Policy Manual. April 21,2015. National Radon Proficiency Program 2015

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1 Policy Manual April 21,2015 National Radon Proficiency Program 2015 AARST - National Radon Proficiency Program (NRPP) ~ Page 1

2 TABLE OF CONTENTS I. General Application 4 II. Residential Measurement Provider Certification 4 A. Requirements 4 B. Residential Measurement Provider, Standard Services 4 C. Residential Measurement, Standard and Analytical Services 5 D. New Applicants 5 E. Applicants Previously EPA Listed 6 III. Residential Mitigation Provider Certification 7 A. Definition 7 B. New Applicants 7 C. Applicants Previously EPA Listed 8 IV. Analytical Laboratory Certification 8 A. Definition 8 B. Application 9 C. Responsible Party 9 D. Renewals 9 V. Devices (For Analytical Services and Laboratories) 9 A. Groups 9 B. Fees 9 C. QA/QC 9 D. Calibrations 10 E. Performance Tests 10 VI. Exams 10 VII. Chambers 11 VIII. QA/QC 23 IX. Initial Training for Certification 23 A. Entry Level Courses 25 B. Tier I Residential Measurement Provider 25 C. Tier II Residential Measurement Provider 25 D. Device Training 26 E. Tier I Residential Mitigation 26 F. Course Guideline Specifics 26 G. Course Approvals 27 AARST - National Radon Proficiency Program (NRPP) ~ Page 2

3 X. Continuing Education 27 A. Guidelines 27 B. Approval for Continuing Education Courses 27 C. Application 27 XI. Fees 28 A. Policy 28 B. Residential Measurement Providers 28 C. Analytical Laboratory 28 XII. Grievances, Compliance Policies and Procedures A. Policy 29 B. NRPP COMPLIANCE MANAGER 30 C. COMPLAINT PROCESS 30 D. CATEGORIES OF COMPLAINT 31 E. ADMINISTRATIVE DECERTIFCATION OR DELISTING 35 F. REINSTATEMENT FOR SUSPENSIONS, REVOCATIONS OR DELISTING 35 G. COMPLIANCE FEE SCHEDULE 36 H. APPEAL PROCESS 36 XIII. New Credential Development 36 XIV. NRPP Policy Advisory Board 36 A. Duties 36 B. Members 37 C. Rules 37 D. Elections 38 XV. Technical And Scince Committee) 38 A. Definition 38 B. Duties 38 C. Members Error! Bookmark not defined. XVI. Support Staff A. Location and Contact 38 B. Duties 38 XVII. State or Regional Committees 39 A. Duties 39 B. Structure 39 XVIII. EPA Protocols and Other Standards 40 Appendix 41 AARST - National Radon Proficiency Program (NRPP) ~ Page 3

4 American Association of Radon Scientists and Technicians (AARST) National Radon Proficiency Program (NRPP) Policy Manual I. General Application A. All applicants must complete and submit an application with correct fees, documentation, and signatures. B. All applicants must read and sign the Code of Ethics, and agree to conduct business in accordance with the protocols established by the U.S. EPA, AARST, NRPP and states, and the quality assurance and quality control guidelines described therein. See Code of Ethics, page 42. C. Those certified by NRPP must use devices or services from a NRPP certified individual or firm. 1 II. Residential Measurement Provider Certification A. Requirements 2 1. Tier I a. Device location, home conditions, real estate protocols, interpretation and recommendations, health effects, mitigation, device overview b. Initial training, exam, device training c. Device performance test for field analytical devices 2. Tier II a. Large building and school surveys, in addition to Tier I b. Tier I training and exam c. Tier II training and exam, device training (if not taken for Tier I) d. Performance test for field analytical devices e. ER, CWLM, health large buildings, HVAC, more entry, diagnostics 3. Standardized measurement reporting forms shall be developed and mandatory for use by NRPP certified service providers Standardized QA/QC plans shall be required, however a three month window shall be allowed for submittal of said plans, from the time the standardized forms are available. 4 B. Residential Measurement Provider, Standard Services 5 1. Definition a. Places and retrieves devices in individual residences with measurement results provided by a Laboratory or a Measurement Provider, Analytical Services 1 As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board November Forms are currently under development and review, 01/00. 4 As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board April 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 4

5 b. Provides interpretation of results c. Provides general information about mitigation d. Operates under same QA/QC plan as the Analytical Services provider, if that Analytical Services provider provides the device. 2. Professional Requirements a. Take NRPP approved course b. Pass NRPP exam c. Receive adequate device specific instruction from provider and so certify. C. Residential Measurement, Standard and Analytical Services 6 1. Definition Provides all services of Residential Measurement Provider as well as analysis of data from device (EIC, CRM) 2. Professional Requirements a. Take NRPP approved course b. Pass NRPP exam c. Receive adequate device-specific instruction from provider and/or manufacturer and so certify d. Pass device performance test e. Have QA/QC plan f. Give device specific instruction to Residential Measurement Provider, Standard Services g. Performance tests required every two years. D. New Applicants 1. Standard Services a. A person holding the residential measurement credential is qualified to place, retrieve, and interpret the results of a measurement device analyzed by a NRPP certified Analytical Laboratory. The credential is for residential settings and is appropriate for individuals performing home inspection services. b. To attain this credential one must have attended a NRPP approved, entry level measurement course, and passed a NRPP radon measurement exam 7 within the previous 12 months. As of January 15, 2008, former listing in EPA s Radon Proficiency Program will no longer be accepted in lieu of completion of a 16-hour entry-level course and passage of the NRPP Measurement exam within the previous 12 months. 8 c. NRPP is accepting certification as a Measurement Provider in the states of Florida, New Jersey and Pennsylvania, in lieu of course and exam, provided applicant supplies a copy of current state certification. 6 As adopted by NEHA-NRPP Board April The EPA exams have not been available since the end of November As adopted by NEHA-NRPP May 2007 AARST - National Radon Proficiency Program (NRPP) ~ Page 5

6 Standard and Analytical Services a. A person holding the Standard and Analytical certification is qualified to place, retrieve, analyze, and interpret the results of a measurement device in the field. Those offering analytical services typically use continuous radon monitors (CRM), continuous working level monitors (CWLM) or electret ion chambers (EIC). b. To qualify for this certification, a person must meet the criteria for standard services as described above and: Submit and follow a QA/QC plan for the device(s) Provide proof of calibration(s) prior to use of all active device(s) used Pass an initial performance test for device within group used 9 E. Applicants Previously EPA Listed 1. Persons previously listed by the EPA as a Residential Measurement Service Provider shall be classified as a Tier I Residential Measurement Provider. (However, said EPA listing shall not qualify an individual for Tier II Measurement Provider.) If a person was EPA listed as a Residential Measurement Service Provider during calendar year 1998, he or she may apply for NRPP certification provided the person can demonstrate course attendance at some time and passage of the EPA exam after July 31, The applicant must also provide proof of acquiring 16 hours of continuing education or passing the NRPP Measurement Exam within 12 months previous to application If the applicant was EPA listed as a Residential Measurement Service Provider at some time, and can demonstrate course attendance but no exam passage after July 31, 1994, the applicant must pass the current NRPP measurement exam. 4. If the applicant was EPA listed as a Residential Measurement Service Provider prior to 1998, and cannot demonstrate course attendance but can provide proof of passing the exam after July 31, 1994, the applicant must take a NRPP approved entry-level measurement course. 5. If the person has never been EPA listed as a Residential Measurement Service Provider but can demonstrate attendance at a NRPP approved entry-level course, it is not necessary to re-take the entry-level course, however the person must pass the NRPP measurement exam. 6. Previous EPA listing as an Analytical Measurement Provider does not qualify an individual for the NRPP Residential Measurement certification. As of January 15, 2008, former listing in EPA s Radon Proficiency Program will no longer be accepted in lieu of completion of a 16-hour entry-level course and passage of the NRPP Measurement exam within the previous 12 months Applications have been processed during the initial phase of NRPP without performance tests, and applicants will be required to participate in such tests once the chambers are approved. 10 As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP May 2007 AARST - National Radon Proficiency Program (NRPP) ~ Page 6

7 III. A. Definition 14 Residential Mitigation Provider Certification 1. R-1 Residential Mitigation Provider a. Assesses the need for, designs and installs systems in existing and new single family dwellings, which reduce radon from the underlying soil. b. This credential includes: Sub-slab depressurization Soil pressurization Sub-membrane depressurization Crawl space depressurization Drain tile depressurization Sump depressurization Block wall depressurization Introductory comments about other techniques that influence interior air 2. R-2 Residential Mitigation Provider Meets all requirements for R-1 certification and is also qualified to use techniques which reduce radon and radon decay products through building ventilation systems, such as: Heat recovery ventilators Radon Decay Product (HEPAs) Shell pressurization B. New Applicants 1 To attain this credential one must have attended an NRPP approved, entry-level mitigation course, based on the following criteria: a. a two day (16 hr) Measurement Course is a PREREQUISITE REQUIREMENT (non exam necessary) in order to take the mitigation course and the mitigation course shall be at least twenty-four (24) hours of instruction, or b. a mitigation course shall be 32 hours of instruction including 8 hours of measurement content. (does not qualify student to take the measurement exam, and c. has passed an NRPP radon mitigation exam within the previous 12 months. 15 NRPP accepts previous EPA listing as a Residential Mitigation Service Provider 16 when combined with proof of acquiring 16 hours of continuing education or passing the NRPP Mitigation Exam within 12 months previous to application. 17 NRPP is accepting current certification, in good standing, as a Mitigation Provider in the states of Ohio, Illinois, Florida, Nebraska, Kansas, Maine, New Jersey, and Pennsylvania, 14 As adopted by NEHA-NRPP April As adopted by NRPP December 19, As adopted by NEHA-NRPP November As adopted by NEHA-NRPP Board October 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 7

8 in lieu of course and exam, provided applicant supplies a copy of current state certification. C. Applicants Previously EPA Listed NRPP accepts EPA listings as a Residential Mitigation Service Provider with end list dates in 1998 or when combined with proof of acquiring 16 hours of continuing education or passing the NRPP Mitigation Exam within 12 months previous to application. 19 If a person was EPA listed as a Residential Mitigation Service Provider prior to calendar year 1998, can demonstrate attendance at an entry-level course, and passed the EPA exam some time after July 31, 1994, he or she must either pass the current NRPP mitigation exam or obtain 16 hours of continuing education. If the applicant was EPA listed as a Residential Mitigation Service Provider prior to calendar year 1998, and can demonstrate course attendance but no exam passage after July 31, 1994, the applicant must pass the current NRPP mitigation exam. If the person has never been EPA listed as a Residential Mitigation Service Provider but can demonstrate attendance at an approved entry-level mitigation course, it is not necessary to re-take the entry-level course, however the person must pass the NRPP mitigation exam. Previous EPA listing as an Analytical Measurement Provider does not qualify an individual for the NRPP Residential Mitigation certification. As of January 15, 2008, former listing in EPA s Radon Proficiency Program will no longer be accepted in lieu of completion of a 24-hour entry-level 20 course and passage of the NRPP Mitigation exam within the previous 12 months. IV. Analytical Laboratory Certification A. Definition An Analytical Laboratory is an organization accredited to perform third party analysis of devices placed and retrieved by others. 2. Every Lab must identify a Responsible Party (see below) who is a NRPP certified Residential Measurement Provider and demonstrates sufficient device training or equivalent, and ensures that performance tests and QA/QC Plans are correctly maintained. 3. The Lab must pass device performance tests Performance tests are required every two years. 18 As adopted by NEHA-NRPP November As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board May As adopted by NEHA-NRPP Board April Applications have been processed during the initial phase of NRPP without performance tests, and applicants will be required to participate in such tests once the chambers are approved. AARST - National Radon Proficiency Program (NRPP) ~ Page 8

9 B. Application The Analytical Laboratory Certification is appropriate for firms that analyze radon and radon decay measurement devices on behalf of residential measurement providers and/or the public. The Analytical Laboratory credential is valid for two years. In addition to submitting a completed application, a Laboratory must: Submit and follow a quality assurance and quality control plan Provide proof of equipment calibration Pass an initial performance test for the device(s) If a Laboratory elects to increase the type of devices analyzed, it may do so for an additional fee, submission of a supplemental QA/QC plan, and passage of a performance test. C. Responsible Party A firm must identify an individual as the Responsible Party, designated to be responsible for quality assurance and quality control aspects of the operation of the laboratory. The Responsible Party must be NRPP certified as a residential radon measurement provider. 23 D. Renewals The Analytical Laboratory certification is renewable every two years. Laboratories must submit to performance tests as required, and must submit annual calibration information for all devices. No continuing education is required, except as necessary to maintain NRPP certification of the Responsible Party. V. Devices (For Analytical Services and Laboratories) A. Groups NRPP has grouped certain combinations of devices for an assessment of a single certification fee. See List of Device Groups, Appendix. B. Fees One fee is assessed per device group. Fees run concurrently with the basic NRPP residential measurement certification, for analytical services or as part of laboratory services. Please refer to page 28 for more information regarding fees. C. QA/QC One QA/QC plan is required for each measurement group, supplemented with calibration certificates for each device. A QA/QC plan that addresses each chamber and electret configuration must be submitted, and annual calibrations must be performed on each reader in service. 23 As adopted by NEHA-NRPP Board April 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 9

10 D. Calibrations Proof of calibration within the last twelve months must be submitted for each measurement device. The calibration date will represent the anniversary date by which future annual calibrations are to occur. The proof of calibration must show: Manufacturer name Model number Serial number Date of calibration Name of facility performing calibration Calibration results (e.g. efficiency) A document has been prepared that describes calibration requirements for radon measurement devices, according to device methodology. See Requirements for Radon Laboratories and Analytical Service Providers, page Error! Bookmark not defined.. E. Performance Tests The NRPP certifies radon chambers for blind performance testing. Analytical Laboratories and initial candidates using field analytical devices are required to submit devices for a blind test. Individuals applying for certification with new devices will be required (and have agreed to, by signing the new or renewal application) to submit devices for a performance test within a reasonable length of time after the chambers are fully accredited. Performance tests will be required on a biennial basis. VI. Exams A. Exam Security Security will follow current NRPP procedures. 2. Exams are to be in paper/pencil format or administered by LaserGrade, an independent computer-based testing company under contract to NRPP Paper/pencil exams utilize paper scan answer sheets to be graded by NRPP, with results posted on the NRPP Web site by ID number and mailed to examinee. 4. NRPP Proctor Agreement is standard basis for NRPP. 5. A single examinee may secure a suitable proctor and arrange for an exam if the examinee is more than 150 miles from a LaserGrade testing facility. A suitable proctor is defined as a government employee, certified librarian or university professor. The proctor may not be an employee, employer, relative, friend or neighbor of the examinee. Arrangements must be cleared in advance through the NRPP Support Office for paper/pencil exams. 6. Instructor may not see or handle the exam. Exams are shipped to independent proctors. 7. A supervisor or employer of the individual taking the exam may not administer exams. 24 As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board May 2007 AARST - National Radon Proficiency Program (NRPP) ~ Page 10

11 B. Exam Procedures 1. Standard a. Exams are issued in accordance with Exam Order Forms, which identify the Chief Examiner and establish a chain of command. b. Exams must be ordered two weeks in advance of exam date. c. Exams may be ordered and administered by any entry-level training provider. d. NRPP will make reasonable accommodations, in the context of offering NRPP exams, to be in accordance with and to maintain its commitment to meet the requirements of the American Disabilities Act (ADA). 26 e. Students having English as the second language may provide his or her own interpreter, however the interpreter must be certified [professional] interpreter and all costs must be borne by the exam taker. 27 VII. 2. Individual Students needing to re-take an exam will do so at a LaserGrade computer-based testing site unless an appropriate facility is more than 150 miles from the examinee s residence. In that instance, the student may use an independent proctor. 28 Independent proctors may not be an employee, employer, relative, friend or neighbor of the student. The proctor must fit into one of the following categories university professor, librarian or government employee. Arrangements must be cleared in advance through the NRPP Support Office for paper/pencil exams. Students utilizing LaserGrade, will make arrangements directly with that organization. Chambers The Purpose of this Document 29 This document is a set of guidelines that will be used to approve radon chambers wishing to become certified by NRPP as either: a) Radon Reference Chambers (secondary); or b) Tertiary Radon Chambers It is intended that the guidelines in this document set minimal standards, which are sufficient to ensure that chambers certified under its rubric will produce a product of high quality and have the confidence of the radon industry and related authorities. Limitations: This document is not intended to set guidelines for radon decay product chambers that are used exclusively for calibration of radon decay product measurement devices. This document is not intended to replace existing draft or completed criteria for the certification 26 As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board May As adopted by AARST-NRPP PAB September 28, 2014 AARST - National Radon Proficiency Program (NRPP) ~ Page 11

12 of radon decay product chambers. See Section 3.0 that follows (formerly Section 2.) Various documents exist and they should be used by NRPP s technical committees in the future, but these documents (for example, the IEC 45B/203/CDV "STAR" protocol, "Design Criteria and Performance Characteristics of Radon Chambers" by Andreas George and Nancy Bredhoff, and "Manual for the Radon Chamber Qualification (RCQ) Proficiency Program" by Jon A. Broadway) were not used, in whole or in part, in the writing of this protocol. 1.0 Radon Reference Chambers (secondary) Radon Reference Chambers (secondary) are facilities that, at a minimum, intercompare directly with the national reference. They are commonly referred to as "secondary" chambers since they represent facilities that are one generation away, in terms of traceability, to the national or international reference. The NRPP recognizes the national reference for radon gas (radon-222) to be that as established by the USEPA radon chambers. However, the NRPP retains the right to approve other reference sources in the event EPA's facilities are unavailable to allow chamber activities that are required by this protocol. Use of certified Radon Reference Chambers (secondary): Performance Testing: The quality associated with an NRPP certified Radon Reference Chamber is required for performance testing of NRPP certified labs and service providers (with analytical capabilities) that seek to obtain or maintain certification. Device Evaluations: This level of quality is also required by NRPP during final performance evaluations that can lead to NRPP approval or listing of a measurement system. Assessing Tertiary Chamber Quality (see Section 2): The quality associated with an NRPP certified Radon Reference Chamber is furthermore required by the NRPP during comparisons for assessing the quality of Tertiary Chambers that seek to obtain or maintain certification. This level of quality is often employed for other services that normally include, but are not limited to, spiking and calibration for quality control needs and evaluations of devices by manufacturers during product development. Unavailability of USEPA Chambers as a National Reference: In support of recommendations by the Technical and Science Committee of AARST (TASC), currently approved Secondary Chambers as of 10/29/2014 are deemed acceptable as the national reference on radon concentrations until such time as EPA or private entities are operational for methodologies that again secure a national AARST - National Radon Proficiency Program (NRPP) ~ Page 12

13 reference. This approval is extended to no later than October 31st, 2016 or until such time as national reference chamber or procedures is established. This approval is dependent upon: a) Intercomparisons between Secondary chambers that must occur no less frequently and within margins of acceptability as portrayed in the NRPP Chamber Protocol for intercomparisons with EPA. b) An uncertainty analysis is conducted by each chamber within the next year if not already existing. c) Prior to NRPP approval of any new applicant seeking approval as a Secondary Chamber and also approval for interim status as a surrogate for the national reference, the applicant/facility shall be subject to an audit conducted by NRPP staff or designated representatives. Evidence to be audited includes the applicant/facility's: quality assurance program; standard operating procedures; uncertainty analysis; and intercomparison data. Prior to NRPP approvals, the audit must conclude sufficient evidence exists to warrant such approvals. 1.1 Compliance with Regulations The chamber facility must provide the NRPP evidence that it complies with all applicable Federal, State and local regulations concerning the ownership of radioactive materials and the discharging of radon gas into the environment. A worker safety document must be available upon request to the NRPP if it is required by any of the regulating agencies. 1.2 Quality Assurance/Quality Control Plan and SOP The chamber facility must make available to the NRPP a Quality Assurance/Quality Control Plan which details the way in which the chamber routinely checks its own performance, the types of control charts or statistics it employs, and the mechanisms that are in place in the event that control charts or statistics indicate that corrective measures need to be taken. A list of the people and their responsibilities is also required. The chamber facility must make available to the NRPP standard operating procedures (SOPs) detailing its current procedures related to conducting performance tests. 1.3 Radon Source The radon source must be a shielded commercial radium-226 source from which the radon is bled off in a controlled fashion. Sources of radon consisting of soil, uranium mill tailings, phosphate tailings or similar materials are not considered acceptable for the purpose of these protocols. 1.4 Chamber Size and Quality of Design AARST - National Radon Proficiency Program (NRPP) ~ Page 13

14 Although a few radon chambers are large enough to walk inside, smaller chambers have proven reliable as long as the number and type of devices being spiked is commensurate with the volume of radon available for spiking. A minimum size of 50 cubic feet (1.4 m 3 ) is strongly recommended because of the propensity for large radon fluctuations when devices are put into or taken out of the chamber, and the very real possibility of some depletion of the radon inside the chamber because of passive diffusion or forced convection of radon from the chamber and into the device being spiked. There is no maximum size limit to the chamber volume As part of the facility's quality control plan, a method of verifying that the radon concentrations are homogeneous throughout the chamber is required. For assessing homogeneous conditions, the radon variations as measured by devices at locations within the chamber should not be larger than the variance otherwise found for the devices under ideal circumstances. For the purposes for measuring homogeneity, a 48-hour exposure is recommended As part of the facility's quality control plan, gamma radiation within the chamber must be assessed throughout the chamber and maintained at a minimum. The facility's quality control plan must ensure that gamma radiation does not interfere with measurement systems that monitor the chamber or the devices being analyzed. 1.5 Required Intercomparisons Regardless of any in-house calibrations or standards employed by the chamber to ascertain chamber values (NIST traceable or otherwise), all chambers shall conduct an intercomparison at least annually with an EPA facility or other facility approved by the NRPP. It is the results of this intercomparison that will be used by NRPP to ascertain the viability of the chamber, as described below Historically, at least one EPA facility has been available for the purposes of the intercomparisons. In the event EPA's facilities are unavailable, the NRPP retains the right to approve other reference sources. In such event, the current NRPP approved reference source shall apply for activities referred to herein regarding activities otherwise conducted by the EPA chamber facilities To conduct the actual intercomparison, four scintillation or Lucas cells (with a minimum volume of 200 ml) are delivered simultaneously to the EPA chamber or other approved reference source. A complete set of instructions on how to conduct the sampling shall accompany the cells. Also, any tubing, pumps, valves, connectors, etc., must be supplied by the private radon chamber For Radon Reference Chambers (secondary), the only devices allowed to be used for intercomparison purposes will be scintillation or Lucas cells as described above. Passive devices (such as detectors AARST - National Radon Proficiency Program (NRPP) ~ Page 14

15 containing charcoal, electret ion chambers and alpha-track detectors) do not have sufficient precision for this purpose. Some continuous radon monitors do have sufficient precision to be used as intercomparison devices, but the decision on which monitors could be used requires lengthy discussions by the technical board of NRPP, which have not yet occurred The four cells are exposed as simultaneously as possible to an identical radon concentration at the EPA facility. The cells are returned to the private chamber as quickly as possible and the EPA chamber informs the NRPP of the target radon concentration, including its estimate of total uncertainty at the 95% confidence level The private chamber personnel analyze the four cells and report the average and the standard deviation of each radon measurement to the NRPP. The NRPP compares the reported values to the EPA target value. A private chamber facility passes the intercomparison if the average of the four cells is within 10% of the EPA target value and every report measurement is within +/- 25% from the EPA target value. 1.6 Reference Systems and Monitoring Practices The radon in the chamber must be monitored and recorded continuously with a continuous radon monitor which has a precision which is as good, or better, than the precision of the device which is being exposed within the chamber at the time and is approved by the NRPP for this use. The continuous monitor must be able to provide hourly readings at the minimum Maintaining Traceability: As part of the facility's quality control plan, the continuous radon monitor (and other supplementary measurement systems) must be periodically analyzed compared to the measurement system used and values obtained from required intercomparisons (see 1.5). This periodic analysis is required to normalize and/or verify the continuous monitor s readings. It is preferred, but not required, that the analysis is conducted daily (e.g. at least one grab sample be taken daily with the results compared to the continuous monitor s output for the equivalent time period). If the radon chamber is being maintained at a constant value over a long time period, then a weekly analysis may be sufficient (e.g. one grab sample taken once a week as long as the chamber value is not varied during that week). AARST - National Radon Proficiency Program (NRPP) ~ Page 15

16 As supplementary systems are employed, the minimum frequency that an analysis must be made for comparing the continuous monitor to the measurement system(s) employed for intercomparisons is monthly. Information gained from the facility's quality control plan must support the minimum frequency that grab samples are conducted. 1.7 Control of Radon Concentrations The chamber must be able to be controlled in such a way as to allow the change in radon concentration in a controlled manner. The radon concentration must be able to be set as low as 4.0 pci/l and as high as 30 pci/l to allow for a variety of exposures. It is preferred, but not necessary, that the chamber be able to be set as high as one hundred pci/l to allow for relatively rapid exposure of long-term devices Once the radon concentration is set to a particular value, there shall be sufficient control of the radon source and/or chamber parameters to be able to maintain the new radon level consistently (defined as meaning that the coefficient of variation of the hourly measurements must be 10%, or less) over the exposure period for the particular device being tested. This does not preclude allowing the chamber operator to vary concentrations during exposures, as deemed appropriate, as long as the radon concentrations are monitored and accounted for or reconciled when reporting chamber exposures. 1.8 Environmental Controls The temperature of the chamber must be able to be maintained at room temperature (68 degrees to 72 degrees Fahrenheit) over the entire exposure period for the particular device being tested. The temperature of the chamber must be monitored continuously with an hourly recording device that must be calibrated in accordance with national standards or manufacturers recommendations and traceable to NIST standards. It is preferred, but not necessary, that the temperature of the chamber be controlled in such a manner as to allow a change in temperature when desired. This does not preclude allowing the chamber operator to vary temperature during exposures as deemed appropriate as long as the temperatures are monitored and the hourly data is available and accounted for or reconciled when reporting chamber exposures The humidity of the chamber must be constantly monitored and recorded at least hourly with a device that is calibrated in accordance with national standards or manufacturers recommendations and traceable to NIST standards. It is necessary that the chamber be able to maintain humidity conditions that reflect realistic (realworld) parameters. It is preferred, but not necessary, that the humidity inside the chamber be controlled in such a way as to allow the humidity to be varied at will and AARST - National Radon Proficiency Program (NRPP) ~ Page 16

17 maintained at any new level set for the duration of an exposure period (dependent upon the device being tested). This does not preclude allowing the chamber operator to vary humidity during exposures, as deemed appropriate, as long as humidity is monitored and the hourly data is available and accounted for or reconciled when reporting chamber exposures It is preferred, but not necessary, that the barometric pressure within the chamber be monitored and recorded at least daily. This information may be useful for correcting calculations involving measurement devices that are sensitive to atmospheric pressure. Barometric pressure data available from a nearby airport, corrected for the station pressure at the elevation of the chamber facility, may be used for this purpose Elevation of the chamber shall be included in reports for chamber exposures. 1.9 Business Practices Because of the potential conflict of interest, a company or individual which runs a private radon chamber shall not performance test any lab or device associated with that company. For example, a laboratory which sells charcoal canisters and also runs a radon chamber shall not use the radon chamber, even if it is certified by NRPP as a performance testing chamber, to performance test its own charcoal canisters. This does not preclude, of course, the chamber from running performance tests on test devices marketed by other companies or from using its chamber to calibrate its own devices Companies or individuals that run private radon chambers (which are certified by NRPP as performance testing chambers) and also manufacture, market or sell radon measurement devices, or have any financial interest in radon measurement devices, shall notify potential performance test customers (laboratories and/or measurement professionals with analytical capabilities) of the types of devices which the company manufactures, markets or sells or has a financial interest in. In this way, the potential customer (laboratory and/or measurement professionals with analytical capabilities) can decide whether it wishes to have its device performance tested by a possible business competitor As long as the EPA action level remains at 4.0 pci/l, it is expected that radon chambers certified by the NRPP will maintain radon concentrations of 4.0 pci/l or higher during performance tests. Except for performance tests of grab devices, the minimum exposure time for the performance testing of all devices will be 48 hours. The minimum exposure (in pci days/l) for a specific device is found by multiplying 4.0 pci/l times the minimum number of days the device can be deployed (as determined from the advertising or manufacturer s brochure accompanying the device). For example, for a device which is advertised as having a 91-day minimum exposure time, the minimum exposure in the chamber will be 4.0 pci/l multiplied AARST - National Radon Proficiency Program (NRPP) ~ Page 17

18 by 91 days, or 364 pci days/l. However, in no case will the exposure time be less than 48 hours, regardless of the radon concentration used. Further, if the device participant specifies a minimum exposure duration greater than 48 hours, the chamber facility should comply with that request if possible. For example, if the participant requests an exposure of no less than 12 days, the chamber facility may be able to comply. However, if the participant requests an exposure of no less than 6 months, the chamber facility likely is not able to comply Minimal educational and/or training standards should include a BS in Physical Science and applicable experience in radiation measurement for a chamber designer and for a chamber operator. The designer and operator shall have at least the training equivalent to that of a two day Radon Measurement Operator course as approved by NRPP. 2.0 Tertiary Radon Chambers Tertiary Radon Chambers are facilities that, at a minimum, intercompare with an accredited Radon Reference Chamber (secondary) as described in Section 1.0. The term "tertiary" therefore indicates an additional or third generation away, in terms of traceability, to the national reference. Use of certified Tertiary Radon Chambers: NRPP certified Tertiary Radon Chambers are used for many purposes including, but not limited to, initial evaluations of devices by manufacturers, spiking and calibration. 2.1 Compliance with Regulations (tertiary chambers): Tertiary chambers must comply with all provisions stipulated in Section Quality Assurance/Quality Control Plan and SOP (tertiary chambers): Tertiary chambers must comply with all provisions stipulated in Section Radon Source (tertiary chambers): For Tertiary chambers, a shielded commercial radium-226 source is recommended but other sources can be acceptable so long as the radon is bled off in a controlled fashion to ensure only radon-222 is present in the chamber. 2.4 Chamber Size and Quality of Design (tertiary chambers): Tertiary chambers must comply with all provisions stipulated in Section Required Intercomparisons (tertiary chambers): AARST - National Radon Proficiency Program (NRPP) ~ Page 18

19 Note: For the purpose of clarity, the term "Radon Reference Chamber" will be used below to indicate NRPP certified Radon Reference Chambers (secondary) Regardless of any in-house calibrations or standards employed by the chamber to ascertain chamber values (NIST traceable or otherwise), all chambers shall conduct an intercomparison with a Radon Reference Chamber at least annually. It is the results of this intercomparison that will be used by NRPP to ascertain the viability of the chamber, as described below The measurement system used to monitor concentrations within the Tertiary Chamber is exposed in the Radon Reference Chamber. The Radon Reference Chamber rccords the target radon concentration, including it's estimate of total uncertainty at the 95% confidence level The Tertiary Chamber personnel analyze the measurements taken and report the average and the standard deviation of each radon measurement to the Radon Reference Chamber. The Radon Reference Chamber renders a report that compares the Tertiary Chamber's reported values to the target values of the Radon Reference Chamber. Tertiary Chamber provides such reports to the NRPP as evidence of required intercomparisons. The report should include an estimate of total uncertainty for the Chamber's monitor or system, at the 95% confidence level. A Tertiary Chamber facility passes the intercomparison if the average of the measurements they report are within 15% of the Radon Reference Chamber target value. 2.6 Reference Systems and Monitoring Practices (tertiary chambers): The radon in the chamber must be monitored and recorded continuously with a continuous radon monitor which has a precision which is as good, or better, than the precision of the device which is being exposed within the chamber at the time and is approved by the NRPP for this use. The continuous monitor must be able to provide hourly readings at the minimum. 2.7 Control of Radon Concentrations (tertiary chambers): The tertiary chamber must be able to control the range of radon concentrations in accordance with Section Environmental Controls (tertiary chambers): Temperature: The temperature of the chamber must be able to be maintained at room temperature (68 degrees to 72 degrees Fahrenheit) over the entire exposure period for the particular device being tested. Tertiary chambers used to test or calibrate devices that are affected by temperature should monitor and record air temperature within the chamber in accordance with Section AARST - National Radon Proficiency Program (NRPP) ~ Page 19

20 2.8.2 Humidity: Tertiary chambers used to test or calibrate devices that are affected by humidity should monitor and record air humidity within the chamber in accordance with Section Other Environmental Factors: Tertiary chambers used to test or calibrate devices that are affected by barometric pressure, gamma radiation or elevation should monitor and record those environmental factors and provided, accounted for or reconciled when reporting chamber exposures. 3.0 Radon Decay Product Chambers 3.1 Compliance with Regulations The chamber must provide NRPP evidence that it complies with all applicable Federal, State and local regulations concerning the ownership of radioactive materials and the discharging of radon gas into the environment. A worker safety document must be provided if it is required by any of the above agencies. This document can be combined with the document required in section 1.1 if the chamber wishes to be certified in both radon and radon decay products. 3.2 Quality Assurance/Quality Control Plan and SOP The chamber must provide NRPP a Quality Assurance/Quality Control Plan which details the way in which the chamber routinely checks its own performance, the types of control charts or statistics it employs, and the mechanisms that are in place in the event that control charts or statistics indicate corrective measures need to be taken. A list of the people and their responsibilities is also required. This document can be combined with the document required in section 1.2 if the chamber wishes to be certified in both radon and radon decay products. The chamber must provide NRPP a standard operating plan (SOP) detailing its normal operating procedures. Any updates that the chamber makes to its SOP shall be forwarded to NRPP in a timely fashion. 3.3 Radon Decay Product Source The radon decay product source will be a shielded commercial radium source from which the radon is bled off in a controlled fashion. In no case may the radon source be soil gas because of the inherent difficulties with soil gas (it is difficult to control and has widely varying amounts of thoron (radon 220)). 3.4 Chamber Size Because of the propensity for radon decay products to plate out on the interior chamber walls, a minimum chamber volume of 125 cubic feet is required. 3.4 Environmental Controls The chamber must be able to be controlled in such a way as to allow the change in radon decay product concentration in a controlled manner. A particle generator is required. The particle generator must have some method of being controlled so that the secular equilibrium of the chamber can be set and maintained. AARST - National Radon Proficiency Program (NRPP) ~ Page 20

21 3.4.2 Once the radon decay product concentration is set to a particular value, there shall be sufficient control of the radon and particle source and/or chamber parameters to be able to maintain the new radon decay product concentration at a constant value (defined as meaning that the coefficient of variation of the hourly measurements must be 10% or less) over the exposure period for the particular device being tested It must be possible to maintain the temperature of the chamber at room temperature (68 degrees to 72 degrees Fahrenheit) over the entire exposure period for the particular device being tested. The temperature of the chamber must be monitored continuously with an hourly recording device. It is preferred, but not necessary, that the temperature of the chamber be controlled in such a manner as to allow a change in temperature when desired The humidity of the chamber must be constantly monitored and recorded at least hourly. It is necessary that the chamber be able to maintain humidity conditions that reflect realistic (real-world) parameters. It is preferred, but not necessary, that the humidity inside the chamber be controlled in such a way as to allow the humidity to be varied at will and maintained at any new level set for the duration of an exposure period (dependent upon the device being tested) It is preferred, but not necessary, that the barometric pressure within the chamber be monitored and recorded at least daily The radon decay product concentration in the chamber must be monitored continuously with a continuous working level monitor which has a precision comparable to the precision of the device which is being exposed within the chamber at the time. The continuous monitor must be able to provide hourly readings at the minimum Periodic grab samples must be taken to normalize or verify the continuous monitor s readings. It is required, that at least one grab sample be taken daily with the results compared to the continuous monitor s output for the equivalent time period The grab samples shall be taken with a minimum flow rate of 10 L/minute and a minimum filter size of 1 diameter. The flow rate needs to be measured accurately. The minimum sampling time for the grab sample is five minutes. Various counting regimes are allowed In order to calculate the counting efficiency of the detector used to analyze the grab sample, some kind of alpha-emitting standard using the same geometry as the filter is required. 3.5 Required Intercomparisons Regardless of any in-house calibrations or standards (NIST traceable or otherwise) employed by the chamber to ascertain chamber values, all chambers shall have an intercomparison with an EPA chamber at least annually. It is the results of this intercomparison that will be used by NRPP to ascertain the viability of the chamber, as described below At this time, it is expected that at least one chamber at the Radiation and Indoor Environment National Laboratory at Las Vegas will be available for the purposes of the AARST - National Radon Proficiency Program (NRPP) ~ Page 21

22 intercomparisons. Any costs involved will have to be borne by the private chambers using the Las Vegas facility To conduct the actual intercomparison, the chamber operator must take the radon decay product (RDP) grab sampling equipment to the EPA chamber and do the intercomparison in person. The same minimum characteristics which described an appropriate grab device in sections and apply Intercomparisons using RDP grabs require that four grabs are taken one after the other, while the target chamber (the EPA chamber) varies the working level concentration. Specifically, two RDP samples (grabs) are taken at one chamber value and two RDP samples (grabs) are taken at a second value. The EPA chamber will then inform NRPP of the two chamber concentrations, including their standard deviations The private chamber will analyze the four samples and report the four individual results to the group at NRPP which will be assigned the responsibility of comparing these four values to the two EPA chamber results. A private chamber will have passed the intercomparison if (a) the average of each pair of samples is within 10% of the corresponding target chamber value and (b) no individual sample is more than 25% from the corresponding chamber value. By EPA chamber value it is meant the radon decay product concentration, plus and minus 2 standard deviations, in WL, as determined by the EPA using whatever methodology for producing the radon decay products and for determining the concentrations they feel are appropriate. Note: the NRPP Technical committees may want to consider averaging the performance ratios (called Bias factors ) as discussed in the U.S. EPA s Manual for the Radon Chamber Qualification (RCQ) Proficiency Program, pages 3-17and 3-18, as an alternative to the passing indicators discussed above. 3.6 Business Practices Because of the potential conflict of interest, a company or an individual which runs a private radon decay product chamber shall not performance test any lab or device associated with that company. For example, a laboratory which sells continuous working level monitors and also runs a performance testing radon decay product chamber shall not use the chamber, even if it is certified by NRPP as a performance testing chamber, to performance test its own continuous working level monitor. This does not preclude, of course, the chamber from running performance tests on test devices manufactured by other companies or from using its chamber to calibrate its own equipment Companies which run private radon decay product chambers (which are certified by NRPP as performance testing chambers) and also manufacture, market or sell radon decay product measurement devices or have any financial interest in the selling or marketing of such devices, shall notify potential performance test customers (laboratories and/or measurement professionals with analytical capabilities) of the types of devices which the company manufactures, markets or sells or has a financial interest in. In this way, the potential customer (laboratory and/or measurement professional AARST - National Radon Proficiency Program (NRPP) ~ Page 22

23 with analytical capabilities) can decide if it wishes to have its device performance tested by a possible business competitor As long as the EPA action level remains at 4.0 pci/l, it is expected that EHA certified radon decay product chambers will maintain radon decay product concentrations of.02 WL or higher during performance tests. Except for performance tests of grab devices, the minimum exposure time for the performance testing of all devices will be 48 hours Minimal educational and/or training standards must be set by the NRPP Technical board for a chamber designer and for a chamber operator. In the interim, it is necessary that the designer and operator have at least the training equivalent to that of a two day Radon Measurement Operator course as offered by the National Radon Training Centers. VIII. QA/QC Certified individuals are required (and agree) to follow the EPA guidelines as described in Indoor Radon and Radon Decay Product Measurement Device Protocols, EPA 402-R , July 1992, and Protocols For Radon and Radon Decay Product Measurements in Homes, EPA 402-R , June The EPA QA/QC Guidelines are available through the EPA s Web site ( AARST NRPP places an emphasis on QA/QC procedures utilized during the course of conducting business (duplicates, blanks, spikes, etc.). Although performance testing is valuable, good QA/QC is necessary at all times. Simple Quality Assurance and Quality Control (QA/QC) plans are under development at this time. These will include methods for determining and reporting QA/QC results, by way of standard forms. Once available, certified individuals are given a reasonable period of time to complete and submit the NRPP QA/QC plans. During the interim, individuals must provide a copy of the latest QA/QC plan (if previously submitted to the U.S. EPA). IX. Initial Training for Certification NRPP is currently issuing interim approvals for training courses, based on EPA guidelines for course review and approvals. The Technical Review Board (TRB) has developed guidelines for training that have been approved by the NRPP Board. 30 A. Entry Level Courses Courses approved by the EPA at the time of its closure shall be granted interim approval by NRPP until such time as new credentials are developed, without being reviewed by the TRB, provided said courses are revised to reflect the elements of the NRPP NRPP will approve all courses. 30 As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board October Specifically adopted by NEHA-NRPP Board November 1998 AARST - National Radon Proficiency Program (NRPP) ~ Page 23

24 3. Training is required before sitting for an exam. 4. Approved NRPP courses are required as part of certification. 5. TRB will establish course criteria and detailed evaluations of initial courses. 6. NRPP Board ultimately approves courses. 7. Providers are subject to fees for course evaluations. 8. All methods of training (CD Rom, video, etc.) are eligible for evaluation. 33 However, existing (i.e. grandfathered) distance learning courses shall not be accepted as preparation for exams NRPP approved courses are not automatically approved if they become available in a different format (i.e., distance learning method) and must be reviewed for NRPP approval As adopted by NEHA-NRPP Board October 1999 and reaffirmed November As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board November 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 24

25 B. Tier I Residential Measurement Provider 36 Physics Health Effects Radon Entry Placement Protocols Device Overview Measurement Interpretation Radon in Water QA/QC Mitigation Tampering Reporting Forms Very basic Base on contents of Citizen s Guide and Home Buyer s and Seller s Guide Factors that effect variability (weather, wind, etc.) Entry components: convection, emanation, water, diffusion Base on EPA Protocols, locations, building conditions Passive and active Base on EPA Protocols Citizen s Guide and Home Buyer s and Seller s Guide Sampling only Simplified format: dupes, blanks, and spikes Basics of ASD Base on Consumer s Guide to Radon (Simple measurement questions shall be on exam 37 ) Use of NRPP forms 1. Working Level is to be covered in summary only, i.e., introduced and briefly described Device specific instruction should be obtained from a NRPP certified provider for each device used. C. Tier II Residential Measurement Provider 39 (Assumes individual has taken Tier I course) Physics Working levels and equilibrium factors (dynamic and secular) Health Effects Epidemiological studies, BEIR reports, interpretation of OSHA (WL) Radon Entry Factors that effect variability (weather, wind, etc.) Entry components: convection, emanation, water, diffusion Effects of HVAC systems, interpreting contributions Devices Grab RN, Grab WL, continuous radon, continuous WL Diagnostic measurements How devices operate and factors that influence their measurement Measurement interpretation Effects of environment, building conditions, HVAC, weather Radon in Water Sampling only but expanded discussion of mitigation techniques QA/QC Large building or multiple building surveys Statistical analysis Mitigation Overview of techniques in large building and WL reduction Reporting Methods Use of NRPP forms and methods for consolidating large survey data 36 As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board April As adopted by NEHA-NRPP Board October 1998 AARST - National Radon Proficiency Program (NRPP) ~ Page 25

26 D. Device Training 40 Device training shall be waived until courses are in place, but will be a requirement for subsequent renewals provided a three-month window is made available. 41 Device Operating Procedures Factors Influencing Device QA/QC Measurement Interpretation Tampering Reporting forms Relating device use to Protocols Environmental factors Means to recognize and correct problems Device checks Calibration requirements Methods for complying with QA/QC plan Use of NRPP simplified QA/QC plan Base on EPA Protocols, Citizen s Guide and Home Buyer s and Seller s Guide Means to detect interference Use of NRPP forms E. Tier I Residential Mitigation A two day (16 hr) Measurement Course is a PREREQUISITE REQUIREMENT 43 (non exam necessary) in order to take the mitigation course and the mitigation course shall be at least twenty-four (24) hours of instruction, OR 2. The mitigation course shall be 32 hours of instruction including 8 hours of measurement content. (does not qualify student to take the measurement exam) 3. Three day course with hands-on, not necessarily fixing a house as a demonstration project 4. Installation of ASD, applying vacuum to soil 5. Basic R3, R4 residential one and two family dwellings, residential care (duplex) 6. Eight hour CE requirements per year 7. Tier I measurement a prerequisite (eg four day course, no Tier I exam necessary) 8. Third party verification of results, with EPA listed device 9. Exam will include questions on measurement. F. Course Guideline Specifics The NRPP Board adopted the TRB specifications for Course Guideline Criteria for Tier I Residential Measurement Providers in November See Appendix. The NRPP Board adopted the TRB specifications for Course Guideline Criteria for Tier I Residential Mitigation Providers in November See Appendix. a two day (16 hr) Measurement Course is a PREREQUISITE REQUIREMENT (non exam necessary) in order to take the mitigation course and the mitigation course shall be at least twenty-four (24) hours of instruction, or 40 As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board November As considered by NEHA-NRPP Board October As Adopted NRPP, December 19, 2013 AARST - National Radon Proficiency Program (NRPP) ~ Page 26

27 the mitigation course shall be 32 hours of instruction including 8 hours of measurement content. (does not qualify student to take the measurement exam) G. Course Approvals Applications for course approvals are available. Please see Appendix. X. Continuing Education A. Guidelines Continuing Education is mandatory for all tiers. 2. Classroom and distance learning are acceptable options. 3. Wide range of course topic areas appropriate. 4. Committees decide on appropriate topics. 5. Individuals may petition for special consideration. 6. Decisions of approval are based upon agenda and/or general outline submission. 7. Approval may be sought by the course provider or the attendee. 8. Content of course is assessed, not the provider. 9. Fees may be charged for evaluation of CE courses. 10. Exam is not acceptable for CE, nor required. 11. No courses may be repeated within a three year period, except initial course (as designated by course number, may be repeatedfor CE once; C.E. course may be repeated once, as designated by course number 12. Courses for upper tier credential acceptable for CE. 13. Once in program, manufacturers courses may be used for CE. 14. Courses are not required to be a minimum length of four hours Continuing education courses should be developed along subject outlines developed by the TRB Some portion of the required continuing education hours will be in the form of refresher material, with the TRB to decide on course material and hours. 47 B. Approval for Continuing Education Courses NRPP has been issuing interim approval for continuing education (CE) courses based on EPA guidelines for course review and approvals. The Technical Review Board (TRB) will revisit the CE guidelines after criteria are in place for entry-level courses and certifications still under development. Category I Guidelines and approval documents, please refer to Appendix. Category II Guidelines and approval documents, please refer to Appendix. C. Application Renewal forms are mailed approximately 60 days before expiration date. 44 As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board October 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 27

28 Renewals are mailed for each certification, and must be submitted separately. Renewal Applications include instructions and individual continuing education status. Laboratory and Analytical Service renewals include current device status. Renewal Applications must be submitted in a timely manner. Applications are reviewed for completeness, and applicants are contacted if information is incomplete. Incomplete applications are returned to applicant if information is not provided within a reasonable time. Updated certification expiration dates are posted on the NRPP Web site, generally on a weekly basis. Certifications are posted by state of residence or physical business location. Please refer to sample renewal application in Appendix. XI. Fees A. Policy Fees are set by through business decisions made by the parent organization. A Board may recommend, may make fee recommendations to the AARST-NRPP, however final decision are with the Executive Director s Office of AARST,. B. Residential Measurement Providers 1. Standard Services a. New applications are $ for a two-year certification b. Renewal applications are $ for a two-year certification 2. Standard and Analytical Services a. A new application is $ as described under standard services, with each type of device (see discussion on Devices, page 9) assessed an additional $75.00 regardless of the amount of devices used within each group. b. Analytical Services run concurrently with the basic Standard Services certification. c. Devices may be added to an individual s existing measurement certification on a quarterly pro-rated basis. d. Service fees may be implemented. C. Analytical Laboratory 1. A new application for an Analytical Laboratory is $ for a two-year certification. 2. A renewal application for an Analytical Laboratory is $ for a two-year certification. 3. Lab certifications include the first methodology of device. Devices are grouped by type. See discussion on Devices, page Each additional device methodology is assessed $75.00 per group, to run concurrently with basic laboratory certification. Devices may be added on a quarterly, pro-rated basis. 5. The devices covered under the laboratory certification will appear on the measurement certification of the Responsible Party for that lab. a. The Responsible Party is classified as offering Standard and Analytical Services, by virtue of all devices covered by the associated laboratory. AARST - National Radon Proficiency Program (NRPP) ~ Page 28

29 b. The Responsible Party must maintain his or her NRPP Residential Measurement Certification, the cost of which is not included under the laboratory certification. D. Residential Mitigation Providers 1. New applications for Residential Mitigation Providers are $ for a two-year certification. 2. Renewal applications for Residential Mitigation Providers are $ for a two-year certification. 3. Service fees may be implemented. XII. Grievances, Compliance Policies and Procedures 48 Compliance with program requirements is an important aspect of the NRPP. Consumer confidence can only be maintained if the tenets and standards upon which the program is based are maintained. A. POLICY: 1. AARST-NRPP (NRPP) reserves the right to deny, revoke, sanction or suspend any NRPP credential or listing due to failed compliance with NRPP policies that include compliance with standards of practice stipulated in those policies. This right is vested in the NRPP program and all decisions shall be verified and upheld by NRPP s Steering Committee. 2. The NRPP reserves the right to establish policies requiring submittal from its program participants of documentation to support compliance with certification or listing requirements. 3. To remain in compliance with national and state laws relating to competitive practices in the marketplace, the AARST-NRPP will not process complaints from business associations or competitors and will not process complaints relating to pricing or market activities. 4. NRPP will not review business or contractual disputes. If the infraction clearly involves contractual issues rather than a violation of protocols or NRPP policies, the aggrieved party is advised by NRPP to seek legal remedies on a local basis. 5. Grievances: The NRPP is serious about compliance and acts when a complaint has been received. NRPP reserves the right to rely on information provided by an aggrieved party (e.g., person who contracted for work), state credentialing programs or other professional credentialing, regulatory or code organizations for investigation and determining NRPP actions related to any alleged misconduct, code of ethics violations or violations of standards of practice. a. Disciplinary actions are at the sole discretion of the NRPP Compliance Manager and Steering Committee or as deferred to adjudication through the institution of a Compliance Review Committee. Disciplinary actions may include, but are not limited to: suspension, revocation and restitution of listings or credentials and sanctions such as additional education requirements and required quality assurance plans with audits for quality. b. The NRPP Credentialing Coordinator shall retain all disciplinary records in the NRPP professional s files. A Rolling Term for receiving and documenting complaints shall be three years. At which time the first twelve months history shall drop from the record, provided such complaint does not involve a conviction of a state or federal felony. 6. Prior to a credential or listing being denied, revoked or suspended, the individual, laboratory, chamber or device manufacturer shall be notified in writing of the charges or policies that warrant such action. 48 Adopted and Enrolled by AARST-NRPP PAB and Board, April, 10, 2015 AARST - National Radon Proficiency Program (NRPP) ~ Page 29

30 7. Any individual, laboratory, chamber or device manufacturer whose credential or listing comes under a review decision for denial, revocation, sanction, or suspension may submit a written appeal to the Compliance Manager or NRPP s Steering Committee within 30 days after receipt of notification of charges or policy. B. NRPP COMPLIANCE MANAGER 1. NRPP shall have a staff, or a consulting staff member, known as the certification Compliance Manager (CM). The CM will investigate and address issues of professional compliance involving all classes of complaint (e.g., Class A, B, C and D.) The NRPP Compliance Manager will review all claims of misconduct by NRPP credentialed professionals on an as-needed basis. a. The Steering Committee may, at their discretion, appoint a substitute Compliance Manager for the purpose of administrative considerations or should a conflict of interest arise with the Compliance Manager. b. In all cases requiring investigation, it is NRPP s intent that the CM seek to resolve issues through clear and concise exchange of information and discussion. It is hoped that this process allows the certified individual or facility to resolve the dispute and to learn from any infraction. In cases where this approach does not provide a remedy, the CM will use as its basis for action on policies announced to all members and the agreement made by all certified individuals or firms to follow the protocols, guidelines and ethics cited on the application form. NRPP maintains these documents as a matter of record, in original form. c. The Compliance Manager will consider grievances received compared to required standards of practice and the NRPP Code of Ethics for NRPP Credentialed Professionals. Ethical considerations include, but are not limited to: i. Any act of fraud, deception or dishonesty in connection with any activity related to NRPP; ii. Misrepresentation of credential status (including stating or implying that the individual certification covers the company); iii. Accepting payment for services but failing to reasonably provide those services in a timely manner; iv. Any other material and intentional misconduct, not otherwise listed above, which is detrimental to the image or reputation of NRPP. C. COMPLAINT PROCESS 1. Complaints must be received in writing by the NRPP from the aggrieved party (e.g. person who contracted for work) or any of the following: - a State Radon Office; - an NRPP staff person forwarding administrative violations; or - Any certifying, code, health, environmental or licensing agency (public or private.) The NRPP also recognizes actions that may be taken by state radon programs. a. Individuals or facilities whose certification or license is revoked under the regulatory authority of a state radon program or who are under a punitive judicial decision related to services are automatically subject to a NRPP investigation to determine if they also violated NRPP policies. b. If a state withdraws certification, during the subsequent NRPP investigation the burden of proof is due from the affected certified individual or facility. c. In the case where NRPP investigates or decertifies a certified individual or facility, it will inform the particular state radon program director of such action. States will receive this notification from the NRPP Executive Director in an expeditious manner. AARST - National Radon Proficiency Program (NRPP) ~ Page 30

31 2. Verbal complaints will not be processed but potential parties are to be encouraged to discuss their complaint with the Compliance Manager before submission. 3. Complaints are to be forwarded to the Compliance Manager for investigation, review and processing. The Compliance Manager will often request additional information from a complainant that may include: written records of the relationship; further written description of the incident or situation; and photographic evidence. The Compliance Manager may also reach out to the complainant for verbal clarity on events before completing review of the investigation. 4. If, after investigating any grievance matter or complaint, there does not seem to be reasonable cause for sanctions or further action, the matter will be dismissed. The complainant and, as applicable, the certified individual or facility in question will be so advised by the Compliance Manager. 5. Should the Compliance Manager find that the charges are with merit: a. The individual or facility in question will be notified in writing and a response to the complaint will be sought. The notification will be sent by: - US Certified Mail or a courier service; or - other verifiable form of electronic communication, to confirm receipt and inform the individual that a complaint exists and the nature of that complaint. The complainant and related parties will also be notified of this action. b. The certified professional or facility will be encouraged to provide acknowledgment of the communication and to submit a written answer to the Compliance Manager within 14 (fourteen) calendar days after receipt of notification of charges. At this time, the certified individual or facility under review will be encouraged to provide a written response to the complainant and/or to the Compliance Manager with any documentation or supporting information regarding the complaint. When applicable, the NRPP Compliance Manager is authorized to function as an arbitrator for interpretation of policy, protocols or standards. 6. Failure of the certified individual or facility to submit a response within 30 (thirty) calendar days shall be deemed a waiver of the certified individual s or facility's right to protest the charges and sanctions imposed that may include but are not limited to: suspension, fees, audits, educational requirements and revocation of credentials or listings. The CM shall review any written appeals received from the certified individual or facility prior to that time. 7. The Compliance Manager shall rule on Class A, B, C and D categories after thirty calendar days from the date the notification was received by the individual or facility. At the discretion of the Compliance Manager, the ruling may be deferred until completion of interactive processes intended to achieve satisfactory resolve for all parties. The Compliance Manager will notify all related parties of the ruling decision. The Compliance Manager shall obtain approval of the Steering Committee prior to invoking extraordinary audit sanctions, suspension and other activities associated with the Class A complaint category that may result in convening a Compliance Review Committee and hearings. D. CATEGORIES OF COMPLAINT AND PREDETERMINED SANCTION SCHEDULE 1. There shall be four categories of infractions and respective sanctions when considering a response to grievances received and infractions that, at the discretion of the Compliance Manager, are deemed verified. The Steering Committee is granted latitude to amend these predetermined sanctions over time in order for them to facilitate viable and fair processes. AARST - National Radon Proficiency Program (NRPP) ~ Page 31

32 Class D Class C Class B Class A First-Time Minor Infraction 2 Points (i.e. 2 additional C.E. credits required prior to renewal) Points are deferred and not required if the complainants concerns are resolved. Specific topics for continuing education may be stipulated. Note: The intent of Class D and C sanctions is to both solve a complainants concerns and to nurture mature practices in professional practice and conduct. Failure to respond or make an effort to resolve the complaint can result in Class A sanctions that could ultimately result in suspension of certification(s). Multiple Infractions Second complaint: 2 points plus 2 points previously deferred for Class D offense (i.e. 4 C.E. credits required prior to renewal). At the discretion of the Compliance Manager relative to the nature of complaint: Specific topics for continuing education may be stipulated Audits of quality assurance plans may be required that include: - Administrative fees for conducting the audit(s), and - Submittal of quality control records across a specified time period before and/or after the date of the infraction(s). Additional Complaints and Unresolved Complaints: The total number of complaints on record times 4 points and audit(s) of quality assurance plans at the discretion of the Compliance Manager relative to the nature of complaints and actions or inactions of the certified individual. Failure to respond to a complaint or four documented case reviews in a three-year period resulting in sanctions shall be deemed a Class A infraction. Infractions with substantial potential for immediate harm to health and safety 8 Points (i.e. 8 additional C.E. credits required) At the discretion of the Compliance Manager relative to the nature of complaint: Additional points may be required (i.e. C.E. credits) A rapid deadline for obtaining continuing education may be stipulated Specific topics for continuing education may be stipulated Audits of quality assurance plans may be required that include: - Administrative fees for conducting the audit(s), and - Submittal of quality control records across a specified time period before and/or after the date of the offense. Egregious Infraction or violation of the trust invested in the individual by virtue of granting the NRPP credential(s) or listing, such as: non-cooperation with an investigation, harassment of a consumer or staff and/or continued violations of standards or policies. Failure to respond to a complaint, multiple administrative oversights in policy adherence, or harassment of a consumer or staff shall be grounds for suspension. The individual, laboratory, listed chamber or listed device shall normally be considered ineligible for reinstatement for a period of 2 years. AARST - National Radon Proficiency Program (NRPP) ~ Page 32

33 Other examples of Class A infractions to warrant this degree of sanctions include, but are not limited to: - Falsification of credential application or renewal application; - Falsification of QA/QC data (Note: inadequate QA/QC will result in discipline and, if not corrected, decertification); - Falsification or failure to provide any information requested by NRPP to investigate any misconduct or code of ethics violation; - Cheating or other irregularities related to the administration of a NRPP examination; - Failure to maintain the confidentiality of credential examination questions or answer sheet; and - Unauthorized possession of, use of or access to NRPP examinations, certificates, wallet identification cards, logos of NRPP, and any other NRPP documents and materials. Flagrant or multiple violations involving four documented case reviews over a three year period that result in sanctions for infractions or lack of adherence to policies shall be grounds for suspension. The individual, laboratory, listed chamber or listed device shall be normally considered ineligible for reinstatement for a period of 5 years. Infractions related to a criminal felony conviction, specifically related to murder, assault, assault and battery (including sexual), fraud, home invasion, extortion, burglary, property theft and larceny shall be grounds for revoking certification. The individual shall normally be ineligible for reinstatement. For clarity, actions that warrant this degree of sanctions include, but are not limited to: Any assault, battery, unlawful harassment, or non-consensual physical contact involving a customer or member of a customer s family, NRPP staff or members of NRPP related committees. Depending upon the nature and severity of the infraction, punitive penalty fees may be additionally assessed as a condition of reinstatement. Consideration of actions in response to a Class A infraction shall be conducted by the Compliance Manager in coordination with, or subsequent to authorization of the NRPP Steering Committee for ruling on: Suspension of certification or listing until resolved Administrative decertification or delisting in accordance with Section XII, E. Revocation of certification or listing Determinations on reinstatement eligibility and probationary conditions and durations in accordance with Section XII, F. AARST - National Radon Proficiency Program (NRPP) ~ Page 33

34 Determinations for convening a Compliance Review Committee for review and adjudication of final determinations on appeals, sanctions, reinstatements, suspensions or revocation of a certification or listing. 2. Compliance Review Committee: In the case of a Class A judgment against the certified individual or facility for determinable infractions of NRPP policies or standards of practice, the Steering Committee may consider adjudicating sanctions through the institution of an ad-hoc Compliance Review Committee composed of three members the NRPP Policy Advisory Board. a. The Compliance Manager who will hold an ex-officio seat on the Policy Advisory Board would form an ad hoc Compliance Review Committee. The ad-hoc committee will review any materials submitted by both the aggrieved party and the subject of the complaint and will consider the recommendations of the Compliance Manager. A webinar based conference call/hearing allowing the professional to answer the charges may be held if the NRPP professional requests a hearing. The ad-hoc committee will, within 2 weeks of the hearing, determine if there is reasonable cause to believe that a violation of applicable protocols or NRRP policies has occurred and, b. The Steering Committee will review and approve the ad hoc committee to ensure no member has a conflict of interest in the case. c. At the discretion of the Compliance Review Committee, sanctions may include but are not limited to: - Administrative fees for conducting any hearings - Continued suspension, revocation of certification or listing, and ineligibility for reinstatement - Conditions required for any reinstatement E. ADMINISTRATIVE DECERTIFCATION OR DELISTING: 1. In cases where a certified individual, laboratory, chamber or device manufacturer does not provide the requisite information for renewal, after a reasonable grace period (typically 30 days), the NRPP administrative office will remove the individual from its list of certified providers or devices. a. The NRPP administrators may reinstate these individual without prejudice subject to sanctions imposed as a result of Compliance Manager rulings. b. If QA/QC procedures have not been followed in the certification renewal process, the administrators are authorized to forward this information to the Compliance Manager. c. Failure to submit appropriate fees related to credentialing shall result in removal from NRPP lists of certified providers or devices. F. REINSTATEMENT FOR SUSPENSIONS, REVOCATIONS OR DELISTING 1. All individuals or facilities seeking reinstatement: a. Shall demonstrate eligibility for reinstatement as determined sufficient by the Compliance Manager and the Steering Committee to warrant eligibility. b. Shall submit to a probation period that may include an audit process with associated fees for auditing up to 24 months of quality control records and other stipulations as determined at the discretion of the Compliance Manager and the Steering Committee. AARST - National Radon Proficiency Program (NRPP) ~ Page 34

35 c. Shall reconcile payment for any fees imposed by the Compliance Manager, Steering Committee or Compliance Review Committee. d. NRPP individuals seeking reinstatement when the certification has been suspended or revoked: i. Shall complete stipulated educational requirements that may include approved entry level certification courses, exams and other criteria associated with a new application for certification. ii. Shall submit QA plans that will be reviewed before being eligible for reinstatement. e. NRPP laboratories, listed chambers or manufacturers of listed devices seeking reinstatement when a certification or listing has been suspended or revoked: i. Shall provide evidence sufficient to successfully demonstrate that steps have been taken to remediate and correct deficiencies. ii. Shall provide evidence sufficient to successfully demonstrate conformance with responsible, accepted policies and procedures for their type of facility. G. COMPLIANCE FEE SCHEDULE The Compliance Manager may utilize the compliance fee schedule to determine administrative sanctions for Class A, B and C infractions and notify the parties of these sanctions as well as providing notification to the Credentialing Coordinator and the NRPP Steering Committee. Administrative fees such as associated with audits, convening meetings or other incidental office activities shall be charged at a rate that is equal to NRPP's hourly costs for providing the relative services. Audits: Current estimates for audits of a quality assurance plan and one month of quality control records: $200 (or $40 per hour). This fee is repeated for each additional month associated with an audit or prorated to a lesser monthly amount when review of quality control evidence is minimal. Compliance Review Committee: Dependent upon the offences being adjudicated. Hourly rates should be expected to be higher for services provided by senior staff and hired consultants (e.g., $75 to $250 per hour). Punitive Penalty Fees: Dependent upon the judgment of the Steering Committee or Compliance Review Committee conducting review and arbitration of a complaint or request for reinstatement, punitive penalty fees can be assessed for up to $3500. H. APPEAL PROCESS: 1. Professionals who receive sanctions have the right to appeal the Compliance Manager and/or Compliance Review Committee decision within 30 days of receiving notification of the ruling. 2. The appeal would be directed to the Steering Committee who would determine the merit of the appeal. a. For Class B, C or D sanctions, the NRPP Steering Committee has authority, at their discretion, to convene a conference call with the professional within 30 days to consider decisions for rendering a judgment to modify or uphold the sanction. b. For all Class A sanctions, decisions of Compliance Review Committee that can include suspensions, revocation of certification or decisions to deny membership shall be final and binding on the member or prospective member. 3. For Class A sanctions: Any member or prospective member aggrieved by a revocation decision or denial of membership my submit, within 40 days of revocation, an appeal of the dispute to binding arbitration in accordance with the rules and procedures established by the American AARST - National Radon Proficiency Program (NRPP) ~ Page 35

36 Arbitration Association. The venue for such arbitration shall be Asheville, North Carolina unless another location is agreed upon by the parties. The arbitrator shall confirm the revocation decision or denial of membership unless the aggrieved member or prospective member demonstrates the decision or denial resulted from bad faith or fraud, or lacked any rational basis. All arbitration awards shall be final and binding on the parties, and shall be enforceable by appropriate proceedings under the applicable laws of North Carolina. Unless otherwise provided by the arbitrator, each party shall pay its pro rata share of the reasonable fees and expenses of the arbitrator. Furthermore: a. the appellant shall pay for their own travel costs and the travel costs of witnesses. b. AARST-NRPP shall not refund any fees or expenses for loss of certification nor compensate either party for their expenses or loss of revenue. XIII. New Credential Development A. C-1 Commercial Radon Mitigation Provider 49 Meets requirements for R-1 and R-2 certifications and is qualified to install systems in existing and new large building which reduce radon and radon decay products. B. C-2 Commercial Radon Mitigation Provider 50 Meets the requirements for C-1 certification and is qualified to assess the need for and design systems in existing and new large buildings which reduce radon and radon decay products. C. Radon in Water Radon in water testing and mitigation certification requirements are to be developed as a parallel program to that for radon in air, with tiers and descriptions to be developed by the TRB. 51 XIV. NRPP Policy Advisory Board (PAB) A. Duties 1. The Policy Advisory Board shall have the ability to develop and recommend procedures for the operation of the NRPP, within parameters necessary to insure the legal operation of the program. 2. Formal meetings are held no less than once a year. 3. Teleconferences are held no less than twice a year. 4. The Staff is responsible for preparing support material as need to render decisions by the NRPP PAB 5. The NRPP Board recommends procedures for the review of initial and continuing education courses, instructors, measurement SOPs, mitigation SOPs, testers, radon mitigators, radon and radon decay product measurement devices, radon labs, and chambers. 49 Under further development, per NEHA-NRPP Board April Under further development, per NEHA-NRPP Board April As adopted by NEHA-NRPP Board April 1999 AARST - National Radon Proficiency Program (NRPP) ~ Page 36

37 B. Members 1. The NRPP Policy Advisory Board is functioning. A list of current Board members is included in the Appendix. 2. Current NRPP PAB members represent the following areas: NRPP (Chair) Regulated States Non-Regulated States Radon Measurement Field Radon Mitigation Field Chambers Laboratories Radon Equipment Manufacturers Education Home Inspectors Real Estate Industry Home Building Industry Local Government Consumer Interests Technical Review Board Certification Compliance Advisor from the EPA 3. The NRPP PAB established a Certification Compliance Committee to examine issues of ethics and standards, and the Chair of said Committee shall hold a voting seat on the Board The Program Staff support the NRPP PAB 5. NRPP Board members are exempt from NRPP certification fees for the period of time served on said Board. C. Rules Meetings shall be conducted by Robert s Rules of Order 2. Board is not required to have a quorum to meet, but do need a majority to vote 3. Members present and votes cast shall be a matter of record 4. Proxies may sit in but not vote 5. Secretary to the Board shall sit for Chair in his absence 6. When mail votes are held, majority of board must approve, by an established end date 7. When voting by fax, as the majority of yea or nay arrive, issue is decided 8. Board members agree to return ballots within five business days of receipt, during electronic or fax votes 9. If time expires without a quorum vote, issue is defeated. 52 As adopted by NEHA-NRPP Board November As adopted by NEHA-NRPP Board October 1998 AARST - National Radon Proficiency Program (NRPP) ~ Page 37

38 D. Elections 1. Elections shall be held according to the bylaws of NRPP 2. Elections are anticipated in the spring of 2000 XV. Technical Review Board (TRB) 54 The AARST Technical and Science Committee (TASC) 55 A. Definition Review Standards 2. Call committees 3. Review curriculum 4. Review courses, considering course content for technical accuracy, with protocol expert B. Duties 1. The TASC insures that educational materials are meeting the needs of the certified individual 2. The TASC assists with the review of new curriculum 3. The TASC currently functions under the guidance of the AARST NRPP Board. 1. The TASC is assisted by liaisons from the NRPP Board. 2. The Support Staff supports the TASC. 3. TASC members are exempt from certification fees for the period of time served on the TASC. XVI. Support Staff A. Location and Contact 1. The Support Office is located at Hendersonville Rd, Fletcher North Carolina The Support Staff may be reached at , or by at B. Duties 1. The Support Office carries out the directives for the AARST Board 57 as they pertain to the NRPP. 2. Duties include clerical support, coordination, and marketing for the AARST-NRPP. 3. Tasks include the following: a. Accepting, reviewing, and processing applications b. Handling funds for certifications and renewals c. Maintaining records of certifications 54 Per agreement with NEHA and AARST, the TRB was replaced by the AARST Technical and Standards Committee in Adopted by AARST-NRPP September 28, As defined by NEHA-NRPP Board October Adopted by AARST-NRPP September 28, 2005 AARST - National Radon Proficiency Program (NRPP) ~ Page 38

39 d. Reviewing complaints lodged against individuals, and presenting cases to the NRPP Compliance Manager and Steering Committee e. Facilitating the development and review of educational programs f. Scheduling NRPP Board meetings g. Informing the NRPP Board chairperson of relevant issues h. Maintaining a Web site with certification lists and information for consumers and radon professionals i. Coordinating national public outreach programs j. Implementing procedures for administrative functions as delegated by the NRPP Board k. Facilitating procedures for appeals l. Developing a process for evaluating the success of the program in concert with the CRCPD m. Distributing and tracking NRPP exam materials, and notifying students of test results. XVII. State or Regional Committees A. Duties 1. State Committees shall provide a local forum for resolving complaints, disseminating public information, supporting locally certified individuals, and allowing for customization of radon related programs. 2. State Committees will attempt to resolve issues/complaints through means available to them through their associated agencies. They may complete fact-finding studies, and present results to the NRPP Board. 3. State Committee members are available to assist with proctoring individual exams in the event of re-take or unusual circumstances. B. Structure 1. State Committees are currently comprised of certified individuals within state or county health departments. 2. State Committee members are exempt from certification fees for the period served on said committee. AARST - National Radon Proficiency Program (NRPP) ~ Page 39

40 XVIII. EPA Protocols and Other Standards A. NRPP originally adopted the EPA Protocols B. NRPP shall participate in the amendment of existing Radon Mitigation Standards to reflect the new NRPP certification program. 58 C. Requirements set forth by other agencies stand. NRPP shall use EPA Mitigation Standards to develop own program, with anything beyond that to be reviewed by the TRB as the need arises. 59 D. Device Placement Interpretation 60 All third party real estate measurements must be done with two devices, co-located and cotemporaneously. For a blind continuous radon monitor, the second device may be any EPA approved device. E. Standards Recognized by the National Radon Proficiency Program (2013) Measurement Standards EPA 1993 Home Protocols EPA Device Protocols ANSI-AARST (MAMF) Protocol for Conducting Radon and RDP Measurements in Multi-Family Buildings AARST (MAH) - Protocols for Conducting Radon and Radon Decay Product Measurements in Homes Mitigation Standards EPA 1993 Radon Mitigation Standards AARST (ASD-RMS 2006) Active Soil Depressurization Radon Mitigation Standard for Low Rise Residential Buildings 2006 * ASTM E Standard Practice for Installing Radon Mitigation Systems in Existing Low Rise Residential Buildings * ANSI-AARST Standard (ANSI/AARST CCAH 2012) Reducing Radon in New Construction of 1 & 2 Family Dwellings and Townhouses" 63 ANSI-AARST Provisional Standard: ANSI/AARSTR RMS-MF (PS) 2013 Radon Mitigation Standards for Multifamily Buildings" As adopted by NEHA-NRPP Board April As adopted by NEHA-NRPP Board April As adopted by NEHA-NRPP Board October As adopted by NEHA-NRPP Board June As adopted by NEHA-NRPP Board June Approved by AARST-NRPP Board June Approved by AARST-NRPP Board June 2013 AARST - National Radon Proficiency Program (NRPP) ~ Page 40

41 Appendix NRPP Code of Ethics New Certification Application Advanced Certification Application Application for the Certification of Radon and Radon Decay Product Chambers Calibration Requirements for Radon Laboratories and Analytical Service Providers Organizational Chart Renewal Application Application and Instructions for Performance Test Chambers Device List Residential Measurement Course Criteria Residential Mitigation Course Criteria Application Continuing Education Courses Category I Provider Category I Attendee Category II Provider/Attendee AARST - National Radon Proficiency Program (NRPP) ~ Page 41

42 Code of Ethics/Disciplinary Policy for NRPP Credentialed Radon Professionals As a radon professional, credentialed by the NRPP National Radon Proficiency Program, I hereby acknowledge, accept and profess to abide by the following code of conduct and ethics: I shall endeavor to keep myself current and informed and satisfy any continuing education requirements that may be in effect for my credential. I shall conduct myself in a professional manner befitting of my credentialed status. I shall proudly represent my credentialed status to the public I serve and I shall provide my professional NRPP certification number in writing to each member of the public (each customer job) for any radon service or system installation that I perform or supervise. I shall do nothing to undermine, detract from, or otherwise cause to develop any damaging associations with respect to this credential. I accept that any activity on my part that will cause this credential any measure of injury serves as a breach and a failure on my part to uphold this code of ethics. Moreover, I accept that such actions for which I might be responsible could result in the revocation of my credential. Protocols: I agree to conduct business in accordance with the protocols and the quality assurance and quality control guidelines prescribed by the NRPP Policy Advisory Board (PAB). The list of standards currently approved by the PAB is available at: For Canadian radon professionals, protocols/guidelines can be found at: I further agree to adhere to specific state, provincial or territorial protocols, laws, codes or regulations that exist for any radon service or system installation that I perform or supervise. I hereby acknowledge and accept the following Disciplinary Policy: NRPP Credential Disciplinary Policy: NRPP reserves the right to sanction or revoke the credential of any individual due to misconduct. The right to deny, revoke, discipline, or suspend a NRPP credential is vested in the NRPP program and all decisions shall be verified and upheld by NRPP s Complaince Manager and Steering Committee. Disciplinary actions are at the sole discretion of the NRPP Steering Committee and may include, but are not limited to: warnings, revocation, restitution and/or additional continuing education. Prior to a credential being denied, revoked or suspended the individual shall be notified in writing of the charges that warrant such action (sent by a traceable method to the individual). Any individual whose credential comes under review for denial, revocation, discipline, or suspension may submit a written appeal to the Steering within 30 days after receipt of notification of charges. NRPP reserves the right to rely upon information provided by state credentialing programs or other professional credentialing organizations related to environmental health in the investigation of any alleged misconduct or code of ethics violations. Misconduct includes but is not limited to: Falsification of credential application or renewal application; Failure to submit appropriate fees related to credentialing; Misrepresentation of credential status (including stating or implying that the individual certification covers the company); AARST - National Radon Proficiency Program (NRPP) ~ Page 42

43 Falsification of QA/QC data (Note: inadequate QA/QC will result in discipline and, if not corrected, decertification); Falsification or failure to provide any information requested by NRPP to investigate any misconduct or code of ethics violation; Accepting payment for services but failing to reasonably provide those services in a timely manner; Cheating or other irregularities related to the administration of a NRPP examination; Failure to maintain the confidentiality of credential examination questions or answer sheet; Unauthorized possession of, use of or access to NRPP examinations, certificates, wallet identification cards, logos of NRPP, and any other NRPP documents and materials; Violation of any provision of the NRPP Code of Ethics for NRPP Credentialed Professionals. Any act of fraud, deception or dishonesty in connection with any activity related to NRPP; Any assault, battery, unlawful harassment, or non-consensual physical contact involving a customer or member of a customer s family, NRPP staff or members of NRPP related committees; Any other material and intentional misconduct, not otherwise listed above, which is detrimental to the image or reputation of NRPP. NRPP Credential Disciplinary Procedure: The NRPP Compliance Manager will review all claims of misconduct by NRPP credentialed professionals on an as needed basis. Should the NRPP Compliance Manager or Steering Committee find that the charges are with merit, the individual in question will be notified in writing via a traceable method. The individual may submit a written appeal to the Steering Committee within thirty calendar days after receipt of notification of charges. Failure to submit an appeal within thirty calendar days shall be deemed a waiver of the individual s right to protest the charges. The Steering Committee shall rule on charges after thirty calendar days from the date the notification was received by the individual and shall review any written appeals received from the individual. All revocation decisions and all decisions to deny membership shall be final and binding on the member or prospective member. Any member or prospective member aggrieved by a revocation decision or denial of membership shall submit the dispute to binding arbitration in accordance with the rules and procedures established by the American Arbitration Association. The venue for such arbitration shall be Asheville, North Carolina unless another location is agreed upon by the parties. The arbitrator shall confirm the revocation decision or denial of membership unless the aggrieved member or prospective member demonstrates the decision or denial resulted from bad faith or fraud, or lacked any rational basis. All arbitration awards shall be final and binding on the parties, and shall be enforceable by appropriate proceedings under the applicable laws of North Carolina. Unless otherwise provided by the arbitrator, each party shall pay its pro rata share of the reasonable fees and expenses of the arbitrator. Acknowledgement and acceptance: All of the information I have provided in this application is accurate to the best of my knowledge. I understand that intentional misrepresentation of this information could be AARST - National Radon Proficiency Program (NRPP) ~ Page 43

44 grounds for loss of certification. By submitting this application, I agree to meet all applicable program requirements. I have read and understand all requirements pertaining to the certification for which I am applying. I have read the above section and have enclosed all information requested for application to the NRPP National Radon Proficiency Program. I understand that it is my responsibility to keep NRPP notified of any changes in pertinent information, and that NRPP will notify NRPP certified individuals only through addresses and phone numbers provided by myself. I understand that my AARST-NRPP certification is not transferable. I understand that my NRPP certification pertains to me as an individual and not any company. I understand that my NRPP certification is subject to review and that I may be assessed an investigation fee if I either instigate a faulty claim against another NRPP certified individual, or if I am found to be in violation of NRPP Code of Ethics or fail to abide by EPA, NRPP or any other protocols adopted by NRPP or Health Canada (for Canadian Radon Professionals) in performing my services. I agree to surrender my NRPP identification card if I voluntarily withdraw or if I am de-certified from the program. I agree to contact appropriate state radon officials and comply with any states laws or regulations before initially offering radon services in any state in which I conduct radon measurement or mitigation services. I further understand that the NRPP is not liable for any damages or harm arising from participation in this program or from any work performed by its participants. Accepted by: Date: AARST - National Radon Proficiency Program (NRPP) ~ Page 44

45 AARST-NRPP APPLICATION FOR CERTIFICATION This application is a basic form to provide NRPP with information necessary to finalize your NRPP certification and also provide you with an opportunity to apply for membership with the American Association of Radon Scientists and Technologists (AARST). Specific instructions for completing this form can be found on-line at After completing the appropriate sections of the application form and calculating your fee (page 3), please send your form and a check or money order made payable to NRPP via regular mail to: NRPP Administrative Office, P.O. Box 2109, Fletcher, NC If you choose to use a courier service (e.g., FedEx, UPS, Airborne Express, etc.), you may send your application package to: NRPP Administrative Office, 4989 Hendersonville RD, Fletcher, N.C Note do not send USPS Express Mail or Priority Mail to this address. All participants must complete the following information. Please complete exactly as you wish to have your information appear on the website. The address that you list here is also the address to which all correspondence from the Program will be sent to you. VITAL INFORMATION Your Name Company Name Address City State or Province Zip or Postal Code Phone # (one number) AARST - National Radon Proficiency Program (NRPP) ~ Page 45

46 Fax # (one number) Home Page AARST - National Radon Proficiency Program (NRPP) ~ Page 46

47 Code of Ethics/Disciplinary Policy for NRPP Credentialed Radon Professionals As a radon professional, credentialed by the NRPP National Radon Proficiency Program, I hereby acknowledge, accept and profess to abide by the following code of conduct and ethics: I shall endeavor to keep myself current and informed and satisfy any continuing education requirements that may be in effect for my credential. I shall conduct myself in a professional manner befitting of my credentialed status. I shall proudly represent my credentialed status to the public I serve and I shall provide my professional NRPP certification number in writing to each member of the public (each customer job) for any radon service or system installation that I perform or supervise. I shall do nothing to undermine, detract from, or otherwise cause to develop any damaging associations with respect to this credential. I accept that any activity on my part that will cause this credential any measure of injury serves as a breach and a failure on my part to uphold this code of ethics. Moreover, I accept that such actions for which I might be responsible could result in the revocation of my credential. Protocols: I agree to conduct business in accordance with the protocols and the quality assurance and quality control guidelines prescribed by the NRPP Policy Advisory Board (PAB). The list of standards currently approved by the PAB is available at: For Canadian radon professionals, protocols/guidelines can be found at: I further agree to adhere to specific state, provincial or territorial protocols, laws, codes or regulations that exist for any radon service or system installation that I perform or supervise. I hereby acknowledge and accept the following Disciplinary Policy: NRPP Credential Disciplinary Policy: NRPP reserves the right to sanction or revoke the credential of any individual due to misconduct. The right to deny, revoke, discipline, or suspend a NRPP credential is vested in the NRPP program and all decisions shall be verified and upheld by NRPP s Steering Committee. Disciplinary actions are at the sole discretion of the NRPP Compliance Manger and Steering Committee and may include, but are not limited to: warnings, revocation, restitution and/or additional continuing education. Prior to a credential being denied, revoked or suspended the individual shall be notified in writing of the charges that warrant such action (sent by a traceable method to the individual). Any individual whose credential comes under review for denial, revocation, discipline, or suspension may submit a written appeal to the Steering within 30 days after receipt of notification of charges. NRPP reserves the right to rely upon information provided by state credentialing programs or other professional credentialing organizations related to environmental health in the investigation of any alleged misconduct or code of ethics violations. Misconduct includes but is not limited to: Falsification of credential application or renewal application; Failure to submit appropriate fees related to credentialing; Misrepresentation of credential status (including stating or implying that the individual certification covers the company); AARST - National Radon Proficiency Program (NRPP) ~ Page 47

48 Falsification of QA/QC data (Note: inadequate QA/QC will result in discipline and, if not corrected, decertification); Falsification or failure to provide any information requested by NRPP to investigate any misconduct or code of ethics violation; Accepting payment for services but failing to reasonably provide those services in a timely manner; Cheating or other irregularities related to the administration of a NRPP examination; Failure to maintain the confidentiality of credential examination questions or answer sheet; Unauthorized possession of, use of or access to NRPP examinations, certificates, wallet identification cards, logos of NRPP, and any other NRPP documents and materials; Violation of any provision of the NRPP Code of Ethics for NRPP Credentialed Professionals. Any act of fraud, deception or dishonesty in connection with any activity related to NRPP; Any assault, battery, unlawful harassment, or non-consensual physical contact involving a customer or member of a customer s family, NRPP staff or members of NRPP related committees; Any other material and intentional misconduct, not otherwise listed above, which is detrimental to the image or reputation of NRPP. NRPP Credential Disciplinary Procedure: The NRPP Steering Committee will review all claims of misconduct by NRPP credentialed professionals on an as needed basis. Should the Steering Committee find that the charges are with merit, the individual in question will be notified in writing via a traceable method. The individual may submit a written appeal to the Steering Committee within thirty calendar days after receipt of notification of charges. Failure to submit an appeal within thirty calendar days shall be deemed a waiver of the individual s right to protest the charges. The Steering Committee shall rule on charges after thirty calendar days from the date the notification was received by the individual and shall review any written appeals received from the individual. All revocation decisions and all decisions to deny membership shall be final and binding on the member or prospective member. Any member or prospective member aggrieved by a revocation decision or denial of membership shall submit the dispute to binding arbitration in accordance with the rules and procedures established by the American Arbitration Association. The venue for such arbitration shall be Asheville, North Carolina unless another location is agreed upon by the parties. The arbitrator shall confirm the revocation decision or denial of membership unless the aggrieved member or prospective member demonstrates the decision or denial resulted from bad faith or fraud, or lacked any rational basis. All arbitration awards shall be final and binding on the parties, and shall be enforceable by appropriate proceedings under the applicable laws of North Carolina. Unless otherwise provided by the arbitrator, each party shall pay its pro rata share of the reasonable fees and expenses of the arbitrator. Acknowledgement and acceptance: All of the information I have provided in this application is accurate to the best of my knowledge. I understand that intentional misrepresentation of this information could be AARST - National Radon Proficiency Program (NRPP) ~ Page 48

49 grounds for loss of certification. By submitting this application, I agree to meet all applicable program requirements. I have read and understand all requirements pertaining to the certification for which I am applying. I have read the above section and have enclosed all information requested for application to the NRPP National Radon Proficiency Program. I understand that it is my responsibility to keep NRPP notified of any changes in pertinent information, and that NRPP will notify NRPP certified individuals only through addresses and phone numbers provided by myself. I understand that my AARST-NRPP certification is not transferable. I understand that my NRPP certification pertains to me as an individual and not any company. I understand that my NRPP certification is subject to review and that I may be assessed an investigation fee if I either instigate a faulty claim against another NRPP certified individual, or if I am found to be in violation of NRPP Code of Ethics or fail to abide by EPA, NRPP or any other protocols adopted by NRPP or Health Canada (for Canadian Radon Professionals) in performing my services. I agree to surrender my NRPP identification card if I voluntarily withdraw or if I am de-certified from the program. I agree to contact appropriate state radon officials and comply with any states laws or regulations before initially offering radon services in any state in which I conduct radon measurement or mitigation services. I further understand that the NRPP is not liable for any damages or harm arising from participation in this program or from any work performed by its participants. Accepted by: Date: Print Name: NRPP ID #: A. Residential Measurement Services (Individual) A.1. Standard Services In addition to completing the Vital Information on Page 1, you must also include a copy of your course completion certificate and proof of having passed your NRPP Measurement Exam. A.2. Standard and Analytical Services (This section applies to individuals who analyze their own device, including printing a data tape from a CRM.) In addition to completing the Vital Information on Page 1, you must also include a copy of your course completion certificate and proof of having passed your NRPP Measurement Exam. You must also complete the following section and INCLUDE PROOF OF CALIBRATION FOR EACH DEVICE UTILIZED AND PROOF OF HAVING PASSED A DEVICE PERFORMANCE TEST FROM EITHER BOWSER MORNER ( X 249) OR RADON MEASUREMENTS LAB ( ) FOR EACH DEVICE GROUP. (See Device list on web site, There is a $75.00 fee for each Device Group. Device Code Device Group Description of Device Total Number of Device Groups - B. Analytical Laboratory (Company who provides 3 rd party analysis for clients) AARST - National Radon Proficiency Program (NRPP) ~ Page 49

50 Each certified Analytical Laboratory must have an individual who is certified for Residential Measurement Services who is designated as the Responsible Party for the Analytical Laboratory. Please list this person below: Name: NRPP ID#: RT In order to become certified as an Analytical Laboratory, you must also complete the following section and INCLUDE PROOF OF CALIBRATION FOR EACH DEVICE UTILIZED AND PROOF OF HAVING PASSED A DEVICE PERFORMANCE TEST FROM EITHER BOWSER MORNER ( X 249) OR RADON MEASUREMENTS LAB ( ) FOR EACH DEVICE GROUP. (See Device list on web site, There is a $75.00 fee for each Device Group-. Device Code Device Group Description of Device Total Number of Device Groups - C. Residential Mitigation Service Provider In addition to completing the Vital Information on Page 1, you must also include a copy of your course completion certificate and proof of having passed your NRPP Mitigation Exam. D. STATE License Applicants for NRPP Certication Submit Copy of Your Current (Active) State License in Lieu of NRPP Exam and Education Requirements. All Other NRPP Applicant and Renewal Requirements Apply. SERVICE AREAS For $5 per state, you can be listed as providing services in states other than your state of residence. This may be especially useful to you if you live near state borders. Please do not check your state of residence. NOTE: The states that are shaded have their own certification/registration program. By checking any of these boxes, you are affirming that you have met all state and local requirements. AARST - National Radon Proficiency Program (NRPP) ~ Page 50

51 Alaska Iowa New Jersey Vermont Alabama Kansas New Mexico Virginia* Arkansas Kentucky New York* Washington Arizona Louisiana North Carolina West Virginia California Maine North Dakota Wisconsin Colorado Maryland Ohio Wyoming Connecticut* Massachusetts Oklahoma Guam Washington, DC Michigan Oregon Puerto Rico Delaware Minnesota Pennsylvania Virgin Islands Florida Mississippi Rhode Island Japan Georgia Missouri South Carolina Canada Hawaii Montana South Dakota Europe Idaho Nebraska Tennessee Illinois Nevada Texas Indiana New Hampshire Utah Or $150 for ALL states and possessions. New York has requirements for labs. Virginia simply requires certification by NRPP or NRSB No state radon filing or license is necessary. Connecticut has requirements for radon mitigators to be licensed home contractors I. AARST MEMBERSHIP APPLICATION Name of Company: Name (Key Contact): Address: Address: City: State: Zip: Providence: Country: AARST - National Radon Proficiency Program (NRPP) ~ Page 51

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