Auto Collision Repair Shops

Auto collision repair shops have the potential to emit hazardous air pollutants (HAPs) that are regulated by both the U.S. Environmental Protection Agency (EPA) and DEQ.

On January 9, 2008, EPA signed into law the Paint Stripping and Miscellaneous Surface Coating Area Source Rule (40 CFR Part 63 subpart HHHHHH), known as "Rule 6H," to reduce the emissions of certain HAPs from the spray application of coatings and from paint stripping using products containing methylene chloride.

Exemption Request

In accordance with 40 CFR Part 63.11170(a)(2), an owner or operator of a motor vehicle or mobile equipment surface coating operation may petition the EPA administrator for an exemption from the regulatory requirements of 40 CFR Part 63 Subpart HHHHHH as they apply to that operation if the owner or operator can demonstrate that the spray-applied coatings used by the facility do not contain target hazardous air pollutants (HAPs). (Note: In determining whether your spray-applied coatings contain target HAPs, do not include coatings applied using hand-held aerosol cans or spray guns with a cup capacity of 3 fluid ounces or less.)

As defined in 40 CFR 63.11180, coatings are "target HAP containing coatings" if they contain compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) at concentrations greater than the following thresholds:

• If the compound is a carcinogen, the coating must contain more than 0.1% by mass of that individual target HAP to be considered a "target HAP containing coating."
• If the compound is not a carcinogen, the coating must contain more than 1.0% by mass of that individual target HAP to be considered a "target HAP containing coating."

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