New Spray Applicator/Painter Training Requirements
New environmental regulations went into effect establishing national emission standards for hazardous air pollutants (HAP) for companies not currently associated with a “major source of HAP emissions”. Manufacturing processes affected by the new regulations include paint stripping operations and spray applications of coatings which contain any of the following HAP’s: chromium, lead, manganese, nickel, or cadmium. Some exemptions are part of the regulation, but many smaller businesses that were exempted before may be subject to this standard because there are no minimum usage quantities. It may be advisable to check your MSDS sheets and manufacturing processes to see if your company’s spraying or paint stripping operation uses any chromium, lead, manganese, nickel, or cadmium.
Some highlights of the requirements include an initial notification requirement for all existing and new startup operations and evaluations of paint stripping practices. One significant change affects all spray application painters who apply surface coatings containing the previously mentioned HAP’s; they must now receive training and certification for the proper spray application of surface coatings in addition to the proper setup and maintenance of spray equipment. The training includes items such as hands-on and classroom training, spray techniques, spray booth maintenance, and other environmental requirements. Spray application by individuals who are not certified will be prohibited. All spray-applied coatings must be in a spray booth, prep station, or mobile enclosure that meets the standards requirements. Painter training must be completed prior to January 10, 2011 and recurring at least every five years.
For more information: 40 CFR Part 63, Subpart HHHHHH