The U.S. Environmental Protection Agency (EPA) is proposing to regulate paint-stripping operations that use methylene chloride and surface coating and autobody refinishing operations that use paints containing hazardous metal compounds. The rule targets hazardous air pollutants (HAPs), which the agency believes may cause cancer or other health disorders. The rule would apply to most coating activities that emit HAPs.
The EPA intends to establish “best practices” (spray booth, spray gun cleaning, etc.) for minimizing HAP emissions during surface-coating operations. All shops would be required to have a filtered spray booth or prep station and use high-volume low-pressure (HVLP) or equivalent spray equipment. Spray guns would be required to be cleaned manually or with an enclosed spray gun washer. The EPA believes many shops have already implemented these best practices. According to the EPA, those facilities that have not yet done so could recover the cost of new equipment and training through a more efficient use of labor and materials. The EPA notes that OSHA already requires spray finishing operations to be performed in a booth or similar enclosure (although the new EPA rule could necessitate the use of more efficient filters than are currently used).
Owners and operators would be required to provide training for their painters on how to properly spray surface coatings and clean the spray equipment. The EPA would prefer that training be comparable to existing programs offered by I-CAR (The Inter-Industry Conference on Auto Collision Repair), STAR (the Spray Technique Analysis and Research program) or other certification organizations. The EPA also anticipates that training and certification programs would be available through state and community colleges or industry initiatives. Painters would be required to complete refresher training and be re-certified every five years.
In addition, owners or operators of a paint-stripping/surface-coating operation would be required to provide the EPA with contact information, a brief description of the operation, the number of spray booths and average number of employed painters and other basic information. Reports would be filed on a yearly basis certifying that the operation is in compliance or identifying activities which do not comply. Owners and operators would also have to maintain records for at least five years that verify painter training/certification, filter replacement, spray gun information, etc.
The rule would not require individuals to produce a training certificate in order to buy paints and coatings. The rule would not apply to painting done with an airbrush or hand-held non-refillable aerosol cans. The EPA did not specifically address “miniature spray guns” that are being used in open areas. It may seek to require spray booths for these operations when it issues a final rule, which is expected in 2008.
The proposal also did not exempt facilities that conduct limited coating operations. Once issued, the EPA will likely provide two years for most businesses to comply with the rule. SEMA intends to submit comments on the proposed rule, which are due on October 17, 2007. SEMA requests industry feedback as soon as possible so that it can be reflected in the comments. Comments may be directed to Jason Tolleson at jasont@sema.org or 202/783-6007, ext. 39.
Link to three-page overview of the proposed rule: www.epa.gov/ttn/oarpg/t3/fact_sheets/paintstrpng_fs090607.pdf
Link to EPA proposed rule: http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-17973.pdf