Proposed air pollution abatement regulations from the U.S. Environmental Protection Agency (EPA) covering automotive painting procedures largely reflect existing "best practices" already in place at most body shops, according to industry leaders who have reviewed the long document.
Published Sept. 17 in the Federal Register, collision shop owners will have two years to fully comply once the rulemaking is officially finalized at a later date.
"There is a two-year period to get your house in order," says Bob Redding, Washington, D.C., representative for the Automotive Service Association (ASA).
The proposal, entitled "National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources," mandates training qualifications for painters and prescribes suitable application technologies along with enacting certification requirements.
"It continues to improve the industry by setting standards for training and equipment, and hopefully it will continue to push the industry up," Redding says. "These are criteria that should be expected of collision repair facilities. We feel that our shops are already meeting the standards. There will be some limited cost on the recordkeeping side."
Aaron Lowe, vice president of government affairs for the Automotive Aftermarket Industry Association (AAIA), said his organization is still obtaining comments from members, but generally he considers it a good proposal.
"It will not be a huge issue for them to comply," says Lowe. "A lot of the things are things that shops are doing already. The EPA tried to use some of the 'best industry practices' and make sure the industry uses them."
EPA officials consulted with the appropriate parties prior to the regulations being promulgated, according to Lowe. "We've been in discussions over the past couple of years over this issue. They talked to the industry, did their homework and went to body shops. You want the regulatory agencies to go out into the industry and see what's going on."
Following publication in the Federal Register, the ASA noted how "we believe that the EPA has adequately met the necessary elements" of reducing HAP (hazardous air pollutants) from body shops. "As stated by the EPA, without adequate training, equipment requirements will have limited value in improving air quality," Redding wrote to the agency. "Equipment requirements such as spray booths, spray guns and gun cleaners are essential pieces to any automotive collision repair facility. A mandatory spray booth requirement for the use of these automotive refinishing products is the most important stipulation included in this proposed regulation."
There are two additional issues ASA would like for the EPA to consider in the final regulation, Redding says. "First, the EPA states that the only exceptions to the spray booth requirement are priming small areas or performing spot repairs with an air brush. Unfortunately, technology now provides 'miniature spray guns' that are being used in open areas. This allows air brush specialists and others to expand the area subject to automotive refinishing products. ASA requests the EPA to consider tightening the final regulation to ensure that any exception, if critically necessary, to the spray booth requirement exclude miniature spray guns or similar technologies. Those persons or business entities using miniature spray guns should be required to have a spray booth," he urged.
"Secondly, the estimated recordkeeping and reporting costs for repair facilities are too low. We asked our association leaders to review the compliance cost estimates, and shop owners believe that the annual hours required to comply are too low."
The AAIA's Lowe agrees. "It's hard for us to gauge what the real cost will be, but I think the EPA underestimated the cost to the body shop."
Mandating HVLP
The recordkeeping and reporting costs are estimated to range from $76 to $95 per facility per year, according to the EPA's analysis. "These costs are too small to have any significant market impact. Whether the costs are absorbed by the affected facilities or passed on to the purchaser in the form of higher prices, the impacts would be quite small."
The proposed regulation is a result of the Clean Air Act of 1990, which requires the U.S. EPA to identify sources that emit one or more of 188 toxic air pollutants, including methylene chloride (MeCl) and metal compounds containing cadmium, chromium, lead, manganese and nickel.
The measure presents stricter requirements regarding toxic standards covering smaller emitting sources in three industry sectors: Paint stripping operations that use MeCl-containing paint stripping formulation, surface coating that involves paints containing metal HAP compounds, and auto body refinishing.
It involves "area sources" defined as those that have the potential to emit less than 10 tons per year of a single toxic air pollutant or less than 25 tons per year of any combination of toxic air pollutants. Through compliance, the practices are designed to reduce overall toxic material consumption, which generally results in savings for the facility involved, according to Redding.
Existing area sources that would be affected by the rule would need to implement equipment and management strategies to comply with the standards if they have not already done so. Otherwise, "You need to think about updating your equipment and practices," Lowe explains. The regulations will be applied to every American body shop, even if yours is located in a sparsely populated region with no apparent air pollution problems.
"We anticipate that many facilities that have not yet implemented these practices will realize an overall cost savings," Redding says.
The equipment standards include confining spray operations within a properly filtered spray booth or preparation station, using high volume low pressure (HVLP) or equivalent spray equipment, and either cleaning spray guns manually or by using an enclosed spray gun washer.
The EPA estimates that some 5,000 facilities would need to purchase and install an enclosed spray gun washer costing about $1,800.
Mandated management practices are to include proper training and certification – valid for a five-year period — of HVLP equipment operators.
The training must entail:
- Surface prep.
- Spray gun set up and operation and spray technique for different types of coatings to improve transfer efficiency and minimize coating usage and overspray.
- Routine spray booth and filter maintenance.
- Paint mixing, matching and applying.
- Solving paint application problems.
- Finish defects causes and cures.
- Safety precautions.
- Environmental compliance.
Cost for training
The estimated cost for training is $1,000 per painter, which covers tuition cost and labor cost for 16 hours of training time, according to the agency's calculations. "A lot of the training requirements can be done through training programs that the paint manufacturers have available," Lowe says.
For a shop not yet participating in a training program, EPA officials believe the expense could be offset by reduced coating costs if the training results in reduced coating consumption.
"Data from the STAR training programs indicate that painters who complete this training can decrease the amount of coating sprayed by about 20 percent per job," the agency contends.
"We estimate that if a typical facility reduced their coating consumption and costs by about 4 percent per year, the cost savings would equalize the increased cost of training after one year, and there would be no net cost in training. To recover the cost of training over five years, a typical facility would need to reduce their coating consumption by slightly less than 1 percent," according to the EPA.
