Auto body shop
There are several state and federal regulations affecting auto body shops in Wisconsin. Among these is the EPA's area source rule for paint stripping and miscellaneous surface coating operations. To help newly regulated shops comply, the Small Business Environmental Assistance Program (SBEAP) developed a comprehensive environmental checklist and other tools to help the industry understand these and other existing regulations.
State air regulations
- Air Permit Exemption for Autobody Refinishers (SB-103)
- Automobile Refinishing RACT (SB-104)
- Auto body repair emissions calculation worksheet (SB-303) [XLS]
EPA Regulations
- Area source rule for paint stripping and miscellaneous surface coating (including auto body refinishing)
- Area Source Rule for Paint Stripping and Miscellaneous Surface Coating Operations (SB-105)
- Watch the EPA training video to learn more about the rule and satisfy one of the training elements required in the rule. If you need the video in Spanish, contact the EPA at the address on the EPA training video webpage and a DVD will be mailed to you that has both English and Spanish versions of the video.
- Auto Body Shops may petition EPA to be exempt from the rule if they meet certain conditions. To help you better understand if you meet those exemption criteria, EPA created a Reg Nav Tool. If you qualify for the exemption, submit a petition to EPA. You can use the R5ERP Example Petition for Exemption from 6H (SB-527) [DOC].
- As of May 9, 2023, instead of submitting a petition to EPA the shop may simply submit a notification that they do not spray coatings that contain any of the target hazardous air pollutants (HAP). EPA has the right to inspect records on the coating HAP content at any time.
- Lists of R5ERP HVLP Gun List (SB-530) [DOC] and R4ERP HVLP-equivalent Spray Gun List (SB-531) [DOC]
- R5ERP Booth Filter Specification Example (SB-532)
- 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 the EPA as circumvention of the rule and a violation.
Submitting the notification of compliance status form
There is an example form for the R5ERP Notification of Compliance Status for 6H (SB-528) [DOC]. However, shops that have not submitted the Notification of Compliance Status form, shops submitting a notification that they do not use any coatings with the target HAPs or a new shop complying with the rule for the first time, must now file all documents electronically with EPA through their Compliance and Emissions Data Reporting Interface (CEDRI) which is accessed through the Central Data Exchange (CDX). For more information on how to register for the EPA's CDX and CEDRI, go to CDX.
- Step-by-step guide to categorizing wastes: DNR's Permit Primer - Solid Waste (start with solid waste and continue through hazardous waste)
- R5ERP Waste Inventory Sheets (SB-533) [DOC]
- Waste Fact Sheets
- Spray Painting and Coating Operations (WA-299)
- Burning Used Oil in a Space Heater (WA-1003)
- Used Oil Management (WA-233) [Used oil includes: motor oils, greases, emulsions, machine shop coolants, antifreeze, heating media, brake fluids, transmission fluids, other hydraulic fluids, electrical insulating oils, metalworking fluids and refrigeration oils.]
- Managing Automotive Engine Used Oil Filters (WA-1522) and Used Oil Filters and Absorbents Landfill Ban Questions and Answers (WA-1503)
- Safe Lamp and Bulb Management (WA-195)
- Management of Solvent-Contaminated Wipes (WA-1207)
- Recycling motor oil, oil filters and other automotive products
- Labs that 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, Table 2 (page 28) to see if results are above levels.
- Are you above 220 lb/mo of waste?
- Go to Hazardous waste forms and checklists for inspection checklists for Small or Large Quantity Generators to be sure you're meeting all requirements.
- Facilities conducting Vehicle Maintenance and Repair (WA-1578) (Mantenimiento y reparación de vehículos (WA-2011)) will have specific waste issues to consider.
- Current WPDES wastewater permit holders
- Car rinse or wash water, NOT going to a holding tank and/or sewer/treatment plant? You need coverage under the DNR's Low-Impact Discharge general permit or potentially an individual wastewater permit.
- Complete the eligibility questionnaire to determine if coverage under the general permit is appropriate.
- Review the fact sheet that summarizes the requirements in the permit.
- Other materials, including links to the Notice of Intent form and Best Management Practice plan, are available on the General Permits webpage.
The DNR and the Small Business Environmental Assistance Program (SBEAP) collaborated with the Small Business Environmental Assistance programs in Illinois, Indiana, Michigan, Minnesota, Ohio and Wisconsin to develop an Environmental Results Program (ERP) for the auto body refinishing shops in these EPA Region 5 states.
The DNR was awarded a State Innovation Grant by the EPA to conduct the Auto Body ERP in partnership with the other Region 5 states. The ERP project involved measuring environmental performance at shops to learn the areas where additional assistance was needed for the shops to understand how to comply with state and federal rules. The final Grant Report to EPA Region 5 summarized the results of the effort to measure environmental performance among auto body shops in Region 5 states. The study found that 18 out of 25 measures showed statistically significant improvement in performance on the EPA auto body rule. For more details, read the final grant report: Region 5 Autobody Refinishing Shops ERP Grant Report (SB-520).
Shop compliance checklist packets and training
The state SBEAPs developed a common checklist with state specific tips on how to know whether your shop is in compliance with the 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 assess whether you have met all the requirements in the EPA's rule. For materials referenced in the checklist for other states go to the state program links below. Additional materials helpful to shops in any state are provided on this page, including resources for painter training.
Materials to help you complete the self-certification checklist
- Training video on using checklist
- R5ERP Waste Log (SB-534) - mentioned in training video
- R5ERP Hazardous Waste Worksheet (SB-535) - mentioned in training video
Using the self-certification checklist
Printable copies of the self-certification checklist are available the individual states linked below, and they are available in both Microsoft Word and Adobe PDF versions.
Illinois
- R5ERP Illinois Self-Certification Checklist - Word (SB-526-W)
- R5ERP Illinois Self-Certification Checklist - PDF (SB-526)
For regulatory information, go to the Illinois SBEAP page on Autobody and Spraycoating.
Indiana
- R5ERP Indiana Self-Certification Checklist - Word (SB-525-W)
- R5ERP Indiana Self-Certification Checklist -PDF (SB-525
Visit IDEM's Collision Repair/Auto Refinishing Shops page for more information on Indiana specific requirements.
Michigan
- R5ERP Michigan Self-Certification Checklist - Word (SB-524-W)
- R5ERP Michigan Self-Certification Checklist - PDF (SB-524)
Review information on topics such as air pollution, waste management, wastewater at Michigan's Environmental Assistance Center web page: Automotive collision repair facilities.
Minnesota
- R5ERP Minnesota Self-Certification Checklist - Word (SB-523-W)
- R5ERP Minnesota Self-Certification Checklist - PDF (SB-523)
To learn more about any of the regulations affecting auto body refinishing shops in Minnesota, go to their webpage: SBEAP industry sector: Automotive - body shop and vehicle maintenance.
Ohio
- R5ERP Ohio Self-Certification Checklist - Word (SB-522-W)
- R5ERP Ohio Self-Certification Checklist - PDF (SB-522)
- R5ERP Notification of Compliance Status for 6H (SB-528) [DOC]
Review information on Auto Repair and Auto Body Shops related to air pollution, waste, wastewater, among others.
The Ohio Air Quality Development Authority's Clean Air Resource Center offers financial resources for shops that need help to install pollution control equipment like a spray booth with high efficiency collection devices
Wisconsin
- R5ERP Wisconsin Environmental Checklist - Word (SB-521-W)
- R5ERP Wisconsin Environmental Checklist - PDF (SB-521)
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: Onsite Safety & Health Consultation in Wisconsin (800-947-0553).
Training resources
- Virtual Collision Repair Shop
- Watch the EPA training video to learn more about the rule and satisfy one of the training elements required in the rule. If you need the video in Spanish, contact the Small Business program at the DNR and a DVD will be mailed to you that has both English and Spanish versions of the video.
Painter training resources
These resources can help a shop demonstrate compliance with the training requirements in the EPA Area Source Rule described in the Air Regulations tab on this page
- EPA's Example Owner/Operator Certification for Painter Training
- 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 R5ERP Painter Training Curriculum (SB-529) [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.
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