4. Radon Measurement Operators
The principles suggest a mixed role in establishing standards for radon measurement
operators and a dominant State role in monitoring and enforcing standards and
requirements for these service providers. An analysis of these respective roles for
standards and monitoring activities is provided below.
Standards and Requirements
One principle applicable to standards activities suggests a dominant State role, while
teeTch principles suggest a mixed role. Radon measurement operators generally
operate on a State or regional level, thus suggesting a State role. However, the
sendees provided are generally similar, except for slight variations in placement and
uSr0f dSs due to geographic variability in environmental conditions and types of
buildings Furthermore, both Federal and State governments currently operate
programs aimed at radon measurement operators, and these programs can be
operated cost effectively at either the Federal or State level. Federal authorities may
be able to provide technical resources and capital investments necessary to develop
exams and other standards. However, States may be able to provide additional
Sards that better address locally prevalent measurement conditions and practices.
Monitoring and Enforcement
The principles suggest a clear State role in monitoring radon measurement operators.
Measurement operators generally conduct business on a State or regional ^1 and
States currently operate the monitoring programs for measurement operators. States
can monitor measurement operators cost effectively as compared to the Federal
government.
A Federal role is evident for activities relevant to radon measurement operators, but
primarily in setting standards and/or requirements. Future Federal standards for
measurement operators should focus on areas where services are similar and/or where
SSSScbScal capability or large capital investments - required S^au—
have a role in supplementing Federal standards as necessary to address specific variation
in service delivery which are prevalent in their State or region (eg. peculiar
Incremental and geologic conditions and/or building stock). There is a dominant role
Tstatrrn monitoring and enforcing compliance with standards and requirements for
adon measurement operators. The Federal role in monitoring and enforcement shoud
focus on responding to State complaints relating to EPA listed measurement operators.
46
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5. Mitigation Contractors
The principles suggest a mixed role in establishing standards for radon mitigators and a
dominant State role in monitoring and enforcing standards and requirements for
mitigation contractors. An analysis of respective roles for standards and monitoring
activities is provided below.
Standards and Requirements
One principle applicable to standards activities suggests a dominant State role while
three such principles suggest a mixed role. Radon mitigators generally operate on a
State or regional level, thus suggesting a State role. The services provided are
generally similar, except for variations in appropriate mitigation techniques which are
based on differences in building stock, building codes, and/or geologic conditions Both
Federal and State governments currently operate programs aimed at radon mitigators
Federal authorities may be able to provide technical resources and capital investments
necessary to develop exams and other standards. However, States may be able to
provide additional standards that better address locally prevalent mitigation techniques
and conditions. o ^
Monitoring and Enforcement
The principles suggest a clear State role in monitoring and enforcing radon mitigation
standards. Radon mitigators generally conduct business on a State or regional level
States currently monitor radon mitigation standards and requirements, and they can do
so effectively as compared to Federal monitoring of radon mitigation installations.
There is a Federal role for activities relevant to radon mitigation contractors but
primarily in setting standards and requirements. Future Federal standards for radon
mitigators should focus on areas where services are similar and where significant
technical capability or large capital investments are required. State authorities have a
role in supplementing Federal standards as necessary to address specific variations in
service delivery which are prevalent in their State or region (e.g. peculiar environmental
and geologic conditions, building stock and building codes). There is a dominant role for
Mates in monitoring and enforcing compliance with standards and requirements for
radon mitigation contractors. Federal activities in this area should focus on responding
to State complaints about EPA listed contractors.
47
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APPENDIX C
LIST OF STATE CONTACTS
ALABAMA
Division of Radiation Control
State Department of Public Health
434 Monroe Street, Room 510
Montgomery, AL 36130-1701
(205) 242-5315
ALASKA
State Department of Health and Social Services
Division of Public Health
P.O. Box H
Juneau, AK 99811-0610
(907) 465-3019
ARIZONA
State Radiation Regulatory Agency
4814 South 40th Street
Phoenix, AZ 85040
(602) 255-4845
ARKANSAS
Div. of Radiation Control & Emergency Mgmt.
State Department of Health
4815 West Markham Street
Little Rock, AR 72205-3867
(501) 661-2301
CALIFORNIA
State Department of Health Services
714 P Street, Room 600
Sacramento, CA 95814
(916) 322-2040
COLORADO
Radiation Control Division
State Department of Health
4210 East llth Avenue
Denver, CO 80220
(303) 331-8481
CONNECTICUT
Radon Program
Connecticut Department of Health Services
Hartford CT 06106-4474
(203) 566-3122
DELAWARE
Office of Radiation Control
Division of Public Health
Delaware Bureau of Environmental Health
P.O. Box 637
Dover, DE 19901
(302) 739-3787
DISTRICT OF COLUMBIA
D.C. Dept. of Consumer & Regulatory Affairs
614 H Street, N.W., Room 1014
Washington, D.C. 20001
(202) 727-7221
FLORIDA
Office of Radiation Control
Department of Health & Rehabilitative Services
1317 Winewood Boulevard
Tallahassee, FL 32499-0700
(904) 488-1525
GEORGIA
State Department of Human Resources
878 Peachtree Street, Room 100
Atlanta, GA 30309
(404) 894-6644
GUAM
Guam Environmental Protection Agency
IT&E Harmon Plaza, D-107
130 Rojas Street
Harmon, Guam 96911
HAWAII
Radiation Branch
State Department of Health
591 Ala Moana Boulevard
Honolulu, HI 96813-2498
(808) 548-4383
IDAHO
State Department of Health and Welfare
Bureau of Preventive Medicine
450 West State Street
Boise, ID 83720
(208) 334-6584
48
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ILLINOIS
Illinois Department of Nuclear Safety
1301 Knotts Street
Springfield, IL 62703
(217) 786-7126
INDIANA
Radiological Health Section
Indiana State Board of Health
1330 W. Michigan Street, P.O. Box 1964
Indianapolis, IN 46206
(317) 633-8563
IOWA
Bureau of Radiological Health
Iowa Department of Public Health
Lucas State Office Building
Des Moines, IA 50319-0075
(515) 281-7781
KANSAS
Radiation Control Program
Environmental Health Services
State Department of Health and Environment
109 SW 9th Street, 6th Fl, Mills Bldg
Topeka, KS 66612
(913) 296-1560
KENTUCKY
Radiation Control Branch
Division of Community Safety
Department of Health Services
Cabinet for Human Resources
275 East Main Street
Frankfort, KY 40621-0001
(502) 564-3700
LOUISIANA
Radiation Protection Division
State Department of Environmental Quality
P.O. Box 14690
Baton Rouge, LA 70898-4690
(504) 925-4518
MAINE
Indoor Air Program
Division of Health Engineering
Department of Health Services
State House, Station 10
Augusta, ME 04333
(207) 289-5692
MARYLAND
Radiological Health Program
Maryland Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3300
MASSACHUSETTS
State Department of Public Health
Western MA Health Office
23 Service Center
Northampton, MA 01060
(413) 586-7525
MICHIGAN
Division of Radiological Health
Bur. of Environmental & Occupational Health
State Department of Public Health
3423 N. Logan Street/Martin L. King, Jr. Blvd.
P.O. Box 30195
Lansing, MI 48909
(517) 335-8190
MINNESOTA
State Indoor Air Quality Unit
925 Delaware Street, SE
P.O. Box 59040
Minneapolis, MN 55459-0040
(612) 627-5012
MISSISSIPPI
Division of Radiological Health
State Department of Health
3150 Lawson Street
P.O. Box 1700
Jackson, MS 39215-1700
(601) 354-6657
MISSOURI
Bureau of Radiological Health
State Department of Health
1730 East Elm, P.O. Box 570
Jefferson City, MO 65102
(314) 751-6083
MONTANA
Occupational Health Bureau
State Dept. of Health & Environmental Sciences
Cogswell Building A113
Helena, MT 59620
(406) 444-3671
49
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NEBRASKA
Division of Radiological Health
State Department of Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, ME 68509
(402) 471-2168
NEVADA
Radiological Health Section
State Health Division
505 East King Street, Room 203
Carson City, NV 89710
(702) 687-5394
NEW HAMPSHIRE
Bureau of Radiological Health
State Division of Public Health Services
Health & Welfare Bldg, Six Hazen Drive
Concord, NH 03301
(603) 271-4674
NEW JERSEY
Radiation Protection Programs
Division of Environmental Quality
Department of Environmental Protection
CN 415, 729 Alexander Road
Trenton, NJ 08625-0145
(609) 987-6389
NEW MEXICO
Radiation Licensing and Registration Section
State Environmental Improvement Division
1190 St. Francis Drive
Santa Fe, NM 87503
(505) 827-2948
NEW YORK
Bureau of Environmental Radiation Protection
State Health Department
Two University Place
Albany, NY 12203
(518) 458-6461
NORTH CAROLINA
Division of Radiation Protection
State Department of Environment, Health, and
Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
(919) 571-4141
NORTH DAKOTA
Division of Environmental Engineering
State Department of Health
1200 Missouri Avenue, Room 304
P.O. Box 5520
Bismarck, ND 58502-5520
(701) 221-5188
OHIO
Radiological Health Program
Department of Health
246 North High Street, P.O. Box 118
Columbus, OH 43266-0118
(614) 644-2727
OKLAHOMA
Radon Protection Division
State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-5221
OREGON
Department of Human Resources
State Health Division
1400 SW 5th Avenue
Portland, OR 97201
(503) 229-5797
PENNSYLVANIA
Pennsylvania Dept. of Environmental Resources
Bureau of Radiation Protection
P.O. Box 2063
Harrisburg, PA 17120
(717) 787-2480
PUERTO RICO
Radiological Health Division
G.P.O. Call Box 70184
Rio Pierdras, Puerto Rico 00936
(809) 767-3563
RHODE ISLAND
Div. of Occupational and Radiological Health
State Department of Health
206 Cannon Building, 3 Capitol Hill
Providence, RI 02908
(401) 277-2438
50
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SOUTH CAROLINA
Bureau of Radiological Health
State Dept. of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-4700
SOUTH DAKOTA
State Department of Water and Natural
Resources
523 E. Capitol
Pierre, SD 57501
(605) 773-3351
TENNESSEE
State Department of Health and Environment
Division of Air Pollution Control
701 Broadway, 4th Floor
Nashville, TN 37247-3101
(615) 741-3651
TEXAS
Radiological Assessment Program
Bureau of Radiation Control
State Department of Health
1100 West 49th Street
Austin, TX 78756
(512) 835-7000
UTAH
Bureau of Radiation Control
State Department of Health
P.O. Box 16690, 288 North, 1460 West
Salt Lake City, UT 84116-0690
(801) 538-6734
VERMONT
Occupational & Radiological Health Operations
Division of Occupational & Radiological Health
State Department of Health
10 Baldwin Street, Administrative Bldg.
Montpelier, VT 05602
(802) 828-2886
VIRGINIA
Bureau of Radiological Health
Department of Health
109 Governor Street, Room 916
Richmond, VA 23219
(804) 786-5932
VIRGIN ISLANDS
Contact the U.S. EPA, Region 2 in New York
Mail Code 2AWM-RAD
26 Federal Plaza
New York, NY 10278
(212) 264-4418
WASHINGTON
Division of Radiation Protection
State Department of Health
Airdustrial Building 5, LE-13
Olympia, WA 98504
(206) 753-4518
WEST VIRGINIA
Office of Environmental Health Services
Industrial Hygiene Division
State Bureau of Public Health
151 llth Avenue
South Charleston, WV 25303
(304) 348-3526
WISCONSIN
Radon Program, Radiation Protection Section
Division of Health
State Department of Health and Social Services
P.O. Box 309
Madison, WI 53701-0309
(608) 267-4795
WYOMING
Environmental Health Programs
State Department of Health
Hathway Building, 4th Floor (Room 482)
Cheyenne, WY 82002-0710
(307) 777-6015
51
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List of Four Radon Regional Training Centers
Southern Regional Radon Training Center
Auburn University (lead center),
University of Louisville, University of Tulsa, and Texas A&M
238 Harbert Engineering Center
Auburn University, AL 36849
(205) 844-4370
Midwest Universities Radon Consortium
University of Minnesota (lead center),
University of Michigan, and Kansas State University
1985 Buford Avenue (240)
St. Paul, MN 55108-1101
(612) 624-5343
Eastern Regional Radon Training Center
Rutgers University
Radiation Science
Kilmer Campus, Bldg. 4087
New Brunswick, NJ 08903
(908) 932-2582
Western Regional Radon Training Center
Colorado State University
Department of Industrial Sciences
Fort Collins, CO 80523
(303) 491-7742
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REGIONAL OFFICES
Region 1
Radiation Program Manager, Region 1
U.S. Environmental Protection Agency
John F. Kennedy Federal Building
Room 2311
Boston, MA 02203
(617) 565-4502
Region 2
Radiation Program Manager, Region 2
U.S. Environmental Protection Agency
Room 1137-L
26 Federal Plaza
New York, NY 10278
(212) 264-4110
Region 6
Radiation Program Manager, Region 6
U.S. Environmental Protection Agency
Chief, Technical Section (6T-ET)
Air, Pesticides and Toxics Division
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7223
Region 7
Radiation Program Manager, Region 7
U.S. Environmental Protection Agency
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7020
Region 3
Radiation Program Manager, Region 3
Special Program Section (2AM12)
U.S. Environmental Protection Agency
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-8326
Region 8
Radiation Program Manager, Region 8
(8HWM-RP)
U.S. Environmental Protection Agency
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1713
Region 4
Radiation Program Manager, Region 4
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-1729
Region 5
Radiation Program Manager, Region 5
U.S. Environmental Protection Agency
77 West Jackson Blvd. (AT-18J)
Chicago, IL 60604-3590
(312) 886-6042
Region 9
Radiation Program Manager, Region 9
(A-l-1)
U.S. Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1048
Region 10
Radiation Program Manager,
Region 10, (AT-082)
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
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iJ-O.S. Government Printing Office : 1992 - 312-014/40083
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