Update: CARB Suggested Control Measure Development

The California Air Resources Board (CARB) continues it process to develop a new Suggested Control Measure (SCM) for Architectural and Industrial Maintenance (AIM) coatings. The SCM is important since the various California Air Districts will use the new SCM to develop their future AIM rule revisions. In addition, the Northeast Ozone Transport Commission (OTC) states will likely also utilize the SCM in the development of lower AIM VOC limits in the Northeast states in the future (OTC Phase III).

This rulemaking could also impact many green building standards, since green building standards tend to reference the CARB AIM SCM.

In October 2018, CARB released a deliberative draft proposed SCM that was based on the California South Coast Air Quality Management District (SCAQMD) AIM Rule 1113, which is the country’s strictest regulation covering VOC in AIM products and includes over 20 limits that are lower than current CARB SCM. Notably, CARB did not include the restrictive SCAQMD Rule 1113 small container exemption provisions.

In December 2018, ACA submitted extensive comments to CARB on the draft proposed SCM, raising concern over the technical feasibility of the problematic lower limits for several categories, including: Industrial Maintenance; Rust Preventatives; Zinc Rich Primers; Metallic Pigmented; Graphic Arts; Aluminum Roof; Stains; Concrete Cure; Floor Coatings; and Form Release Compounds.

In preparation for the CARB’s SCM workshop on Feb. 19 workshop, late last month, CARB released revised SCM language and fortunately CARB decided not to lower the limits for Industrial Maintenance; Rust Preventatives; Zinc Rich Primers; Metallic Pigmented; Graphic Arts; and Concrete Curing Compounds.

CARB is tentatively scheduled to adopt the revised SCM in the summer of 2019.

The February 19 workshop notice can be found at https://www.arb.ca.gov/coatings/arch/e_signed_archcoatSCMworkshopnotice.pdf.

The February 19 public workshop handout and table of limits can be found at https://www.arb.ca.gov/coatings/arch/e_signed_Handout_for_2-19_SCM_Workshop.pdf.

ACA will attend the Feb. 19 public workshop and remain engaged in the CARB development process, collecting comments, concerns and developing industry positions.

Contact ACA’s David Darling for more information.

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