Handbook of Radon.

43. How radon could have been addressed.

In order to understand why radon has developed into such a sensitive and contentious issue in the UK it is necessary to go back to the early 1980s.

An initial and perhaps superfluous observation is that many vested interests were involved.

In the early 1980s, the first contemporary surveys of houses were being undertaken. The first batch of high-level houses that were to be addressed by the author in 1988/89 were discovered in 1981/82.

Some of the earliest interest in domestic radon came from BRE. A contract was let to NRPB to undertake preliminary work. NRPB were at that time not too interested, despite that radon in houses had been known for decades to be a problem in Sweden and in Canada since the 1970's. Essentially this was a matter of personalities, but all was set to change.

In 1976, eighty UK dwellings were measured for indoor radon levels. By the mid to late 1980s sufficient monitoring, mainly using track etch detectors, had been undertaken in houses to confirm a problem in Devon and Cornwall especially. Similar work was undertaken in Sweden in the 1950s and 1960s and in a few States of the USA in the mid 1980s.

However, policy determination was somewhat in abeyance, having been the responsibility of a Division in DOE concerned more with toxic chemicals. This lack of a focus enabled NRPB to take more of a pivotal role. In the USA, publicity became dominated by EPA, despite the large scientific program funded by the US Department of Energy.

In the UK, NRPB's formal role remained to advise the Government on risk factors for radiological protection. Most of its work was at that time centred upon occupational exposure, nuclear facilities, etc.

Territorial problems occur of course with and within the EPA in Washington, and occasionally provide dramatic stories in the scientific Press: in discussing one argument a senior EPA official conceded "it was all a matter of turf".

A game it might be, but in the UK also it is played by public officials who are rarely held responsible for their spending decisions. Indeed, the mark of a proficient administrator seems often to be that he (or she) can spend all the available funds. Much public money and effort is wasted in ritual dances between rival Departments.

Politicians seem powerless to prevent this, even if they wanted to, because of a lack of scientific training. In any case, the rituals are ingrained into government.

For over three years the author was involved in discussions centred on how radon should be addressed. Several Sections of the Handbook allude to this situation.

Early on in both countries, a decision could have been taken to put radon into perspective, to lay before the public the risks as compared to those from other aspects of daily living, and to acknowledge that perspectives from nuclear industries and pollution of the outdoor environment were inappropriate as the basis for a strategy.

In fairness, little had been published in the UK, but seminal papers from the USA had appeared in the international literature.

The benefit would have been a better informed public. Much confusion and anxiety could have been avoided. That this was not done is in part a tribute to the ability of administrators to magnify difficulties and then to ensure that they need to spend years discussing how best to resolve them.

In particular, contact with the Press could have been open rather than characterised by fear, limited disclosure, and carefully rehearsed scripts. With few exceptions, little perspective on radon (save that from NRPB) was allowed to be discussed.

What is perhaps more remarkable at first sight is the lack of effort devoted to discovering and remedying the very highest level houses.

In pioneering work during 1987/8, and illustrative of what one dedicated person can achieve, Cornwall County Council's Architects' Department identified where most of their high level schools might be found, and using local mining and geological knowledge. Since that early work, few very high level schools have been found - although obviously complete coverage was necessary to identify all of them.

A similar exercise for housing could have been undertaken as early as 1980, or even in the mid 1970's. Targeted areas could have been offered free testing and (perhaps) free remediation. Some areas might have been 'blighted' but local knowledge of old uranium mines is available. It is normal to find a correlation between uranium and radium deposits and radon problems in buildings. Indeed the early regional surveys in the UK were centred upon areas known for high uranium and other relevant geological features, but on a broad scale only.

Many of the worst affected houses in the UK are associated with geological faults or mining activity. Some have mine shafts beneath them, some have mines in the rear garden and some are on known lodes. Of course, not all of the worst affected areas could have been discovered by desk studies and a little judicious monitoring. However, in Cornwall it is probably easier than in other counties to predict likely locations of high radon houses because of the well studied geology.

It is also easier to use geological features to predict the locations of high level buildings (above 1500 Bq/m3) than those above 200 Bq/m3, because the latter can be found almost anywhere: with high ground permeability even quite normal concentrations of radon in soil gas can give rise to an elevated level indoors.

A realistic action level for public intervention would have been needed - perhaps 2000 Bq/m3 rather than 400 Bq/m3 (the action level in the UK between 1987 and 1990), and with no more than a few hundred houses being found and remedied. Such an initial programme would have needed to concede openly that to address much smaller doses might have been disproportionately expensive within public health budgets.

Central to the analysis would have been Health Economics, a discipline that was not fully developed in the 1970s, and not then even an accepted part of decision making in the National Health Service.

This was essentially the problem: policy was left to those having a radiological interest, and a course was chartered that would enhance and extend the role and remit of radiological protection for decades. Comparisons with other health problems and benefits (kidney machines, cancer and glaucoma screening, CT scanners, and dozens of other causes) were effectively excluded from the early discussions. The Department of Health in the UK only became actively involved in radon at a late stage.

These events and their consequences may be compared with developments in some States of the USA - see Section 40.

In the UK, the preferred radiological options, including definition of 'affected areas' on the basis of a slim (1%) chance of finding a house containing more than 200 Bq/m3 of radon, and suggesting expenditure for mitigation running into perhaps hundreds of millions of pounds, could not command support at a time of public spending restraint. This was especially the case in view of the uncertain risk factors for radon in housing - a topic that was to be addressed in part via epidemiological studies in several countries and commencing in around 1988/89.

To some extent, the sheer magnitude of possible spending on radon may have increased the appeal of these studies: they could buy time in which to organise a response were the clamouring for a massive public programme to prove ultimately irresistible.

There remains of course every need to clarify the risk factors from indoor radon (and especially to separate out those for non-smokers, see Section 28) prior to embarking on widespread and possibly heroic programmes of building modification.

Thus, the few people who genuinely need expert help - those who may continue to live for years with thousands of Bq/m3 and who may unknowingly be incurring a risk equal perhaps to smoking five or even ten cigarettes per day - have had to await their turn as part of a wide-ranging programme covering areas that are only marginally affected.

Under the 'targeted' scheme, perhaps 20,000 houses would have been tested, and 500 remedied. The total cost might have been £1M to £2M plus a few man-years of dedicated buildings research costing perhaps £250,000.

It cannot be claimed that this is all hindsight but probably too much has now been invested in the present approach for there to be any admission of an alternative policy. Any changes will be presented (as is usual) as enhancements built upon the achievements of the past.

Much the same is occurring in the USA. Policies for targeting high risk areas of the country that should (and could) have been adopted five years ago are being claimed as a development from previous policy.

Only a failure properly to comprehend and classify radon as an issue of indoor health and environment divorced from nuclear perspectives seems adequate to explain the extent to which it has been allowed to be pursued on both sides of the Atlantic.

A few scientists have spoken out, and in the USA they have had the benefit of a Freedom of Information Act.

Nevertheless, in terms of specific action, it seems likely that target areas will be identified - as is now being considered in the USA - and houses above a 'super action level' or regulatory standard, chosen perhaps by NRPB, declared in some way as unfit for habitation, or a public health hazard.

Many rented houses have apparently been cured of damp by way of being found to be a statutory nuisance, but it is considered that a test case may find these decisions inappropriate.

There are of course many problems in targeting areas. Houses are the most private of environments, and telling people that they must monitor for radon in order to cure any problem in their home - either for their own good or in the greater public interest - is entirely out of keeping with many peoples' view of the limits of government intervention.

Entirely different perspectives apply in work-places however, where the consensus is to insist on regulations for health and safety that if applied in the home would lead to many prohibition notices. This seems unlikely to change.

Another perspective is that early in the history of domestic radon mitigation in Canada and the USA very stringent standards were set for the residual concentration, because the source of the problem was (or in some cases was thought to be) man-made. Remedial action was officially suggested in the USA above 37 Bq/m3 (a conversion of 0.01 WL radon daughter concentration, see Section 7, and corresponding to around 80 Bq/m3 of radon gas). This is not much above the average radon level in homes in the USA, and even at the time was clearly an unrealistic target for cost effective widespread mitigation.


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