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 - 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).
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:
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 that all autobody shops:
Initial Notification/Compliance Form - Every shop must submit an initial notification to report spray-coating operations. For your convenience, The North Carolina Division of Air Quality 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 - is to report changes in your operations previously notified on the Compliance Certification Notification form.
Petition for Exemption - is applicable to those shops that no longer use surface coatings containing the regulated hazardous air pollutants, after they had filed the Initial Notification/Compliance form. 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:
Petition for exemption does not apply to this operation.
|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:
|Training, Recordkeeping and Compliance|
Recordkeeping - records must be kept on file for a period of at least five years.
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
- Initial Notification/Compliance Form (Motor Vehicles and Mobile Equipment Surface Coating Operation)
- Petition for Exemption (Motor Vehicles and Mobile Equipment Surface Coating Operation)
- Initial Notification/Compliance Form (Spray-Applied Surface Coating Operation and Paint Stripping Operation)
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.