Nebraska Autobody Association

EPA Air Quality Links  

EPA national emission standards for hazardous air pollutants      

for paint stripping and miscellaneous surcace coating operations

EPA Summary for Autobody Shops PDF     

EPA Rule For Surface Coating & Stripping PDF     

Shop's Initial Notification of Compliance PDF     

Paint Stripping Brochure PDF    

EPA Deadline FAST Approaching for all Body Shops

Written By:  Colette Bruce, Team Safety LLC (SCRS Board Member)   

By January 11, 2010 all body shops must file an Initial Notification with the EPA and/or their State identifying the shops compliance status with

the NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS NESHAP (SUBPART HHHHHH) which became effective in

January 2008.

Such notification may certify that the shop is currently in compliance with all aspects of the rule.  If a shop is not currently in compliance with the

rule, the notification may be filed stating  the shop will be in compliance by the final compliance deadline of January 10, 2011.  An additional

notification must then be submitted by March 11, 2011 to certify this compliance.  

This new rule is intended to control emissions from paint stripping and miscellaneous service coating operations.  To comply with this rule, all

shops must do the following:

Paint Stripping Operations

Implement management practices that minimize emissions of Methylene Chloride (MeCl).

-       Evaluate the need for paint stripping (e.g., is it possible to re-coat without stripping?).

-       Evaluate each application to identify potential alternative stripping methods.

-       Reduce exposure of strippers to air.

-       Optimize application conditions.

-       Practice proper storage and disposal.

For each paint stripping operation with > 1 ton MeCl annual usage, develop and implement a written MeCl minimization plan. No

implementation plan is needed if usage is < 1 ton MeCl; however, sources must still utilize work practices to minimize emissions of MeCl.

Consult the MSDS sheet to identify the amount of MeCl contained in the paint stripper, but note that annual usage should not exceed 181

gallons of MeCl.

Maintain records of annual usage of paint strippers containing MeCl.

Motor Vehicle/Mobile Equipment/Miscellaneous Surface Coating Operations.

-       Train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance (consult 73 FR

1738, pg. 1762, section 63.11173(f)(2)(i)-(iv)).

-       Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency.

-       Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative

pressure or up to 0.05 inches water gauge positive pressure for booths that have seals on all doors and other openings and an automatic

pressure balancing system.

-       Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete

walls or side curtains, and ventilated so that air is drawn into the booth.

-       Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or

air-assisted airless spray gun, or an equivalent technology.

-       Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that

collects used gun cleaning solvent.

-       Train and certify all personnel who spray apply surface coatings no later than 180 days after hiring or by July 7, 2008 (new sources) or by

January 10, 2011 (existing sources).

Once compliant, each shop must maintain a compliance file accessible for inspection. Such file should include the following documents:  

-       Copies of Notifications submitted to EPA.

-       Painter training certifications.

-       Spray booth filter efficiency documentation.

-       Spray gun transfer efficiency.

-       MeCl content information such as MSDS.

-       Annual usage of MeCl for paint stripping, and written MeCl minimization plan if annual usage > 1 ton per year.

-       Deviation and corrective action documentation.

An annual notification of changes report is then required to be filed each calendar year in the event any reportable changes occur.

To obtain further information and assistance in complying with this rule, contact the following sources:

EPA:

http://www.epa.gov/ttn/atw/area/arearules.html

State:

http://www.epa.gov/ttn/atw/area/table_state_contacts.doc

http://www.4cleanair.org/contactUsaLevel.asp

State Air Quality Division

State Small Business Environmental Assistance Program

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