Metal Manufacturing

In Pennsylvania, the metal fabrication industry is subject to a variety of environmental requirements and regulations related to air emissions, hazardous waste, and stormwater.  Activities that may make a small business subject to state and/or federal regulations include: sand blasting, welding, surface coating, and the use of oils or paints, all or which could potentially result in the release of contaminants or pollutants.

Air Emissions

State:

To operate a metal fabrication business in Pennsylvania there are air emission permits that may need to be obtained to demonstrate proper environmental compliance.  Depending on the operation type and the size of the operation, air operating permits may be needed for dry blasting and various NESHAPs

Air emission standards may also be applicable to metal manufacturing facilities that conduct surface coating operations.  Surface coating operations are regulated due to the actual and potential release of volatile organic compounds (VOCs), hazardous air pollutants (HAPs), and particulate matter (PM).  While some facilities may be exempt from required air permits if they are considered a smaller source, they may still be required to maintain other information such as proper recordkeeping of safety data sheets (SDSs) and usage of paints, solvents, thinners, and other chemicals.

Federal:

Those small businesses working in the metal manufacturing industry may need to comply with federal air emission standards if the operations include dry or abrasive air blasting, surface coating or spray painting, and/or welding operations.  These types of activities frequently result in the release of air emissions and may thus be subject through federal standard 40 CFR Part 63 Subpart XXXXXX (6X) for area source fabrication and finishing categories.

To determine if your small metal manufacturing operation may be subject to Subpart 6X, EPA has created a 6X table of applicability by NAICS code with EPA source category and an associated SIC Code description. A helpful EPA flowchart may help determine what requirements and monitoring standards may apply.

Hazardous Waste

In the metal manufacturing industry, hazardous waste can come in many forms: chlorinated oil, waste paint & solvents, sandblasting waste, spent acid & bases, sludges from air and water pollution control units, and a variety of other discarded materials. The four characteristics used to identify hazardous wastes are: ignitability, corrosiveness, reactiveness, and toxicity. 
State:
In Pennsylvania, all aspects of hazardous waste are regulated including the generation, transportation, treatment, and storage of the waste.  Pennsylvania DEP released the 2019 Pennsylvania Hazardous Waste Compliance Guide to help businesses better understand what is required of them as hazardous waste generators. 
Federal:
To help small businesses understand which federal hazardous waste management regulations apply to your business, EPA prepared "Managing Your Hazardous Waste: A Guide for Small Businesses" to help small business owners and operators understand how best to comply with federal hazardous waste management regulations.