EPA 6H Rule Summary
(40 CFR Part 63 Subpart HHHHHH)

On January 9, 2008, the EPA accepted a new standard known as the HAPs 6H rule to reduce the public’s health exposure to Hazardous Air Pollutants (HAPs).  The agency’s main objective is to significantly lessen the amount of HAPs released into the environment during paint stripping or surface coating operations.  During such work practices, the most dangerous chemicals, namely, methylene chloride (MeCl), cadmium, chromium, lead, manganese and nickel compounds, represent significant risk to employee health if proper engineering and administrative controls are not in place.

Because the requirements are extensive, the EPA is allowing existing facilities until January 9, 2011 to reach compliance.  Body shops should review KPA's 6H Checklist to ensure that their paint spray operations are compliant with the EPA 6H rule.

Health Implications

Again, the EPA’s goal is to reduce the public’s exposure of HAP’s that are generated from paint stripping and/or surface coating operations.  Overexposure to MeCl and heavy metal compounds may include but is not limited to:

  • Chronic effects to the Central Nervous System (CNS), causing headaches, dizziness, nausea, and memory loss
  • Decreased visual, auditory, and psychomotor functions
  • Restricted mental development, emphysema, pulmonary edema, and cancer
  • Fatality when exposed to elevated concentrations

The HAPs 6H EPA regulation has been broken down into several requirements in order to comply with the standard:

Paint Areas

  • All painting, paint preparation, and paint stripping must be done in an enclosed paint booth or filtered prep station.
    • This area must have a roof, 3 of the 4 sides enclosed and have a filtered efficiency of at least 98%.

Methylene Chloride (MeCl) Usage

Due to other current EPA rules on the use of MeCl, KPA has long established the recommendation that products containing MeCl not be used in facility operations.  If MeCl products are in use, the following applies:

  • If more than one ton of MeCl is used per year, management must develop and implement a written MeCl minimization plan
  • If less than one ton of MeCl is used per year, there is no written plan required, but the following MeCl alternatives must be considered:
    • Stripping agents that do not contain MeCl such as formic acid, benzyl alcohol, etc.
    • Mechanical stripping
    •  Blasting with wet or dry media
    • Thermal or cryogenic decomposition
    • Intense light

Please note:  Some states have more stringent MeCl usage regulations.  For instance Cal-OSHA and the CA air resource board have restricted usage of MeCl:

The Air Resource Board has adopted a regulation that prohibits the manufacture, sale, or use of automotive cleaning and degreasing products if they contain Perc, MeCl, and TCE. Specifically, the regulation requires manufacturers of brake cleaners, carburetor cleaners, engine degreasers, and general purpose degreasers to eliminate the use of Perc, MeCl, TCE in these products by June 30, 2001.

Spray Gun Requirements

  • Spray guns must be High Volume, Low Pressure (HVLP), or electrostatic, air-assisted air less, or airless spray gun
  • Spray gun cleaning must be done in either an enclosed cleaning machine, by hand if spray guns are disassembled, or by flushing the gun with solvent without spraying (atomization)
  • Several manufacturers have provided us with a list of their spray guns that meet these requirements. 

Training Requirements

  • All employees conducting activities such as paint stripping and or miscellaneous surface coating operations must be properly trained and retrained.  Trainings will consist of but are not limited to:
    • Surface preparation
    • Spray gun set-up and operation including high transfer efficiency spraying techniques
    • Routine spray booth and filter maintenance, paint mixing, matching and application techniques
    • Resolving paint application problems
    • Causes and solutions for finish defects
    • Safety precautions such as respirators, fire hazards, etc
    • Environmental compliance issues
  • Training can be administered through manufacturer training, I-CAR, ASE, etc., or an in house training program. 
  • All spray painters at new sources must complete training no later than 180 days after hiring.   
  • All spray painters at existing sources must complete training no later than 180 days after hiring, or by January 9, 2011, whichever is later.  
  • Initial painter training will be valid for a period of five years, and refresher training must be repeated at least once every five years.
  • Painters that completed training in the last five years before the compliance date will be able to use that training to satisfy the initial requirement. These painters must still renew training within five years of the initial training date.

Notification of Compliance

  • Notification of 6H compliance will vary depending on whether a facility is new or existing. 
  • A new facility must submit their notification of compliance (or target date of compliance) no later than 180 days after their initial set-up. 
  • An existing facility must submit their initial notification of compliance by January 9, 2010. 
    • Full EPA 6 H Rule compliance must be met by January 9, 2011. 

Recordkeeping Requirements

  • Notifications are one-time unless any of the previous information has changed. Notification should be sent to the EPA or state or local air pollution control agency. 
  • Records must be maintained for 5 years and must be kept on site for at least 2 years:
  • Painter training certification with training dates
  • Documentation of filter efficiency
  • Documentation from the spray gun manufacturer proving the gun is an HVLP or otherwise permitted spray gun
  • Copies of any notifications that were sent to the appropriate agency
  • Annual usage of MeCl (if applicable)
  • Documentation of MeCl minimization policies (if applicable)

For more information, see our 6H Checklist and our blog post entitled EPA 6H rule: 9 reasons not to file for an exemption.

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