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.
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.
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.
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.
