You already know the building should be tested. The problem is not the science, and it is probably not you — it is that radon competes for budget against things with louder advocates, and the person approving it has never had to think about it before.
This is the argument, assembled. Take what is useful and leave the rest.
The short version. Four things get radon testing approved: a specific obligation with a date, a defensible number rather than a guess, a smaller option than “test everything”, and an honest account of what doing nothing costs. The fourth is usually the one that moves it — because under the federal regulations the qualified person's report is retained for thirty years, and a decision not to act is documented for just as long as a decision to act.
1. Start with the trigger, not with radon
Nobody approves a budget line for a gas. They approve it for a reason that arrived on a date. Identify which of these you are actually responding to, because it determines the whole shape of the case.
| Trigger | What it gives you |
|---|---|
| Federal regulation — SOR/2026-10 lowers the workplace exposure limit from 800 to 200 Bq/m³ on 30 January 2027 | The strongest case available. A specific instrument, a specific number, a specific date. |
| A worker or committee has asked | A documented question that requires a documented answer. Under the Canada Labour Code an employer must respond in writing to a committee recommendation within a set period. |
| Provincial general duty | No number, but a real obligation to take reasonable precautions against recognised hazards — and radon is a recognised hazard with a published national guideline. |
| A tenant, insurer, purchaser or client has asked | Commercial rather than regulatory, and often faster to fund because it has a named counterparty attached. |
| Nobody has asked | The hardest case, and the one where the exposure research below does the work. |
If you are unsure which jurisdiction applies, resolve that first — the answer changes what you are obliged to do and by when. See which rules apply to your workplace.
2. The number that changes the conversation
The most common internal objection is not “this is expensive.” It is “surely that is a mining problem.”
Peer-reviewed Canadian research published in Scientific Reports in 2022 estimates that 603,000 Canadian workers are exposed to radon above 100 Bq/m³. The industries with the largest numbers of exposed workers are educational services; professional, scientific and technical services; health care and social assistance; and public administration.
And the occupations are administrative assistants, general office support workers, receptionists, and elementary and kindergarten teachers.
Mining behaves differently: it has comparatively few exposed workers but the largest proportion at the extreme end — 43.6% of its exposed workers are above 800 Bq/m³, against 1.5% in educational services. Resource workers are the most exposed by level. Office workers are the most exposed by number.
That single distinction dismantles the objection, and it is peer-reviewed rather than a vendor claim. Full detail and sources: 603,000 Canadian workers are exposed to radon.
3. What you are actually asking to buy
Be precise here, because vagueness is what gets a request deferred. You are asking for a measurement programme with a defined scope, not an open-ended consultancy engagement.
The arithmetic that sets the cost
Under Health Canada's protocol for public buildings, the driver is not floor area and not headcount. It is the number of occupied rooms in contact with the ground — rooms at the lowest level where someone spends four hours or more a day.
- One detector in each such room
- One detector per 200 m² in larger open areas
- Quality-control detectors in addition — duplicates at a proportion of locations, plus blanks
So a ground floor with twelve occupied rooms is roughly thirteen detectors plus QC, not one. Do this count before you ask for money. It converts “we should test the building” into a defensible line item, and it is the first thing any supplier will ask you for.
The other cost drivers
- How many buildings, and whether they are similar to each other. A portfolio of near-identical branches costs far less per building than a portfolio of one-offs, because the placement plan is reusable.
- Who places the detectors. Your own staff following a written protocol is materially cheaper than a technician attending each site. Both are legitimate.
- Whether a certified professional is involved, and whether they attend or work remotely from plans and photographs.
- What you need at the end. Laboratory certificates are the cheap part. An assembled compliance record is the deliverable.
4. Offer a smaller option — this is what gets it approved
If you hold more buildings than one heating season allows, do not put “test everything” in front of a finance committee. Put a risk-ranked, phased plan in front of them, with this season's tranche costed and the rest scheduled.
This is not a workaround. It is a recognised approach: prioritise the highest-risk buildings, document why you ranked them that way, schedule the remainder, and be able to show progress. An employer with a written plan is in a very different position from one with nothing.
Two pieces do the work here: how to risk-rank a building portfolio and how phased compliance works.
Offering the phased option changes the decision from yes or no to how much this year. That is a much easier question for someone to say yes to.
5. What doing nothing costs
Every business case needs this section and most people write it badly, either by threatening or by softening it into nothing. State what is actually true.
The record outlives the decision
This is the argument that lands hardest, and it is the one most people miss.
Under the federal regulations, the qualified person's report from a hazard investigation is retained by the employer for thirty years from signature. That obligation already exists — it did not arrive with the 2026 amendments.
Thirty years is longer than the tenure of everyone who will be in the room when the decision is made. If the question was asked and the answer was to defer, that is part of the record too. Nobody has to threaten anything for that to be uncomfortable; it is simply how documentation works.
Enforcement, stated accurately
Part II of the Canada Labour Code is enforced through a graduated series of measures, and the Labour Program describes the response as depending on the seriousness of the contravention and on the cooperation of the workplace. Available measures include education and counselling, a written assurance of voluntary compliance, a direction to terminate a contravention, administrative monetary penalties with publication of the employer's name, and prosecution.
A worker can complain directly to the Labour Program without raising the matter with the employer first.
Note the phrase cooperation of the workplace. An employer with a documented plan and a partial programme underway is in a materially different conversation from one that did nothing.
The timing cost, which is the concrete one
This is the argument for acting this budget cycle rather than next.
A long-term measurement needs a minimum of 91 days, ideally during the heating season. Counting back from 30 January 2027 puts detector placement in early November 2026, and placement after the end of January pushes the measurement period outside the heating season, which weakens the result.
The usable window is roughly 1 October to the end of January. Miss it and the next opportunity is a year later. That is not a regulatory deadline — it is arithmetic, and it is the reason a decision deferred by one quarter is in practice deferred by twelve months.
6. A summary you can paste into a memo
Adjust the bracketed parts and delete what does not apply.
Recommendation: approve radon measurement at [number] buildings during the 2026–27 heating season, at an estimated [cost], with the remaining [number] buildings scheduled for [period].
Background. Radon is a naturally occurring radioactive gas and a Group 1 carcinogen. Health Canada identifies it as the second leading cause of lung cancer in Canada. Peer-reviewed Canadian research estimates 603,000 workers are exposed above 100 Bq/m³, concentrated in office, education, health care and public administration settings rather than in resource extraction.
Obligation. [For federally regulated employers: SOR/2026-10 lowers the workplace radon exposure limit from 800 to 200 Bq/m³, in force 30 January 2027. The obligation rests on the employer and is expressed as an annual average, which cannot be demonstrated without measurement.] [For provincially regulated employers: no numeric radon limit applies, but the general duty to take reasonable precautions against recognised hazards does, and Health Canada's 200 Bq/m³ guideline applies to all indoor spaces including workplaces.]
Scope. Measurement follows Health Canada's protocol for public buildings: long-term detectors, minimum three months during the heating season, one detector in each occupied room in contact with the ground plus quality-control detectors. Estimated [number] detectors across [number] buildings.
Timing. The measurement window runs from approximately 1 October to the end of January. A decision after that date defers the programme by a full year.
Risk of deferral. The qualified person's report is retained for thirty years, and enforcement under Part II of the Code is graduated and takes account of the cooperation of the workplace. An employer with a documented, phased plan is in a materially stronger position than one with no programme.
Options considered. (a) Full programme this season — [cost]. (b) Risk-ranked phased programme, highest-risk buildings this season — [cost], remainder [period]. (c) Defer — no cost this year, programme delayed twelve months. Recommended: (b).
7. Questions you will be asked, and the answers
“Do we legally have to do this?”
If you are federally regulated: the exposure limit is binding from 30 January 2027, and an annual average cannot be demonstrated without measuring. If you are provincially regulated: no numeric limit applies to radon specifically, but the general duty does, and inaction after a hazard has been identified is precisely what that duty addresses.
“Can't we just do one test in the building?”
Not under Health Canada's public buildings protocol. One detector in each occupied ground-contact room, plus quality-control detectors. A single result for a whole building is not a compliant measurement and will not survive scrutiny.
“Can't we wait and see what other people do?”
You can, but the measurement window is seasonal. Waiting one quarter defers the programme by a year, and if the answer turns out to be high you will have spent that year not knowing.
“Do we need to hire a consultant?”
Not necessarily. The regulation requires a qualified person, defined by knowledge, training and experience rather than by any particular certificate — there is no requirement for C-NRPP certification in the regulation itself. Health Canada's guidance is that a certified professional would ideally be involved in the measurement strategy. See the qualified person question.
“What if the result is high?”
Health Canada’s Guide for Radon Measurements in Public Buildings sets the remediation timeframes for public buildings: within two years for results between 200 and 600 Bq/m³, and within one year above 600 Bq/m³ — and the higher the concentration, the sooner action should be taken. (Health Canada’s guidance for homes differs: corrective action within one year above 200 Bq/m³.) Mitigation typically reduces levels by more than 80% and is usually a one-day job. Budget for the possibility rather than being surprised by it, but note that most buildings test low.
“What do we actually get at the end?”
Laboratory certificates are one part of it. The deliverable is an assembled record — see what a compliant workplace radon record contains. Four of its five elements are generated in the field, not by the laboratory.
Getting a number for the business case
You need a costed figure before you can ask for anything, and you need it without committing to a purchase.
Email support@radontest.ca with the number of buildings, a rough count of occupied ground-contact rooms in each, and your timeline. We will come back with a detector count and a costed scope you can put in a memo — and if a phased approach makes more sense for the size of portfolio involved, we will say so rather than quoting you for everything at once.
We supply long-term detectors listed under the Canadian National Radon Proficiency Program, analysed by a C-NRPP-certified, ISO 17025-accredited laboratory — the combination Health Canada advises people to look for. We handle kit logistics, registration, chain of custody and the assembled record. We are listed by Take Action on Radon on its list of Canadian kit suppliers and are members of CARST.
We do not perform mitigation work, so we have no financial interest in what your results say. RadonTest.ca may be able to help — and if all you need right now is the detector arithmetic so you can size the ask, tell us that and we will send it, before you write the memo.
Read next
What a compliant workplace radon record contains · How to risk-rank a building portfolio · How phased compliance works · The compliance timeline · How commercial radon testing works
RadonTest.ca provides testing logistics and laboratory submission. We do not perform radon mitigation and we do not interpret health risk — Health Canada is the health authority on radon in Canada. This page describes publicly available regulatory information and is not legal advice. Enforcement outcomes depend on circumstances; nothing here should be read as a prediction of how a regulator would act in any particular case.
Sources
Brobbey A, Rydz E, Fenton S, Demers PA, Ge CB, Peters CE. “Characterizing occupational radon exposure greater than 100 Bq/m³ in a highly exposed country.” Scientific Reports 2022;12:21323.
Canada Gazette, Part II, Vol. 160, No. 3 — SOR/2026-10; Canada Occupational Health and Safety Regulations (SOR/86-304), ss. 10.4, 10.5, 10.6, 10.26; Canada Labour Code, Part II; Employment and Social Development Canada, occupational health and safety compliance; Health Canada, Guide for Radon Measurements in Public Buildings; Health Canada, Canadian radon guideline; C-NRPP.