Reducing the Red Tape Hassle

VOC and HAP limits are continually decreasing. And, the amount of regulatory red tape that painters must deal with seems to grow every year. But, a new service that will help you comply with your air permit requirements can save you time and money . . .
#regulation #pollutioncontrol


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Painters have to deal with a lot of issues on a daily basis: film thickness control; curing; racking; transfer efficiency; paint quality; pretreatment, etc. While these issues can cause some headaches, they are what make painting interesting and challenging. Overcoming problems associated with these issues leads to a job well done and a sense of pride, especially because these issues have a significant impact on the quality of the product and the efficiency of the process.

However, there are a number of issues that painters must deal with that have no real impact on the quality of the product or the efficiency of the process. These issues reduce the time, money and energy a company puts into its products. One of the most bothersome of these issues is air pollution control. This is not to suggest that painters aren't for a clean environment. But, it is to say that the ever-increasing amount of legal red tape and tightening standards are making it more and more difficult for painters to concentrate on what they do best-paint parts.

The Red Tape Hassle

In order to comply with air permits, painters must generate an annual emissions report, which is an extremely time consuming and laborious activity. To properly generate an air emissions report, painters must document paint use and other information on a daily basis, but in many facilities this does not happen.

It is quite common for some painting shops to wait until the end of the year to begin working on their annual emission report. Many times the production staff must call the paint manufacturer to get a copy of the MSDS sheet. Then someone in accounting will call to ask how much paint the company has bought this year. The company then hands over the information to its consulting firm to produce the annual emission report. But because the information isn't presented clearly, the consulting firm must call the paint manufacturer to verify the information it was given. Obviously, this isn't the best way to produce the report, but it is understandable since producing the report doesn't add anything to a painting shop's bottom line.

While Chicago Steel Container Corp. (Chicago, IL) was more diligent in producing its reports, the company still found its employees were spending too much time compiling and gathering data and not enough time manufacturing and painting containers. Unlike some companies, Chicago Steel Container does not feel comfortable switching to a waterborne interior coating to eliminate its air pollution control concerns at this time. This is because of the critical role the interior coating plays in providing chemical and corrosion resistance on the company's 55-gal drums.

Therefore, dealing with air permits and annual emissions reports is just another part of the day at Chicago Steel Container. "We are basically doing the same thing in the initial stages of our record keeping," stated Tony Pileggi, vice president of Chicago Steel Container. "We have to compute the number of gallons of each coating used each day. This information is entered on a form that the painter keeps at his workstation. At the end of the day the form is given to our quality manager who then notifies Scientific Control Laboratories of that day's usage.

"In the past, we used to accumulate these daily reports and total them up at the end of the month. At the end of the year we would provide a summary total to Scientific from which they would prepare our air emissions report. We weren't really monitoring our coatings usage that well on a monthly basis before we entered the program."

By doing its reporting in this fashion, Chicago Steel Container was putting its consulting firm at a disadvantage. The consultant spent quite a bit of time tracking down and verifying information, making sure everything was correct. Also, this process increased Chicago Steel Container's costs because it meant the consulting firm had to spend more time generating the annual emission report.

Eliminating the Hassle

About 18 months ago, Chicago Steel Container was approached by Delta Coatings Corp. (its paint supplier) and Scientific Control Laboratories about a new service the two companies were offering. The service was based on a software program created by Scientific Control Laboratories and was designed to automatically generate annual emissions reports.

In order to begin using the service, the two providers tailored the program to Chicago Steel Container's facility. They took into account the spray booths, ovens and type of paints used. They also factored in the different metals used at Chicago Steel Container because the company has some grinding operations. Once the program was tailored to Chicago Steel Container's operation, the company could begin using the service.

As Mr. Pileggi mentioned, the initial step of the company's reporting process is the same. The painter or line worker is required to document the number of gallons used that day for each coating. But, with the new service, instead of a company employee gathering and compiling the data and making numerous calculations, the information is simply faxed to Scientific Control Laboratories. The laboratory then enters the information into the program and sends a fax back to Chicago Steel Container to verify that the information was entered correctly. These faxes can be done on
a daily or weekly basis. At the end of each month, Chicago Steel Container receives a report showing where its emissions stand in relation to its air permit. Finally, at the end of the year, the air program generates an annual air emissions report based on the information Chicago Steel Container faxed to the laboratory throughout the year.

Having its annual emissions report fashioned in this way has produced a number of benefits for Chicago Steel Container, including reduced costs, improved monitoring and increased time producing parts for employees. One of the most obvious benefits of the service is the reduced cost. Using a consultant is similar to using an accountant since they both charge for the amount of time they spend working on your company. Having a consultant produce an annual emissions report can cost anywhere from $4,000-$6,000 depending on the size and complexity of your paint facility.

Chicago Steel Container has greatly reduced that cost. With the new air program there is a one time fee between $300-$500 depending on the number of coatings used. The service then costs between $1,000-$2,000 per year, again depending on the number of coatings used. Not only is Chicago Steel Container saving money by using this service, it now has a fixed cost to produce its annual emissions report. With a consultant, the cost can vary from year to year, but with the program the cost is the same no matter how much time it takes the providers to input the data and complete the report.

Another benefit is that the service has helped Chicago Steel Container improve the monitoring of its facility through the various reports the program can generate. "By providing this information to Scientific Control Laboratories we receive a summary sheet where we can compute our transfer efficiency and analyze the data for anything unusual that needs further review. If the numbers don't look just right we can look for errors before the end of the year," stated Mr. Pileggi. "Generating these reports was just another added benefit of the air program. After the first year in the program we were amazed to find that the difference between our coating usage and purchases was just a few gallons. That makes me feel confident that our air emissions report is accurate."

One other benefit for Chicago Steel Container is that the service has freed up some of its employees' time, which they can now use to produce more containers instead of using that time to comply with various air regulations. While that time may come in small increments throughout the year, it is a substantial time savings when you add it up.

While these benefits don't completely alleviate the problems painters face regarding air pollution regulations, they certainly do help. And when you consider that environmental regulations will probably continue to get more complex and stricter, this service will become more and more valuable.


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