HAPs 6H

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POLLUTION PREVENTION

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PresentersSteven SchillingerPresident - GRC-PIRK Management 775.690.9098 - [email protected]

Len LazarusOffice of Enforcement and Compliance Assurance - [email protected]

Sapna BudevDirector of Industry Programs – [email protected]

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Questions• If you have questions

during the presentation, please submit them using the “Questions” feature

• Questions will be answered at the end of the webinar

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CONTENT

This webinar is designed to help shop owners and managers be familiar with the

requirements of the new HAPs 6H Rule. This webinar does not contain a review of the

entire Rule, but provides an overview for sign industry requirements, compliance dates,

information about related OSHA standards, and simplify some black rumor & gossip.

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National Emissions Standardfor Hazardous Air Pollutants

“NESHAP”(Federal Clean Air Act)

EPA 40 CFR Part 63 Subpart HHHHHH a.k.a. (6H)

• Overview• EPA Requirements

• OSHA Requirements• Enforcement• Local Codes

• Where to Go for Help

a.k.a. NESHAP Rule 40a.k.a. Refinishing Rulea.k.a. Area Source Rulea.k.a. Heavy Metals Rule

The HAPs 6H Rule was publicized in the Federal

Register in 2007 as a result of a lawsuit won by the Sierra Club in 2006. The final Rule

became law in January 2008.

a.k.a. Air Toxics RuleEPA 40 CFR Part 63

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AIR QUALITY PERMITS

SIGN SHOPS CAN EMIT 3-TYPES OF REGULATED POLLUTANTS:

1. Particulate matter (PM) from sanding, blasting, welding, and spray coating

activities; 2. Volatile organic compounds (VOCs) from solvents used in surface prep and

equipment cleaning activities, as well as in the coating formulations; and 3. Other Hazardous air pollutants (HAPs) besides those regulated by the new

HAPs 6H Rule. – Even though a shop may not require a permit, all shops must comply with EPAs Air

Regulations. In addition to the Rule 6H requirements, air quality regulations prohibit the release of pollutants that cause harm to the environment or human health.

– The need for an Air Quality Permit depends on the types and amounts of pollutants emitted from shop activities.

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AIR POLLUTION

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HAZARDOUS AIR TOXICS

http://www.epa.gov/ttn/atw

http://www.epa.gov/ttn/atw

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There are many definitions of heavy metals. • One description says they are the chemical

elements that have a specific gravity 5-times greater than that of water (Life Extension Foundation).

• Another defines heavy metals as particulate matter that are toxic in nature. Most common examples are: Chromium, Copper, Nickel, Mercury, Lead, and Zinc.

HEAVY METALS - AIR TOXICS

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What HAPs are CoveredThe EPA has identified 30 HAPs that pose the

greatest threat to public health.

The EPA has identified categories that account for 90 percent of the releases of the 30 HAPs.

Sign shops are subject to the HAPs 6H Rule if they spray paint or products containing compounds of: chromium, lead, manganese, nickel, or cadmium. (the target HAPs) products.

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AEROSPACE OPERATIONS 10,000+ shops AEROSPACE TRADE ASSOCIATION

PLASTIC COATING OPERATIONS 15,000+ shops PLASTIC & RUBBER TRADE ASSOCIATION

METAL COATING OPERATIONS 20,000+ shops FABRICATED METAL ASSOCIATION

SIGNS SHOPS 30,000+ shops INTERNATIONAL SIGN ASSOCIATION

AUTOMOTIVE COLLISION REPAIR 60,000+ shops AUTOMOTIVE SERVICE ASSOCIATION

SPRAY COATING OPERATIONS

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www.epa.gov/collisionrepair

http://www.epa.gov/collisionrepair

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THE HAPS 6H RULE REGULATES THREE ACTIVITIES: 1) Paint stripping

2) Spray coating of motor vehicles

3) Spray coating of metals and plastics

THE HAPS 6H RULE CAN BE DEVIDED INTO 4-SECTIONS: 4) Booth Enclosures

5) Equipment (Type & Maintenance)

6) Employee Training7) and, Recordkeeping

HAPs 6H REGULATIONS

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DEFINITIONS• Spray application means that coatings are applied

using a hand-held device that atomizes the coating. • Coating means a material spray-applied for

decorative, protective or functional purposes. • Parts and products include:

– Architectural Apparatus– Construction Components– Support Structures & Assemblies– Sign or advertising products made of plastic or metal

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MeCl (Paint Stripping)

The HAPs 6H Rule requires the development of a written MeCl

Minimization Plan for shops that use more than 1 ton of MeCl.

1 ton of MeCl is approximately 180 gallons in one year.

However, most sign shops use much less than 1 ton/yr and don’t need a plan.

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MeCl (Paint Stripper)

• If you use any MeCl, the HAPs 6H Rule requires management practices be implemented: – Evaluate each application to insure there is a need to strip the old

paint from the surface; – Reduce exposure of all MeCl-containing paint strippers; – Optimize application and storage conditions of paint strippers to

reduce the MeCl evaporation. • The HAPs 6H Rule requires recordkeeping for ANY amount

of MeCL:– A list of all the MeCl-containing paint stripper products used; – The MeCl content of each product used; and – Purchase receipts, MSDS, usage records, or calculations.

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Equipment Type & Cleaning

• All spray-applied coatings must be applied with a high-volume low-pressure (HVLP), or equivalent technology.

• Paint spray guns must be cleaned so that an atomized mist is not created outside of the container. – Use an enclosed spray gun cleaner.– Do not spray into the sink, filters or a bucket.

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When using Target HAPs, spray coating to be preformed in a prep station or spray

booth. (some open air spraying exclusion)– The prep stations and spray booths must

have a full roof and at least three complete walls or side curtains.

– Prep stations and spray booths must use filters with 98 percent filter efficiency.

• Establish and document filter change-out schedule and procedure

• Maintain filter purchase records

Spray Booth & Filters

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Owners must keep copies of records for the status of HAPs 6H compliance for a minimum of 5-years.

– Booth filter purchase records.– Spray gun manufacturers’ data sheets. – Spray gun transfer efficiency evidence.– Regional and state compliance notifications.– Paint stripper and spray coating MSDS sheets.– Assessments, deviations or corrective actions.– Employee classroom training records .– Employee hands-on training records.

Record Keeping

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Train and certify all spray equipment operators (helpers & painters) within 180 days.

– A employee list by name, job description (title) and date(s) of training.

– Hands-on (physical) training: setup, operation and usage of equipment, including spray gun transfer efficiency test.

– Classroom (tutorial) instruction: Address the HAPs 6H regulations, procedures and maintenance of equipment, including related environmental health and safety requirements.

Training and Certification

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Hands-On Requirements

____________

________________

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RELATED RULESHealth, Safety and Fire Marshal laws that may apply to

the HAPs 6H Rule are as follows: NFPA – Spray Coating Using Flammable &

Combustible Liquids EPCRA – HazCom/HazMat (Right-to-Know) OSHA – Respiratory Protection OSHA – Flammable and Combustible Liquids OSHA – Air Contaminants OSHA – Cadmium EPA/OSHA – Lead (EPA Renovation, Repair & Painting) OSHA – Chromium

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OSHA has revised the employee notification requirements under the Hexavalent Chromium [Cr(VI)] regulation requiring employers to notify

employees of the results of all exposure determinations. The action comes in the form of a Direct Final Rule, which became effective June

15, 2010.

OSHA CR(vi) Regulation: Each region is required to conduct at least five inspections each year. Employers participating in cooperative Green programs may be

exempt from programmed inspections. Area Offices are required to conduct follow-up inspections on other

toxic substances targeted by the Regulation.

NEW OSHA CrREQUIREMENTS

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RENOVATION, REPAIR &PAINTING RULE

• The EPA RRP Rule represents the most significant and far-reaching Federal lead regulation since the HUD Lead-Safe Housing Rule a decade ago.

• Anyone working on some pre-1978 buildings now need to be certified in the new lead based paint regulations.

• The EPA will not take enforcement action for violations of the RRP rule until October 1, 2010.

• EPA won’t enforce against shops and workers if they signed up for training by September 30, 2010 and complete the training by December 31, 2010.

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Multi- Agency ENFORCEMENT

The HAPs 6H Rule can be implemented and enforced by U.S. EPA, or a delegated authority such as your

State, local, or tribal agency.

Air District

Water District

Regulated Waste

OSHA, Fire Dept or city inspector

http://www.haps6h.com/links.htm

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EPA ENFORCEMENTEPA, State and local governments are responsible for

enforcement of the Clean Air Act. • Citizens can also sue violating sources.

• Before the 1990 CAA, enforcement was through the courts.

• The 1990 Clean Air Act gave EPA authority to bypass court in order to speed up the process.

The federal EPA fines can be up to $37,500 per day.Plus, another $25,000/day (California)

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COMPLIANCE DATESREQUIREMENTS

SOURCE TYPE

NEW EXISTING

General – Enclosures Upon startup January 10, 2011

General – Type and Cleaning of Spray Guns

Upon startup January 10, 2011

Employee TrainingHands-On: 180 days after hire Classroom: 180 days after hire

No later than 180 days after hire of by Jan 10, 2011,

whichever is later

EPA Initial NotificationJuly 7, 2008, or 180 days after

initial startupJanuary 11, 2010

Compliance NotificationJuly 7, 2008, or 180 days after

initial startupMarch 11, 2011

RecordkeepingJuly 7, 2008, or 180 days after

initial startupJanuary 10, 2011

ReportingEach March 1st of the following

calendar yearEach March 1st of the

following calendar year

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Benefits and Burdens Associated NESHAP Paint Stripping and Miscellaneous Spray Coating Rule

C O M P L I A N C E E X E M P T I O N

B e n e fi t s· Green Recognition· Pollution Prevention Employee Protection· Positive Public Image· Spray Coating Efficiency Regulatory Peace-of-Mind

B e n e fi t s No New Filters Delay Upgrades Postpone Training Open Air Spraying Use Old Spray Guns No Waste Management

B u r d e n s Equipment Upgrades Extra Employee Training Paint Stripping Restrictions Additional Waste Management

B u r d e n s Unexpected Violations Uninformed Employees Vibrant Paint Restriction Buy Segregated Products

PROS and CONS

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EPA, OSHA & NFPATYPE OF WASTE WASTE MANAGEMENT REGULATIONS

SANDING DUST DISPOSE OF WASTE DUST COLLECTED IN VACUUM SANDERS PROPERLY.

USED SPRAY BOOTH FILTERS

DO NOT DISPOSE OF USED FILTERS CONTAINING HEAVY METALS:

• CHROMIUM, COPPER, NICKEL, MERCURY, LEAD, AND ZINC, ETC

• (6H TARGET) CHROMIUM, LEAD, MANGANESE, NICKEL, CADMIUM

USED PAINT CUP LINERS

IF THE PAINT DOES NOT CONTAIN METALS, USED PAINT CUP LINERS CONTAINING DRIED PAINT MAY BE DISPOSED OF A NON HAZARDOUS WASTE.

• ONLY IF ALLOWED BY LOCAL LAND FILL LAWS.

EMPTY PAINT CANS

CANS CONTAINING DRIED PAINT MUST BE DISPOSED OF AS HAZARDOUS WASTE UNLESS TESTED TO DEMONSTRATE LEVELS BELOW LIMITS.

USED/RECYCLEDSOLVENT & PAINT

WASTE

LABEL ALL CONTAINERS “HAZARDOUS WASTE” FOR USED SOLVENT PAINT WASTE AND WATERBORNE PAINT WASTE (WASTE WATER & FLOCCULANTS), AND CONSULT A LOCAL HAZARDOUS WASTE DISPOSAL CONTRACTOR FOR PROPER DISPOSAL.

SHOP TOWELSDISPOSABLE TOWELS THAT HAVE BEEN CONTAMINATED WITH HAZARDOUS MATERIALS (SOLVENTS) MUST BE DISPOSED OF AS HAZARDOUS WASTE.

Waste generated in the shop is considered hazardous under

RCRA standards.

• RCRA – Resource Conservation and Recovery Act regulates solid waste management (cradle-to-grave)

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SUMMARY Mandatory Compliance Jan 10, 2011 Employee Training Documentation Purchase Records Documentation Spray Gun Equipment Conformity 98% Efficient Booth Filter Usage Paint Stripper Recordkeeping Open Area Spray Limitation

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Truly “GREEN”According to the FTC standards and EPA,

HAPs 6H compliance is a good start!

www.haps6h.com www.sign.org

http://www.haps6h.com/

http://www.sign.org/

HAPs 6H

Business

Transcript of HAPs 6H