Federal EPA rule 40 CFR Part 63, Subpart HHHHHH (6H) was published in January 2009. The rule applies to any area source that engage in any of the following activities:
- Paint stripping using paint stripper containing methylene chloride (MeCl)
- Spray application of coatings to metal or plastic substrates with coatings containing compounds of Chromium, Lead, Manganese, Nickel, or Cadmium.
Basic Requirements for Surface Coating Operations:
Training
- Must train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance. Martin Senour provides E-learning to help comply with the Training requirement. Contact a Martin Senour Training Center for More Information.
Spray Booths
- Surface coating must be performed in a spray booth or prep station with filter technology to achieve at least 98% capture efficiency. Shops should keep a letter from the filter manufacture stating this.
Application Equipment
- Must use HVLP or an equivalent technology.
- Compliance Date
- Existing Sources (In operation before 9/17/2007) must comply on January 10, 2011.
- New Sources must comply upon start up.
- Reporting and Record Keeping
- Initial Notification (Informs EPA that the facility exists and is subject to the standards):
- Existing Source 1/11/2010
- New Sources 180 days after startup.
Certification of Compliance:
- Existing Sources 3/11/2011
- New Sources as part of initial notification
- Keep records of Training, Filter Efficiency, Notifications sent to EPA.
Resources
- Learning Center – Martin Senour E-Learning Center
- EPA Collision Repair Campaign Web Site - Includes Example Notification Form
- EPA web site - In depth rule information
- EPA 6H Brochure
This page is meant to provide general information on the 6H regulation and is not to be used to judge a shop's compliance or non-compliance with the rule. Compliance must be based on the full text of the rule as published by the U.S. EPA,