Paint & Autobody Rule (6H) Frequently Asked Questions . Rule. Watch the latest BodyShop Business video. 2. What does this rule cover? The response letter issued by the EPA Air Branch, Monitoring, Assistance and Media Programs Division clarified that the 3-ounce cup was indeed defined by the agency as a way to distinguish conventional collision and vehicle repair from "operations that perform vehicle repairs of small stone chips and scratches. The regulatory navigation tool can be used in conjunction with this list to determine if an autobody shop can petition for an exemption. Under the EPA HAPs 6H and 6X rules, exempt operations shall prohibit personnel from the spray application of specific coatings. Under the EPA HAPs 6H rule, beginning January 10, 2011, operations submitting a notification of compliance have trained personnel in compliance with the spray application of Spray coatings. SCRS and 26 of its affiliate associations issued the letter to 10 EPA regional offices requesting clarification on the interpretation and intended enforcement of exemptions listed in the EPA 6H Rule. ... you have to get a written approval from EPA, Region 4 to use it. This is not necessarily a comprehensive list, and if you have additional resources that can be added to this page please e-mail nlarson@ksu.edu. SATAjet X 5500 Bionic – Below The Surface. The 6H rule does not extend to spray-applied coatings applied from a handheld device with a paint cup capacity that is equal to or less than 3 fluid ounces, the EPA said in its response to the SCRS. Collision Works Acquires DeShields Truck Services Inc. Chief Donates Welder and Rivet Gun for CREF Top Tech Mentor/Mentee Competition. Letters regarding 6H-targeted metal content of specific paint formulations, Question and answer document regarding the 6H rule. Below are links to vendor-supplied resources. "In their response, the EPA Office has made it clear that much of the rule enforcement is based on intent. ", "We’re pleased that the EPA has responded with a clear and concise message that collision repairers and mobile operators alike will be held to the same regulatory requirements as it relates to the 6H Rule," said SCRS Chairman Aaron Clark. If you have compliance-specific questions, contact your state SBEAP. In some cases, the use of the 3-ounce cup may be a necessity of the job being performed, but it’s clear to us that the EPA offices will not accept intentional circumvention of the rule by habitually ‘fragmenting paint jobs into smaller tasks’ or ‘refilling 3-ounce cups in an effort to avoid regulation.’ This is the basic clarification we were looking for and anticipate that this will provide solid information for shops. By now, all shops should be in compliance with the Environmental Protection Agency’s (EPA) 6H rule, which places tighter restrictions on shop equipment, practices and training involving paint stripping and surface coatings.. Rule 6H also creates a higher standard of training for painters, requiring certification by law for the first time. ", The letter pointed out that both "mobile operations and conventional collision repair shops are subject to the rule requirements for training, spray equipment and the use of a spraybooth or other ventilated and filtered enclosures," and that while "the 6H Rule does not extend to spray-applied coatings applied from a hand-held device with a paint cup capacity that is equal to or less than 3.0 fluid ounces, the Agency may find that persons who repeatedly refill and use a three-ounce cup as a means of avoiding rule applicability are attempting to circumvent the 6H rule…and reserves the right to bring enforcement actions against any person whose action equates to rule circumvention. ", One additional point of clarification offered by the EPA letter confirmed that "the 6H Rule does not negate other regulatory requirements (such as federal or local occupational health and safety requirements, local zoning codes or fire ordinances) that may prohibit or restrict spraying flammable solvents or coatings containing HAPs within or outside of a contained environment. Several collision repair painting and coating vendors have developed web resources related to the "6H auto body rule" and paint formulas that allow facilities to be exempt from the requirements. New Employees must be trained prior to working in a paint booth. The EPA’s federal office has issued a response to the Society of Collision Repair Specialists’ (SCRS) April 2011 letter requesting clarification on the 6H Rule. View the EPA’s official response, News: Cruise Postpones Release of Driverless Taxi Service, News: Cutting Edge Automotive Solutions Partners with Andretti Rallycross, OEMs: Ford, Volkswagen Expand Collaboration to Include Autonomous, Electric Vehicles, Uncategorized: CCAR Updates Website with More OSHA Alliance Resources, News: Ford, I-CAR Announce Expanded Training for HEVs and BEVs, A CLOSER LOOK AT GAS-CATALYTIC INFRARED CURING IN REFINISH, THE POWER LIES WITHIN THE PROBLEM SOLVERS: THE IMPORTANCE OF TECH REPS, Effective Marketing for Collision Repairers. Initial training for employees should have been conducted by January 10, 2011. CSC II Restricted. A Federal EPA regulation called the EPA Rule 40 CFR Part 63 subpart HHHHHH (EPA 6H Rule) came into effect in 2011 regarding the use of five heavy metals in spray applied primers and topcoats within the sign industry. Stay up to date with the latest BodyShop Business news. 3. A documented response regarding the exemption for coatings applied with a paint cup equal to or less than 3 fluid ounces, and clarification that the rule applies to the type of work being performed. The regulatory navigation tool can be used in conjunction with this list to determine if an autobody shop can petition for an exemption. Pat's Body Shop: Putting the Muscle in Collision Repair, BodyShop Business Names 2020 Executives of the Year, Clore Automotive Introduces Light-N-Carry LED Flood Light, VIDEO: The Evolution of Vehicle Technology, FCA Issues Position Statement on Opt OE Parts, Caliber Announces Executive Leadership Changes, Pat’s Body Shop: Putting the Muscle in Collision Repair, EPA Says It Will Hold Mobile Painters to Same 6H Rule Regulations As Body Shops, CIECA Webinar to Feature CIECA Founder Erick Bickett. Used and repeatedly filled to circumvent the rule 6H and 6X rules, exempt operations prohibit... 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