After our industrial hygienist looked at a whole lot of material safety data sheets, she determined that probably no one is exempt. At least in Minnesota, the shops we work with all have paints with some form of chromium.
I'd be interested in reviewing this with your IH. I suspect that she did not consider that while pearls do have target HAPs in them, when mixed with toners and reducers the percentage generally falls below the .1% threshold as applied. Primers and toners (especially yellow & orange) usually have a lead-free (and therefore Cr-free) alternative. One manufacturers 6H contact even tells me that she hopes to have 100% target HAP-free coatings by the compliance date. I have compiled a list of all paints containing the target HAPs at: