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Environmental Compliance Assistance for Auto Body Repair Shops This resource provides environmental regulatory information for auto body shops. The primary target audience is new businesses which must be in compliance upon startup. This information will also be beneficial to employees at existing shops that are newly assigned to an environmental compliance role. This resource covers air, waste, and wastewater regulations, including both federal and state rules.
Auto body shops repair, repaint, and customize cars, trucks, and other vehicles. Their activities include sanding, cleaning, paint stripping and painting, all of which may release pollutants into the air. Several important aspects of air pollution rules are discussed here as they pertain to auto body shops. Autobody Rule. Auto body shops are regulated by a federal regulation that is often referred to as the Autobody Rule or 6H (40 CFR 63, Subpart HHHHHH) The regulation sets emission standards for certain hazardous air pollutants (HAPs) resulting from overspray during surface coating operations, specifically:
The requirements for compliance with 6H are found on this PCRC Fact Sheet. If none of the coatings used at your facility contain any of the target HAPs listed above, starting in 2023, the 6H rule allows companies to opt out of the standards by submitting a notification to EPA or your state agency (check with your state agency on the notification process.). Records relating to your processes must be kept as a backup to support the notification, but those records don't need to be sent to a state agency/EPA. In determining whether you spray target HAP containing coatings, do not include coatings applied using handheld aerosol cans, or spray guns with a paint cup capacity of 3 fluid ounces or less. These are not considered spray-applied coatings under the 6H rule. Paint manufacturers have reformulated most of their paint products to eliminate content of target HAPs. Check with your paint supplier. Permits. Air permits, largely issued by state agencies, are needed for most industrial operations that emit air pollutants. Examples of equipment that may need an air permit include paint booths, solvent parts washers, and abrasive grinding and blasting operations. However, not all this equipment automatically needs a permit; it depends on the size of the equipment and the amount and type of pollutants (emissions) being released. Also, permitting rules vary from state to state. For example, in many states auto body shops are eligible for "permits by rule" or "registration permits." Check with your state agency. Paints. Paints contain volatile organic compounds (VOCs) which are regulated because they photochemically react in the atmosphere to produce ozone, a component of smog. Years ago, the Clean Air Act focused mainly on reducing VOC emissions from sources such as painting operations by requiring controls on these sources. A revised federal strategy for controlling VOCs from painting operations was implemented in 1998 when EPA published the Automobile Refinish Coatings: National Volatile Organic Compound Emission Standards. This rule regulates the paints used in auto body shops rather than the painting processes. Basically, EPA made it illegal to manufacture or import paints for auto body shops that contain high VOC levels. Since EPA's regulation does not affect the application of automobile refinish coatings, body shops are not directly affected by the regulation's requirements. For more information on air regulations, refer to PCRC's Plain Language Guide to Air Emissions. Any business generating waste must evaluate them to determine if they are hazardous wastes under Federal EPA and state regulations. There are specific rules on how hazardous waste needs to be handled at your shop. There are also record-keeping requirements. Common wastes generated by auto body and auto service shops include:
Some of these may be hazardous wastes mainly because they are ignitable, corrosive or contain high enough concentrations of heavy metals such as lead, cadmium, or chromium. All hazardous waste must be sent off site to a permitted hazardous waste disposal facility and cannot be thrown in the dumpster. PCRC has developed a Plain Language Guide to Hazardous Waste Management that focuses on the federal rules. PCRC also maintains Hazardous Waste State Resources that links you to state agencies, state regulations, state contacts and compliance assistance resources. Process wastewater (as opposed to sanitary wastewater from bathrooms and wash facilities) is frequently generated from cleaning, phosphating and other surface preparation steps associated with coating operations. Also, many paint booths generate wastewater. If your coating operation discharges process wastewater to a Publicly Owned Treatment Works (POTW), then you have specific responsibilities that are defined in the Clean Water Act and its associated regulations. Existing coating facilities that discharge wastewater should already comply with these regulations. New sources must comply with these regulations before they begin discharging wastewater from manufacturing operations. In most locations, your facility will need to obtain a wastewater discharge permit from a city or county agency. Many states have posted regulatory, policy or guidance information on their websites for auto body shops.
Please email us if you are aware of applicable information for your state not listed here and we will update the list accordingly. Other Compliance Assistance Resources US EPA: Paint Stripping and Miscellaneous Surface Coating Operations: National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources (6H). Background information, links to the regulations and fact sheet. US EPA: Collision Repair Campaign. The Collision Repair Campaign is a voluntary effort aimed at reducing exposure to toxic air emissions from collision repair shops. The Campaign helps shops work toward compliance with EPA's Auto Body Rule. US EPA: Automotive Repair and Auto Body. Pollution prevention (P2) and compliance assistance. CCAR: Stepping Through EPA Regulations for Auto Body Painting. Compliance assistance for 6H rule. NSBEAP: Auto Body. Compliance assistance. |