be prepared for epa’s new emission standards
DESCRIPTION
Be Prepared for EPA’s New Emission StandardsTRANSCRIPT
BE PREPARED FOR EPA’S NEW EMISSION STANDARDS
www.kpaonline.com
(866) 356-1735
BE PREPARED FOR EPA’S NEW EMISSION STANDARDS
www.kpaonline.com
(866) 356-1735
KPA – Company ProfileKPA – Company Profile
• Nationwide compliance expert on Safety, Environmental, HR
• Colorado Headquarters• 23 Years Experience • 3000 + Clients
– Dealerships, Service, Repair
• 20 Offices Serving 41 States
• Compliance products and services
– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite training
and tracking– And many more…
QuestionsQuestions
• If you have questions during the presentation, please submit them using the “Questions” feature
• Questions will be answered at the end of the webinar
EPA’s New Emission Standards for Collision Centers
40 CFR Part 63, Subpart HHHHHH
“The 6H Rules”
Paint Stripping and Miscellaneous Surface Coating Operations at Area
SourcesNow in Effect!
Why the Need for this Rule?
CLEAN AIR ACT
EPA’s New 6H Emission Regulations
Misc. Surface Coating
Paint Stripping
Operations
Auto Body Refinishing
3 Sources
What are the Requirements?
Notification
Painter Training
Spray Gun Selection
Spray Gun Cleaning
Spray Booths
Re-Notification
Recordkeeping
Notification
January 11, 2010
Final form is attached
Initial NotificationInitial Notification
Notification FormNotification Form
Return Receipt Required
January 11, 2010
Deadline for Initial Notification
January 10, 2011
Must Meet Major Requirements
March 11, 2011
Deadline to Re-Notify
Regulatory Deadlines
All Painters must complete by January 10, 2011
Renewed Every 5 Years
Available from Multiple SourcesThis webinar does not satisfy all of the requirements
Painter Training Requirements
Spray gun equipment selection, set up, and operation.
Spray techniques for different types of coatings to improve transfer efficiency and minimize coating
usage and overspray.
Routine spray booth and filter maintenance.
Environmental Compliance Requirements of these Regulations.
Painter Training Requirements
HVLP or Equivalent Technology
Electrostatic Application, Airless Spray Gun or an Air-Assisted Airless Spray Gun
Written Approval Required from the EPA for Non-HVLP Sprayers
Spray Gun Selection
If you are spraying solvent through your gun to clean it, you must collect the spray.
The EPA suggests using a fully enclosed spray gun washer, but they do not require it.
Spray Gun Cleaning
KPA
Half Way There!
Is a Booth Required Now?
OSHA Regulations Already Requires a Paint Booth
Can be a Prep Station or Mobile Enclosure
Spray Booth Requirements
98% Removal Efficiency or Higher
Must Be Documented
Change-Out Schedules
Dependent on Specific Shop conditions
Full Roof
4 Complete Walls or Curtains
Ventilated at Negative Pressure
Whole Vehicles
Full Roof
3 Complete Walls or Curtains
Ventilation that Draws Air In
Parts or Subassemblies
For Spot Repairs
Enclosed Enough to Retain All Paint Overspray
Overspray Must Be Directed to the Ventilation System Filters
Mobile Spray Booths
March 11, 2011 Deadline
Check off that you are now in compliance.
Must sign the form this time.
Re-Notification
Only required if your information or status changes.
March 1 Deadline
Annual Notification of Changes
Most Important Step
Must be able to provide required documents.
Maintain for 5 Years
Keep it organized
Recordkeeping
Copies of all signed notifications you send to the EPA.
All signed receipts from the postal service that proves you sent your notifications.
Certification that each painter has completed the training.
Documentation of your filter efficiency.
Documentation for non-HVLP spray guns.
Records of any deviation from the requirements.
What Records Do you have to Keep?
Review
Notification
Painter Training
Spray Gun Selection
Spray Gun Cleaning
Spray Booths
Re-Notification
Recordkeeping
2 Exemptions
Must ensure that all of your sprayed materials do not contain:
• Cadmium - Cd• Chromium - Cr• Lead - Pb• Nickel - Ni• Manganese - Mn
Do you qualify?(unlikely…)
What about the Air Brush Exemption?
Up to 3.0 Fluid Oz.
Can’t ever use anything else
Done!
QUESTIONS?
Free Consulting Time!
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