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New Hampshire Department of Environmental Services

Frequently Asked Questions
for Auto Body Shops
  • Is NHDES requiring auto body shops to switch to waterborne basecoat by January 2012?
    No. NHDES is not requiring auto body shops to switch to waterborne basecoats. This rumor came about through a misunderstanding concerning a recommendation made by the Ozone Transport Commission (OTC) to its member states, including New Hampshire, to require collision repair facilities to convert to waterborne basecoat refinish systems by January 2012. New Hampshire has not adopted this recommendation.

    If you are approached by a vendor, supplier, or anyone else that you must switch due to waterborne coatings, please contact the Small Business Technical Assistance Program.

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  • Are auto body shops subject to Env-A 1400 Regulated Toxic Air Pollutants?

    Yes; however, auto body shops that perform spray coating operations are exempt from the requirements of Env-A 1400 if the following conditions are met:

    • The facility vents emissions from each spray booth/station through an exhaust stack that is vertical and unobstructed, meaning that there is no impediment to vertical flow and the stack extends at least 2 feet higher than any roofline within 10 feet of the stack exit, measured horizontally;
    • The facility is in compliance with federal regulation 40 CFR 63, Subpart HHHHHH; and
    • The facility uses less than 500 gallons per year of commercially available paints or coatings. The facility must maintain records of paint and coating usage on-site to confirm compliance with the usage limit.
    If a source cannot demonstrate compliance with the conditions of exemption listed above, it should contact NHDES regarding applicable permitting obligations.
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  • Does the NESHAP 6H rule require me to purchase a spray booth to paint vehicles?
    No, the NESHAP 6H rule does not require you to purchase a spray booth. However, all spray painting must be performed within an enclosure (roof, and walls or curtains) that is maintained under negative pressure so overspray is captured on a filter technology that is demonstrated to achieve at least 98 percent capture efficiency, as opposed to the overspray being exhausted into the air or landing on the floor of the shop. In addition, the spray painting “booth” must comply with local fire and building codes and OSHA standards.
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NH Department of Environmental Services | 29 Hazen Drive | PO Box 95 | Concord, NH 03302-0095
(603) 271-3503 | TDD Access: Relay NH 1-800-735-2964 | Hours: M-F, 8am-4pm

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