Autobody shop environmental compliance assistance
The DNR and the Small Business Clean Air Assistant Program (SBCAAP) collaborated with the Small Business Environmental Assistance programs in Illinois, Indiana, Michigan, Minnesota and Ohio to develop an Environmental Results Program (ERP) for the autobody refinishing shops in these U.S. Environmental Protection Agency (EPA) Region 5 states. The ERP project involved conducting baseline visits at shops to learn the areas where shops needed additional assistance in understanding how to comply with state and federal rules. A particular focus was on a new rule from the EPA affecting autobody shops nationwide. Based on what the states learned in the baseline visits, the following materials were developed to assist in the areas of greatest need.
Basics
Shop compliance checklist packets and training
The states have developed a common checklist with state specific tips on how to know whether you are in compliance with EPA's rule as well as state air, waste and water requirements. Completing the first part of the checklist (all "EPA - Rule" sections) will help you make sure you have met all the requirements in EPA's rule.
Based on complete responses collected from this checklist, the programs can develop additional tools to help shops ensure they comply.
Materials referenced in the checklist that provide additional information about particular requirements are linked in the specific state tabs on this page. Additional materials helpful to shops in any state are provided in the All states tab on this page, including resources for painter training.
Clarification on use of 3-ounce cups: Small amounts of any type of paint may be sprayed on the shop floor if spray gun cups 3 ounces or less are used. However, be aware that there are still OSHA requirements that would apply to this spraying of flammable solvents. Also, excessive amounts being sprayed using 3-ounce cups (i.e. a whole vehicle) may be seen by EPA as circumvention of the rule and a violation.
Step 1 - Complete the self-certification checklist
- Printable copies of the self-certification checklist are available in each state tab, in both Microsoft Word and Adobe PDF versions.
- Submit hard copies to the appropriate state SBCAAP for compiling results and follow-up assistance as needed.
- Facility-specific results will NOT be shared with regulatory agencies.
Step 2 - Complete and submit the Notification of Compliance Status Form
This form must be mailed to the EPA and states as indicated.
- For Indiana, Michigan, Minnesota and Wisconsin shops, submit the form in Microsoft Word [DOC] or Adobe PDF [PDF].
- Illinois and Ohio have their own forms linked in their specific state tabs on this page.
- Always keep a copy of anything you submit for your records.
Materials to help you complete the checklist
- Training video on using checklist [exit DNR]
- Waste Log [PDF] - mentioned in training video
- Waste Worksheet [PDF] - mentioned in training video
- State-specific resources are available in separate tabs on this web page.
All states
General materials for any state
EPA rule information
- EPA training video [exit DNR]
- EPA Rule FAQ [PDF exit DNR]
- Petition for Exemption form [DOC]
- Lists of paint manufacturers materials with HAPs [exit DNR] - on small biz enviroweb
- Lists of HVLP [DOC] and equivalent [DOC] guns
- Booth Filter Specs example [PDF]
Painter training resources
- EPA's example painter training certification form
- The shop owner can use any combination of classroom and hands-on training to complete the training for each painter, as long as all elements in training curriculum [DOC] are covered.
- Classroom options
- Hands-on options
- Contact your paint gun manufacturer - they may be able to send someone to the shop.
- Shop owner or technician with certified training can train others on techniques learned.
- EPA and/or state webinars [exit DNR]
Other online resources
- EPA DfE Auto Refinish Project [exit DNR]
- Virtual Auto Body Shop [exit DNR]
- STAR (Spray Technique & Research) [exit DNR]
- OSHA Auto Body Repair and Refinishing [exit DNR]
- NIOSH Alert on Diisocyanates [exit DNR]
- CDC/NIOSH spray finishing self-assessment [exit DNR] (focus on technical schools, but good for shops too)
Ill.
Illinois information and materials
Contact information
Illinois Small Business Environmental Assistance Program
Illinois DCEO
500 E Monroe, R-5
Springfield IL 62701
Phone: 800-252-3998
Email: dceo.sbeap@illinois.gov
Checklists and forms
- Self-certification checklist
- Notification of Compliance Status form for Ill shops [PDF exit DNR]
Air pollution
- Illinois Small Business Environmental Assistance Program brochure [PDF exit DNR]
- Ill. Factsheet for Autobody Shops on Paintstripping & Coating NESHAP [PDF exit DNR]
- Ill. Autobody Notification/ Certification/Registration Form [PDF exit DNR]
- Illinois Autobody Initial Notification Letter [PDF exit DNR]
- Ill. NESHAP Compliant Spray Guns List [PDF exit DNR]
- How Do I Manage Asbestos in my Building? [exit DNR]
Waste management
- How Do I Manage my Hazardous Waste? [exit DNR]
- Do I Have a Special Waste? [exit DNR]
- Does My Business Need Generator Identification Numbers and Manifests? [exit DNR]
- Conditionally Exempt Small Quantity Generator (CESQG) information [exit DNR]
- CESQG Certificate of Exemption [PDF exit DNR]
- How Do I Manage My Used Oil & Used Oil Filters? [exit DNR]
- How Do I Manage My Used Rags & Other Absorbents? [exit DNR]
- How to Manage Your Used Tires [exit DNR]
- How to Manage Used Fluorescent & High-Intensity Discharge Lamps as Universal Wastes [exit DNR]
Water
Other
Ind.
Indiana information and materials
Contact information
IDEM – OPPTA
100 N Senate Avenue
MC 60-04, IGCS W041
Indianapolis IN 46204-2251
Phone: 317-233-1039
Email: mstoddar@idem.IN.gov
Self-certification checklist
Air pollution
- Indiana Small Business Guide to Environmental, Safety, and Health Regulations - Air Chapter [PDF exit DNR]
- Initial Notification Form [PDF] for IN shops
Waste management
- Waste Inventory screening checklist [DOC]
- Making a Hazardous Waste Determination [PPT exit DNR]
- Waste-0005 Disposal of Empty Containers as Solid Waste [PDF exit DNR]
- Waste-0010 Management of Contaminated Wipes [PDF exit DNR]
- Waste-0034 Satellite Accumulation of Hazardous Waste by Generators [PDF exit DNR]
- SB Guide - Waste Chapter [PDF exit DNR]
Water
- Indiana Small Business Guide to Environmental, Safety, and Health Regulations - Water chapter [PDF exit DNR]
Mich.
Michigan information and materials
Contact information
Michigan Department of Natural Resources and Environment (DNRE)
Environmental Assistance Program
Phone: 800-662-9278
Email: ostrowskij2@michigan.gov
Self-certification checklist
Air pollution
- Paint Stripping and Miscellaneous Surface Coating at Area Sources [exit DNR]
- Fact Sheet: EPA Autobody Rule - Paint Stripping [PDF exit DNR]
- Fact Sheet: EPA Autobody Rule - Refinishing Motor Vehicles [PDF exit DNR]
Waste management
- Waste Characterization Guidance [PDF exit DNR]
- Conditionally Exempt Small Quantity Generator requirements [PDF exit DNR]
- To locate authorized disposal facilities
- Refer to the directory of hazardous waste disposal facilities [exit DNR].
- Query the Waste Data System (WDS) [exit DNR] for facilities accepting CESQG hazardous waste and universal waste handlers.
- Review the Recycled Materials Market Directory [exit DNR] for recyclers.
- Call 1-800-662-9278 for assistance.
- To locate an authorized transporter, refer to the Participating Transporters [exit DNR] list for the type of waste you are offering for transport
- To evaluate the compliance status of a vendor
- Query the Waste Data System [exit DNR] for facilities in Michigan.
- Query the U.S. EPA Enforcement & Compliance History On-line (ECHO) System [exit DNR] for facilities outside of Michigan.
Water
Contact the Michigan Department of Natural Resources and Environment at 1-800-662-9278.
Minn.
Minnesota information and materials
Contact information
Minnesota Small Business Environmental Assistance Program [exit DNR]
520 Lafayette Rd N
St Paul MN 55115-4194
Phone: 651-282-6143 or 800-657-3938
Self-certification checklist
Air pollution
- Environmental Guide for Small Business: Air Chapter [PDF exit DNR]
- Auto Body (6H) NESHAP Initial Notification Form [DOC exit DNR]
- MN Air Permit Application - Cover Page [DOC exit DNR]
- MN Air Permit Application - Facility Info [DOC exit DNR]
Waste management
- Minn. Hazardous Waste Rule [exit DNR]
- All Minn. Hazardous Waste Fact Sheets [exit DNR]
- Hazardous Wastes at Minn. Auto Body Shops - Table from Checklist [DOC exit DNR]
- Fact sheets
- Evaluate Waste; Determine Generator Size [PDF exit DNR]
- Label and Store Hazardous Waste [PDF exit DNR]
- Treat or Dispose of Hazardous Waste Correctly [PDF exit DNR]
- Train Employees [PDF exit DNR]
- Managing Waste Antifreeze [PDF exit DNR]
- Dry-cell Batteries [PDF exit DNR]
- Lead-Acid Batteries [PDF exit DNR]
- Managing Electronic Wastes [PDF exit DNR]
- Sewering Liquid Waste [PDF exit DNR]
- Evaluating Paint and Ink Wastes [PDF exit DNR]
- Managing Paint Booth Filters [PDF exit DNR]
- Towels, Wipes and Sorbents [PDF exit DNR]
- Managing Used Oil and Related Wastes [PDF exit DNR]
- Burning Used Oil [PDF exit DNR]
- Managing Universal Wastes [PDF exit DNR]
Water
- Met Council Environmental Services [exit DNR]
- Fact sheet: Water-quality Permit Requirements for Wastewater Discharges to Ground Surface and Subsurface [PDF exit DNR]
Other
Ohio
Ohio information and materials
Contact information
Office of Compliance Assistance and Pollution Prevention [exit DNR]
c/o Ohio EPA, Central Office
PO Box 1049
Columbus OH 43216-1049
Rick Carleski, 614-728-1742
Email OCAPP, include "autobody project" in subject line
Checklists and forms
- Self-certification checklist
- Notification of Compliance Status Form [DOC]
Air pollution
Waste management
- Identify Hazardous Waste [PDF exit DNR]
- Hazardous Waste Generator Handbook [PDF exit DNR]
- Read the relevant sections in the Environmental Compliance Guide for Auto Repair Shops [PDF exit DNR]
- Hazardous Waste
- Paint Wastes
- Solvent Contaminated Wipes
- Used Oil
- Antifreeze Recycling
- Lead acid Batteries
Water
- Read the relevant sections in the Environmental Compliance Guide for Auto Repair Shops [PDF exit DNR]
- Wastewater Discharges
- Floor Drains
Other
Wis.
Wisconsin information and materials
Contact information
WI SBCAAP
Bureau of Air Management - AM/7
Department of Natural Resources
PO Box 7921
Madison WI 53707-7921
Phone: 608-264-6153
Email: DNRCleanAir@Wisconsin.gov
Self-certification checklist
Air pollution
- SBCAAP Fact Sheet (AM-422) [PDF]
- Initial Notification Form for EPA Rule and Wis. Shops [PDF]
- Notification of Changes Report Form (future notification required on March 1 in year following any changes or deviation from rule requirements)
- Air Permit Exemption Fact Sheet for Autobody Refinishers (AM-425) [PDF]
- Autobody repair emissions PTE calculation worksheet [PDF]
- Motor Vehicle Refinishing RACT [PDF]
Waste management
- Step-by-step guide to categorizing wastes: DNR's Permit Primer - Solid Waste (start with solid waste and continue through hazardous waste)
- Wis. waste determination/inventory template [DOC]
- Waste Fact Sheets
- Paint Booth Filter and Still Bottoms (WA-035) [PDF]
- Used Antifreeze (WA-356) [PDF]
- Burning Used Oil (WA-1003) [PDF]
- Used Oil Management (WA-233) [PDF]
- Used Oil Filters (WA- 1522) [PDF] and Landfill Ban Q&A (WA-1503) [PDF]
- Used Oil web page at DNR) [PDF]
- Lamp and Bulb Management (WA-195) [PDF]
- Used Rags/wipes (WA-1207) [PDF]
- Labs who can test wastes: Wisconsin accredited laboratories - look for those conducting waste characterization tests
- Toxicity levels - after you get your test results back, check NR 661.24 [PDF exit DNR], Table 2 (page 28) to see if results are above levels.
- A quick reference toxicity table is also provided in the Permit Primer, but may not be as current as NR 661.
- Very Small Quantity Generator waste collection sites [exit DNR]
- Are you above 220 lb/mo of waste?
- Go to DNR's Waste & Materials Management Program forms and checklists for inspection checklists for Small or Large Quantity Generators to be sure you're meeting all requirements.
Water
- Wis. municipal POTW list
- Car rinse or wash water, NOT going to holding tank and/or sewer/treatment plant? You need coverage by DNR's general permit for car washing [PDF]
- Fact sheet on DNR general permits [PDF]
- Form to request coverage [PDF]
Other
Concerned about whether you meet OSHA requirements in your shop?
- Yes, OSHA does apply if you have just one employee!
- For a free consultation on OSHA requirements, contact WISCON, the Wisconsin Safety Consultation Program [exit DNR] (800-947-0553).
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