Paints and Allied Products Manufacturing

Return to the Small Business Environmental Assistance Program (SBEAP) Main Page

The Environmental Protection Agency (EPA) published the rule for National Emission Standards for Hazardous Air Pollutants for Area Sources: Paints and Allied Products Manufacturing on December 3, 2009. The rule impacts manufacturers of paints, inks, adhesives, stains, varnishes, shellacs, putties, sealers, caulks, and other coatings. Areas sources do not emit, or have potential to emit, more than 10 tons per year of a single hazardous air pollutant (HAP) or more than 25 tons per year of any combination of HAP.

  • Owners or operators of an area source facility that performs paints and allied products manufacturing which are generally produced from raw materials by physical means, such as blending and mixing, as opposed to chemical synthesis means, like reactions or distillations.
  • Facilities that process, use, or generate materials containing one or more of the following hazardous air pollutants (HAPs): benzene, methylene chloride, compounds of cadmium, chromium, lead, and nickel.
  • Products that do not leave a dried film of solid material on the substrate, such as thinners, paint removers, brush cleaners, and mold release agents.
  • Electroplated and electroless metal films.
  • Raw materials such as resins, pigments and solvents used in the production of paints and products.
  • Resin, which is covered by the chemical manufacturing area source NESHAP standard. However, facilities that manufacture resins and coatings must comply with both rules.
  1. New operations must submit an Initial Notice and Notice of Compliance no later than 180 days after initial start-up.
  2. A particulate control device must be used to capture particulate emissions while adding dry pigments and other solids that contain compounds of cadmium, chromium, lead, or nickel to a process vessel or milling and grinding equipment.
  3. During the grinding and milling of materials containing compounds of cadmium, chromium, lead, or nickel at least one of the following control techniques must be performed:
    1. particulate emissions must be captured and route to a particulate control device, or
    2. grinding and milling equipment is fully enclosed, or
    3. must ensure pigments and solids are in the solution.
  4. Limit visible emissions from control device to 10% opacity for particulate control devices that vent to the atmosphere. This requirement does not apply to particulate control devices that do not vent to the atmosphere.
  5. Performance tests must be performed on required particulate control devices per rule instructions.
  6. A lid or cover must be used on any process vessel that contains benzene or methylene chloride and the lid or cover must maintain contact along at least 90 percent of the rim.
  7. Leaks and spills of materials containing benzene or methylene chloride must be minimized and cleaned up as soon as practical, but no longer than 1 hour from the time of detection.
  8. Rags or other material that contain solvents that include benzene or methylene chloride must be kept in a closed container.