EPA Autobody Refinishing Shops 40 CFR Part 63 Subpart HHHHHH Rule

Part I

What is the 6H Rule?

Autobody Refinishing Shops 40 CFR Part 63 Subpart HHHHHH Rule

• AKA: The 6H Rule, Rule 40, The Refinish Rule, etc.

• Published in 2008 – MUST COMPLY BY JAN. 10, 2011

• This new EPA rule regulates three activities• Paint Stripping • Surface coating of motor vehicles and mobile

equipment• Surface coating of miscellaneous metal and/or

plastic parts

What is the purpose of this new rule?

• This rule is intended to reduce hazardous air pollution (HAPs) of metals (like chrome, lead cadmium, manganese and nickel) and reduce methylene chloride fumes from Autobody refinishing work.

What does a collision repair center have to do to comply?

• Use HVLP or equivalent transfer efficiency• Use only enclosed prep stations and spray booths meeting the

definition of this rule (w/ minimum 98% efficient filters)• Train all painters to utilize the required technology, including

methods to minimize overspray/waste• No spray gun cleaning by atomization of cleaning solvent into

filters; must use hand breakdown of guns for cleaning or enclosed gun cleaner apparatus

• Keep records to demonstrate compliance• File required notification with EPA and/or your state or local air

agency

Failure to follow these steps could lead to heavy fines.

Paint Stripping

• Implement management practices that minimize emissions of MeCI:

• Evaluate the need for paint stripping (i.e. is it possible to re-coat w/o stripping?)

• Evaluate each application to identify potential alternative stripping methods

• Reduce exposure of strippers to air• Optimize application conditions• Practice proper storage and disposal• Maintain records of annual usage of paint strippers

containing MeCI– If a collision repair facility uses more than 1 ton of MeCI,

it must be indicated on notification to EPA

Surface coating of motor vehicles, mobile equipment, and miscellaneous surfaces

• Be sure to cover these areas in order to be compliant:• Train/certify all painters on spray gun equipment selection,

spray techniques, maintenance, and environmental compliance

• Install/operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency

• Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun or equivalent technology

• Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent

Paint Technicians are required to be trained on the following:

• General terms of the rule• Roles that require training• Coatings covered by rule• Compliancy date• Spray areas and equipment requirements in the shop• Spray gun requirements

• Set up for best transfer efficiency• Operation for best transfer efficiency• Techniques to improve transfer efficiency• Cleaning the gun

Approved Equipment• HVLP (65% transfer efficient and 10psi at cap)• Electrostatic spray guns• Airless spray guns• Air assisted spray guns• Any non-HVLP gun that demonstrates 65% transfer efficiency as

documented by manufacturer• Check local regulations as some areas only allow HVLP

• Exempted activities• Spray applications using a hand-held device with a cup capacity not

more than 3 fluid ounces (89cc)• Power coating• Hand-held, non-refillable aerosol containers• Non—atomizing technology

• Thermal spray operations using solid metallic or non-metallic materials

Spray Area

• All spray-applied coatings must be used in a prep station or spray booth

• Booth and prep station filters must achieve 98% filter efficiency of overspray

• Booth Filters• Capture overspray and decrease emissions by

allowing air to flow evenly• Be sure to establish and document filter change-

out schedule and procedure

Training

• All Painters must receive hands-on training. Owners are required to keep records of the training. Training must include instructions addressing:– Spray gun equipment selection, setup, and operation– Spray technique for different types of coatings to improve

transfer efficiency and minimize coating usage and overspray– Routine spray booth and filter maintenance– Environmental compliance with the requirements of the rule– A description of methods to be used at the completion of the

initial or refresher training to demonstrate, document, and provide certification of successful completion of training

Important Dates

• New shops (shops that begun spraying since 9/17/2007) must comply immediately

• Existing shops must comply by January 10, 2011• Painters must be trained w/in the next 2 years• Training is good for 5 years and a refresher course is required

every 5 years• All spray painters at new sources (new shop employment

location) must complete training no later than 180 days after hiring

• All painters must have a certificate to show date of training• Shops must notify EPA that they are subject to the rule by

1/11/2010 and must submit notification of compliance by 3/11/2011

Keep your records!

• Records to include:• Copies of notifications submitted to EPA• Painter training certifications• Spray booth filter efficiency documentation• Spray gun transfer efficiency• MeCI content information such as MSDS• Annual usage of MeCI for paint stripping, and

written MeCI minimization plan if annual usage >1 ton/year

• Deviation and corrective action documentation

Resources for the 6H Rule

• EPA Collision Repair Site & Sample Notification form: http://www.epa.gov/collisionrepair/

• EPA 6H Information: http://www.epa.gov/ttn/atw/area/paint_stripb.pdf

Part II

Training

Spray gun set-up and adjustments

• Ideal for best Transfer Efficiency (the volume of coating deposited as part of the paint film as a fraction of the volume of paint sprayed)

• Pick the correct nozzle set-up per product recommendations (Found on Tech Data Sheets)

• Reduce product to recommended viscosity (note that additional solvent may exceed VOC limits)

• Set fan control and fluid control knobs to wide open• Set incoming air pressure at maximum psi per spray gun

manufacturer’s recommendations• Spray test patterns• Adjust fan control and air pressure if needed• Spray panel with 50 – 75% overlap

What an ideal spray pattern looks like

Too far from the panel or too much air pressure

Too close to the panel or incorrect fan adjustment

Air Volume vs. Air Pressure

• A locking diaphragm gauge is best

• Cheater valve with gage is also acceptable

• Never use an ‘always guessing’ cheater valve

Air Volume vs. Air Pressure

• Use an air pressure test cap to ensure proper atomizing air pressure

• Use high flow air fittings• Avoid pressure drop by

using correct diameterair hoses. 5/16” hose should not be used for painting. Air hoses should be 3/8” at lengths up to 50 feet.

Gun Distance

Too Close (4 inches or less)

Just Right (6-8 inches)*

Too Far (9 inches or more)

Too Wet Wet Film Not as wetSmall spray pattern Uniform Finish Larger spray patternHigh Transfer Efficiency

Good Transfer Efficiency

Loss in Transfer Efficiency

Need to spray fast Faster coverage Need to spray slowerBetter gloss in clearcoat**

*Always follow gun manufacturer’s guidelines**Remember to keep the gun perpendicular to the surface

Fluid Tip

• To ensure efficient delivery of a product, correct fluid tip is critical

• Use the spray gun manufacturer recommendations for best results (recommendations found on TDS)

Viscosity

• Be sure to follow directions on how to properly thin the product . Correct thinning results in better sprayability, hiding and material consumption.

Proper Overlap

• Transtar recommends using 50-75% overlap when spraying product.

• This insures proper coverage, consistent build, even texture, and lessens the appearance of striping

Trigger Technique and Timing

• To achieve best results, hold trigger evenly and start slightly before panel.

• Move with the gun (like a dance) and hold the trigger until slightly after the panel ends

• This helps insure even coating over the entire panel

Gun Cleaning

• Due to the 6H Rule, you can no longer spray solvent through the gun to clean

• Some locations require an enclosed gun cleaner – even though not required everywhere, they are permitted for use everywhere

• Disassembled guns may be cleaned by hand if in area not requiring an enclosed gun cleaner

No – Mix System

• The No Mix Plus Formula Retrieval System has the tools you need to accurately mix/reduce waste, mix only what you need and track basecoat use/V.O.C’s.

No – Mix System

• Smart Scale interface:• Reduces waste due to over pours• Improves color match• Tracks material use• Tracks V.O.C

Waste Management

• The RCRA (Resource Conservation and Recovery Act) considers some waste from collision repair facilities to be hazardous and require special disposal

• Information regarding hazardous waste management is available on the EPA website (www.epa.gov)

Waste ManagementType of Waste Waste Management Guidelines

Sanding Dust Dispose of waste dust collected in vacuum sanders properly*After wet sanding, allow waste to dry. Sweep up and dispose of dry waste properly.*

Used Paint Booth Filters

DO NOT DISPOSE of used filters containing Cr, Cd, Pb or other metals in garbage**

Used Paint Cup Liners

If paint does not contain metals, used paint cup liners containing dried paint can be disposed of as non hazardous waste***

Empty Paint Cans Cans containing dried paint*** must be disposed of as hazardous waste unless tested to demonstrate metals levels below limits

Used solvent and paint waste

NEVER dispose of waste paint and solvent down storm drains, septic systems, or dry wells.Label all containers of used solvent and paint waste with the words “HAZARDOUS WASTE”, and consult a local hazardous waste disposal contractor for proper disposal.

Shop towels Disposable towels that have been contaminated with hazardous materials (solvents) must be disposed of as hazardous waste.Store towels contaminated with solvents in closed containers to avoid created a fire or explosion hazard. Such towels should not be air dried before being put in the closed container.

* Some primers contain metals** Unless tested to demonstrate metals levels below limits, filters must be disposed of as hazardous wastes.*** If tested to be below limits, empty containers can be disposed of as non-hazardous wastes.