EPA & Techinal Tips | 6H Rule — Do YOUR paint arrestors meet the NEW EPA Regulations?

 

EPA & TECHNICAL TIPS: 6H Rule — Do YOUR paint arrestors meet the NEW EPA Regulations?

Filtration Requirements Under 40 CFR Part 63 Subpart HHHHHH
On January 9, 2009, the Environmental Protection Agency (EPA) published the final rule for 40 CFR Part 63 Subpart HHHHHH, National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operating at Area Sources, also known as 40 CFR Part 63 (6H). The rule applies to all motor vehicle and mobile equipment surface coating operations that paint with hazardous air pollutants (HAPs), including the collision repair industry.

40 CFR Part 63 (6H) created many new regulations ranging from the very broad (develop and document key operating practices) to the very specific (use only approved, high volume, low pressure (HVLP) spray guns and clean such spray guns in an enclosed cleaner or by disassembling gun parts and cleaning by hand). Recognizing both the complexity and questions these new regulations have generated, the EPA developed a website (http://www.epa.gov/collisionrepair/) to provide tools and resources to collision repair businesses, including sample notification forms and training checklists, as well as a copy of the final rule itself (http://www.epa.gov/ttn/atw/area/fr09ja08.pdf).

With respect to filtration, 40 CFR Part 63 (6H) outlines three basic and straight-forward requirements: (i) all coating operations must be conducted in a spray booth or prep station that is fully enclosed by a roof, floor and four walls or full side curtains, (ii) the spray booth or prep station must be ventilated at negative pressure so that air is drawn into rather than out of any openings in the booth walls or prep station curtains, and (iii) the spray booth or prep station must be fitted with exhaust filters demonstrated to achieve at least 98% filter capture efficiency of paint overspray in accordance with a prescribed testing method. Test records must be maintained on-site and demonstrate compliance with this minimum efficiency standard.

Recognizing the importance of both the regulatory test and the need for record keeping, Viskon-Aire reconfirmed 40 CFR Part 63 (6H) compliance in January 2010 of its entire line of exhaust filters / paint arrestors, both fiberglass (SG-15, 107X and XHD) and polyester (PS and Super PS). All Viskon-Aire exhaust filters / paint arrestors passed the 98% minimum efficiency test. Test reports are available on Viskon-Aire’s website(http://viskonaire.com/pages.php?pageid=6).

While using 98%+ efficient paint arrestors is necessary to comply with 40 CFR Part 63 (6H), compliance is also, very simply, a good business practice. Using an inferior paint arrestor will allow overspray to build up in pits, exhaust ducts and fans creating ever greater stress on mechanical components. So while an inferior paint arrestor lessens the need to perform the difficult, dirty and time consuming process of changing exhaust filters, this is merely because insufficient overspray is being capture. As a result, using an inferior paint arrestor will, over time, lead to significantly higher operating costs because mechanical components are substantially more expensive to replace than exhaust filters, not to mention the months and/or years that may be reduced from the operating life of a spray booth or prep station. On the other hand, using a high quality paint arrestor will require more filter changes, probably as frequently as once every two weeks, but at least once a month. This is simply because the exhaust filter is doing its job – capturing the overspray. Consequently, when using high quality, 98%+ capture efficient paint arrestors, it is critical that a change-out routine be developed. Clogged and poorly maintained paint arrestors will not allow overspray to exit the spray booth or prep station, resulting in overspray recirculation. This overspray recirculation will lead to ruined paint jobs as well as contamination of other filters within the spray booth or prep station, and those other filters (ceiling filters in particular) are much more costly to replace than paint arrestors / exhaust filters.

With the introduction of 40 CFR Part 63 (6H) filtration requirements have increased in importance. However, proper filter selection and maintenance, regardless of any regulation, is critically important and, unfortunately, frequently overlooked. As the old FRAM oil filter saying goes, "You can pay me now, or pay me (much more) later." That same adage applies to your spray booth and prep station filters.

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