Radon action guide for provinces and territories: Overview

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The National Radon Program at Health Canada can help provinces and territories develop programs and policies to deal with radon. Get in touch with us for further assistance at radon@hc-sc.gc.ca.

Summary

Radon is a naturally occurring radioactive gas that emanates from the ground and can enter and accumulate in buildings. Radon gas is found in every building in Canada at some level. Radon exposure is the leading cause of lung cancer after smoking, and accounts for an estimated 16% of lung cancer deaths in Canada. Radon risk reduction is easy to address through testing and mitigation. Simple tests involve placing a long-term radon detector in the lowest lived-in level of a building for 3 months during the fall to winter months. Health Canada estimates that about 7% of homes will have a high radon level. This percentage varies significantly across Canada, as indicated by Health Canada's radon map. There are relatively inexpensive and very effective ways to reduce radon exposure in homes and buildings with high radon levels, that is, over the Canadian radon guideline of 200 Bq/m3.

This Radon Action Guide provides many steps provinces and territories can take to reduce radon exposure. Radon affects all types of buildings, and radon action affects many different areas of law and policy concerned with the built environment, from real estate transactions to workplace standards. In Canada’s federal system, the federal government can create guidelines and technical standards, but the provinces and territories are uniquely situated to make law and policy change. Provinces and territories can become leaders in advancing radon action through individual actions across areas such as:

This guide describes how provinces and territories can develop more comprehensive radon strategies.

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Introduction

Radon gas is a naturally occurring radioactive gas that comes from the breakdown of uranium in the ground. While radon is found in every building in Canada, exposure to higher concentrations has significant health effects. Radon exposure is the leading cause of lung cancer after smoking, and accounts for more than 3,000 lung cancer deaths in Canada. The Government of Canada radon guideline is set at 200 Bq/m3. Remedial measures should be undertaken whenever the average annual radon concentration exceeds the Canadian guideline in normally occupied areas of buildings. Across Canada an average of 7% of homes have radon concentrations that exceed the guideline. Radon levels in buildings vary significantly by geography and building characteristics. Surveys have found that in parts of New Brunswick and Manitoba over 40% of homes tested were above the Radon Guideline and in some cities, such as Castlegar, British Columbia and Regina, Saskatchewan over half of homes surveyed have been found above Canada’s Radon Guideline of 200 Bq/m3. Public awareness remains low and a vast majority of Canadian homeowners (more than 90%) have never tested for radon.

Health Canada has developed guidance on radon testing in homes. Testing ideally involves placing a small detector in the lowest regularly occupied level of the home (basement or main floor) for at least 3 months during the heating season. These DIY long-term test kits typically cost $30 to $60 and are available from a variety of online suppliers and hardware stores. “Real-time” digital monitors are also available and can give a short snapshot of radon levels, but should be supplemented with 3-month tests. Radon measurement services from Canadian-National Radon Proficiency Program (C-NRPP) certified professionals are also available, at a much higher cost than the DIY test kits. If test results are high, mitigation professionals can install a radon mitigation system that will reduce the radon level. Techniques to lower radon levels are effective and can save lives. A radon mitigation system, which can be installed in less than a day, will reduce the radon level by more than 80% in most homes. The cost is about the same as other common home repairs, such as replacing the furnace or air conditioner. While waiting for mitigation, people can also temporarily open windows on the lowest level of the home or run a well-maintained mechanical ventilation system to dilute with fresh air.

There are good reasons for provinces and territories to take action on radon. People look to their governments to help them reduce risks and lead healthier, safer lives. Radon is one of a number of emergent indoor air quality concerns which lead to a focus on indoor environmental health. Radon is included in Health Canada’s residential indoor air quality guidelines. Radon mitigation is a relatively inexpensive exercise, and well-designed government radon strategies can be a cost-effective way to save lives.Reference 1

Health Canada’s National Radon Program (NRP) has taken a number of steps to ensure radon is taken seriously in Canada. It:

However, in Canada’s federal system, provinces and territories have jurisdiction over buildings, public health and air quality. Provincial and territorial action is needed to ensure radon is fully addressed. Provincial governments need to ensure radon is addressed by provincial public health agencies, and incorporated into relevant laws regulating the indoor environment. Most radon exposure occurs in homes,Reference 3 and as such, important areas for change are:

Workplaces, schools and care facilities are also important places to reach.

This guide will help guide provincial and territorial governments in developing programs to address radon. It describes broader radon planning and strategy development. It also includes:

This guide builds on comparative research that considers existing actions across Canada, as well as internationally, especially in the United States and European Union. Many US states have specific radon legislation, and in the European Union the Basic Safety Standards Directive requires member states to engage in radon planning, resulting in many country-level legal changes.

Health Canada, C-NRPP and other Canadian organizations have produced extensive guides on testing and mitigation. As companions to the Radon Action Guide, the National Radon Program has also produced:

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Planning for radon

Introduction to radon planning and strategies

All buildings have some level of radon in them. The only way to know how much is to test. Addressing radon requires ensuring measures across many different areas, from workplace standards to residential tenancies to schools and more. This guide includes many measures that provinces and territories can take as discrete actions or bundled together. Governments can start with small steps such as public awareness campaigns while comfort around the issue grows. Governments could also take a more visionary approach and develop a radon plan, which has an overarching aim to systematically address the issue and outlines a range of interventions to achieve that goal. This can ensure a consistent, integrated, and comprehensive approach.

By way of example, the European Union’s Basic Safety Standards Directive requires member states to prepare action plans. International examples of radon action plans further expands on the directive. The directive shows important components of radon planning and how member states such as the United Kingdom have followed it for their own national radon plan.

The BC Lung Foundation has also taken the lead by developing a comprehensive document, Radon: Recommendations for a BC Action Plan. The BC Lung Foundation identified that the province needs a good Radon Action Plan with clear targets for reducing radon exposure, which builds in health equity, and ensures, over time, that no one is exposed to elevated radon in indoor spaces. Radon action is a cost-effective health intervention that saves lives and helps protect everyone's right to a healthy environment. It's part of a broader project for our collective future-- transitioning our building stock to ensure adequate and affordable supply, low carbon, made of sustainably sourced materials. and to ensure good occupant's health.

There are important components and general areas of concern that an action plan should address.

Surveillance: A province or territory needs to know where elevated radon is prevalent, and how many homes, workplaces, and other indoor environments have high radon.

Guidelines: A province or territory can look to the Government of Canada’s Radon Guideline (200 Bq/m3) as the standard for what counts as unacceptable levels of radon. This will help drive programs for education and awareness, and a system of policy, incentives, and laws for reducing radon in different types of built environments.

Reduction strategies: Many places (with radon policies) have distinct laws covering different aspects of the built environment. These include specific interventions covering:

In a federal system such as Canada’s, different aspects of radon planning will fall under the jurisdiction of different orders of government. Health Canada’s National Radon Program has:

However, in Canada, the federal division of powers results in significant gaps that fall on provinces and territories to fill. As this guide discusses, there are many steps remaining for provinces and territories, including:

Learn more about important components of radon planning based on international precedent, and how each order of government in Canada has important roles in the process.

Adopt guiding principles, goals and indicators

Cohesive plans require guiding principles. Health Canada’s National Radon Program’s overarching goal is the reduction of radon-induced lung cancer. Provinces and territories are encouraged to set a similar goal in the development of their radon action plans. Other values are also important, such as health equity and ensuring everyone has access to guidance and resources to maintain and improve good health. When worked into radon planning, health equity can mean adopting policies ensuring lower income homeowners can get subsidies or incentives to remove cost barriers for testing and mitigation. Further steps could include special protections for renters and workers who lack the ability to impose standards in their living and workplaces.

Good planning should build in indicators and targets that are specific, measurable, achievable, and give clear timelines. This will allow policy-makers and the general public to be focused on success and transparently assess the results.Reference 4 For instance, a goal of “reducing the number of homes in the province with elevated radon by half within 10 years” is specific, clear, and measurable and will more directly drive action compared to a vague promise of future reductions.

It is also important to build a process of learning and evaluation into the radon action plan to evaluate what is going right or wrong, learn of unintended consequences, and ensure continuous improvement. Provinces and territories should consider building monitoring and evaluation of programs into the radon policy and planning process. For instance, many provinces have already made changes to their building codes and this could be evaluated with studies to assess whether builders are complying with new building code provisions.

Linkages to other frameworks, strategies and plans

Radon action can be incorporated into broader government policies. For instance, some provinces have chronic disease prevention strategies, which often already address lung cancer. There are dedicated cancer plans which could be extended to include radon action in provinces such as:

A recent focus of city planning has been “healthy built environments” and/or “healthy communities strategies” which promote healthier lifestyles, often including the issue of unhealthy indoor air. These could be extended to include radon action. Ontario’s Health Standards target natural and built environments, including indoor pollutants, and in 2018 were updated to particularly mention radon. Ontario also gives specific direction to health boards to work with municipalities to promote healthy built and natural environments to enhance population health and mitigate environmental health risks. This direction in Ontario has already stimulated a number of health units to take on radon-specific work, including health promotion and coordinated testing programs.

Read about examples of other radon actions that provide language that could be added to:

The Justifications and Policy Rationales for Radon Action document goes into more detail about existing health and environmental strategies in which radon can be included.

Collaboration, partnerships, engagement

Collaboration, consultation, and partnership are important components of policy development and can help to garner public and political support for new initiatives.Reference 5

Provincial level radon planning should include outreach and consultation between:

Health boards and authorities

As previously noted, radon action can be made an important component of health standards and directions given to health boards and authorities. Even without legislative or policy change, provincial and territorial radon planners can work with health boards and authorities to develop and execute a radon action plan. Health boards and authorities will be key players in radon action, given they hold personnel trained in public health and preventive health interventions. Health boards/authorities currently have legal authority to:

Municipalities

Municipalities can play an important role in addressing radon. Municipalities can, for instance, launch their own community testing or incentive programs for testing and mitigation. Municipalities can also help foster coordination between various local authorities such as school boards, libraries and health authorities/boards, each of which can take steps to address radon. Municipalities are the feet on the ground and have a significant role in implementation, ensuring that particular buildings are in fact free of elevated radon levels. Municipalities are responsible for:

These are all important for ensuring low radon in rental accommodations, and places to which the public has regular access.

Provinces and territories can help municipalities with radon action. Provinces and territories can also make clear that radon action is supported by municipal legislation. For instance, municipalities may have broad powers to enact public health bylaws, but when anti-smoking bylaws were being introduced, most provinces clarified municipal law legislation to make it clear that municipalities had the legal power to do so.

Provinces can also:

This guide discusses working with municipalities to ensure Building Code provisions are implemented and inspected, and outlines considerations for new homes. It also discusses model standards of maintenance bylaws that provincial and territorial governments can promote, and outlines considerations for home renters in Canada.

Provincial and territorial governments with an interest in supporting Municipal Radon Action Plans can refer to Radon Action in Municipal Law: Understanding the Legal Powers of Cities and Towns in Canada and Radon Action Guide for Municipalities.

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Finding a home for radon programs

Radon requires a “whole of society” approach in the sense that it requires action across many areas of law, policy, and governmental organization that touch on the built environment.Reference 6 This means that any one agency may face significant barriers to solving the problem if left on its own. For instance, public health ministries are an obvious place to lead a radon action plan. There are important precedents where health officers have interpreted Public Health legislation to take action on radon in AlbertaReference 7 and BC.Reference 8 In Ontario the Public Health Standards have triggered important local level testing initiatives and public outreach. However, if radon is treated as the exclusive domain of public health officers, they may find they have no legislative mandate to make important changes, such as might be required to:

More comprehensive radon planning can help ensure issues are not siloed and create intergovernmental cooperation. Governments should consider a single agency for administering the radon action plan that will:

Another approach is to form a radon working group, a multi-stakeholder task force that brings together radon stakeholders including, as appropriate, staff from relevantReference 9:

References

Reference 1

Gaskin, J., Coyle, D., Whyte, J., Birkett, N. and Krewksi, D., 2019. “A cost effectiveness analysis of interventions to reduce residential radon exposure in Canada,” Journal of Environmental Management 247, pp. 4

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Reference 2

Chen, J., Moir, D. and Whyte, J., 2012. “Canadian population risk of radon induced lung cancer: a re-assessment based on the recent cross-Canada radon survey,”Radiation Protection Dosimetry 152(1-3), pp.-13. Chen, J., 2013. “Canadian lung cancer relative risk from radon exposure for short periods in childhood compared to a lifetime,” International Journal of Environmental Research and Public Health 10(5), pp. 1916-1926. Chen, J., Bergman, L., Falcomer, R. and Whyte, J., 2015. “Results of simultaneous radon and thoron measurements in 33 metropolitan areas of Canada,” Radiation Protection Dosimetry 163(2), pp. 210-216. Chen, J. 2019. “Risk Assessment for Radon Exposure in Various Indoor Environments,” Radiation Protection Dosimetry 185 (2), pp. 143–150.

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Reference 3

Chen, J., 2019. “Risk assessment for radon exposure in various indoor environments,” Radiation Protection Dosimetry185(2), pp. 143-150.

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Reference 4

Boyd, D. 2016, Cleaner, greener, healthier: a prescription for stronger Canadian environmental laws and policies. Vancouver: UBC Press, p. 227.

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Reference 5

De Savigny, D. and Adam, T. eds., 2009. Systems thinking for health systems strengthening. World Health Organization. 82

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Reference 6

Kickbusch, I. and Behrendt, T., 2013. Implementing a Health 2020 vision: governance for health in the 21st century. Making it happen. World Health Organization. Regional Office for Europe. Addy, N.A., Poirier, A., Blouin, C., Drager, N. and Dubé, L., 2014. Whole‐of‐society approach for public health policymaking: a case study of polycentric governance from Quebec, Canada. Annals of the New York Academy of Sciences1331(1), pp. 216-229.

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Reference 7

See Public Health Act, RSA 2000, c. P-37 s. 59 to 61, and the Nuisance and General Sanitation Regulation, Alta Reg 243/2003, using “Nuisance” defined as “a condition that is or that might become injurious or dangerous to the public health, or that might hinder in any manner the prevention or suppression of disease” (Public Health Act, s. 1(ee)). This is further discussed in Quastel et al., ibid. at p. 86.

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Reference 8

Using the Community Care and Assisted Living Act, S.B.C. 2002, c. 75 which empowers medical health officers to attach terms and conditions to a license (s. 11) and to revoke licenses if there is a risk to persons in the care of such facilities (s. 14). For further discussion see Phipps, E., Nicol, A.M., Giesbrecht, D., Cooper, K., Baytalan, G. and Bush, K., 2017. Call for action on radon in child care settings. Environmental Health Review 60(3), pp. 77-81. Quastel, et. al., ibid. at p. 93

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Reference 9

As reported to authors as Nova Scotia practice by John Drage, Senior Geologist/Hydrogeologist, Geoscience & Mines Branch, Department of Lands and Forestry, Nova Scotia

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