By now, almost everyone in the collision industry has heard about the 40 CFR Part 63, Subpart HHHHHH rule, or as it is more commonly referred, the 6H rule. Even though the rule is not brand new, it is still a source of confusion for many. How do I know if the rule even applies to me and when does the rule come into play are some of the most common questions people have concerning the 6H rule.

The 6H rule is intended to reduce hazardous air pollution (HAPs) of metals (like chrome, lead, cadmium, manganese and nickel) and reduce methylene chloride fumes from autobody refinishing work.  If you are a collision and fleet coatings application facility or if you perform paint stripping operations using Methylene Chloride (MeCI) and HAPs this rule applies to you and for most shops.  You must comply with the rule by January 10, 2011.

Here are the two main steps to the rule (outlined to make it easier to understand):

First, it is important to note that the rule regulates three main activities, including: paint stripping using methylene chloride, surface coating of motor vehicles and mobile equipment and surface coating of miscellaneous metal and/or plastic parts.

Second, in order to follow this new rule, you need to make sure that your shop follows these six steps:

1. Send initial notification to EPA by 1/11/2010 and new sources 180 days after startup
2. Use only enclosed prep stations and spray booths meeting the definition of this rule (with minimum 98% efficient filters)
3. Use HVLP or equivalent transfer efficiency guns
4. Train and certify all painters to utilize the required technology
5. Paint spray gun cleaning cannot create any mist of cleaning solvent into the air – breakdown guns by hand for cleaning or use an enclosed gun cleaner apparatus
6. Keep records that demonstrate compliance!

The important thing to remember when following the new 6H rule is to keep your records, including copies of notifications sent to EPA, painter training certifications, MSDS for MeCI content information, deviation and corrective action documentation, etc.

Let us know what you think about the 6H rule and how you’re handling the change at your shop!

For more information, visit these resources:
EPA Collision Repair Site & Sample Notification form:   http://www.epa.gov/collisionrepair/
EPA 6H Information:  http://www.epa.gov/ttn/atw/area/paint_stripb.pdf
Small Business EnviroAssistance: http://www.smallbiz-enviroweb.org/Compliance/NewRules/PaintStripping.aspxm
I-CAR self Study Certification Course:  http://www.i-car.com/index_us.shtml