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EHS Associates, Inc.
The Future of Surface Refinishing
By Bryon Snapp / EHS Associates, Inc.
I recently returned from an EPA sponsored “Train-the-Trainer” workshop held in Kirkland,
Washington. The focus of the daylong workshop was to provide
assistance and best practices information regarding compliance with
the new EPA regulation “National Emission Standards for
Miscellaneous Surface Coating Operations”.
The new EPA requirements are put in place to reduce air emissions
from body & paint operations. Many paint products used in refinishing
work contain the chemicals EPA is targeting - and these new
regulations require refinishing operations to do several things to
prevent these chemicals from getting into the air during spray painting.
Do you spray finish partial or complete cars, trucks, recreational vehicles, buses or equipment such as
tractors, construction equipment or the implements they use? If so, this new rule may directly affect
you and your business.
Spray applied surface coatings such as primer, basecoat or clear-coat that contain any of the following
five hazardous air pollutants (HAPs) will qualify you for this rule: 1) cadmium, 2) chromium, 3) lead, 4)
manganese, or 5) nickel.
The basic requirements of the new rule will require you to:
If your business had an established surface-refinishing component PRIOR to September 17th, 2007, you
have until January 10th, 2011 to comply with this rule—all of the rule requirements must be in place
by that time.
If the initial start-up of your surface refinishing business or reconstructed surface refinishing business
was AFTER September 17th, 2007 you must currently be in compliance with the new rule.
EHS Associates, Inc. is here to assist you with this new rule.
If you would like us to conduct an in-house visit and help you create
a game plan, please give us a call. You have two years to get ready;
please do not wait till it’s too late!
By Bryon Snapp / EHS Associates, Inc.
I recently returned from an EPA sponsored “Train-the-Trainer” workshop held in Kirkland,
Washington. The focus of the daylong workshop was to provide
assistance and best practices information regarding compliance with
the new EPA regulation “National Emission Standards for
Miscellaneous Surface Coating Operations”.
The new EPA requirements are put in place to reduce air emissions
from body & paint operations. Many paint products used in refinishing
work contain the chemicals EPA is targeting - and these new
regulations require refinishing operations to do several things to
prevent these chemicals from getting into the air during spray painting.
Do you spray finish partial or complete cars, trucks, recreational vehicles, buses or equipment such as
tractors, construction equipment or the implements they use? If so, this new rule may directly affect
you and your business.
Spray applied surface coatings such as primer, basecoat or clear-coat that contain any of the following
five hazardous air pollutants (HAPs) will qualify you for this rule: 1) cadmium, 2) chromium, 3) lead, 4)
manganese, or 5) nickel.
The basic requirements of the new rule will require you to:
- Provide the EPA with an “Initial Notification”, indicating that you are subject to the new rule.
- Provide the EPA with an “Annual Notification of Changes Report”,
- Use a fully enclosed and ventilated under negative pressure paint booth to spray finish complete
vehicles. - Use a spray booth or station with three complete sides and a roof to paint vehicle subassemblies
while ventilating to draw vapors into the booth or station. - Install and operate spray booths and stations with filters that are at least 98% efficient at
removing paint particles. - Apply coatings with high volume / low pressure (HVLP) spray guns or equivalent spray gun
technology that meets the specifications of the new rule. - Use a fully enclosed spray gun cleaner to clean paint equipment and prevent the practice of forcing
gun-cleaning solvents through the gun under pressure. - Train and certify painters in the new rules, proper spray gun selection, spray techniques,
maintenance and environmental impacts within 180 days. - Retrain painters every five years.
- Maintain records of painter training, booth filter efficiency ratings, spray gun transfer efficiency
ratings, EPA notifications, submitted EPA reports and records of deviations.
If your business had an established surface-refinishing component PRIOR to September 17th, 2007, you
have until January 10th, 2011 to comply with this rule—all of the rule requirements must be in place
by that time.
If the initial start-up of your surface refinishing business or reconstructed surface refinishing business
was AFTER September 17th, 2007 you must currently be in compliance with the new rule.
EHS Associates, Inc. is here to assist you with this new rule.
If you would like us to conduct an in-house visit and help you create
a game plan, please give us a call. You have two years to get ready;
please do not wait till it’s too late!
