A “√” next to a response in the guide indicates that is the preferred response in terms of environmental compliance. If you select a response without a “√”, you may still be in compliance; however, you should verify that you are in compliance by contacting the appropriate federal or state regulatory agency and discussing your activity with them.

AUTOMOTIVE PAINTING

Does the facility conduct painting/paint removal operations?

The collision repair and paint shop should be painting in appropriate areas within the shop, i.e., paint booths. Note: The facility should verify that there are no drains in the areas where painting occurs.

Yes--Facility conducts painting/paint removal operations.

No--Facility does not conduct painting/paint removal operations.

Does the facility have air permits?

State or local air quality authorities usually issue air pollution permits for certain operations, i.e., automotive painting operations. Check with your state or local air quality authority for applicability and specific requirements.

Yes--Facility has air permits and they are current.   √  Permit No(s) ______________________________.

No--Facility has not obtained air permits.

N/A--Permits are not required.

If "yes" to previous question, does the facility meet air permit conditions?

Yes--Facility is meeting all air permit conditions.  √

No--Facility is not meeting air permit conditions.

N/A--Permits are not required.

Does the facility prepare vehicle surfaces by shot or grit blasting, grinding or sanding?

Yes--Facility uses one of the above methods.

No--Facility does not use one of the above methods.

N/A--Facility is not preparing surfaces for painting at this time.

Does the facility collect paint chips and metal dusts?

An effective practice to assure the optimum collection of paint dusts and chips is to blast and sand within a booth designed with a dust collection control device (e.g., baghouse). Blasting, grinding or sanding operations indoors without dust collection and air pollution controls may expose employees to levels of airborne dust in excess of the OSHA permissible limits for personal exposure to heavy metals, such as lead and cadmium. Conducting operations outdoors allows dust and paint debris to disperse into the environment. Local and state air pollution regulations may not allow this. Check with your state or local air quality authorities.

Yes--Facility collects paint chips and metal dusts using appropriate equipment.  √

No--Facility does not collect paint chips and metal dusts.

N/A--Facility does not conduct paint removal operations.

How does the facility manage stripped paint chips and baghouse dusts?

All materials collected from shot and grit blasting and sanding/grinding operations may be classified as hazardous waste, depending on the previous paint coatings. If the previous paints contained lead or chromium, the waste chips and dusts may be hazardous waste, depending on Toxicity Characteristic Leaching Procedure (TCLP) test results.

Recycle--Facility recycles materials on-site or ships them to a recycling facility.  √

Landfill--Based on waste characterization, facility disposes materials at a municipal or hazardous waste landfill.  √

Other--Method of disposal is not listed here.

N/A--Facility does not have these wastes.

Paint labels or product data sheets (or material safety data sheets [MSDSs]) should contain the VOC (volatile organic compounds) content of the paint. In general, VOC content greater than or equal to 5 lbs/gallon is high, between 4 and 5 lbs/gallon is low, and below 4 lbs/gallon is very low. In some areas, the automotive paint shop may be restricted to only low VOC paints. Check with your local or state air quality authority.

Yes--Facility uses paints with VOC content less than 5 lbs/gallon.  √

No--Facility uses paints with VOC content of 5 lbs/gallon or higher.

N/A--Facility does not have painting operations.

Does the facility prepare paint (quantity) according to the job?

To minimize leftover paint, the shop should calculate the amount of paint needed for each scheduled job, as opposed to preparing a large quantity of paint. If there is a little paint leftover, the shop might consider giving the leftover to their customer for touch-up.

Yes--Facility prepares paint by the job.  √

No--Facility prepares paints in large batches.

N/A--Facility does not have painting operations.

Does the facility take measures to minimize overspray?

Automotive painting shops can use a variety of application equipment to minimize overspray, i.e., air-assisted; airless, high-volume, low pressure turbine; air atomized electrostatic; and airless, or electrostatic application techniques. Another technique is the use of high transfer efficiency spray applicators. High efficiency sprayers should have a label “HVLP” on the gun. This is not yet a federal regulatory requirement but may be required in your state.

Yes--Facility takes measures to minimize overspray.  √

No--Facility does not take measures to minimize overspray.

N/A--Facility does not have painting operations.

When not in use, does the facility store paints in labeled containers?

When not in use, the automotive shop must ensure that paints are properly contained and labeled. The containers must be closed with tight-fitting lids, and stored so that a spill would not reach a drain or otherwise leave the facility. Container labels must indicate contents.

Yes--Facility contains and labels paints as described above.  √

No--Facility does not contain and/or label paints as described above.

N/A--Facility does not store paints.

How does the facility manage used paints and paint waste?

The automotive paint/collision shop should not bury or discard waste paint cans, residuals, or unused paint products on-site. Organic solvent-based paints and residuals may be hazardous wastes and require manifesting, storage, transportation, and disposal in full compliance with hazardous waste regulations.

Aerosol cans that are empty and depressurized (i.e., all propellant is discharged) may be classified as nonhazardous solid waste for off-site disposal.

Reuse--Facility gives away leftover paints and thinners to customers, employees, or at “paint swaps.”  √

Recycle--Items are recycled by a paint recycler.  √

Landfill--Based on waste characterization, facility disposes of paints at a municipal or hazardous waste landfill.  √

Mix with other fluids--Facility mixes materials with other fluids (solvent, used oil).

Drain--Facility pours leftover paint down the drain. Warning: This practice must be stopped immediately.

Other--Method of disposal is not listed here.

N/A--Facility does not generate these wastes.

How does the facility dispose of spray paint booth air filters?

The automotive paint shop must characterize their spray booth air filters. Depending upon the results of the characterization, hazardous or non-hazardous, the shop must dispose the filters accordingly. Filters characterized as non-hazardous can be disposed as a solid waste and into a municipal landfill. Filters characterized as hazardous must be managed as a hazardous waste.

Dispose as hazardous waste--Facility disposes filters containing hazardous paints as hazardous waste.  √

Recycle--Facility sends nonhazardous filters to a recycling facility.  √

Landfill--Facility sends nonhazardous filters to a landfill.  √

Other--Method of disposal is not listed here.

N/A--Facility does not use filters.