Paint Booth Usage Affected by New EPA Rule

WASHINGTON DC – Paint booth usage is now affected by a new EPA rule. The New EPA rule which goes into effect will affect automotive repair shops in the the USA. The new rule is called EPA Rule 40 CFR Part 63 – Subpart 6H and the compliance date is January 10, 2011 for existing shops.

Spray booth operations

The new EPA rule is described fully in a PDF document, published in the Federal Register and is entitled: Environmental Protection Agency, 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources; Final Rule.

The Purpose of the New EPA Rule

The rule, also known as “The 6H Rule”, “Rule 40″ or “The Refinish Rule” was first published in 2008. The purpose of the new rule is to reduce hazardous air pollution (HAPs) of metals (like chrome, lead cadmium, manganese and nickel) and reduce methylenechloride fumes from Autobody refinishing work. The new rule is available as a free download from the EPA website

Activities Affected by The New Rule

The new rule regulates three activities:

  • Paint Stripping
  • Surface coating of motor vehicles and mobile equipment
  • Miscellaneous Surface coating operations

Area Source Categories Renamed

The EPA has also renamed some of its area source categories to more accurately reflect the scope of these source categories. Accordingly, the new rule states:

“Plastic Parts and Products (Surface Coating)” has been renamed “Miscellaneous Surface Coating,” and “Autobody Refinishing Paint Shops” has been renamed “Motor Vehicle and Mobile Equipment Surface Coating”

Compliance With The New Rule

What must collision repair shops do to comply with the new rule?

  • Use HVLP or equivalent transfer efficiency
  • Use only enclosed prep stations and spray booths meeting the definition of this rule (w/ minimum 98% efficient filters)
  • Train all painters to utilize the required technology, including methods to minimize overspray/waste
  • No spray gun cleaning by atomization of cleaning solvent into filters; must use hand breakdown of guns for cleaning or enclosed gun cleaner apparatus
  • Keep records to demonstrate compliance
  • File required notification with EPA and/or your state or local air agency

Failure to follow these steps could lead to heavy fines.

Spray Booths and Prep Stations

Spray booth and prep stations must meet the requirements of the new rule.

  • All spray-applied coatings must be applied in a prep station or spray booth.
  • For motor vehicle and mobile equipment surface coating, prep stations and spray booths
    that are large enough to hold a complete vehicle must have four complete side walls or curtains and a complete roof.
  • For motor vehicle and mobile equipment subassemblies and for miscellaneous surface coating, coatings must be spray applied in a booth with a full roof and at least three walls or side
    curtains.
  • Openings are allowed in the sidewalls and roof of booths used for miscellaneous surface coating to allow for parts conveyors, if needed.
  • The exhaust from the prep station or spray booth must be fitted with filters demonstrated to achieve at least 98 percent filter efficiency of paint overspray.

Helpful links:

  • EPA Autobody Refinishing Shops 40 CFR Part 63 Subpart HHHHHH Rule
    http://www.tat-co.com/media/cms/6H%20Training.pdf
  • The U.S. Environmental Protection Agency’s (EPA) new rule, 40CFR63 Subpart HHHHHH
    http://www.tat-co.com/media/cms/6H%20Targeted%20HAPs%20Letter.pdf
  • EPA RULE 40 CFR PART 63 SUBPART HHHHHH
    http://www.tat-co.com/media/Training%20Certificate_6H.pdf
  • Are You Ready For The 6H Rule?
    http://www.tat-co.com/blog/regulations/are-you-ready-for-the-6h-rule/

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