Steven E. Schillinger, President of GRC-Pirk Management (http://www.recomply.com/) is a KPA partner serving the collision center industry and a specialist on the EPA 6H rule. Steven lists nine reasons why filing for an exemption is a bad idea:
- Exemption form is an application only, not immunity, and requires written acceptance from the EPA
- Guarantees EPA review and/or inspection
- Shops can’t be conditionally exempt, all or none – paint one-time with vibrant or pearl and they’re subject to the rule for the entire year
- Shops will have to prove an exemption each permit renewal period
- Shop assumes vicarious liability if they sign a false affidavit
- Prohibits use of ANY products containing Target HAPs, i.e., 3-M products, cleaners, strippers, any jobbers products, etc. – not just one manufacturers product-line
- Many Air districts have added the rest of the EPA 188 toxic HAPs to a local rule – Delegated Authorities can be more restrictive than the 6H Rule
- Inspectors are instructed to cut a sample of the booth filter for lab-testing – when ANY Target HAPs appear (and they do) shops will have to defend!
- Why file exemption? It’s easy to be compliant and most reputable shops are already in compliance!
Steven also wrote a great article in Auto Body News how this new 6H rule could benefit shop owners as it could eliminate illicit shops.
Body Shops should review KPA’s 6H Checklist to ensure that their paint spray operations are compliant. For more information on EPA rule 6H, see our 6H Rule Overview.
