oversight

Air Pollution: Changes Needed in EPA's Program That Assesses Radon Measurement Firms

Published by the Government Accountability Office on 1990-08-31.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United   States   General   Accounting   Office

Gi!!            Report to the Chairman, Committee on ’
                Science, Space, and Technology, House
                of Representatives


August   1990
                AIR POLLUTION
                ChangesNeeded in
                EPA’s Program That
                AssessesRadon
                Measurement Firms
      United States
GAO   General Accounting  Office
      Washington, D.C. 20648

      Resources, Community,   and
      Economic Development    Division

      B-239005.3

      August   31,199O

      The Honorable Robert A. Roe
      Chairman, Committee on Science,
        Space, and Technology
      House of Representatives

      Dear Mr. Chairman:

      This report responds to your request that we review the Environmental Protection Agency’s
      program that assesses the proficiency of radon measurement companies. The report
      discusses changes that are needed at the federal level to provide homeowners with greater
      assurance that radon measurements are accurate. In addition, it discusses the status of state
      programs that accredit, certify, or license radon measurement companies.

      We are sending copies of the report to appropriate congressional committees; the
      Administrator, EPA; and other interested parties. We will make copies available to others
      upon request.

      If you have any questions regarding this report, please contact me on (202) 275-6111. Major
      contributors to this report are listed in appendix III.

      Sincerely yours,




      Richard L. He&bra
      Director, Environmental Protection
        Issues
                       ExecutiveSummary




                       the RMP program that would increase homeowners’ assurance are (1)
                       requiring measurement firms to pass the RMP program before marketing
                       their devices, and (2) requiring radon measurement firms to demon-
                       strate the existence of adequate quality assurance programs as a condi-
                       tion for participating in the RMP program.

                       Most states have not developed programs that would help to ensure the
                       reliability, consistency, and quality of radon test data that companies
                       provide homeowners. Also, without federal guidelines, the requirements
                       differ in those states that accredit, license, or certify radon measure-
                       ment companies, thus providing homeowners with differing levels of
                       assurance.



Principal Findings

Firms Market Devices   In October 1989 GAO reported cases illustrating why homeowners do not
Without Meeting RMP    have assurance that radon measurements are accurate and why there is
                       a need for additional controls over measurement companies. For
Requirements           example, in a review of EPA'S 1988 testing of radon measurement firms,
                       GAO found that one large measurement company and a few small compa-
                       nies were marketing devices that had not been tested in the RMP pro-
                       gram; one device that was being marketed by one of the large companies
                       did not meet the RMP program’s requirements; several small companies
                       that failed the 1988 testing were marketing devices; and a few small
                       companies that tested some of their devices in the RMP program had been
                       marketing other devices that had not been tested in the program. In a
                       few of these incidences, it appeared the companies may have been pro-
                       viding homeowners with inaccurate measurements.

                       Officials from a sample of the radon testing industry support requiring
                       measurement companies to participate in the RMP program. Of the 32
                       officials GAO interviewed, 27 said participation should be mandatory.
                       Reasons cited for such a requirement included the severity of health
                       effects of radon and the public’s need to have assurance that they are
                       dealing with reputable firms.




                       page3
                  ExecutiveSummary




                  Finally, the nine states that have established programs that accredit,
                  certify, or license radon measurement companies have differing require-
                  ments, which provide different levels of assurance to the homeowner.
                  For example, as mentioned above, five states, have quality assurance
                  requirements while four do not. Seven states require measurement com-
                  panies to meet minimum educational requirements for critical personnel.
                  GAO believes that one reason state requirements differ is that EPA has not
                  defined the degree of control it wants states to exercise over radon mea-
                  surement companies.


                  In testimony at hearings held by the House Subcommittee on Natural
Recommendations   Resources, Agriculture Research, and Environment, Committee on Sci-
                  ence, Space, and Technology, on May 16, 1990, GAO recommended that
                  the Congress provide EPA with the authority to require radon measure-
                  ment companies to successfully pass the RMP program before marketing
                  their devices to the public (GAO/T-RCED-90-54). In addition, GAO recom-
                  mended that EPA (1) establish minimum quality assurance requirements
                  for the different radon measurement devices, and, as a condition for
                  participating in the RMP program, require measurement firms to demon-
                  strate that they have developed and implemented programs that will
                  meet the requirements and (2) issue specific guidance on the type of pro-
                  gram and level of control over radon measurement companies it believes
                  is needed at the state level to provide homeowners with adequate assur-
                  ance that radon measurements are accurate.


                  As requested, GAO did not obtain official agency comments on a draft of
Agency Comments   this report. However, GAO discussed the factual material in the report
                  with EPA officials, who generally agreed that it was accurate, and incor-
                  porated their comments where appropriate. In addition, at the May 16,
                  1990, hearings mentioned above, the Deputy Administrator of EPA testi-
                  fied that EPA was strengthening the RMP program in several ways, one of
                  which is to require participants to implement quality assurance pro-
                  grams. Also, the Deputy Administrator testified that EPA would be
                  designing a model state certification program to assist states in their
                  efforts. EPA did not take a position on requiring firms to pass the RMP
                  program before marketing their instruments.




                  page5                                           GAO/RCRI%?-209RadonTesting
Abbreviations

EPA         Environmental Protection Agency
GAO         General Accounting Office
RMP         Radon Measurement Proficiency


Page7                                         GAO/RCEIWMO9 F&don Testing
                   Chapter 1
                   Introduction




                   found. In October 1989 EPA released the results of radon screening mea-
                   surements in eight additional states-Alaska, Georgia, Iowa, Maine,
                   New Mexico, Ohio, Vermont, and West Virginia-and       on Indian lands in
                   North and South Dakota, Iowa, Nebraska, and New Mexico. EPA stated
                   that the measurement results continue to show elevated radon levels in
                   housing across the country.

                   While EPA maintains that there is no safe level of radon, it recommends
                   action whenever annual average radon levels are greater than about 4
                   picocuries per liter of air.2 EPA estimates that the risk of being exposed
                   to annual radon levels of 4 picocuries over a lifetime of 70 years is com-
                   parable to smoking half a pack of cigarettes each day.


                   Radon can enter a home from several sources (see fig. 1.1). A major
Sourcesof Indoor   source of indoor radon is the soil and rocks surrounding a home. The
Radon              radon gas seeps easily into a home through cracks and openings in foun-
                   dation walls and floors and, more slowly, through concrete walls and
                   floors. The amount of radon entering a home depends on a variety of
                   factors, including the amount of radium in the soil surrounding or
                   beneath a house, the soil’s permeability, the type of house construction
                   (e.g., house with basement versus house with crawl space), and the con-
                   dition of the home’s foundation. Because of these factors, homes on the
                   same block or beside each other can have different radon levels.

                   Radon can also enter a home in other ways. For example, it may enter
                   via water supplied by private underground wells. As water comes in
                   contact with the soil and rocks, it picks up radon. The churning of the
                   water in washers, showers, and sinks releases the radon into the indoor
                   air. Usually, radon is not a problem with large community water sup-
                   plies, where it would likely be released into the outside air before the
                   water reaches a home. Radon can also enter a house from building
                   materials, although generally not a major source, that contain uranium
                   and radium.




                    ‘The concentration of radon in air is measured in units of pic&uries per liter of air; I picoCune per
                    litrr represents the decay of aborlt two radon atoms per minute in a liter of air.



                    Pagr 9                                                             GAO/RCED9@209Radon Testing
             Chapter 1
             Introduction




                                         -
             require skilled operators, such as the continuous radon monitor, can
             measure radon and provide more immediate results without laboratory
             analysis. Companies that provide the laboratory analysis results or the
             results through the use of instruments by a skilled operator are tested
             through the RMP program and are called primary companies.”

                                  -
             EPA established the RMP program in 1986 to assess the capabilities of
RMPProgram   companies providing measurement services to the homeowner. The
             objectives of the program are to (1) assist the states and the public in
             selecting companies that have demonstrated competence in measuring
             indoor radon, and in the long run (2) assure the public through the use
             of standardized measurements and quality assurance procedures, that
             companies’ radon measurements are accurate.

             To achieve these objectives, EPA envisioned a federal/state approach. EPA
             would be responsible for testing the proficiency of firms, whose partici-
             pation in the program would be voluntary, and would encourage firms
             to adopt quality assurance procedures. The states, according to EPA offi-
             cials, would determine any additional regulation of firms, such as man-
             datory participation in the RMP program and mandatory adoption of
             quality assurance programs.

             To pass the RMP program, EPA requires a primary company to (1) follow
             the appropriate measurement protocols,? (2) demonstrate the ability to
             get test results to the proper homeowner, and (3) demonstrate the
             ability to measure radon to within 25 percent of actual levels. To meet
             the first requirement, EI'A generally relies on a company’s statement in
             the application that it follows the protocols. To meet the second and
             third requirements, companies must pass a proficiency test, which
             includes correctly analyzing devices exposed to known levels of radon
             and reporting the results to EPA for verification. EPA publishes a list of

               ‘Primary companies either habe lalwratory capabdities to analyze radon measurement devices after
              they have been exposed to radon or measure the radon levels and analyze the results with their own
              instrumentation and operators. Secondary companies provide services ranging from distribution of
              radon devices to home inspwtion and consultation. EPA does not evaluate secondary companies but
              suggests that consumers only we secondary companies that are affiliated with primary companies
              that have passed the RMP program. This report addresses EPA’s assessment of primary companies
              Only

              ‘Protocols outline procedures for taking radon measurements, specify the standardized house condi-
              tions that should exist at the time of the measurement, and describe the appropriate steps to follow
              and the equpment to use for each EPA-approved measurement method. To date, the following protc-
              cols have been issued: “Interim Indoor Radon and Radon Decay Product Measurement Protocols,”
              (February 1986) (revised and issued in final form, Feb. 1989); and “Interim Protocols for Screening
              and Followop Radon and Radon Decay Product Measurements” (February 1987).



              Page 11                                                          GAO/RCED-90.209 Radon Testing
chapter 1
Introduction




To determine changes that can be made in the RMP program we: relied on
the results of our prior work to demonstrate the need for changes; iden-
tified common elements in other government accreditation programs;
obtained industry’s views, through a telephone survey, on the need to
require certain elements in a proficiency program to provide assurance
that measurement results are accurate; and conducted a survey of the
status of state radon programs.

To obtain industry’s views, we interviewed a sample of representatives
from the 843 radon measurement companies and/or laboratories that
had applied to participate in EPA’S measurement proficiency test round
held in 1989. In this round, EPA tested devices using one of nine measure-
ment methods-activated      charcoal, liquid scintillation, alpha track, elec-
tret ion chamber and radon integrated sampling unit (called passive
devices because they do not require a skilled operator in the field and
can be sent through the mail), continuous radon monitor, continuous
working level monitor, grab radon monitor, and grab working level mon-
itor (called active devices because they do require a skilled operator).

To make sure that we obtained the views of various segments of the
industry, we divided the applicants into four groups. The first group
included all government- and university-affiliated laboratories. The
second group included all large primary companies. We defined a large
primary company as one that provides laboratory analysis for 30 or
more secondary companies. This is the same criterion that we used in
our previous work, as reported in October 1989. The small primary com-
panies (i.e. companies with fewer than 30 secondary companies) were
then placed into one of the remaining two groups. The third group
included any small primary company that applied to test any one of four
popular passive devices-activated      charcoal, liquid scintillation, alpha
track, and electret ion chamber. Finally, the fourth group included any
 small primary company that applied to test only one or more of the four
 active devices or the passive radon progeny integrated sampling unit.
 This latter device is not widely used. Only 9 of the 843 applicants, or
 about 1 percent, applied to participate in the RMP program using the
 radon progeny integrated sampling unit.

The interview instrument used to obtain the information was pretested
with three applicants. After the pretests were completed, we randomly
selected a total of 30 applicants from the four groups. One applicant in
the sample had been interviewed during the pretesting; therefore 29




 Page 13                                          GAO/RCEIWO.209Radon Testing
RMP Program Does Not Provide Adequate
Assurance That Radon Measurements
Are Accurate
                       Even with the increased number of firms demonstrating proficiency in
                       measuring radon, EPA and the public still cannot be assured that all com-
                       panies meet proficiency standards because the voluntary nature of the
                       RMP program allows firms to market measurement devices that have not
                       been tested or that have failed a test. Industry officials generally agreed
                       that participation in the RMP program needs to be mandatory because of
                       the severity of health effects of radon and because of the public’s need
                       to have assurance that they are dealing with reputable firms.

                       Furthermore, the RMP program does not require measurement firms to
                       implement quality assurance programs that ensure quality measure-
                       ments on a day-to-day basis and, consequently, companies may be pro-
                       viding homeowners with inaccurate results. Not requiring firms to
                       implement quality assurance programs seems inconsistent with agency
                       policy, science advisory board recommendations, and other laboratory
                       accreditation programs. Radon industry officials believe quality assur-
                       ance should be required as a condition for participating in the RMP
                       program.

                       We made recommendations for addressing these problems in our May
                       16, 1990, testimony before the House Subcommittee on Natural
                       Resources, Agriculture Research, and Environment, Committee on Sci-
                       ence, Space and Technology. At the hearings the Deputy Administrator
                       of EPA also testified that EPA was enhancing the RMP program in several
                       ways.


                       In October 1989 we reported that 87 percent of the devices companies
Firms Market Devices   had tested in the RMP program in 1988 met the RMP requirements.l How-
Without Meeting RMP    ever, we also reported that the voluntary nature of the program allows
Requirements           firms to market devices that fail the program or that have not been
                       tested in the program When companies are allowed to market devices
                       without demonstrating a minimum level of competency in measuring
                       radon, consumers have no assurance that they are receiving accurate




                       ‘Results for the 1989 RMP testing round show that about 80 percent of the devices that companies
                       submitted for testing passed These figures do not include the double-blind results from the 1989
                       testing round.



                       page15                                                          GAO/RCED-99209RadonTesting
                         Chapter 2
                         RMP Pro@.amDoes Not Provide Adequatr:
                         Assurance That Radon Measurements
                         AR Accurate




                                                -~~
                         A radon measurement company needs a quality assurance program to
RMP Program Does         ensure that its performance in producing accurate measurements meets
Not Require              a minimum level of competence. In fact, our work shows that without
Measurement              such programs, a company may be providing homeowners with inaccu-
                         rate results.
Companies to Have
Quality Assurance
Programs

Quality Assurance        An effective quality assurance program is EPA’S best guarantee that
Procedures Help Ensure   radon measurement firms are performing quality testing on a day-to-day
                         basis. In its protocol, FZA states that the objective of quality assurance is
Accurate Measurement     to ensure that data are scientifically sound, precise, and accurate.
Results
                         Although EPA recommends certain quality assurance procedures for
                         radon measurement companies, the agency does not require companies
                         to develop and implement such procedures as a condition for program
                         participation. Procedures EPA recommends include: controlled calibra-
                         tions of measurement devices in an environment in which radon levels
                         are known, such as in a radon calibration chamber; background and
                         duplicate measurements; written procedures for attaining quality assur-
                         ance objectives; a system for recording and monitoring the results of
                         quality assurance measurements; and maintenance of control charts and
                         related statistical data.

                         If measurement companies do not develop and implement adequate
                         quality assurance programs, they may be providing homeowners with
                         inaccurate results. For example, in our prior work, we found that only
                          12 of 2 1 interviewed companies that participated in 1988 testing were
                         calibrating their equipment. One of the nine companies that did not cali-
                         brate its equipment failed the 1988 testing with a loo-percent error but
                         had been marketing its equipment for a full year before testing. After
                         calibrating its equipment, the company retested and passed.

                         The primary purpose of documented quality control, according to the
                         former Chief, Office of Radiation Measurement, National Institute of
                         Standards and Technology, is to ensure that the capability demonstrated
                         during performance testing is maintained until the next periodic evalua-
                         tion. The recent results of EPA'S double-blind testing of radon measure-
                         ment companies indicate that some firms are having difficulty



                         Page 17                                           GAO/RCED-S0209Radon Testing
                                 cllapter 2
                                 RMPProlpamDowNotPnwideAdeqnate
                                 Assunrnfe That Radon Me-llWIltS
                                 AreAccurnti




Industry Officials Believe       Of the 32 radon testing company officials interviewed, 31 said quality
                                 assurance should be required as a condition for participating in the RMP
RMP Program Should               program. One official said quality assurance should only be required
Require Quality Assurance        after a company passes the RMP program. Some of the reasons officials
                                 gave for requiring quality assurance included the ones below.

                             l The radon measurement area is wide open to abuse because home-
                               owners cannot see, taste, or smell radon.
                             l Quality assurance requirements would force industry to develop good
                               quality control systems and standardize industry practices.
                             . A quality control system is needed as a link between a company’s per-
                               formance on the proficiency test and its everyday work.


EPA Task Force Is                EPA recently established a task force to assess changes that are needed
                                 in the RMP program. In an April 1990 meeting, program officials told us
Developing a Proposal to         the task force was developing a proposal for changes in the RMP program
Implement Quality                that would include requiring measurement companies to have quality
Assurance Requirements           assurance programs as a condition for participating in the RMP program.
                                 In addition, as authorized by the 1988 radon legislation, EPA is devel-
                                 oping a user-fee proposal to cover costs of the RMP program.


                                 On May 16, 1990, the House Subcommittee on Natural Resources, Agri-
House Radon Hearings             culture Research, and Environment, Committee on Science, Space, and
Address Need for                 Technology, held hearings on federal radon testing efforts. In testimony
More Quality                     at those hearings we recommended, on the basis of our work, that the
                                 Congress provide EPA with the authority to require radon measurement
Assurance                        companies to participate in the RMP program and successfully meet its
                                 requirements before marketing their devices to the public.” In addition,
                                 we recommended that EPA establish minimum quality assurance require-
                                 ments for the different radon measurement devices and, as a condition
                                 for participating in the RMPprogram, require measurement firms to
                                 demonstrate that they have developed and implemented programs that
                                 will meet the requirements.

                                 At the hearings the Deputy Administrator of EPA testified that EPA was
                                 strengthening the quality control aspects of the RMP program in several
                                 ways. The changes include expanding double-blind testing, requiring




                                 page19                                         GAO/RCEDW209RadonTesting
Chapter 3

States’ Monitoring of Radon Measurement Firms
Is Limited and Inconsistent

                        In designing the RMP program, EPA envisioned that states, through
                        accreditation or certification programs, would exercise some degree of
                        control over the reliability, consistency, and quality of the measurement
                        data companies provide homeowners. According to EPA officials, the
                        agency expected that states would make participation in the RMP pro-
                        gram mandatory and establish and enforce quality control requirements
                        through state programs.

                        However, we found that EPA'S expectations about the states’ role in con-
                        trolling measurement companies have not been met. From our nation-
                        wide survey of radon coordinators in 50 states and the District of
                        Columbia, we learned that few states have established programs that
                        accredit, certify, or license measurement companies. Furthermore, the
                        differing requirements among those states with programs provide
                        varying levels of assurance. (Appendix II presents a summary of the
                        responses to the questions in our telephone survey.)

                        In our May 16, 1990, testimony before the House Subcommittee on Nat-
                        ural Resources, Agriculture Research, and Environment, Committee on
                        Science, Space, and Technology, we recommended that EPA issue gui-
                        dance on the type of program and level of control it believes is needed at
                        the state level to provide homeowners with adequate assurance that
                        radon measurements are accurate. At these same hearings the Deputy
                        Administrator, EPA, testified that the agency planned to design a model
                        state certification program to assist states in their efforts.


                        Our nationwide survey of state radon coordinators indicates that state
Few States Establish    action to (1) make participation in the RMP program mandatory and (2)
Programs That           establish and enforce quality assurance requirements could take years
Accredit, Certify, or   to occur and may never occur in some states. For example, although the
                        coordinators in 35 states viewed radon levels in homes as a problem in
License Measurement     their states, only nine states have programs that certify, license, or
Companies               accredit radon measurement companies. All nine programs have a
                        requirement that radon measurement companies participate in EPA'S RMP
                        program or in a similar state-run program. However, only five of the
                        programs (those of Delaware, Florida, Iowa, Pennsylvania, and Virginia)
                        are mandatory. Three of the states with voluntary programs (Kentucky,
                        Nebraska, and New Jersey) are attempting to get legislation passed or
                        regulations implemented that would make their programs mandatory.
                        The fourth state (North Dakota) has no plans to change its voluntary
                        program. Of the nine states that have programs, only five have quality
                        assurance requirements.


                        Page21                                          GA0/RCED-90.209RadonTesting
                       Chapter 3
                       States’ Monitoring of Radon Measurement
                       Firms Is Limited and Inconsistent




                       and that each state needed flexibility to design a program that
                       addressed its own particular problem, according to EPA officials. In a
                       May 1988 report, EPA stated such control could include registration, cer-
                       tification, and licensing.’ According to the report, registration, certifica-
                       tion, and licensing differences center around whether the control
                       process is mandatory, whether nonparticipating (e.g., noncertified or
                       nonlicensed) firms are excluded from the market, and whether a fee is
                       charged by the state for the process. Licensing is viewed as the most
                       restrictive form of “quality control,” while registration is the least
                       restrictive. The report noted that the RMP program illustrates a form of
                       registration with no fee-the least restrictive form.

                       Industry representatives we contacted during the review also expressed
                       concern about the effect of state requirements on radon measurement
                       firms. For example, representatives of 3 of the 14 firms marketing their
                       services nationwide indicated that they did not market their devices in
                       one or more states because of existing requirements in those states. In
                       addition, a majority (19) of the industry representatives we interviewed
                       favored federal regulation of any quality assurance requirements that
                       might be imposed. The remaining representatives were divided, with six
                       favoring state regulation, and five favoring industry regulation. One
                       representative indicated a combination of federal and state regulation.
                       One representative did not have a position. The primary reason they
                       gave for preferring federal regulation was the need for uniformity in the
                       requirements. Among the problems associated with state regulation
                       mentioned by individual representatives were overlapping state jurisdic-
                       tions, inconsistencies and conflicts between state requirements, and gen-
                       eral confusion for the industry.

                       In an April 1990 meeting, EPA program officials told us that the radon
                       task force was proposing that a model state certification program docu-
                       ment be developed for guidance to states.


                       In our May 1990 testimony, we recommended that EPA develop and issue
House Radon Hearings   specific guidance on the type of state programs and level of control it
Address Need for       believes is needed to provide homeowners with adequate assurance that
More Uniformity        their radon measurements are accurate.
Among States           At these same hearings the Deputy Administrator, EPA, testified that EPA
                       plans to design a model state certification program to assist states in

                       ‘Key Elementsof a StateRadonProgram,EPA520/l-88-006,Office of Radiationprqqams.



                       Page 23                                                 GAO/RCJD9WN9 Radon Testing
Page 25   GAO/RCRD-90-209Radon Testing
Appendix II

Summ~ of Responsesto QuestionsAsked in
GAO’s Telephone Survey of State
Radon Programs
              1. Please enter your name:




              2. Please enter state m:



              3. Please enter respondent’s name:




              4. Hello, my name is #l of the U.S. General Accounting Office. GAO is an
              independent audit agency that works for Congress. We have been asked
              by the House Committee on Science, Space, and Technology to examine
              the accuracy of radon measurements. As part of that effort, we are sur-
              veying state radon program coordinators to determine the status of
              state radon programs. I would like to ask you some questions about your
              state’s program. The questions generally take about 20 minutes to
              answer. Is this a convenient time for you?

              5. The following questions refer to the status of your state radon
              program.

              6. Has your state passed any radon legislation? (Check only one answer.)

              a. Yes 14 (FL, IL, IN, IA, MD, NB, NH, NJ, NY, PA, RI, TN, VA, WI)
              b. No 37

              7. Does your state have any pending radon legislation? (Check only one
              answer.)

              a. Yes 10 (CA, DE, DC, GA, ME, MA, NJ, OH, PA, WA)
              b.No 41



              Page 27                                         GAO/RclZXM@2#9Radon Testing
Appendix II
summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon Programs




15. Please describe other distribution techniques:




16. Does your state currently provide a list of proficient radon measure-
ment companies to consumers? (Check only one answer.)

a. Yes            48
b. r\;o           3
c. Had in the past 0

17. Does your state currently distribute any other radon brochures/pub-
lications to homeowners? (Prompt for what kinds.) (Check only one
answer.)

a. Yes            49
b. No              2
c. Had in the past 0

18. Is your state currently running TV, radio, or print ads on radon?
(Check only one answer.)

a. Yes               3
b. No              41
c. Had in the past - 7

 19. Is your state currently using any other outreach methods to provide
 consumers with information about radon? (Check only one answer.)

 a. Yes (Go to question 20.) 32
 b. No (Go to question 2 1.) 19

 20. Please explain:




 Page 29                                         GAO/RCED-90209Radon Testing
Appendix II
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon Programs




25. Does your program for radon measurement firms include on-site
inspection of primary measurement companies? (Check only one
answer.)

a. Yes                 4
b. No                -c,
( Not applicable 42

26. Does your progr,un for radon measurement firms include blind-
testing of companies;‘? ( Cheek only one answer.)

a. Yes              I
b. No              h
c. Not applicable 4L’

27. Does your program include radon training for measurement compa-
nies‘? (Check only OIW;Inswer.)

a. Yes              -1
b. No               1
c. Not applicable 4:!

28. Does your state r~bquirclradon measurement firms to participate in
EPA'S RMP testing pr-1)gram and/or a state-run testing program? (Check
only one answer. )

a. EPA'SRMPOnly                        6
b. State program only                  0
c. Either EP.4or stale Ixogram        ??
d. Both EPA and star (’ 1 rograms      0
e. Iiot applicable                    42

29. Are radon meahur‘cmrnt (companies participating in your program
required to calibrar v I llelr rquipmvnt periodically? (Check only one
answer.)

a. Yes                 r3
b. No                  ii
c. Not applicable     1:’




Page 31                                         GAO/RCED-90.209Radon Testing
Appendix II
summary of Responsesto Questions Asked in
GAO’s Telephone Survey of State
RadonPmgrams




35. Does your program have any other requirements? (Check only one
answer.)

a. Yes               4
b. No              -5
c. Not applicable -&?

36. Please explain:




37. Are radon measurement companies required to pay a fee to partici-
pate in your state program? (Check only one answer.)

a. Yes (Go to question 38) 3
b. No (Go to question 40) ??
c. Not applicable         42

38. What is the fee?




39. What time period does that cover? (Enter in months.)

40. Are radon measurement technicians and/or specialists required to
pay a fee to participate in your state program? (Check only one answer.)

a. Yes (Go to question 41.) 3
b. No (Go to question 43.) 3
c. Not applicable          -E




Page 33                                        GAO/RCED-9@209
                                                            Radon Testing
Appendix II
Summary of lt.espomesto Questions Asked In
GAO’sTelephone Survey of State
Radon Programs




47. How satisfied or dissatisfied are you with the technical guidance you
received from EPA? Would you say that you are:

a. Very satisfied                      28
b. Somewhat satisfied                 -il
c. Neither satisfied nor dissatisfied     2
d. Somewhat dissatisfied              - 2
e. Very dissatisfied                      0
f. Not applicable                      77
(Check only one answer.)              -

48. Are there any other types of assistance your state has received from
EPA? (Check only one answer.)

a. No (Go to question 50.) 10
b. Yes (Please explain.)   2-l
                           -
49. How satisfied or dissatisfied were you with that assistance? (Check
only one answer.)

a. Very satisfied                             32
b. Somewhat satisfied                         -3
c. Neither satisfied nor dissatisfied         3
d. Somewhat dissatisfied                         1
e. Very dissatisfied                             1
f. Not applicable                            -lo
50. Overall, how satisfied or dissatisfied are you with the assistance you
have received from EPA? (Check only one answer.)

a. Very satisfied                                    28
b. Somewhat satisfied                                19
c. Neither satisfied nor dissatisfied                  3
d. Somewhat dissatisfied                             Ti
e. Very dissatisfied                                 a
f. Not applicable (If no assistance provided)        7

 51. Are there any types of assistance not currently provided by EPA that
 would be helpful to your state? (Check only one answer.)

 a. No                    19
 b. Yes (Please explain.) 32



 Page 36                                              GAO/RCJXH@209Radon Testing
Appendix U
summaly Of Besponsesto Question.9Asked in
GAO’sTelephone Survey of State
Radon Progralns




56. How important do you believe it is for a program to include blind
testing of radon companies by outside parties? (Check only one answer.)

a. Very important                             41
b. Somewhat important                         3
c. Neither important nor unimportant          7
d. Somewhat unimportant                     73
e. Very unimportant                           -6
f. Don’t know                                --6
57. How important do you believe it is for a program to include on-site
inspections of radon measurement companies? (Check only one answer.)

a. Very important                             15
b. Somewhat important                        28
c. Neither important nor unimportant         ?i
d. Somewhat unimportant                     -7
e. Very unimportant                           0
f. Don’t know                                -6
                                             -
58. How important do you believe it is for a program to make profi-
ciency testing of new primary companies available year round? (Check
only one answer.)

a. Very important                             22
b. Somewhat important                         zl
c. Neither important nor unimportant          3
d. Somewhat unimportant                          6
e. Very unimportant                           7i
f. Don’t know                                --i
 59. How important do you believe it is for a program to require periodic
 retesting of proficient primary companies? (Check only one answer.)

 a. Very important                           35
 b. Somewhat important                       E
 c. Neither important nor unimportant        -l
 d. Somewhat unimportant                        0
 e. Very unimportant                         -6
 f. Don’t know                               3
                                             -




 Page 37                                             GAO/acnrsa-Zos Radon Testing
Appmlix U
Summary of Responsesto Questions Asked in
GAO’s Telephone Survey of State
Radon Programs




64. Are there any other elements that you believe are important to
include in a radon certification program? (Check only one answer.)

a. No (Go to question 66.) 32
b. Yes                     19

65. Please describe any elements you believe should be included:




66. Next, I want to ask a few questions about some other areas that
might be a part of a radon program.

67. How important do you believe it is that EPA act as a radon informa-
tion clearinghouse for the states? (Check only one answer.)

a. Very important                             36
b. Somewhat important                         13
c. Neither important nor unimportant        -3
d. Somewhat unimportant                         0
e. Very unimportant                           T
f. Don’t know                                -0
68. How important do you believe it is to have guidelines for radon mea-
surement in real estate transactions? (Check only one answer.)

a. Very important                            33
b. Somewhat important                        E
c. Neither important nor unimportant         3
d. Somewhat unimportant                        3
e. Very unimportant                          3
f. Don’t know                                r




 Page 39                                            GAO/RCED9O-209Radon Testing
Appendix III

Major Contributors to This Report


     c
Resources,               William F. McGee, Assistant Director
Community, and           Larry A. Goldsmith, Evaluator-In-Charge
                         William H. Roach, Senior Evaluator
Economic                 Michelle A. Gambone, Social Science Analyst
Development Division,    Judy K. Pagano, Operations Research Analyst
Washington, D.C.         Michael E. Schiefelbein, Writer-Editor


                         Richard E. Schultz, Regional Assignment Manager
Philadelphia   Re@ona1   George G. Daugherty, Site Senior
Office                   Lisa A. DiChiara, Staff Evaluator
                         Margaret A. Klucsarits, Staff Evaluator




 (099469)                 Page 41                                      GAO/RCEB9@209Radon Testing
    Ordering   Information

    The fllt  five copies of each GAO report are free. Additional W&Y
    are $2 each. Orders should be sent to the following address, 71
    panied by a check or money order made out to the .Yhd
    of Documents, when necessary. Orders for 100 .~llrl\d=u*rJr+
    mailed to a single address are discounted 25 5;” ..-.

    U.S. General Accounting Office
    P.O. Box 6015
    Gaithersburg, MD 20877

    Orders may also be placed by u+ ! m&Q&y&&-     :


l
Appendix Il
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon Pmgnuns




69. How important do you believe it is to limit a company’s ability to
perform both testing and mitigation? (Check only one answer.)

a. Very important                           11
b. Somewhat important                        13
c. Neither important nor unimportant        13
d. Somewhat unimportant                      10
e. Very unimportant                           3
f. Don’t know                               r

70. Are there any other topics or issues regarding radon that you would
like to discuss?




Page40                                            GA0/RCED90209 Radon Testing
Appendix II
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon Programs




60. How often do you think this retesting should occur? (Short answer-
enter in months.)




61. How important do you believe it is for a program to require critical
radon measurement personnel to meet minimum educational require-
ments? (Check only one answer.)

a. Very important                           32
b. Somewhat important                        13
c. Neither important nor unimportant           4
d. Somewhat unimportant                        1
e. Very unimportant                         T
f. Don’t know                               -i

62. How important do you believe it is for a program to require critical
radon measurement company personnel to meet minimum experience
requirements? (Check only one answer.)

a. Very important                           25
b. Somewhat important                       22
c. Neither important nor unimportant          2
d. Somewhat unimportant                       2
e. Very unimportant                           0
f. Don’t know                               T

63. How important do you believe it is for a program to require radon
measurement companies to report homeowner test results to a govern-
ment office? (Check only one answer.)

a. Very important                            27
b. Somewhat important                       -is
c. Neither important nor unimportant              3
d Somewhat unimportant                            3
e. Very unimportant                               0
f. Don’t know                                     0



Page 33                                               GAO/RCRINWZO9Radon Testing
    Appendix II
    Summary of Responsesto Questions Asked in
    GAO’s Telephone Survey of State
    Radon Progmms




    52. Next, I’d like to read to you a list of elements for a certification pro-
    gram for companies providing radon measurement services. For each
    element, please tell me if you believe this element is important or unim-
    portant in establishing a program to assure homeowners that radon test
    results are accurate.

    53. How important do you believe it is that radon measurement compa-
    nies be tested for accuracy? (Check only one answer.)

    a. Very important                            48
    b. Somewhat important                        -2
    c. Neither important nor unimportant         3
    d. Somewhat unimportant                        1
    e. Very unimportant                          T
    f. Don’t know                               --3
    54. How important do you believe it is to require companies to periodi-
    cally calibrate their equipment using an independent laboratory? (Check
    only one answer.)

    a. Very important                            44
    b. Somewhat important                        -3
    c. Neither important nor unimportant         3
    d. Somewhat unimportant                         1
    e. Very unimportant                          3
    f. Don’t know                               --0
    55. How important do you believe it is for a program to have other
    quality assurance requirements for testing companies? For example:

9 Routine checks of equipment accuracy
l Record keeping, etc.
l Procedures to ensure that measurement equipment is operating prop-
  erly, etc.
  (Check only one answer.)

    a. Very important                           45
    b. Somewhat important                       3
    c. Neither important nor unimportant        0
    d. Somewhat unimportant                       0
    e. Very unimportant                         77
    f. Don’t know                               -6



    Page 36                                             GAO/RCRD-W263Radon TestinS
Appendix II
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon programa




41. What is the fee?




42. What time period does that cover? (Enter in months.)

43. Next, I’d like to ask you a few questions about assistance your state
might have received from EPA.

44. Has your state received any assistance from EPA to provide public
information, for example, Citizen’s Guide? (If no, ask: Did you request
any?) (Check only one answer.)

a. No, not requested               1
b. No, requested but not received 0
c. Yes                            50

45. How satisfied or dissatisfied are you with the assistance you
received from EPA with public information? Would you say that you are:

a. Very satisfied                     27
b. Somewhat satisfied                  19
c. Neither satisfied nor dissatisfied 2
d. Somewhat dissatisfied              -0
e. Very dissatisfied                  0
f. Not applicable                       1
(Check only one answer.)

 46. Has your state received any technical guidance from EPA, for
 example, providing standardized measurement protocols, etc.? (If no,
 ask: Did you request any?) (Check only one answer.)

 a. No, not requested              7
 b. No, requested but not received 1
 c. Yes                           43




 Page 34                                        GAO/RCED-90-209Radon Tczsting
    Appendix II
    Summary of Responsesto Questions Asked in
    GAO’sTelephone Survey of State
    Radon Programs




    30. Are radon measurement companies required to follow any other
    quality assurance procedures? For example:

l Routine checks of equipment accuracy
. Procedures to ensure that measurement equipment is operating properly
. Record keeping (Check only one answer.)

    a. Yes               5
    b. No              -;i
    c. Not applicable -42

    3 1. Are radon measurement companies required to meet minimum radon
    experience qualifications for critical personnel? (Check only one
    answer.)

    a. Yes               7
    b. No              -2
    c. Not applicable -42

    32. Are radon measurement companies required to meet minimum edu-
    cational requirements for critical personnel? (Check only one answer.)

    a. Yes               7
    b. No              3
    c. Not applicable -42

    33. Are radon measurement companies participating     in your program
    required to post a bond‘? (Check only one answer.)

    a. Yes                 1
    b. No                  8
    c. Not applicable -42

    34. Are radon measurement companies participating in your program
    required to submit radon test results to the state? (Check only one
    answer.)

    a. Yes (Request copy of reporting requirements)   6
    b. No                                           -3
    c. Not applicable                               42
                                                    -




    Page 32                                       GAO/RCED.90203Radon Testing
Appendix II
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon programs




21. Does your state currently certify, license, or accredit companies
which perform radon measurements in the state? (Check only one
answer.)

a. Yes (Go to question 23.) 9
b. No                      42

22. Do you foresee that your state will establish a radon certification
program for radon measurement firms in the near future? (Check only
one answer.)

a. Yes/within 1 year          6 (CT, IN, ME, NY, WV, WY)
b. Yes/within next 2 years 2 (AZ, DC, IL, OH)
c. Yes/within next 3 years 0
d. Yes/don’t know when     iij (GA, KS, MA, MN, MS, NH, NM,
                            - OK, UT, VT)
e. No                        22
f. Not applicable           -s
Please skip to question 43

23. Is your program:

a. Mandatory (Go to question 25.) 5
b. Voluntary (Go to question 25.) 2
c. Other                            0
d. Not applicable                 42
(Check only one answer.)

24. Please explain:




Page 30                                         GAO/RCED-90-203Radon Testing
Appendix II
Summary of Responsesto Questions Asked in
GAO’sTelephone Survey of State
Radon Program




8. Has your state designated any funds in this fiscal year to be spent on
a radon program‘? (Check only one answer.)

a. Yes                          18
b. No/part of department budget 14
c. No/no money spent on radon -19

9. What is the current funding level?

$          9      >

10. In your opinion, are radon levels in homes a problem in your state?
(Check only one answer.)

a. Yes             35
b. No          12 (AK, AR, AZ, DC, HI, IN, LA, MS, NC, OK,
               - SC, TX)
c. Do not know 4 (CA. NV, NH, SD)

11. I would like to ask you a few questions about some ways your state
might communicate with homeowners about radon.

12. Does your state currently have a radon hotline? (Check only one
answer.)

a. Yes              19
b. No               30
c. Had in the past -3

13. Does your state currently distribute EPA'S Citizen’s Guide for Radon?
(Check only one answer.)

 a. Yes 50
 b. No - 1

 14. Does your state distribute the Citizen’s Guide upon request or do you
 do direct mailings? (Check only one answer.)

 a. Request only (Go to question 16.)        44
 b. Direct mailing only (Go to question 16.) 3
 c. Both (Go to question 16.)                  6
 d. Other                                   3
 e. Not applicable                             1


 Page 28                                           GAO/RCED90.209Radon Testing
Confidence Intervals for Estimates in Chapter 2


                                     This information is reprinted from our October 1989 report. For a fuller
                                     explanation of our methodology see pages 12 and 13 of that report.
                                     Because we reviewed a statistical sample of companies, each estimate
                                     developed from the sample has a measurable precision. The precision of
                                     our statistical estimates are developed at the 95-percent confidence level
                                     and are shown as the lower and upper bounds of the 95-percent confi-
                                     dence interval (see table 1.1). This means that if we reviewed all of the
                                     companies in our universe, the results of such a review would lie
                                     between the lower and upper bounds of the confidence interval about 19
                                     times out of 20.

                                     We reviewed all eleven large primary companies in round-5 testing;
                                     therefore, no confidence interval is associated with our results for large
                                     companies. We reviewed a sample of small primary companies. Our
                                     sample estimates represent the 347 small primary companies in round 5.

Table 1.1:Confidence Intervals for
Estimates of Results for Small                                                                            Confidence limit (at
Companies                                                                                                  9bpercent level)
                                                                                                          Lower         Upper
                                     Description                                               Estimate   bound         bound
                                     Small companies that were marketinq devices that
                                     had not b&en tested                                                                    22
                                     Small comoanies that were marketlna devices that
                                     had falled kound-5 testing                        -__--         24       11            45
                                     Small companies that tested some of their devices
                                     in the RMP program and marketed other dewces
                                     that had not been tested In the RMP proqram                      3        1            17




                                     Page 26                                                    GAO/RCED-6@266
                                                                                                             Radon Testing
              Chapter 3
              States’ Monitoring of Radon Measurement
              Pinus Is Limited and Inconsistent




              their efforts. EPA expects to complete a draft of this document in the fall
              of 1990.


              As we recommended, states need guidance on the type of program and
Conclusions   level of control EPA believes is needed at the state level. It appears EPA
              has begun to meet this need with its plans to develop guidance on a
              model state certification program.




              Page 24                                          GAO/WED-91X209Radon Testing
                                             chapter3
                                             States’ Monitoring of Radon Measurement
                                             Firms Is LImited and Imomi&mt




                                             Coordinators in 20 states said a program may be established in the
                                             future. The remaining 22 coordinators said a program would probably
                                             not be established. Two reasons coordinators gave for not having a pro-
                                             gram were: a lack of funding or resources for indoor air problems in
                                             general, including radon, and a lack of legislative authority for such
                                             programs.


                                             Not only do states vary in whether or not they require mandatory par-
Requirements Among                           ticipation in their programs, but they also vary in the number and type
State Programs Differ                        of requirements in their programs. The result is that each program gives
                                             a different level of assurance to homeowners regarding the accuracy of
                                             measurements. For example, as table 3.1 shows, five of the nine pro-
                                             grams require companies to calibrate their equipment periodically and
                                             follow other quality assurance procedures. Four of nine programs pro-
                                             vide on-site inspection of measurement companies. The only require-
                                             ment common to all nine programs is for companies to participate in
                                             EPA’S HMP testing program and/or a similar state-run testing program.


Table 3.1: Comparison of State Proaram Reauirements
                                                                                   Mandatory program       Voluntary program
State program requirements                                                       FL PA DE VA         IA    NJ NS ND KY Total
Gmpanres required to participate rn EPA~&%‘%~g~or$~              and/ or
state-run testrng program                                                          x   x    x    x    x     x      x   x       x       9
Mrnrmum education required for crrtical company personnel                          X        X         x     x      x   x       x       7
Mrnimum radon experience requrred for crrtrcal personnel                           x   x    x         x     x      x           x       7
Companres required to submit radon test results                                    x   x    x         x     x                  X       6
sate program includes radon trainrna for measurement companies                     X                 x      x      x   x --L           5
Companies required to calrbrate%r%qurpment
                                      --~~       periodically                      x   x             x      r---               x       5
Other quality assurance procedures requrred, (1) routine checking of
equipment accuracy, (2) procedures to ensure that measurement equrpment
IS operating properly, and (3) record keeping                                      x   x              x      x                 x       5
State program calls for on-sate rnspectron                                         x   x              X                        x       4
Companies and radon specialists rewired to bay a fee                               x   x              X                                3
State program includes blrnd-testing of companres                                      X                                               1
                                                                                                          --__--                   -
Companies required to pos~bonb--           - - ----_--            -                                   X                                I


                                             Although in the survey we did not attempt to establish why some states
                                             had certain requirements and others did not, one reason may be the lack
                                             of guidance from EPA. For the most part, EPA has not defined the degree
                                             of control it wants states to exercise over measurement companies. EPA
                                             believed that the nature of the radon problem varied from state to state



                                             Page 22                                                 GAO/RCEB90-209Radon T&ii
              Chapter2
              RMP Program Does Not Provide Adeqwb
              AssuranceThatRadonMeasurements
              Are Accurate




              participants in the RMP program to implement quality assurance pro-
              grams, and examining the feasibility of enrolling firms in the RMP pro-
              gram more than once a year. EPA did not take a position on requiring
              firms to pass the RMP program before marketing their instruments.

              EPA expects to begin to implement some quality assurance requirements
              and expand the double-blind testing in the fall of 1990 as part of the
              round 7 RMP testing. In a July 1990 meeting, EPA officials expressed con-
              cern about the costs associated with implementing effective quality
              assurance requirements. Officials noted that initial implementation may
              require extensive resources to carry out such activities as reviewing
              quality assurance plans and/or performing on-site inspection of compa-
              nies’ facilities. According to officials in order to manage these costs, it
              may be necessary to phase in quality assurance requirements over a
              2- to 3-year period.

              Finally, legislation was introduced in the House (H.R. 5138) on June 21,
              1990, that would require EPA to establish a mandatory radon measure-
              ment proficiency program as well as quality assurance requirements for
              those participating in the program.


               Homeowners need assurance that companies have demonstrated a min-
Conclusions    imum level of competency in measuring radon and that the measure-
               ment results provided to them have some degree of accuracy. That
               assurance does not exist, however, because firms are not required to
               participate in the RMP program before marketing radon measurement
               devices, and firms are not required to demonstrate the existence of ade-
               quate quality assurance programs. EPA'S plans to begin implementing
               quality assurance requirements for firms participating in the RMP testing
               is the first step in providing the necessary assurance. Further, author-
               izing EPA to require companies to pass the RMP program before marketing
               their devices would provide greater assurance to the public that radon
                measurements are accurate.




               page20                                           GAO/RCED-90209RadonTestii
                            chapter2
                            RMPProgrsmDoesNot
                                           ProvideAdequate
                            Assurance That Radon Measurements
                            Are Accurate




                            maintaining this performance and need to improve quality assurance.3
                            In 1989,14 or about 25 percent of the 55 company methods EPA double-
                            blind tested failed. Fifty-two of the 55 had demonstrated proficiency in
                            the announced test in 1988 or 1989. About 7 or 20 percent of those firms
                            that had demonstrated proficiency in 1988 and were providing radon
                            measurement services failed.

                                                      -
Not Requiring Quality       EPA’spolicy of not requiring measurement companies to implement
Assurance Is Inconsistent   quality assurance programs as a condition to participating in the RMP
                            program seems inconsistent with EPA’S agencywide quality assurance
With Agency Policy,         policy for EPA-sponsored environmental monitoring and measurement
Science Advisory Board      efforts. This policy requires every measurement project to have a
Recommendation, and         written and approved quality assurance plan and applies to all EPApro-
Other Laboratory            gram offices, regional offices, laboratories, contractors, and grantees.
Accreditation Programs
                            In addition, EPA’Sown Science Advisory Board has also recommended
                            that the agency require radon measurement companies to maintain doc-
                            umented quality assurance and measurement procedures for measure-
                            ment devices.’ Specifically, the Board recommended that both detailed
                            descriptions of calibration procedures and calibration data for certain
                            types of measurement devices be submitted with the application for
                            admission to the proficiency testing program.

                            Finally, other government accreditation programs generally require
                            some quality assurance procedures. For example, 19 out of 20 labora-
                            tory accreditation programs discussed in our March 1989 report
                            required equipment calibration, and 12 of the 20 programs included
                            record-keeping requirements.”




                            % double blind-testing EPA acquires devices without a company’s knowledge, exposes the devices to
                            hewn levels of radon and returns the devices to the company for analysis. If the company’s analysis
                            is accurate (within 25.percent of the known radon levels) it passes the proficiency test.

                            “The Science Advkxy Board is a group of independent saentists who review the quality and suffi
                            ciency of scientific data underlying regulatory development of some EPA actions

                            slaboratory Accreditation: Requirements Vary Throughout the Federal Government (GAO/
                                 D89-102, Mar. 28,1989).



                            Page18
                                   Chapter2
                                   RMPFVolpamDoesNotProtideAdequate
                                   Assurance That Radon Measurements
                                   Are Accurate




                                   results. In fact, in a few of the cases cited below it appeared the compa-
                                   nies may have been providing homeowners with inaccurate measure-
                                   ments. The following are cases we reported that illustrate the lack of
                                   controls in the RMP program.2

                           l One large company and an estimated seven small companies were mar-
                             keting devices that had not been tested in the RMP program.
                           . One device that was being marketed by one of the large radon measure-
                             ment companies did not meet the RMP program’s requirements.
                           . An estimated 24 small companies that failed the 1988 testing were mar-
                             keting devices.
                           l An estimated three small companies that tested some of their devices in
                             the RMP program had been marketing other devices that had not been
                             tested in the program.

                                   We also identified a company, not in our sample, that was analyzing
                                   devices in its laboratory under another name after it failed the profi-
                                   ciency test.


Industry Officials Agree           Officials from a sample of the radon testing industry generally agreed
That Measurement Firms             that all measurement companies should be required to demonstrate pro-
                                   ficiency in testing radon. Of the 32 officials we interviewed, 27 said par-
Should Be Required to              ticipation in the RMP program should be mandatory. Below are some of
Demonstrate Proficiency            the reasons industry gave for making participation mandatory.

                               . Radon health effects are severe enough to warrant obtaining assurance
                                 from companies that they are meeting the RMP requirements. Without
                                 mandatory participation, companies will not meet requirements.
                               l The public needs assurance that they are dealing with reputable firms,
                                 and the RMP program is the only means available to companies for dem-
                                 onstrating competence in measuring radon,
                               l The RMP program is the only independent check on a company’s ability
                                 to measure radon.

                                   Five officials said the program should remain voluntary. Their reasons
                                   included these two: the existing program is sufficient, and a mandatory
                                   program would make it more difficult to implement changes.


                                   ‘In our prior review, we sampled all 11 large primary companies (having 30 or more secondary com-
                                   panies) and 100 of the 347 small primary companies (having fewer than 30 secondary companies)
                                   that participated in the 1988 testing (small company sample results are given as estimates to the
                                   universe of 347). The sampling errors for the specific estimates are given in app. I.



                                    Page 16                                                       GAO/RCRD4O-2O9RadonTest~
Chapter 1
Introduction




                                                                      --
new interviews were conducted and added to the three pretest inter-
views. Thus, we obtained information from a total of 32 industry repre-
sentatives, including representatives of 3 government-affiliated
laboratories, 3 university-affiliated laboratories, and 26 commercial
firms. Because our sample was small, the information obtained from our
interviews reflects only the views of those interviewed and should not
be considered representative of the entire universe. Although no
attempt was made to include users of all nine measurement methods, the
sample did include primary laboratories representing all nine EPA-
approved measurement methods.

To determine the status of state radon programs, we conducted a tele-
phone survey of radon coordinators from all 50 states and the District of
Columbia. The survey obtained information on (1) the state radon pro-
grams that accredit, certify, or license companies and their require-
ments; (2) the coordinators’ views on the importance of elements in a
radon measurement certification program in providing homeowners
with assurance that radon measurements are accurate; and (3) states’
efforts to inform the public. Our survey instrument was pretested in
three states.

Our work was conducted at EPA’S headquarters, Washington, DC.; and at
EPA’S RMP program contractor, the Research Triangle Institute, in
Research Triangle Park, North Carolina. The audit work was performed
between June 1989 and March 1990 and followed generally accepted
government auditing standards. We discussed the factual material in the
report with agency officials, who generally agreed that it was accurate,
and have included their comments where appropriate. However, as
requested, we did not obtain official agency comments on the report.




Page 14                                        GAO/RCED90209 Radon Testing
                        Chapter1
                        Introduction




                        firms passing its proficiency test in national reports that are distributed
                        throughout the country and in individual state reports that states
                        distribute.

                        Since 1986 EPA has assessed companies’ competency in measuring radon
                        on six occasions. The number of firms demonstrating proficiency
                        through the RMP program has grown dramatically. For example, about
                        24 firms demonstrated proficiency in EPA'S first test, held in 1986, while
                        about 660 firms were listed in EPA'S latest proficiency report, issued in
                        January 1990. Of the 660 firms, EPA lists about 260 as national
                        companies.


                        In 1985, when EPA began designing its programs for radon, it did not
Radon Legislation       have specific legislative authority. Since that time, two pertinent laws
                        have been enacted. The Superfund Amendments and Reauthorization
                        Act of 1986 requires EPA to (1) conduct a national assessment of radon
                        to determine the extent of the problem and (2) establish a research and
                        development program that will address indoor pollution problems. EPA
                        expects to complete the national assessment in fiscal year 1991. EPA'S
                        research supports activities such as radon mitigation and prevention in
                        schools and workplaces, radon mitigation techniques for existing
                        housing, and radon mitigation techniques for new construction.

                        More recently, the Congress passed Public Law 100551, commonly
                        referred to as the Indoor Radon Abatement Act of 1988, which estab-
                        lished a national goal “that the air within buildings in the United States
                        should be as free of radon as the ambient air outside of buildings.” The
                        act directs EPA to undertake a variety of activities to address the radon
                        problem. A number of the activities, including the RMP program, were
                        already underway as part of EPA'S radon efforts. The act also authorized
                        EPA to develop a user-fee system to defray costs of certain activities,
                        including operating the proficiency program.


                        At the request of the Chairman, House Committee on Science, Space, and
Objectives, Scope,and   Technology, we reported in October 1989 on the uncertainty in radon
Methodology             measurements. On the basis of our findings the Chairman requested that
                        we conduct a follow-up review to determine (1) changes that can be
                        made in EPA'S RMP program to provide more assurance to homeowners
                        that radon measurements are accurate and (2) the status of state radon
                        programs that certify, license, or accredit radon measurement
                        companies.


                        page12                                            GAO/RCEDW2OSRadonTestii
                                          Chapter 1
                                          Introduction




Figure 1.1: Sources and Entry Routes of Indoor Radon




      Soil




                  I                                                                         \
                                                                Loos\    Fitting        Well Water
              Joints
                                                                Pipes                   SUPPlY


                                           Source Adapted from a report entltled Issue Backgrounder   Energy Effuent   New Homes &Indoor Av
                                           Pollutants, Elonnevllle Power Admrvstration



                                           Radon occurs naturally almost everywhere. Current estimates are that
Measuring Radon                            the average radon level in U.S. homes is about 1.5 picocuries of radon.
Levels                                     On the basis of its short-term screening surveys, EPA estimates that eight
                                           million, or about 10 percent, of the homes in the United States have
                                           annual radon levels above 4 picocuries. EPA recommends that everyone
                                           living in detached houses (including trailer homes with permanent foun-
                                           dations), townhouses or rowhouses, and first- or second-floor apart-
                                           ments should test for radon. EPA estimates that about 1.8 million homes
                                           have been tested for radon.

                                           Several different devices are available to measure radon in the home.
                                           Some, such as the popular charcoal canister, measure radon over 2 to 7
                                           days. Another popular device, the alpha track detector, measures radon
                                           for longer periods such as 3 months to a year. Both devices, which can
                                           be purchased from various retail outlets, must be sent to laboratories for
                                           analysis after being exposed to radon. Some more costly devices that



                                           Page 10                                                           GAO/RCED-90.209 Radon Testing
Introduction


                                          ---
                   Radon is a colorless, odorless gas formed by the decay of radium and
                   uranium. Radon is second only to smoking as a cause of lung cancer,
                   according to the Environmental Protection Agency (EPA). EPA and the
                   Public Health Service have advised residents to test their homes for
                   radon and take action when elevated levels are found. To help ensure
                   that the radon measurements homeowners obtain are accurate, EPA
                   issued procedures for taking such measurements and established a vol-
                   untary program for assessing the proficiency of radon measurement
                   devices and the capabilities of the companies that analyze these devices
                   after they have been exposed to radon.

                   In December 1988 the Chairman, House Committee on Science, Space,
                   and Technology asked us to examine the accuracy of the current
                   methods and practices used to measure radon and the assurance home-
                   owners have that measurements are accurate. In October 1989 we
                   reported that radon measurements contained uncertainty because (1)
                   radon devices and the companies analyzing the devices vary in their
                   levels of accuracy and (2) homeowners may not be following EPA’S rec-
                   ommended testing procedures. However, we said opportunities existed
                   through the RMP program to reduce some of the uncertainties and pro-
                   vide more assurance to homeowners that measurements are accurate.’

                   On the basis of our findings, the Chairman requested that we conduct a
                   follow-up review to determine (1) changes that can be made in the RMP
                   program to provide more assurance to homeowners that radon measure-
                   ments are accurate and (2) the status of state radon programs that cer-
                   tify, license, or accredit radon measurement companies.


                   Radon is a health concern because of the increased risk of lung cancer
Radon-A National   associated with exposure to it. Radon briefly remains a gas, and then it
Health Concern     breaks down, or decaays.into radioactive products that tend to adhere to
                   dust and other tiny particles floating in the air. When inhaled, these
                   radioactive particles can damage lung tissue. EPA estimates that about
                   20,000 lung cancer deaths each year in this country may be attributed to
                   radon.

                   In September 1988, on the basis of the results of radon screening mea-
                   surements in 17 states, the EPA Administrator and the Assistant Surgeon
                   General issued a national health advisory on radon, recommending that
                   most homes be tested and action be taken when elevated levels are

                   ‘Air pollution: Uncertainty Exists ITIRadonMeasurements(GAO/RCED-90-25,Oct. 16, 1989).



                   Page8                                                      GAO/RCED-90.209RadonTesting
Contents


Executive Summary                                                                                 2

Chapter 1                                                                                         8
Introduction            Radon-A National Health Concern
                        Sources of Indoor Radon
                                                                                                  8
                                                                                                  9
                        Measuring Radon Levels                                                   10
                        RMP Program                                                              11
                        Radon Legislation                                                        12
                        Objectives, Scope, and Methodology                                       12

Chapter 2                                                                                        16
RMP Program Does        Firms Market Devices Without Meeting RMP
                            Requirements
                                                                                                 16
Not Provide Adequate    RMP Program Does Not Require Measurement Companies                       17
Assurance That Radon        to Have Quality Assurance Programs
                        House Radon Hearings Address Need for More Quality                       19
Measurements Are            Assurance
Accurate                Conclusions                                                              20

Chapter 3                                                                                        21
States’ Monitoring of   Few States Establish Programs That Accredit, Certify, or
                            License Measurement Companies
                                                                                                 21
Radon Measurement       Requirements Among State Programs Differ                                 22
Firms Is Limited and    House Radon Hearings Address Need for More                               23
Inconsistent                Uniformity Among States
                        Conclusions                                                              24

Appendixes              Appendix I: Confidcnee Intervals for Estimates in                        26
                            Chapter 2
                        Appendix II: Summary of Re4ponses to Questions Asked                     27
                            in GAO’s Telephone Survey of State Radon Programs
                        Appendix III: Major Contributors to This Report                          41

Tables                  Table 3.1: Comparison of State Program Requirements                      22
                        Table I. 1: Confidence Intervals for Estimates of Results                26
                            for Small Companies

Figure                  Figure 1.1: Sources and Entry Routes of Indoor Radon                     10




                        Page 6                                          GAO/Rcnrso-Zos Radon Testing
                                ExecutiveSummary




RMP Program Does Not            Although EPA recommends certain quality assurance procedures for
                                radon measurement companies, the agency does not require companies
Require Measurement             to develop and implement such procedures as a condition for partici-
Companies to Have Quality       pating in the RMP program. As a result, GAO found that only 12 of 21
Assurance Programs              interviewed companies that participated in the 1988 testing were cali-
                                brating their equipment (an EPA recommended quality assurance proce-
                                dure). One of the nine companies that did not calibrate its equipment
                                failed the 1988 test with a loo-percent error but had been marketing its
                                equipment for a full year before the test. Also, EPA'S first efforts to test
                                radon measurement companies without their knowledge, called double-
                                blind testing, indicate that some firms are having difficulty providing
                                consistent and accurate measurements. For example, GAO found that 7
                                out of 36, or about 20 percent, of those firms that had demonstrated
                                 proficiency in 1988 and were double-blind tested in 1989 failed.

                                In addition, not requiring measurement companies to implement quality
                                assurance programs as a condition for participating in the RMP program
                                seems inconsistent with EPA'S own agencywide quality assurance policy
                                for EPA-sponsored environmental monitoring and measurement efforts.
                                This policy requires every measurement project to have a written and
                                approved quality assurance plan and applies to all EPAprogram offices,
                                regional offices, laboratories, contractors and grantees.

                                As in the case of mandatory participation, industry officials who test
                                radon also believe quality assurance should be required as a condition
                                for participating in the RMPprogram. Thirty-one of the 32 officials GAO
                                interviewed said some quality assurance needs to be required as a condi-
                                tion for participating in the RMPprogram.

                            -
States Monitoring of            It could take years for states to develop programs that help to ensure
Radon Measurement               the reliability, consistency, and quality of radon test data that compa-
                                nies provide to homeowners, according to GAO'S nationwide survey of
Companies Is Limited and        radon coordinators in 50 states and the District of Columbia. In some
Inconsistent                    states, there are no plans to develop such programs. Only nine states
                                have programs that either certify, license, or accredit radon measure-
                                ment companies, and only five of those have mandatory programs. An
                                additional 20 states may establish a program in the future, while the
                                remaining 22 state coordinators said their states probably would not
                                have a program. Two reasons given for not having a program were lack
                                of funding and lack of legislative authority. In addition, only five of the
                                nine states that have implemented programs have quality assurance
                                requirements for firms measuring radon.


                                 page4                                            GAO/RCED-90.209RadonTesting
Executive Summ~


                   The Environmental Protection Agency (EPA) estimates that 20,000 lung
Purpose            cancer deaths each year may be attributed to indoor radon. In 1986, to
                   help ensure that homeowners obtain accurate radon measurements, EPA
                   published procedures for taking radon measurements and established
                   the voluntary Radon Measurement Proficiency (RMP) program.

                   However, in October 1989, GAO reported to the Chairman, House Com-
                   mittee on Science. Space, and Technology that uncertainties exist in the
                   radon measurements homeowners use to make health-based decisions
                   (GAO/RCED-90-25). Because of GAO'S findings, the Chairman asked GAO to
                   conduct a follow-up review to determine (1) changes that can be made in
                   the RMP program to better assure homeowners that radon measurements
                   are accurate, and (2) the status of state radon programs that certify,
                   license, or accredit radon measurement companies.


                   Radon, a colorless, odorless gas formed by the decay of radium and ura-
Background         nium, occurs naturally almost everywhere, including in the average U.S.
                   home. Several different. devices can be used to measure radon in the
                   home over extended periods of time. Some of the devices, after being
                   exposed to radon, must be analyzed in laboratories to determine the
                   radon levels. Some more costly devices that require skilled operators,
                   such as the continuous radon monitor, can measure radon and provide
                   more immediate results without laboratory analysis. Companies that
                   provide the laboratory analysis or the more costly instruments and a
                   skilled operator are t.ested through the RMP program.

                   In establishing the RMP program EPA envisioned that it would be respon-
                   sible for testing the proficiency of firms, whose participation in the pro-
                   gram would be voluntary, and would encourage firms to adopt
                   procedures that would ensure the quality of measurement results. The
                   states, according to EPA officials, would determine any additional regula-
                   tion of firms, such as mandatory participation in the RMP program and
                   mandatory adoption of quality assurance programs.


                   Homeowners do not have adequate assurance that companies have
Results in Brief   demonstrated a mmimum level of competency in measuring radon and
                   that the test results provided to them have some degree of accuracy.
                   This is because the voluntary nature of the RMP program allows firms to
                   market devices that have not been tested or that failed the test. In addi-
                   tion, the RMP program does not require measurement companies to
                   implement qualit> assurance programs. GAO believes that two changes in


                   page2                                            GAO/RCED90-209RadonTesting