EPA refinish regs
Don't know if this has been posted here so I figured I would let you guys know.
Environmental Protection Agency officials are continuing their fact-finding mission this week as they march toward new regulations aimed at cutting emissions from the refinish process in collision repair facilities.
EPA Environmental Protection Specialist Kim Teal outlined to Collision Industry Conference (CIC) attendees her agency’s process for developing the new rules impacting the refinish market. “The rule will impact everyone, no matter how much you use,” Teal told the audience at the CIC meeting Tuesday in Mandalay Bay.
Teal and her colleagues have been busy visiting shops and gathering data as they prepare to write a proposed rule by 2007. Full implementation of the rule is targeted for August 2011.
Feedback, thus far, has helped the EPA identify a frustrated base of shop owners who are eager to put an end to unsafe and environmentally damaging painting practices performed by some shops and do-it-yourself mechanics.
“Primarily they want a level playing field,” said Teal. “They’re getting tired of having to comply with state and local regulations when there is a shop around the corner that doesn’t have to do anything. This rule will [take care of that].”
And it’s not just shops clamoring for change. Community groups have become incredibly active in their attempts to stop their neighbors from spraying paint at home in their garages at night, and to put an end to bad practices by certain businesses. “No one right now has a way to shut those bad shops or people down. That’s what this rule is—a way to shut them down,” she said.
Another component of the developing rule is a restriction on the “sale and use” of automotive paint products. Shops will have to meet certain certification criteria giving them the green light to spray paint. The rule will attempt to restrict sales of paint to people who are not certified users. “These are the types of things that I need your feedback on,” said Teal.
During her staff’s data gathering, Teal said shop owners have urged the EPA to tighten the language to include “use” restrictions as well as “sales” restrictions. The intent is to limit the sale of products to certified users, who then turn those products over to uncertified people.
The Automotive Service Association (ASA) and National Automobile Dealers Association (NADA) recently wrote Teal supporting regulations that would control the sale and use of automotive refinishing products.
Although the final language is far from settled, the national rule will supercede any state rules shops face related to refinish process compliance. However, in states such as California, where automotive refinish regulations match or exceed the EPA’s final language, Teal does not foresee a need for shops to jump through additional hoops to become certified to be compliant with the national rule.
Here is a thing that a guy over on the P2 forum sent the EPA and there response
Regarding the new auto body refinishing area source rule. What impact
would this have on a home hobbyist such as myself that currently
restores 0-2 classic cars in a typical year? Will a home hobbyist be
allowed to purchase paint supplies? I live in a rural area with very few
homes near me and have invested well over $10,000 in just paint related
equipment in order to do restoration work on my own cars as well as
assist friends. I use only hvlp and compliant gravity feed guns and use
a supplied air respirator. My shop is setup with intake filters,
explosion proof fan and a plenum fitted with 8 20"x20" paint filters. I
don't fish, hunt, watch sports, etc. I play with cars in my own garage.
I recently purchased 7 acres of land with the intention of building a
new house and much bigger shop. My plans were to install an etl listed
paint booth in the new building. The reason for purchasing a parcel of
land that size was so I could continue enjoying my hobby in a new home
with respect for my neighbors. If the new regulations are intended to
stop me from enjoying my hobby this land and shop are worthless to me. I
may as well move to the city. It would be helpful to know the intent of
the new ruling and the effects it will have on someone like myself
before I waste any more money on something that in the future could be
made illegal. The farmers around here spray peanut trailers and such
under shelters all the time. Will this be regulated? Lots of guys in my
area are very passionate about their car hobby and I would hope that the
new regulations would take the little people like me into consideration.
I know that there are guys in the middle of the city trying to paint a
car in their driveway with little concern for their surroundings. I am
not that guy. I am willing to spend the money on a new booth, gun
washer, mixing room, whatever in order to continue enjoying this hobby.
I would be very disappointed if you mandate that only businesses be
allowed to buy paint (not the case now). I have no problem with having
say a certification number issued to me after completing a test (or
having a shop evaluation done ) to insure that I am educated in being
compliant. Even a set amount of supplies I am allowed to buy (under a
certification number ).This would allow you to track the amount of
materials being consumed by a single user. These are just my thoughts
and concerns on the new regulations. Please realize that there are
people like me that have a lot of time and money invested into the
restoration hobby and would like to continue to enjoy it.
Response from Paula
Good afternoon Barry. Sorry I took so long to respond, but I have been
out of the office on travel and just got back today. Kim Teal is the
project manager for the rule so I will copy her on this response. She
can add anything I miss. First of all thank you for offering up your
situation and opinions. So often small businesses want to remain
anonymous and therefore rules are developed without their input. You are
right, we are attempting to develop a rule that applies to everyone, and
reduces emissions, especially in urban settings, where auto refinishing
operations exist close to residential areas.
The short answer to your question is that it sounds like you are doing
what we will expect all others to do. The rule is taking shape and will
most likely require a booth, exhaust filters and the use of HVLP (or
equivalent) spray guns, along with some basic work practice standards to
minimize emissions (such as keeping containers of paint and solvent
closed, etc.). The autobody refinish shops we've talked to and their
associations are strongly advocating point of purchase
controls/restrictions for auto refinish products. It sounds like you are
thinking along the same lines in terms of issuing a certification card.
The card would be the evidence that a painter has received proper
training in paint application and is aware of the rule requirements. We
have no intention of using the card to limit the amount of paint that is
So, yes, as a home hobbyist you will be able to continue to purchase
paint and continue your trade.
US Environmental Protection Agency
Mail Code C539-03
109 TW Alexander Drive
Research Triangle Park, NC 27709
Direct Line: (919) 541-2618
Fax: (919) 541-5689
Pay particular attention to WHO is doing the whinning about this 'problem' Hint it is NOT the 'greenies' no its the BIG shops who feel that they can't compete with the little shops
Also note Ms. Teal's comments about shutting down shops with these regulations. AND also note the comment about limiting sales and the stopping of an end run around the regulations via having someone legitimate buy and then resell to an unauthorized user as was suggested as a 'solution' on another board. In short, Ms Teal seems to have covered all the bases with this proposed legislation to stop sales to all but the biggest shops.
So to those naysayers who THINK they will have a way around the regs maybe in for a big surprise. I don't see a whole lot of suppliers willing to risk fines or worse to sell us some paint 'under the table'. I FULLY expect that buried in this legislation will be provisions to track EVERY sale via a Bar Code or RF -ID chip. So that means that the ''solution' I saw elsewhere- namely having the counter guy ring it up as a ''cash sale' to a big shop is not going to happen for long when the tracking shows MORE paint products sold to a particular user than the user's own records show and they (the big shop) are held liable for all the emissions.
We still have time to find out what members of Congress are on the EPA committee and start to contact them before this becomes law
Below is a letter sent by the National Automobile Dealers Association to Ms Teal. NOTE some of the things THEY suggest as to require in order to purchase paint. Most of these will keep a hobbyist from purchasing paint.
Here's the link to see it in its original format:
October 26, 2005
Ms. Kim R. Teal
Environmental Protection Specialist
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
On behalf of the Automotive Service Association (ASA) and the National Automobile Dealers Association (NADA), we are writing to address the possible regulation of area source emissions from automotive refinishing. ASA is the largest and oldest independent repair association in the nation. ASA’s 13,000 member businesses employ more than 65,000 independent auto service technicians. NADA is the national trade association that represents 20,000 franchised dealerships employing more than one million employees, a significant percentage of whom engage in automotive service and repair.
Franchised dealers and independent repairers are the businesses that America’s motoring public looks to for the repair of their vehicles. We appreciate EPA allowing us the opportunity for input as it moves forward with potential regulation of area source emissions from automotive refinishing. Your visits during the last year to collision repair facilities and industry events will certainly prove helpful as you develop draft rules.
ASA and NADA support an approach that would control the purchase and use of automotive refinishing products, not unlike that used by EPA to regulate motor vehicle air conditioning refrigerants today. Shops in our industry would be required to certify to EPA that they met minimum equipment and facility standards, such as the model equipment guidelines established by a joint EPA-OSHA industry workgroup several years ago (see attached). Shop certification might also require a federal tax identification number, a business license, and/or a valid state sales tax number.
Moreover, prospective purchasers and users of automotive refinishing products would be required to be employed by a certified shop and would need to be trained and tested on VOC management. Right now, for example, I-CAR offers training parameters for collision professionals that are generally accepted by all facets of the collision repair industry.
Clearly, reasonable controls on the purchase and use of automotive refinishing products is key to helping eliminate unnecessary VOC emissions from this industry sector.
Please feel free to contact either of us if we can provide more information regarding this matter.
Robert L. Redding, Jr. Doug I. Greenhaus
Washington, D.C. Representative Director, Environment, Health and Safety
This is what I plan on asking her I would like to know your comments on this and if you think I should add or Change any thing.
Regarding the new auto body refinishing area source rule.
What kind of a impact would this have on a at home hobbyist like myself that restores 0-2 classic cars in a typical year? I live in a farming area and there is not many homes, I have invested around $8000 in Paint related equipment alone, in order for me to restore my own classics as well as help friends finish there vehicles. I own only Compliant and hvlp paint guns, and I also use a Supplied Air Respirator while handling all harmful chemicals in my shop I use intake filters and exhaust paint filters.
From what I understand The EPA is going to make us register for a Certification Card that well require Us to have a Booth, with exhaust filters, And the use of HVLP or Compliant paint guns And know most of the basic standards to minimize emissions All this is very understandable. But What EXACTLY is this major problem they are trying to deal with is it general paint smells? or is it the VOC Rating contributing to smog? if a Dealership has a $80,000 Booth and the painter sprays a gallon of lets say PPG's OMNI MC161 Urethane Clear With a VOC of 4.3lb.Gal Well he pollute Less then if I shot it at home? NO way, The only difference is he has Exhaust filters and only thing it traps is hard Particles Like overspray, And the 4.3 VOC does not get trapped it Evaporates UNLESS he has an afterburner. The result the pollution is not an issue as the over spray well dry in 1-3 minutes. But it don't matter who shoots it the net pollution rate is still 4.3 lbs of VOC.
And having to go through the same training as the professional painters seems a little overboard, And it sounds to me like this is all to get us to pay the same emission etc taxes as the big guys correct?? I mean if we have to pay to be 100% certified painters with 100% certified booths and have to pay all the same emission taxes as the big guys? well then how can a hobbyist like me doing 0-2 cars a year making around $0-3000 bucks profit a year on are hobby, Afford this kind of stuff do us hobbyist Doing 0-2 cars a year not 50-800 like the big body shops do a year. Do us hobbyist get a break? Are we taxed on the amount of paint we buy a year or do we have to pay the same amount as the Body shops? If we are 100% certified painters with 100% certified booths what separates us from the professionals.
How can a hobbyist like me even support are hobby?
So my questions are:
Do we have to go through all the same training as the professionals?
Do we have to meet all the same standards that a professional booth would have?
Do we have to pay all the same emission taxes etc as the body shops or are we taxed only for the paint we buy a year?
Are we limited on the amount of paint we purchase a year?
What is the problem they are trying to Fix is it the General Paint Smells or is it the issue of VOCs getting into the atomosphere and contributing to smog?
Exactly how is a booth going to resolve the problem if the only thing it stops is the overspray and the VOC lb./gal is still released into the atomosphere unless they have an afterburner?
Exactly what is the thinking behind this whole thing, Who and or what does it benefit?
Why is this law being considered?
It would take 50 pages at least but here is a very short time line.
In the 90’s two things happened first was the strong growth of what you would call off the wall companies like Transtar, Matrix, SPI, Marhyde and MANY others producing clears and primers at the major company quality and many of them even better and selling them for around half the price or even less.
The brainwash statements that you must use the same line was now being assaulted and those statements just did not work anymore.
Also in the 90’s the majors made a decision that the only way they could fight off these companies was to offer contracts to the biggest of the big shops.
So they all met in Europe and agreed to keep their prices within pennies of each other
At the sprayable quart level. So now were all on a level playing field and only difference will be how much we want to bid for a certain shop.
The result of this meeting was the justice department filing suit for price fixing and it is still going on today. Last year the smallest company tried to settle for $24,000,000 and the judge said go to hell. Think about this, that company has 3-5% market share so if another company has 40% what will be their cost?? Big Bucks!
At this point they gave up on the medium sized shops and in frenzy went after the big ones. One in Atlanta commands a $1,000,000+ a year check for the paint company to get all its dealerships.
This was a great idea and the price increases were normally done twice a year to pay for these contracts and this year as of last month were on three price increases.
So now their $200-300 a gallon of clear or primer that the contract shop MUST buy has made the medium size shops that weren’t in the past start mixing systems because of the high price and some were just pissed as they felt they were subsidizing there competitors that got the contracts and were putting them at a disadvantage.
The contract shops now paying their high dollars for material can only do in house warranty repairs or insurance work, they no longer can get customer paid work or allover paint jobs.
Their answer, come out with a second cheap line, so all the paint companies did, problem was yes it was priced like the other off the wall companies but remember the quality of these companies were shooting for good quality and the paint companies came out with their industrial low grade crap. Did not work as painters are not stupid.
In summery, insurance work is down with more cars being totaled and the influx of Spanish shops are also killing the big shops and the paint companies have priced themselves out of the market unless, they buy you a paint booth and require you to buy from them.
The next idea, put the 3-4 man size bodyshops and the mexican bodyshops out of business because they polute. Then our big shops will get more business.
The do-it your selfer is just fallout, nothing personal!
MY! The webb we weave!
I just figured that most of you guys would like to know that if you want to keep your painting hobby you better plan on spending 80,000 on a certified booth and 20,000-70,000 to become a certified painter just to be able buy paint?
Kinda like my having to get certified to buy Refrigerant at Autozone.
I've done been thru the EPA game of the week.
Cost me a whopping $12.50 for the OPEN book test kit and a 2 week wait for my "Certification Kard".
Considering they have virtually NOBODY to enforce their LAW'S or FUNDING, Why all the typing?
CASH still RULE'S.
This has been discussed ad infinitum in THIS thread. No need to add anything more here.
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