Surface Coating and Paint Stripping

Federal Rules Affecting Paint Stripping, Autobody Refinishing, and Miscellaneous Surface Coating Operations at Area/Small Sources

EPA 40 CFR Part 63 Subpart HHHHHH (6H)

(See rule)

Training Opportunities

Painters at your facility are required to have training and certification every 5 years. There are several options for training, some of which are presented below for your convenience:

Attention Required

All changes in a facility's operation or submitted information must be logged by December 31st of that year. For each change, the logged information must include the following:

  • date and time period of the change,
  • a description of the nature of the change and
  • the actions taken to correct the change.

The logged information must be submitted in an Annual Report to the appropriate air agencies by March 1st of the following year after the change(s).

No Changes to Report:

  • January 1st, note this information in your records.


Your APC Permit may require your facility to report this information at a certain date.

Record Keeping:

  • Keep copies of all Notifications, Logs, and Reports available at the facility at least 5 years (read permits for actual required time and form keeping data).
  • A Notice of Compliance is due by March 11, 2011
  • Sources in Shelby, Davidson, Knox and Hamilton Counties check with your local air program (Contacts)
  • If you have not submitted a notification stating facility compliance with 6H, then you should do so by March 11, 2011. - See sample compliance notification.
  • Letter of Explanation

For assistance or hard copies:

Contact the the Small Business Environmental Assistance Program’s at 1-800-734-3619 or by e-mail at [Attention: Surface Coating]


On January 9, 2008, the U.S. Environmental Protection Agency published rules to reduce air toxins including methylene chloride and other hazardous air pollutants (HAPs) from surface coating operations at area sources. The final rule is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, 40 CFR Part 63 Subpart HHHHHH (6H). See rule.

An Initial Notice was due January 11, 2010.

Who is affected by this Rule?

Area sources that conduct any of the following:

  • Paint stripping operations that use methylene chloride for the removal of dried paint.
  • Motor vehicle (Autobody) and mobile equipment spray coating operations
  • Miscellaneous surface coating operations (All of the following must apply):
  • Perform hand-held spray painting
  • Spray paint metal, plastic or a combination of the two
  • Use surface coating material that contain chromium, lead, manganese, nickel, or/and cadmium
  • If your facility does auto body painting, and you are exempt from the 6H rule, you must submit an Opt Out Petition. A Sample Opt Out Petition is available for your convenience. Note: even if you are exempt from the 6H rule, you may still be affected by State of TN volatile organic compound rules.

What are the Rule’s Exemptions? (Please check, you could be exempt!)

What is an Area Source?

An area source is a source that does not have the potential to emit more than the following:

  • 10 tons or more per year of a single HAP or
  • 25 tons or more of a combination of one or more HAPS or
  • 100 tons or more per year of a criteria pollutant

What are the significant rule requirements?

Spray painting must be conducted in a booth

  • Painters must use HVLP spray guns or equivalents
  • All painters must complete a training course on proper spray gun use and maintenance
  • Specific spray gun cleaning requirements
  • Paint stripping operations must implement management practices that minimize emissions of methylene chloride

Note — The Tennessee Technology Centers may offer hands on training classes required by the new air pollution control rule. Please visit to find the location nearest you.

What are the Rule’s compliance dates?

New Operations [started after September 17, 2007] (New)

  • Must be in compliance with the new rules upon start-up
  • Must submit an Initial Notification and Notification of Compliance Status no later than 180 days after initial start-up (Call 1800-734-3619 for additional new source information)

Existing Operations [started on or before September 17, 2007]