PF Blog

California Ready to Add New VOC Rule

By: Tim Pennington
8. August 2011



The American Coating Association and several Southern California metal coaters are battling the South Coast Air Quality Management District over proposed Rule 1107 that calls for lowering volatile organic compound emissions from the coating of metal parts and products.


The proposed rule applies to metal coatings or companies that perform metal stripping operations, and to all manufacturers, distributors and suppliers of metal coatings.


At its last working group meeting, SCAQMD staff mentioned possibly lowering the following volatile organic compound (VOC) limits:


  • General One-Component coatings from 275 g/L to 100 g/L
  • General Multi-Component coatings from 340/275 g/L to 100 g/L
  • Extreme High Gloss coatings from 420/360 g/L to 360 g/L
  • Extreme Performance coatings from 420/360 g/L to 275 g/L
  • Prefabricated Architectural One-Component from 275 g L to 100 g/L
  • Prefabricated Architectural Multi-Component from 340/275 g/L to 100 g/L
  • High Performance Architectural - eliminate category


Also of concern, SCAQMD is considering a "Prohibition of Sale" provision that would restrict the sale and distribution for use in the district any coating which, when applied as supplied or thinned or reduced according to the manufacturer's recommendation for application, does not meet the limits of the rule. Since many coatings can be used on various substrates, distributors and paint stores may find complying with this provision very difficult.


The SCAQMD is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties. This area of 10,743 square miles is home to over 16.8 million people - about half the population of the whole state of California. It is the second most populated urban area in the United States and one of the smoggiest.


The SCAQMD held a public hearing on June 15 in which several metal coaters attended and voiced objection to the rule. It wants to have the rules in place by September.


The ACA’s objections are:


General Prohibition: As with the Architectural and Industrial Maintenance (AIM Rule 1113), if adopted as written, SCAQMD inspectors will be able to pursue paint manufacturers, stores, and distributors if coatings intended for use on metal do not meet the applicable volatile organic compound (VOC) limit. What’s more, if this provision is adopted, it is very likely this provision will spread to other SCAQMD rules and across the United States.


100 g/l limit for General, High Gloss, Primer, and Prefabricated Architectural Categories: SCAQMD is assuming that Industrial Maintenance and Architectural and Industrial Maintenance primers can be effectively used on shop applied metal parts and products. Again, if these limits are adopted, they will likely propagate to similar rules across the United States.


Coatings for aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coating operations would be exempted. Nor would the rule apply to architectural components coated at the structure site or at a temporary, unimproved location designated exclusively for that purpose.


Although the rule would apply only to Southern California, SCAQMD is highly influential and its rules are considered a bellwether for environmental policies nationwide.


The read about the proposed rule, visit this link:



The see how SCAQMD encourages reporting air quality problems, watch this video:



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