EPA Finalizes Auto Refinishing Regulation
ASA supports final language
By Robert L. Redding, Jr.
How the new regulation will affect collision shops.
In September 2007, the U.S. Environmental Protection Agency (EPA) proposed the National Emissions Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. At that time and in an October 2007 AutoInc. article, the Automotive Service Association (ASA) expressed support for the language in the proposed regulation.
The EPA allowed comments on the regulation through much of October 2007. Independent repairers provided the majority of comments supporting the proposed regulation to the EPA during the period provided in the Federal Register.
ASA based its support on three general concepts provided in the EPA regulation proposed last September:
- Confining all spray coating operations to a spray booth or equivalent ventilated and filtered enclosure.
- Using only spray equipment that is designed to achieve a high rate of transfer efficiency.
- Having the spray equipment operator trained and certified in the techniques needed to properly set up and operate high transfer efficiency spray equipment to optimize the transfer efficiency.
- The final version was signed Dec. 14, 2007. The major components of the regulation are still in place:
The EPA noted that there are some changes in the final regulation important to repairers. Included in these are exemptions for hobbyists up to two vehicles per year. No compensation for painting these vehicles can be received.
The compliance deadline has also been extended. Once published in the Federal Register, existing sources must "comply no later than three years from the effective date of this notice." This has been increased from two years.
The training provisions have also been revised to allow an owner or operator to certify that their employees have completed training to facilitate the use of in-house training programs. Painters will have 180 days to complete training after hiring or transferring to a surface coating job, instead of 60 days.
The requirements for spray guns have been revised to allow the use of airless or air-assisted spray guns without having to demonstrate that they are equivalent to HVLP guns in transfer efficiency.
Compliance for spray booth filter efficiency can be satisfied through data provided by the filter manufacturer.
ASA had expressed some concern about the record-keeping requirements in the proposed regulation.
The EPA has simplified and reduced the record-keeping requirements in the final regulation. The EPA states that all sources will need to submit an initial notification, but in that initial notification, shops will be asked to state whether they are already in compliance with the requirements of the rule or whether they plan to be in compliance by the compliance date. New sources will also use the initial notification as the notification of compliance status since they would otherwise be due by the same date.
Annual reporting by shops has also been eliminated from the regulation. Annual compliance reports will only need to be submitted if there is a change in any of the initial notification information.
ASA had expressed concern about the use of "miniature" spray guns being subject to the same standard as repair facilities. The EPA responded by stating that the final rule is "intended to cover mobile motor vehicle refinishing operations that bring the coating equipment and supplies to the repaired vehicle, as well as those in which the vehicle is brought to a conventional collision repair shop." If the mobile refinishers apply coatings from a spray guy with a cup size greater than three fluid ounces, they will have to comply with the same training and equipment standards as repair shop owners. If the cup size is equal to or less than three ounces, they do not need to comply with the requirements for training, spray guns and spray booths.
ASA will make available summary compliance information to ASA members. To learn more about the EPA auto refinishing regulation, please go to www.TakingtheHill.com.
Bob Redding is the Automotive Service Association's Washington, D.C., representative. He is a member of several federal and state advisory committees involved in the automotive industry.
For more information about the legislative activities of ASA, visit www.TakingTheHill.com.
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