NYC-WTC_000209427

NYC 9/11 Public Portal Document

EPA FINDS HEPA VACUUMING DOES NOT REMOVE ASBESTOS FROM CARPETS, AND EPA POLICY ON CONTAMINATED CARPETS

EPA studies show asbestos that is embedded in a carpet will not be removed with a HEPA vacuum cleaner. EPA studies also found that even wet process HEPA vacuum systems (steam or water extraction combined with a HEPA vacuum) will only remove 60% of the asbestos. The abstracts of these EPA studies are included in the endnotes/references, and the full studies are available online.’’ HEPA stands for “high efficiency particulate air filter.” A HEPA vacuum does not have more suction power for removing dirt from carpet, it only has an additional filter that does not allow very small particles, indue ing asbestos fibers, to be released in the exhaust.

High impacts such as foot traffic, hitting, or playing on carpet, upholstered furniture, or draperies will release asbestos even if these items were HEPA vacuumed. In addition, asbestos will work its way through the rug backing and settle on the floor or cushioning, which cannot be reached by any kind of vacuum.

Intuitively, if any kind of vacuum really could remove all dust and dirt, then carpeting would always return to its original pristine condition after vacuuming, never getting dirty and needing replacement. Th ere is nothing magic about a HEPA vacuum in its cleaning powers - it only has a better filter to reduce emissions.

Regulations and policy on replacing asbestos-contaminated carpet

Neither the EPA regulations under the Asbestos Hazard Emergency Response Act (AHERA), which covers schools, nor the Clean Air Act (CAA) asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) specifically require the removal of asbestos-contaminated carpet. The regulations instead only require cleaning surfaces to background levels, as well as requiring no visible dust. You would need to argue that if you pulled the carpet back and folded it, you could see dust in the fibers along the backing, or on the cushioning or under the cushioning.

However, the U.S. Army Corps of Engineers has guidelines that are clearer on asbestos- contaminated cai-pet.” They specifically require that carpet to be removed if contaminated with any level of asbestos, not just levels over 1%. The only abatement option is removal, not cleaning.

-8-

CITY_21MC100_002847464

NYC-WTC_000209434