UK National Radon Action Plan, PHE-CRCE-043 https://www.gov.uk/government/publications/uk-national-radon-action-plan
`The abstract to this document claims that “This report presents in a single document, the elements that make up the national radon strategy and the national radon action plan. It fulfils relevant requirements in the 2013 European Union Basic Safety Standards Directive on protection against ionising radiation (EURATOM, 2013).” I think that this statement admits the thought that occurred to me as I read the document for the first time; although labelled as the UK National Radon Action Plan it is not really a plan or a strategy, instead it is a comprehensive description of the work being undertaken in the UK to understand the extent of exposure to Radon, to identify where action should be taken to reduce Radon dose, and to take such steps and monitor their effectiveness.
The section labelled “UK radon strategy” talks about the UK strategy in the third person. It is not a strategy itself but describes a strategy that is off-stage. Where the document states that the UK strategy meets the requirements of the BSS it is really making the credible claim that the UK is already doing what it would have decided to do had it started with a blank sheet of paper and written a strategy in line with the guidance. Essentially the UK had a comprehensive Radon programme before the need was fully articulated in the BSS.
Radon appears in the BSS in a number of places (Article 54 Radon in the workplace, Article 74 Indoor exposure to Radon, Article 103 Radon Action Plan). The BSS requires that there is a national plan to address the long- term risks from radon exposure recognising that the combination of smoking and high radon exposure presents a substantially higher individual lung cancer risk than either factor individually and that smoking amplifies the risk from radon exposure at the population level.
The Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 which came into force on 8th May 2018 require the Secretary of State to set a reference level for public exposure to radon. The reference level for the annual average radon activity concentration in air must not exceed 300 becquerel per cubic metre (regulation 8) in line with BSS Article 74. The BSS calls for a “basis for the establishment of reference levels”. The basis of the UK limits is not clear to me but there is probably a justification somewhere.
Further regulation is found in the Health and Safety at Work etc Act of 1974 and the Management of Health and Safety at Work Regulations 1999.
The SoS is also required to publish information about the hazards of indoor radiation, its measurement and ways of reducing it (Regulation 9). This is satisfied, at least in part, by the website at https://www.ukradon.org/.
There must be a national plan address long term health risks from radon ingress to dwellings, workplaces and buildings with public access (Regulation 10). This must be updated at intervals of no more than five years.
Annex 18 of the EU BSS gives a list of 14 things to consider when setting up a national radon plan. The use of this list is mandated by the 2018 regulations. While I don’t think that the UK is missing anything important with the current approach it is not entirely obvious where each of these topics are covered.
Public Health England have a group focused on the radon issue and they provide leadership within the UK. This document was written by the PHE group along with several other government departments covering the UK and the devolved administrations.
The UK has maps are that identify radon Affected Areas, which are defined as where at least 1% of homes are expected to be above the radon Action Level (200 Bq m-3). These can be found at https://www.ukradon.org/. This shows that my home in Gloucestershire has a “maximum radon potential of less than 1% (in the clear) but with the surrounding area going up to 3 – 5%. Since these values are “indicative” I’m maybe not entirely in the clear. This clearly shows that the need for an “approach, data and criteria for the delineation of areas” is satisfied. It is less clear that a risk assessment has been used to systematically identify the types of buildings that should be surveyed although the UK has a long standing survey programme.
The Forward plan for action on radon states that established UK infrastructure and provisions will be “maintained and supported” but not who will do this and who they will be answerable to which you may expect to find in a strategy. The New topics for consideration” explicitly mentions the annex of the EU BSS and picks up some of the missing elements and promises that they will be given attention and places actions, but not a time frame, on Public Health England.
Maybe next time the PHE will publish a document that looks more like a strategy. In the meantime keep up the good work.
EURATOM (2013). Council Directive 2013/59/EURATOM of 5 December 2013 laying down basic safety standards for protection against the dangers arising from exposure to ionising radiation, Official Journal of the European Union L13/1.
Ionising Radiation (Basic Safety Standards) (Miscellaneous Provisions) Regulations 2018 (which came into force on 8th May 2018)