Painting and Coating 

Painting and coating processes are common for several different industry sectors. These processes typically generate air emissions and solid or hazardous wastes that are regulated by state or federal agencies. For air permitting, the primary concern from these operations are volatile organic compounds volatile organic compounds, or VOCs, hazardous air pollutants, or HAPs and particulate matter, or PM. This sector may be subject to state and federal permitting rules, as well as subject to either area source or major source National Emission Standards for Hazardous Air Pollutants, or NESHAPs, also known as Maximum Achievable Technology Standards or MACTs. These federal standards are performance-based rules designed to significantly reduce toxic air pollutants or air toxics, or HAPs. The links below to various resources may be helpful to small businesses which paint and/or coat various metal, plastic, wood parts as well as automobiles. As always, if you have questions, contact your state SBEAP.  

  • Clean Air Act Guidelines and Standards for Solvent Use and Surface Coating Industry – This site includes a table of industry type that corresponds with solvent use and surface coating regulations. 

  • Reclassification of Major Sources as Area Sources under Section 112 of the Clean Air Act - This rule was finalized on Nov. 19, 2020 and included a technical update to the rule on Dec. 28, 2021. The rule implements clear language of the Clean Air Act that allows a major source of HAPs to reclassify as an area source after acting to limit emissions. It encourages major sources to pursue innovation, source reduction, and control technologies to reduce the emissions of HAPs to below major source levels. A major source of HAPs is defined as a source that emits 10 tons or greater of a single HAP or 25 tons or greater of a combination of HAPs annually.  An area source is defined as a source that emits less than 10 tons of a single HAP or less than 25 tons of a combination of HAPs annually. 

  • EPA National Painting and Coating Resource Center –This resource provides various compliance assistance tools for federal regulations related to painting and coating operations. 

  • NESHAP HHHHHH or 6H – Often called the "autobody rule,” it impacts area sources that paint mobile equipment or parts for automobiles, trucks and the aerospace industry with any of one of five regulated metal HAPs. These include lead, chromium, cadmium, nickel and manganese. If the facility uses methylene chloride as a paint striper, it is also regulated under the 6H.  

  • EPA summary brochure 

  • National SBEAP page for collision repair industry 

  • NESHAP XXXXXX or 6X – Referred to as the "Nine Metal Fabrication and Finishing Source Categories," this rule impacts area sources of specific SIC, that emit five targeted metal fabricating or finishing HAPs as part of any of five different process. These processes include dry abrasive blasting, dry grinding and dry polishing with machines, dry machining, spray painting and welding. 

  • EPA summary brochure 

  • National SBEAP resource page 

  • NESHAP MMMM or 4M – The "Miscellaneous Metal Parts and Product Surface Coating" rule impacts activities at major sources.  

  • NESHAP IIII – This rule impacts major sources that emit HAPs as part of the surface coating of automobiles and light-duty trucks. 

  • NESHAP PPPP – This rule applies to industries that are major sources for HAPs, and surface coat plastic parts and products.