Since April 2010, the EPA requires contractors to be certified and to adhere to lead-safe work practices when doing renovation work on pre-1978 target housing. This requirement falls under the Renovation, Repair and Painting Rule, which is designed to protect occupants of residential property from exposure to lead dust.
A large part of the regulation addresses work practices to limit, contain and clean up dust, which results from renovation, repair and painting operations on pre-1978 homes. One of the most important tools in the RRP process is the HEPA vacuum
What is HEPA?
HEPA, which stands for High Efficiency Particulate Air (filter, filtration), is used in connection with vacuum filters and vacuum cleaners, respirators, air purifiers, etc.
A HEPA filter: is a filter that can remove particles of 0.3 micrometers or larger from the air at 99.97 percent or greater efficiency
A HEPA Vacuum: is defined in the RRP rule 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 (1)
The EPA has further interpreted that definition in the questions and answers portion of their website stating:
- Therefore, renovation firms should look for a vacuum cleaner that was 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. EPA also recommends that renovation firms 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% of 0.3 micron particles). (2)
.
Commercial HEPA Vacuum
A commercial HEPA vacuum, made for the vacuuming of hazardous materials, must be sealed so that air does not leak past the filter. The HEPA filter is the final filter on the machine. There will usually be one or more pre-filters that catch the big stuff upstream before it reaches the HEPA filter. This method insures that:
- 1. The HEPA filter does not get clogged up quickly with debris
and
- 2. The HEPA filter is protected from large chunks of stuff that could damage the filter.
Remember, a cut or gash or any breaks in the HEPA filter renders the filter useless, and makes it no longer a “HEPA” filter.
Shop Vac HEPA filter (above) is intended for retrofitting on a Ship Vac. The filter shown above is one of the better standard shop vacuum HEPA filters.
Note: the metal grid is on the inside, but not on the outside.This is an excellent HEPA filter for non-hazardous pick-up, and can be used to clean up after projects like dustless drywall sanding. It is not recommended for hazardous debris (lead, asbestos, etc.) pick up.
HEPA Attachments
The Beater Bar
The requirement for a “beater bar” floor attachment was put into the RRP regulation to help better clean carpeted surfaces. The beater bar agitates the rug or carpet, helping the vacuum to suction the debris or dust from the carpet more thoroughly than is possible when simply suctioning the carpet with the vacuum.
Shrouds for Mechanical Sanders Etc..
Mechanical sanding, planing, shaving etc. is a prohibited practice, unless the mechanical device is attached to a HEPA vacuum.
Read below:
"Use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines are used with HEPA exhaust control;" (3)
"If the sanding or grinding machines are “shrouded,” which means surrounded with a barrier that prevents dust from flying out around the perimeter, AND attached to a HEPA
vacuum, they can be used." (4)
Shrouds are brush-like enclosures that encompass the sanding head and help to contain the dust within the shrouded enclosure for the HEPA vacuum. The dust is pulled from the enclosed shroud into the vacuum’s collection bag.
The Chip Buddie
The Chip Buddie is not a required attachment (unlike the beater bar floor attachment), but it helps to ensure that paint chip debris does not leave the work area. The Chip Buddie is a hand scrapper attachment for vacuum-scraping. You attach this accessory to your HEPA vacuum hose and scrape the loose paint from the substrate during surface preparation. It is helpful to pre-wet the surface to keep dust from becoming airborne. You can mist the surface with a spray bottle or pump sprayer, then, using the Chip Buddie, vacuum-scrape the loose debris into your wet/dry HEPA vacuum. If you can vacuum the paint scrapings, the amount of debris that falls to the ground will be minimized. The longer the drop to the ground (plastic covered), the greater the drift of the debris will be during the fall. You may need to enlarge the ground plastic to ensure that you catch the debris falling from greater heights. However, the Chip Buddie greatly reduces the amount of falling debris.
Conclusion
For pre-1978 "target housing," the certified painter or renovator must use a HEPA vacuum for clean-up. A shop vacuum retro-fited with a HEPA filter is useful for non-hazardous, post-1978 jobs (in particular new drywall dustless sanding), but is not (by EPA's definition) a HEPA vacuum for purposes of the RRP rule.
Footnotes:
2. Frequent Questions. EPA website. What should I look for when purchasing a HEPA vacuum?
3. Small Entity Compliance EPA, Page 10.
4. Lead Paint Safety U.S. Department of Housing and Urban Development Office of Healthy Homes and Lead Hazard Control, Page 11
EPA requires a HEPA Vacuum
So, whether one should use a HEPA vacuum or a vacuum that is HEPA filtered is determined, in some cases, by the seriousness of the debris being vacuumed. A HEPA filtered house vacuum or shop vacuum manufacturer probably does not intend for you to vacuum up lead dust with their vacuum.
I don’t doubt the fact that the filters on HEPA filtered house and shop vacuums are truly HEPA filters, but the problem is in the seal of the filter in the vacuum, which makes it possible for air to leak past the filter.
Nilfisk Eliminator I and II are shop vacuum style HEPA vacuums.
Nilfisk has a large line of commercial HEPA vacuums.
The Minuteman Lead Vac is a 6 gallon tank ULPA filtered vacuum with 99.99% filtration of particles greater than 0.12 microns
Dustless Technologies HEPA filter enclosed in a metal "cage" for protection. Note: the gasket on top which ensures a airtight seal. The filter is bolted into place, with the gasket forming an air-tight seal.
Retrofitting a HEPA filter on a shop vacuum is not considered a HEPA vacuum by the EPA. The vacuum and filter must be designed to be used as a complete unit. It must also be the final filter on the machine
The whole HEPA vacuum system (filter and vacuum) should be designed for hazardous materials pick-up, and the system should be tested (see Dustless Technologiies HEPA Cert.) for air bypassing the filter and for true HEPA filtration.
Shop Vac HEPA filter excellent for dustless, new drywall sanding, is not for hazardous material pick-up.
Metal cages
Most commercial HEPA vacuums feature a cage with the filter to protect it from tears and cuts. The filter is housed inside the cage, which helps to stop the direct impact to the filter of any large objects or debris.
Multiple filters
Typically, a HEPA vacuum will employ an upstream collection bag, which is, in and of itself, a filter, too. Downstream from this filter will be the final HEPA filter. There may be an intermediate filter somewhere between the two as well. This system of multiple filters allows the upstream filter to catch and hold the bigger particles, leaving only the fine dust to flow further downstream and be caught by the intermediate filter and/or HEPA final filter.
Dustless Technologies universal dust containment shroud.
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Affordable HEPA Vacuum
Model 16006
Dustless HEPA Vacuum
- Certified HEPA rated vacuum system
- Meets EPA standards for RRP Rule.
- Will NOT expel Dust
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- Tool set stores on the machine
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- Interior baffle / wall keeps the HEPA filter dry at all times.
- Meets OSHA, NIOSH and EPA (IEST) standards
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Dustless Technologies Beater Bar Floor Attachment
An air driven rotating brush powered by vacuum suction, spins and churns up debris to be suctioned away by a HEPA Vacuum. This is a required accessory for certified contractors. Used on carpeted floors.
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Dustless Technologies ChipBuddie
Vacuum Scraper
Capture the scrapings at the point of creation. Don't let all the debris fall uncomtrolled to the ground, where the wind can blow and scatter the debris. Attach to a HEPA vacuum, and capture virtually all the shavings. Used properly, very little will fall to the ground.
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HEPA Vacuums
Tools and Attachments
Bearter Bar Floor Tools
The Internet Paint Store.com
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