Region 5 ERP Checklist

Updated 3/2011

Region 5 Autobody ERP – Survey Instrument for EPA Inspections

KEY:

Boldface Font – Spoken question

Normal Font – Site visit record/contacts and response options

Italics – Instruction for inspector (not spoken)

Facility Information
Facility Unique project ID
Facility Name
Facility Address
Name of Facility Contact Person
Telephone number of Facility Contact
Facility in EJ Area? [Y/N and why]
Survey Contact Info
Date of Visit
State/EPA
Name of Inspector
Phone

Baseline Visit Script

If you wish to call ahead to confirm shop is actively painting:

Hi. My name is ___________________________ and I am from the USEPA Region 5. We are …confirming shops that are affected by a federal rule that is now effective. Are you the person I should talk to, or is there an owner or manager who could better answer my questions?

[Reintroduce if transferred to another person.] Thank you for speaking to me. First, I would like to confirm whether you are the type of shop that may be impacted by the rules.

Do the operations at your shop include spray painting vehicles or parts of vehicles with a spray gun?

___ Yes  Ask next question.

___ No  No need to schedule a visit. Track as a “DROP” on the sample list. Read paragraph A.

Do you use ONLY spray guns (including those spraying primer) with 3oz cup size or less?

___ Yes  Could DROP, or visit to confirm. If dropped, track as a “DROP” on the sample list and explain why.

___ No  Read the scheduling script in B:

A. Thank you, but it appears you are not affected by the air toxics rule that we are focusing on at this time. If you would like information on other environmental requirements, I can put you in contact with your state environmental assistance program.

B. As a shop that does spray painting, you may be affected by a number of regulations and in particular the new EPA rule. [Anything else to say since not prearranging for a time?]

On site - Introduction

Hi, my name is [interviewer name]. Is (name of contact) available? [If not available…] Is there another person I should speak to about environmental issues, usually related to use of paints, solvents and disposing of wastes, in your shop? (The ideal respondent is the person from the shop who keeps up with environmental requirements, is familiar with shop set up and operations, and perhaps receives information through training or attending workshops or manages the operations of the shop.)

Hi (name of contact). I am from the USEPA Region 5 office. We are conducting an inspection to check whether you comply with the new rule on autobody refinishing shops. As part of that inspection, I will be going through a survey related to environmental practices at autobody shops.

It will take us about 1 – 2 hrs to talk about these environmental issues and walk through the shop. While we do that, I will be asking a series of questions to complete our survey. Is there an office, or a place where we can sit to go over some of the basic questions first?

It works best to go through all interview questions up front in a quiet office area and then ask to be shown through the shop for observations. Sections A through G = in office. Section I = Walk through questions. If time seems limited (shop owner seems rushed) you may prioritize the questions in order of (1) Basic Info and Air regulatory [A-C & I1 – I8], (2) HW and WW Regs (D-E, I9-I15), (3) BMPs [F-G]. Section A is critical for categorizing the results of the project in the final analysis – DO NOT skip any of those questions unless prompted.

SECTION A: INTRODUCTION

Instructions and Tips

A1. Which of the following categories best describes your role at this shop? (read categories):

___ Owner

___ Manager

­­­___ Technician who applies spray coatings

___ Another role (specify)__________________________________

A2. What type of services does your shop provide? (mark all that apply)

___ Auto mechanical repair ___ Salvage Yard

___ Autobody shop ___ Car dealership

___ Mobile Paint Service ___ Car wash

___ Other (explain):_________________________________________

A3. Did your shop start coating vehicles or parts after September 17, 2007?

___Yes

___No

Defined as a new affected source, and compliance was due Jan 8, 2008.

Mainly, brand new shops only ones affected by this definition. Adding a new booth doesn’t make whole shop “new”, but new booth must meet rule requirements when installed.

A4. How many employees and paint technicians (or anyone who may paint) do you have in your shop?

___ # employees (total at shop)

___ # paint technicians

# employees means total for shop, including owner/manager and office staff

MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR AS PAINT TECHS.

A6. a. Referring to point of sales reports or information from your supplier, how much of each of the following materials have you used or purchased in the last few months?  [12 months preferred]

	Gallons	# mo
(i) Solvent-based (high VOC) coatings
(ii) Water-based coatings (<2 lb/gal VOC)
(iii) High-VOC cleaning solvents
(iv) Low-VOC cleaning solvents
(v) Liquid paint strippers – MeCl
(vi) Liquid paint strippers – non-MeCl

This information may be used to calculate the environmental improvement achieved in the next few years by you and your fellow auto body shops as a group.

________________________________________________

c. Were numbers provided in A6a obtained through accurate records? (Answer NO if estimates.)

___ Yes

___ No

VERY important to get accurate numbers for purposes of making emissions estimates or reduction estimates at the end of the project

Most shops use computerized mixing systems. If, upon inspection, person knows how to use computer, this information can be obtained easily.

Option to just ask for print out from supplier/vendor of 6-12 months of purchase records and calculate at a later time.

A7a. What are your total paint hours from the past few months? [12 months preferred; enter # months]

___________ hours per ______________# mo

b. Were numbers provided in A7a obtained through accurate records? (Answer NO if estimates.)

___ Yes

___ No

[More easily tracked by shops than jobs.] Take six months if that’s all they can get, but 12 months will be a better average across the year.

A8. Do you do any paint work using a gun with 3ounce cup or less?

___ Yes

___ No

If yes, please describe the types of job and frequency: _________________

________________________________________________________________

Useful to capture for future training and providing information on when/where using 3 oz cup is acceptable – if any limitations exist.

That’s about ½ of a Styrofoam coffee cup

SECTION C: EPA NESHAP

Instructions and Tips

SPRAY BOOTH/PREP STATION QUESTIONS

When we walk through the shop, it would be helpful if you could show me your spray booth and exhaust filter system.

C1. a. Does your shop have a spray booth?

___ Yes

___ No  Skip to C2

b. How many spray booths do you have? ______

Answer YES for anything they consider a “booth”—I1 will capture description.

C2. a. Do you have a prep station/area where coatings are applied on vehicle components?

___ Yes

___ No  Skip to C3, or if NO to both C1 and C2 skip to C5

b. How many prep stations/areas do you have?

________

Answer YES if any area besides booth used for painting. I3 will capture description.

Booth or Prep Station Name/ID	% coatings/jobs in booth
i. Booth 1
ii. Booth 2
iii. Booth 3
iv. Booth 4
v. Prep 1
vi. Prep 2
vii. Prep 3
viii. Prep 4
Other: (describe)

C3. a. What is the estimated percentage of spray coatings that are applied in each spray booth versus any prep stations or other areas in the shop?

Note: these are estimates and will be used for informational purposes

C3. b. Did your shop first begin using each enclosure to apply coatings on or before Sept 17, 2007?

c. If any enclosure (paint booth, walled prep area) was installed after September 17, 2007, was the installation due to the new area source NESHAP regulations?

C3	b.	c.
Booth/Prep name/ID	Enclosure used on or before 9/17/2007?	Installed to meet rule?
i. Booth 1	Yes / No	Yes / No
ii. Booth 2	Yes / No	Yes / No
iii. Booth 3	Yes / No	Yes / No
iv. Booth 4	Yes / No	Yes / No
v. Prep 1	Yes / No	Yes / No
vi. Prep 2	Yes / No	Yes / No
vii. Prep 3	Yes / No	Yes / No
viii. Prep 4	Yes / No	Yes / No

Any new booth added to existing source, booth must be in compliance with NESHAP – ONLY booth is treated as new source, not whole facility.

b. Mark an X in the box that applies for each enclosure

c. Please note if companies that purchase and install equipment to comply with the area source NESHAP, this would not make an existing source a new source per 63.11171(c)(1). If they just happened to install or start new operations, then needed to comply by Jan 8, 2008 or upon start up.

C4. a. Is each spray booth/prep station ventilated with an exhaust fan?

___ Yes

___ No 

(i) ____ out of _____ booths/prep areas have an exhaust fan

b. Does your exhaust system have a filter system?

___ Yes

___ No  Skip to C5

CA note: Define that general building with multiple prep areas and wall fan may not be enough for compliance. A small room designed to meet same booth specifications could be OK depending on the exact circumstances.

Depending on what EPA says about determination of room as a booth, we may tweak this instruction.

Regardless of issue above, capture what exists without evaluating compliance in a and b.

Enter answers in table below.

c. Is the filter capture efficiency rating of your exhaust/filter system at least 98 percent?

d. Is the documentation related to the capture efficiency of your exhaust and filter system present and available for review?

e. When was the filter system first used at your shop?

Booth ID/Name	c. Capture >=98%	d. Docs?	e. Date first used
i. Booth 1	Yes / No / Don’t Know	Yes / No
ii. Booth 2	Yes / No / Don’t Know	Yes / No
iii. Booth 3	Yes / No / Don’t Know	Yes / No
iv. Booth 4	Yes / No / Don’t Know	Yes / No
v. Prep 1	Yes / No / Don’t Know	Yes / No
vi. Prep 2	Yes / No / Don’t Know	Yes / No
vii. Prep 3	Yes / No / Don’t Know	Yes / No
viii. Prep 4	Yes / No / Don’t Know	Yes / No

f. Do ALL of the booths meet the exhaust/filter requirements in C4 at this time?

___ Yes

___ No

Enter responses for c-e in Table at bottom of question.

If respondent is unsure of answers, note that this information would typically be found on the filter package or provided by the distributor. If not purchased directly, but through a subcontractor they may need to get in touch with them to make sure what they have.

Must show % efficiency.

Acceptable proof of eff% = reference to EPA rule or list basic test criteria, even if Method not written down:

• uses a high solids bake enamel

• delivered at a rate of at least 135 grams per minute from a conventional (non-HVLP) air-atomized spray gun

• operating at 40 pounds per square inch (psi) air pressure, and

• the air flow rate across the filter shall be 150 feet per minute

We’ll consider documentation complete if it includes: test parameters OR references the 6H rule OR the ASHRAE method.

Watch out to be sure documents match brand of filters in use, if possible.

SPRAY GUN CLEANING

When we walk through the shop, it would be helpful if you could show me the gun cleaning area and operations.

C5. a. Is all paint spray gun cleaning done with a fully enclosed spray gun washer or in a manner that avoids creating a mist of solvent?

___ Yes

___ No

b. If you answer YES to C5a, identify which method(s) are used:

___ Fully enclosed spray gun washer

___ Fully enclosed spray gun washer and occasionally disassemble and clean by hand

___ Flush with solvent (but don’t spray)

___ Clean disassembled gun by hand or through mechanical methods

c. If you answer YES to C5a, when was this spray gun cleaning approach first used at your shop?

____________ (specific date)

d. If you answered No to C5a, how do you clean your guns?

___ Spray coatings and/or solvent through the gun

___ Other (specify) _________________________________________

Using air compressor to quick dry guns after cleaning not relevant to rule, but may increase VOCs…

PAINT STRIPPING

When we walk through the shop, it would be helpful if you could show me the paint stripping operation.

C6. a. Do you use chemical products for paint stripping tasks?

___ Yes

___ No  Skip to C9

b. Do any of the chemical products you use for paint stripping contain Methylene Chloride?

___ Yes

___ No, based on shop knowledge/review  Skip to C9

___ No, after reviewing materials (MSDS or can) at visit  Skip to C9

Some likely brands: StripRDry, Booth Floor Stripper (both made by CMA Philadelphia); Airplane stripper;

Might be used in restoring old cars to take off layers, otherwise unlikely to need solvents – just sanding.

Also known as di-chloromethane (DCM) or methylene dichloride – CAS # is 75-09-2

What if shop uses MeCl to clean tables? Does rule apply to cleaning? YES, since no exemptions are mentioned in the rule – only whether MeCl is used.

C7. a. Do you have records related to your shop’s use of paint stripping products containing MeCl?

___ Yes

___ No

b. If there is documentation, how much product containing MeCl is used annually?

______ Gallons per year (as supported by documentation)

Material usage or purchase records. How many gallons of product do you use?

C8. a. Does your shop have a minimization plan for use of MeCl?

___ Yes

___ No

b. If you use more than 2000 pounds (~150 gallons of MeCl) per year, do you have the minimization plan written and posted where paint stripping is conducted?

___ Yes

___ No

If yes, Field Staff examines documentation.

Plan should include:

• Evaluate need to remove paint

• Evaluate each application for alternatives: (non- or low-; blasting; mechanical; thermo)

• Reduce MeCl stripper exposure to air

• Optimize to reduce evaporation during use

• Proper storage and disposal techniques

If below 150 gallons, considering options for how they are using it and if they can eliminate it.

PAINT FORMULATION/DOCUMENTATION

C9. a. Does your shop have Material Safety Data Sheets (MSDS) and coating formulation data supplied by the manufacturer for ALL the solvents and coatings that you use?

___ Yes

___ No

Electronic versions will be acceptable if they are easily available to employees.

C10. a. Do the coatings used by your shop contain any of the following hazardous air pollutants: chromium, lead, cadmium, nickel, or manganese (includes compounds of these metals)?

___ Yes

___ No

___ Don’t know

b. If you answered No or Don’t Know, have you asked your supplier whether you have the HAPs in the paint?

___ Yes

___ No

Example of MSDS sheet that shows formulation data.

If they answer No or Don’t know, you could review a few MSDS:

red/orange/yellow – lead, chromate

blue/green – cadmium

primer – chromates for corrosion resistance

Capture whether they’ve attempted to determine if HAPs are present by discussion with supplier, in place of field staff going through to determine.

EPA RULE FOLLOW UP

C11. Before this visit, did you know you are affected by the new EPA rule that affects autobody shops and other small paint shops? This standard applies to businesses that coat parts and vehicles and use coatings that contain chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) or use paint stripping materials that contain methylene chloride.

_____ Yes

_____ No

_____ Don’t Know

This is not meant to make a determination, but to gauge their understanding at this point in time. Some may still be completely in the dark about the rule…

C12. a. Are you aware that autobody shops may be able to petition out of new requirements by changing the paints they use?

_____ Yes, I am aware

_____ Yes, I have submitted the petition or received my exemption

_____ No

_____ I would like more information on how to petition out.

b. To petition out you must certify that you do not spray apply any coatings containing chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd)) or compounds containing these metals. Given this information, do you intend to:

• Definitely stop using coatings containing these materials and petition out.

• Explore alternate coatings from your supplier and decide at a later time.

• Continue using coatings containing these metals and comply with the rule.

• Not sure

You can you petition out of coatings requirements but still have to comply with MeCl

C13. a. Have you submitted an initial notification form (due Jan 10, 2010) to USEPA and the state, where required?

___ Yes

___ No

b. Have you submitted a notification of compliance status form (due Jan 10, 2011) to USEPA and the state, where required?

___ Yes

___ No

[Illinois, Wisconsin, Ohio required; Indiana is requesting copies]

[I1 – I8]

SECTION B.i: EPA Rule TRAINING	Instructions and Tips
B2. a. Have ALL your paint technicians been trained in proper selection, use, maintenance of spray equipment, and the requirements of the rule, within the proper time frames? ___ Yes ___ No  (i) If no, How many? ___ out of ___ paint techs have been trained	Add proper time frames tips to answer accurately. MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR. Baseline timelines: Existing – 1/10/11. New – within 180 days of hire or shop start up, whichever is later; may go back 5 years for equivalent training
b. Has the training addressed and/or included the following regarding spray equipment? (read responses; check all that apply) (i) Hands on and Classroom: ___ Spray Gun Selection and Set Up (including measuring viscosity, selecting proper fluid nozzle or tip, achieving proper spray pattern, air pressure and volume, and fluid delivery rate) ___ Spray gun use – (spray technique for different types of coatings to improve transfer efficiency and minimize coating usage and overspray, including maintaining the correct spray gun distance and angle to the part, using proper banding and overlap, and reducing lead and lag spraying at the beginning and end of each stroke) ___ Maintenance (booth and filter - including filter selection and installation) (ii) Classroom: ___ Environmental requirements in federal NESHAP	Hands on training resources vary: paint suppliers (Dupont, PPG), jobbers, associations, tech colleges, etc. BRING A LIST of resources? [But no official approval of training.] “Hands on” will mean some amount of actual practice with a gun, for selection, setup and use, but we will not judge the time spent on hands on. OECA is making a determination of extent of “hands on” definition. Owner or painter can watch DVD online and certify that they watched it/been trained for that piece. May want to have alternate video available. Michigan has video training online.
c. Do you have records on technicians trained on the use of spray equipment? ___ Yes ___ No c.(i) Capture who is trained, and whether equivalent work experience is being used, based on records: ___ All technicians have been properly trained. ___ Some (but not all) technicians have been properly trained or trained on all but environmental requirements ___ None of the technicians has been properly trained ___ Some technicians using equivalent work experience #: ___ of ___ d. Are there any specific reasons paint technicians have not been trained on ALL of the topics? ___ Yes ___ No - Skip to Section C. e. If yes to B2d, what are some of the reasons technicians have not been trained? ___ no locations close by ___ costs ___ timing was bad (describe:_____________________) ___ unaware of training requirements ___ other: ___________________________________________ _______________________________________________________	Field Staff may examine documentation (certificates, dates, places) to determine whether or not the spray technicians have been properly trained (meaning they have been trained in all areas listed in question B2b. above). MAKE SURE AND INCLUDE “BODY” GUYS SPRAYING PRIMERS ON THE FLOOR. 30 year expert still has to provide proof of experience. “Owners and operators who can show by documentation or certification that a painter’s work experience and/or training has resulted in training equivalent to the training required in paragraph (f)(2) of this section are not required to provide the initial training required by that paragraph to these painters.” Document how training has met each of the elements.

END EPA REGULATIONS…MOVE ON TO STATE REGULATIONS.

SECTION H: COMPLIANCE ASSURANCE	Instructions and Tips
H4. a. Have you already received some information on this rule? ____ Yes ____ No  Skip to H5 ____ Don’t know  Skip to H5 If yes, then how and from whom? b. How: ___ Mailing/written materials ___ Videos – training or “fact sheets” ___ E-mail messages/documents ___ Web training ___ Web site ___ Facebook/twitter/YouTube ___ On site visit ___ Training sessions/workshops ___ Other (specify:______________________________________________) c. From whom: ­___ Coating manufacturers or suppliers ___ Corporate environmental division ___ Educational institutions (vocational technical school, community college, specialized training center, etc.) ___ Environmental consultant ___ Other auto body shops ___ Local government (town, city, or county) ___ OSHA ___ Small Business Environmental Assistance Program ___ State environmental agencies ___ Suppliers – equipment/other ___ Trade association ___ U.S. EPA ___ Other (Specify)________________________________________ ___ Don’t know
H5. a. Has your shop been inspected or visited by a government environmental or health and safety official? ____ Yes ____ No  Skip to H6 ____ Don’t know  Skip to H6 b. What type of government official inspected or visited your shop? (check all that apply) ___ EPA ___ State ___ Local government (environmental, health or fire department) ___ OSHA ___ Other (specify) ________________________________________ ___ Don’t know/Cannot recall
H6. Is there any other information about your shop's operations that you'd like to share before we walk through the shop together? Comment:

Now, I would like to walk through the shop.

(The order of these questions may have to be rearranged based on the set up of the shop.)

SECTION I: WALK THROUGH

[I1 – I8 confirm compliance with NESHAP]

Instructions and Tips

I1. a. May I see your spray booth(s)?

Check all that apply to each booth ID’d:

Booth ID (separate column for each booth)	(i) Booth1	(ii) Booth2	(iii) Booth3	(iv) Booth4
Fully enclosed - roof, 4 sides (down draft or similar)
Not fully enclosed, but has:
no roof, 4 sides
roof, 3 sides
no roof, 3 sides
roof, 2 sides
no roof, 2 sides
no roof or sides (open space)
Booth has exhaust fan
Other notes:

b. Is there evidence that at least some spray coating occurs outside of a spray booth?

___ Yes

___ No

___ Not sure (Field Staff describe:_______________________

_______________________________________________________)

c. Do the spray booths ALL meet the requirements in I1 at this time?

___ Yes

___ No

Comments:

Check off booth description and mark whether exhaust present for each booth.

Rule requires booth to have four complete side walls or curtains and a complete roof if large enough to fit a whole vehicle. Only new operations (after 9/17/07, and not done to meet rule) must comply at baseline.

Nothing in rule that says exhaust has to be outdoors, but it does need to be outside the booth (space where painting is taking place, however defined). For now, a space (garage, shed, or other) can be considered a “booth” if doors are kept closed during painting and:

• Negative pressure is maintained with sufficient make-up air, proper filtration, and venting

• Positive pressure if space has downdraft, proper filtration, and venting to outdoors

• No evidence of paint particulates outside openings

If parts are not removed, then full vehicle has to be painted in full booth (four walls/fully enclosed)

OECA is making determination on whether small building is “booth” enclosure.

I2. May I see the filter on the spray booth exhaust? Is the filter in good condition? Look for rips or gaps in the filters; check to see if the filters appear to be clogged with paint residue or dust.

Answer YES if booth has waterwash system in place of dry filters. May not be able to see filter within waterwash system to answer “condition” question. May be installed on enclosed, positive pressure downdraft booths.

Booth ID	a. Has Filter?	b. Condition? (write in good or poor; NA if no filter present)	c. Exhaust pressure (positive or negative to room)
i. Booth 1	Yes / No
ii. Booth 2	Yes / No
iii. Booth 3	Yes / No
iv. Booth 4	Yes / No

d. Do the spray booth exhaust/filter systems ALL meet the requirements in I2 at this time?

___ Yes

___ No

Comments:

Field Staff performs visual inspection of booth and filter and determines whether or not there is a particle filter on the exhaust.

Note to Field Staff: you may see a wall fan and small box with filter. Waterwash booths will not have the same type of filters to observe.

If the filters are not in good condition, Field Staff should ask the shop to revisit manufacturer’s recommendation.

Good = not Poor. Poor will be pretty bad, e.g. holes, rips, gaps, no air movement at all.

Power up booth to evaluate pressure.

Positive only allowed for “downdraft” designed booth – fully enclosed, hard walls, and exhaust in floor.

Anything else must have negative, even 4 curtains and roof with air inflow above and exhaust at floor level. Negative should be “felt” standing at openings.

Mobile operation/enclosure should be observed as well. Try to see it, even if not in operation.

When looking at filters, look for evidence of painters clearing guns into the filters. This would look different than any patterns left on the filters by protective grates.

I3. a. May I see your prep station(s)/area(s) where painting is done?

If no prep station/area(s) present, skip to I5.

Check all that apply to each area ID’d:

Prep Area ID (separate column for each area/station)	(i) Prep 1	(ii) Prep 2	(iii) Prep 3	(iv) Prep 4
Fully enclosed - roof, 3 sides
Not fully enclosed, but has:
no roof, 3 sides
roof, 2 sides
no roof, 2 sides
no roof or sides (open space)
Prep area has exhaust fan
Other:

b. Do the prep stations/areas ALL meet the requirements in I3 at this time?

___ Yes

___ No

Comments:

Field Staff performs visual inspection to confirm that prep station/area(s) is enclosed and ventilated.

Rule requires for motor vehicle and mobile equipment subassemblies, any coatings must be spray applied in a booth with a full roof and at least three walls or side curtains. Only new operations (after 9/17/07, and not done to meet rule) must comply at baseline.

Remember that painting part(s) of a car without disassembling from the whole car requires the whole car to be painted inside a 4-walled booth.

“Spot” painting with an encircling ring which draws spray into the ring and then directs it through proper filtration is permitted by the rule.

I4. May I see the filter on the prep station(s)/area(s) exhaust? Is the filter in good condition? Look for rips or gaps in the filters; check to see if the filters appear to be clogged with paint residue or dust.

Prep Station/Area ID	a. Has Filter?	b. Condition? (write in good or poor, or NA if no filter)	c. Exhaust pressure (positive or negative to room)
(i)	Yes / No
(ii)	Yes / No
(iii)	Yes / No
(iv)	Yes / No

d. Do the prep station/area exhaust/filter systems ALL meet the requirements in I4 at this time?

___ Yes

___ No

Comments:

Field Staff performs visual inspection of pipe and filter and determines whether or not there is a particle filter on the exhaust

Note to Field Staff: you may see a wall fan and small box with filter.

If the filters are not in good condition, Field Staff should ask the shop to revisit manufacturer’s recommendation.

Doesn’t have to be exhausted outdoors, but it does need to be outside the booth (space where painting is taking place, however defined).

Negative should be “felt” standing at openings – even at 3 wall booth, should feel breeze, papers flap toward back of booth, something.

May be good to have hand out for facilities to what to do.

I5. Field Staff: Is lighting in the booths/paint areas clean of paint residue, besides what may be present from the most recent job?

___ Yes

___ No

Based on own observations. Overspray may be indication of poor ventilation.

I6. a. May I see the spray guns you have in the shop? (Check all that apply, or if multiple of same gun, fill in separate lines; include guns not in regular use but available)

Spray Gun	Manufacturer/ Model (X = if gun is stamped HVLP)	Have Docs? Y/N
HVLP (High Volume Low Pressure)	1.
	2.
	3.
	4.
	5.
	6.
HVLP Equivalent	1.
	2.
	3.
	4.
	5.
	6.
Electrostatic
Airless spray gun
Air assisted airless
Conventional (non-compliant)
Other:
Don’t know

b. Do they have only compliant spray guns, based on the requirements for 6H, available for use at this time?

___ Yes

___ No

Comments:

Field Staffs: Look for “HVLP” stamped on the body of the spray gun. If no stamp is visible, air flow of 15-26 cubic feet per minute and PSI at orifice of less than 10 lbs, or at inlet of less than 40 lbs is likely to be an HVLP spray gun. You can also look at purchase records or manuals for indicators of whether a gun is HVLP or not. May want to take HVLP list along with us.

DO NOT EVALUATE HVLP GUN STATUS BASED ON USE OR TECHNIQUE. Not in the scope of the project.

Look at all guns, even if not used. RECOMMEND removing any non-approved guns.

Rule preamble does indicate CA approved guns are OK for HVLP-equivalent. We will use those, and anything else would need separate EPA approval to qualify.

• Conventional: >40 psi and spray 10-12 inches away from vehicle.

• HVLP: <40 psi and spray 8-10 inches from vehicle.

Strong recommendation that any non-compliant guns should be removed from shop by next year compliance deadline.

Manufacturer/Model: only enter info if unsure of HVLP/equivalent status – if shop say it is but not on list or stamped. Just check box if HVLP is obvious.

Documentation: answer yes or no if document was presented for an HVLP equivalent gun. (List of guns provided separately.)

I7. May I see the gun cleaning area, operations? Explain to me what you do here.

Field Staff observes cleaning procedures and categorizes cleaning technique:

___ Uses a fully enclosed spray gun washer

___ Uses a fully enclosed spray gun washer and occasionally disassembles and cleans by hand

___ Flush with solvent (but don’t spray)

___ Spray coatings and/or solvent through the gun

___ Clean disassembled gun by hand or through mechanical methods

___ Other (specify) _____________________________________

Look for any evidence of painters clearing paint from guns into the ventilation hoods or other areas with or without filters.

Not required by rule (possibly by OSHA?), but we can suggest that air flow from above and behind the cleaning station/technician to below and in front of the station/technician (drawing fumes away from the technician’s face).

I8. a. Does chemical paint stripping occur in the shop?

___ Yes

___ No  Skip to I9

b. If yes, ask: May I see the products you use for paint stripping?

Examine products for ingredients with methylene chloride. Do they contain MeCl?

___ Yes, products with methylene chloride are used

___ No, products with methylene chloride are not used

Look at MSDS sheets and/or cans. May want to note whether response matches office visit response.

• Also known as di-chloromethane (DCM) or methylene dichloride

• Chemical Abstracts Service (CAS) Registry Number is 75-09-2

• Advice for you and shops: read the label or MSDS and don’t trust your sense of smell (you may only start smelling MeCl at 200 ppm)

Thank you for your time.

Close inspection as appropriate.

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