Work with chemicals found in paint shops or plastic manufacturers? Here’s a quick primer on the 6H rule and what you can do to stay in compliance. Breaking out the bad puns in the first paragraph – yikes! Let’s get serious here…
A Little Background: What is the NESHAP 6H Rule?
The National Emissions Standards for Hazardous Air Pollutants HHHHHH (6H) is the EPA’s regulation regarding paint stripping, plastic parts and products, and autobody refinishing paint as sources of hazardous air pollutants (HAPS) that are a public health risk.
The regulation pertains to any paint stripping material that contains methyl chloride (Me Cl), spray applications to motor vehicles or mobile equipment, or spray coatings that contain chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) compounds.
This rule took effect in 2008 and required full compliance by 2011, so this isn’t anything new.
How Do I Stay in Compliance?
Check your compliance status. KPA clients are in luck – they can use the 6H Checklist that helps you review topics including:
- Do you have a management plan?
- Are all of your employees trained? All your records maintained and current?
- Documentation for any applicable spray booth, filter efficiency, HVLP spray gun, or painter training certification about 6H regulations should be kept on site.
- If you have lot vendors with spray operations (think minor touch-ups or bumper repair), they must also comply with the regulations.
What if I’m Exempt from the Rule?
If your organization doesn’t use MeCl or spray HAPS, you may be exempt from the rule. If you’ve confirmed the rule does not apply to your facility, the EPA instructs you to submit an updated notification exempting the facility from the rule.
KPA urges businesses subject to this rule, such as automotive collision centers, to ensure compliance at all times.
What are the Risks of Non-Compliance
This rule is typically enforced directly by the US EPA, meaning penalties will be based on the Federal Clean Air Act penalty policy, which is among the most severe in potential fines. This can quickly escalate into 6 and, potentially, 7-figure penalties for larger businesses.
This is one of a whole host of regulations companies need to stay on top of.
Which is where KPA can help. KPA solutions help clients identify, remedy, and prevent workplace safety and compliance problems across their entire enterprise. The combination of KPA’s Vera Suite platform, EHS consulting services, and award-winning training content helps organizations minimize risk so they can focus on what’s important—their core business.