Only a Full Unit Certified HEPA dust extractor meets the EPA RRP regulation guidelines, protecting you from expensive fines!
All current Festool CT Dust Extractor models, shipped to dealers as of October 2011, have been independently tested and certified to be FULL UNIT HEPA Dust Extractors. When you purchase a new Festool CT Dust Extractor, regardless of model, you will find a printed certificate in the box as well as labeling on the dust extractor documenting its Full Unit HEPA certification.
If you are a contractor or remodeler working on projects impacted by the EPA's RRP regulations, and your current vacuum only has a HEPA filter, without Full Unit HEPA Certification, then you are at risk of being cited for non-compliance with the updated requirements. Simply put, there's absolutely no substitute for Full Unit HEPA Certification when using your vacuum for EPA RRP.
According to the EPA, it has finalized all aspects of the EPA RRP regulations effective October 4th, 2011 that includes clarifications to the requirements for vertical containment on exterior renovation projects, the prohibited or restricted work practice provisions, and the requirements for high-efficiency particulate air (HEPA) vacuums. In light of this development, the expectation is to see more broad enforcement of the guidelines. Therefore, if you're not using a Full Unit HEPA vacuum, now's the time to consider upgrading to one!
Why has Festool chosen to be silent about EPA RRP compliance?
As noted above, there were several aspects of the EPA RRP guidelines that were being reviewed by the EPA for amendment. Without finalization of the regulations, we were not in a position to make a statement with full confidence that our CT HEPA Dust Extractors would fully comply. Namely, parts of the proposed regulations specific to HEPA vacuums, how they are tested, filter ratings, and other requirements were under further development. Now that the EPA has released the finalized version of the regulations, we can say with complete confidence that your Festool CT Dust Extractor fully complies with the regulations.
So what's the big deal about Full Unit HEPA Certification?
If you are a remodeler who does EPA RRP work, you want a dust extractor that is going to protect you from being fined for non-compliance with EPA RRP regulations. While there are numerous manufacturers offering a vac with a HEPA filter, this falls short of the actual requirements, which specifically call for a perfect seal between the filter and the vac in which it is installed. For full compliance, you need to be sure that the manufacturer also meets the requirement for "no bypass leakage", a critical hurdle on the path to Full Unit HEPA Certification.
This very important, but easily overlooked, requirement of the regulations could cause you to get smacked with hefty fines! If you're using a Festool CT HEPA Dust Extractor, you can perform RRP tasks with the confidence that you've chosen a vacuum that fully complies with the RRP regulations.
Tell me more about the EPA RRP guidelines and how Festool fully complies with them.
In April 2008 the U.S. Environmental Protection Agency (EPA) enacted a rule regarding Lead paint known as Renovation, Repair, and Painting (EPA RRP), 40 CFR Part 745. This rule covers the practices of renovation such as sanding, cutting, and demolition that may disturb surfaces containing lead-based paint, which has been found to be harmful to adults and children. Any firm performing renovation, repair, or painting projects that disturbs lead-based paint in pre-1978 homes, child care facilities, and schools must be trained and certified by EPA-approved training providers.
The EPA RRP guidelines outline many practices related to the above activities. Some of those practices require the use of HEPA exhaust control and HEPA vacuums. The specific guidance of the EPA RRP defines a HEPA vacuum with this verbiage:
"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."
Festool has exhaustively independently tested its CT Dust Extractors to the strictest standards (IES RP-CC-002, IES-RP-CC-0034.1) to ensure that our units not only filter particles to 0.3 microns with 99.97% efficiency, but also that the seal between the filter and the vacuum does not allow for bypass leakage. We feel that this measure was important, not only to follow the letter of the definition but also to ensure the highest level of protection for the user. Effective October 2011, all Festool CT Dust Extractors (CT MINI, CT MIDI, CT 26, CT 36, & CT 48) will be shipped as Certified Full Unit HEPA Dust Extractors, in accordance with these standards.