SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Amendments to 

Rule 4601 (Architectural Coatings) 

December 17, 2009 

Prepared by: Anna Myers, Air Quality Specialist 

 

Reviewed by: Colette Kincaid, Senior Air Quality Specialist 

 Glenn Reed, Senior Air Quality Specialist 

 Joven R. Nazareno, Senior Air Quality Engineer 

 Creighton Smith, Compliance Supervisor 

 Michael Carrera, Compliance Supervisor 

 George Heinen, Rule Development Supervisor 

 Errol Villegas, Planning Manager 

 

I. SUMMARY 

A. Reasons for Rule Development and Implementation 

The California Air Resources Board (ARB) and the United States Environmental 

Protection Agency (EPA) classified the San Joaquin Valley Air Basin (SJVAB) as 

severe and extreme (as of August 30, 2009) non-attainment for the state and 

federal ozone standards, respectively. In accordance with Federal Clean Air Act 

(CAA) requirements for non-attainment areas, the San Joaquin Valley Unified Air 

Pollution Control District (District) adopted the 2007 Ozone Plan to establish a 

strategy for attaining the eight-hour ozone standards. 

The ozone attainment strategy is comprised of regulatory and incentive-based 

measures to reduce emissions of nitrogen oxides and volatile organic 

compounds (VOC), a precursor of ground-level ozone. The District 2007 Ozone 

Plan includes VOC control measure S-SOL-1 (Architectural Coatings). 

Therefore, this rule development project is subject to CAA and California Health 

and Safety Code (CH&SC) requirements. 

This rule development project will seek to obtain as much VOC emission 

reductions from the source category as is expeditiously practicable, 

technologically feasible, and economically reasonable, as determined by the 

District's Governing Board. The rule development project would attempt to 

satisfy the attainment goal listed in the 2007 Ozone Plan. Furthermore, the 

District intends to satisfy the requirements identified in Table 1. 
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Table 1 

Ozone Plan Commitments 

Subject Reference Requirement 

BACM CAA 189 (b)(1)(B) 

Provisions in attainment plans should include 

the application of best available control 

measures (BACM) to existing major stationary 

sources. 

BARCT 

CH&SC 40919(a)(3) 

2007 Ozone Plan 

 Ozone attainment plan should provide for best 

available retrofit control technology (BARCT) 

for existing permitted sources. 

Deadlines Ozone Plan Rule amendments adoption public hearing by 

the 4th quarter of 2009. 

Feasible 

Controls CH&SC 40914(b)(2) Ozone attainment plans should include "all feasible control measures." 

RACT CAA 182(b)(2) and 

182(f) 

Ozone attainment plans shall assure that 

reasonable available control technology 

(RACT) for volatile organic compounds (VOC) 

is in use at sources and on source categories 

at or above the RACT threshold. 

RACT 

Threshold 

70 Federal Register 

30592-30596 

5/26/05 

The applicable RACT threshold for control 

measures shall be the threshold in effect on 

June 15, 2004. The District’s threshold on 

June 15, 2004 was 10 tons per year (tpy) for 

VOC. 

Reductions 2007 Ozone Plan Estimated reduction is about 2.0 tons VOC 

per day by 2012. 

Timeline CAA Section 

172(c)(1) 

Ozone attainment plans shall implement 

control measures as expeditiously as 

practicable, and provide for attainment. 

B. Climate Change 

The California Global Warming Solutions Act of 2006 (AB 32) created a 

comprehensive, multi-year program to reduce greenhouse gas (GHG) emissions 

in California, with the goal of restoring emissions to 1990 levels by 2020. In the 

coming years, ARB and the Legislature will be developing policies and programs 

to implement AB 32. There are many win-win strategies that can reduce both 

GHG and criteria/toxic pollutant emissions. In relation to criteria pollutants, 

greenhouse gases have been recognized by EPA to contribute to the air 

pollution, and therefore have an impact on the public health and welfare of 

citizens. However, the Districts statutory authority dictates that criteria pollutants 
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be addressed first while also recognizing the impacts of greenhouse gases on 

the environment. 

The San Joaquin Valley Air Pollution Control District’s Governing Board adopted 

the Climate Change Action Plan (CCAP) in August 2008. For CEQA, one of the 

goals of the CCAP is to establish District processes for assessing the 

significance of greenhouse gas impacts. The District has developed a proposed 

policy and proposed guidance for addressing greenhouse gases under CEQA, 

which will be going to the District Governing Board for approval in December 

2009.

C. Description of Project 

Total emissions from architectural coatings and associated materials represent 

almost ten percent of the total VOC emissions from stationary and area sources, 

and almost five percent of all VOC emissions statewide. This rule project would 

amend Rule 4601 (Architectural Coatings) to implement the emission control 

requirements listed in the 2007 Ozone Plan and requirements in the ARB 

Suggested Control Measure (SCM) for architectural coatings, promulgated 

September 2007. Implementing SCM standards will ensure that Rule 4601 

meets RACT requirements in accordance with CAA 182(b)(2) and 182(f). 

As guidelines for developing the proposed changes to Rule 4601, District staff 

looked at the 2007 Ozone Plan, rules in other districts, the ARB 2007 SCM, 

federal rules and regulations, and best available control technology (BACT) 

determinations. The SIP commitment in the District’s 2007 Ozone Plan calls for 

this rule project to reduce 2.0 tons per day (tpd) of VOC, 21% reduction from the 

baseline inventory, upon rule implementation in 2012. Revised proposed 

amendments would reduce VOC emissions by 2.8 tpd (28%) upon rule 

implementation. 

District staff evaluated the option of implementing the South Coast Air Quality 

Management District (SCAQMD) architectural coating VOC limits. While the 

SCAQMD limits would achieve 4.5 tpd (48%) VOC emission reductions it could 

potentially have a significant impact on the regional economy of the San Joaquin 

Valley. Additionally, the cost effectiveness of the SCAQMD VOC limits would be 

more than twice that of the SCM VOC limits. Technical reasons, as discussed 

later in this Final Draft Staff Report, contributed to the District’s decision to 

implement SCM VOC limits. The technical reasons include, but are not limited to 

freeze/thaw stability, safety issues, and performance standards. 
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It is also important to note that the SJVAB is a NOx limited ozone area, while the 

South coast Air Basin is a VOC limited attainment area. As reported in the 

SJVAPCD Annual Report to the Community (October 2008) NOx is the primary 

culprit in the formation of both ozone and PM2.5. Air-quality models that 

simulate future formation, transport, and removal of ozone from the lower 

atmosphere are used to develop an emission-control strategy to meet the 8-hour 

ozone standard. Air-quality computer modeling used for the District's 2007 

Ozone Plan demonstrated that reductions in VOC emissions are relatively weak 

in affecting 8-hour ozone levels compared to the same amount of NOx 

reductions. As such, NOx reductions are more important to attainment than 

VOC reductions. A detailed discussion on the impact on ambient ozone levels 

from NOx and VOC reduction strategies is in Chapter 3 of the SJVAPCD 2007 

Ozone Plan. 

The SCAQMD, on the other hand, is much more VOC limited than the SJVAB 

due to topography, meteorology, and the chemical composition of the air 

pollutants. As stated in the 2007 Air Quality Management Plan (AQMP) for 

SCAQMD, the pathway to lower ozone levels and attainment of the 8-hour ozone 

standard [for SCAQMD] would be more based towards lowering VOC emissions. 

The SCAQMD AQMP also stated that significant VOC reductions are needed for 

the 8-hour ozone standard by 2024. 

Amended Rule 4601 will specify the Best Available Retrofit Control Technology. 

As used in this project, "Best Available Retrofit Control Technology" means an 

emission limitation that is based on the maximum degree of reduction 

achievable, taking into account environmental, energy, and economic impacts by 

each class or category of source (CH&SC 40406). 

D. Rule Amendment Process 

As part of the rule amendment process, District staff conducted a public scoping 

meeting in November 2008. At the scoping meeting, District staff presented the 

objectives of the proposed rulemaking project, explained the District’s rule 

development process, solicited suggestions from affected stakeholders on how 

best to achieve the emission reductions, and informed all interested parties about 

upcoming workshop dates, comment periods, and project milestones. 
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The knowledge gathered during the scoping meeting was used to help in the 

preparation of the first draft rule that was presented at workshop one in March 

2008. A Socioeconomic Focus Group meeting was also conducted in March 

2008, immediately following the workshop. During the Socioeconomic Focus 

Group meeting stakeholders were asked to share estimated costs for compliance 

of the then draft amendments to the rule. The workshop was followed by a public 

comment period. The comments received from the public, affected sources, 

ARB, and EPA during the public workshop process were evaluated and 

incorporated into the drafts of the rule as appropriate. 

The revised proposed rule amendments, Final Draft Staff Report, and 

Socioeconomic Analysis Report has been published prior to the public hearing to 

consider the adoption of the amendments to the rule by the district Governing 

Board. The District’s 2007 Ozone Plan mandates a schedule for the public 

hearing to consider the adoption of the newly amended rules for the fourth 

quarter of 2009. 

II. BACKGROUND 

A. Architectural Coatings 

Architectural coatings are coatings that are applied to stationary structures and 

their accessories. They include house paints, stains, industrial maintenance 

coatings, traffic coatings, and many other products. VOCs are emitted from the 

coatings during application and from the associated solvents used for thinning 

and clean-up. For purposes of this rule architectural coatings are defined as a 

coating to be applied to stationary structures or their appurtenances at the site of 

installation, to portable buildings at the site of installation, to pavements or to 

curbs. 

B. ARB Suggested Control Measure (SCM) 

On October 26, 2007 the ARB approved amendments to the SCM for 

Architectural Coatings. The SCM was developed for districts that need additional 

emission reductions for the attainment or maintenance of state or federal ambient 

air quality standards. ARB amended the SCM to lower the VOC limits, improve 

definitions for coatings, and to promote consistency and uniformity among district 

rules. 

Districts in need of further VOC reductions than the reductions expected to be 

achieved by the approved SCM may also consider the more stringent regulation 

adopted by the South Coast AQMD as its Rule 1113. 
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SCM Amendments 

The amended SCM established VOC content limits for more than 40 categories 

of architectural coatings, compared to the 47 categories in the 2000 SCM. Of the 

47 coating categories in the 2000 SCM, 15 coating categories were eliminated, 

ten were added, and the limits for 19 existing coating categories were made 

more stringent. Table 2 illustrates the SCM recommended VOC limits, as 

presented in the SCM. 

The SCM also calls for several other requirements besides the VOC content limit 

requirements. The additional SCM requirements include: 

• Requirement for operators to submit sales data to ARB 

• New, updated container labeling requirements 

• A “Painting practices” provision for painting operations to follow 

• A new thinning provision specifying allowable thinning practices 

• A sell through provision allowing three years to sell products manufactured 

prior to the effective date of the VOC limit. 
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Table 2 SCM Suggested VOC Content Limits 

Coating Category Effective 1/1/2010 Effective 1/1/2012 

Flat Coatings 50 

Nonflat Coatings 100 

Nonflat - High Gloss Coatings 150 

Specialty Coatings 

Aluminum Roof Coatings 400 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 50 

Bituminous Roof Primers 350 

Bond Breakers 350 

Concrete Curing Compounds 350 

Concrete/Masonry Sealers 100 

Driveway Sealers 50 

Dry Fog Coatings 150 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Floor Coatings 100 

Form - Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatings 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 100 

Metallic Pigmented Coatings 500 

Multi - Color Coatings 250 

Pre- Treatment Wash Primers 420 

Primers, Sealers, and Undercoaters 100 

Reactive Penetrating Sealers 350 

Recycled Coatings 250 

Roof Coatings 50 

Rust Preventative Coatings 250 

Shellacs: 

 - Clear 730 

 - Opaque 550 

Specialty Primers, Sealers, and 

Undercoaters 100 

Stains 250 

Stone Consolidants 450 

Swimming Pool Coatings 340 

Traffic Marking Coatings 100 

Tub and Tile Refinish Coatings 420 

Waterproofing Membranes 250 

Wood Coatings 275 

Wood Preservatives 350 

Zinc-Rich Primers 340 
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SCM V. South Coast AQMD Rule 1113 

ARB staff considered the feasibility of the SCAQMD Rule 1113 VOC limits as a 

part of the SCM development process. ARB staff determined that the SCAQMD 

limits would not be feasible for implementation for several coatings categories in 

other districts, for technical reasons discussed later in this report. As such, ARB 

has deemed that many of the limits in the SCAQMD Rule 1113 are beyond 

RACT. Table 3 below is a comparison between SCAQMD Rule 1113 and the 

SCM illustrating which coatings in Rule 1113 are more stringent than the SCM. 

Table 3 was copied directly from the SCM Staff Report. 

Table 3 Comparison Between SCAQMD Rule 1113 and SCM 

SCAQMD Rule 1113 Category 

Rule 

1113 

Ceiling 

Limit 1

(g/l) 

Rule 

1113 

VOC 

Limit 

(g/l) 

Corresponding Categories in 

SCM 

SCM 

VOC 

Limit 

(g/l) 

Concrete-Curing Compounds 350 100 Concrete Curing Compounds 350 

Floor Coatings 420 50 Floor Coatings 100 

Industrial Maintenance Coatings 420 1002 Industrial Maintenance Coatings 250 

Zinc-Rich IM Primers 420 100 Zinc-Rich Primers 340 

Mastic Coatings 300 300 Mastic Texture Coatings 100

Nonflat Coatings 250 50 Nonflat Coatings 100 

Nonflat High Gloss 250 50 Nonflat - High Gloss 150

Quick-Dry Enamels 400 50 Nonflat - High Gloss 150 

Roof Coatings, Aluminum 500 100 Aluminum Roof Coatings 400 

Rust Preventative Coatings 420 100 Rust Preventative Coatings 250 

Stains (Exterior) 350 100 Stains 250 

Traffic Marking Coatings 100 

Traffic Coatings 250 100 Driveway Sealers 50 

Concrete /Masonry Sealers 100 

Wood Coatings 275 

Basement Specialty Coatings 400 

Reactive Penetrating Sealer 350 

Waterproofing Sealers 400 100 Waterproofing Membranes 250 

Concrete/Masonry Sealers 100 

Basement Specialty Coatings 400 

Reactive Penetrating Sealer 350 

Waterproofing Concrete/Masonry Stone Consolidant 450 

Sealers 400 100 Waterproofing Membranes 250 

Form-Release Compounds 250 

Stone Consolidant 450 

Stub and Tile Refinish 420 

Default NA 250 Default 

50-

150 

1. Ceiling Limit: The maximum allowable VOC content for coatings that are included in the Rule 1113 averaging 

program. 

2. For Industrial Maintenance Coatings, Rule 1113 allows for the use of TBAc as an exempt solvent to help achieve the 

100 g/l VOC limit. 
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• The SCM coating limits need to be suitable for a variety of climates found 

throughout California. As SCAQMD staff has said in public meetings, some 

of the VOC limits in their rule, specifically for Nonflat and Nonflat-high gloss 

coatings are not intended for areas outside the SCAQMD. There are 

concerns with freeze/thaw stability and dirt pick up due to removal of VOCs to 

meet the lower limits. This concern also applies in varying degrees to the 

other categories mentioned above. 

o According to the SCAQMD 2007 Annual Status Report on Rule 1113, 

tests were conducted to measure the freeze/thaw cycle stability of ultra 

low-VOC coatings in a laboratory performance study. The SCAQMD 

staff concluded that 75% of low-VOC coatings failed the test after the 

first cycle; however, one of the low-VOC coatings passed four cycles 

and one passed all five cycles. This is evidence that formulators have 

made progress in addressing the freeze/thaw issue in Flat coatings 

with a VOC of < 50g/l. Conversations with ARB illuminated that the 

evidence presented by SCAQMD is regarding Flat Coatings, not 

Nonflat coatings. Staff searched for more information regarding 

Nonflat and Nonflat-High Gloss Coatings and freeze/thaw test results. 

Staff was unsuccessful in this search. Therefore, based on information 

available at this time, staff must support the SCM VOC limits for 

Nonflat and Nonflat-High Gloss Coatings. 

• The SCM does not contain an averaging provision. In the SCAQMD, coating 

manufacturers can sell products that exceed the VOC limits, if they 

demonstrate that the excess emissions are offset by emissions from sales of 

over-complying products. 

o The 2006 SCAQMD Annual Status Report on Rule 1113 verifies that 

there are coatings available that meet the new standards. SCAQMD 

staff conducted a Web Based Search for Available Future Compliant 

Coatings and found several. It was the recommendation of SCAQMD 

staff in 2006 that “Virtually all coating categories in Rule 1113 except 

for high gloss coatings currently have more than adequate 

replacement products for solvent-based and other higher VOC 

counterparts, many of which are well below the current lowest effective 

limit of 50 g/l VOC.” It was at that time that SCAQMD staff 

recommended amending Rule 1113 to include a new category for nonflat high gloss coatings with a VOC limit of 150 g/l effective on July 1, 

2006. On July 1, 2007 the limit for the new category would be reduced 

to 50 g/l VOC, coinciding with the general non-flat category. The 

suggested amendment also included the category of Quick Dry 

Enamels. The SCAQMD staff also concluded in the 2007 Annual 

Status Report on Rule 1113 that there are increasing numbers and 

volumes of products that meet SCAQMD VOC limits, or are well below 

those limits. 
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Based on conversations with stakeholders and ARB, District staff have 

come to the conclusion that allowing an averaging provision would give 

an unfair advantage to large manufacturers versus small 

manufacturers. Averaging would allow a manufacturer to sell products 

that exceed the VOC limit if they can demonstrate that the excess 

emissions are offset by emissions from over-complying products. 

Small manufacturers may not qualify for the averaging advantage 

because they only manufacture a single type of coating, or do not 

manufacture enough volume to offset noncompliant materials with 

over-compliant materials. 

• The SCM does not contain an exemption for tertiary butyl acetate (TBAc) due 

to concerns about the toxicity of TBAc. SCAQMD Rule 1113 contains a TBAc 

exemption for Industrial Maintenance Coatings only. Under this exemption 

manufacturers do not have to include TBAc when calculating the VOC 

content of industrial maintenance coatings. 

o The SJVAPCD also has an exemption for TBAc; therefore 

manufacturers in the SJVAB will also not have to include TBAc when 

calculating the VOC content of industrial maintenance coatings. 

• The SCM does not contain a small business exemption. Rule 1113 allows 

small businesses in certain categories to be exempt from VOC limits or to 

have additional time to comply with VOC limits. 

o District staff acknowledges that the SCAQMD has an exemption for 

small businesses, and that the SJVAPCD does not provide this 

exemption, but points out that according to SCAQMD compliant 

coatings are readily available. 

• The SCM does not contain an exemption for high elevations. Under Rule 

1113, stains and lacquers do not have to comply with the rule’s VOC limits if 

they are used at an elevation of 4,000 feet or greater above sea level. 

o The SJVAPCD encompasses climate regions that require the use of 

solvents to prevent structural and environmental issues. San Joaquin 

Valley has several areas that fall within Climate Zone 16 as defined by 

the CEC Climate Zone Descriptions, which tends to be found at higher 

altitudes. The weather patterns described in Climate Zone 16 are 

better suited to solvent-based products which can be applied at 32 

degrees Fahrenheit or better and withstand moisture sooner than 

water based products. 

o The solvent in these aluminum coatings allows the coating to “skin” 

while the product cures to its final state. The skinning as defined by 

the NRCA Guide to Roof Coatings is a “function of the time necessary 

to form a dense film on the surface of a liquid coating or mastic to the 

extent that the material is unaffected by a water spray.” Waterborne 
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products must be applied at 40 degrees Fahrenheit or better with 

minimal moisture present during curing, and if applied incorrectly will 

lead to product performance issues such as rain wash off, potentially 

creating environmental hazards; poor film formation, resulting in 

premature coating failure; or if frozen during application or curing, 

result in immediate catastrophic coating failure. 

• The SCM needs to be enforceable by small districts with limited resources. 

Accordingly, the SCM does not contain an averaging provision, which 

requires resources for recordkeeping and auditing. 

o Staff has decided not to recommend the District re-instate the 

averaging provision that was retired in 2005. 

The SCAQMD Rule 1113 does not have exemptions for small containers or 

varnishes, sanding sealers, clear lacquers, and pigmented lacquers, and requires 

manufacturers to submit an annual report to document sales of products sold in 

small containers. The SCM does not contain a requirement for annual reporting, 

and the SCM has a small container exemption for wood coatings. 

III. DISCUSSION 

This source category currently includes any person who supplies, sells, offers for 

sale, applies, or solicits the application of any architectural coating, or who 

manufactures any architectural coating for use within the District. Those who are 

subject to the Rule 4601 (Architectural Coatings) includes, but are not limited to, 

manufacturers, retailers, paint contractors, importers, distributors, public works 

personnel, and construction workers. 

A. Current Regulations 

District Rule 4601 currently limits VOC emissions from architectural coatings. 

This rule specifies architectural coatings storage, cleanup, and labeling 

requirements. The rule applicable to any person who supplies, sells, offers for 

sale, applies, or solicits the application of any architectural coating, or who 

manufactures any architectural coating for use within the District. 

Currently rule language has exemptions for architectural coatings that are sold or 

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

manufacturers for reformulation or repackaging. Also exempted from rule 

requirements are any architectural coatings that are sold in containers with a 

volume of one liter (1.057 quarts) or less. 
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On January 15, 2009, the SJVAPCD Governing Board adopted amendments to 

Rule 1020 (Definitions). The adopted amendments included an amendment to 

the definition of VOC to exempt TBAc. However, the exemption for TBAc is for 

VOC emissions limitations or VOC content requirements only. It is not exempt 

from recordkeeping, emissions reporting, photochemical dispersion modeling, 

and inventory requirements which apply to all VOCs. This provision is based on 

language from the EPA Final Action on TBAc as codified in the Code of Federal 

Regulations (CFR) 40 CFR Part 51.I 00 (s)(5). Also, any use of TBAc exceeding 

a total of one gallon per year per facility will require the operator to apply to 

modify their District Permit to Operate. This provision allows the use of TBAc to 

reduce ozone precursor emissions, but is still protective of public health. For 

further explanation and details of amendments to Rule 1020 (Definitions) please 

refer to Rule 1020 (Definitions). 

B. Summary of Proposed Amendments 

In establishing proposed VOC emission limits, District staff considered and 

evaluated BACT determinations, rules in other California air districts and other 

states, and the ARB SCM for architectural coatings. The main objective of this 

rule project is to obtain as much reduction of VOC from this source category as 

expeditiously practicable, technologically feasible, and economically reasonable. 

Revised Proposed Amendments 

Revised Proposed Amendments include the addition of references to test 

methods and labeling requirements in the definitions section of the rule. Also, 

proposed language omitted some SCM language from Section 6.3.1, that 

language has been added for the sake of clarity and consistency. 

District staff is recommending the following proposed amendments: 

Section 1.0 – Purpose 

No changes proposed at this time. 

Section 2.0 – Applicability 

The phrase “blends or repackages” would be added to rule language to extend 

the applicability of rule language to stakeholders involved in those activities. 

Section 3.0 – Definitions 

Numerous definitions would be added, deleted or modified in order to make this 

rule harmonize with definitions and rule requirements presented in the ARB 

SCM. 
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Section 4.0 – Exemptions 

A reporting requirement will be added for any architectural coating that is sold in 

a container with a volume of one liter or less. The exemption for architectural 

coatings would be further defined by adding “coatings that are supplied and 

offered for sale” to current language, in order to make this rule consistent with the 

ARB SCM. 

Section 5.0 – Requirements 

Section 5.1 VOC Coating Limits 

This rule-amending project would implement the recommended VOC limits per 

the ARB SCM. The following changes are recommended at this time: 15 coating 

categories would be eliminated, ten would be added, nineteen coatings 

categories would remain unchanged, and the VOC content limits for 19 

categories would be lowered. The following is a summary of VOC coating limits 

for this rule. 

The following coating categories will be eliminated effective on and after January 

1, 2011. 

• Antenna Coatings 

• Antifouling Coatings 

• Clear Wood Coatings 

o Clear Brushing 

Lacquers 

o Lacquers 

o Sanding Sealers 

o Varnishes 

• Fire-Retardant Coatings 

o Clear 

o Opaque 

• Flow coatings 

• Quick-Dry Enamels 

• Quick-Dry Primers, Sealers 

and Undercoaters 

• Swimming Pool Repair and 

Maintenance Coatings 

• Temperature-Indicator Safety 

Coatings 

• Waterproofing Sealers 

• Waterproofing 

Concrete/Masonry Sealers 

The following Coating Categories would not have any changes during this rule 

amending project. 

• Bituminous Roof Primers 

• Bond Breakers 

• Concrete Curing Compounds 

• Faux Finishing Coatings 

• Fire Resistive Coatings 

• Form-Release Compounds 

• Graphic Arts Coatings (Sign 

Paints) 

• High Temperature Coatings 

• Industrial Maintenance 

Coatings 

• Magnesite Cement Coatings 

• Metallic Pigmented Coatings 

• Multi-Color Coatings 

• Pre-Treatment Wash Primers 

• Recycled Coatings 
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• Shellacs 

o Clear 

o Opaque 

• Stains 

• Swimming Pool Coatings 

• Wood Preservatives 

The following Coating Categories, and corresponding VOC content limits, would 

be added to rule language effective on and after January 1, 2011. 

• Aluminum Roof Coatings 

(400 g/l) 

• Basement Specialty coatings 

(400 g/l) 

• Concrete/Masonry Sealers 

(100 g/l) 

• Driveway Sealers (50 g/l) 

• Reactive Penetrating Sealers 

(350 g/l) 

• Stone Consolidants (450 g/l) 

• Tub and Tile Refinish 

Coatings (420 g/l) 

• Waterproofing Membranes 

(250 g/l) 

• Wood Coatings (275 g/l) 

• Zinc-Rich Primers (340 g/l) 

The following is a discussion of new coating categories that would be added to 

this rule during this rule-amending project. 

It is important to note that some coating categories, specifically Basement 

Specialty, Reactive Penetrating Sealers, Stone Consolidants, and Tub and Tile 

Refinish, that are being added to rule language, are new to regulation as 

architectural coatings. Prior to the 2007 SCM ARB did not consider these 

coatings to be architectural coatings. With this SCM ARB is declaring that these 

products are now to be considered and regulated as architectural coatings. 

These products have previously been sold in California as either a consumer 

product, an unregulated product, or in small containers. 

This rule amending project will align Rule 4601with the intentions of ARB’s 2007 

SCM to include those coating categories and make them subject to regulation as 

architectural coatings in the Valley. It is also important to note that these coating 

categories are specialized niche categories with small sales volumes and 

emissions as verified in the 2007 ARB SCM Staff Report. According to the 2007 

ARB SCM Staff Report, the combined documented VOC emissions from coatings 

that could be considered a part of the four aforementioned coating categories in 

2004 was 0.02 tons per day. 

To avoid imposing unintended and technologically infeasible VOC limits for the 

four specific coating categories, industry requested a temporary exemption from 

the general coating limits. District staff recommends that industry’s 

recommendation be implemented but that this consideration be accomplished 

through a special provision rather than an exemption. 
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 Amendments to Rule 4601

The following is a discussion of coating categories that would be changed during 

this rule-amending project. 

Aluminum Roof Coatings 

Aluminum Roof Coating is a new category that was formerly included in the 

Metallic Pigmented category. These coatings are primarily used as a topcoat for 

asphalt roof systems or metal roofs that need a reflective coating. They contain 

aluminum flakes for the reflection of solar radiation to reduce the surface 

temperature of the roof and the internal temperature of the structure. These 

aluminum pigments float to the surface of the coating during settling (a process 

known as “leafing”) and they can reflect up to 60% of ultraviolet (UV) rays. They 

also aid in the inhibition of rust formation and alleviate corrosion of metal 

surfaces. These coatings are not intended to prevent water penetration or stop 

leaks, repair seams, or repair blisters, but they can prevent moisture 

accumulation due to the inherent nature of bituminous resin water resistance 

(RCMA, 1997). In addition, most Aluminum Roof coatings are Underwriter’s 

Laboratory (UL) Class A Fire Rated, which improves fire resistance and 

enhances building safety. 

In the first draft of the Rule the VOC content limit for this coating was 100 g/l, 

staff are currently recommending a VOC content limit of 400 g/l. Upon careful 

review of the SCAQMD rule requirements, and the SCM Staff Report (as 

presented in Table 3 of this Final Draft Staff Report), staff have come to the 

conclusion that it would be more appropriate to implement the SCM VOC limit for 

this coating category due to the absence of an Averaging Provision. The 

SJVAPCD will not re-instate the averaging provision that expired in 2005. The 

averaging provision allows for a “ceiling limit” to be used by operators as long as 

they offset those emissions by using other coatings that are over-compliant. The 

SCAQMD VOC content limit for aluminum roof coatings is 100 g/l. The “ceiling 

limit” provision offered by SCAQMD to operators allows the use of coatings with 

VOC content of 500 g/l. 

The SCAQMD has determined that it is technically feasible to implement a 100 

g/l limit for Aluminum Roof coatings, because they have local climactic conditions 

that are not representative of other areas in the State, the SJVAB included. For 

the remainder of California, ARB staff has determined that the technology exists 

to formulate Aluminum Roof Coatings that comply with a 400 g/l limit. 

ARB recommends a 400 g/l VOC limit for Aluminum Roof coatings because the 

VOC limit is technologically and commercially feasible, based on review of ARB 

survey data, complying marketshare, the number of companies making compliant 

products, and product information from manufacturers. The South Coast AQMD 

adopted a 100 g/l limit for Aluminum Roof coatings that became effective January 

1, 2005. ARB’s recommended VOC limit is higher than the limit adopted by the 

South Coast AQMD, because the South Coast area has a temperate climate that 
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is not subject to the weather extremes that occur in other parts of California. 

ARB staff found that solventborne products are needed for colder, wetter 

climates until the technology advances for waterborne products. In addition, 

ARB staff is concerned about potential safety issues associated with the 

generation of hydrogen gas in waterborne aluminum coatings. Based on 

discussions with manufacturers, those products that do meet the South Coast 

limit have been repackaged with plastic containers and vents, have a shelf life of 

six months from production to application, and are usually made to order for 

specific jobs. 

Other reasons supporting the implementation of a 400 g/l VOC content limit for 

Aluminum Roof Coatings have been presented by stakeholders. For example, 

many producers of aluminum roof coatings have qualified their products as 

meeting EPA’s Energy Star Roof Products program. The proposed reduction in 

VOC limits would necessitate a re-evaluation of Energy Star rated aluminum 

coatings by producers of those products. Re-evaluation would require producers 

to take current products off the market for a period of more than three years while 

the coatings are reformulated and resubmitted for three year outdoor testing. 

The shelf life could be reduced to 3-6 months resulting from the chemical 

reaction that occurs between the aluminum and water. This reaction generates 

hydrogen gas, which can become trapped inside the container and may become 

explosive. As such, special care and storage precautions would have to be 

taken when stocking this product to eliminate scenarios where explosions could 

occur. The shortened shelf-life would also result in manufacturers continually 

restocking these coatings, which would lead to additional handling and 

transportation costs, and vehicle miles driven to remove and replace the unsafe 

out dated inventory. 

Caltrans has done extensive research regarding the performance of aluminum 

coatings and has not identified any acceptable 100 g/l products that perform as 

well as coatings with VOC limits between 200 and 250 g/l. The aluminum 

coatings between 200 and 250 g/l that Caltrans uses require trained personnel to 

mix and apply, thus are not for the average contractor, business owner, and/or 

homeowner to use. Caltrans’ research is a strong indicator that the 400 g/l 

stipulated in the 2007 ARB SCM for Architectural Coatings is the appropriate 

VOC limit. 

The significant reduction in the VOC limit could possibly affect the Underwriters 

Laboratory (UL) Class A Fire Rating of many roofing systems. By changing the 

VOC limits of these aluminum coatings from 400 g/l to 100g/l, it would trigger the 

need for reformulation and retesting of many previously approved UL Class A 

Fire rated roofing systems. 
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Tert Butyl Acetate (TBAc) should not be used as a replacement solvent for 

reformulation in Solvent Borne Aluminum Roof Coatings for two reasons: it is not 

an effective solvent for the asphaltic resin binder in these coatings, and it is a 

"red label" (DOT Flammable Liquid). TBAc is a short (C6), polar solvent. It is not 

effective at reducing the viscosity of asphalts, which are blends of long- to verylong chain aliphatic oils and aromatic resins with a flash point of 16.7 oC (62 o

F), 

essentially the same as that of gasoline (roughly 15 oC). This classifies TBAc, 

and any product made from TBAc, as a Flammable Liquid under the Department 

of Transportation regulations. Almost all Fire Protection Associations and 

Building Codes use the DOT definitions as part of their regulations, which may 

have severe consequences throughout the production and distribution chain. 

Basement Specialty Coatings 

Basement Specialty Coatings is a new category that includes coatings formerly 

could have been covered by Waterproofing Sealer and Waterproofing 

Concrete/Masonry Sealer. Basement Specialty Coatings are a clear or opaque 

coating that is labeled and formulated for application to concrete and masonry 

surfaces to provide a hydrostatic seal for basements and other below-grade 

surfaces to prevent the intrusion of water into basement areas, and help prevent 

mold, mildew, and efflorescence. Basement Specialty coatings must be able to 

withstand at least 10 psi of hydrostatic pressure and must be resistant to mold 

and mildew growth and must achieve a microbial growth rating of eight or more. 

Basement Specialty Coatings can be applied by professional contractors or 

homeowners. 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 400 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC limits of 420 g/l. 

For the new Basement Specialty Coating category, ARB recommends a VOC 

limit of 400 g/l. The SCM VOC limit is higher than the 100 g/l limit contained in 

SCAQMD Rule 1113. However, manufacturers that provide coatings in the 

SCAQMD area can still sell products that exceed the 100 g/l limit, if they 

participate in SCAQMD’s averaging program. In addition, the emission reduction 

losses for this category are negligible for a 400 g/l limit as compared to a 100 g/l 

limit, due to the small sales volume. 
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Concrete Curing Compounds 

The Concrete Curing Compounds coating category would not have VOC limits 

made more stringent during this rule-amending project. The SCM VOC content 

limit for this coating category is 350 g/l, while the SCAQMD VOC content limit is 

100 g/l. Upon review of the SCAQMD rule requirements, and the SCM Staff 

Report (as presented in Table 3 of this Final Draft Staff Report), staff have come 

to the conclusion that it would be more appropriate to implement the SCM VOC 

limit for this coating category due to the absence of the averaging provision at the 

District. The SCAQMD allows for a “ceiling limit” of 350 g/l for this coating 

category due to the averaging provision. 

Concrete/Masonry Sealer 

Concrete/Masonry Sealer is a new category that covers coatings formerly 

covered by Waterproofing Sealer, Waterproofing Concrete/Masonry Sealer, and 

other Categories. Concrete/Masonry Sealers are a clear or opaque coating 

labeled and formulated primarily for application to concrete and masonry 

surfaces to prevent penetration of water, provide resistance against abrasion, 

alkalis, acids, mildew, straining, or ultraviolet light, or to harden or dustproof the 

surface of aged or cured concrete. 

Driveway Sealer 

Driveway Sealer is a new category that includes coatings that were formerly 

covered by the default VOC limits. Driveway Sealer is a coating labeled and 

formulated for application to worn asphalt driveway surfaces to fill cracks, seal 

the surface to provide protection, and/or to restore or preserve the appearance. 

Driveway Sealers can extend driveway longevity and protect against weather, 

erosion, oil, and gasoline. If applied and cured properly, Driveway Sealers are 

waterproof. These products are applied with a brush, squeegee, roller, or 

sprayer and they can be applied by homeowners or contractors. 

Fire Retardant Coatings 

Effective on and after January 1, 2011, the Fire Retardant coating categories 

would be eliminated because they are no longer needed. Coatings with fire 

retardant properties would be subject to the VOC limit of their primary coating 

(e.g., Flat, Nonflat, etc.). 

Floor Coatings 

In the first draft the VOC content limit for this coating was 50 g/l, staff are 

currently recommending a VOC content limit of 100 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 
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 Amendments to Rule 4601

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC limits up to 420 g/l. 

ARB recommends a 100 g/l VOC limit for Floor Coatings, the SCM VOC limit is 

technologically and commercially feasible by 2010, based on the high complying 

marketshare, the number of companies making complying products, and 

information provided by manufacturers. The proposed VOC limit is higher than 

the 50 g/l limit contained in the SCAQMD Rule 1113. However, manufacturers 

that provide coatings in the SCAQMD area can still sell products with exceed the 

50 g/l limit, if they participate in SCAQMD’s averaging program. In addition, ARB 

staff research reviewed lists of low-VOC products that could be applied to floors 

and had VOC contents near or below 50 g/l. Under the SCM, almost all of the 

products that were reviewed would be classified as concrete/masonry sealers or 

industrial maintenance coatings, rather than Floor Coatings. Since Floor 

Coatings need to stand up to abrasion from pedestrian traffic, it has been 

challenging to develop resins that can be used to formulate 50 g/l products with 

acceptable performance. Therefore, ARB staff believes that the proposed 100 g/l 

VOC limit is most appropriate at this time and the SJVAPCD staff support this 

conclusion. 

Industrial Maintenance Coatings 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 250 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC limits of 420 g/l. 

On April 2, 2009, ARB approved the “Installation, Operation and Maintenance 

Manual For Standing Loss Control Vapor Recovery System for Existing 

Installations of Aboveground Storage Tanks As Certified by Executive Order VR301-A”. The aforementioned manual describes the tools and methods required 

to install the Standing Loss Control Enhanced Vapor Reduction (EVR) System. 

The manual establishes guidelines that will be adhered to when preparing and 

applying white paint to existing aboveground storage tanks (ASTs), a mandatory 

activity. Only three paints are allowed for the program, the manual identifies 

them as follows: 

1. PPG High Performance Coatings - VOC 241 g/l

2. Ponderosa Paint Co, Inc - VOC 17 g/l

3. ICI Devoe Devthane - VOC 229 g/l 
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For further details of this program please refer to the manual, which is posted on 

the ARB website at http://arb.ca.gov/vapor/ast/eo301a_IOM.pdf. District staff 

has reviewed this manual and has come to the conclusion that it would be 

extremely limiting on operators to comply with the standards therein if the VOC 

content limit were amended to 100 g/l thereby eliminating two of the three 

compliant paint options. Therefore, staff feel it would be more appropriate at this 

time to recommend the VOC content limit for industrial maintenance coatings 

remain at 250 g/l. 

Anti-Graffiti coatings are a subset of Industrial Maintenance category and are 

important in combating graffiti removal from buildings. ARB found that AntiGraffiti coatings up to 250 g/l are being used by State and city agencies, and an 

ARB economic analysis of a 150 g/l limit for anti-graffiti coatings showed that the 

limit was not cost effective. 

Low Solids Coatings 

The VOC Limit for Low Solids Coatings is expressed as “VOC, including water 

and exempt compounds” (i.e., Material VOC or VOC Actual). 

Nonflat Coatings 

In the first draft the VOC content limit for this coating was 50 g/l, staff are 

currently recommending a VOC content limit of 100 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC content of up to 250 g/l. 

The proposed 100 g/l VOC limit is higher than the 50 g/l limit contained in 

SCAQMD Rule 1113. However, manufacturers that provide coatings in the 

SCAQMD area can still sell products that exceed the 50 g/l limit, if they 

participate in SCAQMD’s averaging program. In addition, the SCM needs to be 

technologically feasible throughout California. To comply with the 50 g/l limit, 

some Nonflat coating manufacturers have eliminated glycols in their formulations. 

As a result, their products must be transported in heated trucks and stored in 

heated areas, to prevent freezing. Paints with high water contents can coagulate 

and become unusable if they become frozen. The SCAQMD has a mild climate, 

so freezing temperatures are less of a concern. However, in other areas of 

California, freezing temperatures are more prevalent. ARB staff believes that 

additional research is needed to develop products that perform well in areas with 

more extreme climates, particularly for exterior Nonflat coatings. ARB 

recommends adopting the 100 g/l VOC limit because it is technologically and 
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 Amendments to Rule 4601

commercially feasible based on the complying marketshare, the number of 

companies making complying products, and product information from 

manufacturers. In addition, the proposed limit is supported by the results of 

product testing conducted by Consumers Union, Master Painter’s Institute (MPI), 

University of Missouri-Rolla (UMR), and National Technical Systems (NTS). 

Nonflat-High Gloss Coatings 

In the first draft the VOC content limit for this coating was 50 g/l, staff are 

currently recommending a VOC content limit of 150 g/l. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC content of 250 g/l. The Quick-Dry Enamels coating category 

would be included as a part of the Nonflat-High Gloss coating on and after 

January 1, 2011. The SCAQMD ceiling limit for this category is as high as 400 

g/l VOC content. 

The proposed limit is higher than the 50 g/l limit contained in SCAQMD Rule 

1113. However, manufacturers that provide coatings in the SCAQMD area can 

still sell products which exceed the 50 g/l limit, if they participate in SCAQMD’s 

averaging program. To comply with the 50 g/l limit, some coating manufacturers 

have eliminated glycols in their formulations. As a result, their products must be 

transported in heated trucks and stored in heated areas, to prevent freezing. 

Paints with high water contents can coagulate and become unusable if they 

become frozen. The SCAQMD has a mild climate, so freezing temperatures are 

less of a concern. However, in other areas of California, freezing temperatures 

are more prevalent. ARB staff believes that additional research is needed to 

develop products that perform well in areas with more extreme climates, 

particularly for Nonflat – High Gloss coatings. In addition, more coalescing 

agents allow for the use of harder resins that improve scrub resistance and dirt 

pickup resistance. 

Reactive Penetrating Sealer 

Reactive Penetrating Sealer is a new category that was formerly covered by 

Waterproofing Sealer and Waterproofing Concrete/Masonry Sealer. Reactive 

Penetrating Sealer is a clear or pigmented product that is labeled and formulated 

for application to above-grade concrete and masonry substrates to provide 

protection from water and waterborne contaminants, including but not limited to, 

alkalis, acids, and salts. Reactive Penetrating Sealers must penetrate into 

concrete and masonry substrates and chemically react to form covalent bonds 

with naturally occurring minerals in the substrate. Reactive Penetrating Sealers 

line the pores of concrete and masonry substrates with a hydrophobic coating, 
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 Amendments to Rule 4601

but do not form a surface film. Reactive Penetrating Sealers can be used on 

walls, roadways, bridge decks, sidewalks, driveways, historical monuments, and 

other surfaces. 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 350 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. 

Reactive Penetrating Sealers from the SCM when compared to the SCAQMD 

rule, as illustrated in Table 3 of this Staff Report, are equivalent coatings to 

Waterproofing Sealers and Waterproofing Concrete/Masonry Sealers, each of 

which has a VOC content limit of 100 g/l. The “ceiling limit” provision offered by 

SCAQMD for both coating categories is 400 g/l. 

ARB has determined that a VOC limit of 350 g/l is technologically and 

commercially feasible, based on information provided by manufacturers. This 

would provide a consistent VOC limit for Reactive Penetrating Sealers and 

Concrete Curing Compounds. Both of these categories use similar reactive 

penetrating materials, but the products in the Concrete Curing Compound 

category must be suitable for use on freshly poured concrete. Other types of 

concrete and masonry coatings that do not meet the criteria for Reactive 

Penetrating Sealer would be covered by another category (e.g., 

Concrete/Masonry Sealer, Basement Specialty Coating, Waterproofing 

Membrane, etc.). 

The proposed VOC limit is higher than the 100 g/l limit contained in SCAQMD 

Rule 1113. However, manufacturers that provide coatings in the SCAQMD can 

still sell products which exceed the 100 g/l limit, if they participate in South Coast 

AQMD’s averaging program. In addition, the emission reduction losses for this 

category are negligible for a 350 g/l limit as compared to a 100 g/l limit, according 

to ARB. 

Rust Preventative Coatings 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 250 g/l. The effective date for 

this coating limit would be January 1, 2012. ARB recommends a 250 g/l VOC 

limit for Rust Preventative coatings, effective January 1, 2012. The extra time 

would provide Rust Preventative manufacturers time to reformulate low VOC 

alkyd technologies. Under the SCM VOC limit and definition, most solventborne 

coatings and topcoats would be excluded from the category. Lowering the VOC 

limit from 400 g/l to 250 g/l will eliminate many high-VOC solventborne coatings 
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23 Final Staff Report with Appendices For 

 Amendments to Rule 4601

that were shifted to the Rust Preventative category after VOC limits were 

implemented from the 2000 SCM. New products in this category and existing 

products that comply with the proposed limit are expected to use waterborne 

acrylic latex technology. These types of products have previously been used in 

the Industrial Maintenance category to protect metal substrates from corrosion. 

These coatings generally have VOC contents under 250 g/l and are 

predominantly single component. Although the current Rust Preventative 

category is primarily comprised of solventborne alkyd coatings, it is 

technologically feasible to protect metal substrates from corrosion with 

waterborne acrylic coatings. The VOC limit for the Rust Preventative category is 

higher than the 100 g/l limit in the SCAQMD. However, coating manufacturers 

who sell in the SCAQMD can continue to sell high-VOC Rust Preventative 

coatings if they participate in the SCAQMD averaging program. 

Specialty Primers, Sealers, and Undercoaters 

This coating category VOC content limit would be made more stringent in 2012 

from the current limit of 350 g/l to 100 g/l. ARB recommends a 100 g/l VOC limit 

for Specialty Primers, Sealers, and Undercoaters, effective January 1, 2012. The 

later effective date for Specialty Primers, Sealers, and Undercoaters would allow 

manufacturers to develop appropriate stain-blocking test methods. The VOC 

limit is technologically and commercially feasible by January 1, 2012, based on 

the complying marketshare, test data, the number of companies making 

complying products, and product information from manufacturers. The VOC limit 

is consistent with the limit adopted by the South Coast AQMD. 

Stains

In the first draft of amendments to Rule 4601, staff had divided the category into 

internal and external stains. However, Upon careful review of the SCAQMD rule 

requirements, and the SCM Staff Report (as presented in Table 3 of this Final 

Draft Staff Report), staff have come to the conclusion that it would be more 

appropriate to implement the SCM VOC limit for this coating category due to the 

absence of the averaging provision. The SCAQMD allows for a “ceiling limit” for 

this coating category due to the averaging provision. The “ceiling limit” provision 

offered by SCAQMD to operators allows the use of coatings with VOC limits up 

to 420 g/l. Therefore, staff is recommending this category stay one category with 

a VOC content of 250 g/l as recommended by the SCM. 

ARB recommends maintaining the current 250 g/l VOC limit for Stains, based on 

the complying marketshare, the number of companies making complying 

products, testing data, and product information from manufacturers. The South 

Coast AQMD adopted a 100 g/l limit for Exterior Stains while the limit for Interior 

Stains has remained at 250 g/l. ARB’s SCM limit for Exterior Stains is higher 

than South Coast AQMD limit, while the SCM limit for Interior Stains is the same 

as the South Coast AQMD. ARB staff believes that additional research and 

testing is needed to develop exterior semi-transparent stains that can comply 
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24 Final Staff Report with Appendices For 

 Amendments to Rule 4601

with a 100 g/l VOC limit and perform well throughout California. Based on 

performance testing results in the AVES report, zero-VOC exterior semitransparent stains generally do not perform as well in freeze/thaw, mildew/fungus 

resistance, stain blocking, and dirt pickup, though they generally perform better in 

color change and moisture/UV resistance. South Coast AQMD did not adopt a 

100 g/l limit for interior stains, due to appearance and depth issues related to the 

use of low-VOC clear wood coatings (SCAQMD, 2003). 

According to the ARB survey, exterior Semi-transparent Stains with VOC 

contents below 100 g/l represented close to zero percent of the overall sales 

volume. Based on these data, ARB staff does not believe that there is sufficient 

complying marketshare to support a 100 g/l limit for exterior Semitransparent 

Stains. ARB also believes that there are enforcement concerns with splitting the 

Stains category into Interior and Exterior subcategories. 

Stone Consolidant 

Stone Consolidant is a new category that was previously not considered an 

architectural coating. However, if they had previously been regulated they could 

have been covered by the default VOC limits and Waterproofing Concrete/ 

Masonry Sealer. Stone Consolidants penetrate into stone substrates to help 

restore the integrity of crumbling or decayed materials. These products are often 

considered to be concrete treatments, rather than coatings, and are not for 

general purpose use. The intent of establishing the Stone Consolidant category 

is to support historical preservation efforts by allowing limited use of these 

products under the direction of a stone conservation specialist, such as an 

architect, conservator, or engineer. Stone Consolidants are clear products that 

are designed to leave the surface appearance unchanged. After the 

consolidation process is complete, manufacturers often recommend that the 

substrate be coated with a water repellent to provide protection from the 

elements. Stone Consolidants can be used on a variety of historical structures, 

including statues, monuments, and buildings. 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 450 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC limits of 420 g/l. 
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25 Final Staff Report with Appendices For 

 Amendments to Rule 4601

For the new Stone Consolidant category, the ARB SCM VOC limit is 450 g/l. The 

VOC limit is technologically and commercially feasible by January 1, 2010, based 

on information provided by raw material suppliers and coating manufacturers. 

The VOC limit is higher than the 100 g/l limit contained in South Coast AQMD 

Rule 1113. However, manufacturers that provide coatings in the South Coast 

AQMD area can still sell products exceeding the 100 g/l limit, if they participate in 

South Coast AQMD’s averaging program. In addition, this is a very small 

category and the emission reduction losses for this category are negligible for a 

450 g/l limit as compared to a 100 g/l limit. 

Tub and Tile Refinish Coatings

Tub and Tile Refinish Coatings is a new category that was formerly covered by 

the default VOC limits and Nonflat-High gloss. Tub and Tile Refinish Coatings 

are a clear or opaque coating that is labeled and formulated exclusively for 

refinishing the surface of a bathtub, shower, sink, or countertop. Tub and Tile 

Refinish coatings include primers and topcoats that are used to refurbish 

bathtubs, showers, sinks, countertops, and other tile and porcelain surfaces. 

These products are designed to provide a hard surface that can withstand 

abrasion and immersion in hot water. However, they are not generally 

recommended for pools or hot tubs. Most products provide a glossy sheen, but 

some leave a satin finish. Tub and Tile Refinish coatings can be applied either 

by professional contractors or by homeowners. Most of the products identified by 

ARB staff are multi-component, solventborne formulations with acrylic urethane 

topcoats and epoxy primers. 

In the first draft the VOC content limit for this coating was 250 g/l, staff are 

currently recommending a VOC content limit of 420 g/l. The ARB SCM 

established a new category for Tub and Tile Refinish coatings to clarify how 

these products should be classified and regulated. ARB staff does not believe 

that it is technologically feasible for Tub and Tile Refinish products to be 

formulated to meet the VOC limit for the “Other” category. In addition, it does not 

appear that the products being sold in California are primarily being sold in small 

containers. The definition for the Tub and Tile Refinish category includes strict 

performance requirements to help prevent this category from becoming a 

loophole for Nonflat and other categories. While U.S. EPA considers Tub and 

Tile Refinish products to be covered by Industrial Maintenance, ARB staff does 

not believe that this is appropriate. For the new Tub and Tile Refinish category, 

we are recommending a VOC limit of 420 g/l, effective January 1, 2010. The 

VOC limit is technologically and commercially feasible by January 1, 2010, based 

on the number of companies making complying products and information 

provided by manufacturers. 
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Tub and Tile Refinishing is not currently listed in architectural coating rules for 

the South Coast AQMD. Establishment of the Tub and Tile Refinish category is 

for clarification purposes, rather than for obtaining emission reductions. While 

some products would need to be reformulated to meet the 420 g/l limit, the 

resulting emission reductions would be relatively negligible. 

Waterproofing Membranes 

Waterproofing Membranes is a new category that was formerly covered by 

Waterproofing Sealer and Waterproofing Concrete/Masonry Sealer. 

Waterproofing Membranes are a clear or opaque coating that is labeled and 

formulated for application to concrete and masonry surfaces to provide a 

seamless waterproofing membrane that prevents any penetration of liquid water 

into the substrate. Waterproofing Membranes are intended for application to 

below-grade surfaces, between concrete slabs, inside tunnels, inside concrete 

planters, and under flooring materials. The Waterproofing Membrane category 

does not include topcoats that are included in the Concrete/Masonry Sealer 

category (e.g., parking deck topcoats, pedestrian deck topcoats, etc.). The 

Waterproofing Membrane category is intended for non-wearing surfaces and it 

does not include products that are used to coat the surface of parking decks, roof 

decks, bridges, etc. 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 250 g/l. Waterproofing 

Membranes from the SCM when compared to the SCAQMD rule, as illustrated in 

Table 3 of this Staff Report, are equivalent coatings to Waterproofing Sealers 

and Waterproofing Concrete/Masonry Sealers, each of which has a VOC content 

limit of 100 g/l. Upon careful review of the SCAQMD rule requirements, and the 

SCM Staff Report (as presented in Table 3 of this Final Draft Staff Report), staff 

have come to the conclusion that it would be more appropriate to implement the 

SCM VOC limit for this coating category due to the absence of the averaging 

provision. The SCAQMD allows for a “ceiling limit” for this coating category due 

to the averaging provision. The “ceiling limit” provision offered by SCAQMD for 

both coating categories is 400 g/l. 

ARB recommends a VOC limit of 250 g/l. This limit will apply to the higher-build 

(>25 mil) products that comply with the requirements in the Waterproofing 

Membrane definition. Thinner coatings that provide a waterproofing membrane, 

but do not comply with the definition, will be covered by the new Concrete / 

Masonry Sealer category, and will need to comply with a VOC limit of 100 g/l. 

The limit for Waterproofing Membranes is consistent with the VOC limit for 

Industrial Maintenance coatings. It is expected that there may be some overlap 

between these two categories for products that are used in water/wastewater 

facilities and other applications that are covered by the Industrial Maintenance 

definition. Therefore, ARB believes that a consistent VOC limit makes the SCM 

VOC limits more enforceable. For Waterproofing Membrane products that were 
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previously classified as “Waterproofing Sealers” (250 g/l), the VOC limit remains 

the same. For products that were previously classified as “Waterproofing 

Concrete/Masonry Sealers” (400 g/l), the limit will be a significant decrease. 

ARB staff’s analysis supports the conclusion that the limit is technologically and 

commercially feasible. In the South Coast AQMD, it is expected that 

Waterproofing Membrane products could fall under Industrial Maintenance or 

Waterproofing Sealer, both of which have a VOC limit of 100 g/l. The SCM VOC 

limit is higher than the South Coast AQMD limit. However, manufacturers that 

provide coatings in the South Coast AQMD can still sell products that exceed the 

100 g/l limit, if they participate in the South Coast AQMD averaging program. 

ARB staff believes that additional research is needed to verify the performance of 

100 g/l Waterproofing Membranes in a way that protects the infrastructure 

throughout California. The South Coast AQMD area has a mild climate, so 

climatic conditions are less of a concern. However, in other areas of California, 

the infrastructure is exposed to more extreme climates (e.g., mountainous areas 

with freezing temperatures). ARB staff believes that additional research is 

needed to develop products that perform well in these areas. Therefore, ARB 

staff believes that the current 250 g/l VOC limit is most appropriate at this time. 

Wood Coatings 

Wood Coatings is a new category that was formerly covered by Clear Brushing 

Lacquers, Lacquers, Sanding Sealers, Varnishes, and other categories. In the 

first draft the VOC content limit for this coating was 100 g/l, during the workshop 

it was established that the 100 g/l VOC limit was a type-o. It was intended to be 

275 g/l. The correction has been made to the Table of Standards. Staff is 

currently recommending the originally intended VOC content limit of 275 g/l, in 

alignment with the SCM limit. 

ARB recommends a 275 g/l VOC limit for Wood Coatings, as the VOC limit is 

technologically and commercially feasible, based on the complying marketshare, 

the number of companies making complying products, product information from 

manufacturers, and test results. The SCM limit is consistent with the limit 

adopted by the South Coast AQMD. It is important to note that the vast majority 

of products reported in the survey with VOC limits below 275 g/l are waterborne. 

Few solventborne products meet the proposed VOC limit so they would either 

have to be reformulated, replaced by waterborne products, or use the small 

container exemption. 

Zinc-Rich Primer 

Zinc-Rich Primer is a new coating category that was formerly included in the 

Metallic Pigmented coating category. Zinc-Rich Primers are used to protect steel 

surfaces from corrosion. Regular coatings resist corrosion by forming a barrier 

between the metal and the atmosphere, but Zinc-Rich Primers provide corrosion 

protection via electrochemical reactions. A Zinc-Rich Primer is a coating that 
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28 Final Staff Report with Appendices For 

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contains at least 65 percent metallic zinc powder or zinc dust by weight of total 

solids, is formulated for application to metal substrates to provide a firm bond 

between the substrate and subsequent applications of coatings, and is intended 

for professional use only and is labeled as such. 

In the first draft the VOC content limit for this coating was 100 g/l, staff are 

currently recommending a VOC content limit of 340 g/l. The SJVAPCD will not 

re-instate the averaging provision that expired in 2005. Upon careful review of 

the SCAQMD rule requirements, and the SCM Staff Report (as presented in 

Table 3 of this Final Draft Staff Report), staff have come to the conclusion that it 

would be more appropriate to implement the SCM VOC limit for this coating 

category due to the absence of the averaging provision. The SCAQMD allows 

for a “ceiling limit” for this coating category due to the averaging provision. The 

“ceiling limit” provision offered by SCAQMD to operators allows the use of 

coatings with VOC limits of 420 g/l. 

ARB recommends a 340 g/l VOC limit for Zinc-Rich Primers because the VOC 

limit is technologically and commercially feasible, based on the complying 

marketshare, the number of companies making compliant products, and product 

information from manufacturers. The VOC limit is higher than the 100 g/l South 

Coast AQMD limit. However, manufacturers that provide coatings in the South 

Coast AQMD can still sell products that exceed the 100 g/l limit, if they participate 

in the averaging program. 

Since Zinc-Rich Primers are often applied to critical infrastructure, it is vital that 

they meet the performance specifications established by public agencies. Based 

on ARB discussions with Caltrans and others, ARB staff believes that additional 

research is needed to verify the performance of 100 g/l Zinc-Rich Primers in a 

way that protects the infrastructure throughout California. The South Coast 

AQMD area has a mild climate, so climatic conditions are less of a concern. 

Research is also needed to address potential safety issues associated with the 

production of hydrogen gas, caused by chemical reactions with zinc dust and 

water. Therefore, ARB staff believes that the proposed 340 g/l VOC limit is most 

appropriate at this time. 

Section 5.2 Most Restrictive VOC Limit 

For purposes of this rule, if a coating is marketed for more than one coating 

category, the most stringent VOC limit will apply. However, there are exceptions 

to the most restrictive requirement. This section would be modified to list the 

situations in which the most restrictive limit is not applicable. The modified list 

corresponds with the ARB SCM requirements. 
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Section 5.3 Sell – Through of Coatings 

The Sell-Through provisions for coatings in currently enforced rule language is 3 

years after the effective date of new VOC content limits for coatings. The first 

version of draft amendments to rule requirements recommended that the three 

year provision be amended to a twelve month provision. Upon conversations 

with ARB, EPA, and stakeholders, and research of sell through provisions in 

other districts, staff changed the provision back to a three year sell-through 

provision. Therefore, there would be no changes to this section of the rule from 

the current active version of the rule during this rule amending project. 

Section 5.6 Coatings Not Listed in the Table of Standards 

Coatings not listed in the Table of Standards would be modified to add Nonflat – 

High Gloss coatings as another category in addition to the Flat and Nonflat 

coatings categories already in place. 

Section 5.8 

To avoid imposing unintended and technologically infeasible VOC limits for the 

new coating categories, industry requested a temporary exemption from the 

general coating limits. District staff recommends that industry’s recommendation 

be implemented but that this consideration be accomplished through a special 

provision rather than an exemption. This section would be added to provide that 

language. 

Lacquers 

This section would be deleted, as there will be no lacquer specific category after 

the new requirements become effective on 1/1/011. The SCM, and therefore, 

this rule project would propose that all Clear Wood Coatings be combined under 

the new “Wood Coatings” category. 

Averaging Compliance Option 

This section would be deleted from rule language because it expired in 2005. 

ARB believes that many districts do not have sufficient resources to manage an 

averaging program, and it is difficult for small businesses to participate because 

they have fewer products. 

Section 6.0 – Administrative Requirements

Section 6.1 Labeling Requirements 

Labeling requirements would be updated to add new labeling standards 

consistent with new coatings categories per the SCM. 
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Per stakeholder comments and conversations with ARB the language for labeling 

of Industrial Maintenance Coatings has been amended back to the original 

standards. Also, the labeling requirement for Zinc Rich Primers has also been 

amended to include language matching the Industrial Maintenance coating 

labels, per stakeholder request and conversations with ARB. 

Section 6.2 Reporting Requirements 

A new section would be added to include reporting requirements per the SCM. 

The SCM contains a new requirement to submit sales data. Collection of this 

data is authorized in the California Health and Safety Code which requires 

submission of data to estimate emissions. This provision is intended to expedite 

the collection of survey data for architectural coatings. Under this provision, 

survey data must be provided within 180 days. Conversations with ARB 

confirmed that they do not want stakeholders to keep sales data for a minimum 

of five years, therefore the language has been changed to align with the 2007 

SCM. As such, sales data must be kept on site for three years. 

Section 6.3 Test Methods 

New sections would be added to coincide with new coating categories pursuant 

to the ARB SCM. 

Section 7.0 – Compliance Schedule 

This section would be updated to account for the new amendments to rule 

language by adding the phrase “the dates specified within the text of the rule”. 

Section 8.0 – Averaging Compliance Option 

This section would be deleted in its entirety. The 2000 SCM contained an 

averaging compliance option, which expired in 2005 and was administered by 

ARB staff. The averaging provision that was in Rule 4601 also expired in 2005. 

ARB deleted this provision in the SCM because they believe that many districts 

do not have sufficient resources to manage an averaging program, and that an 

averaging compliance option may inadvertently provide an unfair business 

advantage to large businesses. 

IV. EMISSION REDUCTION ANALYSIS 

According to the 2007 Ozone Plan, total VOC emissions from sources subject to 

Rule 4601 are estimated to be 9.7 tpd in 2012. The total VOC emission 

reductions associated with amendments to rule language is expected to be 2.8 

tpd by 2012. An emission reduction analysis has been prepared, based on the 

best available information at this time. Please see Appendix B for further details. 
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31 Final Staff Report with Appendices For 

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V. COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC section 40920.6(a), a cost effectiveness analysis is required 

for rules that implement BARCT. The purpose of the cost effectiveness analysis is 

to evaluate the economic reasonableness of the rule or rule amendments. The 

analysis also serves as a guideline for developing the control requirements of the 

rule. District staff conducted a cost effectiveness analysis of the proposed 

amendments based on reports from ARB in the SCM as well as the SCAQMD staff 

report. Please see Appendix C for further details. 

VI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, “whenever a district intends to propose the 

adoption, amendment, or repeal of a rule or regulation that will significantly affect 

air quality or emissions limitations, that agency shall, to the extent data are 

available; perform an assessment of the socioeconomic impacts of the adoption, 

amendment, or repeal of the rule or regulation.” 

As a part of the District’s socioeconomic analysis process, District staff convened 

a Focus Group. The Focus Group met on July 1, 2008 to assist in the 

development of the socioeconomic report for the draft rule. 

The Focus Group consisted of volunteers who assisted with the socioeconomic 

analysis by gathering and providing information about costs expected to be 

incurred to comply with the rule and hypothetical business responses to those 

costs. Operators and other interested parties were invited to submit their 

estimate of compliance costs and possible business responses to aid District 

staff in estimating the regulatory compliance costs and business impacts 

resulting from compliance with the rule. This information and supporting data 

was provided to an outside consultant who identified and analyzed the 

socioeconomic impacts of the proposed amendments to Rule 4601 on the 

regional economy. 

A preliminary socioeconomic analysis was conducted using the cost data from 

the March 3, 2009 version of the staff report which recommended the 

implementation of SCAQMD VOC limits for the twelve coating categories with 

lower VOC content limits than the SCM. The preliminary cost effectiveness 

analysis indicated that the SCAQMD coating limits would result in an increase in 

cost of $2.91 per gallon of coating. Staff found that the $2.91 per gallon cost 

increase could potentially have a significant impact on the regional economy of 

the San Joaquin Valley in that it the predicted results of the cost increase would 

be a 2.5% workforce reduction at coating manufacturing operations in addition to 

a cost increase to consumers. The consultant determined that for the 

socioeconomic impacts to be not significant the cost increase could not exceed 
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Final Staff Report: Rule 4601 (Architectural Coatings) December 17, 2009 

32 Final Staff Report with Appendices For 

 Amendments to Rule 4601

the average historic price change of 3% plus a 1.3% standard deviation factor. 

The preliminary socioeconomic information indicated that in addition to the 2.5% 

workforce reduction the cost increase would result in an increase to consumers 

of 5.9%, meaning the SCAQMD limits would have a significant socioeconomic 

impact on the SJVAB. Therefore, staff decided to recommend the VOC content 

limits of the SCM rather than the SCAQMD limits. Staff instructed the consultant 

to update the socioeconomic impact report only using cost data from the SCM 

VOC limits, thereby making it a more accurate and up-to-date document. Please 

see Appendix D for further details. 

VII. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA), staff investigated 

the possible environmental impacts of the revised proposed amendments to Rule 

4601. Based on the lack of evidence to the contrary, District staff has concluded 

that the revised proposed amendments to the rules will not have any significant 

adverse effects on the environment. Staff recommends filing a Notice of 

Exemption under the provisions of Public Resource Code 15061 (b) (3). 

Amendments to Rule 4601 are intended to reduce VOC content below than 

currently in use for certain coating categories and implement work practices that 

will reduce fugitive VOC emissions. In addition, District Staff has considered the 

potential impacts that paint reformulation might have on GHG emissions. Staff 

has determined that reformulation of paint and materials would not require use of 

solvents that would contribute to GHG emissions. Thus, District staff concludes 

that adoption of the revised proposed amendments to the rule would not result in 

increased GHG emissions and therefore, would have no impact on global 

climatic change. 

VIII. RULE CONSISTENCY ANALYSIS 

Pursuant to CH&SC 40272.2, District staff prepared a rule consistency analysis 

that compares the elements of amendments with the corresponding elements of 

other District rules, federal regulations and guidelines that apply to the same 

source category or type of equipment. District staff found that none of the 

revised proposed requirements of these rules would conflict with other District 

rules, or federal rules, regulations, or policies covering similar stationary sources. 

The rule consistency analysis is presented in Appendix E of the Final Draft Staff 

Report. 
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Final Staff Report: Rule 4601 (Architectural Coatings) December 17, 2009 

33 Final Staff Report with Appendices For 

 Amendments to Rule 4601

IX. REASONABLY AVAILABLE CONTROL TECHNIQUES (RACT)

ANALYSIS 

RACT Discussion 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans 

shall assure that RACT for volatile organic compounds (VOC) is applied at 

certain sources. District Rule 4601 is a VOC rule, therefore underwent a RACT 

analysis during this rule amending project. A RACT analysis requires an 

examination of a rule against Federal rules, regulations, and technology 

guidelines as well as comparing it against rules from other Districts in California. 

District Rule 4601 was compared to federal and state regulations and guidance. 

The following is a discussion of that analysis. 

District staff compared emission limits, optional control requirements, and work 

practice standards in District Rule 4601 to comparable requirements in rules from 

the other Air Districts in California nonattainment areas. Further discussion and 

comparisons of District Rule 4601 with rules in other Air Districts in California is 

presented in Section III “Discussion” of the Final Draft Staff Report. District staff 

has concluded based on the aforementioned analyses, that District Rule 4601 

satisfies RACT for architectural coating operations. 

A. Comparison with Federal Rules and Regulations 

EPA – Control Technique Guidelines (CTG) - There is no CTG for this source 

category. 

EPA – Alternative Control Technology (ACT) - There is no ACT for this source 

category. 

Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS for this source category. 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) - There is no NESHAP or 

MACT for this source category. 

B. Comparison with Other California Non-Attainment Areas

District staff compared emission limits, optional control requirements, and work 

practice standards in District Rule 4601 to comparable requirements in rules from 

the following California nonattainment areas: 

• South Coast AQMD Rule 1113 (Architectural Coatings) amended July 

2007 
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Final Staff Report: Rule 4601 (Architectural Coatings) December 17, 2009 

34 Final Staff Report with Appendices For 

 Amendments to Rule 4601

• Bay Area AQMD Regulation 8 Rule 3 (Architectural Coatings) amended 

November 2001 

• Sacramento Metro AQMD Rule 442 (Architectural Coatings) amended 

May 2001. 

• Ventura County APCD Rule 74.2 (Architectural Coatings) amended 

November 2001. 

SCAQMD Rule 1113 

SCAQMD has introduced new coatings limits that are more stringent than the 

state’s 2007 SCM. As a result, coatings that meet these new limits have been 

introduced in the South Coast area beginning in 2005. The new limits were 

phased-in over three years, with the final phase effective in July 2008. 

The SCAQMD architectural coating rule differs the architectural coating rules in 

all other air districts in California in that the SCAQMD allows the use of an 

averaging provision for architectural coatings. This enables the SCAQMD to 

require more stringent coatings limits for certain coatings categories with a ceiling 

limit on the VOC content at levels higher than those in the 2007 ARB SCM. 

ARB staff considered the feasibility of the SCAQMD Rule 1113 VOC limits as a 

part of the 2007 SCM development process. ARB staff determined that the 

SCAQMD limits would not be feasible for implementation for several coatings 

categories in other districts. Table 4 below is a comparison of the VOC content 

limits of SCAQMD Rule 1113 and the 2007 ARB SCM. 

Table 4. Comparison Between SCAQMD Rule 1113 and SCM 

Coating Category 

SCAQMD 

R1113 Ceiling 

VOC Limit (g/l) 

SCAQMD Rule 

1113 VOC 

Limit (g/l) 

ARB 2007 

SCM VOC 

Limit (g/l) 

Concrete-Curing Compounds 350 100 350 

Floor Coatings 420 50 100 

Industrial Maintenance Coatings 420 1002 250 

Zinc-Rich IM Primers 420 100 340 

Mastic Coatings 300 300 100 

Nonflat Coatings 250 50 100 

Nonflat High Gloss 250 50 150 

Quick-Dry Enamels 400 50 150 

Roof Coatings, Aluminum 500 100 400 

Rust Preventative Coatings 420 100 250 

Stains (Exterior) 350 100 250 

Traffic Coatings 250 100 100 

Waterproofing Sealers 400 100 100-400 

Waterproofing Concrete/Masonry Sealers 400 100 100-450 
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The following are the reasons cited by ARB in the Staff Report for the 2007 ARB 

SCM as to why the SCAQMD Rule 1113 (Architectural Coatings) VOC content 

limits are not feasible for other air districts in California. The following language 

is further discussed in Section II.B of this Final Draft Staff Report. 

• The SCM coating limits need to be suitable for a variety of climates found 

throughout California. As SCAQMD staff has said in public meetings, some 

of the VOC limits in their rule, specifically for Nonflat and Nonflat-high gloss 

coatings are not intended for areas outside the SCAQMD. There are 

concerns with freeze/thaw stability and dirt pick up due to removal of VOCs to 

meet the lower limits. This concern also applies in varying degrees to the 

other categories mentioned above. 

• The SCM does not contain an averaging provision. In the SCAQMD, coating 

manufacturers can sell products that exceed the VOC limits, if they 

demonstrate that the excess emissions are offset by emissions from sales of 

over-complying products. 

• The SCM does not contain an exemption for tertiary butyl acetate (TBAc) due 

to concerns about the toxicity of TBAc. SCAQMD Rule 1113 contains a TBAc 

exemption for Industrial Maintenance Coatings only. Under this exemption 

manufacturers do not have to include TBAc when calculating the VOC 

content of industrial maintenance coatings. 

o The SJVAPCD also has an exemption for TBAc; therefore 

manufacturers in the SJVAB will also not have to include TBAc when 

calculating the VOC content of industrial maintenance coatings. 

• The SCM does not contain a small business exemption. Rule 1113 allows 

small businesses in certain categories to be exempt from VOC limits or to 

have additional time to comply with VOC limits. 

• The SCM does not contain an exemption for high elevations. Under Rule 

1113, stains and lacquers do not have to comply with the rule’s VOC limits if 

they are used at an elevation of 4,000 feet or greater above sea level. 

• The proposed SCM needs to be enforceable by small districts with limited 

resources. Accordingly, the proposed SCM does not contain an averaging 

provision, which requires resources for recordkeeping and auditing. 
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Final Staff Report: Rule 4601 (Architectural Coatings) December 17, 2009 

36 Final Staff Report with Appendices For 

 Amendments to Rule 4601

BAAQMD Regulation 8 Rule 3 

BAAQMD adopted amendments to Regulation 8 Rule 3 on July 2009 to 

incorporate the 2007 ARB SCM requirements. This rule amending project is also 

proposing the adoption of the 2007 ARB SCM requirements. Therefore, this rule 

would be as stringent as the BAAQMD Regulation 8 Rule 3 (Architectural 

Coatings). 

Sacramento Metropolitan AQMD Rule 442 and Ventura County APCD Rule 74.2 

These air districts adopted the ARB 2000 SCM for architectural coatings. District 

staff used the 2000 ARB SCM as a template for the October 2001 amendments 

and, therefore, was at the same level of stringency as these air district rules. 

However, the current proposed amendments are based on the ARB 2007 SCM 

limits and are therefore more stringent than these air districts. 

C. Conclusion 

After careful evaluation of prohibitory rules in other California nonattainment 

areas, District staff concludes that District Rule 4601 satisfies RACT for 

architectural coatings. 

X. REFERENCES 

1. Air Resources Board (ARB). “2007 Suggested Control Measure for 

Architectural Coatings”. February 1, 2008. 

2. ARB. “Installation, Operation and Maintenance Manual For Standing Loss 

Control Vapor Recovery System for Existing Installations of Aboveground 

Storage Tanks As Certified by Executive Order VR-301-A”. April 2009. 

http://arb.ca.gov/vapor/ast/eo301a_IOM.pdf

3. ARB. “Staff Report for Proposed Amendments to the Suggested Control 

Measure for Architectural Coatings”. September 2007. 

4. ARB. “Resolution 07-46 approving the 2007 SCM”. October 26, 2007 

5. ARB. “Technical Support Document for Proposed Amendments to the 

Suggested Control Measure for Architectural Coatings. 

http://www.arb.ca.gov/coatings/arch/Approved_2007_SCM.pdf 

6. Bay Area AQMD. “Regulation 8 - Organic Compounds. Rule 3 - Architectural 

coatings”. November 21, 2001. 

7. San Joaquin Valley APCD. “2007 Ozone Plan”. April 30, 2007. 

8. South Coast AQMD. “Rule 1113. Architectural Coatings”. July 13, 2007.