The Environmental Protection Agency (EPA) Lead-Based Paint Renovation, Repair and Painting (RRP) Rule has been in effect since April. Since then the EPA has introduced updates to the rule.
For example the "opt-out" provision has been nixed and the EPA has delayed enforcement of the training and certification portions (see sidebar).
Since the rule went into effect, there has also been a rush for contractors to find equipment and products that will help them comply with the rule. One type of equipment contractors need for compliance is a HEPA vacuum, necessary for clean-up at the end of a project and for attachment to power sanding and grinding equipment used on a jobsite where the RRP Rule is in effect.
The EPA’s definition of a HEPA vacuum in 40 CFR 745.83 reads: “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.”
On its website, the EPA further clarifies: “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).”
What to look for
Because the EPA did not identify a specific test procedure for HEPA vacuums in the RRP Rule, construction supply store owners need to have an open dialog with their manufacturer suppliers when choosing a vacuum to carry that will be compliant with the RRP Rule as written. Here are some questions to ask:
• Was your vacuum designed to work with a HEPA filter? Some manufacturers have put their vacuums through a leak test, which guarantees the only point of exit for air is through a HEPA filter.