In 2009, the Small Business Technical Assistance Program (SBTAP) created an outreach initiative to help auto body/collision repair facilities comply with regulations on air emissions and management of hazardous wastes. As part of the initiative, DES offered multiple workshops through out the state and conducted over 100 site visits.
For air emissions, the focus was on the new EPA National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources - 40 CFR Part 63 Subpart HHHHHH. The deadline for existing shops to certify is March 10, 2011.
Recent DES surveys show many auto body shops are in violation of the Hazardous Waste Rules. All auto body shops are hazardous waste generators, since the shop must clean spray guns with a solvent based product. Even if using water-borne coatings, the primer and clear coat spray guns must be cleaned using solvent. The biggest concerns are failure to conduct a hazardous waste determination, illegal disposal of hazardous waste, and poor waste storage container practices. Survey results also indicate that 38 percent of auto body shops have not notified DES of their hazardous waste activity, making it difficult for DES to help the shops come into compliance, and exposing the shops to additional penalties. This is also a loss of state revenue estimating over $34,000 in notification fees and over $20,000/year in small quantity generator fees.
There are over 600 auto body/collision repair facilities in New Hampshire, and 94 percent have less than 10 employees.