Posts Tagged ‘6H’

6H Rule Now In Effect, Are You Ready?

Tuesday, January 11th, 2011

The 6H Rule is now in effect and establishes two classes of painters – “certified” and “uncertified”.  Certified painters must have had training on use of certain paints commonly used in body shops and collision centers under the new rule.  The rule states “the spray application of surface coatings is prohibited by persons who are not certified as having completed the training described in paragraph (f) of Section 63.11173″.

Steven Schillinger, President of GRC-Pirk, the authorized registrar under the Certified Spray Coating program, states “most collision repair shop owners do their best to protect the environment and provide their employees with a safe and sound workplace …in this era of restricted state and federal budgets, the uniform response from government agencies and civil attorneys has been to increase enforcement activities”.    For more information on EPA rule 6H, see  KPA’s  6H Rule Overview and sign up for my free webinar ” EPA’s New 6H Emission Standards are in place, are you compliant?“ on January 20th at  http://forms.kpaonline.com/go/kpa/6hKPA

Join the converstation: Are you ready for 6H?

Free webinar on EPA’s 6H emission standard

Monday, January 10th, 2011

Have you signed up for the free 6H Emission Standards webinar on January 20, 2011? Peter Zaidel, product manager at KPA, will review the EPA-6H (40 Code of Federal Regulations 63, Subpart HHHHHH) requirements so you can be sure you’re fully compliant. Click here for the registration form.   You cannot make it on January 20? I’d highly recommend you still sign up as you will receive an email after the webinar with a link to the recording.

EPA 6H rule: 9 reasons not to file for an exemption

Thursday, January 7th, 2010

»Download the 6H Rule Compliance Checklist

Steven E. Schillinger, President of GRC-Pirk Management (http://www.recomply.com/) is a KPA partner serving the collision center industry and a specialist on the EPA 6H rule. Steven lists nine reasons why filing for an exemption is a bad idea:

  1. Exemption form is an application only, not immunity, and requires written acceptance from the EPA
  2. Guarantees EPA review and/or inspection
  3. Shops can’t be conditionally exempt, all or none – paint one-time with vibrant or pearl and they’re subject to the rule for the entire year
  4. Shops will have to prove an exemption each permit renewal period
  5. Shop assumes vicarious liability if they sign a false affidavit
  6. Prohibits use of ANY products containing Target HAPs, i.e., 3-M products, cleaners, strippers, any jobbers products, etc. – not just one manufacturers product-line
  7. Many Air districts have added the rest of the EPA 188 toxic HAPs to a local rule – Delegated Authorities can be more restrictive than the 6H Rule
  8. Inspectors are instructed to cut a sample of the booth filter for lab-testing – when ANY Target HAPs appear (and they do) shops will have to defend!
  9. Why file exemption? It’s easy to be compliant and most reputable shops are already in compliance!

Steven also wrote a great article in Auto Body News how this new 6H rule could benefit shop owners as it could eliminate illicit shops.

Body Shops should review KPA’s 6H Checklist to ensure that their paint spray operations are compliant. For more information on EPA rule 6H, see our 6H Rule Overview.

Tip of the month: every facility conducting spray coating must file notification with EPA before January 10

Monday, December 7th, 2009

compliance tip of the month

An initial notification letter or a petition for exemption has to be filed with EPA regarding compliance with 40 CFR Part 63, Subpart HHHHHH (also referred to as the 6H rule). Every facility conducting vehicle spray coating operations must file an initial notification of compliance or a petition for exemption with the EPA by January 10, 2010. The initial notification is ordinarily submitted to both the EPA region where the facility resides, and the delegated regulatory authority, if any. Consult the list of delegated regulatory authorities (PDF) (2pp, 21k).

A free recorded webinar about the 6H rule is available to find out:

  • If you qualify for an exemption, and why you are probably better off not trying to claim the exemption.
  • Requirements for new facilities, and why your definition of a new facility is probably not the same as the EPA’s definition. For example, if you install new paint equipment the EPA may reclassify your shop as a “New Facility”