AIR POLLUTION CONTROL DISTRICT 

COUNTY OF SAN DIEGO

PROPOSED AMENDED RULE 67.0 – ARCHITECTURAL COATINGS

WORKSHOP REPORT 

A notice for a workshop on the proposed Rule 67.0 amendments was mailed to all known 

manufacturers, distributors, and retail sellers of architectural coatings located in San 

Diego County. Notices were also mailed to all Economic Development Corporations and 

Chambers of Commerce in San Diego County, the U.S Environmental Protection Agency 

(EPA), the California Air Resources Board (ARB), and other interested parties. The 

workshop was held on September 6, 2001. Oral and written comments were received 

from affected manufacturers, distributors, end users, and ARB. The comments and 

District responses are as follows: 

1. WORKSHOP COMMENT

The term “industrial use” in Subsection (d)(5) should be defined or clarified. As written, 

after January 1, 2004, a Rust Preventive coating can be applied for industrial uses only if 

it meets the Industrial Maintenance coating VOC content limit specified in Table 1. This 

implies that Rust Preventative coatings can be used for industrial use which conflicts with 

the Subsection (c)(45) definition which states that they are coatings “...formulated 

exclusively for non-industrial use...” 

DISTRICT RESPONSE

The Subsection (d)(5) language has been modified as follows: After January 1, 2004, a 

person shall only apply or solicit the application of a rust preventative coating for nonindustrial uses, unless the rust preventative coating complies with the industrial 

maintenance coating VOC limit specified in Table 1. In addition, the definition for Rust 

Preventative coatings has been revised to delete the word “exclusively.” 

2. WORKSHOP COMMENT

Would a coating applied to a warehouse component, such as shelving, be considered 

‘non-industrial’ use? 

DISTRICT RESPONSE

Yes. Coatings applied to warehouse components, such as shelving, would be considered 

a ‘non-industrial’ use. An industrial maintenance coating could be applied to shelving 

within a warehouse if the shelving was exposed to one or more of the extreme 

environmental conditions specified in the definition of industrial maintenance coating. 
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Rule 67.0 - 2 - 

3. WORKSHOP COMMENT

The amendments to Rule 67.0 propose to lower the VOC content limits of 12 coating 

categories upon adoption. ARB’s Suggested Control Measure (SCM) does not propose 

lower limits for these coatings until January 1, 2003, or January 1, 2004, for Industrial 

Maintenance coatings. The District should not be more stringent than the SCM. It will 

take time for coating manufacturers to produce and distribute coatings that meet the 

lower VOC content limits. 

DISTRICT RESPONSE

The District agrees. Rule 67.0 has been revised to propose that these coatings meet the 

lower VOC limits by January 1, 2003 (January 1, 2004, for Industrial Maintenance 

coatings), consistent with the SCM. 

4. WORKSHOP COMMENT

The District should reconsider the proposed VOC content limit of 250 grams per liter 

(g/l) for Floor coatings. These coatings are currently marketed in California as Industrial 

Maintenance coatings or Quick Dry Enamels with VOC content limits of 420 and 400 g/l, 

respectively. The District should retain a minimum VOC content limit of 400 g/l for 

Floor coatings. 

DISTRICT RESPONSE

The District agrees. The VOC content limit has been revised to 400 g/l, effective upon 

adoption, and 250 g/l effective January 1, 2003, consistent with the SCM. Coatings that 

meet the definitions of both Floor and Industrial Maintenance coatings will be treated as 

Industrial Maintenance coatings for determining allowable VOC content, pursuant to 

Subsection (d)(3). 

5. WORKSHOP COMMENT

If a coating is purchased before the lower VOC content limits take effect on January 1, 

2003, is there a date by which the coating must be applied? 

DISTRICT RESPONSE

No. If a coating complies with the VOC content limits applicable when it is 

manufactured, there are no restrictions on when the coating may be used. The 

appropriate VOC content limit is determined by the manufactured date, which is required 

to be listed on all coating containers. 
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Rule 67.0 - 3 - 

6. WORKSHOP COMMENT

The Appendix A averaging provisions contain ceiling limits specifying the maximum 

allowable VOC content for coatings eligible for averaging. The ceiling limits are 

unnecessary since EPA’s National Architectural Coating Rule provides upper bound 

ceiling limits. In addition, as long as the same emission reductions are achieved, ceiling 

limits only serve to limit a coating manufacturer’s compliance flexibility. 

DISTRICT RESPONSE

The District disagrees. Ceiling limits, recommended by ARB, are necessary to protect 

against regional differences that could result in high VOC products being sold in San 

Diego County. Using EPA’s National Architectural Rule to provide upper bound ceiling 

limits would allow coatings with VOC contents higher than those allowed by current 

Rule 67.0, which has been in effect for over 10 years. Although these emissions would 

be offset from a statewide perspective, VOC emissions could increase in San Diego. 

Including the ceiling limits eliminates this potential. 

7. WORKSHOP COMMENT

The imposition of ceiling limits diminishes the flexibility otherwise provided to 

manufacturers to utilize averaging to produce limited quantities of higher-performing 

coatings. 

DISTRICT RESPONSE

The ceiling limits reflect the VOC content limits found in California air district 

Architectural Coating rules. There is no need to allow the use of coatings with higher 

VOC content limits, since coatings which meet these limits have been readily available 

for nearly 10 years. In addition, the ceiling limits will ensure that existing State 

Implementation Plan (SIP) emission reduction commitments are met throughout the state. 

8. WORKSHOP COMMENT

The proposed Appendix A averaging program will sunset on January 1, 2005. The 

District should consider removing the sunset provision. If averaging achieves the same 

emission reductions, then it should remain a viable alternative to reformulating all 

coating categories. 

DISTRICT RESPONSE

The Appendix A averaging program will be a statewide program authorized by district 

rules, but implemented by the ARB. Therefore, consistency between air district rules is 

important. To maintain statewide consistency, the District will retain the January 1, 
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Rule 67.0 - 4 - 

2005, sunset provision. However, the District is not proposing to submit the amended 

version of Rule 67.0 for inclusion in the federal SIP. The emission reductions are not 

currently necessary to demonstrate compliance with federal attainment requirements. If 

the District, other air districts, or ARB determines it necessary to extend the sunset 

provision, the District will consider recommending such a change at that time. 

9. WORKSHOP COMMENT

Are graphic arts operations subject to the Graphic Arts coating category contained in 

Rule 67.0? 

DISTRICT RESPONSE

No. Rule 67.0 regulates coatings applied to stationary structures and their appurtenances 

at the site of installation. District Rule 67.16 (Graphic Arts Operations) applies to web or 

sheet fed graphics art operations, typically conducted at a graphic arts business. 

10. WORKSHOP COMMENT

Technology assessments are still occurring for several coating categories. The District 

should not submit Rule 67.0 for inclusion in the SIP to avoid locking in VOC content 

limits that may be unachievable. 

DISTRICT RESPONSE

The District agrees. The District is not proposing to submit amended Rule 67.0 as a SIP 

revision unless the emission reductions are determined in the future to be needed for a 

federal attainment demonstration or to meet other federal requirements. 

11. WORKSHOP COMMENT

The District should revise Rule 67.0 to include a coating category for Concrete Protective 

coatings with a VOC content limit of 400 g/l, consistent with the category provided in 

EPA’s National Architectural Coating Rule, which defines it as follows: “Concrete 

Protective Coating means a high-build coating, formulated and recommended for 

application in a single coat over concrete, plaster or other cementitious surfaces. These 

coatings are formulated to be primeless, one-coat systems that can be applied over form 

oils and/or uncured concrete. These coatings prevent the spalling of concrete in freezing 

temperatures by providing long-term protection from water and chloride ion intrusion.” 

This is a high performance, primerless, one-coat system that can be applied over form 

oils and/or uncured concrete. The coating achieves excellent adhesion to the concrete 

and cures to a hard protective coating, lasting for periods of over 20 years without 
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Rule 67.0 - 5 - 

requiring recoating. The coating’s primerless, single coat application and longevity 

features not only reduce VOC emissions, they also reduce worker safety risks. The use 

of this coating results in fewer overall emissions. Less than 50,000 gallons of this 

coating was sold in California by our company in 2000. 

DISTRICT RESPONSE

The addition of a Concrete Protective Coating category was raised during the 

development of the SCM. The District concurs with the conclusion in ARB’s SCM Staff 

Report, that “Concrete Protective Coatings” are already included under the 

Waterproofing Concrete/Masonry Sealer category with a VOC limit of 400 g/l. 

Accordingly, it is not necessary to add a new coating category for “Concrete Protective 

Coatings.” 

12. WORKSHOP COMMENT

The District should revise Rule 67.0 to include a coating category for Anti-Graffiti 

coatings with a VOC content limit of 600 g/l. Anti-Graffiti coatings are used on top of 

paints, coatings, or murals to protect the film underneath. A sacrificial anti-graffiti 

coating (waterborne) will typically be reapplied after one to three washings. Our high 

performance urethane anti-graffiti coating lasts for ten to 15 washings. This eliminates 

the need for successive recoatings and reduces VOC emissions, as repainting is required 

less often when the underlying coating is protected by a hard, permanent anti-graffiti 

system. With the extremely low volume of anti-graffiti coatings used, less than 0.01% 

nationwide, raising the limit to 600 g/l would have minimal impact on the total VOC’s in 

the region. 

DISTRICT RESPONSE

The South Coast Air Quality Management District (SCAQMD) and ARB have identified 

both permanent and sacrificial anti-graffiti coatings that comply with the 250 g/l future 

effective limit for Industrial Maintenance coatings. No specific performance data has 

been provided to the District or ARB to indicate performance problems with the low 

VOC anti-graffiti coatings. The product information sheets for some of these products 

indicate that graffiti can be removed without residual “shadowing” (ghosting) and/or that 

the coating forms a non-porous, monolithic surface, resulting in a very low coefficient of 

friction. One product has been successfully used by Caltrans since 1999. Given the 

availability of low-VOC anti-graffiti coatings, there is no need for a separate coating 

category at 600 g/l. 
Workshop Report - 

Rule 67.0 - 6 - 

13. WORKSHOP COMMENT

The Rule 67.0 definition of Specialty Primer should be revised to be consistent with the 

National Paint and Coating Association definition as follows: “Specialty primer means a 

coating formulated and recommended for application to a substrate to block stains, odors, 

or efflorescence; to seal fire, smoke or water damage; to condition excessively chalky 

surfaces; or recommended for application to exterior wood or wood-based surfaces, or for 

highly alkaline cement, plaster and or other cementitious surfaces. An excessively chalky 

surface is one that is defined as having a chalk rating of four or less as determined by 

ASTM Designation D 4214-98 Photographic Reference Standard No. 1 of the Federation 

of Societies for Coatings Technology ‘Pictorial Standards for Defects’.” (Emphasis 

added.) 

The proposed modification to the Specialty Primer definition would allow the use of 

primers specifically formulated for use on concrete, plaster, wood and other masonry 

surfaces or for highly alkaline cement, plaster and other cementitious surfaces. Without 

this change, these types of primers would be classified as general primers, with VOC 

content limits of 200 g/l effective January 1, 2003. 

At 200 g/l, the ability to maintain a viable primer for specific concrete and masonry 

applications is totally lost. The result would be holidays (holes in the coating), dry spray 

particles, and heavy overlapped films. The use of acetone will not achieve a 200 g/l VOC 

coating and would further contribute to film formation and application problems, 

especially cob webbing. Waterborne primers used in such applications, as well as the top 

coat applied on it, peel off in large sheets, resulting in the entire building being recoated. 

Latex primers or coatings will not adhere to surfaces previously coated with silanes or 

siloxanes, while solvent borne primers will penetrate these hard substrates, forming a 

strong bond with the surface. 

DISTRICT RESPONSE

The current Subsection (c)(52) definition of Specialty Primer is consistent with the SCM 

definition and already includes excessively chalky surfaces (defined as having a chalk 

rating of four or less). Therefore, exterior wood or wood-base surfaces and highly 

alkaline cement plaster or other cementitious surfaces with excessively chalky surfaces 

are already included in this coating category and it is not necessary to change the 

definition as suggested. 

14. WORKSHOP COMMENT

The Rule 67.0 definition of Waterproofing Concrete/Masonry Sealer should be revised as 

follows: “Waterproofing concrete/masonry sealer means a clear or pigmented filmforming or non film-forming coating that is labeled or formulated for sealing concrete 

and masonry to provide resistance against water, alkalis, ultraviolet light, and staining.” 
Workshop Report - 

Rule 67.0 - 7 - 

The addition of the phrase “non-film forming” is recommended so that all concrete and 

masonry sealers are included in this category. We believe it was the intent to have these 

materials included. However, the way the category is worded makes it sound as though 

only film-forming sealers are allowed. 

DISTRICT RESPONSE

The Waterproofing Concrete/Masonry Sealer coating category is a specialty type of 

Waterproofing Sealer, and thus allowed a higher VOC content limit of 400 g/l. Non filmforming Waterproofing Sealers that comply with the 250 g/l VOC content limit are 

readily available. Therefore, it is not necessary to include non film-forming 

Waterproofing Sealers in the specialty category of Waterproofing Concrete/Masonry 

Sealers. 

15. WORKSHOP COMMENT

We are a specialty, high-performance coating manufacturer and therefore do not 

manufacture coatings which lend themselves to very low VOC content, e.g., flat interior 

coatings. We do make every effort to lower the content of our coatings, however, as 

evidenced by the use of our acrylic technology for our concrete protective coatings. The 

averaging provisions can only be effectively used by companies with diverse coating 

lines and this penalizes our company, which has devoted its efforts to developing niche 

market coatings that otherwise would not have been developed, because the volumes are 

too small to interest large manufacturers with diverse product lines. 

DISTRICT RESPONSE

The VOC content limits for Architectural Coatings have been tightening gradually for 

several years as the technology has developed to lower the VOC contents of various types 

of coatings. Higher VOC content limits are provided within the rule for various specialty 

coatings. The VOC content limits proposed within proposed Rule 67.0 are currently 

available or are considered technologically feasible. ARB and the District are committed 

to monitoring industry’s progress in complying with the proposed limits. (See Written 

Comment 16 below.) The averaging provision was adopted in the SCM and Rule 67.0 to 

provide industry with flexibility in meeting new and lower limits. However, use of the 

averaging program is not necessary to comply with the Rule 67.0 coating VOC content 

limits. 

16. WRITTEN COMMENT

Metropolitan Water District of Southern California

The Board Resolution adopting proposed amendments to Rule 67.0 should contain the 

following or equivalent wording: “SDAPCD will monitor the progress and results of the 
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Rule 67.0 - 8 - 

technical assessment being conducted by SCAQMD and the essential public services 

agencies, and will make future modifications to the Rule that may be appropriate.” 

DISTRICT RESPONSE

ARB plans to conduct technology assessments for each coating category with lower 

future effective VOC limits (2003 or 2004) prior to the effective dates in order to monitor 

the industry’s progress in complying with the proposed limits. These technology 

assessments will consider the Essential Public Services Agencies’ test programs, the 

Southern California Alliance of Publicly Owned Treatment Works test program, and the 

National Technical Systems test program. In addition, ARB will be working with the 

South Coast Air Quality Management District (SCAQMD) to identify any potential 

problems industry is having in meeting the lower VOC limits. District staff will follow 

ARB’s technology assessment and SCAQMD’s work to monitor the industry’s progress 

in complying with the standards and make any appropriate changes to the rule as needed. 

The commitment to do this will be included in the Board resolution for Rule 67.0. 

17. ARB WRITTEN COMMENT

The ARB Suggested Control Measure for Architectural Coatings (SCM) definition for 

“Residential” does not appear in Rule 67.0. “Residential” is used in the labeling 

requirements for industrial maintenance coatings. We do not believe that a simple 

dictionary definition of residential is adequate to describe the important labeling 

restrictions for industrial maintenance coatings. To maintain compliance integrity of the 

rule, relevant definitions contained in the SCM should appear in the rule. 

DISTRICT RESPONSE

The District disagrees. As currently written, both the SCM and Rule 67.0 only require 

Industrial Maintenance coatings to be labeled using the term “residential.” There is no 

specific requirement or standard based upon this term, only that the label states such 

coatings are not for residential use. 

18. ARB WRITTEN COMMENT

The exemption for emulsion-type bituminous pavement sealers does not exist in the 

SCM. This provision should either be deleted or reworded to make it clear that these 

products are subject to the District’s cutback and emulsified asphalt rules. We believe 

do-it-yourself repair coatings for driveways are architectural coatings, and could be 

unintentionally exempted by Subsection (b)(1)(iv). The ARB is currently collecting 

speciated survey information to better understand bituminous coatings, and it is possible 

that in the future, driveway repair coatings will be defined as a separate category. 
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Rule 67.0 - 9 - 

DISTRICT RESPONSE

The District agrees. Subsection (b)(1)(iv) has been revised to specify that only 

bituminous pavement sealers applied to roads are exempt from Rule 67.0. These sealers 

are subject to the requirements of District Rule 67.7. 

19. ARB WRITTEN COMMENT

The sentence in the Architectural Coatings definition explaining that coatings used in 

shop application are not architectural coatings has been omitted. We believe that the rule 

needs an explanation that coatings applied in a factory or shop are not architectural, since 

this is a common question asked by both end users and manufacturers. We understand 

that District staff feels that it is important to clarify that spray booths located within a 

facility painting appurtenances create an exception to the shop application definition. 

District staff has suggested that the second sentence of the SCM definition be changed to 

read as follows: “Coatings applied in offsite shop applications or to non-stationary 

structures such as airplanes, ships, boats, railcars, and automobiles, and adhesives are not 

considered architectural coatings for the purposes of this rule.” The word “offsite” would 

clarify that painting of appurtenances done in spray booths within a facility is classified 

as an architectural coating and would leave intact the intent that coatings applied in a 

factory or spray booth away from the facility are not considered architectural. It is also 

consistent with the definition of appurtenance. We agree with this solution. 

DISTRICT RESPONSE

Subsection (c)(6) has been revised as suggested. 

20. ARB WRITTEN COMMENT

SCM Subsections 3.4 (Painting Practices) and 3.5 (Thinning) have been omitted in 

proposed amended Rule 67.0. We understand that storage of VOC-containing materials 

is covered in Rule 67.17, but this rule is not specific for painting practices. Therefore, we 

believe that SCM Subsection 3.4 should be added to Rule 67.0, or at a minimum, Rule 

67.0 should reference Rule 67.17. We note that the District references Rule 2 to define 

the term VOC. We believe that District inspectors should use discretion in not issuing an 

uncovered container citation for both Rules 67.17 and 67.0. 

We understand that SCM Subsection 3.5 is not included in Rule 67.0 because District 

staff feels that it is redundant since it is covered in footnote 1 of Table 1. However, 

footnote 1 is simply a statement that VOC content is calculated to include the 

manufacturer’s maximum thinning recommendation on the label. In contrast, SCM 

Subsection 3.5 prohibits the application of a product thinned more than the manufacturer 

recommends. We added this Subsection to the SCM to enhance enforceability and clarify 

that excess thinning is a violation. 
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Rule 67.0 - 10 - 

The ARB believes that, for statewide uniformity and to maintain compliance integrity of 

the rule, all of Section 3 (Standards) in the SCM should appear in district rules (except 

Section 3.8, which does not apply to San Diego County). 

DISTRICT RESPONSE

District Rule 67.17 already regulates the storage of materials containing volatile organic 

compounds which include architectural coatings. The District will include a reference to 

Rule 67.17 in Rule 67.0. In addition, if Rule 67.0 amendments are approved, the District 

will be notifying affected persons of the new requirements. At that time, the District will 

remind parties of the Rule 67.17 requirements. 

To provide consistency with the SCM, Subsection (d)(7) has been added to prohibit 

thinning beyond the manufacturer’s maximum thinning recommendation. 

21. ARB WRITTEN COMMENT

Subsection (f)(1) states that an annual report to the Executive Officer be submitted. We 

recommend that the District indicate that the report to the Executive Officer must be in 

writing. 

DISTRICT RESPONSE

The District has revised Subsection (f)(1) as suggested. 

22. ARB WRITTEN COMMENT

In Subsection (f)(2)(iv), references to EPA-approved State or local methods do not 

include a complete title and do not specify the version date. We recommend changing 

portions of the rule to read as follows: 

For subsection (J): “Exempt Compounds: `The content of compounds...SCAQMD 

Method 3034-91 (Revised August 19963), Determination of Exempt Compounds, ...”; and 

For subsection (L): “Alternative VOC Content of Coatings: The VOC...SCAQMD 

Method 304-91 (Revised February 19963), Determination of Volatile Organic 

Compounds (VOC) in Various Materials, ...” 

DISTRICT RESPONSE

Subsections (f)(2)(iv)(J) and (L) have been revised as suggested. 
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Rule 67.0 - 11 - 

23. ARB WRITTEN COMMENT

The word “statewide” appears four times in Subsection (d)(6), presumably to emphasize 

that the averaging program is being managed by the ARB statewide, rather than by each 

district individually. The word "statewide" is inappropriate; it precludes a manufacturer 

from submitting a district-specific averaging plan, which he can choose to do. 

DISTRICT RESPONSE

The District disagrees. The proposed wording does not prelude a manufacturer from 

submitting a district-specific averaging plan. However, to provide consistency with the 

averaging program provisions being adopted by other districts, the term “statewide” has 

been deleted from the text and will only be retained in the Section header. 

24. ARB WRITTEN COMMENT

The Table in Appendix A titled “Averaging Categories and VOC Ceiling (Maximum 

VOC allowed)” has no units indicated. We recommend that the District add units to the 

table. We also recommend changing the second column title of the table to read as 

follows: Rule/VOC Limit (In effect 1/1/2003 except Industrial Maintenance Coatings). 

DISTRICT RESPONSE

The District agrees. The Table has been revised as suggested. The special effective date 

for Industrial Maintenance Coating will be included as a footnote. 

10/18/01 

LY:AS:ls