Santa Barbara County APCD Rule 337 337 - 1 June 21, 2012 

RULE 337. SURFACE COATING OF AEROSPACE VEHICLES AND COMPONENTS. (Adopted 

7/10/1990, revised 7/24/1990, 10/20/1994, and 6/21/2012) 

A. Applicability

 This rule is applicable to any person who manufactures any aerospace vehicle coating or aerospace 

component coating for use within the District, as well as any person who uses, applies, or solicits the use or 

application of any aerospace vehicle or component coating or associated solvent within the District. Rule 

337 does not apply to electronic components. 

B. Exemptions

 1. Section D.1 shall not apply to any non-complying coatings with separate formulations used in 

volumes of less than 20 gallons of each non-complying formulation per stationary source in any 

calendar year. To qualify for this exemption from Section D.1, the total volume of non-complying 

coatings used at a stationary source does not exceed 200 gallons annually. Coatings used for 

operations that are exempt per Sections B.2, B.3, B.6, B.8, B.11, B.12, and B.13 shall not be 

included in calculating the volume of coatings used under this exemption. Any person claiming 

this exemption shall maintain on a daily basis records consistent with Section H.7 and make them 

available to the District for review upon request. 

 2. Section E and H shall not apply to touch-up and repair, provided Section D.1 limits are met and 

records are maintained pursuant to a Permit to Operate. 

 3. This rule shall not apply to coatings (including adhesive products and sealant products) supplied 

as aerosol products in non-refillable containers. 

 4. Any coating and associated solvent subject to the requirements of this rule shall be exempt from 

the requirements of Rule 317, Organic Solvents, and Rule 322, Metal Surface Coating Thinner and 

Reducer. Any coating exempt from this rule shall comply with all other applicable District Rules. 

5. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that 

contains two percent by weight or less of each of the following: 

a. Reactive organic compounds, and 

b. Toxic air contaminants (as determined by generic solvent data, solvent manufacturer’s 

composition data or by a gas chromatography test and a mass spectrometry test). 

c. Any person claiming this exemption shall maintain the records specified in Sections 

H.1.a and H.1.f in a manner consistent with Section H.9 and make them available for 

review. 

6. This rule shall not apply to coatings that contain less than 20 grams of reactive organic compound 

per liter (0.17 pounds of reactive organic compound per gallon) of coating, less water and less 

exempt compounds, as applied. 

7. Section D.2 and J.1.a shall not apply to solvents and strippers used in space vehicle manufacturing 

and rework. 

8. This rule shall not apply to chemical milling and electrodeposition (except for electrodeposition of 

coatings). 

9. Section J.1.a shall not apply to any of the following: 
Santa Barbara County APCD Rule 337 337 - 2 June 21, 2012 

a. Cleaning of encasements, including decoy shells or box casings, for electronic 

components that have a total surface area that is less than 2 square feet; 

b. Cleaning of parts, subassemblies, or assemblies that are exposed to strong oxidizers or 

reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine); 

c. Cleaning of aircraft transparencies, polycarbonate, or glass substrates; 

d. Cleaning of solar cells, coated optics, laser hardware, scientific instruments, highprecision optics, telescopes, microscopes, avionic equipment, military fluid systems, and 

thermal control surfaces; 

e. Wipe cleaning during the manufacture, assembly, installation, maintenance, or testing of 

components of breathing oxygen systems that are exposed to the breathing oxygen; 

f. Wipe cleaning and surface activation prior to adhesive bonding; 

g. Wipe cleaning of aircraft and ground support equipment fluid systems that are exposed to 

the fluid, including air-to-air heat exchangers and hydraulic fluid systems; 

h. Wipe cleaning of fuel cells, fuel tanks, and confined spaces. 

10. Section E shall not apply to any of the following: 

a. Any situation that normally requires the use of an airbrush or an extension on the spray 

gun to properly reach limited access spaces; 

b. The use of airbrush application methods for stenciling, lettering, and other identification 

markings. 

11. The chemical milling maskant limits in Section D.1, Table 337-1, shall not apply to any of the 

following: 

a. Touch-up of scratched surfaces or damaged maskant; 

b. Touch-up of trimmed edges. 

12. Section D.1 shall not apply to electric- and radiation-effect coatings that have been designated as 

“classified” by the United States Department of Defense. 

13. This rule shall not apply to coatings (including adhesive products and sealant products) subject to 

the Air Resources Board consumer products regulation found in Title 17 of the California Code of 

Regulations, section 94507 et seq. 

14. Sections D.2 and J.1.a shall not apply to any of the following: 

a. Cleaning or stripping of coating overspray from personal protective equipment; 

b. Wipe cleaning or stripping during fabrication, assembly, installation, and maintenance of 

upholstery, curtains, carpet, and other textile materials used in the interior of the aircraft; 

c. Wipe cleaning or stripping of metallic and nonmetallic materials used in honeycomb 

cores during the manufacture or maintenance of these cores, and cleaning of the 

completed cores used in the manufacture of aerospace vehicles or components. 
Santa Barbara County APCD Rule 337 337 - 3 June 21, 2012 

C. Definitions 

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

definitions shall apply: 

“Ablative Coating” means any 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 the heat or open flame. 

“Adhesion Promoter” means any very thin coating applied to a substrate to promote wetting and form a 

chemical bond with the subsequently applied material. 

“Adhesive” means any substance that is used to bond one surface to another surface by attachment or fused 

union. Adhesives are a type of specialty coating. 

“Adhesive Bonding Primer” means any primer applied in a thin film to aerospace components for the 

purpose of corrosion inhibition and increased adhesive bond strength by attachment. 

“Adhesive Product” means any adhesive, glue, cement, mastic, adhesive bonding primer, adhesive primer, 

adhesive primer for plastics, and any other adhesive primer. Adhesive products are a type of coating. 

“Aerospace Vehicle or Component” means any fabricated part, processed part, assembly of parts, or 

completed unit, with the exception of electronic components, of any aircraft including but not limited to 

airplanes, helicopters, missiles, rockets, and space vehicles includes satellites. 

“Aircraft Fluid Systems” mean those systems that handle hydraulic fluids, fuel, cooling fluids, or oils. 

“Aircraft Transparency” means the aircraft windshield, canopy, passenger windows, lenses and other 

components which are constructed of transparent materials. 

“Airless Spray” means a spray method in which a pump forces the adhesive through an atomizing nozzle 

at high pressure (1,000 to 6,000 pounds per square inch). 

“Antichafe Coating” means any coating applied to areas of moving aerospace components that may rub 

during normal operations or installation. 

“Associated Solvent” means any solvent used in a solvent cleaning machine or for solvent cleaning 

performed in association with surface coating of any aerospace vehicle or aerospace component. 

“Barrier Coating” means any coating applied in a thin film to fasteners to inhibit dissimilar metal 

corrosion and to prevent galling. 

“Bearing Coating” means any 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 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. 

“Bonding Maskant” means any temporary coating used to protect selected areas of aerospace parts from 

strong acid or alkaline solutions during processing for bonding. 

“Caulking and Smoothing Compounds” mean 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. 
Santa Barbara County APCD Rule 337 337 - 4 June 21, 2012 

“Chemical Agent-Resistant Coating” means any exterior topcoat designed to withstand exposure to 

chemical warfare agents or the decontaminants used on these agents. 

“Chemical Milling Maskant” means any coating that is applied directly to aluminum components to 

protect surface areas when chemical milling the component with a Type I or Type II etchant. Type I 

chemical milling maskants are used with a Type I etchant and Type II chemical milling maskants are used 

with a Type II etchant. This definition does not include bonding maskants, critical use and line sealer 

maskants, and seal coat maskants. Additionally, maskants that must be used with a combination of Type I 

or II etchants and any of the above types of maskants (i.e., bonding, critical use and line sealer, and seal 

coat) are not included. Maskants that are defined as specialty coatings are not included under this 

definition. Section C provides definitions of Type I and Type II etchants. 

“Cleaning Operation” means collectively spray-gun, hand-wipe, and flush cleaning operations. 

“Cleaning Solvent” means any liquid material used for hand-wipe, spray gun, or flush cleaning. This 

definition does not include any solution that contains no reactive organic compounds and no toxic air 

contaminants. 

“Clear Coating” means a transparent coating usually applied over a colored opaque coating, metallic 

substrate, or placard to give improved gloss and protection to the color coat. In some cases, a clear coat 

refers to any transparent coating without regard to substrate. 

“Coating” means any material that is applied to the surface of an aerospace vehicle or component to form 

a decorative, protective, or functional solid film, or the solid film itself. Adhesives, sealants, and 

lubricative material are types of specialty coatings. 

“Commercial Exterior Aerodynamic Structure Primer” means any primer used on aerodynamic 

components and structures that protrude from the fuselage, such as wings and attached components, control 

surfaces, horizontal stabilizers, vertical fins, wing-to-body fairings, antennae, and landing gear and doors, 

for the purpose of extended corrosion protection and enhanced adhesion. 

“Commercial Interior Adhesive” means any material used in the bonding of passenger cabin interior 

components. These components must meet the Federal Aviation Administration fireworthiness 

requirements. 

“Compatible Substrate Primer” includes two categories: “compatible epoxy primer” and “adhesive 

primer.” “Compatible epoxy primer” means any primer that is compatible with the filled elastomeric 

coating and is epoxy based. The compatible substrate primer is an epoxy-polyamide primer used to 

promote adhesion of elastomeric coatings such as impact-resistant coatings. “Adhesive primer” means 

any coating that (1) inhibits corrosion and serves as a primer applied to bare metal surfaces or prior to 

adhesive application, or (2) is applied to surfaces that can be expected to contain fuel. Fuel tank coatings 

are excluded from this category. 

“Compliant Material” means any coating, stripper, or solvent that has a reactive organic compound 

content or composite partial pressure that complies with the applicable limit in Sections D.1, D.2, or J.1 

“Confined Space” means any space that (1) is large enough and so configured that an employee can bodily 

enter and perform assigned work; (2) has limited or restricted means for entry or exit (for example, fuel 

tanks, fuel vessels, and other spaces that have limited means of entry); and (3) is not suitable for continuous 

employee occupancy. 

“Contact Bond Adhesive” or “Contact Adhesive” means any adhesive intended by the manufacturer to 

adhere to itself instantaneously upon contact. The adhesive is applied to both adherends and allowed to 

become dry, which develops a bond when the adherends are brought together without sustained pressure. 

for application to both surfaces to be bonded together, is allowed to dry before the two surfaces are placed 

in contact with each other, forms an immediate bond that is impossible, or difficult, to reposition after both 
Santa Barbara County APCD Rule 337 337 - 5 June 21, 2012 

adhesive-coated surfaces are placed in contact with each other, and does not need sustained pressure or 

clamping of surfaces after the adhesive-coated surfaces have been brought together using sufficient 

momentary pressure to establish full contact between both surfaces. Contact adhesive does not include 

rubber cements that are primarily intended for use on paper substrates. Contact adhesive also does not 

include vulcanizing fluids that are designed and labeled for tire repair only. 

“Contact Bond Adhesive-Specialty Substrates” or “Specialty Contact Adhesive” means any contact 

adhesive that is intended by the manufacturer to be used for the bonding of nonporous substrates to each 

other, the bonding of decorative laminate in post-forming application, the bonding of decorative laminate to 

metal, melamine-covered board, or curved surfaces, or the bonding of any substrate to metal, rubber, rigid 

plastic, or wood veneer not exceeding 1/16 inch in thickness. 

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas 

stream prior to discharge to the atmosphere. 

 

“Control System” means any combination of pollutant capture system(s) and control device(s) used to 

reduce discharge to the atmosphere of reactive organic compound or toxic air contaminant emissions 

generated by a regulated operation. 

“Corrosion Prevention System” means any coating system that provides corrosion protection by 

displacing water and penetrating mating surfaces, forming a protective barrier between the metal surface 

and moisture. Coatings and compounds containing oils or waxes are excluded from this category. 

“Critical Use and Line Sealer Maskant” means any temporary coating, not covered under other maskant 

categories, used to protect selected areas of aerospace parts from strong acid or alkaline solutions such as 

those used in anodizing, plating, chemical milling and processing of magnesium, titanium, or high-strength 

steel, high-precision aluminum chemical milling of deep cuts, and aluminum chemical milling of complex 

shapes. Materials used for repairs or to bridge gaps left by scribing operations (i.e., line sealer) are also 

included in this category. 

“Cryogenic Flexible Primer” means any primer designed to provide corrosion resistance, flexibility, and 

adhesion of subsequent coating systems when exposed to loads up to and surpassing the yield point of the 

substrate at cryogenic temperatures (minus 275 degrees Fahrenheit and below). 

“Cryoprotective Coating” means any coating that insulates cryogenic or subcooled surfaces to limit 

propellant boil-off, maintain structural integrity of metallic structures during ascent or re-entry, and prevent 

ice formation. 

“Cyanoacrylate Adhesive” means any fast-setting, single component adhesive that cures at room 

temperature. Also known as "super glue." 

“Depainting” means the removal of a permanent coating from the outer surface of an aerospace vehicle or 

component. 

“Depainting Operation” means the use of a chemical agent, media blasting, or any other technique to 

remove permanent coatings from the outer surface of an aerospace vehicle or components. The depainting 

operation includes washing of the aerospace vehicle or component to remove residual stripper, media, or 

coating residue. 

“Detailing or Touch-up Guns” mean any small air spray equipment, including air brushes, that operate at 

no greater than 5 cubic feet per minute air flow and no greater than 50 pounds per square inch gauge air 

pressure and are used to coat small products or portions of products. 

“Dip Coat Application” means any process in which a substrate is immersed in a solution (or dispersion) 

containing the coating material, and then withdrawn. 
Santa Barbara County APCD Rule 337 337 - 6 June 21, 2012 

“Dry Lubricative Material” means any coating consisting of lauric acid, cetyl alcohol, waxes, or other 

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

“Electric- or Radiation-Effect Coating” mean any coating or coating system engineered to interact, 

through absorption or reflection, with specific regions of the electromagnetic energy spectrum, such as the 

ultraviolet, visible, infrared, or microwave regions. Uses include, but are not limited to, lightning strike 

protection, electromagnetic pulse protection, and radar avoidance. 

“Electrodeposition” means the application of a coating using a water-based electrochemical bath process.

The component being coated is immersed in a bath of the coating. An electric potential is applied between 

the component and an oppositely charged electrode hanging in the bath. The electric potential causes the 

ionized coating to be electrically attracted, migrated, and deposited on the component being coated. 

“Electrostatic Discharge and Electromagnetic Interference Coating” means any coating applied to 

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

electromagnetic interference. 

“Elevated-Temperature Skydrol-Resistant Commercial Primer” means any primer applied primarily to 

commercial aircraft (or commercial aircraft adapted for military use) that must withstand immersion in 

phosphate-ester (PE) hydraulic fluid (Skydrol 500b or equivalent) at the elevated temperature of 150 

degrees Fahrenheit for 1,000 hours. 

“Epoxy Polyamide Topcoat” means any coating used where harder films are required or in some areas 

where engraving is accomplished in camouflage colors. 

“Exterior Primer” means the first layer and any subsequent layers of identically formulated coating 

applied to the exterior surface of an aerospace vehicle or component where the component is used on the 

exterior of the aerospace vehicle. Exterior primers are typically used for corrosion prevention, protection 

from the environment, functional fluid resistance, and adhesion of subsequent exterior topcoats. Coatings 

that are defined as specialty coatings are not included under this definition. 

“Extreme Performance Interior Topcoat” means a topcoat used in interior spaces of aircraft areas 

requiring a fluid, stain, or nicotine barrier. 

“Fastener Manufacturer” means any stationary source that coats aircraft fasteners, such as pins, collars, 

bolts, nuts, and rivets, with solid-film lubricants for distribution. 

“Fastener Sealant” means any sealant applied to a device used to join two or more parts together. 

“Fire-Resistant (Interior) Coating” means: 

1. For civilian aircraft, any coating used on passenger cabin interior parts that are subject to 

the Federal Aviation Administration fireworthiness requirements. 

2. For military aircraft, any coating used on parts that are subject to the flammability 

requirements of MIL-STD-1630A and MIL-A-87721. 

3. For space applications, any coating used on parts that are subject to the flammability 

requirements of SE-R-0006 and SSP 30233. 

“Flexible Primer” means any primer that meets flexibility requirements such as those needed for adhesive 

bond primed fastener heads or on surfaces expected to contain fuel. The flexible coating is required 

because it provides a compatible, flexible substrate over bonded sheet rubber and rubber-type coatings as 

well as a flexible bridge between the fasteners, skin, and skin-to-skin joints on outer aircraft skins. This 

flexible bridge allows more topcoat flexibility around fasteners and decreases the chance of the topcoat 

cracking around the fasteners. The result is better corrosion resistance. 
Santa Barbara County APCD Rule 337 337 - 7 June 21, 2012 

“Flight Test Coating” means any coating applied to aircraft other than missiles or single-use aircraft prior 

to flight testing to protect the aircraft from corrosion and to provide required marking during flight test 

evaluation. 

“Flow Coat Application” means any coating application system, with no air supplied to the nozzle, where 

paint flows over the part and the excess coating drains back into the collection system. 

“Flush Cleaning” means the removal of contaminants such as dirt, grease, oil, and coatings from an 

aerospace vehicle or component or application equipment by passing solvent over, into, or through the item 

being cleaned. The solvent may simply be poured into the item being cleaned and then drained, or be 

assisted by air or hydraulic pressure, or by pumping. Hand-wipe cleaning operations where wiping, 

scrubbing, mopping, or other hand actions are used are not included. 

“Fuel Tank Adhesive” means any adhesive used to bond components exposed to fuel and must be 

compatible with fuel tank coatings. 

“Fuel Tank Coating” means any coating applied to fuel tank components for the purpose of corrosion 

and/or bacterial growth inhibition and to assure sealant adhesion in extreme environmental conditions. 

“Grams of Reactive Organic Compound per Liter of Coating, Less Water and Less Exempt 

Compounds” means the weight of reactive organic compound per combined volume of reactive organic 

compound and coating solids and can be calculated by the following equation: 

 

Grams of reactive organic compounds Ws - Ww - Wes

per liter of coating, less water and less = 

exempt compounds Vm - Vw - Ves

 Where: Ws = Weight of volatile compounds in grams 

 Ww = Weight of water in grams 

 Wes = Weight of exempt compounds in grams 

 Vm = Volume of material in liters 

 Vw = Volume of water in liters 

 Ves = Volume of exempt compounds in liters 

For aerospace coatings that contain reactive diluents, the grams of reactive organic compound per liter of 

coating, less water and less exempt compounds, shall be calculated by the following equation: 

Grams of reactive organic compounds Wrs - Wrw - Wre

per liter of coating, less water and less = 

exempt compounds Vrm - Vrw - Vre

 Where: Wrs = Weight of volatile compounds not consumed during curing in grams 

 Wrw = Weight of water not consumed during curing in grams 

 Wre = Weight of exempt compounds not consumed during curing in grams 

 Vrm = Volume of material not consumed during curing in liters 

 Vrw = Volume of water not consumed during curing in liters 

 Vre = Volume of exempt compounds not consumed during curing in liters 

“Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment includes paint brush, hand-roller, trowel, spatula, 

dauber, rag or sponge. 

“Hand-Wipe Cleaning Operation” means the removal of contaminants such as dirt, grease, oil, and 

coatings from an aerospace vehicle or component by physically rubbing it with a material such as a rag, 

paper, or cotton swab that has been moistened with a cleaning solvent. 
Santa Barbara County APCD Rule 337 337 - 8 June 21, 2012 

“High Temperature Coating” means any coating designed to withstand temperatures of more than 350 

degrees Fahrenheit. 

“Insulation Covering” means any material that is applied to foam insulation to protect the insulation from 

mechanical or environmental damage. 

“Interior Topcoat” means any topcoat used inhabitable interior spaces of aircraft. 

“Intermediate Release Coating” means any 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. 

“Lacquer” means any 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. 

“Limited Access Space” means any internal surfaces or passages of an aerospace vehicle or component 

that cannot be reached without the aid of an airbrush or a spray gun extension for the application of 

coatings. 

“Long Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the aircraft 

manufacturers’ required performance characteristics following 6,000 hours testing, used for metal to 

structural core bonding, and with an adhesive that is specified to be cured at a temperature of 350 degrees 

Fahrenheit plus or minus 10 degrees Fahrenheit.

“Metalized Epoxy Coating” means any coating that contains relatively large quantities of metallic 

pigmentation for appearance and/or added protection. 

“Mold Release” means any coating applied to a mold surface to prevent the molded piece from sticking to 

the mold as it is removed. 

“Natural Draft Opening” means any opening in a room, building, or total enclosure that remains open 

during operation of the facility and that is not connected to a duct in which a fan is installed. The rate and 

direction of the natural draft through such an opening is a consequence of the difference in pressures on 

either side of the wall containing the opening. 

“Non-Complying Coating” means a coating with a reactive organic compound content above a limit 

specified in Section D.1. 

“Noncompliant Material” means any coating, stripper, or solvent that has a reactive organic compound 

content or composite partial pressure that does not comply with the applicable limit in Sections D.1, D.2, or 

J.1. 

 

“Nonstructural Adhesive” means any adhesive that bonds nonload bearing aerospace components in 

noncritical applications and is not covered in any other specialty adhesive categories. 

“Optical Anti-Reflective Coating” means any coating with a low reflectance in the infrared and visible 

wavelength ranges that is used for antireflection on or near optical and laser hardware. 

“Part Marking Coating” means any coatings or inks used to make identifying markings on materials, 

components, and/or assemblies. These markings may be either permanent or temporary. 

“Pretreatment Coating” means any organic coating that contains at least 0.5 percent acids by weight and 

is applied directly to metal or composite surfaces to provide surface etching, corrosion resistance, adhesion, 

and ease of stripping. 
Santa Barbara County APCD Rule 337 337 - 9 June 21, 2012 

“Primer” means the first layer and any subsequent layers of identically formulated coating applied to the 

surface of an aerospace vehicle or component. Primers are typically used for corrosion prevention, 

protection from the environment, functional fluid resistance, and adhesion of subsequent coatings. Primers 

that are defined as specialty coatings are not included under this definition. 

“Radome” means the nonmetallic protective housing for electromagnetic transmitters and receivers (e.g., 

radar, electronic countermeasures, etc.). 

“Rain Erosion-Resistant Coating” means any coating or coating system used to protect the leading edges 

of parts such as flaps, stabilizers, radomes, engine inlet nacelles, etc. against erosion caused by rain impact 

during flight. 

“Reactive Diluent” means a liquid which is a reactive organic compound during application and one in 

which, through chemical and/or physical reactions, such as polymerization, 20 percent or more of the 

reactive organic compound becomes an integral part of a finished material.

“Remanufactured Commercial Aircraft Part” means any aerospace component that is built as a spare 

part or replacement part subject to an existing commercial aircraft specification. 

“Rocket Motor Bonding Adhesive” means any adhesive used in rocket motor bonding applications. 

“Rocket Motor Nozzle Coating” means any catalyzed epoxy coating system used in elevated temperature 

applications on rocket motor nozzles. 

“Rubber-Based Adhesive” means any quick setting contact cement that provides a strong, yet flexible 

bond between two mating surfaces that may be of dissimilar materials. 

“Scale Inhibitor” means any coating that is applied to the surface of a part prior to thermal processing to 

inhibit the formation of scale. 

“Screen Print Ink” means any ink used in screen printing processes during fabrication of decorative 

laminates and decals. 

“Seal Coat Maskant” means any overcoat applied over a maskant to improve abrasion and chemical 

resistance during production operations. 

“Sealant” means any material used to prevent the intrusion of water, fuel, air, or other liquids or solids 

from certain areas of aerospace vehicles or components. There are two categories of sealants: 

extrudable/rollable/brushable sealants and sprayable sealants. Sealants are a type of specialty coating. 

“Sealant Product” means any sealant and sealant primer. Sealant products are a type of coating. 

“Self-Priming Topcoat” means any topcoat that is applied directly to an uncoated aerospace vehicle or 

component for purposes of corrosion prevention, environmental protection, and functional fluid resistance. 

More than one layer of identical coating formulation may be applied to the vehicle or component. 

“Short Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the 

manufacturers’ required performance characteristics following 1,000 hours testing, used for metal to metal 

and metal to structural core bonding, and with an adhesive which is specified to be cured at a temperature 

of 350 degrees Fahrenheit plus or minus 10 degrees Fahrenheit. 

“Silicone Insulation Material” means any 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.”
Santa Barbara County APCD Rule 337 337 - 10 June 21, 2012 

“Solid Film Lubricant” means any very thin coating consisting of a binder system containing as its chief 

pigment material one or more of the following: molybdenum, graphite, polytetrafluoroethylene (PTFE), or 

other solids that act as a dry lubricant between faying surfaces. 

“Solids” mean the non-volatile portion of the coating which after drying makes up the dry film. 

“Solvent” means any liquid containing any reactive organic compound or any toxic air contaminant, which 

is used as a diluent, thinner, dissolver, viscosity reducer, cleaning agent, drying agent, preservative, or other 

similar uses. 

“Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface 

preparation, cleanup, or wipe cleaning) performed outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited to, dirt, soil, oil, lubricants, coolants, moisture, 

fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work 

areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material, 

or sealant is also considered to be solvent cleaning irrespective of the spray material being cured. 

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to 

remove soils, moisture, or other contaminants from the surfaces of materials. Types of solvent cleaning 

machines include, but are not limited to, batch cold, batch vapor, in-line cold, in-line vapor, remote 

reservoir, and gas-path solvent cleaners. Buckets, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with a liquid solvent for cleaning is considered to be 

solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered 

to be a solvent cleaning machine. 

“Sonic and Acoustic Applications” means the use of aerospace materials on aerospace components that 

are subject to mechanical vibration and/or sound wave cavitation. 

“Space Vehicle Coating” means any coating applied to vehicles designed to travel beyond the earth's 

atmosphere. 

“Specialized Function Coating” means any coating that fulfills extremely specific engineering 

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

excludes coatings covered in other Specialty Coating categories. 

“Specialty Coating” means any 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 selfpriming 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. The reactive organic compound 

content limit for the individual specialty coatings are listed in Section D.1, Table 337-2. Definitions for 

each specialty coating category are provide in Section C. 

“Spray Gun” means any device that atomizes a coating or other material and projects the particulates or 

other material onto a substrate. 

“Stripper” means any liquid that is applied to a surface to remove cured or dried coatings such as primers, 

adhesives (e.g., debonding or unglueing), topcoats, and temporary protective coatings. 

“Structural Autoclavable Adhesive” means any adhesive used to bond load-carrying aerospace 

components that is cured by heat and pressure in an autoclave. 
Santa Barbara County APCD Rule 337 337 - 11 June 21, 2012 

“Structural Nonautoclavable Adhesive” means any adhesive cured under ambient conditions that is used 

to bond load-carrying aerospace components or for other critical functions, such as nonstructural bonding 

in the proximity of engines. 

“Surface Preparation” means the removal of contaminants from the surface of an aerospace vehicle or 

component or the activation or reactivation of the surface in preparation for the application of a coating. 

“Temporary Protective Coating” means any coating applied to provide scratch or corrosion protection 

during manufacturing, storage, or transportation. Two types include peelable protective coatings and 

alkaline removable coatings. These materials are not intended to protect against strong acid or alkaline 

solutions. Coatings that provide this type of protection from chemical processing are not included in this 

category. 

“Thermal Control Coating” means any coating formulated with specific thermal conductive or radiative 

properties to permit temperature control of the substrate. 

“Topcoat” means any coating applied over a primer on an aerospace vehicle or component for appearance, 

identification, camouflage, or protection. Coatings that are defined as specialty coatings are not included 

under this definition. 

“Touch-Up” means that portion of the coating operation which is separate from the main coating process 

but necessary to cover minor imperfections or to achieve coverage as required. 

“Touch-Up and Repair” means that portion of the coating operation that is the incidental application of 

coating used to cover minor imperfections in the coating finish or to achieve complete coverage. This 

definition includes out-of-sequence or out-of-cycle coating. 

“Type I Chemical Milling Maskant” see the “Chemical Milling Maskant” definition.

“Type II Chemical Milling Maskant” see the “Chemical Milling Maskant” definition.

“Type I Etchant” means any chemical milling etchant that contains varying amounts of dissolved sulfur 

and does not contain amines. 

“Type II Etchant” means any chemical milling etchant that is a strong sodium hydroxide solution 

containing amines. 

“Viscosity” means the internal friction of a liquid that makes it resistant to flow. 

“Wet Fastener Installation Coating” means any primer or sealant applied by dipping, brushing, or 

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

“Wing Coating” means any corrosion-resistant coating that is resilient enough to withstand the flexing of 

the wings. 

D. Requirements – Reactive Organic Compound Limits

 1. No person shall apply any coating or solicit the use of any coating on any aerospace vehicle or 

component subject to the provisions of this rule, which, as applied, contains reactive organic 

compounds in excess of the limits shown in the tables below. These limits are expressed in grams 

of reactive organic compound per liter of coating, less water and less exempt compounds: 
Santa Barbara County APCD Rule 337 337 - 12 June 21, 2012 

 

Table 337-1: Reactive Organic Compound Content Limits for Coatings Other than Specialty Coatings 

(Grams of Reactive Organic Compound per Liter, Less Water and Less Exempt Compounds) 

Coating Type ROC Limit 

Effective June 21, 2012 

Exterior Primer 350 

Primer 350 

Self-Priming Topcoat 420 

Topcoat 420 

Type I Chemical Milling 

Maskant 

250 

Type II Chemical Milling 

Maskant 

160 

Table 337-2: Reactive Organic Compound Content Limits for Specialty Coatings 

(Grams of Reactive Organic Compound per Liter, Less Water and Less Exempt Compounds) 

 

Coating Type ROC Limit 

 Effective Before 

June 21, 2014 

 Effective On and 

After June 21, 2014 

Ablative Coating 600 600 

Adhesion Promoter 850 250 

Adhesive Bonding Primers: 

 New Commercial Aircraft 250 250 

 All Military Aircraft 805 805 

 Remanufactured Commercial Aircraft Parts 805 805 

 Sonic and Acoustic Applications 805 805 

 Long Term 250 250 

 Short Term 250 250 

Adhesives: 

 Commercial Interior Adhesive 760 760 

 Cyanoacrylate Adhesive 1020 1020 

 Fuel Tank Adhesive 620 620 

 Nonstructural Adhesive 250 250 

 Rocket Motor Bonding Adhesive 890 890 

 Rubber-Based Adhesive 850 850 

 Structural Autoclavable Adhesive 50 50 

 Structural Nonautoclavable Adhesive 850 850 

Antichafe Coating 600 420 

Barrier Coating 420 420 

Bearing Coating 620 620 

Caulking and Smoothing Compounds 850 850 

Chemical Agent-Resistant Coating 550 550 

Clear Coating 520 520 

Commercial Exterior Aerodynamic Structure 

Primer 

350 350 

Compatible Substrate Primer 350 350 

Corrosion Prevention System Compound 710 710 

Cryogenic Flexible Primer 350 350 
Santa Barbara County APCD Rule 337 337 - 13 June 21, 2012 

Coating Type ROC Limit 

 Effective Before 

June 21, 2014 

 Effective On and 

After June 21, 2014 

Cryoprotective Coating 600 600 

Dry Lubricative Material 

 Fastener Manufacturing 120 120 

 Nonfastener Manufacturing 675 675 

Electric- or Radiation-Effect 800 800 

Electrostatic Discharge and Electromagnetic 

Interference Coating 

800 800 

Elevated-Temperature Skydrol-Resistant 

Commercial Primer 

350 350 

Epoxy Polyamide Topcoat 660 660 

Extreme Performance Interior Topcoat 420 420 

Fastener Sealant 675 600 

Fire-Resistant (Interior) Coating 600 600 

Flexible Primer 350 350 

Flight-Test Coatings: 

 Missile or Single Use Aircraft 420 420 

 All Other 600 600 

Fuel Tank Coating (Excluding Fuel Tank 

Adhesive) 

420 420 

High-Temperature Coating 720 720 

Interior Topcoat 340 340 

Insulation Covering 740 740 

Intermediate Release Coating 750 750 

Lacquer 830 830 

Maskants: 

 Bonding Maskant 1,230 1,230 

 Critical Use and Line Sealer Maskant 1,020 1,020 

 Seal Coat Maskant 1,230 1,230 

Metallized Epoxy Coating 700 700 

Mold Release 780 780 

Optical Anti-Reflective Coating 700 700 

Part Marking Coating 850 850 

Pretreatment Coating 

780 780 

Rain Erosion-Resistant Coating 600 600 

Rocket Motor Nozzle Coating 660 660 

Scale Inhibitor 880 880 

Screen Print Ink 840 840 

Sealant 

 Extrudable/Rollable/Brushable Sealant 280 280 

 Sprayable Sealant 600 600 

Silicone Insulation Material 850 850 

Solid Film Lubricants 

 Fastener Manufacturing 250 250 

 Fastener Installation 880 880 

 Nonfastener Manufacturing 880 880 
Santa Barbara County APCD Rule 337 337 - 14 June 21, 2012 

Coating Type ROC Limit 

 Effective Before 

June 21, 2014 

 Effective On and 

After June 21, 2014 

Space Vehicle Coating: 

 Electrostatic-Discharge 800 800 

 Other 1,000 1,000 

Specialized Function Coating 890 890 

Temporary Protective Coating 250 250 

Thermal Control Coating 800 800 

Wet Fastener Installation Coating 675 675 

Wing Coating 750 750 

 

 2. No person shall apply any stripper or solicit the use of any stripper unless it complies with one or 

both of the following: 

 a. The stripper contains less than 300 grams of reactive organic compound per liter of 

material (2.50 pounds of reactive organic compound per gallon). 

 b. The stripper has a reactive organic compound composite partial pressure equal to or less 

than 9.5 millimeters of mercury at 20 degrees Celsius. 

 3. A person may elect to use an add-on control system as an alternative to meeting the requirements 

of Sections D.1, D.2, E, and J, provided all of the applicable requirements below are met. Any 

person choosing to install such control equipment shall obtain an Authority to Construct from the 

District prior to installation. 

 

a. The overall efficiency (the capture efficiency multiplied by the control device efficiency) 

of the total system shall not be less than 85.5 percent, by weight. Alternatively, the 

control device reactive organic compound exhaust concentration shall not exceed 10 parts 

per million by volume as propane or other limit approved by the Environmental 

Protection Agency, the Air Resources Board, and the Control Officer. 

b. Combustion temperature shall be continuously monitored when operating a thermal 

incinerator. 

c. Inlet and exhaust gas temperatures shall be continuously monitored when operating a 

catalytic incinerator. 

d. Control device efficiency shall be continuously monitored when operating a carbon 

adsorber or a control device other than a thermal or catalytic incinerator. 

e. Compliance through the use of an add-on control system shall not result in affected 

pollutant emissions in excess of the affected pollutant emissions that would result from 

compliance with Sections D.1, D.2, E, and J. 

E. Requirements – Application Equipment

 No person shall apply coatings subject to this rule unless the application is performed with equipment 

operating according to the manufacturers operating guidelines. In addition, except as provided in Section 

D.3, the application method employed shall be one of the following: 

 1. Electrostatic spray application, or 

 2. Flow coat application, or 
Santa Barbara County APCD Rule 337 337 - 15 June 21, 2012 

 3. Dip coat application, or 

 4. Roll coater, or 

5. High volume low pressure spraying equipment, or 

 6. Electrodeposition, or 

 7. Hand application methods, or 

 8. Detailing or touch-up guns, or 

 9. Any other application method approved by the Control Officer, the Air Resources Board, and the 

Environmental Protection Agency, that has a coating transfer efficiency equivalent to or greater 

than 65 percent efficiency as measured using the test method specified in Section I.4. 

10. Except as otherwise provided in Section E.11, air-atomized spray may only be used for the 

application of contact adhesives or specialty contact adhesives. 

11. For adhesive products and sealant products with an as applied viscosity of 200 centipoise or 

greater, airless spray, air-assisted airless, and air-atomized spray may be used. 

F. Requirements – General Operating

Any person who owns, operates, or uses any surface coating or depainting equipment for any aerospace 

vehicle or component coating operation shall meet the following requirements: 

1. All reactive organic compound-containing materials, used or unused, including but not limited to 

surface coatings, thinners, cleanup solvents, strippers, or surface preparation materials shall be 

stored and disposed of in nonabsorbent and nonleaking containers equipped with tight-fitting 

covers. All covers shall be in place unless adding material to or removing material from the 

containers, the containers are empty, or doing maintenance/inspection of the containers. 

2. All application equipment, ventilation system, and emission control equipment shall be installed, 

operated, and maintained consistent with the manufacturer’s specifications.

3. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic 

compounds shall be disposed of by one of the following methods: 

a. A commercial waste solvent reclamation service licensed by the State of California. 

b. At a facility that is federally or state licensed to treat, store or dispose of such waste. 

c. Recycling in conformance with Section 25143.2 of the California Health and Safety 

Code. 

4. All covers, valves, drain plugs, and other closure devices designed to reduce surface coating, 

stripper, or solvent evaporation shall not be removed or opened except to process work or to 

perform monitoring, inspections, maintenance, or repairs that require the removal of the covers or 

other closure devices. 

5. Any surface coating, stripper, or solvent spills shall be wiped up immediately and the used 

absorbent material (e.g., cloth, paper, sand, sawdust, etc.) shall be stored in closed containers that 

are handled in accordance with Section F.1. 
Santa Barbara County APCD Rule 337 337 - 16 June 21, 2012 

6. The handling and transfer of coatings, strippers, and cleaning solvents to or from enclosed 

systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or 

spent coatings, strippers, and cleaning solvents shall be conducted in such a manner to minimize 

spills. 

7. Containers used to store coating, solvent, or any waste material that contains reactive organic 

compounds subject to this rule shall be marked or clearly labeled indicating the name of the 

material they contain. 

G. Requirements – Manufacturer Labeling

 1. Each container of any coating subject to this rule shall display the date on which the contents were 

manufactured or a code indicating the date of manufacture. Each manufacturer of such coatings 

shall file with the Air Pollution Control Officer and the Executive Officer of the California Air 

Resources Board an explanation of each code. 

 2. Each container of any coating subject to this rule shall display a statement of the manufacturer's 

recommendation regarding thinning of the coating. This recommendation shall not apply to the 

thinning of coatings with water. The recommendation shall specify that the coating is to be 

employed without thinning or diluting under normal environmental and application conditions 

unless any thinning recommended on the label for normal environmental and application 

conditions does not cause a coating to exceed its applicable standard for reactive organic 

compound content. 

 3. Each container of any coating subject to this rule shall display the maximum reactive organic 

compound content of the coating, as applied, and after any thinning as recommended by the 

manufacturer. Reactive organic compound content shall be displayed as grams per liter or pounds 

per gallon of coating, less water and less exempt compounds. The volatile organic compound 

content may be displayed instead of the reactive organic compound content as long as the 

manufacturer's definition of volatile organic compound is consistent with the definition of reactive 

organic compound contained in District Rule 102, Definitions. Reactive organic compound 

content displayed may be calculated using product formulation data and the formula in Section C, 

or may be determined using the test method in Section I.1. 

H. Requirements – Recordkeeping

 Any person subject to this rule shall comply with the following requirements. Any owner or operator of 

any stationary source comprised of more than one facility may comply with the following requirements on 

a facility basis. 

 1. Maintain a current file of all reactive organic compound-containing materials in use at the 

stationary source subject to this rule. The file shall provide all of the data necessary to evaluate 

compliance and shall include the following information, as applicable: 

 a. material name and manufacturer identification (e.g., brand name, stock identification 

number); 

 b. application method; 

 c. material type, manufacturer’s specific use instructions (e.g., specific use for which the 

material is intended), type operation (e.g., coating, stripping, or solvent cleaning), and, 

for coating operations, the coating type from Table 337-1 or Table 337-2 and equipment 

coated; 

d. specific mixing data (e.g., component volumes or weights) of each component for each 

batch sufficient to determine the mixture’s reactive organic compound content;
Santa Barbara County APCD Rule 337 337 - 17 June 21, 2012 

e. the corresponding reactive organic compound limit(s) from Sections D.1, D.2, and J.1 

and the actual as applied reactive organic compound content of coating used. If 

complying using the “reactive organic compound composite partial pressure” method 

only, provide the actual reactive organic compound composite partial pressure of the 

materials used; and 

f. current coating, stripper, and solvent manufacturer specification sheets, Material Safety 

Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic 

compound content of each material in use at the stationary source subject to this rule. 

Compliance with this provision may be done by ensuring the manufacturer’s 

specifications are listed on the product container. 

 

 2. Maintain records for each reactive organic compound-containing material purchased for use at the 

stationary source. The records shall include, but not be limited to, the following: 

a. material name and manufacturer identification (e.g., brand name, stock identification 

number); and 

b. material type (e.g., coating type from Table 337-1 or Table 337-2, cleanup solvent, 

stripper, etc.). 

3. Maintain records of the disposal method each time waste solvent, waste solvent residue, or other 

waste material that contain reactive organic compounds is removed from the stationary source for 

disposal. 

 4. For each material maintained in response to Section H.1.a, maintain at a minimum, on a monthly 

basis for compliant material and on a daily basis for noncompliant material, a record of the 

following: 

a. volume used (gallons per day, gallons per month); 

b. reactive organic compound content (grams per liter or pounds per gallon); and 

c. resulting reactive organic compound emissions (pounds per day, pounds per month). 

 5. For any stationary source that uses emission control equipment as an alternative to meeting the 

requirements of Sections D.1, D.2, E, or J, daily records of key operating parameter values and 

maintenance procedures that demonstrate continuous operation and compliance of the emission 

control system during periods of emission producing activities shall be maintained. These 

parameters shall include, but not be limited to: 

a. Hours of operation; 

b. All maintenance work that requires the emission control system to be shut down; 

c. All information needed to demonstrate continuous compliance with Section D.3, such as 

temperatures, pressures, and/or flow rates. 

 6. Any records required to be maintained pursuant to this rule shall be kept on site for at least 2 years 

unless a longer retention period is otherwise required by state or federal regulation(s). Such 

records shall be readily available for inspection and review by the District. 

 

7. Any person claiming an exemption under Section B.1 shall maintain: 
Santa Barbara County APCD Rule 337 337 - 18 June 21, 2012 

a. Daily records of the volumes in gallons of noncomplying coating materials used by each 

separate formulation at the stationary source. 

b. Annual running totals, from January 1 of each calendar year, of the volume in gallons of 

non-complying coating materials used at the stationary source for: 

1) Each separate formulation. 

2) All formulations. 

I. Requirements – Compliance Provisions and Test Methods

 1. Coatings and solvent reactive organic compound content shall be measured by the Environmental 

Protection Agency Reference Method 24, its constituent methods, or an equivalent method 

approved by the Environmental Protection Agency, the Air Resources Board, and the Control 

Officer. The determination of exempt compounds shall be performed in accordance with ASTM 

D 4457-1991, “Standard Test Method for Determination of Dichloromethane and 1,1,1-

Trichloroethane in Paints and Coatings by Direct Injection into a Gas Chromatograph,” ASTM 

International. Alternatively, determination of exempt compounds may be performed in 

accordance with the South Coast Air Quality Management District Method 303-91, 

“Determination of Exempt Compounds,” August 1996. The reactive organic compound content of 

materials containing 50 grams of reactive organic compound per liter or less shall be determined 

by the South Coast Air Quality Management District Method 313-91, “Determination of Volatile 

Organic Compounds by Gas Chromatography-Mass Spectrometry,” June 1993, or any other test 

methods approved by the Environmental Protection Agency, the Air Resources Board, and the 

Control Officer. 

 

 2. The control device efficiency for reactive organic compound emissions shall be determined by 

Environmental Protection Agency Test Methods 25, 25A, the South Coast Air Quality 

Management District Method 25.1, “Determination of Total Gaseous Non-Methane Organic 

Emissions as Carbon,” February 1991, or the South Coast Air Quality Management District 

Method 25.3, “Determination of Low Concentration Non-Methane Non-Ethane Organic 

Compound Emissions from Clean Fueled Combustion Sources,” March 2000, as applicable. 

Environmental Protection Agency Test Method 18 or Air Resources Board Method 422, “Exempt 

Halogenated VOCs in Gases,” September 12, 1990, shall be used to determine emissions of 

exempt compounds. 

 3. The capture efficiency for reactive organic compound emissions shall be July 1,determined by 

verifying the use of a Permanent Total Enclosure and 100 percent capture efficiency as defined by 

Environmental Protection Agency Method 204, “Criteria for and Verification of a Permanent or 

Temporary Total Enclosure.” Alternatively, if an Environmental Protection Agency Method 204 

defined Permanent Total Enclosure is not employed, capture efficiency shall be determined using 

a minimum of three sampling runs subject to data quality criteria presented in the Environmental 

Protection Agency technical guidance document “Guidelines for Determining Capture Efficiency, 

January 9, 1995.” Individual capture efficiency test runs subject to the Environmental Protection 

Agency technical guidelines shall be determined by: 

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods 

204 through 204F; or 

b. The South Coast Air Quality Management District “Protocol for Determination of 

Volatile Organic Compounds (VOC) Capture Efficiency,” May 1995 

 

 4. Application equipment coating transfer efficiencies shall be measured using South Coast Air 

Quality Management District Method “Spray Equipment Transfer Efficiency Test Procedure for 

Equipment User,” May 1989. 
Santa Barbara County APCD Rule 337 337 - 19 June 21, 2012 

5. Reactive organic compound composite partial pressures shall be measured using ASTM D 2879-

1997,“Standard Test Method for Vapor Pressure-Temperature Relationship and Initial 

Decomposition Temperature of Liquids by Isoteniscope,” ASTM International, in combination 

with the formula in the Rule 102 definition of “reactive organic compound composite partial 

pressure,” manufacturer's specified reactive organic compound composite partial pressure, or an 

accepted scientific reference approved the Environmental Protection Agency, the Air Resources 

Board, and the Control Officer. 

6. The control device efficiency for toxic air contaminant emissions that are not reactive organic 

compounds shall be determined using: 

a. an Environmental Protection Agency approved test method or methods, or 

b. in the case where there is no Environmental Protection Agency approved test method, a 

District approved detection method applicable for each target toxics specie. 

c. the Control Officer may require more than one test method on any emission control 

device where necessary to demonstrate that the overall efficiency is at least 85.5 percent 

by weight in reducing emissions of reactive organic compounds and/or toxic air 

contaminants. Any technique to convert “parts per million by volume” test method 

results to either 1) “parts per million by weight,” or 2) “mass emission rates” (e.g., 

pounds per hour) shall first be approved by the Control Officer and, if such approval is 

not provided, then the technique shall not be used to show compliance with this rule. 

7. The capture efficiency for toxic air contaminant emissions that are not reactive organic 

compounds shall be determined by using the methods described in Section I.3 modified in a 

manner approved by the District to quantify the mass of liquid or gaseous reactive organic 

compounds and/or toxic air contaminants. 

8. The active and passive solvent losses from spray gun cleaning systems shall be determined using 

South Coast Air Quality Management District's, "General Test Method for Determining Solvent 

Losses from Spray Gun Cleaning Systems," dated October 3, 1989. The test solvent for this 

determination shall be any lacquer thinner with a minimum reactive organic compound composite 

partial pressure of 105 millimeters of mercury at 20 degrees Celsius, and the minimum test 

temperature shall be 15 degrees Celsius. 

9. Viscosity shall be determined by ASTM D 1084-88, “Standard Test Methods for Viscosity of 

Adhesives,” ASTM International.

10. Emissions of reactive organic compounds from the exhaust of an emission control system shall be 

measured by the Environmental Protection Agency Method 25, in combination with 

Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, 

“Exempt Halogenated VOCs in Gases,” September 12, 1990 (to determine emissions of exempt 

compounds). 

11. When more than one test method or set of test methods are specified for any testing, a test result 

showing an exceedance of any limit of this rule shall constitute a rule violation. 

12. The Environmental Protection Agency test methods in effect on June 21, 2012 shall be the test 

methods used to meet the requirements of this rule. 
Santa Barbara County APCD Rule 337 337 - 20 June 21, 2012 

J. Requirements – Solvent Cleaning Associated with Surface Coating of Aerospace Vehicles and 

Components 

Section J requirements shall apply to any person performing solvent cleaning associated with surface 

coating of aerospace vehicles or components, including, but not limited to, use of wipe cleaning cloths, 

hand-held spray bottles, squirt bottles, aerosol products, and the cleaning of application equipment. The 

following requirements become effective June 21, 2013 and are in addition to the general operating 

requirements specified in Section F. 

1. Solvent Requirements 

Except when using an emission control system that meets the requirements of Section D.3, no 

person shall use any solvent to perform solvent cleaning which exceeds the following limits: 

a. When Performing Surface Preparation for Coating Application and Cleanup (Other 

than Spray Application Equipment Cleaning):

1) 200 grams of reactive organic compound per liter (1.67 pounds of reactive 

organic compound per gallon) of material, or 

2) reactive organic compound composite partial pressure of 45 millimeters of 

mercury at 20 degrees Celsius. 

b. When Performing Solvent Cleaning of Spray Application Equipment: 25 grams of 

reactive organic compounds per liter (0.21 pounds of reactive organic compound per 

gallon) of material. In lieu of meeting the reactive organic compound-content limit, a 

person may use an enclosed cleaning system, or equipment that is proven to the 

satisfaction of the Control Officer to be equally effective as an enclosed cleaning system 

at controlling emissions. “Equal effectiveness” of an alternative cleaning system shall be 

determined by the test method referenced in Section I.8 of this rule. If an enclosed 

cleaning system is used, it shall totally enclose spray guns, cups, nozzles, bowls, and 

other parts during washing, rinsing, and draining procedures, and it shall be used 

according to the manufacturer’s recommendations and be closed when not in use.

2. Cleaning Devices and Methods. Except for solvent cleaning of spray application equipment, any 

person performing solvent cleaning with a solvent containing more than 25 grams of reactive 

organic compounds per liter of material shall use one or more of the following cleaning devices or 

methods: 

a. Wipe cleaning where solvent is dispensed to wipe cleaning materials from containers that 

are kept closed to prevent evaporation, except while dispensing solvent or replenishing 

the solvent supply, and where wipes are stored in closed containers to prevent 

evaporation when not in use; 

b. Application of solvent from hand-held spray bottles, squirt bottles, or other closed 

containers with a capacity of one liter or less; or 

c. Non-atomized solvent flow, dip, or flush cleaning method where pooling on surfaces 

being cleaned is prevented or drained, and all solvent runoff is collected in a manner that 

enables solvent recovery or disposal. The collection system shall be kept closed to 

prevent evaporation except while collecting solvent runoff or emptying the collection 

system. 
Santa Barbara County APCD Rule 337 337 - 21 June 21, 2012 

K. Compliance Schedule

Any person who owns, operates, or uses any application equipment to surface coat any aerospace vehicles 

or components shall meet the following compliance schedule: 

1. By July 21, 2012, comply with Section F, Requirements - General Operating. 

2. By December 21, 2012, comply with the recordkeeping provisions in the following Sections: 

a. H.1.d - mixing data, 

b. H.1.e - reactive organic compound content data, 

c. H.2 - purchase records, 

 

d. H.3 - waste disposal records, and 

e. H.4 - daily records for noncompliant materials. 

3. By June 21, 2013, comply with the Section J and Section M requirements. 

4. By June 21, 2012, comply with all other provisions of this rule. 

L. Reporting Requirements 

Submittal of an annual report to the District is required if: 

• A person holds a permit for equipment subject to the requirements of this rule, or 

• A person is subject to the requirements of this rule and applies non-complying coatings. 

The annual report shall be due March 1 and it shall contain the following information for the previous 

calendar year: 

1. monthly totals (gallons) of compliant and noncompliant material used based on the records 

required by Section H.4, 

2. annual totals (gallons) based on each of the coating’s, solvent’s, and stripper’s monthly data, 

3. if claiming the Rule 337.B.1 exemption, annual totals (gallons) of non-complying coatings for 

each separate formulation and all formulations, per Section H.7.b, and 

4. if permitted, name and address of the company or agency, and the Permit to Operate number that 

the surface coating equipment is subject to. 

M. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions 

of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.