M: Welcome to this training on an air regulation that could apply to collision repair shops. The regulation is officially called, “Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources”. F: Wow! That’s a mouthful! M: Yes, it is. Because the regulation is found in the code of federal regulations, Part 63, Subpart H-H-H-H-H-H, it is more commonly referred to as the “6H rule.” F: That’s much easier to remember! So what kinds of things are we going to talk about in this training, and how long will it take? M: Well first I should mention there are note-taking sheets that go along with this presentation. They are found on the flash drive with the collision repair curriculum material. 1 6H Air Regulation
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Transcript
M: Welcome to this training on an air regulation that could apply to collision repair shops.
The regulation is officially called, “Paint Stripping and Miscellaneous Surface Coating
Operations at Area Sources”.
F: Wow! That’s a mouthful!
M: Yes, it is. Because the regulation is found in the code of federal regulations, Part 63,
Subpart H-H-H-H-H-H, it is more commonly referred to as the “6H rule.”
F: That’s much easier to remember! So what kinds of things are we going to talk about in
this training, and how long will it take?
M: Well first I should mention there are note-taking sheets that go along with this
presentation. They are found on the flash drive with the collision repair curriculum
material.
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6H Air Regulation
M: While the 6H rule also applies to other businesses, this training will focus on the
requirements for collision repair shops and will take about 45 minutes. This training is
sponsored by the Kansas Department of Health and Environment and the Kansas Small
Business Environmental Assistance Program. We will briefly cover what types of businesses,
in addition to collision repair, might be under this regulation. Also, we’ll look at what
activities at a collision repair shop might be affected by this rule. You know a business can
get fined if it is caught not following the environmental regulations?
F: That’s right, and it is one of our goals to inform you what an auto body shop might have
to do and what records will have to be kept, in case the shop is ever inspected by EPA or
KDHE for compliance with this air regulation. We will briefly talk about notifications that a
shop owner should have done already, or that will need to be done for new shops. Finally,
we will provide other resources to help with following the rules, preventing pollution, and
ultimately saving money
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6H Air Regulation
F: What do you think we mean by “Area Source”?
M: That’s kind of an odd term. We are talking about air pollution, right?
F: Today we are looking at one part of the air regulations, those regulated under the
National Emission Standards for Hazardous Air Pollutants, or NESHAPs. The Clean Air Act
contains a list of more than 180 chemicals that are officially classified as HAPs. The
NESHAPs regulate two general categories of sources—major sources and area sources.
Major sources emit more HAPs than area sources. Most, if not all, collision repair shops are
going to fall in the area source category. Technically, “area" sources are those that annually
emit less than 10 tons of a single hazardous air pollutant or less than 25 tons of a
combination of HAPs. Note these can be any hazardous air pollutants that are on the HAP’s
list.
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6H Air Regulation
M: The businesses that could fall under this rule are divided into three sources:
First there’s paint stripping operations using methylene chloride (MeCl) to remove dried paint from
various types of surfaces including wood, metal, and plastic. Hopefully, this will never apply to any
of you.
A second operation affected by the 6H rule is a business that spray-applies coatings containing
certain HAPs to any metal or plastic parts or products that are not motor vehicles or mobile
equipment (as described in the third bullet). The hazardous air pollutants that are of concern in this
regulation are Cr, Pb, Mn, Ni, or Cd.
The third source affected by these regulations is a business that spray-applies surface coatings to
motor vehicles and mobile equipment.
F: Wait! Motor vehicles. That sounds like what collision repair specialists do—paint motor vehicles!
M: That’s right. These terms will be defined in the next slide. This category of painters also includes
those who take their “show on the road” – mobile refinishing operations.
F: Does this rule apply to individuals that repair cars as a hobby? Like in their garage at home?
M: It applies if they coat more than 2 vehicles in a year
Note with the third type of affected source, (those who paint motor vehicles or mobile equipment),
it doesn’t matter what hazardous air pollutants you may or may not have in your paint, you are
automatically considered an affected source.
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6H Air Regulation
F: In the regulations, motor vehicle is defined as any self-propelled vehicle, including
automobiles, light duty trucks, golf carts, vans, and motorcycles.
M: What’s considered mobile equipment?
F: Mobile equipment is any device that may be drawn and/or driven on a roadway
including, but not limited to, heavy-duty trucks, truck trailers, fleet delivery trucks, buses,
mobile cranes, bulldozers, street cleaners, agriculture equipment, motor homes, and other
recreational vehicles (including camping trailers and fifth wheels).
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6H Air Regulation
M: So what are the hazardous air pollutants of concern in this regulation?
F: For auto body shops, the rule applies if paints contain any of five chemical compounds:
chromium, cadmium, lead, nickel, or manganese at certain concentrations. The
concentrations depends on whether OSHA has defined that chemical as cancer-causing or
not.
M: So which one of these chemicals are thought to cause cancer and which are not?
F: EPA decided if a compound is known to or might cause cancer, then it is considered a
carcinogen. What this means is that hexavalent chromium (Cr+6), cadmium, lead, and
nickel are carcinogens for this definition and trivalent chromium (Cr+3) and manganese are
in the “other” target HAP compounds category.
M: So if a chemical is thought to cause cancer, and it is present in the paint in a
concentration above 0.1%, than the requirements of this regulation must be followed. Also,
if a chemical is not a carcinogen, but it is present in the paint in a concentration above
1.0%, than the requirements of this reg applies.
The chemical ingredients in your paints, along with their concentrations, may be found in
the material safety data sheet, or MSDS as you may have heard it called.
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6H Air Regulation
At this time, you may pause the presentation and go over some MSDS sheets of coatings to
determine whether they have the targeted metal hazardous air pollutants or HAPs.
Otherwise continue to the next slide.
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6H Air Regulation
M: I heard if I’m a collision repair shop and I don’t use any of the five HAP metals of
concern, then I can get out of being subject to this regulation.
F: That’s right! You can send a form to EPA and KDHE requesting to get out of the
requirements for an auto body shop. You’re sending what’s called a “petition for an
exemption.” You may petition EPA for an exemption if you can certify that the target HAPs
are not found in any of the spray coatings you use in those concentrations given in one of
the earlier slides. Also, the petition must contain a description of the coatings you do use.
M: Where can I get this form to petition for an exemption from the rule?
F: The KS SBEAP included a blank form with this curriculum. You are not required to use the
form, but it makes it handy to be sure all the needed information is included.
M: What if some day in the future, I get a car that needs repairing and I have to use paint
that contains one of the targeted HAPs?
F: Then you will need to notify EPA and KDHE and start complying with these regulations.
The curriculum materials also has a form for notifying the regulatory agencies. This form
has the information requested by the regulation when sending a notification to EPA and
KDHE.
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6H Air Regulation
M: Near the beginning of this training, we said something about a person who repairs cars
as a hobby could be subject to the regulations.
F: That’s right, they could be. But this rule would not affect them, if these individuals or
hobbyists performed spray painting on their personal vehicles, possessions, or property, or
did this for others without compensation. But remember, they can’t paint more than 2 cars
per year. And again, this only applies if they are using paints with one of the targeted
metals.
M: I see where the 6H rule doesn’t apply to facility maintenance activities. What’s
considered a facility maintenance activity?
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6H Air Regulation
F: Most of you in a collision repair training program will probably go on to work at an auto
body shop. But just in case some of you have an opportunity to refinish mobile equipment
in the field, it will be good to know, that is considered a maintenance activity that does not
have to follow the 6H requirements.
M: Some examples include refinishing farm or mining equipment. It also includes items,
such as fork trucks, that are used in a manufacturing facility and which are refinished in
that same facility.
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6H Air Regulation
F: These are the types of activities that the 6H rule may affect: