ALERT! A significant EPA regulation affecting the collision repair industry is now in effect. This regulation is referred to as the Final Rule on National Emissions Standards of Hazardous Air Pollutants (NESHAP).
An Initial Notification form is required to be submitted to the EPA by January 11, 2010; however for new facilities (with new building or stripping/coating equipment installed after September 17, 2007) this form is now due.
The effective date to comply with all requirements (Certification of Compliance) of this new regulation is March 11, 2011 for existing facilities.
Key requirements of this regulation include the following:
Painter training / documentation / certifications: Training is available with ICAR.
Painter certification is due by January 9, 2011 or 180 days after hire, whichever is later. Refresher training is due every 5 years.
Use of enclosed gun washer to minimize emissions.
HVLP spray guns to reduce overspray and increase process efficiency
Enclosed spray booth or fully operating prep station
Documentation of Booth Filter efficiency: 98%
MSDS' are required for all products containing methylene chloride (MeCl)
Documentation showing less than 2,000 lbs. of MeCl product usage per year
Compliance Notification submitted to the EPA by January 11, 2010
Documentation showing any deviations from the EPA's requirements and corrective actions
Link to Michigan DEQ on compliance http://www.michigan.gov/deq/0,1607,7-135-3310_4148-192582--,00.html
