The U.S. Environmental Protection Agency has finalized its automotive refinishing regulation. The Automotive Service Association (ASA) is providing the following overview of the regulation to familiarize auto body repairers with the topics included in the final regulation. The regulation in its entirety can be reviewed on ASA's Legislative Web site, www.TakingtheHill.com, or a downloadable two-page summary of this regulation is available in the Members Only section of the ASA Web site, www.ASAshop.org.

What Is the New EPA Regulation?

The new U.S. Environmental Protection Agency regulation provides for equipment and training restrictions for those engaged in the surface coating of motor vehicles and mobile equipment that are an area source of hazardous air pollutants (HAPs).

Does This Apply to Me?

This regulation applies to all auto body shops in the United States. Surface coatings performed by individuals on their personal vehicles, possessions or property - either as a hobby or for maintenance of their personal vehicles - are exempt from this regulation. The regulation also does not apply to operations performed by individuals for others without compensation.

An individual who spray applies surface coatings on more than two motor vehicles or pieces of mobile equipment per year is subject to the requirements of this regulation.

When Does This Regulation Go into Effect?

Shops that began construction after Sept. 17, 2007, must be in compliance by the start of operations. Existing shops must comply within three years after Jan. 9, 2008.

What Are the Equipment Requirements?

All surface coating operations are required to have the following:

• A high-volume, low-pressure (HVLP) spray gun; electrostatic spray gun; airless spray gun; air-assisted airless spray gun or a gun demonstrated to be equal in transfer efficiency to an HVLP gun.

• Prep station or spray booth with four complete side walls or curtains and a complete roof.

• The exhaust from the prep station or spray booth must be fitted with filters demonstrated to achieve at least 98 percent filter efficiency of paint overspray.

• Spray guns must be cleaned in an enclosed spray gun cleaner or by cleaning the disassembled gun parts by hand.

What Are the Training Requirements?

• Initial painter training will be valid for a period of five years.

• Refresher training must be repeated at least every five years.

• Painters that completed training in the past five years before the compliance date will be able to use that training to satisfy this requirement.

• All spray painters at new sources must complete training no later than 180 days after hiring or 180 days from Jan. 9, 2008, whichever is later.

• All spray painters at existing sources must complete training no later than three years from Jan. 9, 2008, or no later than 180 days after hiring, whichever is later.

What Do I Have to Do?

Shops must submit an initial notification to the U.S. EPA unless the EPA's delegated authority for implementation of the regulation is your state or local air pollution control agency.

The notification must include:

• Name, address, phone number and e-mail address of the owner.

• Physical address of the shop.

• A statement that the source is subject to this standard.

• A brief description of the type of operation and what types of activities are performed at the shop.

If you are a new shop, the notification must be submitted no later than 180 days after initial startup. For existing shops, the initial notification must be submitted within two years after Jan., 9, 2008.

What Types of Records Am I Required to Maintain?

All sources must keep records sufficient to demonstrate that they are in compliance at all times. These include:

• Records that each spray painter has completed the required training.

• Documentation of the filter efficiency of any spray booth exhaust filter material, such as data from the filter manufacturer.

• Documentation from the spray gun manufacturer that each spray gun that does not meet the definition of an HVLP spray gun, electrostatic spray gun, airless spray gun, or air-assisted airless spray gun has been demonstrated to achieve a transfer efficiency equal to one of the other allowed types of spray gun.

• Copies of any notifications or reports that were submitted.

• Records of any deviation from the requirements in the final rule, including the date and time period of the deviation, and a description of the nature of the deviation and the actions taken to correct the deviation.

• Records of any assessments of source compliance performed in support of the initial notification, notification of compliance status or annual notification of changes report.

For more information, please contact:

Denise Caspersen
ASA Collision Division Manager
1901 Airport Freeway Bedford, Texas
(817) 358-5236, direct line
denisec@ASAshop.org

or

Kim R. Teal
Environmental Protection Specialist
U.S. EPA/OAR/OAQPS/SPPD/NRCG
E143-03
Research Triangle Park, NC 27711
Phone (919) 541-5580, direct line
E-mail: teal.kim@epa.gov

Bob Redding is the Automotive Service Association's Washington, D.C., representative. He is a member of several federal and state advisory committees involved in the automotive industry. For more information about the legislative activities of ASA, visit www.TakingTheHill.com.

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