By April 22 We need a HEPA vacuum, Does the CT33 qualify?

[mtj]

I agree with the 2 above posts--I would bet that legal counsel has said to hold off saying anything definitive.  Key to remember here, with RRP we are talking "remodeling" clean-up not "abatement", an issue that was stressed in the class.  We do not do abatement, that is a whole different animal, requires different certs and clearance.  We are just remodelers trying to clean up after our remodeling activities that may disturb some pre-1978 painted surfaces.  We are not doing lead removal or abatement.  I gave up on the Festool vac, bought a Fein 9-20-25 HEPA (Turbo II) even though it doesn't have anything written on the outside of the machine.  The HEPA filter meets the standard of 99.97% at .3 microns.  Good enough for me, time to move on and do my job. 

That said, the way EPA has bungled this whole implementation and keeps changing the rules I predict clearance testing, not just a glorified white glove test, is where this is headed sometime in the not-too-distant future.  I should also add that at least in my area, (western WA) I have heard of no enforcement actions and at least anecdotally, local building inspectors seem to have a "that's the feds, not my deal" approach so far. 

 

[Bob Marino]

Bob I have been watching this thread with interest, I think its brave of you to raise your head over the parapit. As Festool seem a little reticent. We don't have this issue in the UK......Yet.

the extractors were manufactured before the lead issue came about and as such have not been tested for use with lead paint.this much is obvious.I would have thought this might have been part of the testing as lead paint has been known to be a issue for many years.

If I lived in the states and needed to conform with these new laws I would go straight out and buy the best machine with the right stickers on it.job done.

for a small company where extractors are only a part of their line up and not their main business I can see that testing would be expensive and take some considerable time.

I doubt festool has even started testing yet as things like this take many months to set up and many more months testing, then there would be the UL issue.. more time.

I would guess the machines once tested and available for sale would need to be badged as suitable for lead paint removal, I doubt this could be applied to machines already sold and in use.

Maybe Festool should say that users should assume the machine is not suitable for lead paint removal and give a provisional date for having the machines tested.

feel free to jump all over me [big grin]

 Nah, not brave, heck what's to be brave about anyhow? I am just chiming in with little or no more info than anybody else. But you do raise good points; can't see anyone jumpin' on you for that.

Bob

 

[Bob Marino]

I agree with the 2 above posts--I would bet that legal counsel has said to hold off saying anything definitive.  Key to remember here, with RRP we are talking "remodeling" clean-up not "abatement", an issue that was stressed in the class.  We do not do abatement, that is a whole different animal, requires different certs and clearance.  We are just remodelers trying to clean up after our remodeling activities that may disturb some pre-1978 painted surfaces.  We are not doing lead removal or abatement.  I gave up on the Festool vac, bought a Fein 9-20-25 HEPA (Turbo II) even though it doesn't have anything written on the outside of the machine.  The HEPA filter meets the standard of 99.97% at .3 microns.  Good enough for me, time to move on and do my job. 

That said, the way EPA has bungled this whole implementation and keeps changing the rules I predict clearance testing, not just a glorified white glove test, is where this is headed sometime in the not-too-distant future.  I should also add that at least in my area, (western WA) I have heard of no enforcement actions and at least anecdotally, local building inspectors seem to have a "that's the feds, not my deal" approach so far.   

Good post. Correct about lead abatement; my term "lead dust" was a poor choice, as I meant  just as you mention -  clean up where lead may have been disturbed.

Bob

 

[greg mann]

In a recent article about lead paint and remodelling, in Fine Home Building IIRC, they discussed the lack of clear interpretation regarding this issue. FWIW, and that isn't much, there was a picture of a guy using a Festool CT in the article. Go figure. That was probably the best example of good practice the editor could think of. I should go back and re-read the article but the big issue seemed to be centered around just how much of an effort a remodeler puts into dust management, and how that would be judged by any enforcement personnel who have yet received to clear guidelines. In other words, "If you're trying hard to do it right, you are likely to get some leeway." While I think letting common sense prevail is nice, by itself it sure makes for poor circumstances on the jobsite. I can certainly understand why Festool hasn't responded under the present conditions because we still don't have any real clarity.

Folks doing this type of work deserve some clear guidelines regarding suitable equipment. We can argue the relative merits of source capture using Festool sanders and collecters versus any other brand tools used with any other collecters but no one has done the hard work of qualifying components, much less systems. As an example, would a 'non-HEPA certified' C22 with a Rotex be a good lead paint removal tool in the hands of a carefully masked-up operator. I would think so, and probably better than most anything else one might cobble up, especially if done so with a DC that has somehow been 'tested' as true HEPA, but teamed with a less efficient sander. But then, it doesn't matter what I think.

Good luck to all of you who need to deal with these issues.

 

[harry_]

Hi guys,
Today I got this reply from Christian.  I thought all would appreciate the info:

Re: By April 22 We need a HEPA vacuum, Does the CT33 q
? Sent to: ronaldsauve on: Today at 03:20 PM ? Quote Reply Remove   

--------------------------------------------------------------------------------
Thank you for your PM. We will publish something about this topic this week or next week, as we are in the final stages of research. We wanted to be 100% sure to give
the right advice to our customers and brought some experts in and did testing beyond the standard testing. We will publish the results on our website and on the FOG.

Best regards,

Christian Oltzscher

Just keeping this thread alive, as I believe we are all still awaiting the `official word`. [poke]

 

[WarnerConstCo.]

I am thinking the new Cleantex will be the one's.

 

[tjbier]

.

 

[tjbnwi]

I posted this in the thread for the new vacs;

http://www.toolsofthetrade.net/industry-news.asp?sectionID=0&articleID=1365162

The person interviewed set forth the EPA definition of a HEPA vac. He also states they do not certify any tool to be compliant. It is up to the contractor to determine if there equipment is compliant.

Looking at the flow chart for the new vacs it leeds me to believe they will be compliant.

If the 22 & 33 have the same flow chart they would also be compliant. The 22 & 33 have HEPA filters. If all the air is discharged through them, the vac would be compliant. Even without the bag.

The above statements assume there is no leakage in the case as required. 

Do not except a black or white answer from the EPA, the lawyers will never allow it.

Tom