The Paint Rule impacts automotive body shop painting operations that use paint that contain Hazardous Air Pollutants (HAPs). This rule will not regulate hobbyists or facilities using paints that do not contain the listed HAPs. Notification of full compliance status is due by March 11, 2011. The journey begins with these two steps:
Step 1: Compliance
At this point, all collision repair facilities should be in compliance with the NESHAP 6H Rule and verified that your auto body shop has the appropriate state air quality permit in place. This permit is generally required to conduct a paint operation and emit air pollution in any given state. It is usually obtained at the start of operation, or at such time that the shop becomes aware an air permit is required in its state.
Action Item: Verify or obtain the appropriate state air permit for auto body painting in your state.
Step 2: Final Notification Form to Governing Agency by March 11, 2011
Shops subject to the requirements of the Paint Rule must make FINAL NOTIFICATION to the local governing agency or regional EPA by March 11, 2011.
Some Final Notification Forms are available by state and are to be completed and submitted to the applicable agency or agencies by the deadline. (Some states require the form to be submitted to the state Air Quality Division and the Regional EPA Office.) Many states did NOT accept NESHAP authority, so Final Notification forms should be sent to the regional EPA office. See State Delegation List at: http://www.epa.gov/collisionrepair/pdfs/statedelegations.pdf
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