EPA RRP Full Unit Certified Dust Extractor Vacuums

Frequently Asked Questions about Festool's CT HEPA Dust Extractor Compliance with EPA RRP Regulations.

Q. What's the difference between a HEPA filter and a full HEPA unit?

A. A HEPA filter is designed to trap 99.97% of particles down to .3 microns. However, the filter is only as good as the dust extractor in which it's employed. No matter how good the filter is, if the seal between the filter and the vacuum is not sufficient, then there will be bypass leakage through the perimeter, essentially cancelling out any benefit gained from the use of a HEPA filter. All of Festool's current line of dust extractors are Full Unit HEPA Certified, meaning that there is zero detectable bypass leakage between the filter and the unit. With zero bypass leakage, all the air passes through the filter itself, eliminating the potential for harmful particulate matter to make it through the system.

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Q. Why do I need a new filter to meet the RRP requirements? Wasn't my original filter a HEPA filter?

A. Since their launch, Festool CT 26/36 Dust Extractors have included HEPA filters. In our course of our efforts to meet the letter of the EPA-RRP requirements of Full Unit HEPA Certification, however, we have changed filter suppliers. Due to the strict nature of the certification process, we can only provide certification for units that employ the most up to date filter design, from our current supplier. For this reason, we are providing owners of our CT 26 and CT 36 Dust Extractors with brand new filters, plus a hardcopy of the Full Unit HEPA Certificate, free of charge if claimed before 3/31/2012.

Q. Is my existing CT 26/36 a HEPA unit? as originally advertised when I bought it?

A. Though your CT 26/36 was originally shipped with HEPA filters, we can only provide certification for units employing the updated filter, based on the precise specifications of our current supplier. We gladly provide you with the necessary filter, plus a hardcopy of the Full Unit HEPA Certificate so that your unit is fully compliant with EPA-RRP regulations. Simply go to Festoolusa.com/HEPA to provide us with your CT's serial number, plus your shipping address and we will ship the components out to you, free of charge if claimed before 3/31/2012.

Q. I own a Festool CT 22 or CT 33, does it meet the RRP requirements?

A. Festool CT 22 and CT 33 dust extractor models were discontinued in 2010. These units were not designed, tested or marketed as a solution for the EPA's Renovation, Repair and Painting (RRP) regulations. Since 2006, both models have shipped standard with main HEPA filters, which offer filtration levels of 99.997% of particulates down to 0.3 microns in size. Festool continues its commitment to support discontinued power tools with the CT 22 and CT 33 Dust Extractors through the availability of spare parts, accessories, and consumables for a minimum of seven years after the date of discontinuance.

If you are engaged in work that is affected by the EPA's RRP regulations, Festool recommends that you upgrade to the most current models of CT Dust Extractors to fully comply with the rules as they apply to HEPA dust extractors.

Q. I own a CT MINI/MIDI, does it meet the RRP requirements?

A. If installed with a Festool HEPA Filter, designed specifically for the CT MINI and CT MIDI (Festool Product No. 496752), then yes, these units meet the requirements for Full UNIT HEPA Certification. Please click here to view, download or print the related certificate.

Q. How do I obtain a copy of the Full Unit HEPA Certificate for my CT MINI, CT MIDI, CT 26, CT 36 or CT 48?

A. If you own a CT MINI or CT MIDI, you will need to open your unit and examine the HEPA filter to see if it is imprinted with the word "HEPA". If it's not, then you will need to order a new replacement HEPA filter (Festool Product No. 496752) to upgrade your unit to comply with Full Unit HEPA. You can download electronic PDF versions of our Full Unit HEPA Certificates using the links below.

CT MINI Full Unit HEPA Certificate
CT MIDI Full Unit HEPA Certificate
CT 26 Full Unit HEPA Certificate
CT 36 Full Unit HEPA Certificate
CT 48 Full Unit HEPA Certificate

Q. What is the EPA RRP rule I hear so much about?

A. In April 2008 the U.S. Environmental Protection Agency (EPA) enacted a rule regarding lead paint know as Renovation, Repair, and Painting (RRP), 40 CFR Part 745. This rule covers the practices of renovation such as sanding, cutting, and demolition which may disturb surfaces containing lead-based paint, which can be harmful to adults and children. Any firm performing renovation, repair, or painting projects that disturb lead-based paint in pre-1978 homes, child care facilities, and schools must be trained and certified by the 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 vacuums.

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Q. I am primarily engaged in woodworking/cabinet-making, does this apply to me?

A. The RRP rules are designed for contractors performing renovation, repair, and painting to homes built prior to 1978. However, in all facets of woodworking and cabinet making, Festool strongly urges the use of dust extraction with fine particulate filtration to help minimize the exposure to possible carcinogenic agents that may be released through the machining of certain types of wood, coated surfaces or other raw materials.

A good example can be found in the language of California’s Prop 65:

WARNING: Some dust created by power sanding, sawing, grinding, drilling, and other construction activities contains chemicals known to the State of California to cause cancer and birth defects or other reproductive harm. Some examples of these chemicals are: Lead from lead-based paints, Crystalline silica from bricks and cement and other masonry products, and Arsenic and chromium from chemically treated lumber.

Your risk from exposure to these chemicals varies, depending on how often you do this type of work. To reduce your exposure, work in a well-ventilated area and with approved safety equipment, such as dust masks that are specially designed to filter out microscopic particles.

Q. What is meant by "shroud" in the RRP and how does it apply to Festool?

A. While the term "shroud" is not defined in the RRP rules, it implies a method to capture dust particles for the purpose of containment. Whether for sanding, cutting, routing or planing, Festool power tools are engineered for extremely effective dust extraction, including, but certainly not limited to the addition of shrouds, covers, chip collectors, and patented airflow designs, among many others. You will find that our methods of containment are the result of a comprehensive system approach, from the point of dust or chip creation, to the transfer of waste material through effective airflow design, all the way to clean disposal, thanks to our Dust Extractors' smart filter bag designs.

Further, the latest definition from the EPA indicates that the desired result is to collect dust and debris at the point of generation:

§ 745.85 Work practice standards.

(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.

Q. How often should I change my HEPA filter?

A. If your Festool CT Dust Extractor has been used for the purposes of EPA RRP work, you must use the proper personal protective equipment (PPE) while performing main filter replacement and dispose of the filter and filter bag accordingly to EPA RRP guidance and following the local jurisdiction, state, and local requirements.

This is highly subjective depending on degree of use, including frequency, duration, and conditions. Foremost, we strongly urge the use of pre-filter bags which filter dust down to 5 microns, helping to prevent loading of the main HEPA filter, and protect the filter from damage from larger particles of dust and debris. The RRP rules do not provide guidance on this matter, and each different manufacturer may have their own stated guidelines or recommendations. Though it is not possible to apply a hard and fast rule across the spectrum of users or applications, we can provide these basic guidelines:

  • The HEPA filter should be visually inspected at every single bag change.
  • With every other bag change the filter should be removed and the seal (including the filter and the area on which it mounts) should be inspected for debris that could compromise the seal. Carefully remove any debris with a light, clean, non-abrasive cloth with minimum pressure.
  • NEVER use compressed air to 'clean' the filters as it may compromise the efficacy of the filter and the rated filtration.
  • In case of any damage to the filter, replace it at once.
  • Depending on the degree of use, a filter may need to be replaced every month or any other interval up to 6 months. Filters should be replaced every 6 months to maintain the rated performance.
  • Avoid direct contact with the filter element (white cloth-like material).
  • Replace filter immediately if it comes into contact with any sharp object or other harsh debris.
  • One way to ensure the integrity of your CT Dust Extractor for use in RRP-related applications, as well as to help prevent cross-contamination of lead dust and debris would be to designate a CT Dust Extractor, dedicated solely for the purpose of working in lead-based paint applications. A secondary CT Dust Extractor could be designated for non-lead-based work.
  • Replace filter immediately if used without a pre-filter or if the HEPA filter is left in place during a wet extraction operation.
  • If you have any question or doubt as to the integrity of the HEPA filter, it is recommended that it is replaced at once.

Q. Does HEPA main filter deteriorate/degrade over time?

A. Under normal usage conditions, the filter will capture and load with finer particles, down to .3 microns, as intended. Depending on time and application, this build up has the potential to restrict airflow, which may eventually compromise performance of both the filter and the dust extractor. To ensure optimal performance, we recommend regular replacement of the main filter, at least once every 6 months. Depending on severity of use, you may find it advisable to replace your filter as often as once a month.

Q. When does the HEPA main filter need to be replaced?

A. To ensure optimal performance, we recommend regular replacement of the main filter, at least once every 6 months. Depending on severity of use, you may find it advisable to replace your filter as often as once a month.

Q. Can I use Long-Life Filter Bag instead of Self-Cleaning Filter Bag and still be RRP-compliant?

A. RRP best practices recommend that any lead-based paint waste collected from renovation activities should be contained securely for disposal. Festool's single-use Self-Cleaning Filter Bags are equipped with a simple pull-tab closure that prevents dust from escaping during removal from the CT, up to disposal in a trash can or other receptacle. The Long-Life Filter Bags are primarily designed for larger chips and debris from applications such as sawing, routing or planing, and are intended to be emptied and re-used up to 500 times. Long-Life Filter Bags are not intended for fine dust particles, and through repetitive use, may contribute to the re-release of dust particles into the air. As a result of this, we strongly recommend using the Self-Cleaning Filter Bag for RRP-related applications.

Q. Do I have to send my CT HEPA Dust Extractor in for testing every year?

A. Further testing and evaluation is unnecessary if using the CT as intended and following the recommended practices for filter inspection and replacement. If for any reason you would like to have your CT serviced please contact our service department at 800-554-8741.

Q. What kind of maintenance is required/recommended for my HEPA Dust Extractor?

A. Follow the instructions as provided in the owners manual , as well as our recommendations related to filter inspection and replacement.

Q. Do you have a beater bar available for floor vacuuming?

A. Yes, the ruling also requires the use of a beater bar when vacuuming carpets and rugs. Festool offers the Turbo Suction Beater Bar (Item # 450644), a powerful and highly efficient, air-driven suction head that employs spinning brushes to vigorously pull stubborn debris from even high-pile carpet.

Q. Does the CT Dust Extractor's suction performance deteriorate as the Self-Cleaning Filter Bag gets (nearly) full?

A. When used in combination with Festool's Self-Cleaning Filter Bags, your CT Dust Extractor is designed to generate maximum suction up to nearly 100% capacity. During normal use, fine particles of dust will cling to the inner lining of any filter bag, resulting in "caking". During even a short amount of use, this coating of dust has the potential to significantly lower the effective suction power of the dust extractor, resulting in poor extraction efficiency and performance. Caking may also cause additional strain on your dust extractor's motor, contributing to premature failure. All Festool Dust Extractors come standard with Self-Cleaning Filter Bags which expand and collapse with each cycle, effectively releasing/eliminating caked dust, so you get maximum performance up until nearly 100% capacity.

Q. What do I need to do to get my CT 26 or CT 36 Full Unit HEPA Certified?

A. Purchase a replacement HEPA filter and receive a printed certificate for Full Unit HEPA certification. If you own a Festool CT MINI, CT MIDI, CT 48, CT 22 or CT 33, please refer to our FAQs for more information about your particular Dust Extractor model.

Q. What is my cost to convert?

A. : If you purchased your CT Dust Extractor in October 2011 or later, it should already be equipped and properly labeled for HEPA certification. If it does not include the updated components, please visit the above referenced website to register your serial number and receive the necessary pieces. If you purchased prior to October 2011, you will need to purchase a replacement HEPA filter to receive certification.

Q. Can I use the CT AutoClean (AC) #584014 for RRP?

A. The Festool CT AutoClean (AC), product number 584014, Dust Extractor was designed with an automatic filter cleaning mechanism to handle the massive amounts of drywall dust that can be produced by the PLANEX Drywall Sander. It uses a high-performance, 1-micron filter that is not HEPA rated. This unit will accept our HEPA filter as optional equiment, however we have not tested it for RRP compliance and it should not be used for RRP applications.

Q. How can I find the serial number for my CT Dust Extractor?

A. The serial number for your Festool CT Dust Extractor is eight digits in length and begins with "100". If you have the original box, or it is still in the box, you can locate the serial number on a white label on the outside of the box. Refer to the image below for an example of this label.

CT Serial Number Box

You can also locate the serial number on the dust extractor itself. There is a label on the back of the unit. Refer to the image below for assistance in locating the serial number.

Festool serial number