A few months ago, I wrote a short article about a recent job I was working, and the RRP (Renovating, Repairing, Painting) rule regarding the lack of standards for HEPA vacuums. This is a follow-up to that article.
I went into, and completed, that particular job following the RRP standard as best as I understood it, with the best tools and practices at my disposal. The job went well, the customers are satisfied, and no one had any overexposure to lead particulates. My only source of concern was my vacuum system. It was not officially stamped as ‘certified’. Well, now my concerns have been answered. Festool’s new line of CT vacuums has been certified as FULL UNIT HEPA Dust Extractors.
What does this mean for me? Well, two things. For one, I now know, beyond a shadow of a doubt, that I use a system that does, indeed, comply with the EPA standard. It also means that I now have a vacuum (excuse me, “Dust Extractor”) that does everything.
My feeling on vacuums is this: I don’t want to carry around a shop vac for rough cleanup, another vacuum for hooking to my tools, or cleaning inside an occupied home, and then another one that I can use for lead-safe work. What a pain! These Festool vacs combine all three in one.
The tipping point for me on the first two reasons was the ‘longlife filter bag’. I was using the single-use bags and kept thinking, “This is great, but I feel like I’m throwing away money every time I fill one up.” I kind of had to bite the bullet to go with the longlife, but I’m so glad I did. Sometimes, I fill it multiple times a day. Now I don’t have to think about using my dust extractor for rough cleanup during framing; I can just empty the bag! The same goes for when I hook up to my track saw or sander. The same bag will handle both jobs.
Why do I mention all this when we are talking about RRP? Because you cannot use a longlife bag when doing lead renovation work (unless you want to throw it away, and I would certainly discourage that). I keep a box of sealable/disposable bags for when I know it serves the right purpose. We like multi-taskers around here.
What else does this mean? Well, let’s look at cost. Not only do I not have to lug around three different pieces of machinery, I also don’t have to pay for three different pieces of machinery. I can get a decent shop vac for about $100, but if I don’t need a separate shop vac, that’s money in my pocket. Also, do a search for EPA certified vacuums. I didn’t find one model that cost less than the CT Mini, and the closest models didn’t have some key features, like automatic tool start, anti-static hose, and convenient hose/cord storage. Add all these things up, and this CT system begins to look like the most economic choice, as well.
I don’t want to come off sounding like a Festool salesman here, so let me quote Bill Robinson, EPA RRP instructor, and TiC author:
Even if your brand of vac claims to contain a HEPA certified filter, it may not be designed or tested to ensure against what is referred to as “bypass leakage,” meaning that it still may not meet the letter of the RRP regulation.
Good news for me, and you: Festool has just announced that, effective immediately, every one of their CT Dust Extractors is shipped from the factory with full unit HEPA certification. This certification guarantees that the seal between the filter and the vac is perfect, meaning there’s zero possibility for incoming air to get around the filter. What’s more, if you purchased one of these vacs before the changeover, they’ll even send you a brand new filter, plus a certificate, and a HEPA sticker for the outside of the vac.
When it comes to working in older homes these days, dust is no joke. Buying good equipment that’s designed to capture dust at the source is a small investment when you stop to think about it. Not only will you find it easier to meet the new EPA RRP requirements [with these new vacs], you’ll leave behind more satisfied clients, who will appreciate the absence of dust after you leave. Plus, you’ll save on the time and labor you would otherwise waste cleaning up after the fact. It’s a no-brainer, if you ask me.
There you have it.
The older CT 22 and 33 lines do not meet Full Unit HEPA certification, but all of the vacs in the new CT line (the Mini, Midi, CT-26, CT-36, and CT-48) are full unit certified. So, if you are like me and are a ‘Frugal Festoolie’, you will be able to find the right model to match your workload and your budget.
“Wait, so you’re telling me that I can get a RRP compliant unit for $385?!?”
To put it bluntly . . . Yup. :)
Read more about Festool’s HEPA certification by clicking here.
You mention that you used the CT 22, according to festool’s website: If you own a Festool CT 22 or CT 33 dust extractor, you can view or download a PDF copy of the CT 22 and CT 33 HEPA Filter certificate. However, please be aware that, based on our interpretation of the current EPA-RRP regulations, the only certification that will fully comply with EPA RRP guidelines is the Full Unit HEPA Certification, which is not currently available for the older CT 22 and CT 33 units.
I own a CT 22 and am worried compliance, I don’t want to spend several hundred more dollars on another dust collector. Any advice would be appreciated
Thanx for catching my mistake. I inadvertently inserted the wrong model # in my haste while putting this together. In all seriousness, I was so stoked about this news that I wrote and submitted this piece that same day. Should’ve caught it; simple mistake and I apologize for the confusion.
As far as the model in question – the CT22 or even the 33 – I will let the pros comment on that. The only reason I say that is I don’t feel as though I can give you an ironclad explanation on this one. The prior (concerning the CT26 and the rest of the new CT family) is something that I feel more than comfortable standing behind. I just want us all to have the best tools and techniques available at our disposal. This to me seems to be it.
Thanx for contributing to a great subject :)
You’re short sighted and silly in the head! There’s nothing shameless or commercial about this article! Whas the madder wid you? You have a burr under your blanket? Can’t you see that Festool is offering to update filters on vacuums they already sold–months or years ago–for FREE? Excuse me, but please tell me the last time you heard from a tool manufacturer that was offering you a free upgrade? Or any manufacturer? Sometimes I get so impatient with people who are always looking at the glass half-empty (new edit), especially when it comes to manufacturers…as if they’re big brother or something–some corporate evil/enemy we should all be negative about. I’ve met a lot of folks who work for various manufacturers. I’ve found many of them have become good friends of mine, and I like to gauge my friends by sincerity. I was excited that Festool invested so much money on energy in solving the RRP Dust Collection Problem. Sure, it’ll help them sell more dust collectors, but they’re obviously motivated by more than that. Look again. There’s no devil in this handiwork.
Have you never appreciated something (a product or otherwise) so much that you wanted to share it with others? I wish I was being paid by Festool to say this, but I’m not. They have a great product in these HEPA vacs. I recently bought one (ct26) and for much the same reasons as the author. I couldn’t be more pleased. In fact, I’ve already replaced my makita track saw with the TS55, and plan on moving more tools to the Festool line.
I know that I hope to inspire my customers to feel the same way in regards to my products as a carpenter. Why anyone should be ashamed of honest commerce – well I guess you’ll have to enlighten us. If it was one of your customers speaking of your company I don’t think you’d use the same adjective.
Thanks for the article Matt.
I recently picked up a Festool HEPA vac (2022, I know I’m late to the party) and I’ve been talking about it so much, I’ve had to caveat every conversation that I’ve had with “I know this is going to sound like I’m a paid shill from Festool, but…”
I don’t know who hurt you when it comes to commerce, but it was clear that was certainly not the point of this article, which the author even stated.
You’ve visited this page to get information for free – maybe you should go back to scrolling on Facebook or Instagram and allow Zuck to transact with your data in secret – does that type of commerce make you feel better?
Anyways – great article and thank you for the information! Keep up the good work, and long live commerce!
I still feel like I come across as a shill Jack, but I’ve grown to embrace it. I now have 3 dust extractors (2-CT26 and a mini) and a reasonably sized pallet of Systainers full of black & green (I only know the latter cuz I just had to pack them all😂).
I’ve said this from almost the beginning when I started using Festool, “when I find something better, I’ll happily switch.” Welp, still here and no course deviation in sight.
Sounds like I’m not alone👍🏻👍🏻
It has a sticker that says it’s certified so it must be, right?<<<<(sarcasm)
Thus far I am not convinced that RRP procedures nor enforcement are worth complying with. In recent years, I have talked to over a dozen fellow carpenters (all of them seasoned remodelers) and most of them had never even heard of RRP. Of those who had heard about RRP, they weren't concerned. And why should they be? Anyone notice the EPA driving from job to job? Didn't think so. Sure there has been a report about some painter somewhere being busted but I think it's pretty clear that he was being overly blatant about non-compliance. And I think that is why this RRP thing exists.
If you are a 'good' and 'competent' carpenter like me you are already doing what you can to protect your clients against dust… it just makes business sense to keep your client happy. Sure you can go the extra mile and provide them with a "Certified Lead Safe" job – while you're at it you might want to consider filtering out all the VOC's from their project and drive an electric car; whatever you choose to make you a better choice than your competition.
But here's the conclusion – you are here on this website so you obviously care about the quality of your workmanship and thus you go out of your way to be continuously educated about your profession. In fact I bet that is the main reason why you know about RRP while the dozen carpenters I asked were mostly clueless (none of them were really into reading trade mags or websites). Not that I am saying you shouldn't follow the law. You should indeed follow it "to the best of your understanding" but don't stress out and worry that the EPA is standing over your shoulder because from what I have seen so far – they're not.
Be the best carpenter you can be – be safe – be courteous – stay profitable.
I would agree that most of the contractors I see at the forums, bulletin boards and trade shows, the road show included, are conscientious.
That said I suspect there are some details concerning working lead safe that are NOT followed on a regular basis.
A good example is cleaning tools and vacs from job to job.
If you realize how little exposure is required to cause neurological damage to a child than you know htere is enough potential lead dust on your tools to fit the bill.
And I would say that the statement concerning contractors (using the term for anyone doing work on pre-78 homes licensed or not) not knowing about the risks and the rule is true. That does not make any less important.
I was on a site yesterday where a “garden shed” is being renovated to be occupied by children to learn about urban farming and the “contractor” assigned to do the work did not have a clue about lead safe work practices.
Hopefully the tips I gave the site manager will reduce the risk.
And, yes, I will be providing a Festool HEPA compliant vac for the clean up.
Good reply, Bill, and thank you for your help with this story! Of course, I think there’s room for another word in response to Gabe’s comment that that the RRP isn’t something carpenters should worry about…that any carpenter who is careful about keeping his job site clean is doing a good enough job. The fact is, even if the EPA isn’t inspecting your job or any jobs, that’s not the worrisome issue. The real problem will be when a homeowner sues you years down the road if you haven’t made sure that you’re following all the RRP rules and procedures. Believe me, the EPA is not and will not be the problem…lawyers will be the problem. Just because ten or fifteen other carpenters or contractors know nothing about the new rule isn’t going to protect YOU from a lawyer.
Great article – I was specifically impressed with the price. While reading I was thinking “okay how much is this ‘certified sticker’ going to cost?” At less than $400 why not get a great vac with auto tool plug? A no-brainer it seems.
Yeah, now that’s what I was talking about and exactly how I reacted when I first heard the news about these new filters/vacuums.
No… Not shameless commerce. Even if it is advertisement if it’s true and you can you the info then it helps. I would not have known this if I had not read this. It’s a free magazine. If they need to sell a few ads to pay bills, so I can read some of the amazing articles they send out, it’s ok with me and many others.. Even the ads like this are instructional. I found this magazine months ago because I was looking for information on building something and found an article in here about building wheelchair accessible ramps. Nobody else had anything as valuable and instructional and free to boot. I had a friend who had just mentioned he was building one. I was able to pass it on and help him out. Nothing is free in this world. If you want an ad free resource. They call those books. it’s sad but typical that those who have nothing to offer will still complain about free stuff.I love the articles and look forward to reading it for a long time.
Advertising has NOTHING to do with the content of our articles. NOTHING. Advertising doesn’t even cover the cost of publishing this magazine. Sure, it’s nice to have some income, but this magazine is produced as a courtesy and benefit to Katz Roadshow attendees and any other readers who appreciate comprehensive thorough articles on sometimes difficult and sometimes silly subjects about our craft–subjects that aren’t often published in other magazines. We will publish anything about any manufacturer if we believe the story is of value to our readers….of value to our readers…of value to our readers.
I believe that the article may be sending some confusing information. In full disclosure I am a Festool user and enthusiast. I am also a moderator of the festoolownersgroup forum. I am not a paid employee of Festool and have no authority to speak for them officially. The following are my opinions and my understanding only.
In reading the article I believe that readers may get the impression that the CT-22 mentioned has been certified in independent testing to meet the EPA standards. Based on my reading of information published by the manufacturer, that is not the case. In the information published by Festool, their current lineup of 5 dust extractors ( Mini, Midi, CT-26, CT-36, and CT-48) has been tested and certified to meet the applicable standards. The CT-22 and the CT-33 as complete units have NOT been tested for certification. The HEPA filters in those two units have been tested to meet the HEPA filter requirements and have been certified, but the air bypass requirement for the full machine has not.
Please refer to the links in the article for detailed information.
Maybe someone from Festool…like Rick Bush (hint hint)…can chime in here and make sure we’re clear on this issue?
“If you own a Festool CT 22 or CT 33 dust extractor, you can view or download a PDF copy of the CT 22 and CT 33 HEPA Filter certificate. However, please be aware that, based on our interpretation of the current EPA-RRP regulations, the only certification that will fully comply with EPA RRP guidelines is the Full Unit HEPA Certification, which is not currently available for the older CT 22 and CT 33 units.”
Apparently they do not meet the NO bypass leakage requirement set forth by EPA. The Festool statement that shipped with my ct26 says that as of October 2011 ALL of their dust extractors are shipped as “Certified Full Unit HEPA Dust Extractors.”
Does that help? I don’t work for Festool, but it would seem the info is out there.
Glad you and some others found my typo. I can’t comment on the certification of the 22 or 33 (I’ll let better men take care of that) but I actually used a CT26.
Sorry for the confusion but it brought up a good question.
To all those who take time to make your voice heard:
Thank you for all the comments. I’m sorry I can’t respond to all of them individually and I’d like to thank Gary for standing in for me while I’m away.
I’d just like to say 3 things: 1, whether I think the RRP/EPA is right or not, it is still a requirement and I don’t feel comfortable ignoring it. Plus, if I do a good job ‘educating’ my client (do not read as ‘scaring’) they understand I’m looking out for their best interests. That builds confidence.
2, I chose to right this because it works for me. If someone else knows better, tell us; I for one am listening. Why do you think I read this in the first place? And I don’t give a %#£@ who makes it. Quite frankly, if I found something that worked equally as well but cost less, I would be using it. So seriously, if you know something that’s worth sharing, odds are someone wants to hear it.
And 3: Air and respiratory health are very important, regardless of requirements. If you think lead or asbestos are the only things that aren’t good for you you’re on crack. I’m not saying one whiff of dust will turn you into a pile of dust but it certainly won’t make you live any longer.
Bottom line: work smart, be productive, and try not to let governmental reqs make you forget the passion we all have for what we do
Signing off from Ethiopia :)
I think you meant glass half-empty, but we got your point.
Just switching out your filter does not magically clean the tool head, wand, hose, and housing of the vac, so you will be pumping traces of lead into your longlife bag.
As Bill R. said, “If you realize how little exposure is required to cause neurological damage to a child than you know there is enough potential lead dust on your tools to fit the bill.”
Multi-purpose tools are great, but your vac, tool heads, wand, and hose should all be RRP-dedicated. Get another vac that you can feel comfortable letting your kids use to clean up the shop, and don’t use it for remodeling.
Your right about contamination. What I did the first time was wipe everything down (seals/housing – int & ext) with baby wipes. Cheap, biodegradable, and since my kid was under a year old…readily accessible :). I used this practice because it was taught in my Renovate Right class.
As for the rest – the hose (which was my biggest concern with all the corrugations), wand, and head – were rinsed thoroughly. Again, this was my understanding of best practice.
In truth though, I intend to follow your advice anyway. One vac is really not enough if you have multiple tools and want to be efficient. I don’t know if I will dedicate one specifically for RRP because I don’t do it that often and I would probably clean it out anyway because I store it in my van. Don’t want to be inadvertently ingesting that stuff.
Bill and Gary, it is surprising how many people are unaware of the risks of remodeling around lead.
I’m only 27 and thank God that I was introduced to Festool/dust collection/safe lead handling practices at a young age! I talk to guys in their 50s all the time that look at me strangely when I tell them that I have most of my tools on dust collection because it’s unhealthy to breathe just saw dust. Not to mention lead dust!
This is why I own 4 Festool vacs with auto tool plugs and have at least 3 on the job when I’m doing even a mid size trim job. I can have my miter saw, sander, router, domino, etc. hooked up and ready to go at all times. It allows me to use the dust collection without inconveniencing productivity.
Oh yeah, I usually only clean up saw dust on the job site on Fridays for the weekend.
I like to reply to as many comments as I can – both questions/concerns and the positive. All I can say is I wish I knew at 27 what you know now. Keep up the good work…and think about writing sometime.
For anyone looking for the official Festool information, here are the three web pages for reference.
I have a CT 36 and I signed up for the free replacement filter as soon as Shane Holland posted about it on the Festool Owners Group site and it took 23 days for me to receive it. That might vary with the amount of requests they get, so by now, it may take less time.
9 days from order to delivery for me. I don’t follow the FOG much so we may have had differing submission dates. Either way, they sent it…for free! Someone needs to tell them they could have charged us, but maybe we should wait till everyone else gets their filter too ;)
Nice informative article Matt.
I got a CT26 when I bought my Kapex. Just received the “new” Hepa filter and certificate. For those of you with a CT22 or 33 who need a RRP compliance vac, sell it and upgrade. I sold my 3 year old MIDI for $300. (In hindsight though, I should have kept it) I stay away from RRP category work, too much
rigamaroll for a solo guy.
As far as the RRP Rules and getting fanatic about the inside of the hose.
You do a RRP job and follow all the prescribed procedures. Now the HO sees a PI lawyer ad for lead and has their 7 year old’s blood tested for lead. It’s shows positive because the kid has lived there for 7 years. So now guess what……..
I ain’t a gambler.
I’ve taken the EPA class and learned of a few reasons to avoid the Festool model; Cross contamination. The instructor actually suggested taking off the wheels and any attachments that couldn’t be cleaned easily. He had stories of failed clearance testing because the workers pulled the vacuum around on the dirty wheels. With it’s convenient on-board storage, Festools are practically impossible – and very time consuming – to clean. I’ve pretty much decided to sub out the demo on lead jobs due to the likelihood that I won’t follow the law closely enough to win the lawsuit by the NEXT owners of the house I did the work on. And the subs out here in Oakland CA have all used Fein brand vacuums with the wheels removed. One crew just keeps adding a new layer of duct tape on the bottom to give a new, clean, slick surface. It was about 1 1/2″ thick last time I saw it. And yes, that means having a dedicated lead vacuum – or sub-ing it out.
The trouble with this whole RRP “should I do it; should I not” discussion is that it is as subjective as each job we take on. I don’t know about you but pretty much every job I walk into has a different problem that needs solving and it’s not often that I repeat the same thing over and over. The difference in doing a whole house remodel and replacing an old window (both which could feasibly fall under RRP) is just one example of how vast the scope of work could be. I personally wouldn’t take on a job that I thought would be out of reach for my abilities. There are those that I must refer to others just for that reason.
I think for me in the end it just comes down to having the option and not having to make another investment in machinery to accomplish what needs to be done.
Oh BTW, I like the Fein too. Never researched it for RRP work but a good unit none the less. Worked for a guy who had one and never had an issue with it – other than the fact that while carrying it on icy steps one day, I slipped an put my fist right through the top :/
Hope the Festool gods don’t strike me dead with green lightning for posting this :)
First, Matt I apologize for going a little off topic.
1) You’re on the hook for your subs if they don’t follow closely enough.
2) The RRP clearance test was a wipe for dust not lead, maybe he meant an abatement job.
3) How is a “dirty” dedicated unit with an 1 1/2″ of duct tape cross contaminating less than one that is not easily cleaned ?
If you can’t clean a vac well enough to use on a nonlead job to eliminate cross contamination, a dedicated one would leave traces behind every lead job.
Again sorry for off tracking but RRP is still very confusing, Thank EPA !
This is an inevitable conversation that we all know will come up. Is the RRP a bit confusing: Yes. I wish I knew more about it when this law was in it’s early stages. We all might have done more to make it more well defined and user friendly.
I’m with you on the upgrade too. If you look around you will see that anything with a Festool label doesn’t lose much of it’s value when resold. This applies to tools that are out of production too.