EPA 6H Compliance Deadline Has Passed

I just returned from CIC and the lack of understanding about the seriousness of compliance with the new EPA 6H Rule really blew my mind. Maybe I am the only one in the room that believed this is a big deal, but I do know that the IL EPA is taking it seriously too, so here is the timetable once again.

Jan 10, 2010 - Initial notification This was the paperwork that you needed to file to let the EPA know that you understood that that rule was going to take effect in another year and that if you were not in compliance you would be by Jan 10, 2011.

Jan 10, 2011 - Compliance date. If you did not get your shop in compliance, re training, equipment, spray booth and prep station, gun cleaning and record keeping, you missed the date it all needed to be done.

March 10, 2011 - Final notification This is the paperwork you need to send in to verify that you have complied with the rule. If you have not complied there is a part D on the form that allows you to explain how you are not in compliance and what you plan to do to get there (I'll get around to it is not an acceptable answer).

I found this posting in the Environmental Safety and Compliance Group here on Collision Hub and think it is so important I am reposting it here. Thanks to GFS (Global Finishing Solutions) for the info.

More will be posted on the subject after I speak with the Illinois EPA.

We conducted a poll of visitors to our website over the past month, regarding the EPA's 6H rule for spraying in collision shops which will become effective January 10, 2011. While a good portion of people responded that they were indeed ready for the rule, what surprised us, and concerned us, was that the majority of respondents didn't event know what the 6H rule was.

This is troubling news, given that the new rule becomes effective so soon. It makes me wonder how shops will react once inspectors start handing out fines and shutting down shops for non-compliance.

This isn't just a 'fad', or something that can be ignored. This is a Federal mandate that not only takes in to consideration environmental effects, but also the need to provide training and a safe work area for painters. Gone are the days of haphazardly spraying out in the open of your shop.

If you don't know about the 6H Rule, there are many resources out there that can help guide you through the process of compliance.

Here are a couple:

http://www.epa.gov/collisionrepair/

http://www.haps6h.com/

http://www.fenderbender.com/FenderBender/April-2010/The-EPA-is-Comi...

Note that there are some simple solutions available out there, and not every shop will need to invest in a large amount of new equipment. But we do advise people to beware. There are also some solutions that are being sold and marketed as '6H compliant', or that make claims that you can safely spray with them in your shop, but you should always do your research on what really does meet the code, and what does not. The last thing you want is to spend money, only to realize that the equipment isn't sufficient, and then need to replace it.

Tags: 6H, Compliance, EPA, NESHAP

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Comment by Jeanne Silver on January 29, 2011 at 2:19pm: I had a chat with a representative from the IL EPA yesterday and as far as Illinois goes, this is what I know now. March 10 is the final notification date to indicate whether the shop is or is not in compliance and if not, what plans they have to get there. The EPA will work with shops that make the effort to comply. Agents have been trained to conduct inspections in the city of Chicago and surrounding counties. The US EPA has set priorities for the year and the autobody rule is getting a lot of attention. Although enforcement is resource dependent and they may not have enough inspectors yet, the rule is not going away. The violation is a per day fine and the most blatant violators will be cited. Finally, our source stated that the US EPA is committed to inspections and is headquartered in Chicago. To quote our source, "I would not like to be a bodyshop in Chicago that has not complied, after all travel expense is not going to be an issue."

Comment by Global Finishing Solutions on January 21, 2011 at 10:47am: Hi Jeanne,

Just noticed your post, and I want to thank you for re-posting our message about 6H! I sincerely hope that those shops out there who have waited for the deadline to come and go are now actively working to meet the new codes.

Also, they should realize that meeting the new regs also gives them an opportunity to market themselves to their customers. Being able to talk to them about the fact that you're fully compliant with all EPA regs and codes can go a long way in building up your reputation in your market as a proactive business that takes their workers safety and environmental impact seriously.

Comment by Jeff Silver on January 18, 2011 at 8:14pm: Unfortunately, I am old enough to remember the establishment of OSHA in the 70's. While they had their trials and tribulations in the early days, their enforcement was something you didn't fool with. Anyone who took them lightly was in for an unpleasant surprise. This doesn't look much different, and any one who thnks it will go away is probably going to be wrong. At this point the EPA has already earned it's reputation as a government agency that knows how to do its job. Time will only prove it, but I would suggest that all shops get their act together so there is not a repeat of the OSHA experience.

Also, don't take lightly that the government needs sources of funds, and that the fines are very high for non-compliance. The infraction may be small, but the fine could cripple you.

Comment by Jeanne Silver on January 18, 2011 at 2:15pm: Thanks to all of you for contributing all of this valuable information. Hopefully it will reach other shops out there before the EPA comes a callin....

Comment by Jeanne Silver on January 18, 2011 at 2:14pm: Joe Hayes from GMG Envirosafe was kind enough to send me a website from the Wisconsin Department of Commerce that answers questions about use of the 3 oz cup outside of the booth or prep area. This information pertains to the states of IL, IN, MI, MN, OH, and WI. From the website:

CLARIFICATION on use of 3 ounce cups: Small amounts of any type of paint may be sprayed on the shop floor if spray gun cups 3 ounce or less are used. HOWEVER, be aware that there are still OSHA requirements that would apply to this spraying of flammable solvents. ALSO, excessive amounts being sprayed using 3 ounce cups (i.e., a whole vehicle) may be seen by EPA as circumvention of the rule and a violation.

Autobody Shop Environmental Compliance

Comment by Robert Humpal on January 18, 2011 at 11:28am: Its important to note too that in addition to possible equipment and materials compliance there is also a training component. Training is available from a variety of sources including from I-CAR's online course Hazardous Airborne Pollutant Reduction (HAP01). Visit www.i-car.com and click on the Online Training selection from the I-CAR Training menu for more details.

Comment by Melissa on January 18, 2011 at 9:24am

Jeanne, great post. I work for GFS and also find it alarming that some people are not taking these regulations seriously. Thanks for sharing this information and pulling some of that content from our previous post!

If any of you are interested, we just started a blog and recently launched a paint booth training website. Feel free to have a look and share your feedback!

Finishing Academy: http://finishingacademy.com
Blog: http://gfsboothblog.blogspot.com/

Comment by Alicia Jones on January 18, 2011 at 7:39am: Good post Jeanne. This is a definitely a big deal.

Comment by Bob Smith on January 17, 2011 at 6:58pm: Well put Jeanne. Many think this is just another "oh well" matter and are paying little or no attention [some don't even know about it-what hills have they been in] to 6H. From what I have heard and seen they are deadly serious and being soft on enforcement is not in the vocabulary.

When the non beleivers greet the EPA at the door it's going to be to late...end of story.