Ask the Expert Question-and-Answer Archive

by Ron Joseph

July, 2002

Regulations for Paint Mixing Rooms and Touchu

Q. We are located in India. Though we have a state of the art paint shop erected and commissioned by the reputed TAIKISHA ENGINEERING COMPANY, Japan, we have not established a formal paint kitchen.

Due to the exacting standards of paint quality required by discerning customers we do extensive paint touch up even for small defects. We are already JD Power Rating No. 1 for two consecutive years on quality.

We are implementing ISO 14001 Enviornmental Management System at our company and the issues of paint mixing without an enclosure in the paint shop and touch up outside the paint booth cropped up.

We request you to let us know if it is a regulatory issue in US and if so under what act. Even if it is not a regulatory issue in India right now there is a potential of getting implementing in the near future.

I look forward to your valuable advice on the same.

A. Thank you for your request. In the US the individual states are responsible for writing regulations, although is some instances the federal EPA takes on this responsibility. In the case of painting facilities, the volume of paint used on a daily, monthly or annual basis determines if a company is subject to it's state regulations. Also, it depends very much on where within a state the company is located. For instance, a company that is located in a rural community might not be regulated, whereas a company that is located in a large industrial city, such as Los Angeles will be regulated.

In addition, small companies (small paint users) are often exempt from the regulations, while those who use more paint are regulated. In summary, the need to meet regulations depends both on the location of the company within a state, and the volume of paint used per day, month or year. There are other issues that determine whether or not the company will be regulated, but that is outside the scope of this answer.

The regulations are not uniform across the US. However, in general, if a company is regulated by its state, then the company might need to apply for a permit to operate. For instance, mixing room attached to a painting facility might need to have a permit, because it is a source of VOC emissions into the air. (I use the word "might", because there are not hard and fast rules on this matter.)

In terms of fire regulations, I refer you to National Fire Protection Association Bulletin NFPA 33 - Standard for Spray Application Using Flammable or Combustible Materials.

This bulletin outlines all of the fire and safety issues that should be complied with, and NFPA works closely with the federal agency OSHA on these matters. Although I don't have a copy of the bulletin with me, I assume that a mixing room must have a fan to extract the solvent vapors so that their concentration do not pose a fire or explosion risk.