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 either area source or major source National Emission Standards for Hazardous Air Pollutants, or NESHAPs, also known as Maximum Achievable Control Technology Standards or MACTs. These federal standards are performance-based rules designed to significantly reduce hazardous air pollutants, or HAPs. The resources below may be helpful to small businesses which paint and/or coat various metal, plastic, or wood parts as well as automobiles. If you have questions, contact your state SBEAP.
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. If a facility is not a major source, it is an area source (it emits less than 10 tons of a single HAP or less than 25 tons of a combination of HAPs annually).
EPA resources
- Clean Air Act Guidelines and Standards for Solvent Use and Surface Coating Industry – This site includes a table of industry types that correspond 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 with a technical update to the rule on Dec. 28, 2020. 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, eliminating the 1995 “once in, always in” policy. It encourages major sources to pursue innovation, source reduction, and control technologies to reduce the emissions of HAPs to below major source levels.
- EPA's 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. This website contains a separate page that details the 6H rule under the auto body sector.
- NESHAP XXXXXX or 6X – Referred to as the "Nine Metal Fabrication and Finishing Source Categories," this rule impacts area sources with a specific SIC or NAICS, 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.
- NESHAP MMMM or 4M – The "Surface Coating of Miscellaneous Metal Parts and Products" rule impacts activities at major sources of HAPs, requiring:
- EPA’s 4M Rule Overview Page
- Texas Commission on Environmental Quality’s 4M webpage including example forms
- Kansas SBEAP’s Painting and Coating NESHAP Rules webpage including a 4M compliance demonstration spreadsheet
- NESHAP IIII or 4I – The “Surface Coating of Automobiles and Light-Duty Trucks” rule impacts major sources of HAPs which applies topcoat to new automobile or light-duty truck bodies or body parts for new automobiles or new light-duty trucks. In 2020, EPA finalized minor amendments to the rule clarifying the standards are applicable during periods of startup, shutdown and malfunction; require 5-year performance testing for facilities with add-on controls; and require electronic reporting of performance test results.
- NESHAP PPPP or 4P – The "Surface Coating of Plastic Parts and Products” rule applies to industries that are major sources for HAPs and surface coat plastic parts and products.
- EPA’s 4P Rule Overview Page
- Texas Commission on Environmental Quality’s 4P webpage including reference tables and applicability flowchart
Acronyms
- HAP: Hazardous Air Pollutant
- MACT: Maximum Achievable Control Technology
- NAICS: North American Industry Classification System
- NESHAP: National Emission Standards for Hazardous Air Pollutants
- PM: Particulate Matter
- SIC: Standard Industrial Classification
- VOC: Volatile Organic Compound