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Painting and Coating

N95 Respirators are in short supply due to COVID-19. For those using them in the workplace, OSHA has released new guidance on reducing the need for N95s and finding alternatives for some situations.

Painting and coating processes often generate air and waste emissions that are regulated by state or Federal agencies. For air permitting, the sector is impacted by both area source and major source Maximum Achievable Technology Standards or MACTs. These MACT are in place due to National Emission Standards for Hazardous Air Pollutants or NESHAP. The resources below include an EPA webinar and resource center as well as resources for  NESHAPs that often impact small businesses. 

EPA NSBEAP surface coating webinar - New as of Oct. 2019

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

Clean Air Act Guidelines and Standards for Solvent Use and Surface Coating Industry

Reclassification of Major Sources as Area Sources under Section 112 of the Clean Air Act - proposed rule as for June 2019

NESHAP HHHHHH or 6H - Often called the "autobody rule, this rule impacts facilities that paint mobile equipment including automobiles, trucks and aerospace. It is an area source rule and facilities are impacted if any of their paints used contain one of the five  metal HAPs regulated. These five metal HAPs are lead, chromium, cadmium, nickle and manganese. If the facility uses methylene chloride as a paint striper, it is also impacted, but methylene chloride has been targeted for elimination by EPA due to toxicity.

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 the five different process. These five processes include dry abrasive blasting, dry grinding and dry polishing with machines, dry machining, spray painting and welding.

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.

 

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Painting and Coating

(6H NESHAP, 4M MACT, 4W MACT)