2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07

APPENDIX B: 

2000 SUGGESTED CONTROL MEASURE FOR 

ARCHITECTURAL COATINGS 
2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-1 Sept - 07

California Air Resources Board (ARB) 

Suggested Control Measure for Architectural Coatings 

1. APPLICABILITY 

1.1 Except as provided in subsection 1.2, this rule is applicable to any person who 

supplies, sells, offers for sale, or manufactures any architectural coating for use 

within the District, as well as any person who applies or solicits the application of 

any architectural coating within the District. 

1.2 This rule does not apply to: 

 1.2.1 Any architectural coating that is sold or manufactured for use outside of 

the District or for shipment to other manufacturers for reformulation or 

repackaging. 

 1.2.2 Any aerosol coating product. 

 1.2.3 Any architectural coating that is sold in a container with a volume of one 

liter (1.057 quart) or less. 

2. DEFINITIONS

2.0 Adhesive: Any chemical substance that is applied for the purpose of bonding two 

surfaces together other than by mechanical means. 

2.1 Aerosol Coating Product: 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. 

2.2 Antenna Coating: A coating labeled and formulated exclusively for application to 

equipment and associated structural appurtenances that are used to receive or 

transmit electromagnetic signals. 

2.3 Antifouling Coating: A coating labeled and formulated for application to 

submerged stationary structures and their appurtenances to prevent or reduce 

the attachment of marine or freshwater biological organisms. To qualify as an 

antifouling coating, the coating must be registered with both the U.S. EPA under 

the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. Section 136, et 

seq.) and with the California Department of Pesticide Regulation. 

2.4 Appurtenance: Any accessory to a stationary structure coated at the site of 

installation, whether installed or detached, including but not limited to: bathroom 

and kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand 

railings; heating equipment, air conditioning equipment, and other fixed 

mechanical equipment or stationary tools; lampposts; partitions; pipes and piping 

systems; rain gutters and downspouts; stairways, fixed ladders, catwalks, and 

fire escapes; and window screens. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-2 Sept - 07

2.5 Architectural Coating: 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. Coatings applied in shop applications or 

to non-stationary structures such as airplanes, ships, boats, railcars, and 

automobiles, and adhesives are not considered architectural coatings for the 

purposes of this rule. 

2.6 Bitumens: Black or brown materials including, but not limited to, asphalt, tar, 

pitch, and asphaltite that are soluble in carbon disulfide, consist mainly of 

hydrocarbons, and are obtained from natural deposits or as residues from the 

distillation of crude petroleum or coal. 

2.7 Bituminous Roof Coating: A coating which incorporates bitumens that is labeled 

and formulated exclusively for roofing.

 2.8 Bituminous Roof Primer: A primer which incorporates bitumens that is 

labeled and formulated exclusively for roofing. 

2.9 Bond Breaker: A coating labeled and formulated for application between layers of 

concrete to prevent a freshly poured top layer of concrete from bonding to the 

layer over which it is poured. 

2.10 Clear Brushing Lacquers: Clear wood finishes, excluding clear lacquer sanding 

sealers, formulated with nitrocellulose or synthetic resins to dry by solvent 

evaporation without chemical reaction and to provide a solid, protective film, 

which are intended exclusively for application by brush, and which are labeled as 

specified in subsection 4.1.5. 

2.11 Clear Wood Coatings: Clear and semi-transparent coatings, including lacquers 

and varnishes, applied to wood substrates to provide a transparent or translucent 

solid film. 

2.12 Coating: A material applied onto or impregnated into a substrate for protective, 

decorative, or functional purposes. Such materials include, but are not limited to, 

paints, varnishes, sealers, and stains. 

2.13 Colorant: A concentrated pigment dispersion in water, solvent, and/or binder that 

is added to an architectural coating after packaging in sale units to produce the 

desired color. 

2.14 Concrete Curing Compound: A coating labeled and formulated for application to 

freshly poured concrete to retard the evaporation of water. 

2.15 Dry Fog Coating: A coating labeled and formulated only for spray application 

such that overspray droplets dry before subsequent contact with incidental 

surfaces in the vicinity of the surface coating activity. 

2.16 Exempt Compound: A compound identified as exempt under the definition of 

Volatile Organic Compound (VOC), subsection 2.60. Exempt compounds 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-3 Sept - 07

content of a coating shall be determined by U.S. EPA Method 24 or South Coast 

Air Quality Management 

 District (SCAQMD) Method 303-91 (Revised February 1993), incorporated by 

reference in subsection 6.5.10. 

2.17 Faux Finishing Coating: A coating labeled and formulated as a stain or glaze to 

create artistic effects including, but not limited to, dirt, old age, smoke damage, 

and simulated marble and wood grain. 

2.18 Fire-Resistive Coating: An opaque coating labeled and formulated to protect the 

structural integrity by increasing the fire endurance of interior or exterior steel and 

other structural materials, that has been fire tested and rated by a testing agency 

approved by building code officials for use in bringing assemblies of structural 

materials into compliance with federal, state, and local building code 

requirements. The fire-resistive coating and the testing agency must be 

approved by building code officials. The fire-resistant coating shall be tested in 

accordance with ASTM Designation E 119-98, incorporated by reference in 

subsection 6.5.2. 

2.19 Fire-Retardant Coating: A coating labeled and formulated to retard ignition and 

flame spread, that has been fire tested and rated by a testing agency approved 

by building code officials for use in bringing building and construction materials 

into compliance with federal, state and local building code requirements. The 

fire-retardant coating and the testing agency must be approved by building code 

officials. The fire-retardant coating shall be tested in accordance with ASTM 

Designation E 84-99, incorporated by reference in subsection 6.5.1. 

2.20 Flat Coating: A coating that is not defined under any other definition in this rule 

and that registers gloss less than 15 on an 85-degree meter or less than 5 on a 

60-degree meter according to ASTM Designation D 523-89 (1999), incorporated 

by reference in subsection 6.5.3. 

2.21 Floor Coating: An opaque coating that is labeled and formulated for application to 

flooring, including, but not limited to, decks, porches, steps, and other horizontal 

surfaces which may be subject to foot traffic. 

2.22 Flow Coating: A coating labeled and formulated exclusively for use by electric 

power companies or their subcontractors to maintain the protective coating 

systems present on utility transformer units. 

2.23 Form-Release Compound: A coating labeled and formulated for application to a 

concrete form to prevent the freshly poured concrete from bonding to the form. 

The form may consist of wood, metal, or some material other than concrete. 

2.24 Graphic Arts Coating or Sign Paint: A coating labeled and formulated for handapplication by artists using brush or roller techniques to indoor and outdoor signs 

(excluding structural components) and murals including lettering enamels, poster 

colors, copy blockers, and bulletin enamels. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-4 Sept - 07

2.25 High-Temperature Coating: A high performance coating labeled and formulated 

for application to substrates exposed continuously or intermittently to 

temperatures above 204o

C (400oF). 

2.26 Industrial Maintenance Coating: A high performance architectural coating, 

including primers, sealers, undercoaters, intermediate coats, and topcoats, 

formulated for application to substrates exposed to one or more of the following 

extreme environmental conditions listed in subsections 2.26.1 through 2.26.5, 

and labeled as specified in subsection 4.1.4: 

2.26.1 Immersion in water, wastewater, or chemical solutions (aqueous and nonaqueous solutions), or chronic exposure of interior surfaces to moisture 

condensation; 

2.26.2 Acute or chronic exposure to corrosive, caustic or acidic agents, or to 

chemicals, chemical fumes, or chemical mixtures or solutions; 

2.26.3 Repeated exposure to temperatures above 121o

C (250oF); 

2.26.4 Repeated (frequent) heavy abrasion, including mechanical wear and 

repeated (frequent) scrubbing with industrial solvents, cleansers, or 

scouring agents; or 

2.26.5 Exterior exposure of metal structures and structural components. 

2.27 Lacquer: A clear or opaque wood coating, including clear lacquer sanding 

sealers, formulated with cellulosic or synthetic resins to dry by evaporation 

without chemical reaction and to provide a solid, protective film. 

2.28 Low Solids Coating: A coating containing 0.12 kilogram or less of solids per liter 

(1 pound or less of solids per gallon) of coating material. 

2.29 Magnesite Cement Coating: A coating labeled and formulated for application to 

magnesite cement decking to protect the magnesite cement substrate from 

erosion by water. 

2.30 Mastic Texture Coating: A coating labeled and formulated to cover holes and 

minor cracks and to conceal surface irregularities, and is applied in a single coat 

of at least 

10 mils (0.010 inch) dry film thickness. 

2.31 Metallic Pigmented Coating: A coating containing at least 48 grams of elemental 

metallic pigment per liter of coating as applied (0.4 pounds per gallon), when 

tested in accordance with SCAQMD Method 318-95, incorporated by reference in 

subsection 6.5.4. 

2.32 Multi-Color Coating: A coating that is packaged in a single container and that 

exhibits more than one color when applied in a single coat. 

2.33 Nonflat Coating: A coating that is not defined under any other definition in this 

rule and that registers a gloss of 15 or greater on an 85-degree meter and 5 or 

greater on a 60-degree meter according to ASTM Designation D 523-89 (1999), 

incorporated by reference in subsection 6.5.3. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-5 Sept - 07

2.34 Nonflat - High Gloss Coating: A nonflat coating that registers a gloss of 70 or 

above on a 60-degree meter according to ASTM Designation D 523-89 (1999), 

incorporated by reference in subsection 6.5.3. 

2.35 Nonindustrial Use: Nonindustrial use means any use of architectural coatings 

except in the construction or maintenance of any of the following: facilities used 

in the manufacturing of goods and commodities; transportation infrastructure, 

including highways, bridges, airports and railroads; facilities used in mining 

activities, including petroleum extraction; and utilities infrastructure, including 

power generation and distribution, and water treatment and distribution systems. 

2.36 Post-Consumer Coating: A finished coating that would have been disposed of in 

a landfill, having completed its usefulness to a consumer, and does not include 

manufacturing wastes. 

2.37 Pre-Treatment Wash Primer: A primer that contains a minimum of 0.5 percent 

acid, by weight, when tested in accordance with ASTM Designation D 1613-96, 

incorporated by reference in subsection 6.5.5, that is labeled and formulated for 

application directly to bare metal surfaces to provide corrosion resistance and to 

promote adhesion of subsequent topcoats. 

2.38 Primer: A coating labeled and formulated for application to a substrate to provide 

a firm bond between the substrate and subsequent coats. 

2.39 Quick-Dry Enamel: A nonflat coating that is labeled as specified in subsection 

4.1.8 and that is formulated to have the following characteristics: 

2.39.1 Is capable of being applied directly from the container under normal 

conditions with ambient temperatures between 16 and 27o

C (60 and 

80o

F); 

2.39.2 When tested in accordance with ASTM Designation D 1640-95, 

incorporated by reference in subsection 6.5.6, sets to touch in 2 hours 

or less, is tack free in 

4 hours or less, and dries hard in 8 hours or less by the mechanical test 

method; and 

2.39.3 Has a dried film gloss of 70 or above on a 60 degree meter. 

2.40 Quick-Dry Primer, Sealer, and Undercoater: A primer, sealer, or undercoater that 

is dry to the touch in 30 minutes and can be recoated in 2 hours when tested in 

accordance with ASTM Designation D 1640- 95, incorporated by reference in 

subsection 6.5.6. 

2.41 Recycled Coating: An architectural coating formulated such that not less than 50 

percent of the total weight consists of secondary and post-consumer coating, 

with not less than 

10 percent of the total weight consisting of post-consumer coating. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-6 Sept - 07

2.42 Residence: Areas where people reside or lodge, including, but not limited to, 

single and multiple family dwellings, condominiums, mobile homes, apartment 

complexes, motels, and hotels. 

2.43 Roof Coating: A non-bituminous coating labeled and formulated exclusively for 

application to roofs for the primary purpose of preventing penetration of the 

substrate by water or reflecting heat and ultraviolet radiation. Metallic pigmented 

roof coatings which qualify as metallic pigmented coatings shall not be 

considered to be in this category, but shall be considered to be in the metallic 

pigmented coatings category. 

2.44 Rust Preventative Coating: A coating formulated exclusively for nonindustrial use 

to prevent the corrosion of metal surfaces and labeled as specified in subsection 

4.1.6. 

2.45 Sanding Sealer: A clear or semi-transparent wood coating labeled and 

formulated for application to bare wood to seal the wood and to provide a coat 

that can be abraded to create a smooth surface for subsequent applications of 

coatings. A sanding sealer that also meets the definition of a lacquer is not 

included in this category, but is included in the lacquer category. 

 2.46 Sealer: A coating labeled and formulated for application to a substrate for one or 

more of the following purposes: to prevent subsequent coatings from being 

absorbed by the substrate, or to prevent harm to subsequent coatings by 

materials in the substrate. 

 2.47 Secondary Coating (Rework): A fragment of a finished coating or a finished 

coating from a manufacturing process that has converted resources into a 

commodity of real economic value, but does not include excess virgin resources 

of the manufacturing process. 

 2.48 Shellac: A clear or opaque coating formulated solely with the resinous secretions 

of the lac beetle (Laciffer lacca), thinned with alcohol, and formulated to dry by 

evaporation without a chemical reaction. 

 2.49 Shop Application: Application of a coating to a product or a component of a 

product in or on the premises of a factory or a shop as part of a manufacturing, 

production, or repairing process (e.g., original equipment manufacturing 

coatings). 

 2.50 Solicit: To require for use or to specify, by written or oral contract. 

 2.51 Specialty Primer, Sealer, and Undercoater: A coating labeled as specified in 

subsection 4.1.7 and that is formulated for application to a substrate to seal fire, 

smoke or water damage; to condition excessively chalky surfaces, or to block 

stains. An excessively chalky surface is one that is defined as having a chalk 

rating of four or less as determined by ASTM Designation D 4214-98, 

incorporated by reference in 

subsection 6.5.7. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-7 Sept - 07

 2.52 Stain: A clear, semitransparent, or opaque coating labeled and formulated to 

change the color of a surface but not conceal the grain pattern or texture. 

 2.53 Swimming Pool Coating: A coating labeled and formulated to coat the interior of 

swimming pools and to resist swimming pool chemicals. 

 2.54 Swimming Pool Repair and Maintenance Coating: A rubber based coating 

labeled and formulated to be used over existing rubber based coatings for the 

repair and maintenance of swimming pools. 

 2.55 Temperature-Indicator Safety Coating: A coating labeled and formulated as a 

color-changing indicator coating for the purpose of monitoring the temperature 

and safety of the substrate, underlying piping, or underlying equipment, and for 

application to substrates exposed continuously or intermittently to temperatures 

above 204o

C (400oF). 

 2.56 Tint Base: An architectural coating to which colorant is added after packaging in 

sale units to produce a desired color. 

 2.57 Traffic Marking Coating: A coating labeled and formulated for marking and 

striping streets, highways, or other traffic surfaces including, but not limited to, 

curbs, berms, driveways, parking lots, sidewalks, and airport runways. 

 2.58 Undercoater: A coating labeled and formulated to provide a smooth surface for 

subsequent coatings. 

 2.59 Varnish: A clear or semi-transparent wood coating, excluding lacquers and 

shellacs, formulated to dry by chemical reaction on exposure to air. Varnishes 

may contain small amounts of pigment to color a surface, or to control the final 

sheen or gloss of the finish. 

 2.60 Volatile Organic Compound (VOC): 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: 

 2.60.1 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); 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-8 Sept - 07

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 

2.60.2 the following low-reactive organic compounds which have been exempted 

by the U.S. EPA: 

acetone; 

ethane; 

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

perchloroethylene; and 

methyl acetate. 

2.61 VOC Content: The weight of VOC per volume of coating, calculated according to 

the procedures specified in subsection 6.1. 

 2.62 Waterproofing Sealer: A coating labeled and formulated for application to a 

porous substrate for the primary purpose of preventing the penetration of water. 

2.63 Waterproofing Concrete/Masonry Sealer: A clear or pigmented film-forming 

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

provide resistance against water, alkalis, acids, ultraviolet light, and staining. 

2.64 Wood Preservative: A coating labeled and formulated to protect exposed wood 

from decay or insect attack, that is registered with both the U.S. EPA under the 

Federal Insecticide, Fungicide, and Rodenticide Act (7 United States Code 

(U.S.C.) Section 136, et seq.) and with the California Department of Pesticide 

Regulation. 

3. STANDARDS

3.1 VOC Content Limits: Except as provided in subsections 3.2, 3.3, 3.8, 3.9, and 

3.10, no person shall: (i) manufacture, blend, or repackage for sale within the 

district; 

(ii) supply, sell, or offer for sale within the district; or (iii) solicit for application or 

apply within the district, any architectural coating with a VOC content in excess of 

the corresponding limit specified in Table 1, after the specified effective date in 

Table 1. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-9 Sept - 07

3.2 Most Restrictive VOC Limit: If anywhere on the container of any architectural 

coating, or any label or sticker affixed to the container, or in any sales, 

advertising, or technical literature supplied by a manufacturer or anyone acting 

on their behalf, any representation is made that indicates that the coating meets 

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

categories listed in Table 1, then the most restrictive VOC content limit shall 

apply. This provision does not apply to the coating categories specified in 

subsections 3.2.1 through 3.2.15. 

3.2.1 Lacquer coatings (including lacquer sanding sealers). 

3.2.2 Metallic pigmented coatings. 

3.2.3 Shellacs. 

3.2.4 Fire-retardant coatings. 

3.2.5 Pretreatment wash primers.

3.2.6 Industrial maintenance coatings.

3.2.7 Low-solids coatings.

3.2.8 Wood preservatives. 

3.2.9 High temperature coatings.

3.2.10 Temperature-indicator safety coatings.

3.2.11 Antenna coatings. 

 3.2.12 Antifouling coatings. 

3.2.13 Flow coatings. 

3.2.14 Bituminous roof primers. 

 3.2.15 Specialty primers, sealers, and undercoaters. 

3.3 Sell-Through of Coatings: A coating manufactured prior to the effective date 

specified for that coating in Table 1 may be sold, supplied, or offered for sale for 

up to three years after the specified effective date. In addition, a coating 

manufactured before the effective date specified for that coating in Table 1 may 

be applied at any time, both before and after the specified effective date, so long 

as the coating complied with the standards in effect at the time the coating was 

manufactured. This subsection 3.3 does not apply to any coating that does not 

display the date or date-code required by subsection 4.1.1. 

SCM Clarification - New subsection “3.3.1” 

 (See June 7, 2001 letter to all districts by Mike Kenny, ARB Executive Officer)

 3.3.1 A coating included in an approved Averaging Program that does not comply with 

the specified limit in Table 1 may be sold, supplied, or offered for sale for up to 

three years after the end of the compliance period specified in the approved 

Averaging Program. In addition, such a coating may be applied at any time, both 

during and after the compliance period. This subsection 3.3.1 does not apply to 

any coating that does not display on the container either the statement: “This 

product is subject to architectural coatings averaging provisions in California,” or 

a substitute symbol specified by the Executive Officer of the ARB. This 

subsection 3.3.1 shall remain in effect until January 1, 2008. 

3.4 Painting Practices: All architectural coating containers used to apply the 

contents therein to a surface directly from the container by pouring, siphoning, 

brushing, rolling, padding, ragging or other means, shall be closed when not in 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-10 Sept - 07

use. These architectural coating containers include, but are not limited to, 

drums, buckets, cans, pails, trays or other application containers. Containers of 

any VOC-containing materials used for thinning and cleanup shall also be closed 

when not in use. 

3.5 Thinning: No person who applies or solicits the application of any architectural 

coating shall apply a coating that is thinned to exceed the applicable VOC limit 

specified in 

Table 1. 

3.6 Rust Preventative Coatings: Effective January 1, 2004, no person shall apply 

or solicit the application of any rust preventative coating for industrial use, unless 

such a rust preventative coating complies with the industrial maintenance coating 

VOC limit specified in Table 1. 

3.7 Coatings Not Listed in Table 1: For any coating that does not meet any of the 

definitions for the specialty coatings categories listed in Table 1, the VOC content 

limit shall be determined by classifying the coating as a flat coating or a nonflat 

coating, based on its gloss, as defined in subsections 2.20, 2.33, and 2.34 and 

the corresponding flat or nonflat VOC limit shall apply. 

3.8 Industrial Maintenance Coatings:

3.8.1 After January 1, 2004, a manufacturer, seller, or user may petition the 

APCO to apply an industrial maintenance coating with a VOC content up 

to 340 g/l if all of the following conditions are met: 

3.8.1.1 The industrial maintenance coating is to be applied in a district 

located within the North Central Coast, San Francisco Bay Area, 

or North Coast Air Basins. 

3.8.1.2 The petition submitted to the APCO contains the following 

information, as applicable: job requirements and description, 

volume of coating, maximum VOC content, and a certification 

that a complying coating meeting the job performance 

requirements is not available. 

3.8.1.3 If the APCO grants written approval, such approval shall contain 

volume and VOC limit conditions. Until written approval is 

granted by the APCO and received by the petitioner, all 

provisions of this rule shall apply. 

3.8.2 The APCO shall not approve any petition under subsection 3.8.1 if the 

approvals previously granted by the APCO during the calendar year, 

when combined with the petition under consideration, would result in 

excess VOC emissions for that calendar year which would be greater 

than 5 percent of the annual emission reduction achieved within the 

district from implementing the January 1, 2004, VOC limit for industrial 

maintenance coatings. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-11 Sept - 07

3.8.3 Coatings subject to this provision shall be sold only if an approved petition 

(or a copy of it) is provided prior to the sale. Coatings subject to this 

provision shall not be available to the general public. 

 3.9 Lacquers: Notwithstanding the provisions of subsection 3.1, a person or facility 

may add up to 10 percent by volume of VOC to a lacquer to avoid blushing of the 

finish during days with relative humidity greater than 70 percent and temperature 

below 65o

F, at the time of application, provided that the coating contains acetone 

and no more than 

550 grams of VOC per liter of coating, less water and exempt compounds, prior 

to the addition of VOC. 

3.10 Averaging Compliance Option: On or after January 1, 2003, in lieu of 

compliance with the specified limits in Table 1 for floor coatings; industrial 

maintenance coatings; primers, sealers, and undercoaters; quick-dry primers, 

sealers, and undercoaters; quick-dry enamels; roof coatings; rust preventative 

coatings; stains; waterproofing sealers, as well as flats and non-flats (excluding 

recycled coatings), manufacturers may average designated coatings such that 

their actual cumulative emissions from the averaged coatings are less than or 

equal to the cumulative emissions that would have been allowed under those 

limits over a compliance period not to exceed one year. Such manufacturers 

must also comply with the averaging provisions contained in Appendix A, as well 

as maintain and make available for inspection records for at least three years 

after the end of the compliance period. This subsection 3.10 and Appendix A 

shall cease to be effective on January 1, 2005, after which averaging will no 

longer be allowed. 

4. CONTAINER LABELING REQUIREMENTS

4.1 Each manufacturer of any architectural coating subject to this rule shall display 

the information listed in subsections 4.1.1 through 4.1.8 on the coating container 

(or label) in which the coating is sold or distributed. 

 4.1.1 Date Code: The date the coating was manufactured, or a date code 

representing the date, shall be indicated on the label, lid, or bottom of the 

container. If the manufacturer uses a date code for any coating, the 

manufacturer shall file an explanation of each code with the Executive 

Officer of the ARB. 

 4.1.2 Thinning Recommendations: A statement of the manufacturer’s 

recommendation regarding thinning of the coating shall be indicated on 

the label or lid of the container. This requirement does not apply to the 

thinning of architectural coatings with water. If thinning of the coating 

prior to use is not necessary, the recommendation must specify that the 

coating is to be applied without thinning. 

 4.1.3 VOC Content: Each container of any coating subject to this rule shall 

display either the maximum or the actual VOC content of the coating, as 

supplied, including the maximum thinning as recommended by the 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-12 Sept - 07

manufacturer. VOC content shall be displayed in grams of VOC per liter 

of coating. VOC content displayed shall be calculated using product 

formulation data, or shall be determined using the test methods in 

subsection 6.2. The equations in 

 subsection 6.1 shall be used to calculate VOC content. 

4.1.4 Industrial Maintenance Coatings: In addition to the information 

specified in subsection 4.1.1, 4.1.2, and 4.1.3, each manufacturer of any 

industrial maintenance coating subject to this rule shall display on the 

label or lid of the container in which the coating is sold or distributed one 

or more of the descriptions listed in subsections 4.1.4.1 through 4.1.4.3. 

4.1.4.1 “For industrial use only.” 

4.1.4.2 “For professional use only.” 

4.1.4.3 “Not for residential use or Not intended for residential use.” 

4.1.5 Clear Brushing Lacquers: Effective January 1, 2003, the labels of all 

clear brushing lacquers shall prominently display the statements “For 

brush application only,” and “This product must not be thinned or 

sprayed.” 

4.1.6 Rust Preventative Coatings: Effective January 1, 2003, the labels of all 

rust preventative coatings shall prominently display the statement “For 

Metal Substrates Only.” 

4.1.7 Specialty Primers, Sealers, and Undercoaters: Effective January 1, 

2003, the labels of all specialty primers, sealers, and undercoaters shall 

prominently display one or more of the descriptions listed in subsection 

4.1.7.1 through 4.1.7.5. 

4.1.7.1 For blocking stains. 

4.1.7.2 For fire-damaged substrates. 

4.1.7.3 For smoke-damaged substrates.

4.1.7.4 For water-damaged substrates.

4.1.7.5 For excessively chalky substrates.

4.1.8 Quick Dry Enamels: Effective January 1, 2003, the labels of all quick dry 

enamels shall prominently display the words “Quick Dry” the dry hard 

time. 

4.1.9 Nonflat - High Gloss Coatings: Effective January 1, 2003, the labels of 

all nonflat - high gloss coatings shall prominently display the words “High 

Gloss.” 

5. REPORTING REQUIREMENTS

5.1 Clear Brushing Lacquers: Each manufacturer of clear brushing lacquers shall, 

on or before April 1 of each calendar year beginning in the year 2004, submit an 

annual report to the Executive Officer of the ARB. The report shall specify the 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-13 Sept - 07

number of gallons of clear brushing lacquers sold in the State during the 

preceding calendar year, and shall describe the method used by the 

manufacturer to calculate State sales. 

5.2 Rust Preventative Coatings: Each manufacturer of rust preventative coatings 

shall, on or before April 1 of each calendar year beginning in the year 2004, 

submit an annual report to the Executive Officer of the ARB. The report shall 

specify the number of gallons of rust preventative coatings sold in the State 

during the preceding calendar year, and shall describe the method used by the 

manufacturer to calculate State sales. 

5.3 Specialty Primers, Sealers, and Undercoaters: Each manufacturer of specialty 

primers, sealers, and undercoaters shall, on or before April 1 of each calendar 

year beginning in the year 2004, submit an annual report to the Executive Officer 

of the ARB. The report shall specify the number of gallons of specialty primers, 

sealers, and undercoaters sold in the State during the preceding calendar year, 

and shall describe the method used by the manufacturer to calculate State sales. 

5.4 Toxic Exempt Compounds: For each architectural coating that contains 

perchloroethylene or methylene chloride, the manufacturer shall, on or before 

April 1 of each calendar year beginning with the year 2004, report to the 

Executive Officer of the ARB the following information for products sold in the 

State during the preceding year: 

 

5.4.1 the product brand name and a copy of the product label with legible usage 

instructions; 

5.4.2 the product category listed in Table 1 to which the coating belongs; 

5.4.3 the total sales in California during the calendar year to the nearest gallon; 

5.4.4 the volume percent, to the nearest 0.10 percent, of perchloroethylene and 

methylene chloride in the coating. 

5.5 Recycled Coatings: Manufacturers of recycled coatings must submit a letter to 

the Executive Officer of the ARB certifying their status as a Recycled Paint 

Manufacturer. The manufacturer shall, on or before April 1 of each calendar year 

beginning with the year 2004, submit an annual report to the Executive Officer of 

the ARB. The report shall include, for all recycled coatings, the total number of 

gallons distributed in the State during the preceding year, and shall describe the 

method used by the manufacturer to calculate State distribution. 

5.6 Bituminous Coatings: Each manufacturer of bituminous roof coatings or 

bituminous roof primers shall, on or before April 1 of each calendar year 

beginning with the 

year 2004, submit an annual report to the Executive Officer of ARB. The report 

shall specify the number of gallons of bituminous roof coatings or bituminous roof 

primers sold in the State during the preceding calendar year, and shall describe 

the method used by the manufacturer to calculate State sales. 

6. COMPLIANCE PROVISIONS AND TEST METHODS
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-14 Sept - 07

6.1 Calculation of VOC Content: For the purpose of determining compliance with 

the VOC content limits in Table 1, the VOC content of a coating shall be 

determined by using the procedures described in subsection 6.1.1 or 6.1.2, as 

appropriate. The VOC content of a tint base shall be determined without colorant 

that is added after the tint base is manufactured. 

6.1.1 With the exception of low solids coatings, determine the VOC content in 

grams of VOC per liter of coating thinned to the manufacturer's maximum 

recommendation, excluding the volume of any water and exempt 

compounds. Determine the VOC content using equation 1 as follows: 

Where: 

VOC Content = grams of VOC per liter of coating 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

Vw = volume of water, in liters 

Vec = volume of exempt compounds, in liters 

 6.1.2 For low solids coatings, determine the VOC content in units of grams of 

VOC per liter of coating thinned to the manufacturer's maximum 

recommendation, including the volume of any water and exempt 

compounds. Determine the VOC content using equation 2 as follows: 

Where: 

VOC Contentls = the VOC content of a low solids coating in grams of 

VOC per liter of coating 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

6.2 VOC Content of Coatings: To determine the physical properties of a coating in 

order to perform the calculations in subsection 6.1, the reference method for 

VOC content is 

U.S. EPA Method 24, incorporated by reference in subsection 6.5.11, except as 

provided in subsections 6.3 and 6.4. An alternative method to determine the 

VOC content of coatings is SCAQMD Method 304-91 (Revised February 1996), 

 (1)

V ) ec ( Vm - Vw -

W ) ec W - Ww - s ( VOC Content = 

 (2) ( Vm )

W ) ec W - Ww - s ( = ls VOC Content
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-15 Sept - 07

incorporated by reference in subsection 6.5.12. The exempt compounds content 

shall be determined by SCAQMD Method 303-91 (Revised August 1996), 

incorporated by reference in subsection 6.5.10. To determine the VOC content 

of a coating, the manufacturer may use U.S. EPA Method 24, or an alternative 

method as provided in subsection 6.3, formulation data, or any other reasonable 

means for predicting that the coating has been formulated as intended (e.g., 

quality assurance checks, record keeping). However, if there are any 

inconsistencies between the results of a Method 24 test and any other means for 

determining VOC content, the Method 24 test results will govern, except when an 

alternative method is approved as specified in subsection 6.3. The District Air 

Pollution Control Officer (APCO) may require the manufacturer to conduct a 

Method 24 analysis. 

6.3 Alternative Test Methods: Other test methods demonstrated to provide results 

that are acceptable for purposes of determining compliance with subsection 6.2, 

after review and approved in writing by the staffs of the District, the ARB, and the 

U.S. EPA, may also be used. 

6.4 Methacrylate Traffic Marking Coatings: Analysis of methacrylate 

multicomponent coatings used as traffic marking coatings shall be conducted 

according to a modification of U.S. EPA Method 24 (40 CFR 59, subpart D, 

Appendix A), incorporated by reference 

in subsection 6.5.13. This method has not been approved for methacrylate 

multicomponent coatings used for other purposes than as traffic marking 

coatings or for other classes of multicomponent coatings. 

6.5 Test Methods: The following test methods are incorporated by reference herein, 

and shall be used to test coatings subject to the provisions of this rule: 

6.5.1 Flame Spread Index: The flame spread index of a fire-retardant coating 

shall be determined by ASTM Designation E 84-99, “Standard Test 

Method for Surface Burning Characteristics of Building Materials” (see 

section 2, Fire-Retardant Coating). 

6.5.2 Fire Resistance Rating: The fire resistance rating of a fire-resistive 

coating shall be determined by ASTM Designation E 119-98, “Standard 

Test Methods for Fire Tests of Building Construction Materials” (see 

section 2, Fire-Resistive Coating). 

6.5.3 Gloss Determination: The gloss of a coating shall be determined by 

ASTM Designation D 523-89 (1999), “Standard Test Method for Specular 

Gloss” (see section 2, Flat Coating, Nonflat Coating, Nonflat - High Gloss 

Coating, and Quick-Dry Enamel). 

6.5.4 Metal Content of Coatings: The metallic content of a coating shall be 

determined by SCAQMD Method 318-95, “Determination of Weight 

Percent Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD

Laboratory Methods of Analysis for Enforcement Samples (see section 2, 

Metallic Pigmented Coating). 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-16 Sept - 07

6.5.5 Acid Content of Coatings: The acid content of a coating shall be 

determined by ASTM Designation D 1613-96, “Standard Test Method for 

Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, 

Varnish, Lacquer, and Related Products” (see section 2, Pre-treatment 

Wash Primer). 

6.5.6 Drying Times: The set-to-touch, dry-hard, dry-to-touch, and dry-to-recoat 

times of a coating shall be determined by ASTM Designation D 1640-95, 

“Standard Test Methods for Drying, Curing, or Film Formation of Organic 

Coatings at Room Temperature” (see section 2, Quick-Dry Enamel and 

Quick-Dry Primer, Sealer, and Undercoater). The tack-free time of a 

quick-dry enamel coating shall be determined by the Mechanical Test 

Method of ASTM Designation D 1640-95. 

6.5.7 Surface Chalkiness: The chalkiness of a surface shall be determined 

using ASTM Designation D 4214-98, “Standard Test Methods for 

Evaluating the Degree of Chalking of Exterior Paint Films” (see section 2, 

Specialty Primer, Sealer, and Undercoater). 

6.5.8 Exempt Compounds--Siloxanes: Exempt compounds that are cyclic, 

branched, or linear completely methylated siloxanes, shall be analyzed 

as exempt compounds for compliance with section 6 by BAAQMD 

Method 43, “Determination of Volatile Methylsiloxanes in Solvent-Based 

Coatings, Inks, and Related Materials,” BAAQMD Manual of Procedures, 

Volume III, adopted 11/6/96 (see section 2, Volatile Organic Compound, 

and subsection 6.2). 

6.5.9 Exempt Compounds--Parachlorobenzotrifluoride (PCBTF): The 

exempt compound parachlorobenzotrifluoride, shall be analyzed as an 

exempt compound for compliance with section 6 by BAAQMD Method 41, 

“Determination of Volatile Organic Compounds in Solvent Based Coatings 

and Related Materials Containing Parachlorobenzotrifluoride,” BAAQMD

Manual of Procedures, Volume III, adopted 12/20/95 (see section 2, 

Volatile Organic Compound, and subsection 6.2).

6.5.10 Exempt Compounds: The content of compounds exempt under U.S. 

EPA Method 24 shall be analyzed by SCAQMD Method 303-91 (Revised 

1993), “Determination of Exempt Compounds,” SCAQMD Laboratory 

Methods of Analysis for Enforcement Samples (see section 2, Volatile 

Organic Compound, and subsection 6.2). 

6.5.11 VOC Content of Coatings: The VOC content of a coating shall be 

determined by U.S. EPA Method 24 as it exists in appendix A of 40 Code 

of Federal Regulations (CFR) part 60, “Determination of Volatile Matter 

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

Surface Coatings” (see subsection 6.2). 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-17 Sept - 07

6.5.12 Alternative VOC Content of Coatings: The VOC content of coatings 

may be analyzed either by U.S. EPA Method 24 or SCAQMD Method 

304-91 (Revised 1996), “Determination of Volatile Organic Compounds 

(VOC) in Various Materials,” SCAQMD Laboratory Methods of Analysis 

for Enforcement Samples (see subsection 6.2). 

6.5.13 Methacrylate Traffic Marking Coatings: The VOC content of 

methacrylate multicomponent coatings used as traffic marking coatings 

shall be analyzed by the procedures in 40 CFR part 59, subpart D, 

appendix A, “Determination of Volatile Matter Content of Methacrylate 

Multicomponent Coatings Used as Traffic Marking Coatings” (September 

11, 1998) (see subsection 6.4). 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

B-18 

 Table 1 

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Limits are expressed in grams of VOC per litera of coating thinned to the manufacturer’s maximum 

recommendation, excluding the volume of any water, exempt compounds, or colorant added to tint bases. 

“Manufacturer’s maximum recommendation” means the maximum recommendation for thinning that is 

indicated on the label or lid of the coating container. 

Coating Category Effective 1/1/2003 Effective 1/1/2004 

Flat Coatings 100 

Nonflat Coatings 150 

Nonflat - High Gloss Coatings 250 

Specialty Coatings

Antenna Coatings 530 

Antifouling Coatings 400 

Bituminous Roof Coatings 300 

Bituminous Roof Primers 350 

Bond Breakers 350 

Clear Wood Coatings 

• Clear Brushing Lacquers 

• Lacquers (including lacquer sanding 

sealers) 

• Sanding Sealers (other than lacquer 

sanding sealers) 

• Varnishes 

680 

550 

350 

350 

Concrete Curing Compounds 350 

Dry Fog Coatings 400 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Fire-Retardant Coatings: 

• Clear 

• Opaque 

650 

350 

Floor Coatings 250 

Flow Coatings 420 

Form-Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

B-19 

Table 1 Continued 

Coating Category Effective 1/1/2003 Effective 1/1/2004

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatingsb 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 300 

Metallic Pigmented Coatings 500 

Multi-Color Coatings 250 

Pre-Treatment Wash Primers 420 

Primers, Sealers, and Undercoaters 200 

Quick-Dry Enamels 250 

Quick-Dry Primers, Sealers, and Undercoaters 200 

Recycled Coatings 250 

Roof Coatings 250 

Rust Preventative Coatings 400 

Shellacs: 

• Clear 

• Opaque 

730 

550 

Specialty Primers, Sealers, and Undercoaters 350 

Stains 250 

Swimming Pool Coatings 340 

Swimming Pool Repair and Maintenance 

Coatings 

340 

Temperature-Indicator Safety Coatings 550 

Traffic Marking Coatings 150 

Waterproofing Sealers 250 

Waterproofing Concrete/Masonry Sealers 400 

Wood Preservatives 350 

a Conversion factor: one pound VOC per gallon (U.S.) = 119.95 grams VOC per liter. 

b Units are grams of VOC per liter (pounds of VOC per gallon) of coating, including water and exempt compounds. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-20 Sept - 07

APPENDIX A: 

AVERAGING PROVISION
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-21 Sept - 07

A. AVERAGING PROVISION

A.1 The manufacturer shall demonstrate that actual emissions from the coatings 

being averaged are less than or equal to the allowable emissions, for the 

specified compliance period using the following equation: 

 

∑ ≤

n

i = 1

GiMi

∑

n

i =1

GiViLi

Where: 

 ∑ = n

i =1

GiMi Actual Emissions

 ∑ = n

i =1

GiViLi AllowableEmissions

Vm

Vm Vw Vec Vi − − =

Coating VOC ( also known as VOC Regulatory )

Material VOC ( also known as VOC Actual) Vi =

For Zero VOC Coatings:

Vm

Ws Ww Wec Mi − − =

Vm - Vw - Vec

Ws- Ww - Wec Where : Coating VOC =

Mi Material VOC Content of Product (i), in pounds per gallon;

Gi Total Gallons of Product (i)subject to Averaging;

=

=

Vi = Percent by VolumeSolids and VOCin Product (i);

except that in this Appendix weights are in pounds and volumes are in gallons.

Where : Ws, Ww, Wec, Vm, Vw, and Vec are defined in subsection 6.1,

For Non - Zero VOC Coatings:

Li = Regulatory VOC Content Limit for Product (i), in pounds per gallon (aslisted in Table1)

Vi = Percent Solids by Volume
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-22 Sept - 07

The averaging is limited to coatings that are designated by the manufacturer. 

Any coating not designated in the averaging Program shall comply with the VOC 

limit in Table 1. The manufacturer shall not include any quantity of coatings that 

it knows or should have known will not be used in the State, if statewide coatings 

data are used. If district-specific coatings data are used, the manufacturer shall 

not include any quantity of coatings that it knows or should have known will not 

be used in the district. 

SCM Clarification - New Section “A.1.1” 

 (See June 7, 2001 letter to all districts by Mike Kenny, ARB Executive 

Officer) 

A.1.1 In addition to the requirements specified in subsection A.1, manufacturers 

shall not include in an Averaging Program any coating with a VOC 

content in excess of the following maximum VOC contents, for the 

applicable categories. 

Averaging Category VOC Limit (Li)1 

grams/liter 

Maximum 

VOC Content 

grams/liter 

Flat 100 250 

Nonflat (Excludes High 

Gloss) 

150 250 

Floor 250 400 

Industrial Maintenance 250 420 

Primer, Sealer, 

Undercoater 

200 350 

Quick Dry Primer, Sealer, 

Undercoater 200 450 

Quick Dry Enamel 250 400 

Roof 250 300 

Bituminous Roof 300 300 

Rust Preventative 400 400 

Stains 250 350 

Waterproofing sealers 250 400 

1. As listed in Table 1. Used when determining allowable emissions in 

subsection A.1. 

A.2 AVERAGING PROGRAM (PROGRAM)

At least six months prior to the start of the compliance period, manufacturers 

shall submit an Averaging Program to the Executive Officer of the Air Resources 

Board. As used in this Appendix A, “Executive Officer” means the Executive 

Officer of the Air Resources Board. Averaging may not be implemented until the 

Program is approved in writing by the Executive Officer. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-23 Sept - 07

Within 45 days of submittal of a complete Program, the Executive Officer shall 

either approve or disapprove the Program. The Program applicant and the 

Executive Officer may agree to an extension of time for the Executive Officer to 

take action on the Program. 

A.3 GENERAL REQUIREMENTS 

The Program shall include all necessary information for the Executive Officer to 

make a determination as to whether the manufacturer may comply with the 

averaging requirements over the specified compliance period in an enforceable 

manner. Such information shall include, but is not limited to, the following: 

 A.3.1 An identification of the contact persons, telephone numbers, and 

name of the manufacturer who is submitting the Program. 

 A.3.2 An identification of each coating that has been selected by the 

manufacturer for inclusion in this program that exceeds the applicable 

VOC limit in 

 Table 1, its VOC content specified in units of both VOC actual and 

 VOC regulatory, and the designation of the coating category. 

 A.3.3 A detailed demonstration showing that the projected actual emissions 

will not exceed the allowable emissions for a single compliance period 

that the Program will be in effect. In addition, the demonstration shall 

include VOC content information for each coating that is below the 

compliance limit in Table 1. The demonstration shall use the equation 

specified in subsection A.1 of this Appendix for projecting the actual 

emissions and allowable emissions during each compliance period. 

The demonstration shall also include all VOC content levels and 

projected volume within the State for each coating listed in the 

Program during each compliance period. The requested data can be 

summarized in a matrix form. 

 A.3.4 A specification of the compliance period(s) and applicable reporting 

dates. The length of the compliance period shall not be more than one 

year or less than six months. 

 A.3.5 An identification and description of all records to be made available to 

the Executive Officer upon request, if different than those identified 

under subsection A.3.6. 

 A.3.6 An identification and description of specific records to be used in 

calculating emissions for the Program and subsequent reporting, and 

a detailed explanation as to how those records will be used by the 

manufacturer to verify compliance with the averaging requirements. 

 A.3.7 A statement, signed by a responsible party for the manufacturer, that 

all information submitted is true and correct, and that records will be 

made available to the Executive Officer upon request. 

A.4 REPORTING REQUIREMENTS 

A.4.1 For every single compliance period, the manufacturer shall submit a 

mid-term report listing all coatings subject to averaging during the first 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-24 Sept - 07

half of the compliance period, detailed analysis of the actual and 

allowable emissions at the end of the mid-term, and an explanation as 

to how the manufacturer intends to achieve compliance by the end of 

the compliance period. The report shall be signed by the responsible 

party for the manufacturer, attesting that all information submitted is 

true and correct. The mid-term report shall be submitted within 45 

days after the midway date of the compliance period. A manufacturer 

may request, in writing, an extension of up to 15 days for submittal of 

the mid-term report. 

A.4.2 Within 60 days after the end of the compliance period or upon 

termination of the Program, whichever is sooner, the manufacturer 

shall submit to the Executive Officer a report listing all coatings 

subject to averaging during the compliance period, providing a 

detailed demonstration of the balance between the actual and 

allowable emissions for the compliance period, any identification and 

description of specific records used by the manufacturer to verify 

compliance with the averaging requirement, and any other information 

requested by the Executive Officer to determine whether the 

manufacturer complied with the averaging requirements over the 

specified compliance period. The report shall be signed by the 

responsible party for the manufacturer, attesting that all information 

submitted is true and correct, and that records will be made available 

to the Executive Officer upon request. A manufacturer may request, 

in writing, an extension of up to 30 days for submittal of the final 

report. 

A.5 RENEWAL OF A PROGRAM

A Program automatically expires at the end of the compliance period. The 

manufacturer may request a renewal of the Program by submitting a renewal 

request that shall include an updated Program, meeting all applicable Program 

requirements. The renewal request will be considered conditionally approved 

until the Executive Officer makes a final decision to deny or approve the renewal 

request based on a determination of whether the manufacturer is likely to comply 

with the averaging requirements. The Executive Officer shall base such 

determination on all available information, including but not limited to, the midterm and the final reports of the preceding compliance period. The 

Executive Officer shall make a decision to deny or approve a renewal request no 

later than 45 days from the date of the final report submittal, unless the 

manufacturer and the Executive Officer agree to an extension of time for the 

Executive Officer to take action on the renewal request. 

A.6 MODIFICATION OF A PROGRAM 

A manufacturer may request a modification of the Program at any time prior to 

the end of the compliance period. The Executive Officer shall take action to 

approve or disapprove the modification request no longer than 45 days from the 

date of its submittal. No modification of the compliance period shall be allowed. 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-25 Sept - 07

A Program need not be modified to specify additional coatings to be averaged 

that are below the applicable VOC limits. 

A.7 TERMINATION OF A PROGRAM 

A.7.1 A manufacturer may terminate its Program at any time by filing a written 

notification to the Executive Officer. The filing date shall be considered 

the effective date of the termination, and all other provisions of this rule 

including the VOC limits shall immediately thereafter apply. The 

manufacturer shall also submit a final report 60 days after the termination 

date. Any exceedance of the actual emissions over the allowable 

emissions over the period that the Program was in effect shall constitute a 

separate violation for each day of the entire compliance period. 

A.7.2 The Executive Officer may terminate a Program if any of the following 

circumstances occur: 

A.7.2.1 The manufacturer violates the requirements of the approved 

Program, and at the end of the compliance period, the actual 

emissions exceed the allowable emissions. 

A.7.2.2 The manufacturer demonstrates a recurring pattern of 

violations and has consistently failed to take the necessary 

steps to correct those violations. 

A.8 CHANGE IN VOC LIMITS

If the VOC limits of a coating listed in the Program are amended such that its 

effective date is less than one year from the date of adoption, the affected 

manufacturer may base its averaging on the prior limits of that coating until the 

end of the compliance period immediately following the date of adoption. 

A.9 LABELING

Each container of any coating that is included in averaging program, and that 

exceeds the applicable VOC limit in Table 1 shall display the following statement: 

"This product is subject to architectural coatings averaging provisions in 

California.” A symbol specified by the Executive Officer may be used as a 

substitute. 

A.10 VIOLATIONS 

The exceedance of the allowable emissions for any compliance period shall 

constitute a separate violation for each day of the compliance period. However, 

any violation of the requirements of the Averaging Provision of this rule, which 

the violator can demonstrate, to the Executive Officer, did not cause or allow the 

emission of an air contaminant and was not the result of negligent or knowing 

activity may be considered a minor violation. 

A.11 SUNSET OF AVERAGING PROVISION 
2000 SCM 

As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified 

in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive 

Officer. 

California Air Resources Board B-26 Sept - 07

The averaging provision set forth in Appendix A shall cease to be effective on 

January 1, 2005, after which averaging will no longer be allowed. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board Sept - 07 

APPENDIX C: 

AIR QUALITY STANDARDS AND 

NONATTAINMENT AREAS 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board Sept - 07 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-1 Sept - 07 

AIR QUALITY STANDARDS 

C.1. Current Ozone and Particulate Matter Standards 

To protect California’s population from the harmful effects of ozone and PM, 

federal and State air quality standards for these contaminants have been 

established. These standards are shown in Table C-1. 

The ARB adopted new PM standards in June of 2002, responding to 

requirements of the Children's Environmental Health Protection Act (Senate Bill 

25, Escutia 1999). This Act requires the evaluation of all health-based ambient 

air quality standards to determine if the standards adequately protect human 

health, particularly that of infants and children. The subsequent review of the PM 

standards resulted in the recommendation of more health-protective ambient air 

quality standards for PM10 and a new standard for PM2.5. The new PM standards 

became effective in 2003. 

For ozone, the ARB approved a new eight-hour standard of 0.070 ppm and 

retained the one-hour ozone standard of 0.09 ppm in April 2005. These updated 

standards resulted from an extensive review of the scientific literature, which 

indicated that significant harmful health effects could occur among both adults 

and children if exposed to levels above these standards. 

Table C-1 

Ambient Air Quality Standards for Ozone, PM10, and PM2.5

Pollutant Averaging Time State Standard National Standard 

1 Hour 0.09 ppm 

(180 μg/m3

) ---- 

Ozone 

8 Hour 0.070 ppm 

(137 μg/m3

) 

0.08 ppm 

(157 μg/m3) 

24 Hour 50 μg/m3

 150 μg/m3

PM10 Annual Arithmetic Mean 20 μg/m3 ---- 

24 Hour ---- 35 μg/m3

PM2.5 Annual Arithmetic Mean 12 μg/m3

 15 μg/m3

C.2. California Clean Air Act 

The California Clean Air Act (CCAA) was enacted in 1988 and has the 

fundamental goal that all areas of California are to attain the State ambient air 

quality standard for ozone by the earliest practicable date. The State eight-hour 

ozone standard is set by the ARB, and is more stringent than the federal eighthour ozone standard. As specified in the CCAA, the ARB has designated areas 

of California to be in “attainment” or “nonattainment” for the State ozone 

standard. Local districts that are nonattainment for the State ozone standard are 

required by the CCAA to prepare plans, which must be designed to achieve and 

maintain the standard by the earliest practicable date. In developing their plans 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-2 Sept - 07 

each district determines which measures are necessary to include, as well as the 

specific details of each included measure. 

C.3. Status of Air Quality – State Standards 

State law indicates that the California Legislature intends progress toward clean 

air to be made as quickly as possible. The CCAA specifically declares that it is 

the intent of the Legislature that the state air quality standards be achieved “...by 

the earliest practicable date...” (Health and Safety Code, sections 40910 and 

40913(a)). Unhealthy levels of ozone and PM are not limited to urban areas, but 

can be found in nearly every county in California as seen in Figures C-1, C-2, 

and C-3. These figures highlight areas that exceed the State ambient air quality 

standards (i.e. “nonattainment areas”). 

The 35 districts in California have air quality planning responsibilities. Of the 

35 districts, 30 are nonattainment for the State 1-hour/8-hour ozone standard, 

31 are nonattainment for the State 24-hour/annual PM10 standard, and 11 are 

nonattainment for the State annual PM2.5 standard. For the State ozone and 

PM10 standards, a district is designated “nonattainment” for ozone if it does not 

meet either the 1-hour or 8-hour standard and “nonattainment” for PM10 if it does 

not meet either the 24-hour or annual standard. Table C-2 lists the districts that 

have been designated “nonattainment” because they exceed State standards for 

ozone or PM. Of the 30 ozone nonattainment districts, all but eight already have 

an architectural coatings rule. These eight districts are the Great Basin Unified, 

Amador County, Calaveras County, Mariposa County, Tuolumne County, 

Northern Sierra, Siskiyou County, and Glenn County Districts. Some of these 

districts are impacted by upwind districts and will have no requirements to adopt 

an architectural coating rule based on the proposed SCM. Of the 31 PM10

nonattainment districts, all but ten have an architectural rule. These ten districts 

include the above eight ozone nonattainment districts with the exception of 

Amador County and Siskiyou County and the addition of the North Coast Unified, 

Mendocino County, Modoc County, and Lassen County Districts. The only PM2.5

nonattainment district without an architectural rule is the Northern Sierra AQMD. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-3 Sept - 07 

Figure C-1 

2006 Area Designations for State Ambient Air Quality Standard for Ozone 

(ARB, 2006b) 

Attainment

Unclassified

Nonattainment-Transitional

Nonattainment
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-4 Sept - 07 

Figure C-2 

2006 Area Designations for State Ambient Air Quality Standard for PM10

(ARB, 2006b) 

Attainment

Unclassified

Nonattainment-Transitional

Nonattainment
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-5 Sept - 07 

Figure C-3 

2006 Area Designations for State Ambient Air Quality Standard for PM2.5

(ARB, 2006b) 

Attainment

Unclassified

Nonattainment-Transitional

Nonattainment
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-6 Sept - 07 

Table C-2 

2006 State Nonattainment Areas for Ozone, PM10, and PM2.5

State 

Nonattainment 

Air Basin Air District County Ozone PM10 PM2.5

1 Great Basin Great Basin Unified Alpine X 

 Valley APCD Inyo X X 

 Mono X X 

2 Lake Tahoe 

Placer County 

APCD 

Placer (eastern 

portion) X 

 

El Dorado County 

AQMD 

El Dorado (eastern 

portion) X 

3 Mojave Desert 

Mojave Desert 

AQMD 

San Bernardino 

(central portion) X X X 

 Kern County APCD Kern (eastern portion) X X 

 South Coast AQMD 

Riverside (eastern 

portion) X X 

 

Antelope Valley 

AQMD 

Los Angeles (northeast 

portion) X X 

4 

Mountain 

Counties 

Amador County 

APCD Amador X 

 

Calaveras County 

APCD Calaveras X X 

 

Mariposa County 

APCD Mariposa X X2 

 

Tuolumne County 

APCD Tuolumne X 

 

El Dorado County 

AQMD 

El Dorado (western 

portion) X X 

 

Placer County 

APCD Placer (central portion) X X 

 Northern Sierra Nevada X X 

 AQMD Plumas X X4 

 Sierra X 

5 North Central Monterey Bay Santa Cruz X X 

 Coast Unified APCD Monterey X X 

 San Benito X X 

6 North Coast 

Northern Sonoma 

County APCD 

Sonoma (northern 

portion) X 

 North Coast Unified Del Norte X 

 AQMD Humboldt X 

 Trinity X 

 Mendocino AQMD Mendocino X 

7 

Northeast 

Plateau 

Siskiyou County 

APCD Siskiyou X 

 Modoc APCD Modoc X 

 Lassen APCD Lassen X 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-7 Sept - 07 

Table C-2 

2006 State Nonattainment Areas for Ozone, PM10, and PM2.5

State 

Nonattainment 

Air Basin Air District County Ozone PM10 PM2.5

8 Sacramento 

Butte County 

AQMD Butte X X X 

Valley Colusa County 

APCD Colusa X1 X 

 

Glenn County 

APCD Glenn X1 X 

 

Shasta County 

AQMD Shasta X X 

 

Feather River 

AQMD Sutter X X 

 Yuba X X 

 

Tehama County 

APCD Tehama X X 

 

Sacramento Metro 

AQMD Sacramento X X X 

 

Placer County 

APCD 

Placer (western 

portion) X X X 

 Yolo-Solano AQMD 

Solano (eastern 

portion) X X 

 Yolo X X 

9 Salton Sea South Coast AQMD 

Riverside (central 

portion) X X 

 

Imperial County 

APCD Imperial X X X3 

10 San Diego 

San Diego County 

APCD San Diego X X X 

11 San Francisco Bay Area AQMD Alameda X X X 

 Bay Area Contra Costa X X X 

 Marin X X X 

 Napa X X X 

 San Francisco X X X 

 San Mateo X X X 

 Santa Clara X X X 

 

Solano (western 

portion) X X X 

 

Sonoma (southern 

portion) X X X 

12 San Joaquin San Joaquin Valley Fresno X X X 

 Valley 5 APCD Kern (western portion) X X X 

 Kings X X X 

 Madera X X X 

 Merced X X X 

 San Joaquin X X X 

 Stanislaus X X X 

 Tulare X X X 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-8 Sept - 07 

Table C-2 

2006 State Nonattainment Areas for Ozone, PM10, and PM2.5

State 

Nonattainment 

Air Basin Air District County Ozone PM10 PM2.5

13 

South Central 

Coast 

San Luis Obispo 

County APCD San Luis Obispo X X 

 

Santa Barbara 

County APCD Santa Barbara X X 

 

Ventura County 

APCD 

Ventura (continental 

portion) X X X 

14 South Coast South Coast AQMD 

Los Angeles (western 

portion) X X X 

 Orange X X X 

 

Riverside (western 

portion) X X X 

 

San Bernardino 

(southwestern portion) X X X 

(ARB, 2006a; 2006b) 

1. Nonattainment-Transitional 

2. Yosemite National Park Only 

3. City of Calexico Only 

4. Portola Valley Only 

5. In April 2007, the Governing Board of the San Joaquin Valley Air District voted to ask the U.S. EPA to designate 

the air basin as “Extreme” nonattainment for ozone. This designation would create a deadline of 2024 for the 

basin to meet the federal 8-hour ozone standard. 

In many of the nonattainment districts, substantial additional emission reductions 

will be necessary in order to achieve and maintain the State ozone standard. 

The SCM will be available for adoption by the above districts in order to reduce 

VOC emissions and attain or maintain the State ozone and PM standards. 

C.3. Status of Air Quality – Federal Standards 

Federal law also indicates that the U.S. Congress intends progress toward clean 

air to be made as quickly as possible. The federal Clean Air Act declares that 

the federal air quality standards are to be achieved “...as expeditiously as 

practicable...” (Federal Clean Air Act, sections 172(a)(2), 181(a), and 188(c)). 

Thirty-five counties or portions of counties are designated as nonattainment for 

the federal 8-Hour Ozone standard with attainment dates ranging from 2007 to 

2021. Table C-3 lists the districts that have been designated “nonattainment” 

because they exceed federal standards for ozone. The San Joaquin Valley and 

South Coast air basins are expected to have until 2023 to attain the federal 

standard, by invoking the “bump-up” provision in the federal Clean Air Act. 

For particulate matter, the South Coast Air Basin and the San Joaquin Valley Air 

Basin are the only two areas in the State that exceed the annual federal PM 2.5 

standard. These areas are required by federal law to develop SIPs describing 

how they will attain the standards by 2015. The U.S. EPA further requires that all 

necessary emission reductions be achieved one calendar year sooner – by 2014 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-9 Sept - 07 

– in recognition of the annual average form of the standard. The Owens Valley is 

the only federal PM10 nonattainment area. It did not meet its December 31, 

2006 attainment date and must submit plan revisions by December 31, 2007 

detailing how it will reach attainment. 

Table C-3 

8-Hour Federal Ozone Nonattainment Areas 

Federal 

Nonattainment 

Area Air District County 

Federal 8-Hr 

Ozone 

Designation 

(Attainment 

Year) 

1 

Amador and 

Calaveras Counties Amador County APCD Amador 

Subpart 1 

(2009) 

(Central Mountain) Calaveras County 

APCD Calaveras 

2 Chico Butte County AQMD Butte 

Subpart 1 

(2009) 

3 Imperial County Imperial County APCD Imperial Marginal (2007)

4 

Kern County 

(Eastern Kern) Kern County APCD Kern (eastern portion) 

Subpart 1 

(2009) 

5 

Los Angeles South 

Coast Air Basin South Coast AQMD 

Los Angeles (western 

portion) 

Severe-17 

(2021) 

 Orange 

 

Riverside (western 

portion) 

 

San Bernardino 

(southwestern portion) 

6 

Los Angeles – San 

Bernardino Antelope Valley AQMD 

Los Angeles 

(northeastern portion) 

Moderate 

(2010) 

Counties (Western 

Mojave) Mojave Desert AQMD 

San Bernardino (central 

portion) 

7 

Mariposa and 

Tuolumne Counties Mariposa County APCD Mariposa 

Subpart 1 

(2009) 

 (Southern Mountain) 

Tuolumne County 

APCD Tuolumne 

8 

Nevada County 

(Western Part) Northern Sierra AQMD 

Nevada (western 

portion) 

Subpart 1 

(2009) 

9 

Riverside County 

(Coachella Valley) South Coast AQMD 

Riverside (central 

portion) Serious (2013) 

10 Sacramento Metro 

El Dorado County 

AQMD 

El Dorado (western 

portion) Serious (2013) 

 Placer County APCD Placer (western portion) 

 

Sacramento Metro 

AQMD Sacramento 

 Yolo-Solano AQMD Solano (eastern portion) 

 Yolo 

11 San Diego 

San Diego County 

APCD San Diego 

Subpart 1 

(2009) 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-10 Sept - 07 

Table C-3 

8-Hour Federal Ozone Nonattainment Areas 

Federal 

Nonattainment 

Area Air District County 

Federal 8-Hr 

Ozone 

Designation 

(Attainment 

Year) 

12 San Francisco Bay Bay Area AQMD Alameda 

Marginal 

(2007) 

 Area Contra Costa 

 Marin 

 Napa 

 San Francisco 

 San Mateo 

 Santa Clara 

 

Solano (western 

portion) 

 

Sonoma (southern 

portion) 

13 San Joaquin Valley San Joaquin Valley Fresno Serious (2013) 

 APCD Kern (western portion) 

 Kings 

 Madera 

 Merced 

 San Joaquin 

 Stanislaus 

 Tulare 

14 

Sutter County 

(Sutter Buttes) Feather River AQMD 

Sutter (Sutter Buttes 

portion) 

Subpart 1 

(2009) 

15 Ventura County Ventura County APCD 

Ventura (continental 

portion) 

Moderate 

(2010) 

15 Federal 

Nonattainment 

Areas 20 Air Districts 35 Counties 

(U.S. EPA, 2007) 

C.5. Improving Air Quality 

Over the past 40 years, air pollution control agencies in California have been 

working diligently to improve air quality. Much of the effort was directed towards 

the more traditional sources of air pollution such as mobile sources (e.g., cars, 

trucks, etc.) and stationary sources (e.g., factories, power plants, etc.) 

While there have been dramatic gains in reducing emissions from these 

traditional sources, there is a need for further reductions from other sources of 

emissions, including architectural coatings, to continue to make progress toward 

meeting the State and Federal ambient air quality standards and protecting the 

public health of California citizens. Emissions from all other sources, including 

architectural coatings, have become more significant as emissions from the 

traditional sources are further reduced. Therefore, the emissions from these 

sources must be evaluated for further reductions. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-11 Sept - 07 

Architectural coatings comprise an important source of emissions in California 

because they are widely distributed, emit VOCs when used, and contribute to the 

air pollution problem in California. Although each container of paint may seem to 

be a small source of emissions, when the total number of users in California is 

aggregated, the total VOC emissions become significant. Implementation of the 

proposed SCM will continue the progress toward meeting California’s air quality 

goals. 

C.6. State Implementation Plan Commitments 

For areas with unhealthy levels of air pollutants, clean air laws require districts to 

develop plans to describe how they will attain ambient air quality standards. 

The CCAA requires districts that have been designated nonattainment for the 

State ambient air quality standards to prepare and submit plans for attaining and 

maintaining the standards (see Health and Safety Code §40910 et seq.). 

In addition, the federal Clean Air Act requires that districts designated 

nonattainment for the federal ambient air quality standards prepare State 

Implementation Plans (SIPs) to demonstrate attainment with the federal 

standards. SIPs are a compilation of several documents, including new and 

previously submitted plans, programs (e.g., monitoring, modeling, permitting, 

etc.), district rules, State regulations and federal controls. State law makes ARB 

the lead agency for submittal of California’s SIPs. Local air districts and other 

agencies (e.g., Bureau of Automotive Repair) prepare SIP elements and submit 

them to ARB for review and approval. ARB forwards the compiled SIP revisions 

to U.S. EPA for approval. 

There are 15 non-attainment areas for the federal ozone standard and 2 nonattainment areas for the PM2.5 standard. For these areas, Ozone SIPs and 

PM2.5 SIPs must be adopted and sent to the U.S. EPA by June 2007 and 

April 2008, respectively. The SIPs must show how each area will attain the 

federal standards. To do this, the SIPs will identify the amount of emissions that 

must be reduced in each area to meet the standard and the emission controls 

needed to reduce the necessary emissions. Emission reductions from district 

rules, including architectural coatings rules, are an essential part of California’s 

effort to attain air quality standards for ozone. 

Six local air districts in two federal ozone nonattainment areas included control 

measures for architectural coatings in their draft or final 2007 Ozone SIPs. 

These districts are: 

• El Dorado AQMD1 • Sacramento Metropolitan AQMD1

• Feather River AQMD1 • San Joaquin Valley Unified APCD2

• Placer County APCD1 • Yolo-Solano AQMD1

1. The Sacramento Federal Ozone Nonattainment Area includes all of Sacramento and Yolo Counties, 

portions of Placer and El Dorado Counties, eastern Solano County and southern Sutter County. 

2. San Joaquin Valley Unified APCD adopted its ozone SIP in April 2007 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-12 Sept - 07 

Table C-4 lists the emission reduction commitments for architectural coatings in 

the draft or final 2007 Ozone SIPs for each district. 

Table C-4 

2007 Ozone SIP Commitments For VOC Emission Reductions 

From Architectural Coating Measures 

District Implementation 

Year 

2012 ROG 

Planning 

Inventory2

(tpd) 

Emission 

Reductions 

in 2012 

(tpd) 

% 

Reductions 

El Dorado County AQMD1 2012 0.38 0.06 16% 

Feather River AQMD Pre-2012 0.02 0.003 15% 

Placer County APCD3 2013 0.89 0.13 15% 

Sacramento Metropolitan AQMD 2012 4.12 0.62 15% 

San Joaquin Valley Unified APCD 2012 9.7 2.0 21% 

Yolo-Solano County AQMD 2011 0.96 0.14 15% 

TOTAL: 16.1 2.95 18% 

1. El Dorado County had not yet adopted the 2000 SCM limits at the time that the draft 2007 SIP was developed. 

Therefore, their SIP Commitment value is actually larger, but for the purpose of this table we are only including the 

2007 SCM commitment. 

2. The 2012 ROG Planning Inventory is based on ARB’s 2001 Architectural Coating Survey and does not reflect the 

data from ARB’s 2005 Architectural Coating Survey that was used to develop the proposed SCM. 

3. For Placer County, values represent the 2018 ROG Planning Inventory and the 2018 Emission Reductions. 

ARB staff believes that the proposed SCM will achieve reductions that are in line 

with emission reductions claimed by districts in their draft 2007 Ozone SIPs (see 

Table C-5). The proposed SCM is expected to achieve about a 28 percent 

emission reduction. The values in Table C-5 assume that the emissions from 

architectural coatings are approximately 95 tpd statewide, on an annual average 

basis, not including emissions from thinning and clean-up (ARB, 2006c). 

Statewide emissions are apportioned to districts, based on population. Districts 

outside of the South Coast AQMD represent 56% of the State’s population which 

corresponds to 53 tpd of VOC emissions from architectural coating usage. The 

South Coast AQMD is not expected to adopt the proposed SCM because its 

architectural coatings Rule 1113 includes VOC limits that are, in most cases, at 

least as stringent as the proposed SCM. Since the non-South Coast districts are 

the primary target for adoption of the SCM, we are only estimating emission 

reductions for those districts. The emission reductions from the SCM are 

estimated to be about 4.3 tpd for the six districts with SIP commitments and 

about 10.7 tpd from the remaining non-South Coast districts for a total estimated 

emission reduction of 15 tpd, in the non-South Coast AQMD portion of the State. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board C-13 Sept - 07 

Table C-5 

Comparison of Estimated Emission Reductions From the Proposed SCM 

and the 2007 Ozone SIP Commitments 

 [A] [B] [C] [D] [E] [F] 

 =[A]*[95 tpd] = [B]*[C] = [A]/[56%] =[E]*[15 tpd] 

Districts with 

SIP 

Commitments 

% of CA 

Population2

Emission 

Inventory 

(TPD in 

2004)3

SIP 

Commitment 

(%) 

SIP 

Commitment 

(TPD in 2004)

% of Total 

SCM 

Reductions 

Reductions 

From SCM 

(TPD in 2004)

El Dorado 

(part)1

0.50% 0.48 16% 0.08 0.89% 0.13 

Feather River 0.40% 0.38 15% 0.06 0.71% 0.11 

Placer County 0.80% 0.76 15% 0.11 1.43% 0.21 

Sacramento 

Metro 

3.70% 3.52 15% 0.53 6.61% 0.99 

San Joaquin 9.80% 9.31 21% 1.96 17.50% 2.63 

Yolo-Solano 0.90% 0.86 15% 0.13 1.61% 0.24 

TOTAL: 16.1% 15.3 2.9 4.3 

1. El Dorado County had not yet adopted the 2000 SCM limits at the time that the draft 2007 SIP was developed. 

Therefore, their SIP Commitment value includes reductions from the 2000 SCM and the proposed 2007 SCM. 

2. The “% of CA Population” may not represent the entire district population. For some districts in the Sacramento 

Nonattainment Area, only a portion of the district population is included for SIP planning purposes. 

3. Emission Inventory data are based on data from ARB’s 2005 Architectural Coating Survey. These data are for 

coatings only and do not include emissions from thinning solvents, cleanup solvents, or additives. 

REFERENCES 

Air Resources Board. The California Almanac of Emissions and Air Quality, 2006 

Edition. Online, Internet at http://www.arb.ca.gov/aqd/almanac/almanac.htm. 

2006. (ARB, 2006a) 

Air Resources Board. “Area Designations and Maps”. Online Internet at 

http://www.arb.ca.gov/regact/area06/adisor.pdf and 

http://www.arb.ca.gov/regact/area06/appc.pdf. September, 2006. (ARB, 2006b) 

Air Resources Board. “2005 Architectural Coatings Survey, Draft Report.” 

September, 2006. (ARB, 2006c) 

United States Environmental Protection Agency. “Classifications of 8-Hour 

Ozone Nonattainment Areas”. Online internet at 

http://www.epa.gov/air/oaqps/greenbk/gnc.html. August 16, 2007. 

(U.S. EPA, 2007) 

2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07

APPENDIX D: 

SUMMARY OF CURRENT VOC LIMITS 
2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07
California Air Resources Board D-1 

NOTE: This summary is provided for comparison purposes ONLY. Please refer to the official rule language for complianc

Table D-1: Summary of Architectural Coating Rules and VOC Limits1 in California

Agency 

U.S. 

EPA CARB Antelope 

Bay Area Butte Colusa

El 

Dorado

Feather 

River Imperial Kern Mojave Monterey

Northern 

Sonoma

Placer Sacra- mento San Diego San Joaquin

San 

Luis 

Obispo

Sa

Barb

Rule 

Reference 

63 FR 

176: 

48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426 485 218 442 67 4601 433 32

Adopted 

Sep 

98 

Jun 

77 Jul 97 Mar 78 

July 

79 1979 Sep 94

June 

91 Nov 82

Apr 

72 Feb 79 May 79 Apr-02 

Jun 

79 Dec 78

Nov 

77 Apr 91 Mar-02 Oct 

Last Amended 

Feb 

00 

Jun 

00 Mar-03 Nov 01 

Aug02 Jul-02 Sep 94 Nov-02 Feb-05 Sep- 06 Feb-03 Apr-02 Dec- 01 May- 01 Dec- 01 Oct-01 Nov

Antenna 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 53Anti-Fouling 450 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 40Anti-Graffiti 600 340 Bituminous Coatings and Mastics 500 Bituminous Roof Coatings 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 30Bituminous Roof Primers 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Bond Breakers 600 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Calcimine Recoaters 475 Chalkboard Resurfacers 450 Concrete Curing Compounds 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Concrete Curing Compounds for Roadways and Bridges Concrete Curing and Sealing Compounds 700 Concrete Protective 400 Concrete Surface Retarders 780 Conversion Varnishes 725 Dry Fog 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 40Extreme High Durability 800 Faux Finishing/ Glazing (Japans) 700 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35
California Air Resources Board D-2 

Table D-1: Summary of Architectural Coating Rules and VOC Limits1 in California

Agency 

U.S. 

EPA CARB Antelope 

Bay Area Butte Colusa

El 

Dorado

Feather 

River Imperial Kern Mojave Monterey

Northern 

Sonoma

Placer Sacra- mento San Diego San Joaquin

San 

Luis 

Obispo

Sa

Barb

Rule 

Reference 

63 FR 

176: 

48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426 485 218 442 67 4601 433 32

Fire Proofing, Exterior Fire Resistive 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Fire Retardant, Clear 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 65Fire Retardant, Opaque (Pigmented) 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Fire Retardant/ Resistive, Clear 850 Fire Retardant/ Resistive, Opaque 450 Flats 250 100 100 100 100 100 (250)2 100 100 100 100 100 100 100 100 100 100 100 10Flats, Specialty 400 Floor 400 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 25Flow 650 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 42Form Release Compounds 450 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 25Graphic Arts (Sign Paints) 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 50Heat Reactive 420 High Temperature Industrial Maintenance 420 High Temperature 650 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 42Impacted Immersion 780 Industrial Maintenance 450 250 250 250 250 250 420 250 250 250 250 250 250 250 250 250 250 250 25Lacquers, Clear Brushing 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 68Lacquers, Clear or Opaque/ Pigmented (including clear lacquer sanding sealers) 680 550 550 550 550 550 680 550 550 550 550 550 550 550 550 550 550 550 55Low Solids Coatings1 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 12Low Solids Stains1 120 120 Low Solids 120 120 
California Air Resources Board D-3 

Table D-1: Summary of Architectural Coating Rules and VOC Limits1 in California

Agency 

U.S. 

EPA CARB Antelope 

Bay Area Butte Colusa

El 

Dorado

Feather 

River Imperial Kern Mojave Monterey

Northern 

Sonoma

Placer Sacra- mento San Diego San Joaquin

San 

Luis 

Obispo

Sa

Barb

Rule 

Reference 

63 FR 

176: 

48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426 485 218 442 67 4601 433 32

Wood Preservatives1Magnesite Cement 600 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 45Mastic Texture 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 30Metallic Pigmented 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 50Multi-Color 580 250 250 250 250 250 420 250 250 250 250 250 250 250 250 250 250 250 25Nonferrous Ornamental Metal Lacquers and Surface Protectants 870 Nonflat Coatings 380 150 150 150 150 150 (250) 2 150 150 150 150 150 150 150 150 150 150 150 15Nonflat High Gloss Coatings 250 250 250 250 250 (250) 2 250 250 250 250 250 250 250 250 250 250 250 25Nuclear 450 Pre-Treatment Wash Primers 780 420 420 420 420 420 675 420 420 420 420 420 420 420 420 420 420 420 42Primers and Undercoaters 350 Primers, Sealers, and Undercoaters 200 200 200 200 200 350 200 200 200 200 200 200 200 200 200 200 200 20Quick Dry Enamels 450 250 250 250 250 250 400 250 250 250 250 250 250 250 250 250 250 250 25Quick Dry Primers, Sealers, and Undercoaters 450 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 20Recycled Coatings 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 25Repair and Maintenance Thermoplastic 650 Roof 250 250 250 250 250 250 300 250 250 250 250 250 250 250 250 250 250 250 25Roof, Aluminum Rust Preventative 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 40Sanding Sealers Sanding Sealers (NonLacquer) 550 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Sealers 400 
California Air Resources Board D-4 

Table D-1: Summary of Architectural Coating Rules and VOC Limits1 in California

Agency 

U.S. 

EPA CARB Antelope 

Bay Area Butte Colusa

El 

Dorado

Feather 

River Imperial Kern Mojave Monterey

Northern 

Sonoma

Placer Sacra- mento San Diego San Joaquin

San 

Luis 

Obispo

Sa

Barb

Rule 

Reference 

63 FR 

176: 

48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426 485 218 442 67 4601 433 32

(including interior clear wood sealers) Shellacs, Clear 730 730 730 730 730 730 730 730 730 730 730 750 730 730 730 730 730 730 73Shellacs, Opaque/ Pigmented 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 55Specialty Primers Specialty Primers, Sealers, and Undercoaters 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Stains 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 25Stains, Clear 550 Stains, Exterior Stains, Interior Stains, Semitransparent 550 350 Stains, Opaque 350 350 Stain Controllers 720 Swimming Pool 600 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 34Swimming Pool Repair & Maintenance 340 340 340 340 340 650 340 340 340 340 340 340 340 340 340 340 340 34TemperatureIndicator Safety 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 55Thermoplastic Rubber and Mastics 550 Traffic 150 150 150 150 150 150 250 150 150 150 150 150 150 150 150 150 150 150 15Varnishes 450 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Waterproofing Sealers 250 250 250 250 250 400 250 250 250 250 250 250 250 250 250 250 250 25Waterproofing Concrete/ Masonry Sealers 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 40Water Proofing Sealers and Treatments 600 
California Air Resources Board D-5 

Table D-1: Summary of Architectural Coating Rules and VOC Limits1 in California

Agency 

U.S. 

EPA CARB Antelope 

Bay Area Butte Colusa

El 

Dorado

Feather 

River Imperial Kern Mojave Monterey

Northern 

Sonoma

Placer Sacra- mento San Diego San Joaquin

San 

Luis 

Obispo

Sa

Barb

Rule 

Reference 

63 FR 

176: 

48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426 485 218 442 67 4601 433 32

Water Proofing Sealers and Treatments, Opaque 600 Wood Preservatives 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 35Wood Preservatives, Below Ground 550 350 Wood Preservatives, Clear and Semitransparent 550 350 Wood Preservatives, Opaque 350 350 Zinc Rich Industrial Maintenance Primers Zone Marking 450 

Notes: 1. Volatile Organic Compound (VOC) limits are expressed as “VOC Regulatory” or “Coating VOC” (grams of VOC per liter of coating, less water a

categories except Low Solids. The VOC limit for Low Solids is expressed as VOC Actual or Material VOC (grams VOC per liter of coating, inclu

compounds) 

2. Parentheses indicate 250 g/l VOC limits that are based on El Dorado’s default provision, but the limits are not specifically stated in the rule. 

3. The South Coast AQMD Rule 1113 VOC limit for Flat coatings becomes effective on 7/1/08. Rule 1113 allows for the use of tertiary Butyl Acet

the 100 g/l VOC limit for the Industrial Maintenance category only. 

4. The EPA rule states that if a coating is not included in their table of VOC limits, it is classified as either a Flat (250 g/l) or Nonflat (380 g/l) based 

The ARB 2000 SCM and many district rules state that, if a coating is not included in their table of VOC limits, it is classified as either a Flat (100 

the gloss level. 

5. California districts not mentioned in this table are subject to the VOC limits in the U.S. EPA National Architectural Coating Rule 

2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

APPENDIX E: 

EMISSION REDUCTION CALCULATION METHODOLOGY 
2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-1 Sept - 07 

Emission Reduction Calculations 

ARB staff estimated emission reductions based on 2004 sales data, as reported 

in the 2005 Survey. For each category with a proposed reduction in VOC limit, 

ARB staff calculated the expected emission reductions for each product that was 

reported in that category. For each reported product in the survey, 

[Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions] 

where 

“Pre-Limit Emissions” are calculated directly from survey data for each product, 

as reported 

“Post-Limit Emissions” are estimates based on the potential impact of the lower 

VOC limit 

ARB staff used the following assumptions and protocols to perform emission 

reduction calculations: 

• When estimating “Post-Limit Emissions”, we assumed that the volume 

percent of solids remained constant for each product after it was 

reformulated to meet the proposed VOC limit. 

• When estimating “Post-Limit Emissions”, we assumed that the sales 

volume remained constant for each product after it was reformulated to 

meet the proposed VOC limit. 

• When estimating “Post-Limit Emissions”, we assumed a portion of the 

VOC in each product was replaced by either water or exempt compounds 

after the product was reformulated to meet the proposed VOC limit. 

• If a product was included in an averaging program and had a high VOC 

content that exceeded the limit in the 2000 SCM, we did not calculate 

emission reductions from the product’s high VOC content. For high-VOC 

products in averaging programs, we only calculated emission reductions 

from the VOC limit in the 2000 SCM down to the proposed VOC limit. 

• If a product was noncompliant and had a high VOC content that exceeded 

the limit in the 2000 SCM, we did not calculate emission reductions from 

the product’s high VOC content. For high-VOC noncompliant products, 

we only calculated emission reductions from the VOC limit in the 2000 

SCM down to the proposed VOC limit. 

• If a product was “overcompliant” and had a low VOC content that was 

below the limit in the 2000 SCM, but above the proposed limit, we only 

calculated emission reductions from the product’s actual VOC content 

down to the proposed VOC limit. 

• If a product was “overcompliant” and had a low VOC content that was 

already below the proposed limit, no emission reductions were calculated. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-2 Sept - 07 

• Emission reductions were only calculated for products sold in large 

containers (greater than one liter), because small containers (one liter or 

less) are exempt from the SCM VOC limits. 

The next section of this appendix contains a document with a detailed 

explanation of the methodology that was used to calculate emissions and 

emission reductions. 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-3 Sept - 07 

NOTE: The following document was submitted to the United States 

Environmental Protection Agency in December, 2005, in response to a request 

for comments regarding emission reduction calculations methods. This 

document describes ARB’s recommended methodology for calculation of 

emission reductions. 

California Air Resources Board (ARB) Comments 

Reference: Federal Register, Vol. 70, No. 168, August 31, 2005, U.S. 

Environmental Protection Agency (U.S. EPA), “Advance Notice to Solicit 

Comments, Data and Information for Determining the Emissions Reductions 

Achieved In Ozone Nonattainment and Maintenance Areas From the 

Implementation of Rules Limiting the VOC Content of AIM Coatings” (i.e., ANPR) 

Background: U.S. EPA is soliciting comments, data and information for 

determining how to calculate the reductions in volatile organic compound (VOC) 

emissions achieved in ozone nonattainment and maintenance areas from the 

implementation of rules which limit the VOC content of architectural coatings 

(commonly referred to as architectural and industrial maintenance, or AIM, 

coatings). In response to the ANPR, ARB is submitting a recommended 

methodology that is detailed below. 

ARB’s Recommended Methodology for Calculating Emission Reductions 

ARB has completed seven surveys of AIM coatings sold in California, and we are 

currently working on our eighth AIM survey. A summary of the surveys is 

provided below: 

Surveyed 

Calendar 

Year 

Sales 

Volume 

(gallons) 

VOC 

Emissions 

(pounds) 1

VOC Emissions 

per Gallon Sold 

(lb VOC/gal) 

1975 48,206,000 82,417,000 1.71 

1980 57,247,000 91,949,000 1.61 

1984 58,481,000 97,718,000 1.67 

1988 77,876,000 84,124,000 1.08 

1990 77,056,000 77,236,000 1.00 

1996 87,496,000 72,594,000 0.83 

2000 98,455,172 80,104,000 0.81 

2004 In progress - - 

1. Emissions do not include emissions from thinning and cleanup solvents. 

The most recent three surveys have collected particularly detailed data, 

including: VOC ingredient weight percentages; VOCACTUAL (a.k.a., Material 

VOC); VOCREGULATORY (a.k.a., Coating VOC); and Volume Percent Solids. ARB 

and the local air districts have used this survey data to characterize specific 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-4 Sept - 07 

coating categories and conduct detailed analyses of the impacts that may result 

from lower VOC limits. 

Based on our experience, we believe that the methodology for calculating 

emission reductions is dependent upon the type of data that are available to 

support the calculation. If detailed survey data are available that include specific 

product information, a detailed analysis of potential reductions can be conducted 

for each product. If no detailed data are available, it will be necessary to use a 

more general approach that relies on emission factors and estimated product 

parameters, as illustrated in the following table. 

AVAILABLE DATA EMISSION REDUCTION 

CALCULATION METHOD 

Option 

1: 

Detailed Product Information is 

Available, Including: 

• VOCACTUAL

• VOCREGULATORY

• Volume % Solids 

• Sales Volume 

Calculate potential emission 

reductions for each reported 

product in each coating 

category. 

Option 

2: 

Only General Data are Available: 

• e.g., Nationwide Sales and 

Population 

Calculate overall emission 

reductions for entire coating 

category. 

Each of these approaches is discussed below. 

Option 1: Detailed Emission Inventory

Step 1: Identify the available data.

Conducting a survey of coating manufacturers is one of the best ways to collect 

detailed data on the AIM coatings being sold in the area of concern. It is 

important that survey data be representative of the geographic area and the 

appropriate VOC limits. For example, the most recent survey data from 

California may not be representative of coatings that are being sold elsewhere in 

the United States, because California’s longstanding VOC limits have been 

generally lower than those in other states. In addition, coatings that have high 

sales volumes in California may have lower sales volumes in other parts of the 

country. 

Available data should include a detailed survey with the following information for 

each reported AIM product: 

• VOCACTUAL (Material VOC) 

• VOCREGULATORY (Coating VOC) 

• Volume % Solids 

• Sales Volume (gallons) 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-5 Sept - 07 

Step 2: Calculate emission reductions for each product. (see Appendix for 

details)

Emission reductions represent the difference between the VOC emissions before 

a limit is adopted and the emissions after a limit is adopted. 

For each reported product in the survey, 

[Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions] 

“Pre-Limit Emissions” can be calculated directly from survey data for each 

product: 

[Pre-Limit Emissions, lbs VOC] = [VOCACTUAL, lb VOC/gal coating]*[Sales 

Volume, gals coating] 

“Post-Limit Emissions” are estimates based on the potential impact of the lower 

VOCREGULATORY limit. When the VOCREGULATORY limit is lowered, some coatings 

will need to be reformulated and, consequently, they will have a new VOCACTUAL

value. It’s possible to predict a new VOCACTUAL value using the following 

equation: 

[NEW VOCACTUAL] = [Avg. VOC Density, g/l]*[VOCREGULATORY Limit, g/l]*[Vol. % Solids] 

 ([Avg. VOC Density, g/l]-[VOCREGULATORY Limit, g/l]) 

where 

Average VOC Density = 880 grams/liter 

VOCREGULATORY Limit = New VOCREGULATORY Limit, grams/liter 

Vol. % Solids = Volume Percent Solids, as reported for each product 

[Post-Limit Emissions, lbs VOC] = [NEW VOCACTUAL, lb VOC/gal coating]*[Sales 

Volume, gals coating] 

Calculation of the predicted new VOCACTUAL is based on the following 

assumptions: 

• Maintain constant Volume % Solids. 

It is assumed that the volume percentage of solids in the reformulated 

coating will be the same as the volume percentage of solids for the 

coating reported in the survey. When analyzing our survey data, we 

have not found a linear correlation between VOCACTUAL values and 

volume percentage of solids. This is illustrated in Figure 1, a scatter 

diagram that shows volume percentage of solids vs. VOCACTUAL

content for Flat and Nonflat architectural coatings. Therefore, we see 

no need to adjust solids contents when analyzing the effects of lower 

VOC limits. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-6 Sept - 07 

Because we are assuming the volume percentage of solids remains 

constant in the coatings, we use the reported volume of coatings when 

estimating the “Post-Limit Emissions”. There is no need to adjust the 

reported volume up or down to account for the same amount of overall 

solids being applied to surfaces. 

• Maintain constant sales volume. 

As just mentioned, it is assumed that the volume of reformulated 

coating will be the same as the volume of existing coatings reported in 

the survey. However, some have argued that this approach 

underestimates future sales volume, because they believe it takes 

more low-VOC waterborne coating (e.g., 90%-100% more) to provide 

the same amount of hiding power as a high-VOC solventborne coating. 

A gallon of waterborne coating generally contains a lower volume 

percentage of solids than a gallon of solventborne coating, and it is 

assumed that less solids means less hiding power. ARB recently 

sponsored a research project that disproves this claim. The project 

tested the hiding properties of ten solventborne coatings and twenty 

waterborne coatings by determining the quantity of coating that was 

required to provide equivalent hiding. On average, it took 

approximately 1.3 gallons of waterborne coating and 1.1 gallons of 

solventborne coating, a difference of only 18%, to provide equivalent 

hiding when painting a typical room. (Incidentally, the waterborne 

coating only emitted an average of 0.3 lbs of VOCs, while the 

solventborne coating emitted 2.9 lbs of VOCs.) Therefore, we believe 

this study also supports our assumption to keep the coating volume 

constant. Some results from this research project are provided in 

Figure 2, which contains graphs that illustrate the gallons of coating 

required to provide hiding vs. VOC content. 

• Assume a portion of the VOC in the product is replaced by either 

water or exempt compounds to meet the new VOCREGULATORY limit. 

Step 3: Determine Overall Emission Reduction Percentage. 

After emission reductions are calculated for each product, add up the individual 

reductions to determine the overall emission reduction percentage: 

[% Reduction] = ([Total Pre-Limit Emissions] – [Total Post-Limit Emissions]) 

 [Total Pre-Limit Emissions] 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-7 Sept - 07 

Figure 1: Volume % Solids vs. VOCACTUAL* 

FLATS

[Volume % Solids] vs. [VOCACTUAL]

0

10

20

30

40

50

60

70

80

90

100

0 20 40 60 80 100 120 140 160 180

VOCACTUAL (g/l)

Volume % Solids

NONFLATS - HIGH, MEDIUM & LOW GLOSS

[Volume % Solids] vs. [VOCACTUAL]

0

10

20

30

40

50

60

70

80

90

100

0 50 100 150 200 250 300

VOCACTUAL (g/l)

Volume % Solids

*Data obtained from ARB 2001 Architectural Coating Survey. 

 Note: Charts do not include coatings with VOCREGULATORY greater than 250 g/l. 
2007 ARB SCM 

California Air Resources Board E-8 

Figure 2: Gallons of Coating Required to Provide Adequate Hiding When Painting a Typical Roo

Architectural Coatings - WATERBORNE

[Gallons to Hide] vs. [VOCACTUAL]

0.81.01.21.41.61.8

0 20 40 60 80 100 120

VOCACTUAL (g/l)

Gallons of Coating to Hide 352 square feet

Architectural Coatings - SOLVENTBORN

[Gallons to Hide] vs. [VOCACTUAL]

0.81.01.21.41.61.8

0 50 100 150 200 250 

VOCACTUAL (g/l)

Gallons of Coating to Hide 352 square feet

Architectural Coatings - WATERBORNE

[Gallons to Hide] vs. [VOCREGULATORY]

0.81.01.21.41.61.8

0 50 100 150 200 250

VOCREGULATORY (g/l)

Gallons of Coating to Hide 352 square feet

Architectural Coatings - SOLVENTBORN

[Gallons to Hide] vs. [VOCREGULATORY]

0.81.01.21.41.61.8

0 50 100 150 200 250 

VOCREGULATORY (g/l)

Gallons of Coating to Hide 352 square feet

* Dimensions of a typical room are 10 ft. x 12 ft. with an 8-foot ceiling (352 sq. ft.) Data obtained from: Censullo, A.C., D.R. Jones, M.T. Wills, “Correlation 

Hiding as it Relates to Calculation of VOC Content in Architectural Coatings”, Table 14, dated December 2004. 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-9 Sept - 07 

Option 2: General Emission Inventory

Step 1: Identify the available data.

If detailed local survey data are not available, emission reductions can be estimated 

using general publicly-available information. At a minimum, the available data should 

include the following, both of which can be obtained from the U.S. Census website: 

• Nationwide Sales Volume 

• Population or Housing Unit Data (state and national) 

Nationwide coating sales volume can be obtained from the following report that is 

available on the U.S. Census website: 

• Current Industrial Report, MA325F – Paint and Allied Products 

http://www.census.gov/industry/1/ma325f04.pdf

(Note: When using this report, AIM coatings include those titled “Architectural 

Coatings”, “Industrial New Construction and Maintenance Paints”, and “Traffic 

Marking Paints”.) 

After using the Current Industrial Report to identify total AIM sales nationwide, it’s 

possible to assign a portion of the nationwide sales to an individual state, by using the 

state’s percentage of national population or housing units. Population data and housing 

unit data can be found on the following U.S. Census website: 

• http://www.census.gov/popest/states/tables/NST-EST2003-01.pdf 

http://factfinder.census.gov/home/saff/main.html

Step 2: Determine appropriate emission factors. 

Use an emission factor based on pounds VOC emitted per gallon of coating 

(i.e., VOCACTUAL.) ARB Architectural Coating Surveys can be used to identify salesweighted average values for VOCACTUAL in various categories. Survey reports are 

readily available online which include data summaries for coating sales that occurred 

during calendar years 1990, 1996, and 2000. For some categories, the types of 

coatings that were reported in older ARB surveys may be similar to the types of 

coatings being sold currently in other states where VOC limits are higher. However, it is 

important to note that coatings sold in California have historically been subject to more 

stringent VOC limits than coatings sold elsewhere in the United States. For example, in 

1990, Nonflat architectural coatings in California were being regulated with a 250 g/l 

VOC limit. This limit is significantly lower than the 380 g/l VOC limit that was adopted 

under the U.S. EPA’s 1998 National Volatile Organic Compound Emission Standards 

for Architectural Coatings, which is currently in place in much of the U.S. Due to these 

differences, emission factors based on California survey data may be lower than the 

appropriate factors for other areas of the United States. Alternatively, the summary 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-10 Sept - 07 

table on page 1 of this document can be used to estimate an overall emission factor for 

architectural coatings. 

ARB staff do not recommend using ARB’s on-line emission inventory data to determine 

emission factors on a per capita basis. This data incorporates highly localized 

information that may not be appropriate for other areas. For example, the growth 

percentages that are used to develop emission forecasts are specific to different 

California county government organizations. In addition, California has 35 air districts 

and these districts can have different architectural coating regulations, which result in 

different control factors within the emissions inventory. Air districts in California can 

have one of the following three types of architectural coating rules: (1) A rule that is 

based on ARB’s 2000 Suggested Control Measure; (2) U.S. EPA’s 1998 National 

Volatile Organic Compound Emission Standards for Architectural Coatings; or (3) the 

South Coast Air Quality Management District’s Rule 1113. For these reasons and 

others, we believe that statewide survey data from actual survey reports are the best 

source of information when trying to develop general emission factors. 

Step 3: Determine appropriate control factors. 

The supporting documentation for architectural coating regulations will usually contain 

the expected percent reduction in VOC emissions that will result when the regulation is 

implemented (i.e., the control factor.) Sources of control factors include the following: 

• ARB Staff Report for the Proposed Suggested Control Measure for 

Architectural Coatings, Executive Summary; June 6, 2000; 

http://www.arb.ca.gov/coatings/arch/sreport/vol1-2.pdf

• South Coast Air Quality Management District Rule 1113, amendments 

adopted on: Nov. 8, 1996; May 14, 1999; and Dec. 5, 2003. SCAQMD staff 

reports are available at http://www.aqmd.gov

It is also possible to estimate control factors, using a variation of the method discussed 

previously in Option #1 and the following equations: 

[Control Factor, %] = [Pre-Limit VOCACTUAL, g/l]-[NEW VOCACTUAL, g/l] 

 [Pre-Limit VOCACTUAL, g/l] 

where 

Pre-Limit VOCACTUAL, g/l = The VOCACTUAL value for a typical coating, prior to adoption 

of a new limit. In some cases, sales-weighted average VOCACTUAL

values can be obtained from ARB survey reports. However, it is 

important to note that the ARB values may be lower than those 

found in other parts of the United States. 

[NEW VOCACTUAL] = [Avg. VOC Density, g/l]*[VOCREGULATORY Limit, g/l]*[Vol. % Solids] 

 ([Avg. VOC Density, g/l]-[VOCREGULATORY Limit, g/l]) 
 2007 ARB SCM for Architectural Coatings 

California Air Resources Board E-11 Sept - 07 

Average VOC Density = 880 grams/liter 

VOCREGULATORY Limit = New VOCREGULATORY Limit, grams/liter 

Vol. % Solids = Volume Percent Solids, % for a typical coating. In some cases, 

sales-weighted average Volume % Solids values can be obtained from ARB survey 

reports. However, it is important to note that the ARB values may be different than 

those found in other parts of the United States. 

Step 4: Calculate overall emission reductions. 

Determine potential emission reductions (see Appendix for details.) 

For the entire inventory, 

[Emission Reductions, lbs] = [Coating Sales, gals]*[Emission Factor, lb/gal]*[Control 

Factor, %] 

Conclusion: ARB staff believes that the methodology that is used for calculation of 

emission reductions for AIM coatings should be flexible enough to accommodate the 

type of data that are available to support the analysis. It is unlikely that there is one 

method that will be suitable for all regions of the country, because the types of coatings 

and the available data vary widely depending on location. Therefore, we encourage 

U.S. EPA to develop guidance on this topic that gives states and regions the flexibility to 

account for these differences, rather than adopting a rule that would result in a 

prescriptive approach. 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-12 Sept - 07 

This Appendix contains detailed emission reduction calculations, based on the 

two approaches discussed in the main document. 

Option 1: Detailed Emission Inventory

Step 1: Identify the available data.

Product VOCACTUAL

(g/l) 

VOCREGULATORY

(g/l) 

Volume % 

Solids 

Sales Volume 

(gals) 

#1 78 190 33% 10,000 

#2 110 220 39% 7,500 

#3 350 350 55% 5,000 

#4 55 140 34% 2,500 

Step 2: Calculate emission reductions for each product. 

Eqn. 1: [Pre-Limit Emissions, lbs VOC] = [VOCACTUAL, lb VOC/gal 

coating]*[Sales Volume, gals coating] 

Eqn. 2: [NEW VOCACTUAL, g/l] = [Dvoc, g/l]*[VOCREGULATORY Limit, g/l]*[Vs] 

 ([Dvoc, g/l]-[VOCREGULATORY Limit, g/l]) 

where 

Dvoc = Average VOC Density, which is assumed to be approximately 880 

grams/liter 

VOCREGULATORY Limit = New VOCREGULATORY Limit, grams/liter 

Vs = Volume Percent Solids, % 

To convert from units of (grams/liter) to (lbs/gal): 

[VOCACTUAL, lbs VOC] = [VOCACTUAL, grams VOC] * [1 lb VOC] * [3.785 liters coating]

gal coating liter coating [454 grams VOCi [1 gal coating]

Eqn. 3: [Post-Limit Emissions, lbs VOC] = [NEW VOCACTUAL, lb VOC/gal]*[Sales 

Volume, gals coating] 

Eqn.4: [Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions] 

Example Calculation for Product #1: 

[Pre-Limit Emissions] = [78 grams/liter]*[1 lb/454 grams]*[3.785 

liters/gal]*[10,000 gals] = 6,503 lbs VOC 

Assume the New VOCREGULATORY Limit is 150 g/l. 

[NEW VOCACTUAL] = [880 g/l]*[150 g/l]*[33%] = 60 g/l 

 ([880 g/l]-[150 g/l]) 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-13 Sept - 07 

[Post-Limit Emissions] = [60 g/l]*[1 lb/454 grams]*[3.785 liters/gallon]*[10,000 

gals] = 5,002 lbs VOC 

[Emission Reductions] = [6,503] – [5,002] = 1,501 lbs VOC 

A summary of the emission reduction calculations for Products #1- #4 is 

provided below. All products are in the same coating category with a new 

VOCREGULATORY Limit of 150 g/l. 

Product Pre-Limit 

Emissions 

(lbs VOC) 

NEW 

VOCACTUAL

(g/l) 

Post-Limit 

Emissions 

(lbs VOC) 

Emission 

Reduction 

(lbs VOC) 

#1 6,503 60 5,002 1,501 

#2 6,878 71 4,440 2,438 

#3 14,590 100 4,169 10,421 

#4 1,146 

No reductions were calculated 

for Product #4, because it 

already complied with the new 

VOCREGULATORY limit. 0 

TOTAL: 29,117 14,360 

Step 3: Determine Overall Emission Reduction Percentage. 

For these four products, the overall emission reduction percentage: 

[% Reduction] = ([29,117] – [14,360]) = 51% 

 [29,117] 

Option 2: General Emission Inventory

Step 1: Identify the available data.

For example, the following table illustrates how to estimate coating usage data 

for Arizona: 

 United States Arizona 

Population in 2004 285,691,501 5,633,997 

(2% of United States) 

Housing Units 122,671,734 2,458,231 

(2% of United States) 

Sales Volume: 

Architectural Coatings 822,186,000 gals 16,443,720 gals 

Industrial New Construction and 

Maintenance Paints - Interior 22,492,000 gals 449,840 gals 

Industrial New Construction and 

Maintenance Paints - Exterior 35,167,000 gals 703,340 gals 

Traffic Marking Paints 35,907,000 gals 718,140 gals 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-14 Sept - 07 

Step 2: Determine appropriate emission factors. 

Category 

Emission 

Factors*, based 

on 1990 sales 

(lb VOC/gal) 

Emission 

Factors*, based 

on 1996 sales 

(lb VOC/gal) 

Architectural Coatings 0.93 0.74 

Industrial New Construction 

and Maintenance Paints – 

Interior & Exterior 2.86 2.43 

Traffic Marking Paints 0.90 0.93 

*Emission factors are based on data reported in ARB Architectural Coating surveys and they do not 

 include emissions from the use of thinning and cleanup solvents. 

Example emission calculations are provided below, using emission factors based 

on ARB 1996 data: 

Category Example Emissions Calculations 

Architectural Coatings 

[16,443,720 gals]*[0.74 lb/gal] = 

12,168,353 lbs 

Industrial New Construction 

and Maintenance Paints – 

Interior & Exterior 

[449,840+703,340 gals]*[2.43 lb/gal] = 

2,802,227 lbs 

Traffic Marking Paints [718,140 gals]*[0.93 lb/gal] = 667,870 lbs 

Total Pre-Limit Emissions = 12,168,353 + 2,802,227 + 667,870 lbs = 

15,638,450 lbs emitted 

Step 3: Determine appropriate control factors. 

Listed below are the AIM VOC limit reductions from ARB’s 2000 Suggested 

Control Measure. For California, these reductions resulted in a control factor of 

approximately 20% from a 1996 baseline. However, control factors can vary, 

depending on the particular emission inventory for an area and the combination 

of old limits and new limits. 

Category 

Control Factor = 

20%, based on 

ARB SCM 

Old Limit

New 

Limit 

Flat 250 100 

Industrial Maintenance 420 250 

Lacquers 680 550 

Multi-Color 420 250 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-15 Sept - 07 

Category 

Control Factor = 

20%, based on 

ARB SCM 

Old Limit

New 

Limit 

Nonflat: High Gloss 250 250 

Nonflat: Low Gloss 250 150 

Nonflat: Medium Gloss 250 150 

Primer, Sealer, Undercoater 350 200 

Quick Dry Enamel 400 250 

Quick Dry Primer, Sealer, Undercoater 450 200 

Roof 300 250 

Rust Preventative 420 400 

Stains: Clear/Semitransparent & 

Opaque 

350 250 

Swimming Pool Repair & Maintenance 650 340 

Traffic Marking Paints 250 150 

Waterproofing Sealers 400 250 

Alternatively, control factors for individual categories can be estimated using the 

following equations: 

[Control Factor, %] = [Pre-Limit VOCACTUAL, g/l]-[NEW VOCACTUAL, g/l] 

 [Pre-Limit VOCACTUAL, g/l] 

where 

Pre-Limit VOCACTUAL, g/l = The VOCACTUAL value for a typical coating, prior to 

adoption of a new limit. In some cases, sales-weighted 

average VOCACTUAL values can be obtained from ARB survey 

reports. However, it is important to note that the ARB values 

may be lower than those found in other parts of the United 

States. 

[NEW VOCACTUAL] = [Avg. VOC Density, g/l]*[VOCREGULATORY Limit, g/l]*[Vol. % Solids] 

 ([Avg. VOC Density, g/l]-[VOCREGULATORY Limit, g/l]) 

Average VOC Density = 880 grams/liter 

VOCREGULATORY Limit = New VOCREGULATORY Limit, grams/liter 

Vol. % Solids = Volume Percent Solids, % for a typical coating. In some 

cases, sales-weighted average Volume % Solids values can be obtained 

from ARB survey reports. However, it is important to note that the ARB 

values may be different than those found in other parts of the United 

States. 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-16 Sept - 07 

This alternative method has the advantage of being able to provide estimated 

emission reductions for individual categories, rather than using an overall control 

factor for all categories. To use this method, it is necessary to identify typical 

coatings that provide representative values for the Pre-Limit VOCACTUAL and 

Volume % Solids. This information can be obtained by working with 

manufacturers and reviewing product data sheets. 

Provided below is an example of estimated control factors for several categories. 

These factors were estimated using ARB architectural coating survey data, but 

the same approach can be used by inputting data obtained from manufacturers 

and different values for the old and new VOC limits. 

ARB SURVEY DATA - 1996 SALES 

Coating Category 

SWA 

VOCREG

(g/l) 

SWA 

VOCACTUAL

(g/l) 

SWA Vol. 

% Solids 

Old VOCREG

Limit (g/l) 

New 

VOCREG

Limit (g/l) 

NEW 

VOCACTUAL

(g/l) 

Estd. 

Control 

Factor 

Flats 98 40 35% 250 100 39 1% 

Industrial Maintenance 300 291 60% 420 250 210 28% 

Lacquer – Clear 649 626 20% 680 550 293 53% 

Lacquer – Opaque 545 527 27% 680 550 396 25% 

Multi-Color 263 163 33% 420 250 115 29% 

Nonflat - High Gloss 248 160 40% 250 250 N/A N/A 

Nonflat – Low Gloss 134 61 36% 250 150 65 0%* 

Nonflat - Medium Gloss 155 69 37% 250 150 67 3% 

Primer, Sealer, 

Undercoater 170 118 37% 350 200 96 19% 

Quick Dry Enamels 403 393 50% 400 250 175 56% 

Quick Dry PSUs 303 272 44% 450 200 114 58% 

Roof 23 16 45% 300 250 157 0%* 

Rust Preventative 371 367 48% 420 400 352 4% 

Stains – Clear 285 240 34% 350 250 119 51% 

Stains – Semitransparent 401 357 38% 350 250 133 63% 

Stains – Opaque 157 82 36% 350 250 126 0%* 

Swimming Pool Repair & 

Maintenance 569 569 29% 650 340 161 72% 

Traffic Marking 154 111 58% 250 150 105 6% 

Waterproofing Sealers – 

Clear 347 234 36% 400 250 126 46% 

Waterproofing Sealers – 

Opaque 219 191 47% 400 250 164 14% 

* No estimated control factor could be calculated because the predicted “NEW VOC Actual” value was 

higher than the existing “SWA VOC Actual” value. Calculation of a control factor by this method requires 

that the “NEW VOC Actual” be lower than the existing “SWA VOC Actual”. 

“N/A” = Not Applicable because the VOC limit was not changed. Nonflat – High Gloss is included for 

informational purposes only. 

Step 4: Calculate overall emission reductions. 

[Emission Reductions, lbs] = [Coating Sales, gals]*[Emission Factor, lb/gal]* 

[Control Factor, %] 
2007 ARB SCM for Architectural Coatings

California Air Resources Board E-17 Sept - 07 

Category Example Emission Reduction Calculations 

Architectural Coatings 

[16,443,720 gals]*[0.74 lb/gal]*[20%] = 

2,433,671 lbs 

Industrial New Construction 

and Maintenance Paints – 

Interior & Exterior 

[449,840+703,340 gals]*[2.43 lb/gal]*[20%] = 

560,446 lbs 

Traffic Marking Paints 

[718,140 gals]*[0.93 lb/gal]*[20%] = 

133,574 lbs 

Total Reductions = 2,433,671 + 560,446 + 133,574 lbs = 3,127,691 lbs reduced 

Assumptions: 

(1) Arizona’s current product mix is similar to California’s 1996 product mix. 

(2) Arizona’s current VOC limits are similar to California’s pre-2000 SCM limits. 

(3) The overall control factor is 20%. 

2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

APPENDIX F: 

SCM WORKSHOP NOTICES 
2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 
Linda S. Adams 

Secretary for 

Environmental Protection

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board Robert F. Sawyer, Ph.D., Chair 

1001 I Street • P.O. Box 2815 

Sacramento, California 95812 • www.arb.ca.gov Arnold Schwarzenegger

 Governor 

November 7, 2006 

Dear Sir or Madam: 

You are invited to participate in a public workshop to discuss proposed changes to the 

Air Resources Board’s (ARB or Board) Suggested Control Measure for Architectural 

Coatings (SCM). The SCM is a model rule which has been used by California air 

pollution control districts to develop architectural coating rules. Currently, twenty air 

districts have rules based on the SCM that was approved by the Board in 2000. 

At the workshop ARB staff will discuss the following: 

• Project timeline and development activities; 

• ARB’s architectural coating survey analysis; 

• Districts’ State Implementation Plan commitments; 

• Coating category definitions and other SCM areas of concern; and 

• Concept of reactivity-based standards. 

The date, time, and location of the workshop are: 

 Date: Tuesday, December 12, 2006 

 Time: 10:00 a.m. to 12:00 p.m. 

 Location: Training 2 West and East, 2nd Floor 

 Address: Cal/EPA Headquarters 

 1001 I Street 

 Sacramento, California 95812 

If you wish to participate by phone, please contact Lynna Negri at (916) 324-8018 or at 

lnegri@arb.ca.gov to ensure that adequate phone lines are available. The dial-in 

number for phone participants is (866) 755-6191, passcode 2181331. 

At least one week prior to the workshop, we will post an agenda and handouts on our 

website at http://www.arb.ca.gov/coatings/arch/arch.htm. To be notified of when these 

materials are posted, please sign up for the Architectural Coatings ListServe at 

http://www.arb.ca.gov/listserv/arch-ctgs.htm. 
Sir or Madam 

November 7, 2006 

Page 2 

We look forward to your participation in this workshop. If you have special 

accommodations or language needs, please contact Lynna Negri at (916) 324-8018 or 

at lnegri@arb.ca.gov. TTY/TTD/Speech-to-Speech users may dial 7-1-1 for the 

California Relay Service. For public transportation information, please contact Regional 

Transit at (916) 321-BUSS or view the transportation information on the California 

Environmental Protection Agency’s web site at 

http://calepa.ca.gov/epabldg/location.htm. 

If you have any questions about the workshop, please contact Mr. Jim Nyarady, 

Manager, Strategy Evaluation Section, at (916) 322-8273 or jnyarady@arb.ca.gov. 

Sincerely, 

Barbara Fry, Chief 

Measures Assessment Branch 

cc: Mr. Jim Nyarady, Manager 

 Strategy Evaluation Section 
Linda S. Adams 

Secretary for 

Environmental Protection

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board Robert F. Sawyer, Ph.D., Chair 

1001 I Street • P.O. Box 2815 

Sacramento, California 95812 • www.arb.ca.gov 

Arnold Schwarzenegger

 Governor 

February 8, 2007 

Dear Sir or Madam: 

You are invited to participate in a public workshop to discuss proposed changes to the 

Air Resources Board’s (ARB or Board) Suggested Control Measure for Architectural 

Coatings (SCM). The SCM is a model rule which has been used by California air 

pollution control districts to develop architectural coating rules. Currently, twenty air 

districts have rules based on the SCM that was approved by the Board in 2000. 

At the workshop ARB staff will discuss the following: 

• Project timeline and development activities; 

• Preliminary proposed VOC limits; and 

• Preliminary proposed revisions to coating category definitions. 

The date, time, and location of the workshop are: 

 Date: Tuesday, March 13, 2007 

 Time: 1:30 p.m. to 3:30 p.m. 

 Location: Training 1 East and West, 1st Floor 

 Address: Cal/EPA Headquarters 

 1001 I Street 

 Sacramento, California 95812 

If you wish to participate by phone, please contact Sarah Penfield at (916) 324-8181 or 

at spenfiel@arb.ca.gov to ensure that adequate phone lines are available. The dial-in 

number for phone participants is (866) 755-6191, passcode 2181331. 

Prior to the workshop, we will post an agenda and handouts on our website at 

http://www.arb.ca.gov/coatings/arch/arch.htm. To be notified of when these materials 

are posted, please sign up for the Architectural Coatings ListServe at 

http://www.arb.ca.gov/listserv/arch-ctgs.htm. 
Sir or Madam 

February 8, 2007 

Page 2 

We look forward to your participation in this workshop. If you have special 

accommodation needs, please contact ARB’s Disability Coordinator at (916) 323-4916. 

If you are a person with limited English and would like to request interpreter services, 

please contact ARB’s Bilingual Manager at (916) 323-7053. TTY/TTD/Speech-toSpeech users may dial 7-1-1 for the California Relay Service. For public transportation 

information, please contact Regional Transit at (916) 321-BUSS or view the 

transportation information on the California Environmental Protection Agency’s web site 

at http://calepa.ca.gov/epabldg/location.htm. 

If you have any questions about the workshop, please contact Mr. Jim Nyarady, 

Manager, Strategy Evaluation Section, at (916) 322-8273 or jnyarady@arb.ca.gov. 

Sincerely, 

Barbara Fry, Chief 

Measures Assessment Branch 

cc: Mr. Jim Nyarady, Manager 

 Strategy Evaluation Section 
Linda S. Adams 

Secretary for 

Environmental Protection

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

Air Resources Board Robert F. Sawyer, Ph.D., Chair 

1001 I Street • P.O. Box 2815 

Sacramento, California 95812 • www.arb.ca.gov Arnold Schwarzenegger

 Governor 

May 1, 2007 

Dear Sir or Madam: 

You are invited to participate in a public workshop to discuss proposed changes to the 

Air Resources Board’s (ARB or Board) Suggested Control Measure for Architectural 

Coatings (SCM). The SCM is a model rule which has been used by California air 

pollution control districts to develop architectural coating rules. Currently, twenty air 

districts have rules based on the SCM that was approved by the Board in 2000. 

At the workshop ARB staff will discuss the following: 

• Project timeline and development activities; 

• Draft proposed revisions to the SCM rule language; 

• Draft proposed VOC limits; and 

• Draft proposed revisions to coating category definitions. 

The date, time, and location of the workshop are: 

 Date: Wednesday, June 6, 2007 

 Time: 9:00 a.m. to 12:00 p.m. 

 Location: Training 1 East and West, 1st Floor 

 Address: Cal/EPA Headquarters 

 1001 I Street 

 Sacramento, California 95812 

If you wish to participate by phone, please contact Sarah Penfield at (916) 324-8181 or 

at spenfiel@arb.ca.gov to ensure that adequate phone lines are available. The dial-in 

number for phone participants is (866) 755-6191, passcode 2181331. 

Prior to the workshop, we will post an agenda and handouts on our website at 

http://www.arb.ca.gov/coatings/arch/arch.htm. To be notified of when these materials 

are posted, please sign up for the Architectural Coatings ListServe at 

http://www.arb.ca.gov/listserv/arch-ctgs.htm. 
Sir or Madam 

May 1, 2007 

Page 2 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov. 

California Environmental Protection Agency

Printed on Recycled Paper

We look forward to your participation in this workshop. If you have special 

accommodation needs, please contact ARB’s Disability Coordinator at (916) 323-4916. 

If you are a person with limited English and would like to request interpreter services, 

please contact ARB’s Bilingual Manager at (916) 323-7053. TTY/TTD/Speech-toSpeech users may dial 7-1-1 for the California Relay Service. For public transportation 

information, please contact Regional Transit at (916) 321-BUSS or view the 

transportation information on the California Environmental Protection Agency’s web site 

at http://calepa.ca.gov/epabldg/location.htm. 

If you have any questions about the workshop, please contact Mr. Jim Nyarady, 

Manager, Strategy Evaluation Section, at (916) 322-8273 or jnyarady@arb.ca.gov. 

Sincerely, 

Barbara Fry, Chief 

Measures Assessment Branch 

cc: Mr. Jim Nyarady, Manager 

 Strategy Evaluation Section 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board Sept - 07

APPENDIX G: 

ECONOMIC ANALYSIS DETAILS 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board Sept - 07
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-1 Sept - 07 

Summary of Economic Analysis Methodology 

Summary 

The total cost of the proposed SCM to affected businesses is estimated to be 

$4 million per year in annualized nonrecurring costs and $8.3 million per year in 

recurring costs. This equates to $12.3 million dollars annually over the project 

horizon. This represents the cost of raw materials, research and development, 

equipment, testing, and training to architectural coatings manufacturers. 

This appendix covers the methodology used in the Economic Analysis presented 

in Chapter 7. The methodology is similar to what was used in previous ARB 

regulations (ARB, 1990; ARB, 1991; ARB, 1997; ARB, 1999; ARB, 2000; ARB, 

2003; ARB, 2004; ARB, 2005) and follows guidelines recommended by Cal/EPA 

for economic analysis (Cal/EPA, 1996).

Methodology 

For this analysis, we considered the impact to architectural coatings 

manufacturers. Although other entities such as distributors, retailers, end users 

and raw material suppliers may be impacted, coating manufacturers will be the 

primary entities affected. 

First, we analyzed data from the 2005 Architectural Coatings Survey to 

determine complying and noncomplying volume for the 16 categories that have a 

proposed change to the VOC limit, and a projected emission reduction of more 

than .01 tons per day (tpd) outside of the South Coast Air Quality Management 

District (SCAQMD). We assumed that costs would not be incurred for coatings in 

a category that did not have a proposed limit. We also determined the number of 

noncomplying products and the expected emission reductions for each of these 

categories based on the survey data. These data are summarized in Table G-1. 

Table G-1 

Survey Data Inputs for Cost Calculations Outside of SCAQMD for Categories 

with Greater Than .01 TPD Emission Reduction 

Coating Category 

Proposed 

Limit 

(g/l) 

Emission 

Reductions 

(Tons/Day) 

Estimated # of 

Non-Compliant 

Products 

Estimated # of 

Non-Compliant 

Gallons per 

Year 

Aluminum Roof 400 0.19 48 193,566 

Bituminous Roof 50 0.17 42 79,722 

Concrete Masonry 

Sealer 100 0.54 243 647,318 

Dry Fog 150 0.31 39 120,535 

Flat 50 3.12 2,079 19,213,031 

Floor 100 0.07 167 100,834 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-2 Sept - 07 

Table G-1 

Survey Data Inputs for Cost Calculations Outside of SCAQMD for Categories 

with Greater Than .01 TPD Emission Reduction 

Coating Category 

Proposed 

Limit 

(g/l) 

Emission 

Reductions 

(Tons/Day) 

Estimated # of 

Non-Compliant 

Products 

Estimated # of 

Non-Compliant 

Gallons per 

Year 

Mastic Texture 100 0.10 22 79,316 

Non Flat 100 2.79 2,121 12,649,813 

Non Flat High Gloss 150 0.91 362 1,074,079 

PSU 100 1.12 323 3,747,874 

Roof 50 0.07 87 135,698 

Rust Preventative 250 1.57 303 832,567 

Specialty PSU 100 2.62 70 859,266 

Traffic Marking 100 0.09 87 320,397 

Waterproofing 

Membrane 250 0.09 13 98,848 

Wood Coatings 275 1.41 940 736,786 

Total 15.2 6,946 40,889,649 

We collected data from manufacturers with the 2007 Economic Impacts Survey. 

This survey was sent to all manufacturers who responded to the 2005 

Architectural Coatings Survey who manufactured products in one of the affected 

categories. This survey collected information on the number of products that 

would need to be reformulated due to the proposed limits of the SCM and the 

cost to reformulate those products. 

Based on responses to the ARB Economic Survey and discussions with 

manufacturers, more than half of the non-complying products that will be 

reformulated will be in response to the proposed limits of the SCAQMD. This is 

confirmed by comparing the portion of non-complying products in the ARB 2005 

survey and the responses to the Economic Survey. For the purposes of this 

analysis, we assumed that half of the non-complying products would be 

reformulated due to the proposed limits of the SCM. 

From these responses, we sorted the recurring and non-recurring costs by 

category where applicable, and applied the average of all responses in 

categories that did receive a specific response. This data is summarized in 

Table G-2. 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-3 Sept - 07 

Table G-2 

Non-Recurring and Recurring Cost from 2007 ARB Economic Impacts 

Survey

Coating Category 

ARB Economic Survey 

Reported Nonrecurring Cost 

to Reformulate 

(Dollars per Product) 

ARB Economic Survey 

Reported Non-Raw Material 

Recurring Costs 

(Dollars per Year per 

Product) 

Aluminum Roof 11,625 $86,328 

Bituminous Roof 17,171 $75,537 

Concrete Masonry 

Sealer 6,068 $437,036 

Dry Fog 7,332 $70,142 

Flat 3,642 $3,739,082 

Floor 14,893 $300,350 

Mastic Texture 7,332 $39,567 

Nonflat 4,014 $3,814,619 

Nonflat High Gloss 4,719 $651,057 

PSU 5,681 $580,916 

Roof 17,281 $156,470 

Rust Preventative 7,332 $544,946 

Specialty PSU 4,263 $125,895 

Traffic Marking 8,533 $156,470 

Waterproofing 

Membrane 7,332 $23,381 

Wood Coatings 5,391 $1,690,590 

Based on the ARB survey, product data sheets and discussions with 

manufacturers, staff determined the ingredients of typical complying and noncomplying formulations for the 20 categories. These formulations were sent out 

to industry for comments. 

Data on the raw materials were obtained from chemical manufacturers, 

distributors of raw materials, Chemical Market Reporter (CMR) Magazine, and 

discussions with manufacturers. Resin costs are the primary influence on raw 

materials cost for most coatings and, because there are a variety of resins with 

differing costs, resins have the most variable impact on raw materials cost. 

Resin costs were taken from the CMR chemical prices in 2000, and were inflated 

by the producer price index between 2000 and 2007 for plastic material and resin 

manufacturers (BLS, 2007). 

In cases where there were no data available for an ingredient, a default price of 

$1.50 per pound was used. 

Comparing the difference in raw material costs between typical complying and 

non-complying formulations gave us the amount of cost or cost savings in raw 

materials a manufacturer would incur if changing from a typical non-compliant 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-4 Sept - 07 

coating to a typical complying coating. These costs are summarized in 

Table G-3. 

Table G-3 

Raw Material Cost Differential Between Complying and Non-Complying 

Products 

Coating Category 

Raw Material 

Cost of a 

Typical 

Complying 

Formulation 

Raw Material 

Cost of a 

Typical NonComplying 

Formulation 

Difference of Raw 

Material Cost of 

Complying and 

Non-Complying per 

Gallon 

Aluminum Roof $3.17 $3.66 -$0.49 

Bituminous Roof $2.57 $2.96 -$0.39 

Concrete Masonry 

Sealer $2.35 $3.52 -$1.17 

Dry Fog $6.87 $8.71 -$1.85 

Flat $4.13 $4.45 -$0.32 

Floor $5.24 $4.24 $1.00 

Mastic Texture $5.85 $4.43 $1.42 

Nonflat $5.58 $4.86 $0.72 

Nonflat High Gloss $4.35 $5.99 -$1.64 

PSU $4.64 $4.23 $0.42 

Roof $5.54 $7.48 -$1.94 

Rust Preventative $5.98 $7.57 -$1.59 

Specialty PSU $4.53 $6.30 -$1.77 

Traffic Marking $3.79 $3.55 $0.24 

Waterproofing 

Membrane $12.27 $8.35 $3.90 

Wood Coatings $5.00 $9.67 -$4.67 

These costs were multiplied by the non-complying volume to determine the 

recurring raw material related cost of the proposed limits. 

The recurring costs from Table G-2 were multiplied by the number of products 

that would need to be reformulated for each category. The total annual cost is 

the sum of the raw material related costs, the recurring non-raw material costs 

and annualized non-recurring costs. These calculations are summarized in 

Table G-4. 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-5 Sept - 07 

Table G-4 

Calculated Annual Cost 

Coating Category 

Annual 

Recurring 

Costs (Raw 

Material) 

Dollars per 

Year 

Annual 

Recurring 

Costs (Non-raw 

Material) 

Dollars per 

Year 

Annualized 

Nonrecurring 

Cost Dollars 

per Year 

Total Annual 

Cost per Year 

Aluminum Roof -$94,785 $86,328 $64,441.97 $55,985

Bituminous Roof -$30,718 $75,537 $83,287.43 $128,106

Concrete Masonry 

Sealer -$749,150 $437,036 $170,288.94 -$141,826

Dry Fog -$222,428 $70,142 $33,023 -$119,264

Flat -$6,189,405 $3,739,082 $874,438 -$1,575,886

Floor $100,339 $300,350 $287,232 $687,922

Mastic Texture $112,598 $39,567 $18,629 $170,794

Nonflat $9,120,928 $3,814,619 $983,224 $13,918,771

Nonflat High Gloss -$1,758,417 $651,057 $197,285 -$910,076

PSU $1,563,126 $580,916 $211,915.10 $2,355,957

Roof -$263,878 $156,470 $173,629 $66,220

Rust Preventative -$1,324,934 $544,946 $256,566 -$523,423

Specialty PSU -$1,517,941 $125,895.00 $34,463 -$1,357,584

Traffic Marking $78,066 $156,470 $85,735 $320,271

Waterproofing 

Membrane $385,012 $23,381 $11,008 $419,401

Wood Coatings -$3,443,964 $1,690,590 $585,185 -$1,168,189

Total -$4,235,550 $12,492,381 $4,070,350 $12,327,181

The cost effectiveness is determined by taking the total annual cost of a category 

and dividing by the annual emission reduction. Assuming all costs are passed on 

to consumers, we calculate the cost increase per gallon. The cost increase per 

gallon to end users is determined by taking the total cost of the category, dividing 

by the number of non-compliant gallons, and multiplying by a factor of 4X. This 

represents the assumption that the cost of a product is doubled from the 

manufacturer to the distributor, and is doubled again from the distributor to the 

end user. Taking the raw material costs for complying and non-complying 

products, and using the same 4X multiplier gives cost increase per gallon. This 

data is summarized in Table G-5. 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-6 Sept - 07 

Table G-5 

Calculated Cost-Effectiveness and Cost Increase Per Gallon 

Coating Category 

Individual 

Cost 

Effectiveness 

for Each 

Limit (Dollars 

per Pound 

VOC 

Reduced) 

Cost Increase to 

Consumers per 

Gallon (4X) 

Typical NonComplying Cost 

per Gallon 

Typical 

Complying 

Cost per Gallon 

Aluminum Roof $0.41 $1.16 $14.63 $12.67

Bituminous Roof $1.02 $6.43 $11.84 $10.30

Concrete Masonry 

Sealer -$0.36 -$0.88 $14.09 $9.40

Dry Fog -$0.52 -$3.96 $34.86 $27.47

Flat -$0.69 -$0.33 $17.81 $16.52

Floor $13.90 $27.30 $16.96 $20.94

Mastic Texture $2.37 $8.61 $17.72 $23.40

Non Flat $7.03 $4.40 $19.44 $22.32

Non Flat High 

Gloss -$1.37 -$3.39 $23.96 $17.41

PSU $2.73 $2.51 $16.90 $18.57

Roof $1.38 $1.95 $29.94 $22.16

Rust Preventative -$0.46 -$2.51 $30.30 $23.93

Specialty PSU -$0.71 -$6.32 $25.19 $18.12

Traffic Marking $4.76 $4.00 $14.18 $15.16

Waterproofing 

Membrane $6.56 $16.97 $33.38 $48.96

Wood Coatings -$1.13 -$6.34 $38.70 $20.00

Weighted Average $1.12 $1.21 

A sensitivity analysis was conducted to determine the impacts on the annual 

costs from assumed changes to resin costs, the primary variable influence on 

raw material costs. We conducted this analysis with four different runs, one 

baseline and three assumed increases in resin prices. As Table G-6 shows, 

even with an extreme assumption of 50% increase in compliant resin price, the 

overall cost-effectiveness of the proposed limits are still consistent with the cost 

effectiveness values for past ARB regulations shown earlier in Table 7-3. 

We assumed the resin costs for complying coatings would increase by a certain 

level. Resin costs are the primary influence on raw materials cost for most 

coatings and, because there are a variety of resins with differing costs, resins 

have the most variable impact on raw materials cost. The resin portion of a 

coating typically represents about 20% to 50% or more of the total raw materials 

cost of a gallon of coating. With current ingredient prices as the baseline 

scenario, we conducted complete cost-effectiveness calculations at 10%, 20%, 

and 50% assumed increases in compliant resin costs. The 10% and 20% 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-7 Sept - 07 

assumed resin price increases are consistent with the socioeconomic impacts 

analysis conducted by the SCAQMD and confidential comments provided by 

some manufacturers. To be conservative, we use the 20% resin price increase 

assumption wherever we refer to the “average” cost-effectiveness of each limit 

and the overall cost-effectiveness. The 50% assumed resin price increase is 

intended as an extreme upper boundary for purposes of the sensitivity analysis 

and is not suggested by any information available to staff as reflective of 

projected actual resin prices when the proposed limits become effective. 

Table G-6 

Cost-Effectiveness of Proposed Limits Under Sensitivity Analysis

 Baseline 10% Increase 20% Increase 50% 

Increase 

Coating Category RCM = 1.0 RCM = 1.1 RCM = 1.2 RCM = 1.5 

Aluminum Roof $0.41 $0.41 $0.41 $0.41 

Bituminous Roof $1.02 $1.02 $1.02 $1.02 

Concrete Masonry Sealer -$0.60 -$0.48 -$0.36 -$0.01 

Dry Fog -$0.86 -$0.69 -$0.52 -$0.01 

Flat -$1.76 -$1.23 -$0.69 $0.92 

Floor $13.06 $13.50 $13.94 $15.26 

Mastic Texture $1.80 $2.09 $2.37 $3.24 

Non Flat $4.65 $5.84 $7.03 $10.61 

Non Flat High Gloss -$1.92 -$1.65 -$1.37 -$0.55 

PSU $1.40 $2.06 $2.73 $4.71 

Roof $0.12 $0.75 $1.38 $3.26 

Rust Preventative -$0.80 -$0.63 -$0.46 $0.06 

Specialty PSU -$0.83 -$0.77 -$0.71 -$0.53 

Traffic Marking $3.47 $4.11 $4.76 $6.70 

Waterproofing Membrane $4.70 $5.63 $6.56 $9.34 

Wood Coatings -$1.48 -$1.31 -$1.13 -$0.62 

Overall CostEffectiveness $0.20 $0.65 $1.11 $2.49 

On the following pages, we present typical formulations for complying and 

non-complying products. As noted earlier, these formulations were developed 

based on survey data, product datasheets, and input from manufacturers. In 

cases where an ingredient comprised less than 5% of the total weight of a 

formulation, the ingredient was changed to “All Other VOCs” or “All Other Solids.” 

The formulations shown have an assumed 20% increase in resin prices for the 

future complying product. 
2007 ARB SCM for Architectural Coatings 

California Air Resources Board G-8 Sept - 07 

References 

Air Resources Board. Technical Support Document. “Proposed Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products.” 

(a.k.a. “Phase I Consumer Products Regulation). August 1990. (ARB, 1990) 

Air Resources Board. Technical Support Document. “Proposed Amendments to 

the Statewide Regulation to Reduce Volatile Organic Compound Emissions from 

Consumer Products – Phase II.” (a.k.a. “Phase II Consumer Products 

Regulation). October 1991. (ARB, 1991) 

Air Resources Board. Executive Summary and Technical Support Document. 

“Initial Statement of Reasons for Proposed Amendments to the California 

Consumer Products Regulation.” (a.k.a. “Mid-Term Measures I”). June 6, 1997. 

(ARB, 1997) 

Air Resources Board. Introduction and Executive Summary and Technical 

Support Document. “Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation.” (a.k.a. “Mid-Term Measures II”). 

September 10, 1999. (ARB, 1999) 

Air Resources Board. Staff Report for the 2000 Suggested Control Measure for 

Architectural Coatings. June, 2000. (ARB, 2000) 

Air Resources Board. “Initial Statement of Reasons for the Proposed 

Amendments to the California Aerosol Coatings Products, Antiperspirants and 

Deodorants, and Consumer Products Regulations, Test Method 310, and 

Airborne Toxic Control Measure for Para-Dichlorobenzene Solid Air Fresheners 

and Toilet/Urinal Care Products.” May 7, 2004. (ARB, 2004) 

Air Resources Board. Staff Report for the Suggested Control Measure for 

Automotive Coatings. October, 2005. (ARB, 2005) 

Air Resources Board. 2005 Architectural Coatings Survey, Draft Report. 

September, 2006. (ARB, 2006) 

U. S. Department of Labor, Bureau of Labor Statistics. Producer Price Index 

Industry Data – Plastics Material and Resin Manufacturing. July 11, 2007. 

(BLS, 2007) 

California Environmental Protection Agency. Memorandum from Peter M. 

Rooney, Undersecretary, to Cal/EPA Executive Officers and Directors. 

Economic Analysis Requirements for the Adoption of Administrative Regulations. 

Appendix C (Cal/EPA Guidelines for Evaluation Alternatives to Proposed Major 

Regulations). December 6, 1996. (Cal/EPA, 1996) 
Category Aluminum Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 43% 30%

VOC Limit (g/l): 500 400

VOC Reg. for Sample Formulation (g/l): 433 302

Density (lbs/gallon): 8.4 8.4

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E)

Asphalt $0.17 32% $0.05 30% $0.05

Calcium Carbonate $0.17 7% $0.01 25% $0.04

Aluminum $0.90 17% $0.15 15% $0.14

All Other Solids $0.65 3% $0.02

Mineral Spirits $0.50 22% $0.11 30% $0.15

Aromatic 100 $0.50 13% $0.06

Medium Aliphatic Solvent 

Naphtha $0.42 9% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.44 $0.38

% Cost Differential Relative to Current Product -13.4%

Total Cost, $/Gallon $3.66 $3.17

Total Cost Differential per Gallon Relative to Current Product -$0.49

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Bituminous Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties

Weight % VOC: 28% 0%

VOC Limit (g/l): 300 50

VOC Reg. for Sample Formulation (g/l): 292 0

Density (lbs/gallon): 8.7 8.7

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E) 

Asphalt $0.17 65% $0.11 40% $0.07

Cellulose Fiber $1.50 5% $0.08

Clay Bentonite $2.00 11% $0.22

All Other Solids $0.90 2% $0.02 1% $0.01

Water $0.00 48% $0.00

Stoddard Solvent $0.50 28% $0.14

Sum 100% 100%

Total Cost, $/Pound $0.34 $0.30

% Cost Differential Relative to Current Product -13.0%

Total Cost, $/Gallon $2.96 $2.57

Total Cost Differential per Gallon Relative to Current Product -$0.39

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant Typical Compliant
Category Concrete Masonry Sealer Assumed Resin Cost Multiplier (RCM) 1.2

 (Water Repellent/Weather Resistance)

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 25% 3%

VOC Limit (g/l): 400 100

VOC Reg. for Sample Formulation (g/l): 389 84

Density (lbs/gallon): 13.0 11.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Titanium Dioxide $1.18 5% $0.06 5% $0.06

Cement $0.06 25% $0.02

Silica $0.65 20% $0.13

Calcium Carbonate $0.17 20% $0.03 27% $0.05

Acrylic Resin $0.85 1.2 5% $0.04 25% $0.25

Water $0.00 40% $0.00

Hydrocarbon Solvent 

(Naphtha) $0.46 18% $0.08

Aromatic Solvent $0.50 7% $0.04

All Other VOCs $0.60 2% $0.01

Additives (VOC) $1.50 1% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.40 $0.39

% Cost Differential Relative to Current Product -2.6%

Total Cost, $/Gallon $5.16 $4.26

Total Cost Differential per Gallon Relative to Current Product -$0.91

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Concrete Masonry Sealer Assumed Resin Cost Multiplier (RCM) 1.2

 (Decorative/Stain Resistance)

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 7% 0%

VOC Limit (g/l): 400 100

VOC Reg. for Sample Formulation (g/l): 372 0

Density (lbs/gallon): 8.6 8.4

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Acrylic Resin $0.85 15% $0.13

Siloxane Resin $1.50 1.2 3% $0.05

Water $0.00 78% $0.00 97% $0.00

Diethylene Glycol Monomethyl 

Ether $1.28 5% $0.06

All Other VOCs $1.35 1% $0.01

Additives (VOC) $1.50 1% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.22 $0.06

% Cost Differential Relative to Current Product -74.7%

Total Cost, $/Gallon $1.90 $0.47

Total Cost Differential per Gallon Relative to Current Product -$1.43

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Dry Fog Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties

Weight % VOC: 29% 3%

VOC Limit (g/l): 400 150

VOC Reg. for Sample Formulation (g/l): 400 85

Density (lbs/gallon): 11.5 11.5

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Titanium Dioxide $1.18 26% $0.31 20% $0.24

Alkyd Resin $0.71 45% $0.32

Vinyl Acrylic Copolymer Resin $0.71 1.2 $0.00 40% $0.34

Water $0.00 $0.00 37% $0.00

VM&P Naptha $0.46 28% $0.13

All Other VOCs 1% $0.01 3% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.76 $0.60

% Cost Differential Relative to Current Product -21.2%

Total Cost, $/Gallon $8.71 $6.87

Total Cost Differential per Gallon Relative to Current Product -$1.85

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Flat Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties

Weight % VOC: 4% 2%

VOC Limit (g/l): 100 50

VOC Reg. for Sample Formulation (g/l): 90 47

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 19% $0.22 17% $0.20

Calcium Carbonate $0.17 16% $0.03 $0.00

Silicates $0.65 9% $0.06 15% $0.10

Talc $0.15 16% $0.02

Vinyl Acrylic Resin $0.71 1.2 13% $0.09 9% $0.08

Water $0.00 39% $0.00 41% $0.00

All Other VOCs 4% $0.05 2% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.45 $0.41

% Cost Differential Relative to Current Product -7.2%

Total Cost, $/Gallon $4.45 $4.13

Total Cost Differential per Gallon Relative to Current Product -$0.32

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Floor Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 6% 3%

VOC Limit (g/l): 250 100

VOC Reg. for Sample Formulation (g/l): 180 95

Density (lbs/gallon): 10.0 11.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Titanium Dioxide $1.18 14% $0.17 16% $0.19

Calcium Carbonate $0.17 10% $0.02 14% $0.02

Acrylic Resin $0.85 1.2 20% $0.17 23% $0.23

Water $0.00 50% $0.00 44% $0.00

All Other VOCs 6% $0.07 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.42 $0.48

% Cost Differential Relative to Current Product 12.2%

Total Cost, $/Gallon $4.24 $5.24

Total Cost Differential per Gallon Relative to Current Product $1.00

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Mastic Texture Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 15% 3%

VOC Limit (g/l): 300 100

VOC Reg. for Sample Formulation (g/l): 239 74

Density (lbs/gallon): 9.5 11.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Titanium Dioxide $1.18 8% $0.09 8% $0.09

Mica $0.45 20% $0.09 26% $0.12

Perlite $0.45 5% $0.02

Acrylic Resin $0.85 1.2 28% $0.28

Alkyd Resin $0.71 1.2 27% $0.19

Water $0.00 25% $0.00 35% $0.00

Hydrocarbon Solvent 

(Naphtha) $0.46 15% $0.07

All Other VOCs 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.47 $0.53

% Cost Differential Relative to Current Product 14.0%

Total Cost, $/Gallon $4.43 $5.85

Total Cost Differential per Gallon Relative to Current Product $1.42

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Non Flat Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties

Weight % VOC: 6% 4%

VOC Limit (g/l): 150 100

VOC Reg. for Sample Formulation (g/l): 153 104

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 17% $0.20 21% $0.25

Silicates $0.65 8% $0.05

All Other Solids 3% $0.02

Calcium Carbonate $0.17 7% $0.01

Acrylic Resin $0.85 1.2 23% $0.19 22% $0.22

Water $0.00 44% $0.00 45% $0.00

All Other VOCs 6% $0.05 4% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.48 $0.56

% Cost Differential Relative to Current Product 15.6%

Total Cost, $/Gallon $4.83 $5.58

Total Cost Differential per Gallon Relative to Current Product $0.75

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Non Flat High Gloss Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 6% 3%

VOC Limit (g/l): 250 150

VOC Reg. for Sample Formulation (g/l): 154 106

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 18% $0.21 11% $0.13

Acrylic Resin $0.85 1.2 27% $0.23 20% $0.20

Silica $0.65 5% $0.03 11% $0.07

Water $0.00 44% $0.00 55% $0.00

All Other VOCs 6% $0.12 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.60 $0.44

% Cost Differential Relative to Current Product -27.3%

Total Cost, $/Gallon $5.99 $4.35

Total Cost Differential per Gallon Relative to Current Product -$1.64

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category PSU Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 4% 2%

VOC Limit (g/l): 200 100

VOC Reg. for Sample Formulation (g/l): 120 60

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 13% $0.15 15% $0.18

All Other Solids 6% $0.07 5% $0.06

Acrylic Resin $0.85 1.2 15% $0.13 18% $0.18

Talc $0.15 12% $0.02 10% $0.02

Water $0.00 50% $0.00 50% $0.00

All Other VOCs 4% $0.05 2% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.42 $0.46

% Cost Differential Relative to Current Product 10.6%

Total Cost, $/Gallon $4.20 $4.64

Total Cost Differential per Gallon Relative to Current Product $0.44

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 20% 2%

VOC Limit (g/l): 250 50

VOC Reg. for Sample Formulation (g/l): 252 51

Density (lbs/gallon): 10.5 10.5

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 10% $0.12 10% $0.12

Zinc Oxide $2.20 5% $0.11 5% $0.11

Acrylic Resin $0.85 1.2 30% $0.25 25% $0.25

Calcium Carbonate $0.17 35% $0.06 18% $0.03

Water $0.00 40% $0.00

All Other VOCs 2% $0.03 2% $0.02

Aliphatic Hydrocarbons $0.50 12% $0.06

Propylene Glycol $1.35 6% $0.08

Sum 100% 100%

Total Cost, $/Pound $0.71 $0.53

% Cost Differential Relative to Current Product -26.0%

Total Cost, $/Gallon $7.48 $5.54

Total Cost Differential per Gallon Relative to Current Product -$1.94

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Rust Preventative Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 33% 5%

VOC Limit (g/l): 400 250

VOC Reg. for Sample Formulation (g/l): 391 127

Density (lbs/gallon): 9.9 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 25% $0.30 23% $0.27

All Other Solids $0.65 4% $0.03

Alkyd Resin $0.71 38% $0.27

Acrylic resin $0.85 1.2 28% $0.28

Water $0.00 44% $0.00

Stoddard Solvent $0.50 31% $0.16

All Other VOCs 2% $0.02 5% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.77 $0.60

% Cost Differential Relative to Current Product -21.8%

Total Cost, $/Gallon $7.57 $5.98

Total Cost Differential per Gallon Relative to Current Product -$1.59

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Specialty PSU Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 26% 2%

VOC Limit (g/l): 350 100

VOC Reg. for Sample Formulation (g/l): 312 61

Density (lbs/gallon): 10.0 11.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Titanium Dioxide $1.18 8% $0.09 15% $0.18

Talc $0.15 37% $0.06 23% $0.03

All Other Solids 4% $0.06 3% $0.05

Acrylic Resin $0.85 1.2 14% $0.14

Alkyd Resin $0.71 25% $0.18

Water $0.00 43% $0.00

All Other VOCs 1% $0.01 2% $0.01

Mineral Spirits $0.95 25% $0.24

Sum 100% 100%

Total Cost, $/Pound $0.63 $0.41

% Cost Differential Relative to Current Product -34.6%

Total Cost, $/Gallon $6.30 $4.53

Total Cost Differential per Gallon Relative to Current Product -$1.77

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Traffic Marking Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 7% 5%

VOC Limit (g/l): 150 100

VOC Reg. for Sample Formulation (g/l): 110 78

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Titanium Dioxide $1.18 7% $0.08 7% $0.08

Calcium Carbonate $0.17 52% $0.09 53% $0.09

Acrylic Resin $0.85 1.2 14% $0.12 16% $0.16

Water $0.00 20% $0.00 19% $0.00

All Other VOCs 7% $0.06 5% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.35 $0.38

% Cost Differential Relative to Current Product 6.9%

Total Cost, $/Gallon $3.55 $3.79

Total Cost Differential per Gallon Relative to Current Product $0.24

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Waterproofing Membrane Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 32% 20%

VOC Limit (g/l): 400 250

VOC Reg. for Sample Formulation (g/l): 383 240

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D) 

Wt%

(E)

Cost

(B) X (C) X (E) 

Butyl Benzyl Phthalate $1.50 10% $0.15

Asphalt $0.17 10% $0.02

Carbon Black $2.29 10% $0.23

Calcium Carbonate $0.17 18% $0.03 20% $0.03

Polyurethane Resin $1.50 1.2 40% $0.60 40% $0.72

Water $0.00

Hydrocarbon Solvent 

(Naphtha) $0.46 28% $0.13 20% $0.09

All Other VOCs $1.50 4% $0.06

Sum 100% 100%

Total Cost, $/Pound $0.83 $1.22

% Cost Differential Relative to Current Product 46.7%

Total Cost, $/Gallon $8.35 $12.24

Total Cost Differential per Gallon Relative to Current Product $3.90

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Lacquer Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 33% 10%

VOC Limit (g/l): 550 275

VOC Reg. for Sample Formulation (g/l): 545 265

Density (lbs/gallon): 8.3 8.7

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Nitrocellulose $1.50 20% $0.30

Acrylic Resins $0.85 1.2 20% $0.20

Polyurethane Resins $1.50 1.2 8% $0.14

Additives $1.50 5% $0.08 4% $0.06

Water $0.00 $0.00 58% $0.00

Acetone $0.70 42% $0.29

Methyl-n-Amyl Ketone $1.50 10% $0.15

Butyl Acetate $1.50 10% $0.15 $0.00

All Other VOCs 13% $0.05 10% $0.13

Sum 100% 100%

Total Cost, $/Pound $1.11 $0.54

% Cost Differential Relative to Current Product -51.4%

Total Cost, $/Gallon $9.36 $4.71

Total Cost Differential per Gallon Relative to Current Product -$4.65

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Varnish Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 36% 10%

VOC Limit (g/l): 350 275

VOC Reg. for Sample Formulation (g/l): 349 271

Density (lbs/gallon): 8.1 8.6

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Polyurethane Resins $1.50 1.2 56% $0.82 24% $0.42

Additives $1.50 8% $0.12 6% $0.09

Water $0.00 $0.00 60% $0.00

Distillate (Petroleum), 

Hydrotreated Light $0.95 14% $0.13

Stoddard Solvent $1.50 10% $0.15

Medium Aliphatic Solvent 

Naphtha $0.42 10% $0.04

All Other VOCs 2% $0.02 10% $0.15

Sum 100% 100%

Total Cost, $/Pound $1.28 $0.66

% Cost Differential Relative to Current Product -48.8%

Total Cost, $/Gallon $10.39 $5.65

Total Cost Differential per Gallon Relative to Current Product -$4.74

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant
Category Opaque Lacquer Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant

Weight % VOC: 19% 6%

VOC Limit (g/l): 550 275

VOC Reg. for Sample Formulation (g/l): 438 107

Density (lbs/gallon): 8.5 8.5

Formulation and Cost Comparison

Wt%

(D)

Cost

(B) X (D)

Wt%

(E)

Cost

(B) X (C) X (E)

Nitrocellulose $1.50 24% $0.36

Titanium Dioxide $1.18 10% $0.12 10% $0.12

Additives $1.50 2% $0.03 3% $0.05

Silicates $0.65 6% $0.04 6% $0.04

Acrylic Resin $0.85 1.2 26% $0.26

Calcium Carbonate $0.17 6% $0.01 7% $0.01

Water $0.00 42% $0.00

Acetone $0.70 16% $0.11

All Other VOCs 12% $0.12 6% $0.08

Isobutyl Isobutyrate $1.50 5% $0.08

Butyl Acetate 1- $1.50 8% $0.12

Isobutyl Acetate $1.50 6% $0.09

VM&P Naphtha $0.46 5% $0.02

Sum 100% 100%

Total Cost, $/Pound $1.10 $0.56

% Cost Differential Relative to Current Product -49.4%

Total Cost, $/Gallon $9.33 $4.72

Total Cost Differential per Gallon Relative to Current Product -$4.61

Assumptions: (1) Cost of "All Others" or "Additives" remains at $1.50 per pound

(2) Average unit size = 1 gallons

(3) RCM: Assumed Compliant Resin Cost Multiplier.

 RCM = 1.0 unless otherwise specified.

Typical Compliant

Component

(A)

Unit Cost 

($/lb)

(B)

RCM

(C)

Typical Non-Compliant