Is that what we are doing bitching? I beg to differ. — Andrew Costigan

Unlike 15 years ago, the standards committee is actually writing enforceable laws, at least for us in Minnesota. Who's the fox and who's the hen-house? — Steven Reichert

Andrew and Steven,
I urge you to get some basic education on this subject. Your responses imply you are ignorant of the rule promulgation process. These incorrect statements are not helping your case. All of the information below is publicly available via your favorite search engine.

Contrary to what you may believe, I assert the ANSI/AARST process is SUPERIOR to other code standard writing bodies. Let's test this assertion against the biggest ANSI construction code writing body - The International Code Council (ICC). This organization is considered by many as the gold standard for construction code promulgation. They produce a wide variety of standards for residential and commercial codes. In Minnesota alone, they publish your residential building code, commercial building code, Energy code, ADA code, Mechanical code, Conservation code and Fire prevention code.




While they allow a wide variety of stakeholder groups to join their organization and participate in committee work, ONLY GOVERNMENT REGULATORS ARE ALLOWED TO VOTE. Contractors do not get to vote. Screenshot of the voting summary below. Attached is the PDF of the entire ICC voting rules.




Compare that to AARST/ANSI where every stakeholder group on the committee has a vote, even contractors. Beyond that, the stakeholder groups have roughly the same number of votes. The opinions of regulators are not superior to any other group. There are no foxes or hens (or even hen houses) on the committee. Just a collection of professionals trying to create a quality standard. I encourage you to learn about the ANSI/AARST process. You may be surprised at how balanced and accessible the process is for everyone involved.

Freeze ups are rare and resolve themselves within a day or two. Systems installed in Climate Zones 6 and 7 do have unique challenges and most reputable mitigation professions know what they are and do their best to minimize them and education their customers. We for example almost never install critter guards because they quickly build up ice. Building codes are climate zone specific, perhaps our standards should be too. — Steven Reichert

Hello Steven,
This reply is an excellent example of a potentially persuasive comment to the committee. It is concise, avoids hyperbole, the author limits his reply to topics within his expertise, and he attempts to offer an alternative that is practical while adhering to the goal of rule.
If you were to submit this statement in a comment to the committee with minimal adjustments, it would likely receive serious consideration.

*Please note that I did not promise, guarantee, assert or imply that this statement will have any impact on the committee whatsoever. I am also not publicly endorsing this approach in any way. I am simply pointing out that, generally speaking, comments with similar attributes have been more seriously discussed/debated by the committee than other approaches.

Tony - I think the questions the radon mitigation professionals in this country need answers to right now are in David Smiths post. — Andrew Costigan

Hey Andrew,
I addressed David's comments as requested. Can you please answer the questions I asked you?

Hey @David Smith someone requested that I reply to your post, so I did. Unless I specifically mention your name, my answers are directed more toward the group than you specifically. If you have any questions, give me a call so we can discuss it.

On November 7th, I contacted the EPA for assistance on the alarm requirement. — David Smith

David, I understand you are concerned about this issue. Just curios, did you reach out to anyone at NRPP or the Standards committee before going to the EPA? If not, why?
I have been a member of the AARST Board of Directors (BOD) for most of the past 10 years. I have been a member of the mitigation committee for at least the last 4 years. I have presented about a dozen times at conference and have provided my contact info at every possible opportunity to help people in the industry. I mention this not to boast but to point out that we, as an industry, are terrible collaborators. I do not think I have fielded 5 calls from any member of our industry that wanted to voice concern or seek assistance for a given issue. I, like many others on the BOD, take my role as a member of the BOD very seriously and always attempt to help members whenever possible. I feel it is the duty of the BOD to respond appropriately when a member reaches out for assistance. That does not mean I have the ability to solve their problem, but I would have at least been able to point you in the most appropriate direction to address their concerns. In this case I would have steered you toward submitting a comment to the MIT committee instead of suggesting you attempt to rally support at the EPA. I would have even offered my assistance to help you compose a persuasive comment similar to the help I offered @Rich Whisler in this thread (still hoping to hear from you Rich). I would have suggested you stay away from the cost of currently available products or asserting the alarms are going off during freeze ups because that it exactly why the alarm mandate passed. This argument is not persuasive to most stakeholders, especially consumer advocates. If you are in this industry to reduce radon exposure, you cannot be unconcerned about exposing clients to elevated radon levels in the home when it is cold outside. Encouraging the client to press the snooze button on the alarm because it will go away on its own in a couple of days is not, in my opinion, a professional response. Instead, I would suggest you focus on reliability issues of the currently available models. This is an objective metric which can persuasive if presented correctly.

Alarm failure in part helped create this extension of the standard. — David Smith

I am not sure who led you to believe this, but they may have been mistaken.

A. “Lasting service”. — David Smith

David, this is part of an informative background section that is specifically inserted to help the system designer (mitigation specialist) consider some system specific items that may influence their choice for type of alarm. Prior to responding to your comment, I reviewed this section and it reminded me the most appropriate alarm type for the cold weather is likely a unit that monitors electrical draw of the motor. To me, this would be preferable in a northern climate because it would be unlikely to announce a false alarm due to freeze up if the impeller continues to spin when the system has a pressure and flow rate of zero. I will also add that I am unaware of any mitigation alarms currently on the market that function solely on electrical draw. I can remember one from years ago, but it is no longer made.

I nor anyone I know have been provided with independent study information on the alarm products currently available. — David Smith

If you come across one, or conduct this study yourself, please send me a copy.

A one-year warranty indicates that manufacturers might not have confidence in their product. — David Smith

I disagree with this. There was a time when all fans came with a 1-year warranty. Then one of manufacturers increased their warranty to 3 years in an attempt to gain market share. The other manufacturers matched the term after a while. Then one of them went to 5 years and the rest followed suit. It seems they called a truce at 5 years. The bottom line is fan warranties improved due to competition in the marketplace. If we went back to just 1 manufacturer, the remaining company would reduce their warranty immediately. I expect a similar scenario will play out with alarms over the next decade.
I also believe we are spoiled a bit in this industry when it comes to dealing with warranty claims and I would like to say thank you to them for treating us so well.

therefore giving the consumer a false sense of a working radon system. — David Smith

This is a bit hyperbolic. I do not believe a u-tube comes with a five-year warranty. Does this give them the same false sense of a working radon system?

Many professionals are questioning as to how to abide by this requirement when the systems they install are all or mostly on the exterior of the building. — David Smith

If they are mostly on the outside, then they must be partially on the inside... which is where I would put the alarm. I would agree that one of the most difficult scenarios to install an alarm would be a system that was entirely on the outside of the building. That does not mean it is Impossible.
As for the small minority of installs that are 100 % on the exterior because that is the only option, I don’t know of a good solution but it would seem these are the systems that would benefit most from an alarm.

We have not been provided with data indicating the reliability of the alarms during climate changes or other conditions that may affect these devices — David Smith

Did you ask your preferred alarm manufacturer for this data? I would think they would have some kind of idea about the life expectancy of their product.

It is unfair to ask radon mitigation professionals to be “guinea pigs” for any device without proper funding to assist. — David Smith

Please clarify what you mean by guinea pigs and funding to assist.

Is it a fair and just expense for the consumer? My many years of service to the industry says it is not and I will have to apologize to all the homeowners I serve for the unnecessary expense if my state adopts this ruling. — David Smith

Are you objecting to the concept of a notification alarm or just the current ones on the market? I can understand if you feel the current products underperform. I am also not super excited with the current ones on the market. Many seem to be designed and manufactured with a specific price point, not expected lifespan, as the primary goal.
I know you manufacture some of the products you sell. If you are so underwhelmed with the current products, why don’t you develop your own product? There appears to be a demand for it. I hope you (and others) are working on it right now.

The EPA has assured me that they have contacted all regional headquarters to inform states that their funding is NOT affected by adopting or not adopting this alarm ruling. — David Smith

Can you please elaborate on this point? To exactly what funding are you referring? The USEPA contacted all regional headquarters via a memo in April of 2020 that specifically addressed SIRG funding and standards. It is attached to this reply. Had you reached out to me, or any other BOD member, we would have given you this document. It is part of the USEPA public record and available on their web site. If you read it you will see they are recommending the adoption of the standards. They even point to “several critical elements including, public transparency, a formal comment and response process, periodic review, and a balanced and representative range of stakeholder involvement” as a justification for recommendation.

how are “should”, “shall” and “best practice” to be used in the standards. — Randy Weestrand

2.5.1 Conventions
The terms "shall", "required" and "normative" indicate provisions here in that are considered mandatory.
Terms such as "should", "recommended" or, "informative" indicate provisions that are considered to be helpful or good practice, but which are not mandatory.

As entrepreneurs in a free market, — Randy Weestrand

I am going to have to disagree here. The radon industry is not a free market, it's a regulated market, and here is how one can tell. If it were truly a free market, you could do whatever you want without any restrictions. One could even sell radon systems that were constructed entirely out of cardboard tubing, paper mache, elmers glue and low voltage computer fans that vented at grade. Fortunately the radon industry has regulations which makes it a regulated or mixed market to prevent such tomfoolery. It has regulations that everybody must follow. There are very few, if any, actual free markets in the United States.

Tony’s “Simple Rules for a Persuasive Argument…Dos and Do Nots” are Spot On! — John Mallon

Thanks @John Mallon

1. Our default system has the pipe in the garage. If the basement is likely to be finished, the gauge goes in the garage. In the winter, an alarm at the gauge location will be subject to long term extreme cold. In the summer (90 degrees, 90% RH), the pipe and alarm will be wet with condensation. Will the currently available alarms survive in this environment? — Randy Weestrand

One alternative would be to install the u-tube and alarm in the basement and if the basement is ever finished they can install an access panel.

2. If not, will survivable alarms be invented- and will they be at a price point acceptable to our clients? — Randy Weestrand

I understand that some clients may prefer to have the alarm in the garage. If a survivable alarm was available, you could offer it to them as a upgrade to the standard alarm that would go in the basement that they would have to create an access hole for. That way your client can decide if the price is worth it.

3. There are mitigators who would call the alarm issue their “Ruby Ridge”. They won’t comply, and will suffer as a result. Does the standards committee really want to play the role of the feds and force this confrontation, or is it time to stand down? — Randy Weestrand

I understand that there is a group of stakeholders that feel passionate about this issue, however, the argument put forth in this question is unlikely to be persuasive to other professionals in the industry. It is far more likely that industry consensus will change based on a argument which is supported by data. Demonstrating that x% of the time alarms go off are due to a malfunction of the unit would be a far more persuasive argument than the rule should change because you know someone who is not going to comply.

Now I am sure Tony will put what I just posted here in quotations and tell me why I am wrong and he is right or what I should have said differently. But that's my 2 cents... — Andrew Costigan

Andrew,

It seems as though we are talking past one another which can happen on these forums. I am genuinely trying to understand your viewpoint. I am, however having difficulty determining the root of the problem. It seems as though you have had a bad experience with alarms. I think that is pretty clear. The radon community is small, however, the accusations surrounding this issue are plentiful. I have been told that the people who object to alarms are the same people who knowingly install inferior systems which are subject to freeze up in the cold weather. Those who allege this also assert that they install systems in the same climate and do not experience issues with alarms. I am not inclined to believe such extraordinary claims without evidence so I came here in an attempt to get the information directly from the source.

I would like to offer an alternative approach that may assist in our mutual goals.

Please feel free to help me understand your view on the following questions:

1. What minimum temperature should a mitigation system be designed to operate at before freezing is expected?
2. Do you believe the majority of local contractors in your area take similar steps to minimize the potential for freeze ups as you do? If not, do they do more or less?
3. Do you provide any performance guarantees in your contract for radon reduction? If so, are their any caveats regarding freeze ups?
4. Do you believe contractors who take shortcuts in weatherproofing are responsible for the issues they are experiencing with the alarms?
5. Are you or your clients worried about elevated radon levels in the house during freeze ups?


BTW - The quoting feature is a relatively unknown part of the website. It is a useful tool for this format because replies are not nested to their parent comment, they are listed in chronological order. Providing a quote of whom you are responding to allows everyone to quickly understand the scope of the discussion. It is really easy to use. You just have to highlight whatever text you want to quote and a mini dialogue box is shown near your cursor with the word "Quote" Once you click on it, the system does the rest for you. See screenshot below for clarity. You can also @ somebody like this @Andrew Costigan by choosing the @ symbol at the top of this reply box and typing in the persons name. It will notify that person you mentioned them in a post. Like I did in my comment to @John Mallon when referring to personal CRM's. Until someone decides to change the format of the list serve to have nested comments, the quoting function is the the best way to keep track of conversations. Isn't that right @Admin?

In Ohio I don’t believe it is required - but I would hope because of how much you advocate for them about how great they are that you would be installing them on every one of your systems. That’s why I ask how they have been working for you since January of 2019. I would hope that any mitigator that is on the standards committee that voted to have these alarms required are actively following what they have required the entire mitigation community to follow. — Andrew Costigan

Yes, All of our installations meet or exceed all the relevant requirements of the jurisdiction where the installation was located. We have actually been installing alarms on every commercial system since before 2015 so this change in the rule did not effect me. We have installed alarms on all our residential systems since before the mandate as well.

This may come as a surprise but being a member of the committee does not earn me a free pass to do whatever I want. That's not how this works. I don't agree with everything in the current standards, but I follow them because those are the rules. I do, however, make my personal opinions known on items I disagree with via the same comment system available to any stakeholder. ANSI/AARST expects this attitude from me and every other committee member.

In MN we are required to install these alarms on every system we install or face potential fines. We technically do not have the option to simply not use them. We are forced to. — Andrew Costigan

This hyperbole doesn't help your case. You are required to follow all the rules. You don't have the option to simply not follow any of the requirements. That is why they are called requirements, not suggestions. This rule is not more draconian than the rest of the standard because you disagree with it.

After looking at the list of names that contributed to the ANSI/AARST SGM 2017 standard I find it troubling that the amount of mitigators on their are of a small percentage. — Andrew Costigan

I think this comment is due to ignorance in how the standard promulgation process works. ANSI mandates all stakeholders have representation on the committee. This means more than mitigators are required. The committee also needs representation from local government, state government, NGOs, manufacturers, consumer advocates and building scientists. Not all of these groups are mitigators, nor should they be. I can assure you the ESC did an admirable job identifying and seating individuals with relevant experience. Mitigation professionals are well represented on the committee in terms of experience, viewpoint and geographic location. If memory serves me correctly, about a dozen members on the SGM-SF committee had significant mitigation experience which is more than any other stakeholder group. If the standards were written exclusively by mitigation professionals, they would not be accredited by ANSI nor recognized by the regulatory agencies. The committee roster from SGM-SF 2017 is attached to this reply for reference,.

And of the ones on the list - I would like to know how many actively install systems in a climate like ours. — Andrew Costigan

There were several people on the committee from your state and more from places with a similar climate.

I personally would also like to see a new method for including mitigators in on decisions that effect our business’s like a system alarm. — Andrew Costigan

There is already a method for including industry in the decision making process. It is the commenting process that Dallas outlined in his initial reply. You can access it here. I encourage you to use it. You can also volunteer to work on a committee here. the ESC is always looking for qualified people to help when a committee seat becomes available.

We are the back bone of the industry and I fell like we are getting pushed to the side while a small majority tries to insert themselves into what we built. — Andrew Costigan

Please clarify this assertion. I do not want to misinterpret you, but this reads like there is some knid of conspiracy going on. Who are:

• the backbone of the industry?
• The small majority?
• The "we" in "what we built"?

and what are they trying to insert themselves into?

This individual standard needs more time to be thought through and more input from the ones being forced to install them. — Andrew Costigan

This has been in the standard since the 2017 edition. How much more time do you need?

A failed radon fan event does not need a blaring alarm event that instant. — Andrew Costigan

There is a mountain of dead fans out there that have not been replaced that would beg to differ.

There are many low cost crm monitors available today that would be a great alternative to a blaring alarm. And I think most homeowners would agree. — Andrew Costigan

Most consumer CRMs have an alarm built in. Some will even text your phone. If you have a CRM in the house and the system freezes over for several days like you said in another post, the radon levels will rise and you will be flooded with phone calls about high radon levels and a non-functioning system. The CRM is the same as the alarm, it just waits a day or so until the conditions are worse until it informs the client.

And what about normal fan failures. — Randy Weestrand

How do you tell the difference between a fan failure and system freeze up? Do you just assume it is a freeze up because it is cold outside?

I and most mitigators in MN (see Randy’s original post) do not agree with setting off an alarm at 3:00am and waking up a homeowner because their system froze. A terrible idea to say the least and crippling to our businesses when the next day we will get run over by phone calls. — Andrew Costigan

I do not understand this. Are you asserting that your systems should only work under certain weather conditions? If so, what are those conditions?

I am not sure what you mean Andy. I posted about 10 comments over the last couple of hours and I cannot tell which one you are replying to. I am happy to elaborate. And yes, I have bench tested many of the new products on the market now and some that are still in the works. Unfortunately, I cannot disclose which ones I have evaluated, nor will I recommend any specific product. We have hundreds of them in the field with no significant issues.

As a longtime member of the Mitigation Standards Committee, I hope to provide some insight.
Before I begin, I want to remind everyone that these comments are mine alone. I am not speaking on behalf of the MSC or AARST. I think @admin (Dallas Jones) did an admirable job of responding for the organization.

The following email was sent to all 120 Minnesota mitigation licensees with a publicly available email address. — Randy Weestrand

But an alarm, whether smoke, CO, burglar, seat belt etc. implies an immediate risk. A fan failure or freeze up is not an immediate risk and should not be announced with an alarm. — Randy Weestrand

I would argue this is close but not completely correct. Alarms are not used to imply an immediate risk. That is what warning labels are for. Alarms are intended to provoke immediate action. When the smoke alarm goes off, the intention is not for you to think about the number of people who die in house fire every year (4,000), it is to make you get up and get out of the house. The homeowner should take immediate action when the mitigation system is not operating properly.

MDH is enforcing the ANSI / AARST rule that all systems have an alarm — Randy Weestrand

I think it would be appropriate to clean this up to say MDH is enforcing ALL the rules in the ANSI/AARST standards. This includes all the ones with which you agree and disagree. I imagine there is another email in which you congratulate MDH for enforcing the policies you agree with.

1. Which most closely matches your opinion?

40 ....61% ...Alarms imply imminent danger, and are not appropriate in any climate
13 ....20% ...Alarms are good, but not in Minnesota’s climate
7 ......10% ...Require alarms, but only when there is one with just a light and no audible alarm
6 ........9% ...Require alarms now, the available alarms are fine
66 . 100% ...Total responses — Randy Weestrand

It is significantly more difficult to compose a fair and accurate survey question that one would think. Like mitigation diagnostics, polling is the real-world application of scientific theories. One rarely gets it correct with no experience. Even with the best of intentions, many questions end up with an unintentional bias. Dishonest polling is referred to as Push Polling where the poll uses loaded questions to sway the results toward a particular goal. This article gives a quick overview of polling bias.

The question above is an example of what the article would call a double-barreled question which means the question or response contains 2 or more concepts that are not necessarily connected. One's stance on alarm's is not necessarily connected to the climate. When analyzing this data, one has to guess which of the concepts was more influential to the respondent. The problem is the motivational factor will differ by respondent which leads to junk data.

One could use this dataset to assert 100% of respondents believe we should require alarms at some point because they are good, and they imply imminent danger though this assertion would be easily debunked if you study the questions and the answers. If you think that is dishonest, I will point you to the primary source for this entire thread: AARST/ANSI SGM-SF 2017. On the first page of the standard, in the introduction, there is a paragraph with the headingContinuous Maintenance of This Standard. It informs the reader that they can request a change of the standard at any time and provides general instructions for starting the process. This makes me wonder if anyone of one the aggrieved party actually took the time to read the entire standard or if they found out about this change 3 years later because of an informational bulletin from a regulatory agency. Quite honestly, their concern about this issue would have held more weight in my mind if they had voiced their discontent when the standard was published in 2017. Below is a screenshot from page i of the SGM-SF 2017.




The best way to remove the ambiguity in this question is to separate it into the component parts.
One question each regarding:

• What alarms imply to you.
• What, if any, climate are they appropriate for?
• Should we require alarms?
• If so, when should we require them?
• Should an alarm have a light, a noise or both?
• Do you like the alarms that are currently on the market?

Once we see the question broken out into the core concepts, it is easier to see how the data may not be useful.
Lastly, while I believe your data to be representative of the people who responded to your survey, I do not believe it is representative of the industry.
I have heard someone from Ohio tell me alarms are great, but only in Florida. If you think this reply does not fit your survey because the person is from Ohio, you can see why I contend this poll is not necessarily representative of the industry.

The use of audible alarms on radon mitigation systems is inappropriate and will decrease the safety of the homeowners and add liability to our profession by encouraging homeowners to ignore their systems (unless there is an alarm going off) and will diminish the number of homeowners that actually listen to our industry when we say
“The EPA Recommends that every home is retested every 2 years”
I believe there is increased legal liability for the mitigator or standards organization if we tell people they are protected from system failure with an audible alarm, and then system performance is compromised by a failed alarm or some other unforeseen circumstances.
….
I don’t know how we would handle the volume of calls we would if there were audible alarms going off in hundreds (thousands) of homes. I also expect that convincing people it is ok to stay in their homes while an alarm is going off is going to be much tougher than we experience with our clients today.
I would probably not be able to do anything else but take these calls and this would severely negatively impact my ability to remain in business. — Rich Whisler

I need to preface this comment with a reminder that my opinions on the list serve are mine alone. I am not claiming to represent AARST or the MIT committee.
Rich,
I applaud your effort to make your voice heard and would like to offer some potentially helpful feedback. I have been involved in the MIT committee's review of public comments for several years now, so I understand how to make a persuasive argument to the committee. Below are some simple rules to follow:

Do NOT:
1. Make outrageous claims without evidence, especially in the first sentence. I can see the committee trying to understand a scenario in which the addition of an alarm to an otherwise properly installed system will decrease the safety of the homeowner or how it would encourage the homeowner to ignore the system. If they cannot find rapid and near unanimous agreement in your preamble, they will not advocate serious consideration for the rest of your comment.
2. Avoid hyperbole. Neither the world is going to end, nor the industry is going to collapse if your intentions are not made reality.
3. Send in a form letter with generic language. The committee reviews all comments with the same procedure whether they are from a single person or an entire group. Inundating the standard committee staff with dozens of copies of the same comment does not add any actual weight to your comment.
4. Assert or imply anything regarding ANSI/AARST’s legal liability. No matter how well intended; this
always comes off as a veiled threat and your entire comment is construed as counterproductive.

Do:
1. Be respectful. Not sure why I have to mention this, but I do because of previous comments.
2. Stick to your field of expertise: I would avoid commenting on legal liability or any other professional field unless you have some type of relevant expertise.
3. Offer an alternative approach to the issue: Most comments that are submitted have already been discussed by the committee. The chances of the committee removing an entire section is minimal. Finding common ground with the committee by offering a different approach or adjusted language is far more achievable.
4. Address 1 issue per comment. We have been discouraged in the past by comments that try to address many issues in a single comment which led to a significant amount of extra work for both the committee and the commenter when the intent of the commenter was misunderstood by the committee.
5. Be concise. Try to describe your issue in as few sentences as possible. It is already a lengthy process to discuss each comment. Responding to the comments for the 2018 version of SGM-MF took several 2- hour meetings. Adding unnecessary background and anecdotes to your comment drags the process out.
If you would like to discuss how to revise your specific comment to potentially make it more persuasive, send me an email.

Maybe there’s some confusion on my part. — Randy Weestrand

Randy, I was genuinely impressed to read your response to @Admin comment. Your public acknowledgment that you may have been mistake is something that has been missing in public discourse over the last 5 years or so. I have to admit, I am not always as gracious when facing a similar situation.