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
Guidelines for The New Body Shop Rules
EPA’s New Emission Standards for Collision Centers
October 15, 2009
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
Sources
Why the Need for this Rule?Why the Need for this Rule?
CLEAN AIR ACT
EPA’s New 6H
Emission Regulations
Misc. Surface Coating
Paint Stripping
Operations
Auto Body Refinishing
What are the New Requirements?
Notification
Painter Training
Spray Gun Selection
Spray Gun Cleaning
Spray Booths
Re-Notification
Recordkeeping
Notification
January 11, 2010
3 Months
Form is Attached
Initial Notification FormInitial Notification Form
Initial Notification FormInitial Notification Form
Initial Notification FormInitial Notification Form
http://www.smallbiz-enviroweb.org
Initial Notification FormInitial Notification 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
Painter Training Requirements
All Painters must complete by January 10, 2011
Renewed Every 5 Years
Available from Multiple Sources
Painter Training Must Include:
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
New 6H Regulations.
Spray Gun Selection
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 Cleaning
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.
KPA
Spray Booth Requirements
Is the EPA requiring all painters to have a booth now?
OSHA Regulations Already Requires a Paint Booth
Can be a Prep Station or Mobile Enclosure
29 CFR 1910.107
Spray Booth Requirements
Ventilation is Required
Filter Efficiency of 98%
Spray Booth for Refinishing Whole Vehicles
Full Roof
4 Complete Walls or Curtains
Ventilated at Negative Pressure
Spray Booth for Refinishing Parts
Full Roof
3 Complete Walls or Curtains
Ventilation that Draws Air In
Mobile Spray Booths
For Spot RepairsEnclosed Enough to Retain All Paint OversprayOverspray Must Be Directed to the Ventilation System Filters
Re-Notification
March 11, 2011 Deadline
Check off that you are now in compliance.
Must sign the form this time.
Annual Notification of Changes Report
Only required if your information or status changes.
March 1 Deadline
Recordkeeping
Most Important Step
Must be able to provide required documents.
What records must you keep?
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.
Recordkeeping
Must Retain Records for 5 Years
Designate a specific location to maintain these records.
Good News – We are almost done!
Bad News – We still need to cover 2 complicated issues.
New Facility?
If you installed new equipment after September 17, 2007.
Equipment includes: Mixing Room, Mixing Room Equipment, Prep Station, Spray Booth, Spray Guns and Associated Equipment, Spray Gun Cleaning Equipment, Solvent Recyclers
So you are a New Facility – What’s the big Deal?
Your Compliance Date was the Day You Opened!
New Facilities Should Already have done:
Notification
Painter Training
Spray Gun Selection
Spray Gun Cleaning
Spray Booths
Re-Notification
Recordkeeping
Exemption?
Must ensure that all of your sprayed materials do not contain:
Cadmium - CdChromium - Cr
Lead - PbNickel - Ni
Manganese - Mn
Exemption?
Exemption?
Exemption?
QUESTIONS?
Free Consulting Time!
Contact InformationContact Information
43– KPA CONFIDENTIAL –
The recorded webinar and presentation slides will be emailed to you today including your local representative’s contact information.
www.kpaonline.com
866-356-1735
Chuck ElliottEHS Engineer
[email protected](404) 626-6310
Cameron CurtisAccount Executive
[email protected](303) 228-2389
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