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.