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?

Transcription

1 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. 1

2 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 2

3 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 areasources. 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. 3

4 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. 4

5 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). 5

6 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. 6

7 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. 7

8 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. 8

9 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 theseindividuals 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 maintenanceactivities. What s considered a facility maintenance activity? 9

10 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. 10

11 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 11

12 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 12

13 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 13

14 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. 14

15 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. 15

16 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 16

17 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 17

18 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 18

19 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 19

20 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?] 20

21 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 21

22 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] 22

23 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. 23

24 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. 24

25 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. 25

26 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. 26

27 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. 27