Dear AARST Community,
We are sending you the AARST position statement below to alert you to a problem with a looming EPA-proposed change to Appendix F of the IRC. AARST intends to pursue options to reverse ICC acceptance of the proposal, seek approval of alternatives, and communicate broadly that this code change is bad for consumers and unworthy of code official support.
AARST Statement on EPA’s Proposal for Radon Testing
The International Code Council (ICC) develops the national building codes. AARST has made proposals over several years to get into the ICC codes radon-related building practices pertinent to radon standards that were more health-protective than the current code language. This year, EPA, without consulting with AARST, submitted an ineffective testing proposal “RM5-18” that did not pass, but then submitted a new version of RM5-18 (see Figure 1 for the exact language). On the day that AARST discovered what was in the revised RM5-18, AARST contacted EPA to express written opposition to it and requested that EPA withdraw the proposal. EPA did not. The flawed proposal was moved forward by ICC members during an in-person hearing October 26th and is now being voted on by the code officials from across the US, requiring a 2/3 vote to pass. AARST is pursuing options to reverse any positive decision.
The primary problem with the EPA proposal is the lack of reference to, and complete disregard of the overall substance of, the current consensus standards for radon in homes, ANSI-AARST MAH, SGM, and CCAH – yet EPA has been a partner in the development of those standards.
There are numerous parts of the EPA code change proposal that, if codified into the building code, will expose the unsuspecting public to higher risk of radon exposure while undermining progress made by the professional radon industry. For example:
Item 2. “If the system has an active fan, the residence shall be tested with the fan operating.”
! Fails to mention closed building conditions and HVAC operating.
Item 5. “Testing shall be performed with a commercially available radon test kit or with a continuous radon monitor that can be calibrated.”
! Should be a CRM that has been calibrated subject to compliance with QA.
! Should be an approved radon test kit, not anything the internet has to offer.
“Testing with test kits shall include two tests, and the test results shall be averaged.”
! Should require two for each area served by different HVAC per Item 3.
“Testing shall be in accordance with the testing device manufacturer’s instructions.”
! Allows reliance on, in many cases, a one-page pamphlet (if at all).
! Fails to require compliance with standard of practice in ANSI-AARST MAH.
Item 6. “Testing shall be performed by the builder, a registered design professional, or an approved third party.”
! Should not be performed by the builder or other self-interested party.
! Should be performed by a qualified individual.
! Encourages builders to violates some state laws requiring radon professional.
Item 8. “Written test results shall be included with construction documents.”
! Provides no assurance that the test result will ever be seen by buyer/ occupant.
Item 9. “An additional pre-paid test kit shall be provided to the owner to utilize at the owner’s discretion.”
! Provides no assurance that the test kit will ever be available to the buyer/ occupant: owner, a defined term in the code, means the builder unless the home is presold or being custom built.
Item 10. “Where the radon test result is 4 pCi/L or greater, the fan for the radon vent pipe shall be installed as specified in Sections AF103.8 and AF103.12.””
! Builds into the building code the illusion that the response to a high radon level is a fan alone, not mitigation performed by a qualified individual.
! Permits the builder to install a fan, any kind of fan, without detail of fan-specific considerations/installation per ANSI-AARST CCAH or SGM.
! Misleading – the referenced Appendix F sections specify only location and power supply.
! Requires no retest to determine final result below the EPA Action Level.