Editor’s note: The following guest editorial was submitted to Repairer Driven News by Tony Pendola, PE, Small Business Ombudsman/Small Business Environmental Assistance Provider (SBEAP) for the North Carolina Department of Environmental Quality. This editorial was provided to provide direct insight to the small-business owners and employees who are responsible for 6H compliance.

By Tony Pendola

The EPA has a rule that affects tens of thousands of autobody/collision repair shops nationwide.

Most of the EPA’s rules state that if the rule applies to you, you must comply. However, this rule, known as 6H, automatically applies to every shop. If your shop hasn’t taken specific actions outlined in the rule, it is out of compliance. Being out of compliance with an EPA rule could cause trouble with upper management, insurance carriers, OEM certification programs, et cetera.

Since this rule was passed in 2008, automotive paint manufacturers have nearly eliminated the paints containing the pollutants the EPA regulates. That’s excellent news for the employer, the sprayers, and the environment. The bad news is that in order for you to be in compliance, you must take action.

Shops have the choice of being subject to the rule or exempted through a process.

In general, the requirements of the rule are:

• • Do all spraying in a negative pressure booth or prep stations
  • Use 98% efficient booth filters.
  • Use HVLP or equivalent spray guns.
  • Clean guns in a container so no mist/spray escapes.
  • Train sprayers on 6H and retrain them every five years.
  • Report and re-report any changes online using EPA’s CEDRI website and
  • Don’t use a methylene chloride stripper.

Even though shops comply with most of the requirements, many choose to be exempt so that they cannot be penalized if something goes wrong. Because exempt shops no longer have to do anything required by the rule, they are free to do things like putting new sprayers to work immediately without specialized 6H training. Booth time can be extremely precious in terms of both money and timing.

Another reason some shops choose to be exempt is so they can spray non-explosive primer on the shop floor. All shops with an OSHA-approved method of avoiding the requirement for a booth, such as those that spray outdoors, must seek an exemption.

There are two options if a shop chooses to go the exemption route. The first is to make an online request that the EPA/state confirm you may be exempt. The other option is to provide the same information in the same manner, simply notifying them that your shop is exempt. Many owners do not like this option because they feel it leaves all liability with the shop. These owners prefer that EPA/state officials use whatever criteria they deem appropriate to evaluate the submittal and send back a letter on government letterhead stating that the shop is exempt.

The simplest way to ensure your shop can be exempt is to review the list of paints that your manufacturer may make that contain regulated ingredients. EPA has a Regulation Navigation Tool that walks you through the process. The tool also includes links to your paint manufacturers’ list of paints containing the regulated pollutants.

It is recommended to send a copy to your state or local air agency to ensure they are properly notified. Generally, the state or local air agency is responsible for responding. Please also consider doing as many of the rule’s requirements as possible. They were designed to save you paint, emissions, waste, and/or money! Every little bit can make your shop more profitable.

Most states have technical assistance providers to help you. They are usually confidential, non-regulatory, and free. Go to nationalsbeap.org/states to find the contact information for these free helpers and additional resources about 6H on that homepage.

Images

Featured image: Tony Pendola, tony.pendola@deq.nc.gov.