SCRS issues letter to EPA seeking clarification on paint cup exemption

April 11, 2011

April 11, 2011 The Society of Collision Repair Specialists (SCRS) and 26 of its affiliate associations issued a letter to the Environmental Protection Agency (EPA) requesting a more stringent interpretation of the 3 fluid ounce paint cup exemption listed in the EPA Rule 6H.

SCRS’ letter states that the 3 fluid ounce paint cup exemption has created a practice where some businesses are claiming to be exempt from the 6H rule by filling 3-ounce paint cups multiple times while doing traditional collision repair operations in an attempt to continue to perform the work in an uncontained or mobile environment.

An exemption that invalidates pollution controls based solely on the size of tools being used rather than the amount of pollution being generated is an ineffective and harmful policy, the SCRS stated in the letter. Because the rule is silent on the refilling of the 3-ounce paint cups, there exists a continued potential to circumvent the rule.

"This is an extremely sensitive issue in markets like New Jersey that have a growing population of mobile refinishers," said Charles Bryant, executive director of the Alliance of Automotive Service Providers of New Jersey (AASP/NJ). "Our member repair facilities are working diligently to meet and often exceed the standards of environmental responsibility, and that advancement often requires an investment on their part. It is important to ensure that everyone operating within the market is meeting these requirements, and that we don't have entities undermining the intent of the regulations so that they can compete unsafely without needing to recover the investment in the standard.”

The letter suggests that the exemption of 3 fluid ounces or less should be changed to read that a hand-held device with a paint cup capacity that is equal to or less than 3 fluid ounces cannot be refilled or be able to spray more than 3 fluid ounces of spray-applied coating per vehicle repair.

The letter requests a response from the EPA on three items:

• A documented response regarding the exemption for coatings applied with a paint cup equal to or less than 3 fluid ounces, and clarification that the rule applies to the type of work being performed.

• A documented response 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 stated 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’s response to the letter will be posted to the SCRS website at

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