Eastern Kern Air Pollution Control District 

Rule 410.4A 

MOTOR VEHICLE AND MOBILE EQUIPMENT 

REFINISHING OPERATIONS 

FINAL STAFF REPORT 

March 13, 2014 

Prepared by 

Jeremiah Cravens 

Air Quality Specialist II 

Reviewed by 

Glen Stephens, P.E.

Air Pollution Control Officer

Eastern Kern Air Pollution Control District 

2700 “M” Street, Suite 302 

Bakersfield, California 93301 

(661) 862-5250  www.kernair.org
Table of Contents

I. BOARD ADOPTION .................................................................................. 1 

II. INTRODUCTION ....................................................................................... 1 

III. MOTOR VEHICLE AND MOBILE EQUIPMENT COATINGS .................... 2 

IV. MOTOR VEHICLE REFINISHING EMISSIONS ........................................ 2 

V. VOC EMISSIONS REDUCTIONS.............................................................. 3 

VI. APPLICABILITY......................................................................................... 3 

VII. CHANGES IN CATEGORIES AND DEFINITIONS.................................... 3 

VIII. EXCLUDED CATEGORIES AND DEFINITIONS....................................... 4 

IX. EXEMPTIONS ........................................................................................... 7 

X. CHANGES IN REQUIREMENTS............................................................... 7 

XI. VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS ............... 10 

XII. SOLVENTS.............................................................................................. 12 

XIII. ADMINISTRATIVE REQUIREMENTS..................................................... 12 

XIV. TEST METHODS..................................................................................... 12 

XV. ECONOMIC IMPACTS ............................................................................ 12 

XVI. ENVIRONMENTAL IMPACTS................................................................. 13 

XVII. SOCIOECONOMIC IMPACTS................................................................. 14 

TABLE 1: NEW CATEGORY NAMES ....................................................... 5 

TABLE 2: VOC CONTENT LIMITS.......................................................... 11 

APPENDIX A AMENDED RULE 410.4A, MOTOR VEHICLE AND 

MOBILE EQUIPMENT REFINISHING OPERATIONS 

CLEAN VERSION 

APPENDIX B AMENDED RULE 410.4A, MOTOR VEHICLE AND 

MOBILE EQUIPMENT REFINISHING OPERATIONS 

STRIKEOUT UNDERLINE VERSION 

APPENDIX C RESPONSE TO COMMENTS
410.4A Final Staff Report 

I. BOARD ADOPTION 

Rule 410.4A, Motor Vehicle and Mobile Equipment Refinishing Operations was 

amended by the Eastern Kern Air Pollution Control District (District)’s Governing 

Board on March 13, 2014 at its regular Board meeting in Rosamond California. 

Amended Rule 410.4A became effective and enforceable upon adoption. A copy 

of the Rule has been submitted to the California Air Resources Board (ARB) for 

their review and then to be forwarded to the U.S. Environmental Protection 

Agency (EPA) for inclusion into the State Implementation Plan (SIP). 

II. INTRODUCTION 

Rule 410.4A was originally adopted May 6, 1991 and amended April 6, 1995, 

March 7, 1996, and March 13, 2014. This staff report presents an extensive 

revision of the Rule. Amended Rule 410.4A limits volatile organic compound 

(VOC) emissions from coatings and solvents used in production, repair, refinish, 

or maintenance operations where motor vehicles, mobile equipment, or 

associated parts and components are coated. A majority of the amendments are 

based on the California Air Resources Board (ARB) Suggested Control Measure 

(SCM) for Automotive Coatings. The SCM is designed to promote uniformity 

amongst air district's that use it as a template for amending their motor vehicle 

and mobile equipment refinishing/coating rules. 

On November 6, 2013 the District held a public rule development workshop at 

the Mojave Veteran's Building in Mojave, CA. At this workshop District staff 

presented proposed revisions to Rule 410.4A, Motor Vehicle and Mobile 

Equipment Refinishing Operations. The District submitted copies of the 

proposed revision to ARB and EPA for an initial review prior to the workshop. A 

30-day public review and comment period followed the workshop. 

District received comments and suggested changes from EPA, ARB, and 

industry. District considered all comments and suggested changes. 

Appendix A is Amended Rule 410.4A, Motor Vehicle and Mobile Equipment

Refinishing Operations. 

Appendix B shows all changes made to Rule 410.4A, Motor Vehicle and Mobile 

Equipment Refinishing Operations in strikeout underline form. 

Appendix C is the District’s Response to Comments following the November 6, 

2013 public workshop held at the Mojave Veteran’s Center in Mojave, CA. 

EKAPCD 1 Draft 3/13/2014 
410.4A Final Staff Report 

III. MOTOR VEHICLE AND MOBILE EQUIPMENT COATINGS 

Motor vehicle and mobile equipment coatings are coatings that are applied to 

motor vehicles and mobile equipment. Such coatings are sold as components 

that must be mixed to be applied. The main coating categories include primers, 

color coatings, and clear coatings. These three broad coating categories 

account for approximately 84 percent of the sales reported in California. 

Remaining sales consist of a variety of coatings such as pretreatment coatings or 

adhesion promoters intended for use on bare metal or plastics. 

Motor vehicle and mobile equipment coatings are typically used to refinish, 

repair, or restore vehicles such as: automobiles, vans, trucks, truck trailers, 

buses, motorcycles, golf carts, tanks, armored personnel carriers, trains, railcars, 

mobile cranes, bulldozers, and street cleaners. Aerosol coatings (e.g., spray 

paint) or original equipment manufacturer coatings are not considered motor 

vehicle and mobile equipment coatings for applicable intent and purposes of this 

rule. 

IV. MOTOR VEHICLE REFINISHING EMISSIONS 

Coatings used in motor vehicle and mobile equipment refinishing operations 

represent a moderate source of volatile organic compound (VOC) emissions 

throughout California. VOC emissions are precursors to the formation of ozone 

and particulate matter (PM), which are California’s most serious air quality 

problems. VOCs react photochemically with oxides of nitrogen (NOx) to form 

ozone. Ozone is a strong oxidizer that irritates the human respiratory system, 

increases airway hyperreactivity, increases airway inflammation, and damages 

plant life and property. Exposure to ozone can be associated with hospitalization 

for cardiopulmonary causes, asthma episodes, restrictions in physical activity, 

and premature death. 

VOC emissions from motor vehicle and mobile equipment coatings can also lead 

to the formation of particulate matter (PM), which consists of very small liquid and 

solid particles suspended in the air. PM of concern include particles smaller than 

10 microns in size (PM10), as well as the subset of fine particles smaller than 2.5 

microns in size (PM2.5). When inhaled, PM10 and PM2.5 can travel deep into the 

lungs and reduce human pulmonary function. 

When motor vehicle and mobile equipment coatings are applied, the solvents 

that hold the coatings in suspension evaporate into the atmosphere and 

contribute to VOC emissions. 

EKAPCD 2 Draft 3/13/2014 
410.4A Final Staff Report 

V. VOC EMISSIONS REDUCTIONS 

Motor vehicle and mobile equipment coatings contain solvents which evaporate 

when they are applied. Most of the solvents used in these coatings are VOCs. 

Rule 410.4A is intended to reduce VOC emissions by establishing limits on the 

VOC content of motor vehicle and mobile equipment coating categories. VOC 

limits are expressed in grams of VOC per liter of coating, less water and exempt 

compounds, and vary with each coating category. In general VOC limits are met 

by replacing some of the solvents in motor vehicle and mobile equipment 

coatings with water, exempt compounds such as solvents with low 

photochemical reactivity, increasing the amount of solids, such as resins and 

pigments, or with a combination of these approaches. 

Average annual statewide VOC emissions from automotive coatings, excluding 

solvent usage for surface preparation and cleanup, are estimated to be 

approximately 20.7 tons per day (tpd) or about two percent of the total statewide 

stationary source VOC emissions. ARB has calculated that statewide 

implementation of the automotive refinishing SCM would lower VOC emissions 

from automotive coatings by about 13.4 tpd. This produces approximately a 65% 

reduction in VOC emissions from automotive coatings. 

VI. APPLICABILITY

Provisions of Rule 410.4A are applicable to motor vehicle and mobile equipment

refinishing operations as defined in this staff report and to any person who 

supplies, sells, offers for sale, manufactures, distributes, uses, applies, or solicits 

the use or application of any automotive coating or associated solvent within the 

District. 

VII. CHANGES IN CATEGORIES AND DEFINITIONS 

To enhance clarity, enforcement, and to limit the types of products that qualify for 

inclusion into each specific category of Rule 410.4A, Section IV, Definitions of the 

rule provides definitions for revised and new terms that are not self-explanatory. 

Definitions for the following items have been revised in 410.4A: 

 Electrostatic Spray Application 

 Exempt Compounds 

 High-Volume, Low-Pressure (HVLP) 

 Metallic/Iridescent Topcoat 

 Mobile Equipment 

 Pretreatment Coating 

 Primer 

 Specialty Coating 

 Spot/Panel Repair 

 Touch-Up Coating 

 Volatile Organic Compound 

EKAPCD 3 Draft 3/13/2014 
410.4A Final Staff Report 

Definitions for the following items have been added to 410.4A 

 Adhesion Promoter 

 Aerosol Coating Product 

 APCO 

 Assembly Line 

 Associated Parts and Components 

 Automotive Coating 

 Automotive Coating Component 

 Automotive Refinishing Facility 

 California Air Resources Board 

 Cleaning Operations 

 Clear Coating 

 Coating 

 Color Coating 

 Emission Control System 

 EPA 

 Motor Vehicle 

 Multi-Color Coating 

 Single-Stage Coating 

 Solvent 

 Spray Booth 

 Surface Preparation 

 Temporary Protective Coating 

 Transfer Efficiency 

 Truck Bed Liner Coating 

 Underbody Coating 

 Uniform Finish Coating 

 VOC Content 

VIII. EXCLUDED CATEGORIES AND DEFINITIONS 

Definitions for the following items have been deleted from Rule 410.4A because 

they were found unnecessary. Products from deleted categories default to the 

most closely related category if not called-out in a definition. 

 Antiglare Coating 

 Basecoat/Clearcoat System 

 Camouflage Coating 

 Color Match 

 Extreme Performance Coating 

 Grams of VOC per Liter of Coating 

Applied, Excluding Water and Exempt 

Compounds 

 Grams of VOC per liter of Material 

 Group I Vehicle 

 Group II Vehicle 

 Large/Heavy Duty Truck 

 Light and Medium Duty Truck or Van 

 Multistage Topcoat 

 Primer Sealer 

 Primer Surfacer 

 Reducer/Thinner 

 Three-Stage Coating System 

Definitions for Grams of VOC per Liter of Coating Applied, Excluding Water and 

Exempt Compounds and Grams of VOC per liter of Material have been replaced 

with the definition VOC Content. 

Table 1 displays the new category name that each existing or deleted product will 

now fall under. If a coating does not meet any of the definition for a specific 

category listed in Table 1, it will fall into the category labeled “Any other coating 

type” and the VOC limit of 250 grams per liter (g/l) will apply. Limits are 

expressed in grams of VOC per liter of coating thinned to the manufacturer’s 

maximum recommendation, excluding the volume of any water and exempt 

compounds. 

EKAPCD 4 Draft 3/13/2014 
410.4A Final Staff Report 

TABLE 1 

NEW CATEGORY NAMES 

New Category Existing/Deleted Category

Adhesion Promoter:  Adhesion promoter 

Cavity Wax:  Cavity Wax 

Deadener:  Deadener 

Clear Coating: 

 Antiglare Coating 

 Basecoat/Clearcoat System 

 Extreme Performance Coating 

 Heat Resistant 

 Impact Resistant Coating 

 Low-Gloss Coatings 

 Multistage Topcoat 

Color Coating: 

 Antiglare Coating 

 Basecoat/Clearcoat System 

 Camouflage Coating 

 Extreme Performance Coating 

 Heat Resistant 

 Multi-Stage Topcoat System 

 Multi-Color Topcoat 

 Multi-Color Multi-Stage 

Gasket/Gasket Sealing Material:  Gasket/Gasket Sealing Material 

Lubricating Wax/Compound  Lubricating Wax/Compound 

Multi-Color Coating: 

 Multi-Color Coatings 

 Multi-Color Multi-stage 

 Multi-Color Topcoat 

 Three-Stage Coating System 

Pretreatment Coating: 

 Pretreatment 

 Pretreatment Coating 

 Pretreatment Wash Primer 

Primer: 

 Extreme Performance Coating 

 Heat Resistant 

 Precoat 

 Primer 

 Primer Sealer 

 Primer Surfacer 

 Water Hold-Out Coating 

 Weld-Thru Coatings 

EKAPCD 5 Draft 3/13/2014 
410.4A Final Staff Report 

TABLE 1 continued

New Category Existing/Deleted Category

Primer: 

 Extreme Performance Coating 

 Heat Resistant 

 Precoat 

 Primer 

 Primer Sealer 

 Primer Surfacer 

 Water Hold-Out Coating 

 Weld-Thru Coatings 

Sealer  Sealer 

Single-Stage Coating: 

 Antiglare Coating 

 Extreme Performance Coating 

 General Topcoat 

 Heat Resistant 

 Impact Resistant Coating 

 Iridescent Topcoat 

 Metallic Topcoat 

 Nonmetallic Topcoat 

 Noniridescent Topcoat 

 Solid Color Topcoat 

 Topcoat (aka All Other Topcoats) 

Specialty Coating 

 Adhesion Promoters 

 Uniform Finish Blenders Elastomeric 

Materials 

 Gloss Flatteners 

 Bright Metal Trim Repair 

 Antiglare/Safety Coatings 

 Cut In or Jambing Clear Coatings 

Temporary Protective Coating:  Temporary Protective Coating 

Truck Bed Liner Coating:  Impact Resistant Coating 

Trunk Interior Coating  Trunk Interior Coating 

Underbody Coating: 

 Extreme Performance Coating 

 Impact Resistant Coating 

 Rubberized Asphaltic Underbody 

Uniform Finish Coating:  Finish Blenders 

Any other coating type:  Bright Metal Trim Repair Coating 

EKAPCD 6 Draft 3/13/2014 
410.4A Final Staff Report 

IX. EXEMPTIONS 

The Exemptions Section of the amended Rule has been moved from Section III 

to Section V, immediately after Definitions and before Requirements. None of 

the previous exemptions have been removed but the following exemptions have 

been added: 

 Any automotive coating or associated solvent that is offered for sale, sold, or 

supplied in 0.5 fluid ounce or smaller containers intended to be used by the 

general public to repair tiny surface imperfections. 

 Any automotive coating or associated solvent that is offered for sale, sold, or 

manufactured for use outside of the District or for shipment to other 

manufacturers for reformulation or repackaging. 

 Any coating applied to motor vehicles or mobile equipment, or their 

associated parts and components, during manufacture on an assembly line. 

 Surface Preparation and Equipment Cleanup Requirements, shall not apply to 

the use of surface preparation solvents to clean plastic parts just prior to 

coating or VOC-containing materials for the removal of wax and grease 

provided that non-aerosol, hand-held spray bottles are used with a maximum 

solvent VOC content of 780 g/L and the total volume of the solvent does not 

exceed 20 gallons per year per facility. Records of solvent usage shall be 

kept in accordance with Section VII.C.4 of this Rule.

X. CHANGES IN REQUIREMENTS 

The following requirements have been added to Rule 410.4A: 

 Most Restrictive VOC Limit: If anywhere on the container of any 

automotive coating, or any label or sticker affixed to the container, or in 

any sales, advertising, or technical literature supplied by a person, any 

representation is made that indicates that the coating meets the definition 

of or is recommended for use for more than one of the coating categories 

listed in Table of Standards, then the lowest VOC content limit shall apply. 

 Spray gun: If a spray gun is used, the end user must demonstrate that the 

gun meets the HVLP definition in Section IV.V in design and use. A 

satisfactory demonstration must be based on the manufacturer's published 

technical material on the design of the gun and by a demonstration of the 

operation of the gun using an air pressure tip gauge from the 

manufacturer of the gun. 

 Surface Preparation: VOC content of surface preparation solvent shall not 

exceed 25 g/l (0.2 lb/gal), as calculated pursuant to Section IV.RR.3, 

unless Section V.E applies. 

EKAPCD 7 Draft 3/13/2014 
410.4A Final Staff Report 

 Sell-Through/Existing Stock of Coatings: A coating manufactured prior to 

amendment date of this rule, that complied with the VOC Content limit(s) 

in effect at that time, may be sold, supplied, or offered for sale for 12 

months after rule adoption date. Such a coating may be applied at any 

time, both before and after adoption date, provided manufacture DateCode and VOC Content is clearly printed on coating container. 

The following requirements of Rule 410.4A have been revised: 

 VOC Content Limits has been revised from: Except as provided by 

Subsection IV.C., effective on the dates specified, no person shall refinish, 

or spot/panel repair any Group I vehicle, or where color match is required, 

any Group II vehicle, Mobile Equipment, or parts and components of such 

vehicles or equipment, using a coating with VOC content in excess of the 

following limits as applied. To: No person shall apply a coating to any 

motor vehicle, mobile equipment, or its associated parts and components, 

with a VOC regulatory content, as calculated pursuant to Section IV.RR.1, 

in excess of the limits expressed in Table of Standards, except as 

provided in Sections VI.C and VI.J.

 Alternate Emission Control has been revised from: In lieu of complying 

with VOC content limits specified in subsections IV.A. and IV.B., air 

pollution control equipment with a capture efficiency of at least 85% and a 

control efficiency of at least 90% may be used. To: Alternate Emission 

Control: In lieu of complying with VOC content limits specified in Table of 

Standards, an emission control system with a capture efficiency of at least 

90% and a control efficiency of at least 90% may be used if it has been 

approved in writing by the Air Pollution Control Officer (APCO). Any 

approved emission control system must be maintained and used in proper 

working condition at all times. Use of a VOC emission control system 

shall not result in emissions in excess of those that would have been 

emitted had the operator complied with the provisions of Section V.A.

 Application has been revised from: No person shall coat any Group I or 

Group II Vehicle, or Mobile Equipment, or parts and components of such 

vehicles and equipment, unless one of the following methods is used. To: 

Coating Application Methods: No person shall apply any coating to any 

motor vehicle, mobile equipment, or associated parts and components 

unless one of the following application methods is used. 

Section VI.E does not apply to underbody coatings, graphic arts 

operations, truck bed liner coatings, or any coating use of less than one 

(1) fluid ounce (29.6 milliliters).

 Other application method demonstrated to achieve at least 65% transfer 

efficiency, for example, flow or continuous coating. Has been revised to: 

Any alternative coating application method which has been demonstrated 

EKAPCD 8 Draft 3/13/2014 
410.4A Final Staff Report 

to achieve at least 65% transfer efficiency or the equivalent efficiency of 

an HVLP and approved, in writing, by the EPA and APCO.

 Storage and Disposal has been revised from: Regardless of VOC content, 

all VOC-containing materials used in solvent cleaning operations, such as 

solvents, and cloth and paper moistened with solvents, shall be stored in 

non-absorbent, non-leaking containers kept closed at all times except 

when filling or emptying. To: Regardless of VOC content, all automotive 

coating components, automotive coatings, and solvents, shall be stored in 

non-absorbent, vapor-tight containers kept closed at all times except when 

filling or emptying.

 Prohibition of Sale, No person shall offer for sale or sell within the District 

any coating if such product is prohibited by any provisions of this Rule. 

This prohibition shall apply to sale of any coating to be applied at any 

physical location within the District.

Has been revised to: Prohibition of Sale or Manufacture: No person shall 

manufacture, blend, repackage for sale, supply, sell, offer for sale or 

distribute within the District any coating with a VOC content in excess of 

the limits specified in Section VI.A.

Notwithstanding the provisions of this section, a person may manufacture, 

blend, repackage for sale, supply, sell, offer for sale, or distribute a coating 

with a VOC content in excess of the limits specified in section VI.A under 

the following circumstances and provided all of the requirements of 

section VII.C.6 are also met:

1. The coating is used exclusively within an emission control system as 

allowed in Section IV.C, or

2. Coating is exempt under one or more of the provisions of Section V.A.

 Prohibition of Specification: No person shall solicit or require for use or 

specify application of a coating on a Group I Vehicle or Group II Vehicle 

and Mobile Equipment or its parts and components, if such use or 

application results in a violation of provisions of this Rule. This prohibition 

shall apply to all written or oral contracts under terms of which any coating 

subject to provisions of this Rule is to be applied to any vehicle, mobile 

equipment or part or component at any physical location within the District.

Has been revised to: No person shall solicit or require the use of, or 

specify the application or use of any coating or solvent on a motor vehicle 

or mobile equipment, or its associated parts and components, if such use 

or application results in a violation of this Rule. This prohibition shall apply 

to all written or oral contracts, including but not limited to, job orders, 

under the terms of which any coating or solvent subject to provisions of 

this Rule is to be applied. This prohibition shall not apply to coatings or 

solvents that meet the criteria specified in Section VI.H.

EKAPCD 9 Draft 3/13/2014 
410.4A Final Staff Report 

The following requirements of Rule 410.4A have been deleted: 

 VOC Content Limits: Except as provided by Subsection IV.C., effective on 

the dates specified, where color match is not required, no person shall 

refinish or spot/panel repair any Group II vehicle, or Mobile Equipment, or 

parts and components of such vehicle or equipment using a coating with a 

VOC content in excess of the following limits as applied.

 1. Surface Cleaning: No material shall be used containing VOC in excess 

of 200 grams per liter (1.7 lb/gal) of material to remove dirt, oils, or 

other contaminants prior to application of surface coatings or 

adhesives.

2. Stripping: No material shall be used containing VOC in excess of 200 

grams per liter of material to strip any coating.

4. Cleaning of Polyester Resin Application Equipment: Solvents used for 

cleaning polyester resin application equipment shall comply with one of 

the limits specified below:

a. Solvent shall have a VOC content of 200 grams or less per liter (1.7 

lb/gal); or

b. Solvent shall have a VOC content of 1100 grams or less per liter 

(9.2 lb/gal) and a VOC composite partial pressure of 1.0 mm Hg or 

less at 20/C (68/F).

 1. Specialty Coatings: No person shall use any specialty coating with a 

VOC content in excess of 840 g/l (7.0 lbs/gal), excluding water and 

exempt compounds. Where use of specialty coatings, except 

antiglare/safety coatings, exceeds one gallon per day, use of such 

coatings shall not exceed 5.0 percent of all coatings applied on a daily 

basis.

XI. VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS 

The previous version of Rule 410.4A (3/7/96) had two sets of VOC limits for 

automotive coatings commonly referred to as Group I and Group II vehicles. 

Coatings used on passenger cars typically have higher VOC limits than coatings 

used on large vehicles such as trucks and buses. Amended Rule 410.4A 

eliminates Group I and Group II vehicles categories and establishes one set of 

VOC limits for passenger vehicles, heavy-duty vehicles, and mobile equipment. 

The previous Rule also had composite VOC limits for multi-stage systems that 

apply to the total VOC content of the color coat and clear coat combined. 

Amended Rule 410.4A eliminates composite VOC limits for multi-stage systems 

and replaces them with specific VOC limits for clear coatings and color coatings. 

EKAPCD 10 Draft 3/13/2014 
410.4A Final Staff Report 

Amended Rule 410.4A establishes VOC content limits for the following 

seventeen automotive coating categories: Cavity Wax, Adhesion Promoter, 

Cavity Wax, Clear Coating, Color Coating, Deadener, Gasket/Gasket Sealing 

Material, Lubricating Wax/Compound, Multi-Color Coating, Pretreatment Coating, 

Primer, Sealer, Single-Stage Coating, Specialty Coating, Temporary Protective 

Coating, Truck Bed Liner Coating, Underbody Coating, Uniform Finish Coating, 

and Any other coating type. These automotive coating categories were chosen 

because they are similar to those in existing California air district automotive 

refinishing rules. 

Table 2 details the maximum VOC content limit for each of the seventeen 

automotive coating categories. Limits are expressed in grams of VOC per liter of 

coating thinned to the manufacturer’s maximum recommendation, excluding the 

volume of water and any exempt compound. If a coating is represented in such 

a way that indicates it can be used in more than one coating category listed in 

Table 1, then the lowest, most restrictive, VOC content limit will apply. If a 

coating does not meet any of the definitions of a specific category then that 

coating will default to the “Any other coating type” category and a VOC limit of 

250 grams per liter (g/l) will apply. 

TABLE 2 

VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS 

Content expressed in Grams per Liter (Pounds per Gallon) 

Less Water and Exempt Compounds 

Coating Category VOC Limit 

Adhesion Promoter 540 (4.5) 

Cavity Wax 650 (5.4) 

Clear Coating 250 (2.1) 

Color Coating 420 (3.5) 

Deadener 650 (5.4) 

Gasket/Gasket Sealing Material 200 (1.7) 

Lubricating Wax/Compound 700 (5.8) 

Multi-Color Coating 680 (5.7) 

Pretreatment Coating 660 (5.5) 

Primer 250 (2.1) 

Sealer 650 (5.4) 

Single-Stage Coating 340 (2.8) 

Specialty Coating 540 (4.5) 

Temporary Protective Coating 60 (0.5) 

Truck Bed Liner Coating 200 (1.7) 

Trunk Interior Coating 650 (5.4) 

Underbody Coating 650 (5.4) 

Uniform Finish Coating 540 (4.5) 

Any other coating type 250 (2.1) 

EKAPCD 11 Draft 3/13/2014 
410.4A Final Staff Report 

XII. SOLVENTS

For purpose of this rule, solvents are defined as any liquid containing an organic 

compound or combination of organic compounds used as diluent, thinner, 

dissolver, viscosity reducer, cleaning agent, or other similar uses. These liquids 

are principally derived from petroleum and include petroleum distillates, 

chlorinated hydrocarbons, chlorofluorocarbons, ketones, and alcohols. 

Solutions, emulsions, and dispersions of water and soap, or water and detergent, 

are not considered organic solvents. Soaps and detergents are considered 

water based surfactants. 

Solvents used for cleaning of coatings application equipment remains the same 

with a VOC content limit of 950 grams or less per liter (7.9 lb/gal) of material and 

with a VOC composite partial pressure of 35 mm Hg or less at 20/C (68/F). The 

District has retained this limit largely because the equipment cleaning methods 

require solvents to be contained in a closed system. However, surface 

preparation solvents have a revised VOC limit that shall not exceed 25 g/l (0.2 

lb/gal). 

The 25 g/l limit is the lowest VOC content limit that is technologically and 

commercially feasible and has been since January 1, 2009. 25 g/l VOC content 

can be achieved through the use of exempt compounds. Many air districts 

require solvents in various coating operation rules to meet the 25 g/l VOC 

content limit. 

XIII. ADMINISTRATIVE REQUIREMENTS 

Rule 410.4A contains an extensive revision of the Administrative Requirements 

section. Please see Section VII, Administrative Requirements of Appendix A for 

complete details and Section VII, Administrative Requirements of Appendix B for 

strikeout underline changes. 

XIV. TEST METHODS 

Rule 410.4A contains an extensive revision of the Test Methods section. Please 

see Section VIII, Test Methods of Appendix A for complete details and Section 

VIII, Test Methods of Appendix B for strikeout underline changes.. 

XV. ECONOMIC IMPACTS 

Economic impacts are quantified to the extent feasible, but economic impact 

analyses can be inherently imprecise by nature, especially given the 

unpredictable behavior of companies in a highly competitive market. Therefore, 

some projections are necessarily qualitative or semi-quantitative, based on 

general observations about the motor vehicle coatings industry. 

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410.4A Final Staff Report 

Economic impact analysis for Amended Rule 410.4A provides a general picture 

of the economic impacts that a typical businesses might encounter. However, 

staff recognizes that individual companies may experience impacts different than 

those projected in this analysis. 

Information provided in this economic analysis is based on ARB’s findings in their 

October 2005, Staff Report for the Proposed SCM for Automotive Coatings. The 

data is associated with statewide implementation of the Motor Vehicle Coatings 

SCM. 

ARB estimates overall cost-effectiveness of the Motor Vehicle Coatings SCM to 

be approximately $1.43 (in current dollars) per pound of VOCs reduced. This 

cost-effectiveness is comparable in magnitude to that reported for other ARB 

consumer product regulations and measures, which generally have fallen within 

a range of no cost to about $6.90 per pound of VOCs reduced. For example, the 

SCM for architectural coatings had an average cost-effectiveness of $3.20 per 

pound of VOCs reduced. 

ARB found that most automotive refinishing facilities and coatings manufacturers 

would be able to absorb the cost of the proposed SCM with no significant 

adverse impacts on their profitability. This finding is indicated by ARB’s 

estimated change in “Return on Owner’s Equity” (ROE) analysis. The analysis 

found an average decrease in the state-wide ROE of about 0.07 percent for 

coatings manufacturers and 15 percent for automotive refinishing facilities. 

If all costs of the proposed SCM are absorbed by automotive refinishing facilities, 

the decrease in ROE exceeds the 10 percent threshold typically used to indicate 

a potential for adverse impacts on profitability. However, ARB expects the costs 

incurred by manufacturers and automotive refinishing facilities to be passed on to 

consumers. If the entire cost of the proposed SCM were passed on to 

consumers, the average price for a repair would increase by about $11. This 

represents an increase of about 0.5% for a $2,200 repair. 

It is expected that most businesses will pass on their increased costs to 

consumers. Therefore, no noticeable change in employment, business creation, 

elimination, expansion, or business competitiveness in California will be 

adversely affected. In addition, ARB's economic analysis has found no 

significant adverse fiscal impacts on any local or State agencies. 

XVI. ENVIRONMENTAL IMPACTS

Both the California Environmental Quality Act (CEQA) and ARB policy require an 

evaluation of the potential adverse environmental impacts of proposed projects. 

Based on the information provided in ARB’s October 2005 Staff Report for the 

Proposed SCM for Automotive Coatings, District has determined that no 

significant adverse environmental impacts should occur as a result of adopting 

Amended Rule 410.4A. 

EKAPCD 13 Draft 3/13/2014 
410.4A Final Staff Report 

EKAPCD 14 Draft 3/13/2014 

The primary environmental benefit of Amended Rule 410.4A is a reduction in the 

formation of tropospheric (ground level) ozone, PM10 and PM2.5. It has long 

been known that exposure to ground level ozone, PM10 and PM2.5 have 

adverse impacts on public health. Amended Rule 410.4A will help protect public 

health by reducing the public’s exposure to these potentially harmful emissions. 

Additionally, automotive coatings contain several known TACs such as toluene, 

xylenes, and methyl ethyl ketone (MEK). Current use of these compounds 

account for approximately 27 percent of the VOC emissions from automotive 

refinishing coatings. To some extent these TACs can be reduced by 

reformulation to lower VOC coatings. District Rule 102 (Definitions) lists Tertiary 

Butyl Acetate (t-butyl acetate) TBAC or TBAc as an exempt organic compound

that is not a VOC for purposes of VOC emissions limitations or VOC content 

requirements. It is estimated that TBAC could be used to substitute toluene, 

xylenes, and MEK by as much as 50 percent, thereby substantially reducing 

VOC emissions. 

Pursuant to the Section 15061, Subsections (2) & (3) of the CEQA Guidelines, 

staff will prepared and file a Notice of Exemption for this project upon adoption. 

XVII. SOCIOECONOMIC IMPACTS 

CHSC Section 40728.5 exempts districts with a population of less than 500,000 

persons from the requirement to assess the socioeconomic impacts of adopting 

rules. Eastern Kern County population is below 500,000 persons. 

Remainder of Page Intentionally Left Blank 
 

APPENDIX A: 

AMENDED RULE 410.4A 

MOTOR VEHICLE AND MOBILE EQUIPMENT 

REFINISHING OPERATIONS 
410.4A Final Staff Report – Amended Rule 

RULE 410.4A Motor Vehicle and Mobile Equipment Refinishing Operations - Adopted 

5/6/91, Amended 4/6/95, 3/7/96, 3/13/14 

I. Purpose

The purpose of this rule is to limit volatile organic compound (VOC) emissions from 

coatings and solvents used in production, repair, refinish, or maintenance operations where 

motor vehicles, mobile equipment, or associated parts and components are coated. 

II. Applicability

The provisions of this Rule are enforceable upon amendment date and shall apply to any 

person who supplies, sells, offers for sale, manufactures, distributes, uses, applies, or 

solicits the use or application of any automotive coating or associated solvent within the 

District. 

III. Severability

Each provision of this rule shall be deemed severable, and in the event that any provision of 

this rule is held to be invalid, the remainder of this rule shall continue in full force and 

effect. 

IV. Definitions

A. Adhesion Promoter: A coating, which is labeled and formulated to be applied to 

uncoated plastic surfaces to facilitate bonding of subsequent coatings, and on which, a 

subsequent coating is applied. 

B. Aerosol Coating Product: A pressurized coating product containing pigments or resins 

that dispenses product ingredients by means of a propellant, and is packaged in a 

disposable can for hand-held application, or for use in specialized equipment for ground 

traffic/marking applications. 

C. APCO: Air Pollution Control Officer of the Eastern Kern Air Pollution Control 

District. 

D. Assembly Line: An arrangement of industrial equipment and workers in which the 

product passes from one specialized operation to another until complete, by either 

automatic or manual means. 

E. Associated Parts and Components: Structures, devices, pieces, modules, sections, 

assemblies, subassemblies, or elements of motor vehicles or mobile equipment that are 

designed to be a part of motor vehicles or mobile equipment but which are not attached 

to motor vehicles or mobile equipment at the time of coating the structure, device, 

piece, module, section, assembly, subassembly, or element. “Associated parts and 

components” does not include circuit boards. 

Appendix A A-1 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

F. Automotive Coating: Any coating or coating component used or recommended for use 

in motor vehicle or mobile equipment refinishing, service, maintenance, repair, 

restoration, or modification, except metal plating activities. Any reference to 

automotive refinishing or automotive coating made by a person on the container or in 

product literature constitutes a recommendation for use in motor vehicle or mobile 

equipment refinishing. 

G. Automotive Coating Component: Any portion of a coating, including, but not limited 

to, a reducer or thinner, toner, hardener, and additive, which is recommended by any 

person to distributors or end-users for use in an automotive coating, or which is 

supplied for or used in an automotive coating. The raw materials used to produce the 

components are not considered automotive coating components. 

H. Automotive Refinishing Facility: Any shop, business, location, or parcel of land where 

motor vehicles or mobile equipment or their associated parts and components are 

coated, including autobody collision repair shops. “Automotive Refinishing Facility” 

does not include the original equipment manufacturing plant where the motor vehicle or 

mobile equipment is completely assembled. 

I. California Air Resources Board (CARB or ARB): Air Resources Board of the 

California Environmental Protection Agency. 

J. Cleaning Operations: The removal of loosely held uncured adhesives, inks, coatings, or 

contaminants, including, but not limited to, dirt, soil, or grease, from motor vehicles, 

mobile equipment, associated parts and components, substrates, parts, products, tools, 

machinery, equipment, or general work areas. 

K. Clear Coating: Any coating that contains no pigments and is labeled and formulated 

for application over a color coating or clear coating. 

L. Coating: A material which is applied to a surface and forms a film in order to beautify, 

preserve, repair, or protect such a surface. 

M. Color Coating: Any pigmented coating, excluding adhesion promoters, primers, and 

multi-color coatings, that requires a subsequent clear coating and which is applied over 

a primer, adhesion promoter, or color coating. Color coatings include 

metallic/iridescent color coatings. 

N. Electrodeposition: Applying an electrically-charged dip coating onto object to be 

coated. 

O. Electrostatic Spray Application: Any method of spray application of coatings where an 

electrostatic attraction is created between the part to be coated and the paint particles. 

P. Emission Control System: Any combination of capture systems and control devices 

used to reduce VOC emissions from automotive coating operations. 

Q. EPA: The United States Environmental Protection Agency. 

Appendix A A-2 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

R. Exempt Compounds: As defined in District Rule 102, Definitions, “Exempt 

Compounds”. 

S. Graphic Arts Operation: Application of logos, letters, numbers or graphics to a painted 

surface with or without use of a template. 

T. High-Volume, Low-Pressure (HVLP): Spray equipment permanently labeled as such 

and which is designed and operated between 0.1 and 10 pounds per square inch, gauge, 

(psig) air atomizing pressure measured dynamically at the center of the air cap and at 

the air horns and with liquid supply pressure less than 50 psig. 

U. Metallic/Iridescent Topcoat: Coating as applied containing more than 5 g/1 (0.042 

lb/gal) of visible metal or iridescent particles, where such particles are visible in the 

dried film. 

V. Mobile Equipment: Equipment drawn or capable of being driven on a roadway, 

including, but not limited to a: truck body, truck trailer, utility body, camper shell, 

mobile crane, bulldozer, construction and farm heavy equipment, concrete mixers, 

street cleaner, golf cart, all terrain vehicles, implements of husbandry, military tank or 

other tracked military vehicle and hauling equipment used inside and around airports, 

depots, and industrial and commercial plants. 

W. Motor Vehicle: As defined in Rule 102, Definitions. 

X. Multi-Color Coating: Any coating that exhibits more than one color in the dried film 

after a single application, is packaged in a single container, and hides surface defects on 

areas of heavy use, and which is applied over a primer or adhesion promoter. 

Y. Precoat: Coating applied to bare metal primarily to deactivate metal surface for 

corrosion resistance and adhesion. 

Z. Pretreatment Coating: Coating containing a minimum of 0.5% acid by weight and not 

more than 16 percent solids by weight necessary to provide surface etching and is 

labeled and formulated for application directly to bare metal surfaces to provide 

corrosion resistance and adhesion. 

AA. Primer: Any coating, which is labeled and formulated for application to a substrate to 

provide 1) a bond between the substrate and subsequent coats, 2) corrosion resistance, 

3) a smooth substrate surface, or 4) resistance to penetration of subsequent coats, and 

on which a subsequent coating is applied. Primers may be pigmented. 

BB. Refinish: Coating of vehicles, their parts and components, or mobile equipment, 

including partial body collision repairs, for the purpose of protection or beautification 

and subsequent to the original coating applied at an Original Equipment Manufacturing 

(OEM) plant coating assembly line. 

CC. Single-Stage Coating: Any pigmented coating, excluding primers and multi-color 

coatings, labeled and formulated for application without a subsequent clear coat. 

Single-stage coatings include single-stage metallic/iridescent coatings. 

Appendix A A-3 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

DD. Solvent: As defined in Rule 410.3, Organic Solvent Degreasing Operations. 

EE. Spray Booth: Any power ventilated structure of varying dimensions and construction 

provided to enclose or accommodate a spraying operation and which meets the 

Uniform Fire Code. A spray booth shall confine and limit, by dry or wet filtration, the 

escape to the atmosphere of overspray particulate matter, exhaust through filters or 

other air pollution control device approved by the APCO and provide adequate 

ventilation, air velocity, and safety features, as required by the Uniform Fire Code. 

FF. Specialty Coating: Coating necessary for unusual job performance requirements, 

including, but not limited to, adhesion promoters, uniform finish blenders elastomeric 

materials, gloss flatteners, bright metal trim repair, anti-glare/safety coatings, and cut in 

or jambing clear coatings. 

GG. Spot/Panel Repair: Non-assembly line process of repairing and restoring a portion of a 

motor vehicle, or associated parts or components of less than 1 square foot (929 square 

centimeters). 

HH. Surface Preparation: The use of VOC containing solvents applied with cloth, sponge, 

or other medium for the purpose of removing dust, grease, and other contaminants from 

a surface just prior to application of a coating. 

II. Temporary Protective Coating: Any coating which is labeled and formulated for the 

purpose of temporarily protecting areas from overspray or mechanical damage. 

JJ. Topcoat: Coating applied over a primer or an original equipment manufacturer finish 

for the purpose of protection or appearance. 

KK. Touch-Up Coating: A coating used to cover minor coating imperfections appearing 

after the main coating operation. 

LL. Transfer Efficiency: The amount of coating solids adhering to the object being coated 

divided by the total amount of coating solids sprayed, expressed as a percentage. 

MM. Truck Bed Liner Coating: Any coating, excluding clear, color, multi-color, and single 

stage coatings, labeled and formulated for application to a truck bed to protect it from 

surface abrasion. 

NN. Underbody Coating: Any coating labeled and formulated for application to wheel 

wells, the inside of door panels or fenders, the underside of a trunk or hood, or the 

underside of the motor vehicle. 

OO. Uniform Finish Coating: Any coating labeled and formulated for application to the 

area around a spot repair for the purpose of blending a repaired area’s color or clear 

coat to match the appearance of an adjacent area’s existing coating. 

PP. Utility Body: Special purpose service compartment or unit to be bolted, welded, or 

affixed onto an existing cab and chassis. Such compartment may serve as storage for 

equipment or parts. 

Appendix A A-4 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

QQ. Volatile Organic Compound (VOC): Any compound containing at least one atom of 

carbon, excluding Exempt Compounds as listed in Rule 102 Definitions. 

RR. VOC Content:

1. VOC regulatory for Coatings: VOC in grams per liter of coating, excluding water 

and exempt compounds, and shall be calculated by the following equation: 

VOC regulatory content = Wv - Ww - Wec

 Vm - Vw – Vec 

2. VOC actual for Coatings: VOC in grams per liter of material shall be calculated 

using the following equation: 

VOC actual content = Wv - Ww - Wec

 Vm 

3. VOC content for Solvents: VOC in grams per liter of material shall be calculated 

by the following equation: 

VOC content = Wv - Ww - Wec

 Vm 

Where: 

VOC content = amount of volatile organic compounds in grams/liter 

Wv = weight of volatiles in grams 

Ww = weight of water in grams 

Wec = weight of exempt compounds in grams 

Vm = volume of material (coating or solvent, as applicable) in liters 

Vw = volume of water in liters 

Vec = volume of exempt compounds in liters 

V. Exemptions

A. Requirements of this Rule shall not apply to the following operations: 

1. Graphic Arts Operations as defined in Section IV.S. 

2. Any automotive coating or associated solvent that is offered for sale, sold, or 

supplied in 0.5 fluid ounce or smaller containers intended to be used by the general 

public to repair tiny surface imperfections. 

3. Coating operations employing hand-held non-refillable aerosol cans, 18 oz. or less, 

provided the area to be covered does not exceed nine square feet per vehicle to 

repair minor surface damage and imperfections. 

4. Any automotive coating or associated solvent that is offered for sale, sold, or 

manufactured for use outside of the District or for shipment to other manufacturers 

for reformulation or repackaging. 

Appendix A A-5 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

5. Any coating applied to motor vehicles or mobile equipment, or their associated 

parts and components, during manufacture on an assembly line. 

B. Requirements of Section VI.D (Spray Booth) shall not apply to: 

1. Touch-up coating operations as defined in Section IV.KK, not exceeding nine 

square feet per vehicle. 

2. Coating of motor vehicle engine compartments, engine components, and suspension 

components, provided such components are replaced in the vehicle. 

3. Application of primers, primer surfacers and precoats not exceeding nine square 

feet per vehicle, provided VOC content does not exceed 250 g/l and coatings 

contain no lead or chromium compounds. 

4. Application of coatings to a vehicle, due to shape or size, not reasonably contained 

in a spray booth. To qualify for this exemption a person shall comply with the 

following requirements: 

a. Submit a written request on a case by case basis to the APCO describing 

vehicle(s) to be coated, size of spray booth, physical size of vehicle(s) (length, 

width, and height), number of vehicle(s) to be coated, time required to paint 

vehicle(s), estimated volume of coating(s) to be used, date when vehicle(s) or 

mobile equipment is to be coated, and VOC content of each coating used; 

b. Such request shall be submitted ten calendar days prior to surface coating a 

motor vehicle or mobile equipment outside a spray booth. The APCO shall 

provide a written determination to the requester within five calendar days of 

proposed surface coating of the motor vehicle or mobile equipment; and 

c. The APCO may grant written approval for a specified time period, not to exceed 

one year. 

C. Coating operations and/or facilities exempt from this Rule shall comply with all other 

applicable District prohibitory Rules. 

D. Provisions of Sections VI.C. through VI.G. and Section VII. shall not apply to coating 

of one vehicle per twelve month period, by the registered owner of the vehicle being 

painted, provided the surface coating does not contain lead or chromium compounds. 

E. Section VI.F, Surface Preparation and Equipment Cleanup Requirements, shall not 

apply to the use of surface preparation solvents to clean plastic parts just prior to 

coating or VOC-containing materials for the removal of wax and grease provided that 

nonaerosol, hand-held spray bottles are used with a maximum solvent VOC content of 

780 g/l and the total volume of the solvent does not exceed 20 gallons per year per 

facility. Records of solvent usage shall be kept in accordance with Section VII.C.4 of 

this Rule. 

Appendix A A-6 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

VI. Requirements

A. VOC Content Limits: No person shall apply a coating to any motor vehicle, mobile 

equipment, or its associated parts and components, with a VOC regulatory content, as 

calculated pursuant to Section IV.RR.1, in excess of the limits expressed in Table of 

Standards, except as provided in Sections VI.C and VI.J. 

TABLE OF STANDARDS 

VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS 

Content expressed in Grams per Liter (Pounds per Gallon) 

Less Water and Exempt Compounds 

Coating Category VOC Limit 

Adhesion Promoter 540 (4.5) 

Cavity Wax 650 (5.4) 

Clear Coating 250 (2.1) 

Color Coating 420 (3.5) 

Deadener 650 (5.4) 

Gasket/Gasket Sealing Material 200 (1.7) 

Lubricating Wax/Compound 700 (5.8) 

Multi-Color Coating 680 (5.7) 

Pretreatment Coating 660 (5.5) 

Primer 250 (2.1) 

Sealer 650 (5.4) 

Single-Stage Coating 340 (2.8) 

Specialty Coating 540 (4.5) 

Temporary Protective Coating 60 (0.5) 

Truck Bed Liner Coating 200 (1.7) 

Trunk Interior Coating 650 (5.4) 

Underbody Coating 650 (5.4) 

Uniform Finish Coating 540 (4.5) 

Any other coating type 250 (2.1) 

B. Most Restrictive VOC Limit: If anywhere on the container of any automotive coating, 

or any label or sticker affixed to the container, or in any sales, advertising, or technical 

literature supplied by a person, any representation is made that indicates that the 

coating meets the definition of or is recommended for use for more than one of the 

coating categories listed in Table of Standards, then the lowest VOC content limit shall 

apply. 

Appendix A A-7 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

C. Alternate Emission Control: In lieu of complying with VOC content limits specified in 

Table of Standards, an emission control system with a capture efficiency of at least 

90% and a control efficiency of at least 90% may be used if it has been approved in 

writing by the Air Pollution Control Officer (APCO). Any approved emission control 

system must be maintained and used in proper working condition at all times. Use of a 

VOC emission control system shall not result in emissions in excess of those that would 

have been emitted had the operator complied with the provisions of Section V.A. 

D. Spray Booth: All surface coatings subject to this Rule shall be applied within a 

permitted, properly maintained, and operational paint spray booth located at a site with 

proper city or county zoning. 

E. Coating Application Methods: No person shall apply any coating to any motor vehicle, 

mobile equipment, or associated parts and components unless one of the following 

application methods is used: 

1. Brush, dip, flow, or roll coating conducted in accordance with manufacturer's 

recommendations. 

2. Electrostatic or electrodeposition application conducted in accordance with 

manufacturer's recommendations. 

3. HVLP spray equipment operated in accordance with manufacturer's 

recommendations. 

4. Spray gun: If a spray gun is used, the end user must demonstrate that the gun meets 

the HVLP definition in Section IV.T in design and use. A satisfactory 

demonstration must be based on the manufacturer's published technical material on 

the design of the gun and by a demonstration of the operation of the gun using an 

air pressure tip gauge from the manufacturer of the gun. 

5. Any alternative coating application method which has been demonstrated to achieve 

at least 65% transfer efficiency or the equivalent efficiency of an HVLP and 

approved, in writing, by APCO. 

Section VI.E does not apply to underbody coatings, graphic arts operations, truck bed 

liner coatings, or any coating use of less than one (1) fluid ounce (29.6 milliliters). 

F. Surface Preparation and Equipment Cleanup Requirements: No person shall conduct 

surface preparation or equipment cleanup for activities subject to provisions of this 

Rule unless the following VOC limits are met and methods are used: 

1. VOC content of surface preparation solvent shall not exceed 25 g/l (0.2 lb/gal), as 

calculated pursuant to Section IV.RR.3, unless Section V.E applies. 

Appendix A A-8 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

2. Coatings Application Equipment Cleaning: Solvents used for cleaning of coatings 

application equipment shall comply with both limits specified below: 

a. Solvent shall have a VOC content of 950 grams or less per liter (7.9 lb/gal) of 

material; and 

b. Solvent shall have a VOC composite partial pressure of 35 mm Hg or less at 

20/C (68/F). 

3. Cleaning Devices and Methods Requirements: No person shall perform solvent 

cleaning operations unless one of the following cleaning devices or methods is 

used: 

a. Wipe cleaning; 

b. Spray bottles or containers with a maximum capacity of 16 fluid ounces from 

which solvents are applied without a propellant-induced force; 

c. Cleaning equipment having a closed solvent container during cleaning 

operations, except when depositing and removing objects to be cleaned, and 

closed during nonoperation except during maintenance and repair of the 

cleaning equipment itself; 

d. Remote reservoir cold cleaner operated in conformance with District Rule 

410.3, Organic Solvent Degreasing Operations; 

e. System totally enclosing spray guns, cups, nozzles, bowls, and other parts 

during washing, rinsing, and draining procedures; 

f. Non-atomized solvent flow method collecting cleaning solvent in a container or 

a collection system closed except for solvent collection openings and, if 

necessary, openings to avoid excessive pressure build-up inside the container; or 

g. Solvent flushing method discharging cleaning solvent into a container closed 

except for solvent collection openings and, if necessary, openings to avoid 

excessive pressure build-up inside the container. Discharged solvent from such 

equipment shall be collected into containers without atomizing into open air. 

Solvent may be flushed through the system by air or hydraulic pressure, or by 

pumping. 

G. Storage and Disposal: Regardless of VOC content, all automotive coating components, 

automotive coatings, and solvents, shall be stored in non-absorbent, vapor-tight 

containers kept closed at all times except when filling or emptying. 

H. Prohibition of Sale or Manufacture: No person shall manufacture, blend, repackage for 

sale, supply, sell, offer for sale or distribute within the District any coating with a VOC 

content in excess of the limits specified in Section VI.A. 

Appendix A A-9 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

Notwithstanding the provisions of this section, a person may manufacture, blend, 

repackage for sale, supply, sell, offer for sale, or distribute a coating with a VOC 

content in excess of the limits specified in section VI.A under the following 

circumstances and provided all of the requirements of section VII.C.6 are also met: 

1. The coating is used exclusively within an emission control system as allowed in 

Section VI.C, or 

2. Coating is exempt under one or more of the provisions of Section V.A. 

I. Prohibition of Specification: No person shall solicit or require the use of, or specify the 

application or use of any coating or solvent on a motor vehicle or mobile equipment, or 

its associated parts and components, if such use or application results in a violation of 

this Rule. This prohibition shall apply to all written or oral contracts, including but not 

limited to, job orders, under the terms of which any coating or solvent subject to 

provisions of this Rule is to be applied. This prohibition shall not apply to coatings or 

solvents that meet the criteria specified in Section VI.H. 

J. Sell-Through/Existing Stock of Coatings: A coating manufactured prior to amendment 

date of this rule, that complied with the VOC Content limit(s) in effect at that time, may 

be sold, supplied, or offered for sale for 12 months after rule adoption date. Such a 

coating may be applied at any time, both before and after adoption date, provided 

manufacture Date-Code and VOC Content is clearly printed on coating container. 

VII. Administrative Requirements

A. Compliance Statement Requirement

1. For each individual automotive coating or automotive coating component, the 

manufacturer and repackager shall include the following information on product 

data sheets, or an equivalent medium: 

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in 

grams per liter; 

b. The weight percentage of volatiles, water, and exempt compounds; 

c. The volume percentage of water and exempt compounds; and 

d. The density of the material (in grams per liter). 

2. For each individual ready to spray mixture (based on the manufacturer’s and 

repackager’s stated mix ratio), the manufacturer and repackager shall include the 

following information on product data sheets, or an equivalent medium: 

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in 

grams per liter; 

b. The weight percentage of volatiles, water, and exempt compounds; 

c. The volume percentage of water and exempt compounds; and 

d. The density of the material (in grams per liter). 

Appendix A A-10 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

3. The manufacturer and repackager of solvents subject to this rule shall include the 

VOC content as supplied, calculated pursuant to section IV.RR.3, expressed in 

grams per liter, on product data sheets, or an equivalent medium. 

B. Labeling Requirements

1. The manufacturer and repackager of automotive coatings or automotive coating 

components shall include on all containers the applicable use category(ies), and the 

VOC actual for coatings and VOC regulatory for coatings, as supplied, expressed in 

grams per liter. 

2. The manufacturer and repackager of solvents subject to this rule shall include on all 

containers the VOC content for solvents, as supplied, expressed in grams per liter. 

C. Record Keeping Requirements

Any person who uses coatings or solvents, subject to this rule, shall maintain and have 

the following available on site at all times: 

1. A current list of all VOC containing products in use that includes any data 

necessary to evaluate compliance, including but not limited to, the following 

information as applicable: 

a. Material name and manufacturer's identification; 

b. Application method; 

c. Material type (coating as listed in Table of Standards) and specific use 

instructions; 

d. Specific mixing instructions; 

e. VOC actual and VOC regulatory for coatings, as applied, or VOC content for 

solvent. 

2. Daily coating and solvent use records, including the following information for each: 

a. Volume of each coating/solvent mix ratio; 

b. VOC content in grams/liter (or pounds/gallon) as applied/used; 

c. Volume of each coating/solvent in liters (or gallons) applied/used; 

d. Type and amount of solvent used for cleanup and surface preparation. 

If purchase records are used to determine the amount of solvents used, then records 

and manifests of the amounts of solvents disposed of or sent to a recycler must also 

be maintained and made available to the APCO upon request. 

3. Current manufacturer specification sheets, material safety data sheets, technical data 

sheets, or air quality data sheets, which list the VOC actual for coatings and VOC 

regulatory for coatings of each ready-to-spray coating (based on the manufacturer’s 

stated mix ratio), and VOC content of each solvent. 

4. Purchase records identifying the coating type (as listed in Table of Standards), 

name, and volume of coatings and solvents. 

Appendix A A-11 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

5. Alternate Emissions Control Records: Any person using an emission control 

system shall maintain daily records of key system operating parameters which will 

demonstrate continuous operation and compliance of the emission control system 

during periods of VOC emission producing activities. “Key system operating 

parameters” are those parameters necessary to ensure or document compliance with 

Section VI.C., including, but not limited to, temperatures, pressure drops, and air 

flow rates. 

6. Record Keeping Requirements for Prohibition of Sale: Any person claiming an 

exception specified in Section VI.H shall keep a detailed log of each automotive 

coating component and automotive coating manufactured, blended, repackaged for 

sale, supplied, sold, offered for sale, or distributed showing: 

a. The quantity manufactured, blended, repackaged for sale, supplied, sold, offered 

for sale, or distributed, including size and number of containers; 

b. The VOC regulatory for coatings; 

c. The VOC actual for coatings; 

d. To whom they were supplied, sold, offered for sale, or distributed, or for whom 

they were manufactured, blended, or repackaged for sale including the name, 

address, phone number; and 

e. The specific exception being utilized under Section VI.C. 

7. Record Retention: Records required by this Rule shall be retained for a minimum 

of three years and made available to the APCO upon request. 

VIII. Test Methods

The following test methods are incorporated by reference herein, and shall be used to test 

emission sources subject to the provisions of this rule. A source is in violation of this rule 

if any measurement by any of the listed applicable test methods exceeds any standard of 

this rule. 

A. Acid Content: Measure of acid content shall be determined by using ASTM D1613-03 

“Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates 

Used in Paint, Varnish, Lacquer, and Related Products” (October 2003). 

B. Analysis of Samples: Samples of VOC as specified in this Rule shall be analyzed by 

EPA Method 24 as set forth in Appendix A of Title 40 of the Code of Federal 

Regulations (40 CFR) Part 60, “Determination of Volatile Matter Content, Water 

Content, Density, Volume Solids, and Weight Solids of Surface Coatings”. Analysis of 

halogenated exempt compounds shall be conducted using CARB Method 422, 

“Determination of Volatile Organic Compounds in Emissions from Stationary Sources” 

(September 12, 1990). 

C. Alternative Test Methods: The use of other test methods which are determined to be 

equivalent or better and approved, in writing, by the APCO, ARB, and EPA may be 

used in place of the test methods specified in this rule. 

Appendix A A-12 Draft 3/13/2014 
410.4A Final Staff Report – Amended Rule 

Appendix A A-13 Draft 3/13/2014 

D. Control and Capture Efficiency: Capture and control efficiency of emission control 

systems shall be determined as specified in EPA’s “Guidelines for Determining Capture 

Efficiency,” (January 9, 1995) and 40 CFR 51, Appendix M, Methods 204-204f as 

applicable. Total organic emissions of emission control systems shall be determined 

using EPA Method 25, 25A or 25B. 

E. Determination of Emissions: Emissions of VOC shall be measured by EPA Method 25, 

25A, or 25B, as applicable and analysis of halogenated exempt compounds shall be 

conducted using CARB Method 432, “Determination of Dichloromethane and 1,1,1- 

Trichloroethane in Paints and Coatings” (September 12, 1998). 

F. Exempt Organic Compound Content of Coatings: The exempt organic compound 

content of coatings or solvents shall be determined using ASTM Method D 6133- 02, 

Standard Test Method for Acetone, p-Chlorobenzotrifluoride, Methyl Acetate, or tButyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and 

Raw Materials by Direct Injection into a Chromatograph. Exempt organic compound 

content, other than as determined above, shall be determined by using CARB Method 

422, CARB Method 432, or South Coast AQMD Method 303-91, “Determination of 

Exempt Compounds” (February 1993). 

G. HVLP Equivalency: Spray Equipment HVLP equivalency shall be determined by 

using South Coast Air Quality Management District’s “Guidelines for Demonstrating 

Equivalency with District Approved Transfer Efficient Spray Guns” (September 26, 

2002). 

H. Metallic Content: The metallic content of a coating shall be determined by South Coast 

Air Quality Management District Test Method 318-95, " Determination of Weight 

Percent Elemental Metal in Coatings by X-ray” (July 1996). 

I. Transfer Efficiency: Spray equipment transfer efficiency shall be determined by using 

South Coast Air Quality Management District Method "Spray Equipment Transfer 

Efficiency Test Procedure for Equipment User", (May 24, 1989). 

J. VOC Composite Partial Pressures: VOC composite partial pressures shall be 

determined using either manufacturer's information regarding formulation or using 

ASTM Methods E169-04, Standard Practices for General Techniques of UltravioletVisible Quantitative Analysis or E260-96, Standard Practice for Packed Column Gas 

Chromatography for determination of mole fractions and then summing products of 

each VOC component's vapor pressure and its mole fraction. For materials containing 

no non-VOC components, VOC composite partial pressure can be measured directly by 

ASTM Method D2879-10 Standard Test Method for Vapor Pressure-Temperature 

Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope. 

K. VOC Emissions from Spray Gun Cleaning Systems: VOC emissions shall be 

determined using South Coast AQMD "General Test Method for Determining Solvent 

Losses from Spray Gun Cleaning Systems" (October 3, 1989). 
APPENDIX B: 

AMENDED RULE 410.4A 

MOTOR VEHICLE AND MOBILE EQUIPMENT 

REFINISHING OPERATIONS 

STRIKEOUT UNDERLINE VERSION 
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-1 Draft 3/13/2014 

RULE 410.4A Motor Vehicle and Mobile Equipment Refinishing Operations - Adopted 

5/6/91, Amended 4/6/95, 3/7/96, 3/13/14

I. Purpose

The purpose of this rule is to limit volatile organic compound (VOC) emissions from 

coatings and solvents used in production, repair, refinish, or maintenance operations 

where motor vehicles, mobile equipment, or associated parts and components are coated.

II. Applicability

The provisions of this Rule are enforceable upon amendment date and shall apply to any 

person who supplies, sells, offers for sale, manufactures, distributes, uses, applies, or 

solicits the use or application of any automotive coating or associated solvent within the 

District.

III. Severability

Each provision of this rule shall be deemed severable, and in the event that any provision 

of this rule is held to be invalid, the remainder of this rule shall continue in full force and 

effect.

IIIV. Definitions

A. Adhesion Promoter: A coating, which is labeled and formulated to be applied to 

uncoated plastic surfaces to facilitate bonding of subsequent coatings, and on which, a 

subsequent coating is applied.

B. Aerosol Coating Product: A pressurized coating product containing pigments or 

resins that dispenses product ingredients by means of a propellant, and is packaged in 

a disposable can for hand-held application, or for use in specialized equipment for

ground traffic/marking applications.

C. APCO: Air Pollution Control Officer of the Eastern Kern Air Pollution Control 

District.

A. Antiglare Coating: coating not reflecting light.

D. Assembly Line: An arrangement of industrial equipment and workers in which the 

product passes from one specialized operation to another until complete, by either 

automatic or manual means.

E. Associated Parts and Components: Structures, devices, pieces, modules, sections, 

assemblies, subassemblies, or elements of motor vehicles or mobile equipment that 

are designed to be a part of motor vehicles or mobile equipment but which are not 

attached to motor vehicles or mobile equipment at the time of coating the structure, 

device, piece, module, section, assembly, subassembly, or element. “Associated parts 

and components” does not include circuit boards.

F. Automotive Coating: Any coating or coating component used or recommended for 

use in motor vehicle or mobile equipment refinishing, service, maintenance, repair, 
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Appendix B B-2 Draft 3/13/2014 

restoration, or modification, except metal plating activities. Any reference to 

automotive refinishing or automotive coating made by a person on the container or in 

product literature constitutes a recommendation for use in motor vehicle or mobile 

equipment refinishing.

G. Automotive Coating Component: Any portion of a coating, including, but not limited 

to, a reducer or thinner, toner, hardener, and additive, which is recommended by any 

person to distributors or end-users for use in an automotive coating, or which is 

supplied for or used in an automotive coating. The raw materials used to produce the 

components are not considered automotive coating components.

H. Automotive Refinishing Facility: Any shop, business, location, or parcel of land 

where motor vehicles or mobile equipment or their associated parts and components 

are coated, including autobody collision repair shops. “Automotive Refinishing 

Facility” does not include the original equipment manufacturing plant where the 

motor vehicle or mobile equipment is completely assembled.

B. Basecoat/Clearcoat System: topcoat system composed of pigmented basecoat 

followed by transparent clearcoat. A basecoat/clearcoat system's Volatile Organic 

Compound (VOC) content shall be calculated using the following formula:

VOC bc/cc = VOC bc + 2 VOC 

cc

3

Where:

VOC bc/cc = sum of VOC content as applied in basecoat (bc) and clearcoat (cc) 

system.

VOC bc = VOC content as applied of any given basecoat.

2 VOC cc = two times VOC content as applied of any given clearcoat.

C. Camouflage Coating: applied on military vehicle or mobile equipment intended to 

conceal such equipment from detection.

I. California Air Resources Board (CARB or ARB): Air Resources Board of the 

California Environmental Protection Agency.

D. Catalyst: substance enhancing a reaction between chemical compounds.

J. Cleaning Operations: The removal of loosely held uncured adhesives, inks, coatings, 

or contaminants, including, but not limited to, dirt, soil, or grease, from motor 

vehicles, mobile equipment, associated parts and components, substrates, parts, 

products, tools, machinery, equipment, or general work areas.

K. Clear Coating: Any coating that contains no pigments and is labeled and formulated 

for application over a color coating or clear coating.
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Appendix B B-3 Draft 3/13/2014 

L. Coating: A material which is applied to a surface and forms a film in order to 

beautify, preserve, repair, or protect such a surface.

M. Color Coating: Any pigmented coating, excluding adhesion promoters, primers, and 

multi-color coatings, that requires a subsequent clear coating and which is applied 

over a primer, adhesion promoter, or color coating. Color coatings include 

metallic/iridescent color coatings.

E. Color Match: ability of a repair coating to blend into an existing coating so color 

differences are not visible.

FN. Electrodeposition: applying Applying an electrically-charged dip coating onto 

object to be coated. 

GO. Electrostatic Spray Application: Any method of spray application of coatings 

where an electrostatic attraction is created between the part to be coated and the paint 

particles. spraying an electrically-charged coating onto an object.

P. Emission Control System: Any combination of capture systems and control devices 

used to reduce VOC emissions from automotive coating operations.

Q. EPA: The United States Environmental Protection Agency.

HR. Exempt Compounds: As defined in District Rulecompounds identified as exempt 

under the definition of volatile organic compounds 102, Subsection L.Definitions, 

“Exempt Compounds”. 

I. Extreme Performance Coating: coating used on surface of Group II Vehicle, Mobile 

Equipment, or their parts or components, intended, during use, to be exposed to any 

of the following during use:

1. Industrial grade detergents, cleaners, or abrasive scouring agents,

2. Unprotected shipboard conditions, or

3. Corrosive environmental conditions.

J. Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt 

Compounds: weight of VOC per combined volume of VOC and coating solids shall 

be calculated using the following equation:

Grams of VOC per Liter of

Coating Applied, Excluding

Water and Exempt Compounds = Ws - Ww - Wec

Vc - Vw – Vec

Where:

Ws = weight of VOC in grams

Ww = weight of water in grams

Wec = weight of exempt compounds in grams

Vc = volume of coating in liters
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Appendix B B-4 Draft 3/13/2014 

Vw = volume of water in liters

Vec = volume of exempt compounds in liters

K. Grams of VOC per liter of Material: weight of VOC per volume of material using the

following equation:

Grams of VOC per Liter of Material = Ws - Ww - Wec

Vm

Where:

Ws = weight of VOC in grams

Ww = weight of water in grams

Wec = weight of exempt compounds in grams

Vm = volume of material in liters

LS. Graphic Arts Operation: application Application of logos, letters, numbers or 

graphics to a painted surface with or without use of a template. 

M. Group I Vehicle: passenger car, large/heavy duty truck cab and chassis, light and

medium duty truck or van, or motorcycle.

N. Group II Vehicle: bus.

OT. High-Volume, Low-Pressure (HVLP) Spray: Spray equipment permanently 

labeled as such and which is designed and operatedapplying coating using a gun 

operating between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing

pressure measured dynamically at the center of the air cap and at the air horns and 

with liquid supply pressure less than 50 psig. 

P. Large/Heavy Duty Truck: truck having a manufacturer's gross vehicle weight rating 

of over 10,000 pounds.

Q. Light and Medium Duty Truck or Van: truck or van having a manufacturer's gross

vehicle weight rating of 10,000 pounds or less.

RU. Metallic/Iridescent Topcoat: coating Coating as applied containing more than 5 

g/1 (0.042 lb/gal) of visible metal or iridescent particles, where such particles are 

visible in the dried film..

V.S. Mobile Equipment: equipment Equipment drawn or capable of being driven on a 

roadway, including, but not limited to a: truck body, truck trailer, utility body, camper 

shell, mobile crane, bulldozer, construction and farm heavy equipment, concrete 

mixers, street cleaner, golf cart, all terrain vehicles, implements of husbandry,

military tank or other tracked military vehicle and hauling equipment used inside and 

around airports, depots, and industrial and commercial plants.

W. Motor Vehicle: As defined in Rule 102, Definitions.
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Appendix B B-5 Draft 3/13/2014 

T. Multistage Topcoat: topcoat system consisting of basecoat/clearcoat system (twostage) or basecoat/midcoat/clearcoat system (three-stage).

X. Multi-Color Coating: Any coating that exhibits more than one color in the dried film 

after a single application, is packaged in a single container, and hides surface defects 

on areas of heavy use, and which is applied over a primer or adhesion promoter.

UY. Precoat: coating Coating applied to bare metal primarily to deactivate metal 

surface for corrosion resistance and adhesion. For compliance with this Rule, any 

precoat shall be followed by a water-based primer coat.

VZ. Pretreatment Wash PrimerCoating: coating Coating containing a minimum of 

0.5% acid by weight and not more than 16 percent solids by weight, necessary to 

provide surface etching and is labeled and formulated for application, and applied 

directly to bare metal surfaces to provide corrosion resistance and adhesion. 

WAA. Primer: Any coating, which is labeled and formulated for application to a 

substrate to provide 1) a bond between the substrate and subsequent coats, 2) 

corrosion resistance, 3) a smooth substrate surface, or 4) resistance to penetration of 

subsequent coats, and on which a subsequent coating is applied. Primers may be 

pigmented.coating applied prior to application of a topcoat for the purpose of 

corrosion resistance and adhesion of the topcoat.

X. Primer Sealer: coating applied prior to application of a topcoat for the purpose of

corrosion resistance, adhesion of the topcoat, color uniformity, and to promote the

ability of an undercoat to resist penetration by the topcoat.

Y. Primer Surfacer: coating applied prior to application of a topcoat for the purpose of

corrosion resistance, adhesion of the topcoat, and promoting a uniform surface by 

filling in surface imperfections.

Z. Reducer/Thinner: solvent used to thin coating.

AABB. Refinish: coating Coating of vehicles, their parts and components, or mobile 

equipment, including partial body collision repairs, for the purpose of protection or 

beautification and subsequent to the original coating applied at an Original 

Equipment Manufacturing (OEM) plant coating assembly line.

CC. Single-Stage Coating: Any pigmented coating, excluding primers and multi-color 

coatings, labeled and formulated for application without a subsequent clear coat. 

Single-stage coatings include single-stage metallic/iridescent coatings.

DD. Solvent: As defined in Rule 410.3, Organic Solvent Degreasing Operations.

EE. Spray Booth: Any power ventilated structure of varying dimensions and construction 

provided to enclose or accommodate a spraying operation and which meets the 

Uniform Fire Code. A spray booth shall confine and limit, by dry or wet filtration, the 

escape to the atmosphere of overspray particulate matter, exhaust through filters or 

other air pollution control device approved by the APCO and provide adequate 

ventilation, air velocity, and safety features, as required by the Uniform Fire Code.
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Appendix B B-6 Draft 3/13/2014 

BBFF. Specialty Coating: coating Coating necessary due to for unusual job performance 

requirements, including, but not limited to, adhesion promoters, uniform finish 

blenders elastomeric materials, gloss flatteners, bright metal trim repair, and antiglare/safety coatings, and cut in or jambing clear coatings.

. 

CCGG. Spot/Panel Repair: nonNon-assembly line process of repairing and restoring a 

portion of a motor vehicle, or associated parts or components of less than 1 square 

foot (929 square centimeters)to predamaged condition.

HH. Surface Preparation: The use of VOC containing solvents applied with cloth, sponge, 

or other medium for the purpose of removing dust, grease, and other contaminants 

from a surface just prior to application of a coating.

II. Temporary Protective Coating: Any coating which is labeled and formulated for the 

purpose of temporarily protecting areas from overspray or mechanical damage.

DD. Three-Stage Coating System: topcoat system composed of pigmented basecoat, 

semitransparent midcoat, and transparent clearcoat. A three-stage coating system's 

VOC content shall be calculated using the following formula:

VOC 3-stage = VOC bc + VOC mc + 2 VOC cc

4

Where:

VOC 3-stage = average VOC content as applied in a three-stage coating system.

VOC bc = VOC content as applied of any given basecoat.

VOC mc = VOC content as applied of any given midcoat.

2 VOC cc = two times VOC content as applied of any given clearcoat.

EEJJ. Topcoat: coating Coating applied over a primer or an original equipment 

manufacturer finish for the purpose of protection or appearance. 

FFKK. Touch-Up Coating: coating A coating used to cover minor coating imperfections 

appearing after the main coating operation.applied by brush, airbrush, detail HVLP 

spray equipment, or hand held, non-refillable aerosol cans to repair minor surface 

damage and imperfections, after main coating process, and not exceeding nine square 

feet per vehicle.

LL. Transfer Efficiency: The amount of coating solids adhering to the object being 

coated divided by the total amount of coating solids sprayed, expressed as a 

percentage.

MM. Truck Bed Liner Coating: Any coating, excluding clear, color, multi-color, and 

single stage coatings, labeled and formulated for application to a truck bed to protect 

it from surface abrasion.
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Appendix B B-7 Draft 3/13/2014 

NN. Underbody Coating: Any coating labeled and formulated for application to wheel 

wells, the inside of door panels or fenders, the underside of a trunk or hood, or the 

underside of the motor vehicle.

OO. Uniform Finish Coating: Any coating labeled and formulated for application to the 

area around a spot repair for the purpose of blending a repaired area’s color or clear 

coat to match the appearance of an adjacent area’s existing coating.

GGPP. Utility Body: special Special purpose service compartment or unit to be bolted, 

welded, or affixed onto an existing cab and chassis. Such compartment may serve as 

storage for equipment or parts. 

HHQQ. Volatile Organic Compound (VOC): any Any compound containing at least one 

atom of carbon, excluding Exempt Compounds as listed in Rule 102 Definitions.

except for exempt compounds (see Subsection II.H.).

RR. VOC Content:

1. VOC regulatory for Coatings: VOC in grams per liter of coating, excluding water 

and exempt compounds, and shall be calculated by the following equation:

VOC regulatory content = Wv - Ww - Wec

 Vm - Vw – Vec

2. VOC actual for Coatings: VOC in grams per liter of material shall be calculated 

using the following equation:

VOC actual content = Wv - Ww - Wec

 Vm

3. VOC content for Solvents: VOC in grams per liter of material shall be calculated 

by the following equation:

VOC content = Wv - Ww - Wec

 Vm

Where:

VOC content = amount of volatile organic compounds in grams/liter

Wv = weight of volatiles in grams

Ww = weight of water in grams

Wec = weight of exempt compounds in grams

Vm = volume of material (coating or solvent, as applicable) in liters

Vw = volume of water in liters
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Appendix B B-8 Draft 3/13/2014 

Vec = volume of exempt compounds in liters

IIIV. Exemptions

A. Requirements of this Rule shall not apply to the following operations: 

1. Graphic Arts Operations as defined in Subsection II.L Section IV.S.

2. Any automotive coating or associated solvent that is offered for sale, sold, or 

supplied in 0.5 fluid ounce or smaller containers intended to be used by the 

general public to repair tiny surface imperfections.

23. Coating operations employing hand-held non-refillable aerosol cans, 18 

oz. or less, provided the area to be covered does not exceed nine square feet per 

vehicle to repair minor surface damage and imperfections.

4. Any automotive coating or associated solvent that is offered for sale, sold, or 

manufactured for use outside of the District or for shipment to other 

manufacturers for reformulation or repackaging.

5. Any coating applied to motor vehicles or mobile equipment, or their associated 

parts and components, during manufacture on an assembly line.

B. Requirements of Section IV.DVI.D (Spray Booth) shall not apply to:

1. Touch-up coating operations as defined in Section II.FFIV.KK, not exceeding 

nine square feet per vehicle. 

2. Coating of motor vehicle engine compartments, engine components, and 

suspension components, provided such components are replaced in the vehicle. 

3. Application of primers, primer surfacers and precoats not exceeding nine square 

feet per vehicle, provided VOC content does not exceed 250 g/l and coatings 

contain no lead or chromium compounds. 

4. Application of coatings to a vehicle, due to shape or size, not reasonably 

contained in a spray booth. To qualify for this exemption a person shall comply 

with the following requirements: 

a. Submit a written request on a case by case basis to the APCO Control Officer 

describing vehicle(s) to be coated, size of spray booth, physical size of 

vehicle(s) (length, width, and height), number of vehicle(s) to be coated, time 

required to paint vehicle(s), estimated volume of coating(s) to be used, date 

when vehicle(s) or mobile equipment is to be coated, and VOC content of 

each coating used; 

b. Such request shall be submitted ten calendar days prior to surface coating a 

motor vehicle or mobile equipment outside a spray booth. The APCO Control 

Officer shall provide a written determination to the requester within five 
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Appendix B B-9 Draft 3/13/2014 

calendar days of proposed surface coating of the motor vehicle or mobile 

equipment; and 

c. The APCO Control Officer may grant written approval for a specified time 

period, not to exceed one year. 

C. Coating operations and/or facilities exempt from this Rule shall comply with all other 

applicable District prohibitory Rules. 

D. Provisions of Subsections Sections IVI.C. through VI.G. and Section VII. shall not 

apply to coating of one vehicle per twelve month period, by the registered owner of 

the vehicle being painted, provided the surface coating does not contain lead or 

chromium compounds. 

E. Section VI.F, Surface Preparation and Equipment Cleanup Requirements, shall not 

apply to the use of surface preparation solvents to clean plastic parts just prior to 

coating or VOC-containing materials for the removal of wax and grease provided that 

nonaerosol, hand-held spray bottles are used with a maximum solvent VOC content 

of 780 g/l and the total volume of the solvent does not exceed 20 gallons per year per 

facility. Records of solvent usage shall be kept in accordance with Section VII.C.4 of 

this Rule.

IVI. Requirements

A. VOC Content Limits: No person shall apply a coating to any motor vehicle, mobile 

equipment, or its associated parts and components, with a VOC regulatory content, as 

calculated pursuant to Section IV.RR.1, in excess of the limits expressed in Table of 

Standards, except as provided in Sections VI.C and VI.J.

Except as provided by Subsection IV.C., effective on the dates specified, no person shall 

refinish, or spot/panel repair any Group I vehicle, or where color match is required, 

any Group II vehicle, Mobile Equipment, or parts and components of such vehicles or 

equipment, using a coating with VOC content in excess of the following limits as 

applied:

TABLE OF STANDARDS

VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS

Content expressed in Grams per Liter (Pounds per Gallon)

Less Water and Exempt Compounds

Coating Category VOC Limit

Adhesion Promoter 540 (4.5)

Cavity Wax 650 (5.4)

Clear Coating 250 (2.1)

Color Coating 420 (3.5)

Deadener 650 (5.4)

Gasket/Gasket Sealing Material 200 (1.7)
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Appendix B B-10 Draft 3/13/2014 

Lubricating Wax/Compound 700 (5.8)

Multi-Color Coating 680 (5.7)

Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Sealer 650 (5.4)

Single-Stage Coating 340 (2.8)

Specialty Coating 540 (4.5)

Temporary Protective Coating 60 (0.5)

Truck Bed Liner Coating 200 (1.7)

Trunk Interior Coating 650 (5.4)

Underbody Coating 650 (5.4)

Uniform Finish Coating 540 (4.5)

Any other coating type 250 (2.1)

VOC Content Limits

(Grams of VOC Per Liter of Coating Less Water and

Less Exempt Compounds)

Coating Current Effective 1/1/96

 

Pretreatment 780 g/l 780 g/l

Wash Primer (6.5 lb/gal) (6.5 lb/gal)

 

Primer/Primer 340 250

Surface Precoat (2.8) (2.1)

 

Primer Sealer 420 420

(3.5) (3.5)

 

Multistage Topcoat 600 540

(5.0) (4.5)

 

Singlestage Topcoat 600 420

(5.0) (3.5)

 

Metallic/Iridescent 600 540

Topcoat (5.0) (4.5)

B. VOC Content Limits: Except as provided by Subsection IV.C., effective on the dates 

specified, where color match is not required, no person shall refinish or spot/panel 

repair any Group II vehicle, or Mobile Equipment, or parts and components of such 

vehicle or equipment using a coating with a VOC content in excess of the following 

limits as applied:

VOC Content Limits
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Appendix B B-11 Draft 3/13/2014 

(Grams of VOC Per Liter of Coating Less Water and

Less Exempt Compounds)

Coating Current Effective 1/1/96

 

Pretreatment 780 g/l 780 g/l

Wash Primer (6.5 lb/gal) (6.5 lb/gal)

 

Primer/Primer Surfaces 340 250

Primer Sealer/Precoat (2.8) (2.1)

 

Topcoat 420 420

(3.5) (3.5)

 

Metallic/Iridescent 420 420

Topcoat (3.5) (3.5)

 

Extreme Performance* 750 420

(6.2) (3.5)

 

Camouflage 420 420

Topcoat (3.5) (3.5)

* Any person seeking to use an extreme performance coating in any application 

subject to this Rule shall comply with requirements of Subsection V.A.

B. Most Restrictive VOC Limit: If anywhere on the container of any automotive 

coating, or any label or sticker affixed to the container, or in any sales, advertising, or 

technical literature supplied by a person, any representation is made that indicates that 

the coating meets the definition of or is recommended for use for more than one of 

the coating categories listed in Table of Standards, then the lowest VOC content limit

shall apply.

C. Alternate Emission Control: In lieu of complying with VOC content limits specified 

in subsections IV.A. and IV.B.Table of Standards, air pollutionan emission control 

equipment system with a capture efficiency of at least 90% and a control efficiency of 

at least 90% may be used if it has been approved in writing by the Air Pollution 

Control Officer (APCO). Any approved emission control system must be maintained

and used in proper working condition at all times. Use of a VOC emission control 

system shall not result in emissions in excess of those that would have been emitted 

had the operator complied with the provisions of Section V.A.

with a capture efficiency of at least 85% and a control efficiency of at least 90% may be 

used.

D. Spraybooth Booth: All surface coatings subject to this Rule shall be applied within a 

permitted, properly maintained, and operational paint spray booth located at a site 

with proper city or county zoning. 

E. Coating Application Methods Equipment Requirements: No person shall coat apply

any coating to any Group I or Group II Vehicle,motor vehicle, or Mobile mobile 
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Appendix B B-12 Draft 3/13/2014 

Equipmentequipment, or associated parts and components of such vehicles and 

equipment, unless one of the following application methods is used: 

1. Brush, dip, flow, or roll coating conducted in accordance with manufacturer's 

recommendations, 

2. Electrostatic or electrodeposition application conducted in accordance with 

manufacturer's recommendations, 

3. High Volume Low Pressure (HVLP) spray equipment operated in accordance 

with manufacturer's recommendations, or

4. Spray gun: If a spray gun is used, the end user must demonstrate that the gun 

meets the HVLP definition in Section IV.T in design and use. A satisfactory 

demonstration must be based on the manufacturer's published technical material 

on the design of the gun and by a demonstration of the operation of the gun using 

an air pressure tip gauge from the manufacturer of the gun.

45. Other Any alternative coating application method which has been 

demonstrated to achieve at least 65% transfer efficiency or the equivalent 

efficiency of an HVLP and approved, in writing, by APCO. , for example, flow or 

continuous coating.

Section VI.E does not apply to underbody coatings, graphic arts operations, truck bed 

liner coatings, or any coating use of less than one (1) fluid ounce (29.6 milliliters).

F. Surface Preparation and Equipment Cleanup Requirements: No person shall conduct 

surface preparation or equipment cleanup for activities subject to provisions of this 

Rule unless the following VOC limits are met and methods are used: 

1. VOC content of surface preparation solvent shall not exceed 25 g/l (0.2 lb/gal), as 

calculated pursuant to Section IV.RR.3, unless Section V.E applies.

1. Surface Cleaning: No material shall be used containing VOC in excess of 200 

grams per liter (1.7 lb/gal) of material to remove dirt, oils, or other contaminants 

prior to application of surface coatings or adhesives.

2. Stripping: No material shall be used containing VOC in excess of 200 grams per 

liter of material to strip any coating.

32. Cleaning of Coatings Application Equipment: Solvents used for cleaning 

of coatings application equipment shall comply with both limits specified below: 

a. Solvent shall have a VOC content of 950 grams or less per liter (7.9 lb/gal) of 

material; and 

b. Solvent shall have a VOC composite partial pressure of 35 mm Hg or less at 

20/C (68/F). 
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Appendix B B-13 Draft 3/13/2014 

4. Cleaning of Polyester Resin Application Equipment: Solvents used for cleaning 

polyester resin application equipment shall comply with one of the limits 

specified below:

a. Solvent shall have a VOC content of 200 grams or less per liter (1.7 lb/gal); or

b. Solvent shall have a VOC content of 1100 grams or less per liter (9.2 lb/gal)

and a VOC composite partial pressure of 1.0 mm Hg or less at 20/C (68/F).

52. Cleaning Devices and Methods Requirements: No person shall perform 

solvent cleaning operations unless one of the following cleaning devices or 

methods is used: 

a. Wipe cleaning; 

b. Spray bottles or containers with a maximum capacity of 16 fluid ounces from 

which solvents are applied without a propellant-induced force; 

c. Cleaning equipment having a closed solvent container during cleaning 

operations, except when depositing and removing objects to be cleaned, and 

closed during nonoperation except during maintenance and repair of the 

cleaning equipment itself; 

d. Remote reservoir cold cleaner operated in conformance with District Rule 

410.3, Organic Solvent Degreasing Operations; 

e. System totally enclosing spray guns, cups, nozzles, bowls, and other parts 

during washing, rinsing, and draining procedures; 

f. Non-atomized solvent flow method collecting cleaning solvent in a container 

or a collection system closed except for solvent collection openings and, if 

necessary, openings to avoid excessive pressure build-up inside the container; 

or 

g. Solvent flushing method discharging cleaning solvent into a container closed 

except for solvent collection openings and, if necessary, openings to avoid 

excessive pressure build-up inside the container. Discharged solvent from 

such equipment shall be collected into containers without atomizing into open 

air. Solvent may be flushed through the system by air or hydraulic pressure, or 

by pumping. 

G. Storage and Disposal: Regardless of VOC content, all automotive coating 

components, automotive coatings, and solvents VOC-containing materials used in 

solvent cleaning operations, such as solvents, and cloth and paper moistened with 

solvents, shall be stored in non-absorbent, non-leakingvapor-tight containers kept 

closed at all times except when filling or emptying. 

H. Prohibition of Sale or Manufacture: No person shall manufacture, blend, repackage 

for sale, supply, sell, offer for sale or sell distribute within the District any coating 

with a VOC content in excess of the limits specified in Section VI.A.
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-14 Draft 3/13/2014 

Notwithstanding the provisions of this section, a person may manufacture, blend, 

repackage for sale, supply, sell, offer for sale, or distribute a coating with a VOC 

content in excess of the limits specified in section VI.A under the following 

circumstances and provided all of the requirements of section VII.C.6 are also met:

if such product is prohibited by any provisions of this Rule. This prohibition shall apply 

to sale of any coating to be applied at any physical location within the District.

1. The coating is used exclusively within an emission control system as allowed in 

Section VI.C, or

2. Coating is exempt under one or more of the provisions of Section V.A.

I. Prohibition of Specification: No person shall solicit or require for the use of, or 

specify the application of aor use of any coating or solvent on a Group I Vehicle or 

Group II Vehicle motor vehicle and or Mobile mobile Equipment equipment, or its 

associated parts and components, if such use or application results in a violation of 

provisions of this Rule. This prohibition shall apply to all written or oral contracts, 

including but not limited to, job orders, under the terms of which any coating or 

solvent subject to provisions of this Rule is to be applied. This prohibition shall not 

apply to coatings or solvents that meet the criteria specified in Section VI.H. to any 

vehicle, mobile equipment or part or component at any physical location within the 

District.

J. Sell-Through/Existing Stock of Coatings: A coating manufactured prior to 

amendment date of this rule, that complied with the VOC Content limit(s) in effect at 

that time, may be sold, supplied, or offered for sale for 12 months after rule adoption 

date. Such a coating may be applied at any time, both before and after adoption date, 

provided manufacture Date-Code and VOC Content is clearly printed on coating 

container.

J. Specialty Coatings: No person shall use any specialty coating with a VOC content in 

excess of 840 g/l (7.0 lbs/gal), excluding water and exempt compounds. Where use of 

specialty coatings, except antiglare/safety coatings, exceeds one gallon per day, use of 

such coatings shall not exceed 5.0 percent of all coatings applied on a daily basis.

VII. Administrative Requirements

A. Compliance Statement Requirement

1. For each individual automotive coating or automotive coating component, the 

manufacturer and repackager shall include the following information on product 

data sheets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in 

grams per liter;

b. The weight percentage of volatiles, water, and exempt compounds;

c. The volume percentage of water and exempt compounds; and,
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-15 Draft 3/13/2014 

d. The density of the material (in grams per liter).

2. For each individual ready to spray mixture (based on the manufacturer’s and 

repackager’s stated mix ratio), the manufacturer and repackager shall include the 

following information on product data sheets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in 

grams per liter;

b. The weight percentage of volatiles, water, and exempt compounds;

c. The volume percentage of water and exempt compounds; and,

d. The density of the material (in grams per liter).

3. The manufacturer and repackager of solvents subject to this rule shall include the 

VOC content as supplied, calculated pursuant to section IV.RR.3, expressed in 

grams per liter, on product data sheets, or an equivalent medium.

AB. Labeling Requirements

1. VOC Content: The manufacturer and repackager of automotive coatings or

automotive coating components shall include on all containers the applicable use 

category(ies), and the VOC actual for coatings and VOC regulatory for coatings, 

as supplied, expressed in grams per liter. Each container (or accompanying data 

sheet) of any coating subject to this Rule and manufactured after May 6, 1992 

shall display maximum VOC content of the coating as applied, including coating 

components and after any thinning as recommended by the manufacturer. VOC 

content shall be displayed as grams of VOC per liter less water and exempt 

compounds. VOC content displayed shall be determined using Subsection VI.A. 

test methods or calculated using product formulation data if U.S. EPA approves 

this as equivalent to Subsection VI.A.

2. Thinning Recommendations: The manufacturer and repackager of solvents 

subject to this rule shall include on all containers the VOC content for solvents, as 

supplied, expressed in grams per liter. Each container (or accompanying data 

sheet) of any coating subject to this Rule and manufactured after May 6, 1992 

shall display a statement of manufacturer's recommendation regarding thinning of 

the coating. This requirement shall not apply to thinning of coatings with water.

BC. Record Keeping Requirements

Any person who uses coatings or solvents, subject to this rule, shall maintain and 

have the following available on site at all times:subject to Section IV. or Subsection 

V.B. shall maintain and have available during an inspection:

1. A current list of all VOC containing products in use that includes containing all 

any data necessary to evaluate compliance, including but not limited to, the 

following information, as applicable: 
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-16 Draft 3/13/2014 

a. Material name and manufacturer's identification, 

b. Application method, 

c. Material type (coating as listed in Table of Standards) and specific use 

instructions, for example, "Group I single stage topcoat or precoat shall be 

applied to bare metal and followed with compliant primer",

d. Specific mixing instructions, 

e. Maximum VOC actual and VOC regulatory for content of coatings, as 

applied, or VOC content for solventincluding thinning solvents, hardeners, 

etc., excluding water and exempt compounds, and 

f. Coating composition and density.

2. Daily coating and solvent use records, including the following information for 

each:

a. Volume of each coating/solvent mix ratio,

b. VOC content in grams/liter (or pounds/gallon) as applied/used,

c. Volume of each coating/solvent in liters (or gallons) applied/used.

d. Type and amount of solvent used for cleanup and surface preparation. 

If purchase records are used to determine the amount of solvents used, then 

records and manifests of the amounts of solvents disposed of or sent to a recycler 

must also be maintained and made available to the APCO upon request.

3. Current manufacturer specification sheets, material safety data sheets, technical 

data sheets, or air quality data sheets, which list the VOC actual for coatings and 

VOC regulatory for coatings of each ready-to-spray coating (based on the 

manufacturer’s stated mix ratio), and VOC content of each solvent.

4. Purchase records identifying the coating type (as listed in Table of Standards), 

name, and volume of coatings and solvents.

5. Alternate Emissions Control Records: Any person using an emission control 

system shall maintain daily records of key system operating parameters which 

will demonstrate continuous operation and compliance of the emission control 

system during periods of VOC emission producing activities. “Key system 

operating parameters” are those parameters necessary to ensure or document 

compliance with Section VI.C., including, but not limited to, temperatures, 

pressure drops, and air flow rates.

6. Record Keeping Requirements for Prohibition of Sale: Any person claiming an 

exception specified in Section VI.H shall keep a detailed log of each automotive 
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-17 Draft 3/13/2014 

coating component and automotive coating manufactured, blended, repackaged 

for sale, supplied, sold, offered for sale, or distributed showing:

a. The quantity manufactured, blended, repackaged for sale, supplied, sold, 

offered for sale, or distributed, including size and number of containers;

b. The VOC regulatory for coatings;

c. The VOC actual for coatings;

d. To whom they were supplied, sold, offered for sale, or distributed, or for 

whom they were manufactured, blended, or repackaged for sale including the 

name, address, phone number; and,

e. The specific exception being utilized under Section VI.C.

7. Record Retention: Records required by this Rule shall be retained for a minimum 

of three years and made available to the APCO upon request.

2. Daily job and coating and solvent use records, including the following 

information:

a. Each type of vehicle, equipment, part or component coated. Vehicle types are 

the following:

1) Group I Vehicle,

2) Group I Vehicle with lacquer,

3) Group II Vehicle and Mobile Equipment with color match, or

4) Group II Vehicle and Mobile Equipment with no color match;

b. Specific coatings used on each job, e.g. pretreatment wash primer, precoat, 

topcoat;

c. Volume in liters (or gallons) of each component and mix ratio;

d. VOC content in grams/liter (or pounds/gallon) as applied/used;

e. Specific solvents used;

f. Volume of each solvent used in liters (or gallons); and

g. Primers and primer surfacers mixed for use on multiple vehicles may be 

recorded as single line item including all information required in Subsections 

V.2.c. through V.2.f., above.

3. Capture and control equipment operating records, if applicable, including:

a. Periods of operation corresponding to use records kept for Subsection V.B.2. 

showing control equipment was used as necessary,
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-18 Draft 3/13/2014 

b. Key system operating parameters showing operation as required to comply 

with this Rule and as intended by manufacturer,

c. Date performed, and description of all control system maintenance.

4. Purchase records showing date, type, and amount of VOC containing material. All 

records shall be maintained for three years and made available for inspection by 

the Control Officer upon request.

VIII. Test Methods

The following test methods are incorporated by reference herein, and shall be used to test 

emission sources subject to the provisions of this rule. A source is in violation of this rule 

if any measurement by any of the listed applicable test methods exceeds any standard of 

this rule.

EA. Measurement of Acid Content: - Measure of Acid acid content of Pre-Treatment 

Wash Primers shall be conducted and reported in accordance withdetermined by 

using ASTM D1613-85 03 “Standard Test Method for Acidity in Volatile Solvents 

and Chemical Intermediates used Used in Paint, Varnish, Lacquer, and Related 

Products” (October 2003). 

AB. Analysis of Samples: - Samples of VOC as specified in this Rule shall be 

analyzed by U.S. EPA Method 24 as set forth in Appendix A of Title 40 of the Code 

of Federal Regulations (40 CFR) Part 60, “Determination of Volatile Matter Content, 

Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings”.and 

analysis Analysis of halogenated exempt compounds shall be conducted using 

CARB Method 432 422, “Determination of Volatile Organic Compounds in 

Emissions from Stationary Sources” (September 12, 1990).or ASTM D4457-85 and 

be consistent with provisions set forth in the Federal Register (FR. Vol. 56, No. 52, 

March 18, 1991).

C. Alternative Test Methods: The use of other test methods which are determined to be 

equivalent or better and approved, in writing, by the APCO, ARB, and EPA may be 

used in place of the test methods specified in this rule.

D. Control and Capture Efficiency: Capture and control efficiency of emission control 

systems shall be determined as specified in EPA’s “Guidelines for Determining 

Capture Efficiency,” (January 9, 1995) and 40 CFR 51, Appendix M, Methods 204-

204f as applicable. Total organic emissions of emission control systems shall be 

determined using EPA Method 25, 25A or 25B.

BE. Determination of Emissions: - Emissions of VOC shall be measured by U.S. 

EPA Method 25, 25A, or 25B, as applicable. and analysis of halogenated exempt 

compounds shall be conducted using CARB Method 432, “Determination of 

Dichloromethane and 1,1,1- Trichloroethane in Paints and Coatings” (September 12, 

1998).

C. Determination of Capture Efficiency - Where add-on control equipment is utilized, 

capture efficiency shall be determined in accordance with 40 CFR 52.741.
410.4A Final Staff Report – Strikeout and Underline Amended Rule 

Appendix B B-19 Draft 3/13/2014 

F. Exempt Organic Compound Content of Coatings: The exempt organic compound 

content of coatings or solvents shall be determined using ASTM Method D 6133- 02, 

Standard Test Method for Acetone, p-Chlorobenzotrifluoride, Methyl Acetate, or tButyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and 

Raw Materials by Direct Injection into a Chromatograph. Exempt organic compound 

content, other than as determined above, shall be determined by using CARB Method 

422, CARB Method 432, or South Coast AQMD Method 303-91, “Determination of 

Exempt Compounds” (February 1993).

G. HVLP Equivalency: Spray Equipment HVLP equivalency shall be determined by 

using South Coast Air Quality Management District’s “Guidelines for Demonstrating

Equivalency with District Approved Transfer Efficient Spray Guns” (September 26, 

2002).

DH. Quantification of Metallic Content/Iridescent Topcoat: - Quantification of 

coating as The a metallic/iridescent topcoat content of a coating shall be determined 

by South Coast Air Quality Management District "Test Method 311318-9195", "

Determination of Weight Percent Elemental Metal in Coatings by X-ray” (July 

1996).Analysis of percent Metals in Metallic Coatings by Spectrographic Method".

FI. Demonstration of Transfer Efficiency: - Spray equipment transferTransfer efficiency 

shall be demonstrated determined by using South Coast Air Quality Management 

District Method "Spray Equipment Transfer Efficiency Test Procedure for Equipment 

User", (May 24, 1989). 

GJ. Determination of VOC Composite Partial Pressures: - VOC composite partial 

pressures shall be determined using either manufacturer's information regarding 

formulation or using ASTM Methods E168-92, E169-9304, Standard Practices for 

General Techniques of Ultraviolet-Visible Quantitative Analysis or E260-91 96,

Standard Practice for Packed Column Gas Chromatography for determination of mole 

fractions and then summing products of each VOC component's vapor pressure and 

its mole fraction. For materials containing no non-VOC components, VOC 

composite partial pressure can be measured directly by ASTM Method D2879-8610

Standard Test Method for Vapor Pressure-Temperature Relationship and Initial 

Decomposition Temperature of Liquids by Isoteniscope.

HK. Determination of VOC Emissions From from Spray Gun Cleaning Systems: -

VOC emissions shall be determined using South coast Coast Air Quality 

Management districtAQMD "General Test Method for Determining Solvent Losses 

from Spray Gun Cleaning Systems" (October 3, 1989).

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APPENDIX C 

AMENDED RULE 410.4A 

MOTOR VEHICLE AND MOBILE EQUIPMENT 

REFINISHING OPERATIONS 

RESPONSE TO COMMENTS 
410.4A Final Staff Report - Response to Comments 

Appendix C C-1 Draft 3/13/2014

On November 6, 2013 the District held a public rule development workshop at the 

Mojave Veteran's Building in Mojave, CA to present proposed revisions of Rule 

410.4A, Motor Vehicle and Mobile Equipment Refinishing Operations. The District 

submitted copies of the proposed revision to the Air Resources Board (ARB) and the 

Region IX office of the U.S. Environmental Protection Agency (EPA) in October, 

2013 for an initial 30-day review. 

Upon completion of review EPA offered comments and suggested changes to 

District staff regarding the proposed revision of Rule 410.4A. ARB did not provide 

comments or suggested changes but responded to the District that they would wait 

to review the rule upon submission of the final draft. 

Industry representatives present at the 11/6/2013 workshop asked various questions 

regarding the proposed amendments and submitted written comments within 30-

days following the workshop. Appendix C addresses comments, questions, and 

suggested changes regarding the proposed revision of Rule 410.4A. 

Appendix C is separated into two sections based on EPA comments and suggested 

changes and industry/public comments and questions. 

I. EPA COMMENTS 

The following changes were made to the 8/1/2013 proposed revision of Rule 410.4A 

in response to EPA comments.

Section III, Definitions 

1. EPA commented: P,Q,R,S, should be reorganized in alphabetical order 

District corrected this issue. 

2. EPA commented: OO: The limit of nine square feet is an addition to the 

SJVAPCD's definition. This seems excessive for touch-up. 

District revised to match Rules 410.4 and 410.8 

Section V, Requirements 

1. EPA commented: C. Consider raising the capture efficiency requirement to 90%. 

SJVAPCD Rule 4602 has an overall capture and control efficiency of 90%. 

 District revised per suggestion. 
410.4A Final Staff Report - Response to Comments 

Appendix C C-2 Draft 3/13/2014

2. EPA commented: J. How will this prohibition of possession be enforced?

District: This provision has been removed and sell through provision added (see 

Section VI.J of Appendix A)

Section VII, Administrative Requirements 

1. EPA commented: C-4: Although this rule requires the use of compliant coatings 

and solvents only, consider requiring daily records similar to that in SJVAPCD's 

Rule 4602. 

 District revised this subsection to match Rule 410.4 recordkeeping requirements 

in order to maintain rule consistency. 

Section VIII, Test Methods 

In order to maintain District Rule consistency, Section VIII, Test Methods has been 

revised to closely match Section VII, Test Methods of Rule 410.4. 

1. EPA commented: B. Include the title and date (September 12, 1989) for CARB's 

Method 432 in this first instance. The title in subsection H may be eliminated. 

Include the title for ASTM D4457-85. 

 District revised this section to match Rule 410.4 Analysis of Samples, Section 

VII.B. 

2. EPA commented: F. Add the SCAQMD test method date: October 3, 1989. 

District revised this section to match Rule 410.4. 

3. EPA commented: G. Later versions of ASTM D2879 have been approved by 

EPA. If appropriate, use -96, -97 or -10.

District revised per suggestion. 

4. EPA commented: H. See comment in subsection B. Also the EPA-approved 

CARB Method 422 is dated Sept. 12, 1990 and the EPA-approved SCAQMD 

Method 303-91 is dated August 1996.

District revised per suggestion. 
410.4A Final Staff Report - Response to Comments 

Appendix C C-3 Draft 3/13/2014

II. INDUSTRY/PUBLIC COMMENTS

The following comments were made by industry representatives at, and following the 

11/6/2013 workshop in Mojave, CA. 

American Coatings Association 

American Coatings Association (ACA) submitted the following written comments 

regarding Rule 410.4A on 12/6/2013.

Section II, Applicability 

1. ACA commented: Effective dates: ACA suggests that a clearly defined regulatory 

effective date be added to the rule. As drafted, the proposed regulations do not 

have an effective date. Other California Air Districts have listed an effective date 

per Coating Category in the VOC Content Limits For Motor Vehicle Coatings 

table. Additionally, an effective date can be listed by a separate statement. ACA 

suggest a one-year transition period, prior to the new VOC limits taking effect. 

District added the following language to Section II, Applicability “provisions of this 

Rule are enforceable upon amendment date” and a 12-month sell-through 

provision (see Section VI.J). 

Section IV, Definitions 

1. ACA commented: The following definitions are not mentioned in the proposed 

regulations and should be removed from the definition section: 

i. Catalyst 

ii. Color Match 

iii. Stationary Coating Operation. 

 District revised per suggestion. 

2. ACA commented: The definition of specialty coating should specifically include 

“cut in” or “jambing clear” coatings. 

District revised per suggestion. 

3. ACA commented: The definition of Spot/Panel is redundant. To clarify this 

definition, the language “to a predamanged condition” should be removed. 

District revised per suggestion. 
410.4A Final Staff Report - Response to Comments 

Appendix C C-4 Draft 3/13/2014

4. ACA commented: The definition of Reducer/Thinner should be removed. The 

definition of Solvent should be revised to read as follows: “A VOC-containing fluid 

used to perform cleaning operations or to reduce the viscosity of a coating.” 

District removed Reducer/Thinner and revised Solvent definition to match rules 

410.4 and 410.8. 

5. ACA commented: The following language should be removed from the definition 

of Precoat: “For compliance with this rule, any precoat shall be followed by a 

water-based primer coat.” Compliance with this proposed rule should be based 

solely on VOC content stated in the Volatile Organic Compound (VOC) Content 

Limits for Motor Vehicle Coating Table. 

District revised per suggestion. 

Section V, Exemptions 

1. ACA commented: Consistent with the CARB SCM, ACA suggests including an 

exemption for “assembly lines, as follows: “Any coating applied to motor vehicles 

or mobile equipment, or their associated parts and components, during 

manufacture on an assembly line.” 

 District added exemption (see Section V.A.5. of Appendix A). 

Section VI, Requirements 

1. ACA commented: Sell Through Provision: ACA respectfully requests that a 

clearly expressed sell through provision be added to the rule. The addition of a 

sell through would allow businesses to sell or use products manufactured before 

the effective date for a specified period of time. ACA suggests a sell through 

period of one year after the effective date. 

 District revised per suggestion (see Section VI.J). 

2. ACA commented: VOC Limit for Specialty Coatings: The proposed regulations 

contain VOC limits of 540 g/l for two types of specialty coatings: 1) Adhesion 

Promoters, and 2) Uniform Finish Coatings. ACA urges the Eastern Kern APCD 

to extend this VOC limit of 540 g/l to all specialty coatings, and to remove the 

specific specialty coatings categories for Adhesion Promoters and Uniform Finish 

Coatings. 

 District revised per suggestion. 
410.4A Final Staff Report - Response to Comments 

Appendix C C-5 Draft 3/13/2014

3. ACA commented: Section VI: Requirements E(5) reads as follows: “Any 

alternative coating application method which has been demonstrated to achieve 

at least 65% transfer efficiency or the equivalent efficiency of an HVLP and 

approved, in writing, by the EPA and APCO.” Under the National Auto Refinish 

Rules, there is no requirement for approval by EPA, and multiple agency reviews 

will put an unnecessary burden on manufacturers. ACA urges Eastern Kern 

revise Section IV: Requirements E(5) by replacing “EPA” with “the California Air 

Resources Board (CARB)” or another local or state Air Quality Authority. 

 District removed “EPA”. APCO written approval remains, APCO will make 

determination based on information provided by ARB, EPA, or other air districts 

testing data and approvals. 

Section VII, Administrative Requirements

1. ACA commented: Administrative Requirements B(1) reads as follows: “Coatings: 

The manufacturer and repackager of automotive coatings or automotive coating 

components shall include on all containers the applicable use category(ies), and 

the VOC actual for coatings and VOC regulatory for coatings, as supplied, 

expressed in grams per liter.” Automotive coatings components do not fit into 

categories and VOC content is not relevant for compliance. The VOC content of 

the ready to spray coating is relevant for compliance. Therefore, ACA suggests 

that section VII(B)(1) be revised to read as follows: “Coatings: The manufacturer 

and repackager of automotive coatings shall include on all containers the 

applicable use category(ies), and the VOC actual as supplied and VOC 

regulatory as supplied, expressed in grams per liter.” 

 District removed “Coatings” and “Solvents” were removed from Subsections 

VII.B.1. and VII.B.2. Language from both Subsections are word for word from 

ARB’s SCM. 

2. ACA commented: Section VII: Administrative Requirements C(6) reads as 

follows: “Record Keeping Requirements for Prohibition of Sale: Any person 

claiming an exception specified in Section VI.H shall keep a detailed log of each 

automotive coating component and automotive coating manufactured, blended, 

repackaged for sale, supplied, sold, offered for sale, or distributed showing: 

a. The quantity manufactured, blended, repackaged for sale, supplied, sold, 

offered for sale, or distributed, including size and number of containers; 

b. The VOC regulatory for coatings; 

c. The VOC actual for coatings; 

d. To whom they were supplied, sold, offered for sale, or distributed, or for whom 

they were manufactured, blended, or repackaged for sale including the name, 

address, phone number, retail tax license number, and valid district permit 

number; and, 

e. The specific exception being utilized under Section VI.C. 
410.4A Final Staff Report - Response to Comments 

Appendix C C-6 Draft 3/13/2014

Requiring the manufacturer to keep records maintaining the retail tax license 

number and valid district permit number is an unnecessary burden for both 

manufacturers and distributors. ACA recommends the removal of the retail tax 

license number and valid district permit number from section C(6)(d) and section 

(e) in its entirety – “the specific exception being utilized under Section VI.C.” 

 District removed “Coatings” and “Solvents” were removed from Subsections 

VII.B.1. and VII.B.2. Language from both Subsections are word for word from 

ARB’s SCM. 

District: Requested change sounds reasonable, revised per suggestion. 

3. ACA commented: To give facilities adequate time to gather requested 

information, ACA recommends the following change to the rule language: 

“Records required by this Rule shall be retained for a minimum of three years 

and made available to the APCO within 90 days after request.” 

 

District did not make change; Facility permit conditions usually require records to 

be held on premises and made available to the District upon Inspector/APCO 

request. 

PPG 

PPG submitted the following written comments regarding Rule 410.4A on 

11/19/2013.

Section II, Applicability 

1. PPG commented: am concerned that I did not see a date of implementation for 

this revision. While products are available & accepted in the 13 air districts that 

have already implemented a CARB SCM type rule, the technology required will 

take time for painters in Eastern Kern APCD to learn how to correctly apply. 

Hands-on training is strongly recommended for the waterborne basecoats 

considered critical to compliant technologies as these products handle differently 

than solvent borne. Also there will be time needed to flush the old technology 

higher VOC products out of the system. Coatings are expensive; shops will not 

want to waste even partial containers. Disposal of serviceable products would 

only place an extra unneeded burden on waste facilities. In the other districts that 

have updated their regulations, typically up to 12 months have been allowed to 

transition. 

District added the following language to Section II, Applicability “provisions of this 

Rule are enforceable upon amendment date” and a 12-month sell-through 

provision (see Section VI.J). 
410.4A Final Staff Report - Response to Comments 

Appendix C C-7 Draft 3/13/2014

Section VI, Requirements 

1. PPG commented: Solvents used for spray gun cleaners set at 25 g/L maximum 

will force formulators to use a limited number of exempt compounds which may 

not offer the best qualities desired in a gun cleaner. Obviously there are high 

exempt content products available, but there could be better options. I would 

suggest the approach used by Bay Area AQMD which does not set a limit for this 

category. As these products are required to be used in an enclosed device, they 

will be contained for eventual recycling. Use of exempt formulations will almost 

certainly require costlier formulations that will not deliver the efficient cleaning 

properties offered by the full selection of VOC containing solvents. Used in a 

proper device there will be limited releases to the environment and with recycling 

& reuse of solvents derived no need to set a VOC limit for this category. 

 District: limit for surface preparation will remain at 25 g/l and limits for Application 

Equipment Cleaning will remain at 950 grams or less per liter (7.9 lb/gal) of 

material with a VOC composite partial pressure of 35 mm Hg or less at 20/C 

(68/F). (See Section VI.F. of Appendix A) 

Edwards Air Force Base 

Edwards Air force Base (Edwards) submitted the following written comments 

regarding Rule 410.4A on 12/6/2013.

We request EKAPCD revise the sell-through date to 12 months after effective date 

of the rule. 

District: Sell-through provision was added (Section VI.J.). 

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