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Auto body and auto service shops generate hazardous wastes, air emissions, and wastewater and must comply with both federal and state regulations. Please note the regulations vary and applicability depends on the types of operations you perform at your shop, where it is located, and presence of municipal service for sewerage and drinking water.

For a comprehensive summary of requirements, see our Environmental Compliance Guide for Auto Repair Shops.

The tabs below present additional information and resources to assist in complying with regulatory requirements.

Air permits are needed for operations that emit air pollutants.  Examples of equipment that may need an air permit include paint booths, solvent parts washers, abrasive grinding or blasting operations, and gasoline dispensing pumps and tanks. However, not all of this equipment automatically needs a permit - it depends on the size of the equipment and the amount of pollutants (emissions) being released.

For all your shop's operations, you should look at the following three categories to see which operations are exempt and which may need an air permit:


De minimis exemption, OAC 3745-15-05 - If you can demonstrate that the equipment or operation does not emit more than 10 pounds per day of air pollutants, it is classified as a de minimis source of air pollution and does not need an air permit. However, you must keep records to prove your emissions remain below 10 pounds per day.

For paint booths, VOCs (volatile organic compounds) are released when painting or cleaning spray guns. You can calculate your daily emissions by multiplying the amount of paint and solvent you use each day by the corresponding VOC content of the material (from the Material Safety Data Sheet).

Examples of equipment that may meet the definition of de minimis include:

  • Low-usage paint booths (using about 1.5 gallons or less of total paint and solvent per day);
  • Used oil burners rated less than 500,000 Btu per hour (provided only used oil generated on the premises is burned);
  • Intermittent welding operations.

De minimis exemption guidance

Copy of OAC 3745-15-05 (De minimis source exemption) and example emission calculations and recordkeeping forms to document a de minimis exemption for a paint booth.

Listed exemptions – OAC 3745-31-03 lists more than 45 types of equipment that are exempt from permitting.

Examples of exempt equipment include:

  • Solvent recycling units less than 20 gallons capacity;
  • Self-contained abrasive blasting cabinets;
  • Solvent parts washers having a liquid surface area less than or equal to ten square feet and not using methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform;
  • Parts washers using detergent cleaners;
  • Grinding and machining operations having dust collection systems or no visible emissions;
  • Storage tanks less than 700 gallons;
  • Refrigerant reclaiming and recycling machines
  • Gasoline dispensing operations having a maximum annual throughput of less than 6000 gallons per year.

If you are claiming either the de minimis exemption or one of the listed exemptions, you do not need to notify or get approval from the Ohio EPA.

The PBR, OAC 3745-31-03(A)(4)(g), is a simplified installation and operating permit option available to certain auto body collision repair shops. To qualify for the PBR, shops must meet all of the following criteria:

  • The facility has two or fewer paint spray booths used for painting;
  • The facility does not do more than fifty jobs per week;
  • The facility does not use more than three thousand gallons combined of all coatings, solvents, and other volatile organic compound (VOC) containing materials in any calendar year;
  • The facility performs all painting operations in enclosed spray booth(s) which are designed to confine and direct the paint overspray, fumes, and vapors to a powered ventilation system and are equipped with either a dry filtration or water wash system(s) to capture paint overspray;
  • The facility applies any paint or coatings by one of the following means; high volume low pressure (HVLP) spray equipment, or electrostatic application equipment;
  • The exhaust stack(s) of each paint spray booth at the facility:
  1. Is equipped with a fan designed to achieve an exhaust flow capacity of at least ten thousand cubic feet per minute.
  2. Discharges air contaminants in a vertical direction, without obstructions like rain caps, goose neck exhaust, or other obstructions.
  3. Has a stack height which is at least sixteen feet, as measured from ground level to the point of discharge to the atmosphere.
  4. Has a point of discharge no closer than sixty feet to the nearest facility property line.

The PBR requires a shop to follow good housekeeping practices and to keep annual records of paint and solvent usage.  There is no cost to register under the PBR.

To obtain coverage under the PBR, you must complete and submit a simple, one-page notification form to Ohio EPA. Once Ohio EPA receives and approves your PBR request, you will receive a 10-digit air pollution facility ID number. You can look up your air pollution facility ID number on Ohio EPA's Web site.

Permit-by-Rule User's Guide for Auto Body Refinishing

This guidebook provides information on how to properly use and comply with the permit-by-rule (PBR) provisions for auto body refinishing facilities specified in OAC 3745-31-03(A)(4)(g). The PBR exempts small auto body refinishing shops from complex air pollution permits provided the spray booths meet certain design criteria and the company follows certain operating practices.

 Permit by Rule Form

 If you qualify for the permit-by-rule, use this form to register for permit by rule authorization to install and operate your auto body shop.  It includes instructions and a district office directory of where to send your form.

 Permit by Rule Web Page

 Division of Air Pollution Control web page for permit by rule information and registration lookup.

If you cannot use the exemptions or PBR, you must get an air permit, or PTIO per OAC 3745-31-02. You must apply for and receive your PTIO before installing and operating the equipment.  Please note that if you are already operating your business and discover that you need an air permit, you must still complete and submit PTIO applications.

The terms and conditions of your permit will usually have emission limits. In addition, the permit will outline monitoring, operating conditions and record-keeping requirements for your company. Once you get the permit, it is very important that you read and understand the terms and conditions contained in it.

Air permit applications are processed through your district Ohio EPA office or your local air agency.  If the Ohio EPA inspects your facility, the air inspector will focus on your compliance with the permit or permit-by-rule requirements.  It is very important you have the required records available for the inspector.

 PTIO Forms

 Facilities that are not de minimis and do not qualify for the permit-by-rule need a PTIO. The required forms are 3150a-Permit to Install and Operate Application and #3103 – Emissions Activity Category Form: Surface Coating Operation.  Note: One #3103 form is needed for each booth.  Other EAC forms may be needed for non-exempt equipment like boilers, l

 EPA District Offices

 Map of Ohio EPA District Offices and Local Air Agencies, by county, with addresses and contact information.  These offices process permits and do inspections.

National Emission Standards for Hazardous Air Pollutants (40 CFR 63, Subpart HHHHHH)

(Note: This federal EPA rule applies nationwide to shops spraying coatings or using paint strippers and cleaners containing methylene chloride)

 

Subpart HHHHHH Brochure (English)
 

Subpart HHHHHH Brochure (Spanish)

 

Explains requirements of the federal NESHAP rule
 
 

Frequently Asked Questions (FAQ) for 6H Rule

This helpful FAQ guide answers common questions about applicability, compliance and reporting for the NESHAP rule. Also contains supplemental contact information for Ohio.  Revised 2/15/11

 

NESHAP Initial/Compliance Combined Notification Form (Ohio version)

Ohio combined form covering initial notification and compliance certification for Subpart HHHHHH (English)

Due Jan 10, 2010

 

NESHAP Notice of Compliance Status (Ohio version)

Ohio form for certifying compliance with Subpart HHHHHH  

 Due March 11, 2011

 

NESHAP Petition for Exemption form

Generic form to apply to U.S. EPA for an exemption from the NESHAP rule. To qualify, you must certify you use no products that contain methylene chloride and no coatings that contain heavy metals (chromium, lead, nickel, manganese, or cadmium.)

 

EPA NESHAP Video & training

Link to EPA's Collision Repair Campaign’s training info and 20-minute video featuring NASCAR’s Jeff Gordon explaining the NESHAP rule requirements. (English and Spanish options) Contact OCAPP at 800-329-7518 for a copy of the DVD.

 

Compliance resource page for 6H rule

Link to resources from the network of state small business assistance programs. Contains paint manufacturer’s lists of paints containing heavy metals, lists of approved HVLP guns, and other state information.

 

U.S. EPA Area Source Rules Web Page

This web site contains the official rule language, notification form templates, implementation tools, and background information for numerous area source NESHAP rules promulgated by U.S. EPA.

 

 OAC 3745-21-18 - Commercial motor vehicle and mobile equipment refinishing operations.

 This rule specifies VOC per gallon limits for auto refinishing coatings, cleanup practices, and paint technician training. Applicable in the Akron, Cleveland, Cincinnati, and Dayton metro counties. (NOTE: These rule requirements are independent of the federal NESHAP rule)

 OAC 3745-17-11 - Particulate Matter Standards

 

Generally, this rule requires spray painting operations to employ booth enclosures and filters to control particulate overspray.  However, paragraph (A)(1)(k) of the rule exempts spray operations that employ hand-held cup spray guns from this requirement.  Note that the federal NESHAP 6H rule requires spray operations to be enclosed and to have 98% efficient filtration.  

Used Oil Regulations

Link to Ohio's regulations and related guidance for the proper management of used oil. 


Environmental Compliance Guide for Auto Repair Shops

 This guidebook summarizes some of the major environmental requirements that could apply to your auto body/repair shop and includes checklists to self-evaluate your operations. It provides you with a starting point to identify areas where you business might be subject to regulation. It may not cover every requirement and should not be used as your only source of information on the regulations.

Permit-by-Rule User's Guide for Auto Body Refinishing

This guidebook provides information on how to properly use and comply with the permit-by-rule (PBR) provisions for auto body refinishing facilities specified in OAC 3745-31-03(A)(4)(g). The PBR exempts small auto body refinishing shops from complex air pollution permits provided the spray booths meet certain design criteria and the company follows certain operating practices.

De minimis exemption guidance

Copy of OAC 3745-15-05 (De minimis source exemption) and example emission calculations and recordkeeping forms to document a de minimis exemption for a paint booth.


Wastewater Discharges

An auto repair shop may generate process wastewater from equipment cleaning, car washing, paint spray booths or other sources. Under Ohio EPA’s regulations, options for handling process wastewater include direct and indirect discharges.

Only sanitary waste and wastewater (from bathrooms and hand washing sinks) can go to an on-site sewage treatment or disposal system. Process wastewater containing chemicals, oils or other contaminants CANNOT go into an on-site system.

Ohio EPA’s regulations prohibit the discharge of process wastewater into injection wells without a permit. Examples of injection wells include dry wells, drain fields and cesspools. Septic tanks, mound systems or leach fields are defined as injection well systems.


Any discharge of industrial wastewater to “waters of the state” requires a discharge permit from Ohio EPA’s Division of Surface Water. This permit is called a national Pollutant Discharge Elimination System (NPDES) permit. Examples of waters of the state include streams, rivers, lakes, ponds, marshes, watercourses, waterways, wells and springs. Wastewater discharges entering a conveyance system (like a ditch or storm sewer) that leads to a waterway may also require an NPDES permit.

You may also be required to treat wastewater to remove harmful contaminants (for example, metals, chemicals, oils or grease) before it is discharged. If treatment is required, a separate permit is needed to construct wastewater treatment units, called a permit-to-install (or PTI). The PTI application is reviewed by Ohio EPA’s Division of Surface Water.

Often, the local publicly owned treatment works (POTWs) are responsible for regulating the companies that discharge wastewater to them. A large POTW may be able to handle the wastewater from your business. However, even large wastewater treatment plants are not generally designed to handle industrial wastes like chemicals, metals, oils, etc. They are designed to handle sewage related wastes and wastewater. Because of this, the treatment plant may require you to conduct “pretreatment” (for example, removal of metals, oil or grease, etc.) before discharging your wastewater to them.

If you want to discharge industrial wastewater to a local POTW, discuss it with the treatment plant directly. Permission to discharge to the POTW and/or obtaining a permit may be necessary. If you must construct wastewater treatment or storage units, a PTI from Ohio EPA is required.

Contact the Division of Surface Water at your local Ohio EPA district office for more information on the wastewater discharge and permitting requirements.

Many small businesses have floor drains. A common floor drain system can include a concrete trench that runs down the center of a shop floor. The trench is designed to capture water, cleaners, oil, dirt or other materials. Some shops have small rectangular or round floor drains connected to underground piping.

Some floor drains are necessary for day-to-day operations. Others are used for emergency purposes only.  And some floor drains don’t seem to have any apparent use. Do you know where the floor drains in your business go? Are you discharging wastewater or other fluids into your floor drains?

It is very important that you know where all your floor drains lead, and are aware of Ohio EPA’s regulations that apply to your dis-charge activities. If you do not know where your drains lead, or if you are using floor drains improperly, you could be contaminating nearby surface waters or drinking waters.

Some floor drains lead into a sanitary sewer, where wastewater goes directly to a POTW. Other floor drains lead to an on-site sewage treatment system like a septic tank. Sometimes floor drains lead directly to an underground holding tank or discharge to a waterway or to the ground outside. Ohio EPA’s water pollution control regulations apply to all of these activities.

Any company that wants to discharge industrial wastewater to waters of the state needs to obtain a NPDES permit from Ohio EPA. If your floor drains lead to any water of the state, you must have a discharge permit for this activity.

Companies that discharge industrial wastewater directly to a POTW are also regulated. Often, the POTW regulates the dis-charge activities. If you are discharging to a POTW, you need to contact the plant to discuss your activities. You may be required to obtain a permit for the discharge. In addition, you may be required to treat the wastewater before discharging (for example, oil/water separation, removing solids, chemicals, etc.).

If you have a floor drain which leads to an injection well, you are subject to Ohio’s underground injection control (UIC) regulations. The UIC regulations are in place to protect underground drinking water sources from becoming contaminated. If you are discharging industrial wastewater to a floor drain that leads to a septic system or other injection well system, you could be in violation of Ohio’s water pollution control laws. Examples of injection wells include dry wells, drain fields and cesspools. In addition, a floor drain that is tied to a septic tank, mound system or leach field is defined as an injection well system.

Under Ohio EPA’s water pollution control regulations, a company cannot discharge industrial wastewater into an injection well. This activity is strictly prohibited unless a company has obtained a permit to drill and a permit to operate (UIC permit) from Ohio EPA’s Division of Drinking and Ground Waters. This includes discharging industrial wastewater to an on-site sewage treatment system (for example, a septic tank or leach field). Not only would this activity without a permit be a violation, the discharged materials (chemicals, solids, oil, etc.) could also damage your on-site system.

The use of some disposal wells has been completely banned, including the use of motor vehicle waste disposal wells.

  • Check all your floor drains and make sure you know where they drain.
  • If you are using floor drains to discharge industrial wastewater into a septic system or onto the ground, you must stop these discharge activities immediately. You must find another way to manage your wastewater.
  • If you are using floor drains to discharge industrial wastewater to a water of the state, and you do not have an NPDES permit, you must stop these discharge activities immediately. You must either obtain a permit or find another way to manage wastewater.
  • If you are using floor drains to discharge wastewater to a local wastewater treatment plant, make sure the treatment plant knows about this activity. You may be required to conduct treatment on the wastewater before discharging it. You may also need to get a permit for the discharge.
  • Do not put other fluids like oil, solvents, paints or chemicals into a floor drain. This could contaminate your property and lead to large fines and cleanup costs.
  • Consider installing an emergency shut-off on the drain pipes to prevent accidental spills from entering the sewer.
  • If you have floor drains at your company that you are not using, think about having them capped or plugged. Good housekeeping and planning can help avoid costly problems later.

If you have any questions about floor drains and Ohio’s water pollution control requirements, contact your local Ohio EPA district office, Division of Surface Water (DSW) for assistance.

Contact Ohio EPA’s Division of Drinking and Ground Water, UIC Program at (614) 644-2752 for more information about injection wells.

Any business generating wastes must evaluate them to determine if they are hazardous wastes under Ohio’s EPA’s regulations. There are specific regulations on how hazardous waste needs to be handled at your shop. There are also recordkeeping requirements.

Common wastes generated by auto body and auto service shops include:

  • Spent solvents
  • Waste paints and thinners
  • Still residues/bottoms (sludge)
  • Solvent contaminated shop rags
  • Paint booth filters
  • Discarded chemicals
  • Used oil and filters
  • Used antifreeze
  • Lead acid batteries
  • Scrap tires
  • Fluorescent bulbs (lamps)

Some of these may be hazardous wastes mainly because they are ignitable, corrosive, or contain high enough concentrations of heavy metals such as lead, cadmium or chromium.  All hazardous wastes must be sent off site to a permitted hazardous waste disposal facility and cannot be thrown in the dumpster.

See the Environmental Compliance Guide for Auto Repair Shops for more detailed information on these wastes and proper disposal requirements.

The best way to “Go Green” and reduce pollution is to prevent it in the first place. Pollution prevention can range from low-cost improvements to changes in equipment and operating practices. These changes can also reduce energy and utility costs.  Below are some ex¬≠amples of the many pollution prevention options for auto body and auto service shops.

  • Keep ALL solvent containers closed to limit evaporation
  • Avoid use of coatings that contain toxic metals (chromium, lead, cadmium, nickel, and manganese) by asking suppliers for alternative formulations
  • Use Paintless dent repair techniques
  • Avoid use of methylene-chloride based paint strippers
  • Use an automatic enclosed gun washer
  • Use water-based or low-solvent coatings (primers, basecoats and painting)
  • Use low-VOC solvents or thinners
  • Employ a two-stage solvent cleaning procedure:  Wash first with used solvent, then wash with clean solvent.  When first wash solvent no longer cleans, replace with second wash solvent, replace second wash solvent with fresh solvent, recycle first wash waste solvent.
  • Recycle solvents with on-site distillation unit or off-site recovery service
  • Have an inventory system (first-in, first-out) in place to prevent products from going out of date
  • Use computerized paint mixing system to minimize mistakes/over-mixing
  • Use non-solvent based putty/fillers
  • Reusable aerosol or pump spray containers
  • Use a disposable paint cup system to minimize unused paint and emissions
  • Use a ventilated sander or self-contained media plaster to minimize emissions from preparing parts
  • Employ wet sanding techniques
  • Use Roll-on Primer
  • Turn on paint booth only when necessary
  • Keep booth lights clean
  • Change booth filters regularly to ensure good airflow (which reduces draw on HVAC motors)
  • Select variable speed drives and motors for paint booth fans
  • Use heated air recirculation
  • Purchase new or replacement energy efficient equipment (motors, fans, lighting, spray guns)
  • Install timers/motion sensors on booth lighting to reduce energy use
  • Install specialized controls (timers, motion sensors) that turn off or throttle back lights, heat, or equipment when areas are not occupied and/or in use
  • Install programmable thermostat for heating/cooling
  • Install efficient fluorescent lights (T-8 or better)
  • Encourage employees to turn off lights with reminder signs
  • Clean light fixture reflectors to increase available light
  • Reduce lighting intensity where acceptable
  • Take advantage of day-lighting if possible
  • Complete an energy audit/aware of monthly electricity/fuel use
  • Insulate building, windows and hot/cold ducts or pipes
  • Use electric tools like shop-vacs or blow dryers instead of the compressed air system
  • Purchase energy efficient office products/machines (computers, copiers, etc.)
  • Regularly check  compressed air system for leaks and repair all leaks found 
  • Regularly check  air compressor to ensure the pressure setting isn’t higher than it needs to be
  • Do a quick leak check:  Walk along compressor pipes/hoses right after turning off the compressor, and listen for hissing.  Keep a record of whether the compressor cycles on and off frequently when not in use.  A ¼-inch leak can cost you $2,800 per year.
  • Consider buying an ultrasonic leak detector.  Many are inexpensive and can save about $500/year for each leak repaired.
  • Think about whether the air compressor is properly sized for your foreseeable future needs.  Every 2 PSI reduced can save you 1% in electricity usage and cost.
  • Consider individual turbines for HVLP or small electric tools for specific purposes like buffing or sanding.  It may be preferable for certain types of high-CFM pneumatic equipment.

If you have gasoline dispensing operation on site, please see our Gasoline Dispensing page for more information.

U.S. EPA regulates how freon is handled from motor vehicle air conditioners. The rules also set standards for freon recovery and disposal.  The Clean Air Act prohibits venting freon into the atmosphere.

Technician Training

Technicians who recover freon from motor vehicles must be trained and certified by a U.S. EPA-approved organization. Training must include instruction on the proper use of equipment, regulatory requirements, importance of refrigerant recovery and the effects of ozone depletion. To be certified, technicians must pass a test demonstrating their knowledge in these areas. A list of approved testing programs is available from the U.S. EPA ozone hotline and Web site.

Approved Equipment

Technicians who service motor vehicles must use U.S. EPA-approved equipment for refrigerant recovery and recycling. Recover/recycle equipment cleans the refrigerant so that contaminants like oil, air and moisture reach acceptably low levels. A list of approved recovery and recycling equipment is available from U.S. EPA’s ozone hotline and Web site. Service shops performing recovery/recycle operations must certify to U.S. EPA that they own approved equipment.

Disposal and Recordkeeping

Freon recovered from vehicles must either be sent off-site to a reclamation facility or recycled on site. For any recycling done on site, there are specific procedures in the regulations that you must follow. For refrigerants sent to a reclamation facility, you must keep records, including the name and address of the reclaimer.

U.S. EPA’s Ozone Protection Program Hotline: 800-296-1996

www.epa.gov/ozone/index.html

If you need help financing equipment that reduces air pollution, such as buying more efficient spray painting equipment or filtration units, contact:

Ohio Air Quality Development Authority’s Clean Air Resource Center (800) 225-5051 or (614) 224-3383www.ohioairquality.org

The Clean Air Resource Center (CARC) is an independent, non-regulatory state agency. CARC is not part of the Ohio EPA. CARC does not enforce air quality regulations. Instead, CARC helps businesses meet EPA air regulations while also reducing costs and gaining tax exemptions.

CARC provides loans to help businesses finance air pollution control or prevention projects, for example, new dry cleaning machines with cleaner emissions. In addition to loans, they also provide small business grants to cover the closing costs of financing pollution control projects. 

Answer Place

 Ohio EPA's tool for frequently asked questions.  Search key word "auto body".

Publications Catalog

 List of Ohio EPA publications relevant to auto bodyshops.

CCAR  Web site for the Coordinating Committee for Automotive Repair (CCAR) Green Link.  Has useful tools for EPA and OSHA compliance, virtual shop guides, etc.