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EPA AutoRefinisher regs interpretated

Discussion in 'The Hokey Ass Message Board' started by BigChief, Dec 21, 2007.

  1. BigChief
    Joined: Jan 14, 2003
    Posts: 2,084

    BigChief
    Member

    One of the hats I get to wear here at GM/Trison that I’m a Certified Chemical Hygiene Officer. I sometimes have to interpret these laws, bills, rules and regs and see how they affect the laboratories and operations here where I work.

    This is my interpretation of the bill. I've got plenty of experience looking and reading these things but what I'm explaining here may not be the end-all information you'll need. There are very likely local issues and other aspects of the requirements listed in other bills. I'm also sure some of the professional painters/shop owners here on the HAMB can also add information to this as well. BUT, here is the main reg and what I'm getting out of it......Enjoy.

    First off, this bill/law isn't about smog, the environmental issues in China or “the Man” out to get us. It is not about the trees, the gr*** or the birds…..this is about keeping some pretty nasty chemicals out of your body, out of your neighbors bodies and out of your kids brains (they seem to put enough stuff there by themselves these days anyway). The regs published in this bill are nothing new to large industry as they’ve had to do this (and much more) for many years. The chemicals that are being targeted (methylene chloride, heavy metals and various solvents) cause cancer and nervous system damage. The damage is demonstrated and proven, this isn’t a myth - they will catch up with you. These compounds are not user friendly and for a very long time the automotive refinisher industry has been fortunate enough to have the EPA turn a blind eye to it for since they knew (and the refinishers lobbied as such) that this was going to be a big change and was going to affect many shops, especially the small ones. This was an impending situation (doom?) that has been a long time in coming.

    I also do my own bodywork and painting. My dad had a resto shop for 25 years, I’ve worked in other shops since then and I do my work at a friends shop and a garage I rent on a farm down the road from where I live. Luckily I’m in an area that is zoned agricultural/commercial so using paints in bulk isn’t going to get me into any trouble as long as I “take care of business” and follow the rules. If you are shooting cars in your garage at home and it’s zoned residential then you are on your own with the zoning officers. These regs will most likely give the local zoning officers more ‘bite’ if/when the subject of you painting cars at your home in residential areas comes up.

    Many small shops and individual folks who are serious about doing their own work already have most of the training and tools they need to meet these ‘new’ requirements anyway.

    Here are the requirements in a nutshell:

    Training. All paint companies offer training on the proper handling, use and disposal of their products. From what I can tell, this is all you need to take to become certified in regard to this EPA requirement. They cover all the required areas the EPA wants you to be educated on during these courses. If your buying paint from your local supplier chances are you’ll be able to attend the cl*** at a local bodyshop or paint supply store….sometimes for free or a small fee. Believe it or not they DO want to sell you their paints and materials. You could also check out your local community college or BOCES/vocational school bodyshops for cl***es and courses. Certification is required every five years.

    Guns. No more conventional guns. You’ll need to buy an HPLV gun and keep the owners manual and/or factory literature for it in a filing cabinet. Roll-on high build primers are looking more and more inviting........

    Gun Cleaning. No more running solvent through the gun and into the atmosphere during the cleaning process. You’ll need to purchase a gun cleaning cabinet. If you can’t afford to buy a gun cleaning cabinet (who can, they’re darn expensive) then you’ll need to dis***emble the gun and clean it by hand.

    Booths. You’ll need to shoot your cars in a spray "booth". The exhaust fan needs to be able to pull the air out of the booth and through paint filters made for spray paint booths. These filters are not that expensive and it is not that difficult to turn your own garage into a “compliant booth” with some creativity and the right materials. An $80,000 booth might make your paint jobs cleaner/better but you don’t need an expensive booth to be EPA compliant. All you need to do is prove the exhaust PULLS all the air out of the booth (with appropriate air turn-over) and that the exhaust is being filtered through compliant paint filters. Someday down the road they may also require you to have the booth tested and to register the "booth". Again, not that difficult to do or comply with.

    Methylene chloride and paint/solvent waste. You will need to track the amount of MeCl and solvents/paints you are using. Basically write it all down and keep your receipts. You should do this for all of your shop chemicals. The process “the Man” like to call this is the “Cradle to Grave” tracking of hazardous materials. If you really want to snooze and learn more about this process look up RCRA (the Resource Conservation and Recovery Act). You’ll also have to dispose of the materials properly. If its smaller amounts you might be able to take it to your local town hazardous materials collection site (most towns have a designated place/area to take these materials from home owners). It may be a monthly, quarterly or annual event depending on the town. If you are making more than just a little waste you’ll probably have to hire a place like Safety Clean to come take a barrel of materials from time to time. It is not killer expensive and its much better than putting the stuff in a landfill with your household trash. If your using over 150 gallons of MeCl annually then it’s a whole new ball of wax that I’m sure we don’t need to cover here.

    So basically......Get your training. You probably could use it anyway. Go get an HPLV gun and learn to use it (I like them about as much as a condom but I’ve got to switch too). Clean your paint gun responsibly. Fix up your “booth” with the right filters. Keep an eye on your chemicals and dispose of them properly….and be prepared to prove that your doing so.

    This is not brain surgery. Yes, it ****s but its also being responsible in light of how these nasty materials can hurt you and the rest of us.

    Happy Painting!

    -Bigchief.
     
  2. TagMan
    Joined: Dec 12, 2002
    Posts: 6,364

    TagMan
    ALLIANCE MEMBER

    I knew you were a bright guy, but I have a whole new respect for you now!! Thanks for the intelligent, well written, easy to understand explanation.
     
  3. Don Moyer
    Joined: Jun 2, 2005
    Posts: 3,882

    Don Moyer
    Member

    thanks for putting that into plain english, but I still think he is out to get me. The comparison of an HVLP and a condom is funny, and right on! Now I gotta go out and change my exhaust fan set up!
     
  4. DrJ
    Joined: Mar 3, 2001
    Posts: 9,419

    DrJ
    Member

    But I can buy gallons of **** grade Lacquer thinner at a Home Big Box store, and paint my whole house inside and out with Lacquer or oil base Enamel, if I can find it, just not a car... :rolleyes:

    Follow the money!$!
     
  5. Good post, thanks for the effort!
     
  6. It is posts like this, that make this place so Great.
    Thanks.
    HemiDeuce.
     
  7. BigChief
    Joined: Jan 14, 2003
    Posts: 2,084

    BigChief
    Member

    Glad I was able to contribute.
     
  8. 392_hemi
    Joined: Jun 16, 2004
    Posts: 1,737

    392_hemi
    Member

    I posted a lot of this info from a SEMA press release about a month or two ago and not many people noticed. About 99% of the time I am against government regulation, but in this case, it makes a lot of sense. Modern automotive finishes contain some really nasty chemicals, and anyone trying to save some money and or make a buck doing paint jobs without the proper equipment is going to be very sorry down the road when they have to deal with the health consequences, which are very real.
     
  9. SinisterCustom
    Joined: Feb 18, 2004
    Posts: 8,277

    SinisterCustom
    Member

    Great post....thanks for the breakdown of it all......
    I learned with HVLP's......so I love 'em......
    I'm trying to get my own custom painting business going.....just small stuff, bikes, etc...This info is a BIG help!
    Is there a point at which a paint "booth" is not needed? Say for artists/airbrushing????
     
  10. 392_hemi
    Joined: Jun 16, 2004
    Posts: 1,737

    392_hemi
    Member

    It doesn't take a lot of this stuff to mess you up, so even airbrushing and small parts I wouldn't do without proper respirator, etc. at a minimum. Part of the problem is some of these chemical ac***ulate in the body, so continued exposure to even small quan***ies can be very damaging.
     
  11. Jalopy Jim
    Joined: Aug 3, 2005
    Posts: 1,867

    Jalopy Jim
    Member

    In my Furniture business I haave just switched from lacqueer to polyurathane finishes. The lacqueer thinned was starting to get to me. Even wearing a resperator and using a down draft finishing room. So I would not doubt that Automotive finishes are a lot tougher on your body.
    I will be painting my 54 in 2008 and have concern for my health. I probably buy a paint suit.
     
  12. Dads-53
    Joined: Sep 8, 2006
    Posts: 171

    Dads-53
    Member

    What BigChief is telling you guys is true. I was a paint rep. for BASF, (RM, Glasurit and Limco) for 30 years and you can not be to carefull. Wear gloves cleaning up equiptment resporators and something over your arms when painting. It also goes through your skin. I have been painting for 45 years and wish I would have been more aware of it the first 20 but we didn't know then what we know now. Your charcoal respator should be kept in air tight conatiner and only used about 40 hours. Guys I have helped bury some good customers over the years because of not being carful enough until it was to late.
    Take care Don
     
  13. pimpin paint
    Joined: May 31, 2005
    Posts: 4,937

    pimpin paint
    Member
    from so cal

    Hey DrJ,

    BINGO! BINGO! BINGO!.....we have a winner!

    I'm told that lacquer thinner, linseed oil and any other paint product
    that emits VOCs days are numbered, here in SoCal. Conventional
    spary guns were outlawed in the 90s out here. I can no longer buy
    alkyd enamel in five gallon cans as spraying that much material in
    one day will exceed maxium amount of VOCs the SS Waffen a.k.a.
    South Coast Air Quality Management District will permit.

    And yes, I'm a paint outlaw, and will burn in Hell with the rest of
    my friends.

    S****ey Devils C.C.

    Happy Xmas
    Happy Whatever
     
  14. BigChief
    Joined: Jan 14, 2003
    Posts: 2,084

    BigChief
    Member

    Its always a good idea to have good ventilation. For shooting components the bill says a three sided room that has a negative air flow (drawing air out of the room/booth/hood) is acceptable. Air brushes put out very small volumes and I would imagine that you could get away with a 'nuisance' or 'comfort' type ventilation in that case.....a fan drawing fumes away from you, etc. ....and, of course, a respirator.

    -Bigchief.
     
  15. This is just a way to put everyone but the largest and most expensive paint shops out of the paint business. And to hell with hobbyists. The big paint shops are still going to be spraying paint and their solvent fumes are still going to be blowing into the air, it's just that now the ordinary Joe will not be able to participate. They think we're all too stupid to read the product bulletins and do anything safely.

    I guess all those painters that work at Maaco or Earl Scheib are going to be super genius scientists once they've gone through a day of training. Us hobbyists could never possibly have enough brains to figure out how to put a respirator on or which direction to spray the gun (toward the car, or toward our face?). And cleaning the gun -- ooohhhh, that's so terribly complicated. We could never possibly figure out how to clean a gun. Do we lick it with our tongue? And we just love to waste lacquer thinner, so we probably use 8 or 9 gallons of lacquer thinner to clean a 2 oz touch up gun. And all of us hobbyists love the smell of paint so we never wear a respirator, and we love cracked chapped hands, so we would never put gloves on. We better have the government step in to hold our hands and show us these miracles of modern science forcefully. Here little hobbyist dude, this is called a rubber glove. It goes onto your hand. Your thumb goes into the shorter hole.

    Gimme a break! I don't know anyone stupid enough to spray modern paints without a respirator, and practically everyone now uses an HVLP gun because they save paint. Do they really need to make even more stringent rules for this stuff to "save us" from our own stupidity? Rules that are so stiff that it just wipes out the entire hobby? Is that what we want? For the government to hold our hands every step of the way like we're little children and take away any sense of freedom we might have ever had? While they're at it, why don't we make stoves illegal because you might get an ouchie on your finger. And paper illegal because you might get a paper cut. Oooohhh, the chemicals are "really nasty", so all chemicals must be banned to everyone. Gasoline is "really nasty" too. Let's ban it. And Tequila is pretty nasty too. Let's ban that or make you go through specialized booze training. Rat poison is "pretty nasty" too -- better ban it.

    I heard on the news the other day that the quack mayor of San Francisco wants to make a new tax on soda pop. He claims it's because soda makes people fat and unhealthy, and they need a tax on it to help pay for all the fat people in hospitals. This country is just going whacko with this meddling "nanny state" mentality. I do not want the government micromanaging my entire existence. And I just can't understand why there are so many people who are willing to go along with this **** and lose all freedom to make sure that nobody can ever do anything that might possibly harm them.

    Convertibles and drive through restaurants will be the next thing to be made illegal to save us from the deadly effects of sunlight and cheeseburgers.

    Everybody knows that auto paint is toxic. The can says so and has plenty of warnings. The guy selling the paint always warns everyone to wear a respirator. What changed that suddenly nobody can be trusted to work with paint anymore? Nothing! Just more ******* intrusion into our lives and taking away of our freedom by the government.
     
  16. thanks for breakin down the legalese so a even a cajun can understand it!
     
  17. BTTT, this is the thread that most ignored last week. Great info, read up.
     
  18. SinisterCustom
    Joined: Feb 18, 2004
    Posts: 8,277

    SinisterCustom
    Member

    Thanks Chief.....yeah, I always spray in a ventilated area, with a small fan drawing fumes away and usually wear a respirator......with exception to Createx and Auto Air on small jobs......

    I live out in the boonies, but I still set up my garage with makeshift filters when painting big jobs......not only keeps the paint from going out, keeps the BUGS from getting in!:D
     
  19. Jalopy Joker
    Joined: Sep 3, 2006
    Posts: 34,082

    Jalopy Joker
    Member

    My hat is off to Big Chief for trying to clarify things for us common folk. But, I salute Rusty Bolts for trying to clarify how our world is being turned upside down by Big Brother. A big problem is that there are a lot of fools out there that have no common sense whatsoever. They always go to the extreme and help reek havoc on the rest of us.
     
  20. INXS
    Joined: Dec 3, 2005
    Posts: 348

    INXS
    Member

    I just got back from my Dupont jobber and they know nothing about this. Of course it's a Carquest store that sells paint and related supplies and the parts sales seem to take priority. The manager offered to look into it for me as he'll be seeing the Dupont rep on Thursday.

    I read over the EPA link last night. Thanks to Big Chief for his interpretation of all the legal speak. I'm in the process of finishing my new paint room and will need to make sure it will comply with the filtration requirements.

    I guess what's still unclear to me is exactly what this means to someone who has a couple of project cars in process in a home hobby shop and might do one or two complete paint jobs in a year. If they are only doing work on vehicles that are their own and do no customer work is there an exemption?
     
  21. Retrorod
    Joined: Jan 25, 2006
    Posts: 2,034

    Retrorod
    Member

    We have been living with this stuff out here in Kalifornia for quite some time. I stopped painting at home some years ago and the only thing I might do from time to time is a little airbrush work with water-base color. When I think back 20 years when I shot completes all the time in my garage with makeshift exhaust fans, minimal masks and no regard for my own well-being.......it kinda worries me now, will I suffer any long term effects??? I hope not.

    Thanks Chief!! Great work.
     
  22. After re-reading this I feel good knowing that I am pretty much in compliance already!

    A side note, a pal had a pissy neighbor here that called the EPA on him. Local EPA guy came over and asked a couple questions, when it was clear that it was a personal hobby shop he had no issues (nosy claimed he was running a bodyshop) with my pal. In fact he gave an impromtu lesson on disposing of shop waste etc............guy actually was very helpfull and rahter pissed the neighbor drug him out there!
     
  23. BigChief
    Joined: Jan 14, 2003
    Posts: 2,084

    BigChief
    Member

    I didn't get a chance to go through all the regs....BUT, I imagine that the folks with signs out front and cars sitting around will get the first/most attention with the small hobby folks slipping through the cracks until they come to the attention of the local zoning board and/or pissy neighbors. The way they'll most effectively sqeeze the hobby folks is probably through the restricted sale of the materials......"LET ME SEE YOUR PAPERS!!!" comes to mind. In any case its not a bad idea to have your receipts on hand, records up to date and the ability to demonstrate that your responsibly disposing of the materials and filtering your booth/hood space in case Da MAN shows up asking questions.

    -Bigchief.
     
  24. arkiehotrods
    Joined: Mar 9, 2006
    Posts: 6,802

    arkiehotrods
    Member

    There's a new thread on this already, but SEMA reports that the EPA worked with them to exempt hobbyists who paint up to two cars per year from the regulations. You can check it out at www.sema.org

    This is a major change from what has been reported lately, thanks to the efforts of SEMA and SAN to protect our hobby.
     
  25. 392_hemi
    Joined: Jun 16, 2004
    Posts: 1,737

    392_hemi
    Member

    Here's the post from earlier today.

    EPA INCLUDES SEMA RECOMMENDATIONS IN NEW AUTOBODY PAINTING RULE

    New Regulation Protects Hobbyists and Environment

    The U.S. Environmental Protection Agency (EPA) has issued a rule to regulate paint stripping operations that use methylene chloride and surface coating, and auto body refinishing operations that use paints containing hazardous metal compounds. The rule targets hazardous air pollutants (HAP) which the agency believes may cause cancer or other health disorders. The rule applies to most coating activities that emit HAP but, notably, the EPA followed SEMA’s recommendation and exempted low-volume operations such as when hobbyists restore or customize one or two cars. The EPA incorporated a number of other SEMA suggestions to make the rule as friendly as possible for companies that have spray-coating operations.

    The EPA rule establishes “best practices” (spray booth, spray gun cleaning, etc.) for minimizing HAP emissions during surface coating operations. All shops are effectively required to have a filtered spray booth or prep station and use high-volume low-pressure (HVLP) or equivalent spray equipment. Spray guns are required to be cleaned manually or with an enclosed spray gun washer. The EPA believes many shops have already implemented these best practices.

    According to the EPA, those facilities that have not yet done so could recover the cost of new equipment through a more efficient use of labor and materials. The EPA notes that the Occupational Safety and Health Administration (OSHA) already requires spray finishing operations to be performed in a booth or similar enclosure (although the new EPA rule could necessitate the use of more efficient filters than currently used).

    Owners and operators are required to provide training for their painters on how to properly spray surface coatings and clean equipment. The EPA has established minimum criteria required for in-house training, similar to existing programs offered by I-CAR (The Inter-Industry Conference on Auto Collision Repair ), STAR (the Spray Technique ****ysis and Research program), or other certification organizations. Painters would be required to complete refresher training and be re-certified every five years.

    Existing operations have up to three years to purchase equipment and complete the initial training of employees. As recommended by SEMA, the EPA will rely on self-certification for training programs. Nevertheless, companies subject to the rule must send the EPA a one-time notification form stating that they are in compliance with the rule or will be within the allotted three years. Companies will have two years to submit the notification form which will contain contact information and a brief description of the operation: number of spray booths, average number of employed painters, etc. (SEMA will publish a sample notification form and EPA contact information when it becomes available). Companies will be required to maintain in-house records verifying painter training/certification, filter replacement, a plan to control paint stripping chemicals, etc.

    SEMA worked closely with a number of member companies, other trade ***ociations and the EPA to craft a rule that should have minimal impact on the hobbyist community. As a result, the regulation does not apply to paint stripping and surface coating performed by individuals as part of a hobby, or for maintenance of their personal vehicles so long as those activities do not exceed two motor vehicles (or the equivalent in pieces) per year.

    Additionally, the rule does not apply to painting done with an airbrush or hand-held, non-refillable aerosol cans. As noted above, paint training is self-certified. The EPA did not pursue an earlier proposal that would have required individuals to produce a training certificate in order to buy paints and coatings. The rule is expected to take effect in January 2008, but as noted most businesses will have up to three years to comply with its various provisions.
     
  26. INXS
    Joined: Dec 3, 2005
    Posts: 348

    INXS
    Member

    Well this is good news for the hobby and another reason to support the efforts of SEMA.

    From what I read in the proposal, and from Big Chiefs deciphering it all for us, of all the proposed requirements nothing in and of itself seemed to be too unreasonable to expect of a paint facility as far as solvent handling, and gun cleaning. Proper filtration of paint mists exiting the booth is pretty easily accomplshed with the right filters. Sounds like most of this can be accomplished at not much cost and would be just plain sound practices even for the hobby guys. The proposed training requirements if affordable would benefit anyone that sprays paint.

    No one likes to have their hand forced to do things especially when we perceive the rules to be created and slipped through the cracks to become law by some bureaucracy. But I doubt it will get better as the years go on. It is good to know that sound reasoning came through in this case though.

    Thanks for interpreting this and keeping us updated, Big Chief.
     
  27. Rusty Kustoms
    Joined: Feb 5, 2006
    Posts: 238

    Rusty Kustoms
    Member

    This is great info, thanks!! I always wear a respirator and gloves when anywhere near paint, I know too many "old school" painters that cant hardly walk anymore from years of painting without protection. There are a lot of guys that lost their careers because of the effects of these chemicals, just cause it doesnt affect you today doesnt mean it wont affect you in a few years.
     
  28. CamaroKid
    Joined: Jan 1, 2008
    Posts: 132

    CamaroKid
    BANNED
    from Texas

    Sad thing is the Iso's. that kill us are the ones that humans can't smell . The bloodborn pathogens that we absorb in our skin and eyes , never come out ! Hell , I'm screwed ! At least I won't ever have to do another "FLAME JOB" if I go to Hell ?
     
  29. INXS
    Joined: Dec 3, 2005
    Posts: 348

    INXS
    Member


    Camaro Kid you're absolutely right on the point about absorption through the skin and eyes. Especially the eyes! Think about what isocyanates like- heat and moisture. Eyes and lungs.
    I've always been diligent about wearing a charcoal respirator and leave the room between coats. Never go into the booth without it on. I'll leave the exhaust fan on low speed overnight to keep solvents moving away from the finish and open the overhead door the next day to let in fresh air while unmasking etc.

    I never gave much thought about my eyes though. Man I can remember spraying some of Martin Senour's Ureglo (which was like Imron) and my eyes would just flood water. I'd have to stop to wipe my eyes to finish spraying a coat and they'd bother for a few days after.

    Today my lung capacity is bad. I've just been to the Dr.s before Christmas for a physical. Haven't felt good for awhile. Real tired beat up feeling, and my wife finally convinced me to go. They did a test where you blow into a tube and it measures capacity or whatever. I could hardly get the machine to get a good reading to calibrate. Dr. wants me back in for more tests. I've never smoked 'cept maybe a few in Jr. High. JUst never liked it.

    My advice to anyone spraying paint is get a full face or hood type suppled fresh air system. Wear a welding mask when welding and grinding. Don't think that a two catridge mask is good enough to spray paint. It really does nothing for isocyanates.
     
  30. Jalopy Joker
    Joined: Sep 3, 2006
    Posts: 34,082

    Jalopy Joker
    Member

    See other thread "Another Reason To Support SEMA' Then click on site listed to join SAN
     

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