Legislation making it unlawful to pollute varies from state to state. High quality, fast repairs are a priority for staying in business and cost and time constraints may tempt owners to do the minimum. However, preventing pollution makes good business sense in the long run. It can increase competitive advantage and save an auto body shop money through:

• Improved public image and service quality (happier and healthier employees work more efficiently and take more pride in their work).
• Reduced inventory costs by using fewer raw materials.
• Reduced waste disposal costs (especially hazardous waste).
• Reduced waste water disposal and/or treatment costs.
• Reduced liability risks.
• Reduced regulatory paperwork and related costs.

Area Source Standards

EPA has generated new regulations for the “Area Sources.” Area sources are those that emit less than 10 tons annually of a single hazardous air pollutant or less than 25 tons or more annually of a combination of hazardous air pollutants. Previously they were not regulated since individually they are small emitters; however together these area sources represent a significant contribution to the emission of many hazardous air pollutants. These sectors will soon be subject to emissions standards as defined under the Clean Air Act.

Auto body refinishing shops are one of the area sources that is regulated. To learn more, please visit the Rule and Implementation Information for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources page on the EPA website.

Advantages of acting “ahead of the curve”

Knowing that regulations are coming soon, you have time to shop around for the best practices and technologies that allow your business to comply with upcoming regulations as well as add profitability and efficiency to your bottom line. Eliminating toxic emissions reduces your liability risk associated with employee health as well as fines or costly remediation. As a proactive business, you can avoid such problems by anticipating the coming changes and looking for the win-win strategies. Since many emissions reductions strategies serve to reduce costs and/or update processes and technologies, your business may become more competitive in the process of lowering toxic emissions.

How P2 Can Reduce Operating Costs

Switching to less hazardous products such as low VOC paints and aqueous solvents reduces disposal costs and regulatory liabilities, not to mention employee risks.

When operated correctly, high-volume, low-pressure (HVLP) spray guns have notably higher transfer efficiencies (60-70%) than conventional spray guns (20-30%). When HVLP spray guns are used by effectively trained technicians, more paint ends up on the car and less is lost as overspray. This efficiency is a health benefit to painters (who have less contact with toxic paint components) and to the shop (by saving money on paint and labor costs without sacrificing productivity).

Hazardous Waste is Expensive!

A hazardous waste, as defined by the Resource Conservation and Recovery Act (RCRA), is a waste that appears on any one of four RCRA hazardous waste lists or that exhibits any one of the following characteristics:

• Ignitable – A liquid with a flash point below 140 degrees F; a non-liquid capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes; and/or a flammable compressed gas. An example would be mineral spirits.
• Corrosive – An aqueous-based liquid with a pH less than or equal to 2.0 (strong acid) or a pH great than or equal to 12.5 (strong base). Examples include battery acid and alkaline cleaning solvents.
• Reactive – Wastes that are unstable or undergo violent chemical reactions when combined with water or other materials. An example would be hydrogen sulfide.
• Toxic – A waste that contains metals or organic compounds. An example would be certain hot tank wastes containing high levels of lead, silver, or other metal.

Potential Hazardous Wastes in the Autobody Shop

• Spent gun cleaning and parts washing solvents can be regulated hazardous waste if they exhibit hazardous characteristics such as: corrosivity, low flash points, and/or because they contain more than 10% F-listed solvents such as 1,1,1-trichloroethane or perchloroethylene.
• Paint stripping and sanding operations may generate regulated hazardous waste if the paint has a high metals content (this is common in older and military vehicles), and/or if any solvents used in stripping are hazardous (they often contain F-listed solvents such as methylene chloride). These types of wastes would have to be counted toward an auto body shop’s total monthly generation of regulated hazardous waste.
• Off-spec or waste paint may be a regulated hazardous waste because of toxicity from heavy metals or ignitability from solvent additives.

For more information on hazardous materials and waste, contact the U.S. Environmental Protection Agency at the weblink above. This link has many aspects of all the RCRA regulated waste issues in an A to Z searchable format.

Other Concerns

• Diisocyanates, found in automotive finishes, are a serious health concern. Auto refinishers who have become sensitized to diisocyanates risk serious harm, if they use diisocyanate-containing materials without adequate protective equipment. In humans, diisocyanates can cause:
  • Respiratory sensitization (shortness of breath, wheezing, coughing, or asthmatic reactions)
  • Dermal sensitization (skin irritation or allergic reactions)
  • Pulmonary toxicity
  • Eye irritation
  • Lung toxicity
  • Cancer
  • Death
• The U.S. Environmental Protection Agency (EPA) requires that all coatings manufactured in or imported into the United States for auto body refinishing meet specific limits on volatile organic compound (VOC) content as of January 11, 1999. These regulations affect autobody shops that are not already using low VOC coatings.
• Mineral spirits is a commonly used solvent for gun and parts cleaning because of its ability to quickly dissolve paint, oil, grease, dirt, and grime. Although it is effective for cleaning, mineral spirits raise significant environmental and human health concerns:
  • Mineral spirits contain VOCs that contribute to smog formation and may be toxic when inhaled.
  • Mineral spirits evaporate quickly, making worker exposure difficult to control.
  • Solvent cleaning units can be a facility’s greatest source of hazardous waste if not used properly.
  • Using mineral solvents can create unnecessary environmental, worker health, and fire liabilities for an auto body shop.
• If an auto body shop has to manage refrigerants, keep the following in mind:
  • It is illegal to vent chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs) into the atmosphere.
  • Federal regulations require that CFC-12 and HCFCs be recycled. However, it is acceptable to use in-stock, recycled, or remanufactured stocks of these chemicals.
  • All facilities servicing motor vehicle air conditioning systems must certify to EPA that they have acquired and are properly using approved CFC or HCFC recycling equipment.
  • EPA requires that facilities with refrigerant recycling equipment keep records of the name and address of the facility to which any refrigerant is sent for reclamation. These records must be kept for three years. The facility must also have records showing that all persons authorized to operate any recycling equipment are currently certified.

  For more information on CFCs and the automotive repair industry: www.epa.gov/ozone/title6/609/

• The EPA has determined that the discharge of commercial wastewater (other than from toilets, showers, etc.) is prohibited without a permit. Septic systems, cesspools, sumps, and floor drains are considered Class V Injection Wells and are regulated by the EPA (40 CFR Parts 144 and 146). http://www.epa.gov/safewater/uic/class5/pdf/guide_uic-class5_small_ent_compl.pdf