American Coatings Association

California’s South Coast Air Quality Management District (SCAQMD) remains in a holding pattern with its amendments to Rule 1107 for limiting volatile organic compounds (VOC) in the Coating of Metal Parts and Products as it works to determine how to model worker exposure to tertiary butyl acetate (TBAc) and dimethyl carbonate (DMC).

The current proposed limits for General One-Component/Multi-Component, Prefabricated Architectural One-Component/Multi-Component, Primers are 150 g/l on 1/1/2014 and 100 g/l on 1/1/2017, respectively. The proposal also lowers the limit for Lacquers to 275 g/l and Graphic Arts coatings to 150 g/l on Jan. 1, 2014.

ACA on Oct. 14, 2011 submitted comments to SCAQMD on its proposed changes to Rule 1107. In its comments, ACA requested that SCAQMD make some simple amendments to certain definitions for clarification and accuracy.

The district had identified “compliant” coatings and has developed tables containing regulatory information, physical properties, and performance testing data for these coatings, and asked manufacturers, if their coatings were listed, to fill in any gaps in the tables.

ACA has been an active participant with SCAQMD throughout the rulemaking process. In earlier rounds of comments, several of the amendments to the proposed rule were consistent with ACA and industry comments, including the following:

• Extending the compliance dates by two years;
• Including a sell through provision;
• Modifications to the prohibition of sales provision;
• Relaxation of the spray equipment requirements for high viscosity coatings;
• Revised extreme high gloss coating definition; and
• Exemption of TBAc and DMC (under certain conditions and/or via permit).

Regarding the exemption of TBAc and DMC, in its most recent comments, ACA expressed concern that the district would use overly conservative assumptions in modeling worker exposures, and recommended the SCAQMD provide the assumptions to stakeholders prior to the modeling effort. ACA also noted that in California, the state’s Occupational Safety and Health Administration (OSHA) is responsible for regulating worker safety issues, not the district.  

ACA commented that the district’s proposed six month sell-through period was too short, and suggested that it be changed to a one year sell-through period. ACA noted that it will take manufacturers, distributors, and users at least a year to lock-out, inform customers, and clear products from inventories. As ACA has commented numerous times on other rules, if the district imposes sell-through periods that are too short, it’s possible that products will be thrown away, and as a result, air quality concerns shift to concerns about waste. Given the current economy, ACA argued that allowing the industry an additional six months to work through inventory makes economic sense.

ACA also noted in its comments that with industry, it is still evaluating the proposed combination regulatory/material VOC limits for General Waterborne VOC limits. These limits do not make sense to industry, since they would require major reformulation change and the 100 g/l material VOC limits may not be achievable; however, ACA maintained that additional review and discussions are needed before we can fully comment on this proposal.

Consistent with other district rules, ACA also suggested that recordkeeping should not apply to aerosol coatings.

The most recent version of the proposed amended rule is available at: http://www.aqmd.gov/enewsletterpro/uploadedimages/000004/PAR1107083011_r1.pdf.

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