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Quality Assurance PlanFor Conducting Radon Measurements MDH Standard QA Plan V3.1 Date of original QA Plan 10/31/2019 Date of Last Revision --/--/----- RADON MEASUREMENT QUALITY ASSURANCE PLANContentsQuality Assurance Plan ..................................................................................................... 1For Conducting Radon Measurements ........................................................................................... 1 1. Introduction ......................................................................................................................... 4 Policy and Commitment.......................................................................................................... 4 Quality Assurance Plan Purpose ............................................................................................. 4 Quality Assurance Goal and Objectives .................................................................................. 4 2. Organization ......................................................................................................................... 4 3. Description of Operations .................................................................................................... 5 Duties of the Quality Assurance Officer ................................................................................. 5 Personnel and Subcontractor Qualifications .......................................................................... 5 Documents and Records ......................................................................................................... 5 4. Measurement Procedures ................................................................................................... 5 Measurement Devices ............................................................................................................ 5 Measurement Standards of Practice ...................................................................................... 6 Inform Client about Required Test Conditions ....................................................................... 6 Safety ...................................................................................................................................... 6 Measurement Placement and Assessment of Test Conditions .............................................. 6 New Construction Test Conditions ......................................................................................... 7 Post-Mitigation Measurements .............................................................................................. 7 5. Data Collection, Validation, Reporting, Entry and Retention .............................................. 7 Data Collection ........................................................................................................................ 7 Data Validation ....................................................................................................................... 8 Data Reporting ........................................................................................................................ 8 6. Internal Quality Control ....................................................................................................... 9 Commitment to Quality and Objective ................................................................................... 9 Continuous Radon Monitors ................................................................................................. 10 Calibration ............................................................................................................................. 10 Routine Instrument Checks................................................................................................... 10 Duplicates.............................................................................................................................. 10 Crosschecks ........................................................................................................................... 11 Passive Devices ..................................................................................................................... 11 Routine Instrument Checks................................................................................................... 112 RADON MEASUREMENT QUALITY ASSURANCE PLAN Duplicates.............................................................................................................................. 12 Blanks .................................................................................................................................... 12 Spikes .................................................................................................................................... 13 7. Corrective Action................................................................................................................ 13 8. Quality Assurance Training ................................................................................................ 14 9. Quality Assurance Audits and Reports ............................................................................... 15 10. Definitions ...................................................................................................................... 15 11. References ...................................................................................................................... 19 Radon Test Placement and Retrieval Checklist..................................................................... 223 RADON MEASUREMENT QUALITY ASSURANCE PLAN 1. IntroductionPolicy and CommitmentIn order to protect health and financial interests of building owners and occupants, it is thepolicy of our organization to provide accurate, reproducible, and valid measurements of indoorradon concentrations. Each measurement employee is individually and collectively committedto the highest quality work in accordance with this plan
Quality Assurance Plan PurposeThe purpose of this Quality Assurance (QA) Plan is to: set policies, performance goals, andobjectives; identify responsibilities; establish procedures for assessing performance relative toquality; and to define corrective actions when needed
It is important to recognize that usually quality assurance (QA) practices result not in theidentification of out-of-control processes, but in the continued documentation of stable, withinlimits operations. Only with such documentation can the validity of measurement results bedefended
This QA plan will be revised with any adjustments involving changes of personnel andmeasurement devices as well as regulatory requirements or professional associationrecommendations. If there are no revisions triggering changes, this plan will be reviewed aminimum of annually
Quality Assurance Goal and ObjectivesOur staff are committed to providing customers with accurate, valid, reproducible, anddefensible radon measurements which may be used to make critical decisions about radiation-related environmental health
The objectives of the QA plan are to maintain a quality measurement program and todocument relative quality. In addition, a QA program adds greatly to an operatorsunderstanding of the methods they use and provides early detection of problems so that theycan be rectified quickly and completely
We collect evidence of the relative quality of our performance and evaluate that evidencethrough Quality Control (Section 6), take Corrective Action as needed (Section 7), and conductQuality Assurance Audits (Section 9). A record of this evidence and resulting actions aremaintained with those of this QA Plan
2. OrganizationLicensed radon professionals are responsible for our organization’s field radon measurements
The owner/president is responsible for all aspects of operations. Quality Assurance Officer isresponsible to the President for all QA as related to field operations and for field measurementsand data analysis
This QA Plan was reviewed by all personnel involved with radon work and will continue to bemade available for future reference
4 RADON MEASUREMENT QUALITY ASSURANCE PLAN 3. Description of OperationsDuties of the Quality Assurance OfficerThe Quality Assurance Officer’s responsibilities are to:▪ ensure proper storage of radon measurement devices;▪ design and present training to new employees and, on an annual basis, to all employees;▪ oversee measurement device use including placement and retrieval;▪ create and maintain QA records;▪ prepare or oversee client test reports and to specify how they are distributed to clients;▪ manage and oversee quality control (QC) measures;▪ initiate QA audits;▪ make recommendations on corrective action and to insure corrective action is carried out;▪ initiate QA audit reporting to management; and▪ participate in all meetings regarding staffing, training, equipment, record keeping, and changes in practices and procedures
Personnel and Subcontractor QualificationsStaff members and/or contractors conducting radon measurement services are individuallylicensed as radon measurement professionals by Minnesota Department of Health (MDH). Thisincludes anyone placing and/or retrieving testing devices
Documents and RecordsAll records and documents are maintained so they are legible, retrievable, and protected fromfire, water, theft, and deterioration for a minimum period of 3 years. Computer software andrecords for our radon measurements are routinely backed up to the cloud or a remote server
Each individual radon professional shall submit their quarterly measurement data to MDH onthe schedule outlined in the radon licensing rules:▪ April 30 for the period of January 1 through March 31;▪ July 30 for the period of April 1 through June 30;▪ October 30 for the period of July 1 through September 30; and▪ January 30 for the period of October 1 through December 31 of the previous year
4. Measurement ProceduresWe perform radon measurements in accordance with Minnesota state statutes, rules, adoptedmeasurement standards of practice, and the instructions of the measurement devicemanufacture(s)
Measurement DevicesThe measurement devices used shall be listed for meeting the requirements of Minnesota statestatutes and rules and be approved for use by the state and NRPP
The manufacturer’s operating instructions are attached to the QA Plan
5 RADON MEASUREMENT QUALITY ASSURANCE PLANUntil use, radon measurement devices shall be stored in dry, low radon environments, and permanufacturer instructions
Measurement Standards of PracticeOur company will follow the Minnesota Radon Licensing Act and Rules and the protocols andstandards listed below:▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products in Homes (ANSI/AARST MAH-2019) or successor ANSI/AARST standards, and test each unique foundation type;▪ ANSI/AARST Standard: Protocol for Conducting Radon and Radon Decay Product Measurements in Multifamily Buildings (ANSI/AARST MAMF-2017) or successor ANSI/AARST standards;▪ ANSI/AARST Protocol for Conducting Measurements of Radon and Radon Decay Products in Schools and Large Buildings (ANSI/AARST MALB-2014) or successor ANSI/AARST standards
Inform Client about Required Test ConditionsWe will make reasonable efforts to inform the person responsible for the house of requiredand recommended test conditions a minimum of 12 hours prior to the test as well as during thetest
The person responsible for closed-building conditions will be requested to sign a non-interference agreement that indicates knowledge of the testing conditions contained in theagreement and a willingness to cooperate in maintaining the required test conditions. If suchan agreement cannot or will not be signed by the responsible individual(s), the licensed radonprofessional will indicate in the test report that a signature was not obtained
SafetyThe licensed radon professional shall not enter any area or perform any test that woulddamage property or risk the professional’s own or another’s safety. If it is known that closed-house conditions are detrimental to the health of the occupants, then the radon survey using ashort-term test shall not be done
Measurement Placement and Assessment of Test ConditionsWe will place radon measurement devices in testing sites and under conditions in accordancewith the Minnesota Radon Licensing Act and Rules and according to the protocols andstandards listed above in Measurement Standards of Practice (as shown in Table 3.3 ofANSI/AARST MAH 2019)
The radon professional will visually assess test conditions when deploying and retrievingdevice(s). Included in this assessment, to ensure essential closed-building protocolrequirements are met, the items in table 4-A, table 4-B (if applicable), and Exhibit 1 fromANSI/AARST MAH 2019 will be visually inspected
See example placement/retrieval checklist at the end of this QA plan
6 RADON MEASUREMENT QUALITY ASSURANCE PLANIf the radon measurement is a long-term measurement of 90- days or more in duration, closed-building conditions need not be maintained prior to, nor during the radon test. For long-termtests, it is recommended that at least half the test period should be during the season that thedwelling is most likely to be operated with closed-house conditions so that the results of thetest are more accurate indicators of the yearly average
Short term test periods should optimally collect at least 48 hours of valid sampling time
Deployment periods shall not be less than 46 hours. In addition, if a short-term test is longerthan 2 days, whenever practical it is recommended, but not required, to terminate the testnominally at 24-hour increments to reflect day to night fluctuations in radon concentrationswithin a dwelling
For continuous radon monitors, care should be taken to account for data that are producedbefore equilibrium conditions have been established in a flow-through cell. Generally,conditions stabilize after the first four hours. Measurements made prior to this time areprobably low, and the first four hours of data may be discarded or incorporated into the resultusing system correction factors. If the first four hours of data are discarded, the remaininghours of data can be averaged and are sufficient to represent a two day measurement
New Construction Test ConditionsNewly built homes are tested in accordance with this QA Plan. If the following items are part ofthe completed dwelling, they must be installed and completed before the radon test isinitiated: all exterior doors, all windows, all heating appliances, all fireplaces and fireplacedampers, all insulation and exterior siding, all wall and ceiling coverings to be completedincluding interior drywall or paneling (does not include decorative finishing of walls, floors orceilings). If testing personnel know construction work, which will likely affect the test results, isto be done inside the dwelling during the test period, the test must be scheduled during a timewhen such interference is less likely to take place
Post-Mitigation MeasurementsA post-mitigation measurement is conducted to confirm the relative impact of mitigation. Thepost-mitigation measurement is a short-term test made in the same location(s) as the pre-mitigation test(s). The test must not be started sooner than 24-hours after the start-up of theradon mitigation system and within 30 days after the installation of the system. The test musthave 12-hours of closed house conditions before the start of the test and closed houseconditions during the test. In addition to the post-mitigation test, it must be recommended tothe client that they test every two-years thereafter
5. Data Collection, Validation, Reporting, Entry and RetentionData CollectionIf the hourly printout from the CRM is not given in the customer report, it will be available tocustomer for at least three years following the test
7 RADON MEASUREMENT QUALITY ASSURANCE PLANData ValidationValid data is produced when a measurement system, including storage, field deployment,transport, analysis, and reporting are operating “in control” and within QC limits and when in-control QC checks have been made both before and after a set of validated data. It is theresponsibility of the qualified measurement professional to conduct, record, and makeavailable the results of QC checks relevant to each reported result
The Quality Assurance Officer will review some radon reports to ensure the QA Plan is beingfollowed. Validation factors include proofreading files to see that information entered into thecomputer from the test placement/retrieval checklist is correct. Any errors found duringvalidation checks are documented including who made the errors, the dates of the errors, andhow these errors were resolved
Data ReportingThe measurement report shall include:▪ The complete address of the test, including zip code;▪ Company name, contact information and identification of the measurement professional (including MDH licensing number) placing and retrieving the test device;▪ Exact location(s) of the detector(s) including level of home and exact room and location within that room tested;▪ The start and stop, date and times for each measurement device;▪ The detector model or type and identification numbers;▪ The calibration date if using a CRM;▪ Hourly data from the CRM must either be included in the report or provided to the client upon request;▪ Removal of or backing out portions of hourly data imbedded within the contiguous sampling period reported shall invalidate the measurement except for removing the 1 st 4 hours for correction factors, 1st 12 hours for closed-house conditions, or 1st 24 hours for newly installed mitigation system;▪ Identification of organization used to analyze detectors;▪ Radon Information Sources including state radon office and how to obtain federal or state guidance documents;▪ The individual and average results of duplicate measurements;▪ Description of observed building conditions and other factors that are temporary in nature and may affect the measurement results;▪ Deviation(s) from protocol;▪ If a mitigation system was present;▪ Recommendations; and▪ If applicable, whether the occupant or responsible party has agreed in writing to abide by the closed house conditions twelve hours before the test and throughout the test period
The measurement report should describe the general limitations of the test such as thefollowing statement:8 RADON MEASUREMENT QUALITY ASSURANCE PLAN▪ There can be uncertainty with any radon measurement due to statistical variations and other factors such as: daily and seasonal variations in radon concentrations; due to changes in the weather and operation of the dwelling; as well as possible interference with the necessary test conditions that could influence the results
All test results include a statement, which recommends that the dwelling be re-tested in eachof the following cases whether or not the dwelling has been mitigated: If a new addition is added or significant renovation occurs; If a ground contact area was not previously tested is occupied or a home is newly occupied; If the home was unoccupied during the test, the home should be retested after occupancy; Heating or cooling systems are significantly altered resulting in changes to air pressures or distribution; If occupied by a new owner; If ventilation is significantly altered by extensive weatherization, changes to mechanical system or comparable procedures; If significant openings to the soil occur due to: o Groundwater or slab surface water control systems (e.g. sumps, perimeter drain tile, shower/tub retrofits, etc.) or, o Natural settlement causing major cracks or penetrations occur in the home’s foundation walls or slab; If significant nearby construction blasting, earthquakes or formation of sink holes nearby; If a mitigation system is altered, modified or repaired
A sample reporting form shall be attached to this QA Plan
6. Internal Quality ControlQuality control refers to the technical activities that measure the attributes and performance ofa process, item, or service against defined standards in order to verify that they meetestablished specifications, including documentation
Commitment to Quality and ObjectiveOur staff is committed to providing customers with accurate, valid, reproducible, anddefensible radon measurements which may be used to make critical decisions about radiation-related environmental health. The due diligence of each employee and contractor involved withradon measurement is critical for achieving this goal
A critical step to insure radon measurements meet nationally accepted quality standards is toconduct quality control (QC) measurements at prescribed rates and systematically over time
QC measurements shall be recorded electronically or in a logbook as soon as practicable, andshall be maintained for a minimum of three years. Failed QC measurements should be repeatedprior to investigation and corrective action
9 RADON MEASUREMENT QUALITY ASSURANCE PLANA measurement system must operate in such a way as to produce repeatable and stable qualitycontrol results. This is accomplished by performing calibration with background checks,crosschecks and duplicates for CRMs, and duplicates, spikes, and blanks for passive methods, aswell as other method-specific checks
Continuous Radon Monitors CalibrationCalibration refers to the process of determining the response of a measurement device to aseries of known radon concentrations and making necessary adjustments to the device
Calibration is made every 12 months or after repair for each CRM by either, the monitormanufacturer or a national radon proficiency program approved calibration laboratoryapproved by the device manufacturer
Any monitor that does not have a calibration certification, dated within 12 months, must beremoved from service
In addition to calibration, an annual background check is performed by purging with clean agedair or nitrogen. The manufacturer or calibration laboratory completes this process at the timeof calibration
Routine Instrument ChecksInstrument checks involve using the manufacturer’s instructions for checking for properworking condition including checking battery voltage levels, cleaning screen inlet ports, andverifying that calibration is up-to-date. Performance checks will be made before everymeasurement
DuplicatesRadon measurements, like all measurements, usually do not produce exactly the same results,even for simultaneous, co-located measurements. Duplicate are two side-by-sidemeasurement devices placed 4 to 8 inches apart, or as specified by the manufacturer, thatsimultaneously measure radon
The objective of duplicate tests is to assess the precision error of the measurement method or,in other words, how well two side-by-side measurements agree or disagree
Duplicates shall be made at a rate of 10% of all measurement locations or 50 per month,whichever is less. Tests should be randomly distributed and deployed in the normal course ofbusiness across a variety of projects, operators, and environments
When duplicate measurements are made, the results are reported as such to the customer whoreceives the primary test. The individual results and the average of the two will be reported. Inaddition, results of duplicates are recorded on Duplicate Control Charts
10 RADON MEASUREMENT QUALITY ASSURANCE PLANPrecision involving duplicates is calculated by using Relative Percent Difference (RPD). RPD isequal to the difference between the higher test result minus the lower test result divided bythe average of the two duplicate test results, which is then multiplied by 100. The RPD result isthen compared to warning levels and control limits. The Warning Level is set at the deviationfrom ideal performance that would be expected to occur by chance only 5% of the time, andControl Limits are set at that deviation from ideal performance that would be expected to occurby chance only 1% of the time. The Warning Level indicates a potential problem, which shouldbe investigated. The Control Level indicates that the measurement system should be subject tocorrective action and probable recalibration
The control and warning limits for duplicates are:▪ at concentrations averaging less than 2 pCi/L, the control limit is 1 pCi/L,▪ between 2 and 3.9 pCi/L, ▪ the warning level is 50% RPD; ▪ the control limit is 67% RPD;▪ 4 or more pCi/L, ▪ the warning level is 28% RPD; ▪ the control limit is 36% RPD
If within any 30-day period, precision errors are found that exceed control limits or if any twoexceed warning levels within a month, an investigation will be launched, if applicable, inconsultation with the analytical laboratory and state authorities
CrosschecksCrosschecks are conducted to determine bias and are made every 5 to 7 months after a CRMhas been calibrated. For at least 48 hours, the CRM past calibration by 5 to 7 months(designated as CRM-1) is cross-checked with any CRM that has been calibrated within the past12 months but not at the same time as CRM-1 (designated as CRM-2). This procedure is mosteffective when CRM 2 has been recently calibrated. When possible, a crosscheck is performedin an environment with a radon concentration that is about 4 pCi/L or greater
When crosscheck measurements are made, the results are reported as such to the customerwho receives the primary test. The individual results and the average of the two will bereported. In addition, the results of crosscheck measurements are recorded on a CrosscheckControl Log and Chart
The crosscheck is also counted as a duplicate and RPD is calculated the same as a duplicate
Passive Devices Routine Instrument ChecksChecks include examining packaging upon both receipt and disbursement of the devices
11 RADON MEASUREMENT QUALITY ASSURANCE PLAN DuplicatesRadon measurements, like all measurements, usually do not produce exactly the same results,even for simultaneous, co-located measurements. Duplicates are two side-by-sidemeasurement devices placed 4 to 8 inches apart, or as specified by the manufacturer, thatsimultaneously measure radon
The objective of duplicate tests is to assess the precision error of the measurement method or,in other words, how well two side-by-side measurements agree or disagree
Duplicates shall be made at a rate of 10% of all measurement locations or 50 per month,whichever is less. Tests should be randomly distributed and deployed in the normal course ofbusiness across a variety of projects, operators, and environments
When duplicate measurements are made, the results are reported as such to the customer whoreceives the primary test. The individual results and the average of the two will be reported. Inaddition, results of duplicates are recorded on Duplicate Control Charts
Precision involving duplicates is calculated by using Relative Percent Difference (RPD). RPD isequal to the difference between the higher test result minus the lower test result divided bythe average of the two duplicate test results, which is then multiplied by 100. The RPD result isthen compared to warning levels and control limits. The Warning Level is set at the deviationfrom ideal performance that would be expected to occur by chance only 5% of the time, andControl Limits are set at that deviation from ideal performance that would be expected to occurby chance only 1% of the time. The Warning Level indicates a potential problem, which shouldbe investigated. The Control Level indicates that the measurement system should be subject tocorrective action
The control and warning limits for duplicates are:▪ at concentrations averaging less than 2 pCi/L, the control limit is 1 pCi/L,▪ between 2 and 3.9 pCi/L, ▪ the warning level is 50% RPD; ▪ the control limit is 67% RPD;▪ 4 or more pCi/L, ▪ the warning level is 28% RPD; ▪ the control limit is 36% RPD
If within any 30-day period, precision errors are found that exceed control limits or if any twoexceed warning levels within a month, an investigation will be launched, if applicable, inconsultation with the analytical laboratory and state authorities
BlanksBlanks are measurements performed to determine if the measurement device may haveunintended exposure (background) during storage, handling and shipping. A blank is anunexposed measurement device that is opened, immediately closed and sealed, and, like anexposed measurement device, labelled with plausible start and stop dates and times, and then12
The purpose of this Quality Assurance (QA) Plan is to: set policies, performance goals, and objectives; identify responsibilities; establish procedures for assessing performance …
This new American National Standard addresses the complexities of properly mitigating multifamily dwelling over four units that require specialized techniques and quality assurance. This American National Standard is the first complete consensus standard and is an update of the 1993 EPA Protocol on Radon and Radon Decay Measurement in Homes.
As a general principle, the Federal government’s reliance on privately developed voluntary consensus based standards is to be preferred over the Federal government developing such standards. For more information, please visit " Guidance on the Use of Voluntary Consensus Standards for State Indoor Radon Grant Recipients ."
This new American National Standard addresses the complexities of properly measuring radon in large and complicated building structures that require specialized techniques and quality control and assurance to address complicated building designs and specialized airflow. This ANSI/AARST standard is for measuring radon levels in multifamily housing.
This standard specifies minimum requirements for quality systems designed to quantify the concentration of radon-222 gas in air by qualified professionals (QPs) and laboratories, whose data are intended to be used to determine the need for, or success of mitigation.