Certified Lead Renovator Training

EPA Renovation, Repair, and Painting (RRP) Rule requires the use of equipment with a High Efficiency Particulate Air (HEPA) filter under two circumstances:

"HEPA Vacuum" is required as part of the interior work area cleaning: 40 CFR 745.85(a)(5)(ii) states that "The firm must clean all objects and surfaces in the work area and within 2 feet of the work area in the following manner, cleaning from higher to lower:

Walls. Clean walls starting at the ceiling and working down to the floor by either vacuuming with a HEPA vacuum or wiping with a damp cloth.

Remaining surfaces. Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs."

EPA defines a HEPA vacuum at 40 CFR 745.83.

"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 requirement that all air drawn into the machine is goes through the air filter with no leakage is a tough standard. It gets at the heart of a problem with many vacuums labeled as "HEPA." Putting a HEPA filter in a vacuum does little good if the air bypasses the filter. Over the years, studies indicate that most vacuums would not meet this standard.

Unfortunately, there is no approved method to test HEPA vacuums to determine whether they meet EPA's definition. Without an approved method, a Certified Renovator has no way of knowing whether the vacuum they are using meets the definition or not.

PHEAF

The Indoor Environmental Standards Organization (IESO) is developing an ANSI standard that may help. IESO 4310 is a "Portable High Efficiency Air Filtration (PHEAF) Device Field Testing and Validation Standard." The proposed standard was published for public comment in May 2009. We will update this webpage when it is finalized. If the device meets the Category 5 standards, you will have confidence that it meets EPA's definition. It may meet EPA's definition if it rates a lower category but it is not so clear.

A few disclaimers are important to remember:

EPA's refers to "design" and not actual manufacture, operation, and maintenance of the equipment. Design is a subjective standard that leaves provides little clarity. The term "abatement" suffers from the same flaw since it is contingent on the "design" and has been a source of confusion since 1996.
The PHAEF uses a portable, laser particle counter that measure the amount and size of particles coming in and leaving the device. It cannot tell the difference between lead that is bypassing the filter and grease, oil or metal shavings generated by the motor. While it is a great measure of the overall performance of the device, it goes beyond lead.
IESO's PHAEF standard is not yet final.

With those disclaimers in mind, click here for the test results on 25 different HEPA-equipped devices that were tested and evaluated based on the draft PHAEF standard.

HEPA Exhaust Control

"HEPA Exhaust Control" is required for high-speed paint removal: 40 CFR 745.85(a)(3) states that "The use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited unless such machines are used with HEPA exhaust control."

EPA does not define the term "HEPA Exhaust Control." Presumably, it would be a HEPA Vacuum with enough capacity to collect all of the debris and dust caused by the use of the machine.

Using a HEPA Vacuum

The EPA Model Certified Lead Renovator Courses do not address one of the critical tasks for an renovation project: How to use and maintain the HEPA vacuum. But if a renovator gets this wrong, then HEPA may not help cleanup dust. Worse, it could spread dust. Some suggestions:

Cleaning: If the filter - whether the HEPA filter or the prefilters - gets loaded down with dust and debris, the HEPA vacuum will not move enough air to collect lead dust and lead debris from the renovation. The renovator must periodically clean the vacuum and replace the prefilter - and depending on the design - the HEPA filter. Wisconsin Department of Health Services developed a great two-page fact sheet on "How to Safely Change a Lead Contaminated HEPA Vacuum Bag." They use a common canister vacuum to show how to change the prefilter.
Sealing: Before you turn off a HEPA vacuum, you need to cover the end of the air intake home with tape or bag the beater bar. If you don't do this, the dust and debris in the hose will fall out and recontaminate the workplace or be released in the truck or someone else's home. When you need to use the vacuum, turn the vacuum on and then remove the tape or bag. Remember, when the unit is turned off, the air intake openings must be sealed.
Training: Instructors should consider the following:
- Consider adding a demonstration about HEPA vacuum cleaning to the training. Allow the students to open up a HEPA vacuum and see how it works.
- Consider having the students bring their new unused HEPA vacuums into class so you can help them during breaks or lunch. Make sure it has not been used and contaminated with lead.
- Watch the students during hands-on exercises to make sure they seal up the vacuum when it is turned off. If they forget, dump the debris and dust on the cleaned up workplace for a great visual and have them reclean.

10320 Little Patuxent Parkway, Suite 500 • Columbia, MD 21044
Phone: 410.992.0712 • Fax: 443.539.4150