Texas Surface Coating PBR Preparation

Surface Coating Permit By Rule-PBR in Texas

Many Texas manufacturers are unaware of environmental regulations that require companies to seek “authorizations” from TCEQ for emitting air pollutants for their painting and coating processes.

Texas Commission on Environmental Quality has a very specific air authorization for this activity: “Surface Coating, 106.433” This authorization is a “PBR” or Permit by Rule. In order to meet the requirements of this regulation, companies must take inventory of all associated paints and/or coatings and track their usage and emissions to prove that they don’t exceed PBR emissions thresholds. This can be a daunting task….

This brief blog post is designed to give some basic guidelines to help companies begin the process.

The information gathering process is normally the most time consuming part of the permit process.

Identify all of the paints you use including manufacturer name, specific color (some colors have different VOC emissions) and the associated Safety Data Sheet. If you have the old Material Safety Data Sheets, hang on to those since the new data sheets may not include the VOC content. You should already have this as part of the Chemical Inventory requirement of OSHA’s Hazard Communications standard. This will also a requirement under the Permit by Rule.
Identify all the solvents used for thinning or for cleaning equipment.
Any surface coating usage records. If you were tracking the quantity of paint used per project or task that would help. This also includes the amount of solvents used for thinning and cleaning.
If your company has not been tracking usage, you can collect purchase records for the past three years of all the surface coatings and solvents. Basic usage can be determine from purchase records.
Any process specifications where you have calculated the quantity of surface coating and thinner needed for products of fixed sizes.
Identify any process equipment such as ovens, hot water heaters, forklifts and anything else that may burn some type of fuel. These emissions would have to be taken into consideration for your overall permit requirements.

In the meantime, and while you begin gathering this information, it’s highly recommended to immediately start tracking your coating/painting usage. Again, you should be tracking is Paint name & color, quantity used, quantity of solvent used for thinning, quantity of solvent used for cleaning, time painting started and time painting ended. This would help start documenting usage that will later help with PBR calculations.

Learn more about other TCEQ environmental regulations here.

Have Questions About PBR Regulations and How To Meet Them?

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By Russell Carr|2022-03-21T12:55:51-05:00June 6th, 2017|State & Local Regulation, Texas Environmental Regulations, Texas Hazardous Materials Regulations|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Texas Surface Coating PBR Preparation