It seems there is a misconception on here that MN mitigators are installing a lot of exterior systems - not true.
Interior garage run systems are very common and preferred when we can - as the homes layout allows.
Now lets get back to the the freeze ups. Bottom line - it boils down to the amount of humid soil gas being pushed out the exhaust. Nothing else matters when you get down to temps that cold. When you are sucking on dry soil - freeze ups are not very common. Sucking on wet soil - you will have a freeze up at 20 below - guaranteed. I have seen with my own eyes interior system freeze as well. Example - I put a system alarm on a builder installed passive system a few years ago. Completely interior and well insulated. The home owner called me that winter during a polar vortex period telling me the alarm was going off. Remember the freeze up starts at the exhaust end and works its way down. Radon vent pipes produce condensation ( we all know that) as humid sub slab air cools to its dew point in the vent pipe. During prolonged periods of very cold weather, condensation can create ice crystals which can accumulate and block air flow, temporarily rendering the system inoperable until the temperature rises. A freeze up can be diagnosed by a major drop in the U-tube manometer. Freeze ups generally do not last for prolonged periods - but can depending on the severity of the what we call the polar vortex. This would create a large amount of nuisance alarms going off.

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...

I have three remaining questions:

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?

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

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?

Can’t find the pictures, Tony, did look. For all, I spent my years as Chair of the Multi-family Mitigation Standard and on the Large Building / School Mitigation Standard. My great thanks goes to those currently contributing. Lots of Monday Morning Quarterbacks with critiques ranging from constructive to offensive. Tony’s “Simple Rules for a Persuasive Argument…Dos and Do Nots” are Spot On!

My 2 Cents:
Alarms that signal the fan is not working is a good idea, but like every change will meet some resistance from Mitigators. A sticker near the fan alarm that explains that this might be temporary due to weather and, if necessary, a phone explanation with a nervous client advising to keep an eye on it for the next few days should be sufficient. We have more problems with alarming personal monitors bought by homeowners showing 4.3 pCi/l in mid-January.
John Mallon

I am a 23-year veteran of the radon mitigation industry as well as a distributor of radon products. I have the unique privilege of speaking with mitigation professionals all over the country every day and have been hearing many concerns regarding the alarm requirement. As a radon products distributor, I would only gain from the alarm requirement; but as a fellow mitigator I heard, understood, and agreed with the concerns being voiced. On November 7th, I contacted the EPA for assistance on the alarm requirement. At that time, the standards committee had been formally asked to extend the alarm requirement for an additional year and denied it.

The alarm requirement 9.2.2 was originally instituted in 2017 and was postponed to 1-1-2019 for radon application. Alarm failure in part helped create this extension of the standard. It was termed as time for “product manufacturers to develop improved and cost-effective products”. Requirement 9.2.2 goes on to say that strong considerations include, but are not limited to:

A. “Lasting service”. I nor anyone I know have been provided with independent study information on the alarm products currently available. A one-year warranty indicates that manufacturers might not have confidence in their product. It is highly possible that that a 1-year warranty alarm device will fail before a 5-year warranty fan, therefore giving the consumer a false sense of a working radon system. Most agree that a typical radon fan will last 8-12 years – we should be able to have the same confidence in an alarm. Additionally, the alarm products currently on the market must be climate controlled. 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.
B. “False notifications”. We have not been provided with data indicating the reliability of the alarms during climate changes or other conditions that may affect these devices.

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

I would also like to pose this question: 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.

Only one state has enforced this ruling and it is my hope that no other states adopt this until some of these issues get resolved. 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.

Thank you for your time,
David Smith

Thank you David. It speaks volumes that a man who makes money selling alarms feels that an alarm mandate is a bad idea. And what the h***!!! This is only being enforced in Minnesota??? That also speaks volumes.

Wow David - very well written... and couldn’t have hit the nail of this controversial requirement more squarely on the head!
Thank you for sharing this.

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?

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.

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

Thanks @John Mallon

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

When SGM-SF 2017 was implemented, the standards committee a incorrectly anticipated suppliers would be able to develop “improved and cost-effective products” by 2019. None to have done so to date. There have been no new commercially available monitor products released subsequent to it’s publication. The only solutions that meet all the requirements of the standard are monitors the operating on 120v AC household power. All of those solutions cost over $120.00 and need to be wired to a separate circuit from the fan (9.2.3.2). With customary mark-up and the cost of an electrical contractor need to install a circuit for a monitor, the customer cost would easily exceed $500.

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.

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?

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. — Tony McDonald

Tony - if this is how you feel; then why is the standards committee not delaying the implementation of the alarm? It says right in the standard - the delay to January 1, 2019 was to allow product manufactures time to develop "improved and cost effective products". This clearly hasn't happened.

And yes - we have performance guarantees on all of our systems and always have.

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. — Tony McDonald

I will have to agree with you on this one Tony - "if" alarms / active notification devices are here to stay. Then one like you describe above would be appropriate for northern climates like MN. I am also glad to see you at least agree of the false alarm issue on what is currently available to us. There actually hasn't been a new alarm to hit the market since 2017.

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? — Tony McDonald

A frozen exhaust will usually start to begin at or below 5 degrees F - and again this also depends on how much humidity is being pushed out.

All mitigators in MN are mindful of the potential for frozen exhausts - I am really not sure if they are doing more or less.

Performance guarantees on all of our systems. I have yet to have a homeowner not understand the possibility of this condition when we discuss it. Its a short term issue not long term one.

Was there an alarm study conducted to answer #4 - this is the 1st winter these alarms have been required and so far we haven't had much of any polar air yet. I am shocked the committee didn't want to see at least a 12 month study done on these alarms before requiring them for everyone.

For number 5 - a frozen exhaust is a temporary condition due to severe winter weather and one that doesn't usually last long enough to be a large concern. If it was for months on end - then obviously that's a big problem.

It seems there is a lot of unfounded emphasis on cold weather performance on radon systems being discussed here. 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.

UPDATE: The Executive Stakeholders Committee of the ANSI-AARST Radon Standards Consortium met late on Friday afternoon January 8th. Joshua Kerber made the following motion: "The ESC resolves to direct the mitigation committee to review the requirements for active alert monitors and address as appropriate. In addition, the ESC committee resolves to review and refine its notification process to ensure that all stakeholders receive ample notification for implementation of standards revisions." Chrys Kelley seconded the motion and it passed unanimously.

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.

UPDATE: The Executive Stakeholders Committee of the ANSI-AARST Radon Standards Consortium met late on Friday afternoon January 8th. Joshua Kerber made the following motion: "The ESC resolves to direct the mitigation committee to review the requirements for active alert monitors and address as appropriate. In addition, the ESC committee resolves to review and refine its notification process to ensure that all stakeholders receive ample notification for implementation of standards revisions." Chrys Kelley seconded the motion and it passed unanimously. — Admin

Thank you for sharing this Dallas.
Can you or someone familiar with the process explain what this means?

The way I read it that the active alert monitors requirement is tabled for now. Correct me if I'm wrong? More importantly, I have grave concerns that a member of the standards committee also has regulatory authority over radon professionals in their state. It's an obvious conflict of interest. We don't allow law enforcement to make the laws.

obvious conflict of interest — Steven Reichert

Interesting fact here, when the standards consortium was first formed 15 years ago or so, several states felt that industry writing its own standards was like the fox guarding the hen house. Then they got involved and saw that it was a legit process and we were just trying to get the standards right. They saw that a single voice or perspective couldn’t dictate direction. Instead, the balanced viewpoints were actually fixing gaps in early EPA work so they got more involved. Just as with a mitigator, a tester, an educator, a laboratory, a Federal Agency, a consumer advocate, an architect, a builder, a due diligence company, a home inspector, a manufacturer, or a radon chamber, they had input but couldn’t dictate the outcome. That is actually the strength of the consortium. As @Bill Brodhead pointed out previously, everyone on the committees have biases. The process and Bylaws, which have resulted in ANSI accreditation, which allowed them to become recognized and used in Federal and State policies, has actually grown the industry and is transforming it into a real industry instead of the hobby shop that it was for years. The state perspective is an important one and you might be surprised that they are actually on “our” side. I’m proud of the fact that I was one of the first ones holding one end of the olive branch. We can’t let go now.

That being said - for full transparency.
Can the list of all the committee’s be posted on here and a list of the names on them?

list of all the committee’s — Andrew Costigan

They are all available on the Association's website: https://standards.aarst.org/

Are the minutes from all these closed door meetings also public record?

Until you have lived and volunteered on a committee trying to write a standard, please don't bitch to loudly. I know their are parts of our Canadian CGSB standards that i really don't like and i think are nuts but that is part of the committee process. i reallly hated some parts that we the working groups spent hours on that got changed in the final draft to something that the working groups did not agree to......... but as a whole i think we created something that served Canadians better that what we had before. i would like to thank my working group chairs who stuck at stick handling it all through.

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

Minnesota Administrative Rules 4620.7500 states Radon measurement professionals and radon mitigation professionals measuring radon in single-family residences must:
. . . . .
E. Radon mitigation professionals performing radon mitigation in houses must comply with Soil Gas Mitigation Standards for Existing Homes (ANSI/AARST SGM-SF-2017) or successor ANSI/AARST standards.
. . . . .
Violations subject to civil money fines of up to $10,000

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?