quality assurance plan for conducting radon measurements ... · web view☐ if the home has...

Instructions

This QA Plan template is intended for single family homes. If you do multifamily testing or schools and large buildings, additional information will be needed.

If you are using Radalink testing device or an electret ion chamber integrating device, please use a QA template specific to that device.

[Information in the [ ] brackets are instructions or places where your organization’s information should be inputted. Please check to ensure all [ ] are removed and that the document is personalized to how you and your company will operate.]

[Use as specific information as possible, including names of responsible individuals and procedures. The QA Plan is a "living document" that is frequently revised and referenced.]

[To edit headers and footers, put mouse over header or footer and double-click.]

[ O R G A N I Z A T I O N ’ S N A M E ] R A D O N M E A S U R E M E N T Q U A L I T Y A S S U R A N C E P L A N

Quality Assurance Plan For Conducting Radon Measurements

[Organization Name][Organization’s Street Address, City, State, Zip Code]

______________________________________Organization Owner’s or Responsible Party’s Signature

[Organization Owner’s Name or Other Responsible Party], [Title]

_____________________________________Quality Assurance Officer’s Signature

[Quality Assurance Officer’s Name], Quality Assurance Officer

[The QA Plan must be signed by the organization’s owner or responsible party and the QA Officer.]

The above signatures represent the awareness of, approval of, and commitment for carrying out this plan by all persons who have significant responsibility for ensuring that the provisions of this plan are implemented. Handwritten changes in this QA Plan may be used on a temporary basis, if they are initialed, dated, and the responsible officials initial and date their signatures on the signature page.

MDH Template V2.2

Date of original QA Plan--/--/-----

Date of Last Revision--/--/-----

Content

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sQuality Assurance Plan..................................................................................................................2

For Conducting Radon Measurements..........................................................................................2

1. Introduction........................................................................................................................5

Policy and Commitment.........................................................................................................5

Quality Assurance Plan Purpose............................................................................................5

Quality Assurance Goal and Objectives.................................................................................5

2. Organization........................................................................................................................5

3. Description of Operations...................................................................................................6

Duties of the Quality Assurance Officer.................................................................................6

Personnel and Subcontractor Qualifications..........................................................................7

Documents and Records........................................................................................................7

4. Measurement Procedures...................................................................................................7

Measurement Devices...........................................................................................................7

Measurement Standards of Practice......................................................................................8

Inform Client about Required Test Conditions.......................................................................8

Safety.....................................................................................................................................8

Test Conditions......................................................................................................................8

Performing Tests in Buildings with Multiple Foundation Types...........................................10

New Construction Test Conditions.......................................................................................10

Post-Mitigation Measurements...........................................................................................10

Measurement Placement.................................................................................................... 11

5. Data Collection, Validation, Reporting, and Entry and Retention.....................................11

Data Collection.....................................................................................................................11

Data Validation.................................................................................................................... 12

Data Reporting.....................................................................................................................12

6. Internal Quality Control....................................................................................................13

Commitment to Quality and Objective................................................................................13

Duplicates............................................................................................................................ 14

Routine Instrument Checks..................................................................................................14

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Blanks...................................................................................................................................15

Spikes...................................................................................................................................15

Calibration........................................................................................................................... 15

Crosschecks..........................................................................................................................16

7. Corrective Action...............................................................................................................16

8. Quality Assurance Training................................................................................................17

9. Quality Assurance Audits and Reports..............................................................................18

10. Definitions.....................................................................................................................18

11. References.....................................................................................................................22

Appendix A. Radon Test Notification Form(s)......................................................................25

Appendix B. Radon Test Placement and Retrieval Checklist................................................26

Appendix C. Radon Test Reporting Form.............................................................................30

Appendix D. Duplicates Control Log and Chart for All Devices............................................31

Appendix E. Blank Control Log and Chart for Passive Measurement Devices......................32

Appendix F. Spike Control Log and Chart for Passive Measurement Devices......................32

Appendix G. Crosscheck Control Log and Chart for Continuous Radon Monitors................32

Appendix H. Standard Operating Procedures......................................................................34

Appendix I. Internal Audit Checklist.....................................................................................35

Appendix J. Calibration Certificates or Logbook...................................................................37

[The table of contents is linked with headers in the plan and the page numbers and entries may be changed by clicking on the top right of the table.]

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1. Introduction Policy and CommitmentIn order to protect health and financial interests of building owners and occupants, it is the policy of our organization to provide accurate, reproducible, and valid measurements of indoor radon concentrations. Each measurement employee is individually and collectively committed to the highest quality work in accordance with this plan.

Quality Assurance Plan Purpose The purpose of this Quality Assurance (QA) Plan is to: set policies, performance goals, and objectives; identify responsibilities; establish procedures for assessing performance relative to quality; and to define corrective actions when needed.

It is important to recognize that usually quality assurance (QA) practices result not in the identification of out-of-control processes, but in the continued documentation of stable, within limits operations. Only with such documentation can the validity of measurement results be defended.

This QA Plan will be maintained and updated by [name, Owner] [or the name, QA Officer]. This QA plan will be revised with any adjustments [for example; modify as needed] involving changes of personnel and measurement devices as well as regulatory requirements or professional association recommendations. If there are no revisions triggering changes, this plan will be reviewed a minimum of annually.

Field Measurement Technicians and Support Staff listed in this document shall submit recommended changes to the Quality Assurance Officer.

Quality Assurance Goal and Objectives Our staff are committed to providing customers with accurate, valid, reproducible, and defensible radon measurements which may be used to make critical decisions about radiation-related environmental health.

The objectives of the QA plan are to maintain a quality measurement program and to document relative quality. In addition, a QA program adds greatly to an operators understanding of the methods they use and provides early detection of problems so that they can be rectified quickly and completely.

We collect evidence of the relative quality of our performance and evaluate that evidence through Quality Control (Section 6), take Corrective Action as needed (Section 7), and conduct Quality Assurance Audits (Section 9). A record of this evidence and resulting actions are maintained with those of this QA Plan.

2. Organization[Please complete section to reflect what type of company you work for, your service area and the type of testing you conduct.]

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[Organization Name] provides radon measurement services in [City, State] and in other communities within a [__] mile radius.

[Please complete section for the type of testing you do. Provide a list of staff that conduct radon testing. Provide company location and if you use a lab, the name and location of the lab.]

We perform measurements of radon concentrations for [residences, commercial buildings, and schools]. In general, the number of measurements performed ranges from [_] to [_] per month. The laboratory [and if different,] or office is located at [both addresses if different address].

Licensed radon professionals are responsible for our organization’s field radon measurements. [Name], President is responsible for all aspects of operations. [Name], Quality Assurance Officer is responsible to the President for all QA as related to field operations and for field measurements and data analysis.

The staff consists of :[modify those portions of the following as needed; the list should include the names of all individuals who have responsibilities to provide radon services; identify which individual has ultimate authority to stop unsafe, low quality or inadequate work.]

▪ [name], President and Owner, [if appropriate, NRPP certification and/or state license number]

▪ [if any, name], Measurement Quality Assurance Officer, [if appropriate, NRPP certification and/or state license number] [Note, if there is only one employee who is also the owner and sole-proprietor, that individual is the QA Officer and he or she is responsible for ALL aspects of the quality process]

▪ [name], Field Test Technician, [NRPP certification and/or state license number]▪ [name], Field Test Technician, [NRPP certification and/or state license number]▪ [name], Field Test Technician, [NRPP certification and/or state license number]▪ [name], Support Staff, [if appropriate, NRPP certification and/or state license number]

QA Plan was distributed to all personnel listed above.

3. Description of OperationsDuties of the Quality Assurance OfficerThe Quality Assurance Officer’s responsibilities are to:

▪ design, develop, and implement the Measurement QA Plan; ▪ document, review and update a written Measurement QA Plan and Standard Operating

Procedures (SOPs); ▪ ensure proper storage of radon measurement devices; ▪ design and present training to new employees and, on an annual basis, to all employees; ▪ oversee measurement device use including placement and retrieval; ▪ create and maintain QA records; ▪ prepare or oversee client test reports and to specify how they are distributed to clients;▪ manage and oversee quality control (QC) measures;▪ initiate QA audits; ▪ make recommendations on corrective action and to insure corrective action is carried out;

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▪ initiate QA audit reporting to management; and ▪ participate in all meetings regarding staffing, training, equipment, record keeping, and

changes in practices and procedures.

Personnel and Subcontractor QualificationsStaff members and/or contractors conducting radon measurement services are individually licensed as radon measurement professionals by Minnesota Department of Health (MDH). This includes anyone placing and/or retrieving testing devices. Records of all training are maintained for a minimum of three years.

Documents and RecordsAll records and documents are maintained so they are legible, retrievable, and protected from fire, water, theft, and deterioration for a minimum period of 3 years. Computer software and records are customized for our radon measurements and are routinely backed up to the cloud or a remote server. [If the data are stored on the hard drive of a computer, specify the name and model number of the computer as well as how these data are backed-up for example, data are also stored to the cloud and/or an external hard drive.]

Each individual radon professional shall submit their quarterly measurement data to MDH on the schedule outlined in the radon licensing rules:

▪ April 30 for the period of January 1 through March 31;▪ July 30 for the period of April 1 through June 30;▪ October 30 for the period of July 1 through September 30; and▪ January 30 for the period of October 1 through December 31 of the previous year.

4. Measurement ProceduresWe perform radon measurements in accordance with the instructions of the measurement device manufacture(s).

Measurement Devices The measurement devices used shall be listed for meeting the requirements of Minnesota state statutes and rules and be approved for use by the state and NRPP. The measurement devices are as follows: [fill out information for devices you use. Delete information on device types you do not use.]

▪ Continuous Radon Monitor[s] manufactured by [company name], [approximate number of monitors in service], [NRPP certification number].

▪ Activated Charcoal Adsorption (gamma-ray spectroscopy) Equilibrating Devices manufactured and analyzed by [laboratory name], [state license number].

▪ Liquid Scintillation (spectroscopy) Equilibrating Devices manufactured and analyzed by [laboratory name], [state license number].

▪ Alpha-track Integrating Detectors manufactured and analyzed by [laboratory name], [state license number].

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▪ Electret Ion Chamber Integrating Devices manufactured [if appropriate] and analyzed] by [laboratory name], [NRPP certification and/or state license number].

Further information about the above listed measurement devices and the manufacturer’s operating instructions are found in the Appendix J, Standard Operating Procedures.

Until use, radon measurement devices shall be stored in dry, low radon environments at temperatures ranging from 60 to 85OF.

Measurement Standards of PracticeOur company will follow the Minnesota Radon Licensing Act and Rules and the protocols and standards listed below [delete radon measurement protocols you do not use]:

▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products in Homes (ANSI/AARST MAH-2014) or successor ANSI/AARST standards, and test each unique foundation type;

▪ ANSI/AARST Standard: Protocol for Conducting Radon and Radon Decay Product Measurements in Multifamily Buildings (ANSI/AARST MAMF-2017) or successor ANSI/AARST standards;

▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products in Schools and Large Buildings (ANSI/AARST MALB-2014) or successor ANSI/AARST standards.

Inform Client about Required Test ConditionsWe will make reasonable efforts to, verbally and in writing, inform clients of required and recommended test conditions a minimum of 24 hours prior to the test as well as during the test (see “Required Test Conditions Notification” [Appendix A] and “Test in Progress Notification” [Appendix B)].

Each individual responsible for the property to be tested will be requested to sign a non-interference agreement that indicates knowledge of the testing conditions of this QAP and a willingness to cooperate in maintaining the required test conditions. If such an agreement cannot or will not be signed by the responsible individual(s), the licensed radon professional will indicate in the report why the signature was not obtained (see Appendix D).

SafetyThe licensed radon professional shall not enter any area or perform any test that would damage property or risk the professional’s own or another’s safety. If it is known that closed-house conditions are detrimental to the health of the occupants, then the radon survey using a short-term test shall not be done.

Test Conditions For radon measurement devices placed by [Organization Name] personnel, the tester will visually assess test conditions when deploying and when retrieving device(s) for (see Appendix C).

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Closed building conditions▪ Short-term measurements of two- or-three days in length, the property must have closed-

building conditions a minimum of 12-hours before the radon test begins. If closed house conditions were not met prior to or during the test, then this must be noted on the report.

▪ If closed house conditions were not met when test was activated, for a CRM▪ test period must be extended 12 hours; and▪ The average of the test results shall exclude the first 12 hours of the test.

▪ If closed house conditions were not met when test was activated, for a passive device, the test must be extended to at least 4 days or the test postponed.

Deviation from protocol - examples include:▪ Devices placed in locations that don’t meet minimum requirements of this standard and

the reason was unavoidable;▪ Observed noncompliance with or deviations from required conditions such as closed-

building conditions;▪ Observed deviation from a normal occupied temperature;▪ Changes in the detector’s placement, whether any seal has been altered or test interfered

with; and▪ Any observed anomalies in data produced by a CRM that in the test professional’s opinion

may indicate a deviation from testing protocols.

Mitigation system present/functional▪ If a mitigation system was observed, it must be noted and if it appeared to be operational.▪ If any temporary mitigation strategies were observed, this must be noted in the report.▪ It is okay to provide a statement in the report that the measurement company offers no

findings as to the proper operation of the mitigation system.

Air exchanger present▪ If a permanently installed ventilation system, such as a heat recovery ventilator or air-to-air

heat exchanger, is active during the test but ready access exists for deactivation or it functions intermittently, this must be noted in the report.

Description of building conditions or other temporary factors must be reported, examples include:▪ Short term tests should not be conducted when severe weather conditions are expected

according to the National Weather Service (unusually severe storms or periods of unusually high winds). If tests are conducted in severe weather conditions then it shall be noted in the test report.

▪ Condition of any permanent vents (i.e. open/closed) such as crawlspace vents.▪ Setting of forced-air HVAC system fan (on/auto/off).▪ The condition of active or passive air supplies to the building or to combustion appliances.▪ Any construction activities being done to the house that could affect radon levels.

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If the radon measurement is a long-term measurements of 90- days or more in duration, closed-building conditions need not be maintained prior to nor during the radon test. For long-term tests, it is recommended that at least half the test period should be during the season that the dwelling is most likely to be operated with closed-house conditions so that the results of the test are more accurate indicators of the yearly average.

Short term test periods should optimally collect at least 48 hours of valid sampling time. Deployment periods shall not be less than 46 hours. In addition, if a short-term test is longer than 2 days, whenever practical it is recommended, but not required, to terminate the test nominally at 24-hour increments to reflect day to night fluctuations in radon concentrations within a dwelling.

For continuous radon monitors, care should be taken to account for data that are produced before equilibrium conditions have been established in a flow-through cell. Generally, conditions stabilize after the first four hours. Measurements made prior to this time are probably low, and the first four hours of data may be discarded or incorporated into the result using system correction factors. If the first four hours of data from a 48-hour measurement are discarded, the remaining hours of data can be averaged and are sufficient to represent a two day measurement.

Performing Tests in Buildings with Multiple Foundation Types [You must state how you will test buildings with multiple foundation types.]

Minnesota Rules Section 4620.7500 requires a separate test be performed for each unique foundation type. “Foundation type” is defined as a basement, crawl space, slab-on-grade, or any other construction technique approved by local building code. The tests shall be performed at the same time so that they are done under the same testing conditions. Test results shall be reported individually and not averaged together. Multiple foundation buildings will be tested using [activated charcoal kits, multiple CRMs, a combination of CRMs and activated charcoal kits].

New Construction Test ConditionsNewly built homes are tested in accordance with this QA Plan. If the following items are part of the completed dwelling, they must be installed and completed before the radon test is initiated: all insulation, all exterior doors, all windows, all fireplaces and fireplace dampers, all heating appliances, all ceiling coverings, all interior surface materials on exterior walls and ceilings, all exterior siding, and weatherproofing and caulking. If testing personnel know construction work, which will likely affect the test results, is to be done inside the dwelling during the test period, the test must be scheduled during a time when such interference is less likely to take place.

Post-Mitigation MeasurementsA post-mitigation measurement is conducted to confirm the relative impact of mitigation. The post-mitigation measurement is a short-term test made in the same location(s) as the pre-mitigation test(s). The test must not be started sooner than 24-hours after the start-up of the radon mitigation system and within 30 days after the installation of the system. The test must

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have 24-hours of closed house conditions before the start of the test and closed house conditions during the test. In addition to the post-mitigation test, it must be recommended to the client that they test every two-years thereafter.

Measurement PlacementWe will place radon measurement devices in testing sites and under conditions in according with the Minnesota Radon Licensing Act and Rules and according to the protocols and standards listed above in Measurement Standards of Practice.

Devices placement will be selected with the following parameters:

▪ Within the general breathing zone;▪ At least 3 feet from exterior doors and windows;▪ At least 20 inches above the floor (optimal height less than 8 feet above the floor);▪ At least 12 inches from exterior walls;▪ At least 12 inches below the ceiling;▪ In a location where the detector is likely not to be disturbed;▪ Not inside a closet or cupboard;▪ Not inside a crawlspace, sumps or nooks within the building foundation;▪ Not in areas of high humidity such as basements, laundry rooms and kitchens;▪ Not near drafts;▪ Not near a heat source; and▪ Not on or near objects that may produce radiation such as natural stone.

5. Data Collection, Validation, Reporting, and Entry and Retention

Data Collection[Carefully read section. Fill out information on the device type(s) being used. Delete any device types not being used.]

Radon measurements collected by [Organization Name] are analyzed by [laboratory name] passive, time-integrated measurement device analytical laboratory. The report from the analytical laboratory are attached to each customer report and maintained in [Organization Name]’s database. The Lower Limit of Detection (LLD) of the [brand name and analytical laboratory number] is specified by the manufacturer as [_] pCi/L. [contact the laboratory’s technical staff for this information; the LLD is usually well below 1 pCi/L.]

Continuous Radon Monitors used by [Organization Name] produce print-outs of hourly and overall average radon test results. Except when client requests otherwise, the printouts are attached to each customer report and maintained in [Organization Name]’s data base.] If the hourly printout is not given in customer report, it will be available to customer for at least one year following the test. The Lower Limit of Detection (LLD) of the [brand name and model number] Continuous Radon Monitor is specified by the manufacturer as [_] pCi/L. [contact the monitor’s technical staff for this information; the LLD is usually well below 1 pCi/L.]

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Data ValidationValid data are produced when a measurement system, including storage, field deployment, transport, analysis, and reporting are operating “in control” and within QC limits and when in-control QC checks have been made both before and after a set of validated data. It is the responsibility of the qualified measurement professional to conduct, record, and make available the results of QC checks relevant to each reported result.

[For the paragraph below, please state what percent of records are reviewed by the QA officer vs. measurement technician. If you are the only measurement specialist and fill the role of QA officer, you must review 100% of the test results.]

Prior to reporting measurement results to the customer, [_] percent of radon measurement data are reviewed and, if valid, signed-off by the [Organization Name]’s [specify one] [QA Officer or Company President and Owner]. Validation factors include proofreading files to see that information entered into the computer from the test placement/retrieval checklist is correct. Any errors found during validation checks are documented including who made the errors, the dates of the errors, and how these errors were resolved.

Data ReportingThe measurement report shall include:

▪ The complete address of the test, including zip code;▪ The name and contact information for the person responsible for the test site;▪ The name and MDH licensing number of the person placing and the test device;▪ Exact location(s) of the detector(s) including level of home and exact room and location

within that room tested;▪ The name and MDH licensing number of the person retrieving the test device;▪ The start and stop, date and times for each measurement device;▪ The detector model or type and identification numbers;▪ The calibration date if using a CRM;▪ Radon Information Sources including state radon office and how to obtain federal or state

guidance documents;▪ The individual and average results of duplicate measurements;▪ Description of observed building conditions and other factors that are temporary in nature

and may affect the measurement results;▪ A statement that the test may not reflect the client’s risk from radon if such conditions are

altered from those existing during the test period;▪ Deviation from protocol; ▪ If a mitigation system was present; ▪ Recommendations, as shown sample reporting form in Exhibit F; and ▪ If applicable, whether the occupant or responsible party has agreed in writing to abide by

the closed house conditions twelve hours before the test and throughout the test period (Appendix D).

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The measurement report should describe the general limitations of the test such as the following statement:

▪ There can be uncertainty with any radon measurement due to statistical variations and other factors such as: daily and seasonal variations in radon concentrations; due to changes in the weather and operation of the dwelling; as well as possible interference with the necessary test conditions that could influence the results.

All test results include a statement, which recommends that the dwelling be re-tested in each of the following cases whether or not the dwelling has been mitigated:

If a new addition is added or significant renovation occurs; If a ground contact area was not previously tested is occupied or a home is newly occupied; If the home was unoccupied during the test, the home should be retested after occupancy; Heating or cooling systems are significantly altered resulting in changes to air pressures or

distribution; If occupied by a new owner; If ventilation is significantly altered by extensive weatherization, changes to mechanical sys-

tem or comparable procedures; If significant openings to the soil occur due to: Groundwater or slab surface water control systems (e.g. sumps, perimeter drain tile,

shower/tub retrofits, etc.) or, Natural settlement causing major cracks or penetrations occur in the home’s foundation

walls or slab; If significant nearby construction blasting, earthquakes or formation of sink holes nearby; If a mitigation system is altered, modified or repaired.

A sample reporting form is found in Appendix E.

6. Internal Quality Control Quality control refers to the technical activities that measure the attributes and performance of a process, item, or service against defined standards in order to verify that they meet established specifications, including documentation.

Commitment to Quality and Objective Our staff is committed to providing customers with accurate, valid, reproducible, and defensible radon measurements which may be used to make critical decisions about radiation-related environmental health. The due diligence of each employee and contractor involved with radon measurement is critical for achieving this goal.

A critical step to insure radon measurements meet nationally accepted quality standards is to conduct quality control (QC) measurements at prescribed rates and systematically over time. QC measurements shall be recorded [electronically or in a logbook; specify one] as soon as practicable, but no later than five working days after completion of measurements and shall be

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maintained for a minimum of three years. Failed QC measurements are repeated prior to investigation and corrective action.

A measurement system must operate in such a way as to produce repeatable and stable quality control results, including background for CRMs, crosschecks and duplicates for CRMs, and duplicates, spikes, and blanks for passive methods, as well as other method-specific checks.

[Note: use only the following sections that are relevant to the measurement devices you use, for example: blanks and spikes are applicable if you use passive integrating or equilibrating measurement device users while calibration and crosschecks are applicable to CRM users. Duplicates and routine instrument checks are required regardless of the type of device you use.]

Duplicates [Required for radon testing, regardless of the type of testing device used. If you only have one CRM, please state how you will conduct duplicates.]

Radon measurements, like all measurements, usually do not produce exactly the same results, even for simultaneous, co-located measurements. The objective of duplicate tests is to assess the precision error of the measurement method or, in other words, how well two side-by-side measurements agree or disagree.

Duplicate are two side-by-side measurement devices placed 4 to 8 inches apart or as specified by manufacturer that simultaneously measure radon.

All radon measurement devices used include randomly distributed duplicates deployed in the normal course of business across a variety of projects, operators, and environments at a rate of 10% of all measurement locations or 50 per month, whichever is less, and a minimum of three per year.

When possible, duplicates are made in environments where radon concentrations are greater than 4 pCi/L.

When duplicate measurements are made, the results are reported as such to the customer who receives the primary test. The individual results and the average of the two will be reported. In addition, results of duplicates are recorded on Duplicate Control Charts (see Appendix F).

When conducting a duplicate with a CRM, measurements are compared after the ramp-up period (if the CRMs have that capability).

Routine Instrument Checks[Required for radon testing, regardless of the type of testing device used. Delete information not relevant to your operation (i.e. if you only have CRMs, delete the passive device sentence.]

For passive, time-integrated measurement devices, checks include examining packaging upon both receipt and disbursement of the devices. For CRMs, performance checks involve using the manufacturer’s instructions for checking for proper working condition including checking battery voltage levels, cleaning screen inlet ports, and verifying that calibration is up-to-date. Performance checks will be made before every measurement.

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Blanks [For passive devices only]

Blanks are measurements performed to determine if the measurement device may have unintended exposure (background) during storage, handling and shipping. A blank is an unexposed measurement device that is opened, immediately closed and sealed, and, like an exposed measurement device, labelled with plausible start and stop dates and times, and then returned to the analytical laboratory. Blanks must be the same type, configuration, and from the same analytical laboratory as the other devices used by the provider. To facilitate problem investigations, it is important to track the environments that the measurement devices are stored, transported, and used.

Blanks are made at least monthly or otherwise at a rate of 5% of monthly measurements or 25 per month, whichever is less. The results of blank measurements are recorded on a Blank Control Chart (see Appendix G).

Blank test results should be less than the minimum detectable concentration of the passive measurement device. If background is detected with any blank, the analytical laboratory is immediately contacted.

[If charcoal radon measurement devices are used, state whether they are stored in monitored, low-humidity and low-radon environments. If not, storage blanks will be conducted at a rate of 5%.]

SpikesSpikes are also called known exposure measurements and are made to determine accuracy at a rate of 3/100 measurements, minimum of 3 per year, and a maximum of 6/month. Spike measurements are obtained from a spiking chamber that is certified by NRPP. The process involves: 1) sending an unused passive measurement device(s) to the NRPP approved chamber; and 2) then, after it is returned, sending the device to the device’s analytical laboratory.

Spiked devices must be the same type and configuration as those used by the measurement provider. In the event of an order of more than 50 passive measurement devices, at least one spiked measurement will be made before using the remaining devices as well as periodically over the course of the year.

The results of spiked measurements are recorded on a Spike Control Log and Chart (see Appendix H).

Calibration [For CRMs only]

Calibration refers to the process of determining the response of a measurement device to a series of known radon concentrations and making necessary adjustments to the device. Calibration is made every 12 months or after repair for each CRM by either, the monitor manufacturer or a national radon proficiency program approved calibration laboratory approved by the device manufacturer.

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Any monitor that does not have a calibration certification, dated within 12 months, must be removed from service.

In addition to calibration, an annual background check is performed by purging with clean aged air or nitrogen. The manufacturer or calibration laboratory completes this process at the time of calibration.

Calibration dates shall be [specify how you will track when machines are due for calibration such as record in logbook or calibration certificates for each CRM will be kept in appendix L].

Crosschecks[For CRMs only] [Crosschecks must be done using two CRMs. If you only have one device, please state how you will conduct crosschecks (e.g. borrow/rent/buy another device).]

Crosschecks are conducted to determine bias and are made every 5 to 7 months after a CRM has been calibrated. For at least 48 hours, the CRM past calibration by 5 to 7 months (designated as CRM-1) is cross-checked with any CRM that has been calibrated within the past 12 months but not at the same time as CRM-1 (designated as CRM-2). This procedure is most effective when CRM 2 has been recently calibrated. When possible, a crosscheck is performed in an environment with radon concentrations that is about 4 pCi/L or greater.

When crosscheck measurements are made, the results are reported as such to the customer who receives the primary test. The individual results and the average of the two will be reported. In addition, the results of crosscheck measurements are recorded on a Crosscheck Control Log and Chart (see Appendix I).

7. Corrective ActionThis section specifies procedures and corrective action taken when: problems have been revealed by QC measures or internal QA audits; deviations from routine circumstances are found; and complaints or suggestions are received from customers or licensed radon professionals.

The QA Officer is responsible for assessing the potential impact or effects of problems on radon testing and initiating corrective action. To avoid problem recurrence, corrective action includes initiation of preventive actions. Documentation of your investigation and corrective action is an essential part of the QA plan. Having an unusual QC measurement is possibly acceptable, however, not investigating the issue defeats the whole purpose of the doing the test.

If there is a pattern of quality control measurements that is not within the expected range of results, then the system may be out of control and all results are questionable. When a QC measurement is in the warning level, there may be a potential problem and investigation is required. When a QC measurement is outside the control limit, the measurement system shall be subject to corrective action and probably recalibration.

Investigation includes communicating with MDH, instrument providers, the analysis laboratory and shippers (as relevant) to find and fix the cause of poor measurement performance, as well as thorough documentation of the problem, the solution and preventive action. Failed QC checks may indicate a problem with already-completed measurements, and corrective action in

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that case may include retesting environments where previous measurements are not defensible. Investigation records document how the results of QC checks were used to validate or invalidate measurements already conducted with that measurement system.

It is important to note that some failed QC results, especially those near the limits, may occur solely by chance and not be due to a correctible problem. This can be the case if the QC check is repeated and is within limits. In such cases, no corrective action is needed, but it shall be documented.

Important Duplicate Requirement: If one measurement is equal to or greater than 4 pCi/L and the other below, the higher result may not be twice or more than the other. Such measurements MUST be repeated. Examples are 2.0 and 4.1 or 1.9 and 4.0.

If blanks exceed the lower limit of detection, MDH and the analysis laboratory will be contacted to identify the cause of the problem. The remainder of the test kits will not be used until the problem is identified to determine if all of the kits have been contaminated. Necessary corrective actions will be taken as advised by the analysis laboratory and MDH.

If problems are found during internal audits or inspections, the QA Plan will be reviewed and staff will be trained on proper procedures. If deviations from proper procedures (e.g. detectors not returned within the time limit, house conditions, improperly returned devices, device tampering, and so on), this will be noted on the test report. The test will be considered invalid and the recommendation will be made to retest.

8. Quality Assurance Training The Quality Assurance (QA) Officer is responsible for reviewing and developing the training plans for all staff and the plans for retraining when procedures change. New staff shall receive QA training prior to conducting radon measurements. Adequate training is given high priority, since the implementation of this QA plan is dependent upon the staff’s understanding of its requirements. The training includes an emphasis on each employee’s ethical and legal responsibilities for reliable and valid measurement test results as well as reporting of those results.

Personnel are responsible for knowing everything in this QA Plan, which falls within their particular area of responsibility. This QA Plan is the principle source document for the QA procedures and protocols, which must be known and practiced by responsible company personnel.

The QA Officer provides each employee with a copy of this QA Plan in which the specific QA activities and responsibilities for that particular employee are clearly marked and indexed.

Prior to conducting radon measurements and at least annually thereafter, the QA Officer checks each involved employee’s knowledge and understanding of their QA duties and responsibilities as defined in this Plan. If, in the judgment of the QA Officer, an employee does not adequately understand his/her responsibilities, follow-up instructions and checks are carried out until acceptable understanding is demonstrated. The QA Officer notifies the employee’s supervisor of each check result and these results are given consideration in compensation and job advancement reviews.

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9. Quality Assurance Audits and Reports [An audit can be conducted by the owner, an employee such as the QA Officer, or an outside auditor. An audit should include a written report of findings, a written assessment of whether or not the QA Plan is achieving its goals, and suggestions for improving the program due to changes in technology, quality concepts, regulations or environmental conditions.]

QA Audits are formal, structured comprehensive and independent reviews to determine whether quality activities comply with planned arrangements and are suitable to achieve objectives.

The QA Officer conducts QA Audits every six months [otherwise monthly, bi-monthly or quarterly for larger volume measurement provider] and reports audit results in writing to the [Owner or Manager]. QA Audit Reports contain the following information about measurement data quality [modify as needed]: record keeping; results of duplicates, comparison checks, blank and spike test results; calibration completions; crosschecks; routine instrument checks; source check results; results of any additional audit steps; and revisions of the QA Plan; and corrective action needed and enacted. An example of an audit checklist is found in Appendix K.

All QA audit records are retained indefinitely.

10. Definitions▪ As Constant as Practicable: This term is defined by agreement between the provider of the

device(s) and the operator of the Standard Test Atmosphere for Radon (STAR; also known as a radon chamber), taking into consideration the inherent function of the device(s) and the design limitations and operational requirements of the STAR.

▪ Audit: A systematic and independent examination to determine whether quality activities and related results comply with planned arrangements and whether these arrangements are implemented effectively and are suitable to achieve objectives.

▪ Blind: A type of performance test of the analytical capability of a method in which a sample is not identified as a performance test to the analyst.

▪ Calibration Factor: That factor or function that represents the relationship between the method’s response and the concentration to which it is responding. The calibration relationship is the ratio of “rise,” or the response (dependent variable represented on the vertical axis), to the “run” of the concentration being analyzed (independent variable represented on the horizontal axis), and therefore, in all cases the calibration factor is based on measurement system response divided by the concentration to which it is responding.

▪ Coefficient of Variation (COV): The sample standard deviation (s) of a set of measurements expressed as a percentage of the arithmetic mean of the measurements; COV = 100 (s/mean).

▪ Collocation: Measurements conducted in which the inlet or diffusion area of every set of two separate devices is not closer than 4 inches (10 cm) and not further than 8 in (20 cm) in both the horizontal and vertical plane, and in the same room. The usual objective of collocation is to simultaneously measure the same radon concentration.

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▪ Continuous Radon Monitor (CRM): An electronic device that: (1) is capable of providing reviewable, numeric measurements of radon concentration averaged over time intervals of 1 hour or less; (2) has a minimum detectable concentration (MDC) of no greater than 4 pCi/L (148 Bq/m3) for a 1-hour measurement; and (3) has a calibration factor of at least 2 counts per hour per 37 Bq/m3 (2 cph per pCi/L or 0.054 counts per hour [cph] per Bq/m3).

▪ Corrective Action: Actions taken to identify and eliminate root causes of a problem, thus preventing their recurrence. It is important to note that some failed QC results, especially those near the limits, may occur solely by chance and not be due to a correctible problem. In such cases, a repeat of the QC check will meet the criteria for continued stable operation, and no corrective action may be needed. Investigation includes communicating with MDH, instrument providers, the analysis laboratory and shippers (as relevant) to find and fix the cause of poor measurement performance, as well as thorough documentation of the problem, the solution and preventive action. Failed QC checks may indicate a problem with already-completed measurements, and corrective action in that case may include retesting environments where previous measurements may be suspect. Corrective action records should indicate how the results of QC checks were used to validate or invalidate measurements already conducted with that measurement system.

▪ Data Validation: Valid data are produced when a measurement system, including storage, field deployment, transport, analysis, and reporting are operating “in control” and within (Quality Control (QC) limits and in-control QC checks have been made both before and after a set of validated data. It is the responsibility of the qualified measurement professional to conduct, record, and make available the results of QC checks relevant to each reported result. For example, if approximately 100 measurements are conducted each quarter with a single charcoal device configuration, there must be documented, within-limits QC results for at least five blanks, three spikes, ten duplicate pairs, and a record of exposure conditions during storage, both before and after the approximately 100 measurement results made during that quarter. The record of these satisfactory QC checks should be part of the quality system documentation and available to auditors.

▪ Equilibrating Method: This class of device employs a material such as activated charcoal that adsorbs radon from the air. During exposure to constant radon concentrations, temperatures, and humidity, a state of equilibrium is reached between the quantity of adsorbed radon and the concentration of radon in the surrounding air. Once equilibrium is established, radon may exchange between the charcoal and the air. Some of the adsorbed radon may be replaced by moisture from the air and, thus, the quantity of adsorbed radon may decrease after equilibrium is established. If the radon concentration, temperature, or humidity in the environment changes, the adsorption properties of the charcoal change, and radon may desorb so as to maintain the state of equilibrium.Moisture in the air competes with adsorption sites on the charcoal; therefore, less radon is adsorbed when the air contains more moisture (higher relative humidity). In addition, less radon is adsorbed by charcoal at higher temperatures.Therefore, devices using adsorption of radon by activated carbon are subject to effects of moisture and temperature. Device providers may need to consider such effects to meet the requirements of the standard. This class of device can provide a good representation of the average radon concentration during the exposure period as long as there are no large changes in the radon

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concentration during the exposure. Depending on the design of the device, its response may be significantly influenced by the radon concentration in the air during the last 12 hours or so of the exposure period. Because of the half-life of radon and the time, it takes for equilibrium to be established between the adsorbed radon and the radon concentration in the air, this class of device is typically limited to exposure durations from 2 to 7 days. Calibration of an equilibrating device is accomplished through exposures of representative sets of devices in a STAR for various time periods and under various controlled and monitored conditions of radon concentration, temperature and humidity.

▪ In Control: A measurement system operating in such a way as to produce repeatable and stable quality control results, including background for CRMs, crosschecks and comparison checks for CRMs, and duplicates, spikes, and blanks for passive methods, as well as other method-specific checks. This standard presents limits on QC results derived from industry statistics applicable to categories of measurement methods. Each measurement system can develop more restrictive limits than those presented here, based on their QC results, which should in all cases be derived using the method described in appendix XXX and documented. Until such time as a measurement system derives such limits from their own QC results, the limits presented in this standard can be applied to determine data validity.

▪ Lower Limit of Detection Counting Technology Methods (LLDCT): the smallest net count rate at which there is 95% confidence that a signal above background is detected. For the purpose of this standard, and for devices that rely on counting technology, the following equation is used (Currie, 1968):▪ LLDCT = [2.71/ts + 3.29(Rb/tb + Rb/ts)½] ▪ Where: LLDCT = Lower Limit of Detection (cpm) for counting technology methods▪ ts = Sample counting time (min)▪ Rb = Background or blank count rate (cpm)▪ tb = Background or blank counting time (min)

▪ Measurement System: All the components that are involved in the measurement of 222Rn concentration and that are part of the quality system, including the trained measurement professional and those assisting in data management, auditors, shippers, the analysis laboratory, and anyone else who is part of the system used routinely to provide valid measurement results. MS-PC: Performance Specifications for Instrumentation Systems Designed to Measure Radon Gas in Air, American National Standards Institute, 2015.

▪ Minimum Detectable Concentration (MDC): The lowest concentration that is detectable above background with 95% confidence. This concentration is derived from the LLD by applying the same factors that are used to convert the sample net count rate to radon concentration or integrated concentration. For a CRM, the LLD is divided by the calibration factor to obtain the MDC. For charcoal devices, the net count rate may be divided by factors that take into account such parameters as the adsorbed moisture, the duration of the exposure, the system counting calibration factor, and radioactive decay.

▪ Quality Assurance Plan: A Quality Assurance Plan is a formal document describing in comprehensive detail the necessary quality assurance policies, quality control procedures, and other technical activities that need to be implemented to ensure that the results of the work performed will satisfy the stated performance or acceptance criteria. The QAP should define objectives to be attained (for example, QC limits at various stages of the operations)

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and the responsibilities and authorities of personnel especially in regards to data quality and corrective action.

▪ Quality Control (QC): The technical activities that measures the attributes and performance of a process, item, or service against defined standards to verify that they meet established specifications, including documentation.

▪ Quality System: The overall management of an organization that establishes a quality policy and procedures to implement that policy, including documented policies, objectives, principles, organizational authority, responsibilities, accountability, and implementation plan of an organization for ensuring quality in its work processes and services (International Standards Organization [ISO] 9000:2000, 2.2.3). Quality system documentation will include the following elements: (1) organization and responsibilities, including accountability for the QC measurements and their documentation; (2) measurement, data review and reporting procedures; (3) procedures for ensuring measurement device and data custody tracking; (4) analytical procedures; (5) assessments (audits) and corrective action; and (6) Quality Assurance (QA) reporting. All six elements should be documented in a QA Plan and associated standard operating procedures.

▪ Percent Error (RPE): A statistic used to evaluate the difference between a measurement and the conventionally true value, which may be a more recently calibrated CRM or a chamber concentration. The RPE is the degree from which a single measured value (X) deviates from the conventionally true value (T). The RPE is calculated using the following equation and compared against QC limits. Although the equation uses the absolute value of the difference, it is important to note that if one measurement is consistently greater or less than the other, there may be a calibration difference between the two measurement systems that should be identified. ▪ RPE = absolute value [100 (X – T) / T] * 100▪ X = Measured value (Bq/m3, pCi/L, Bq-h/m3, or pCi-d/L)▪ T = Conventionally true value (in the same unit as X)

▪ Relative Percent Difference (RPD): A statistic used to evaluate the difference between two measurements when neither one can be assumed to be more accurate than the other. The RPD compares the difference between two measurements divided by their mean, which in this case is the best estimate of the true concentration. Note that a 14% RPD corresponds to a 10% COV for two measurements. RPD is always positive, as there is no reason to assume that one measurement is more accurate than the other, and RPD is used as an estimate of imprecision.▪ RPD = [(A - B) / mean] * 100, where ▪ A = the larger result, ▪ B = the smaller result, and mean = the average of the two results.

▪ Standard Test Atmosphere for Radon (STAR): A standard test atmosphere for radon (often called a “radon chamber”), sufficient in size and configuration, radon concentration range, and radon concentration controls such that: ▪ at least five simultaneous and independent measurements of radon concentration can

be conducted at the high and/or low limits of the ranges of radon concentration (e.g., in pCi/L) or integrated concentration (e.g., in pCi-d/L), during which time the conditions in the STAR are as constant as practicable;

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▪ the function of the devices being tested is their function for measuring radon concentration; temperature, relative humidity and radon concentration are recorded hourly or more frequently by devices with annual National institute of Standards and Technology (NIST)-traceable calibrations (or traceable as defined below) and documented uncertainty estimates;

▪ barometric pressure in the STAR at local conditions is recorded or otherwise available and included in exposure reports;

▪ temperature and relative humidity are controlled to within the limits of this standard for the particular test being conducted; and

▪ the uncertainty of the average radon concentration during the exposure period is calculated using methods recommended by NIST (NIST TN-1297), published and reported with each exposure.

The STAR is operated under a documented quality management system consistent with recognized international standards such as ISO 9001.

▪ Traceability: Property of the result of a measurement whereby it can be related to stated references, usually national or international standards, through an unbroken chain of comparisons all having stated uncertainties. The concept is often expressed by the adjective traceable. The unbroken chain of comparisons is called a traceability chain [VIM: 1993, 6.10].

▪ Warning Levels and Control Limits: Warning Levels are set at that deviation from ideal performance that would be expected to occur by chance only 5% of the time, and Control Limits are set at that deviation from ideal performance that would be expected to occur by chance only 1% of the time. This standard provides default warning levels based on industry practice that in control operations exhibit a 14% RPD for concentrations greater than or equal to 4 pCi/L, and a 25% RPD for concentrations between 2 and 4 pCi/L.

11. References

AARST/ANSI 2017 Protocols for Conducting Radon and Radon Decay Product Measurements in Multifamily Buildings, Fletcher, NC: American Association of Radon Scientists and Technologists.

AARST/ANSI 2014 Protocols for Conducting Radon and Radon Decay Product Measurements in Homes, Fletcher, NC: American Association of Radon Scientists and Technologists.

AARST/ANSI 2014 Protocols for Conducting Radon and Radon Decay Product Measurements in Schools and Large Buildings, Fletcher, NC: American Association of Radon Scientists and Technologists.

AARST/ANSI 2015 Performance Specifications for Instrumentation Systems Designed to Measure Radon Gas in Air (MS-PC), Fletcher, NC: American Association of Radon Scientists and Technologists.

AARST/ANSI 2018 Quality Assurance for Radon Measurement Systems, Hendersonville, NC: American Association of Radon Scientists and Technologists.

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Air Chek 2009a “QA and Quality Control Plan for the Measurement of Indoor Radon Concentrations in Ohio with ProChek Activated Charcoal Test Kits,” Mills River, NC: Air Chek, Inc.

Air Chek 2009b “QA and Quality Control Plan for the Measurement of Indoor Radon Concentrations with ProChek Activated Charcoal Test Kits,” Mills River, NC: Air Chek, Inc.

DEP 2015 Pennsylvania Radon Certification Forms and Information, Harrisburg, PA: Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection.

Femto-Tech 2008 “QA and Quality Control Plan for Measurement of Indoor Radon Concentrations with the Femto-Tech Model CRM-510 or CRM-510LP Continuous Monitor, Dayton, OH: Femto-Tech.

IEMA 2005 Radon QA Program Guidance, Springfield, IL: Illinois Department of Emergency Management.

ISO 2015 Quality Management Systems – Requirements, Geneva, Switzerland: International Standards Organization.

Nebraska Radon Program undated “QA Plan for Conducting Radon Measurements,” Lincoln, NE: Nebraska Health and Human Services.

New Jersey Radon Section 2014 “QA/QC Plan Review Checklist,” Trenton, NJ: Department of environmental Protection, Division of Environmental Safety and Health.

ODH 2012 “Frequently Asked Questions Concerning Radon Licensing,” Columbus, OH: Ohio Department of Health Radon Licensing Program.

Ronca-Battista, M and Brodhead, B (circa 1994) “AARST Model QA Plan,” Fletcher, NC: American Association of Radon Scientists and Technologists.

Steves, K 2013 “QA Plan Checklist for Measurement Technicians/Laboratories,” Topeka, KS: Kansas Department of Health and Environment.

Steves, K, Hannah, DS, Hart, D, Snook, J and Steen, S 2013 KDHE QA Plan for Conducting Radon Measurements, Topeka, KS: Kansas Department of Health and Environment.

US EPA 1992 Indoor Radon and Radon Decay Measurement Protocols (EPA-402-R-92-004), Washington, DC: U.S. Environmental Protection Agency.

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US EPA 1993 Protocols for Radon and Radon Decay Product Measurements in Homes (EPA-402-R-92-003), Washington, DC: U.S. Environmental Protection Agency.

US EPA 1997 National Radon Proficiency Program: Guidance on QA, Washington, DC: U.S. Environmental Protection Agency.

[Go through all Exhibits and Appendices to ensure items are attached and the forms you use are included or that the forms included are customized to how you will use them. If you cannot figure out how to attach a document, it can be uploaded as a separate attachment.]

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Appendix A. Radon Test Notification Forms[Insert the document(s) you will be using as notification of required test conditions prior to and during the radon test. A noninterference agreement is also required. You may have three separate forms for this or they may be combined into one. We recommend using the MDH Radon Test Notification Form which can be can be found at Licensing for Radon Measurement Professionals (https://www.health.state.mn.us/communities/environment/air/radon/measurementprof.html). If you cannot figure out how to add the form(s) to this document, it can be uploaded as a separate attachment.]

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https://www.health.state.mn.us/communities/environment/air/radon/measurementprof.html




Appendix B. Radon Test Placement and Retrieval Checklist

Placement Checklist☐ Address of test: ______________________________________________________________

☐ Contact name and phone number: _______________________________________________

☐ Has the required written test conditions notification been given?

☐ If the home has multiple foundation types such as basement, crawlspace, and slab-on-grade, it is necessary that a test be conducted in the living area above each foundation type (e.g. a livable basement would have the device placed in basement, for a crawlspace, the test device would be placed in the living space above the crawlspace).

☐ If the ground-contacted area of the home is greater than 2,000 sq. ft., an additional test device(s) is recommended.

☐ Is an additional testing device needed to perform a duplicate to comply with QC requirements?

☐ Obtain measurement device(s) for site to be tested and record each test device serial number:

Device #1___________________________________________Calibration Date ____/____/____



Inspect and document building/testing conditions

☐ Will the house be occupied during the test? Circle: Yes or No

☐ Are required test conditions observed when the measurement device is deployed? Yes / No

▪ If closed house conditions were not met prior to or during the test, then this must be noted on the report.

▪ If closed house conditions were not met when test was activated, for a CRM, the test could be postponed for 12 hours, or the test period must be extended 12 hours and the first 12 hours of the test shall be excluded from the average.

▪ If closed house conditions were not met when test was activated, for a passive device, the test must be extended to at least 4 days or the test postponed.

☐ Is a heat recovery ventilator or air-to-air heat exchanger installed in the building? Yes / No

☐ Is unit functional and properly maintained? Yes / No

☐ Does ready access exist for turning unit on/off? Yes / No

☐ Is unit set to operate during the test, and at what setting? Yes / No __________________

☐ Is a radon mitigation system installed in the building? Yes / No

☐ Does system appear to be functional? Yes / No

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☐ Is system on? Yes / No

☐ Are there any temporary mitigation strategies observed, including ____________________?

☐ Are there any unavoidable construction activities being done to the house that could possibly affect radon levels? Yes / No

Activities noted:________________________________

☐ Are there any unusually severe storms or periods of unusually high winds forecasted during the testing period. If so, testing at a different time should be considered.

Conditions noted/forecasted: ________________________

☐ Are there any permanent vents, such as crawlspace vents to the outside? Yes / No

☐ Position of the vents: Open / Closed

☐ Is there a forced-air HVAC system? Yes / No

☐ Fan setting: On/Auto/Off

☐ Condition of active or passive air supplies to the building or to combustion appliances. Supplies are: operating as intended / blocked

☐ If this is a real estate test, place the test device on the lowest level that may be used for occupancy whether the level is or is not finished. If this is a non-real estate test, place on lowest occupied level of the home. In case of multiple foundation types, more than one test device will be needed.

☐ Do not place the test device in drafts from heating or air conditioning vents or fans.

☐ Do not place the test device in closets, kitchen, bathroom, laundry room or other closed or high humidity areas. Bedrooms, living rooms, or dens are good testing locations.

☐ Either place the measurement device on a stable surface (but not on a stone surface) or, if called for in the device instructions, hang the device(s) at normal breathing level.

☐ Do not place the test device on or near heat sources nor in direct sunlight.

☐ Test under normal occupied temperature (65 to 80OF).

☐ Place the test device at least 20 inches above the floor or, if the device is to be suspended, [8 feet above the floor and a minimum of 12 inches below the ceiling.

☐ Place the test device at least 3 feet from windows or exterior doors or otherwise, a minimum of 12 inches from an exterior wall.

☐ Place the test device at least 4 inches from other objects.

☐ At the test location per device instructions, open the test device or start the CRM.

☐ Record start time and date below and, if appropriate, on the test device.

☐ Leave the testing in progress notice in a conspicuous location.

☐ Initiate any tamper resistant methods if used. Methods used: ________________________

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☐ Note exact test location (floor/room/location):____________________________________________________________

Date_______________ Time_______________ Name & MDH License #____________________

☐ Note any deviations from protocol and why it was unavoidable:

______________________________________________________________________________

______________________________________________________________________________

Retrieval Checklist☐ When the measurement device was retrieved, were required test conditions observed? Yes/ No

▪ If closed house conditions were not met when the test was retrieved, then it is recommended that the test results be considered invalid and another test be performed.

☐ If a heat recovery ventilator or air-to-air heat exchanger is present, was it operating? Yes / No

☐ If there is a forced-air HVAC system, is the fan setting the same as when the test device was placed? Yes / No

☐ If mitigation system present, was it on? Yes / No

☐ Note radon testing device location to determine if it had been moved or tampered with during the test.

☐ Any construction activities being done to the house that could possibly affect radon levels? Yes / No Activities noted:_______________________________________________________

☐ Were there any unusually severe storms or periods of unusually high winds during the testing period? Conditions noted/forecasted: ______________________________________________________________________________

☐ Are there any permanent vents, such as crawlspace vents to the outside? Yes / No

☐ Position of the vents: Open / Closed

☐ Note any deviations from protocol and why it was unavoidable: ______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

☐ Note radon testing device location to determine if it had been moved or tampered with during the test.

☐ End the test by turning off the CRM or reseal the measurement device.

☐ Record stop date and time below and, if appropriate, on the device.

Date_______________ Time_______________ Name & MDH License #____________________

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Return the measurement device(s) to the analytical laboratory as soon as practical. Activated charcoal adsorption devices must be returned to the analytical laboratory within 4 days.

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Appendix C. Radon Test Reporting Form[Attach the test report template you will use for reporting test results to customers. If you cannot figure out how to add the form to this document, it can be uploaded as a separate attachment.]

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[You must include a copy of the template you are using. It can be submitted either as an Excel spreadsheet or a printout of the template you are using. You may submit it as part of this document or upload it as a separate document. The MDH example that can be used can be found at Licensing for Radon Measurement Professionals (https://www.health.state.mn.us/communities/environment/air/radon/measurementprof.html)

Appendix D. Duplicates Control Log and Chart for All DevicesDevices are placed 4 to 8 inches from the primary measurement device to evaluate precision. Precision involving duplicates are calculated by using Relative Percent Difference (RPD). RPD is equal to the difference between the higher tests results minus the lower test result divided by the average of the two duplicate test results, which is then multiplied by 100. The RPD result is then compared to warning levels and control limits. The Warning Level is set at the deviation from ideal performance that would be expected to occur by chance only 5% of the time, and Control Limits are set at that deviation from ideal performance that would be expected to occur by chance only 1% of the time. The Warning Level indicates a potential problem, which should be investigated. The Control Level indicates that the measurement system should be subject to corrective action and probable recalibration.

The control and warning limits for duplicates are:

▪ at concentrations averaging less than 2 pCi/L, the control limit is 1 pCi/L, ▪ between 2 and 3.9 pCi/L,

▪ the warning level is 50% RPD [unless otherwise stated by the device manufacturer ]; ▪ the control limit is 67% RPD [unless otherwise stated by the device manufacturer ];

▪ 4 or more pCi/L, ▪ the warning level is 28% RPD [unless otherwise stated by the device manufacturer]; ▪ the control limit is 36% RPD [unless otherwise stated by the device manufacturer].

If within any 30-day period, precision errors are found that exceed control limits or if any two that exceed warning levels within a month, an investigation will be launched, if applicable, in consultation with the analytical laboratory and state authorities.

Select where duplicates will be recorded and what template you will be using.

Duplicates will be recorded in a separate [workbook or logbook]. [Organization name] will be using [the MDH template for QC measurement or an in-house spreadsheet or provided by device manufacturer]

[The below is specific to MDH template]

There are three worksheets for calculating Relative Percent Difference (RPD):

▪ A1. for recording duplicates) averaging less than 2 pCi/L; ▪ A2. for recording and charting duplicates averaging between 2 and 4 pCi/L; and ▪ A3. for recording and charting duplicates averaging 4 pCi/L or greater.

These worksheets reflect monitoring of measurement precision.

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Appendix E. Blank Control Log and Chart for Passive Measurement DevicesIf blank results are above the device’s minimum detection limit, it must be investigated.

Select where blanks will be recorded and what template you will be using.

Blanks will be recorded in a separate [workbook or logbook]. [Organization name] will be using [the MDH template for QC measurement or an in-house spreadsheet or provided by device manufacturer]

Appendix F. Spike Control Log and Chart for Passive Measurement DevicesRelative Percent Error (RPE) is calculated by subtracting the difference between the spiking chamber’s value and that obtained from the analytical laboratory with the difference divided by the spiking chamber’s value. The results are plotted on a control chart). The Warning Level, which indicates a potential problem, is when the RPE is greater than 28% RPE. The Control Limit is plus or minus 36%. RPE. If RPE exceeds plus or minus 36%, an investigation is initiated in consultation with the analytical laboratory and documented.

Select where spikes will be recorded and what template you will be using.

Spikes will be recorded in a separate [workbook or logbook]. [Organization name] will be using [the MDH template for QC measurement or an in-house spreadsheet or provided by device manufacturer]

Appendix G. Crosscheck Control Log and Chart for Continuous Radon Monitors The initial four hours of measurement data are deducted from the calculations [unless otherwise specified by the device manufacturer]. The warning and control limits for CRMs are a Relative Percent Errors (RPE) as follow:

Relative bias is calculated as the difference between the measured and the reference value divided by the reference value. To assess the results of crosschecked measurements over time, the results are plotted on a Means Control Chart . EPA 402-R-95-012, Guidance on Quality Assurance provides guidance on how to set warning and control limits. In general, the expectation is that the values of RPE fall between +10% and -10%, but the entire range of +20% to -20% is considered “in control.” Outside of +/-20% but inside +/-30% is the warning range and outside of +/-30% is the control limit. It is important to notice and document whether one result is consistently greater than or less than the other, because that is an indication that there may be a bias error, probably caused by calibration differences between the CRMs, and should be investigated.

Select where crosschecks will be recorded and what template you will be using.

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Crosschecks will be recorded in a separate [workbook or logbook]. [Organization name] will be using [the MDH template for QC measurement or an in-house spreadsheet or provided by device manufacturer].

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Appendix H. Standard Operating Procedures[Standard Operating Procedures (SOP) are written instructions for performing all tasks that affect measurement data quality including analytical and testing functions as well as chain of custody.]

[ Either a link to the manufacturer’s instructions must be included or the manufacturer’s instructions attached to this document or uploaded as a separate document to the application.]

[An SOP must be specific for each type of measurement device and model you use.]

[The SOP must include specific directions on how to use, operate, and/or analyze each device. Site or include a copy of the manual or instructions for brevity]

[You may develop your own SOP(s) or adapt SOPs from the device manufacturer.]

This Standard Operating Procedure (SOP) is written specifically for [device name and model number].

A simplified SOP follows: [modify as appropriate]

1) Upon receipt of any radon measurement device, inspect the device for damage and store the device(s) in a monitored low-humidity, low-radon environment.

2) Unless otherwise specified by the manufacturer, passive measurement devices shall have a maximum one-year shelf life when stored in their original containers and in the environment prescribed in #1.

3) Remove detector from storage and note the date and address of placement in chain-of-custody log.

4) Transport detector in passenger compartment of vehicle inside a case to avoid damage.

5) Enter the home and, if present, have initial discussion with client.

6) Perform a visual inspection to determine if required test conditions have been met, level of home for device placement, room to test, and location within that room. If required test conditions were not found at the scheduled deployment, the test shall be postponed until required conditions are met.

7) Place the measurement device in the desired location, noting in the file the level, location, date, time, and conditions as well as start or opening the test device. If required test conditions were not present at retrieval of the measurement device(s), the test shall be reported as not valid.

8) If the responsible party or occupant did not sign the voluntary compliance statement, this fact shall be noted on the test report (Appendix D) and record and, if possible, the reason for non-signature.

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Appendix I. Internal Audit ChecklistAudit Performed by: _____________________________________________ Date: __________

Audit Approved by: ______________________________________________ Date: __________

Item (QAP Section, Exhibit [E] or Appendix [A])

Observed Concerns Comments Correction Actions Done

Staff Distribution List Current (2)

Device List Current (4)

Measurement Procedures Current (4)

Pre-Test Notification Procedure Reviewed (4; E.A)

Testing in Progress Procedure Reviewed (4; E.B)

Test Placement/Retrieval Procedure Reviewed (4; E.C)

Voluntary Compliance Procedure Reviewed (4; E.D)

Detector Chain of Custody Procedure Reviewed (E.E)

Data Collection Current (5)

Data Validation Current (5)

Reporting Form & Procedure Reviewed (5; E.F)

Comparison Check/ Duplicates Current (6; A.A)

Routine Instrument Checks Current (6)

Blanks Current (6; A.B)

Spikes Current (6; A.C)

Crosschecks Current (6; A.D)

Standard Operating Procedures Current (A.E)

Calibration Current (6; A.G)

Instrument Checks Current (6)

QA Objectives, Audits & Reports Current (6 & 9)

Corrective Actions Current (7)

QA Training Current (8)

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Appendix J. Calibration Certificates or Logbook[For CRMs only. Delete if only use passive devices.]

[You may paste calibration certificates for each CRM you are using in logbooks (see section 5) or insert them following this cover sheet.]

[State how you are tracking when devices where calibrated and when they are due to be calibrated. Include an example of the logbook or the calibration certificates.]

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