Auto Refinishing Record Keeping

All auto-body refinishers are required to maintain detailed coating and solvent usage records and material data sheets. Permitted automotive refinishers are requested to maintain charts or lists comparing all coatings and solvents for which limits have been established in Rule 234, Automotive Refinishing Operations to the associated Rule limit. In addition, shops must keep and maintain other logs, records, and material data sheets that record material usage and the VOC content of coating products. Automotive refinishers that are exempt from District permitting due to low coating volume (i.e. less than 1 gallon of coating per day) are required to keep records to maintain the exemption. The exemption form from permitting is available.

Records documenting compliance be kept in the formats provided here, or in equivalent alternative summary formats that provide the information that is required by Rule 234. If the required information is not kept in the manner prescribed by Rule 234, this is a violation of the rule. Record keeping is not an end in itself - operators cannot maintain compliance with Rule 234 limitations without knowing the VOC information that is the subject of the record keeping, and furthermore compliance cannot be demonstrated to the District without these records. This request is made pursuant to Section 500, Monitoring and Records, of Rule 234, Automotive Refinishing Operations, and pursuant to Health and Safety Code Section 42303, Information Disclosure.

Rule 234, Automotive Refinishing Operations, requires operators of facilities subject to the Rule to maintain a current listing of all as-applied VOC containing materials in use at the facility. In addition, current coating technical data sheets, which list the VOC content of each material, are required to be available for review on site. A record of the total facility VOC emissions is also required on a monthly basis. The rule also requires that any person using precoat shall verify compliance with Section 307 by retaining purchase invoices and records of applied volume of precoat on a monthly basis.

To aid complying with Rule 234, we are providing the following three forms:

• Coating System Line Products List is required for each paint system used and stored on site. This is a listing of all of the paint system components that have VOC containing compounds, which make up your paint system. A list may be provided to you by the manufacturer or distributor of your coating system, and can be used if it has all the information required by Rule 234. The list must reflect current coating use. The form is downloadable as a printable Portable Document Format - PDF - file for handwritten entry, and as a a Microsoft Word file for electronic file entry.
  
  
• Miscellaneous VOC-Containing Products List is required for VOC containing products that are not part a paint “system”, but assist in the refinishing process. Examples of materials that are required to be listed include aerosols that do not have pigments or resins, like strippers, or bulk solvent. The list must reflect current products used. The form is downloadable as a printable PDF file for handwritten entry, and as a Microsoft Word file for electronic file entry.
  
  
• A Monthly Record of VOC Emissions from Automotive Refinishing Operations is required. The monthly log is acceptable and compliant if it includes both paint system and miscellaneous product usages and meets the requirements of Rule 234. The form is downloadable as a printable PDF file for handwritten entry, and as a Microsoft Excel file for electronic file entry. Instructions are provided in a PDF file, and as a Microsoft Word file.
  
  The "monthly usage log" form was corrected on September 19, 2005. The "precoat/primer" ratio limit has been corrected from 5% to 25%; and the "specialty coating/all coating" ratio limit has been corrected from 25% to 5%.

Technical Data Sheets are required for each VOC containing material used and listed on a Product Lists. Technical data sheets must include the VOC content “As Applied Without Water and Exempt Solvents”, as well as “As Applied With Water and Exempt Solvents”. The VOC content “As Applied Without Water and Exempt Solvents” is required for determining compliance with rule limits. Whereas the VOC content “As Applied With Water and Exempt Solvents” is required to calculate monthly VOC emissions.

All required records must be retained for at least 3 years and are to be made available to the District’s inspector upon request.

If you have questions concerning record keeping requirements for Automotive Refinishing you may contact John Finnell, Senior Engineer at (530) 745-2324. Permitted facilities may request a compliance consultation meeting to informally review your record keeping practices.

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