HUD’s Departmentwide Radon
Policy Notice
Office of Environment and Energy
February 27, 2024
February 27, 2024 HUD Policy on Radon 1
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February 27, 2024 HUD Policy on Radon 2
HUD Presenters and Staff
Kristin Fontenot, Director, Office of Environment and
Energy
Glenn Schroeder, Program Analyst, Office of
Environment and Energy
Lauren Hayes Knutson, Director Environmental
Planning Division, Office of Environment and Energy
February 27, 2024 HUD Policy on Radon 3
HUD Departmental Radon Policy Notice
On January 11, 2024, HUD published its departmentwide radon policy notice,
Departmental Policy for Addressing Radon in the Environmental Review Process
With this Notice, HUD is addressing the risk of residential radon exposure
across the entire Department for the first time ever
The policy falls under HUD’s contamination regulations at 24 CFR 50.3(i) &
58.5(i)(2), part of the environmental (NEPA) review of proposed HUD-
supported projects
The Policy requires consideration of radon gas in buildings as part for
proposed HUD projects subject to HUD contamination regulations
Radon testing is not required, but mitigation is required if the method used to
consider radon shows levels at 4.0 pCi/L or greater
February 27, 2024 HUD Policy on Radon 4
Radon Policy Notice: Implementation Basics
Final Policy was published as CPD Notice CPD-23-103 on January 11, 2024
It goes into effect on April 11, 2024 for all non-tribal and recipients, and January
11, 2026 for all Tribe, Tribally Designated Housing Entity (TDHE), and
Department of Hawaiian Homeland (DHHL) recipients
On these dates, REs and HUD staff must consider radon as part of any non-
tiered environmental review (ER) that is not yet certified, regardless of
where they are in the ER process
Tiered reviews:
For tier 1 and tier 2 reviews completed prior to the effective date: HUD
strongly recommends compliance with the policy for any in-progress and
new tier 2 reviews, but do not require it
For tier 1 reviews in-progress during or started after the effective date: you
must comply with the policy for the tier 1 and all subsequent tier 2 reviews
February 27, 2024 HUD Policy on Radon 5
What is Not Subject to The Policy Notice
• Non-HUD projects: projects with no HUD nexus
• HUD projects not subject to HUD’s contamination regulations:
• Projects not subject to NEPA review (ex. issuance of single-family FHA
mortgages)
• Those at the “Categorically Excluded Not Subject To” (CENST) level of review
Buildings with no enclosed areas having ground contact; buildings that are not
residential and will not be occupied for more than 4 hours per day; buildings
with existing mitigation systems where radon levels are below 4 pCi/L
Note: Projects under the FHA Multifamily Accelerated Processing Guide (MAP
Guide) and Healthcare Mortgage Insurance Program Handbook are subject to
the Notice, but they have their own existing, stricter radon requirements
February 27, 2024 HUD Policy on Radon 6
Does the Notice Apply to My HUD Project ?
The notice does not
apply to your project,
but you must document
if using test results from
the last 5 years.
Does the project involve structures that are or are
intended to be occupied at least 4 hours/day?
Does the project require an environmental review at the Categorically
Excluded Subject to (CEST), EA, or EIS level?
Do all buildings meet one of the
exemptions in the notice?
Yes
No
The notice does not
apply to your project.
You must comply with the
notice for your project.
The notice does not
apply to your project
.
Yes
No
Yes
No
February 27, 2024 HUD Policy on Radon 7
How To Consider Radon under the Policy Notice
Preferred, Best Practice: ANSI/AARST radon testing and mitigation standards
Alternative strategies that can be used (if testing not otherwise required by law/reg):
o Do-It-Yourself (DIY) Testing: Use of individual DIY home radon test kits
o Continuous Radon Monitoring Devices: for use by trained local government staff in
remote areas
o Review of science-based data on radon in the area where the project site is located:
state/tribal geologic data, CDC radon test data
Note: Actual testing for radon is not required under the draft policy
If use of any of the above methods determines that indoor radon levels are or may be
above 4 pCi/L, then the RE must document and implement a mitigation plan.
The mitigation plan must: identify the radon level; describe the radon reduction
system that will be installed; establish an ongoing maintenance plan; establish a
reasonable timeframe for implementation; and require post-installation testing by a
licensed radon professional, where feasible.
February 27, 2024 HUD Policy on Radon 8
ANSI/AARST Standards
There is no national federal radon testing nor mitigation standards of practice
The American National Standards Institute (ANSI) and American Association of
Radon Scientists and Technologists (AARST) have promulgated voluntary
consensus standards for both radon testing and mitigation for a variety of
situation (ANSI/AARST standards)
These standards are the “industry standard” standards of practice for radon
testing and mitigation in the U.S.
Use of the relevant ANSI/AARST testing standard is HUD’s recommended best
practice for consideration of radon
February 27, 2024 HUD Policy on Radon 9
ANSI/AARST Standards
Using this preferred approach involves complete compliance with the relevant
ANSI/AARST testing protocol
Under the Notice, the must recent, current version of the standards must be
used (currently 2023)
Two current protocols for testing:
ANSI/AARST MAH-2023: Protocol for Conducting Measurements of Radon
and Radon Decay Products in Homes
ANSI/AARST MA-MFLB-2023: Protocol for Conducting Measurements of
Radon and Radon Decay Products in Multifamily, School, Commercial and
Mixed-Use Buildings
All standards can be viewed online for free or purchased as PDFs from AARST
website
February 27, 2024 HUD Policy on Radon 10
DIY Testing
Do-it-yourself (DIY) test kits allowed in single-family dwelling units for “single-family” homes,
buildings that feature 1-4 dwelling units
If testing a building with more than 1 dwelling unit, one test kit must be used for each dwelling
unit
DIY tests can be used by consumers with no prior training
All manufacturer instructions should be followed precisely
Tests should ideally be approved by the National Radon Safety Board (NRSB) or the National
Radon Proficiency Program (NRPP)
HUD cannot recommend specific test kits nor brands; contact your state or the National Radon
Program Services at KSU for recommendations and assistance
DIY test kits are either short-term (2-7 days) or long-term (3-12 months) and must then be mailed
to a lab to receive results
Test kits cost anywhere from about $15-$40 dollars, inclusive of any lab fee, and can be purchased
online or at hardware stores or obtained for free or at a reduced price from your state’s radon
control program
February 27, 2024 HUD Policy on Radon 11
Continuous Radon Monitors
In remote areas where other types of testing is not possible or feasible, the use of
continuous radon monitors (CRMs) by the local government is allowed to measure
radon levels
The local government, such as a local health department or environmental
department, may decide to purchase CRMs and train staff to use it
CRMs continuously monitor the radon level and update typically once an hour
CRMs must be used in accordance with the manufacture’s instructions by trained
staff and staff should staff should ensure proper quality control and quality
assurance for each device
Devices should also ideally be approved by the NRSB or NRPP
Contact your state or the National Radon Program Services at KSU for
recommendations and assistance
February 27, 2024 HUD Policy on Radon 12
Review of Science-Based Data: The Basics
This alternative option involves the use of available science-based data to determine
whether the project site is located in an area that has average documented radon
levels at or above 4.0 pCi/L
This will often be done by examining documented mean average pre-mitigation
radon test results from reputable sources, such as state radon test databases, and the
Center for Disease Control’s (CDC) National Environmental Public Health Tracking
Radon Test Data (CDC Data)
Other sources include State/Tribe-generated radon information, such as surveys of
radon levels from collecting radon measurement data or geological studies that
identify high risk area
Data used must correspond to the smallest geographic area for which the minimum
amount of documented test results exist
Often, data, such as documented test results, will be shown at the county level,
which is the largest level one must look at data
February 27, 2024 HUD Policy on Radon 13
Review of Science-Based Data: The Basics
Data used must be the best available data must be used, which is the most current data that best
indicates the level of radon concentration at a project site and comes from the best source
For example, if using CDC data, utilize data from states, rather than labs, whenever possible
Additionally, use the latest 10 years of radon testing results for a project area, if using this type
of data
The average radon level ascertained from this review is then assumed to be the level within any
particular building(s) that are part of your HUD project, if no testing is done
Therefore, if the review shows levels at or above 4.0 pCi/L, then mitigation must be performed
If there are less than 10 documented test results over the previous 10 years for which data is
available in a given county and there is no other available science-based data, then there is a “lack
of scientific data”
In this case, no further consideration of radon is needed if testing is infeasible or impracticable
February 27, 2024 HUD Policy on Radon 14
Review of Science-Based Data: Examples of Data
Sources
CDC National Environmental Public Health Tracking Network Radon Data
Contains data reported to CDC by state governments and national private radon labs; can
be viewed as a map or chart
Data is maintained in these two data sets: data from states (preferable) and data from labs
When using CDC testing data, always use mean, pre-mitigation radon levels in tested buildings
Go to CDC Tracking Network Webpage Select Data Step 1: Content Radon Radon
Tests From States Annual Mean Pre-Mitigation Radon Measurement in Tested Buildings
Step 2: Geography Type State by County Step 3: Geography Select state Step 4:
time Select Years Go
Screenshots of maps from the CDC Tracking Network webpage are sufficient for ER
documentation purposes
February 27, 2024 HUD Policy on Radon 15
Review of Science-Based Data: Examples of Data
Sources
February 27, 2024 HUD Policy on Radon 16
Review of Science-Based Data: Examples of Data
Sources
February 27, 2024 HUD Policy on Radon 17
Mitigation
Mitigation under the Notice functions just as other mitigation under 50.3(i) and 58.5(i)
does
If radon testing or a review of science-based data shows a radon level for a building at or
above 4 pCi/L, then the ERR must include a mitigation plan
If using a review of science-based data, however, radon testing can be done prior to
initiation of mitigation to determine if mitigation is truly necessary for a building
If a review of science-based data shows levels at or above 4.0 pCi/L but subsequent testing
shows levels in the building below 4.0, no mitigation is needed
By electing to test, ER preparers and recipients may ultimately save funds by avoiding
unnecessary radon mitigation
Mitigation plans must: identify the radon level; consider the risk to occupants’ health;
describe the radon reduction system that will be installed; whenever possible, establish an
ongoing maintenance plan to ensure the system is operating as intended; establish a
reasonable timeframe for implementation; and require post-installation testing.
Where feasible, post-installation testing should be conducted by a licensed radon professional.
February 27, 2024 HUD Policy on Radon 19
Documenting the ERR and HEROS
The Environmental Review Record (ERR) must document compliance with the Notice
Including documentation of any test results or test value gained from a scientific data review,
and, if needed, any mitigation plan
Documentation may include ANSI/AARST testing reports, mitigation reports or plans, emails of test
results from DIY test kits, emails from state radon control program staff, and more
Certain documentation (such as when using CDC-maintained testing data) can be completed
using screenshots, like when using NEPAssist for other types of contamination
If there is a lack of scientific data for a particular project, and an RE chooses not to conduct testing
because it would be infeasible or impracticable, then the RE must document the lack of scientific
data and “a basis for the conclusion that testing would be infeasible or impracticable”
To document the latter, REs must show that they assessed what it would take to test the
building(s) within the property and whether that was feasible or practicable under the
circumstances
For example, an RE may state that the cost of having a credentialed radon tester test the building was
infeasible when compared with the cost of a low dollar amount project
No specific documents are needed to document that testing would be infeasible or impracticable
February 27, 2024 HUD Policy on Radon 20
Documenting the ERR and HEROS
For reviews done in HEROS, all compliance with the Notice will be done within the
contamination screen, including uploads of documents and screenshots
The HEROS contamination screen will be updated to include radon-specific fields to
document compliance with the Notice
The contamination screen is not yet updated to include fields for the Radon Policy but is
expected to be in the next 2-6 months
Note: Compliance with the Notice is still required regardless of whether HEROS
provides radon-specific fields
Until HEROS is updated all documentation, including any testing reports,
screenshots, evidence of radon levels, mitigation plans, and more must be uploaded
manually into the existing fields in the contamination screen
February 27, 2024 HUD Policy on Radon 21
Other Radon Requirements- Federal, State and Local
The HUD Radon Policy Notice does not preempt or override any existing
federal, state, or local requirements regarding residential radon testing and
mitigation that may be more strict or comprehensive than the policy notice
For HUD projects subject to the Multifamily Accelerated Processing (MAP)
Guide, the Healthcare Mortgage Insurance Program Handbook 4232.1 Rev-1,
the RAD Program Notice and Supplemental Notice 4B, or other current HUD
radon requirement that is more prescriptive, REs must comply with both that
particular document and the Radon Policy Notice
Additionally, many states and local jurisdictions have radon testing and/or
mitigation requirements that may apply to a particular HUD project
If unsure, check with your state’s radon control program
February 27, 2024 HUD Policy on Radon 22
Radon Testing and Mitigation as Eligible HUD Program
Costs
Program or grant name
Is radon testing an
eligible expense?
Is radon
mitigation an
eligible expense?
Community Development Block Grant (CDBG) Yes Yes
Community Development Block Grant CARES Act (CDBG-
CV)
Yes Yes
Community Development Block Grant Disaster Recovery
(CDBG-DR)
Yes Yes
Community Development Block Grant Mitigation (CDBG-
MIT)
Yes Yes
Community Project Funding (CPF) Grants Yes Yes
Continuum of Care Program (CoC) Yes Yes
Emergency Solutions Grants Program Yes Yes
FHA-Insured Healthcare Loans Yes Yes
FHA-Insured Multifamily Loans Yes Yes
Green and Resilient Retrofit Program (GRRP) Yes Yes
HOME Investment Partnerships American Rescue Plan
Program (HOME-ARP)
Yes Yes
HOME Investment Partnerships Program (HOME) Yes Yes
Housing Opportunities for Persons With AIDS (HOPWA) Yes Yes
Housing Trust Fund (HTF) Yes Yes
HUD Section 8 renewals with capital repairs Yes Yes
HUD Section 8(bb) Transfer of Budget Authority. Yes Yes
Indian Community Development Block Grant (ICDBG) Yes Yes
Indian Housing Block Grant Program (IHBG) Yes Yes
Public Housing Capital and Operating Funds Yes Yes
Rental Assistance Demonstration (RAD) Yes Yes
Section 108 Loan Guarantee Program Yes Yes
Section 202 Supportive Housing for the Elderly Program Yes Yes
Section 811 Supportive Housing for Persons with
Disabilities Program
Yes Yes
Self-Help Homeownership Opportunity Program (SHOP) Yes Yes
Transfers of Rental Assistance with HUD Held or Insured
Debt and/or Use Restrictions ("Section 209 Transfers.")
Yes Yes
• For all major HUD programs, both radon testing and
mitigation are eligible program expenses, allowing
grantees and REs to use program funds to cover any
needed costs for testing and mitigation within the
ER
• This means that grantees and REs may not have to
pay out of pocket to cover any up-front costs for
radon testing or mitigation
• Barriers to fund testing and/or mitigation: a high
cost when compared to the project’s budget and
a need to spend funds elsewhere
• Bottom line: Recipients can use existing HUD funds
to cover radon costs for an ER
February 27, 2024 HUD Policy on Radon 23
Frequently Asked Questions
Q: My state requires the building be tested by a credentialed radon tested, but the HUD Notice doesn’t
require that. Does that mean I don’t have to have the building tested by a credentialed tester?
A: No. You must still follow your state’s requirements. In this case, following the state testing
requirements would satisfy that portion of the HUD Notice.
Q: My property has a residential building, but I am using HUD funding for non-interior work, such as
replacement of a sidewalk; does that mean I don’t have to comply with the Notice?
A: No. 24 CFR 50.3(i) and 58.5(i) require that a contamination analysis be done for the “property” being
proposed for use in HUD programs, so even though the work being done is not to a residential building,
radon must be considered for all buildings covered by the notice on the property.
Q: I am a PHA. Is there any way I can avoid having to consider radon for all buildings in my public
housing portfolio?
A:Yes! By using tiered reviews, PHAs and other grantees with multiple buildings can set their
environmental reviews up so that radon must be considered only at buildings where HUD funds are
being expended.
February 27, 2024 HUD Policy on Radon 24
Frequently Asked Questions
Q: My HUD project involves new construction of a residential building. How do I comply
with the Policy Notice when there is no building to test yet?
A: For new construction, radon testing must be done after construction and after the ER
is certified. The ERR must include a condition for post-construction radon testing
followed by mitigation if needed. The ERR must then be updated with the radon
evaluation and proof of any required mitigation when complete.
Q: Are there other opportunities to help me pay for radon testing and/or mitigation?
A: Yes! In addition to using existing HUD funds to pay for testing or mitigation as part of
an ER, there are other potential opportunities to assist with testing and mitigation.
HUD’s Radon Testing & Mitigation Demonstration Grant Program provides funds to
eligible PHAs to plan for, test, and mitigate against radon. Additional competitive grant
funding may be available through the EPA for radon mitigation. Other funding may exist
for Tribes and other types of grantees as well. Some states also offer mitigation
assistance to low-income homeowners
.
February 27, 2024 HUD Policy on Radon 25
Frequently Asked Questions
Q: Will there be exceptions to requiring radon testing/mitigation in older homes, historic
homes/buildings, and/or buildings in very rural areas where testing and mitigation systems
may be very expensive or unavailable?
A: Under the Notice, testing is not required, and radon consideration can be completed using
a review of science-based data. For mitigation, there are no exceptions for these types of
situations. Additionally, compliance with Sec. 106 of the National Historic Preservation Act
may be required for installation of mitigation systems. Contact your HUD OEE regional POC or
State Historic Preservation Office for guidance.
Q: What if radon mitigation is required, but the cost is too high for my small dollar project?
A: If radon mitigation is required, then it must be performed, or the project must be rejected.
Q: How do we apply this policy to demolition projects?
A: The Notice would not apply to buildings being demolished, as they will not be intended to
be occupied at least 4 hours/day.
February 27, 2024 HUD Policy on Radon 26
Getting Technical Assistance and Useful Resources
For all questions and technical assistance on the Policy Notice, please reach out to your regular
HUD environmental POC. Find that person here:
https://www.hud.gov/program_offices/comm_planning/environment_energy/staff
For assistance with selecting a test or monitoring device, industry standards, and becoming
certified in testing or mitigation, and other educational information, check out the National Radon
Program Services at Kansas State University:
https://sosradon.org/
To find contacts for your state radon control program:
https://sosradon.org/state%20program%20contacts
To view the ANSI/AARST standards online for free:
https://standards.aarst.org/
HUD Radon Testing & Mitigation Demonstration Grant Program:
www.grants.gov/web/grants/view-opportunity.html?oppId=349163
EPA Tribal Indoor Air Funding Directory:
https://tribalindoorairfunding.org/
February 27, 2024 HUD Policy on Radon 27
Questions?
February 27, 2024 HUD Policy on Radon 28
Radon Professional Certification
Model
In brief.
Radon Testing and MitigationFebruary 27, 2024 29
Radon Measurement Certification Model
State-Required Radon Credentials
HUD Policy on Radon 30February 27, 2024
State Certification/License Required (Y/N) Disclosure Required (Y/N) MF Meas Standards Adopted (Y/N) MF Mit Standards Adopted (Y/N)
CA Y Y N N
CO Y Y N N
CT Y Y N N
FL Y Y N N
IL Y Y N N
IN Y Y N N
IA Y Y N N
KS Y Y Y Y
KY Y Y N N
ME N Y N Y
MN Y Y N Y
NE Y Y N Y
NH Y Y N N
NJ Y Y N N
OH Y Y N N
PA Y Y N N
RI Y Y Y Y
UT Y (Mit Only) N N Y
VA Y Y Y Y
WV Y Y N N
Radon Measurement Certification Model
State Level Credentialing Model
Completion of a state-approved 16-hour introductory radon
measurement course
Successful passage of either a state or national certification exam
Two commonly accepted national certification Exams
National Radon Proficiency Program (NRPPS) Radon Measurement
Professional Exam
National Radon Safety Board (NRSB) Radon Measurement Specialist
Exam
Submission of required paperwork and fee payment
Radon Testing and Mitigation 31February 27, 2024
Radon Measurement Certification Model
Voluntary Credentialing Model
Two current USEPA-recognized voluntary credentialing programs
National Radon Proficiency Program (NRPP)
https://nrpp.info/
National Radon Safety Board (NRSB)
https://nrsb.org/
State radon programs in non-credentialing states ONLY recommend
working with radon measurement professionals certified through one
or both of these organizations
Radon Testing and Mitigation 32February 27, 2024
Radon Measurement Certification Model
Voluntary Credentialing Model
Completion of a program-approved 16-hour introductory radon
measurement course
Successful passage of the program’s national certification exam
Submission of required paperwork and fee payment
Radon Testing and Mitigation 33February 27, 2024
Radon Mitigation Certification Model
State Level Credentialing Model
Completion of a state-approved 24-hour introductory radon
mitigation course
Some states have mandatory field training requirements in additional
to the course work
Successful passage of either a state or national certification exam
Two commonly accepted national certification Exams
National Radon Proficiency Program (NRPPS) Radon Mitigation Specialist
Exam
National Radon Safety Board (NRSB) Radon Mitigation Specialist Exam
Submission of required paperwork and fee payment
Radon Testing and Mitigation 34February 27, 2024
Radon Mitigation Certification Model
Voluntary Credentialing Model
Completion of a program-approved 24-hour introductory radon
measurement course
May require field experience as part of the certification process
Successful passage of the program’s national certification exam
Submission of required paperwork and fee payment
Radon Testing and Mitigation 35February 27, 2024
