From another forum regarding my issue
I sent a request to the EPA for information about "are there any special rules for hobbyist auto painters?"
I just got very nice reply from Kim Teal, Environmental Protection Specialist, U.S. EPA, North Carolina (teal.kim@epa.gov)
I ASKED THE FOLLOWING QUESTIONS:
I would like to know where I can find EPA regulations related to “Hobbyist Automotive Painters”. I tried the
www.epa.gov website FAQ but could not locate any related information.
Is there a provision that allows a hobbyist to paint 1 or 2 cars per year? Are there simple guidelines for disposal of solvents, paints and for cleaning equipment? Do hobbyists need to be certified (licensed) in order to buy paint, etc?
Please provide a “link” to EPA Guidelines on Hobbyist Automotive Painting rules & regulations
Thanks in advance,
Bob Sheridan La Verne, CA 91750
KIM TEAL RESPONDED BACK AS FOLLOWS:
Mr. Sheridan,
The regulation you're referring to is actually for autobody refinishing shops; however, we had many questions about what activities qualify as hobbyist and so we added a definition to this rule clarifying what we consider to be hobbyist activities. See pages 1745 (last column),
COMMENTS: Several comments noted that the applicability of the proposed rule, as written, could be interpreted to apply to all paint stripping and surface coating operations, and included no exemptions for automobile hobbyists or homeowners stripping and painting their own property or vehicles. Nearly all commenters felt that paint stripping and surface coating by hobbyists and homeowners should be exempt from the rule. Several commenters suggested that EPA establish a de minimis usage threshold, based on either major source surface coating rules or state volatile organic compounds (VOC) rules, to exclude noncommercial paint stripping or surface coating operations. The commenters noted that hobbyist and homeowner activities are difficult to locate because they are located in residential areas and are intermittent. However, one commenter suggested that the rule should have no exemptions and any individual painting vehicles should be subject to the proposed equipment and training requirements.
RESPONSE: EPA re-examined the scope of the source categories that we listed based on the 1990 national emissions inventory. The analyses that were the basis for the source category listing for paint stripping, miscellaneous surface coating, and motor vehicle and mobile equipment surface coating focused on commercial operations, along with some government and institutional operations, such as municipal garages that service fleet vehicles. Homeowners and hobbyists were not part of these analyses and were not intended to be part of the listed source categories. Therefore, the final rule has been revised to clarify that it does not cover paint stripping and surface coating performed by individuals on their personal vehicles, possessions, or property, either as a hobby or for maintenance. This subpart also does not apply when these operations are performed by individuals for others without compensation, which is akin to the hobbyist and homeowner activities not considered in the baseline inventory that formed the basis for the listing of the source categories at issue here. However, for motor vehicle and mobile equipment surface coating operations, an individual surface coating more than two vehicles per year will be covered by the rule. This limit on the number of vehicles coated per year was included so that commercial automobile surface coating shops could not avoid compliance by claiming to be a hobby shop. The limit was based on information collected from automobile hobbyists during the rule development. The hobbyists that provided information to the EPA suggested that a legitimate hobbyist would complete no more than two automobile restorations or customizations per year.
* * * 1760 What This Subpart Covers § 63.11169 What is the purpose of this subpart? Except as provided in paragraph (d) of this section, this subpart establishes national emission standards for hazardous air pollutants (HAP) for area sources involved in any of the activities in paragraphs (a) through (c) of this section. This subpart also establishes requirements to demonstrate initial and continuous compliance with the emission standards contained herein. * * * § 63.11169 (d) This subpart does not apply to any of the activities described in paragraph (d)(1) through (6) of this section. * * * § 63.11169 (d) (3) Surface coating or paint stripping performed by individuals on their personal vehicles, possessions, or property, either as a hobby or for maintenance of their personal vehicles, possessions, or property. This subpart also does not apply when these operations are performed by individuals for others without compensation. An individual who spray applies surface coating to more than two motor vehicles or pieces of mobile equipment per year is subject to the requirements in this subpart that pertain to motor vehicle and mobile equipment surface coating regardless of whether compensation is received.
(See attached file: Final Paint Stripping and Misc Surface Coating Area Source Rule.pdf)
In summary, hobbyists have NO requirements under this rulemaking. They are NOT a regulated entity.
Please let me know if I can be of further assistance.
Sincerely,
Kim R. Teal Environmental Protection Specialist U.S. EPA/OAR/OAQPS/SPPD/NRCG E143-03 Research Triangle Park, NC 27711 EMAIL:
teal.kim@epa.gov DIRECT: (919) 541-5580
I hope some of you "hobbyist painters" such as me appreceiate having the latest information. I anyone wants me to send them the EPS .pdf file containg the "January 2009 Paint Stripping and Surface Coating Final Rule" send an email to me at
Bob5837@La.twcbc.com
Seems i'll be finishing my car this week afterall
