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 was January 11, 2010.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…
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.
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.”
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
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.
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?
January 11, 2010
Deadline for Initial Notification
January 10, 2011
Must Meet Major Requirements
March 11, 2011
Deadline to Re-Notify
All Painters must complete by January 10, 2011
Renewed Every 5 Years
Available from Multiple Sources
This webinar does not satisfy all of the requirements
Painter Training Requirements
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
Painter Training Requirements
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 Selection
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 Gun Cleaning
Is a Booth Required Now?
OSHA Regulations Already Requires a Paint Booth
Can be a Prep Station or Mobile Enclosure
Spray Booth Requirements
98% Removal Efficiency or Higher
Must Be Documented
Dependent on Specific Shop conditions
4 Complete Walls or Curtains
Ventilated at Negative Pressure
3 Complete Walls or Curtains
Ventilation that Draws Air In
Parts or Subassemblies
For Spot Repairs
Enclosed Enough to Retain All Paint Overspray
Overspray Must Be Directed to the Ventilation System Filters
Mobile Spray Booths
March 11, 2011 Deadline
Check off that you are now in compliance.
Must sign the form this time.
Only required if your information or status changes.
March 1 Deadline
Annual Notification of Changes
Most Important Step
Must be able to provide
Maintain for 5 Years
Keep it organized
Copies of all signed notifications you send to the EPA.
All signed receipts from the postal service that proves you
sent your notifications.
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.
What Records Do you have to Keep?