Replies to This Discussion

Permalink Reply by Leon Bousquet on December 9, 2009 at 12:23pm

The Federal Regulation 40 CFR Part 63 Subpart HHHHHH is a Federal Regulation. In Mass we have the compliance for filing on January 8, 2010. The EPA has trained some people on the Web and also some of their paperwork gives shops a phone number to report non-compliant shops. As to the EPA enforcement, the best defense is a good offense. File the required paperwork and be done with it. If you do not have a manufactuered booth, as some of my customers do, I am reporting that and letting the EPA sort out what they want, this will definately take some time as the EPA has moved slowly to date. The filing date is January 8, 2010, the compliance date is January 2011. Also, the OTC has passed the new lower VOC limits to be in effect by January 1, 2012. Get ready for waterborne.

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Permalink Reply by Sheila on December 21, 2009 at 12:59pm

Actually, NOWHERE in the ruling does it say you need to state what kind of booth you have.

By doing so you are going outside of what is required.

Why you find it necessary to report anything other than what the law requires is a bit ....hmm. I find that rather presumptuous on your part that it is within your rights as a jobber to do so as long as what they have is compliant(unless your trying to sell them a booth).

And it is the shop OWNERS or COMPANY OFFICIALrequirement to do the notifications, not a jobbers. You need to check out the notification and compliance forms. It doesn't ask anything about what 'kind' of booth a person has.

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Permalink Reply by Leon Bousquet on December 21, 2009 at 1:20pm

I think Ashley has the right spot to research the answer about a booth. I make no presumptions for any of my customers. As I have stated, not all of my customers have a manufactuered booth. I am helping them comply with the EPA regulation though. I do not sell spray booths. My issue is to be sure my shops comply with the heavy metal, filter and spray gun compliance. By reporting, I mean I am suppling my customers with the necasary forms, from the EPA site, MSDS info, school info, etc. and letting them fill out their pieces of it. I am not reporting to anyone, I should not have said it that way. I am helping my customers comply, that is my part. Sorry for the confusion.

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Permalink Reply by Sheila on December 21, 2009 at 10:58pm

My apologies if I got a bit tempermental there. But I had one of our regional sellers of booths and auto products try to convince me I 'had' to buy a factory made booth to be legal. My own research proved that untrue from what I could figure out..

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Permalink Reply by Ashley Zanolli on December 17, 2009 at 7:20pm

Yes it is correct that all shops need to be registered with the EPA by January 2010 and certified by January 2011. I also recommend that you check out the collision repair campaign website
http://www.epa.gov/collisionrepair/
There is a notification form you can download from this site (see the box on the right hand side of your screen that says "auto body rule") and some additional information that may assist you in understanding the requirements of the Federal rule, which is attached below. The notifcation form is due by January 11, 2010 or within 180 days of start-up for new shops.

As for the paint booth requirements, you should refer to the attached rule language for paint booth requirements - No where in the rule does EPA require you to purchase a $20,000 down-draft negative pressure paint booth. Here are some rule exerpts that may help clarify your questions regarding paint booth requirements. According to section 63.11173 (e)(2)(ii) on page 1761 of the attached rule,
" Spray booths and preparation stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed with a full roof and four complete walls or copmplete side curtains, and must be ventilated at negative pressure so that air is drawn into any openings in the booth walls or preparation station curtains. However, if a spray booth is fully enclosed and has seals on all doors and other openings and has an automatic pressure balancing system, it may be operated at up to, but not more than 0.05 inches water gage positive pressure."
According to section 63.11173 (e)(2)(iii) on page 1762 of the attached rule,
"Spray booths and preparation stations that are used to coat miscellaneous parts and products or vehicle SUBassemblies must have a full roof, at least THREE complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth. The walls and roof of a booth may have openings, if need be to allow for conveyors and parts to pass through during the coating process." (This last part is more relevant for miscellaneous surface coating operations)
As for mobile repairs, according to section 63.11173 (e)(2)(iii) on page 1762 of the attached rule,
"Mobile ventilated enclosures that are used to perform spot repairs must enclose, and, if necessary seal against the surface around the area being coated such that the paint overspray is retained within the enclosure and directed to a filter to capture paint overspray".

The penalties for noncompliance (now a maximum of $37,500 per day per violation) are laid out in these two rather complex documents:

http://www.epa.gov/compliance/resources/policies/civil/penalty/amen...

which revises

http://www.epa.gov/compliance/resources/policies/civil/caa/stationa...

I hope this helps to answer your questions and concerns.

Thanks!
Ashley Zanolli - EPA Region 10, Seattle, WA

Attachments:

• Paint stripping Surface coating Final Rule 73FR1738 Jan 9 -2008.pdf, 230 KB

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Permalink Reply by Sheila on December 21, 2009 at 12:35pm

We are also a small shop and built our own booth. The new rule is very easy to implement. Even with-out the mass produced booths it is easy. Just because we didn't buy a factory made booth doesn't make ours any less legal. The factory booths are just bolt together panels.

Just because our booth is not mass produced on a factory line in no way makes it not fit the EPA 6H rule.

In laymens terms the only two things your booth needs to do are be at negative pressure, that means that the booth is drawing IN dust and dirt and not pushing out VOC's and have filters that have 98% capture efficiency.

=training
=filters
=prep stations
=booths
=Guns HVLP
=Gun Cleaning

Negative Pressure is simple, open the man door to your booth, stand in the doorway, do you feel the air being drawn past you into the booth? If so that is negative pressure. The goal of that part of the ruling is so that all your over spray is going out through the filter, not out the booth into the environment. If your fan isn't drawing into the booth then you probably have more problems than the 6H rule.lol For a prep stations the same applies, it needs to drawing air in, not pushing it out.

Next you need to make sure your filters are at the required 98% capture efficiency. This too is simple. To the best of my knowledge according to a local paint booth sales company if your filters are 22 grams or have a metal screen backer then they should comply. You can always check with a local HVAC company and they can tell you what filters comply.

Painter Training I did the I-CAR online class. Then went over all the details with the guys and trained them myself. Although I am going to the Dupont class regarding the 6H rule in February so I can be even more knowledgeable about some of the spraying techniques. But any painter worth their pay should know how to use proper technique to minimize overspray anyhow. If they don't they are wasting product.

HVLP Gunsif you don't already use them then buy one. Or if you read the fine print you can use non-hvlp if you can prove(get out your guns literature and be ready to show the EPA to prove it) they are equal to HVLP. Again simple.

Gun Cleaning cannot have any atomization. That means you can disasemble you gun in a 5 gallon bucket and clean it by hand. Just don't put it together and spray gun cleaner through it to clean it into the air. A real gun cleaning cabinet is necessary for this. It's about $1500 for a decent one , I saw one for $700ish too.

Now get a file folder, go to the epa site and send in your notification, they have an editable file for you can use.

You don't have to certify compliance until 2011 january.

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Permalink Reply by Bill Fowler on January 5, 2010 at 3:40pm

I think the methane gas being generated by all the B.S. coming out of Washington is doing more damage to the environment than we ever could.
How's that whole global warming thingy working out for you, Al? The ice caps aren't disappearing, they're relocating. The high temperature in my neighborhood today never got above freezing and I'm in Mississippi. Lows this week will be in the single digits every day. Record low temperatures and record snowfalls over most of the nation seem to me to be exposing the whole scam for just what it is, a scam. The increased scrutiny of our industry by the EPA will only serve to hasten our demise and you should remember that this is the same EPA that restricted the amount of paint that automobile manufacturers could use in a production year. Robots needed to be protected from isocyanates during the manufacturing process, but my hillbilly a#@ could use all I wanted in the repair process. Go figure.

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