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Spray-Painting: When Compliance Counts

June 4, 2013

If you own or operate a business that involves paint stripping or surface coating, you may want to check whether or not your business complies with the current Area Source rules for hazardous pollutants. Ensuring compliance will not only protect your business from worker health casualties and potential lawsuits, but also will save your business from wastefully spraying profits and pollutants into the air.

We at PPRC have spent the last six years helping businesses realize that compliance does not automatically mean cuts in profits. We have helped dozens of businesses comply with Area Source spray efficiency regulations while also saving substantial costs in materials, time, and poor worker health.

Over five years have passed since the EPA enacted (take a big breath) the 40CFR63 Subpart HHHHHH of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. Known as 6H, or “The Paint Rule,” the law aimed to reduce emissions of five hazardous heavy metal air pollutants (HAPs) commonly found in automotive paints, primers, and coatings. The rule applies to any industry, shop, or small business that sprays once per year with coatings containing any of these HAPs:

  • Lead (Pb), (greater or equal to 0.1 percent)
  • Manganese (Mn), (greater or equal to 1.0 percent)
  • Nickel (Ni), (greater or equal to 0.1 percent)
  • Cadmium (Cd), (greater or equal to 0.1 percent)
  • Chromium (Cr), (greater or equal to 0.1 percent)

The law required compliance by 2011. But many small auto-body shops and other spray-painting businesses still operate without proper equipment or technical training. We have worked with some industries that meet part, but not all, of the requirements. And we have worked with others that did not know they were supposed to be in compliance. The positive response to our training sessions suggests that many businesses in our region are not taking advantage of the opportunity to improve the efficiency and safety of their spraying operations.

The Spray Technique Analysis and Research (STAR®) program was developed by the Iowa Waste Reduction Center (IWRC) at the University of Northern Iowa to improve the overall efficiency of manual spray coating operations by enhancing the techniques of spray technicians. You can read more about the benefits of the STAR training program on our website, or via California.gov’s STAR Training Overview.

Case studies suggest the financial benefits of Spray Technique Analysis and Research (STAR®) and NESHAP trainings. For example, the Woodfold Manufacturing Inc., in Forest Grove, Oregon, applied the STAR program to its shutter painting line in 2007. PPRC helped track the program’s results. The company banked over $34,000 in annual cost-savings from improved transfer efficiency, and over $44,000 in overall savings per year. PPRC estimates that our 2011 STAR program, which trained 240 painters, saved businesses over $ 3,000,000, while reducing 99,500 pounds of air emissions.


How to check if your business is in compliance?

If your business spray-paints any metal or plastic parts, you may be subject to NESHAP rules. We suggest taking a look at a recent Material Safety Data Sheet (MSDS) to see whether or not your business uses paints with any of the heavy metals subject to regulation. Look at Section 2 of the document to see information on the composition of the paint’s ingredients. It should look like this:



If your MSDS shows levels of Pb, Cd, Ni, Cr, or Mn – including compounds containing these metals – then you have two legitimate options. You can work with your paint supplier to procure paint that doesn’t include these toxic metals. Or, you can get a spray-painting efficiency training that satisfies the EPA requirements. We’re confident that the latter option will not only prove less expensive, but will save money while protecting worker and environmental health. Your annual savings in material and health costs will far outweigh the costs of the STAR program.

By Cyrus Philbrick (Communications Manager) and Ken Grimm (Industrial Outreach Coordinator)


Ken Grimm, PPRC’s Industry Outreach lead, has completed the IWRC’s Train-the-Trainer course in addition to compiling nearly 20 years of industrial and automotive paint experience. Ken has provided train-the-trainer courses to more than two dozen Community and Technical Colleges in the Pacific Northwest, as well as training to more than 100 collision repair shops and industrial facilities.

To inquire about training dates and costs, please contact the project manager, Ken Grimm, at (206) 352-2050 or kgrimm@pprc.org

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