April 28, 2004

If you only paint small areas and are able to comply with ALL of the following six requirements, then you may be exempt from Part 228 and registration provided you do the following:

1. apply coatings using high volume low pressure spraying with a maximum cap pressure of 10.0 psig;
   
   
2. clean spray guns using techniques that minimize VOC emissions;
   
   
3. use coatings that do not exceed the appropriate VOC content limits in Table 2 of Part 228;
   
   
4. exhaust emissions into appropriate emission control equipment;
   
   
5. apply coatings to work areas that do not exceed 9.0 square feet;
   
   
6. use no more than 55 gallons of coatings and cleaning solvents on an annual basis. The owner or operator of the facility where the coating line operates must retain for five years, records of the quantity of coatings and cleaning solvents used on an annual basis.

This exemption makes sense if you NEVER paint the whole vehicle. In fact, you probably can’t even paint the entire hood of a car. However, body shops that can comply with ALL six items can save $160 per year by not having to register their facility.