EPA's revised risk estimates for radon coincide with the recommendations of the National Academy of Science. The risk estimate is that radon causes 7,000 to 30,000 deaths annually, with a certain risk of 14,000 deaths. The EPA Science Advisory Board concluded that the risk figures are "a solid, well documented and defensible central estimate of the radon-related lung cancer deaths in the U.S. and probable range of uncertainty." The Agency for Toxic Substances and Disease Registry also issued a report on radon toxicity. ATSDR concludes that "even conservative estimates suggest that radon is one of the most important environmental causes of death." ATSDR reports that 14% of all current cases of lung cancer could be attributable to radon. In 1993 the International Commission on Radiological Protection circulated a report on radon protection which coincides with the risk estimates by EPA and CDC in 1992 (House Energy and Commerce, 1993). Just this year, the National Cancer Institute performed and independent review of the risk data and estimated that 6,000 to 36, 000 lung cancer deaths per year are radon induced. NCI's central risk estimate for radon induced lung cancer deaths was estimated at 15,000 per year.

In 1986, the United States Surgeon General, the American Lung Association, and the Environmental Protection Agency began repeatedly recommending that everyone test their homes for radon. To date, fewer than 9% of American homes have been tested for radon. The EPA action guideline level for radon is 4 picocuries per liter of air (pCi/l). Bear in mind that the EPA action guideline level for radon is not a safety standard. EPA generally sets its safety standard limits based on a 1 in 10,000 to 1 in 1 million risk of death over a lifetime of exposure, however, the radon action guideline level is set at a level equivalent to a 1 in 1 hundred risk of death over a lifetime of exposure. In essence, those individuals exposed to 4 pCi/l of unregulated radon are being exposed to 100 to 10,000 times more cancer risk than if they were exposed to the maximum safety standard levels of any EPA regulated Carcinogen. Radon must be treated for what it is: a radioactive carcinogen. It is not more or less potent at various levels, it is radiation. The alpha radiation generated from polonium 218 and polonium 214 is the exact same alpha radiation generated from radon 222, so why treat radon differently? The Nuclear Regulatory Commission limits non-occupational nuclear plant workers, such as secretaries, to a cumulative exposure of 500 mrem per year, yet the typical homeowner who spends 66% of his time in his home with a radon level of 4 pCi/l is being exposed to radiation more than 35 times the 10 CFR 50 limit. Moreover, when considering the increase in the number of in-home offices across the United States, the average exposure period for homeowners is increasing dramatically.

Schools pose an additional concern. If an elementary school spends 8 hours per day and 180 days per year in a classroom that contains 4 pCi/l of radon, that child will receive a radiation dose of over 200 mrem. That child and his classmates will have received nearly twice the allowable limits set forth in 10 CFR 50 and nearly twice the allowable limits set forth in 10 CFR 20 which establishes permissible exposure limits for non-occupational nuclear plant workers under the age of 18. The exposure limits established in 10 CFR 20 pertain to individuals who are being compensated for working in an area where there is a known risk for possible radiation exposure. Isn't it reasonable to expect our homes, schools, workplaces to have more stringent guidelines for radiation exposure than those developed for nuclear plant employees? When using the lowest risk National Academy of Science BEIR IV figures, exposure to radon at the EPA action guideline level poses thousands of times more risk than exposure to any other carcinogen at the safety standard levels established by EPA.

EPA's national map of radon zones corresponds well with testing data from private industry that pin-points high radon areas. The EPA map appears to do an excellent job of identifying the areas of the country with the most severe radon problems yet testing data clearly shows that it is still essential that all homes be tested for radon. Data generated by private testing firms indicate that elevated radon levels exist in virtually every locale. States such as Arizona, California, and Hawaii have been associated with low radon risk, however, excessive radon levels have been discovered in each state. The geology of the area is only one variable that effects indoor radon levels. Building construction and mechanical system design are key components influencing indoor radon levels. In Paradise Valley, Arizona, a high percentage of homes tested for radon exceeded the EPA action guideline level. Many of the large ranch-style homes in this community utilize heating and cooling systems that actually elevate radon levels significantly within the home. Similar mechanical systems in California and Hawaii have resulted in elevated radon levels in structures that ordinarily would have tested below the EPA action guideline level.

AARST is aware that some individuals have expressed concern about measurement technologies. EPA's Science Advisory Board has thoroughly reviewed this issue and provided guidance on both short and long term measurements. The guidance of the SAB has been relied on to develop AARST and EPA radon testing protocols.

Our association sees S.657 as a significant step forward in reducing the enormous economic and human cost that radon poses on the American public. Every year radon costs the United States over two billion dollars in both direct and indirect health care costs (Oster, Colditz & Kelly, 1984). This cost analysis does not include the lost productivity incurred by society with each lung cancer death. In essence, a single year's cost of direct and indirect health care for radon-induced lung cancer will pay for the entire cost of testing every home in the United States for the deadly carcinogen.

AARST looks forward to the opportunity to work with the members and staff of this Committee to establish radon programs that will reduce the risk to human health that radon poses. AARST is confident that such a program can be readily developed upon passage of S.657. I hope that these observations and suggestions are helpful to the Committee's consideration of the matters before it. Thank you again for the opportunity to provide this testimony.

Nor Environmental