A new Environmental Protection Agency (EPA) rule, "40 CFR Part 63
Subpart HHHHHH, National Emission Standards for Hazardous Air
Pollutants: Paint Stripping and Miscellaneous Surface Coating
Operations at Area Sources," applies to all body shops and to many
other small shops that paint metal and/or plastic parts. It also
includes separate requirements for businesses that use chemical paint
strippers containing methylene chloride (MeCl).
The rule requires the specific use of specified equipment and
management practices. Shops must also keep records of training and
compliance activities, and must submit reports and notifications to the
EPA or other designated agencies. Existing shops have up to three years
to comply; new shops must comply upon start-up.
Shops that conduct the following practices and use the following equipment may already comply with many of the requirements:
- Apply spray coatings in a booth, prep station or mobile
enclosure; all with exhaust filters that capture at least 98 percent of
the paint overspray; - Use HVLP spray guns (or other application equipment with high transfer efficiencies);
- Use enclosed gun washers (or other methods that reduce emissions of cleaning solvent).
Shop owners must certify that their painters have received hands-on and
classroom training. Training and certifications are valid for up to
five years. Required topics include:
- Selection, setup and operation of spray equipment;
- Application techniques to improve transfer efficiency;
- Environmental compliance.
Although the EPA intends this rule to cover all body shops, there’s
no provision for shops to petition the agency for exemption. The
petition must include a description of coatings sprayed and a
certification that these coatings do not contain "target HAPs" or
compounds of cadmium, chromium, lead, manganese and nickel.
Akzo Nobel worked closely with the EPA to develop a checklist for best practices (click HERE).
To see the EPA’s Fact Sheet on the rule, click HERE.
For updates on the rule and other topics of interest to body shops, check out the "What’s New" link at www.ccar-greenlink.org.
