Federal EPA Area Source NESHAP Rule 6H

Federal EPA rule 40 CFR Part 63, Subpart HHHHHH (6H) was published in January 2009. The rule applies to any area source that engages in any of the following activities:

Paint stripping using paint stripper containing methylene chloride (MeCl)
Spray application of coatings to metal or plastic substrates with coatings containing compounds of chromium, lead, manganese, nickel or cadmium.

Basic Requirements for Surface Coating Operations:

Training:

Must train/certify all painters on spray gun equipment selection, spray techniques, maintenance and environmental compliance. Sherwin-Williams provides help to comply with the training requirement. Contact a Sherwin-Williams representative for more information.

Spray Booths:

Surface coating must be performed in a spray booth or prep station with filter technology to achieve at least 98% capture efficiency. Shops should keep a letter from the filter manufacture stating this.

Application Equipment:

Must use HVLP or an equivalent technology.

Compliance Date:

Existing sources (in operation before 9/17/2007) must comply on January 10, 2011.
New sources must comply upon start-up.

Reporting and Record Keeping:

Initial Notification (Informs EPA that the facility exists and is subject to the standards):

Existing source 1/11/2010
New sources 180 days after startup.

Certification of Compliance:

Existing sources 3/11/2011
New sources as part of initial notification

Keep records of training, filter efficiency, and notifications sent to EPA.

Resources:

This page is meant to provide general information on the 6H regulation and is not to be used to judge a shop's compliance or non-compliance with the rule. Compliance must be based on the full text of the rule as published by the U.S. EPA.