EKAPCD 410.9-1 3/13/2014 

RULE 410.9 Wood Products Surface Coating Operations – Adopted 3/13/2014 

I. Purpose

The Purpose of this Rule is to limit Volatile Organic Compound (VOC) emissions from 

wood product surface coatings. This Rule specifies wood coatings, storage, cleanup and 

disposal of organic solvents and waste solvent materials associated with the use of wood 

product coatings. 

II. Applicability

Provisions of this Rule shall apply to surface coating of wood products. 

III. Definitions

A. Air Dried: A process whereby the coated object is cured or dried at ambient 

temperature or at a temperature below 194°F. 

B. Application Equipment: A device, including, but not limited to, a spray gun, brush, and 

roller, used to apply adhesives, coatings, or inks. 

C. ASTM: American Society for Testing and Materials. 

D. Baked: A process whereby the coated object is heated above ambient temperature to a 

temperature at or above 194°F for the purpose of curing or drying. 

E. Brush Coating: The manual application of coatings using brushes or rollers. 

F. Capture Efficiency: In percent, is the ratio of the weight of the VOC in the effluent 

stream entering the control device to the weight of VOC emitted from wood product 

coating operations, both measured simultaneously, and can be calculated by the 

following equation: 

Capture Efficiency = [Wc/We] x 100 

Where: Wc = weight of VOC entering control device 

We = weight of VOC emitted 

G. Clear Sealer: A coating containing binders, but not opaque pigments, which seals the 

wood product prior to application of the subsequent coatings. 

H. Clear Topcoat: A final coating which contains binders, but not opaque pigments, and is 

specifically formulated to form a transparent or translucent solid protective film. 

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

beautify and/or protect such surface. 
 

EKAPCD 410.9-2 3/13/2014 

J. Composite Wood: A manufactured material consisting of tightly compressed wood 

fibers bonded with resins which includes, but is not limited to, particleboard, fiberboard 

and hardboard. 

K. Cured Adhesive, Cured Coating, or Cured Ink: an adhesive, coating, or ink that is dry 

to the touch. 

L. Degreaser: A tank, tray, drum or other container in which objects to be cleaned are 

exposed to a solvent or solvent vapor in order to remove contaminants. The objects to 

be cleaned include, but are not limited to, parts, products, tools, machinery, and 

equipment. An enclosed spray application equipment cleaning system is not a 

degreaser. 

M. Dip Coating: The process in which a substrate is immersed in a solution (or dispersion) 

containing the coating material, and then withdrawn after allowing the excess coating 

to drain. 

N. Dissolver: An organic solvent that is added to an adhesive, coating, or ink in order to 

melt or to liquefy solid particles. 

O. EPA: United States Environmental Protection Agency 

P. Filler: A material which is applied to a wood product, and whose primary function is to 

build up, or fill the voids and imperfections in the wood product to be coated. This shall 

not include composite wood edge filler. 

Q. Grams of VOC per Liter of Coating, Less Water and Exempt Compounds: The weight 

of VOC content per combined volume of VOC and coating solids and can be calculated 

by the following equation: 

Grams of VOC per liter of coating, Ws - Ww - Wec

less water and exempt compounds = Vm - Vw – Vec 

Where: 

Ws = weight of volatile compounds (grams) 

Ww = weight of water (grams) 

Wec = weight of exempt compounds (grams) 

Vm = volume of material (liters) 

Vw = volume of water (liters) 

Vec = volume of exempt compounds (liters) 

R. High Gloss Coating: Any coating which achieves at least 85% reflectance on a 60 

degree gloss meter when tested by ASTM Method D-523-08. 

S. High-Solid Stains: Stains containing more than 1 pound of solids per gallon of 

material, and include wiping stains, glazes, and opaque stains. 
 

EKAPCD 410.9-3 3/13/2014 

T. High-Volume, Low-Pressure (HVLP) Spray Equipment: 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. Ink: A fluid that contains dyes and/or colorants and is used to make markings but not 

to protect surfaces. 

V. Liquid Leak: A visible solvent leak from a container at a rate of more than three drops 

per minute, or a visible liquid mist. 

W. Low-Solid Stain: A stain containing 1 pound, or less, of solids per gallon of material. 

X. Maintenance Cleaning: The cleaning of tools, forms, molds, jigs, machinery, and 

equipment (except coating application equipment, ink application equipment, or 

adhesive application equipment), and the cleaning of work areas where maintenance or 

manufacturing occurs. 

Y. Mold-Seal Coating: the initial coating applied to a new mold or repaired mold to 

provide a smooth surface which, when coated with a mold release coating, prevents 

products from sticking to the mold. 

Z. Multi-Colored Coating: a coating which exhibits more than one (1) color when applied 

and which is packaged in a single container and applied in a single coat. 

AA. Non-Absorbent Container: A container made of non-porous material that does not 

allow the migration of solvents through it. 

BB. Non-Atomized Solvent Flow: Solvents in the form of a liquid stream without the 

introduction of any propellant. 

CC. Pigmented Coating: A final opaque coating which contains binders and colored 

pigments, and is specifically formulated to hide the wood surface and form a solid 

protective film. 

DD. Potential to Emit: The maximum capacity of a facility to emit any air pollutant under 

its physical and operational design. Any physical or operational limitation on the 

capacity of the facility to emit an air pollutant, including air pollution control 

equipment and restrictions on hours of operation, emissions, or on the type or amount 

of material combusted, stored, or processed, shall be treated as part of its design if the 

limitation is enforceable by the EPA Administrator. 

EE. Roll Coating: The application of coatings from a paint trough to a flat surface by a 

mechanical series of rollers. 

FF. Sanding Sealer: A coating containing binders, which seals the wood prior to 

application of the subsequent coatings. 
 

EKAPCD 410.9-4 3/13/2014 

GG. Stripper: Solvent used to remove material such as cured adhesives, cured inks, cured or 

dried paint, cured or dried paint residue or temporary protective coating. 

HH. Surface Preparation: The removal of contaminants from a surface prior to the 

application of coatings, inks, or adhesives or before proceeding to the next step of a 

manufacturing process. 

II. Transfer Efficiency: A ratio of the amount of coating solids adhering to the object 

being coated to the total amount of coating solids used in the application process, 

expressed as a percentage. 

JJ. Thinner: A solvent that is used to dilute coatings to reduce viscosity, color strength, 

and solids, or to modify drying conditions. 

KK. Touch Up: That portion of the coating operation which is incidental to the main 

coating process but necessary to cover minor imperfections or to achieve coverage as 

required. 

LL. Volatile organic Compound (VOC): As defined in Rule 102, Definitions. 

MM. Wood Products: Surface-coated room furnishings which include cabinets (kitchen, 

bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, and any other coated 

objects made of wood, composite wood, simulated wood material used in combination 

with wood or composite wood; and/or paper laminated on composite wood. 

IV. Exemptions

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

A. Residential noncommercial operations. 

B. Small wood products coating operations (< 20 gallons usage/year). 

C. Coating of wooden musical instruments. 

D. The application of coatings by template (to add designs, letters or numbers to wood 

products). 

E. Aerosol-spray coatings used for touch up and repair. 

F. Specific types of finishes (imitation wood grain, crackle lacquers, and faux and leaf 

finishes).Architectural coatings. 
 

EKAPCD 410.9-5 3/13/2014 

V. Requirement

A. With the exception of the exemptions listed in Section IV of Draft Rule 410.9, an 

operator shall not apply to any wood product, any coating, aerosol, or adhesive with a 

VOC content as applied, that exceeds the applicable limit specified in Table 1 or Table 

2. 

TABLE 1

VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION

VOC Content Limits Expressed in Grams per Liter 

Less Water and Exempt Compounds 

Content Category VOC Limit g/l VOC Limit lb/gal 

1. Clear Topcoat 275 2.3 

2. Clear Sealers 240 2.3 

3. Filler 275 2.3 

4. High-Solids Stain 240 2.0 

5. Ink 500 4.2 

6. Mold-Seal Coating 750 6.3 

7. Multi-Colored Coating 275 2.3 

8. Pigmented Coating 275 2.3 

9. Sanding Sealer 240 2.3 

TABLE 2 

VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION 

VOC Content Limits Expressed in Grams per Liter 

of Material, as Applied 

VOC Content Category VOC Limit g/l VOC Limit lb/gal 

1. Low-Solids Stain 120 1.0 

2. Stripper 350 2.9 

No person shall use any stripper on wood products unless: 

1. The reactive organic compound content is 350 grams per liter (2.9 lb/gal) of 

material or less; or 

2. The reactive organic compound composite partial pressure of the stripper is 2 mm 

Hg (0.04 psia) or less at 20o

C (68oF). 

B. Most Restrictive VOC Limit: If anywhere on the container of any wood 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 1 or Table 2, then the lowest VOC content limit shall 

apply. 
 

EKAPCD 410.9-6 3/13/2014 

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. Any approved emission control system 

must be maintained and used in proper working condition at all times. 

D. Equipment Requirements: Spray application of wood coatings shall only be performed 

by the following: electrostatic equipment, high-volume, low pressure (HVLP) spray 

equipment, hand roller, flow coat, roll coater, dip coat, paint brush, detailing or touchup 

guns, 

E. Surface preparation and Equipment Cleanup Requirements: No person shall conduct 

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 III.Q., unless such cleaning operation is performed 

within the control of an APCO approved VOC emission control system that meets 

the requirements of Section V.C. 

2. 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). 

3. Cleaning-Devices and Methods: 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 guns, cups, nozzles, bowls, and other parts during 

washing, rinsing, and draining procedures; 
 

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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 solvent into a closed container, 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 in containers without atomizing into open air. 

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

pumping. 

VI. Administrative Requirements

A. Labeling Requirements: Each manufacturer of any wood product coating subject to this 

Rule shall display information listed in Subsections VI.A.1. through VI.A.3. on coating 

container (or label) in which coating is sold or distributed or an accompanying data 

sheet 

1. Date Code: date coating was manufactured, or date code representing date, shall be 

indicated on label, lid or bottom of container. If manufacturer uses a date code for 

any coating, manufacturer shall file an explanation of each code with the Executive 

Officer of the CARB. 

2. Thinning Recommendations: statement of manufacturer's recommendation 

regarding thinning of coating shall be indicated on label or lid of container. This 

requirement does not apply to thinning of architectural coatings with water. If 

thinning of coating prior to use is not necessary, recommendation must specify 

coating is to be applied without thinning. 

3. VOC Content: Each container or accompanying data sheet of any coating subject to 

this Rule shall display either maximum or actual VOC content of coating, as 

supplied, as well as maximum thinning as recommended by manufacturer. VOC 

content shall be displayed in grams of VOC per liter (or pounds per gallon) of 

coating. VOC content displayed shall be calculated using product formulation data, 

or shall be determined using test methods in Subsection VII. 

B. Record Keeping Requirements

An operator is required to maintain the coating manufacturer's specifications, either 

listed on the coating container, product data sheet, or Safety Data Sheet (SDS), 

available for review and shall maintain daily records which show the following 

information as applicable: 

1. A current list of VOC containing products in use containing all data necessary to 

evaluate compliance, including the following information, as applicable: 

a. Material name and manufacturer's identification; 
 

EKAPCD 410.9-8 3/13/2014 

b. Application method; 

c. Material type and specific use instructions; 

d. Specific mixing instructions; 

e. Maximum VOC content of coating as applied, including 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 used of each component and mix ratio; 

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

c. Volume in liters (or gallons) applied/used. 

3. Capture and control equipment operating records, if applicable, including: 

a. Periods of operation corresponding to use records kept for Subsection VI.B.2. 

showing control equipment was used as necessary; 

b. Key system operating parameters showing operation as required to comply with 

this Rule and as intended by manufacturer; and 

c. Date performed, and description of all control system maintenance. 

Records required by the proposed Rule shall be retained for a minimum of three (3) 

years and made available on site during normal business hours to the APCO, ARB, or 

EPA upon request. 

VII. Test Methods

A. Analysis of Samples - Samples of VOC as specified in this Rule shall be analyzed by 

U.S. EPA Method 24 Determination of Volatile Matter Content, Water Content, 

Density, Volume Solids, and Weight Solids of Surface Coatings 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 , 

or ASTM D-4457-85 Standard Test Method for Determination of Dichloromethane and 

1,1,1-Trichloroethane in Paints and Coatings by Direct Injection into a Gas 

Chromatograph. 

B. Determination of Emissions - Emissions of VOC shall be measured by U.S. EPA 

Method 25, 25A, or 25B, as applicable. 
 

EKAPCD 410.9-9 3/13/2014 

C. Determination of Capture Efficiency - Where add-on control equipment is utilized, 

capture efficiency shall be determined in accordance with 40 CFR Appendix M – 

Methods 204-204F. 

D. Measurement of Acid Content - Acid content of Pre-Treatment Wash Primers shall be 

conducted and reported in accordance with ASTM D1613-06 Standard Test Method for 

Acidity in Volatile Solvents and Chemical Intermediates used in Paint, Varnish, 

Lacquer, and Related Products. 

E. Demonstration of Transfer Efficiency - Transfer efficiency shall be demonstrated using 

South Coast Air Quality Management District Method "Spray Equipment Transfer 

Efficiency Test Procedure for Equipment User". 

F. Determination of VOC Composite Partial Pressures - VOC composite partial pressures 

shall be determined using either manufacturer's information regarding formulation or 

using ASTM methods E168-06 – Standard Practices for General Techniques of Infrared 

Quantitative Analysis, E169-93 – Standard Practices for General Techniques of 

Ultraviolet- Visible 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 PressureTemperature Relationship and Initial Decomposition Temperature of Liquids by 

Isonteniscope. 

G. Determination of VOC Emissions From Spray Gun Cleaning Systems - VOC emissions 

from spray gun cleaning systems shall be made using South Coast Air Quality 

Management District "General Test Method for Determining Solvent Losses from 

Spray Gun Cleaning Systems". 

H. When more than one test method or set of test methods is specified for any testing, a 

violation of any requirement of this rule established by any one of the specified test 

methods or set of test methods shall constitute a violation of this rule." 

VIII. Compliance Schedule

A. New Sources

1. Owners or Operators of any facility proposing to install wood coating operations 

and required to comply with Section V of this rule shall obtain an Authority to 

Construct (ATC) in accordance with Rule 210.1 prior to installation or operation of 

any wood coating operation. 

2. Owners or Operators of any facility with wood coating operations exempt by 

Section IV of this rule shall maintain records of wood coatings use, in accordance 

with Section VI, B upon initial operations. 
 

EKAPCD 410.9-10 3/13/2014 

B. Existing Sources

1. Owners or Operators of any facility with wood coating operations required to 

comply with Section V of this rule shall obtain a valid Permit to Operate (PTO) or 

an Authority to Construct (ATC). Owner or operator shall apply for an ATC within 

180 days from the adoption of this Rule. 

2. Owners or Operators of any facility with wood coating operations exempt by 

Section IV of this rule shall maintain records of wood coatings use within 180 days 

of this rule being adopted. 

3. Owners or operators with valid PTO(s), required to comply with Section V of this 

rule shall be in full compliance within 12 months of rule adoption. 

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