In January 2008 the Environmental Protection Agency (EPA) published a final rule concerning the National Emission Standard for Hazardous Air Pollutants (HAPs), Paint Stripping and Miscellaneous Surface Coatings at Area Sources.
How does this affect collision repair facilities? An area source is defined as a manufacturing or service facility that has 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. Due to the application of refinishing materials through a spray atomization process, collision repair facilities are considered an area source of hazardous air pollutants.Training on hazardous air pollutant reduction processes is a requirement of the final rule. I-CAR's new Hazardous Airborne Pollutant Reduction (HAP01) online training program can serve as the knowledge-based training portion of the requirement. The program was developed in cooperation with several refinishing product makers and other industry professionals.
At first glance, the rule may appear to be overwhelming. But after taking a closer look, nearly all of the requirements of the final rule are already common practices in most collision repair facilities. The EPA took time to visit several collision repair businesses to determine what practices were being done to reduce emissions of HAPs. They also asked for input from the industry during the comment phase of the rule, to ensure that the standards set forth by the rule were attainable and economically feasible for collision repair facilities.Target HAP
The EPA defines a HAP as any substance in the air that can cause harm to humans or the environment. The EPA has identified 188 materials and compounds that are classified as HAPs, some of which are commonly used in refinishing materials. In the final rule, the target HAPs are listed as being compounds or substances containing chromium, lead, manganese, nickel or cadmium.
In the last several years, refinishing product makers have made great strides to reduce the amount of these compounds in refinishing materials. This does not mean that the products are 100-percent safe. Most refinishing products still contain other hazardous substances that are not classified as HAPs. These hazardous substances can still have negative health effects. Make sure you identify and use the appropriate personal protective equipment that the product maker recommends.Is your facility a source?
How do you know if the products that you use contain target HAPs? The quickest answer to this question, short of checking the Material Safety Data Sheet of each product that your facility uses, is to assume that it may contain the target HAPs.
There may be the possibility of filing for an exemption of the rule if the products that your facility uses do not contain the target HAPs. By doing so, however, you must be able to verify that there are no products currently in your facility that contain the target HAP, and ensure that every new product that you may use does not contain the target HAPs. The benefits related to becoming compliant most likely will outweigh the perceived benefits of filing for an exemption. Spray application processes that reduce overspray and improve transfer efficiency result in less material usage. The penalties for not being in compliance may far outweigh the cost of becoming compliant to the final rule.
If you are an existing source, you must submit an initial notification that the facility is a source of HAPs. This is sent to the EPA, or to a state or local air pollution control agency that has been designated by the EPA. A copy of the notification should also be sent to the EPA, unless the EPA regional office has waived the dual-reporting requirement. In the initial notification, the source must notify the EPA whether or not the facility is within compliance or whether the facility will be in compliance by the facility's effective date.
New facilities must submit the initial notification within 180 days of startup; existing facilities must submit it no later than one year before their required compliance date. If the initial notification did not specify that the facility was within compliance, the facility must submit a notification of being compliant within 60 days after the compliance date.
If you are a new source, meaning that new major refinishing equipment has been installed, or the facility is in a new location, you are required to comply to the final rule within 180 days of the effective date of the final rule, or 180 days after the employee being hired, whichever is later. Existing facilities have three years from the effective date of the final rule, or 180 days after the date of hire, whichever is later.
Equipment and training requirements
The final rule includes several equipment requirements, including:
- Spray guns must demonstrate at least 65 percent transfer efficiency.
- Spraybooth filter media must be at least 98 percent efficient, and spraybooth pressure must be below 0.05" of water. Originally, the rule required negative spraybooth pressure, but from input provided during the comment period, the rule was changed to allow a slight degree of positive spraybooth pressure.
- Spray guns must be cleaned in an enclosed spray gun cleaner, or they must be disassembled and cleaned manually without atomization of the cleaning solvent.
- Knowledge-based and hands-on training. There are a number of training components that the EPA requires of the training in order to be compliant.
- Notification of compliance and the ability to demonstrate that the necessary training has been completed in accordance with the EPA requirements.
Also included are both classroom and hands-on training requirements on spray gun techniques and processes to increase transfer efficiency and decrease the amount of hazardous airborne pollutants that are generated. Any person who uses a spray gun to apply a finish must be trained.
The I-CAR online training program was developed with cooperation of several refinishing product makers and other industry professionals, with the goal being the development of a program that is both economical and easily accessible. In addition to covering all of the required knowledge-based training requirements, the training program teaches managers and supervisors how to self-certify their staff on the hands-on portion of the training requirement.
