Darcy, I get that
"HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency particulate air (HEPA) filter "
By definition to be a HEPA filter it must pass laboratory testing (each filter, as a completed unit--not just the media) If a filter is from the same batch as other tested filters, but hasn't been tested and documented then it is NOT a HEPA filter according to federal standard 209D (this is the governing standard) The US government Defined What is HEPA, however American consumers think that "HEPA" on some packaging means it is better....so the manufactures have responded by adding the name and using media that would meet the standards in their filters then went on to play games, guessing correctly at worse, 60minutes would do an expose, test a few and find out that the filters pass. When dealing with the Federal government we have to use their definitions so if a filter is not tested/documented it is not HEPA even if it WOULD pass the test.
Now. this is the perspective from an educated lead abatement supervisor. None of the training that i received touched upon this in my RRP class which said basically if it says HEPA and it is not a "shop vac" then you are probably ok.... [unsure] [wink] The people who will inspect your jobsite and investigate complaints will initially be lead abatement inspectors or those trained by them and this is one of the things they look for.
Thanks Craig