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EPA responds to SCRS letter seeking 6H clarification

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Oct. 7, 2011—The Environmental Protection Agency (EPA) on Thursday responded to the Society of Collision Repair Specialists (SCRS) regarding clarification on the EPA’s interpretation of Rule 6H.

In April, the SCRS issued a letter to the 10 EPA regional offices, which requested a response from the EPA on three items:

• Clarification regarding the exemption for coatings applied with a paint cup equal to or less than 3 fluid ounces, and that the rule applies to the type of work being performed.
• Clarification that a 3 fluid ounce cup cannot be used and repeatedly filled to circumvent the rule.
• Clarification that while a business applying coatings may be exempt from Rule 6H by meeting certain requirements, the exemption does not negate other additional regulatory requirements that may prohibit spraying flammable solvent or coatings with Hazardous Air Pollutants (HAPs) outside of a contained environment.

The EPA Air Branch, Monitoring, Assistance and Media Programs Division, clarified that the 3 ounce cup is defined by the EPA as a way to distinguish conventional collision and vehicle repair from "operations that perform vehicle repairs of small stone chips and scratches.” The EPA said that both mobile operations and conventional collision repair shops are subject to the rule requirements for training, spray equipment, and the use of a spray booth or other ventilated and filtered enclosures.

The 6H rule does not extend to spray-applied coatings applied from a handheld device with a paint cup capacity that is equal to or less than 3 fluid ounces, the EPA said in its response to the SCRS.

The EPA said that people who repeatedly refill and use a 3 ounce cup as a means of avoiding rule applicability are attempting to circumvent the 6H rule. The EPA reserves the right to bring enforcement actions against any person whose action equates to rule circumvention, according to the SCRS.

In addition, the EPA confirmed that the 6H rule does not negate other regulatory requirements that may prohibit or restrict spraying flammable solvents or coatings containing HAPs within or outside of a contained environment, according to the SCRS.

"We are pleased that the EPA has responded with a clear and concise message that collision repairers and mobile operators alike will be held to the same regulatory requirements as it relates to the 6H Rule," said Aaron Clark, chairman of the SCRS. "In their response, the EPA Office has made it clear that much of the rule enforcement is based on intent. In some cases the use of the 3 ounce cup may be a necessity of the job being performed, but it is clear to us that the EPA offices will not accept intentional circumvention of the rule by habitually fragmenting paint jobs into smaller tasks or refilling 3 ounce cups in an effort to avoid regulation. This is the basic clarification we were looking for, and anticipate that this will provide solid information for shops."

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