Paint & Autobody Rule (6H) Frequently Asked Questions

What does this rule cover?

The rule restricts the use of methylene chlorine (MeCl) in paint-stripping operations and using paint with regulated metals [chromium (Cr), nickel (Ni), manganese (Mn), lead (Pb), and cadmium (Cd)] in coating processes.

How is North Carolina implementing the rule?

The North Carolina Division of Air Quality and the Small Business Environmental Assistance Program are providing education and outreach to autobody shops in North Carolina while enforcing the rule.

What operations apply to this rule?

The rule combines three operations: Mobile Equipment Surface Coating, Surface Coating Painting and Motor Vehicle, and Paint-Stripping.

If I am an autobody shop owner, how does this rule apply to me?

If you are the owner of an autobody shop, the rule requires you to report your activities to the Division of Air Quality, reduce emissions, and train your personnel in the use of personal protection equipment, spray coating selection, paint spray gun and paint booth filter selection.

If I am an autobody shop manager, how does this rule apply to me?

The rule applies in the same way to shop owners and managers.

If I paint cars as a hobby for my friends and myself but don't receive money for it, does the rule apply to me?

If you paint more than two cars per year, the rule still applies to you even though you do not get paid for this work. However, if you paint one vehicle per year, the rule does not apply to you, whether you are paid or not.

In the paints or coatings, what metals are regulated?

The metals regulated by this rule are: chromium (Cr), nickel (Ni), manganese (Mn), lead (Pb), and cadmium (Cd).

Where do I obtain information about these metals contained in paints and coatings?

The information is provided in the paint-can labels or the information provided by manufacturers/suppliers on a document called MSDS- a Material Safety Data Sheet.

Can I obtain a copy of this information from the paint manufacturers or suppliers?

Yes, just ask the paint supplier for it.

If I use water-based paints, how does the rule apply to me?

The rule applies to paints that contain any of the regulated metals, which are chromium (Cr), nickel (Ni), manganese (Mn), lead (Pb), and cadmium (Cd).

What kind of booths do I need to comply with the requirements of the rule?

The rule establishes that spray-booths must be fully enclosed with a full roof and four complete walls or completed side curtains. They also must be ventilated at negative pressure so that air is drawn into the booth.

What are the rule requirements for this activity?

The rule establishes that mobile ventilated enclosures that are used to perform spot repairs must be enclosed and, if necessary, sealed against the surface around the area being coated so that paint overspray is retained within the enclosure and directed to a filter for capturing paint overspray.

What kind of filter efficiency does the rule require?

All spray booths, preparation stations, and mobile enclosures must be fitted with a type of filter technology that is demonstrated to achieve at least 98% capture of paint overspray.

How can I demonstrate a filter's efficiency?

To demonstrate compliance with the requirement of the rule, use the published filter efficiency data provided by filter vendors.

What kinds of spray-guns are required or permitted by the rule?

All spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray-gun, electrostatic application, airless spray gun, air assisted airless spray-gun, or an equivalent technology that is demonstrated by the spray-gun manufacturer to achieve transfer efficiency comparable to one of the spray-gun technologies listed above for a comparable operation.

If I have a spray-gun that is not classified HVLP, can I use it to paint?

If you have a spray-gun that is not classified HVLP, you have to get a written approval from EPA, Region 4 to use it.

What if I have a spray gun used just for touch ups? Is it regulated by the rule?

For the purposes of this subpart, spray gun with paint cup capacity less than 3.0 fluid ounces (89 cubic centimeters) are not regulated by the rule.

How should I clean spray-guns?

Spray-gun cleaning may be done by hand cleaning of the disassembled spray-gun parts in a container of solvent, by flushing solvent through the spray-gun without atomizing the solvent and paint residue, or by using a fully enclosed spray-gun washer.

If I have a spray-gun that is not classified HVLP, can I use it to paint?

If you have a spray-gun that is not classified HVLP, you have to get a written approval from EPA, Region 4 to use it.

What paints are regulated?

Paints containing chromium (Cr), nickel (Ni), manganese (Mn), lead (Pb), and cadmium (Cd) are regulated. To determine whether the paints used in your shop contain these metals, the material safety data sheet provided by the manufacturer or supplier can be consulted.

Where I can find the paint content information? Vendors or manufacturers?

The paint content information could be found on the paint can labels or the Material Safety Data Sheet (MSDS) provided by manufacturers.

Why do I have to report?

The rule requires that autobody shops submit an Initial Notification no later than start-up operations or January 11, 2010, whichever is latest.

What kind of notification form do I have to fill out?

The North Carolina Division of Air Quality has designed an Initial Notification/Compliance Form that includes all the information required by the rule.

Where can I find the Initial Notification/Compliance Form?

You can download the form, fill in with appropriate information, SIGN the form and submit it to both the US EPA and NC DAQ following the instructions at the bottom of the form.

To whom do I send the notification form?

The submittal instructions are indicated at the bottom of the form. The form must be sent to both the US EPA and NC DAQ.

When do I have to report?

You have until January 11, 2010 to report an initial notification, and then you have until March 11, 2011 to achieve compliance. However, the rule provides an opportunity to both notify and to comply at the same time.

What is the difference between the Notification form and Compliance form?

Both forms have been combined for your benefit. The Initial Notification part is to notify your status as existing or new shop and the kind of operation that your shop is performing. The Compliance form is to certify the compliance with the rule. You only need to select the correct box. The boxes are located at item 4 of the second page of the form.

Can I submit both forms at the same time?

Yes, the rule allows you to submit both an initial notification and compliance notification at the same time.

What are the training requirements of the rule?

The rule requires that painters be trained in: spray-gun equipment selection; set up and operation; spray technique for different types of coatings; routine spray booth and filters selection and maintenance; and environmental compliance of this rule.

When can I train my personnel?

All personnel must be trained and certified no later than 180 days after hiring or no later than January 10, 2011, whichever is latest.

What kind of records must I keep?

Painter training records or certifications, must be kept on site for five years. All personnel must receive refresher training that meets the requirements of the rule and be re-certified every five years.

Can I do on-the-job training to certify my personnel?

Yes, the rule brings the flexibility for autobody shop painters to obtain their certification through in-job training.

What kind of records do are needed to maintain my compliance with the rule?

You have to keep an on-site copy of the Notification and Compliance form and any revisions, and copies of the painter training certifications. If you applied for a petition for exemption a copy must kept as part of your records.

How long do these records have to be maintained?

The records must be kept on-site for a term of five years.

What is a petition for exemption and to whom does it apply?

On or after May 9, 2023, autobody shops are no longer required to submit a petition for exemption.  They can simply submit a notification to the US EPA and NC DAQ that indicates that they do not spray apply any target HAP containing coatings.  Autobody shops are still required to retain records that describe the coatings that are spray applied. 

Who do I contact for more information?

If you are a small business owner or operator, please contact the Small Business Environmental Assistance Program 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.