The 6H NESHAP commonly refers to the US EPA federal regulation called the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources*. [40 CFR 63, Subpart HHHHHH].  This regulation affects:

AUTOMOTIVE REFINISHING OPERATIONS
All autobody and refinishing shops are subject to the regulation and its requirements.  The following fact sheets and notification forms have been developed to help you understand and comply with the regulation.

• Just the Facts: New EPA Requirements for Automotive Refinishing

• Just the Facts: Spray Painter Training & Certification Requirements

• Initial Notification & Notification of Compliance Status form

• Petition for Exemption for Motor Vehicle or Mobile Equipment Surface Coating Operations form

EPA has developed several tools to further explain the importance and relevance of this regulation, including a video starring NASCAR driver Jeff Gordon and featuring testimonies from large and small shop owners.  This information is available on the EPA website.  

Although EPA will not be approving spray painter training and certification courses, many paint manufacturers and trade associations have established their own training course.  Check with your local vendor or representative for availability.  Alternatively, internet-based training programs (such as I-CAR) are also being established.

METHYLENE CHLORIDE PAINT STRIPPING OPERATIONS
Facilities that use any amount (even very little) of methylene chloride to remove dried paint (including but not limited to paint, enamel, varnish, shellac and lacquer) from wood, metal, plastic and other substrates is subject to this regulation and must:

• Implement management practices to minimize the evaporative emissions of MeCl by

• evaluating each application to ensure there is a need for paint stripping,
• evaluating each MeCl paint stripping operations to ensure no alternative technology is available,
• reducing exposure of MeCl to the air,
• optimizing conditions at time of application to reduce evaporation, and
• practicing proper storage and disposal of paint strippers.

• If you use more than 1 ton of MeCl annually, you must also do the following:

• Maintain copies of annual usage of paint strippers containing MeCl on site at all times,
• Develop and implement a written MeCl minimization plan and keep plan on site, and
• Post a sign outlining the MeCl minimization plan in each area where paint stripping occurs.

* “Area Sources” are non-major facilities whose air emissions are below 25 tons per year total hazardous air pollutants and below 10 tons per year for any single hazardous air pollutant.  Facilities that are exempt from permitting requirements or have either a valid Registration or State Facility Permit are “area sources”.

This regulation does not affect surface coating or paint stripping operations that are performed: at military installations; on munitions or equipment used exclusively for transporting military munitions; by individuals on their personal possessions or by individuals for others without compensation; maximum two motor vehicles or pieces of mobile equipment per year (regardless if compensated or not); meeting the definitions of “research and laboratory activities” or “quality control activities”; or operations that are regulated by another area source NESHAP.

• Just the Facts: New EPA Requirements for Methylene Chloride Paint Stripping Operations