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 A while back you mentioned waterborne paints. That got me thinking: Is there a new waterborne regulation out that we have to comply with?

You are probably referring to the National Emission Standards for Hazardous Air Pollutants (NESHAP) . Although spraying waterborne paints is considered a “best practice” in regard to reducing hazardous air pollutants (HAPs), nowhere in the NESHAP rule does it say collision repair facilities are required to use waterborne paints.

NESHAP compliance deadlines for existing collision repair facilities established prior to Sept. 17, 2007, that have not undergone 50 percent or more renovation to their existing coating facility are as follows (installations after Sept. 17, 2007, must be in compliance now):

Jan. 11, 2010 – Initial notification to the Environmental Protection Agency.

Jan. 10, 2011 – Painting in booths, prep stations or other structures to meet regulations: 98% or better filter efficiency, HVLP spray equipment or equivalent, gun washers or manual non-atomizing spray gun cleaning techniques, training, and documentation of all.

March 11, 2011 – Compliance certification with the EPA.

The EPA offers exemptions for collision repair facilities that can demonstrate that their coatings do not contain the metal HAPs or other products documented within NESHAP.

Many state-of-the-art collision repair facilities that have utilized “best practices” in their operations are currently close to meeting or exceeding these compliance issues.


Ray Fisher is the president of ASA-Michigan. This article represents his opinion and does not reflect the views of ASA-Michigan.

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