Auto Body Refinishing Operations: What EPA’s 6H Means To You

If your organization is involved in auto body refinishing, you may have received a letter recently from the Indiana Department of Environmental Management (IDEM), outlining the requirements set forth by 40 CFR 63 Subpart HHHHHH (or 6H), the “National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources.” To further our commitment to keeping our clients informed and in compliance, we have created an overview of this regulation, reviewing the type of operations affected, the reporting process, and the compliance procedures.

Intent of 6H:

The goal behind 6H is to reduce emissions of certain listed heavy metal Hazardous Air Pollutants, called Target HAP’s. Target HAPs include Chromium (Cr), Lead (Pb), Manganese (Mn), Nickel (Ni) and Cadmium (Cd). These materials are found in many of the paints and strippers used in the auto body refinishing industry.

Operations to which 6H may apply include:

• Automotive refinishing, unless specifically exempted;
• Paint stripping, if strippers containing methylene chloride (MeCl) are used;
• Surface coating, if certain Target HAPs are used. Current or future use of paints containing Target HAPs is regulated under 6H.

6H Reporting Requirements

If an operation is:	Then…
not an automotive refinisher, and does not use MeCl or Target HAP’s,	this rule is not applicable.
an automotive refinisher, and does not use any of the Target HAPs (and never will),	a petition for applicability exemption should be submitted to the EPA administrator.
a user of MeCl or paints containing any of the Target HAP’s,	an initial notification should be submitted to the EPA administrator. Next, training should be conducted, and then a Compliance Status Report should be submitted stating company compliance. According to the EPA, even if a company is out of compliance, the sooner the process toward compliance is completed, the better.

6H Compliance Process Dates:

• Initial Notification should have been submitted to the EPA by January 10, 2010.
• Initial training for employees should have been conducted by January 10, 2011.
• New Employees must be trained prior to working in a paint booth.
• Notification of Compliance Status Report is Due March 10, 2011.
• Annual Report must be completed every time a change in compliance status or method of compliance occurs.
• Employee retraining must be conducted every 5-years.

Training:

Within its rules, 6H specifies the areas training programs must cover:

1. Spray gun equipment selection, set up, and operation, including: measuring coating viscosity; selecting the proper fluid tip or nozzle; and achieving the proper spray pattern, air pressure and volume, and fluid delivery rate.
2. Spray technique for the different types of coatings to improve transfer efficiency and minimize coating usage and overspray, including: maintaining the correct spray gun distance and angle to the part; using proper banding and overlap; and reducing lead and lag spraying at the beginning and end of each stroke.
3. Routine spray booth and filter maintenance, including filter selection and installation.
4. Environmental compliance with the requirements of 6H.

Other 6 H Requirements:

• There must be documentation available from the filter manufacturer certifying the exhaust filters on the paint booths to be at least 98% efficient.
• All spray guns must be high volume low pressure (HVLP) or have documentation certifying they are HVLP equivalent.
• Other detailed requirements. Please contact DECA for further information.

Making sure your company comes into and maintains compliance with federal and state environmental regulations is not always a straightforward task. DECA’s Compliance Program can guide you through the full compliance process, or can address just specific portions. Our program will ensure compliance for your company, provide training documentation and certificates for your employees, maintain records, and create an online compliance calendar to make certain the re-training dates are not missed down the road. Please call our office (317-575-0095) for a free initial consultation on this Rule.
Note: This article is intended solely as an overview of the stated regulation. Please contact DECA or review the actual regulation for complete details.