Welcome to KPA’s webinar for the updated body shop rules, EPA’s New Emission Standards for Collision Centers.In 2008, the EPA published a new regulation which will require all collision centers to take action in one form or another. Today we are going to review these new requirements and provide you with the information you need to help you achieve compliance.
These regulations can be found in 40 CFR Part 63, Subpart HHHHHH, and thus these regulations are commonly referred to as “The 6H Rules”, also known as the new emission standards for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.
The requirements of this rule cover 7 areas; Notification, Painter Training, Spray Gun Selection, Spray Gun Cleaning, Spray Booths, Re-Notification and finally Recordkeeping.Now we want to break down these individual requirements in detail so that you can have a good working knowledge of these regulations.
The first step is Notification.The Deadline is January 11, 2010 , whichis just 3 months from now.You can use the Federal Initial Notification Form that you will receive a link for in a follow-up email. This form can be a bit confusing, so let’s point out a few things…
When you are filling out these forms, it is important to remember that these forms are not just for body shops, so some of these questions are not going to apply to your facility - they are directed more at paint stripping operations.On the form at this link we have already checked off some of the boxes to reflect the proper response for the typical collision center.
Also on the initial notification form it is very important that you DO NOT sign it at the bottom. If you sign the form now you are certifying that you are already in compliance with the 2011 requirements, which we have not yet covered.The only facility that would need to sign this now would be a new source that is confident that they are in compliance, which would be rare at this point.
It would also be a good idea to check with your state’s environmental protection agency to see if they have developed their own version of this form. Another great resource for this is the Small Business Environmental Business Assistance Program, and there website is on the screen.
It is very important that whenever you are sending a required form to a regulator like the EPA, be sure that you send it by means of a traceable route to prove it was sent and that it was prior to the deadline.Alright - That is it for the first step. Everybody catch your breath and we will move on.
Just to clarify, January 11, 2010 is the upcoming deadline for the initial notification.January 10, 2011 is the deadline to meet the additional major compliance requirements, which we are about to cover.You will also need to Re-Notify by March 11, 2011. On this second notification you will sign the form this time, stating that you are in compliance with all of the new requirements. We will discuss Re-Notification procedures near the end.So what are the 2011 requirements? Let’s look at them now…
So let’s look at the Painter Training Requirements.ALL Painters must be certified by January 2011, and will need recertification every 5 years. New employees must be trained within 180 days of hire.This training is available from multiple sources currently and the availability will increase as we get closer to the 2011 deadline.
Painter Training Must Include:Spray gun equipment selection, set up, and operation.Spray techniques for different types of coatings to improve transfer efficiency and minimize coating usage and overspray.Routine spray booth and filter maintenance.Environmental Compliance Requirements of these New 6H Regulations.
Let’s move on to the next step, spray gun selection.You need to make sure ALL Painters are using HVLP Spray guns, or something that the EPA considers equivalent technology. The EPA will require you to obtain documented approval for non-HVLPspayers.
Let’s move on to Spray Gun Cleaning.Reading directly from the regulations, it says that “All paint spray gun cleaning must be done so that an atomized mist or spray of gun cleaning solvent and paint residue is not created outside of a container that collects used gun cleaning solvent.”So what does that mean?
Alright, we have covered more than half of the steps already…lets move on to a big one…Spray Booth Requirements.
The question I get most often about these new rules is if the EPA is now going to require all painters to have a paint booth? A paint booth is required, but this is not a new EPA rule. Technically, OSHA regulations already require you to use a paint booth. (29 CFR 1910.107)The EPA does however now specify the minimum requirements for a paint booth, which could also be a Prep Station or Mobile Enclosure, as long as they meet these requirements, which we will discuss now.
All Paint Booths, Prep Stations or Mobile Enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98-percent capture of paint overspray. What does that mean? They must be ventilated and use filters that are documented to be98% efficient.
Next, All Paint Booths and Prep Stations used to paint complete vehicles must be fully enclosed with a full roof, four complete walls or side curtains, and must be ventilated at negative pressureor have an automated pressure balancing system.
The next requirement for paint booths is that all Paint Booths and Prep Stations used to paint parts or subassembliesmust have a full roof, at least three complete walls or side curtains, and it must be ventilated so that air is drawn into the booth.
The final booth requirement is for the mobile spray booths. Reading directly from the regulations, “Mobile ventilated enclosures that are used to perform spot repairs must enclose and, if necessary, seal against the surface around the area being coated such that paint overspray is retained within the enclosure and directed to a filter to capture paint overspray.”
I want to make sure that we are clear on this…when refinishing these vehicles, it must be done inside an enclosure with filtered ventilation. If you are just refinishing a part, you still must do it inside an enclosure with filtered ventilation.
Assuming you followed the guidelines we laid out here, you notified the EPA by January 2010 that you would be in compliance with all of the items we just covered by January 2011. Once you do become compliant with these new requirements, you must Re-Notify the EPA by sending in the same notification form, but this time you will check off that you are now in compliance, and you will need to sign the form this time.
Once you have sent in your re-notification you do not need to send in any more notifications again unless your information or status changes. In that case you must send in the notification of changes by March 1st of each year.
And now to the last step, Recordkeeping. It may sound like a minor step, but if you have an EPA audit, you will soon learn that this is really the most important step. You must be able to provide documentation to the EPA to prove that you are in compliance.
copies of all notifications and reports required painter training certification documentation of filter efficiency if spray gun does not meet definition of acceptable technologies documentation from spray gun manufacturer that Administrator has determined equivalent transfer efficiency records of any deviations from requirements in the rule, including date and time period it occurred, a description of deviation, and corrective actions taken
Make sure you retain these records for at least 5 years, and we recommend you designate a specific location for these records.
The first complicated issue is whether or not your facility is considered a new facility or an existing facility. This is not based on when you opened your body shop or how long you have been in business at your current location. Under these 6H regulations, you are considered a new facility if you installed new equipment after September 17, 2007.
Existing facilities have the deadlines we have already discussed, mostly January 2011.Unfortunately, new facilities are supposed to be in compliance with all of these rules on the first day they were open. If you installed new equipment, you were to be in compliance on the date the equipment was installed.
So yes, all of these things we have just discussed, you are supposed to have done all of them already.
The last issue we need to cover is the exemption. Yes, you can apply for exemption from these new regulations, but KPA does not recommend this because it will be difficult to monitor and maintain your exemption status.
The first way to qualify for the exemption is to certify to the EPA that you do not use sprayed materials that contain these metals shown here. Despite what you think, almost all paint lines contain at least one of these metals or their compounds.
The other way to qualify for the exemption is to certify to the EPA that you only use a paint cup with a total capacity that is equal to or less than 3.0 fluid ounces. As most of you already know, that size is typical of airbrushing equipment, and not really practical for automotive refinishing.
If you are still determined to apply for the exemption, consider this…The EPA went as far to write into the Federal Register that they “expect that few, if any, petitions will be received” for the exemption.
Also, it does not appear that the new requirements are that strict and complying with them is not going to be as difficult as we originally thought.Alright, so that is the new Body Shop Emission Standards. Now wasn’t that fun?I am going to turn this back over to Cameron now…
Initial Notification Form
Initial Notification Form
Return Receipt Required
January 11, 2010
Deadline for Initial Notification
January 10, 2011
Must Meet Major Requirements
March 11, 2011
Deadline to Re-Notify
Painter Training Requirements
All Painters must complete by January 10, 2011
Renewed Every 5 Years
Available from Multiple Sources
Painter Training Must Include:
Spray gun equipment selection, set up, and
Spray techniques for different types of coatings to
improve transfer efficiency and minimize coating
usage and overspray.
Routine spray booth and filter maintenance.
Environmental Compliance Requirements of these
New 6H Regulations.
Spray Gun Selection
HVLP or Equivalent Technology
Electrostatic Application, Airless Spray Gun or an
Air-Assisted Airless Spray Gun
Written Approval Required from the EPA for Non-HVLP Sprayers
Spray Gun Cleaning
If you are spraying solvent through your gun to
clean it, you must collect the spray.
The EPA suggests using a fully enclosed spray gun
washer, but they do not require it.
Spray Booth Requirements
Is the EPA requiring all painters to have a booth now?
OSHA Regulations Already Requires a Paint Booth
Can be a Prep Station or Mobile Enclosure
29 CFR 1910.107
Spray Booth Requirements
Ventilation is Required
Filter Efficiency of 98%
Spray Booth for Refinishing Whole Vehicles
4 Complete Walls or Curtains
Ventilated at Negative Pressure
Spray Booth for Refinishing Parts
3 Complete Walls or Curtains
Ventilation that Draws Air In
Mobile Spray Booths
For Spot Repairs
Enclosed Enough to Retain All Paint
Overspray Must Be Directed to the Ventilation System
March 11, 2011 Deadline
Check off that you are now in compliance.
Must sign the form this time.
Annual Notification of Changes Report
Only required if your information or status changes.
March 1 Deadline
Most Important Step
Must be able to provide
What records must you keep?
Copies of all signed notifications you send to the EPA.
All signed receipts from the postal service that proves you sent your
Certification that each painter has completed the training.
Documentation of your filter efficiency.
Documentation for non-HVLP spray guns.
Records of any deviation from the requirements.
Must Retain Records for 5 Years
Designate a specific location to maintain these records.
Good News – We are almost done!
Bad News – We still need to cover 2 complicated issues.
If you installed new equipment after September 17, 2007.
Equipment includes: Mixing Room, Mixing Room Equipment, Prep
Station, Spray Booth, Spray Guns and Associated Equipment, Spray
Gun Cleaning Equipment, Solvent Recyclers
So you are a New Facility – What’s the big Deal?
Your Compliance Date was the Day You Opened!
New Facilities Should Already have done:
Spray Gun Selection
Spray Gun Cleaning
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