SCRS and Affiliates Issue Letter to EPA Regional Offices on 6H Rule - BodyShop Business
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SCRS and Affiliates Issue Letter to EPA Regional Offices on 6H Rule


In a letter released on Monday, April 4, 2011, the
Society of Collision Repair Specialists (SCRS) and 26 of its Affiliate
Associations requested more stringent interpretation from the 10 U.S. EPA
regional offices regarding the exemptions listed in the EPA 6H Rule.

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The letter specifically addresses the growing use of 3
oz. paint cups to potentially exempt affected businesses.

"Unfortunately, the application of the rule has
created a practice where some businesses are claiming to be exempt by filling 3
oz. cups multiple times while doing traditional collision repair operations in
an attempt to continue to perform the work in an uncontained or mobile
environment," the letter states. "It is our position that an
exemption which invalidates pollution controls based solely on the size of the
tool being used rather than the amount of pollution being generated is
ineffective and harmful policy; because the rule is silent on the refilling of
the 3 oz. cups, there exists a continued potential to circumvent the


"This is an extremely sensitive issue in markets
like ours in New Jersey that have a growing population of mobile
refinishers," said Alliance of Automotive Service Providers of New Jersey
(AASP/NJ) Executive Director Charles Bryant. "Our member repair facilities
are working diligently to meet and often exceed the standards of environmental
responsibility, and that advancement often requires an investment on their
part. It is important to ensure that everyone operating within the market is
meeting these requirements, and that we don’t have entities undermining the
intent of the regulations so that they can compete unsafely without needing to
recover the investment in the standard. AASP/NJ is so appreciative to have an
organization with such size and credibility like SCRS, and its affiliates, to
work with on these issues."


SCRS and the endorsing associations recommended that the
EPA Regional offices refer to language found in the comments documented in the
federal register that indicate that the initial purpose of the exemption was
specifically to address stone chip, scratch and small graphic airbrush work –
and to distinguish that work from work done in a conventional collision repair

The letter suggests "that this exemption of 3.0
fluid ounces (89 cubic centimeters (cc)) or less should be changed to read that
a hand-held device with a paint cup capacity that is equal to or less than 3.0
fluid ounces (89 cc) cannot be refilled or be able to spray more than 3.0
fluid ounces of spray-applied coating per vehicle repair."


The letter also reiterates additional comments in the
federal register that specifically say that mobile refinishers are still
subject to the rule requirements for "training, spray equipment and use of
a spraybooth or other ventilated and filtered enclosure" if they’re
performing more traditional collision repair functions.

The letter specifically requests a documented response
from the EPA on three items:

• The exemption for
coatings applied with a paint cup equal to or less than 3 fluid oz., and
clarification that the rule applies to the type of work being performed


• That a 3 fluid oz. cup cannot be
used and repeatedly filled to circumvent the rule.

• Clarification that while a business applying coatings may
be exempt from Rule 6H by meeting certain stated requirements, the exemption
does not negate other additional regulatory requirements (such as OSHA, local
zoning codes or fire ordinances) that may prohibit spraying flammable solvent
or coatings with Hazardous Air Pollutants (HAPs) outside of a contained

"Efforts such as this, where SCRS is working
side-by-side with our affiliates to address real issues in the marketplace,
speaks directly to the foundation which SCRS was built upon," said SCRS
Executive Director Aaron Schulenburg. "We have been fortunate to grow this
network of strong and active associations, and harnessing our collective voice
is perhaps one of the most effective resources we have to work with. This
approach has proven to be succesful in other situations, and I am confident
that as we continue to apply this approach of working together with our
affiliates, and other interested associations, we will realize the tangible
betterment for our collective membership that we seek."


Once received and compiled, the responses will be
distributed through the SCRS Affiliate Associations and posted to the SCRS

More information:

Read the full letter






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