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By Jan. 11, all body shops must file an Initial Notification with the EPA and/or their state identifying their compliance status with the National Emission Standards for Hazardous Air Pollutants, Subpart HHHHHH (NESHAP or the 6H Rule), which became effective in January 2008.
The notification should either certify that the shop is currently in compliance with all aspects of the rule, or, if a shop is not currently in compliance with the rule, the notification can be filed stating the shop will be in compliance by the deadline of Jan. 10, 2011. An additional notification must then be submitted by March 11, 2011 to certify this compliance.
This new rule is intended to control emissions from paint stripping and miscellaneous service coating operations. To comply with this rule, all shops must do the following:
Paint Stripping Operations
Implement management practices that minimize emissions of methylene chloride (MeCl).
Evaluate the need for paint stripping (e.g., is it possible to recoat without stripping?).
Evaluate each application to identify potential alternative stripping methods.
Reduce exposure of strippers to air.
Optimize application conditions.
Practice proper storage and disposal.
For each paint stripping operation with greater than one ton MeCl annual usage, develop and implement a written MeCl minimization plan. No implementation plan is needed if usage is less than one ton MeCl; however, sources must still use work practices to minimize emissions of MeCl. Consult the MSDS sheet to identify the amount of MeCl contained in the paint stripper, but note that annual usage should not exceed 181 gallons of MeCl.
Maintain records of annual usage of paint strippers containing MeCl.
Motor Vehicle/Mobile Equipment/Miscellaneous Surface Coating Operations
Train/certify all painters on spray gun equipment selection, spray techniques, maintenance and environmental compliance (consult 73 FR 1738, pg. 1762, section 63.11173(f)(2)(i)-(iv)).
Install/operate filter technology on all spraybooths/stations/enclosures to achieve at least 98 percent capture efficiency.
Spraybooths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic pressure balancing system.
Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and be ventilated so that air is drawn into the booth.
Spray-applied coatings must be applied with a high-volume, low-pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology.
Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent.
Train and certify all personnel who spray apply surface coatings no later than 180 days after hiring or by July 7, 2008 (new sources) or by Jan. 10, 2011 (existing sources).
Once compliant, each shop must maintain a compliance file accessible for inspection. The file should include the following documents:
Copies of notifications submitted to the EPA.
Painter training certifications.
Spraybooth filter efficiency documentation.
Spray gun transfer efficiency.
MeCl content information such as MSDS.
Annual usage of MeCl for paint stripping, and written MeCl minimization plan if annual usage is greater than one ton per year.
Deviation and corrective action documentation.
An annual notification of changes report is then required to be filed each calendar year in the event any reportable changes occur.
Read "Featheredge, Prime and Block: Case Closed" in the upcoming January 2010 edition of BodyShop Business for more information on the 6H Rule and attorney Jim Rodenhouse’s assertion that the 6H Rule settles the debate among repairers and insurers on whether featheredge, prime and block is a body procedure or a paint procedure.
Initial Notification Document provided by the Automotive Service Association Collision Division