Pelican said:
I understand that Ecomike, as someone who is professionally involved in the chemical industry, has a valid reason for taking an interest in this proposed regulation. However, I skimmed the 126 pages and I don't see how this would impact me in the slightest except possibly adding a few bucks onto the cost of a professional paint job that I already can't afford.
As far as I can see this is aimed at facilities with annual particulate emissions in the tons and MeCl use in the hundreds of gallons. It appears "rattle can" sprays are not affected even by the professional shops and that many very small shops are exempted entirely although I may have misunderstood that point.
With respect to the massive intervention of the federal government in every conceivable aspect of our lives, while it may help us get through the day by venting on the various internet forums and to our friends and family, the fact is that without massive well organized and highly funded efforts, very few regulations or proposals such as this are going to be changed. Doesn't mean we shouldn't try.
Having said all that, I don't necessarily think this proposal, taken strictly on its own merits and not within the overall distrust of governmental regulations, is all that onerous.
Ecomike, please post back if I am missing the point as to how this affects us as
members working on our own vehicles.
Pelican,
Thanks for the comments,
I am still working my way through it, I am on page 52, but so far to answer some of your comments, Anything you buy that is ever painted, or that has painted parts in it could be affected, including its cost.
Regardless of what the reg was or is aimed at, it seems to me to cover anyone spray painting anything with any kind of spray rig using any kind of paint. Although exempting aerosols sounds noble, it might drive many of us to stop using any professional, low emission, low overspray equipment so we can still paint cheaply outdoors. EPA sometimes seems to be blind to unintended consequences like this.
In other words, if a farmer wants to re-paint his tractor out in the middle of no-where on a 50 acre trac of his own land, with a Binks 18 gun that he already owns, this regulation would prohibit that, unless he bought and used a paint booth ($30,000), bought and used an enclosed paint gun cleaner ($3,000), paid to get trained and certified by someone who has no credential requirements to be the trainer (note that anyone can be a trainer to train people that need training under EPA for R12 certification, or for DOT or Hazmat training like first responders, in other words their are no strict requiments for the trainers, just hang a shingle and start training and certifying people, it's BS, as it has no meat behind the trainer's credential requirements. :scared:
So I'd be pissed :flame:if had to pay someone to train and certifiy me to do something I am better qualified to teach than the trainer. Then if the farmer uses any paint stripper with MeCl, he would need to keep records to prove he used less 150 gallons in any one year. Oh, and the farmer would need to buy a new HVLP approved paint gun ($2,000-?) and scrap his Binks 18 gun and paint pot just to paint one tractor. So, onerous? Hell yes, Mr. Farmer would be quite pissed at Mr. Government inspector telling him to spend $40,000 on the entire set up before he could paint his tractor. Oh, and if you install a paint booth instead of painting outdoors, you need automatic fire protection equipment as well, so add say $5,000 for that.:bawl:
In Texas there is currently an exemption for limited outdoor spray painting, but this proposed new reg as I see it so far would end all outdoor spray painting. That Texas exemption does require a specific distance between the outdoor painting operation and neighboring properties, and limits the hourly, daily and yearly paint spray volume.
It appears to me that one would need to do the paper work to track MeCl usage to prove that one is not using over 150 gallons per year.They do not even define how usage is measured that I have read so far (I'm still reading).
Where did you see small shop exemptions? I am still looking for exemptions for people that spray only paints that do not contain the listed HAP metals?
Lastly, you would be amased at the effect that one well thought out clearly understood, well worded, public comment can have on a proposed regulation. I was involved in a 10 year battle with EPA's new MPM rule for waste water treament (basically requires waste water treatment for waste water that was used to clean any kind of metal parts now). One City waste water plant complained that the EPA's proposed rule to force industry to reduce the iron and alluminum concentrations in their waste water discharges (that came from their waste water pretreatment operations) to city waste water plants would simply cause the city waste water plants to buy and use more alluminum and iron salts in the precipitation stages of the city plants.
In other words the EPA had not bothered to find out if forcing industry to remove those two metals was even needed or desired by the Public Waste water treatment plants.That one comment had a huge effect on the rule, and those two metals were completely dropped from the final EPA rule on MP&M waste water discharge limits. (MP&M = Metal Products and Machinery category under the Clean Water Act, 40 CFR). On the other hand, I have seen govenment regs get issued that seem to excel at evidencing the potential stupidity of bureaucracies.:twak:
