Steps to Comply with Regulations
On December 14, 2007, The Environmental Protection Agency issued a final rule for area sources titled, National Emission Standards for Hazardous Air Pollutants (Subpart HHHHHH): Paint Stripping and Miscellaneous Surface Coating Operations.
First you must determine if your shop falls under these regulations. EPA 6H Regulatory Navigation Tool and EPA Brochure (PDF)
If you determine that you fall under these rules, you must submit an Notification of Compliance Status to the appropriate EPA regional office. This notification is also located in the links column of the left.
Requirements of Regulations
- All spray painting must be done in a spray booth, preparation station or mobile enclosure. All paint booth filters are required to attain a minimum of 98% capture efficiency.
- You must use HVLP, Electrostatic, Airless, Air-assisted airless or other spray technology that has been demonstrated and approved to achieve equivalent transfer efficiency.
- Spray gun cleaning should prevent atomizing cleaning solvents and all solvents used to clean spray guns should be properly contained.
All spray painters should be trained and certified. In order to meet this requirement:
- Have your painter(s) complete and submit the online training course.
- Conduct hands-on training of your painter(s) practicing the techniques outlined in the hands-on training presentation.
- Checklist for conducting Hands-on-Painter Training
- Verify completion of both online and hands-on training in the company administrator dashboard and download a certificate of completion.
Please see the NESHAP for additional information on rule applicability and exemptions at 40 CFR Part 6, Subpart HHHHHH. The NESHAP also applies to paint stripping operations that use methylene chloride (MeCl) to remove dried paint from wood, plastic, metal or other substrate. A separate fact sheet summarizing the paint stripping
requirements is available for download here (PDF)paint stripping operations that use methylene chloride (MeCl) to remove dried paint from wood,plastic, metal or other substrate. A separate fact sheet summarizing the paint strippingrequirements is available at
You must also keep accurate and up-to-date records of the following:
- Documentation of spray booth filter efficiency.
- Painter training certification.
- Records of all notifications and reports required in this rule.
- If using spray gun other than HVLP, Electrostatic, Airless or Air-assisted airless, you must have documentation from the spray gun manufacturer that the gun meets equivalent transfer efficiency requirements.
IWRC Online Painter Training provides training on painting technique, equipment setup and booth maintenance as partial fulfillment of NESHAP 6H painter training/certification requirements. Other training and certification options exist. For guidance on other training options, please contact your state small business assistance program listed at: