RULE 410.8 Aerospace Assembly and Coating Operations - Adopted 3/13/2014 

I. Purpose

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

aerospace coatings and adhesives, and from cleaning, stripping, storing, and disposal of 

organic solvents and waste solvent materials associated with the use of aerospace coatings 

and adhesives. This rule also provides administrative requirements for recording and 

measuring VOC emissions. 

II. Applicability

Except as provided in Section IV, the provisions of this rule are applicable to the 

manufacturing, assembling, coating, masking, bonding, paint stripping, surface cleaning, 

service, and maintenance of aerospace components, and the cleanup of equipment, storage, 

and disposal of solvents and waste solvent materials associated with these operations. 

III. Definitions

A. Ablative Coating: A coating that chars when exposed to open flame or extreme 

temperatures, as would occur during the failure of an engine casing or during 

aerodynamic heating. The ablative char surface serves as an insulative barrier, 

protecting adjacent components from heat or open flame. 

B. Adhesion Promoter: A coating applied to a substrate in a monomolecular thickness to 

promote wetting and form a chemical bond with the subsequently applied material. 

C. Adhesive: A substance that is used to bond one surface to another. 

D. Adhesive Bonding Primer: A coating applied in a very thin film to aerospace adhesive 

bond detail components for corrosion inhibition and adhesion. 

E. Aerosol Coating: A mixture of pigments, resins, and liquid and gaseous solvents and 

propellants packaged in a disposable container for hand-held application. 

F. Aerospace Component: Any raw material, partial or completed fabricated part, 

assembly of parts, or completed unit of any aircraft, helicopter, missile, or space 

vehicle, including integral equipment such as models, mock-ups, prototypes, molds, 

jigs, tooling, hardware jackets, and test coupons. 

G. Aerospace Material: Any coating, primer, adhesive, sealant, maskant, lubricant, 

stripper or hand-wipe cleaning or clean-up solvent used during the manufacturing, 

assembly, refinishing, maintenance or service of an aerospace component. Preservative 

oils and compounds, form release agents not containing solids, greases, and waxes are 

not aerospace materials for the purpose of this rule. 

H. Antichafe Coating: A coating applied to areas of moving aerospace components which 

may rub during normal operation. 

EKAPCD 410.8-1 3/13/2014 
I. Antique Aerospace Vehicle or Component: An aircraft or component thereof that was 

built at least 30 years ago. An antique aerospace vehicle would not routinely be in 

commercial or military service in the capacity for which it was designed. 

J. Anti-Wicking Wire Coating: The outer coating of a wire which prevents fluid wicking 

into the insulation of the wire. 

K. Air Pollution Control Officer (APCO): Eastern Kern Air Pollution Control District Air 

Pollution Control Officer, or his designee. 

L. ARB: California Air Resources Board. 

M. ASTM: American Society for Testing and Materials. 

N. Barrier Coating: A coating applied in a thin film to fasteners to inhibit dissimilar metal 

corrosion and to prevent galling. 

O. Bearing Coating: A coating applied to an antifriction bearing, a bearing housing, or the 

area adjacent to such a bearing in order to facilitate bearing function or to protect the 

base material from excessive wear. A material shall not be classified as a bearing 

coating if it can also be classified as a dry lubricative material or a solid film lubricant. 

P. Brush Coating: Manual application of coatings using brushes and rollers. 

Q. Caulking and Smoothing Compounds: Semi-solid materials which are applied by hand 

application methods and are used to aerodynamically smooth exterior vehicle surfaces 

or fill cavities such as bolt hole accesses. A material shall not be classified as a 

caulking and smoothing compound if it can also be classified as a sealant. 

R. Chemical Agent-Resistant Coating (CARC): An exterior topcoat designed to withstand 

exposure to chemical warfare agents or the decontaminants used on these agents. 

S. Chemical Milling: The removal of metal by chemical action of acids or alkalis. 

T. Clear Topcoat: A clear or semi-transparent coating applied over a primer for purposes 

such as appearance, identification, or protection. 

U. 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 excluding preservative oils and compounds, form 

release agents not containing solids, greases, and waxes. 

V. Commercial Exterior Aerodynamic Structure Primer: A primer utilized for the purpose 

of extended corrosion protection, which is only used on the exterior of passenger and 

cargo doors, supporting door structures, aerodynamic components, and structures of 

commercial aircraft which protrude from the fuselage, such as wings and attached 

components, control surfaces, horizontal stabilizer, vertical fins, wing-to-body fairings, 

antennae, landing gear and landing gear doors. 

EKAPCD 410.8-2 3/13/2014 
W. Composite Partial Pressure: The sum of the partial pressures of the VOC compounds in 

a solvent. The VOC composite partial pressure is calculated as follows: 

n (Wi)(VPi) Σ i=1 MWi PPc = Ww k We n Wi

MWw + Σ e=1 MWe + Σ i=1 MWi

Where: 

Wi = Weight of the “i”th VOC compound, in grams 

Ww = Weight of water, in grams 

We = Weight of exempt compound, in grams 

MWi = Molecular weight of the “i”th VOC compound, in grams per gram-mole 

MWw = Molecular weight of water, in grams per gram-mole 

MWe = Molecular weight of the “e”th exempt compound, in grams per gram-mole 

PPc = VOC composite partial pressure at 20o

C (68oF), in mm Hg 

VPi = Vapor pressure of the “i”th VOC compound at 20o

C (68oF), in mm Hg 

X. Conformal Coating: A coating applied to electrical conductors and circuit boards to 

protect them against electrical discharge damage and/or corrosion. 

Y. Decorative Laminate Primer: An adhesive bonding primer which is applied to a 

substrate to enhance adhesion between the decorative laminate and the subsequently 

applied substrate, and is cured at a maximum temperature of 250°F. 

Z. Dip Coating: The process in which a substrate is immersed in a solution (or dispersion) 

containing the coating and then withdrawn. 

AA. Dry Lubricative Coating: A coating consisting of lauric acid, cetyl alcohol, waxes, or 

other non-cross linked or resin-bound materials which act as a dry lubricant or 

protective coat. 

BB. Electric-Effect Coating: An electrically-conductive coating. 

CC. Electrodeposition: A dip coating application method where the paint solids are given 

an electrical charge which is then attracted to a substrate. 

DD. Electromagnetic Interference (EMI) Coating: A coating applied to space vehicles, 

missiles, aircraft radomes, and helicopter blades to disperse static energy or reduce 

electromagnetic interference. 

EE. Electronic Wire Coating: The outer electrical insulation coating applied to tape 

insulation of a wire specifically formulated to smooth and fill edges. 

FF. Electrostatic Application: A sufficient charging or atomized paint droplets to cause 

deposition principally by electrostatic attraction. This application shall be operated at a 

minimum 60 KV power. 

EKAPCD 410.8-3 3/13/2014 
GG. EPA: United States Environmental Protection Agency. 

HH. Epoxy Based Fuel Tank Coating: A coating which contains epoxy resin that is applied 

to integral fuel tank components of aircraft to protect the fuel tank from corrosion and 

the by-products of bacterial growth. 

II. Epoxy Polyamide: A tough chemically resistant polyamide-cured epoxy coating that 

provides long-term protection for alloys exposed to hot corrosive environments. 

JJ. Fastener Sealant: A sealant applied to a device used to join two or more parts together. 

KK. Fire Resistant Coating - Civilian (interior): A cabin interior coating that passes Federal 

Aviation Administration standards using the Ohio State University Heat Release, Fire 

and Burn Tests. 

LL. Flight Test Coating: A coating applied to an aircraft prior to flight testing to protect the 

aircraft from corrosion and to provide required marking during flight test evaluation. 

MM. Flow Coating: A coating application system with no air supplied to the nozzle and 

where paint flows over the part and the excess coating drains back into a collection 

system. 

NN. Fuel Tank Adhesive: An adhesive used to bond components continuously exposed to 

fuel and which must be compatible with and used with fuel tank coatings. 

OO. Fuel Tank Coating: A coating applied to the interior of a fuel tank or areas of an 

aircraft that are continuously wetted by fuel to protect it from corrosion and/or bacterial 

growth. 

PP. Grams of VOC per Liter of Coating, Less Water and Exempt Compounds: The weight 

of VOC content per combined volume of VOC and coating solids and can be calculated 

by the following equation: 

Grams of VOC per liter of coating, Ws - Ww - Wec

less water and exempt compounds = Vm - Vw – Vec 

Where: 

Ws = weight of volatile compounds (grams) 

Ww = weight of water (grams) 

Wec = weight of exempt compounds (grams) 

Vm = volume of material (liters) 

Vw = volume of water (liters) 

Vec = volume of exempt compounds (liters) 

EKAPCD 410.8-4 3/13/2014 
QQ. Grams of VOC per Liter of Material: The weight of VOC per volume of material and 

can be calculated by the following equation:

Ws - Ww - Wec Grams of VOC per liter of material = Vm 

Where: 

Ws = weight of volatile compounds (grams) 

Ww = weight of water (grams) 

Wec = weight of exempt compounds (grams) 

Vm = volume of material (liters) 

RR. Hand Application Methods: The application of coatings, sealants, or adhesives by nonmechanical hand-held equipment including but not limited to paint brushes, hand 

rollers, caulking guns, trowels, spatulas, syringe daubers, non-refillable aerosol cans, 

rags, and sponges. 

SS. High Temperature Coating: A coating that is certified to withstand temperatures of 

more than 350°F. 

TT. High-Volume, Low-Pressure (HVLP) Spray Equipment: Spray equipment permanently 

labeled as such and which is designed and operated between 0.1 and 10 pounds per 

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

the air cap and at the air horns and with liquid supply pressure less than 50 psig. 

UU. Impact Resistant Coating: A flexible coating that protects aerospace components, such 

as aircraft landing gear, landing gear compartments, and other surfaces subject to 

abrasive impacts from runway debris. 

VV. Intermediate Release Coating: A thin coating applied beneath topcoats to assist in 

removing the topcoat in depainting operations and generally to allow the use of less 

hazardous depainting methods. 

WW. Lacquer: A clear or pigmented coating formulated with a nitrocellulose or synthetic 

resin to dry by evaporation without a chemical reaction. Lacquers are resoluble in their 

original solvent. 

XX. Liquid Leak: A visible solvent leak from a container at a rate of more than three drops 

per minute or a visible liquid mist. 

YY. Long Term Adhesive Bonding Primer (Metal to Structural Core Bonding): An 

adhesive bonding primer that has met the aircraft manufacturers’ required performance 

characteristics following 6000 hours testing. Used for metal to structural core bonding 

and with an adhesive that is specified to be cured at 350°F ± 10°F. 

ZZ. Maskant for Chemical Milling: A coating applied directly to an aerospace component 

to protect surface areas when chemical milling such component. 

EKAPCD 410.8-5 3/13/2014 
AAA. Metalizing Epoxy Coating: A coating that contains relatively large quantities of 

metallic pigmentation for appearance and/or added protection. 

BBB. Mold Release: A coating applied to a mold surface to prevent the molded piece from 

sticking to the mold as it is removed. 

CCC. Non-Absorbent Container: A container made of non-porous material that does not 

allow the migration of solvents through it. 

DDD. Non-Leaking Container: A container without liquid leak. 

EEE. Non-Structural Adhesive: An adhesive that bonds non-load carrying aircraft 

component in non-critical applications. 

FFF. Normal Business Hours: Monday through Friday, 8:00 am to 5:00 pm. 

GGG. Optical Anti-Reflective Coating: A coating with a low reflectance in the infrared and 

visible wavelength range and is used for anti-reflection on or near optical and laser 

hardware. 

HHH. Organic Solvent: The same as “Solvent.” 

III. Organic Solvent Cleaning: As defined in Rule 410.3, Organic Solvent Degreasing 

Operations. 

JJJ. Part Marking Coating: Coatings or inks used to make identifying markings on 

materials, components, or assemblies. These markings may be permanent or 

temporary. 

KKK. Phosphate Ester Resistant Wire Ink Coating: A coating that is used for surface 

identification, mark on aerospace wire or cable, and inhibits the corrosion caused by 

contact with phosphate ester type hydraulic fluids. 

LLL. Pretreatment Coating: A coating which contains no more than 12 percent solids by 

weight and at least one-half (0.5) percent acid by weight and is applied directly to metal 

surfaces to provide surface etching, corrosion resistance, adhesion, and ease of 

stripping. 

MMM. Primer: A coating applied directly to an aerospace component for purposes of 

corrosion prevention, protection from the environment, functional fluid resistance, and 

adhesion of subsequent coatings, adhesives, or sealants. 

NNN. Radiation-Effect Coating: A coating which helps in the prevention of radar detection. 

OOO. Rain Erosion Resistant Coating: A coating that protects leading edges, flaps, 

stabilizers, and engine inlet lips against erosion caused by rain during flight. 

PPP. Remanufactured Aircraft Part: An aerospace component that is built as a spare part or 

replacement part subject to an existing commercial aircraft specification. 

EKAPCD 410.8-6 3/13/2014 
QQQ. Rocket Motor Nozzle Coating: A catalyzed epoxy coating system used in elevated 

temperature applications on rocket motor nozzles. 

RRR. Roll Coating: Application of coatings from a paint trough to a flat surface by 

mechanical series of rollers. 

SSS. Scale Inhibitor: A coating that is applied to the surface of a part prior to thermal 

processing to inhibit the formation of tenacious scale. 

TTT. SCAQMD: South Coast Air Quality Management District. 

UUU. Screen Print Ink: An ink used in screen printing processes during fabrication of 

decorative laminates and decals. 

VVV. Sealant: A viscous semisolid material that is applied with a syringe, caulking gun, or 

spatula to fill voids in order to seal out water, fuel, other liquids and solids, and in some 

cases air movement. 

WWW.Silicone Insulation Material: An insulating material applied to exterior metal surfaces 

for protection from high temperatures caused by atmospheric friction or engine exhaust. 

These materials differ from ablative coatings in that they are not “sacrificial”. 

XXX. Short Term Adhesive Bonding Primer: An adhesive bonding primer that has met the 

manufacturers’ required performance characteristics following 1000 hours testing. 

Used for metal to metal and metal to structural core bonding with an adhesive which is 

specified to be cured at a temperature of 350°F ± 10°F. 

YYY. Solid Film Lubricant: A very thin coating consisting of a binder system containing as 

its chief pigment material one (1) or more of the following: molybdenum disulfide, 

graphite, polytetrafluoroethylene (PTFE) or other solids that act as a dry lubricant 

between closely-fitting surfaces. 

ZZZ. Solvent: As defined in Rule 410.3, Organic Solvent Degreasing Operations. 

AAAA. Sonic and Acoustic Applications: The use of aerospace materials on aerospace 

components that are subject to mechanical vibration or sound wave cavitation. 

BBBB. Space Vehicle Coating: A coating applied to a vehicle designed to travel and operate 

beyond earth's atmosphere. 

CCCC. Specialty Coating: A coating that, even though it meets the definition of a primer, 

topcoat, or self-priming topcoat, has additional performance criteria beyond those of 

primers, topcoats, and self-priming topcoats for specific applications. These 

performance criteria may include, but are not limited to, temperature or fire resistance, 

substrate compatibility, antireflection, temporary protection or marking, sealing, 

adhesively joining substrates, or enhanced corrosion protection. 

EKAPCD 410.8-7 3/13/2014 
DDDD. Specialized Function Coating: A coating that fulfills specific engineering requirements 

that are limited in application and characterized by low volume usage. This category 

excludes coatings covered in other Specialty Coating categories. 

EEEE. Stripper: A volatile liquid applied to remove a maskant for chemical processing, cured 

or dried paint, cured or dried paint residue, or temporary protective coating. 

FFFF. Structural Adhesive - Autoclavable: An adhesive used to bond load-carrying aircraft 

components and is cured by heat and pressure in an autoclave. 

GGGG. Structural Adhesive - Nonautoclavable: An adhesive cured under ambient conditions 

and is used to bond load-carrying aircraft components or other critical functions, such 

as nonstructural bonding near engines. 

HHHH. Surface Cleaning: Any method of cleaning outside of a degreaser, including, but not 

limited to, wipe cleaning and equipment flushing. 

IIII. Temporary Protective Coating: A coating applied to an aerospace component to protect 

it from mechanical and environmental damage during manufacturing or shipping. 

JJJJ. Thermal Control Coating: A coating formulated with specific thermal conductive or 

radiative properties to permit temperature control of the substrate. 

KKKK. Topcoat: A coating applied over a primer for purposes such as appearance, 

identification, or protection. 

LLLL. Touch-Up Operation: The application of Aerospace Materials to repair minor surface 

damage and imperfections after the main coating process. 

MMMM.Transfer Efficiency: The ratio of the weight or volume of coating solids adhering to the 

part being coated to the weight or volume of coating solids used in the application 

process expressed as a percentage. 

NNNN. Unicoat: A coating that is applied directly to an aerospace component for purposes of 

corrosion protection, environmental protection, and functional fluid resistance that is 

not subsequently topcoated. A unicoat is used in lieu of the application of a primer and 

a topcoat. 

OOOO. Volatile Organic Compounds (VOCs): As defined in Rule 102, Definitions. 

QQQQ. Waste Solvent Material: Any solvent which may contain dirt, oil, metal particles, 

sludge, or waste products; or wiping material containing VOCs including, but not 

limited to, paper, cloth, sponge, rag, or cotton swab used in organic solvent cleaning. 

RRRR. Wet Fastener Installation Coating: A primer or sealant applied by dipping, brushing, or 

daubing to fasteners that are installed before the coating is cured. 

SSSS. Wing Coating: A coating that is corrosion resistant and is resilient enough to withstand 

the flexing of wings. 

EKAPCD 410.8-8 3/13/2014 
IV. Exemptions

A. Jet engine or rocket engine flushing operations using any solvent other than 

trichloroethylene are exempt from this rule. 

B. Coatings applied using non-refillable aerosol spray containers. 

C. Except for the provisions of Section VI, VOC limits for solvents and strippers listed in 

Section V shall not apply to space vehicle manufacturing. 

D. Except for the recordkeeping provisions of Sections VI.A.1 and VI.A.4, the 

requirements of Section V shall not apply to aerospace assembly and component 

coating facilities using not more than four (4) gallons of products containing VOCs per 

day. Solvent-containing materials used in operations subject to Rule 410.3, Organic 

Solvent Degreasing Operations shall not be included in this determination. 

E. Except for the provisions of Section VI, Section V shall not apply to laboratories which 

apply coatings, solvents, and adhesives to test specimens for purpose of research, 

development, quality control, and testing for production-related operations. Any person 

claiming this exemption shall provide operational records, data, and calculations as 

determined by the APCO to be necessary to substantiate this claim. 

F. Coatings that have been designated as “classified” by the Department of Defense or 

used on space vehicles are exempt from the VOC content limits of the following 

categories as listed in the Table of Standards: 

1. Ablative Coating, Bearing Coating, Caulking and Smoothing Compounds, 

Chemical Agent-Resistant Coating, Electromagnetic Interference Coating, 

Intermediate Release Coating, Lacquer, Metalized Epoxy Coating, Mold Release, 

Part Marking Coating, Rocket Motor Nozzle Coating, Silicone Insulation Material, 

Specialized Function Coating, Thermal Control Coating, Epoxy Polyamide, and 

Wet Fastener Installation Coating; 

2. The Fastener Sealant category is exempt from the 600 g/l VOC limit but must still 

comply with the 675 g/l VOC limit; 

3. The Sealant (Extrudable/Rollable/Brushable) category is exempt from the 280 g/l 

VOC limit but must still comply with the 600 g/l VOC limit. 

G. Provisions of Section V.A. shall not apply to: 

1. Coatings or refillable aerosols with separate formulations that are used in volumes 

of less than fifty (50) gallons in any calendar year provided that the total of such 

formulations applied annually by a facility is less than 200 gallons; 

2. Adhesives with separate formulations that are used in volumes of less than one half 

(0.5) gallon on any day or less than ten (10) gallons in any calendar year; 

3. Touch-up coatings and stencil coatings; or 

EKAPCD 410.8-9 3/13/2014 
4. Rework operations performed on antique aerospace vehicles or associated 

components. 

Any operator seeking to claim the exemption in Section IV.F shall notify the APCO in 

writing that substitute compliant coatings are not available. 

H. The provisions of Section V.E. shall not apply to the application of coatings that 

contain less than 20 grams of VOC per liter of coating less water and exempt 

compounds. 

V. Requirements

A. Aerospace Coatings and Adhesives: An operator shall not apply to any aerospace 

component, any coating, aerosol, or adhesive with a VOC content, less water and 

exempt compounds, as applied, in excess of the limits listed in the Table of Standards 

for Aerospace Component Products Containing VOCs. 

TABLE OF STANDARDS 

VOC CONTENT LIMITS FOR AEROSPACE COMPONENT COATING PRODUCTS

Content expressed in Grams per Liter 

Less Water and Exempt Compounds 

VOC Content Category VOC Limit 

I. PRIMERS 

1. General 350 

2. Adhesive Bonding Primers 

a. Commercial Aircraft 250 

b. Military Aircraft 805 

3. Commercial Exterior Aerodynamic Structure Primer 650 

4. Compatible Substrate Primer 780 

5. Cryogenic Flexible Primer 645 

6. Elevated-Temperature Skydrol-Resistant Commercial Primer 740 

7. Flexible Primer 640 

8. Low-Solids Corrosion Resistant Primer 350 

9. Primer Compatible with Rain Erosion-Resistant Coating 850 

II. COATINGS 

1. Ablative Coating 600 

2. Adhesion Promoter Coating 850 

3. Antichafe Coating 600 

4. Bearing Coating 6201

5. Chemical Agent-Resistant Coating 5501

EKAPCD 410.8-10 3/13/2014 
TABLE OF STANDARDS Continued 

VOC Content Category VOC Limit 

6. Conformal Coating 750 

7. Cryoprotective Coating 600 

8. Electricomagnetic/Radiation Effect Coating 800 

9. Electromagnetic Interference (EMI) Coating 8001

10. Fire-Resistant (Interior) Coating 

a. Civilian 650 

b. Military 800 

c. Space 800 

11. Flight-Test Coating 

a. Used on Missiles or Single Use Aircraft 420 

b. All Other 840 

12. Fuel-Tank Coating 

a. General 420 

b. Rapid Cure 720 

13. High-Temperature Coating 850 

14. Impact-Resistant Coating 420 

15. Intermediate Release Coating 7501

16. Lacquer Coating 830 

17. Metallized Epoxy Coating 7401

18. Mold Release Coatings 7801

19. Optical Anti-Reflection Coating 700 

20. Part Marking Coating 8501

21. Pretreatment Coating 780 

22. Rain Erosion-Resistant Coating 800 

23. Rocket Motor Nozzle Coating 6601

24. Scale Inhibitor Coating 880 

25. Space-Vehicle Coatings, Other: does not include Electric 

Discharge and EMI Protection Coating or Fire-Resistant 

(Interior) Coating 

1000 

26. Specialized Function Coating 8901

27. Temporary Protective Coating 250 

28. Thermal Control Coating 8001

29. Topcoat 

a. Clear 520 

b. Epoxy Polyamide 6601

c. Other 420 

30. Unicoat Coating (Self Priming Topcoats) 420 

31. Wet Fastener Installation Coating 6751

EKAPCD 410.8-11 3/13/2014 
TABLE OF STANDARDS Continued 

VOC Content Category VOC Limit 

32. Wing Coating 750 

33. Wire Coatings 

a. Electronic 420 

b. Anti-Wicking 420 

c. Pre-Bonding Etchant 420 

d. Phosphate Ester Resistant Ink 925 

III. ADHESIVES

1. Commercial Interior Adhesive 760 

2. Cyanoacrylate Adhesive 1020 

3. Fuel-Tank Adhesive 620 

4. Non-Structural Adhesive 250 

5. Rocket Motor Bonding Adhesive 890 

6. Rubber-Based Adhesive 850 

7. Space Vehicle Adhesive 800 

8. Structural Adhesive 

a. Autoclavable 50 

b. High Temperature - Autoclavable 650 

c. Non-Autoclavable 850 

IV. SEALANTS

1. Rollable, Brushable or Extrudable Sealant 2802

2. Fastener Sealant 675 

3. Other 600 

V. MASKANTS

1. Bonding Maskant 1230 

2. Critical Use and Line Sealer Maskant 750 

3. Chemical Milling Maskant 

a. For use with Type I Etchant 250 

b. For use with Type II Etchant 160 

c. For Chemical Processing 

*Less water, Exempt Compounds and (PERC) 250* 

4. Photolithographic Maskant 850 

5. Seal Coat Maskant 1230 

EKAPCD 410.8-12 3/13/2014 
TABLE OF STANDARDS Continued 

VOC Content Category VOC Limit 

VI. LUBRICANTS -- 

1. Fastener Installation Lubricant 

(applied at time of Aircraft/component assembly) 

a. Solid-Film Lubricant 880 

b. Dry Lubricative Material 675 

2. Fastener Lubricative Coating 

(applied at time of Fastener Manufacture) 

a. Solid-Film Lubricant 250 

b. Dry Lubricative Material 120 

c. Barrier Coating 420 

3. Non-Fastener Lubricative Coatings 

(applied at time of non-Fastener Manufacture) 

a. Solid-Film Lubricant 880 

b. Dry Lubricative Materials 675 

VII. OTHER

1. Caulking and Smoothing Compound 850 

2. Corrosion Prevention Compound System 710 

3. Insulation Covering 740 

4. Screen Print Ink 840 

5. Silicone Insulation Material 850 

1 Coatings that have been designated as “classified” by the Department of Defense or 

coatings that are used on space vehicles are exempt from these coating limits. 

2 Coatings that have been designated as “classified” by the Department of Defense or 

coatings that are used on space vehicles are exempt from the 280 g/l limit, but must 

comply with a 600 g/l limit. 

B. Evaporative Loss Minimization

1. Surface Cleaning: No operator shall use a solvent for surface cleaning, clean-up, or 

jet engine or rocket engine gas path cleaning or flushing. Not exempt under Section 

IV of this rule, excluding stripping coatings or cleaning coating application 

equipment, unless: 

a. The solvent contains less than 200 grams of VOC per liter (1.67 lb/gal) of 

material, as applied; or 

b. The VOC composite vapor pressure of the solvent is less than or equal to 45 

mm Hg (0.87 psia) at a temperature of 68°F. 

EKAPCD 410.8-13 3/13/2014 
2. Coating Application Equipment Cleaning

An operator shall not use VOC-containing materials to clean spray equipment used 

for the application of coatings, adhesives, or ink, unless one of the following 

methods is used: 

a. An enclosed system or equipment proven to be equally effective at controlling 

emissions is used for cleaning. The enclosed system must totally enclose spray 

guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining 

procedures; be used according to the manufacturer’s recommendations; and 

remain closed when not in use; 

b. Unatomized discharge of cleaning solvent into a waste container that is kept 

closed when not in use; 

c. Disassembled spray gun that is cleaned in a vat and kept closed when not in use; 

or 

d. Atomized spray into a waste container that is fitted with a device designed to 

capture atomized cleaning solvent emissions. 

3. In lieu of compliance with Sections V.B.1. or V.B.2. an operator may control VOC 

emissions from surface cleaning operations or from cleaning coating application 

equipment with a VOC emission control system that meets the requirements of 

Section V.F. 

C. Coating Strippers

1. No operator shall use or specify for use within the District a coating stripper unless 

it contains less than 300 grams of VOC per liter (2.5 lb/gal), as applied, or has a 

VOC composite vapor pressure of 9.5 mm Hg (0.18 psia) or less at 68°F. 

2. In lieu of compliance with Section V.C.1, an operator may control emissions from 

coating stripper operations with a VOC emission control system that meets the 

requirements of Section V.F. 

D. Storage and Disposal of VOC Containing Materials: An operator shall store or dispose 

of fresh or spent solvents, waste solvent cleaning materials such as cloth, paper, etc., 

coatings, adhesives, catalysts, and thinners in closed nonabsorbent and non-leaking 

containers. Storage containers shall remain closed at all times except when depositing 

or removing the contents or when empty. 

E. Application Equipment Requirements: No operator shall apply any coating subject to 

the provisions of this rule unless one (1) of the following application methods is used: 

1. Brush, dip, flow, or roll coating conducted in accordance with manufacturer's 

recommendations; 

EKAPCD 410.8-14 3/13/2014 
2. Electrostatic or Electrodeposition application conducted in accordance with 

manufacturer's recommendations; 

3. HVLP spray equipment operated in accordance with manufacturer's 

recommendations: 

a. HVLP spray equipment manufactured prior to January 1, 1996, the end user 

shall demonstrate that the gun meets HVLP spray equipment standards. 

Satisfactory proof will be either in the form of manufacturer's published 

technical material or by a demonstration using a certified air pressure tip gauge, 

measuring the air atomizing pressure dynamically at the center of the air cap 

and at the air horns. 

b. A person shall not sell or offer for sale for use within the District any HVLP 

spray equipment without a permanent marking denoting the maximum inlet air 

pressure in psig at which the gun will operate within the parameters specified in 

Section III.TT. 

4. Spray gun: If a spray gun is used, the end user must demonstrate that the gun meets 

the HVLP definition in Section III.TT. in design and use. A satisfactory 

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

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

air pressure tip gauge from the manufacturer of the gun. 

5. Any alternative coating application method which has been demonstrated to achieve 

at least 65 percent transfer efficiency or the equivalent efficiency of HVLP spray 

equipment and approved, in writing, by APCO. 

8. In lieu of compliance with Sections V.E.1. through V.E.5., an operator may control 

VOC emissions from application equipment with a VOC emission control system 

that meets the requirements of Section V.F. 

F. VOC Emission Control System

As an alternative to meeting the requirements of Sections V.A., V.B., V.C., or V.E., an 

operator may install a VOC emission control system provided that the VOC emission 

control system meets all of the following requirements: 

1. The VOC emission control system shall be approved by the APCO. 

2. The VOC emission control system shall comply with the requirements of Sections 

V.F.3. through V.F.5. during periods of emission-producing activities. 

3. The VOC emission control system collection device shall have a control efficiency 

of at least 95 percent, by weight. 

4. The VOC emission control system can demonstrate a capture efficiency of at least 

90 percent by weight. 

EKAPCD 410.8-15 3/13/2014 
5. In no case shall compliance through the use of a VOC emission control system 

result in VOC emissions in excess of the VOC emissions which would result from 

compliance with applicable provisions of Sections V.A., V.B., V.C., or V.E. 

6. The minimum required overall capture and control efficiency of an emission control 

system at which an equivalent or greater level of VOC reduction will be achieved 

shall be calculated by using the following equation: 

VOC LWc 1-(VOC LWn,Max / Dn,Max ) CE = 1- x 100 VOC LWn,Max

x 1- (VOC LWc / Dc) 

Where: 

CE = Minimum Required Overall Capture and Control 

Efficiency, percent 

VOCLWc = VOC Limit, less water and exempt compounds 

VOCLWn,Max = Maximum VOC content of noncompliant coating used 

in conjunction with a control device, less water and 

exempt compounds 

Dn,Max = Density of solvent, reducer, or thinner contained in 

the noncompliant coating, containing the maximum 

VOC content of the multi-component coating 

Dc = Density of corresponding solvent, reducer, or thinner 

used in the compliant coating system. 

G. Prohibition of Solicitation: No person shall solicit, specify, or require an operator to 

use any coating, solvent, spray equipment, or VOC emission control system that does 

not meet the limits or requirements of this rule. 

H. Sell-Through/Existing Stock of Coatings: A coating manufactured prior to amendment 

date of this rule, that complied with the VOC Content limit(s) in effect at that time, may 

be sold, supplied, or offered for sale for 12 months after rule adoption date. Such a 

coating may be applied at any time, both before and after adoption date, provided 

manufacture Date-Code and VOC Content is clearly printed on coating container. 

I. Specialized Military Coating Operations VOC Requirements: APCO may approve 

alternative VOC or vapor pressure limits for coatings, adhesives or solvents that are 

specified in specialized military Technical Orders, for which no viable substitutions are 

available. The owner/operator must submit a written request to the APCO, and present 

documentation and sufficient justification regarding the operation and materials. 

EKAPCD 410.8-16 3/13/2014 
VI. Administrative Requirements

A. Recordkeeping

1. An operator subject to the requirements of this rule shall have coating 

manufacturer's specifications, either listed on the coating container, product data 

sheet, or on Safety Data Sheet (SDS), available for review and shall maintain daily 

records which show the following information as applicable: 

a. Manufacturer name and type for each coating, solvent, thinner, reducer or 

stripper used; 

b. Mix ratio by volume of components added to the original material prior to 

application; 

c. Grams of VOC per liter of each coating, solvent, thinner, reducer, or stripper 

less water and exempt compounds, as applied; 

d. Volume and method of application of each coating, solvent, thinner, reducer, or 

stripper applied; and 

e. Vapor pressure of solvents used. 

2. An operator shall maintain records to support that the following coatings have been 

specified for their intended application: 

a. Adhesion promoter; 

b. Antichafe coating; 

c. Electric/radiation effect; 

d. Fuel tank adhesive; 

e. High temperature coating; 

f. Impact resistant coating; 

g. Optical anti-reflective coating; 

h. Rain erosion resistant wing coating. 

3. An operator using a VOC emission control system pursuant to Section V.F. as a 

means of complying with this Rule, shall maintain daily records of key system 

operating parameters and maintenance procedures, which will demonstrate 

continuous operation and compliance of the VOC emission control system during 

periods of emission-producing activities. Key system operating parameters are 

those necessary to ensure compliance with VOC limits. The parameters may 

include, but are not limited to, temperatures, pressures, and flow rates. 

4. Records required by this Rule shall be retained for a minimum of five (5) years and 

made available on site during normal business hours to the APCO, ARB, or EPA 

upon request. 

EKAPCD 410.8-17 3/13/2014 
EKAPCD 410.8-18 3/13/2014 

B. Test Methods

1. Coating and solvent VOC content shall be determined using EPA Method 24 or its 

constituent methods. The VOC content of coatings containing exempt halogenated 

VOCs shall be determined by using ARB Method 432, “Determination of 

Dichloromethane and 1,1,1- Trichloroethane in Paints and Coatings” (September 

12, 1998). or SCAQMD Method 303 (Determination of Exempt Compounds). 

2. The solid content of pretreatment coatings shall be determined using EPA Method 

24. The acid content of pretreatment coatings shall be determined using ASTM 

Method D1613 06 (Standard Test for Acidity of Volatile Solvents and Chemical 

Intermediates used in Paint, Varnish, Lacquer and Related Products). 

3. The test method for determining the fire resistance of an interior coating shall be 

Federal Aviation Administration-required Ohio State University Heat Release, Fire 

and Burn Tests. 

4. The VOC composite vapor pressure of a blended solvent shall be determined by 

quantifying the amount of each organic compound in the blend using gas 

chromatographic analysis SCAQMD Test Method 308-91 “Quantitation of 

Compounds by Gas Chromatography” (February 1993) and by calculating the VOC 

composite vapor pressure of the solvent by summing the product of the vapor 

pressure of each pure component and its molar fraction. For the purpose of this 

calculation, the blend shall be assumed to be an ideal solution where Raoult's Law 

applies. The vapor pressure of each pure component shall be obtained from 

published reference manuals or handbooks. 

5. VOC emissions from enclosed systems used to clean coating application equipment 

shall be determined by the manufacturer using the SCAQMD General Test Method 

for Determining Solvent Losses from Spray Gun Cleaning Systems. 

6. The control efficiency of a VOC emission control system’s control device(s) shall 

be determined using EPA Methods 2, 2A, 2C, or 2D for measuring flow rates and 

EPA Methods 25, 25A, or 25B for measuring the total gaseous organic 

concentrations at the inlet and outlet of the control device. EPA Method 18 or ARB 

Method 422, “Determination of Volatile Organic Compounds in Emissions from 

Stationary Sources” (September 12, 1990) shall be used to determine the emissions 

of exempt compounds. 

7. The capture efficiency of a VOC emission control system’s collection device(s) 

shall be determined according to EPA’s “Guidelines for Determining Capture 

Efficiency,” January 9, 1995 and 40 CFR 51, Appendix M, Methods 204-204F, as 

applicable, or any other method approved by EPA, ARB, or APCO. 

8. When more than one test method or set of test methods are specified for any 

emissions testing, a violation of any test established in Section VI.B. shall constitute 

a violation of the Rule.