EPA Issues Major Source Emission Standards for Surface CoatingsPosted 6/25/2004
By Robert L. Redding, Jr.
Federal and state policymakers are witnessing increased activity in the area of surface coating legislation and regulations. Despite a flurry of activity at the state level during the 1990s, the finalization of the national volatile organic compound rule and numerous government advisory committees, paint policy initiatives as they relate to autobody repair have waned in recent years.
The latest action on paint policy is the April publication of the National Emission Standards for Hazardous Air Pollutants: Surface Coating of Automobiles and Light-Duty Trucks. Although this impacts major sources of hazardous air pollutants such as "automobile and light-duty truck assembly plants," its timing is significant considering the recent state activity on paint in New Jersey, Assembly Bill 2127 and the U.S. Environmental Protection Agency's (EPA's) interest in a future regulation for auto body shops in dealing with paint products.
The EPA's latest regulation implements Clean Air Act requirements that these targeted operations meet hazardous air pollutant (HAP) emissions standards "reflecting the application of the maximum achievable control technology (MACT)." It is important to note that the EPA's mission for the regulation is to "protect air quality and promote the public health by reducing emissions of HAP in the automobile and light-duty truck surface coating source category." The EPA has identified these pollutants as follows:
The EPA estimates that these new requirements will reduce this emissions category by approximately 60 percent. This is a decrease from 10,000 tons per year to 4,000 tons per year. An additional 12,000 tons of volatile organic compounds will be reduced each year. The primary sources for HAP emissions are coating application, drying and curing. Residual emissions are a product of the cleaning of booths, application and spray equipment and also mixing and storage.
This regulation presents an opportunity for the collision industry to note the EPA's principal areas of concern in automotive paint policy. With regard to adverse "Health Effects," the EPA points to the potential toxic effects to the central nervous system such as fatigue, nausea, tremors and lack of coordination. Also included in the EPA's health effects analysis are adverse effects on the liver, kidneys, blood, respiratory system and developmental effects.
Two governmental initiatives in the past reviewing the health impacts of automotive paint and coatings relative to the autobody industry were the SPRAY study by the Yale University School of Medicine sponsored by the National Institute of Occupational Safety and Health (NIOSH) and the Paint Stewardship industry initiative hosted by the EPA, NIOSH and the Occupational Safety and Health Administration (OSHA).
Repairers should note the record-keeping requirements for these major sources in new regulation. Although different from what could be required of autobody shops, the trend of certain record-keeping issues should not be ignored. The record-keeping requirement may be the biggest potential burden for any future autobody shop paint and coatings regulation.
During the regulation's comment period, one commentator suggested an exemption for the smaller usage of paint and coatings - 250 gallons per year or less. Generally, the EPA rejected this request but did allow for the exemption of "touch-up" bottles.
In the rule's discussion of health benefits, it notes that there "may be up to 100 people exposed to HAP above reference concentration levels as a result of emissions from these facilities." Currently no one, in a rough risk assessment, is exposed "to a lifetime cancer risk above 10 in a million and perhaps 6,000 people are exposed to a lifetime cancer risk above one in a million as a result of emissions from these facilities."
Despite the focus on major emitters, repairers should do a quick review of the regulation to project future issues that may confront the autobody industry at the state and federal levels. Paint and automobile manufacturers have faced these issues of late.
Auto body repairers can review the EPA's new regulation by going to ASA's legislative Web site, www.TakingTheHill.com.
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