Radon action guide for provinces and territories: Reduction actions

The following are distinct actions that provinces can take, either as standalone interventions or as part of a broader radon action plan.

On this page

• Testing, databases and mapping
• Education and awareness
• Recognizing certified radon professionals
• Government buildings and operations
• Reducing radon in new homes
• Reducing radon in owner-occupied homes
• Rented homes
• Work, study and care spaces
• Energy efficiency
• Smoking cessation
• Conclusion
• References

Testing, databases and mapping

Importance of widespread testing

Health Canada stresses that all homes have some level of radon and should be tested. There is now considerable guidance for the general public and radon professionals for how to test and mitigate. Because radon levels vary significantly by location, identifying high radon areas is important for targeting policy interventions. In British Columbia, radon provisions in the BC Building Code, 2018 are directed at municipalities where there are clear indicators (including from surveys and testing initiatives) that there are radon problems.^{Reference 1} In Ontario, the Building Code radon provisions apply where “radon gases are known to be a problem”.^{Reference 2} Many initiatives, such as public education, outreach efforts, and subsidies for testing and mitigation will be more efficient and effective if targeted at high radon risk areas.

Health Canada's 2012 Cross-Canada Survey of Radon Concentrations in Homes was an important first step. However, due to the budget and logistics of surveying all of Canada, it has a limited sample size of approximately 100 results per health region.

There are a variety of testing initiatives across the country, including testing of government-owned buildings at the federal level, public buildings such as schools, and community testing of homes. Examples include:

• Evict Radon (Alberta)
• Take Action on Radon
  • This program enrolls municipalities in the 100 Test Kit Challenge.

However, most parts of Canada still do not have sufficient numbers of test results.

Learn more about:

• Health Canada's 2012 Cross-Canada Survey of Radon Concentrations in Homes

Building awareness, community testing and citizen science

To date, many agencies in Canada have started programs to hand out test kits free of charge or on a subsidized basis. It is important to distinguish different types of programs and rationales.

Some initiatives are primarily oriented towards building awareness. They seek to both build awareness of radon and help individuals test. Take Action on Radon’s “100 Test Kit Challenge” is a good example of this.

Community testing initiatives are oriented towards learning radon prevalence in the community. Here, researchers estimate an appropriate sample size to allow sufficiently precise estimates for a municipality or region. For example, hundreds of test results per area were completed to help support policy changes related to building codes and public health standards in the Ontario communities of:

• Kingston
• Frontenac
• Thunder Bay
• Windsor-Essex
• Lennox & Addington

In citizen science projects, individual home occupants are asked to test their homes in exchange for allowing researchers to collect radon readings and survey data. Results are typically held in university or health agency databases and are used to provide evidence-based reporting and guidance to the target area.

There are a variety of programs providing digital radon monitors in public libraries. Patrons are able to check them out (akin to book loans) and conduct a radon test at home. Currently there are radon library lending programs in:

• Alberta
• British Columbia
• Nova Scotia
• Ontario
• Prince Edward Island

These programs can help people with limited funds, or who want an initial introduction to radon. These programs should be considered a screening test only with a primary goal of raising awareness about radon. Health Canada recommends a long-term test (3 months) during the heating season be conducted in addition to the use of a digital radon monitor. These programs can help people understand radon and can motivate them to conduct long-term tests. Provinces and territories can support municipalities to work with libraries, supporting lending programs or the distribution of long-term test kits to patrons/community members. Health Canada, in collaboration with provincial lung associations and radon experts, has developed a radon library lending program guide to provide libraries across the country with support, education, and useful resources to run an effective and successful radon monitor lending program.

In practice, these different testing approaches are compatible and can be combined in a single program. For instance, a community testing initiative can also have a significant public awareness component, and also collect survey data to be shared with researchers.

Learn more about:

• citizen science projects
• programs providing digital radon monitors in public libraries

Databases and maps

Data collection is important to support the development and implementation of Radon Action plans. A radon database can help build understanding of how radon intersects with local health conditions (such as prevalence of smoking), the links between geological radon and risks in homes, or whether some people have a greater genetic susceptibility to radiation-related illness. Creating a radon map or other visual resource can be an effective way of communicating risk and supporting policy action. For instance, knowledge of local radon risks in the real estate industry can serve to put buyers, sellers, and realtors on alert that radon may be a latent defect in houses for sale.

The government of Nova Scotia and a private sector company (Radon Environmental Management Corp.) have produced maps by using underlying geological and soil information. However, radon concentrations also depend on building structure and design, and collecting indoor tests is also an important way to estimate local radon risks. Health Canada has developed a radon risk map utilizing:

• national geological data
• data from radon laboratories
• data from the Cross-Canada Radon Survey (2011)
• the Radon/Thoron Survey in Canadian Metropolitan Areas (2013)
• Nova Scotia and Radon Environmental Management Corp.’s survey data

In creating maps and databases, efforts can be made to collect test data from diverse sources, such as:

• academic research
• citizen science projects
• results of community testing initiatives
• government testing of its own buildings
• health associations who have sold or distributed radon test kits

This can require careful attention to obtaining consent and coordinating survey questions to allow for data to be combined. To help with coordination and share knowledge on the technical details of database and mapping, database managers, researchers and mappers across Canada have formed the Canadian Radon Database and Mapping Working Group. In developing maps and databases, provinces and territories should consider consulting with members of this group or other experts in radon mapping and database management.

Learn more about:

• Radon risk map
• Databases and mapping
• Radon risk map for Nova Scotia
• Accessing Health Canada’s radon data
• Canadian Radon Database and Mapping Working Group

Collection and reporting of test results

There are possibilities for ensuring that whenever buildings are tested for radon, the results are placed into databases. The Canadian government has compiled radon tests of its own buildings, and provincial governments could require that any in-house testing initiatives make public the results. This guide discusses certification of radon professionals. Once radon professionals are certified there can be further requirements that any radon test results obtained be shared with government agencies. A provincial or territorial government could couple the creation of databases with requirements for radon professionals and testing laboratories to contribute to it.

Learn more about:

• Certification of radon professionals
• Jurisdictions (and regulations) that require reporting of test results

Education and awareness

A key component of addressing radon is ensuring that people know that it is a health risk and have the tools to act to remedy it. Many countries and sub-national governments around the world have radon education programs.

While diverse agencies such as municipalities, health authorities, centres for disease control, and government agencies may have information on web pages, it is helpful to have a centralized provincial/territorial information portal which can be kept up to date. This helps people navigate the problem of many different and conflicting information sources through the provision of reliable, government-endorsed, and up-to-date public health information.

Along with web resources, other communication and outreach techniques should be used to effectively reach the target audiences, such as:

• radio
• webinars
• television
• print media
• social media
• public meetings

It is also important to ensure awareness efforts extend to diverse unilingual language users in your communities who may be more receptive to information presented in a language other than English or French.^{Reference 3}

Access Health Canada and Take Action on Radon outreach and communication resources, as well as those from other government agencies.

Resolutions

Educational programs can be strengthened by broad resolutions, such as a legislature recognizing November as Radon Action Month in Canada. Health Canada’s 2019 proclamation is a good example. 

Empower health authorities

An empowered public health administration will play a key role in advancing radon action. Many health authorities have the legal power to offer education on radon but individual officials may lack a clear mandate. One way to improve the situation is to follow the lead of the Ontario Public Health Standards which establish action on radon as a minimum expectation by the Province for its boards of health.

Target at-risk audiences

Some agencies have found ways of particularly targeting persons at high risk of radon. For instance, where homes with exceptionally high radon levels are found, Public Health England provides additional individual practical support to the householders that can include^{Reference 4}:

• on-site visits
• individual advice
• assistance in remediating
• periodic radon monitoring

Community testing and citizen-science approaches to engagement

These can create more active ways of engaging publics in radon. As mentioned earlier, testing initiatives can help people learn about radon, but also contribute to community level knowledge and science on the topic.^{Reference 5}

Learn more about awareness, citizen science and community testing.

Tap into existing duties

Many people have direct responsibilities relevant to reducing radon. Landlords, employers, school districts, and others in charge of indoor spaces already have broad obligations to meet health and safety requirements. What is needed from provincial and territorial authorities is to raise awareness about radon and communicate how radon fits into those obligations. For instance, real estate licensees generally have duties to be knowledgeable about environmental conditions and to take the appropriate steps to alert their clients of known health or environmental concerns. Several real estate councils and associations in Canada have been able to significantly advance radon awareness and action through notifying real estate professionals about the ways that their existing duties extend to radon.

Learn more about:

• Real estate transactions
• Real estate agents’ duties around radon

Offer training to trades and professional groups

A variety of occupational and professional groups do not know enough about radon. Municipal building inspectors, building tradespeople and contractors, family doctors, pharmacists and others would be better equipped and more likely to correctly address radon in their work given the correct capacity-building.

Learn more about radon courses for professionals.

Guidance and protocols on testing and mitigation

Health Canada and the Canadian General Standards Board have already developed many guidance documents on best practices for testing and mitigating different types of buildings. Provinces and territories can reference these materials to help guide the general public and professionals who work with radon.

Learn more about best practices for testing and mitigation.

Add radon to educational curriculum

Provinces and territories have an excellent opportunity to ensure students learn about the importance of indoor air quality issues and radiation. Educating children and youth helps spread the message to parents and families and helps ensures that in the future the issues are understood through the population.

Support outreach with stronger action

Governments can send the message that an issue is important through having clear policy and law change. This includes many tools discussed in this guide, such as incentives and subsidies for testing and mitigation, and a host of regulatory and legislative changes.

Learn more about jurisdictions with legal requirements around radon education.

Recognizing certified radon professionals

Radon measurement in larger buildings, and installing radon reduction systems in any building, can require specialized knowledge. In some cases, such as real estate transactions, parties engaged in arms-length transactions require a reliable third party to provide an assessment. As such, qualified radon professionals are an important part of a societal response to the radon problem.

Licensing and certification of professionals

Health Canada recommends radon mitigation and measurement professionals certified through the Canadian National Radon Proficiency Program (C-NRPP). However, certification remains voluntary. While Canadian provinces have jurisdiction for regulating professions, none have acted on this for radon professionals. However, many professions, such as plumbers or massage therapists do require certification. Consumers may be faced with advertisements and offers for radon abatement from unqualified providers. Consumers who do not know the details of radon may be drawn to providers who offer services at a low cost, creating a danger that substandard work could drive out better qualified providers and become normalized. Licensing and certification can thus ensure high standards and guarantee quality to consumers.

Learn more about model language on regulating radon professionals and see examples of jurisdictions where this has been done.

Ensuring professional standards

In Canada, C-NRPP oversees professional education and training, and imposes its own duties on members, set by the C-NRPP Policy Advisory Board. This includes following guidance documents from:

• Health Canada
• C-NRPP’s own internal documents
• the Canadian General Standards Board
• the Canadian Association of Radon Scientists and Technologists

As well, C-NRPP has a system for approving radon measurement devices and analytical laboratories.

In regulating radon professionals, provinces and territories should consider requiring C-NRPP certification as the appropriate standard.

Learn more about:

• Resources for professionals (C-NRPP)
• Becoming a certified professional (C-NRPP)
• Listed radon measurement devices (C-NRPP)

Professional contribution to radon databases and maps

Another advantage of certified professionals is they can be directed to contribute testing results to centralized databases. C-NRPP certified professionals already do this in Canada on a voluntary basis and so help produce C-NRPP’s radon map. Twelve US states mandate not only that radon service providers be certified but that they deliver test results to state agencies.

Learn more about:

• C-NRPP’s radon map
• Example US state mandate (New Jersey)
• Radon professionals contributing to radon databases

Ensuring services are available

Service provision in Canada has been primarily through the private sector. However, governments can have a role, at times, in supporting a still-developing industry. In some locations, there may be a relative absence of C-NRPP professionals, in part because there is not yet customer demand. This creates a potential vicious circle, as consumers who need the services have trouble accessing them. Some provinces have, in the past, taken the approach of directly subsidizing trades workers to take C-NRPP certification. Various types of construction, electrical, plumbing or engineering occupations are obvious entry points.^{Reference 6} Provinces should also consider regular monitoring of the industry to ensure services are available to consumers.

Government buildings and operations

Governments have broad duties to ensure spaces are safe, whether as employers, landlords (in relation to social housing), or “occupiers.” A government might also choose to construct its own buildings to higher standards as a way of acting ethically, leading by example, or to help support local environmental industries. Government testing can also be a way to build databases and maps.

The federal government has conducted extensive testing of federally occupied buildings, and some provinces have also tested their buildings. Some US states have enacted specific legislation requiring testing in government buildings.

Where widespread mandatory certification of radon professionals is not yet in place, provinces and territories should consider requiring C-NRPP certified professionals be used for any radon work in government owned buildings.

Learn more about radon testing in government buildings and operations.

Reducing radon in new homes

Building codes

New construction is an excellent place to implement radon provisions, given that Building Codes are often updated, this is an area where health and safety standards are widely accepted, and targeting new construction is particularly cost-effective. There are radon provisions in the (model) National Building Code (with the radon provisions last updated in 2010), and many provinces have incorporated some radon provisions in their Code. Learn more about radon provisions in Building Codes in Canada. The National Radon Program continues to work with Codes Canada and the National Research Council to encourage improvements in the radon provisions in the National Building Code. Provinces and territories without radon provisions, or with older iterations of radon standards, should consider updating their Codes.

To unpack the variety of codes in Canada, it may be useful to analyze different radon reduction strategies, ranging from the most rudimentary to the most effective.

Learn more about:

• A Comparison of Three Radon Systems in British Columbia Homes: Conclusions and Recommendations for the British Columbia Building Code

Health Canada recommends that all provinces and territories incorporate radon reduction into their building codes. The Canadian General Standard Board’s 2019 “Radon control options for new construction in low-rise residential buildings” is the recognized mitigation standard in Canada and should be referenced in building codes. The standard provides detailed technical prescriptions for radon mitigation strategies.

There are significant benefits to targeting radon prone areas and requiring new homes to have operational systems (at least a passive sub-slab system), ensuring that homes are built with less radon in them and reducing the incidence of radon-induced lung cancer in higher risk regions.

If building codes continue to require forms of ‘rough-ins’ that are incomplete, provinces and territories should consider requiring clear labelling on these systems stating that they are incomplete. Radon levels in a home will normally not be known until after occupancy, and further radon testing is required by homeowners once they occupy the home. Provinces and territories can consider requiring builders to leave radon test kits and informational guides with new home-owners.

In updating building codes, provinces and territories should also consider important procedures. It is a good idea to require C-NRPP certified professionals be involved in designing, overseeing, and building radon systems in new construction. Any installed radon systems should be labeled. Post-construction testing is necessary to ascertain whether systems have actually reduced radon levels. As well, building codes need to be followed, and provinces should include educational outreach for builders to ensure proper implementation. Provinces should consider research and follow-up surveys to determine the impacts of their building code changes on radon levels in homes and other buildings.^{Reference 8}

Learn more about:

• Construction Code (Government of Québec)

Inspections

A building code is only as good as its implementation. Radon mitigation is often overlooked in whole or in part during post-construction inspections, due to lack of^{Reference 9}:

• resources
• understanding of radon issues
• clarity regarding who is responsible for inspecting radon mitigation systems

Building code legislation should include requirements for education and technical assistance in administering new standards.^{Reference 10}

Canadian provinces generally delegate building code enforcement to municipalities, either by direct requirement^{Reference 11} or matter of course.^{Reference 12} Municipalities may also face liability for negligent inspection.^{Reference 13} Education and training for inspectors concerning radon will therefore be a key component of provincial collaboration with municipalities.

New home warranty

Many real estate associations and councils in Canada now treat elevated radon as a latent defect in home sales. This same idea can extend to new homes. Most Canadian provinces have new home warranty systems in place which provide for protection from defects in structure, materials, and workmanship. Tarion (Ontario’s provider) explicitly recognizes high radon as a defect and provides direction to home buyers on how to address the issue with builders. Tarion’s policies apply even where the Ontario Building Code radon provisions are not enforced.

Provinces should give explicit direction to make sure that high radon is understood to be a defect in structure or materials in a home. Provinces can consider recommending or requiring that home builders provide information to new homeowners about the risks of radon and the importance of conducting a long-term radon test after moving in. Radon information should also be included in applicable guidance documents, such as:

• continuing education requirements for building contractors
• construction performance guides for warranty-approved builders

Learn more about:

• New home warranties and radon
• Radon and your warranty (Tarion)

Reducing radon in owner-occupied homes

While Building Code changes can be an important way to address radon, only 1 to 2% of the housing stock is newly built each year. There are, however, a suite of interventions that can help reach the existing housing stock.

Real estate transactions

Radon should be considered a consumer protection issue for buyers and sellers of homes. There is already significant action in Canada related to addressing radon in the real estate process. Quebec courts have stated that radon could be considered a latent defect.^{Reference 14} Common law courts would likely make the same finding. A significant number of real estate associations and regulatory councils across Canada have concluded that radon is a latent defect in a home, meaning that sellers have a duty to disclose to buyers known elevated radon levels. In the United States some states have passed laws that enshrine the same principles.^{Reference 15}

Typically, governance of real estate transactions is a complex mix of government legislation, independent regulatory oversight, and industry self-governance. In some cases, provincial radon planning may proceed through a process of education, coordination, and cooperation with industry and independent regulators. Existing experience in Canada suggests both associations and regulators have shown willingness to act, when informed. That said, radon planning should not lose sight of the ability of provincial governments to introduce new legislation and use this power in negotiating with associations and regulators. Key pieces to consider implementing include:

Clarification of agents’ duties

These include proactively discussing radon with their clients (whether sellers or buyers), raising the issue in negotiations, and disclosing known high radon levels as a latent defect.

Learn more about policies for radon reduction in existing homes, including:

• details on the work of Canadian provincial level real estate councils
• associations in issuing guidance to buyers, sellers and real estate agents

Radon on the Property Disclosure Statement

This includes:

• known radon levels
• whether there has been a long-term (91-day) test
• the date of any testing
• any mitigation performed

See examples of Canadian provinces where radon is specifically mentioned in disclosure forms for real estate transactions.

Mandating information for home buyers

For example, having sellers give standard forms, typically produced by public health agencies, to buyers. Some US states require such statements, including^{Reference 16}:

• Delaware
• Florida
• Iowa
• Illinois
• Kansas
• Minnesota
• Montana
• New Hampshire

An alternative approach might be to work with trade associations/regulators to streamline information that realtors give to clients as part of their own professional duties.

Learn more about:

• Database of State Indoor Air Quality Laws, Radon Excerpt (Environmental Law Institute)

Requiring testing and mitigation prior to sale

This is common practice in the United States, but relies on short term (typically 2 day) radon tests. Health Canada does not recommend short term testing because radon levels fluctuate over time and short term tests can give false positive or negative results. Imposing a 91-day testing period (plus time to arrange for mitigation) would represent a significant delay for some sellers. However, doing it is an excellent opportunity to drive wide scale reduction in lung cancer risks and can work together with broader public interest housing and real estate regulation. One option is to have a testing and mitigation requirement as the default position, but allow sellers to be exempt if there is a holdback clause in the Contract for Purchase and Sale. This allows a radon test to be completed after the property transfers and for a release of funds to cover the cost of testing and mitigation. It is important to require that mitigation work done in contemplation of homes sales be completed by certified mitigation professionals. 

Subsidies and financing for homeowners

In many cases, testing and mitigating elevated radon is a cost-effective health intervention. Health economists have found radon interventions on par with or less expensive than other medical and drug expenses governments regularly incur with an eye to improving life-expectancy and quality of life. This is particularly so in high radon potential areas.^{Reference 17} Subsidies and incentives work to share the costs of a collective good. Equity considerations arise as well. Homeowners with lower incomes will tend to push off into the future radon testing and any needed mitigation.

Subsidies for mitigation should only be made available where mitigation is performed by C-NRPP certified radon professionals.

Learn more about a range of subsidy and incentive programs for homeowners, such as:

• tax credits for mitigation work
• prices as an incentive to test one’s home

Strata and condominium units

Special attention should be given to the unique situation of people who live in strata properties (in British Columbia) and condominiums (elsewhere in Canada). The enabling legislation for this type of housing arrangement typically allocates to:

• owners the responsibility to maintain and repair their own units
• a common corporation the duty to maintain and repair common areas

Legislation does not spell out particular indoor health standards.^{Reference 18} Care should be taken to ensure that any rules around real estate transactions (such as mandatory information or latent defects), home warranty, subsidies and incentives, and certifications extend to strata and condominium units. Special education and outreach on radon can be directed at strata councils and condominium boards or specialty organizations, such as the Condominium Authority of Ontario.

Rented homes

Over a third of Canadian households rent their homes. Attention to renters and social housing is important for ensuring action on radon follows principles of health equity, and to ensure a healthy home environment for the tenants. Renters do not normally have the legal right nor the funds to conduct major repairs on buildings they do not own.

Testing programs should be careful to include rented accommodation, and education and awareness programs can be specifically tailored to renters. As well, there are a number of areas of law, regulation and policy that can specifically target radon in rented homes.

Residential tenancies and landlord-tenant law

Each province and territory has legislation, typically named as residential tenancy or landlord-tenant law, that includes necessary terms in the landlord-tenant contract. Generally, these include broad provisions giving landlords the duty to ensure living spaces are in “good repair.” Administrative tribunals in Ontario and Quebec have already held that elevated radon will violate those provisions.^{Reference 19} It is only a matter of time (and efforts by renters and their advocates) before tribunals in other provinces and territories also identify radon as a problem. One way to ensure such tribunals make findings around radon is to support tenants’ advocacy organizations and housing advocates to bring cases forward. More generally, education should be directed at both landlord and tenant groups. Provinces and territories can also work with tribunals to provide interpretations and guidance documents that indicate residential tenancy law supports radon action.

A further step would be to implement new legislation or regulation that makes clear what counts as a problematic state of disrepair. This makes it much easier for renters (or their advocates) to explain the issue to landlords and avoids the situation where a renter has to go to a tribunal to have their situation taken seriously. For instance, in the United Kingdom, the Homes (Fitness for Human Habitation) Act 2018 together with regulations take explicit steps to protect tenants through listing out a series of indoor contaminants, air quality issues, and health hazards that affect rented accommodation (and so render it unfit for human habitation). This includes radiation from radon. Renters can also be protected through Public Health Regulations and municipal level Standards of Maintenance Bylaws. Standards of Maintenance Bylaws are further discussed in the Radon Action Guide for Municipalities.

Provinces and territories could update their residential tenancies laws to require radon testing in occupied rentals in contact with the ground. Mitigation should be explicitly required if tests show levels above the Canadian Guideline. This would make explicit when landlords test, disclose results to tenants, and mitigate high radon in rental dwellings.^{Reference 20} This would allow landlords and tenants to understand their rights and obligations by direct reference to legislation or regulation and may help avoid the cumbersome process of applying to administrative tribunals to secure rights.

In some provinces or territories it may be appropriate to specify this only for known radon-prone areas. One option could be to allow renters to test and if necessary pay the costs of mitigation and then recoup this from landlords—in the form of reduced rent. In British Columbia this power is already given to tenants in areas of “emergency repairs”^{Reference 21} which could be clarified to include mitigation of elevated radon. For radon reduction it is recommended that the use of certified mitigation professionals be required. This will ensure the quality of service and an ability to be able to track compliance and report radon results through the accreditation body.

Landlords and their organizations are more likely to support radon measures that do not simply pass on to them the costs for supplying a social good. Policy makers should consider linking mandatory requirements to address radon in rental accommodation with forms of financial support for housing providers, such as:

• direct grants
• extending tax credits
• subsidized or free radon testing kits
• other incentives for radon work

Learn more about:

• Existing legislation and model language suitable at the provincial and territorial level
• Radon and Renters: Current BC Law and Potential for Reform (BC Lung Foundation)
• Guide for tenants: Homes (Fitness for Human Habitation) Act (United Kingdom Ministry of Housing, Communities & Local Government)

Housing and maintenance standards

Some Canadian provinces have explicit housing standards that apply to residential accommodation. Generally, these are regulations to public health acts, and empower health officers to take action once a renter lodges a complaint with them. This can provide renters with access to a sympathetic advocate rather than needing to go through a complex tribunal process. Currently no provincial or territorial standards explicitly include radon in housing and maintenance standards.

It might be possible for health officials with knowledge and understanding around radon to apply very general public health clauses to renters’ complaints and work with a landlord to require mitigation. In Alberta a health officer drew on general nuisance clauses in the Public Health Act and the Nuisance and General Sanitation Regulation.^{Reference 22}

A better approach is to ensure that radon and other indoor air quality concerns are explicitly mentioned in these regulations. Ideally there needs to be direction given to health boards and authorities to take action on radon, coupled with supportive policies, such as empowering health officers to spend the time needed to learn about, and take enforcement action concerning, elevated radon.

In many cases provinces have delegated maintenance standards to municipalities (see also Radon Action Guide for Municipalities). Provinces should then work with municipalities to ensure radon is considered. If provinces have model standards of maintenance bylaws, they should be sure radon is included.

Learn more about:

• examples and model language for health regulations
• model language for standards of maintenance bylaws

Affordable housing

Canada has a hybrid system of support for non-market housing and care should be taken to tailor radon policies to each type.

Some building sites are owned directly by provincial governments and their agencies. In these cases, governments should address radon both as part of their own operations and as part of their responsibilities as landlords. Indeed, a number of provinces and public housing corporations have already conducted radon testing. Beyond testing and mitigation programs, efforts can include updating internal standards, guides, and toolkits for housing managers.

Often, affordable housing is provided by non-profit housing societies. There are many avenues for addressing radon here, including:

• updating guides and toolkits
• directed education to providers
• ensuring radon testing and mitigation requirements are included in required standards and operating and management agreements

Policy makers should consider direct subsidies and incentives for testing and mitigation as well as tying requirements to financial support.

Special consideration should be given to housing cooperatives, which make up a sizeable number of social housing units in Canada. While housing cooperative participants typically pay rent on a month-to-month basis, they largely have a membership, rather than tenant status. Most inhabitants are also collective owners of buildings and land. They do not have protection under landlord-tenant laws. Underlying legislation covering cooperative associations does not specify indoor air quality or other health standards. Issues as to indoor health and environment standards are established by bylaws of the cooperative or settled by collective decision making. Unlike strata units, cooperatives often do make collective decisions (and pool money) for some maintenance issues within individual units. A good approach can be to direct education and outreach to housing cooperatives. Provinces and territories can also offer forms of assistance such as drafting model policies for housing cooperatives or providing targeted subsidies and incentives for radon testing and mitigation.

Some provinces have moved to providing portable rent subsidies—these allow eligible individuals to receive subsidy for rental units (at times provided by co-ops and non-profit housing providers, but also through private market rental units). This may occur for persons in need in locations where no subsidized housing is available. While landlord-tenant laws will apply, housing agencies may also conduct independent checks to ensure basic safety standards are met.^{Reference 23} A further condition for review of potential units could include radon testing, disclosure of results to agencies and tenants, and, if needed, mitigation.

Work, study, and care spaces

Workplaces

It is estimated that the majority of exposure to radon in the Canadian population is from time spent at home.^{Reference 24} Still, it is important to test and reduce radon exposure in work environments, schools, and daycares.

The Canada Labour Code, which governs workplaces under federal jurisdiction, has been updated to reflect the National Radon Guideline of 200 Bq/m³. As well, the Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials (NORM) recommends a radon protection framework for all workplaces in Canada. The NORM Guidelines provide a tailored way to ensure workplaces align with the National Radon Guideline of 200 Bq/m³ and other radiation protection standards.

Provinces and territories should ensure their occupational health and safety regulation provide workers protection against elevated radon. Provincial and territorial workplace legislation does not generally provide specific wording on radon in the normal workplace, although some do have provisions for ionizing radiation or incorporate lists of exposures from organizations such as the American Conference on Government Industrial Hygienists (ACGIH). All provinces, however, have “general duty clauses” that require attention to hazards.^{Reference 25} One important example that can be followed is Ontario, which has issued guidance for how the NORM Guidelines work together with the general duty clause to apply to workplaces in the province. Provincial and territorial regulators should identify types of workplaces that are prone to elevated radon levels. Workplaces commonly identified as having large numbers of exposed workers include:

• universities
• public administration
• banks and credit unions
• federal protective services
• elementary and secondary schools

Other industries where workers are prone to exposure to naturally occurring radioactive materials include^{Reference 26}:

• metal recycling
• oil and gas production
• water treatment facilities
• mineral extraction and processing
• forest products and thermal-electric production

Efforts should be taken by workplace regulators to ensure employers measure and monitor workplace radon levels and communicate the results to employees.

Learn more about:

• Radon occupational exposures (CAREX Canada)
• Radon in the workplace (Ontario Ministry of Labour)
• Canadian Guidelines for the Management of Naturally Occurring Radioactive Materials
• How to help provinces and territories update their workplace standards to ensure workers are protected from elevated radon

Schools, day-cares and long-term care facilities

Exposure to high radon during childhood increases the lifetime risk of developing lung cancer later in life.^{Reference 27} There is a legal basis for radon action in schools based on the occupational health and safety rights of staff, but also because schools have broad duties to protect the health of students. In addition, schools can share educational information with families to encourage testing at home. Learn more about Canadian school testing programs, noting that in many parts of the county only a few schools have been tested.

Many US states and other countries specifically mandate testing in schools. Specific rules not only help create transparency but can ensure all schools are tested.

Childcare centres and long-term care facilities are another important area for addressing radon. Like schools, childcare settings would ideally be covered by workplace legislation, but may be introduced earlier in the process given the immediacy of concern and public sentiment. In some US states there is specific legislation. In Canada, at least one health authority has ordered radon testing in childcare settings as part of licensing requirements.

Learn more about:

• childcare testing initiatives in Canada
• jurisdictions with requirements for school testing
• jurisdictions with mandatory childcare setting testing
• Radon in schools: A summary of testing efforts across Canada

Energy efficiency

Many provinces and territories are moving to promote energy efficiency in homes and building codes across Canada will over time adopt stricter energy efficiency standards. However, attention to energy efficiency needs to be matched with attention to radon. The limited exchange between indoor and outdoor air in energy efficient homes can prevent radon from escaping into the outdoors. Energy-efficient home insulation practices reduce heat loss but also often suppress air exchange. Indeed, increasing airtightness can elevate mean radon concentrations by over 50%.^{Reference 28} Tight buildings that control indoor air flow have unique advantages beyond reducing energy use, including:

• ensuring quiet
• thermal comfort
• lack of moisture ingress

However, care must be taken to avoid unwanted consequences, of which radon is a major concern.^{Reference 29} Energy efficiency programs and guides thus need to be coupled with attention to ventilation rates as well as testing and mitigating for radon.^{Reference 30}

There are clear opportunities and benefits to providing education and outreach to existing energy efficiency initiatives to make clear the importance of radon. Learn more about energy efficiency guides and programs that include recommendations for radon.

Radon action should include ensuring that any government (or agency)-linked incentive and financing programs include incentives for radon testing and mitigation along with efficiency and other “green building” improvements. This can extend to home repair loan programs, but also subsidies, loans, and financing programs by public utilities.

Learn more about:

• financing programs
• Indoor Radon Air Pollution (United States General Accounting Office)

Smoking cessation

There is a strong synergistic interaction between radon exposures and smoking, given the damage both cause to lungs.^{Reference 31} Provinces and Territories should consider combining radon awareness and smoking cessation programs. Cessation program outreach workers can be trained in radon awareness and learn about local area risks, and when contacting or counselling smokers in high radon potential zones, explain the radon problem and its relevance. Clinical interventions, such as nicotine prescriptions, can be coupled with free radon test kits and subsidies for mitigation. Because the rates of lung cancer are so high amongst smokers with chronic exposure to high radon, these interventions are likely to be highly cost-effective.^{Reference 32}

Conclusion

This guide will facilitate and support provinces and territories in developing a Radon Action Plan by providing justification and evidence-based links to existing frameworks, strategies and policies where radon can be considered or incorporated. Included in this document and the Appendix are a variety of resources, examples, links, key messages and sample language that can be used in the development of a Radon Action Plan. It includes numerous actions that can be taken individually or together to start to help reduce the incidence of radon-induced lung cancer in your local communities.

The Radon Action Guide is broken down into sections and component parts and includes supporting evidence and examples so that provinces and territories can build a broad and comprehensive plan or take individual, discrete steps. Radon action can be advanced by choosing a few high impact and appealing interventions, such as ensuring daycare centres or government-operated social housing are tested. In some cases, the first step will be to develop more awareness, and provinces and territories can take advantage of the materials developed by Health Canada’s National Radon Program materials. Other key actions include increasing testing and collecting data to get a better understanding of the regions with higher radon risk. Provinces and territories can use this data to give direction to public health agencies, and target education to professional groups such as real estate licensees and municipal building officials. In many areas, such as landlord-tenant, occupational health and safety, and real estate licensees there is broad scope for alerting people to existing laws, and having agencies issue interpretive bulletins, rather than more formal legal change. There is also significant scope for governments to work with other organizations and institutions, such as academic researchers who conduct citizen science projects, or provincial lung associations who conduct outreach. Municipalities, other local governments, local health boards, schools and libraries will also be important stakeholder partners.

Significant radon outreach and action have been achieved in Canada since the National Radon Program began. Provinces and territories are encouraged to take advantage of the existing resources and materials from the National Radon Program, Take Action on Radon Network and many of the already existing initiatives by provinces, territories, regulatory councils and non-profits in Canada. By using this guide and taking action on radon you will help people, improve indoor environments and save lives.

Learn more about:

• National Radon Program
• Take Action on Radon Network