The NESHAP compliance deadline is quickly approaching (Jan. 10, 2011). Some paint companies have promoted lines that would allow for an EPA exemption. My local trade organization says otherwise. What do you think?
Paint manufacturers are continually improving their formulas to rid their paints of six particular hazardous air pollutants (HAPs). And if those are properly documented, you could file for exemption. But I caution repairers to review all criteria before filing for exemption. Here’s why:
• No paints in your repair facility can contain any portion of the six HAPs, regardless of possession.
• Future purchases are under review here, too. If a paint formula should change and suddenly contain one of the HAPs, you would then need to comply with the NESHAP rule.
• Paint strippers containing methylene chloride cannot be used or stored on the premises.
And NESHAP isn’t your only concern. There are rules to comply with in other areas of the EPA and with other government regulators. The Occupational Safety & Health Administration has repair facility requirements that have been in place long before NESHAP. Current regulations under the Uniform Mechanical Code also have many definitions and requirements that include strict guidelines about the necessary air movement, definitions of a spray area, and what products require a booth or enclosure, along with many others.
Compliance with the NESHAP rule does not guarantee a repair facility that they are compliant with these other regulators. Check with your state, as many offer an outreach program that will assist you with facility assessments, without enforcing penalties on you at that time.
Ray Fisher is the president of ASA-Michigan. This article represents his opinion and does not reflect the views of ASA-Michigan.
