UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1143, 

Consumer Paint Thinners & Multi-Purpose Solvents

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

June 2011
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Agency: South Coast Air Quality Management District 

(SCAQMD)

Previously Submitted Rule: Rule 1143 – Consumer Paint Thinners & MultiPurpose Solvents

Adopted – March 6, 2009

Amended – July 9, 2010

Subject of this TSD: Rule 1143 – Consumer Paint Thinners & MultiPurpose Solvents 

Amended – December 3, 2010

Submitted – April 5, 2011

RULE SUMMARY - Rule 1143 reduces emissions of Volatile Organic 

Compounds (VOCs) from the use, storage and disposal of consumer paint 

thinners and multi-purpose solvents used in thinning coating materials, cleaning 

coating application equipment and other solvent cleaning operations by limiting 

the VOC content. Provisions are made for sell-through of consumer thinners and 

multi-purpose solvents produced before January 1, 2010, and all exempt 

products must still be subject to the recording and recordkeeping requirements. 

Rule 1143 is consistent with the California Air Resources Board (CARB) 

Consumer Products Regulations (CPR).

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency – We are not evaluating this rule regarding Clean Air Act 

Reasonably Available Control Technology requirements, because there is 

no CTG for this category and we do not expect the rule to apply to major 

sources. CARB’s Consumer Products Regulation, Title 17, California Code 

of Regulations (CCR), Division 3, Chapter 1, Subchapter 8.5, Article 2, 

Sections 94507 – 94517 was used to help evaluate the stringency of this 

requirement. 

3. SIP Relaxation - We have evaluated this SIP revision to determine 

whether it would interfere with any applicable requirement concerning 

attainment and reasonable further progress (RFP) or any other applicable 

requirement of the Act (CAA 110(l)) or modify, in a nonattainment area, any 

SIP-approved control requirement in effect before November 15, 1990 

(CAA 193).
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Enforceability – The reporting, recordkeeping, testing and other requirements 

generally ensure that the submitted rule can be enforced. The type of artist 

solvents and thinners are specifically defined in section (c) (1). The sell-through 

provision of subsection (b) (2) (A) stipulates the effective dates for the VOC limits 

and clarifies that the provisions do not apply to products that do not meet the 

interim requirements. In the Administrative Requirements of subsections (e) (1) 

through (7) the requirements for labelling of and education for flammable thinner 

and solvents are clearly specified. The Recordkeeping of section (f) details 

manufacturers’ recordkeeping requirements that exceed those of the CPR.

Stringency- With a 25 gram/liter VOC limit for Consumer Paint Thinner and MultiPurpose Solvent, the rule is expected to reduce VOC emissions by 9.69 tons/year 

in by 2012. SCAQMD projected 9.7 tons/day emissions reduction by 2014 for this 

source in the PM2.5 Plan and 10.1 tons/day emissions reduction by 2023 for this 

source in the Ozone Plan. The rule is consistent with CARB’s consumer product 

requirements and we have no basis to require more stringent requirements at this 

time. 

SIP Relaxation –We propose to determine that our approval of the submittal 

would comply with CAA section 193 because there are no previous versions of 

these requirements in the SIP. We similarly propose to determine that our 

approval of the submittal would comply with CAA section 110(l), because the 

proposed SIP revision would not interfere with the on-going process for ensuring 

that requirements for RFP and attainment of the NAAQS are met, and the 

submitted SIP revision is more stringent than requirements previously approved 

into the SIP.

RULE DEFICIENCIES - We have identified no deficiencies with Rule 1143

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

1. For clarity, we recommend that the following terms be defined in section

(c):

a. Formulated to meet low VOC limits

b. Flammable, Extremely Flammable

c. Polyaspartic and Polyurea Coatings.

d. Industrial Maintenance (IM) Coatings, Zinc-Rich Primers and High 

Temperature IM Coatings.

e. Institutional use

2. In section (i), Test Methods, please clarify that both Method 303 and 304 

are SCAQMD test methods and include the entire number and EPAapproved date:

a. SCAQMD Method 303-91, August 1996 (Determination of Exempt 

Compounds) 
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b. SCAQMD Method 304-91, February 1996 (Determination of VOC in 

Various Materials) 

3. The severability clause in section (k) should state that, “...In the event any 

of the exceptions to this rule is held by judicial order to be invalid, the 

persons or circumstances covered by the exception shall nevertheless be 

required to comply with the remainder of this rule.”

EPA ACTION - The District staff report associated with Rule 1143 projects it will

reduce VOC emissions by 9.69 tons per day by 2012. The rule fulfils the relevant 

CAA §110 part D requirements. EPA staff recommends a full approval of Rule 

1143 pursuant to CAA §110(k) (3) and §301(a). 

ATTACHMENTS -

1. SCAQMD Rule 1143, Consumer Paint Thinners & Multi-Purpose Solvents,

as submitted on April 5, 2011.

2. SCAQMD Rule 1143, Consumer Paint Thinners & Multi-Purpose Solvents,

as submitted on July 9, 2010.

ADDITIONAL REFERENCES -

1. “Consumer Products Regulation”, Including September 2009 amendments

http://www.arb.ca.gov/consprod/regs/2009/cpreg2010.pdf

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf

3. “Model Volatile Organic Compound Rules for Reasonable Available Control 

Technology,” EPA-Staff Working Document, June 1992.

http://www.epa.gov/ttn/oarpg/t1/ctg/flexpkg_draftctg20060804.pdf