Auto Body & Auto Repair Compliance Pack
Compliance pack for auto body and auto repair shops. Isocyanate-paint exposures, VOC controls, welding fume, silica from grinding, EPA NESHAP refinishing emission controls.
When this template is required
Auto body shops face significant occupational exposures: isocyanate-containing paints (asthma sensitizer), VOC exposure, welding fume, silica from grinding/sanding, and chemical exposures (solvents, hardeners). EPA NESHAP requires emission controls and operator training. State paint regulations add layers.
Why this template
Isocyanate-paint focus
Isocyanates in 2K (two-part) paints cause occupational asthma — sensitization at very low exposures, often irreversible. Pack addresses isocyanate-specific prevention beyond general HazCom.
EPA NESHAP 6H operator training
EPA's Auto Body Refinishing NESHAP (40 CFR 63 Subpart HHHHHH) requires operator training and emission controls. Pack includes the training documentation EPA requires.
Welding + silica overlay
Auto body involves welding (panel repair) and silica generation (grinding, sanding body filler). Both exposures addressed.
Paint booth fire prevention
Paint booths are significant fire risks (flammable solvents, ignition sources). EAP includes paint booth-specific fire prevention and response.
What you receive
- Auto Body Safety Program
- HazCom (paints, solvents, cleaners, hardeners)
- Respiratory Protection Program (paint booth, grinding)
- Isocyanate exposure procedure (sensitization prevention)
- EPA NESHAP 6H paint operator training documentation
- Welding/Cutting/Brazing safety
- Silica exposure procedure (grinding/sanding)
- PPE Hazard Assessment
- Hazardous waste handling (used oil, solvents)
- EAP (fire — paint booths are fire risk)
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Auto body collision repair shops
- Auto refinishing operations
- Independent auto repair shops
- Dealership service departments
- Truck and equipment repair
- Specialty auto restoration
Frequently asked
What's isocyanate exposure?
2K (two-part) auto refinishing paints contain isocyanates as the hardener. Isocyanates cause occupational asthma at very low exposure levels through sensitization — once sensitized, even tiny exposures trigger asthma attacks. Sensitization is often irreversible. Prevention: a supplied-air respirator fed with Grade D breathing air for all spray application — 29 CFR 1910.94(c)(6)(iii)(a) requires air-supplied or other NIOSH-approved respiratory protection for an operator downstream in a booth — plus booth airflow and a documented clearance period, local exhaust and closed containers at the mixing bench, chemical-resistant gloves changed on a set interval, and a symptom reporting route. Air-purifying respirators are used only for the mixing, sanding and cleaning tasks the pack's task record assigns them to, on a written cartridge change schedule.
What's EPA NESHAP 6H?
40 CFR 63 Subpart HHHHHH (Auto Body Refinishing) — EPA's emission standard for paint stripping and miscellaneous surface coating. Requires the shop to ensure and certify that every painter, including contract painters, has completed training meeting the content requirements of 40 CFR 63.11173(f) — initial within 180 days of hire, re-certified every five years. EPA does not approve training providers; the shop may use any program, including in-house, that meets the content, and documented equivalent experience can satisfy the initial requirement. Also requires emission controls on spray booths and paint application equipment, and recordkeeping. Pack includes the operator training documentation.
Does this cover silica?
Yes, on the basis the general industry standard requires. The pack does not assume body filler contains crystalline silica — formulations differ by brand and grade — so it requires section 3 of each filler, putty, primer and abrasive SDS to be read and the answer recorded product by product (Appendix AC), then builds the written exposure control plan required by 29 CFR 1910.1053(f)(2)(i) around the tasks that actually generate it. Note the general industry standard has no Table 1, so the construction Table 1 control route is not available for routine in-shop work.
What about used oil and solvents?
Spent solvent, waste paint, gun wash and some paint booth filters require a hazardous waste determination under 40 CFR 262.11. Used oil is managed separately under 40 CFR part 279 unless it is mixed with hazardous waste or fails the 1,000 ppm halogen presumption at 40 CFR 279.21(b). The pack covers both routes, plus generator category, accumulation, labeling and manifesting.