Agenda Date: June 19, 2008 

Agenda Placement: Regular 

Estimated Time: 15 Minutes 

Continued Item: No 

 Board Agenda Item

TO: Air Pollution Control District Board 

FROM: Terry E. Dressler, Air Pollution Control Officer 

CONTACT: Rebecca Armstrong, 961-8888 

SUBJECT: Proposed Amended Rule 339, Motor Vehicle and Mobile Equipment 

Coating Operations 

 

RECOMMENDATION: 

That the Board: 

A. Hold a public hearing to receive testimony on proposed amended Rule 339. 

B. Approve the Resolution attached to this Board Letter. Approval of the resolution will 

result in the following actions: 

1. CEQA Findings: Adopt the CEQA findings (Attachment 1) pursuant to the 

California Environmental Quality Act (CEQA) and the CEQA guidelines. 

2. Rule Findings: Adopt the associated rule findings (Attachment 2) in support of the 

proposed amended Rule 339 pursuant to Health and Safety Code Section 40727 

regarding necessity, authority, clarity, consistency, nonduplication, and reference. 

The rule findings also acknowledge public comments received on the proposed rules 

(Attachment 3) and adopt the Response to Comments (Attachment 4) as findings of 

the Board. 

3. Amended Rule Adoption: Adopt proposed amended Rule 339 (Attachment 5). 

EXECUTIVE SUMMARY: 

The 2007 Clean Air Plan includes a commitment for the Santa Barbara County Air 

Pollution Control District (APCD) to adopt an Air Resources Board Suggested Control 

Measure (SCM) to control volatile organic compound (VOC) emissions from coatings 

and solvents associated with the coating of motor vehicles, mobile equipment, and 

associated parts and components. Proposed amended APCD Rule 339 will fulfill this 

SCM requirement and the APCD’s 2007 Clean Air Plan commitment. This rule will 
2 

apply to auto body and mobile equipment coating shops. Specifically, this rule is 

applicable to any person who supplies, sells, offers for sale, manufactures, or distributes 

any automotive coating or associated solvent for use within Santa Barbara County, as 

well as any person who uses, applies, or solicits the use or application of any automotive 

coating or associated solvent within the County. 

Existing Rule 339 limits the amount of VOC in motor vehicle and mobile equipment 

coatings. The revised rule will reduce the amount of allowable VOC in the coatings and 

also control solvents used in association with the spray painting. The proposed amended 

Rule 339 replaces the existing Rule 339 with the SCM limits and retains some existing 

Rule 339 provisions. 

Staff conducted two workshops (Sept. 19 and 20, 2007) and discussed this state-required 

rule revision at several autobody shop association meetings. The regulated community is 

prepared to comply with the SCM requirements with the exception of the provision that 

all solvents be limited to 25 grams per liter of VOC content. According to the autobody 

shop owners, there are certain situations that require higher VOC-content material to 

assure a quality paint finish. Staff, with the concurrence of industry, addressed this issue 

by adding a limited 20 gallon annual usage exemption for high-VOC solvents used 

during presanding preparation. 

DISCUSSION: 

Objectives 

Existing Rule 339 limits the amount of volatile organic compounds (VOC) in motor 

vehicle and mobile equipment coatings. The revised rule will reduce the amount of 

allowable VOC in the coatings and also control solvents used in association with the 

spray painting. Rule modifications are needed to implement the state ARB Suggested 

Control Measure (SCM) for the application of automotive coatings and to fulfill the 

APCD’s “all feasible measure” requirement of the 2007 Clean Air Plan. The proposed 

amended Rule 339 replaces the existing Rule 339 with the state SCM and retains several 

existing Rule 339 provisions (as explained further below). 

Background 

The 2007 Clean Air Plan calls for the adoption of revised Rule 339 for controlling 

volatile organic compound (VOC) emissions from autobody coating operations. In order 

to claim these emission reductions in the State Implementation Plan, the Air Resources 

Board and the U.S. Environmental Protection Agency require the APCD to adopt the 

control measure in a rule. 

The primary objective of the rule is to reduce volatile organic compound emissions from 

Motor Vehicle and Mobile Equipment Coating Operations. Staff conducted two 

workshops (Sept. 19 and 20, 2007) and discussed this pending rule revision at several 

autobody shop association meetings. The regulated community is prepared to comply 

with the SCM requirements with the exception of one provision: all solvent shall be 

limited to 25 grams of VOC per liter. According to the autobody shop owners, there are 
3 

certain situations that require higher VOC-content material to assure a quality paint 

finish. After discussing this issue with shop owners and supply distributors, staff and the 

regulated community agree that this concern should be addressed by adding a limited 20 

gallon annual usage exemption for high-VOC solvents used during presanding 

preparation. 

Other deviations from the SCM include maintaining the requirement that all painting be 

done in a booth. Consequently, we are also maintaining exemptions associated with this 

requirement in Section B.5 and B.6. The existing rule also provides relief for painting 

conducted by the vehicle’s registered owner. Thus the exemption as indicated in Section 

B.7 of the proposed amended rule has been retained. 

When staff brings a proposed amended rule to your Board, the changes are normally 

shown in strikeout and underline format. However, since all of existing Rule 339 is 

essentially being replaced with the SCM, this proposed amended rule is shown in regular 

text. The attached draft proposed amended Rule 339 in Attachment 5 is the state SCM 

with a few provisions of the existing Rule 339 kept in place (as referenced above). Most 

of the deviations are administrative (e.g., definitions) that arise from the addition of the 

aforementioned exemptions and/or are necessary for rule clarity.

 

The proposed Rule 339 is similar to the South Coast AQMD Rule 1151 and Ventura 

County’s proposed amended Rule 74.18 with the exception of the 20 gallon annual 

solvent pre-sanding preparation exemption. 

Rule 339 Requirements 

Rule 339 requires all motor vehicle and mobile equipment coating facilities to use waterborne coatings and to reduce the large majority of their cleaning solvents to a 25 gram per 

liter VOC limit. See the table in Section D.1 of Rule 339 (Attachment 5) for the new 

specific coating limits. 

Rule 339 Permitting Requirements 

 

No new or modified permits are required as a result of this rule revision for affected 

facilities (i.e., autobody shops) that are currently permitted. The minor modifications and 

improvements that are made to autobody shops will be noted during the time of the 

facility triennial permit reevaluation.

Rule 339 Source Testing, Record Keeping, and Reporting Requirements 

 

The Source Testing requirements and Test Methods are those that are required of the 

SCM. 

Recordkeeping requirements (monthly) are the same as currently required of the existing 

Rule 339. 
4 

Reporting requirements are the same as the existing Rule 339 requirements. Reporting 

includes submission of required records by March 1st for the prior calendar year and 

submission of source test reports within 45 days of test completion. 

Unless otherwise specified, the provisions of this rule as adopted on June 19, 2008 

become effective January 1, 2009. In addition, during the interim period between June

19, 2008 and January 1, 2009, the provisions in Rule 339 as adopted on April 17, 1997 

remain in effect. 

Implications to Sources 

Affected Sources

The adoption of amendments to Rule 339 will directly affect the sources that coat motor 

vehicles and mobile equipment in Santa Barbara County. There are approximately 70 

auto body coating shops currently permitted by the APCD in the county. 

A significant effort was expended toward public outreach to inform affected sources 

regarding the new upcoming SCM coating and solvent cleaning requirements. Staff has 

been speaking to the autobody coating industry about this upcoming SCM for 

approximately two years. All permitted sources and interested parties have been 

contacted via mail since the commencement of this rule revision process. Additionally, 

two publicly noticed workshops, one in Santa Barbara and one in Santa Maria, were held 

on September 19 and 20, 2007. 

Staff have worked closely with industry to keep them aware of the schedule for this rule 

revision process and have worked to accommodate their requests when possible. The 

majority of the autobody shops in the county either have completed or are in the process 

of working with the manufacturers jobbers to train their staff on the application of waterborne coatings. 

Exempt Sources

The exemptions that are in the existing Rule 339 were maintained for the revised (SCM) 

version of the rule. One additional exemption was added as part of this SCM rule 

revisions process to allow a higher VOC-content preparation solvent material for removal 

of road tar, wax, and grease, to assure a quality paint finish. Over half of the auto body 

shop owners in the county signed a petition requesting this exemption. Thus, we have 

addressed this issue by adding a limited usage exemption of high-VOC solvent in Section 

B.8 (see Attachment 5). This provision limits usage to no more than 20 gallons per year 

with recordkeeping to demonstrate compliance with this limit. 

Implications to APCD Budget 

The cost of implementing proposed amended Rule 339 is expected to be primarily for 

compliance and permitting staff activities. The routine cost for permitting reevaluations 

will remain as is for this industry. Permit reevaluations are performed triennially by the 

APCD permitting staff. The compliance staff’s inspection schedule will also remain as is 
5 

for this industry. The standard APCD application and reevaluation fees in Rule 210 will 

pay for these activities.

Comparison to Existing Federal, State and Local Requirements 

Pursuant to the H&SC §40727.2, the APCD is required to identify all existing federal, 

state, and local air pollution control requirements that apply to the same equipment or 

source category as the rule proposed for adoption or modification by the APCD. These 

other air pollution control requirements include federal New Source Performance 

Standards (NSPS), federal National Emissions Standards for Hazardous Air Pollutants 

(NESHAPs), Best Available Control Technology (BACT) and any other District rule 

applying to the same equipment. 

 On September 11, 1998, the Environmental Protection Agency (EPA) promulgated 

national volatile organic compound (VOC) standards for automotive refinish coatings 

pursuant to Section 183(e) of the Clean Air Act. On Page 48808 of the Federal Register 

(9/11/98, Volume 63, Number 176), EPA states that although regulated entities in all 

states will be required to comply with the national standards, some states may wish to 

promulgate VOC standards more stringent than the national rule to assist in achieving 

attainment with the federal ambient air quality standards for ozone. VOC emission are 

precursors to the formation of ozone. The proposed standards adopted by ARB in their 

SCM are more stringent than the national rule. 

The APCD is aware of recently adopted federal NESHAPs that applies to and regulates 

autobody shops and their methods of operation. On January 9, 2008, EPA adopted a 

NESHAPs for Paint Stripping and Automotive Refinishing. These regulations only apply 

if the shops use paint strippers containing methylene chloride or if the coatings applied 

contain any one of the following target Hazardous Air Pollutants: chromium, lead, 

manganese, nickel or cadmium. 

Health and Safety Code Section 40727.2 (a) requires the proposed amendments to Rule 

339 to be compared with Best Available Control Technology (BACT). The 2005 SCM 

developed by the Air Resources Board has new requirements that are considered to be 

BACT. This rule development is based directly on and contains all the requirements of 

the SCM. 

Emission Reductions 

To reduce the formation of volatile organic compounds, industry will be using lowerVOC coatings and lower-VOC solvents for cleaning operations. Upon adoption of 

revised Rule 339, VOC emissions will be reduced by approximately 0.1404 tons per day 

or approximately 51 tons per year overall. Over 90 percent of the VOC emission 

reductions result from the switch from solvent to waterborne coatings for the color or 

base coat applied at almost all auto body shops. The emission reductions projected to 

occur through implementation of proposed Rule 339 are consistent with the reductions 

assumed in the 2007 Clean Air Plan. 
6 

The worst-case amount of solvent emissions that are estimated to be emitted from the 

limited use of the 20 gallon annual high VOC solvent exemption are: 

(70 shops) x (20 gals/shop per year) = 1400 gals/year total in the county 

(1400 gals/yr) x (1 yr/365 days) = 3.84 gals/day total in the county 

(3.84 Gals/day x 6.8 lbs/gal VOC content) = 26.08 lbs/day (or 0.0130 tons/day and 4.75 

tons/year) VOC total in the county 

Based on discussions with suppliers, 20 gallons per year represents the presanding 

solvent use by the largest volume shop in the county. This assumed 20 gals per year 

usage for all shops is conservative. 

Rulemaking Process and Schedule 

The rulemaking schedule for this amended rule included two public workshops that were 

held September 19 and 20, 2007 in Santa Barbara and Santa Maria, respectively. Staff 

took the draft rule to the Community Advisory Committee (CAC) on March 12, 2008 and 

on April 23, 2008. At the April 23, 2008 meeting, after discussing and clarifying the 

revisions that were proposed at the March 12th meeting, the CAC recommended that the 

Board adopt Rule 339 as presented by the APCD staff . The motion passed with a vote of 

11:2:0. 

Public Review: Public Comments Submitted to Date 

Attachments 3 and 4 contain public comments received at the public workshops held in 

September 2007 and written comments received to date for this proposed amended rule. 

The majority of the questions and comments that APCD staff received were based on 

permitting, compliance schedule, and rule requirements. 

Public comments are being accepted up until this Board Hearing. 

Cost-Effectiveness 

According to the 2005 ARB staff report for the Suggested Control Measure, the overall 

estimated cost-effectiveness is $ 1.43 per pound of VOC reduced. This compares 

favorably to new sources that are subject to BACT controls up to $9 per pound of VOC 

reduced. ARB performed an analysis of economic impacts on the implementation of the 

SCM. This analysis may be found in Chapter VII of the Staff Report for the Proposed 

SCM for Automotive Coatings dated October 2005. 

The major cost of complying with the proposed rule amendments to the 70 permitted auto 

body coating facilities in the county centers around the conversion to the waterborne 

color coat. These coatings are typically used at auto body shops to repair damaged 

vehicles. The cost of this conversion for a one spray booth operation was estimated by 

CARB to be approximately $ 6,600 per facility. This includes costs for additional air 

movement equipment or fans to decrease dry times, new or modified spray equipment, 
7 

new spray gun washers, and cost of painter training to understand how to spray the new 

coatings. 

Health and Safety Code Section 40920.6(a) requires district to identify one or more 

potential control options, assess the cost-effectiveness of those options, and calculate the 

incremental cost-effectiveness. Health and Safety Code Section 40920.6 also requires an 

assessment of the incremental cost-effectiveness for proposed regulations relative to 

ozone, carbon monoxide (CO), sulfur oxides (SOx), nitrogen oxides (NOx), and their 

precursors. 

Incremental cost effectiveness is defined as the difference in control costs divided by the 

difference in emission reductions between two potential control options achieving the 

same emission reduction goal of a resolution. The proposed amendments require the 

most stringent viable VOC limits with no other viable control option that can achieve the 

same amount of emission reductions. Therefore, the incremental cost-effectiveness 

analysis does not apply to this rulemaking. 

California Environmental Quality Act (CEQA) 

Pursuant to Section 15168 (c) of the State California Environmental Quality Act (CEQA) 

Guidelines, the proposed rule revisions to Rule 339 were examined in the light of the 

program EIR for the 1991 Air Quality Attainment Plan and subsequent environmental 

documents, including the 2007 Clean Air Plan Supplemental EIR. The APCD 

determined that a CEQA Addendum to existing environmental documents must be 

prepared. CEQA Findings to be adopted by the APCD Board are provided in Attachment 

1. Any subsequent changes in the project description during the public review period 

will undergo additional environmental review under the CEQA. 

FISCAL IMPACT: 

The cost of implementing proposed amended Rule 339 is expected to be primarily for 

compliance and permitting staff activities. The standard APCD application and 

reevaluation fees in Rule 210 will pay for these activities. 

SPECIAL INSTRUCTIONS: 

Please send a certified minute order and signed resolution to Rebecca Armstrong, APCD, for 

transmittal to the Air Resources Board. 

CONCURRENCES:

County Counsel. 
8 

ATTACHMENTS: 

 Resolution 

 Attachment 1: CEQA Findings 

 Attachment 2: Rule Findings 

 Attachment 3: Public Comments 

 Attachment 4: Response to Public Comments 

 Attachment 5: Proposed Amended Rule 339 
BOARD RESOLUTION 

PROPOSED AMENDED RULE 339 

MOTOR VEHICLES AND 

MOBILE EQUIPMENT COATING OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District

260 North San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800 

 

Formatted: Font color: Auto
Santa Barbara County APCD 

Resolution – Revisions to Rule 339 -1- June 19, 2008 

RESOLUTION OF THE AIR POLLUTION 

CONTROL DISTRICT BOARD OF THE COUNTY OF 

 SANTA BARBARA, STATE OF CALIFORNIA 

In the Matter of ) APCD Resolution No. 

 ) 

Adopting Amendments to Rule 339 ) 

_________________________________)

RECITALS

1. The Air Pollution Control District Board of the County of Santa Barbara 

(“Board”) is authorized to adopt, amend, or repeal rules and regulations pursuant to Health and 

Safety Code section 40725 et seq. 

 2. Pursuant to Health and Safety Code section 40001, the Board is required to 

adopt and enforce rules and regulations to achieve and maintain the state and federal ambient air 

quality standards. 

 3. The Board has determined that a need exists to amend Rule 339 (Motor 

Vehicle and Mobile Equipment Coating Operations) for the purpose of implementing the 2007 

Clean Air Plan control measure R-SC-4 for controlling volatile organic compound emissions. 

NOW, THEREFORE, IT IS HEREBY RESOLVED THAT: 

1) This Board has held a hearing and accepted public comments in accordance with 

the requirements of Health and Safety Code section 40725 et seq. 

2) The California Environmental Quality Act (“CEQA”) findings set forth in 

Attachment 1 of the Board Package dated June 19, 2008 (herein after “Board Package”) are 

hereby adopted as findings of this Board pursuant to CEQA and the CEQA guidelines. 

 3) The general rule findings set forth in Attachment 2 of the Board Package are 

hereby adopted as findings of this Board pursuant to Health and Safety Code section 40727. 
Santa Barbara County APCD 

Resolution – Revisions to Rule 339 -1- June 19, 2008 

 4) The Responses to Public Comments set forth in Attachment 4 of the Board 

Package are hereby adopted as findings of this Board. 

 5) Rule 339 as set forth in Attachment 5 of the Board Package is hereby adopted as a 

rule of the Santa Barbara County Air Pollution Control District pursuant to Health and Safety 

Code section 40725 et seq. 

 6) The Board authorizes the Control Officer to transmit Rule 339 to the State Air 

Resources Board in compliance with applicable state and federal law. Additionally, the Board 

authorizes the Control Officer to do any other acts necessary and proper to obtain necessary 

approvals of the new rule by the California Air Resources Board and the United States 

Environmental Protection Agency. 

 PASSED AND ADOPTED by the Air Pollution Control District Board of the 

County of Santa Barbara, State of California, this 19th day of June, 2008, by the following vote: 

 AYES: 

 NOES: 

 ABSTAIN: 

 ABSENT: 

ATTEST: 

TERRENCE E. DRESSLER _______________________________ 

CLERK OF THE BOARD, Chair, Air Pollution Control 

 District Board of the County of 

By____________________________ Santa Barbara 

 Deputy 

 APPROVED AS TO FORM: 

 DANIEL J. WALLACE 

 SANTA BARBARA COUNTY COUNSEL 

 By____________________________ 

 Deputy 

 Attorneys for the Santa Barbara 

 Air Pollution Control District
ATTACHMENT 1 

CEQA FINDINGS 

PROPOSED AMENDED RULE 339 

MOTOR VEHICLES AND 

MOBILE EQUIPMENT COATING OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District 

260 North San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800 

Formatted: Font color: Auto
Santa Barbara County APCD 1-1 June 19, 2008 

CEQA Findings – Rule 339 

ATTACHMENT 1 

CEQA FINDINGS 

The Board finds that: 

• The potential environmental impacts of this rule were found to be adequately described 

and analyzed in the 1991 AQAP EIR, the 2007 CAP SEIR based on the Addendum 

prepared for this project. 

 

• The adoption and implementation of Rule 339 will not have significant adverse impacts 

on the environment. 

• No relaxation in meeting ambient air quality standards for ozone will result. No crossmedia impacts were identified. 

• Pursuant to § 15162 of the State CEQA Guidelines, no new effects will occur and no new 

mitigation measures are required beyond those considered in the 1991 AQAP EIR and 

the 2007 CAP SEIR. 

• The 1991 AQAP EIR and the 2007 CAP SEIR were previously determined by this Board 

to have been completed in compliance with CEQA and were reviewed and considered by 

the Board prior to approving the 2007 CAP. 

• Pursuant to § 15168 (e) of the State CEQA Guidelines, a specific notice was included in 

the 30-day public notice issued prior to rule adoption with the required statements. 
ATTACHMENT 2 

RULE FINDINGS 

PROPOSED AMENDED RULE 339 

MOTOR VEHICLES AND 

MOBILE EQUIPMENT COATING OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District 

260 San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800 

. 

Formatted: Font color: Auto
Santa Barbara County APCD 2-1 June 19, 2008 

Rule Findings – Rule 339 

ATTACHMENT 2 

 RULE FINDINGS FOR PROPOSED RULE 339 

Pursuant to California Health and Safety Code Section 40727, the Board makes the following 

findings for the adoption of Proposed New Rule 361, Motor Vehicle and Mobile Equipment 

Coating Operations. 

Necessity

The Board determines that it is necessary to adopt amended Rule 339 to fulfill the commitment 

in the 2007 Clean Air Plan to implement control measures R-SC-4 for controlling volatile 

organic compound emissions from the motor vehicle and mobile equipment coating operations. 

Authority

The Board is authorized under state law to adopt, amend, or repeal rules and regulations pursuant 

to Health and Safety Code Section 40000, and 40725 through 40728 which assigns to local and 

regional authorities the primary responsibility for the control of air pollution from all sources 

other than exhaust emissions from motor vehicles. Additionally, pursuant to Health and Safety 

Code Section 40702, the District Board is required to adopt rules and regulations and to do such 

acts as are necessary and proper to execute the powers and duties granted to it and imposed upon 

it by State law. 

Clarity

The Board finds that proposed amended Rule 339 are sufficiently clear. The rules were publicly 

noticed, and reviewed by the Community Advisory Council. The rules are written or displayed 

so that persons directly affected by them can easily understand their meaning. 

Consistency

The Board determines that proposed amended Rule 339 is consistent with, and not in conflict 

with or contradictory to, existing federal or state statutes, court decisions, or regulations with 

regard to the control of volatile organic compound emissions from motor vehicle and mobile 

equipment coating operations. 

The neighboring air pollution control district South Coast Air Quality Management District has 

adopted a similar rule. Based on this evidence, the Board finds that the rules are consistent with 

neighboring air pollution control districts. 
Santa Barbara County APCD 2-2 June 19, 2008 

Rule Findings – Rule 339 

Nonduplication

The Board finds that proposed amended Rule 339 (Motor Vehicle and Mobile Equipment 

Coating Operations) does not impose the same restrictions as any existing state or federal 

regulation, and the proposed rule is necessary and proper to execute the powers and duties 

granted to, and imposed upon, the APCD. 

Reference

The Board finds that we have authority under state law to adopt Rule 339 to pursuant to Health 

and Safety Code Section 39002 which assigns to local and regional authorities the primary 

responsibility for the control of air pollution from all sources other than exhaust emissions from 

motor vehicles. Additionally, pursuant to Health and Safety Code Section 40702, the Board is 

required to adopt rules and regulations and to do such acts as are necessary and proper to execute 

the powers and duties granted to it and imposed upon it by State law. 

 Public Comment

Response to Comments

The Board has reviewed the response to comments included in Attachment 4 and hereby 

approves those responses to comments as findings.
Santa Barbara County APCD 2-1 June 19, 2008 

Rule Findings – Rule 339 
. 

ATTACHMENT 3 

PUBLIC COMMENTS ON 

PROPOSED AMENDED RULE 339, 

MOTOR VEHICLE AND 

MOBILE EQUIPMENT COATING OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District 

260 San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800

Formatted: Font color: Auto
Santa Barbara County APCD 

Public Comments – Rule 339 3 - 1 June 19, 2008 

PUBLIC COMMENTS 

PROPOSED AMENDED RULE 339, 

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING 

OPERATIONS 

As of June 4, 2008, the District has received the attached public comments on this proposed 

amended rule. 
ATTACHMENT 4 

APCD RESPONSE TO 

PUBLIC COMMENTS ON 

PROPOSED AMENDED RULE 339, 

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING 

OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District 

260 San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800 

Formatted: Font color: Auto
Santa Barbara County APCD 

Response to Comments – Rule 339 4 - 1 June 19, 2008 

APCD RESPONSE TO PUBLIC COMMENTS 

PROPOSED AMENDED RULE 339, 

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING 

OPERATIONS 

As of June 4, 2008, the District has received and responded to (see attachments) the public comments on 

this proposed amended rule.

Formatted: Font: Not Italic

Formatted: Font: Not Italic
ATTACHMENT 5 

PROPOSED AMENDED RULE 339 

MOTOR VEHICLE AND MOBILE EQUIPMENT 

COATING OPERATIONS 

June 19, 2008 

Santa Barbara County Air Pollution Control District 

260 San Antonio Road, Suite A 

Santa Barbara, California 93110 

(805) 961-8800 

Formatted: Font color: Auto
Santa Barbara County APCD Rule 339 339 - 1 June 19, 2008

RULE 339. MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS. 

(Adopted 11/5/1991, Revised 5/17/1994, 12/15/1994, 4/17/1997, and [date of revised rule adoption])

A. Applicability and Purpose

 This rule is applicable to any person who supplies, sells, offers for sale, manufactures, or 

distributes any automotive coating or associated solvent for use within the District, as well as any 

person who uses, applies, or solicits the use or application of any automotive coating or 

associated solvent within the District. 

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

and solvents associated with the coating of motor vehicles, mobile equipment, and associated 

parts and components. 

B. Exemptions 

 Except as otherwise specified below, the requirements of this rule shall not apply to: 

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

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

reformulation or repackaging. 

 

 2. Any aerosol coating product. 

3 Any automotive coating that is sold, supplied, or offered for sale in 0.5 fluid ounce or 

smaller containers intended to be used by the general public to repair tiny surface 

imperfections. 

4. Any coating applied to motor vehicles or mobile equipment, or their associated parts and 

components, during manufacture on an assembly line. 

5. With prior written approval of the Control Officer, the provisions of D.9 shall not apply 

where coatings are applied to a vehicle(s) which, due to shape or size, cannot reasonably 

be contained in a spray booth. Any person seeking an exemption from D.9 shall comply 

with the following: 

 

a. Submit a written request to the Control Officer identifying the vehicle(s) to be 

coated, the size of the spray booth, the physical size of the vehicle(s) (i.e. length, 

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

vehicle(s), estimated volume of coating used, the date in which the vehicle or 

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

and 

b. The request shall be submitted in hardcopy writing to the District Santa Barbara 

Office, marked “ATTENTION – REQUEST FOR CONTROL OFFICER 

EXEMPTION DETERMINATION”. The Control Officer will provide a 

written determination to the requester within five (5) business days upon receipt 

of the exemption request. If the Control Officer does not act (i.e., grant or deny) 

on any properly submitted request within five business days of receiving the 

request, the exemption is automatically granted. 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 2 June 19, 2008

c. Notwithstanding B.5.b, no person shall be exempt from D.9 unless a written 

approval of exemption is obtained from the Control Officer. The Control 

Officer may grant written approval for a specified time period, not to exceed 

one year. 

 6. The provisions of Section D.9 shall not apply to the following: 

a. a motor vehicle engine compartment and mating assemblies of engine and 

suspension components where such components are replaced in the engine 

compartment. 

b. the application of any undercoat which contains no lead or chromium 

compounds and is limited to one major panel per vehicle, or equivalent area, not 

to exceed an aggregate of 16 square feet per vehicle. 

 7. The provisions of Sections D.2 through D.9 and Sections E and F shall not apply to the 

following: 

a. painting of no more than one vehicle per year, by the registered owner of the 

vehicle being painted, provided that the surface coating being used does not 

contain lead or chromium compounds; 

b. the application of touch-up coatings; 

c. lettering and striping applied using hand application methods. 

8. The provisions of Section D.8.a shall not apply to any person using a solvent to remove 

dust, grease, wax and other contaminants from a surface prior to sanding, provided that 

person meets the following requirements : 

a. the solvent is applied exclusively by use of non-aerosol, hand-held spray bottles. 

b. the total volume of the solvent does not exceed 20 gallons per year per 

automotive refinishing facility. 

c. the VOC content of the solvent does not exceed 780 grams per liter. 

d. records are maintained on a monthly basis of the running annual total of the 

solvent used to demonstrate compliance with this exemption; and

e. solvent records are kept in compliance with the requirements in Sections F.3, 

F.4, and F.7 of this rule. 

C. Definitions:

See Rule 102 for definitions not limited to this rule. For the purpose of this rule, the following 

definitions apply. 

 1. “Adhesion Promoter” means a coating, which is labeled and formulated to be applied 

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

subsequent coating is applied. 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 3 June 19, 2008

2. “Aerosol Coating Product” means a pressurized coating product containing pigments 

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

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

ground traffic/marking applications. 

3. “Assembly Line” means an arrangement of industrial equipment and workers in which 

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

automatic or manual means. 

4. “Associated Parts and Components” means structures, devices, pieces, modules, 

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

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

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

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

and components” does not include circuit boards. 

5. “Automotive Coating” means any coating or coating component used or recommended 

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

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

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

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

equipment refinishing. 

6. “Automotive Coating Component” means any portion of a coating, including, but not 

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

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

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

components are not considered automotive coating components. 

7. “Automotive Refinishing Facility” means any shop, business, location, or parcel of 

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

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

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

the motor vehicle or mobile equipment is completely assembled. 

8. “CARB” means the California Air Resources Board. 

9. “Cleaning Operations” means the removal of loosely held uncured adhesives, inks, 

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

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

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

10. “Clear Coating” means any coating that contains no pigments and is labeled and 

formulated for application over a color coating or clear coating. 

11. “Coating” means a material which is applied to a surface and forms a film in order to 

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

12. “Color Coating” means any pigmented coating, excluding adhesion promoters, 

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

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

metallic/iridescent color coatings. Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 4 June 19, 2008

13. “Electrostatic Spray Application” means any method of spray application of coatings 

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

particles. 

14. “Emission Control System” means any combination of capture systems and control 

devices used to reduce VOC emissions from automotive coating operations. 

15. “Exempt Compounds” means, for the purposes of this rule, the compounds listed in 

Sections C.42.a and C.42.b. 

 

16. “Graphic Arts Operation” means the application of logos, letters, numbers, or 

graphics to a painted surface by brush, roller, or airbrush. 

17. “Hand Application Methods” means the application of coatings by one of the 

following methods: air brush, paint brushes, hand rollers, caulking guns, trowels, 

spatulas, syringe daubers, rags, and sponges. 

18. “High-Volume, Low-Pressure (HVLP)” means spray equipment permanently labeled 

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

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

and at the air horns. 

 19. “Lacquer” means a clear or pigmented coating formulated with nitrocellulose or 

synthetic resin to dry by evaporation without a chemical reaction and to provide a quickdrying, solid protective film. 

20. “Metallic/Iridescent Color Coating” means any coating that contains more than 0.042 

pounds per gallon (5 grams per liter) of metal or iridescent particles as applied, where 

such particles are visible in the dried film. 

21. “Mobile Equipment” means any device that may be drawn and/or driven on rails or a 

roadway including, but not limited to, trains, railcars, truck trailers, mobile cranes, 

bulldozers, street cleaners, and implements of husbandry or agriculture. 

22. “Motor Vehicle” means any self-propelled vehicle, including, but not limited to, cars, 

trucks, buses, golf carts, vans, motorcycles, tanks, and armored personnel carriers. 

23. “Multi-Color Coating” means any coating that exhibits more than one color in the 

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

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

24. “Person” shall have the same meaning as defined in Health and Safety Code Section 

39047. 

25. “Pretreatment Coating” means any coating that contains a minimum of one-half (0.5) 

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

provide surface etching and is labeled and formulated for application directly to bare 

metal surfaces to provide corrosion resistance and adhesion. 

26. “Primer” means any coating, which is labeled and formulated for application to a 

substrate to provide 1) a bond between the substrate and subsequent coats, 2) corrosion Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 5 June 19, 2008

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

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

27. “Primer Sealer” means any coating which is labeled and formulated for application 

prior to the application of a color coating for the purpose of color uniformity, or to 

promote the ability of the underlying coating to resist penetration by the color coating. 

28. “Refinishing” means any coating of vehicles, their exterior parts or components, or 

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

or beautification and which is subsequent to the original coating applied at an Original 

Equipment Manufacturer (OEM) plant coating assembly line. 

29. “Single-Stage Coating” means any pigmented coating, excluding primers and multicolor coatings, labeled and formulated for application without a subsequent clear coat. 

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

30. “Solvent” means a VOC-containing fluid used to perform cleaning operations. 

31. “Spot/Panel Repair” means repair of an area on a motor vehicle, piece of mobile 

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

centimeters). 

 

32. “Spray Booth” means a power ventilated structure of varying dimensions and 

construction provided to enclose or accommodate a spraying operation and to confine 

and limit the escape of spray vapor and residue and to exhaust it safely. 

33. “Temporary Protective Coating” means any coating which is labeled and formulated 

for the purpose of temporarily protecting areas from overspray or mechanical damage. 

 

 34. “Thinner” means a volatile liquid used to lower the solid concentration or the viscosity 

of a coating. 

 35. “Touch-up Coating” means a coating applied by brush, air brush, detail HVLP spray 

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

imperfections. 

 36. “Transfer Efficiency” means the amount of coating solids adhering to the object being 

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

37. “Truck Bed Liner Coating” means any coating, excluding clear, color, multi-color, 

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

it from surface abrasion. 

38. “Underbody Coating” means any coating labeled and formulated for application to 

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

underside of the motor vehicle. 

 39. “Undercoat” means any pretreatment wash primer, primer, or primer sealer. 

40. “Uniform Finish Coating” means any coating labeled and formulated for application to 

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

coat to match the appearance of an adjacent area’s existing coating. Deleted: April 17, 1997

Formatted: Font: Times New

Roman, 11 pt, No underline, Font

color: Auto
Santa Barbara County APCD Rule 339 339 - 6 June 19, 2008

41. “U.S. EPA” means the United States Environmental Protection Agency. 

42. “Volatile Organic Compound (VOC)” means any volatile compound containing at 

least one atom of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, 

metallic carbides or carbonates, and ammonium carbonate, and excluding the following: 

a. methane; 

methylene chloride (dichloromethane); 

1,1,1-trichloroethane (methyl chloroform); 

trichlorofluoromethane (CFC-11); 

dichlorodifluoromethane (CFC-12); 

1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113); 

1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114); 

chloropentafluoroethane (CFC-115); 

chlorodifluoromethane (HCFC-22); 

1,1,1-trifluoro-2,2-dichloroethane (HCFC-123); 

2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124); 

1,1-dichloro-1-fluoroethane (HCFC-141b); 

1-chloro-1,1-difluoroethane (HCFC-142b); 

trifluoromethane (HFC-23); 

pentafluoroethane (HFC-125); 

1,1,2,2-tetrafluoroethane (HFC-134); 

1,1,1,2-tetrafluoroethane (HFC-134a); 

1,1,1-trifluoroethane (HFC-143a); 

1,1-difluoroethane (HFC-152a); 

cyclic, branched, or linear completely methylated siloxanes; 

the following classes of perfluorocarbons: 

(A) cyclic, branched, or linear, completely fluorinated alkanes; 

(B) cyclic, branched, or linear, completely fluorinated ethers with 

no unsaturations; 

(C) cyclic, branched, or linear, completely fluorinated tertiary 

amines with no unsaturations; and 

(D) sulfur-containing perfluorocarbons with no unsaturations and 

with the sulfur bonds only to carbon and fluorine; and 

b. the following low-reactive organic compounds which have been 

exempted by the U.S. EPA: 

acetone; 

ethane; 

parachlorobenzotrifluoride (1-chloro-4-trifluoromethyl benzene); 

perchloroethylene; 

methyl acetate; and 

 tertiary butyl acetate (tBAc). 

43. “VOC Content” 

a. “VOC Regulatory for Coatings” means VOC in grams per liter of coating, 

excluding water and exempt compounds, and shall be calculated by the 

following equation: 

VOC Regulatory Content = (Wv - Ww – Wec)

 (Vm - Vw – Vec) Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 7 June 19, 2008

b. “VOC Actual for Coatings” means VOC in grams per liter of material shall be 

calculated using the following equation: 

VOC Actual Content = (Wv - Ww – Wec)

 (Vm) 

c. “VOC Content for Solvents” means VOC in grams per liter of material shall 

be calculated by the following equation: 

VOC Content = Wv - Ww - Wec

 Vm 

Where: 

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

Wv = weight of volatiles in grams 

Ww = weight of water in grams 

Wec = weight of exempt compounds in grams 

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

Vw = volume of water in liters 

 

Vec = volume of exempt compounds in liters 

D. Requirements

1. Coating Limits. No person shall apply to any motor vehicle, mobile equipment, or 

associated parts and components, any coating with a VOC regulatory content, as 

calculated pursuant to Section C.43.a, in excess of the following limits, except as 

provided in Section D.3:

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 8 June 19, 2008

*English units are provided for information only. 

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

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

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

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

categories listed in Section D.1, then the lowest VOC content limit shall apply. 

3. Alternative Compliance. Instead of complying with the VOC content limits specified in 

Section D.1, a person may use an emission control system that has been approved, in 

writing, by the Executive Officer or Air Pollution Control Officer of the District and 

which achieves an overall control efficiency of at least 85 percent as determined pursuant 

to Sections E.5 and E.6. Any approved system emission control must be maintained and 

used at all times in proper working condition. 

4. Prohibition of Possession. No person shall possess at any automotive refinishing 

facility, any automotive coating that is not in compliance with Section D.1 or D.3, as 

applicable. Effective January 1, 2010, no person shall possess at any automotive 

refinishing facility, any solvent with a VOC content greater than 25 grams per liter. 

VOC Regulatory Limit, as applied, 

in grams per liter (pounds per gallon*) 

Coating Category 

Effective 

January 1, 2009

Effective 

January 1, 2010

Adhesion Promoter 540 (4.5) 

Clear Coating 250 (2.1) 

Color Coating 420 (3.5) 

Multi-Color Coating 680 (5.7) 

Pretreatment Coating 660 (5.5) 

Primer 250 (2.1) 

Primer Sealer 250 (2.1) 

Single-Stage Coating 340 (2.8) 

Temporary Protective Coating 60 (0.5) 

Truck Bed Liner Coating 310 (2.6) 

Underbody Coating 430 (3.6) 

Uniform Finish Coating 540 (4.5) 

Any other coating type 250 (2.1) 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 9 June 19, 2008

5. Prohibition of Sale or Manufacture. No person shall manufacture, blend, repackage 

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

VOC content in excess of the limits specified in Section D.1. 

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

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

in excess of the limits specified in Section D.1 under the following circumstances and 

provided all of the requirements of Section F.6 are also met: 

a. The coating is for use exclusively within an emission control system as allowed 

in Section D.3, or 

b. The coating is for use outside the District. 

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

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

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

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

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

the provisions of this rule is to be used or applied. This prohibition shall not apply to 

coatings that meet the criteria specified in Section D.5. 

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

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

application methods is used: 

a. Brush, dip, or roller. 

b. Electrostatic spray. 

c. High-Volume Low-Pressure (HVLP) spray equipment. 

d. Use of a spray gun: If a spray gun is used, the end user must demonstrate that the 

gun meets the HVLP definition in Section C.18 in design and use. A satisfactory 

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

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

an air pressure tip gauge from the manufacturer of the gun. 

e. Any alternative method that achieves a transfer efficiency quivalent to, or higher 

than, the application methods listed in Sections D.7.a, D.7.b, or D.7.c as 

determined per Section E.9. Written approval from the Executive Officer or Air 

Pollution Control Officer of the District shall be obtained for each alternative 

method prior to use. Section D.7 does not apply to underbody coatings, graphic 

arts operations, truck bed liner coatings, or any coating use of less than one (1) 

fluid ounce (29.6 milliliters). 

8. Solvent Limits and Evaporative Loss Minimization 

a. Effective January 1, 2010, each solvent present at any automotive refinishing 

facility shall not exceed a VOC content of 25 grams per liter as calculated 

pursuant to Section C.43.c. 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 10 June 19, 2008

b. Solvent-laden materials shall be stored in closed containers. 

c. All automotive coating components, automotive coatings, and solvents shall be 

stored in closed vapor-tight containers. 

d. No person shall clean spray equipment unless a closed system is used. However, 

equivalent control equipment can be used if the Executive Officer or Air 

Pollution Control Officer of the District approves it in writing prior to use. 

e. All waste automotive coating components, automotive coatings, and solvents 

shall be stored in closed vapor-tight containers, except while adding to or 

removing them from the containers. 

9. Spray Booth Requirement. All surface coatings which are subject to this rule shall be 

applied in a properly maintained and operating spray booth that has a District issued 

Permit to Operate or an Authority to Construct that allows operation and in full 

compliance with all conditions of any such permit. 

E. Test Methods 

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

coatings and solvents subject to the provisions of this rule. A source is in violation of this rule if 

any measurement by any of the listed applicable test methods exceeds the standards of this rule. 

1. Methyl Acetate, Acetone, t-Butyl Acetate, and PCBTF Content. The quantity of 

methyl acetate, acetone, t-butyl acetate, and parachlorobenzotrifluoride (as specified in 

Sections C.15, C.42, and C.43) shall be determined by using ASTM Standard D 6133-02: 

“Standard Test Method for Acetone, p-Chlorobenzotrifluoride, Methyl Acetate or t-Butyl 

Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw 

Materials by Direct Injection Into a Gas Chromatograph,” (February 2003), ASTM 

International. 

2. Acid Content. Measurement of acid content (as specified in Section C.25) shall be 

determined by using ASTM Standard D 1613-03 “Standard Test Method for Acidity in 

Volatile Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and 

Related Products,” (October 2003), ASTM International. 

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

equivalent or better and approved, in writing, by the Executive Officer or Air Pollution 

Control Officer of the District, CARB, and U.S. EPA may be used in place of the test 

methods specified in this rule. 

4. VOC Content of Coatings or Solvents. VOC content (as specified in Sections C.43, 

D.1, and D.8.a) shall be determined by U.S. EPA Method 24 as set forth in Appendix A 

of Title 40 of the Code of Federal Regulations (40 CFR) Part 60, “Determination of 

Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of 

Surface Coatings”. 

5. Control Efficiency. When either U.S. EPA Method 25, 25A, or 25B is used to 

determine VOC emissions, control device equivalency (as specified in Section D.3) shall 

be determined as specified in U.S. EPA’s “Guidelines for Determining Capture 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 11 June 19, 2008

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

applicable. 

6. Determination of Alternative Compliance. Alternative compliance (as specified in 

Section D.3) shall be determined by U.S. EPA Method 25, 25A, or 25B, Title 40 Code of 

Federal Regulations, Part 60, Appendix A as applicable. A source is in violation if the 

measured VOC emissions, as measured by any of the test methods, exceed the standards 

specified in Section D.3. 

7. Metallic Content. The metallic content of a coating (as specified in Section C.20) shall 

be determined by South Coast Air Quality Management District Method 318-95, 

“Determination of Weight Percent Elemental Metal in Coatings by X-ray” (July 1996). 

8. Exempt Compound Content. Exempt compound content, other than as determined 

pursuant to Section E.1, (as specified in Sections C.15, C.42 and C.43) shall be 

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

Trichloroethane in Paints and Coatings” (September 12, 1998); CARB Method 422, 

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

(January 22, 1987); or, South Coast Air Quality Management District (SCAQMD) 

Method 303-91, “Determination of Exempt Compounds” (February 1993). 

9. Transfer Efficiency. Spray equipment transfer efficiency (as specified in Sections C.36 

and D.7.e) shall be determined by using South Coast Air Quality Management District 

“Spray Equipment Transfer Efficiency Test Procedure for Equipment User” (May 24, 

1989). 

10. HVLP Equivalency. Spray equipment HVLP equivalency (as specified in Section 

D.7.d) shall be determined by using South Coast Air Quality Management District 

“Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient 

Spray Guns” (September 26, 2002). 

F. Recordkeeping 

1. Compliance Statement Requirement 

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

manufacturer and repackager shall include the following information on product 

data sheets, or an equivalent medium: 

i. The VOC actual for coatings and VOC regulatory for coatings, expressed 

in grams per liter; 

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

iii. The volume percentage of water and exempt compounds; and, 

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

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

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

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

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 12 June 19, 2008

i. The VOC actual for coatings and VOC regulatory for coatings, expressed 

in grams per liter; 

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

iii. The volume percentage of water and exempt compounds; and, 

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

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

VOC content as supplied, calculated pursuant to Section C.43.c, expressed in 

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

2. Labeling Requirements

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

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

the VOC actual for coatings and VOC regulatory for coatings, as supplied, 

expressed in grams per liter. 

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

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

liter. 

3. Maintenance of Records. Records required by this rule shall be retained for a minimum 

of three years and made available for inspection by District personnel upon request. 

4. Recordkeeping Requirements. Any person who uses coatings or solvents subject to 

this rule shall maintain and have available at all times, on site, the following: 

a. A current list of all coatings and solvents used that are subject to this rule. This 

list shall include the following information for each coating and solvent: 

i. material name and manufacturer; 

ii. application method; 

iii. coating type (as listed in Section D.1) and mix ratio specific to the 

coating; 

iv. VOC actual for coatings and VOC regulatory for coatings, as applied, or 

VOC content for solvent; and, 

v. whether the material is a coating or solvent. 

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

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

VOC regulatory for coatings of each ready-to-spray coating (based on the 

manufacturer’s stated mix ratio) and automotive coating components, and VOC 

content of each solvent. 

c. Purchase records identifying the coating type (as listed in Section D.1), name, 

and volume of coatings and solvents. 

Deleted: April 17, 1997
Santa Barbara County APCD Rule 339 339 - 13 June 19, 2008

5. Recordkeeping Requirements for Emission Control Systems. Any person using an 

emission control system shall maintain daily records of key system operating parameters 

which will demonstrate continuous operation and compliance of the emission control 

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

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

Section D.3, including, but not limited to, temperatures, pressure drops, and air flow 

rates. 

6. Recordkeeping Requirements for Prohibition of Sale. Any person claiming an 

exception specified in Section D.5 shall keep a detailed log of each automotive coating 

component and automotive coating manufactured, blended, repackaged for sale, supplied, 

sold, offered for sale, or distributed showing: 

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

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

b. The VOC regulatory for coatings; 

c. The VOC actual for coatings; 

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

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

address, phone number, retail tax license number, and valid district permit 

number; and, 

e. The specific exception being utilized under Section D.5. 

7. Annual Reports. Any person subject to this rule shall keep and maintain a record of the 

total automotive refinishing facility VOC emissions used on a monthly basis. These 

records shall be summarized for the previous calendar year and submitted to the District 

by March 1. 

G. Rule Effective Date

Unless otherwise specified, the provisions of this rule as adopted on June 19, 2008 become effective

January 1, 2009. 

 APPROVED AS TO FORM: 

 

 DANIEL J. WALLACE 

 SANTA BARBARA COUNTY COUNSEL 

 By____________________________ 

 Deputy 

 Attorneys for the Santa Barbara 

 Air Pollution Control District 

Deleted: April 17, 1997