The U.S. Environmental Protection Agency (EPA) has issued a rule to regulate paint stripping operations that use methylene chloride and surface coating, and auto body refinishing operations that use paints containing hazardous metal compounds. The rule targets hazardous air pollutants (HAP) which the agency believes may cause cancer or other health disorders. The rule applies to most coating activities that emit HAP but, notably, the EPA followed SEMA’s recommendation and exempted low-volume operations such as when hobbyists restore or customize one or two cars. The EPA incorporated a number of other SEMA suggestions to make the rule as friendly as possible for companies that have spray-coating operations.
The EPA rule establishes “best practices” (spray booth, spray gun cleaning, etc.) for minimizing HAP emissions during surface coating operations. All shops are effectively required to have a filtered spray booth or prep station and use high-volume low-pressure (HVLP) or equivalent spray equipment. Spray guns are 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 through a more efficient use of labor and materials. The EPA notes that the Occupational Safety and Health Administration (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 currently used).
Owners and operators are required to provide training for their painters on how to properly spray surface coatings and clean equipment. The EPA has established minimum criteria required for in-house training, similar 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. Painters would be required to complete refresher training and be re-certified every five years.
Existing operations have up to three years to purchase equipment and complete the initial training of employees. As recommended by SEMA, the EPA will rely on self-certification for training programs. Nevertheless, companies subject to the rule must send the EPA a one-time notification form stating that they are in compliance with the rule or will be within the allotted three years. Companies will have two years to submit the notification form which will contain contact information and a brief description of the operation: number of spray booths, average number of employed painters, etc. (SEMA will publish a sample notification form and EPA contact information when it becomes available). Companies will be required to maintain in-house records verifying painter training/certification, filter replacement, a plan to control paint stripping chemicals, etc.
SEMA worked closely with a number of member companies, other trade associations and the EPA to craft a rule that should have minimal impact on the hobbyist community. As a result, the regulation does not apply to paint stripping and surface coating performed by individuals as part of a hobby, or for maintenance of their personal vehicles so long as those activities do not exceed two motor vehicles (or the equivalent in pieces) per year.
Additionally, the rule does not apply to painting done with an airbrush or hand-held, non-refillable aerosol cans. As noted above, paint training is self-certified. The EPA did not pursue an earlier proposal that would have required individuals to produce a training certificate in order to buy paints and coatings. The rule is expected to take effect in January 2008, but as noted most businesses will have up to three years to comply with its various provisions.
For additional information, contact Stuart Gosswein at email@example.com.