M: Welcome to this training on an air regulation that could apply to collision repair shops.

The regulation is officially called, “Paint Stripping and Miscellaneous Surface Coating

Operations at Area Sources”.

F: Wow! That’s a mouthful!

M: Yes, it is. Because the regulation is found in the code of federal regulations, Part 63,

Subpart H-H-H-H-H-H, it is more commonly referred to as the “6H rule.”

F: That’s much easier to remember! So what kinds of things are we going to talk about in

this training, and how long will it take?

M: Well first I should mention there are note-taking sheets that go along with this

presentation. They are found on the flash drive with the collision repair curriculum

material.

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6H Air Regulation

M: While the 6H rule also applies to other businesses, this training will focus on the

requirements for collision repair shops and will take about 45 minutes. This training is

sponsored by the Kansas Department of Health and Environment and the Kansas Small

Business Environmental Assistance Program. We will briefly cover what types of businesses,

in addition to collision repair, might be under this regulation. Also, we’ll look at what

activities at a collision repair shop might be affected by this rule. You know a business can

get fined if it is caught not following the environmental regulations?

F: That’s right, and it is one of our goals to inform you what an auto body shop might have

to do and what records will have to be kept, in case the shop is ever inspected by EPA or

KDHE for compliance with this air regulation. We will briefly talk about notifications that a

shop owner should have done already, or that will need to be done for new shops. Finally,

we will provide other resources to help with following the rules, preventing pollution, and

ultimately saving money

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6H Air Regulation

F: What do you think we mean by “Area Source”?

M: That’s kind of an odd term. We are talking about air pollution, right?

F: Today we are looking at one part of the air regulations, those regulated under the

National Emission Standards for Hazardous Air Pollutants, or NESHAPs. The Clean Air Act

contains a list of more than 180 chemicals that are officially classified as HAPs. The

NESHAPs regulate two general categories of sources—major sources and area sources.

Major sources emit more HAPs than area sources. Most, if not all, collision repair shops are

going to fall in the area source category. Technically, “area" sources are those that annually

emit less than 10 tons of a single hazardous air pollutant or less than 25 tons of a

combination of HAPs. Note these can be any hazardous air pollutants that are on the HAP’s

list.

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6H Air Regulation

M: The businesses that could fall under this rule are divided into three sources:

First there’s paint stripping operations using methylene chloride (MeCl) to remove dried paint from

various types of surfaces including wood, metal, and plastic. Hopefully, this will never apply to any

of you.

A second operation affected by the 6H rule is a business that spray-applies coatings containing

certain HAPs to any metal or plastic parts or products that are not motor vehicles or mobile

equipment (as described in the third bullet). The hazardous air pollutants that are of concern in this

regulation are Cr, Pb, Mn, Ni, or Cd.

The third source affected by these regulations is a business that spray-applies surface coatings to

motor vehicles and mobile equipment.

F: Wait! Motor vehicles. That sounds like what collision repair specialists do—paint motor vehicles!

M: That’s right. These terms will be defined in the next slide. This category of painters also includes

those who take their “show on the road” – mobile refinishing operations.

F: Does this rule apply to individuals that repair cars as a hobby? Like in their garage at home?

M: It applies if they coat more than 2 vehicles in a year

Note with the third type of affected source, (those who paint motor vehicles or mobile equipment),

it doesn’t matter what hazardous air pollutants you may or may not have in your paint, you are

automatically considered an affected source.

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6H Air Regulation

F: In the regulations, motor vehicle is defined as any self-propelled vehicle, including

automobiles, light duty trucks, golf carts, vans, and motorcycles.

M: What’s considered mobile equipment?

F: Mobile equipment is any device that may be drawn and/or driven on a roadway

including, but not limited to, heavy-duty trucks, truck trailers, fleet delivery trucks, buses,

mobile cranes, bulldozers, street cleaners, agriculture equipment, motor homes, and other

recreational vehicles (including camping trailers and fifth wheels).

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6H Air Regulation

M: So what are the hazardous air pollutants of concern in this regulation?

F: For auto body shops, the rule applies if paints contain any of five chemical compounds:

chromium, cadmium, lead, nickel, or manganese at certain concentrations. The

concentrations depends on whether OSHA has defined that chemical as cancer-causing or

not.

M: So which one of these chemicals are thought to cause cancer and which are not?

F: EPA decided if a compound is known to or might cause cancer, then it is considered a

carcinogen. What this means is that hexavalent chromium (Cr+6), cadmium, lead, and

nickel are carcinogens for this definition and trivalent chromium (Cr+3) and manganese are

in the “other” target HAP compounds category.

M: So if a chemical is thought to cause cancer, and it is present in the paint in a

concentration above 0.1%, than the requirements of this regulation must be followed. Also,

if a chemical is not a carcinogen, but it is present in the paint in a concentration above

1.0%, than the requirements of this reg applies.

The chemical ingredients in your paints, along with their concentrations, may be found in

the material safety data sheet, or MSDS as you may have heard it called.

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6H Air Regulation

At this time, you may pause the presentation and go over some MSDS sheets of coatings to

determine whether they have the targeted metal hazardous air pollutants or HAPs.

Otherwise continue to the next slide.

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6H Air Regulation

M: I heard if I’m a collision repair shop and I don’t use any of the five HAP metals of

concern, then I can get out of being subject to this regulation.

F: That’s right! You can send a form to EPA and KDHE requesting to get out of the

requirements for an auto body shop. You’re sending what’s called a “petition for an

exemption.” You may petition EPA for an exemption if you can certify that the target HAPs

are not found in any of the spray coatings you use in those concentrations given in one of

the earlier slides. Also, the petition must contain a description of the coatings you do use.

M: Where can I get this form to petition for an exemption from the rule?

F: The KS SBEAP included a blank form with this curriculum. You are not required to use the

form, but it makes it handy to be sure all the needed information is included.

M: What if some day in the future, I get a car that needs repairing and I have to use paint

that contains one of the targeted HAPs?

F: Then you will need to notify EPA and KDHE and start complying with these regulations.

The curriculum materials also has a form for notifying the regulatory agencies. This form

has the information requested by the regulation when sending a notification to EPA and

KDHE.

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6H Air Regulation

M: Near the beginning of this training, we said something about a person who repairs cars

as a hobby could be subject to the regulations.

F: That’s right, they could be. But this rule would not affect them, if these individuals or

hobbyists performed spray painting on their personal vehicles, possessions, or property, or

did this for others without compensation. But remember, they can’t paint more than 2 cars

per year. And again, this only applies if they are using paints with one of the targeted

metals.

M: I see where the 6H rule doesn’t apply to facility maintenance activities. What’s

considered a facility maintenance activity?

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6H Air Regulation

F: Most of you in a collision repair training program will probably go on to work at an auto

body shop. But just in case some of you have an opportunity to refinish mobile equipment

in the field, it will be good to know, that is considered a maintenance activity that does not

have to follow the 6H requirements.

M: Some examples include refinishing farm or mining equipment. It also includes items,

such as fork trucks, that are used in a manufacturing facility and which are refinished in

that same facility.

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6H Air Regulation

F: These are the types of activities that the 6H rule may affect:

Mixing rooms and equipment

Spray booths, ventilated prep stations, curing ovens

Spray guns

Spray gun cleaning equipment

Equipment used for storage, handling, recovery, or recycling of cleaning solvent or

waste paint

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6H Air Regulation

M: These are the types of activities that won’t be affected by the rule because they aren’t

considered “spray-applied”:

If you paint with a hand-held device with a cup capacity of less than or equal to 3

fluid oz. [This size is said to be less than the minimum practical amount of coating

that could be used to refinish a bumper or fender. Therefore, it helps distinguish

those sources that are doing small scratch and spot repairs from those that are

doing work that is more typically done at a collision repair shop.]

Powder coating is not activity that is subject to the 6H rule

Neither are hand-held, non-refillable aerosol containers.

F: And neither is non-atomizing technology. Non-atomizing applications include using

brushes, rollers, or hand wiping. It also includes coating techniques such as flow, dip,

electrodeposition, web, and coil. Touch up markers or marking pens are also considered

non-atomizing.

Thermal spray operations using solid metallic or non-metallic materials are also

exempt activities

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6H Air Regulation

DELETE???

This slide lists several types of coatings that are not affected by the new rule:

Decorative, protective, or functional materials that consist only of protective oils

Paper film or plastic film that may be pre-coated with adhesive

Adhesives, sealants, or caulking materials

Temporary protective coatings

In-mold coatings in the manufacture of reinforced plastic composite parts

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6H Air Regulation

M: Now we will look at the requirements for motor vehicle and mobile equipment surface

coating operations.

F: It should be noted that these requirements are basic P2 and BMPs that many have been

promoting for years. The rule took what used to be P2 and BMPs and now made them

mandatory.

M: For example, coatings must be applied in a spray booth, preparation station, or mobile

enclosure that is fitted with a filter system demonstrated to have 98% collection efficiency.

Check with the vendor or manufacturer for this information.

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6H Air Regulation

F: Booths and prep stations for complete motor vehicles or mobile equipment must have

A full roof,

Four walls or side curtains

Be ventilated at negative pressure

OR if it’s fully enclosed and completely sealed, then it can be a downdraft booth

operated at up to, but no more than 0.05 inches water gauge positive pressure.

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6H Air Regulation

M: Booths and prep stations for vehicle parts must have

A full roof

Just THREE walls or side curtains (remember complete motor vehicles or mobile

equipment must have four walls)

This three-sided booth must be ventilated such that air is drawn into the booth

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6H Air Regulation

Mobile enclosures for spot repairs must seal against the surface being coated such that

paint overspray is retained in the enclosure and directed to the filter

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6H Air Regulation

F: So what are the requirements for paint guns?

M: Spray-applied coatings must be applied with one of the following gun technologies:

High volume, low pressure (HVLP)

Electrostatic

Airless

Air-assisted airless

Or some other spray technology approved by EPA, that will achieve an equivalent

transfer efficiency as an HVLP gun

F: The regulation does not require these listed spray technologies be used if painting is

performed by students and instructors at paint training centers or for coating aerospace

vehicles

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6H Air Regulation

M: So what are the requirements for cleaning spray guns?

F: Ultimately the goal is to prevent creating an atomized mist. Avoid spraying cleaning

solvent and paint residue outside the container used to collect waste solvent.

Acceptable gun cleaning options include

Hand cleaning a disassembled gun

Flushing the gun with solvent, without spraying

Using a fully enclosed gun washer

Or using a combination of non-atomizing methods

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6H Air Regulation

M: The new rule has training requirements related to topics that have a direct effect on

reducing air pollution.

Painters must be certified as having completed training in proper spray application, setup,

and maintenance of spray equipment. The training will be certified by the owner or

operator.

There’s no designated body to certify or approve training

The rule allows for in-house training

F: (These training requirements do not apply to students of an accredited surface coating

training program who are under the direct supervision of an instructor who is certified

under these requirements) [mention how the instructor gets certified?]

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6H Air Regulation

M: All personnel who spray apply coatings (including contractors) must be trained.

Initial training must be done for an employee within 180 days of his or her hire date

Personnel at can use training that took place up to five years prior to the 180-days date, if it

met elements of the training program required in the rule

Refresher training must be received at least once every five years following the initial

training date

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6H Air Regulation

M: So what are the elements of the training program?

F: The training program must include spray gun equipment selection, set up, and operation

(measuring viscosity, selecting tip or nozzle, spray pattern, air pressure & volume, fluid

delivery rate)

M: It should teach the best spray technique for different types of coatings to improve

transfer efficiency and minimize coating usage and overspray (this includes optimum spray

gun distance & angle to the part, using proper banding & overlap, and reducing lead and

lag spraying at the beginning and end of each stroke)

F: Routine spray booth & filter maintenance should be included in the training plus proper

filter selection and installation

M: Training should also discuss requirements of this area source 6H rule and how to stay in

compliance.

F: Traditionally, students of collision repair programs have been taught the topics required

in the 6H rule training program requirements, with the exception of this last bullet. [And

that’s what you are covering right now!!! –needs better phrasing]

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6H Air Regulation

M: The regulations say the owner or operator must certify that training was completed.

How can he or she do that?

F: The certification must include:

The name and job description of each painter who is required to be trained;

A description of the hands-on and classroom instruction used, covering elements of

training program;

And a description of methods used at the completion of the training to demonstrate

the training was successful.

There’s a form to make it easier. It is included with this curriculum. Complete one

form for each painter.

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6H Air Regulation

M: If you are an owner or operator of a surface coating operation, these are the records

you must keep…

Certification that each painter has completed the required training with the date

the initial training and the most recent refresher training was completed

Documentation of the filter efficiency of any spray booth exhaust filter material

If a gun doesn’t meet the definition of an acceptable technology (HVLP,

electrostatic, airless, or air-assisted airless) and has at least a 3 oz. cup capacity,

then you must have documentation from the spray gun manufacturer that the EPA

Administrator has determined the gun to have an equivalent transfer efficiency as

that of an HVLP gun

You must keep copies of all submitted notifications and reports that were required

Just as with the paint stripping recordkeeping requirements, you must keep records

of any deviations from requirements in the rule.

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6H Air Regulation

F: And as with every NESHAP (National Emission Standards for Hazardous Air Pollutants),

there are notification and reporting requirements.

This informs EPA that a facility is subject to the standards and when the source will be in

compliance.

M: There are forms provided in the curriculum materials and they are available on the Web.

You don’t have to use them. You just have to be sure to submit all the information required

in the regulations.

F: The forms make it easier to submit all the required information.

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6H Air Regulation

M: So what reports must be submitted?

F: All affected sources must submit a report in each calendar year in which information

previously submitted has changed. This includes notification when paint stripping sources

increase their usage to more than one ton/year.

Then a Notification of Compliance Status report is due by March 1 of the following year.

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6H Air Regulation

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M: There are numerous resources available to help with implementing best management

practices. A list of these resources are compiled and included with the curriculum package.

F: This ends our presentation on the “6H rule.” Don’t hesitate to contact the small business

environmental assistance hotline with questions.

6H Air Regulation