With all of the confusion surrounding the new requirements for remodeling work in houses built before 1978, one of the biggest sources of confusion we hear about is the HEPA vac requirement.
As I wrote in the April E-Newsletter/blog:
"Proper lead clean up will require contractors to equip their company with a HEPA vac that meets the EPA's definition as follows. "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."
The last sentence has caused a lot of confusion to date. Contractors ready to make the mandated purchase are wondering which models qualify and manufacturers have been hesitant to claim that their tools meet this "no blow-by" clause to the letter of the law because no testing protocol is in place to definitively prove this performance. Zero percent of a vac's airflow escaping around seals is a tough claim to make, and in all probability, virtually impossible to guarantee on the job."
"A spokesperson for the EPA told us that the "no blow-by" clause was intended to keep contractors from outfitting any old shop vacuum with an aftermarket HEPA filter and considering it a qualified HEPA vacuum."
Since then, several manufacturers have examined the requirements and now feel comfortable enough to make the claim that certain vacs in their product line will indeed meet the EPA's requirements as currently written. I have researched and compiled a list of these vacs for the benefit of our readers. To reiterate, the EPA does not certify vacs, or any type of products, and there currently is no test procedure specifically for RRP rule-compliant vacs. And of course, Tools of the Trade and our parent company are not qualified to designate appropriate vacs. The only entity represented here that is making the claim that these vacs comply with the RRP rule requirements are the individual vac manufacturers themselves. We cautiously recommend that you find a company's guarantee of qualification--in writing--for a vac before you buy it.
The rationale here is that if the EPA requires a vac that meets a certain standard of performance but there is no easy way for an individual to determine an individual vac's suitability, a written guarantee of compliance from the manufacturer should be enough to satisfy an inspector who has doubts about your vac. This is, at the very least, a reasonable attempt by a contractor to fulfill the requirements as they currently stand.
So with no further ado, here's the list.
(An asterisk indicates the manufacturer's product choice for contractor use.)
- Bosch: Airsweep HEPA
- Dustless Technologies: HEPA model #16006
- Fein: Turbo II HEPA model #92025
- Hilti: VC20-U HEPA and VC40-U HEPA
- Metabo: ASR2050 with HEPA set
- Mastercraft: Backpack Vacuum, *Enviromaster CT-5, Enviromaster 7, HEPA Poly wet/dry vac, HEPA steel dry vac
- Minuteman: BPV HEPA backpack vac, Lead vac, Microvac, X250 wet/dry, X829 Series
- Nikro: LV02, LV10, LV15, LVW15 wet/dry
- Pullman-Holt: 390ASB, 45HEPA Dry
- Nilfisk brands: (some vacs may be the same, but sold as a different model under different brands)
- Advance: *AWD HEPA, Canistar HEPA
- Clarke: Summit 9 HEPA
- Kent/ Euroclean: GD930H, *UZ934H, UZ964H
- Nilfisk: *Eliminator 1, Eliminator 2, GD10 Backpack, *GD930 (Lead RRP), GM80, GM80i, UZ 934, 118
- Nilfisk Alto: *Attix 30 HEPA, Attix 50 HEPA
This list is by no means exhaustive; we contacted several other companies who never got back to us with verified model numbers. And according to the EPA spokesman we contacted, any certified HEPA vac sold as a dedicated HEPA vac should qualify.
If the EPA decides to add another clause to disqualify vacs that are sold in two versions--both with standard filters and with HEPA filters--manufacturers will have to act fast to assign a unique model number to the HEPA version so the HEPA filter would not be considered a retrofit. And companies that sell the vac with a standard filter and require you buy an upgraded HEPA filter to get HEPA performance would also have to sell a unique version that only comes with the HEPA filter. If the EPA decides to disqualify vacs that can work with both standard and HEPA filters (so an inspector could be sure the vac was using a HEPA filter on the job without opening it), that would throw out a lot of vacs on the list. In that case, a manufacturer would have to make their HEPA model not able to fit a standard filter by modifying the filter or mount in some deliberate way.
Both of these scenarios are possibilities, and we know of no assurance that previously-qualifying vacs would be grandfathered in to meet further refinements of the requirements.
Like we said before, we'll keep you posted.
Michael Springer
