EPA Waffles on Which Vacuums Can Be Used to Clean Up Lead
Contractors seeking to comply with the new Renovation, Repair, and Painting (RRP) rule know what supplies they need to buy: tape, polyethylene sheeting, mops, wipes, and the like. What they may not know is which HEPA vacuum to use for cleanup in buildings containing lead. Under the RRP, a HEPA vacuum is defined as one that “has been designed with a high efficiency particulate (HEPA) filter as the last filtration stage.” But the definition does not include any standard for testing or certifying the machines, and it’s not yet clear how EPA inspectors will decide which vacuums qualify. The agency chose not to provide a list of approved vacuums because models are constantly changing.
An official EPA commentary on the development of the RRP sheds some light. (Both it and the 20-page rule are part of a 79-page document the agency has made available to the public. You can download a copy at epa.gov. According to this commentary, the EPA did not intend to approve the use of inexpensive vacuums retrofitted with HEPA filters. Such vacuums “are not necessarily properly sealed or designed so that the air flow goes exclusively through the HEPA filter,” the agency has found; instead, the vacuum should be designed for the “integral use of HEPA filters” (see page 46 of the pdf). The RRP requires vacuum cleaners to 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” (page 69).
This 79-page document contains the new lead rule itself (which runs about 20 pages), commentary about its development, text from the lead-hazards pamphlet that renovators are required to give homeowners, and lots of other information. You can download a pdf from the EPA’s Web site (epa.gov).
Vacuums leak. Leaks have always been a problem with vacuum cleaners. Gore CleanStream, which manufactures retrofit filters for Ridgid, Craftsman, Shop-Vac, and Genie machines, says its HEPA filters should not be used to collect hazardous materials because the vacuum might leak. And Tom Wangerin, an environmental consultant and long-time trainer of abatement contractors, cautions that “even the good vacuums tend to leak and must be adjusted before use. If we’re involved with an environmental cleanup, we get the vacuums tested.” According to Wangerin, the existing methods for testing vacuums were developed for the nuclear industry and are impractical for use on most job sites.
The Indoor Environmental Standards Organization (IESO) is developing a standard known as PHEAF testing, which would make it easier to test portable vacuums. This method uses a hand-held laser particle counter to compare the number of particles going into the vacuum with the number coming out. Tom Neltner of the National Center for Healthy Housing suggests that “the EPA could come out and say, ‘If a vacuum meets the IESO standard it probably meet ours.’” There is, however, a drawback to counting the particles in a vacuum’s exhaust air: A laser particle counter cannot distinguish between particles of lead that bypass the filter and metal shavings, carbon dust (from brushes), and lubricant coming out of the motor.
What qualifies as HEPA? The EPA defines a HEPA filter as one capable of removing at least 99.97 percent of particles down to 0.3 microns in size. Although standards exist for testing filters, the EPA chose not to include them in the RRP. In the absence of a specified standard, there’s no way to be certain that a particular filter complies.
Most of the industrial-grade vacuums used by lead- and asbestos-abatement contractors have filters that have been individually tested and certified, usually to MIL-STD-282 (the U.S. military standard) or IEST-RP-CC007 (an Institute of Environmental Science and Technology standard). The vacuums themselves typically accept only HEPA filters that, to prevent leaks, are tightly bolted or clamped to the machine.
JoAnn Copperud, an RRP trainer for RGA Environmental, an environmental consulting firm, recommends buying an industrial-grade machine like a Nilfisk GD930, a $600 canister-style vacuum that’s popular with lead-abatement contractors. According to Copperud, “any vacuum good enough for lead and asbestos abatement is good enough for the RRP. It will be more expensive than the cheap shop vacs contractors are accustomed to, but it will work a whole lot better.” Among the better-known makers of industrial HEPA vacuums are Nilfisk, Euroclean, Pullman-Holt, Nikro, Minuteman, Kent, and Mastercraft.
It’s not clear how the dust-collecting vacuums commonly used by carpenters will fare under the rule, because most can be equipped with more than one kind of filter. Darren Diess of Dustless Technologies says he is aware of instances where OSHA objected to contractors vacuuming lead dust with machines that take more than one kind of filter. This is because inspectors want to be able to look at the machine and know what kind of filter it contains without having to open it. According to Diess, the HEPA version of his company’s vacuum takes only HEPA filters tested to IEST-RP-CC007.
Bosch and Porter-Cable say their dust-collecting vacuums should not be used to collect toxic materials like asbestos or lead, even when equipped with optional HEPA filters. Fein, on the other hand, has issued a letter stating that its dust extractors comply with the RRP because they’re “designed to provide internal HEPA infiltration.” If the EPA decides to exclude vacuums that accept both HEPA and non-HEPA filters, this could spell trouble for current models from Fein, Festool, and Hilti.
The safest bet. Until the EPA clarifies what it will and won’t accept, there’s no way to know for sure which vacuums — or filters — meet the new regulations. But in the interim, remodelers who don’t want to wait can probably safely assume that any pro-duty HEPA vacuum used in the abatement industry is good enough. — David Frane