New EPA Lead Dust Rules, An Official Festool Perspective?

N

nycneal

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Joined
Sep 10, 2009
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17
Apologies if this has been asked and answered before. The answer will be news to me.

The EPA's new Renovation, Repair and Painting (RRP) rules go into effect in April. One of the prime directives is KEEP THE (potential lead) DUST DOWN.

HEPA-filter vacuums will play a key role in all this.

Does anyone know if Festool has issued a formal statement about how well the dust collectors conform to these new rules?

It would provide the customers at least one reassurance in the flurry of forms they'll be receiving after April.

It will also reassure accountants and partners about the need/expense for such good tools. Now they're "required" by law.

Thanks.

Neal
 
Here is the last response we at the Forum have had here from Festool that I am aware of from October 28, 2009. 

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
Click to expand...
 
While I am no expert on the regulations and restrictions, there is yet another advantage to Festool's DCs besides hepa. The exhaust air can be vented outside by way of adding another hose to an outlet port. In essence, the air is hepa filtered and then disposed off to the outside atmosphere. Of course all this is after the superior dust collection at the source as well.
 
Neal, RRP instructors aren't recommending any specific brand or model that meets the EPA's standard from what I understand. It's very unlikely we will hear anything since the EPA's definition of HEPA filtered vacuum is so vague. There is speculation that ANSI will set a HEPA standard in the near future and the EPA may adopted that standard. Until then don't expect much in the way of reliable info. 
 
here is one point that needs to be mentiioned. It is not EPA but OHSA that sets the standard for HEPA  both HUD and EPA follow the OSHA standard.  OSHA sets the standard through regulation they do not approve any tool, either the tool meets the regulator specifications or it does not.  This is determined by third party testing labs. 

OSHA/NIOSH/HUD/EPA: interaction, area of responsibility, and enforcement took up almost 1 full day of my 5 day abatement training
Craig
 
Charimon said:
here is one point that needs to be mentiioned. It is not EPA but OHSA that sets the standard for HEPA  both HUD and EPA follow the OSHA standard.  OSHA sets the standard through regulation they do not approve any tool, either the tool meets the regulator specifications or it does not.  This is determined by third party testing labs. 

OSHA/NIOSH/HUD/EPA: interaction, area of responsibility, and enforcement took up almost 1 full day of my 5 day abatement training
Craig
Click to expand...

As far as I can tell the EPA has cited no OHSA (or any other) standard for HEPA vacs in the new RRP rules. It seems to be very unclear if or when any official standard will be adopted. In other words, sit tight for as long as you can.
 
I see doom for older houses.
This may not turn out very well for a lot of people.
It will really piss me off if they blow me crap about working on my own 120 year old farm house.

This all does not sit well.
It is really just more hassle than anything.
 
I would really appreciate a response soon from Festool on these Vac's. I'm scheduled to take the course on Feb. 18th and I'd like to believe that I'm already tooled up for this work. If not, I need to know so I can get ready by buying the appropriate equipment.

I currently have a CT-33 that is a permanent set up in my shop and would like to get a CT-22 for portable use. If it doesn't meet the standards set by the EPA in the RRP rule then I need to get something else.

The sooner this info comes out the better... 
 
Jason W said:
I would really appreciate a response soon from Festool on these Vac's......
Click to expand...

Don't blame Festool or any other manufacturer. There is no test or standard cited in the RRP law for manufacturers to meet. They are in the dark just as much as we are. Until a standard is adopted no one will know what vacs will be officially accepted. There seems to be no consensus if or when that will happen. 
 
Quote:
HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particles of 0.3 microns with 99.97% efficiency. The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the HEPA filter with none of the air leaking past it.

This the best I can find from the rules and regs.

Check your stats on the CT's and you should realize they will exceed the minimums.
 
745.85 Work Standards
Quote:
(ii) The use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited unless such machines are used with HEPA exhaust control.
745.227 (abatement)
Quote:
(ii) Machine sanding or grinding or abrasive blasting or sandblasting of lead-based paint is prohibited unless used with High Efficiency Particulate Air (HEPA) exhaust control which removes particles of 0.3 microns or larger from the air at 99.97 percent or greater efficiency;

couple more parts.
 
THe only thing I see is osha approved hepa filter in a sealed vac that filters to .3 microns and 99.97% extraction.

Now who in the heck is going to be able to measure the 99.97% number out in the field.
Good luck on them policing that.
 
Brice Burrell said:
Jason W said:
I would really appreciate a response soon from Festool on these Vac's......
Click to expand...

Don't blame Festool or any other manufacturer. There is no test or standard cited in the RRP law for manufacturers to meet. They are in the dark just as much as we are. Until a standard is adopted no one will know what vacs will be officially accepted. There seems to be no consensus if or when that will happen.   
Click to expand...

Actually, they do.

Pg. 44 "ii. Final rule requirements. Vacuums used as part of the work practices being finalized in this final rule must be HEPA vacuums, which are to be used and emptied in a manner that minimizes the reentry of lead into the workplace. The term ??HEPA vacuum?? is defined as a vacuum which has been designed with a HEPA filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particles of
0.3 microns with 99.97% efficiency. The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the filter with none of the air leaking past it"

and "When cleaning carpets, the HEPA vacuum must be equipped with a beater bar to aid in dislodging and collecting deep dust and lead from carpets. The beater bar must be used on all passes on the carpet face during dry vacuuming."

Pg. 45 "One commenter contended that HEPA vacuums with beater bars were not currently available on the market at the time comments were submitted. However, EPA has been able to identify commercial vacuum manufacturers as well as department store brands that currently offer HEPA vacuums with beater bar attachments."
 
Also from Pg. 46 "EPA also disagrees with the commenter that suggested that vacuums that are retrofitted with a HEPA filter should be considered sufficient for purposes of this rule. These vacuums are not necessarily properly sealed or designed so that the air flow goes exclusively through the HEPA filter. EPA agrees with the commenter who stated that HEPA vacuums are vacuums which have been designed for the integral use of HEPA filters, in which the contaminated air flows through the HEPA filter in accordance with the instructions of its manufacturer and for which the performance standard for the operation of the filter is defined. EPA also agrees with those commenters that contended that the rule should contain a more-specific definition of HEPA vacuum. Accordingly, this final rule defines ??HEPA vacuum?? as a vacuum which has been designed with a HEPA filter as the last filtration stage and includes a description of what the term HEPA means. The definition of ??HEPA vacuum?? also specifies that the vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the filter with none of the air leaking past it."
 
Jason W said:
Actually, they do.

Pg. 44 "ii. Final rule requirements. Vacuums used as part of the work practices being finalized in this final rule must be HEPA vacuums, which are to be used and emptied in a manner that minimizes the reentry of lead into the workplace. The term ??HEPA vacuum?? is defined as a vacuum which has been designed with a HEPA filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particles of
0.3 microns with 99.97% efficiency. The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the filter with none of the air leaking past it"

and "When cleaning carpets, the HEPA vacuum must be equipped with a beater bar to aid in dislodging and collecting deep dust and lead from carpets. The beater bar must be used on all passes on the carpet face during dry vacuuming."

Pg. 45 "One commenter contended that HEPA vacuums with beater bars were not currently available on the market at the time comments were submitted. However, EPA has been able to identify commercial vacuum manufacturers as well as department store brands that currently offer HEPA vacuums with beater bar attachments."
Click to expand...

Jason, the point is there is not an official standard cited for their terms "a vacuum which has been designed with a HEPA filter as the last filtration stage" or "The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the filter with none of the air leaking past it". You will not the only item defined specifically is the HEPA filter. The term HEPA filter is defined by OSHA and NIOSH as the same. However, I don't believe there is such a thing as a HEPA certified vacuum. I'm not sure but there might be vacuums certified for lead abatement but that's not the same thing. The EPA's definition is very vague to say the least. That's why we aren't seeing any certified HEPA vacs according to the RRP law.   

Jason, when you take the class I bet you won't be able to pin the instructor down on a vacuum officially accepted by the EPA for RRP work. Remember just because a vacuum used by the instructor doesn't mean it's officially accepted. This whole RRP thing is a mess, that's why I'm rushing out to get RRP certified.
 
Brice Burrell said:
Jason, when you take the class I bet you won't be able to pin the instructor down on a vacuum officially accepted by the EPA for RRP work. Remember just because a vacuum used by the instructor doesn't mean it's officially accepted. This whole RRP thing is a mess, that's why I'm rushing out to get RRP certified.
Click to expand...

Brice
That is correct but not accurate  The EPA does not accept (officially or otherwise) Vacuums ,  that is not their job.  If the instructor is any good he will be able to point to any number of Vacuums that meet all regulatory requirements for RRP and he will be 100% positive that they will pass!    Nilfisk, Pullman/Holt, Minuteman all make vacs that meet these standards.  I love my Attix 8 HEPA  http://www.nilfisk-alto.us/upload/8880031_attix_8_12_001.pdf  The Hepa is $519  This is the same VAC that Festool sells in Europe for use with the Planex  Maybe they should import some to meet the RRP rules as Nilfisk has already passed all the certs.

Craig
 
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