The letter asks EPA to disallow the paint booth exemption for repairers spraying from a 3 oz. paint cups. The letter says, “Unfortunately, the application of the rule has created a practice where some businesses are claiming to be exempt, by filling 3 oz. cups multiple times while doing traditional collision repair operations, in an attempt to continue to perform the work in an uncontained or mobile environment,” the letter states. “It is our position that an exemption which invalidates pollution controls based solely on the size of tool being used rather than the amount of pollution being generated is ineffective and harmful policy; because the rule is silent on refilling of the 3 oz cups, there exists a continued potential to circumvent the rule.”
Read the entire, unedited letter.