Collision Repair/Auto Refinishing Shops
Along with applicable waste and water regulations, Collision Repair and Auto Refinishing Shops may be subject to federal and state environmental regulations concerning air emissions. 40 CFR 63, Subpart HHHHHH (6H or the U.S. EPA Autobody Rule) regulates emissions of Cadmium, Chromium, Lead, Manganese, Nickel, and Methylene Chloride resulting from overspray during surface coating operations.
The Indiana state rule, 326 IAC 8-10, regulates emissions of volatile organic compounds (VOCs). For example, evaporation of solvent used as an ingredient in a base coat formula would be regulated by 326 IAC 8-10. The CTAP Automobile Refinishing presentation [PDF] identifies both similarities and differences between the two (2) regulations (state and federal), as well as identifying key features of both.
A presentation [PDF] on the specific aspects of 6H and some elements of 326 IAC 8-10, was made on December 6, 2016 to air inspectors. Compliance and Technical Assistance Program (CTAP) staff are available to assist Collision Repair and Auto Refinishing Shops with general or specific questions and concerns as well as to help them understand and comply with applicable environmental regulations.
40 CFR 63.11169 To 63.11180 - Subpart HHHHHH
Area Source forms must be submitted to:
U.S. EPA Region 5
Air Enforcement & Compliance Assurance Branch AE-17J
77 West Jackson Boulevard
Chicago, IL 60604
Courtesy copies may be sent to:
Indiana Department of Environmental Management
Office of Air Quality, Compliance and Enforcement Branch
100 North Senate Avenue IGCN 1003
Indianapolis, IN 46204-2251
Owners or operators may petition U.S. EPA for exemption from this regulation if none of the coatings contain any of the target HAPs listed above. The petition must be submitted to and approved by U.S. EPA.
Information Required By U.S. EPA For A Petition For Exemption:
Regarding 40 CFR 63, Subpart HHHHHH (6H or the U.S. EPA Autobody Rule), Indiana collaborated with five (5) other states (Illinois, Michigan, Minnesota, Ohio and Wisconsin) to develop informational tools to help an autobody shop comply with 6H. The results of this collaboration can be found within the Environmental Results Program (ERP) for Autobody Refinishing Shops Project [PDF].
The State of Wisconsin hosts the website where informational tools can be found..
- Initial Notification/Notification of Compliance Status Report for Paint Stripping [PDF]
- Making a Hazardous Waste Determination [PDF]
- Self-Certification Checklist [DOC]
- Waste Inventory Screening Checklist [PDF]
The following resources are available to provide further assistance:
- Compliance Manual [PDF]
- For Indiana's Collision Repair and Auto Refinishing shops featuring environmental, fire, and health and safety regulations.
- Disposal of Empty Containers as Solid Waste (Waste-0005, available on the IDEM Nonrule Policies page)
- Management of Contaminated Wipes and Reusable Cloth Items [PDF]
- Satellite Accumulation of Hazardous Waste by Generators [PDF]
- Alternative Control Techniques: Automobile Refinishing [PDF]
- Automotive Refinishing Safety Information
- Collision Repair Campaign
- Pollution Prevention Opportunities for the Transportation Industry [PDF]
- Reduction of Volatile Organic Compound Emissions from Automobile Refinishing [PDF]
- Rule and Implementation Information for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources