Back to Federal guidance

Cold DOP aerosol testing of vacuum HEPA filters

Summary OSHA answered whether vacuum HEPA filters could be certified using cold DOP aerosol. It said cold aerosol has a broader particle size distribution than the thermally generated test aerosol and was not acceptable for testing and certifying filter efficiency under the asbestos standards. OSHA marks the posted memorandum as corrected in 2005.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-09-06
Date issued
September 6, 1990
Status
Active
Status last verified October 9, 2026

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

September 6, 1990

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

ATTN: ARA'S FOR TECHNICAL SUPPORT

THRU: LEO CAREY, Office of Field Programs

FROM: THOMAS J. SHEPICH, Director, [Directorate of Science, Technology, and Medicine]

SUBJECT: High-Efficiency Particulate Air (HEPA) Filters For Vacuum Cleaning Equipment

We have recently received inquiries regarding "cold" DOP (dioctyl or di-2-ethylhexyl phthalate) aerosol, generated at ambient temperature, and whether it can be used to test vacuum cleaner HEPA filters to meet the requirements as specified in the OSHA asbestos standards 29 CFR 1910.1001 and [29 CFR 1926.1101].
The HEPA filter test method, commonly employed by the nuclear industry and the military, uses a thermally generated monodisperse DOP aerosol as the challenge agent. The mass median particle size for the monodisperse aerosol is 0.3 micrometer, since this size is considered to be the most difficult to remove by the filter media.
The significant difference between "cold" DOP aerosol which is polydisperse and thermally generated DOP aerosol which is monodisperse is not widely understood. Many distributors and operators of filtration equipment, when specifying filters, do not differentiate between monodisperse and polydisperse DOP testing, believing the reference to "DOP" is all that is needed. The main difference between the "monodisperse" and "polydisperse" aerosol, is the particle size distribution. The geometric standard deviation of a monodisperse aerosol is less than 1.4, while the standard deviation for a polydisperse aerosol usually exceeds 2.0. Consequently, since polydisperse DOP aerosol has a size distribution outside the range of thermally generated monodisperse aerosol, "cold" DOP aerosol is not acceptable for use in testing and certifying the efficiency of HEPA filters.
Please contact [the Directorate of Science, Technology, and Medicine at (202) 693-2300] if you have any questions.
[Corrected 6/2/2005]

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace