Radon Testing in a Retirement/Nursing Home

[Mike Tracy]

I have been asked by an out of state company to do radon testing on a retirement/nursing home. They are going to supply the canisters and lab costs. They are asking me to handle the placement and retrieval due to state licensing requirements.

Based on the floor plan of buildings, I am looking at placing close to 100 canisters. I am trying to come up with a cost to do this. Any help would be appreciated.

Mike Tacy

[Scott Patterson]

I have been asked by an out of state company to do radon testing on a retirement/nursing home. They are going to supply the canisters and lab costs. They are asking me to handle the placement and retrieval due to state licensing requirements.

Based on the floor plan of buildings, I am looking at placing close to 100 canisters. I am trying to come up with a cost to do this. Any help would be appreciated.

Mike Tacy

How much time do you think you will have invested in the drop off, recoding each canister time & location and then the retrieval and recoding each canister time of test end and then sending them off?

I did a similar project but I provided the test kits. It took me around 5 minutes per location (remember you will have 2 devices per location) so if the 100 canisters are for 50 rooms or locations this means you will have around 4-5 hours just at the site. Add in your drive time and the time to package and overnight to the lab and cost to overnight and this will give you an idea. You will pretty much invest a half day plus setting them up and the same picking them up.

I would be in the $1,600 to $1,800 range for 50 locations on one site.

The test kits are comparatively inexpensive, you can buy charcoal kits with testing for under $10 each all day long. Don't let the fact they are supplying the kits make you think that you should not charge a good fee for doing all of the work.

[Mike Tracy]

How much time do you think you will have invested in the drop off, recoding each canister time & location and then the retrieval and recoding each canister time of test end and then sending them off?

I did a similar project but I provided the test kits. It took me around 5 minutes per location (remember you will have 2 devices per location) so if the 100 canisters are for 50 rooms or locations this means you will have around 4-5 hours just at the site. Add in your drive time and the time to package and overnight to the lab and cost to overnight and this will give you an idea. You will pretty much invest a half day plus setting them up and the same picking them up.

I would be in the $1,600 to $1,800 range for 50 locations on one site.

The test kits are comparatively inexpensive, you can buy charcoal kits with testing for under $10 each all day long. Don't let the fact they are supplying the kits make you think that you should not charge a good fee for doing all of the work.

Thanks Scott. I have done some work for these folks before and has just seven locations and charged a fee for approximately one half day. In counting the rooms with ground contact, it looks like it will be about 159 locations. I think I have an idea of what to charge now.

Mike Tracy, ACI
Tri State Certified LLC

[Scott Patterson]

Thanks Scott. I have done some work for these folks before and has just seven locations and charged a fee for approximately one half day. In counting the rooms with ground contact, it looks like it will be about 159 locations. I think I have an idea of what to charge now.

Mike Tracy, ACI
Tri State Certified LLC

Be sure that 2 test are used per location in order to meet EPA protocols. With 159 locations that will be over 300 test kits and that will take a bunch of time recording all the locations, times, etc.

[Matt Bezanson]

Be sure that 2 test are used per location in order to meet EPA protocols. With 159 locations that will be over 300 test kits and that will take a bunch of time recording all the locations, times, etc.

I believe the 2-test per location requirement is for real estate transactions. For testing buildings like this, you need to be familiar with a different set of standards: "ANSI-AARST Standard: Protocol for Conducting
Radon and Radon Decay Product Measurements in
Multifamily Buildings"

Even if your jurisdiction doesn't require adherence to the standard, it's the best way to cover your backside liability-wise.

[Scott Patterson]

I believe the 2-test per location requirement is for real estate transactions. For testing buildings like this, you need to be familiar with a different set of standards: "ANSI-AARST Standard: Protocol for Conducting
Radon and Radon Decay Product Measurements in
Multifamily Buildings"

Even if your jurisdiction doesn't require adherence to the standard, it's the best way to cover your backside liability-wise.

HI Matt, I have not seen that protocol for a building like this. I found this in the Multi Family guidelines.

4.2.1.1 Simultaneous Testing: Conduct the
measurement at each location with two short term
passive test detectors at the same time in
the same location for at least 48 hours under
closed building protocols. (See 6 below).

Test periods of at least 4 to 5 days are
recommended for multifamily buildings
when short-term tests are employed, because
it is sometimes difficult to ensure closed building
conditions existed 12 hours prior to
the test at every dwelling.

Locate devices no less that 4 inches (10
centimeters) from other test devices and
surrounding objects or as recommended by
the manufacturer or laboratory. The results of
both measurements should be reported. Use
the average of the two results to determine if
this location needs mitigation.

Looks like with passive testing, Multi-Family requires two devices as well. If you have something different please post it so we are all on the same page.

[Stuart Brooks]

I've done this before but not on this scale. I set at least one duplicate and submit a blind for testing. The company supplied charcoal envelopes and shipping via FedEx back to the lab. The test results go directly to my client. Make sure the building management sends a maintenance manager or someone similar to enter the apartments when you set and retrieve the tests. I generally set my fee at $50 - $75 per test depending on the number of tests and the distance to travel. If they supply charcoal envelopes, takes some tape, string, and push pins with you. Sometimes finding a place to set them is difficult.

[Caoimhín P. Connell]

I suggest you determine why the facility wants the work performed before you do anything.

Two years ago, I was involved in a law suit wherein a mining operation needed radon monitoring for regulatory purposes. An Home Inspector foolishly decided that he knew something about radon, radiation and monitoring since he was a “Certified� radon guy.

The Home Inspector put out a bunch of those goofy little charcoal canisters believing they could actually measure radon. The mining company relied on the “results� and was subsequently threatened with a fine by the regulatory agency. To settle the matter, the Home Inspector was told to take his invoice and pound sand – the mine hired an Industrial Hygienist to perform the necessary exposure monitoring. The Home Inspector was lucky he was not sued.

The EPA protocol used in real estate transactions is entirely incapable of actually measuring radon and is entirely incapable of performing any kind of radiation exposure data. The protocol has no basis in actual science and cannot be used outside of the intended real estate context.

So – it would be advisable to first learn why the facility needs to perform the work, and if it has anything to do with actual exposure assessments or radiation issues, then I suggest you contact a Health Physicist or an Industrial Hygienist.

Cheers!
CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

AMDG

[Ken Rowe]

The EPA protocol used in real estate transactions is entirely incapable of actually measuring radon and is entirely incapable of performing any kind of radiation exposure data. The protocol has no basis in actual science and cannot be used outside of the intended real estate context.

Could you explain this please? I'm curious as the Radon Technician Measurement Course I went through doesn't focus on "real estate context" and I utilize CRMs.

[Stuart Brooks]

I suggest you determine why the facility wants the work performed before you do anything.

Two years ago, I was involved in a law suit wherein a mining operation needed radon monitoring for regulatory purposes. An Home Inspector foolishly decided that he knew something about radon, radiation and monitoring since he was a “Certified� radon guy.

The Home Inspector put out a bunch of those goofy little charcoal canisters believing they could actually measure radon. The mining company relied on the “results� and was subsequently threatened with a fine by the regulatory agency. To settle the matter, the Home Inspector was told to take his invoice and pound sand – the mine hired an Industrial Hygienist to perform the necessary exposure monitoring. The Home Inspector was lucky he was not sued.

AMDG

The facilities were being sold and the buyer's commercial representatives wanted random tests performed. Their reps contacted an outfit in Colorado to handle all environmental testing. They contacted me, asked what I would charge to set the tests, retrieve them and ship to the lab. They supplied the charcoal envelopes - registered to them, how many tests they wanted set, to include one duplicate test and one blind test, then included the FedEx shipping label to the lab. I set the tests, record the information of where and when. I then return to pick them up after two days and record the time. I packed and shipped the tests and got my check. I never see the test results. I'm just local labor.

I'm not a fan of charcoal tests. If given the time I would use my CRMs. Since I only have three, I would have to rotate them through the test locations.

[Stuart Brooks]

Could you explain this please? I'm curious as the Radon Technician Measurement Course I went through doesn't focus on "real estate context" and I utilize CRMs.

Ditto! I don't think EVERYTHING dealing with environmental issues has to be a scientific study. Waiting to see the reply. I want to find out how ignorant I am.

[Caoimhín P. Connell]

Hello Mr. Rowe:

In response to your question, you can find a lot of the answers to your questions here::

Radon: Truth vs. myth

Also – I will direct you to the US EPA Document titled:

Protocols for Radon and Radon Decay Product Measurements in Homes
Office of Air and Radiation (6609J) EPA 402-R-93-003, June 1993

The preface of which reads:


Preface
This document, the Protocols for Radon and Radon Decay Product Measurements in Homes (EPA 402-R-92-003, May 1993), is a guidance document. However, one condition of participation in the Agency's National Radon Proficiency Program (RPP) for radon measurement and radon reduction (mitigation) proficiency, is conformance with these protocols. Conformance with its companion document, the Indoor Radon and Radon Decay Product Measurement Device Protocols (EPA 402-R- 92-004, July 1992), is also a condition of participation in the Proficiency Program.

Together these protocol documents provide the technical support for the Agency's radon policy and guidance to consumers that is contained in, but not limited to, the Home Buyer's and Seller's Guide to Radon (EPA 402-R-93-003, March 1993), A Citizen's Guide to Radon (EPA 402-K-92-001), and the
Consumer's Guide to Radon Reduction (EPA 402-K-92-003, August 1992).

I hope that helps!

Cheers!
CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

[Ken Rowe]

CaoimhÃ*n,

I'm well aware of the EPA protocols in radon testing. I passed the Radon Technician Measurement course 10 years ago and have performed several hundred tests over the past 10 years. Information from your website doesn't do anyone any good. It's not from a regulatory agency.

What you seem to be claiming is a Certified Radon Measurement technician shouldn't be testing for radon and that only industrial hygienist should be. Enlighten me on what the industrial hygienist would do differently.

Granted, when dealing with a mine the Mine Safety and Health Administration sets the regulation to follow ANSI N13.8-1973 14.3 and levels are measured in Working Levels, not pc/l. But that's the only industry I can think of that regulates radon levels different than the EPA standards. By the way, most mining operations have the MSHA do the radon monitoring. Granted the home inspector in the case you cited really had no business testing for radon in a mine utilizing charcoal canisters, as none measure working levels, but in all reality, the mine had no business hiring him either.

[Stuart Brooks]

CaoimhÃ*n,

I'm well aware of the EPA protocols in radon testing. I passed the Radon Technician Measurement course 10 years ago and have performed several hundred tests over the past 10 years. Information from your website doesn't do anyone any good. It's not from a regulatory agency.

What you seem to be claiming is a Certified Radon Measurement technician shouldn't be testing for radon and that only industrial hygienist should be. Enlighten me on what the industrial hygienist would do differently. ...snipped

Ken - I looked at his site and link a couple of years ago and found that his links to supporting documentation were to his own documentation. Yes, I'm with you on this. What would a IH do differently especially in home or small commercial testing. From his prior posts, I think his biggest beef is the apparently arbitrary 4 pCi/l limit. I remember reading somewhere that the WHO wants to set the limit to 2.7 pCi/l.

[Caoimhín P. Connell]

Good morning, Mr. Rowe:

I too passed the EPA radon proficiency test – 23 years ago. I aced the test, what was your score? Mind you, in order to get a perfect score on the test, I realized it was necessary to answer several of the question incorrectly, but in a way that the EPA wanted them to be answered.

What you seem to be claiming is a Certified Radon Measurement technician shouldn't be testing for radon and that only industrial hygienist should be. Enlighten me on what the industrial hygienist would do differently.

Answer:
No respectable, knowledgeable, ethical Industrial Hygienist would perform residential testing for radon. A respectable, knowledgeable, ethical Industrial Hygienist would understand the radiation toxicology and epidemiological studies associated with radon in homes and educate the homeowner that there is no known risk associated with residential radon and advise the homeowner that it is a scam and not to waste their money.

Information from your website doesn't do anyone any good. It's not from a regulatory agency.

Response:
That’s a fascinating line of logic I have never encountered before. I supposed that a medical degree from Harvard would be similarly useless in your mind since Harvard is not a government agency either.

The information on my page comes from a guy who was a radiation safety officer for 16 years, and who used to teach radiation toxicology at places like the Rocky Flats Nuclear facility and performed radiation safety audits for obscure places like the Los Alamos National Laboratory, so what would I know eh?

Do you really believe that your CWL monitor is measuring radon? Apparently so – and that comes from the fact that the EPA training program is pitched so that a person with a Sixth Grade education can pass it – were you aware of that?

If you read the information on my page, you would also learn that the EPA “pCi/l� (or as you incorrectly call it “pc/l�) is not translatable to a real pCi/l – were you aware of that? Apparently not.

I can safely say that for all your “hundreds� of tests over the last ten years – you have never… NEVER… not once, ever in your career, ever measured radon. You just think you have, because you are an EPA Certified radon guy and you think that your radon class actually taught you something about radon, radiation, and sampling theory – but it didn’t, Mr. Rowe. Which is why EPA Radon certified contractors are never hired to perform legitimate regulatory radiation exposure monitoring.

I hope that helps.

Cheers!
CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

P.s. - Mr. Brooks has a long history of just making up his own "facts" as he goes along, (as evidenced by his last post) and is not known for his intellectual honesty and I no longer respond to his comments.

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

AMDG

[Ken Rowe]

Actually your statements don't help at all. Yes, I understand I don't measure actual radon levels, but the byproducts of decomposition of the radon. I also understand that 100 medical degrees from Harvard are useless if those holding the degrees can't pass their licensing exam because they refuse to follow regulatory protocol. I further understand that you're getting very defensive and I'm sorry to have put you in that position.

But, you haven't answered the question. How would an industrial hygienist measure radon differently than a certified measurement tech?

By the way, we're not hear to debate whether you think radon is harmful. We're not here to debate EPA action levels. What you or I think has no bearing on the protocols set forth by regulatory agencies.

Ps. sorry for my previous typo, good thing you caught it or nobody would have know what I was referring to.

[Caoimhín P. Connell]

Hello Mr. Rowe –

Actually I’m not defensive at all. I literally spend most of my day preparing arguments in one form or another. That is what I do.

But, you haven't answered the question. How would an industrial hygienist measure radon differently than a certified measurement tech?

Yes, I did answer your question in the above post where I said:

Answer:
No respectable, knowledgeable, ethical Industrial Hygienist would perform residential testing for radon. A respectable, knowledgeable, ethical Industrial Hygienist would understand the radiation toxicology and epidemiological studies associated with radon in homes and educate the homeowner that there is no known risk associated with residential radon and advise the homeowner that it is a scam and not to waste their money.

Next:

By the way, we're not hear to debate whether you think radon is harmful. We're not here to debate EPA action levels. What you or I think has no bearing on the protocols set forth by regulatory agencies.

Actually, I’m here to “debate� the original post which exlisively had to do with the establishment of data quality objectives, and had nothing to do with regulatory agencies. Which is why I prefaced my original response with:

I suggest you determine why the facility wants the work performed before you do anything.

Look, I’m not an home inspector, I would be horrible as an home inspector, I would be completely incompetent as an home inspector, and that is why I hire my own favorite home inspector when I buy an house. I’m a scientist, I eat and breathe chemistry, toxicology and epidemiology, physiology microbiology – and radiation falls into that. My point is that if an Home Inspector thinks that just because they went to a three day class on radon, suddenly they are an expert on radon, or sampling, or radiation, and leave the primary area of “measuring radon� outside the context of real estate, they are entering into a field for which they have no competency.

Therefore, as I said, in my original response:

So – it would be advisable to first learn why the facility needs to perform the work, and if it has anything to do with actual exposure assessments or radiation issues, then I suggest you contact a Health Physicist or an Industrial Hygienist.

Now – I hope that helps.

CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

AMDG

[Ken Rowe]

Read the original post; he's been asked to do RADON TESTING at a NURSING HOME. Not an radiation exposure assessment and not in a mine. Therefore EPA radon testing protocols are to be used.

So, let me get this straight:

So – it would be advisable to first learn why the facility needs to perform the work, and if it has anything to do with actual exposure assessments or radiation issues, then I suggest you contact a Health Physicist or an Industrial Hygienist.

No respectable, knowledgeable, ethical Industrial Hygienist would perform residential testing for radon.

My point is that if an Home Inspector thinks that just because they went to a three day class on radon, suddenly they are an expert on radon, or sampling, or radiation, and leave the primary area of “measuring radon� outside the context of real estate, they are entering into a field for which they have no competency.

So you want the client to contact an unrespectable, unknowledgeable, unethical Industrial Hygienist to perform their radon test because Certified Radon Measurement technicians have no competency? And you're not being defensive?

Why don't you just admit that the Certified Radon Measurement technician would be performing the exact same test (other than in a mine) as an Industrial Hygienist? They both need to follow appropriate protocols, they're both using the same equipment and as you stated, with all your degrees and experience you had to attend the same three day class to get certified.

[Caoimhín P. Connell]

Good morning, Mr. Rowe –

I’m not entirely sure how you able to misunderstand my posts to such an extreme degree.

The original poster was asking about performing radon testing as a nursing home. My original answer was to advise the poster to first determine “why� the facility was requesting the service. Answering the “why� will dictate the necessary data quality objectives; which in turn will dictate the necessary protocol, and will therefore dictate the necessary technical proficiency of the consultant, which will speak to the issue of whether it should be an Home Inspector, or a Health Physicist/Industrial Hygienist.

Until the “why� questions has been asked, you would not know if the EPA protocols were appropriate or not, since you would not know the data quality objectives. You are merely assuming, without foundation, that you know why the facility has requested the service.

Mr. Rowe – if you want to engage me, you must actually read what I have said, and not impugn to me things I have not said. Nowhere in my post did I ever suggest the client “…contact an unrespectable, unknowledgeable, unethical Industrial Hygienist to perform their radon test because Certified Radon Measurement technicians have no competency.�

What I said was “No respectable, knowledgeable, ethical Industrial Hygienist would perform residential testing for radon.� That is the answer to your question when you asked:

But, you haven't answered the question. How would an industrial hygienist measure radon differently than a certified measurement tech?

I have now answered your question three times, and for some reason, you cannot see my answer.

Why don't you just admit that the Certified Radon Measurement technician would be performing the exact same test (other than in a mine) as an Industrial Hygienist?

Answer:
Because they wouldn’t. No respectable, knowledgeable, ethical Industrial Hygienist would perform residential testing for radon.

They both need to follow appropriate protocols, they're both using the same equipment ...

Answer:
No they wouldn’t . The Industrial Hygienist would determine the necessary data quality objectives, and select a protocol to meet those data quality objectives and use equipment that would be commensurate with the data quality objectives. The home inspector would use the EPA protocol which is entirely incapable of producing legitimate data.

…with all your degrees and experience you had to attend the same three day class to get certified.

Again that is not true, you are very badly misinformed. I am not required to use the EPA protocols. If I were to perform “radon monitoring� and an home, I am not bound to follow the EPA protocols. If I were to perform “radon monitoring� in an home, I would not have to be certified by the EPA to perform the work in residences. If I were hired to challenge the work from an EPA Certified radon guy in an house and the case went to court, my opinions and my protocols, would take precedence over the work of the EPA Certified Home Inspector, since my work is evidence-based, objective science. The EPA Certified radon guy’s work, is not evidence-based, objective science it is a blind adherence to a protocol that is not accepted by science.

In any event, I do not perform such testing, since there is no market for legitimate radiation exposure monitoring in residences.

If you don’t read my posts, Mr. Rowe, there is little benefit in answering your comments.

I hope that helps.

Cheers!
CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

AMDG

[Stuart Brooks]

Ken - nice work! Really getting to a sometimes very pompous ego. Nicely put points.

I've known many totally useless PhDs. They are too often professional students who were brilliant at researching a very narrow topic. They had no real life work experience and no common sense. If you took them outside of there specialty field they were lost. So having medical degrees, advanced degrees, or whatever doesn't automatically make them someone you would trust with your life; anymore than an incompetent IH (not pointing any fingers - truly).

I do say that blowing off Radon would be, for a home inspector, a very serious liability issue. In my Radon classes, it was stressed over and over to ALWAYS preface any statement about Radon or dangers from Radon with "According to the EPA". Otherwise, we would be purporting ourselves as experts, which we are not.

I'm sure Mr Connell could find a few people who would disagree with his theories at CanSAR: Cancer Survivors Against Radon ‎

[Ken Rowe]

I’m not entirely sure how you able to misunderstand my posts to such an extreme degree.

I haven't misunderstood anything you've said. In fact, I've quoted you. You make no sense whatsoever. The OP stated RADON TESTING. There, I've put it in bold for you again. Radon testing done anyplace other than a mine would follow EPA protocols.

An Industrial Hygienist would have to follow EPA protocols which means they would have to use the same procedures and equipment approved by the EPA that a radon measurement tech would use.

You stated the client should contact an Industrial Hygienist for testing, then went on to say no respectable, knowledgeable, ethical Industrial Hygienist would perform the test. Leaving the only possible conclusion that you want the test to be performed by an industrial hygienist who is not respectable, unknowledgeable and unethical.

Now you're claiming to have never said that.

If I were hired to challenge the work from an EPA Certified radon guy in an house and the case went to court, my opinions and my protocols, would take precedence over the work of the EPA Certified Home Inspector, since my work is evidence-based, objective science. The EPA Certified radon guy’s work, is not evidence-based, objective science it is a blind adherence to a protocol that is not accepted by science.

Please provide a case history where this has ever happened, as I don't believe it ever has.

[Caoimhín P. Connell]

Hello Mr. Rowe:

It’s becoming clear you are not reading my responses. Nevertheless, for the benefit of those following the thread, I’ll continue.

The OP stated RADON TESTING. There, I've put it in bold for you again. Radon testing done anyplace other than a mine would follow EPA protocols.

Simply not true, Mr. Rowe. You are very badly misinformed. The ONLY time the EPA protocols should be followed is when an otherwise untrained radon consultant performs “radon testing� in a residential setting and usually for a real estate transaction, and no other time. As I mentioned, if I were to perform a “radon� evaluation in a residential home, I would NOT be required to follow the EPA protocol (and in fact, my professional reputation would be harmed if I did follow the EPA protocols, since I would be held to a much higher standard than the US EPA protocols afford).

An Industrial Hygienist would have to follow EPA protocols …

Simply not true Mr. Rowe – you are laboring under a profound misconception. Please see what I stated earlier. There's no point in responding, if you won't fully read what I've stated.

… which means they would have to use the same procedures and equipment approved by the EPA that a radon measurement tech would use.

Simply not true Mr. Rowe – YOU would have to follow the EPA protocols, and my professional reputation would be harmed if I “lowered� myself to using such junk-science protocols in an evaluation – even in a residential evaluation. I do NOT have to follow the EPA protocols; I am held to an higher standard of care.

You stated the client should contact an Industrial Hygienist for testing,

Simply not true Mr. Rowe – please go back and read what I actually said, you are very, very, very confused.

… then went on to say no respectable, knowledgeable, ethical Industrial Hygienist would perform the test.

Yes, at least you got that part right.

Leaving the only possible conclusion that you want the test to be performed by an industrial hygienist who is not respectable, unknowledgeable and unethical.

Now I just have to conclude with how I prefaced my previous post:

� I’m not entirely sure how you able to misunderstand my posts to such an extreme degree.�

And now, by your responses, I suspect that the casual reader will quite fully understand my point.

Good luck to you, Mr. Rowe, I suspect I’ve gone as a far as I can with this.

Cheers!
CaoimhÃ*n P. Connell
Forensic Industrial Hygienist
Forensic Applications Consulting Technologies, Inc. - Home

(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)

AMDG

[Ken Rowe]

As I mentioned, if I were to perform a “radon� evaluation in a residential home, I would NOT be required to follow the EPA protocol (and in fact, my professional reputation would be harmed if I did follow the EPA protocols, since I would be held to a much higher standard than the US EPA protocols afford).


my professional reputation would be harmed if I “lowered� myself to using such junk-science protocols in an evaluation – even in a residential evaluation. I do NOT have to follow the EPA protocols; I am held to an higher standard of care.

Please explain to all of us how the standards you follow differ than the standards the EPA has in place. Please cite the government standards you would have to follow. Your ramblings on your own website don't count.

If I were hired to challenge the work from an EPA Certified radon guy in an house and the case went to court, my opinions and my protocols, would take precedence over the work of the EPA Certified Home Inspector, since my work is evidence-based, objective science. The EPA Certified radon guy’s work, is not evidence-based, objective science it is a blind adherence to a protocol that is not accepted by science.

Again I'll ask you to cite case law regarding your disregard for the EPA protocols. Again, your ramblings on your own website don't count.