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Letter to the Editor

AASP/NJ and NJ DEP Working Together on VOC Compliance

Assisting AASP/NJ at the meeting were the paint suppliers, Till Paint Company and Central Paint/Color Source. The major area of concern was what an inspector should look for to determine compliance.

Subject to formal review and approval within the NJ DEP, the staff agreed to propose clarifying inspection guidance. Under the proposal shops VOC record keeping would be satisfied by:

• A list of coatings being used
• Copies of the manufacturer’s VOC content for the coating as applied (after mixing and reduction)
• Making a Representation the shop is not intermixing different manufacturer’s components into the coating
• Confirming the shop is following the manufacturer's recommendations.

Under these circumstances no log or calculation by the shop is necessary. If the shop is intermixing or not following the coating manufacturer’s recommendation, that shop will have to calculate and prove compliance.

"That huge sigh of relief you hear is coming from the collision repair industry in New Jersey," AASP/NJ President Bob Everett said. "Along with many of our paint suppliers and jobbers, AASP/NJ has been attempting to educate our membership on the requirements the DEP looks for when it goes out on inspections. To tentatively agree with the state on what those requirements should be is a big step to a final resolution."

"The meeting came about as county health departments started doing inspections, asking shops for records that we believe should not be required, particularly daily paint logs," explained AASP/NJ Legislative Chairman Brian Vesley, who was AASP/NJ’s representative at the meeting. "On several occasions when shops did not produce what they were asked for, fines were threatened and confusion was abundant. If the understanding is ratified by the DEP, we plan to have joint training with the DEP for the inspectors and the jobbers so that everyone will have the same understanding. AASP/NJ is thankful that the DEP staff has been available and receptive to making enforcement effective and fair."

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