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Author Topic: By April 22 We need a HEPA vacuum, Does the CT33 qualify?  (Read 17488 times)

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Offline ronaldsauve

  • Posts: 5
    • Green Design Build
Does the CT33 HEPA vac qualify for Working Safely With Lead cleanup?  Starting April 22, 2010, contractors will be required to use HEPA vacs to cleanup jobsites.  Do these qualify?
The last time I posted, I was referred to posts from last fall; (2009).  I need something more current, as by next week I'll need a vacuum.  I prefer your CT33 to others, as it has the best balance of features. The Festool CT33 is definitely the one I would most like to own.   
Thanks very much!
Ronald Sauve

Festool USA does not pre-approve the contents of this website nor endorse the application or use of any Festool product in any way other than in the manner described in the Festool Instruction Manual. To reduce the risk of serious injury and/or damage to your Festool product, always read, understand and follow all warnings and instructions in your Festool product's Instruction Manual. Although Festool strives for accuracy in the website material, the website may contain inaccuracies. Festool makes no representations about the accuracy, reliability, completeness or timeliness of the material on this website or about the results to be obtained from using the website. Festool and its affiliates cannot be responsible for improper postings or your reliance on the website's material. Your use of any material contained on this website is entirely at your own risk. The content contained on this site is provided for informational purposes only and does not constitute professional advice.


Offline Holzhacker

  • Posts: 997
    • www.aic-chicago.com
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #1 on: April 12, 2010, 11:09 PM »
Ronald, do another search this topic was just covered again last week. The vacuums essentially do qualify but there are other requirements to pay attention to for full compliance. Consider PM Charimon, he is the resident lead guy. Some of us remain alive despite lead and asbestos.
"The Code is not a ceiling to reach but a floor to work up from"

Offline Brice Burrell

  • Posts: 7388
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #2 on: April 12, 2010, 11:15 PM »
Does the CT33 HEPA vac qualify for Working Safely With Lead cleanup?  Starting April 22, 2010, contractors will be required to use HEPA vacs to cleanup jobsites.  Do these qualify?
The last time I posted, I was referred to posts from last fall; (2009).  I need something more current, as by next week I'll need a vacuum.  I prefer your CT33 to others, as it has the best balance of features. The Festool CT33 is definitely the one I would most like to own.   
Thanks very much!

I'd like to know this too. I heard over at the JLC forum that Fein is saying their vacs with the HEPA filter installed comply with the new RRP laws.


Ronald, do another search this topic was just covered again last week. The vacuums essentially do qualify but there are other requirements to pay attention to for full compliance. Consider PM Charimon, he is the resident lead guy. Some of us remain alive despite lead and asbestos.

I agree Charimon is the lead abatement expert but no one seems to be an expert on the new RRP laws so be careful who's information your trust.

Offline ronaldsauve

  • Posts: 5
    • Green Design Build
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #3 on: April 12, 2010, 11:34 PM »
I just contacted Christian through his email.  Hopefully, he will be free to let us know.  I understand, especially given the ambiguity of the EPA "requirements", that he may not be able to definitively tell us without actual EPA confirmation. 
On a side note, the Fien is qualified according to their website, but I still would prefer the Festool CT33.  I feel like it has a better balance of features.
Ronald Sauve

Offline Charimon

  • Posts: 651
  • Tool and Tile Junkie
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #4 on: April 13, 2010, 01:20 AM »
Lets see I posted this over on another thread http://festoolownersgroup.com/other-tools-accessories/new-king-of-the-vacuum-hill-the-nilfisk-attix-30/

NOTE about HEPA and HEPA COMPLIANCE:

EXCERPT from HEPA FILTER CONFORMANCE  TECHNICAL BULLETIN.PDF

"By definition a HEPA filter is a tested filter that is at least 99.97% efficient on particles 0.3 micron in size . Now we have vacuum cleaners and other consumer items claiming to use HEPA filters − absolutely not! These filters are not individually tested and many of them actually use a lesser efficiency media. HEPA


Rarely do sequentially tested filters test at the same penetration and resistance. If each label is a duplicate of the previous it is doubtful that the manufacturer tested every filter. The IEST Recommended Practice, Underwriters Laboratories Standard, government specifications and definitions of HEPA filters, require testing of every filter.

Can a filter be defined as a HEPA filter because the media manufacturer has tested a piece of the media?

All HEPA media is tested by the media manufacturer. It is a different testing method than that used for a completely assembled filter. Some manufacturers will reference the media manufacturers' test, assemble a product, and make inference that they are providing a HEPA filter. This is an absolute misstatement. In order to meet the aforementioned Practices and Standards, every HEPA filter must be tested after all components are assembled.


Warner mentioned that the Festool Hepa filters have  "some printed hepa info on them as well"  
If anyone can tell me what that info is or if it meets the above specifications then keep that document and you should be fine if/when an inspector or client asks if that is a Hepa filtered Vacuum
« Last Edit: April 13, 2010, 01:25 AM by Charimon »
"The existence of the flame thrower proves that at one time, somewhere, somebody said, " You Know, There's a group of people over there that I'd like to set on fire right now but they're too far away."

Offline WarnerConstCo.

  • Posts: 4162
    • Warner Mill Works
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #5 on: April 13, 2010, 01:45 PM »
the filters don't have anything printed on them besides festool, hepa filter, part #
and what ct's it fits.

Offline ronaldsauve

  • Posts: 5
    • Green Design Build
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #6 on: April 13, 2010, 09:20 PM »
Hi guys,
Today I got this reply from Christian.  I thought all would appreciate the info:

Re: By April 22 We need a HEPA vacuum, Does the CT33 q
? Sent to: ronaldsauve on: Today at 03:20 PM ? Quote Reply Remove   

--------------------------------------------------------------------------------
Thank you for your PM. We will publish something about this topic this week or next week, as we are in the final stages of research. We wanted to be 100% sure to give
the right advice to our customers and brought some experts in and did testing beyond the standard testing. We will publish the results on our website and on the FOG.

Best regards,

Christian Oltzscher
Ronald Sauve

Offline ccmviking

  • Posts: 411
    • Blue River Cabinetry Kitchen and Bath
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #7 on: April 14, 2010, 09:51 AM »
     One of the most important things about complying is taking the class.  After that if you are at least making a good and reasonable attempt they'll cut you some slack.  From what I've seen the Festool vac's are going to be better or equal to most others out there.  The fact that during the training they can't even recommend a product that meets the standard is what's troubling.  In showing them the festool, the instructors and one inspector seemed to think it would be good.  When Aprill 22nd rolls around just make sure if you have a "Festool" vac vs "No" Vac.  Any inspector is going to want to see that you are making a good attempt at containment and protection.  I'm sure that none of us will be perfect at it and I think that'll be ok. 

    What this will do is raise the costs of an actual business like ours on these jobs, and provide more work to the unlicensed/non tax or insurance paying people standing out in front of Home Depot as home owners go there to get them to do their project.  We do what we can now to talk the home owners into doing their own demo to save them some money.  It's something a lot of them are capable of and they don't really have to worry about RRP themselves.  Well I'm off now to tear out a pre-78 bathroom (tub, tile, flooring, etc.) and the CT33 will be there cleaning up the muck.   :-\
     
« Last Edit: April 14, 2010, 08:44 PM by ccmviking »

Offline WarnerConstCo.

  • Posts: 4162
    • Warner Mill Works
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #8 on: April 22, 2010, 11:47 AM »
Hi guys,
Today I got this reply from Christian.  I thought all would appreciate the info:

Re: By April 22 We need a HEPA vacuum, Does the CT33 q
? Sent to: ronaldsauve on: Today at 03:20 PM ? Quote Reply Remove   

--------------------------------------------------------------------------------
Thank you for your PM. We will publish something about this topic this week or next week, as we are in the final stages of research. We wanted to be 100% sure to give
the right advice to our customers and brought some experts in and did testing beyond the standard testing. We will publish the results on our website and on the FOG.

Best regards,

Christian Oltzscher


Where is this announcement?

Offline unityroad

  • Posts: 150
  • photos
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #9 on: May 16, 2010, 11:55 AM »
Hello, so are the vacs compliant? Or not? [scared] [eek]
You are only as good as your ability to get PAID.

Offline dsweetser

  • Posts: 130
  • Adirondack, NY USA
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #10 on: May 16, 2010, 01:40 PM »
I PMed Christian several weeks ago. He stated that the testing company should have the result be 5/7. I have heard nothing new so far. There are several vacs that meet the requirements, ie. no leakage, all exhaust thru hepa filter, Fein Turbo II I have found to be the least expensive. It also has a electric powered carpet attachment that complies.

I have 2 CT33's. Wish I ___knew____ they meet the requirements.  I am certified and my firm is waiting for it's certification from EPA. In the mean time I am permitted to act as though the firm is compliant.

Don
Don

Offline unityroad

  • Posts: 150
  • photos
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #11 on: June 06, 2010, 10:48 PM »
Hello, Its been awhile.  One more time for the cheap seats. Do the festool vavs comply for us carpenters who work in pre 78 homes ??? ??? ????
You are only as good as your ability to get PAID.

Offline mtj

  • Posts: 2
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #12 on: June 07, 2010, 12:39 PM »
I have also been following this thread and await an answer, also for the CT22.
Thank you.

Offline Rhett

  • Posts: 10
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #13 on: June 07, 2010, 11:04 PM »
There are MANY of us waiting for this seemingly simple answer.

Offline harry_

  • Posts: 1333
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #14 on: June 08, 2010, 01:13 PM »
There are MANY of us waiting for this seemingly simple answer.

 [dead horse] ,maybe?
Disclaimer: This post is for educational and entertainment purposes only. Any resemblance to real persons, living or dead is purely coincidental. Void where prohibited. Some assembly required. Batteries not included. Contents may settle during shipment. Use only as directed. No other warranty expressed or implied. This is not an offer to sell securities. May be too intense for some viewers. No user-serviceable parts inside. Subject to change without notice. One size fits all (very poorly).

Offline Rhett

  • Posts: 10
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #15 on: June 09, 2010, 01:31 PM »
There are MANY of us waiting for this seemingly simple answer.

 [dead horse] ,maybe?

Clever and original as your emoticon is, I think all we're asking is for the difinitive answer promised to us.

Offline harry_

  • Posts: 1333
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #16 on: June 09, 2010, 05:49 PM »
There are MANY of us waiting for this seemingly simple answer.

 [dead horse] ,maybe?

Clever and original as your emoticon is, I think all we're asking is for the difinitive answer promised to us.

Rhett,

I agree.

The emoticon is neither clever or original, however I was asking a legitimate question.
Disclaimer: This post is for educational and entertainment purposes only. Any resemblance to real persons, living or dead is purely coincidental. Void where prohibited. Some assembly required. Batteries not included. Contents may settle during shipment. Use only as directed. No other warranty expressed or implied. This is not an offer to sell securities. May be too intense for some viewers. No user-serviceable parts inside. Subject to change without notice. One size fits all (very poorly).

Offline Rhett

  • Posts: 10
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #17 on: June 09, 2010, 07:09 PM »
I'm sorry. It is a pretty cute emoticon though.

I was told in the RRP class that the qualified HEPA vacs would say "HEPA" on them. The CT22 doesn't say it specifically but I know it has them, I even bought replacement filters for it just in case mine clog on the job.

You would think Festool would be more interested in promoting the qualification as this is such a new law and people are buying HEPA vacs by the truckload! At least Fein is promoting theirs, if only I could figure out how to stack all my systainers on it.

Offline Bob Marino

  • Posts: 3242
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #18 on: June 10, 2010, 08:31 AM »
   
 I am in no way speaking for Festool, but I am sure they are not just sitting back, ignoring this subject and letting things happen as they may. I would think they are seeking  legal as well as scientific counsel before releasing a statement or making a pronouncement. This is an area (lead filtration) where not "getting it right" could result in horrendous legal issues and costs, especially for a relatively small company like Festool USA and especially in our very litigious society.

 Just my 2 cents.

 Bob
Former Festool  Dealer since 2002; user well before that!

Offline Festoolfootstool

  • Posts: 2076
  • The trouble with Bob is its all about Bob
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #19 on: June 10, 2010, 10:21 AM »
Bob I have been watching this thread with interest, I think its brave of you to raise your head over the parapit. As Festool seem a little reticent. We don't have this issue in the UK......Yet.

the extractors were manufactured before the lead issue came about and as such have not been tested for use with lead paint.this much is obvious.I would have thought this might have been part of the testing as lead paint has been known to be a issue for many years.

If I lived in the states and needed to conform with these new laws I would go straight out and buy the best machine with the right stickers on it.job done.

for a small company where extractors are only a part of their line up and not their main business I can see that testing would be expensive and take some considerable time.

I doubt festool has even started testing yet as things like this take many months to set up and many more months testing, then there would be the UL issue.. more time.

I would guess the machines once tested and available for sale would need to be badged as suitable for lead paint removal, I doubt this could be applied to machines already sold and in use.

Maybe Festool should say that users should assume the machine is not suitable for lead paint removal and give a provisional date for having the machines tested.

feel free to jump all over me [big grin]
If the milk turns out to be sour, I ain't the kind of **** to drink it.......

Why do Festool accessories only have a two month guarantee here in the UK ?

Offline mtj

  • Posts: 2
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #20 on: June 10, 2010, 11:37 AM »
I agree with the 2 above posts--I would bet that legal counsel has said to hold off saying anything definitive.  Key to remember here, with RRP we are talking "remodeling" clean-up not "abatement", an issue that was stressed in the class.  We do not do abatement, that is a whole different animal, requires different certs and clearance.  We are just remodelers trying to clean up after our remodeling activities that may disturb some pre-1978 painted surfaces.  We are not doing lead removal or abatement.  I gave up on the Festool vac, bought a Fein 9-20-25 HEPA (Turbo II) even though it doesn't have anything written on the outside of the machine.  The HEPA filter meets the standard of 99.97% at .3 microns.  Good enough for me, time to move on and do my job. 

That said, the way EPA has bungled this whole implementation and keeps changing the rules I predict clearance testing, not just a glorified white glove test, is where this is headed sometime in the not-too-distant future.  I should also add that at least in my area, (western WA) I have heard of no enforcement actions and at least anecdotally, local building inspectors seem to have a "that's the feds, not my deal" approach so far.   

Offline Bob Marino

  • Posts: 3242
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #21 on: June 10, 2010, 02:53 PM »
Bob I have been watching this thread with interest, I think its brave of you to raise your head over the parapit. As Festool seem a little reticent. We don't have this issue in the UK......Yet.

the extractors were manufactured before the lead issue came about and as such have not been tested for use with lead paint.this much is obvious.I would have thought this might have been part of the testing as lead paint has been known to be a issue for many years.

If I lived in the states and needed to conform with these new laws I would go straight out and buy the best machine with the right stickers on it.job done.

for a small company where extractors are only a part of their line up and not their main business I can see that testing would be expensive and take some considerable time.

I doubt festool has even started testing yet as things like this take many months to set up and many more months testing, then there would be the UL issue.. more time.

I would guess the machines once tested and available for sale would need to be badged as suitable for lead paint removal, I doubt this could be applied to machines already sold and in use.

Maybe Festool should say that users should assume the machine is not suitable for lead paint removal and give a provisional date for having the machines tested.

feel free to jump all over me [big grin]

  Nah, not brave, heck what's to be brave about anyhow? I am just chiming in with little or no more info than anybody else. But you do raise good points; can't see anyone jumpin' on you for that.

Bob
« Last Edit: June 10, 2010, 03:31 PM by Bob Marino »
Former Festool  Dealer since 2002; user well before that!

Offline Bob Marino

  • Posts: 3242
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #22 on: June 10, 2010, 03:35 PM »
I agree with the 2 above posts--I would bet that legal counsel has said to hold off saying anything definitive.  Key to remember here, with RRP we are talking "remodeling" clean-up not "abatement", an issue that was stressed in the class.  We do not do abatement, that is a whole different animal, requires different certs and clearance.  We are just remodelers trying to clean up after our remodeling activities that may disturb some pre-1978 painted surfaces.  We are not doing lead removal or abatement.  I gave up on the Festool vac, bought a Fein 9-20-25 HEPA (Turbo II) even though it doesn't have anything written on the outside of the machine.  The HEPA filter meets the standard of 99.97% at .3 microns.  Good enough for me, time to move on and do my job. 

That said, the way EPA has bungled this whole implementation and keeps changing the rules I predict clearance testing, not just a glorified white glove test, is where this is headed sometime in the not-too-distant future.  I should also add that at least in my area, (western WA) I have heard of no enforcement actions and at least anecdotally, local building inspectors seem to have a "that's the feds, not my deal" approach so far.   

 Good post. Correct about lead abatement; my term "lead dust" was a poor choice, as I meant  just as you mention -  clean up where lead may have been disturbed.

Bob
Former Festool  Dealer since 2002; user well before that!

Offline greg mann

  • Posts: 1906
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #23 on: June 11, 2010, 03:37 PM »
In a recent article about lead paint and remodelling, in Fine Home Building IIRC, they discussed the lack of clear interpretation regarding this issue. FWIW, and that isn't much, there was a picture of a guy using a Festool CT in the article. Go figure. That was probably the best example of good practice the editor could think of. I should go back and re-read the article but the big issue seemed to be centered around just how much of an effort a remodeler puts into dust management, and how that would be judged by any enforcement personnel who have yet received to clear guidelines. In other words, "If you're trying hard to do it right, you are likely to get some leeway." While I think letting common sense prevail is nice, by itself it sure makes for poor circumstances on the jobsite. I can certainly understand why Festool hasn't responded under the present conditions because we still don't have any real clarity.

Folks doing this type of work deserve some clear guidelines regarding suitable equipment. We can argue the relative merits of source capture using Festool sanders and collecters versus any other brand tools used with any other collecters but no one has done the hard work of qualifying components, much less systems. As an example, would a 'non-HEPA certified' C22 with a Rotex be a good lead paint removal tool in the hands of a carefully masked-up operator. I would think so, and probably better than most anything else one might cobble up, especially if done so with a DC that has somehow been 'tested' as true HEPA, but teamed with a less efficient sander. But then, it doesn't matter what I think.

Good luck to all of you who need to deal with these issues.
Greg Mann
Oakland, Michigan

Offline harry_

  • Posts: 1333
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #24 on: July 16, 2010, 06:29 PM »
Hi guys,
Today I got this reply from Christian.  I thought all would appreciate the info:

Re: By April 22 We need a HEPA vacuum, Does the CT33 q
? Sent to: ronaldsauve on: Today at 03:20 PM ? Quote Reply Remove   

--------------------------------------------------------------------------------
Thank you for your PM. We will publish something about this topic this week or next week, as we are in the final stages of research. We wanted to be 100% sure to give
the right advice to our customers and brought some experts in and did testing beyond the standard testing. We will publish the results on our website and on the FOG.

Best regards,

Christian Oltzscher

Just keeping this thread alive, as I believe we are all still awaiting the `official word`. [poke]
Disclaimer: This post is for educational and entertainment purposes only. Any resemblance to real persons, living or dead is purely coincidental. Void where prohibited. Some assembly required. Batteries not included. Contents may settle during shipment. Use only as directed. No other warranty expressed or implied. This is not an offer to sell securities. May be too intense for some viewers. No user-serviceable parts inside. Subject to change without notice. One size fits all (very poorly).

Offline WarnerConstCo.

  • Posts: 4162
    • Warner Mill Works
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #25 on: July 16, 2010, 06:55 PM »
I am thinking the new Cleantex will be the one's.

Offline tjbier

  • Posts: 328
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #26 on: August 30, 2010, 10:20 PM »
.
Tom- ps, I read these.

Offline tjbnwi

  • Posts: 6394
  • No longer in Cedar Tucky Indiana
Re: By April 22 We need a HEPA vacuum, Does the CT33 qualify?
« Reply #27 on: August 31, 2010, 03:30 PM »
I posted this in the thread for the new vacs;

http://www.toolsofthetrade.net/industry-news.asp?sectionID=0&articleID=1365162

The person interviewed set forth the EPA definition of a HEPA vac. He also states they do not certify any tool to be compliant. It is up to the contractor to determine if there equipment is compliant.

Looking at the flow chart for the new vacs it leeds me to believe they will be compliant.

If the 22 & 33 have the same flow chart they would also be compliant. The 22 & 33 have HEPA filters. If all the air is discharged through them, the vac would be compliant. Even without the bag.

The above statements assume there is no leakage in the case as required. 

Do not except a black or white answer from the EPA, the lawyers will never allow it.

Tom