Paint & Autobody Rule (6H)

On January 9, 2008, EPA issued a standard that regulates operations related to the Paint Stripping, Miscellaneous Surface Coating, and Motor Vehicle and Mobile Equipment Operations Area Source category - 40 CFR 63 - Subpart HHHHHH.

Since issuing the standard, the NC Division of Air Quality, NC Small Business Environmental Assistance Program, EPA Region 4 and paint manufacturing companies have engaged in an outreach effort to identify and help autobody shops and facilities comply with the rule.

This rule attempts to reduce emissions of cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn), and nickel (Ni) emitted during the spray application surface coating operations.

Also, the rule regulates paint stripping operations that remove dried coating using products containing methylene chloride (MeCl).

On November 10, 2022, revisions to 40 CFR 63 Subpart HHHHHH were published in the Federal Register. On or after May 9, 2023, autobody shops may simply submit a notification to the Administrator that they do not spray apply any target HAP containing coatings. A separate petition for exemption is no longer required. Autobody shops are still required to retain records that describe the coatings that are spray applied.  

The latest revisions to this federal rule also require all notifications/reports/forms to be submitted electronically to the United States Environmental Protection Agency (US EPA) at https://cdx.epa.gov.  A separate copy of each notification/report/form must also be submitted to the appropriate regional office of the North Carolina Division of Air Quality (NC DAQ) at the addresses found here: https://www.deq.nc.gov/DAQ-Regional-Offices.

Operation Categories

Subpart HHHHHH, commonly called 6H, includes three operation categories: Motor Vehicles and Mobile Equipment Operations, Spray-Surface Coating Operations, and Paint Stripping Operations.

Motor Vehicles and Mobile Equipment Surface Coating Operation

The Autobody Shop Rule regulates the spray application of coatings to automobiles, light trucks, heavy duty trucks, buses, construction equipment, self-propelled vehicles, and equipment that may be towed and/or driven on a roadway.

The rule applies:

  • If you spray apply, on any part or surface made of metal or plastic or a combination of both, coatings that contain the regulated hazardous air pollutants.
  • Or if you spray apply coatings to more than two motor vehicles or a piece of mobile equipment per year.

The rule does not apply to you if you paint personal vehicles, possessions, or property, either as a hobby or for maintenance and when these operations are performed without pay,

The rule requires all autobody shops to submit an initial notification form to the US EPA and the NC DAQ. The initial notification form will guide the autobody shop owner/operator through the process of determining if they are subject to the rule or exempt. Those facilities that are subject to the rule are required to take additional actions including, but not limited to, the following:

  • Train/certify all painters on spray gun selection, spray techniques, maintenance, and environmental rules.
  • Install and operate filters in ALL spray booths, stations and enclosures to capture at least 98% of the paint overspray.
  • Apply spray coatings with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or similar application method.
  • Clean paint spray guns so that no cleaning solvent or paint residue escapes during cleaning.

Forms

Initial Notification/Compliance Form - Every shop must submit an initial notification to report spray-coating operations. For your convenience, the NC DAQ has combined initial, compliance, and annual change notifications into one form. The Initial and Compliance Notification form is a one-time event report.

Annual Change Notification - This form is to report changes in your operations from those previously specified on an earlier 40 CFR 63 Subpart HHHHHH notification form. The Initial Notification/Compliance Form can also be used to report any annual changes in operations. 

Petition for Exemption - This form can be submitted on a voluntary basis but is no longer required as recent rule revisions allow exempt facilities to report on their initial notifications or subsequent notifications that they do not use any coatings containing chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni) or cadmium (Cd). This petition only applies to motor vehicle and mobile equipment surface coating operations. 

Spray-Applied Surface Coating Operation

Spray-applied surface coating operations, as defined by the rule, are operations using a hand-held device to apply an atomized mist of coating which then deposits the coating on a substrate.

Facilities must comply with this rule if they spray-apply coatings containing chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni) or cadmium (Cd) and the emissions of these regulated pollutants are less than 10 tons per year of a single pollutant, or less than 25 tons per year of a combination of hazardous air pollutants.

Spray-applied surface coating facilities must:

  • Submit the Initial Notification/Compliance Form to EPA and NC Division of Air Quality.
  • Train/certify all painters on spray gun selection, spray techniques, maintenance, and environmental rules.
  • Install and operate filters in ALL spray booths, stations and enclosures to capture at least 98% of the paint overspray.
  • Apply spray coatings with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or similar application method.
  • Clean paint spray guns so that no cleaning solvent or paint residue escapes during cleaning.

Paint Stripping Operation

Facilities must comply with this rule if they perform paint stripping operations to remove dried coatings with products containing methylene chloride (MeCl) on any part or product made of wood, metal, plastic or a combination of these materials and emit less than 10 tons per year.

Paint stripping operations facilities must:

  • Submit the Initial Notification/Compliance Form to EPA and NC Division of Air Quality.
  • Use best practices to limit the emissions of MeCl.
  • Consider alternatives to re-coating without using MeCl to remove dried coating.
  • For all work, consider other ways to strip that do not use MeCl.
  • Try to reduce MeCl emissions.
  • Develop and implement a minimizing plan for MeCl, if you use more than 2,000 pounds per year.

Training, Recordkeeping and Compliance

Recordkeeping

Records must be kept on file for a period of at least five years.

Autobody Shops and Spray-Applied Surface Coating Operations
  • Copies of Initial Notification/Compliance Forms submitted.
  • Spray booth filter efficiency documentation.
  • Spray gun transfer efficiency.
  • Painter training certifications.
Paint Stripping Operations
  • Paint stripping MeCl content information, (e.g. MSDS).
  • MeCl Annual usage.
  • Copy of MeCl minimization plan.

Training Deadlines

  • Painters at new sources have 180 days after hire to complete training.
  • Refresher training is required at least once every five years following the initial training date.

Compliance Dates

  • Existing Sources: January 10, 2011
  • New Sources: Upon startup after January 9, 2008
    (An affected source is a new source if construction commenced after September 17, 2007, or if new surface coating equipment was installed at a source not actively engaged in miscellaneous surface coating prior to September 17, 2007)

Additional Information

Training DVD

A free 19-minute training video is available, starring former NASCAR driver Jeff Gordon and featuring testimonies from large and small shop owners.

Forms in Spanish

Contacts

If you are a small business owner or operator, please contact the Small Business Environmental Assistance Program (1-877-623-6748) for additional information. If you are a facility operating with an environmental permit or you have plans to build a new facility, please contact the NCDAQ Regional Office closest to you.

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