CARB Developing New Suggested Control Measure AIM Coatings

The California Air Resources Board (CARB) is working on the development of 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.

CARB has indicated that it intends to base the new SCM on the California South Coast Air Quality Management District (SCAQMD) AIM Rule 1113.

The SCAQMD Rule 1113 is the country’s strictest regulation covering VOC in AIM products and   includes over 20 limits that are lower than current CARB SCM. These include, but are not limited to, problematic lower limits for Industrial Maintenance; Rust Preventatives; Aluminum Roof; Stains; Waterproofing Sealers; Concrete Cure; and Form Release Compounds.

CARB initially indicated it would propose a 100 g/l limit for Stains, which would be more stringent than the current SCAQMD limits (SCAQMD includes a 250 g/l limit for interior stains). CARB also initially indicated that it intended to include colorant limits that were more stringent than SCAQMD. However, CARB has decided to propose the current SCAQMD limits for Stains and Colorants.

Further, while CARB initially suggested is was not going to modify the Small Container Exemption as SCAQMD has, CARB is now going to assess the potential emission reductions that could be achieved from modifying the exemption. CARB will also include “aggregation language” that would prohibit the marketing and sale of “aggregated” small container exemption products.

CARB is tentatively scheduled to release the draft proposal at the first SCM meeting tentatively scheduled for Nov. 7, 2018. CARB hopes to bring the proposed SCM to the CARB Board in the Spring/Summer of 2019.

ACA is engaged in the CARB development process, collecting comments, concerns and developing industry positions, and will remain so as the SCM progresses.

Contact ACA’s David Darling for more information.

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