Proposed air quality rules affecting automotive refinishing that were released by the Environmental Protection Agency this fall are generally being viewed positively by the collision repair industry.
"We believe that the EPA has adequately met the necessary elements of three important pieces in the proposed regulation: equipment, training, and enforcement," said Bob Redding, Washington, D.C., representative for the Automotive Service Association (ASA).
Redding said he believes that many shops are already in compliance with the proposed rules but that the regulations will raise the bar for those not adequately protecting the environment.
"We know there are people out there painting who are not doing it in a spray booth with proper training, for example," Redding said. "We're hopeful this will lift them up and raise the industry standard."
What's required?
The proposed regulation is a result of the Clean Air Act of 1990, which requires the EPA to identify sources that emit one or more of the 188 listed toxic air pollutants. Specifically included in the regulation are stricter requirements for "area sources" engaged in paint stripping or various surface-coating operations, including autobody refinishing.
"Area sources" are defined as those that have the potential to emit less than 10 tons a year of a single toxic air pollutant or less than 25 tons a year of any combination of toxic air pollutants.
Area sources that would be affected by the rule will need to implement equipment and management practices to comply with the proposed standards, if they have not already done so. But the practices are designed to reduce overall toxic material consumption, which generally results in a savings to the business as well.
The proposed regulation places a number of requirements on collision repair shops. In terms of training, shops will be responsible for ensuring that all painters have completed training in the proper application of surface coatings. The training must cover specific items such as spray gun setup, surface prep, spray booth and filter maintenance, transfer efficiency, and environmental compliance. Painters must be certified within 60 days of hire and recertified every five years.
In terms of equipment, all painting of vehicles must be done in a spray booth (or, in the case of painting of some vehicle parts, a prep station) that meets the regulation's requirements. The booth, for example, must be fully enclosed with four complete walls and a full roof, and use a filter system fitted with polyester fiber or fiberglass filters (or the equivalent) that capture at least 98 percent of paint overspray. The booth must also be ventilated at negative pressure.
Prep stations must have a full roof, at least three complete walls or complete side curtains, and must be ventilated so that air is drawn into the booth.
ASA was pleased to see that the EPA included the spray-booth requirements, Redding said.
"The Pennsylvania state regulation, which was the first one we were real active on, did not include a spray booth on the equipment side, and we were really disappointed in that," he said. "Then the Ozone Transport Commission, a quasi-government group that covers states from Virginia all the way to Vermont, basically adopted the Pennsylvania regulation, so you had a bad model that people were adopting. So this is a real opportunity to make it right, and we're pleased with it."
The proposed regulation also requires that all spraying of coatings be done with a high-volume, low-pressure (HVLP) spray gun (or by some method with an equivalent transfer efficiency).
All spray gun cleaning must be done either with solvents that do not contain the hazardous air pollutants or within a fully enclosed spray gun cleaner. Hand cleaning of parts with solvent is permitted, but spraying solvent through the gun is prohibited.
The EPA estimates that the regulation will require about 5,000 shops to purchase an enclosed gun cleaner and that a similar number will have to install new spray booths.
Shops will have two years from the time the regulation is put into effect--which Redding believes will be by 2008--to comply with its requirements. Redding said that ASA also believes the regulation is enforceable, as compliance can be monitored and enforced either by state or regional air quality regulators.
ASA urges rules on "miniguns"
The EPA accepted comments on the proposed rule until mid-October, and Redding said ASA had heard from "a lot of shop owners saying they were writing letters of support."
Redding wrote the official letter from ASA officials to the EPA generally supporting the proposal, although pointing to two potential areas of concern. The first dealt with one exception to the spray booth requirement in the proposed regulation that allows priming of small areas or performing spot repairs with an air brush.
"Unfortunately, technology now provides 'miniature spray guns' that are being used in open areas," Redding wrote. "This allows air brush specialists and others to expand the area subject to automotive refinishing products. ASA requests the EPA to consider tightening the final regulation to ensure that any exception, if critically necessary, to the spray booth requirement exclude 'miniature spray guns' or similar technologies. Those persons or business entities using 'miniature spray guns' should be required to have a spray booth."
The proposed regulation also spells out the anticipated costs of compliance. The EPA's estimated cost for training, for example, is $1,000 per painter, which covers tuition costs and labor cost for 16 hours of training time. This cost could be offset, the EPA estimates, over five years through a 1 percent reduction in the amount of coatings sprayed. The EPA calculates that training and use of HVLP spray equipment should reduce material use sufficiently to offset any such initial investment. The regulation points to data from one study indicating that painters completing the spray technique training decreased the amount of coating sprayed by about 20 percent per job.
But in its letter of comment to the EPA, the ASA said it believed one of the agencies cost estimates was inaccurate. The EPA estimates that the annual cost recordkeeping and reporting by shops to comply with the regulation would be less than $100 per facility, a number ASA believes is too low.
ASA also reiterated to the EPA its belief that the most effective method for enforcing automotive refinishing regulations is controlling the paint product at "the point of purchase." Redding acknowledged, however, that any such "point of sale" regulations on who can purchase automotive refinish products is strongly opposed by paint distributors.
"So although not optimum, ASA believes the enforcement for this regulation, as proposed by the EPA, will be sufficient," he said. "The EPA spent a great deal of time researching this issue and visiting collision repair facilities. The agency also listened to what collision repairers had to say about regulating the use of these products."
Copies of the proposed regulation, as well a fact sheet about it and the ASA letter in support of the regulation, can be found at the ASA legislative Web site (www.TakingTheHill.org).
New requirements not so new in many areas
Collision repair shops in many parts of California and some other states will look at the EPA's proposed air quality requirements for body shops and think, "Been there. Done that."
Some states and air quality districts have long ago required the use of spraybooths, enclosed gun cleaners and HVLP spray equipment. Any such local or state air quality regulations will still apply when the new federal rules go into affect, and shops must always comply with the strictest rule in their area, whether local, state, or federal.
For California shops, for example, that means the pending deadlines for switching to waterborne basecoats remain in place. That deadline is next July 1 for the South Coast Air Quality Management District in the Los Angeles area. Similar requirements will go into effect in other Northern and Southern California air quality districts in 2009.
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