Dealing with radon emissions

in respect of new development

Summary report and recommended framework for planning
guidance
 BRITISH GEOLOGICAL SURVEY

RESEARCH REPORT RR/00/07

Dealing with radon emissions in

This study was commissioned by
the Department of the
respect of new development
Environment, Transport and the
Regions (Contract No. MP0621),
but the views expressed in it are
not necessarily those of the
Department Summary report and recommended framework for
planning guidance
Geographical index
England and Wales

Subject index
Radon, land-use planning, J D Appleton
development, building control,
health and safety, environmental British Geological Survey
health.
J C H Miles
ISBN 0 85272 365 2 National Radiological Protection Board
C R Scivyer
Cover illustration
Recommended radon planning
Building Research Establishment
constraints map of England and P H Smith
Wales (derived from Maps 1
and 2, BR211 (1999). Land Use Consultants

Bibliographic reference
APPLETON, J D, M ILES, J C H,
SCIVYER, C R, and SMITH, PH.
2000. Dealing with radon
emissions in respect of new
development. Summary report
and recommended framework for
planning guidance. British
Geological Survey Research
Report, RR/00/7. 26pp

Crown Copyright 2000

Copyright in the typographical
arrangement and design vests in
the Crown.

Published for the Department of

the Environment, Transport and
the Regions under licence from
the Controller of Her Majesty's
Stationery Office

Applications for reproduction

should be made in writing to The
Copyright Unit, Office of Public
Services, Her Majesty's
Stationery Office, St. Clements
House, 116 Colegate, Norwich
NR3 1BQ Keyworth, Nottingham British Geological Survey 2000
BRITISH GEOLOGICALSURVEY ACKNOWLEDGMENTS

The full range of Survey publications is available from the BGS The authors are grateful to Dr David Brook (Chairman of the
Sales Desk at the Survey headquarters, Keyworth, Nottingham. Steering Group), Dr Brian Marker, Ms Moira Johnson, Ms Melissa
The more popular maps and books may be purchased from BGS- Thomas (Nominated Officers) and Mr Brian Freeland of the
approved stockists and agents and over the counter at the DETR, to all other members of the Steering Group (listed below),
Bookshop, Gallery 37, Natural History Museum (Earth Galleries), and to Local Planning Authorities personnel who assisted in the
Cromwell Road, London. Sales desks are also located at the BGS study as well as to colleagues at the British Geological Survey
London Information Office, and at Murchison House, Edinburgh. (Tony Myers, John Stevenson, Niall Spencer, David Talbot) and
The London Information Office maintains a reference collection of LUC (Jon Grantham).
BGS publications including maps for consultation. Some BGS
books and reports may also be obtained from the Stationery Office
Publications Centre or from the Stationery Office bookshops and DETR Steering Group
agents.
Mr F J Atkins (NHBC)
The Survey publishes an annual catalogue of maps, which lists Dr A J Burke (BRD-DETR)
published material and contains index maps for several of the BGS Mr T J Gregory (Cornwall County Council/Association of County
series. Councils)
Mr J T Hague (Local Government Associations)
Mr G A Hudd (Somerset County Council)
The British Geological Survey carries out the geological survey of Mr M Johnson (BRD-DETR)
Great Britain and Northern Ireland (the latter as an agency service Mr M Jones (Association of District Councils)
for the government of Northern Ireland), and of the surrounding Dr A J Macpherson (RAS-DETR)
continental shelf, as well as its basic research projects. It also Dr H J Prosser (Welsh Assembly)
undertakes programmes of British technical aid in geology in Mr B W T Spiers (Scottish Executive)
developing countries as arranged by the Department for Prof. I Thornton (Centre for Environmental Technology, Imperial
International Development and other agencies. College of Science, Technology and Medicine)
Mr D W Tuffin (The Royal Institution of Chartered Surveyors)
The British Geological Survey is a component body of the Natural Mr P Watson (County Planning Officer's Society)
Environment Research Council. Mr P Watts (The Royal Town Planning Institute)

British Geological Survey Offices

Keyworth, Nottingham NG12 5GG

0115936 3100 Fax 0115936 3200
e-mail: sales @bgs.ac.uk
www.bgs.ac.uk

Murchison House, West Mains Road, Edinburgh EH9 3LA

0131 667 1000 Fax 0131 668 2683

London Information Office at the Natural History Museum (Earth

Galleries), Exhibition Road, South Kensington, London SW7 2DE
0207589 4090 Fax 0207584 8270
0207942 5344/45

Forde House, Park Five Business Centre, Harrier Way, Sowton,

Exeter, Devon EX2 7HU
01392 445271 Fax 01392 445371

Geological Survey of Northern Ireland, 20 College Gardens,

Belfast BT9 6BS
01232 666595 Fax 01232 662835

Maclean Building, Crowmarsh Gifford, Wallingford,

Oxfordshire OX10 8BB
01491 838800 Fax 01491 692345

Parent Body

Natural Environment Research Council

Polaris House, North Star Avenue, Swindon, Wiltshire SN2 1EU
01793 411500 Fax 01793 411501
Executive summary

INTRODUCTION

In the early 1990s, administrative and policy responses to radon problems in new development had limitations in that:

new development was not adequately covered by existing responses in radon-prone areas which had not been
designated as radon Affected Areas.
the mapping procedures used to identify those areas where protective measures were required in new dwellings in
some cases resulted in radon protection not being installed where required, and vice versa.
material change of use or non-domestic development, including workplaces and certain residential institutions, was not
adequately dealt with.
procedures were not in place to ensure that developers were made aware of requirements for protective measures in
new dwellings or of employersresponsibilities with regard to radon under the Health and Safety at Work etc. Act 1974
and Ionising Radiations Regulations 1985 at the planning or pre-planning stage.
developers and future occupiers of buildings subject to material change of use (for example from agricultural or
workplace to domestic use (e.g. barn conversions)) but not subject to Requirement C2 of Schedule 1 of Building
Regulations 1991 were not necessarily made aware of the possible need for protective or remedial measures.

These limitations have been addressed by the Department of the Environment, Transport and the Regions (DETR) research
programme Dealing with radon emissions in respect of new developmentwhich aimed to identify the circumstances, if any,
where new development may be adversely affected by radon emissions and the appropriate response to such problems.
Fulfilment of these objectives will help to ensure that occupiers of new domestic and non-domestic developments will be ade-
quately protected against the harmful affects of radon. The research programme was carried out by the British Geological
Survey (BGS) working in collaboration with the Building Research Establishment Ltd. (BRE), Land Use Consultants (LUC)
and the National Radiological Protection Board (NRPB)

This report describes administrative responsibilities and policy responses; summarises how radon in new development is
dealt with through the building control system; describes a potential planning response that may deal with some of the
perceived limitations in the current response through building control; and provides a recommended framework for
guidance for building control, planning and environmental health.

ADMINISTRATIVE RESPONSIBILITIES AND POLICY RESPONSES

England and Wales

Responsibility for dealing with the radon issue is shared by the Department of the Environment, Transport and the Regions
(DETR), the Health and Safety Commission (HSC), and the NRPB (which is sponsored by the Department of Health). The
National Assembly of Wales has responsibility for radon policy for existing dwellings in Wales. BRE provides technical
guidance on protective and remedial measures. Local Authority building control officers and Approved Inspectors enforce reg-
ulations and guidance for dealing with radon in new development through the Building Regulations. The Health and Safety
Commission is responsible for defining standards, through the Ionising Radiations Regulations 1999 and any future legisla-
tion, that need to apply in workplaces. The Commission is also responsible for issuing guidance and enforcing the regulations.
This is done through the Health and Safety Executive (HSE) and Local Authority Environmental Health Departments. The
BGS researches the geological controls on radon.

Responses in other countries

Eight other European countries (Czech Republic, Denmark, Finland, Ireland, Latvia, Norway, Slovak Republic and Sweden)
have regulations and guidelines for construction requirements to prevent elevated radon concentrations in new buildings.
Austria, Germany, Greece and Switzerland plan to introduce such regulations. In most of the countries with regulations,
enforced radon protection in new buildings is specified in the national Building Codes. Implementation of regulations is
normally shared by National and Local authorities. Seven European countries (Czech Republic, Denmark, Finland, Ireland,
Norway, Slovak Republic and Sweden) have regulations and guidelines for radon prevention in the planning stages of new

v
development (e.g. where construction permits are applied for dwellings, offices and factories). Austria and Germany are con-
sidering the introduction of guidance and/or regulations for dealing with radon at the planning stage. In the Czech Republic,
Ireland, Slovak Republic and Sweden, regulations require an investigation of radon risk at construction sites before building
is permitted.

In Canada, radon is considered to be a minor regional problem and is dealt with at the construction stage as part of local
building codes. In the USA, the indoor radon strategy is implemented by the US Environmental Protection Agency (EPA) and
involves national and regional surveys, health studies, geological mapping and characterisation studies, land evaluation activ-
ities, mitigation and prevention activities, and issuing health guidelines. There are no federal requirements for the construc-
tion of new buildings in the USA. Each local authority area has its own version of the Building Code in which radon is treated
like any other building problem. Most of the US does not have mandatory regulations or guidelines.

BUILDING CONTROL AND BUILDING REGULATIONS

New dwellings
Statutory requirements relating to radon are contained in Requirement C2 of Schedule 1 of the Building Regulations 1991 for
England and Wales which states: Precautions shall be taken to avoid danger to health and safety caused by substances found
on or in the ground to be covered by the building. The Approved Document refers to BRE Report, BR211, Radon: Guidance
on protective measures for new dwellings, for detailed guidance on where such protection is necessary and practical con-
struction details. The guidance in the Approved Document is limited to new dwellings and extensions but the requirement
applies to all buildings.

Identification of development sites where radon protection required in new dwellings

Potential options for targeting radon protective measures in new dwellings and extensions to dwellings through the Building
Control system include:

BC-1: Universal application of radon protective measures.

BC-2: Mapping defines need for protective measures.
BC-3: Mapping defines need for protective measures. Site investigation may be used to permit relaxation of regulation if
the developer wishes to use this option.
BC-4: Universal site investigation defines the need for protective measures.

Whereas it might be considered that Option BC-1 would involve unnecessary expenditure in much of England and Wales,
blanket installation of a radon barrier would actually involve minimal additional cost to new dwellings (about 50100) and
would result in benefits to the development other than radon protection. Although cost is a consideration in the assessment of
regulatory proposals, it is not the deciding factor.

Options BC-2 and BC-3 both require maps that can be readily used by Building control bodies, developers and others concerned
with radon protective measures. Recommendations for the production of a radon potential map for use by building control and
planning systems evolved out of a study of the relative advantages and disadvantages of using grid square radon potential
mapping and geological radon potential mapping to designate areas where radon protective measures are required. It was
concluded that geological radon potential mapping in general provides the best spatial detail and accuracy as this method relates
radon risk to geology identified as the most important overall control on the concentration of radon in dwellings. A geolog-
ical radon potential mapping exercise for England and Wales was carried out as part of this research programme using the BGS
1:250 000 scale lithostratigraphic (bed rock) and the 1:625 000 scale drift digital map data. Combinations of bed-rock and drift
(unconsolidated deposits) with geological radon potentials considered to require protection were mapped and converted into a
5 km grid map for publication in the revised version of BR211 (1999). The 5 km grid maps were upgraded to take into con-
sideration more detailed 1:50 000 scale maps covering some of the most radon-prone areas of England.

The results of this research programme indicate that in most cases it is impractical to assess the severity of a radon problem
on a particular site accurately until the building has been constructed and occupied, therefore precautions should be taken in
areas where high radon levels have been predicted by the mapping programme. Radon site investigation techniques are not
yet reliable or cost-effective enough to be incorporated into guidance.

A requirement for a radon site investigation to be carried out on all new development sites (Option BC-4), as is currently
required in Sweden, for example, would lead to unnecessary expenditure for both developers and Building Control authorities.

vi
Revised Guidance (BR211, 1999)
Amendments to the guidance document (BR211) published in November 1999 reflect greater knowledge of radon-prone areas
and the advances made in developing practical cost-effective protective measures. The DETR Building Regulations Division
devised a system for determining the level of protection needed based on two sets of maps that show, as 5 km grid squares of
the National Grid used by the Ordnance Survey, where radon protective measures are indicated and whether a geological
assessment might allow a lower level of protection.

Radon protection in new workplace buildings

Although there is a gap within guidance to support the Building Regulations regarding radon protection for workplace buildings,
there are a number of reasons that make it difficult to develop similar guidance to that developed for dwellings:

there is a far wider variation in construction types used, as well as in the size and use of buildings than with dwellings,
which make it difficult to offer precise guidance.
identification of those areas where protective measures in new workplaces should be installed would be difficult using
grid square or geological radon potential mapping.

A prudent developer, especially in an area where radon emissions are high, should consider the possibility that radon levels
inside the building may be high enough to require protective measures and to provide them at initial construction. This is par-
ticularly important for new multi-purpose work place developments.

RADON AND THE PLANNING SYSTEM

Radon as a material planning consideration

Since radon emissions in new development can pose a risk to peoples health, they may be a material planning consideration.
It follows, therefore, that local planning authorities should have regard where necessary to the issue of radon emissions in
preparing development plans and deciding on planning applications, the aim being to ensure that radon protective or remedial
measures are incorporated, where appropriate.

Potential Planning Response

Radon is not mentioned in current planning legislation or planning policy guidance issued by the Government. None of the
planning authorities in areas with high radon that have adopted or approved development plans has a policy relating to radon.
There are no circumstances where the problem of radon emissions in new development cannot be overcome through appro-
priate protective or remedial measures. It would therefore be inappropriate for planning permission to be refused solely
because of the presence of potentially harmful radon concentrations.

Response to planning consultation

Consultation with representatives of the planning profession regarding the potential role of the planning system in dealing with
radon in new development identified the following main issues:

(i) Most planners consulted agree that whereas the planning system should address the problem of radon emissions in
new development, the role of the planning system should be confined to the provision of information about the
problem and how it can be overcome.
(ii) Maps in BR211 (1999) could be used to produce planning constraints maps. These would indicate those areas
where informatives need to be attached to planning decision notices for new development and changes of use.
(iii) The planning system should not be used as a means of ensuring that the appropriate Building Regulations and Health
and Safety Legislation are effectively enforced. A simple informative attached to planning permissions would meet
any perceived duty of local authorities to inform of potential hazards in those cases where it isnt covered by current
legislation and would do no harm in cases which are covered.

RECOMMENDED FRAMEWORK FOR GUIDANCE

Introduction
There are four main categories of new development or changes to use of land in radon-prone areas which may result in
people being exposed to radon emissions. These are:

vii
Category 1 new dwellings or extensions to dwellings; material alteration to dwellings or conversion to domestic use;
Category 2 new workplaces or residential institutions or material changes to workplace use;
Category 3 change from workplace to domestic use not involving material alteration/conversion;
Category 4 change from domestic to workplace or non-domestic residential use not involving material alteration or
conversion.

The following recommendations provide a framework for dealing with radon in these categories of new development through
Planning, Building Control, Health & Safety and Environmental Health systems.

Planning
The role of the planning system should be confined to the provision of information about the problem of radon emissions in
new development and how it can be overcome (i.e. through the application of relevant Building Regulations and Health and
Safety Legislation and the provision of information about relevant guidance). The information should be contained in develop-
ment plans and in decision letters about individual planning applications.

It is recommended that the radon issue should be addressed as part of the current revision of PPG 23 on Planning and Pollution
Control (Contaminated Land) and the Technical Advice Note (TAN) on Planning, Pollution Control and Waste Management
in Wales.

A system based on planning informatives may be the most practical option for ensuring that radon protection is adequately
dealt with in cases of material change of use (such as barn conversions) or non-domestic development, including workplaces
and certain residential institutions.

This potential planning response appears to deal effectively with the last three of the limitations of current responses (see
Introduction above).

Building Control
Statutory requirements relating to radon are contained in Requirement C2 of Schedule 1 of the Building Regulations 1991 for
England and Wales. BRE Report, BR211, Radon: Guidance on protective measures for new dwellings, provides detailed
guidance on where such protection is necessary and practical construction details. The guidance in the Approved Document
is limited to new dwellings and extensions but the requirement applies to all buildings. Whereas buildings other than dwellings
are subject to Requirement C2 of the Building Regulations, this could be made clearer if a paragraph on non-domestic building
was added to the Approved Document to Part C. Additional guidance is available for workplaces (BR293) and for remedial
measures in existing dwellings (BR227 and BR250).

The maps and plates in BR211 (1999) provide information on the location of those areas where radon protective measures are
required in new dwellings and extensions to dwellings (Category 1 above). These maps could also be used to indicate where
it may be advisable to install protective measures in Category 2 developments and where it may be advisable to monitor for
radon in Category 3 and 4 developments, in order to verify whether remedial measures are required.

Health & Safety and Environmental Health

Regulations and guidance designed to protect the health and safety of employees and others who have access to workplaces
are enforced by the HSE and Local Authority Environmental Health Departments (LAEHD). Employers occupying Category
2 and 4 developments in radon-prone areas for the first time would be responsible for carrying out a suitable and sufficient
radon risk assessment.

Scotland and Northern Ireland

Whereas this report is directed towards dealing with radon emissions in new development in England and Wales, many aspects
of the framework for guidance would also be applicable, in principle, to new development in Scotland and Northern Ireland.

viii
Contents

1 Introduction 1

2 Administrative responsibilities and policy response 3

England and Wales 3
Responses in other European countries 4
Introduction 4
Czech Republic 4
Sweden, Norway and Finland 4
Switzerland 5
Responses in Non-European countries 5
Canada 5
USA 5
Further background information 5

3 Building control and building regulations 6

Introduction 6
Building Control and Building Regulations: new dwellings 6
Identification of development sites where radon protection might be required in new dwellings 7
Revised Guidance (BR211, 1999) 8
Radon protection in new workplace buildings 15
Current responses 15
Options for dealing with radon in new workplaces 15
Other types of new development, material alteration and material change of use 16

4 Radon and the planning system 17

Radon as a material planning consideration 17
Potential Planning Response 17
The Role of Planning Policy Guidance 17
The Role of Development Plans 18
The Role of Development Control 18
Alternative Approach Using Planning Conditions 18
Response to consultation with the planning professionals 20
Radon as a material planning consideration 20
Role of Planning Policy Guidance 20
Role of development plans 20
Role of development control 21
Conclusions and recommendations 21

5 Recommended framework for guidance 23

Introduction 23
Planning 23
Building Control 23
Health & Safety and Environmental Health 24
Scotland and Northern Ireland 24

Appendix I Background information on radon 25

Appendix II Planning consultees 25
Appendix III References 26

ix
FIGURES

1 Map 1 (BR211, 1999) showing 5 km grid squares in England and Wales where basic (light brown) and full (dark brown)
radon protection should be provided in new dwellings 10
2 Map 2 (BR211, 1999) showing 5 km grid squares in England and Wales where a geological assessment should be
carried out. Shaded squares underlain, completely or in part, by geological units which require basic (light shaded) or
full (dark shaded) radon protection to be provided in new dwellings 11
3 Plate 7 (BR211, 1999) showing 5 km grid squares in the East Midlands where basic (light brown) and full (dark brown)
radon protection should be provided in new dwellings 12
4 Plate 18 (BR211, 1999) showing 5 km grid squares in the East Midlands where a geological assessment should be
carried out. Shaded squares underlain, completely or in part, by geological units which require basic (light shaded) or
full (dark shaded) radon protection to be provided in new dwellings 13
5 Flow chart indicating how to use the maps in Annexes A and B (BR211) to decide what level of protection is necessary
in a new dwelling 14
6 Planning procedures for dealing with radon emissions in new development 19

TABLE

1 Radon protective measures which should be provided in new dwellings, depending on the shading found in grid squares
on maps in Annexes A and B of BR211
(1999) 15

x
1 Introduction

1.1 Radon is a naturally occurring radioactive gas. It decays to form radioactive particles that can enter the body by inhala-
tion. Inhalation of the short-lived decay products of radon has been linked to an increase in the risk of developing
cancers of the respiratory tract, especially of the lungs, and is considered to cause approximately 5% of deaths from
lung cancer in the UK. In order to limit the risk to individuals, the Government has adopted an Action Level for radon
in dwellings of 200 becquerels per cubic metre (Bq m-3). The Government advises householders that, where the radon
level exceeds the Action Level, measures should be taken to reduce the concentration.

1.2 Radon gas comes from uranium that occurs naturally in the ground. The production of radon from rock and overbur-
den, including glacial and fluvial deposits and soil, is affected primarily by the amount of uranium within the rock-
forming minerals and their weathering products. The variation in radon levels between different parts of the country is
mainly controlled by the underlying geology. Most radon remains in rocks and soils. However, once released from
minerals, it can migrate through bedrock and soils and accumulate in buildings.

1.3 Radon enters a building primarily by airflow from the underlying ground. The key routes by which radon enters
buildings are through cracks in solid floors or walls below ground level, through construction joints and cavities in
walls, or through gaps in suspended concrete or timber floors or gaps around service pipes. In addition, the heating and
ventilation systems, and life style of the house occupants are important factors affecting radon accumulation in
buildings.

1.4 In radon affected homes, the problem of radon can usually be tackled with simple, effective and relatively inexpensive
measures, which are comparable in cost to work such as damp-proofing and timber treatment. The cost of installing
radon protective measures in new dwellings is relatively low (50150 per dwelling) in comparison with the direct and
indirect costs associated with treating lung cancer.

1.5 In the early 1990s, administrative and policy responses to radon problems in new development had limitations in that:

new development was not adequately covered by existing responses in radon-prone areas which had not been
designated as radon Affected Areas.
the mapping procedures used to identify those areas where protective measures were required in new dwellings
in some cases resulted in radon protection not being installed where required, and vice versa.
they did not adequately cover material change of use or non-domestic development, including workplaces and
certain residential institutions
procedures were not in place to ensure that developers were made aware of requirements for protective measures
in new dwellings or of employersresponsibilities with regard to radon under the Health and Safety at Work
etc. Act 1974 and Ionising Radiations Regulations 1985 at the planning or pre-planning stage
developers and future occupiers of buildings subject to material change of use (for example from agricultural or
workplace to domestic use (e.g. barn conversions)) but not subject to Requirement C2 of Schedule 1 of
Building Regulations 1991 were not necessarily made aware of the possible need for protective or remedial
measures.

1.6 These limitations have been addressed by the Department of the Environment, Transport and the Regions (DETR)
research programme Dealing with radon emissions in respect of new development which aimed to identify the cir-
cumstances, if any, where new development may be adversely affected by radon emissions and the appropriate
response to such problems.

The objectives of the research were:

a) to identify the circumstances where new development or changes to land use may result in people being
exposed to radon emissions which are prejudicial to health or are above the Action Level;
b) to consider what information is required to enable such radon risks to be assessed and precautions to be targeted
more effectively and how this should be collected, collated and presented;

1
 c) to examine what options, including preventive and remedial measures, are available to prevent adverse
accumulations of radon within new development; and
d) to present results in forms suitable for both specialists and non-specialists in issues associated with radon.

1.7 Fulfilment of these objectives will help to ensure that occupiers of new domestic and non-domestic developments will
be adequately protected against the harmful affects of radon.

1.8 The research programme, carried out by the British Geological Survey (BGS) working in collaboration with the
Building Research Establishment Ltd. (BRE), Land Use Consultants (LUC) and the National Radiological Protection
Board (NRPB), started in December 1995. The consultation exercise and subsequent revision of the Guidance
Document BR211 Radon: guidance on protective measures in new dwellings delayed execution of the project. This
process extended the research programme from February 1997 until publication of the revised guidance in November
1999.

1.9 The purpose of this report is to explain the background to dealing with radon in new development; highlight where
improvements to the responses could be made; identify the available options for dealing with radon in new develop-
ment including their relative advantages and disadvantages; identify the potential role of the planning system; and
finally to present conclusions and recommendations on which option(s) would be most appropriate and effective for
ensuring that new development is protected against radon emissions.

1.10 The report has a further four sections following this introduction:

Section 2 describes administrative responsibilities and policy responses.

Section 3 summarises how radon in new development is dealt with through the building control system.
Section 4 describes a potential planning response that may deal with some of the perceived limitations in the current
response through building control.
Section 5 provides a recommended framework for guidance for building control, planning and environmental health.

2
2 Administrative responsibilities and policy responses

England and Wales

2.1 Responsibility for dealing with the radon issue is shared by the Department of the Environment, Transport and the
Regions (DETR), the Health and Safety Commission (HSC), and the NRPB (which is sponsored by the Department of
Health). The National Assembly of Wales has responsibility for radon policy for existing dwellings in Wales.

2.2 The DETR Radioactive Substances Division is responsible for radon policy in England and the National Assembly for
Wales has responsibility for radon policy in Wales. The DETR Building Regulations Division is responsible for
Regulations and guidance relating to radon protection in new buildings in England and Wales. The NRPB advises,
researches, and provides technical services regarding protection against ionising and non-ionising radiations. To this
end it is currently monitoring radon in homes and workplaces and delineating Affected Areas. The NRPB has found
that the average level of radon in dwellings in Britain is about 20 Bq m-3. Based on the estimated risks of lung cancer
from prolonged exposure, the NRPB has recommended, and the Government has accepted, an Action Level for radon
in homes of 200 Bq m-3. If the annual average radon level in a home exceeds this value, householders are advised to
take action to reduce it.

2.3 The NRPB has recommended that parts of Britain with 1% probability or more of homes being above the Action Level
should be designated as Radon Affected Areas. These areas are designated by the NRPB by mapping levels of radon in
existing homes. Other areas, referred to in this report as radon-prone, are known to have the potential for radon
problems but they have not yet been designated as Radon Affected Areas. The BGS researches the geological controls
on radon and provides geological radon potential maps for the DETR for use in identifying with greater precision the
location of homes likely to be above the Action Level and to inform future radon measurement campaigns.

2.4 Provision has been made in Requirement C2 of Schedule 1 of the Building Regulations 1991 for the protection of new
buildings against the ingress of radon. BRE provides technical guidance on protective and remedial measures. Local
Authority building control officers and Approved Inspectors enforce regulations and guidance for dealing with radon
in new development through the Building Regulations.

2.5 The Health and Safety Commission is responsible for defining standards, through the Ionising Radiations Regulations
1999 and any future legislation, that need to apply in workplaces. The Commission is also responsible for issuing
guidance and enforcing the regulations. This is done through the Health and Safety Executive (HSE) and Local
Authority Environmental Health Departments.

2.6 Under the Health and Safety at Work etc. Act 1974 (HSW Act), employers must ensure the health and safety of
employees and others who have access to that working environment. Protection from exposure to radon at work is
specified in the Ionising Radiations Regulations 1999 made under the HSWAct. The concentration at which measures
should be taken in work places, based on the Ionising Radiations Regulations 1999 and the associated Approved Code
of Practice Part 3 Exposure to radon (HMSO, 1988), is 400 Bq m-3.

2.7 Radon is not mentioned in current planning legislation or planning policy guidance issued by the Government. None
of the planning authorities in areas with high radon which have adopted or approved development plans has a policy
relating to radon, although Cornwall and Derbyshire County Councils include information on the radon issue in their
draft structure plans.

2.8 On the basis of a preliminary consultation exercise with representatives of the planning profession carried out in
January 1996, it became evident that the principal reasons for the lack of coverage of radon in development plans were:

the issue is considered to be of relatively minor importance and can be dealt with inexpensively through
installation of protective measures under Building Regulations;
there are inadequate data upon which to base an enforceable policy (i.e. the level of risk varies significantly
between different parts of an authoritys area);
there is a danger of blightingland without justification.

3
 Responses in other European countries
Introduction
2.9 Eight other European countries (Czech Republic, Denmark, Finland, Ireland, Latvia, Norway, Slovak Republic and
Sweden) have regulations and guidelines for construction requirements to prevent elevated radon concentrations in new
buildings. Austria, Germany, Greece and Switzerland plan to introduce such regulations. In most of the countries with
regulations, enforced radon protection in new buildings is specified in the national Building Codes. Implementation of
regulations is normally shared by National and Local authorities (kerblom, 1999).

2.10 Seven European countries (Czech Republic, Denmark, Finland, Ireland, Norway, Slovak Republic and Sweden) have reg-
ulations and guidelines for radon prevention in the planning stages of new development (e.g. where construction permits
are applied for dwellings, offices and factories). Austria and Germany are considering the introduction of guidance and/or
regulations for dealing with radon at the planning stage. In the Czech Republic, Ireland, Slovak Republic and Sweden,
regulations require an investigation of radon risk at construction sites before building is permitted (kerblom, 1999).

Czech Republic
2.11 The radon programme in the Czech Republic is legislatively supported by the (i) Governmental Decree No. 538, (ii)
Law No. 18/1997 Coll., on Peaceful Utilisation of Nuclear Energy and Ionising Radiation and (iii) Regulation of the
SJB (State Office for Nuclear Safety) No. 184/1997 Coll., on Radiation Protection Requirements. Radon protective
measures must be implemented when a building is not located in a low radon risk area. All new development sites in
the Czech Republic require, under Building Regulations, a site investigation comprising a geological survey and mea-
surement of radon in soil gas (Barnet, 1994; Matoln, 1996). Radon concentrations in dwellings are generally propor-
tional to concentrations in soil gas (Neznal et al., 1994; Barnet and Miksov, 1999).

Sweden, Norway and Finland

2.12 The radon strategy in Sweden is similar in many respects to that developed in England and Wales. It is based on the mea-
surement of radon in existing dwellings in parallel with the requirement for installation of appropriate protective measures
in new dwellings. The Swedish Radiation Protection Institute (SSI) has overall responsibility for radon in dwellings
including measurement techniques and judgement of risks. The National Board of Health and Welfare is responsible for
setting limitsfor existing houses and the National Housing Board sets limits for new houses (Snihs, 1992).

2.13 The Swedish Planning and Building Act (1987) requires every municipal authority to draw up plans for land utilisation
which include details of matters that may affect land owners (Planning and Building Act 1:3, 1:4). The scale of these
plans is usually 1:50 000 or more. Chapter 2 of the act states Built up areas shall be located on land which is suitable
with regards to the health of the residents. The chapter specifically mentions radon, requiring radon risk maps to be
included in municipal plans.

2.14 Radon risk mapping based on results from long term monitoring in dwellings has highlighted high and low risk areas. The
maps are used to determine whether radon protection is required in new buildings. Further to this, and in contrast to the
policy in England and Wales, the Swedish National Board of Housing, Building and Planning has adopted a ground classi-
fication based on geology, permeability and soil gas radon measurement. This procedure is used to achieve a greater
accuracy in predicting radon emissions expected on a particular construction site. Local building boards are responsible for
deciding which protective measures should be installed according to radon risk determined from site investigations. In
normal situations, when the concentration of radon in soil air is 10000 to 50 000 Bq m-3 the house has to have a radon pro-
tective construction whereas when the concentration is higher than 50 000 Bq m-3, a radon safe construction has to be used.
Below 10 000 Bq m-3 no radon protection is required although open penetrations to the ground below the house have to be
sealed. Abuilding licence is granted only when the local authority is satisfied that the risk for radon has been considered
and appropriate protective measures used to ensure that the radon level in the new house does not exceed 70 Bq m-3.

2.15 Whereas site investigations at the planning stage of construction work provide information of direct relevance to radon
protection requirements, they are relatively expensive. In addition, scientific analysis has shown that radon (and other
soil gas) measurements taken from boreholes may give inaccurate results. When the soil is disturbed by bore holes the
emanation rate is changed and strong lateral and vertical variations in soil properties means that there is a need for
many boreholes across the site in order to obtain an accurate estimate of soil gas radon concentrations (C. Samuelsson,
personal communication). Measurement of radon in the ground is carried out by municipal authorities and also by
private companies. The SSI is responsible for calibration of equipment (Snihs, 1992).

2.16 The Swedish Council for Building Research has prepared guidance on protecting new buildings. It should be noted,
however, that house construction in Sweden differs in many ways from that in England and Wales. Basement con-
struction and the use of mechanical heating and ventilation systems are more common in Sweden.

4
2.17 Whilst planning procedures in Sweden require soil gas investigation, planning approval is rarely (if ever) rejected due
to high risk from radon gas levels and gamma radiation. However, there appears to be an underlying policy to restrict
building in high-risk areas.

2.l8 In Sweden, the future owner is responsible for ensuring that radon in a building does not exceed 200 Bq m-3. Buildings
regulations for radon protection have the legal status of Functional Requirement and stipulate that the radon concen-
tration in a room where people stay longer than just temporarily shall not exceed 200 Bq m-3 (kerblom, 1999).

2.19 The Radiation Protection Institutes in Finland and Norway basically follow the same policy as in Sweden (Nordic
Radiation Protection Institutes, 1986).

Switzerland
2.20 In Switzerland, it is a legal requirement that houses with radon levels in excess of 1000 Bq m-3 must have remedial
action taken. As a consequence there is a need to ensure that new buildings incorporate protective measures. Research
is currently underway to develop appropriate guidance for protecting new buildings. At present radon is not considered
to be a planning issue.

Responses in Non-European countries

Canada
2.21 In Canada, much of the early development of the current radon policy responses was carried out principally to deal
with radon problems in and around uranium mining areas. Radon is now considered to be a minor regional problem
and is dealt with at the construction stage as part of local building codes. Guidance on protective measures for new
buildings is offered by the Canada Mortgage and Housing Corporation which advises developers to contact the
Department of Health and Welfare in Ottawa or local authority building control for advice on areas where radon pro-
tective measures should be installed.

USA
2.22 In the USA, the main objective of the Indoor Radon Abatement Act 1988 was to set a target for reducing indoor radon levels
down to background levels. The Act allows individual states and local authorities to run their own radon programmes.

2.23 The indoor radon strategy is implemented by the US Environmental Protection Agency (EPA) and involves national
and regional surveys, health studies, geological mapping and characterisation studies, land evaluation activities, miti-
gation and prevention activities, and issuing health guidelines1. Radon is recognised by policymakers, as one of the
countrys most serious environmental health issues. The EPA Map of Radon Zones assigns each of 3141 counties across
the US to one of three radon zones based on radon potential (USGS, 1992). The zones have predicted average indoor
screening level of >148 Bq m-3 (Zone 1), 74148 Bq m-3 (Zone 2) and <74 Bq m-3 (Zone 3). Five factors were used to
determine radon potential: indoor radon measurements, geology, aerial radioactivity, soil permeability and foundation
type. Additional booklets for each individual state are intended to be used by local authorities in developing local
protocols for dealing with radon.

2.24 There are no federal requirements for the construction of new buildings in the USA. There are, however, model stan-
dards of construction which each State and local authority can use and interpret locally to suit their particular circum-
stances. As a consequence each local authority area has its own version of the Building Code in which radon is treated
like any other building problem. The EPA has prepared a series of guidance papers featuring model standards and tech-
niques for the control of radon in new buildings (EPA, 1994). Few states have a co-ordinated new-build policy with
regard to radon and approaches can vary dramatically from State to State, between counties and even between districts
within counties. Some states, notably Florida and Washington States have drafted Model standards and techniques for
the control of radon in new buildings. Few areas carry out monitoring of completed houses, even where it forms a
requirement within the Building Code.

2.25 Whereas 3 of the 50 states, as well as 40 counties, cities and towns in the US have regulations mandated by law, most
of the US does not have mandatory regulations or guidelines (kerblom, 1999).

Further background information

2.26 Further background information on radon can be obtained from the publications listed in Appendix I.

1 Details available at http://www.epa.gov/iaq/radon/

5
3 Building control and building regulations

Introduction
3.1 Building control is separate from, but complementary to, the planning system. Its purpose is to ensure that, for certain
types of development where the Building Regulations apply, the detailed design of buildings will ensure that the
completed building provides a healthy and safe environment for people in and around it. The Government wishes to
ensure that building control, or any other form of regulation, does not duplicate the function of the planning system
(PPG1, para. 35) and vice versa.

Building Control and Building Regulations: new dwellings

3.2 The purpose of the Building Regulations 1991 is to secure the health and safety of people in and around buildings.
Building Regulations are mandatory, but cast in a functional form. They are supported by Approved Documents, which
are not mandatory but give guidance as to how the Building Regulations may be met.

3.3 Statutory requirements relating to radon are contained in Requirement C2 of Schedule 1 of the Building Regulations
1991 for England and Wales2 which states: Precautions shall be taken to avoid danger to health and safety caused by
substances found on or in the ground to be covered by the building. The Approved Document3 refers to BRE Report,
BR211, Radon: Guidance on protective measures for new dwellings, for detailed guidance on where such protection
is necessary and practical construction details. The guidance in the Approved Document is limited to new dwellings
and extensions but the requirement applies to all buildings.

3.4 In early editions of the guidance (BR211, 1991, as revised 1992) the results of radiological surveys of radon in existing
houses were used to identify those areas where precautionary measures were required4. These were listed by civil
parish but were based upon data supplied to BRE by the NRPB in the form of 5 km grid square radon potential maps
(Miles et al., 1990, 1992)5. Guidance in BR211 (1991, as revised 1992) advised that one of two levels of protective
measures should be incorporated, dependent upon the likely severity of the radon problem:

secondary measures (provision for future sub-floor extraction) based on NRPB reports showing areas where it
was estimated that 310% of existing dwellings exceed 200 Bq m-3;
full radon protection (installation of a radon barrier and a provision for future sub-floor extraction) based on
NRPB reports showing areas where it was estimated that >10% of existing dwellings have radon levels
exceeding 200 Bq m-3.

3.5 Clause 3 of BR211 (as revised 1992) stated: within the areas listed, any site on which there is little or no possibility
of an enhanced level of radon will obviously need no precautionary measures; for instance the subsoil may be such as
to prevent the passage of radon or may be permanently saturated.

3.6 Supplementary guidance on using geology to assess indoor radon risk in new dwellings was issued as an information
sheet in January 1996. It outlined how applicants seeking building approval within Derbyshire, Somerset and
Northamptonshire could use geological data to demonstrate the application of Clause 3. It relied upon the applicant
providing the Building Regulations approving body with the results of a site assessment comprising: desk study,
ground investigation; and an assessment of risk.

3.7 Complementary supplementary guidance could have been, but was not, adopted for providing protective measures in
additional geologically defined radon-prone areas that were not included within the scope of BR211 (as revised 1992).

2 Department of the Environment and the Welsh Office. The Building Regulations 1991. Statutory Instrument 1991 No 2768.
London, HMSO, 1991.
3 Department of the Environment and the Welsh Office. Building Regulations (England and Wales) 1991, Approved Document
C, Site preparation and resistance to moisture, London, HMSO (1992 edition, amended.)
4 Figures 3(a), (b) and (c), Amendments to BR211 (December 1992)
5 Radon potential maps indicate the variation in probability that existing dwellings will exceed a radon reference level, which in
the UK is the Action Level (200Bq m -3). Grid square radon potential maps, of the type produced by the NRPB, are based on
the measurement of radon concentrations in existing dwellings.

6
3.8 BR211 (as revised 1992) only applied to the five counties of England and Wales that were declared radon Affected
Areas in 1991. The more recently published BGS 1:625 000 scale map of radon potential based on solid geology for
the whole of Great Britain (Appleton and Ball, 1995) and 1:250 000 scale maps of selected areas, together with the
NRPB 5 km grid square maps of indoor radon in England and Wales (Lomas et al., 1996, 1998), indicate that elevated
radon levels are widely distributed in England and Wales, albeit in many cases confined to relatively small areas.

3.9 With this in mind there was a need to consider how the BR211 (as revised 1992) guidance might be revised to include
the new areas and what building control procedures would provide the most effective means of dealing with radon in
new development. There was clearly a need for guidance in the new areas.

Identification of development sites where radon protection might be required in new dwellings
3.10 Potential options for targeting radon protective measures in new dwellings and extensions to dwellings through the
Building Control system were identified:

BC-1 Universal application of radon protective measures.

BC-2 Mapping defines need for protective measures.
BC-3 Mapping defines need for protective measures. Site investigation may be used to permit relaxation of
regulation if the developer wishes to use this option.
BC-4 Universal site investigation defines the need for protective measures.

3.11 Whereas it might be considered that Option BC-1 would involve unnecessary expenditure in much of England and
Wales, blanket installation of a radon barrier would actually involve minimal additional cost to new dwellings (about
50100) and would result in benefits to the development other than radon protection. Indeed, it may be considered
good building practice, as it would provide enhanced protection against the entry of moisture and other types of gases
(such as carbon dioxide and methane) into the dwelling. The radon barrier may not, however, provide adequate pro-
tection in methane-prone areas, for example if there are aggressive ground conditions, a risk of excessive ground
movement or an extreme gassing regime (see BR212 Construction of new buildings on gas-contaminated land. BRE,
1991b). Universal application of radon protective measures would assist in securing the health of people in new
buildings and at the same time reduce the risk of blight and undue personal anxiety. It should be noted, however, that
although cost is a consideration in the assessment of regulatory proposals, it is not the deciding factor.

3.12 Options BC-2 and BC-3 both require maps that can be readily used by Building control bodies, developers and others
concerned with radon protective measures. Practical options currently available for identifying areas or sites where new
development requires protection include (a) NRPB grid square radon potential maps, (b) geological radon potential
maps, (c) a combination of NRPB grid square and geological radon potential maps and (d) site investigation. A detailed
evaluation was carried out of the relative advantages and disadvantages of using grid square radon potential mapping
and geological radon potential mapping6 to designate areas where radon protective measures are required.
Recommendations for the production of a radon potential map for use by building control and planning systems have
evolved from an evaluation of mapping options in areas with many house radon measurements (Derbyshire and
Northamptonshire) and also in selected areas with relatively few house radon measurements7. This demonstrated that
the maps in BR211 (as revised 1992) have limitations that could result in radon protection not being installed where
required and vice versa. It was concluded that geological radon potential mapping in general provides the best spatial
detail and accuracy as this method relates radon risk to geology identified as the most important overall control on
the concentration of radon in dwellings. A geological radon potential mapping exercise for England and Wales was
carried out as part of this research programme using the new BGS 1:250 000 scale lithostratigraphic (bed rock) and the
1:625 000 scale drift digital map data which became available in November 1998. Combinations of bed-rock and drift
(unconsolidated deposits) with geological radon potentials considered to require protection were mapped and converted
into a 5 km grid map for publication in the revised version of BR211. The new radon map (Annex B in BR211 (1999))
is similar in format to the Radon Atlas of England (Lomas et al., 1996), except that it shows those grid squares which
are underlain, completely or in part, by geological units which require protection.

3.13 More detailed geological radon potential data is available for twenty 1:50 000 scale geological map sheets covering the
most radon-prone parts of Derbyshire, Northamptonshire, Nottinghamshire, Leicestershire, Lincolnshire, Oxfordshire,

6 In the UK, geological radon potential indicates the probability that existing dwellings sited on a geological unit will exceed the
radon Action Level (200Bq m-3). The radon potential of any combination of bed-rock and drift (unconsolidated deposit) may
be determined by statistical analysis of radon measurements made in existing dwellings.
7 Evaluation of mapping and site investigation methods for targeting areas where new development requires installation of radon
protective measures. British Geological Survey Research Report (in preparation).

7
 Shropshire, Somerset and Yorkshire8,9. The main purpose of the 1:50 000 scale maps is to identify localised areas of
England where radon concentrations are most likely to have >5% probability of being above the Action Level and to
inform any future radon measurement campaigns. Whereas the maps help to identify those areas where radon protec-
tive measures are required in new dwellings, they should not be used as the basis for a Stage 2 Geological Assessment
(see BR 211 (BRE, 1999)). This is because the information on the 1:50 000 scale maps shows the average radon
potential for each geological unit whereas more detailed information may be used to generate the site specific Radon
Protective Measures (RPM) Site Reports10. The 5 km grid maps derived from the 1:250 000 scale geological radon
potential assessment were upgraded to take into consideration the results of the more detailed 1:50 000 scale maps.

3.14 Research has demonstrated that in the far south-west of England (Ordnance Survey 100-km grid squares SW and SX),
uranium mineralization can cut across mapped geological boundaries, and grouping house radon data by geological
unit may not be the best approach to mapping radon potential. In this area, the NRPB has produced a 1-km grid square
radon potential map for the detailed targeting of the requirement for protective measures in new dwellings (Miles and
Appleton, 2000).

3.15 In Option BC-3, which applied to the 1996 interim guidance for new dwellings, the developer had the option of
applying for relaxation of the requirement for measures based on the results of a geological site investigation (incor-
porating desk studies, ground investigations and soil gas radon measurements). The site investigation and report would
have needed to be executed by a suitably qualified geologist. The technical protocols for soil gas radon measurements
and assessment of results were not clearly defined in the interim guidance. Indeed, the reliability of radon site investi-
gations was uncertain at that time and was investigated further as part of the current research programme. The results
of this research programme11 indicate that in most cases it is impractical to assess the severity of a radon problem on
a particular site accurately until the building has been constructed and occupied, therefore precautions should be taken
in areas where high radon levels have been predicted by the mapping programme. Radon site investigation techniques
are not yet reliable enough to be incorporated into guidance. In the interim guidance, it was also noted that the use of
the site investigation option to obtain relaxation of requirement for measures is unlikely to be a cost-effective option
unless the development is for more than 1020 dwellings.

3.16 A requirement for a radon site investigation to be carried out on all new development sites (Option BC-4), as is
currently required in Sweden, for example, would lead to unnecessary expenditure for both developers and Building
Control authorities. This option was not considered further.

Revised Guidance (BR211, 1999)

3.17 Amendments to the guidance document (BR211) have evolved over two years following a DETR consultation
exercise12. The principal changes in BR211 reflect greater knowledge of radon-prone areas and the advances made in
developing practical cost-effective protective measures. In addition, the development of protective measures and the
monitoring of their effectiveness indicated that the general approach to radon protection should be reconsidered and
embody the findings of recent research.

3.18 In the revised BR211 (1999) it states that There are two main methods of achieving radon protection in new dwellings:
passive and active. The passive system involves providing a barrier to the radon. This can usually be achieved by increas-
ing the general airtightness of the damp-protection provided in floors and walls. The active system consists of providing
natural or mechanical underfloor ventilation, or a powered radon-extract system, as an integral part of the services of the
dwelling. The last two options will incur running and maintenance costs for the life of the building. Passive systems are
to be preferred in new houses, although they may need to be supplemented in some areas with provision for active pro-
tection. No guidance is currently supplied for suspended timber ground floors in dwellings. The DETR is sponsoring
research into the protection of this form of construction and will publish the results in due course.

8 Prepared by the BGS in collaboration with the NRPB for the Radioactive Substances Division of the DETR (Miles and
Appleton, 2000).
9 Mapping radon potential on the basis of house radon and geology requires that digitised geological maps are available. The
300 1:50000 scale map sheets covering England are being digitised under the BGS DIGIMAPprogramme, which is
scheduled to be complete in 2001. The 5km grid maps in Annex B (BR211) will be upgraded using the spatially more
accurate 1:50000 map data.
10 RPM site reports are available from: National Geological Records Centre, British Geological Survey, Keyworth,
Nottingham NG12 5GG (Tel: 0115 936 3109; Fax: 0115 936 3276; e-mail: ngrc@bgs.ac.uk). Further information and an
order form are available on the BGS web site http://www.bgs.ac.uk/radon and will also be available in the near future on
http.//www.british-geological-survey.co.uk/
11 Evaluation of mapping and site investigstion methods for targeting areas where new development requires installation of radon
protective measures. British Geological Survey Research Report (in preparation).
12 DoE Consultation Paper, March 1997: Proposed amendments to the Approved Document to Part C of the Building Regulations
and to Guidance Document BR211 Radon: guidance on protective measures for new dwellings.

8
3.19 In the Approved Document to Part C of the Building Regulations, it indicates that the precise areas where radon pro-
tective measures should be taken are reviewed by the DETR in the light of advice from the NRPB13. The NRPB Radon
Atlas of England (Lomas et al., 1996) and the Radon Atlas of Wales (Lomas et al., 1998) indicated that radon protec-
tion was required in more areas than those listed in BR211 (as revised 1992). The 1999 edition of BR211 was published
on 11 November 1999 to reflect this change and also the results of the current research project.

3.20 The DETR Building Regulations Division devised a system for determining the level of protection needed based on
two sets of maps that show, as 5km grid squares of the National Grid used by the Ordnance Survey, where protective
measures from radon will or may be needed. The areas shown on the maps will need to be revised as more informa-
tion becomes available and the maps will be amended accordingly. The 5 km grid squares can be easily cross refer-
enced to local area Ordnance Survey maps at scales that are used for building control and for planning purposes (e.g.
1:50 000, 1:25 000 or 1:10 000). The two map sets are quite different due to the way they have been prepared. The
NRPB maps (Annex A, BR211 (1999)) are based on a statistical analysis of radon measurements in existing houses and
show 5 km grid squares for which the estimated percentages of homes above the radon Action Level (AL; 200 Bq m-3)
exceed the threshold percentages designated for either basic (3% >AL) or full (10%>AL) radon protection (Figures 1
and 3). The BGS maps (Annex B, BR211 (1999)) are also based on a statistical analysis of radon measurements in
existing houses but indicate those grid squares which are underlain, completely or in part, by geological units for which
the estimated percentages of homes above the Action Level exceed the thresholds for either basic or full radon protec-
tion. The shading on the BGS maps (Figures 2 and 4) shows the highest geological radon potential found somewhere
within the grid square rather than the average for the grid square (shown on the NRPB maps). As a result there are
many more grid squares shown on the BGS maps (Annex B, BR211) than on the NRPB maps (Annex A, BR211).

3.21 If a site falls within one of the squares shaded on the Annex B (BGS) maps, it does not necessarily mean that it must
have radon protection. This is because some of the grid squares contain bed rocks and unconsolidated (drift) deposits
with lower radon potential than the maximum levels shown on the map. In many cases the geological radon potential
varies considerably within a grid square. In other cases, only a very small area (sometimes only a few hundred square
metres) with a radon potential exceeding the thresholds for basic or full protection occurs within the grid square but,
as the squares are coded according to the highest radon potential, the whole square has been shaded. The level of pro-
tection that might be required is thus site specific, and can be determined by reference to the relevant radon potential
map followed by a geological assessment of the site. In BR211 (1999) the two types of map are complementary, and
neither should be used in isolation.

3.22 There is a flow chart in the 1999 Edition of BR 211 that sets out a two-stage procedure to be followed when using the
maps in the guidance. It makes it clear when full protection should be installed, and when no protection is necessary
at all. It also indicates where, when no protection or the installation of basic protection is indicated by the NRPB maps,
the BGS maps should be consulted to establish if underprotection might be possible. In Stage 2 of the procedure it is
stipulated that a geological assessment should be carried out if the site is in a shaded square on Map 2 and Plates 12 to
22 in Annex B of BR211 (1999). A geological assessment involves checking whether a site is on or close to a geolog-
ical unit for which either basic or full radon protection is required. Radon Protective Measures (RPM) site reports are
generated by the BGS Radon Protective Measures Geographical Information System (RPM-GIS)14. The search area
(circle or rectangle) used for a site assessment is increased by a buffer zone of 50 m in areas with 1:50 000 scale data
and 500 m in areas with 1:250 000 scale data. This is to allow for potential inaccuracies in the position of the geolog-
ical radon potential boundaries. The geological assessment advisory report indicates the highest level of protection
required within the buffered search area. Consideration must be given to installing basic or full radon protection if the
geological assessment shows that this is required.

3.23 The two-stage procedure is illustrated in the flow chart in Figure 5 and Table 1.

3.24 There are sectors within some light and dark brown shaded 5 km grid squares shown on the maps in Annex A that are
underlain by geological units with radon potential lower than the 3% or 10% thresholds designated for the installation
of basic and full measures. In other cases, the developer may encounter geological evidence that could cast doubt on
the result of the RPM geological assessment. This evidence might be either from the BGS 1:10 000 scale geological
map15 or from geological site investigations, which would have to be carried out by a qualified geologist. In such
situations, builders or their professional advisers may be able to demonstrate that there is no significant danger to health
caused by radon in the ground covered by the buildings.

13 and the British Geological Survey. The maps in Annex B of BR211 (1999) were produced for the DETR by the BGS in collaboration with the
NRPB.
14 See footnote 10.
15 For a detailed follow-up geological radon potential assessment based on BGS 1:10000 scale geologicall data contact: Land Survey South Enquiry
Service, British Geological Survey, Keyworth, Nottingham NG12 5GG (Tel: 0115 936 3192; Fax: 0115 936 3192; e-mail: geohelp@bgs.ac.uk

9
 NT NU

NX HWRC_SDST

NY NZ

SD SE TA

CL_LMST

SH SJ SK TF TG

SM SN SO SP TL TM

SR SS ST SU TQ TR

SW SX SY SZ TV

Figure 1 Map 1 (BR211, 1999) showing 5 km grid squares in England and Wales where basic (light
brown) and full (dark brown) radon protection should be provided in new dwellings.
The administrative boundaries shown on this map are based upon the OS map by the DETR with the permission of
Ordnance Survey on behalf of The Controller of Her Majestys Stationery Office. Unauthorised reproduction infringes
Crown Copyright and may lead to prosecution or civil proceedings. Licence Number: GD272671. (Cartography by
BGS on behalf of the DETR; reproduced from BR211 (1999) with permission from the Copyright Unit, HMSO).

10
 NT NU

NX HWRC_SDST

NY NZ

SD SE TA

CL_LMST

SH SJ SK TF TG

SM SN SO SP TL TM

SR SS ST SU TQ TR

SW SX SY SZ TV

Figure 2 Map 2 (BR211, 1999) showing 5 km grid squares in England and Wales where a geological
assessment should be carried out. Shaded squares underlain, completely or in part, by geological units
which require basic (light shaded) or full (dark shaded) radon protection to be provided in new
dwellings.
The administrtive boundaries shown on this map are based upon the OS map by the DETR with the permission
of Ordnance Survey on behalf of The Controller of Her Majestys Stationery Office. Unauthorised reproduction
infringes Crown Copyright and may lead to prosecution or civil proceedings. Licence Number: GD272671.
(Mapping and cartography by BGS on behalf of the DETR; reproduced from BR211 (1999) with permission from
The Copyright Unit, HMSO).

11
 2 Huddersfield

Scunthorpe
1 Barnsley
Grimsby
Brigg
Doncaster
4
0
Rotherham
Gainsborough
9 Louth
Sheffield

8 Worksop

Buxton
Chesterfield
Lincoln
7 Bolsover

Mansfield
Matlock
6
Newark

SK
Ripley
5
Sleaford
Boston

Ilkeston Nottingham
4
Grantham
Derby

3
Burton Upon Trent
Spalding

2 Loughborough
Coalville

1 Lichfield Oakham

Leicester
Tamworth
3
0 Atherstone
Narborough March
Peterborough
Hinckley
Nuneaton
9
Birmingham

Solihull Coventry
8 Kettering

Rugby Thrapston

Huntingdon
7 Redditch Wellingborough
Royal Leamington Spa
Daventry
Northampton
6
Cambridge
Stratford upon Avon

5
SP Towcester
Bedford

Biggleswade

4 Banbury Milton Keynes

Letchworth
3
Stevenage

Luton
2
4 5
0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5

Figure 3 Plate 7 (BR211), 1999) showing 5 km grid squares in the East Midlands where basic (light
brown) and full (dark brown) radon protection should be provided in new dwellings.
The administrative boundaries shown on this map are based upon the OS map by the DETR with the permission of
Ordnance Survey on behalf of The Controller of Her Majestys Station Office. Unauthorised reproduction infringes
Crown Copyright and may lead to prosecution or civil proceedings. Licence Number: GD272671. (Cartography by
BGS on behalf of the DETR; reproduced from BR211 (1999) with permission from The Copyright Unit, HMSO).

12
 2 Huddersfield

Scunthorpe
1 Barnsley Grimsby
Brigg
Doncaster
4
0
Rotherham
Gainsborough
9 Sheffield Louth

8 Worksop

Buxton
Chesterfield
Lincoln
7 Bolsover

Mansfield
Matlock
6
Newark

SK
Ripley
5
Sleaford
Boston

Ilkeston Nottingham
4
Grantham
Derby

3
Burton Upon Trent
Spalding

2 Loughborough
Coalville

1 Lichfield Oakham

Leicester
Tamworth
3
0 Atherstone Narborough March
Peterborough
Hinckley
Nuneaton
9
Birmingham

Solihull Coventry
8 Kettering

Rugby Thrapston

Huntingdon
7 Redditch Wellingborough
Royal Leamington Spa
Daventry
Northampton
6
Cambridge
Stratford upon Avon

5
SP Towcester
Bedford

Biggleswade

4 Banbury Milton Keynes

Letchworth
3
Stevenage
Luton
2
4 5
0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5

Figure 4 Plate 18 (BR211, 1999) showing 5 km grid squares in the East Midlands where a geological
assessment should be carried out. Shaded areas underlain, completely or in part, by geological units
which require basic (light shaded) or full (dark shaded) radon protection to be provided in new
dwellings.
The administrative boundaries shown on this map area are based upon the OS map by the DETR with the
permission of Ordnance Survey on behalf of The Controller of Her Majestys Stationery Office. Unauthorised
reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. Licence Number:
GD272671. (Mapping and cartography by BGS on behalf of the DETR; reproduction from BR211 (1999) with
permission from The Copyright Unit, HMSO).

13
 First refer to the maps in Annex A

Is the dwelling being Yes Install full protection

built in a dark brown No need to refer to
square? Annex B

No

Is the dwelling being

No Yes
built in a light brown
square?

Install basic protection and refer

Refer to Annex B to see whether
to Annex B to see whether
geological data should be sought
geological data should be sought
to establish if basic or full
to establish if full protection should
protection should be considered
be considered

Now refer to the maps in Annex B

No Is the dwelling being Yes

built in a dark shaded
square?

No Is the dwelling being Yes Consideration should be given to

built in a lightly shaded geological data and whether full or
square? basic protection might be
necessary

No protection Consideration should be given to

is needed geological data and whether basic
protection might be necessary

Figure 5 Flow chart indicating how to use the maps in Annexes A and B (BR211) to decide what
level of protection is necessary in a new dwelling (reproduced from BR211 (1999) with permission from
The Copyright Unit, HMSO).

3.25 In both these situations, the developer would be well advised to consider whether prospective purchasers or occupiers
of the dwellings would consider the installation of radon protective measures a positive feature.

3.26 A different approach has been taken in Scotland where NRPB 5 km grid maps are used to identify areas where Stage
1 and Stage 2 protective measures should be incorporated16. Stage 1 and Stage 2 protective measures are equivalent,
respectively, to basic and full radon protection in England and Wales. Stage 1 protective measures are required in 5 km
grid squares for which the estimated percentages of homes above the radon Action Level (200 Bq m-3) is between 1 and
10%. No account is taken of geological radon potential.

16 BR376 Radon: guidance on protective measures for new dwellings in Scotland (BRE, 1996b)

14
Table 1 Radon protective
Shading of maps in Annex A
measures which should be
provided in new dwellings, White Light Brown Dark Brown
depending on the shading found
in grid squares on maps in White None Basic Full
Annexes A and B of BR211
(1999 edition)17. Light grey Basic, unless Basic Full
geological report18
Shading of maps in indicates None
Annex B
Dark grey Full, unless Full, unless Full
geological report geological report
indicates Basic or indicates Basic
None

Radon protection in new workplace buildings

Current responses
3.27 Under the Health and Safety at Work etc. Act 1974 (HSW Act) employers must ensure the health and safety of employees
and others who have access to that working environment. Protection from exposure to radon at work is specified in the
Ionising Radiations Regulations 1999 made under the HSWAct. These Regulations apply to workplaces where the level
of radon exceeds a defined threshold. For most practical purposes application of IRR99 occurs where the average radon
level, measured in the winter months when the levels are usually at their highest, exceeds 400 Bq m3.

3.28 Regulation 3 of the Management of Health and Safety at Work Regulations 1999 requires employers to carry out a
suitable and sufficient risk assessment to decide what control measures are needed under health and safety regulations.
An employer occupying a building as a workplace in a radon-affected area for the first time will need to take into
account the radon concentration in that risk assessment. Where the radon in air concentration in the building is above
the threshold level in the Ionising Radiation Regulations 1999 (namely 400 Bq m -3) regulation 7 of those Regulations
requires that the assessment is sufficient to identify the measures needed to restrict exposure of persons to ionising
radiation. As a consequence it might be considered prudent to include protective measures during construction in
radon-prone areas (BR211 (1999), Annexes A and B).

3.29 The technical guidance contained in BR211 (1999) may be of use to designers and builders of new structures whose form
of construction and compartmentation is similar to housing and where the heating and ventilation regime is similar to
that used in housing. This is likely to include small office buildings and primary schools. Interim guidance on protective
measures for new non-domestic buildings is included in BRE Report BR293 Radon in the Workplace (BRE, 1995) and
on remedial measures relevant to major alterations (such as barn conversions) in BRE Report BR267: Major alterations
and conversions (BRE, 1994a). These guidance documents offer advice on simple cost-effective measures that can be
incorporated during the construction of new buildings or when extending or converting existing buildings. This is seen
as interim advice to assist those developers and building owners who want to incorporate measures. The guidance is
based on scaled up protective measures of the type recommended for dwellings. The BRE is monitoring sites to assess
the effectiveness of the guidance in terms of practical application, minimising radon levels and cost.

3.30 Few local building control authorities actively require protective measures to be installed in new workplaces. Most
authorities advise inclusion where appropriate but do not make this a requirement for building regulation approval.
Building control conditions would have to be necessary; relevant to the development; enforceable and precise.

Options for dealing with radon in new workplaces

3.31 Although there is clearly a gap within guidance to support the Building Regulations regarding radon protection for
workplace buildings, there are a number of reasons that make it difficult to develop similar guidance to that developed
for dwellings:

there is a far wider variation in construction types used, as well as in the size and use of buildings than with
dwellings, which make it difficult to offer precise guidance.

17 Adapted from Environmental Radon Newsletter, Issue 23, p.1.

18 Geological radon protective measures (RPM) site reports are available from: National Geological Records Centre, British Geological Survey,
Keyworth, Nottingham NG12 5GG (Tel: 0115 936 3109; Fax: 0115 936 3276; e-mail: ngrc@bgs.ac.uk). Further information and an order
form are available on the BGS web site http://www.bgs.ac.uk/radon and will also be available in the near future on
http://www.british-geological-survey.co.uk/

15
 identification of those areas where protective measures in new workplaces should be installed would be
difficult using grid square or geological radon potential mapping. This is because the number of radon
measurements made in workplaces is very small and the range of workplace types very wide. In addition,
monitoring results, unlike those for dwellings where most results are held by the NRPB, are scattered between
suppliers of detectors so mapping in the same way as dwellings would be impractical.

3.32 It has been estimated that for a typical open plan factory or warehouse unit with a total floor area of approximately
4000 m2, the additional cost of installing radon protective measures would be in the region of 1500. This would
include the cost of improved sealing of existing damp-proof membranes and provision of eight sumps and manifolded
pipework for subsequent connection to extractor fans. This solution in itself will considerably reduce the likelihood of
elevated indoor radon levels. However should this prove inadequate and remediation is required, the cost of later instal-
lation of two fans is estimated to be approximately 500, giving an overall installation cost of 2000. These costings
should be considered as being illustrative.

3.33 The alternative solution would be to install remedial measures as necessary later. It is difficult to put a cost to this, as
with a building of this size, remediation would almost certainly be carried out in several stages targeted at the worst
affected part of the building first. However, if it is assumed that a similar coverage in terms of subfloor depressurisation
is required as the previous example (i.e. eight sumps) and that minimal internal disruption is required, then there would
be a need for at least eight separate mini sump systems each fitted with a fan costing approximately 750 per system
to install - giving an overall installation cost of 6000.

3.34 A prudent developer, especially in an area where emissions are high, should consider the possibility that radon levels
inside the building may be high enough to require protective measures and to provide them at initial construction. This
is particularly important for new multi-purpose work place developments. See also para. 4.39 below.

Other types of new development, material alteration and material change of use
3.35 Procedures for dealing with radon protection where there is material alteration or material change of use through the
use of planning informatives are outlined in para. 4.14 and Figure 6 of this document. Building Control authorities
could adopt a similar system. However, this would have the disadvantage that developers would not become aware of
potential radon problems at the pre-planning and planning stage. Because of this, they may incur financial penalties, if
for example, buildings had to be re-designed to incorporate protective or remedial measures. Alternatively, Regulation
6 (Material Change of Use) of the Building Regulations could be changed to address these deficiencies.

3.36 For these reasons, a system based on planning informatives may be the most practical option for ensuring that radon
protection is adequately dealt with in cases of material change of use (such as barn conversions) or non-domestic devel-
opment, including workplaces and certain residential institutions. Other types of building are subject to Requirement
C2 of the Building Regulations but this could be made clearer if a paragraph on non-domestic building was added to
the Approved Document to Part C.

16
4 Radon and the planning system

Radon as a material planning consideration

4.1 The purpose of the planning system is to regulate the use and development of land in the public interest. The system
is also intended to provide guidance to help people plan the use of their land confidently and sensibly.

4.2 Development control involves the determination of applications for planning permission. Planning permission is
required for any development of land. Planning decisions on proposals to build on land or to change its use are usually
made by local planning authorities. The system operates on the basis that applications for development should be deter-
mined in accordance with the development plan, unless material considerations dictate otherwise.

4.3 Planning Policy Guidance Note 1 (PPG1)19, which sets out the general policy and principles of the planning system,
states that: In principle, any consideration which relates to the use and development of land is capable of being a
material planning consideration (para.50).

4.4 Since radon emissions in new development can pose a risk to peoples health, they may be a material planning con-
sideration. It follows, therefore, that local planning authorities should have regard where necessary to the issue of radon
emissions in preparing development plans and deciding on planning applications, the aim being to ensure that radon
protective or remedial measures are incorporated, where appropriate.

4.5 When considering a potential planning response to the radon issue, analogies can usefully be drawn with land insta-
bility and methane emissions, both of which are naturally occurring phenomena. The former is currently addressed in
PPG 14 (Development on Unstable Land), which advises local authorities to take account of land stability in preparing
development plans and in deciding on planning applications. Recent research into methane emissions and other
naturally occurring gases concluded that the issue should be addressed by planning because not all development is
subject to control under the Building Regulations (Appleton, Hooker and Smith, 1995; Wardell Armstrong, 1996).

Potential Planning Response

4.6 There are no circumstances where the problem of radon emissions in new development cannot be overcome through
appropriate protective or remedial measures. It would therefore be inappropriate for planning permission to be refused
solely because of the presence of potentially harmful radon concentrations.

4.7 However, it is considered that the planning process could be used to inform potential developers and the general public
of the radon issue and of the requirement or possible need for protective or remedial measures for certain types of
development or change of use in radon-prone areas. This information could be provided in development plans and in
pre-application discussions. Planning informatives, forming part of a decision notice, would ensure that developers are
made aware of the possible requirement for protective or remedial measures under either Requirement C2 of Schedule
1 of the Building Regulations 1991 or the Ionising Radiations Regulations 1999.

4.8 This approach would complement the functions of building control, the HSE and local authority Environmental Health
Officers.

The Role of Planning Policy Guidance

4.9 Planning policy guidance would draw attention to these roles of the planning system with respect to radon emissions
in new development. Rather than a separate PPG on the subject, it may be more appropriate to combine this guidance
with that relating to other physical constraints, such as contaminated land and emissions of methane and other harmful
gases.

4.10 Planning policy guidance would seek to advise local planning authorities how radon could be dealt with using the
following procedures.

19 In Wales, refer to Planning Guidance (Wales): Planning Policy, 1999

17
 The Role of Development Plans
4.11 Structure Plans and Part 1 of Unitary Development Plans20 might include a general statement indicating that radon
emissions are an issue which local authorities may need to take into account when preparing development plans and
determining applications for planning permission. The statement would provide information about the radon issue, its
geographical extent, and explain that the problem can be overcome through appropriate protective or remedial
measures. Reference would need to be made to the maps in BR211, which would, in effect, be considered as a radon
constraints mapshowing those areas affected or potentially affected by radon emissions. There are probably very few
situations where additional detail would be required for planning.

4.12 Local Plans and UDPs Part II would give detailed expression to the general statements in Structure Plans and Part 1 of
Unitary Development Plans. They would indicate that, for certain types of development or material change of use in
radon-prone areas, protective or remedial measures might be required by Building Control.

The Role of Development Control

4.13 The function of development control, at the pre-application stage, would be to remind applicants that, for development
or changes of use in radon-prone areas, protective or remedial measures are likely to be required by Building Control.

4.14 At the planning application stage, subject to other material considerations, planning permission could be granted with
an informative that:

in the case of new dwellings, extensions to dwellings and material alteration and material change of use
(e.g. major structural alterations and conversions to domestic use, such as barn conversions), radon protective
measures may be required by Building Control, in accordance with Requirement C2 of the Building
Regulations21. The developer would be referred to BR211 (New dwellings) or BR267 (Major Alterations and
Conversions).
in the case of new workplaces or new residential institutions22, radon protective measures may be required.
The developer would be referred to BR293 (Radon in workplaces) or alternative detailed guidance, should this
be considered necessary 23.
in the case of a change from workplace to domestic use which does not involve major structural alterations
to floor and foundations (material alterations), radon monitoring and subsequent remediation may be
required. The developer would be referred to BR250 (Radon remedial measures in existing dwellings).
in the case of change from domestic to workplace or non-domestic residential use, radon protection, radon
monitoring and subsequent remediation may be required. The developer would be referred to BR293 (Radon in
workplaces)24.

4.15 Since planning informatives would be a matter of public record, any future purchaser not discovering the risk of radon
would be negligent in not doing so. Such information should be included in the Home Sellers Information Pack, should
this aspect of the DETRs recent initiative25 to improve co-ordination of the home buying and selling process be
adopted. An optional enquiry (No. 36) about radon gas precautions already appears on the local authority searches form
(CON. 29 (1994): Enquiries of Local Authority).

4.16 A flow diagram illustrating the potential planning response is in Figure 6.

Alternative Approach Using Planning Conditions

4.17 An alternative approach would be to ensure that applications for development or material changes in use which might
expose people to significant levels of radon, but are not subject to the Building Regulations, are granted subject to a

20 In Wales, refer to Planning Guidance (Wales): Unitary Development Plans, 1996

21 A change from agricultural or workplace to domestic use which involves major construction work to floor and foundations, such as a barn
conversion, is not subject to Requirement C2 of the Building Regulations. Amendment of Regulation 6 (Material Change of Use) of the
Building Regulations (England and Wales) 1991 would help to address this point.
22 Certain residential institutions are not referred to in Approved Document C to the Building Regulations. These include childrens homes and
homes for the elderly.
23 An employer using a workplace would be responsible, under the Health and Safety at Work etc. Act 1974 and the Ionising Radiations Regulations
1999, for ensuring that employees and others who have access to that working environment were protected from exposure to radon.
24 In Wales, refer to Planning Guidance (Wales): Unitary Development Plans, 1996
25 DETR Consultation Paper The Key to Easier Home Buying and Selling (ISBN 1 85112 134 X)

18
FORWARD PLANNING

Does the plan area include radon-prone NO

areas as indicated by Annex A and B No action
maps in BR211 (1999)?

YES

Include statement in development plan

referring to maps in BR211.

DEVELOPMENT CONTROL

Does the application area lie within a NO

radon-prone area on the Annex A and B No action
maps in BR211?

YES

Is the application for new dwelling(s), YES Grant planning permission subject to other material considerations,
extension(s) to dwelling(s) or material with informative that radon protective measures may be required by
alteration to dwelling or conversion to Building Control under Requirement C2 of the Building Regulations.
domestic use? (Guidance: BR211 (1999) and BR267)

NO

Grant planning permission subject to other material considerations,

Is the application for (1) a new YES with informative that radon protective measures may be required
workplace or residential building or (2) (Guidance: BR293). Advise developer that employer will be
material change to workplace use? responsible for ensuring monitoring and remediation (if necessary)
is carried out.

NO

Grant planning permission subject to other material considerations,

Is the application for a change from YES with informative that radon remedial measures may be required
workplace to domestic use not involving (Guidance: BR250 and House Holders Guide to Radon).
material alteration or conversion? Monitoring should be strongly advised. Householder responsible for
remediation.

NO

Grant planning permission subject to other material considerations,

Is the application for a change from YES with informative that monitoring and subsequent remedial measures
domestic to workplace or non-domestic
may be required (Guidance: BR293). Advise developer that employer
residential use not involving material
will be responsible for ensuring monitoring and remediation (if
alteration or conversion?
necessary) is carried out.

Figure 6 Planning procedures for dealing with radon emissions in new development.

19
 planning condition. The condition would state that the development should not commence until radon protective
measures (or the results of investigations which disprove the need for such measures) are submitted to and approved
by the local planning authority, in consultation with Building Control.

4.18 With respect to changes of use that do not involve major structural alterations to floor and foundations (material alter-
ations), however, the imposition of conditions would not be practical. This is because radon monitoring has to be
carried out over a three month period after occupation of the buildings in order to assess whether remedial measures
are required. Thus conditions could only be attached to planning approvals for new workplaces, and certain new resi-
dential institutions, together with conversions to workplace use which involve major structural alterations to floor and
foundations.

4.19 The procedures to be followed if this alternative approach was adopted are identical to those illustrated in Figure 6 with
the exception that the fourth box down in the right hand column (outlined in bold) would contain the following text:

Grant planning permission subject to other material considerations, with a condition that radon protective measures
(or the results of investigations which disprove the need for such measures) are approved by the local planning
authority, in consultation with Building Control (Guidance: BR293).

Response to consultation with the planning professionals

4.20 In November 1997, representatives of the planning profession were consulted regarding the potential role of the
planning system in dealing with radon in new development. Consultees are listed in Appendix II. Responses were
received from 34 local authorities (44% of those consulted), the Planning Officers Society, and the Royal Town
Planning Institute. The following paragraphs summarise the response to the main issues.

Radon as a material planning consideration

4.21 Virtually all consultees agreed that radon emissions are a material planning consideration and, as such, there should be
a planning response of some kind. A few consultees noted that, in radon-prone areas, it is considered that local author-
ities had a duty at least to notify developers of the issue.

Role of Planning Policy Guidance

4.22 To this end it was generally agreed that planning policy guidance should draw attention to the issue of naturally
occurring radiation and advise local planning authorities on the appropriate response at the development plan stage and
at the development control stage. It was felt that this endorsement of the issue at the national level is necessary to
ensure a consistency of approach in the regions - particularly as far as the responses of the Government Offices and the
National Assembly of Wales to draft development plans are concerned.

4.23 The general consensus was that the radon issue should be addressed as part of the current revision of PPG 23 on
Planning and Pollution Control (Contaminated Land).

Role of development plans

4.24 Most consultees considered that the role of development plans should be to inform developers and the general public
of radon-prone areas, and that for certain types of development or land use change in such areas, building control may
require radon protective measures. Given that the purpose would be to provide information, rather than a basis for
development control, it was considered the radon issue should be addressed as part of the text of a plan as opposed
to a policy statement.

4.25 South Gloucestershire Council included with its response a relevant extract from the South Gloucestershire Draft Local
Plan:

Some contaminants occur naturally. In some areas within South Gloucestershire radon emissions are such
that protective measures may be required under the Building Regulations. The National Radiological
Protection Board will carry out radon tests. (para. 3.247)

4.26 The Planning Officers Society highlighted the need for guidance from the DETR on how the spatial extent and seri-
ousness of the radon risk can be mapped as accurately as possible.

20
 Role of development control
4.27 It was generally considered that the role of the development control process should also be informative. At the pre-
application stage the function of development control would be to remind applicants that for certain types of develop-
ment or land use change in radon-prone areas, protective measures may be required by building control.

4.28 At the planning application stage, planning permission for development in radon-prone areas should be granted (subject
to other material considerations) with relevant informatives (or advisory notes) about the Regulations and legislation
applying to the development concerned. Some concern was expressed about the legal or other means by which devel-
opers and subsequent owners are required to pass on the information to new owners. Disclosure to new owners is dealt
with to some extent by Optional Enquiry 36 on the Law Society search form26, which asks if the house is in an area
where radon precautions are needed.

4.29 It was widely recognised that the informative approach has limitations - not least that informatives are not enforceable.
However, the use of planning conditions to overcome this problem was considered generally to be inappropriate. Two
main reasons were given.

4.30 First, it is debatable whether such a condition would be consistent with DOE Circular 11/95 (The Use of Conditions in
Planning Permissions), which explains that, in considering whether a particular condition is necessary, authorities
should ask themselves whether planning permission would have to be refused if that condition was not to be imposed.

4.31 Second, the condition could only be attached to planning approvals for new workplaces and certain new residential
institutions, together with conversions to workplace use which involve major structural alterations to floor and foun-
dations. With respect to changes of use which do not involve major structural alterations to floor and foundations, the
imposition of conditions would not be practical because radon monitoring has to be carried out over a three month
period after occupation of the buildings in order to assess whether remedial measures are required.

4.32 This prompted a number of consultees to say that a better solution would be to extend the scope of control under the
Building Regulations to cover, in addition to new dwellings:

(i) new workplaces and new residential institutions (e.g. homes for children and the elderly) or major conversions
to workplace use;
(ii) change from workplace to domestic use which does not involve major structural alterations to floor and
foundations; and
(iii) change from domestic to workplace or non-domestic residential use not involving major alteration or
conversion.

4.33 It was felt that such an approach is more appropriate than using the planning process as an intermediary between
developers and building control. It is also more logical because the solutions lie in the details of construction, which
in themselves are not planning considerations.

4.34 In the absence of such an extension to the Building Regulations, however, some consultees argued that the planning
condition approach (where practical) does offer a means of achieving the desired goal - that radon protective and
remedial measures are incorporated as far as possible in radon-prone areas.

Conclusions and recommendations

4.35 Most planners consulted agree that the planning system should address the problem of radon emissions in new devel-
opment. The role of the planning system, however, should be confined to the provision of information about the
problem and how it can be overcome (i.e. the relevant Building Regulations and Health and Safety Legislation). The
information should be contained in development plans and in decision letters about individual planning applications.

4.36 Maps 1 and 2 of BR211 (1999) (reproduced in Figures 1 and 2) could be combined to produce planning constraints
maps. These would indicate those areas where informatives need to be attached to planning decision notices for new
development and changes of use.

4.37 An informative might be worded: It is possible that land covered by the development application lies within a radon-
prone area and that radon protective measures may be required by Building Control under Requirement C2 of the

26 CON.29 (1994) Enquiries of Local Authority (1994 Edn.)

21
 Building Regulations (Guidance BR211 and BR267). You are advised to follow the appropriate guidance to verify
whether protective measures are required. The wording of the informative could be modified to cover the other three
cases given in the right-hand boxes of Figure 6. There might be some merit in printing all four informatives as standard
on Planning Permission forms in order to avoid errors of omission. Inappropriate informatives could be deleted.

4.38 The planning system should not, in the opinion of most planners consulted, be used as a means of ensuring that the
appropriate Building Regulations and Health and Safety Legislation are effectively enforced. This should be done by
the relevant administrative structures themselves. For this reason, amongst others, planning conditions should not be
used with respect to radon emissions in new development.

4.39 There is a perception that the Building Regulations and Health and Safety legislation do not cover all forms of devel-
opment or land use change potentially affected by radon emissions which are potentially prejudicial to health (or are
above the Action Level). This may be because the information in the Approved Document to Part C and supplemen-
tary guidance is limited to new dwellings. In fact Requirement C2 of the Building Regulations applies to all new
buildings. Its application to material changes of use is limited because the scope of Regulation 6 is restricted to selected
requirements of Schedule 1, which does not currently include Requirement C2. It would be better if these limitations
did not have to be addressed through the planning system (apart from through the provision of information). These lim-
itations could be dealt with by appropriate amendments to the Building Regulations.

4.40 Whereas radon may be material to a new development, it is effectively covered in most situations by other legislation.
A simple informative attached to planning permissions would meet any perceived duty of local authorities to inform of
potential hazards in those cases where it isnt covered by current legislation and would do no harm in cases which are
covered.

4.41 The potential planning response outlined above appears to deal effectively with the last three of the limitations of
current responses identified in paragraph 1.5 above.

22
5 Recommended framework for guidance

Introduction
5.1 There are four main categories of new development or changes to use of land in radon-prone areas which may result
in people being exposed to radon emissions. These are:

Category 1 new dwelling(s) or extension(s) to dwellings; material alteration to dwellings or conversion to

domestic use;
Category 2 new workplaces or residential institutions or material changes to workplace use;
Category 3 change from workplace to domestic use not involving material alteration/conversion;
Category 4 change from domestic to workplace or non-domestic residential use not involving material alteration
or conversion.

5.2 The following sections provide recommendations on how radon in new development should be dealt with through
Planning, Building Control, Health & Safety and Environmental Health systems.

Planning
5.3 The role of the planning system should be confined to the provision of information about the problem of radon
emissions in new development and how it can be overcome (i.e. through the application of relevant Building
Regulations and Health and Safety Legislation and the provision of information about relevant guidance). The infor-
mation should be contained in development plans and in decision letters about individual planning applications.

5.4 A flow diagram (Figure 6) and paras. 4.64.16 provide more detail on how this could be achieved.

5.5 It is recommended that the radon issue should be addressed as part of the current revision of PPG 23 on Planning and
Pollution Control (Contaminated Land) and the Technical Advice Note (TAN) on Planning, Pollution Control and
Waste Management in Wales.

Building Control
5.6 It is the purpose of Building Control to ensure that, for certain types of development where the Building Regulations
apply, the detailed design of buildings will ensure that the completed building provides a healthy and safe environment
for people in and around it.

5.7 Statutory requirements relating to radon are contained in Requirement C2 of Schedule 1 of the Building Regulations
1991 for England and Wales which states: Precautions shall be taken to avoid danger to health and safety caused by
substances found on or in the ground to be covered by the building.

5.8 The Approved Document27 refers to BRE Report, BR211, Radon: Guidance on protective measures for new dwellings,
for detailed guidance on where such protection is necessary and practical construction details. The guidance in the
Approved Document is limited to new dwellings and extensions but the requirement applies to all buildings. Additional
guidance is available for workplaces (BR 293) and for remedial measures in existing dwellings (BR 227 and BR 250).

5.9 Whereas buildings other than dwellings are subject to Requirement C2 of the Building Regulations, this could be made
clearer if a paragraph on non-domestic building was added to the Approved Document to Part C.

5.10 The maps and plates in BR211 (1999) and the BGS Radon Potential Measures GIS provide information on the location
of those areas where radon protective measures are required in new dwellings and extensions to dwellings (Category
1 in 5.1 above). These maps could also be used to indicate where it may be advisable to install protective measures in

27 Building Regulations (England and Wales) 1991, Approved Document C, site preparation and resistance to moisture, London, HMSO, 1991.

23
 Category 2 developments and where it may be advisable to monitor for radon in Category 3 and 4 developments, in
order to verify whether remedial measures are required.

Health & Safety and Environmental Health

5.11 Regulations and guidance designed to protect the health and safety of employees and others who have access to work-
places are enforced by the HSE and Local Authority Environmental Health Departments (LAEHD).

5.12 Employers occupying Category 2 and 4 developments in radon-prone areas for the first time would be responsible for
carrying out a suitable and sufficient radon risk assessment. Such employers might be reached, where appropriate,
through HSEs workplace contact officers.

Scotland and Northern Ireland

5.13 Whereas this report is directed towards dealing with radon emissions in new development in England and Wales, many
aspects of the framework for guidance would also be applicable, in principle, to new development in Scotland and
Northern Ireland. Guidance on radon protective measures for new dwellings has been issued in Scotland (BR376, BRE,
1999b).

24
Appendix I

Background information on radon

Useful information on radon in existing dwellings is given in the following free publications which can be obtained by writing to: DETR
Free Literature, PO Box 236, Wetherby, West Yorkshire, LS23 7NB.

Radon A Householders Guide

Radon You Can Test for it
Radon A Guide for Homebuyers and Sellers
Radon A Guide to Reducing Levels in Your Home

Information in the booklets is also available on the DETR website at: http://www.environment.detr.gov.uk/radioactivity/index.htm

You can get advice about radon, its health risks and details of how to order the radon test from the NRPB Radon Freephone on 0800 614529
or by post from NRPB, Chilton, Didcot, Oxfordshire OX11 0RQ.

Accumulations of radon in dwellings can be fairly easily and inexpensively dealt with. You can get practical advice about construction work
to reduce radon levels from the Building Research Establishment (BRE) Radon hotline on 01923 664707.

The Ionising Radiation Regulations, 1999, require employers to take action when radon is present above a defined level in the workplace.
Advice may be obtained from your local Health and Safety Executive Area Office or the Environmental Health Department of your local
authority. The BRE publishes a guide: Radon in the workplace (BR293).

BRE publications may be obtained from Construction Research Communications Ltd, 151 Roseberry Avenue, London EC1R 4QX
(Tel: 020 7505 6622; Fax: 020 7505 6606).

Geological radon potential assessment methods are described in the British Geological Survey Technical Report WP/95/2 Radon and back -
ground radioactivity from natural sources: characteristics, extent and relevance to planning and development in Great Britain which may
be obtained from the Sales Desk, British Geological Survey, Keyworth, Nottingham NG12 5GG (Tel: 0115 936 3241; Fax: 0115 936 3488).

A comprehensive list of publications about radon with details of prices and how to obtain them is published in the Environmental Radon
Newsletter, Issue 16 (Autumn 1998) available from the NRPB.

Appendix II

Planning consultees
1 The chief planning officers of all local authorities (counties and districts/boroughs) in the radon Affected Areas listed
in BR211(as revised 1992) (5 counties and 49 districts in total);

2 The chief planning officers of all local authorities (counties and districts/boroughs) in additional radon-prone areas
(selected on the basis of the geological radon potential map published by BGS in 199528) (11 counties and 12 districts
in total);

3 The Planning Officers Society;

4 The Royal Town Planning Institute.

28 1:625000 scale Radon Potential Based on Solid Geology maps of Great Britian (North and South sheets) in Appleton and Ball (1995).

25
Appendix III

References Czech Republic IV. BARNET, I (editor). Czech Geological Survey,

Prague.
KERBLOM, G. 1999. Radon Legislation and National
Guidelines. Statens strlskyddinstitut Report No. 99:18 DEPARTMENT OF THE ENVIRONMENT. 1992a. PPG1 (General
(Stockholm: Swedish Radiation Protection Institute (SSI)). (Also policy and Principles).
available at http://arcas.nuclear.mech.ntua.gr/~erricca/erriaker.pdf) DEPARTMENT OF THE ENVIRONMENT. 1992b. PPG12
APPLETON, J D, and BALL, T K. 1995. Radon and background (Development Plans and Regional Planning Guidance).
radioactivity from natural sources: characteristics, extent and DEPARTMENT OF THE ENVIRONMENT. 1996. PPG 14
relevance to planning and development in Great Britain. British (Development on Unstable Land).
Geological Survey Technical Report WP/95/2. DEPARTMENT OF THE ENVIRONMENT. 1994. PPG 23 (Planning
APPLETON, J.D, H OOKER, P J, and SMITH, N J P. 1995. Methane, and Pollution Control).
carbon dioxide and oil seeps from natural sources and mining DEPARTMENT OF THE ENVIRONMENT. 1995. Circular 11/95 (The
areas: characteristics, extent, and relevance to planning and Use of Conditions in Planning Permissions).
development in Great Britain. British Geological Survey
EPA. 1994. Model Standards and Techniques for Control of
Technical Report, WP/95/1
Radon in New Buildings. US Office of Air and Radiation
APPLETON, J.D, and BALL, T K. In press. Geological radon (6604-J), EPA 402-R-94-009, March 1994 (also available at
potential mapping. In Geoenvironment mapping: methods, http://www.epa.gov/iaq /radon/pubs/newconst.html).
theory and practice. BOBROWSKY, P (editor). (Rotterdam:
LOMAS, PR, GREEN, B M R, MILES, J C H, and KENDALL, G M.
Balkema.)
1996. Radon Atlas of England. National Radiation Protection
BARNET, I. 1994. Radon risk classification for building Board, Chilton. NRPB-R290.
purposes. In Radon Investigations in the Czech Republic.
LOMAS, PR, GREEN, B M R, and MILES, J C H. 1998. Radon in
BARNET, I, and NEZNAL, M (editors). V: 1825. (Prague: Czech
Dwellings in Wales: Atlas and 1998 Review. National Radiation
Geological Survey.)
Protection Board, Chilton. NRPB-R303.
BARNET, I, and MIKSOV, J. 1999. The GIS approach to radon
MATOLN, M. 1996. Reference sites for measurement of radon
risk mapping in the Czech Republic. 5th International
volume activity in soil air in the Czech Republic. In 72 77
Conference on Rare Gas Geochemistry, Debrecen, Hungary.
Radon Investigations in the Czech Republic VI. BARNET, I, and
BUILDING RESEARCH ESTABLISHMENT (BRE). 1991a. Radon: NEZNAL, M (editors). (Prague: Czech Geological Survey.)
guidance on protective measures for new dwellings. Building
MILES, J C H. 1998. Mapping radon-prone areas by log-normal
Research Establishment Report BR 211.
modelling of house radon data. Health Physics, 74(3): 37378.
BUILDING RESEARCH ESTABLISHMENT (BRE). 1991b.
MILES, J C H, and BALL, T K. 1996. Mapping radon-prone areas
Construction of new buildings on gas-contaminated land.
using house radon data and geological boundaries. Environment
Building Research Establishment Report BR 212.
International. 22 (Suppl. 1): 779 782.
BUILDING RESEARCH ESTABLISHMENT (BRE). 1993. Surveying
MILES, J C H, GREEN, B M R, LOMAS, P R, and CLIFF, K.D. 1990.
dwellings with high radon indoor levels: BRE guide to radon
Radon affected areas: Cornwall and Devon. Documents of the
remedial measures in existing dwellings. Building Research
NRPB 1(4): 37 43.
Establishment Report BR 250.
MILES, J C H, GREEN, B M R, and LOMAS, P R. 1992. Radon
BUILDING RESEARCH ESTABLISHMENT (BRE). 1994a. Major
affected areas: Derbyshire, Northamptonshire and Somerset.
alterations and conversions. Building Research Establishment
Documents of the NRPB 3(4): 19 28.
Report BR 267.
MILES, J C H, and APPLETON, J D. 2000. Identification of
BUILDING RESEARCH ESTABLISHMENT (BRE). 1994b. Radon and
localised areas of England where radon concentrations are most
buildings: 3. Protecting new extensions and conservatories.
likely to have >5% probability of being above the Action Level.
Building Research Establishment Report XL 10.
DETR Report No: DETR/RAS/00.001.
BUILDING RESEARCH ESTABLISHMENT (BRE). 1995. Radon in the NEZNAL, M, NEZNAL, M, and Smarda, J. 1996. Assessment of
workplace. Building Research Establishment Report, BR 293. radon potential of soils a five-year assessment. Environment
BUILDING RESEARCH ESTABLISHMENT (BRE). 1998. Radon International 22(Suppl. 1): 81 828.
sumps: BRE guide to radon remedial measures in existing NORDIC RADIATION PROTECTION INSTITUTES IN DENMARK, F INLAND,
dwellings. Building Research Establishment Report, BR 227 ICELAND, NORWAY, SWEDEN. 1986. Naturally Occurring
(Second edition). Radiation in the Nordic Countries: Recommendations
BUILDING RESEARCH ESTABLISHMENT (BRE). 1999a. Radon: SNIHS, JO. 1992. Swedish Radon Programme. In Radon 2000
guidance on protective measures for new dwellings. Building Conference Proceedings. ORIORDAN, M C O, and MILES, J C H
Research Establishment Report, BR 211. (editors). Radiation Protection Dosimetry, Vol. 42, No. 3, 1 184.
BUILDING RESEARCH ESTABLISHMENT (BRE). 1999b. Radon: USGS (UNITED STATES GEOLOGICAL SURVEY). 1992. Geologic
guidance on protective measures for new dwellings in Scotland. Radon Potential of EPA Regions 110. U.S. Geological Survey
Building Research Establishment Report, BR 376 Open File Reports.
BURIAN, I, MERTA, J, ETAL . 1993. Estimation of the category of WARDELL ARMSTRONG. 1996. Methane and Other Gases from
radon risk emission on individual building area questions and Disused Coal Mines: The Planning Response. (London: Wardell
different approaches. 18 21 in Radon Investigations in the Armstrong, TSO.)

26
 IS BN 0-8 52 72 -365 -2

9 78 08 5 2 72 36 5 4