EPA - Acknowledgement of Proficiency Progs

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  • 8/7/2019 EPA - Acknowledgement of Proficiency Progs

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    EPA Acknowledgement of Non-Federal National RadonProficiency Programs

    Since the close of EPAs National Radon Proficiency Program (RPP) in 1998, there have been a number of requests thatEPA offer some form of recognition of non-Federal radon proficiency programs. EPA has offered a one-timeacknowledgment, based on meeting set recognition criteria (following this document), to any non-Federal radonproficiency program that lists or certifies radon measurement, mitigation service providers and/or analytical serviceproviders. EPA believes that it is appropriate to develop recognition criteria that call for a non-Federal radon proficiencyprogram to incorporate, at a minimum, program elements that comprised EPAs former voluntary RPP. EPA continues toencourage States, industry and consumers to work together to identify those elements that would improve non-Federalradon proficiency programs and go beyond EPAs former voluntary RPP. These improved elements should then beadopted as standards of practice.

    Both of the existing non-Federal national radon proficiency programs (The National Radon Safety Board (NRSB) and TheNational Environmental Health Associations (NEHA) National Radon Proficiency Program) participated in the evaluation.

    On March 30, 2001, EPA issued letters to both organizations stating the following:

    The Environmental Protection Agency (EPA) has completed its review of the (NRSBs or NEHAsNRPPs) application submitted for EPAs evaluation of Non-federal National Radon Proficiency

    Programs. Based solely on its review of the materials submitted, EPA finds that the following categories(listed here by program) successfully satisfy EPAs minimum criteria for operation of a non-federalNational Radon Proficiency Program (as established and implemented as described in the applicationssubmitted to EPA on March 1, 2001).

    Former EPA RPP Program Name NRSB Equivalent Program Name

    Analytical Service Provider Accredited Radon Laboratories

    Residential Radon Measurement Provider Radon Measurement Specialist

    Residential Radon Mitigation Provider Radon Mitigation Specialist

    Former EPA RPP Program Name NEHA NRPP Equivalent Program Name

    Analytical Service Provider Analytical Laboratories

    Residential Radon Measurement ProviderRadon Measurement Provider Offering StandardServices

    Analytical Service Provider AND Residential RadonMeasurement Provider

    Residential Measurement Provider Offering Standardand Analytical Services (RMPSAS)

    Residential Radon Mitigation Provider Residential Mitigation Provider

    Because of expected changes in the radon industry, this acknowledgment is only valid through

    December 31, 2002, at which time this determination will expire. There will be no extensions of thisdetermination. This determination is not applicable if changes are made to the program(s) as submittedto EPA, or if it is not implemented as described to EPA. To avoid misleading the public, you may notmake public reference to this EPA determination after December 31, 2002.

    Any references to EPAs determination in advertisements should avoid misleading consumers in thisregard. We recommend that you use the following description:

    For NRSB: EPA has reviewed NRSBs description of its Accredited Radon Laboratoryprogram; Radon Measurement Specialist; and, Radon Mitigation Specialist categoriesand has determined that they are consistent with EPAs former program categoriesAnal tical Service Provider; Residential Radon Measurement Provider; and, Residential

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    Radon Mitigation Provider, respectively. EPA has not reviewed the actual operations ofNRSBs Board, operation of its day-to-day operations, nor performed any audits of itsquality assurance program, examinations, or device evaluation program.

    For NEHAs NRPP: EPA has reviewed NEHAs NRPPs description of its AnalyticalLaboratories program; Residential Measurement Provider Offering Standard andAnalytical Services (RMPSAS) program; Residential Measurement Provider OfferingStandard Services program; and, Residential Mitigation Provider program and hasdetermined that they are consistent with EPAs former program categories Analytical

    Service Provider, Residential Radon Measurement Provider and Residential MitigationProvider, respectively. EPA has not reviewed the actual operation of NEHAs NRPPBoard, operation of its day-to-day operations, nor performed any audits of its qualityassurance program, examinations, or device evaluation program.

    If you have questions or comments on this recognition process, you can contact James Long at (202) 564-9433, or via e-mail at [email protected].

    For more information on how to contact either of the Non-federal National Radon Proficiency Programs (listed herealphabetically):

    The National Environmental Health Association (NEHA)National Radon Proficiency Program

    Administrative Offices525 East Fountain Boulevard, Suite 201Colorado Springs, CO 80903(719) 227-7518(719) 632-9607 (fax)http://www.radongas.org/e-mail: [email protected]

    The National Radon Safety Board (NRSB)P.O. Box 426

    Putnam Valley, NY 105791-866-329-3474(914) 345-8862 (fax)http://www.nrsb.orge-mail: [email protected]

    (Reference herein to any specific commercial products, process, or service by trade name, trademark, manufacturer,or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the UnitedStates Government.)

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    October 20, 2000

    Criteria for EPA Evaluation of

    Non-Federal National Radon Proficiency Programs

    U.S. Environmental Protection Agency

    Office of Air and Radiation

    Office of Radiation and Indoor Air

    Indoor Environments Division (6609J)

    1200 Pennsylvania Avenue, N.W.

    Washington, DC 20460

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    -i-

    Table of Contents

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

    II. EPAs Recognition of Non-Federal Radon Proficiency Programs ............ 2

    A. Recognition .................................................................................... 2

    1. Development of Criteria ............................................................. 22. Application Process ................................................................... 2

    B. Application for Recognition ............................................................. 3

    III. Evaluation Criteria for Analytical Service Provider Programs, and

    Residential Measurement and Mitigation Service Provider Programs ..... 3A. Criteria for Recognition of an Analytical Service Provider Program ... 3

    1. Device Performance Test ....................................................... 42. Develop and Implement a Quality Assurance Plan ...................... 4

    3. Adhere to Protocols .................................................................. 54. Reassessment of Qualifications on a Biennial Basis ................... 6

    5. Compliance with Program Requirements .................................... 6

    B. Criteria for Recognition of a Residential Measurement ServiceProvider Program ............................................................................. 61. Examinations ............................................................................. 6

    2. Adhere to Protocols ................................................................. 73. Develop and Implement a Quality Assurance Plan ..................... 7

    4. Reassessment of Qualifications on a Biennial Basis .................. 75. Provide Lists of Certified/Proficient Individuals ........................ 8

    6. Compliance with Program Requirements ................................... 8

    7. Consumer Information ........................................................... 9C. Criteria for Recognition of a Residential Mitigation Service

    Provider Program ............................................................................ 91. Training .................................................................................. 9

    2. Examinations ............................................................................ 93. Adhere to EPA Radon Mitigation Standards .............................. 10

    4. Reassessment of Qualifications on a Biennial Basis ................. 105. Provide Lists of Certified/Proficient Individuals ....................... 10

    6. Compliance with Program Requirements .................................. 11

    Appendix A - List of Resources ................................................................ 12Appendix B - Sample Acknowledgment Letter to Successful Applicants .... 13

    Appendix C - Sample Letter to Applicants Who are DeniedAcknowledgment ............................................................... 14

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    Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs

    October 20, 2000

    Page 1 of 14

    Criteria for EPA Evaluation of Non-Federal National Radon Proficiency Programs

    I. Introduction

    In 1988, Congress enacted the Indoor Radon Abatement Act (IRAA), which established a

    long-term national goal to reduce indoor radon levels to the point that air within buildings is as

    free of radon as the air outside. Under 15 USC 2665, 305(a)(2), Technical Assistance to

    States for Radon Programs, IRAA provided EPA authority to develop and implement activities

    designed to assist State radon programs, including operation of a voluntary program to rate the

    effectiveness of radon measurement devices and methods, the effectiveness of radon mitigation

    devices and methods, and the effectiveness of private firms and individuals offering radon-

    related services.

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

    (RMP) Program to assist consumers in identifying organizations capable of providing reliable

    radon measurement services. The Radon Contractor Proficiency (RCP) Program was

    established in 1989 to evaluate the proficiency of radon mitigators in residences and provide

    information to the public on proficient mitigators. In 1991, EPA expanded the RMP Program,

    adding a component to evaluate the proficiency of individuals who provide radon measurement

    services in the home. In 1995, these Programs were consolidated to form the National Radon

    Proficiency Program (RPP). A number of factors contributed to EPAs closing down its RPP on

    September 30, 1998. In addition to EPAs budgetary constraints, the radon industry itself had

    matured and appeared willing and capable of running their own proficiency program.

    Prior to closing its RPP, EPA began investigating the feasibility of privatizing the RPP and

    worked with stakeholders, and, in particular, the Conference of Radiation Control Program

    Directors, Inc. (CRCPD) and the American Association of Radon Scientists and Technologists(AARST), to this end.

    Currently, there are two privately-run National Radon Proficiency Programs, one run by the

    National Environmental Health Association (NEHA) and one run by the National Radon Safety

    Board (NRSB). Since the close of EPAs RPP, there have been a number of requests that EPA

    offer some form of recognition of these non-Federal programs. In response to these requests,

    on May 22, 2000, EPA issued draft criteria that would be used in evaluating these non-Federal

    radon proficiency programs. The draft criteria were posted on EPAs web site, and sent to key

    stakeholders representing States, consumers, industry, and the two current non-Federal radon

    proficiency programs. EPA received fourteen individual and joint comments on the draft criteria

    from a wide range of stakeholders and these comments have informed EPAs development of

    the final criteria.

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    Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs

    October 20, 2000

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    II. EPAs Recognition of Non-Federal Radon Proficiency Programs

    A. Recognition

    1. Development of Criteria

    In its 5/22/00 draft criteria, EPA proposed that it would recognize/re-evaluate privateproficiency programs every three years. This periodic review process would have

    EPA play a substantial continuing role in overseeing any recognized proficiency

    program which a number of commenters did not support. Moreover, some of the

    commenters wanted EPA to develop criteria that would require non-Federal

    proficiency programs to comply with standards well in excess of EPAs former

    voluntary National Radon Proficiency Program (RPP). In consideration of thesecomments, and to further encourage States, industry, and consumers to be involved

    in ensuring that non-Federal programs meet their needs, EPA has decided that it will

    offer a one-time process to recognize those programs that apply within a specified

    period of time.

    EPA believes that it is appropriate to develop recognition criteria that call for a non-

    Federal radon proficiency program to incorporate, at a minimum, program elements

    that comprised EPAs former voluntary RPP. EPA continues to encourage States,

    industry and consumers to work together to identify those elements that would

    improve non-Federal radon proficiency programs and go beyond EPAs former

    voluntary RPP. These improved elements should then be adopted as standards of

    practice.

    2. Application Process

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

    as meeting EPAs minimum criteria for a residential measurement service provider

    program or a residential mitigation service provider program or an analytical service

    provider program. To achieve this recognition, the non-Federal program will have to

    prove that it contains at least all of the components (or their equivalent) of the

    applicable portion of EPAs former voluntary National Radon Proficiency Program.

    These are outlined in further detail in Section III below.

    EPA will issue a letter of recognition for each program (residential measurement

    service provider program, residential mitigation service provider program, and/or

    analytical service provider program) that satisfies EPA criteria. This will be based

    solely on the information contained in the programs application(s). A copy of these

    recognition letters will also be posted (see Appendix B and C for samples of each

    type of letter) on http://www.epa.gov/radonpro/index.html. If an applicant does not

    meet the established criteria, EPA will issue a letter to this effect, and will post this

    determination on its web site.

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    Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs

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    B. Application for Recognition

    An application for EPAs recognition should be submitted to the following address so that

    it will be received by EPA no later than March 1, 2001.

    Mr. James W. Long

    U.S. Environmental Protection AgencyIndoor Environments Division (6609J)1200 Pennsylvania Avenue, N.W.

    Washington, DC 20460

    Applicants can submit one application for recognition for one or more program elements

    (measurement, mitigation and/or analytical), but must fully address the criteria for each

    of these recognitions in sufficient detail in separate sections of their application. Policy or

    procedural manuals should be submitted in support of the application. The applicant

    should highlight any deviation from the criteria in Section III below, and provide a detailed

    explanation as to why the applicants program element still remains equivalent to that of

    EPAs former voluntary National Radon Proficiency Program.

    EPA encourages all applicants to make public the contents of their application. However,

    in accordance with established EPA procedures contained in the Code of Federal

    Regulations, an applicant may assert a business confidentiality claim that covers part or

    all of their application. If an applicant chooses to assert such a claim, it must do so at

    the time of application. Information covered by such a claim will be disclosed by EPA

    only to the extent, and by means of, the procedures set forth in 40 CFR Part 2, SubpartB.

    Should EPA find that an application is deficient, EPA will give the applicant notice of the

    deficiencies and give the applicant 30 calendar days from the date of receipt of the notice

    to remedy them. Failure by the applicant to remedy the deficiencies within the 30-day

    period will result in a determination that the applicant has not shown that its program

    element meets EPAs criteria, and such a determination will be posted on EPAs web

    site.

    III. Evaluation Criteria for Analytical Service Provider Programs, and Residential

    Measurement and Mitigation Service Provider Programs

    A. Criteria for Recognition of an Analytical Service Provider Program

    Analytical measurement services are defined as radon measurement services or

    activities that include the capability to extract, read, analyze, or manipulate the data from

    radon measurement device(s), and calculate the final concentration for the client testreport. These capabilities include, but are not limited to, reading and recording initial and

    final voltages, printing data tapes, recording concentrations from a data window, or

    downloading the data to a some form of device/system for test report generation. An

    analytical service provider program shall require its participants to adhere to quality

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    Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs

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    assurance/quality control (QA/QC) principles and appropriate radon measurement

    protocols.

    1. Device Performance Test

    An analytical service provider program shall require a device performance test for

    each radon test device or method listed by participants in its program. An analyticalservice provider program shall require participants to provide measurement results

    that are within at least what EPAs former RPP required, 25% of the chamber target

    value. A more detailed discussion of what EPA required in its device performance

    test is contained in, U.S. EPA National Radon Proficiency Program Handbook, EPA

    402-R-95-013, July 1996 which is available on the EPA website at:http://www.epa.gov/radonpro/.

    2. Develop and Implement a Quality Assurance Plan

    An analytical service provider program should develop criteria for a quality assurance

    program and the program should require participants to adopt these criteria as they

    develop their own quality assurance plan(s). An analytical service provider programshould also require participants in the program to operate by, and maintain their

    quality assurance plan throughout their participation for each device listed in the

    subject analytical service provider plan(s). The program should require that the

    participants plan be updated whenever the program participant wishes to add a

    device to a listing or certification in the program. Also, EPAs guidance on quality

    assurance (Radon Measurement Proficiency Program: Guidance on Quality

    Assurance, EPA document 402-R-95-012) recommends that quality assurance

    program criteria provide details, practices, and procedures unique to each device

    used by a radon measurement service provider. An analytical service provider

    program should adopt criteria for a quality assurance plan that address all four of the

    following elements.

    Chain of Custody: A quality assurance plan should demonstrate custody

    procedures for tracking specific measurement devices. All radon

    measurement tests performed should have supporting documentation, which

    provides complete chain-of-custody information. All certified or listed devices

    in an analytical service provider program should carry a unique identifier, such

    as a serial number. Analytical service provider programs should require

    participants in their program to keep a record of the residential measurement

    service providers whose devices they analyze and be specific to the devices

    analyzed.

    Calibration: An analytical service provider program must require its

    participants to be able to describe the process, in writing, of how devicesused by participants are calibrated. EPA recommends that an analytical

    service provider program should require participants in the program to have

    their devices calibrated at least biennially. Calibration ensures that results of

    analyses are accurate within acceptable limits. An analytical service provider

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    Criteria for EPA Recognition of Non-Federal Radon Proficiency Programs

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    program should require that all continuous radon and continuous working level

    measurement devices display calibration information. This calibration label

    should list the calibration facility, the calibration date, and the calibration

    expiration date. An analytical service provider program should require

    participants to maintain records of calibration certificates and/or logs for all

    devices listed by the participant in the program.

    Checks for Background: A quality assurance plan should also include

    instructions on how to assess the effect of background radiation on

    measurement results.

    Spiked, Blank and Duplicate Samples: Depending on the measurement

    device or method, criteria for a quality assurance plan should require that

    participants regularly use of one or more of the following checks for bias and

    precision.

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

    S Duplicates are two or more measurements with identical equipmentexposed over the same time interval at the same location.

    Additional guidance for analytical service provider programs in developing criteria for

    quality assurance plans available under EPA Order 5360.1 A2, Policy and Program

    Requirements for the Mandatory Agency-wide Quality System(May 5, 2000), which

    reaffirms the policy defined under EPA Order 5360/1 (April 1984), and the EPA Order

    5360 (2000), EPA Quality Manual for Environmental Programs. More information on

    EPAs quality program are available at: http://www.epa.gov/quality/index.html.

    3. Adhere to Protocols

    An analytical service provider program shall require participants in its program toagree to adhere to the EPAs Measurement Device and Homes Protocols, that are

    referenced in Appendix A, or some equivalent or better device and homes protocols.

    There are many Federal, State, university, and private organizations who perform

    radon measurements, therefore, it is important that an analytical service provider

    program follow consistent procedures to assure accurate and reproducible

    measurements, and to enable valid intercomparison of measurement results.

    S Indoor Radon and Radon Decay Product Measurement Device Protocols.

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

    These protocols provide method-specific technological guidance that can be

    used as the basis for standard operating procedures. In keeping with goodlaboratory practices, each program participant should develop its own detailed

    instrument-specific procedures that incorporate recommendations found in

    this and other radon-related protocol and guidance documents.

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

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

    4. Reassessment of Qualifications on a Biennial Basis

    An analytical service provider program should require participants to remain abreast

    of new developments in the radon industry and to continue to hone their skills. Theanalytical service provider program should require participants to fulfill biennial

    listing/certification requirements. The biennial requirements may include device

    performance tests, review of the participants quality assurance procedures, and/or a

    review of the participants quality control (QC) measurement data during the previous

    listing/certification period, etc.

    5. Compliance with Program Requirements

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

    process for evaluating complaints, including fair procedures that afford opportunities

    for providers and complainants to present their views to an impartial party (to be

    determined by the analytical service provider program). EPA suggests thatconsequences (e.g., delisting/decertification for incompetence, inappropriate

    practices or fraud) of program non-compliance should be clearly stated in

    informational materials provided by the analytical service provider program and

    should be implemented when appropriate.

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

    A residential measurement service provider program should evaluate participants on

    their knowledge in providing reliable radon measurement services in the home. EPA

    considers the following components necessary elements for a residential measurement

    service provider program to assess the qualifications of participants so as to ensure that

    consumers receive reliable, quality measurement services.

    1. Examinations

    A residential measurement service provider program shall require participants to

    demonstrate knowledge sufficient to provide reliable radon measurement services in

    a residential setting. EPA considers the preferred method to demonstrate thisknowledge to be passing a written or, for example, a computer-based exam, as a

    condition to being initially listed or certified. The exam should be designed to evaluate

    an individuals knowledge necessary to ensure valid radon measurements and

    effective consumer communication. EPA continues to offer an extensive list of

    resources to assist in the development of an exam and as a study aid for participants

    to prepare for the exam(s) (see Appendix A).

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    2. Adhere to Protocols

    A residential measurement service provider program shall require participants in its

    program to agree to adhere to EPAs Measurement Device and Homes Protocols,

    that are referenced in Appendix A, or some equivalent or better device and homes

    protocols. There are many Federal, State, university, and private organizations who

    perform radon measurements, therefore, it is important for that a residentialmeasurement service provider program follow consistent procedures to assure

    accurate and reproducible measurements, and to enable valid intercomparison of

    measurement results.

    S Indoor Radon and Radon Decay Product Measurement Device Protocols.

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

    These protocols provide method-specific technological guidance that can be

    used as the basis for standard operating procedures. In keeping with good

    laboratory practices, each program participant should develop its own detailed

    instrument-specific procedures that incorporate recommendations found in

    this and other radon-related protocol and guidance documents.

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

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

    3. Develop and Implement a Quality Assurance Plan

    A residential measurement service provider program shall develop criteria for a

    quality assurance program and the program should require participants to adapt this

    criteria as they develop their own quality assurance plan(s). A residential

    measurement service provider program should require that the participants plan be

    updated whenever the program participant wishes to add a device to a listing or

    certification in the program. Also, EPAs guidance on quality assurance (RadonMeasurement Proficiency Program: Guidance on Quality Assurance, EPA document

    402-R-95-012) recommends that a quality assurance plan provide details, practices,

    and procedures unique to each device used by a radon measurement service

    provider. (See III.A.2. above for further EPA guidance regarding development of

    quality programs.) The elements of the guidance are designed to provide a

    framework for quality assurance practices that can be modified, and added to,

    according to the specific needs of the measurement program.

    4. Reassessment of Qualifications on a Biennial Basis

    A residential measurement service provider program should require participants to

    remain abreast of new developments in the radon industry and to continue to honetheir skills. The program shall require participants to fulfill a biennial re-listing/re-

    certification requirement. This requirement could be achieved by completing

    continuing education requirements. A residential measurement service provider

    program should demonstrate how continuing education course work is approved and

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    how participants document their completion of continuing education credits. A

    residential measurement service provider program that approves course providers

    should require these providers to update their course materials on a regular basis to

    ensure that as new technical information is developed this information is incorporated

    into the course material. As part of its former continuing education program, EPA

    developed course evaluation criteria that can be used as guidance in developing a

    continuing education program (see Appendix A).

    A residential measurement service provider program must be able to demonstrate

    how its continuing education program is designed to maintain a participants relevant

    knowledge in the radon field. A residential measurement service provider program

    should require participants to submit documentation showing their completion of, atleast, sixteen hours of continuing education. Under its former voluntary RPP, EPA

    required that at least half of these credits come from completion of program-

    evaluated or approved courses, with the other half of the continuing education

    requirements coming from a variety of informal radon-related activities and

    experience. EPA will consider this approach acceptable for a non-Federal residential

    measurement service provider program. Each formal course should include an

    evaluation mechanism built into the lesson plan to ensure that attendeesdemonstrate attainment of the learning outcomes with a certificate of successful

    completion awarded upon completion of the course requirements.

    5. Provide Lists of Certified/Proficient Individuals

    Consumers seeking the services of a radon measurement service professional need

    a resource they can use to find qualified service professionals. EPA recommends

    that consumers contact their State Radon Contact to determine what are the, or

    whether there are, requirements associated with providing radon measurement in a

    particular State. Some States maintain lists of contractors available in their state or

    they have proficiency programs or requirements of their own. EPA recommends that

    a residential measurement service provider program offer convenient ways forconsumers and other groups to search for their listed radon professionals in an

    easily accessible media (e.g., the world wide web).

    6. Compliance with Program Requirements

    A residential measurement service provider program shall have a compliance

    component and a process for evaluating complaints, including fair procedures that

    afford opportunities for providers and complainants to present their views to an

    impartial party (to be determined by the residential measurement service provider

    program). EPA suggests that consequences (e.g., delisting/decertification for

    incompetence, inappropriate practices or fraud) of program non-compliance should

    be clearly stated in informational materials provided by the residential measurementservice provider program and should be implemented when appropriate.

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    7. Consumer Information

    In addition, a residential measurement service provider program shall require

    participants to provide all customers the following information:

    S The results of the radon test, including an explanation of what the test result

    means in reference to established benchmarks for concern, including EPAsradon action level of 4 pCi/L (picoCurries per liter);

    S If the radon test exceeds established benchmarks (such as EPAs action level

    of 4 pCi/L), information about possible re-testing and information on how to

    obtain mitigation services (such as is provided in EPAs Consumer's Guideto Radon Reduction How to Reduce Radon Levels in Your Home... EPA

    Document Number 402-K-92-003).

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

    A residential mitigation service provider program should evaluate participants on their

    knowledge in providing reliable radon mitigation services in the home. EPA considers thefollowing components necessary elements for a residential mitigation service provider

    program to be able to assess the qualifications of participants so as to ensure that

    consumers receive reliable, quality services.

    1. Training

    A residential mitigation service provider program shall incorporate requirements that

    participants complete at least 16 hours of hands-on training. A residential mitigation

    service provider program should be able to prove that training courses, at a

    minimum, contain the guidance in EPAs Radon Mitigation Standards. EPA

    Document Number 402-R-93-078, October 1993 (Revised April 1994), or equivalent

    information. The EPA Radon Mitigation Standardsset a base level of performance

    for all residential mitigation service providers.

    2. Examinations

    A residential mitigation service provider program should require participants to

    demonstrate knowledge sufficient to provide reliable radon mitigation services in aresidential setting. EPA considers the preferred method to demonstrate this

    knowledge to be passing a written or, for example, a computer-based exam, as a

    condition to being initially listed or certified. The exam should be designed to evaluate

    an individuals knowledge necessary to ensure valid radon mitigations and effective

    consumer communication. EPA continues to offer an extensive list of resources to

    assist in the development of an exam and as a study aid for participants to prepare

    for the exam(s) (see Appendix A).

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    3. Adhere to Radon Mitigation Standards

    A residential mitigation service provider program shall require participants in its

    program to agree to adhere to appropriate standards and protocols, such as those

    found in EPAs Radon Mitigation Standards. EPA Document Number

    402-R-93-078, October 1993 (Revised April 1994), or similar document.

    EPAs Radon Mitigation Standards provide uniform standards that residential

    mitigation service provider programs can use to ensure quality and effectiveness in

    the design, installation, and evaluation of radon mitigation systems.

    4. Reassessment of Qualifications on a Biennial Basis

    A residential mitigation service provider program should require participants to

    remain abreast of new developments in the radon industry and to continue to hone

    their skills. The program shall require participants to fulfill a biennial re-listing/re-

    certification requirement. This requirement could be achieved by completing

    continuing education requirements. A residential mitigation service provider program

    should demonstrate how continuing education course work is approved and howparticipants document their completion of continuing education credits. A residential

    mitigation service provider program that approves course providers should require

    these providers to update their course materials on a regular basis to ensure that as

    new technical information is developed this information is incorporated into the

    course material. As part of its former continuing education program, EPA developed

    course evaluation criteria that can be used as guidance in developing a continuing

    education program (see Appendix A).

    A residential mitigation service provider program must be able to demonstrate how its

    continuing education program is designed to maintain a participants relevant

    knowledge in the radon field. A residential mitigation service provider program should

    require participants to submit documentation showing their completion of, at least,sixteen hours of continuing education. Under its former voluntary RPP, EPA required

    that at least half of these credits come from completion of program-evaluated or

    approved courses, with the other half of the continuing education requirements

    coming from a variety of informal radon-related activities and experience. EPA will

    consider this approach acceptable for a residential measurement service provider

    program. Each formal course should include an evaluation mechanism built into the

    lesson plan to ensure that attendees demonstrate attainment of the learning

    outcomes with a certificate of successful completion awarded upon completion of the

    course requirements.

    5. Provide Lists of Certified/Proficient Individuals

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

    resource they can use to find qualified service professionals. EPA recommends that

    consumers contact their State Radon Contact to determine what are the, or whether

    there are, requirements associated with providing radon mitigation in a particular

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    State. Some States maintain lists of contractors available in their state or they have

    proficiency programs or requirements of their own. EPA recommends that a

    residential mitigation service provider program offer convenient ways for consumers

    and other groups to search for their listed radon professionals in an easily accessible

    media (e.g., the world wide web).

    6. Compliance with Program Requirements

    A residential mitigation service provider program shall have a compliance component

    and a process for evaluating complaints, including fair procedures that afford

    opportunities for providers and complainants to present their views to an impartial

    party (to be determined by the residential mitigation service provider program). EPAsuggests that consequences (e.g., delisting/decertification for incompetence,

    inappropriate practices or fraud) of program non-compliance should be clearly stated

    in informational materials provided by the residential mitigation service provider

    program and should be implemented when appropriate.

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    Appendix A

    List of Resources

    A Citizen's Guide to Radon (second edition) The guide to protecting yourself and your family

    from radon. EPA Document Number 402-K-92-001, September 1994.

    Consumer's Guide to Radon Reduction How to Reduce Radon Levels in Your Home... EPA

    Document Number 402-K-92-003.

    El Radn Gua para su proteccin y la de su familia Documento de la Agencia de los Estados

    Unidos para la Proteccin Ambiental Nmero 402-K-93-005, septiembre del 1993.

    Home Buyer's and Seller's Guide to Radon. EPA Document Number: 402-R-93-003, March

    1993. (Note: A newly revised version of the Guideis about to be released - 402-K-00-008, July

    2000).

    Model Standards and Techniques for Control of Radon in New Residential Buildings.

    EPA Document Number 402-R-94-009, March 1994.

    Radon Mitigation Standards. EPA Document Number 402-R-93-078, October 1993 (Revised

    April 1994).

    Technical Support Document for the 1992 Citizen's Guide to Radon. EPA Document

    Number 400-R-92-011, May 1992.

    Indoor Radon and Radon Decay Product Measurement Device Protocols. EPA

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

    Protocols for Radon and Radon Decay Product Measurements in Homes. EPA Document

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

    Radon Measurement Proficiency Program: Guidance on Quality Assurance , EPA

    document 402-R-95-012

    U.S. EPA National Radon Proficiency Program Handbook, EPA 402-R-95-013, July 1996

    EPA Order 5360.1 A2, Policy and Program Requirements for the Mandatory Agency-wide

    Quality System, May 5, 2000 (http://www.epa.gov/quality)

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    Appendix B

    Sample Acknowledgment Letter to Successful Applicants

    [Organizations Name] [Date]

    [Organizations Representative]

    [Address][City, State, Zip]

    RE: EPAs Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or

    Residential Mitigation Service Provider Program or Analytical Service Provider Programs]

    Dear Sir/Madam:

    EPA has completed its review of your programs application dated __/__/__. Based solely

    on its review of the materials submitted, EPA finds [the subject programs] residential

    measurement service provider program [or residential mitigation service provider program, or

    analytical service provider program] successfully satisfies EPA criteria for operation of a non-

    Federal national radon proficiency program if established and implemented as described in your

    application. Because of expected changes in the radon industry, this acknowledgment is only

    valid through December 31, 2002, at which time this determination will expire. There will be no

    extensions of this determination. This determination is not applicable if changes are made to the

    program as submitted to EPA, or if it is not implemented as described to EPA. To avoid

    misleading the public, you may not make public reference to this EPA determination after

    December 31, 2002.

    Any references to EPAs determination in advertisements should avoid misleading

    consumers. We recommend that you use the following description:

    EPA has reviewed [your organizations] description of its [your program name] andhas determined that the description of [your programs name] is consistent with EPAs

    criteria for operation of a non-Federal residential measurement service provider program[or a residential mitigation service provider program or an analytical service provider

    program]. EPA has not reviewed the actual operation of [your programs name].

    We will post the results of our determination on our web site at:

    http://www.epa.gov/radonpro. If you have any questions concerning this letter, you may contact

    James Long of my staff at (202) 564-9433 or [email protected].

    Sincerely yours,

    Mary T. Smith, DirectorIndoor Environments Division

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    Appendix C

    Sample Letter to Applicants Who are Denied Acknowledgment

    [Organizations Name] [Date]

    [Organizations Representative]

    [Address]

    [City, State, Zip]

    RE: EPA Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or

    Residential Mitigation Service Provider Program or Analytical Service Provider Programs]

    Dear Sir/Madam:

    Based on EPAs review of your submission dated __/__/00, we can not find that your

    residential measurement service provider program [or residential mitigation service provider

    program, or analytical service provider program] meets EPAs criteria for a non-Federal national

    radon proficiency program. You have 30 calendar days from the date of your receipt of this letter

    to address the concerns described in the attachment. If you fail to successfully address these

    concerns within the time frame allocated, no more consideration will be given to your

    submission and EPA will issue you a formal denial of your application and post the results of our

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

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

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

    Sincerely yours,

    Mary T. Smith, Director

    Indoor Environments Division

    Attachment