I am a Virginia Licensed Home Inspector and an NRPP-certified radon measurement professional. My comments are specifically directed toward short-term radon testing, which is commonly performed during real estate transactions and frequently marketed to homeowners as a means of assessing radon risk. The majority of radon tests I perform are associated with real estate transactions, providing me direct experience with how consumers use and interpret short-term radon testing.

The primary concern with radon is long-term exposure. Radon levels naturally fluctuate from day to day and season to season, often increasing during colder months when homes are closed and stack-effect pressures are greater. A 48-hour test provides only a snapshot of conditions and cannot determine a home's true long-term average radon level.

Ironically, many of the lowest-cost radon testing options available to consumers provide more useful information than the most commonly performed professional test. A long-term monitor costing a fraction of a professionally administered 48-hour test can provide a better picture of a home's actual radon exposure because it captures seasonal and day-to-day fluctuations that short-term testing cannot. The Virginia Department of Health also provides free radon test kits to consumers, further increasing access to testing without the need for additional regulatory burdens.

In my opinion, additional licensing requirements for radon measurement professionals will have minimal, if any, impact on consumer protection. The limitations of short-term testing are inherent to the testing method and cannot be addressed through additional licensure.

At the same time, the economics of professional radon testing are becoming increasingly challenging. I am seeing more requests to subcontract testing from professionals who have chosen not to renew their certifications because the service is difficult to offer profitably after accounting for equipment costs, calibration requirements, continuing education, insurance, certification fees, and administrative overhead. Additional state licensing requirements would further increase costs, likely reducing the number of professionals offering testing services while increasing costs to consumers.

The Commonwealth should also consider that consumers already have access to inexpensive long-term monitoring devices and free test kits through the Virginia Department of Health. Increasing the regulatory burden on professional testing services is unlikely to meaningfully improve consumer protection when lower-cost testing options are already widely available.

In my opinion, the most effective consumer protection measures are education and improved building practices. Radon-resistant construction techniques, including passive radon systems, should be encouraged or required in all new homes, not just those located in areas identified as high-risk on EPA radon maps. Elevated radon levels are routinely found outside those mapped areas, including homes built on the Yorktown Formation and homes constructed with imported fill materials.

If additional oversight is deemed necessary, I encourage the Commonwealth to focus on public education, enforcement of existing requirements, and radon-resistant construction practices rather than creating additional regulatory burdens for professionals who are already certified through nationally recognized programs.