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Author Topic: Festool HEPA filter vacs and the EPA Lead rqmts.  (Read 12066 times)

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Offline Chuck Kiser

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  • Carpenter in the Desert
    • Knollwood Construction Company
Festool HEPA filter vacs and the EPA Lead rqmts.
« on: October 27, 2009, 06:06 PM »
Hey Festool Guys,

Can you tell me whether or not the Festool vacs with HEPA filters are suitable and allowed for lead dust removal and containment for the upcoming EPA requirements for renovators?

If you have not looked into this it is going to be a big deal next year. It might be worth a look-see. [unsure]
Life is too short for bad wine or cheap tools.

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Offline Dan Rush

  • Posts: 569
  • Trim carpenter
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #1 on: October 27, 2009, 06:50 PM »
Chuck,

When at the 1st training event, this very subject came up, and I'm pretty sure that the HEPA vacs do meet the requirements.  But don't rely on my somewhat iffy memory, wait for verification from Festool. 

(By the way, the 125 has seen a quite bit of use, Thanks! )

Dan

Offline Peter Halle

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #2 on: October 27, 2009, 09:16 PM »
Chuck,

A Dan said, wait for the answer from Festool, although in this litigious world I would expect either a non answer or a no answer.  This is a perfect example of a situation where a manufacturer could set themselves up to make a mint or protect themselves.  I honestly hope that I am wrong this time. 

Peter
Disclaimer:  I have been involved with the development of some TSO Products.  I have offered thoughts and ideas freely.  I am not paid but I may receive products during the development process or afterwards.

Offline Inner10

  • Posts: 184
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #3 on: October 27, 2009, 11:09 PM »
Thats an excellent question, I was putting off the purchse of my next vac because I can see the day where all remodeler's are required to have HEPA vacs here.

I would assume Festool would be a little more concerned with the european market and their restrictions first.

Offline Charimon

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #4 on: October 27, 2009, 11:33 PM »
Look at the EU  sites and you will see different ratings on their vacs.  as Festool vacs are made by other manufactures i am sure that the ratings will be available somewhere. ::)

Craig
"The existence of the flame thrower proves that at one time, somewhere, somebody said, " You Know, There's a group of people over there that I'd like to set on fire right now but they're too far away."

Offline WarnerConstCo.

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #5 on: October 28, 2009, 01:12 AM »
As of right now, everyone is confused, trust me.

Dan, you want to go to a class we are setting up in Indy?

Offline Alex

  • Posts: 5506
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #6 on: October 28, 2009, 05:46 AM »
Can you tell me whether or not the Festool vacs with HEPA filters are suitable and allowed for lead dust removal and containment for the upcoming EPA requirements for renovators?

I can't comment on your situation in America but here in Europe they would probably not suffice. Hazardous materials need a so called 'absolute' filter which means NO dust can escape the vac. In Festool's case, this would be the Special application dust extractor SRH 45. Knowing you're in America though, your rules are perhaps/probably a bit more lenient.

To be sure, you'd better turn to some government environmental agency for this information, before you blow a lot of money on the wrong vac.

Offline Chuck Kiser

  • Posts: 150
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    • Knollwood Construction Company
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #7 on: October 28, 2009, 06:37 AM »
Can you tell me whether or not the Festool vacs with HEPA filters are suitable and allowed for lead dust removal and containment for the upcoming EPA requirements for renovators?

I can't comment on your situation in America but here in Europe they would probably not suffice. Hazardous materials need a so called 'absolute' filter which means NO dust can escape the vac. In Festool's case, this would be the Special application dust extractor SRH 45. Knowing you're in America though, your rules are perhaps/probably a bit more lenient.

To be sure, you'd better turn to some government environmental agency for this information, before you blow a lot of money on the wrong vac.


That is the problem here Alex. The EPA (federal) and state level information is so convoluted that you can't make heads or tails of it. My biggest gripe (I have many) is that for most of the work that could cause the type of condition is not required to have permits. Sooooooo how does the local building official even know when enforcement is required. I see some forward thinking construction pros trying to do the right thing getting blown out of the water, price wise, by the rest of the remodelers who don't know or care about the EPA lead requirements.
Life is too short for bad wine or cheap tools.

FS2700, FS1400(2), TS55, TS75, CT Midi, CT 22 w/ boom, ETS150/5, RO150, DF500, OF1400, OF1010, MFT1080(3), PS300, DX93, LR32, MFS700, MFS400, MFK700, ETS125, RTS400, RS2E, KAPEX, MFT/ KAPEX

Offline Inner10

  • Posts: 184
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #8 on: October 28, 2009, 07:24 AM »
Quote
The EPA (federal) and state level information is so convoluted that you can't make heads or tails of it. My biggest gripe (I have many) is that for most of the work that could cause the type of condition is not required to have permits. Sooooooo how does the local building official even know when enforcement is required.

Chuck your absolutly right, it won't be enforced.

Although it would make a good sales pitch against thoes that arn't willing to spend the money on the proper vacume.  When I bid jobs I always tell people to ask for proof of licence/insurance.  I would add it to my little pitch to ensure that others have the proper vacume, may help weed out some of the riff-raff.

Offline Holzhacker

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #9 on: October 28, 2009, 09:34 AM »
Unless you are going to be doing federally funded jobs I wouldn't worry about meeting those requirements to the letter. I don't see local officials having the manpower or knowledge to enforce such rules. On a federally funded job you would like have to provide documentation that the equipment you are using meets the requirements, whether anyone actually checks that onsite would be another story. I wouldn't be surprised if there are enough exclusions to keep small jobs from not coming under the requirements. Besides you would likely have to acknowledge the presence of lead in the first place. Is that something you or your client are licensed to do? Probably not so don't sweat it. IL has a lead testing license requirement. The class, etc will run about $1000.00 to get a IL license and then after some other requirements (forget the details, looked it up last year) you can then get EPA certification. IL has a list of approved educators for licensing and service providers on the state website.
"The Code is not a ceiling to reach but a floor to work up from"

Offline Christian Oltzscher

  • Festool Employee.
  • Posts: 157
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #10 on: October 28, 2009, 10:05 AM »
Thank you for the question.

At this point we cannot answer your question. It is difficult to get a definitive answer. We are in contact with different authorities to
find out what the requirements actually are. As soon as we can give you a solid answer, you will hear from us.

Independent from any EPA requirements, we always have been concerned for the health of our customers (and their customers). This is why we deliver all CT22 and CT33 vacs with Hepa filters. And this is why we design all of our tools with superior dust extraction.

Keep in mind that the filtration
is just the very last step in dust extraction. Only the dust that reaches the Hepa filter can be filtered. If your tool doesn't pick the dust up, but
throws it all over the place, the Hepa filter won't do you any good. And if the dust sticks to your workpiece, your clothing, the tool, and the hose,
because you are not using an antistatic system, the dust won't make it to the filter.

For us this is less a question of EPA requirements and regulations. It is a question of providing the best dust extraction available, no matter
what the requirements are, because we believe in the benefits of good dust extraction for you, your customers, your tools, and the environment.

Thanks,

Christian





Offline Chuck Kiser

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #11 on: October 28, 2009, 10:45 AM »
Thank you Christian. That is about what I thought. These types of changes will take along time to integrate into the building codes, practices and the manufacturers who support them.

Regards,
Life is too short for bad wine or cheap tools.

FS2700, FS1400(2), TS55, TS75, CT Midi, CT 22 w/ boom, ETS150/5, RO150, DF500, OF1400, OF1010, MFT1080(3), PS300, DX93, LR32, MFS700, MFS400, MFK700, ETS125, RTS400, RS2E, KAPEX, MFT/ KAPEX

Offline WarnerConstCo.

  • Posts: 4076
    • Warner Mill Works
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #12 on: October 28, 2009, 11:36 AM »
I typed a big long reply, figured I wasted my time.

If you are that ignorant, that you think it wont affect you, better start saving your money for the fines now.

Offline Holzhacker

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #13 on: October 28, 2009, 12:07 PM »
What? What are you mad about, please explain. [huh]
"The Code is not a ceiling to reach but a floor to work up from"

Offline WarnerConstCo.

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    • Warner Mill Works
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #14 on: October 28, 2009, 01:44 PM »
I'm sorry, I dont want to skate around a federal law.  It affects every house pre-1978, that is a lot of houses.

It's an issue when there are children living there, especially under 12.

I believe that anymore than a 6 sq/ft area will require some form of containment/protection.

It is not up to a building inspector to regulate this.

You will be required to present a pamphlet to the ho that shows proper containment procedures, and what lead paint can do to them.

If you want to skate the issue and not do anything about it, then save some money for fines.  They will be making examples out of people.

Offline Holzhacker

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #15 on: October 28, 2009, 03:08 PM »
I'm also not interested in 'skating around federal law'. I think it is important to look at this issue within the context of the world we work and live in. Is it an issue, Yes. Is it good that there are new regulations, Probably. However jumping the gun about how to deal with this and whether or not to buy a new Vac now or later based on 'possible' needs doesn't make much sense either.
Are you going to assume that every pre 1978 house you go look at a job at is going to have lead paint? Are you qualified, licensed, trained to make that assessment? Do you have a testing kit or an account with a testing lab to send samples to for testing? Are you going to demand the homeowner test, verify and provide you with documentation prior to you being WILLING to work on their house? If the place has been rehabbed at all over the last 3-4 decades any lead paint is either gone or fully encapsulated by layers of new paint. Once again who is going to assess that, the carpenter?
Hello, Mr. Homeowner, yes I would love to remodel your kitchen but first I have to test these samples to see if they contain lead paint. If they do it will add $2000 to the cost of the job to encapsulate the kitchen, provide air filtration and proper disposal. Can I have a check to start now, please?
How many jobs do you think you will actually get? How about NONE. Either the cost will be too high or they will think you are a scammer. Sorry I think you are putting the cart before the horse on this one. Not enough info about whether or to what extent the new regulations will apply to small RES rehab.
I agree contractors should do a much better job of handling and recycling construction materials. The guy should just buy whatever Vac he wants now. Next year is next year.
"The Code is not a ceiling to reach but a floor to work up from"

Offline WarnerConstCo.

  • Posts: 4076
    • Warner Mill Works
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #16 on: October 28, 2009, 04:09 PM »
Yes, I will.  Everytime I go look at a project next year, after April, I will be giving the HO a copy of the pamphlets and expect them to read over them and ask questions about what will need to be done.

It is a way to set yourself apart from the truck and ladder rack guys that are running rampent right now, under bidding everything, just to keep busy, even at a loss. 

I am in this field because I enjoy it and I like to make a profit.  Carpenters don't have to be poor, we should all be well paid (we will always be in demand)

I am not going to sit around and wait for the new laws to be in effect and then have to scramble to conform to them.

I suppose you just rip out asbestos and despose of it, because no one is watching.

It's all about having a safe environment for the people that live in the house while you are working on it.
I dont care what kind of Vac he gets, all I care about is doing the right thing.

Yes, I am going to assume that there is a possibility of lead paint in every pre-1978 house.  I would rather err on the cautious side.
Part of the whole classes and certification is so as a responsible carpenter/contractor, you ensure the health, safety and well being of all involved in the project, from grandpa Earl, the 6 month old baby and the family pet.

Offline dsweetser

  • Posts: 129
  • Adirondack, NY USA
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #17 on: October 28, 2009, 04:14 PM »
Perhaps you should look at the EPA site, epa.gov/lead/, which spells out the rules and regulations effective April 22, 2010. You will have to test. You will have to follow procedures. You will have to be trained & then obtain certification from the EPA.
Don

Offline WarnerConstCo.

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #18 on: October 28, 2009, 04:28 PM »
Perhaps you should look at the EPA site, epa.gov/lead/, which spells out the rules and regulations effective April 22, 2010. You will have to test. You will have to follow procedures. You will have to be trained & then obtain certification from the EPA.

 [thanks]

Offline Tom Bellemare

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #19 on: October 28, 2009, 05:49 PM »
Apparently, renovation contractors are already required to provide their customers this pamphlet if the house is pre-1978.

The following is an excerpt from the pamphlet...


Quote
Federal law requires that individuals receive certain information before renovating six square feet or more of painted surfaces in a room for interior projects or more than twenty square feet of painted surfaces for exterior projects in housing, child care facilities and schools built before 1978.
  • Homeowners and tenants: renovators must give you this pamphlet
    before starting work.
  • Child care facilities, including preschools and kindergarten classrooms,
    and the families of children under the age of six that attend those facilities: renovators must provide a copy of this pamphlet to childcare facilities and general renovation information to families whose children attend those facilities.

Also, beginning April 2010, federal law will require contractors that disturb lead-based paint in homes, child care facilities and schools, built before 1978 to be certified and follow specific work practices to prevent lead contamination. Therefore beginning in April 2010, ask to see your contractor's certification.


It's just around the corner...


Tom
Tom Bellemare
Customer Svc
Tool Home LLC
www.tool-home.com
512-428-9140

Offline vteknical

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #20 on: October 28, 2009, 07:02 PM »
Fortunate for vacuum mfg's, it just says a Hepa vacuum.   Hepa Filters do not make vacuums any better if they are not designed with emissions in mind.
   

If they said Hepa certified vacuum that's a whole new ball game.  That would means the entire vacuum cleaner is as efficient as a Hepa filter, which would put vac prices in another category all together.

Offline Charimon

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #21 on: November 17, 2009, 11:28 PM »
I am revisiting this thread because i am in the middle of the Lead ABATEMENT supervisor course. Air samples, Action level, containment, respirators, decontamination sites.  Omaha is a Federal Superfund  [eek] site and i may be changing my focus to where the Government will be throwing  several hundred millions of dollars for the next 15 years..

this is the 5 day course for abatement projects and not the renovators course ................The wording in the HUD ,EPA, Guidelines and OSHA 1926 say HEPA filtered Vac What this means is there is only filtered air exiting the vac.  this would include air being used to cool the motor.

Is this the case with the CT vacs?
"The existence of the flame thrower proves that at one time, somewhere, somebody said, " You Know, There's a group of people over there that I'd like to set on fire right now but they're too far away."

Offline Holzhacker

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #22 on: November 18, 2009, 08:45 AM »
Great timing for this to come back around. Does anyone know or have a link to the approved/disapproved removal methods? Client called yesterday asking if using a heat gun to remove lead paint from trim and windows was allowed or not. I told her I didn't think it was a good idea and wouldn't recommend it due to the potential fumes. Told her I'd look into what is approved or not. BTW why do you ask? Turns out their contractor is removing lead paint from windows and trim in a unit using a heat gun. Tenant is complaining of fumes and headaches. The tenant wants the client to pay for a hotel room.
Markus
"The Code is not a ceiling to reach but a floor to work up from"

Offline greg mann

  • Posts: 1800
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #23 on: November 18, 2009, 12:48 PM »
Tenant deserves protection. This may not be what the client wants to hear but people deserve to be safe.
Greg Mann
Oakland, Michigan

Offline Charimon

  • Posts: 651
  • Tool and Tile Junkie
Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #24 on: November 18, 2009, 05:45 PM »
Holtzhacker

The tenet should not even be in a lead work area.  [scared]  The area designated a lead work area by signs.  The proper worksite preparation level containment erected.   The work completed. And the site properly decontaminated.  If the job lasts more than a day there are other things that need to be done.  This requirement will all come into effect for every remodel or renovation in any home built before 1978, Apr of 2010


An electric heat Gun under 1100 F is acceptable. liquid Stripers,  Wet sanding and Scraping are allowed.  Hepa attached tools are allowed.  HUD guidelines Abatement. Chp 12 page 12-33. I believe the LS 130  Ets and Rotex sanders and The Trion Jig saw with all attached covers would based on FIG 12-16 and the description of such tools found in Chapter 12 Section IV.D.2  Mechanical Removal Methods (pages 12-39, 40, 41),  fit Hud guidelines.


OSHA has nothing to say, 29 CFR 1926.62 Lead, about methods only that lead exposure be kept below action levels  (For the protection of the worker they dont care about tenents) before action is taken (not going to elaborate here)


Craig

Unless this is an historic area they would be much better off replacing windows.  ie Cheeper to remove and replace than to fix and repaint.





« Last Edit: November 18, 2009, 08:44 PM by Charimon »
"The existence of the flame thrower proves that at one time, somewhere, somebody said, " You Know, There's a group of people over there that I'd like to set on fire right now but they're too far away."

Offline Rick Christopherson

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #25 on: November 18, 2009, 07:09 PM »
No, the motor cooling intake port is on the side of the vac and is not filtered. You can see this a little more obviously when you open the lid on the vac, as the vent is part of the upper chamber, and you can feel the suction from the vent too. I have not seen the new vacs yet, so I don't know if this aspect of the design has changed.

It has been 20 years since I did any industrial hygiene oversight, but I would think this requirement has some qualifications to its applicability. If the vac is used exclusively for inside containment, or exclusively for outside containment, then it logically shouldn't matter. However, I assume this was added because there is no guaranty that the vac would not change duties from one project to the next, and contamination ingested at one project site could be expelled at another project site.

Offline Brice Burrell

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #26 on: November 18, 2009, 08:29 PM »
Thanks Rick.
Check out my new blog, The Green and Dark Blue Blog.

Offline Holzhacker

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Re: Festool HEPA filter vacs and the EPA Lead rqmts.
« Reply #27 on: November 18, 2009, 08:57 PM »
Thanks for the replies and info. After all these years I still fail to fully understand why clients/landlords do some of the things they do. Supposedly the contractor put some plastic up. I doubt there is actual containment. If it were me, I would have replaced the windows just from an energy standpoint alone. Stripper isn't that hard to use for trims once you get the hang of it. A friend of mine used to own a stripping shop. People would bring in doors, sash old big trim, hutches. He died prematurely. The way he used to get sick a lot, it wouldn't surprise me if all the chemicals took some years off of him. He's actually sitting on my bookshelf next to me right now, (his remains).
Markus
"The Code is not a ceiling to reach but a floor to work up from"