COSTING THE EARTH?
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Colin Sowman finds how the EPA will affect paintshops and where managers can get help. SUICIDAL — that's how many paint shop managers feel about the Environmental Protection Act (EPA), says John Ward. He is business director with paintshop equipment distributor Bancroft. "The other half put their heads in the sand and say this doesn't apply to us," he says. At the application end of the business, I&J Commercial Spray Centre in Loughborough is one of the largest independent commercial vehicle sprayers in the country with six booths and 26 people in the shops.
"In our area we are the most visible paintshop and an obvious target for the local authority. We must be seen to be doing the right thing," says I&J joint md Tom Blackwell. "We are experts in applying paint, not in the EPA, paint technology, spray guns or booths. We must rely on our suppliers for this expertise," he says, and expects others in a similar situation to do the same.
I&J's open day with all its suppliers present gave an opportunity to start looking at what the act will mean in practice and what will be required to meet its provisions.
Charles Kozma from Burntwood Engineering, which supplied the extraction equipment to I&J, highlighted one aspect of the EPA: it is an "enabling" act. This is a common Government procedure where only the basis for legislation is laid before Parliament for discussion and approval. The details of the act come later and are at the discretion of the relevant Secretary of State. This means the Environment Secretary can change the detail of the EPA without recourse to Parliament.
Consequently paintshops which do not come within the scope of the act now might find the ground rules change tomorrow to include them. This is also true for the equipment requirements and specifications as contained in the Secretary of State's guidance note — Respraying of Road Vehicles. The notes, ref PG6/ 34(92), are available from HMSO for 0.45 and are essential reading for paintshop managers, says Peter Henry, research executive with Trimite.
"Most people don't realise they are involved in the legislation," he says. Some think the limits for registration are on the solvent in the paint and not that used for cleaning. But it includes all solvent — in paint, hardeners, thinners, cleaners or sealants.
Paintshop records
Every paintshop must determine which limit is applicable and should now be keeping records of the amount of solvent purchased. Paint companies now mark the solvent content on the can or publish tables. The paintshop's records will show if it falls within the scope of the act and require authorisation.
Those that need to register with the local authority will have to do so by 30 Sept (31 March '93 in Scotland) and pay the application fee, now £900. The annual fee is now £550. The local authority will have to say within two weeks if the application has been "duly made".
Between two and six weeks after the application the paintshop must advertise the fact in a local paper. Within one year of application the local authority must grant an initial authorisation — or give reasons for refusal.
Within a year of the initial authorisation being granted the paintshop must submit a plan to upgrade its process to that required by the act.
"Following every recommendation to the letter immediately could put some paintshops out of business," says Blackwell. immediate compliance is not required, however, unless you fail to register before the deadline when in addition to a possible 220,000 fine and a two-year prison sentence, the business will be classified as a new process and immediate compliance will be required.
By 1994/5 paintshops have the choice of using "compliant coatings" or meeting a VOC emission limit of 50mg/m3. To comply with this limit would almost certainly involve using activated carbon filters in the booth exhaust. These will require changing and disposal under the "Duty of Care" legislation.
Reduced solvent
Using the 'compliant coatings' route requires the use of paints, gunwash and other consumables with reduced solvent content. While the technology (and expenditure) is outside the control of paintshops, managers should be aware of the likely changes over the next few years. Not only is a reduced solvent content required in 1995 but it reduces further in 1998. Paint manufacturers expect that new low VOC coatings will be available by that time with water-based paints being the most likely.
All paint companies are working on these products. "To be a viable alternative to solvent-based paints, the waterbased ones must dry in an oven in not over an hour," says Blackwell.
There are several new requirements relating to the booth itself, explains Kozma. By 1 April 1998 the total particulate emission from the booth is restricted to 10rng/m3. Most booths or spray areas installed after 1973 should be upgradeable — but at a cost. "Any booth can meet the limit, it is just a matter of putting in the correct filtration," says Kozma.
Booths must also operate under negative pressure. Most do already but singlefan systems will have problems. With twin-fan systems a simple adjustment will be necessary. Many modern booths already contain a warning device to show the operator if it becomes pressurised. Installing these devices on older booths should not cause problems.
However, with a firmer filtration system and a requirement of 5Ornis air movement at the exit to the stack, existing fans may not be up to the job. A replacement fan could be about £1,000. When the booth or spray area is upgraded the manufacturer or modifying company must issue a certificate confirming compliance. If that is not available, a test to ensure conformity must be carried out every six months.
By 1 April 1998 the exhaust stack from the booth must meet new requirements. Minimum height is eight metres above the ground level with a further stipulation that it should be three metres above the roof ridge height.
In Henry's experience fewer than 5% of paintshops have stacks that reach above the ridge. The regulations state that the height of surrounding buildings may affect the required height of the stack but local authorities interpret this in different ways. Exhaust stacks must not have any restriction (such as chinese hats) to the air flow, although a wire bird guard is allowed. However, rain cannot be allowed to enter the stack as it could damage the euipment. There are two ways round this says Kozma: you can put an annulus round the top section of the stack or a U-bend arrangement in the ducting to allow the water to escape.
Paintshops might be tempted to reduce the diameter of the stack to speed up the air Row using the existing fans. But remember, to dry the water-based paint expected in 1998, high air movements in the booth will be required. Therefore it is easier and cheaper to modify the booth once only.
The regulations specify that in paint application, a method with a demonstratable transfer efficiency of 65% must be used for all commercial vehicle coatings by 1 Oct 1994. This may be by HVLP (with an automistion pressure of 67.5 kPa — 10 psi), air-assisted airless, electrostatic or any other system meeting the efficiency target.
Satisfactory finish
Alan Selby from ICI Autocolor says the first generation of HVLP sprayguns did not give an acceptable performance but the latest ones are better. ICI is to start evaluating HVLP guns, so it must feel that they are capable of giving a satisfactory finish.
Bancroft finds that many paintshops have difficulty with HVLP equipment. Their compressors can only just cope with the normal spray equipment, says Ward. "As soon as you put a high-volume spraygun and a couple of face masks on the system the pressure drops off.
"A drop of a couple of pounds of pressure when operating a traditional spraygun is not too serious: when you only have lOpsi to start with you have a problem," says Ward. Another problem he has found is where the compressor is used to supply the whole shop. With these installations the pressure is reduced if someone starts a pneumatic sander while another is doing a spray job.
The regulations call for all equipment cleaning to be carried out in an automatic, totally enclosed machine or one of similar efficiency. There are many systems that collect the gunwash for recycling
but are not totally enclosed or automatic.
Bancroft's advice is to question the supplier/contractor about whether the equipment or modifications will comply with the act. Do it directly, and do not accept any sales patter — get a yes or no. If the salesman cannot or will not give a straight yes, don't buy.
Paintshop managers should read the regulations before applying for registration, says Henry, as there are pitfalls. Simple questions like what measures are currently taken to reduce solvent escape, can prove troublesome. Entering "nothing" creates a bad impression whereas "ensuring lids are replaced" and "sending all gunwash for recycling" is more positive.
Henry advises that at the rime of making an application the paintshop manager should look at upgrading the equipment. By doing so he can assess the costs involved and work this into the business plan. Then when it comes to presenting the upgrading plan to the local authority he can say: "I can do X within a year but Y will have to wait until 1995". Take the time the act allows but adopt a positive attitude when negotiating with the local authority, says Henry.
Ward confirms that. He says managers should set out their plans for compliance and as the deadlines approach the paint companies and equipment manufacturers will produce the technology to take them the rest of the way.