Linn County Air Quality Division
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Paint Stripping and Surface Coating

40 CFR Part 63, Subpart HHHHHH (NESHAP 6H)

General Requirements (PDF File)
General Guidance (DOC File | PDF File)
NESHAP 6H Fact Sheet (DOC File | PDF File)
NESHAP 6H Decision Tree (PPT File | PDF File)
February 2009 DNR Presentation (PPT File | PDF Presentation | PDF Handouts)
Paint Stripping Operations (DOC File | PDF File)
FAQ on HVLP Equivalency (PDF File)
Compliance and Training Support (Iowa Waste Reduction Center)

Initial Notification | Notification of Compliance Form - January 10, 2011 (DOC File | PDF File)

Brief Summary
New EPA Regulations for
Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources
40 CFR Part 63 Subpart HHHHHH

EPA has requirements to reduce air pollution from compounds of cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), and also to reduce methylene chloride (MeCl) fumes, from autobody finishing work. These compounds pose health risks to anyone who breathes the air when these fumes are present. Many paints used in autobody refinishing work contain these metallic compounds and many of the paint strippers utilized in this industry contain MeCl. These regulations require autobody shops and refinishing businesses to prevent these metals from getting into the air during spray painting or paint stripping.

The surface coating rules are expected to reduce emissions of hazardous air pollutants by about 14 million pounds per year. Any initial costs for compliance with the new regulations are expected to be recouped through cost savings from more efficient material usage.

Existing shops must comply with the requirements of NESHAP 6H by January 10, 2011. New shops must comply with the requirements before initiating painting or paint stripping operations. Although EPA has no requirements for hobbyists or private citizens, two things should be noted: (1) the following are also good practices to improve the air quality for anyone exposed to autobody paint overspray; and (2), the new regulations strictly define what qualifies one as a "hobbyist" or "private citizen" when it comes to autobody painting and paint stripping.

Below is a short summary of the requirements for autobody refinishing shops listed in NESHAP 6H:

  1. All spray painting must be completed inside a spray booth.
    • Full cars must be painted in a spray booth with four walls, a roof, and a ventilation system. Filters in the booth have to remove at least 98% of the particulates (air filter sellers will have the appropriate information to ensure the selected filters meet this requirement).
    • Parts of cars must be painted in a booth with at least three walls or flaps, a roof, and a ventilation system that pulls air into the spray booth.
    • Spot repairs must be done in an enclosure which prevents any mist from escaping the enclosure.
    • Miscellaneous items that fit inside a spray booth must be painted inside a booth. For items too large for a spray booth, please contact the Air Quality Branch for more specific information.
  2. Painters must use spray guns and techniques to reduce overspray (e.g., HVLP).
  3. All painters must receive training. Owners or operators must maintain records of the training received by each painter. For information on techniques, available workshops, and other information, see the Collision Repair Campaign to Reduce Air Toxics.
  4. Spray gun cleaning cannot create any mist of cleaning solvent to the air. Solvent may be sprayed through the gun for cleaning purposes only if an enclosed gun cleaner is used. Otherwise, the gun must be cleaned manually.
  5. All shops must send a notification to the EPA with the following information by January 2011:
    • Location of facility.
    • Description of spray painting equipment.
    • Confirmation that the shop has the necessary equipment and training.
    • A copy of this notification must be forwarded to: Linn County Public Health Air Quality Branch, 1020 6th Street SE, Cedar Rapids, IA 52401.
    • An example of this notification can be found here.
  6. Exemptions to the rule include: facility maintenance activities, which include the application of coatings to stationary structures or their appurtenances at the site of installation; portable buildings at the site of installation; and to pavements and curbs.

Below is a short summary of the requirements paint stripping using MeCl listed in NESHAP 6H. Owners or operators shall:

  1. Evaluate whether paint stripping is required to complete the re-coat.
  2. Look for ways to complete the paint stripping using materials that do not contain MeCl.
  3. If materials containing MeCl are required, utilize methods that limit the fumes of MeCl, such as:
    • Avoid unnecessary exposure of solvents to the air.
    • Use the best possible application conditions.
    • Store and dispose of equipment properly.
  4. Maintain records demonstrating the MeCl content of materials used, such as Safety Data Sheets (SDS).
  5. Maintain records of the annual MeCl usage for paint stripping and, if more than 2,000 pounds per year is used, a written plan for minimizing MeCl usage at the facility.
  6. Maintain documentation for events higher in MeCl usage and a plan to deal with them.

For more details and assistance, please contact the Air Quality Branch.