SCRS, affiliates petition EPA for equal enforcement of 6H rule
Jan. 1, 2020
The Society of Collision Repair Specialists (SCRS) and 26 of its affiliate associations requested more stringent interpretation from the 10 EPA regional offices regarding exemptions listed in the EPA rule Subpart HHHHHH- National Emissions Standards
The Society of Collision Repair Specialists (SCRS) and
26 of its affiliate associations requested more
stringent interpretation from the 10 EPA regional
offices regarding exemptions listed in the EPA rule
Subpart HHHHHH- National Emissions Standards for
Hazardous Air Pollutants: Paint Stripping and
Miscellaneous Surface Coating Operations at Area Sources
Rule
6H.)
The letter asks EPA to disallow the paint booth
exemption for repairers spraying from a 3 oz. paint
cups. The letter says, “Unfortunately, the application
of the rule has created a practice where some businesses
are claiming to be exempt, by filling 3 oz. cups
multiple times while doing traditional collision repair
operations, in an attempt to continue to perform the
work in an uncontained or mobile environment,” the
letter states. “It is our position that an exemption
which invalidates pollution controls based solely on the
size of tool being used rather than the amount of
pollution being generated is ineffective and harmful
policy; because the rule is silent on refilling of the 3
oz cups, there exists a continued potential to
circumvent the rule.”
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