Criteria for EPA Evaluation of Non-Federal National Radon Proficiency Programs

Transcription

1 Criteria for EPA Evaluation of Non-Federal National Radon Proficiency Programs U.S. Environmental Protection Agency Office of Air and Radiation Office of Radiation and Indoor Air Indoor Environments Division (6609J) 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

2 Table of Contents I. Introduction... 1 II. EPA s Recognition of Non-Federal Radon Proficiency Programs... 2 A. Recognition Development of Criteria Application Process... 2 B. Application for Recognition... 3 III. Evaluation Criteria for Analytical Service Provider Programs, and Residential Measurement and Mitigation Service Provider Programs... 3 A. Criteria for Recognition of an Analytical Service Provider Program Device Performance Test Develop and Implement a Quality Assurance Plan Adhere to Protocols Reassessment of Qualifications on a Biennial Basis Compliance with Program Requirements... 6 B. Criteria for Recognition of a Residential Measurement Service Provider Program Examinations Adhere to Protocols Develop and Implement a Quality Assurance Plan Reassessment of Qualifications on a Biennial Basis Provide Lists of Certified/Proficient Individuals Compliance with Program Requirements Consumer Information... 9 C. Criteria for Recognition of a Residential Mitigation Service Provider Program Training Examinations Adhere to EPA Radon Mitigation Standards Reassessment of Qualifications on a Biennial Basis Provide Lists of Certified/Proficient Individuals Compliance with Program Requirements Appendix A - List of Resources Appendix B - Sample Acknowledgment Letter to Successful Applicants Appendix C - Sample Letter to Applicants Who are Denied Acknowledgment i-

3 Criteria for EPA Evaluation of Non-Federal National Radon Proficiency Programs I. Introduction In 1988, Congress enacted the Indoor Radon Abatement Act (IRAA), which established a long-term national goal to reduce indoor radon levels to the point that air within buildings is as free of radon as the air outside. Under 15 USC 2665, 305(a)(2), Technical Assistance to States for Radon Programs, IRAA provided EPA authority to develop and implement activities designed to assist State radon programs, including operation of a voluntary program to rate the effectiveness of radon measurement devices and methods, the effectiveness of radon mitigation devices and methods, and the effectiveness of private firms and individuals offering radonrelated services. In response to this authorization, EPA established the Radon Measurement Proficiency (RMP) Program to assist consumers in identifying organizations capable of providing reliable radon measurement services. The Radon Contractor Proficiency (RCP) Program was established in 1989 to evaluate the proficiency of radon mitigators in residences and provide information to the public on proficient mitigators. In 1991, EPA expanded the RMP Program, adding a component to evaluate the proficiency of individuals who provide radon measurement services in the home. In 1995, these Programs were consolidated to form the National Radon Proficiency Program (RPP). A number of factors contributed to EPA s closing down its RPP on September 30, In addition to EPA s budgetary constraints, the radon industry itself had matured and appeared willing and capable of running their own proficiency program. Prior to closing its RPP, EPA began investigating the feasibility of privatizing the RPP and worked with stakeholders, and, in particular, the Conference of Radiation Control Program Directors, Inc. (CRCPD) and the American Association of Radon Scientists and Technologists (AARST), to this end. Currently, there are two privately-run National Radon Proficiency Programs, one run by the National Environmental Health Association (NEHA) and one run by the National Radon Safety Board (NRSB). Since the close of EPA s RPP, there have been a number of requests that EPA offer some form of recognition of these non-federal programs. In response to these requests, on May 22, 2000, EPA issued draft criteria that would be used in evaluating these non-federal radon proficiency programs. The draft criteria were posted on EPA s web site, and sent to key stakeholders representing States, consumers, industry, and the two current non-federal radon proficiency programs. EPA received fourteen individual and joint comments on the draft criteria from a wide range of stakeholders and these comments have informed EPA s development of the final criteria. Page 1 of 14

4 II. EPA s Recognition of Non-Federal Radon Proficiency Programs A. Recognition 1. Development of Criteria In its 5/22/00 draft criteria, EPA proposed that it would recognize/re-evaluate private proficiency programs every three years. This periodic review process would have EPA play a substantial continuing role in overseeing any recognized proficiency program which a number of commenters did not support. Moreover, some of the commenters wanted EPA to develop criteria that would require non-federal proficiency programs to comply with standards well in excess of EPA s former voluntary National Radon Proficiency Program (RPP). In consideration of these comments, and to further encourage States, industry, and consumers to be involved in ensuring that non-federal programs meet their needs, EPA has decided that it will offer a one-time process to recognize those programs that apply within a specified period of time. EPA believes that it is appropriate to develop recognition criteria that call for a non- Federal radon proficiency program to incorporate, at a minimum, program elements that comprised EPA s former voluntary RPP. EPA continues to encourage States, industry and consumers to work together to identify those elements that would improve non-federal radon proficiency programs and go beyond EPA s former voluntary RPP. These improved elements should then be adopted as standards of practice. 2. Application Process Upon successful application, a non-federal proficiency program will be recognized as meeting EPA s minimum criteria for a residential measurement service provider program or a residential mitigation service provider program or an analytical service provider program. To achieve this recognition, the non-federal program will have to prove that it contains at least all of the components (or their equivalent) of the applicable portion of EPA s former voluntary National Radon Proficiency Program. These are outlined in further detail in Section III below. EPA will issue a letter of recognition for each program (residential measurement service provider program, residential mitigation service provider program, and/or analytical service provider program) that satisfies EPA criteria. This will be based solely on the information contained in the program s application(s). A copy of these recognition letters will also be posted (see Appendix B and C for samples of each type of letter) on If an applicant does not meet the established criteria, EPA will issue a letter to this effect, and will post this determination on its web site. Page 2 of 14

5 B. Application for Recognition An application for EPA s recognition should be submitted to the following address so that it will be received by EPA no later than March 1, Mr. James W. Long U.S. Environmental Protection Agency Indoor Environments Division (6609J) 1200 Pennsylvania Avenue, N.W. Washington, DC Applicants can submit one application for recognition for one or more program elements (measurement, mitigation and/or analytical), but must fully address the criteria for each of these recognitions in sufficient detail in separate sections of their application. Policy or procedural manuals should be submitted in support of the application. The applicant should highlight any deviation from the criteria in Section III below, and provide a detailed explanation as to why the applicant s program element still remains equivalent to that of EPA s former voluntary National Radon Proficiency Program. EPA encourages all applicants to make public the contents of their application. However, in accordance with established EPA procedures contained in the Code of Federal Regulations, an applicant may assert a business confidentiality claim that covers part or all of their application. If an applicant chooses to assert such a claim, it must do so at the time of application. Information covered by such a claim will be disclosed by EPA only to the extent, and by means of, the procedures set forth in 40 CFR Part 2, Subpart B. Should EPA find that an application is deficient, EPA will give the applicant notice of the deficiencies and give the applicant 30 calendar days from the date of receipt of the notice to remedy them. Failure by the applicant to remedy the deficiencies within the 30-day period will result in a determination that the applicant has not shown that its program element meets EPA s criteria, and such a determination will be posted on EPA s web site. III. Evaluation Criteria for Analytical Service Provider Programs, and Residential Measurement and Mitigation Service Provider Programs A. Criteria for Recognition of an Analytical Service Provider Program Analytical measurement services are defined as radon measurement services or activities that include the capability to extract, read, analyze, or manipulate the data from radon measurement device(s), and calculate the final concentration for the client test report. These capabilities include, but are not limited to, reading and recording initial and final voltages, printing data tapes, recording concentrations from a data window, or downloading the data to a some form of device/system for test report generation. An analytical service provider program shall require its participants to adhere to quality Page 3 of 14

6 assurance/quality control (QA/QC) principles and appropriate radon measurement protocols. 1. Device Performance Test An analytical service provider program shall require a device performance test for each radon test device or method listed by participants in its program. An analytical service provider program shall require participants to provide measurement results that are within at least what EPA s former RPP required, ±25% of the chamber target value. A more detailed discussion of what EPA required in its device performance test is contained in, U.S. EPA National Radon Proficiency Program Handbook, EPA 402-R , July 1996 which is available on the EPA website at: 2. Develop and Implement a Quality Assurance Plan An analytical service provider program should develop criteria for a quality assurance program and the program should require participants to adopt these criteria as they develop their own quality assurance plan(s). An analytical service provider program should also require participants in the program to operate by, and maintain their quality assurance plan throughout their participation for each device listed in the subject analytical service provider plan(s). The program should require that the participant s plan be updated whenever the program participant wishes to add a device to a listing or certification in the program. Also, EPA s guidance on quality assurance (Radon Measurement Proficiency Program: Guidance on Quality Assurance, EPA document 402-R ) recommends that quality assurance program criteria provide details, practices, and procedures unique to each device used by a radon measurement service provider. An analytical service provider program should adopt criteria for a quality assurance plan that address all four of the following elements. Chain of Custody: A quality assurance plan should demonstrate custody procedures for tracking specific measurement devices. All radon measurement tests performed should have supporting documentation, which provides complete chain-of-custody information. All certified or listed devices in an analytical service provider program should carry a unique identifier, such as a serial number. Analytical service provider programs should require participants in their program to keep a record of the residential measurement service providers whose devices they analyze and be specific to the devices analyzed. Calibration: An analytical service provider program must require its participants to be able to describe the process, in writing, of how devices used by participants are calibrated. EPA recommends that an analytical service provider program should require participants in the program to have their devices calibrated at least biennially. Calibration ensures that results of analyses are accurate within acceptable limits. An analytical service provider Page 4 of 14

7 program should require that all continuous radon and continuous working level measurement devices display calibration information. This calibration label should list the calibration facility, the calibration date, and the calibration expiration date. An analytical service provider program should require participants to maintain records of calibration certificates and/or logs for all devices listed by the participant in the program. Checks for Background: A quality assurance plan should also include instructions on how to assess the effect of background radiation on measurement results. Spiked, Blank and Duplicate Samples: Depending on the measurement device or method, criteria for a quality assurance plan should require that participants regularly use of one or more of the following checks for bias and precision. S Spikes are samples that are exposed to a known radon concentration. S Blanks are unexposed samples. S Duplicates are two or more measurements with identical equipment exposed over the same time interval at the same location. Additional guidance for analytical service provider programs in developing criteria for quality assurance plans available under EPA Order A2, Policy and Program Requirements for the Mandatory Agency-wide Quality System (May 5, 2000), which reaffirms the policy defined under EPA Order 5360/1 (April 1984), and the EPA Order 5360 (2000), EPA Quality Manual for Environmental Programs. More information on EPA s quality program are available at: 3. Adhere to Protocols An analytical service provider program shall require participants in its program to agree to adhere to the EPA s Measurement Device and Homes Protocols, that are referenced in Appendix A, or some equivalent or better device and homes protocols. There are many Federal, State, university, and private organizations who perform radon measurements, therefore, it is important that an analytical service provider program follow consistent procedures to assure accurate and reproducible measurements, and to enable valid intercomparison of measurement results. S Indoor Radon and Radon Decay Product Measurement Device Protocols. EPA Document Number 402-R , July These protocols provide method-specific technological guidance that can be used as the basis for standard operating procedures. In keeping with good laboratory practices, each program participant should develop its own detailed instrument-specific procedures that incorporate recommendations found in this and other radon-related protocol and guidance documents. Page 5 of 14

8 S Protocols for Radon and Radon Decay Product Measurements in Homes. EPA Document Number 402-R , June Reassessment of Qualifications on a Biennial Basis An analytical service provider program should require participants to remain abreast of new developments in the radon industry and to continue to hone their skills. The analytical service provider program should require participants to fulfill biennial listing/certification requirements. The biennial requirements may include device performance tests, review of the participant s quality assurance procedures, and/or a review of the participant s quality control (QC) measurement data during the previous listing/certification period, etc. 5. Compliance with Program Requirements An analytical service provider program shall have a compliance component and a process for evaluating complaints, including fair procedures that afford opportunities for providers and complainants to present their views to an impartial party (to be determined by the analytical service provider program). EPA suggests that consequences (e.g., delisting/decertification for incompetence, inappropriate practices or fraud) of program non-compliance should be clearly stated in informational materials provided by the analytical service provider program and should be implemented when appropriate. B. Criteria for Recognition of a Residential Measurement Service Provider Program A residential measurement service provider program should evaluate participants on their knowledge in providing reliable radon measurement services in the home. EPA considers the following components necessary elements for a residential measurement service provider program to assess the qualifications of participants so as to ensure that consumers receive reliable, quality measurement services. 1. Examinations A residential measurement service provider program shall require participants to demonstrate knowledge sufficient to provide reliable radon measurement services in a residential setting. EPA considers the preferred method to demonstrate this knowledge to be passing a written or, for example, a computer-based exam, as a condition to being initially listed or certified. The exam should be designed to evaluate an individual s knowledge necessary to ensure valid radon measurements and effective consumer communication. EPA continues to offer an extensive list of resources to assist in the development of an exam and as a study aid for participants to prepare for the exam(s) (see Appendix A). Page 6 of 14

9 2. Adhere to Protocols A residential measurement service provider program shall require participants in its program to agree to adhere to EPA s Measurement Device and Homes Protocols, that are referenced in Appendix A, or some equivalent or better device and homes protocols. There are many Federal, State, university, and private organizations who perform radon measurements, therefore, it is important for that a residential measurement service provider program follow consistent procedures to assure accurate and reproducible measurements, and to enable valid intercomparison of measurement results. S Indoor Radon and Radon Decay Product Measurement Device Protocols. EPA Document Number 402-R , July These protocols provide method-specific technological guidance that can be used as the basis for standard operating procedures. In keeping with good laboratory practices, each program participant should develop its own detailed instrument-specific procedures that incorporate recommendations found in this and other radon-related protocol and guidance documents. S Protocols for Radon and Radon Decay Product Measurements in Homes. EPA Document Number 402-R , June Develop and Implement a Quality Assurance Plan A residential measurement service provider program shall develop criteria for a quality assurance program and the program should require participants to adapt this criteria as they develop their own quality assurance plan(s). A residential measurement service provider program should require that the participant s plan be updated whenever the program participant wishes to add a device to a listing or certification in the program. Also, EPA s guidance on quality assurance (Radon Measurement Proficiency Program: Guidance on Quality Assurance, EPA document 402-R ) recommends that a quality assurance plan provide details, practices, and procedures unique to each device used by a radon measurement service provider. (See III.A.2. above for further EPA guidance regarding development of quality programs.) The elements of the guidance are designed to provide a framework for quality assurance practices that can be modified, and added to, according to the specific needs of the measurement program. 4. Reassessment of Qualifications on a Biennial Basis A residential measurement service provider program should require participants to remain abreast of new developments in the radon industry and to continue to hone their skills. The program shall require participants to fulfill a biennial re-listing/recertification requirement. This requirement could be achieved by completing continuing education requirements. A residential measurement service provider program should demonstrate how continuing education course work is approved and Page 7 of 14

10 how participants document their completion of continuing education credits. A residential measurement service provider program that approves course providers should require these providers to update their course materials on a regular basis to ensure that as new technical information is developed this information is incorporated into the course material. As part of its former continuing education program, EPA developed course evaluation criteria that can be used as guidance in developing a continuing education program (see Appendix A). A residential measurement service provider program must be able to demonstrate how its continuing education program is designed to maintain a participant s relevant knowledge in the radon field. A residential measurement service provider program should require participants to submit documentation showing their completion of, at least, sixteen hours of continuing education. Under its former voluntary RPP, EPA required that at least half of these credits come from completion of programevaluated or approved courses, with the other half of the continuing education requirements coming from a variety of informal radon-related activities and experience. EPA will consider this approach acceptable for a non-federal residential measurement service provider program. Each formal course should include an evaluation mechanism built into the lesson plan to ensure that attendees demonstrate attainment of the learning outcomes with a certificate of successful completion awarded upon completion of the course requirements. 5. Provide Lists of Certified/Proficient Individuals Consumers seeking the services of a radon measurement service professional need a resource they can use to find qualified service professionals. EPA recommends that consumers contact their State Radon Contact to determine what are the, or whether there are, requirements associated with providing radon measurement in a particular State. Some States maintain lists of contractors available in their state or they have proficiency programs or requirements of their own. EPA recommends that a residential measurement service provider program offer convenient ways for consumers and other groups to search for their listed radon professionals in an easily accessible media (e.g., the world wide web). 6. Compliance with Program Requirements A residential measurement service provider program shall have a compliance component and a process for evaluating complaints, including fair procedures that afford opportunities for providers and complainants to present their views to an impartial party (to be determined by the residential measurement service provider program). EPA suggests that consequences (e.g., delisting/decertification for incompetence, inappropriate practices or fraud) of program non-compliance should be clearly stated in informational materials provided by the residential measurement service provider program and should be implemented when appropriate. Page 8 of 14

11 7. Consumer Information In addition, a residential measurement service provider program shall require participants to provide all customers the following information: S The results of the radon test, including an explanation of what the test result means in reference to established benchmarks for concern, including EPA s radon action level of 4 pci/l (picocurries per liter); S If the radon test exceeds established benchmarks (such as EPA s action level of 4 pci/l), information about possible re-testing and information on how to obtain mitigation services (such as is provided in EPA s Consumer's Guide to Radon Reduction How to Reduce Radon Levels in Your Home... EPA Document Number 402-K ). C. Criteria for Recognition of a Residential Mitigation Service Provider Program A residential mitigation service provider program should evaluate participants on their knowledge in providing reliable radon mitigation services in the home. EPA considers the following components necessary elements for a residential mitigation service provider program to be able to assess the qualifications of participants so as to ensure that consumers receive reliable, quality services. 1. Training A residential mitigation service provider program shall incorporate requirements that participants complete at least 16 hours of hands-on training. A residential mitigation service provider program should be able to prove that training courses, at a minimum, contain the guidance in EPA s Radon Mitigation Standards. EPA Document Number 402-R , October 1993 (Revised April 1994), or equivalent information. The EPA Radon Mitigation Standards set a base level of performance for all residential mitigation service providers. 2. Examinations A residential mitigation service provider program should require participants to demonstrate knowledge sufficient to provide reliable radon mitigation services in a residential setting. EPA considers the preferred method to demonstrate this knowledge to be passing a written or, for example, a computer-based exam, as a condition to being initially listed or certified. The exam should be designed to evaluate an individual s knowledge necessary to ensure valid radon mitigations and effective consumer communication. EPA continues to offer an extensive list of resources to assist in the development of an exam and as a study aid for participants to prepare for the exam(s) (see Appendix A). Page 9 of 14

12 3. Adhere to Radon Mitigation Standards A residential mitigation service provider program shall require participants in its program to agree to adhere to appropriate standards and protocols, such as those found in EPA s Radon Mitigation Standards. EPA Document Number 402-R , October 1993 (Revised April 1994), or similar document. EPA s Radon Mitigation Standards provide uniform standards that residential mitigation service provider programs can use to ensure quality and effectiveness in the design, installation, and evaluation of radon mitigation systems. 4. Reassessment of Qualifications on a Biennial Basis A residential mitigation service provider program should require participants to remain abreast of new developments in the radon industry and to continue to hone their skills. The program shall require participants to fulfill a biennial re-listing/recertification requirement. This requirement could be achieved by completing continuing education requirements. A residential mitigation service provider program should demonstrate how continuing education course work is approved and how participants document their completion of continuing education credits. A residential mitigation service provider program that approves course providers should require these providers to update their course materials on a regular basis to ensure that as new technical information is developed this information is incorporated into the course material. As part of its former continuing education program, EPA developed course evaluation criteria that can be used as guidance in developing a continuing education program (see Appendix A). A residential mitigation service provider program must be able to demonstrate how its continuing education program is designed to maintain a participant s relevant knowledge in the radon field. A residential mitigation service provider program should require participants to submit documentation showing their completion of, at least, sixteen hours of continuing education. Under its former voluntary RPP, EPA required that at least half of these credits come from completion of program-evaluated or approved courses, with the other half of the continuing education requirements coming from a variety of informal radon-related activities and experience. EPA will consider this approach acceptable for a residential measurement service provider program. Each formal course should include an evaluation mechanism built into the lesson plan to ensure that attendees demonstrate attainment of the learning outcomes with a certificate of successful completion awarded upon completion of the course requirements. 5. Provide Lists of Certified/Proficient Individuals Consumers seeking the services of a radon mitigation service professional need a resource they can use to find qualified service professionals. EPA recommends that consumers contact their State Radon Contact to determine what are the, or whether there are, requirements associated with providing radon mitigation in a particular Page 10 of 14

13 State. Some States maintain lists of contractors available in their state or they have proficiency programs or requirements of their own. EPA recommends that a residential mitigation service provider program offer convenient ways for consumers and other groups to search for their listed radon professionals in an easily accessible media (e.g., the world wide web). 6. Compliance with Program Requirements A residential mitigation service provider program shall have a compliance component and a process for evaluating complaints, including fair procedures that afford opportunities for providers and complainants to present their views to an impartial party (to be determined by the residential mitigation service provider program). EPA suggests that consequences (e.g., delisting/decertification for incompetence, inappropriate practices or fraud) of program non-compliance should be clearly stated in informational materials provided by the residential mitigation service provider program and should be implemented when appropriate. Page 11 of 14

14 Appendix A List of Resources A Citizen's Guide to Radon (second edition) The guide to protecting yourself and your family from radon. EPA Document Number 402-K , September Consumer's Guide to Radon Reduction How to Reduce Radon Levels in Your Home... EPA Document Number 402-K El Radón Guía para su protección y la de su familia Documento de la Agencia de los Estados Unidos para la Protección Ambiental Número 402-K , septiembre del Home Buyer's and Seller's Guide to Radon. EPA Document Number: 402-R , March (Note: A newly revised version of the Guide is about to be released K , July 2000). Model Standards and Techniques for Control of Radon in New Residential Buildings. EPA Document Number 402-R , March Radon Mitigation Standards. EPA Document Number 402-R , October 1993 (Revised April 1994). Technical Support Document for the 1992 Citizen's Guide to Radon. EPA Document Number 400-R , May Indoor Radon and Radon Decay Product Measurement Device Protocols. EPA Document Number 402-R , July Protocols for Radon and Radon Decay Product Measurements in Homes. EPA Document Number 402-R , June Radon Measurement Proficiency Program: Guidance on Quality Assurance, EPA document 402-R U.S. EPA National Radon Proficiency Program Handbook, EPA 402-R , July 1996 EPA Order A2, Policy and Program Requirements for the Mandatory Agency-wide Quality System, May 5, 2000 ( Page 12 of 14

15 Appendix B Sample Acknowledgment Letter to Successful Applicants [Organization s Name] [Organization s Representative] [Address] [City, State, Zip] [Date] RE: EPA s Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or Residential Mitigation Service Provider Program or Analytical Service Provider Programs] Dear Sir/Madam: EPA has completed its review of your program s application dated / /. Based solely on its review of the materials submitted, EPA finds [the subject program s] residential measurement service provider program [or residential mitigation service provider program, or analytical service provider program] successfully satisfies EPA criteria for operation of a non- Federal national radon proficiency program if established and implemented as described in your application. Because of expected changes in the radon industry, this acknowledgment is only valid through December 31, 2002, at which time this determination will expire. There will be no extensions of this determination. This determination is not applicable if changes are made to the program as submitted to EPA, or if it is not implemented as described to EPA. To avoid misleading the public, you may not make public reference to this EPA determination after December 31, Any references to EPA s determination in advertisements should avoid misleading consumers. We recommend that you use the following description: EPA has reviewed [your organization s] description of its [your program name] and has determined that the description of [your program s name] is consistent with EPA s criteria for operation of a non-federal residential measurement service provider program [or a residential mitigation service provider program or an analytical service provider program]. EPA has not reviewed the actual operation of [your program s name]. We will post the results of our determination on our web site at: If you have any questions concerning this letter, you may contact James Long of my staff at (202) or long.james@epa.gov. Sincerely yours, Mary T. Smith, Director Indoor Environments Division Page 13 of 14

16 Appendix C Sample Letter to Applicants Who are Denied Acknowledgment [Organization s Name] [Organization s Representative] [Address] [City, State, Zip] [Date] RE: EPA Evaluation of Non-Federal - Residential Measurement Service Provider Programs [or Residential Mitigation Service Provider Program or Analytical Service Provider Programs] Dear Sir/Madam: Based on EPA s review of your submission dated / /00, we can not find that your residential measurement service provider program [or residential mitigation service provider program, or analytical service provider program] meets EPA s criteria for a non-federal national radon proficiency program. You have 30 calendar days from the date of your receipt of this letter to address the concerns described in the attachment. If you fail to successfully address these concerns within the time frame allocated, no more consideration will be given to your submission and EPA will issue you a formal denial of your application and post the results of our determination on the EPA website at: If you have any questions concerning this determination, you may contact James Long of my staff at (202) or long.james@epa.gov. Sincerely yours, Attachment Mary T. Smith, Director Indoor Environments Division Page 14 of 14