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40 CFR 63 Subpart HHHHHH covers facilities that strip paint using Methylene Chloride (MeCl) and/or spray-applied coatings that contain cadmium, chromium, lead, manganese, and/or nickel.  “Spray-applied coating operations” covers two separate types of facilities:

  1. Motor vehicle or mobile equipment operations (i.e. body shops)
  2. Miscellaneous surface coating. 

Requirements for MeCl Stripping Operations

For paint-stripping operations using Methylene Chloride, facilities must implement management practices that minimize emissions of MeCl, including:

  • Evaluate the need for paint stripping (e.g., is it possible to re-coat without stripping?).
  • Evaluate each application to identify potential alternative stripping methods.
  • Reduce exposure of strippers to air.
  • Optimize application conditions.
  • Practice proper storage and disposal.

Those facilities using more than 1 ton of Methylene Chloride annually must develop a written MeCl minimization plan.  All facilities must maintain records of annual usage of paint strippers containing MeCl.

Requirements for Surface Coating Operations

Facilities that spray-apply coatings containing any of the targeted HAP metals must comply with the following:

  • Train and certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance.  Painters must be trained and certify within 180 days of hire, or by January 10, 2011.
  • Install and operate filter technology on all spray booths/stations/enclosures to achieve at least 98% capture efficiency.
  • Spray booths/stations used to refinish complete motor vehicles or mobile equipment must be fully enclosed and ventilated at negative pressure or up to 0.05” water gauge positive pressure for booths that have seals on all doors and other opening and an automatic pressure balancing system.
  • Spray booths/stations used to coat miscellaneous parts or products or vehicle subassemblies must have a full roof, at least three complete walls or side curtains, and be ventilated so that air is drawn into the booth.
  • Spray-applied coatings must be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology
  • Paint spray gun cleaning must be done so that an atomized mist or spray of the cleaning solvent is not created outside a container that collects used gun cleaning solvent.

Petition for Exemption

Facilities that only spray-apply coatings that do not contain the targeted metal HAPs can petition OAQC and the EPA for exemption from the requirements of this rule.  In this petition, the facility must certify that it does not spray-apply coatings that contain any of the targeted HAPs, and must provide information on the coatings that are spray-applied.  Download a copy of the Petition for Exemption form.

Compliance Dates:

Existing Facilities January 10, 2011
New Facilities July 7, 2008 or 180 days after startup

Notification Dates:

Initial Notification Existing Sources: January 11, 2010
New Sources: July 7, 2008 or 180 days after startup
Notification of Compliance Existing Sources: March 11, 2011
New Sources: As part of initial notification
Annual Notification of Compliance All sources: March 31st of each year – submitted to OAQC; must submit Notification of Changes to both OAQC and EPA if any reportable changes occurred in previous calendar year

Notification Forms:
Initial Notification/Notif
ication of Compliance
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Annual Notification of Compliance
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Petition for Exemption
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*If you have trouble reading or accessing these documents, please contact OAQC at 402-444-6015.*

Useful Links:
EPA published 6H brochurepdf symbol
e-CFR for 40 CFR 63 Subpart HHHHHH
NDEQ Air Toxics Notebook page for 6H
EPA's Collision Repair Campaign page

*The City of Omaha cannot guarantee the accuracy or accessibility of any document published by outside agencies.*