In April, 2010 the Environmental Protection Agency’s Renovation, Repair and Painting (RRP) Rule went into full effect nationwide and changed how most remodelers and painters have to work on houses built before 1978. Under the rule, work that “disturbs” lead-based paint--or any paint if untested--must comply with prescribed practices for dealing with dust and debris containing lead. Contractors engaged in this work must complete a training course and the individual and his firm must both hold certifications from the EPA. In addition, detailed records must be kept as proof that lead-safe work practices were followed on each job. The only contractors not held to this national rule are those subject to RRP programs imposed by their own state or municipality (and approved by the EPA). And of course, other rules and restrictions may apply for work in HUD homes and commercial facilities.
The RRP Rule doesn’t actually require using a vacuum for cleaning up the job site, but if you do use one for collecting the dust and debris of lead-based paint (or untested paint), it has to be a certified HEPA vac. The rule does require the use of a HEPA vac as power tools create dust, however.
Here’s what the EPA has to say on the matter from the Work Practice Standards:
(3.ii) The use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited on painted surfaces unless such machines have shrouds or containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the point of generation. Machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.
Here’s how the EPA defines a HEPA Vacuum, as listed in the Definitions section of the standard:
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 particulates 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. HEPA vacuums must be operated and maintained in accordance with the manufacturer's instructions.
Recommended Practices for Vacs
Based on the results of my performance testing (which will be published in the Spring issue of Tools of the Trade) and information gleaned from the experience of RRP contractors, there are a few good rules to follow for using HEPA vacs on RRP job sites.
- Always use a fleece filter bag--or paper filter bag as a second choice--and make sure the bag stays properly attached. Filter bags make containment and disposal of dust and debris easier and safer and act as a first stage filter to protect the main HEPA filter. A clean filter maintains high airflow for better performance and should help avoid the dust leakage problems I experienced when the filters were caked with dust.
- Carry a 2 1/4-inch hose, extension tubes, and nozzles for faster and easier pickup of bigger debris. Use the thinner hose for cleaning up the finer stuff and anytime you’re extracting dust from a power tool.
- Contractors quickly learn to treat their HEPA vac as a specialized piece of equipment and do not put it into service doing double duty as a general cleanup vac on non-RRP Rule jobs. Besides the threat of introducing lead dust into other sites, using the vac sparingly prolongs the life of expensive HEPA filters and liner bags.
- Since the various surfaces of these vacs make them nearly impossible to decontaminate by wiping off all dust as required, contractors end up transporting and storing the vacs in a big plastic bag. Keeping the hoses and nozzles in a separate bag makes it easier to lug everything around.
- I’m a big fan of using aftermarket cyclonic separators on my clean-up vacs to keep dust away from the filters and to make dumping debris easier (one bucketful at a time). During this test I experimented with using small liner bags in my five gallon cyclonic separator and it worked perfectly. As a primary filter, it doesn’t change the last stage of filtration being a HEPA filter as required by the RRP Rule, so unless its use violates any written instructions provided with your vac, it should be okay to use a separator on an RRP Rule job. With a fleece filter bag working as a secondary filter inside the vac, the amount of dust ever reaching your HEPA filter as a third stage should be minuscule and should make it last a long time.