What do you need to know?

Please look below for some of our most commonly asked questions. Don’t see what you need? Contact us and we’ll get back to you soon.

Paperwork

This will vary based on the type of business that you are in and where you are located in the United States. The most commonly required plans are as follows: Hazard Analysis, Hazard Communication, Respirator Program, Emergency Action Program, Injury & Illness Prevention Program, OSHA Recordkeeping, Lockout Tagout, Forklift Program, and Hazard Material Business Plan

Documentation must include an agenda of what was reviewed, a signed attendance sheet from employees, and a date the training occurred.

There isn’t a requirement for these records beyond current employees, however we believe it to be good practice to keep these records indefinitely.

You must register the machine with the EPA and have any employee that uses it certified. We can help, click here for more information.

30 years

3 years

3 years

A booth filter test is not a requirement if the business would prefer to dispose of the filter media as Hazardous Waste. However, this tends to be more expensive. A new test will only need to be completed if the chemicals being used change

Regulatory Requirements

OSHA requires this to be completed every year.

5 years

February 1st through April 30th of every year in a common area for all employees such as a break room.

This will vary based on the type of business that you are in and where you are located in the United States. We can help, click here.

Posters & Logs

You do not need an all-in-one poster as you can post the information yourself if you prefer. However, most businesses find it easier to just maintain an all-in-one type poster for the business to ensure all bases are covered.

This will depend on regulations that may change every year. Some “poster companies” will tell you they made changes to the form and you need a new one, but if the content from a regulation and law standpoint did not change, you are in compliance even though it may have been purchased a few years ago.

These need to be posted in all immediate areas of flammable chemicals.

If there are any doors in your facility that do not lead to an exit that could be mistaken for an exit, you will need a No Exit sign. If the door is marked as a bathroom (for example), you do not need a No Exit.

For plumbed units, weekly. For manufactured units, you will use the recommendation from the manufacturer (most suggest weekly).

Weekly

Monthly

As they occur with indications of which respirators and/or filters were changed out (i.e. Exhaust vs. Floor)

Every 6 months

Daily

Body Shop

Click here for complete requirements

Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

This will depend on the type of business that you are in and the various operations that are being performed. We can help with a job hazard assessment to give you the minimum requirements per ANSI standards. Contact us for more information.

Fire Safety

An extinguisher must be mounted, accessible with 36″ clearance, be tagged for service within the last 12 months, pin in place, must have a sign indicating its location, and must be in the green on the gauge.

An emergency exit must be unlocked during business hours, free of obstructions in the immediate area, and have an illuminated EXIT sign above it.

An electrical panel must have 36″ of clearance in the immediate area, be unlocked, doors closed, no open spaces for breakers, and all breakers must be clearly labeled.

All gas cylinders must be stored upright, secured to prevent tipping, capped, and oxygen and acetylene separated by 20 feet. This applies even for empty gas cylinders, however it does not apply if the cylinders are currently “in use” by being on a welder or cart.

Paint Equipment

A mix room must have 4″ spill containment, be an enclosed room, have explosion proof wiring for electrical equipment, have a sprinkler or fire suppression system, have adequate ventilation, have a light and fan on a switch, and the door must remain closed at all times except when entering or leaving the room.

A prep station must have a roof, 3 side walls or curtains, curtains that extend from the roof to the floor, and the air is drawn into the area (curtains will pull slightly inward).

This will vary depending on your location. It is best that you review this with a local paint booth vendor or contractor.

Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

You will not be in compliance with 6H-NESHAP in this instance.

The gun washer must remain closed at all times unless in active use and be exhausted outside.

Car Wash

Any secondary container must be clearly labeled with the name of the chemical, name of the manufacturer, and any hazard warnings or HMIS information. This includes spray bottles of water.

The rule of thumb is that if there is a regular presence of water (i.e. car washing) than any outlet that may be used by the employees in the area must ground fault protected. This would include an outlet that may be somewhere else, but accessed by an extension cord.

This will vary by the types of chemicals that are being used and where you are located in the United States. Contact us for help.

Waste

Liquid paint waste, solid paint waste, thinner waste, used oil, used antifreeze, shop rags, shop dust, and paint booth filters are the most common.

If you are storing a chemical that requires spill containment, the  best rule of thumb is that the containment must be equal to or greater in capacity than the largest container that you have stored on the containment (i.e. a 55 gallon drum needs at least 55 gallon containment).

If you have not had them tested and certified as non-hazardous, then they must be disposed of as hazardous waste with a licensed transporter and disposal facility. We can help you get them tested. Once they are certified non-hazardous, you can discard them in your general waste streams. Click Here to learn more.

These can’t go into the trash. They must be disposed of as Universal Waste. We recommend taking them to a local hardware store for disposal (i.e. Lowe’s).

No. All paint products must go into a liquid paint waste drum before the PPS liner or cans are thrown into the general waste streams. If you have hardened paint from recycling your thinner, then the solid waste must be disposed of as hazardous waste.

Personal Protective Equipment

Most likely safety glasses and chemical resistant gloves depending on job responsibilities.

Most likely safety glasses, chemical resistant gloves, and a respirator depending on job responsibilities.

Most likely a UV mask, leather gloves, and a respirator depending on job responsibilities.

Most likely safety glasses, chemical resistant gloves, cut resistant gloves, ear plugs, steel toed boots, and a respirator depending on the job responsibilities.

Most likely a shoot suit, chemical resistant gloves, safety glasses, and a respirator depending on the job responsibilities. A painter must also wear a fresh air intake system or PAPR system that would take the place of a respirator.

NESHAP 6H

The Rule requires that shops opened after September 17, 2007 to be in full compliance with the rule as of January 9, 2008. These shops are considered “new sources” and if they are not in compliance with the rule they can face penalties. Pursue Compliance Certification and submit as soon as possible.

You are in violation of the Rule. Submit the Initial Notification as soon as possible.

While EPA may not specifically “shut down” a shop, they can impose fines that may be difficult for a small business to cover.

The ultimate responsibility for compliance with the rule is on the owner of the shop, not the individual painters.

Spray booths for spray painting vehicles must be fully enclosed and be ventilated at negative pressure or up to 0.05 inches water gauge positive pressure. Booths must have seals on all doors and other openings and an automatic pressure balancing system.

Prep stations for spray painting parts off of vehicles must have a full roof, at least three complete walls or side curtains (up to the roof). They must be ventilated so air is drawn into the prep station.

All spray priming and painting must be done in an appropriate booth or prep station.

Parts can be primed and painted in an approved prep station.

Vehicles or parts on a vehicle must be sprayed in an approved booth.

The federal rule is silent on code issues as those can vary at the local level. However, compliance with the federal rule is NOT an excuse to disregard local code or safety requirements which still apply as do all applicable OSHA requirements.

A room with three walls and a pull down door may be considered a booth, but it must also meet the filter requirements and must function as a booth (with no storage of extra parts, old materials, etc.) The room’s ceiling may then function as the roof of the booth.

No, the rule only applies to “spray application” of products, so sanding is not a covered activity under this rule.

Parts attached to the vehicle can only be sprayed in your spray booth. Any part not attached to the vehicle may be sprayed in either an approved prep station or the spray booth.

The EPA’s NESHAP 6H regulation has specific painter training requirements that must include:

  • Spray gun selection, set-up, and operation
  • Techniques to improve transfer efficiency and minimize overspray
  • Routine spray booth and filter maintenance
  • Filter selection and installation
  • Proper spray gun cleaning
  • NESHAP compliance requirements

Required hands-on training must include the following:

  • Successful completion of content training
  • HVLP or equivalent gun usage
  • Proper mixing of materials
  • Spray gun set-up, usage, and cleaning consistent with training and regulation
  • Spraying only in booth and / or approved prep station
  • Proper spray techniques
  • Booth maintenance procedures implemented and documented

Owner / Operator Certification

We recommend that this hands-on training be done as part of the painter training certification in the shop. This certification must be signed only by the owner / operator of the business, not a paint company, jobber, equipment supplier, EnviroSafe or other vendor. Details on certification are found in EnviroSafe’s NESHAP Manager’s Handbook.

Please note that the NESHAP painter training requirements are distinct from the 60-Minute Annual Compliance SP2 Training requirements. Painter training must be refreshed and certified by the owner/operator every 5 years.

The owner or operator of the shop is the responsible party under the requirements of the federal rule, and paperwork and recordkeeping are part of the rule requirements. It is important to maintain all records in a location that is easily accessible if an inspector comes to your shop. If you do not have the necessary recordkeeping and documentation you can be found to be in violation of the rule and can face penalties.

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