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The Rule 6H Effect

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By now, all shops should be in compliance with the Environmental Protection Agency’s (EPA) 6H rule, which places tighter restrictions on shop equipment, practices and training involving paint stripping and surface coatings.

Rule 6H also creates a higher standard of training for painters, requiring certification by law for the first time. Experts say the new era of painting regulations is something both shop owners and painters must understand, not only for health and safety reasons, but also to avoid breaking the law and ending up with a potential $37,500-a-day tag.

“You can’t get out of this rule, you have to petition for exemption or file for compliance.”
– Steven Schillinger, president of Reno, Nev.-based GRC-Pirk Management Co.

“That puts a company right out of business,” says Steven Schillinger, president of Reno, Nev.-based GRC-Pirk Management Co., which led the development of the Certified Spray Coating (CSC) program to help educate painters and register those in compliance with the new rule.
The new training standards split the automotive painting workforce into the following classes:

Unrestricted (employer is compliant). These painters work at shops that have submitted a notification of compliance with the 6H rule. They have received both classroom and hands-on training in spray equipment selection, painting techniques, maintenance and other related issues.

Restricted (employer is exempt). These painters work at shops that have received exemption approval from the EPA. They have to be trained not to use chemicals containing methylene chloride for paint stripping. They can’t spray any coatings containing chromium, cadmium, lead, manganese or nickel.

Unrestricted painters can spray any kind of product, and restricted painters can only spray so-called screened products. Both unrestricted and restricted painters receive the same training, but the restricted painters must comply with EPA regulations to keep from receiving a fine.
“You can’t get out of this rule,” Schillinger says. “You have to petition for exemption or file for compliance.”

That means shop owners and painters will have to maintain strong communication about their shop’s status, paint products and equipment to avoid a slip-up should an EPA inspector visit the business. Working with a paint company that says it meets 6H standards isn’t enough, Schillinger says. For shops that apply for an exemption, every piece of equipment and anything that goes through the spray gun must be analyzed to make sure none of the prohibited pollutants are involved in the paint process.

Schillinger says the 6H rule, if followed, has the ability to boost the credibility of painters. “It steps the industry up a couple of notches,” he says. “They are truly professionals now with this.”

One of the goals of the CSC program, an online service created with the help of authorities, insurance companies and paint suppliers, was to build pride in the profession by providing independent third-party verification of training achievement related to the 6H rule. The site also allows a fast, paperless certification reference for any painter who voluntarily submits training records. The service can be found at haps6h.com.

So far, 5,000 painters are registered and Schillinger says about 100 are signing up each week.

Eric Schmitz, vice president of KPA, a compliance consulting company, says he’s been keeping an eye on that growth. KPA has its own database of training records, which it has been asked to share on the CSC site, but Schmitz says he wants to see more development out of the site before he makes a decision.

Schmitz says even though the deadline has passed, many shop owners are still going through the certification process and it’s not too late to get it done without fines if a facility was unaware of the deadlines. He says nearly every body shop should seek painter certification.
“It is almost impossible for one of these shops to fall into restricted just based on the quantity of paint they are using,” he says. “We’re seeing that everyone goes out and gets 6H registration because there’s really no gray area there.”

But, he says, shops should be mindful about other EPA regulations beyond 6H. Now that compliant facilities have handed out their addresses and phone numbers, the EPA could show up for a random inspection that goes beyond compliance with surface coatings and paint stripping.

“This is the one that’s in the spotlight right now. This is the regulation that’s garnered the attention,” Schmitz says. “But it doesn’t mean other regulations should be overlooked, and there are a lot of them.”

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