Federal EPA rule 40 CFR Part 63, Subpart HHHHHH (6H) was published in January 2009. The rule applies to any area source that engage in any of the following activities:

  • Paint stripping using paint stripper containing methylene chloride (MeCl)
  • Spray application of coatings to metal or plastic substrates with coatings containing compounds of Chromium, Lead, Manganese, Nickel, or Cadmium.

Sherwin-Williams® Automotive Products

List of Products Containing 6H Target HAPs

Basic Requirements for Surface Coating Operations:

Must train/certify all painters on spray gun equipment selection, spray techniques, maintenance, and environmental compliance. Sherwin - Williams provides an E-learning system to help comply with the Training requirement. Contact a Sherwin-Williams Training Center for more information.

Spray Booths
Surface coating must be performed in a spray booth or prep station with filter technology to achieve at least 98% capture efficiency. Shops should keep a letter from the filter manufacture stating this.

Application Equipment
Must use HVLP or an equivalent technology.

Compliance Date

  • Existing Sources (In operation before 9/17/2007) must comply on January 10, 2011.
  • New Sources must comply upon start up.

Reporting and Record Keeping

Initial Notification (Informs EPA that the facility exists and is subject to the standards):

  • Existing Source 1/11/2010
  • New Sources 180 days after startup.

Certification of Compliance:

  • Existing Sources 3/11/2011
  • New Sources as part of initial notification

Keep records of Training, Filter Efficiency, Notifications sent to EPA.


This page is meant to provide general information on the 6H regulation and is not to be used to judge a shop's compliance or non-compliance with the rule. Compliance must be based on the full text of the rule as published by the U.S. EPA.