| Booths, HVLP and painter training mandated under new federal reg |
by John Yoswick
New air quality rules impacting automotive refinishing that were finalized by the Environmental Protection Agency late last year are generally being viewed positively by the collision repair industry.
“We believe that the EPA has adequately met the necessary elements of three important pieces in the proposed regulation: equipment, training and enforcement,” Bob Redding, Washington, D.C., representative for the Automotive Service Association (ASA), said.
Redding said he believes that many shops are already in compliance with the proposed new rules, but that the regulations will raise the bar for those not adequately protecting the environment.
“We know there are people out there painting who are not doing it in a spray booth with proper training, for example,” Redding said. “We’re hopeful this will lift them up and raise the industry standard.”
The new regulation is a result of the Clean Air Act of 1990, which requires the EPA to identify sources that emit one or more of the 188 listed toxic air pollutants. Specifically included in the regulation are stricter requirements for “area sources” engaged in paint stripping or various surface coating operations, including autobody refinishing.
“Area sources” are defined as those that have the potential to emit less than 10 tons per year of a single toxic air pollutant or less than 25 tons per year of any combination of toxic air pollutants.
Area sources that would be affected by the rule will need to implement equipment and management practices to comply with the new standards, if they have not already done so. But the practices are designed to reduce overall toxic material consumption, which generally results in a savings to the business as well.
The regulation places a number of requirements on collision repair shops. In terms of training, shops will be responsible for ensuring all painters have completed hands-on training in the proper application of surface coatings. The training must cover specific items such as spray gun setup, surface prep, spray booth and filter maintenance, transfer efficiency, and environmental compliance. Painters must be certified within 180 days of hire and recertified every five years.
In terms of equipment, all painting of vehicles must be done in a spray booth (or, in the case of painting of some vehicle parts, a prep station) that meets the regulation’s requirements. The booth, for example, must be fully enclosed with four complete walls and a full roof, and use a filter system fitted with polyester fiber or fiberglass filters (or the equivalent) that capture at least 98 percent capture of paint overspray. Compliance for spray booth filter efficiency can be satisfied through data provided by the filter manufacturer.
Prep stations must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth.
The new EPA regulation also requires that all spraying of coatings be done with a high-volume, low-pressure (HVLP) spray gun (or in some way that has an equivalent transfer efficiency). The requirements were changed just before being finalized to allow the use of airless or air-assisted spray guns without having to demonstrate that they are equivalent to HVLP guns in transfer efficiency.
All paint spray gun cleaning must be done either with solvents that do not contain the hazardous air pollutants, or within a fully-enclosed spray gun cleaner. Hand cleaning of parts with solvent is permitted but spraying solvent through the gun is prohibited.
The EPA estimates that the regulation will require about 5,000 shops to purchase an enclosed gun cleaner, and that a similar number will have to install new spray booths.
Shops will have three years from the time the regulation was finalized – so until January of 2011 – to comply with its requirements. Redding said ASA also believes the regulation is enforceable, as compliance can be monitored and enforced either by state or regional air quality regulators.
Prior to the regulation being finalized, ASA wrote to the EPA generally supporting the proposal although expressing concern for its exception to the spray booth requirement for those priming of small areas or performing spot repairs with an air brush.
“Unfortunately, technology now provides ‘miniature spray guns’ that are being used in open areas,” Redding wrote in ASA’s letter to the EPA. “This allows air brush specialists and others to expand the area subject to automotive refinishing products. ASA requests the EPA to consider tightening the final regulation to ensure that any exception, if critically necessary, to the spray booth requirement exclude ‘miniature spray guns’ or similar technologies. Those persons or business entities using ‘miniature spray guns’ should be required to have a spray booth.”
The EPA responded by saying the regulation is intended to cover mobile vehicle refinishing operations, and only exempts from the paint booth and other requirements those applying coatings from a spray gun with a cup size of three ounces or less.
Hobbyists, those defined as spraying up to two vehicles per year without compensation are also exempted.
The regulation also spells out what the anticipated costs of compliance are. The EPA’s estimated cost for training, for example, is $1,000 per painter, which covers tuition costs and labor cost for 16 hours of training time. This cost could be offset, the EPA estimates, over five years through a 1 percent reduction in the amount of coatings sprayed. The EPA calculates that training and use of HVLP spray equipment should reduce materials use sufficiently to offset any such initial investment. The regulation points to data from one study that indicated painters completing the spray technique training decreased the amount of coating sprayed by about 20 percent per job.
ASA was also pleased to see the EPA make some changes to the reporting and record-keeping requirements in the regulation. All sources will need to submit an initial notification stating whether they are already in compliance with the requirements or whether they plan to be in compliance by the compliance date. Annual compliance reports will only need to be submitted if there is a change in any of the initial notification information.
Redding said although ASA believes that the most effective method for enforcing automotive refinishing regulations is controlling the paint product at “the point of sale,” any such regulations on who can purchase automotive refinish products is strongly opposed by paint distributors.
“So although not optimum, ASA believes the enforcement for this regulation will be sufficient,” Redding said. “The EPA spent a great deal of time researching this issue and visiting collision repair facilities. The agency also listened to what collision repairers had to say about regulating the use of these products.”
© 2007 Image Output
John Yoswick, a freelance writer based in Portland, Oregon, who has been writing about the automotive industry since 1988, is also the editor of the CRASH Network.
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