Comment submitted by S. A. Grinshpun

The opinion below is submitted upon the EPA request to comment on whether the rule should allow the use of vacuums other than those equipped with HEPA filters. HEPA FILTERS. It is important to realize that the filter selection itself does not assure the desirable level of cleaning. The vacuum cleaner?s performance depends on the filter efficiency and the vacuum unit configuration/design characteristics. Our published studies showed that the pick-up efficiency and the filter by-pass effect may affect the overall capture efficiency as much as the efficiency of the filter. Furthermore, the overall efficiency of a vacuum cleaner (as well as the filter) is particle size dependent, and the supermicrometer leaded particles (carrying major weight) are, as a rule, collected more efficient than those of about 0.3-1 micron. Generally, I believe that it is appropriate to expand the required vacuum cleaners from ?HEPA vacuums only? to ?HEPA vacuums or other devices of equivalent efficacy? as articulated by the US Department of HUD. CLEARANCE AFTER HAZARD REDUCTION ACTIVITIES. In my opinion, the clearance requirement should be included as a part of the Lead Renovation, Repair and Painting Program, with no exceptions.