by Sue Schauls, CCAR Environmental & Safety Consultant
FAQS: Do Community Colleges and Vocational Schools need to comply with the Paint Rule?
YES. The new Paint Rule or the National Emission Standards for Hazardous Air Pollutants (NESHAP) 6H that applies to auto body shop means that school training programs need to be complaint with the rule too. Actually any commercial entity that surface coats metal with paints that contain any one of the target Hazardous Air Pollutants (HAPs) must comply.
FAQS: Is compliance difficult to achieve for schools?
NO. Most schools already operate in a compliant manner. In most cases the school simply needs to make sure that the paperwork gets filed with the appropriate agency. Specifically the NOTIFICATION FORM must be filed with the EPA Regional Office or the state AIR Quality agency that has taken delegation of the responsibility. A State Delegation list is maintained by EPA.
Download the NOTIFICATION FORM at http://www.epa.gov/collisionrepair/pdfs/6h_compliance_ex.pdf
Review the list of Agencies to which the FORM may be sent including State Delegations at http://www.epa.gov/collisionrepair/pdfs/statedelegations.pdf
FAQS: Is this the only paint permit the school will need?
NO. Every shop/school must ensure compliance with the state air quality division. Many states do NOT require small volume users to hold an actual air permit issued from the state, however to maintain the permit exemption the auto body shop must keep documentation on the volume of sprayables used each day.
Logging spray activity does not mean logging mixed paint volume.
Date Volume Mix Amount Sprayed Hazardous Waste Generated
8-3-11 3 oz 2 oz 1 oz
Most states have a Small Business Environmental Assistance Program and/or Small Business Ombudsman. Making contact with your SBAP is also a great way of getting included in workshop invitations and regulatory alerts. Find your state program at http://www.smallbiz-enviroweb.org/Contacts/sbosbeap.aspx.
FAQS: What are the “targeted HAPs”?
The rule applies if coatings contain targeted HAPs:
• Lead (Pb), (> 0.1 percent)
• Manganese (Mn), (> 1.0 percent)
• Nickel (Ni), (> 0.1 percent)
• Cadmium (Cd), (> 0.1 percent)
• Chromium (Cr), (> 0.1 percent)
The threshold level for the targeted HAPs in the Paint Rule is the same as for OSHA reporting via the Material Safety Data Sheet (MSDS). That means any one of the targeted HAPs is listed on any one MSDS in the school’s paint line makes the Paint Rule applicable at the facility.
FAQS: What are the Paint Rule Requirements?
Paint Rule Checklist
To have been completed by January 10, 2011
☐ Maintain record of state air emissions permit (if applicable)
☐ Maintain copies of the Paint Rule (NESHAP 6H) Initial Notification and/or the Final Notification forms sent to the appropriate agency
☐ Maintain manufacturer documentation of filter efficiency
☐ Maintain records of painter training participation (renew in 5 years)
☐ Paint booth exhaust systems must use 98% efficient booth filters
☐ Spray booths/prep stations must be used
☐ Spray guns must be efficient types such as HVLP
☐ Spray gun cleaning does not allow atomization of thinner through gun for cleaning and
☐ recommends an automated enclosed gun wash and/or
☐ hand cleaning of paint guns
☐ Painter training requires:
☐ Review of the rule
☐ Information on routine booth maintenance practices
☐ Discussion and hands-on practice of gun set-up
☐ Hands-on practice and discussion of spray techniques
☐ Final Notification of compliance due to EPA or state agency by March 11, 2011