Painting and Coating

Businesses with painting and coating operations have many requirements when it comes to recordkeeping and regulatory compliance. In conjunction with the Iowa Department of Natural Resources, the IAEAP has developed numerous programs and resources to help facilities with compliance.

Air Quality Permit Requirements

Owners and operators of air pollution sources, including painting and coating operations, are required to obtain air quality permits or utilize applicable exemptions to meet applicable air pollution standards. The following identifies air permit options for painting and coating facilities.


The permit-by-rule is a permitting option specifically for liquid spray booths, facilities in compliance with these requirements are deemed in compliance with air construction permitting requirements.

  • One Gallon Permit-by-Rule 

    • this option can be utilized by facilities that never spray more than one gallon of sprayable material in a single day (not average). Facilities must apply for the permit-by-rule using Iowa Easy Air and track daily usage.

  • Three Gallon Permit-by-Rule

    • this option can be utilized by facilities that never spray more than three gallon of sprayable material in a single day (not average). Facilities utilizing this option must have a 22ft tall stack (above the ground), apply for the permit-by-rule using Iowa Easy Air and track daily usage.

Air Quality Construction Permit

Facilities that are not able to utilize the permit-by-rule will need to apply for and obtain an Air Quality construction permit. Air quality construction permit applications must be completed and submitted using Iowa Easy Air.


The Iowa DNR permit exemptions can be found in the Iowa Administrative Code (567 IAC 22.1(2)) here.

Common exemptions applicable to painting and coating operations include Indoor-vented powder coating operations, emissions from the storage and mixing of paints and solvents plant maintenance and upkeep activities including painting.


The IAEAP has created several resources to assist facilities with recordkeeping requirements related to painting and coating operations.

Man using laptop computer to access his account on Paint Tracker recordkeeping web application

Paint Tracker

Online recordkeeping program developed by the IAEAP to help facilities track usage and emissions from painting and coating operations.

Features of Paint Tracker

  • It’s FREE
  • Easily record facility information, permit limits, product information and material usage.
  • Track material usage and emissions for multiple booths.
  • Track multiple facilities in the same place.

Maintain records in one location for easy retrieval.

Meet regulatory requirements for recordkeeping and tracking.



The following information applies to facilities affected by the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Surface Coating Operations (40 CFR, Part 63, Subpart HHHHHH) referred to here as "6H." This rule applies to certain facilities that spray coating. This rule applies to facilities that spray coatings that contain one or more of the following: cadmium, chromium, lead, nickel, or manganese to motor vehicles, mobile equipment or other products made of metal or plastic.

Basic Requirements for Compliance

Painter Training

Painters must be trained in setup and maintenance of spray equipment, spray technique, booth and filter maintenance, and environmental compliance. Refresher training is required every five years.

Spray Booth Exhaust Systems

Filter systems must have a 98% collection efficiency.

Spray Guns

Coatings must be applied using HVLP, electrostatic, airless or air-assisted airless spray guns.


Maintain records on painter training, filter efficiency, notifications and more.

NESHAP Resources

General Information

6H NESHAP Fact Sheet

6H Guide

Paint Stripping Fact Sheet

Iowa DNR Requirements

Iowa DNR Initial Notification | Notification of Compliance Status | Exemption Notification

EPA Requirements

CEDRI (Compliance and Emissions Data Reporting Interface)

CEDRI Registration Guide

CEDRI Reporting Guide

These resources and information have been developed by the Iowa Air Emissions Assistance Program, a program focused on training and educating Iowa small businesses with less than 100 employees. The Iowa Air Emissions Assistance Program is funded by the Iowa Department of Natural Resources. This information is intended solely as guidance, cannot be used to bind the Iowa Department of Natural Resources and is not a substitute for reading applicable statutes and regulations.