By now, everyone involved in residential remodeling should know about the EPA's Renovation, Repair, and Painting (RRP) rule, which requires certification and training for contractors who work on homes built before 1978. The rule took effect this past April, but the EPA has extended the date of enforcement to October 1st; training must now be completed by December 31, 2010. As of midsummer – when this issue went to print – there were still plenty of questions and confusion regarding the requirements for tools and equipment. In particular the government was still in the process of clarifying for carpenters, plumbers, painters, electricians, and other residential contractors how the cleanup and disposal of waste materials and workplace dust and debris should be handled.

Tools spoke with EPA spokesman Dale Kemery about the scarcity of information on this issue. "I went to our website [epa.gov/lead] to see if there was anything referring to tools and equipment – and there isn't," he acknowledged.

Kemery promised that the missing information would be added to the website soon. Meanwhile, he noted that "details on work practices" – including cleanup and disposal of waste materials, dust, and debris – "are available in the agency's small-business compliance guide for the rule" (epa.gov/lead/pubs/sbcomplianceguide.pdf). Even this information, he cautioned, may be amended on the EPA website as the program moves forward.

As for tools and equipment currently required under the RRP, he provided a short list: "Common construction/safety products like plastic sheeting, tape, HEPA vacuums, HEPA shrouds for tools, Swiffer mops, et cetera. All are discussed in the certified renovator course and are used to contain the work area, minimize dust, and clean up thoroughly."

He also offered a definition of what the EPA considers acceptable cleanup equipment: "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 capable of capturing particles of 0.3 microns with 99.97 percent 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."

He added that renovation contractors should look for a vacuum cleaner "designed to be operated with a HEPA filter, rather than a shop vacuum that can be fitted with a HEPA filter in place of the original basic filter. A vacuum retrofitted with a HEPA filter is not necessarily properly sealed or designed so that all of the intake air goes through the HEPA filter."

The EPA also recommends that renovators "ask the manufacturer or retailer whether the machine has been tested to ensure that it achieves the high efficiency required of a HEPA filter – capturing 99.97 percent of 0.3 micron particles." For a list of vacuums that manufacturers claim meet these requirements, click here.

Kemery pointed out that the EPA certifies only contractors, not products, and it's up to those doing the work to choose and use tools and materials specified under the ruling. Also, although personal protective equipment such as respirators and safety suits is outside the scope of this rule, such equipment may be mandated by yet another government agency – OSHA.