FEDERAL REGULATIONS FOR SURFACE COATING OF MOTOR VEHICLES AND MOBILE EQUIPMENT AT AREA SOURCES

OVERVIEW OF THE RULE

The NESHAP for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (Rule) was proposed in the Federal Register on September 17, 2007 and the final Rule was promulgated on January 9, 2008.  The Rule regulates three activities:

1) Paint stripping using methylene chloride.
2) Surface coating of motor vehicles and mobile equipment.
3) Surface coating of miscellaneous metal and/or plastic parts.

The final Rule, Title 40, Part 63, Subpart HHHHHH of the Code of Federal Regulation (40 CFR 63) is found in the Federal Register notice published January 9, 2008 (pages 1760-1768). To assist you in cross referencing the Federal Register notice, sections of the Subpart are identified throughout the fact sheet (e.g. §63.11180).

Paint Stripping means use of methylene chloride (MeCl) for the removal of dried paint (includes paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic and other substrates.

GENERAL REQUIREMENTS

Paint Stripping:
If you use paint strippers containing methylene chloride, you must meet the following requirements:

1. Evaluate each application to ensure there is a need for paint stripping.
2. Evaluate each methylene chloride paint stripping operation to ensure
there is no alternative technology that can be used.
3. Reduce exposure of paint strippers containing methylene chloride to the    air.
4. Optimize application conditions to reduce evaporation.
5. Practice proper storage and disposal of paint strippers.

If you use more than one (1) ton of methylene chloride annually approximately 150 gallons), you must do the following:

1. Implement the requirements above.
2. Maintain records on site at all times of annual usage of paint strippers
containing methylene chloride.
3. Develop and implement a written methylene chloride minimization plan.
(The plan must be kept on site.)
4. Post a placard or sign outlining the methylene chloride minimization plan
in each area where the paint stripping occurs.

NOTIFICATIONS/REPORTS

The Rule requires: 1) an initial notification identifying basic information about the facility 2) notification of compliance status with the general requirements of the Rule and 3) annual notification of changes report to be submitted if there are changes at your facility that impacts information on forms you have previously submitted or if there are deviations from the regulatory requirements that occurred during the previous calendar year.

Contact Us or Call (773) 523-3100 our technical staff  if you have any questions or require help in completing initial notification form.

HOW TO TREAT COMPLEXED CYANIDES IN YOUR EFFLUENT

Most modern metal-finishing firms that generate cyanide-bearing wastewaters employ alkaline chlorination treatment prior to metal precipitation. This treatment process will oxidize cyanides, which are amenable to chlorination (i.e., the cyanide that can be oxidized by the alkaline chlorination process), to less than 1.0 mg/l cyanide.

The cyanide ions that cannot be “broken down” in the alkaline chlorination process are in very stable cyanide complexes, such as ferrocyanides or ferricyanides. These complexes are basically impossible to treat and are largely unaffected by traditional alkaline chlorination.

Accu-Labs has developed a cost effective process for treating complexed metal cyanides in your effluent efficiently. The Accu-Lab #707p EZ Treat process will precipitate the cyanide ion, and allow it to be removed in a subsequent clarification process. Results of EPA sampling of such a process showed that an average influent concentration of 2.7 mg/l CN was treated to less than 0.023 mg/l CN.

If you ever had trouble meeting your local POTW’s discharge limits for cyanide, contact Accu-Labs today to talk to one of our knowledgeable service representatives and discover how truly “EZ” it is to achieve total discharge compliance with the help of Accu-Labs #707p EZ Treat system!

WHY TAKE THE CHANCE?

Features and Benefits of Accu-Labs #707p EZ Treat Process:
* One-step process
* Saves time, chemicals, and money
* Precipitates complexed cyanides of nickel, iron, and zinc easily
* No Special Equipment required

PROVIDES TOTAL CYANIDE COMPLIANCE!

How to use # 707P EZ-Treat For removal of complexed cyanides:

1. Treat waste stream in normal manner to eliminate amenable cyanides.

2.Adjust pH to within 1.0 – 6.0.

3.Add the required amount of # 707P EZ-Treat:One quart will precipitate approximately 50 ppm of total cyanide in 100 gallons of effluent.

4.Add one pound of zinc sulfate for each quart of # 707P EZ-Treat used in Step 2.

5.Adjust pH to 7.5 – 9.0 for precipitation

OSHA Cr PEL UPDATE!!

The 3rd Circuit Court of Appeals (Philadelphia) upheld OSHA’s PEL of 5 ug/m3 based on economic feasibility and denied arguments made by Public Citizen’s, a national, nonprofit consumer advocacy organization, except for the issue of employee notification when an operation exceeds the Action Level.
OSHA has analyzed the economic ramifications whether this standard under consideration would eliminate the competitive structure of an entire industry. It was determined that the proposed 1 ug/m3 PEL was too costly for electroplating job shops and concluded that these shops should not be expected to absorb the costs to comply with a 1 ug/m3 standard.
Though the battle may have been won, there are still tighter restrictions still being proposed. The National Institute for Occupational Safety and Health (or NIOSH) is the United States federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. NIOSH is making the proposed recommendation of a permissible exposure limit (PEL) of 0.2 ug/m3!

Accu-Labs, Inc. is committed to providing regulatory compliance management assistance to our customer base and will be happy to answer any questions pertaining to the new OSHA PEL.  Accu-Labs can also assist your company with the air monitoring requirements outlined in the OSHA PEL standard. Contact Us or Call (773) 523-3100 today for more information!!

HOW CAN I SAVE 50% ON MY CLEANING COSTS

50-SE PREMIUM MATRIX CLEANER from ACCU-LABS is the next generation of premium cleaning technology. Production results have proven ACCU-LABS’ 50-SE Premium Matrix cleaner provides the best available cleaning at up to HALF THE COST!.

The building blocks of this new innovation are accomplished by combining the most recent surfactant technology in a concentrated matrix form with caustic soda or other liquid alkali builder. This product can be used either as a soak cleaner or as an electro-cleaner in a variety of applications. This surfactant system is also capable of cleaning a array of base materials ranging from aluminum to steel with minor modifications…ONE CLEANER DOES IT ALL!! Reduced inventory, improved cash flow and lower operating costs are some of the advantages the end user will witness when using this cleaning system. ACCU-LABS’ Premium Matrix cleaner contains no phosphates or complexing agents and has been proven to be easily waste-treatable.

To find out more about 50-SE Premium Matrix Cleaner Contact Us or call (773) 523-3100.

RoHS COMPLIANT “NON-CHROMATE” CONVERSION COATINGS FOR ALUMINUM

ACCU-LABS 628-DM conversion coating process is available as a chromium free alternative for corrosion protection for aluminum substrates. The 628-DM coating provides a beautiful golden color with excellent corrosion resistance. Parts treated with 628-DM conversion coating process have consistently achieved 168 hours of salt spray protection per ASTM B-117. The coating is abrasion resistant and lends itself to good paint adhesion. ACCU-LABS 628-DM conversion coating process was developed to meet and exceed current RoHS standards, with the intention that all chromium compounds may eventually be banned. ACCU-LABS 628-DM development team was led by Robert Burnson. Bob brings with him over 50 years of hands on formulating experience. Bob was one of the early pioneers in environmentally green chemistry, especially in the areas of non-cyanide alternative chemistries and trivalent conversion films.

Contact Us or Call (773) 523-3100 today for a free sample for evaluation purposes!!

ARE YOU READY FOR RoHS?

The RoHS Directive, EU Directive 2002/95/EG, which will go into effect on July 1, 2006 in Europe, mandates that electrical and electronic products (EEE) put in the market within the European Union (EU) shall contain restrictive levels of the following substances:

q                 Lead (Pb)

q                 Cadmium (Cd)

q                 Mercury (Hg)

q                 Hex-Chromium (Cr6+ )

q                 PBB’s

q                 PBDE’s

This Directive, which aims to protect human health and the environment and mirrors the Directive on Waste Electrical and Electronic Equipment (WEEE), applies to electrical and electronic equipment that is dependent on electric or electromagnetic fields in order to work properly. The RoHS/WEEE Directive does not call for a total elimination of these substances. It mandates that the homogeneous materials within complaint products, or materials that cannot be mechanically disjointed into different materials, contain no more than maximum concentration levels of the six restricted substances. The definition of homogeneous materials has caused some confusion, but has been clarified as “a material that cannot be mechanically disjoined in to different materials”, such the PVC insulation on insulated copper wire.

This Directive is just the beginning in a long line of new international directives aimed at protecting human health and the environment:

 The state of California is initiating their own version EU’s RoHs Directive, The Electronic Waste Recycling Act of 2003 is scheduled to take effect January 2007. (20 other states in the United States have bills pendingfor RoHS-like regulations.)

 • China’s Regulation for Pollution Control of Electronic Products (RPCEP), is modeled after RoHS but has more restrictions is scheduled to go into effect around August 2006.

•The green procurement practices (JPSSI) in Japan has more stringent mandates than RoHS.

• Taiwan, Korea, Canada, and Australia are initiating versions of the RoHS directive.

As the RoHS deadline looms, companies that have not begun the process of becoming RoHS compliant are behind the curve. At Accu-Labs Inc., we are dedicated to the research and development of RoHS compliant chemistry that is engineered to conform to an ever changing global manufacturing environment. Contact Us or Call (773) 523-3100 with any of your RoHS related questions.