Attachment 6

Board of Directors Agenda Packet from June 19, 2014 Rule Hearing 

Rule 323.1 

2

EXECUTIVE SUMMARY:

The California Air Resources Board (CARB) recommends that local air districts update their 

architectural coating rule requirements with revised coating volatile organic compound limits and 

other rule provisions.

a This rulemaking action will adopt the CARB recommendations in a new 

Rule 323.1. Current Rule 323 will be phased out three years after Rule 323.1 becomes effective. 

CARB supports using this phased approach, which allows retailers to sell products manufactured 

before the new requirements become effective without disrupting their normal inventory turnover.

DISCUSSION:

Objectives:

Adoption of Rule 323.1 will fulfill emission reduction commitments the District made in the 2010 

Clean Air Plan. Once adopted, staff will submit Rule 323.1 to CARB for consideration of inclusion 

into the State Implementation Plan (SIP) and to EPA for an update to the federal Outer Continental 

Shelf Air Regulations. If CARB approves the rule for inclusion in the SIP, CARB will submit it on 

the behalf of the District to EPA for SIP consideration.

Background:

CARB has designated the Santa Barbara County Air Pollution District as a moderate nonattainment 

area for the state 8-hour ozone standard. Architectural coatings are a large source of volatile organic 

compound emissions in Santa Barbara County, accounting for about 500 tons in 2012 (Ref. 1). 

Volatile organic compound emissions cause the formation of ozone and particulate matter less than 

ten microns in size, two of the pollutants of concern in Santa Barbara County. Rule 323.1 uses the 

term volatile organic compound in lieu of reactive organic compound for consistency with the 2007 

CARB Suggested Control Measure (SCM). For all intents and purposes both terms have the same 

meaning.

The District originally adopted Rule 323 on October 18, 1971, to regulate volatile organic 

compound (VOC) emissions from the use of architectural coatings. Since 1971, the District has 

amended the rule eight times: February 24, 1975; August 22, 1977; June 11, 1979; March 11, 1985; 

February 20, 1990; March 16, 1995; July 18, 1996; and November 15, 2001. 

The amendments in 1975 through 1985 revised effective dates of technology-forcing limits and 

clarified language. The amendments in February 1990 revised the rule to be consistent with the 

1989 CARB SCM. The 1995 and 1996 amendments dealt with general rule cleanup issues and 

expanded the list of compounds exempt from the definition of volatile organic compound. The 2001 

amendment incorporated the June 2000 CARB SCM VOC content limits.

 

a The recommendations are within the CARB’s 2007 Suggested Control Measure for Architectural 

Coatings.
3

Implications to the Regulated Community:

WHO IS AFFECTED?

Any person who:

1. Supplies, sells, or offers for sale any architectural coating for use within the District; or

2. Manufacturers, blends, or repackages any architectural coating for use within the District; or

3. Applies or solicits the application of any architectural coating within the District.

WHAT ARE THE PROPOSED ARCHITECTURAL COATING REQUIREMENT CHANGES?

In general, the VOC content limits and other rule provisions in Rule 323.1 are consistent with the 

2007 ARB SCM. The District departed from the 2007 ARB SCM to address the phasing out of 

Rule 323. We also made other minor deviations to address CARB and stakeholder concerns. 

Examples of these include adding an anti-bundling provision to the one-liter exemption and adding 

an early compliance provision. The District’s document entitled, “Project Description Summary of 

the Effects of New Rule 323.1, Architectural Coatings,” provides detailed information on the 

proposed requirement changes as compared to existing Rule 323 and the 2007 CARB SCM.

FISCAL IMPACTS TO THE REGULATED INDUSTRY DUE TO NEW RULE 323.1:

According to the 2007 ARB SCM, assuming manufacturers passed their cost increases for 

compliance with the SCM coating VOC limits on to consumers, the average potential increase is 

about $1.21 per gallon ($1.36/gal in 2013 dollars). Further, based on the average cost per gallon for 

consumers of $19.20 ($21.56/gal in 2013 dollars), the average increase in the cost per gallon would 

be about six percent. a

ARB estimated that the total annualized cost of the SCM to be $12.3 million ($13.8 million/year in 

2013 dollars). Apportioning this figure to Santa Barbara County, the total annualized cost of the 

SCM is about $250,000 ($280,000/year in 2013 dollars).

Emission Reductions and Cost Effectiveness:

WHAT ARE THE PROJECTED VOC EMISSION REDUCTIONS FROM RULE 323.1?

The planning year 2020 VOC emission reduction due to Rule 323.1 is nearly 98 TPY (about 0.25 

tons per day). This VOC emission reduction is from reducing the coating VOC content limits. This 

VOC emission reduction is significantly greater than the 32.4 tons per year predicted in the 2010 

Clean Air Plan for planning year 2020. 

The following table shows the projected emission reductions for this rulemaking activity. It should 

 

a Staff converted from 2007 dollars to 2013 dollars using a CA Consumer Price Index of 12.3 percent.
4

be noted that the projected future emissions also take growth into consideration.

Rulemaking Emission Inventory and Emission Reduction Data 

VOC Planning 

Emission Inventory

Base Year 2012, 

Tons/Day 

(Tons/Year)

Planning Year 

2020, Tons/Day 

(Tons/Year)

Planning Year 

2030, Tons/Day 

(Tons/Year)

Projected Emissions

Before Control

1.3730 1.4416 1.6267

(501.1410) (526.1981) (593.7519)

Projected Emission 

Reductions

0.2546 0.2674 0.3017

(92.9376) (97.5845) (1.3250)

Projected Emissions 

After Control

1.1184 1.1743 1.3250

(408.2034) (428.6136) (483.6394)

WHAT IS THE RULE 323.1 COST EFFECTIVENESS?

The cost effectiveness of Rule 323.1 is $3,017 per ton of VOC reduced. This cost effectiveness 

figure compares favorably with the cost-effectiveness of similar regulations. 

Implications to the APCD Budget:

The District anticipates the current staffing levels will be sufficient for inspections and industry 

outreach programs to implement the new rule provisions.

Identification of Existing Federal Regulations and Air Pollution Control District Regulations that 

Apply to the Same Equipment or Source Type Covered by Rule 323.1

Pursuant to Health and Safety Code section 40727.2, District staff prepared a rule consistency 

analysis that compares the elements of amendments with the corresponding elements of other 

District rules, federal regulations, and guidelines that apply to the same source category or type of 

equipment. District staff found that none of the proposed requirements of Rule 323.1 would conflict 

with other District rules, or federal rules, regulations, or policies covering similar stationary 

sources.

Comparisons to Adjacent Local Air Pollution Control Districts:

Air districts adjacent to the Santa Barbara County Air Pollution Control District include the San 

Joaquin Unified Valley Air Pollution Control District, the Ventura County Air Pollution Control 

District, and the San Luis Obispo County Air Pollution Control District.
5

The San Joaquin Unified Valley APCD and the Ventura County APCD incorporated the 2007

CARB SCM limits into their architectural coating rules in 2009 and 2010, respectively. The San 

Luis Obispo County APCD has not amended their architectural coating rule to include the 2007

CARB SCM provisions. 

Public Review:

WHAT PUBLIC REVIEW PROCESS DID THE 2007 CARB SCM UNDERGO?

The California Air Resource Board commenced the public review process for the 2007 SCM with 

the formation of an industry working group in October 2006. CARB staff held three public 

workshops and meetings on December 12, 2006; March 13, 2007; and June 6, 2007. The first 

workshop focused on general discussions regarding the SCM update, the project timeline, and the 

technical approach. At the second workshop, CARB staff presented draft VOC limits and revised 

definitions for several major coating categories. At the third workshop, CARB staff presented draft 

regulatory language for the entire SCM (Ref. 2). 

WHAT PUBLIC REVIEW PROCESS DID THE PROPOSED NEW RULE 323.1 UNDERGO?

The District released the proposed rule and Project Description Summary in February 2014. Staff 

conducted a public workshop on March 11, 2014 and met with representatives of the SherwinWilliams company on March 18, 2014. In early April, the District sent notices to stakeholders on 

project revisions. On April 15, staff posted to our web site responses to comments received on the 

project to date. On April 19, the District posted updated versions of Rule 323.1 and the Project 

Description Summary.

On May 14, 2014, staff provided the Community Advisory Council (CAC) with a briefing on the 

project. After the briefing and further CAC discussions, the CAC passed a motion to recommend 

that the Board of Directors adopt Rule 323.1.

The California Air Resources Board submitted comments to the District on May 15, 2014. Based on 

these comments, staff made some minor text changes for clarification and made a slight change to 

one exemption.

California Environmental Quality Act:

The California Environmental Quality Act (CEQA) requires environmental review for proposed 

Rule 323.1, Architectural Coatings. The District is the lead agency on this project. Proposed 

revisions to Rule 323 were examined in the Environmental Impact Report (EIR) for the 2010 CAP 

which concluded that the implementation of revised architectural coating rule requirements would 

not result in any significant environmental impacts. The District has elected to adopt a new Rule 

323.1 instead of amending Rule 323. However, the same CEQA analysis applies to Rule 323.1 that 

applied to Rule 323.
6

The District finds that the 2010 CAP EIR may be used to fulfill the environmental review 

requirements of the current project. CEQA Guidelines section 15168(c)(2) allows subsequent 

activities to be approved without the need for a new environmental document if the impacts of those 

activities were examined in an EIR, and have no new effects or mitigation measures. District staff 

have evaluated the environmental impacts related to proposed Rule 323.1, and have concluded that 

the environmental impacts were adequately analyzed in the 2010 CAP EIR.

CEQA findings to be adopted by the District Board, as well as a discussion of these findings, are 

provided in Attachment 1.

Concurrences:

County Counsel has reviewed this Board Letter and its attachments and approves them as to form.

SPECIAL INSTRUCTIONS:

After adoption by the Board, please have the Board Chair sign the attached resolution and return a 

copy along with a copy of the minute order to Douglas Grapple of the Air Pollution Control 

District.

REFERENCES

1. Santa Barbara County APCD Architectural Coating Inventory for Baseyear 2012.

2. California Air Resources Board “Staff Report for Proposed Amendments to the Suggested 

Control Measure for Architectural Coatings,” September 2007.

Attachments

Resolution

Attachment 1 - CEQA Findings

Attachment 2 - Rule Findings

Attachment 3 - Public Comments and Responses to Public Comments

Attachment 4 - Rule 323.1, Architectural Coatings
BOARD RESOLUTION

PROPOSED RULE 323.1

ARCHITECTURAL COATINGS

June 19, 2014

Santa Barbara County Air Pollution Control District

260 San Antonio Road, Suite A

Santa Barbara, California 93110

(805) 961-8800

Santa Barbara County APCD

Resolution – Proposed Rule 323.1 - 1 - June 19, 2014

RESOLUTION OF THE AIR POLLUTION

CONTROL DISTRICT BOARD OF THE COUNTY OF 

SANTA BARBARA, STATE OF CALIFORNIA

In the Matter of ) APCD Resolution No. 

)

Adopting Rule 323.1 )

)

_______________________________________ )

RECITALS

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

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

Safety Code section 40725 et seq.

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

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

quality standards.

3. The Board has determined that a need exists to adopt Rule 323.1, Architectural 

Coatings, to implement Health and Safety Code sections 40914, 40918 & 40924(b) under the 

District’s 2010 Clean Air Plan. Rule 323.1 implements the 2010 Clean Air Plan proposed control 

measure R-SC-1 for controlling volatile organic compound emissions.
Santa Barbara County APCD

Resolution – Proposed Rule 323.1 - 2 - June 19, 2014

NOW, THEREFORE, IT IS HEREBY RESOLVED THAT:

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

requirements of Health and Safety Code section 40725 et seq.

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

Attachment 1 of the Board Package dated June 19, 2014 (herein after “Board Package”) are 

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

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

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

4) The Responses to Public Comments, as set forth in Attachment 3 of the Board 

Package are hereby adopted as findings of this Board.

5) Rule 323.1 as set forth in Attachment 4 of the Board Package is hereby adopted as

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

Code section 40725 et seq.

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6) The Board authorizes the Control Officer to transmit Rule 323.1 to the State Air 

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

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

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

Protection Agency. 

PASSED AND ADOPTED by the Air Pollution Control District Board ofthe 

County of Santa Barbara, State of California, this_ day of ______ , 20_, by the 

following vote: 

AYES: 

NOES: 

ABSTAIN: 

ABSENT: 

ATTEST: 

Louis D. Van Mullem, Jr. 

Clerk of the Board 

By ____ ~----------------

Deputy 

Santa Barbara County APCD 

Resolution- Proposed Rule 323.1 

Chair, Air Pollution Control 

District Board of the County of 

Santa Barbara 

APPROVED AS TO FORM: 

MICHAEL C. GHIZZONI 

SANTA BARBARA COUNTY COUNSEL 

By~~Uik 

- 3 -

Deputy 

Attorneys for the Santa Barbara County 

Air Pollution Control District 

June 19, 2014 

ATTACHMENT 1

CEQA FINDINGS

PROPOSED RULE 323.1

ARCHITECTURAL COATINGS

June 19, 2014

Santa Barbara County Air Pollution Control District

260 San Antonio Road, Suite A

Santa Barbara, California 93110

(805) 961-8800

Santa Barbara County APCD - CEQA Findings - 1-1 June 19, 2014

Rule 323.1 Project

ATTACHMENT 1

CEQA FINDINGS

The Santa Barbara County Air Pollution Control District (District) found that the potential 

environmental impacts of revised Rule 323 (Architectural Coatings) were adequately described 

and analyzed in the EIR for the 2010 Clean Air Plan. The District now proposes to implement 

changes to the architectural coating rule requirements as Rule 323.1. However, the same CEQA 

analysis for Rule 323 revisions is valid for new Rule 323.1.

The Board finds that:

 Pursuant to Section 15168 (c)(2) of the California Environmental Quality Act this 

rulemaking activity is within the scope of the 2010 Clean Air Plan Environmental Impact 

Report and the Environmental Impact Report adequately describes the activity for the 

purposes of the California Environmental Quality Act.

 Pursuant to Section 15168 (c)(2) of the California Environmental Quality Act, the 

impacts related to Rule 323.1, were examined in the program Environmental Impact 

Report for the 2010 Clean Air Plan, and no new effects could occur and no new 

mitigation measures are required. Therefore, no new environmental document is required.

 The Environmental Impact Report for the 2010 Clean Air Plan was previously 

determined by this Board to have been completed in compliance with the California 

Environmental Quality Act and was reviewed and considered by the Board prior to 

approval.

 Any subsequent changes to the project description during the public review period will 

undergo additional environmental review under the California Environmental Quality Act 

if it is determined that the changes are outside the scope of the 2010 Clean Air Plan 

Environmental Impact Report. 

ATTACHMENT 2

RULE FINDINGS

PROPOSED RULE 323.1

ARCHITECTURAL COATINGS

June 19, 2014

Santa Barbara County Air Pollution Control District

260 San Antonio Road, Suite A

Santa Barbara, California 93110

(805) 961-8800

Santa Barbara County APCD 2-1 June 19, 2014

Rule Findings – Proposed Rule 323.1

ATTACHMENT 2

RULE FINDINGS FOR PROPOSED RULE 323.1, ARCHITECTURAL COATINGS

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

findings for the adoption of proposed Rule 323.1, Architectural Coatings,.

Necessity

The Board determines that it is necessary to adopt Rule 323.1, Architectural Coatings, to comply 

with California State Health and Safety Code Section 40920 which requires air districts in 

California to develop rules to implement their plans for attaining state ambient air quality 

standards.

Authority

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

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

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

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

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

do such acts as are necessary and proper to execute the powers and duties granted to it and 

imposed upon it by State law.

Clarity

The Board finds that proposed Rule 323.1, Architectural Coatings, is sufficiently clear. Proposed 

Rule 323.1 was publicly noticed and reviewed by the Community Advisory Council. The rule is 

written or displayed so that its meaning can be easily understood by persons directly affected by 

it.

Consistency

The Board determines that proposed Rule 323.1, Architectural Coatings, is consistent with, and 

not in conflict with or contradictory to, existing federal or state statutes, court decisions, or 

regulations with regard to the control of emissions of volatile organic compounds from 

architectural coatings. 

Air pollution control districts statewide are expected to amend their architectural coatings rule 

requirements to be consistent with the Suggested Control Measure adopted by the California Air 

Resources Board on October 26, 2007. The San Joaquin Unified Valley APCD and the Ventura 

County APCD incorporated the 2007 California Air Resources Board Suggested Control 

Measure provisions into their architectural coating rules in 2009 and 2010, respectively. Based 

on this evidence, the Board finds that the rule is generally consistent with neighboring air 

pollution control districts.
Santa Barbara County APCD 2-2 June 19, 2014

Rule Findings – Proposed Rule 323.1

Nonduplication

The Board finds that the proposed Rule 323.1, Architectural Coatings, does not impose the same 

restrictions as any existing state or federal regulation, and the proposed rule is necessary and 

proper to execute the powers and duties granted to, and imposed upon, the District.

Reference

The Board finds that we have authority under state law to adopt proposed Rule 323.1, 

Architectural Coatings, pursuant to Health and Safety Code Section 39002. Health and Safety 

Code Section 39002 assigns to local and regional authorities the primary responsibility for the 

control of air pollution from all sources other than exhaust emissions from motor vehicles.

Additionally, pursuant to Health and Safety Code Section 40702, the Board is required to adopt 

rules and regulations and to do such acts as are necessary and proper to execute the powers and 

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

Public Comment

Response to Comments

The Board has reviewed the responses to public comments included in Attachment 3 and hereby 

approves those responses to comments as findings.
ATTACHMENT 3

PUBLIC COMMENTS AND RESPONSES TO PUBLIC 

COMMENTS

PROPOSED RULE 323.1

ARCHITECTURAL COATINGS

June 19, 2014

Santa Barbara County Air Pollution Control District

260 San Antonio Road, Suite A

Santa Barbara, California 93110

(805) 961-8800

Santa Barbara County APCD 3-1 June 19, 2014

Public Comments and Responses to Comments - Proposed Rule 323.1

ATTACHMENT 3

PUBLIC COMMENTS AND RESPONSES TO PUBLIC COMMENTS

Note: Comments on draft Rule 323.1 

received before May 18, 2014 and the 

District’s responses to those comments are 

maintained by staff. These are available 

upon request.

Comments from California Air Resources 

Board, June 6, 2014

COMMENT 1

Section A.2 indicates that Rule 323.1 shall 

be effective on January 1, 2015 and Section 

A.3 indicates that rule 323 shall remain in 

effect until January 1, 2015. This would 

cause both Rule 323 and Rule 323.1 to be 

effective on January 1, 2015. It is 

recommended that Rule 323 remain in effect 

until December 31, 2014, eliminating 

overlap between the two rules.

RESPONSE TO COMMENT 1

The two sections in question are shown 

below:

A. Applicability [. . .]

2. Rule 323.1 shall be effective on 

January 1, 2015.

3. Rule 323, Architectural Coatings, 

shall remain in effect in its entirety 

until January 1, 2015. A coating 

manufactured prior to January 1, 

2015 may be sold, supplied, or 

offered for sale for up to three 

years after January 1, 2015, 

provided that the coating complied, 

at the time of manufacture, with all 

applicable provisions in Rule 323 

as revised November 15, 2001. 

Such coating may also be applied at 

any time, both before and after 

January 1, 2015. This Section does 

not apply to any coating that does 

not display the date or date code 

required by Section E.1.a of this 

rule.

Staff do not see how the Rule 323 and Rule 

323.1 are both effective on the same day: 

January 1, 2015. We read Section 323.1.A.3 

to mean that Rule 323 is no longer in effect 

as of January 1, 2015.

COMMENT 2

Section B.5 states that the “rule shall not 

apply to any coating that contains less than 

20 grams of VOC per liter (0.17 pounds of 

VOC per gallon) of coatings, less water and 

less exempt compounds, as applied.” This 

would allow manufacturers who deemed 

their products to fall below this threshold to 

not label their products with VOC content, 

date code, or thinning recommendations, 

complicating enforcement efforts. In 

addition to eliminating all labeling 

requirements, it also excludes these products 

from reporting and recordkeeping 

requirements.

RESPONSE TO COMMENT 2

We amended the exemption to make it a 

partial rule exemption, as follows:

B. Exemptions [. . .]
Santa Barbara County APCD 3-2 June 19, 2014

Public Comments and Responses to Comments - Proposed Rule 323.1

5. The requirements of With the 

exception of Sections E and F, this 

rule shall not apply to any coating 

that contains less than 20 grams of 

VOC per liter (0.17 pounds of 

VOC per gallon) of coating, less 

water and less exempt compounds, 

as applied.

Per discussions with ARB staff on May 19, 

2014, the revised exemption is acceptable to 

them.

COMMENT 3

Section C provides a definition for “Ablative 

Coating.” Inclusion of this additional 

definition is unnecessary as this coating is 

an Industrial Maintenance Coating. Further, 

the proposed limit for Ablative Coating is 

the same as that of Industrial Maintenance 

Coating. It is recommended that the 

definition for Ablative Coating be 

eliminated from Section C, and the VOC 

content limit for Ablative Coating be 

stricken from Table 323.1-1.

RESPONSE TO COMMENT 3

The District added this distinct category at 

the request of a stakeholder: United Launch 

Alliance, L.L.C. (ULA). Due to the unique 

operations involved with space launches, we 

believe a definition of Ablative Coatings 

with a Table 323.1-1 limit of limit of 250 g/l 

is appropriate. Hence, we did not delete the 

definition or delete the Ablative Coatings 

category from Table 323.1-1.

COMMENT 4

Section E.1.e. should be modified to delete 

the terms “Not for residential use” and “Not 

intended for residential use.” This is 

obsoleted language from the 2000 Suggested 

Control Measure for Architectural Coating

RESPONSE TO COMMENT 4

On April 18, 2014, David Darling of the 

American Coatings Association (ACA) 

specifically requested that we add two 

additional labeling provisions into both the 

Industrial Maintenance (Section E.1.e) and 

the Zinc Rich Primer (E.l.k) labeling 

provisions. His letter indicates, in part:

Changing product labels is very 

expensive. To reduce the regulatory 

burden for those coatings manufacturers 

that use the IM label statements “Not 

For Residential Use,” or “Not Intended 

For Residential Use,” ACA urges Santa 

Barbara retain all four IM statements in 

Rule 323.1. In addition, ACA suggests 

that Santa Barbara include all four label 

statements for Zinc-Rich Primers 

(primers used for IM coatings) as well. 

Please note that the following California 

Air Districts have adopted the 2007 

California Air Resources Board 

Suggested Control Measures for 

Architectural Coatings (CARB 2007 

SCM) and included all four IM and 

Zinc Rich Primer labeling statements: 

San Joaquin, Ventura, Imperial, Eastern 

Kern, Placer, Mojave, and Antelope 

Valley. 

Staff verified that all four label statements 

were in all the rules referenced by Mr. 

Darling. We also believe the spirit and intent 

of the two ARB 2007 SCM provisions (“For 

industrial use only” or “For professional use 

only”) are essentially met with the two 

additional statements: “Not for residential 

use” and “Not intended for residential use.” 

Hence, we did not modify the rule to align 

with the 2007 SCM text.
Santa Barbara County APCD 3-3 June 19, 2014

Public Comments and Responses to Comments - Proposed Rule 323.1

COMMENT 5

Section E.1.k. should be modified to delete 

the terms “For industrial use only”, “Not for 

residential use” and “Not intended for 

residential use.” This is obsoleted language 

from the 2000 Suggested Control Measure 

for Architectural Coatings.

RESPONSE TO COMMENT 5

Same as the Comment 4 response.

COMMENT 6

Section G.3 makes reference to Section G.7, 

but rule contains no Section G.7.

RESPONSE TO COMMENT 6

Right, staff changed the text as shown 

below:

G. Compliance Provisions and Test 

Methods [. . .]

3. Alternative Test Methods: Other 

test methods demonstrated to 

provide results that are acceptable 

for purposes of determining 

compliance with Section G.2 or 

G.7, after review and approved in 

writing by the staffs of the District, 

the California Air Resources 

Board, and the Environmental 

Protection Agency, may also be 

used.

COMMENT 7

Please modify Section G.5 as follows “Test 

Methods: The following test methods are 

incorporated by reference herein, and shall 

be used to test coatings and solvents subject 

to the provisions of this rule”.

RESPONSE TO COMMENT 7

Right, staff changed the text as shown 

below:

5. Test Methods: The following test 

methods are incorporated by 

reference herein, and shall be used 

to test coatings and solvents subject 

to the provisions of this rule:

COMMENT 8

Please correct Section G.5.a to read 

“Standard Test Methods for Fire tests of 

Building and Construction and Materials”. 

The 2007 Suggested Control Measure for 

Architectural Coatings listed this title 

incorrectly.

RESPONSE TO COMMENT 8

Right, staff changed the text as shown 

below:

a. Fire Resistance Rating: The fire 

resistance rating of a fire-resistive 

coating shall be determined by 

ASTM Designation E119-07, 

“Standard Test Methods for Fire 

Tests of Building and Construction 

and Materials,” ASTM 

International (see Section C, FireResistive Coating).
Santa Barbara County APCD 3-4 June 19, 2014 

Public Comments and Responses to Comments - Proposed Rule 323.1 

Comments from Robert Wendoll of the 

Dunn-Edwards Corporation, 

June 17, 2014

COMMENT 1 

Dunn-Edwards Corporation is a Californiabased manufacturer and distributor of 

architectural coatings, serving the 

Southwestern United States. Our Main 

Office and a majority of our retail outlets are 

located in California, where we employ 

more than 1,500 people directly, and 

contribute indirectly to the livelihoods of 

thousands more professional painting 

contractors and maintenance staff painters 

throughout the state. 

RESPONSE TO COMMENT 1

Comment noted. 

COMMENT 2 

Dunn-Edwards is pleased to support the 

adoption of Santa Barbara County APCD 

Proposed Rule 323.1 – Architectural 

Coatings, as recommended for adoption at 

the Board hearing on June 19, 2014. As it is 

essentially consistent with the California Air 

Resources Board’s Suggested Control 

Measure for Architectural Coatings, the new 

rule will promote effective enforcement by 

the District, efficient distribution of product 

by manufacturers and retailers, and simplify 

compliance for painters, both professional 

and do-it-yourselfers. We thank District staff 

for their consideration of comments 

previously offered by Dunn-Edwards and 

the American Coatings Association. 

RESPONSE TO COMMENT 2

Comment noted. 
ATTACHMENT 4

PROPOSED RULE 323.1

ARCHITECTURAL COATINGS

June 19, 2014

Santa Barbara County Air Pollution Control District

260 San Antonio Road, Suite A

Santa Barbara, California 93110

(805) 961-8800

Santa Barbara County APCD Rule 323.1 323.1 - 1 [date of rule adoption] 

RULE 323.1. ARCHITECTURAL COATINGS. (Adopted [date of rule adoption], Effective January 1, 

2015) 

A. Applicability

1. Except as provided in Section B, this rule is applicable to any person who: 

a. Supplies, sells, or offers for sale any architectural coating for use within the District; or 

b. Manufactures, blends, or repackages any architectural coating for use within the District; 

or 

c. Applies or solicits the application of any architectural coating within the District. 

2. Rule 323.1 shall be effective on January 1, 2015. 

3. Rule 323, Architectural Coatings, shall remain in effect in its entirety until January 1, 2015. A 

coating manufactured prior to January 1, 2015 may be sold, supplied, or offered for sale for up to 

three years after January 1, 2015, provided that the coating complied, at the time of manufacture, 

with all applicable provisions in Rule 323 as revised November 15, 2001. Such coating may also 

be applied at any time, both before and after January 1, 2015. This Section does not apply to any 

coating that does not display the date or date code required by Section E.1.a of this rule. 

 

B. Exemptions

 1. The requirements of this rule shall not apply to the following: 

a. Any architectural coating that is supplied, sold, offered for sale, or manufactured for use 

outside of the District or for shipment to other manufacturers for reformulation or 

repackaging. 

b. Any aerosol coating product. 

2. With the exception of Section F, this rule shall not apply to any architectural coating sold in a 

container with a volume of one liter (1.057 quarts) or less provided: 

a. The coating containers are not bundled together to be sold as a unit that exceeds one liter 

(1.057 quarts), excluding containers packed together for shipping to a retail outlet, 

warehouse, or a military distribution or redistribution facility. 

3. Any architectural coating operation that is not conducted as part of a business is exempt from the 

requirements of Section D.4 of this rule. 

4. Early Rule 323.1 compliance provision: 

Prior to January 1, 2015, any coating that meets the definition in Section C for a coating category 

listed in Table 323.1-1 and complies with the corresponding VOC limit in Table 323.1-1 and with 

the Most Restrictive VOC limit in Section D.2 and the corresponding Labeling Requirement in 

Section E, if applicable, shall be considered in compliance with this rule and exempt from Rule 

323. 

5. With the exception of Sections E and F, this rule shall not apply to any coating that contains less 

than 20 grams of VOC per liter (0.17 pounds of VOC per gallon) of coating, less water and less 

exempt compounds, as applied. 

 
Santa Barbara County APCD Rule 323.1 323.1 - 2 [date of rule adoption]

C. Definitions

See Rule 102, Definitions, for definitions not limited to this rule. For the 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 a rocket launch. The ablative char surface serves as an insulative barrier, protecting 

underlying coatings or surfaces from the heat or open flame.

“Adhesive” means any chemical substance that is applied for the purpose of bonding two surfaces together 

other than by mechanical means.

“Aerosol Coating Product” means any pressurized coating product containing pigments or resins that 

dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held 

application, or for use in specialized equipment for ground traffic/marking applications.

“Aluminum Roof Coating” means any coating labeled and formulated exclusively for application to roofs 

and containing at least 84 grams per liter of coating (0.7 pound per gallon of coating) of elemental 

aluminum pigment. Pigment content shall be determined in accordance with South Coast Air Quality 

Management District Method 318-95, “Determination of Weight Percent Elemental Metal in Coatings By 

X-Ray Diffraction,” incorporated by reference in Section G.5.c of this rule.

“Appurtenance” means any accessory to a stationary structure coated at the site of installation, whether 

installed or detached, including, but not limited to: bathroom and kitchen fixtures; cabinets; concrete forms; 

doors; elevators; fences; hand railings; heating equipment, air conditioning equipment, and other fixed 

mechanical equipment or stationary tools; lampposts; partitions; pipes and piping systems; rain gutters and 

downspouts; stairways, fixed ladders, catwalks, and fire escapes; and window screens.

“Architectural Coating” means any coating to be applied to stationary structures or their appurtenances at 

the site of installation, to portable buildings at the site of installation, to pavements, or to curbs. Coatings 

applied in shop applications or to non-stationary structures such as airplanes, ships, boats, railcars, and 

automobiles, and adhesives are not considered architectural coatings for the purposes of this rule.

“Asphalt” means the dark-brown to black cementitious material (solid, semi-solid, or liquid in 

consistency) of which the main constituents are bitumens which occur naturally or as a residue of 

petroleum refining.

“Basement Specialty Coating” means any clear or opaque coating that is labeled and formulated for 

application to concrete and masonry surfaces to provide a hydrostatic seal for basements and other belowgrade surfaces. Basement Specialty Coatings shall meet the following criteria:

a. Coating shall be capable of withstanding at least 10 pounds per square inch of hydrostatic 

pressure, as determined in accordance with ASTM Designation D7088-04, “Standard 

Practice for Resistance to Hydrostatic Pressure for Coatings Used in Below Grade 

Applications Applied to Masonry,” ASTM International; which is incorporated by 

reference in Section G.5.k of this rule; and

b. Coating shall be resistant to mold and mildew growth and shall achieve a microbial 

growth rating of 8 or more, as determined in accordance with ASTM Designation D3273-

00, “Standard Test Method for Resistance to Growth of Mold on the Surface of Interior 

Coatings in an Environmental Chamber,” ASTM International, and ASTM Designation 

D3274-95, “Standard Test Method for Evaluating Degree of Surface Disfigurement of 

Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt Accumulation,” 

ASTM International; incorporated by reference in Section G.5.q of this rule.
Santa Barbara County APCD Rule 323.1 323.1 - 3 [date of rule adoption] 

“Bay Area Air Quality Management District Method 41 (Revised 2005), “Materials Containing 

Parachlorobenzotrifluoride”” means the test method adopted by the Bay Area Air Quality Management 

District as of [date of rule adoption]. 

“Bay Area Air Quality Management District Method 43 (Revised 2005), “Determination of Volatile 

Methylsiloxanes in Solvent-Based Coatings, Inks, and Related Materials”” means the test method 

adopted by the Bay Area Air Quality Management District as of [date of rule adoption]. 

“Bitumens” means any black or brown materials, including, but not limited to, asphalt, tar, pitch, and 

asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons, and are obtained from 

natural deposits or as residues from the distillation of crude petroleum or coal. 

“Bituminous Roof Coating” means any coating which incorporates bitumens that is labeled and 

formulated exclusively for roofing.

“Bituminous Roof Primer” means any primer which incorporates bitumens that is labeled and formulated 

exclusively for roofing and intended for the purpose of preparing a weathered or aged surface or improving 

the adhesion of subsequent surfacing components.

“Bond Breaker” means any coating labeled and formulated for application between layers of concrete to 

prevent a freshly poured top layer of concrete from bonding to the layer over which it is poured. 

“Coating” means any 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. 

“Colorant” means any concentrated pigment dispersion in water, solvent, and/or binder that is added to an 

architectural coating after packaging in sale units to produce the desired color. 

“Concrete Curing Compound” means any coating labeled and formulated for application to freshly 

poured concrete to perform one or more of the following functions: 

a. Retard the evaporation of water; or 

b. Harden or dustproof the surface of freshly poured concrete. 

“Concrete/Masonry Sealer” means any clear or opaque coating that is labeled and formulated primarily 

for application to concrete and masonry surfaces to perform one or more of the following functions: 

a. Prevent penetration of water; or 

b. Provide resistance against abrasion, alkalis, acids, mildew, staining, or ultraviolet light; or 

c. Harden or dustproof the surface of aged or cured concrete. 

“Driveway Sealer” means any coating labeled and formulated for application to worn asphalt driveway 

surfaces to perform one or more of the following functions: 

a. Fill cracks; or 

b. Seal the surface to provide protection; or 

c. Restore or preserve the appearance. 

“Dry Fog Coating” means any coating labeled and formulated only for spray application such that 

overspray droplets dry before subsequent contact with incidental surfaces in the vicinity of the surface 

coating activity. 
Santa Barbara County APCD Rule 323.1 323.1 - 4 [date of rule adoption]

“Exempt Compound” means any compound identified as exempt under the definition of “Volatile 

Organic Compound (VOC).” Tertiary-butyl acetate, also known as t-butyl acetate or tBAc, shall be 

considered exempt as a VOC only for purposes of VOC emissions limitations or VOC Content 

requirements and shall be considered a VOC for purposes of all recordkeeping, emissions reporting, 

photochemical dispersion modeling, and inventory requirements which apply to VOCs. Exempt compounds 

content of a coating shall be determined by Environmental Protection Agency Method 24 or South Coast 

Air Quality Management District Method 303-91 (Revised 1996), “Determination of Exempt Compounds,” 

incorporated by reference in Section G.5.h and Section G.5.g of this rule, respectively. 

“Faux Finishing Coating” means any coating labeled and formulated to meet one or more of the 

following criteria:

a. A glaze or textured coating used to create artistic effects, including, but not limited to: 

dirt, suede, old age, smoke damage, and simulated marble and wood grain; or

b. A decorative coating used to create a metallic, iridescent, or pearlescent appearance that 

contains at least 48 grams of pearlescent mica pigment or other iridescent pigment per 

liter of coating as applied (at least 0.4 pound per gallon); or

c. A decorative coating used to create a metallic appearance that contains less than 48 grams 

of elemental metallic pigment per liter of coating as applied (less than 0.4 pound per 

gallon), when tested in accordance with the South Coast Air Quality Management 

District Method 318-95, “Determination of Weight Percent Elemental Metal in Coatings 

By X-Ray Diffraction,” incorporated by reference in Section G.5.c of this rule; or

d. A decorative coating used to create a metallic appearance that contains greater than 48 

grams of elemental metallic pigment per liter of coating as applied (greater than 0.4 

pound per gallon) and which requires a clear topcoat to prevent the degradation of the 

finish under normal use conditions. The metallic pigment content shall be determined in 

accordance with the South Coast Air Quality Management District Method 318-95, 

“Determination of Weight Percent Elemental Metal in Coatings By X-Ray Diffraction,” 

incorporated by reference in Section G.5.c of this rule; or

e. A clear topcoat to seal and protect a Faux Finishing coating that meets the requirements 

of Section a, b, c, or d above. These clear topcoats shall be sold and used solely as part of 

a Faux Finishing coating system, and shall be labeled in accordance with Section E.1.d of 

this rule.

“Fire-Resistive Coating” means any coating labeled and formulated to protect structural integrity by 

increasing the fire endurance of interior or exterior steel and other structural materials. The Fire Resistive 

category includes sprayed fire resistive materials and intumescent fire resistive coatings that are used to 

bring structural materials into compliance with federal, state, and local building code requirements. FireResistive coatings shall be tested in accordance with ASTM Designation E119-07, “Standard Test Methods 

for Fire Tests of Building Construction and Materials,” ASTM International, incorporated by reference in 

Section G.5.a of this rule. Fire Resistive coatings and testing agencies shall be approved by building code 

officials.

“Flat Coating” means any coating that is not defined under any other definition in this rule and that 

registers gloss less than 15 on an 85-degree meter or less than 5 on a 60-degree meter according to ASTM 

Designation D523-89(1999), “Standard Test Method for Specular Gloss,” ASTM International, 

incorporated by reference in Section G.5.b of this rule.

“Floor Coating” means any opaque coating that is labeled and formulated for application to flooring, 

including, but not limited to, decks, porches, steps, garage floors, and other horizontal surfaces that may be 

subject to foot traffic.
Santa Barbara County APCD Rule 323.1 323.1 - 5 [date of rule adoption]

“Form-Release Compound” means any coating labeled and formulated for application to a concrete form 

to prevent the freshly poured concrete from bonding to the form. The form may consist of wood, metal, or 

some material other than concrete.

“Graphic Arts Coating or Sign Paint” means any coating labeled and formulated for hand-application by 

artists using brush, airbrush, or roller techniques to indoor and outdoor signs (excluding structural 

components) and murals, including lettering enamels, poster colors, copy blockers, and bulletin enamels.

“High Temperature Coating” means any high performance coating labeled and formulated for 

application to substrates exposed continuously or intermittently to temperatures above 204 degrees Celsius 

(400 degrees Fahrenheit).

“Industrial Maintenance Coating” means any high performance architectural coating, including primers, 

sealers, undercoaters, intermediate coats, and topcoats formulated for application to substrates, including 

floors, exposed to one or more of the following extreme environmental conditions listed in Section a 

through e below, and labeled as specified in Section E.1.e of this rule:

a. Immersion in water, wastewater, or chemical solutions, including aqueous and nonaqueous solutions, or chronic exposure of interior surfaces to moisture condensation; or

b. Acute or chronic exposure to corrosive, caustic or acidic agents, or to chemicals, 

chemical fumes, or chemical mixtures or solutions; or

c. Frequent exposure to temperatures above 121 degrees Celsius (250 degrees Fahrenheit); 

or

d. Frequent heavy abrasion, including mechanical wear and frequent scrubbing with 

industrial solvents, cleansers, or scouring agents; or

e. Exterior exposure of metal structures and structural components.

“Low Solids Coating” means any coating containing 0.12 kilogram or less of solids per liter (1 pound or 

less of solids per gallon) of coating material as recommended for application by the manufacturer. The 

VOC Content for Low Solids Coatings shall be calculated in accordance with the definition of “VOC 

Actual” within Section C of this rule.

“Magnesite Cement Coating” means any coating labeled and formulated for application to magnesite 

cement decking to protect the magnesite cement substrate from erosion by water.

“Manufacturer” means any person, company, firm, or establishment who imports, blends, assembles, 

produces, packages, repackages, or re-labels any architectural coating, not including retail outlets where 

labels or stickers may be affixed to architectural coating containers or where colorant is added at the point 

of sale.

“Manufacturer’s Maximum Thinning Recommendation” means the maximum recommendation for 

thinning that is indicated on the label or lid of the coating container.

“Mastic Texture Coating” means any coating labeled and formulated to cover holes and minor cracks and 

to conceal surface irregularities, and is applied in a single coat of at least 10 mils (at least 0.010 inch) dry 

film thickness.

“Medium Density Fiberboard (MDF)” means any composite wood product, panel, molding, or other 

building material composed of cellulosic fibers, usually wood, made by dry forming and pressing of a 

resinated fiber mat.
Santa Barbara County APCD Rule 323.1 323.1 - 6 [date of rule adoption] 

“Metallic Pigmented Coating” means any coating that is labeled and formulated to provide a metallic 

appearance. Metallic Pigmented coatings shall contain at least 48 grams of elemental metallic pigment 

(excluding zinc) per liter of coating as applied (at least 0.4 pound per gallon), when tested in accordance 

with South Coast Air Quality Management District Method 318-95, “Determination of Weight Percent 

Elemental Metal in Coatings By X-Ray Diffraction,” incorporated by reference in Section G.5.c of this 

rule. The Metallic Pigmented Coating category does not include coatings applied to roofs or Zinc-Rich 

Primers. 

“Multi-Color Coating” means any coating that is packaged in a single container and that is labeled and 

formulated to exhibit more than one color when applied in a single coat. 

“Multicomponent Coating” means any coating requiring the addition of a separate reactive resin, 

commonly known as a catalyst or hardener, before application to form an acceptable dry film. 

“National Cooperative Highway Research Report 244 (1981), “Concrete Sealers for the Protection of 

Bridge Structures”” means the test method adopted by the Transportation Research Board as of [date of 

rule adoption]. 

“Nonflat Coating” means any coating that is not defined under any other definition in this rule and that 

registers a gloss of 15 or greater on an 85-degree meter and 5 or greater on a 60-degree meter according to 

ASTM Designation D523-89(1999), “Standard Test Method for Specular Gloss,” ASTM International, 

incorporated by reference in Section G.5.b of this rule. 

“Nonflat - High Gloss Coating” means any nonflat coating that registers a gloss of 70 or greater on a 60-

degree meter according to ASTM Designation D523-89(1999), “Standard Test Method for Specular 

Gloss,” ASTM International, incorporated by reference in Section G.5.b of this rule. Nonflat – High Gloss 

coatings shall be labeled in accordance with Section E.1.i. 

“Particleboard” means any composite wood product panel, molding, or other building material composed 

of cellulosic material, usually wood, in the form of discrete particles, as distinguished from fibers, flakes, or 

strands, which are pressed together with resin. 

“Pearlescent” means exhibiting various colors depending on the angles of illumination and viewing, as 

observed in mother-of-pearl. 

“Plywood” means any panel product consisting of layers of wood veneers or composite core pressed 

together with resin. Plywood includes panel products made by either hot or cold pressing (with resin) 

veneers to a platform. 

“Post-Consumer Coating” means any finished coating generated by a business or consumer that have 

served their intended end uses, and are recovered from or otherwise diverted from the waste stream for the 

purpose of recycling. 

“Pretreatment Wash Primer” means any primer that contains a minimum of 0.5 percent acid, by weight, 

when tested in accordance with ASTM Designation D1613-06, “Standard Test Method for Acidity in 

Volatile Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products,” 

ASTM International, incorporated by reference in Section G.5.d of this rule, that is labeled and formulated 

for application directly to bare metal surfaces to provide corrosion resistance and to promote adhesion of 

subsequent topcoats. 

“Primer, Sealer, and Undercoater” means any coating labeled and formulated for one or more of the 

following purposes: 

a. To provide a firm bond between the substrate and the subsequent coatings; or 

b. To prevent subsequent coatings from being absorbed by the substrate; or 
Santa Barbara County APCD Rule 323.1 323.1 - 7 [date of rule adoption] 

 c. To prevent harm to subsequent coatings by materials in the substrate; or 

 d. To provide a smooth surface for the subsequent application of coatings; or 

 e. To provide a clear finish coat to seal the substrate; or 

 f. To block materials from penetrating into or leaching out of a substrate. 

“Reactive Penetrating Sealer” means any clear or pigmented coating that is labeled and formulated for 

application to above-grade concrete and masonry substrates to provide protection from water and 

waterborne contaminants, including, but not limited to, alkalis, acids, and salts. Reactive Penetrating 

Sealers shall penetrate into concrete and masonry substrates and chemically react to form covalent bonds 

with naturally occurring minerals in the substrate. Reactive Penetrating Sealers line the pores of concrete 

and masonry substrates with a hydrophobic coating, but do not form a surface film. Reactive Penetrating 

Sealers shall meet all of the following criteria: 

a. The Reactive Penetrating Sealer shall improve water repellency at least 80 percent after 

application on a concrete or masonry substrate. This performance shall be verified on 

standardized test specimens, in accordance with one or more of the following standards, 

incorporated by reference in Section G.5.r of this rule: ASTM Designation C67-07, 

“Standard Test Methods for Sampling and Testing Brick and Structural Clay Tile,” or 

ASTM Designation C97-02, “Standard Test Methods for Absorption and Bulk Specific 

Gravity of Dimension Stone,” or ASTM C140-06, “Standard Test Methods for Sampling 

and Testing Concrete Masonry Units and Related Units,” ASTM International; and 

b. The Reactive Penetrating Sealer shall not reduce the water vapor transmission rate by 

more than 2 percent after application on a concrete or masonry substrate. This 

performance shall be verified on standardized test specimens, in accordance with ASTM 

Designation E96/E96M-05, “Standard Test Methods for Water Vapor Transmission of 

Materials,” ASTM International, incorporated by reference in Section G.5.s of this rule; 

c. Products labeled and formulated for vehicular traffic surface chloride screening 

applications shall meet the performance criteria listed in the National Cooperative 

Highway Research Report 244 (1981), incorporated by reference in Section G.5.t of this 

rule; and 

d. Containers for Reactive Penetrating Sealers shall be labeled in accordance with Section 

E.1.g of this rule. 

 

“Recycled Coating” means any architectural coating formulated such that it contains a minimum of 50 

percent by volume of post-consumer coating, with a maximum of 50 percent by volume of secondary 

industrial materials or virgin materials. 

“Roof Coating” means any non-bituminous coating labeled and formulated for application to roofs for the 

primary purpose of preventing water penetration, reflecting ultraviolet light, or reflecting solar radiation. 

“Rust Preventative Coating” means any coating formulated to prevent the corrosion of metal surfaces for 

one or more of the following applications: 

a. Direct-to-metal coating; or 

b. Coating intended for application over rusty, previously coated surfaces. 

The Rust Preventative category does not include the following: 
Santa Barbara County APCD Rule 323.1 323.1 - 8 [date of rule adoption] 

a. Coatings that are required to be applied as a topcoat over a primer; or 

b. Coatings that are intended for use on wood or any other non-metallic surface. 

Rust Preventative coatings are for metal substrates only and shall be labeled as such, in accordance 

with the labeling requirements in Section E.1.f of this rule. 

“Secondary Industrial Materials” means any products or by-products of the paint manufacturing process 

that are of a known composition and have economic value but can no longer be used for their intended 

purpose. 

“Semitransparent Coating” means any coating that contains binders and colored pigments and is 

formulated to change the color of the surface, but not conceal the grain pattern or texture. 

“Shellac” means any clear or opaque coating formulated solely with the resinous secretions of the lac 

beetle, Laccifer lacca, and formulated to dry by evaporation without a chemical reaction. 

“Shop Application” means any application of a coating to a product or a component of a product in or on 

the premises of a factory or a shop as part of a manufacturing, production, or repairing process (e.g., 

original equipment manufacturing coatings). 

“Solicit” means to require for use or to specify, by written or oral contract. 

“South Coast Air Quality Management District Method 303-91 (Revised 1996), “Determination of 

Exempt Compounds,” August 1996,” means the test method adopted by the South Coast Air Quality 

Management District as of [date of rule adoption]. 

“South Coast Air Quality Management District Method 304-91 (Revised 1996), “Determination of 

Volatile Organic Compounds (VOC) in Various Materials”” means the test method adopted by the 

South Coast Air Quality Management District as of [date of rule adoption]. 

“South Coast Air Quality Management District Method 318-95, “Determination of Weight Percent 

Elemental Metal in Coatings by X-Ray Diffraction”” means the test method adopted by the South Coast 

Air Quality Management District as of [date of rule adoption]. 

“Stain” means any semitransparent or opaque coating labeled and formulated to change the color of a 

surface but not to conceal the grain pattern or texture. 

“Stone Consolidant” means any coating that is labeled and formulated for application to stone substrates 

to repair historical structures that have been damaged by weathering or other decay mechanisms. Stone 

Consolidants shall penetrate into stone substrates to create bonds between particles and consolidate 

deteriorated material. Stone Consolidants shall be specified and used in accordance with ASTM 

Designation E2167-01, “Standard Guide for Selection and Use of Stone Consolidants,” ASTM 

International, incorporated by reference in Section G.5.u of this rule. Stone Consolidants are for 

professional use only and shall be labeled as such, in accordance with the labeling requirements in Section 

E.1.h of this rule. 

“Swimming Pool Coating” means any coating labeled and formulated to coat the interior of swimming 

pools and to resist swimming pool chemicals. Swimming pool coatings include coatings used for 

swimming pool repair and maintenance. 

“Tint Base” means any architectural coating to which colorant is added after packaging in sale units to 

produce a desired color. 

“Traffic Marking Coating” means any coating labeled and formulated for marking and striping streets, 

highways, or other traffic surfaces, including, but not limited to, curbs, berms, driveways, parking lots, 
Santa Barbara County APCD Rule 323.1 323.1 - 9 [date of rule adoption]

sidewalks, and airport runways.

“Tub and Tile Refinish Coating” means any clear or opaque coating that is labeled and formulated 

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

coatings shall meet all of the following criteria:

a. The coating shall have a scratch hardness of 3H or harder and a gouge hardness of 4H or 

harder. This shall be determined on bonderite 1000, in accordance with ASTM 

Designation D3363-05, “Standard Test Method for Film Hardness by Pencil Test,” 

ASTM International, incorporated by reference in Section G.5.m of this rule; and

b. The coating shall have a weight loss of 20 milligrams or less after 1000 cycles. This shall 

be determined with CS-17 wheels on bonderite 1000, in accordance with ASTM 

Designation D4060-07, “Standard Test Method for Abrasion Resistance of Organic 

Coatings by the Taber Abraser,” ASTM International, incorporated by reference in 

Section G.5.n of this rule; and

c. The coating shall withstand 1000 hours or more of exposure with few or no #8 blisters. 

This shall be determined on unscribed bonderite, in accordance with ASTM Designation 

D4585-99, “Standard Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation,” ASTM International, and ASTM Designation D714-02e1, “Standard Test 

Method for Evaluating Degree of Blistering of Paints,” ASTM International, incorporated 

by reference in Section G.5.o of this rule; and

d. The coating shall have an adhesion rating of 4B or better after 24 hours of recovery. This 

shall be determined on unscribed bonderite, in accordance with ASTM Designation 

D4585-99, “Standard Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation,” ASTM International, and ASTM Designation D3359-02, “Standard Test 

Methods for Measuring Adhesion by Tape Test,” ASTM International, incorporated by 

reference in Section G.5.l of this rule.

“Veneer” means any thin sheets of wood peeled or sliced from logs for use in the manufacture of wood 

products such as plywood, laminated veneer lumber, or other products.

“Virgin Materials” means any materials that contain no post-consumer coatings or secondary industrial 

materials.

“Volatile Organic Compound (VOC)” means any compound containing at least one (1) atom of carbon, 

except for the following exempt compounds: 

a. acetone

b. ammonium carbonate

c. carbon dioxide

d. carbon monoxide

e. carbonic acid

f. dimethyl carbonate

g. ethane

h. metallic carbides or carbonates

i. methane

j. methyl acetate

k. methyl chloroform (1,1,1-trichloroethane)

l. methyl formate; HCOOCH3

m. cyclic, branched, or linear completely methylated siloxane compounds

n. methylene chloride

o. parachlorobenzotrifluoride

p. perchloroethylene (tetrachloroethylene)
Santa Barbara County APCD Rule 323.1 323.1 - 10 [date of rule adoption]

q. the following four classes of perfluorocarbon (PFC) compounds: 

i. cyclic, branched, or linear, completely fluorinated alkanes, 

ii. cyclic, branched, or linear, completely fluorinated ethers with no unsaturations, 

iii. cyclic, branched, or linear, completely fluorinated tertiary amines with no 

unsaturations, and

iv. sulfur containing perfluorocarbons with no unsaturations and with sulfur bonds 

only to carbon and fluorine.

r. propylene carbonate

s. tertiary-butyl acetate; C6H12O2 (“acetic acid, 1,1-dimethylethyl ester”)

Tertiary-butyl acetate (also known as t-butyl acetate or tBAc) shall be considered exempt 

as a VOC only for purposes of VOC emissions limitations or VOC Content requirements 

and shall be a VOC for purposes of all recordkeeping, emissions reporting, 

photochemical dispersion modeling, and inventory requirements which apply to VOCs.

t. CFC-11 (trichlorofluoromethane)

u. CFC-12 (dichlorodifluoromethane)

v. CFC-113 (1,1,2-trichloro-1,2,2-trifluoroethane)

w. CFC-114 (1,2-dichloro 1,1,2,2-tetrafluoroethane)

x. CFC-115 (chloropentafluoroethane)

y. HCFC-22 (chlorodifluoromethane)

z. HCFC-31 (chlorofluoromethane)

aa. HCFC-123 (1,1,1-trifluoro 2,2-dichloroethane)

ab. HCFC-123a (1,2-dichloro-1,1,2-trifluoroethane)

ac. HCFC-124 (2-chloro-1,1,1,2-tetrafluoroethane)

ad. HCFC-141b (1,1-dichloro 1-fluoroethane)

ae. HCFC-142b (1-chloro-1,1 difluoroethane)

af. HCFC-151a (1-chloro-1-fluoroethane)

ag. HCFC-225ca (3,3-dichloro-1,1,1,2,2-pentafluoropropane) 

ah. HCFC-225cb (1,3-dichloro-1,1,2,2,3-pentafluoropropane) 

ai. HFC-23 (trifluoromethane)

aj. HFC-32 (difluoromethane)

ak. HFC-43-10mee (1,1,1,2,3,4,4,5,5,5-decafluoropentane)

al. HFC-125 (pentafluoroethane)

am. HFC-134 (1,1,2,2-tetrafluoroethane)

an. HFC-134a (1,1,1,2-tetrafluoroethane)

ao. HFC-143a (1,1,1-trifluoroethane)

ap. HFC-152a (1,1-difluoroethane)

aq. HFC-161 (ethylfluoride)

ar. HFC-227ea (1,1,1,2,3,3,3-heptafluoropropane)

as. HFC-236ea (1,1,1,2,3,3-hexafluoropropane)

at. HFC-236fa (1,1,1,3,3,3-hexafluoropropane)

au. HFC-245ca (1,1,2,2,3-pentafluoropropane)

av. HFC-245ea (1,1,2,3,3-pentafluoropropane)

aw. HFC-245eb (1,1,1,2,3-pentafluoropropane)

ax. HFC-245fa (1,1,1,3,3-pentafluoropropane) 

ay. HFC-365mfc (1,1,1,3,3-pentafluorobutane)

az. HFE-7000; n-C3F7OCH3; (1,1,1,2,2,3,3-heptafluoro-3-methoxy-propane)

ba. HFE-7100; (CF3)2CFCF2OCH3; (2-(difluoromethoxymethyl)-1,1,1,2,3,3,3-

heptafluoropropane) or C4F9OCH3; (1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy-butane)

bb. HFE-7200; (CF3)2CFCF2OC2H5; (2-(ethoxydifluoromethyl)-1,1,1,2,3,3,3-

heptafluoropropane) or C4F9OC2H5; (1-ethoxy-1,1,2,2,3,3,4,4,4-nonafluorobutane)

bc. HFE-7300; (1,1,1,2,2,3,4,5,5,5-decafluoro-3-methoxy-4-trifluoromethyl-pentane)

bd. HFE-7500; (3-ethoxy- 1,1,1,2,3,4,4,5,5,6,6,6-dodecafluoro-2- (trifluoromethyl) hexane)
Santa Barbara County APCD Rule 323.1 323.1 - 11 [date of rule adoption]

“VOC Actual” means the weight of VOC per volume of coating and it is calculated with the following 

equation:

(Ws ̶ Ww ̶ Wec)

 VOC Actual =

 (Vm)

Where:

VOC Actual = the grams of VOC per liter of coating (also known as “Material 

VOC”)

Ws = weight of volatiles, in grams

Ww = weight of water, in grams

Wec = weight of exempt compounds, in grams

Vm = volume of coating, in liters

“VOC Content” means the weight of VOC per volume of coating. VOC Content is “VOC Regulatory,” 

as defined in Section C of this rule, for all coatings except for those in the Low Solids category. For 

coatings in the Low Solids category, the VOC Content is “VOC Actual,” as defined in Section C of this 

rule. If the coating is a multicomponent coating, the VOC Content is “VOC Regulatory” as mixed or 

catalyzed. If the coating contains silanes, siloxanes, or other ingredients that generate ethanol or other 

VOCs during the curing process, the VOC Content shall include the VOCs emitted during curing.

“VOC Regulatory” means the weight of VOC per volume of coating, less the volume of water and exempt 

compounds. It is calculated with the following equation:

(Ws ̶ Ww ̶ Wec)

 VOC Regulatory =

(Vm ̶ Vw ̶ Vec)

Where:

VOC Regulatory = grams of VOC per liter of coating, less water and exempt compounds 

(also known as “Coating VOC”)

Ws = weight of volatiles, in grams

Ww = weight of water, in grams

Wec = weight of exempt compounds, in grams

Vm = volume of coating, in liters

Vw = volume of water, in liters

Vec = volume of exempt compounds, in liters

“Waterproofing Membrane” means any clear or opaque coating that is labeled and formulated for 

application to concrete and masonry surfaces to provide a seamless waterproofing membrane that prevents 

any penetration of liquid water into the substrate. Waterproofing Membranes are intended for the following 

waterproofing applications: below-grade surfaces, between concrete slabs, inside tunnels, inside concrete 

planters, and under flooring materials. Waterproofing Membranes shall meet the following criteria:

a. Coating shall be applied in a single coat of at least 25 mils (at least 0.025 inch) dry film 

thickness; and

b. Coatings shall meet or exceed the requirements contained in ASTM Designation C836-

06, “Standard Specification for High Solids Content, Cold Liquid Applied Elastomeric 

Waterproofing Membrane for Use with Separate Wearing Course,” ASTM International, 

incorporated by reference in Section G.5.p of this rule.
Santa Barbara County APCD Rule 323.1 323.1 - 12 [date of rule adoption]

The Waterproofing Membrane category does not include topcoats that are included in the 

Concrete/Masonry Sealer category (e.g., parking deck topcoats, pedestrian deck topcoats, etc.).

“Wood Coating” means any coating labeled and formulated for application to wood substrates only. The 

Wood Coatings category includes the following clear and semitransparent coatings: lacquers; varnishes; 

sanding sealers; penetrating oils; clear stains; wood conditioners used as undercoats; and wood sealers used 

as topcoats. The Wood Coatings category also includes the following opaque wood coatings: opaque 

lacquers; opaque sanding sealers; and opaque lacquer undercoaters. The Wood Coatings category does not 

include the following: clear sealers that are labeled and formulated for use on concrete/masonry surfaces; or 

coatings intended for substrates other than wood.

Wood Coatings shall be labeled “For Wood Substrates Only,” in accordance with Section E.1.j of 

this rule.

“Wood Preservative” means any coating labeled and formulated to protect exposed wood from decay or 

insect attack, that is registered with both the Environmental Protection Agency under the Federal 

Insecticide, Fungicide, and Rodenticide Act (7 United States Code Section 136, et seq.) and with the 

California Department of Pesticide Regulation.

“Wood Substrate” means any substrate made of wood, particleboard, plywood, medium density 

fiberboard, rattan, wicker, bamboo, or composite products with exposed wood grain. Wood products do not 

include items comprised of simulated wood.

“Zinc-Rich Primer” means any coating that meets all of the following specifications:

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

solids; and

b. Coating is formulated for application to metal substrates to provide a firm bond between 

the substrate and subsequent applications of coatings; and

c. Coating is intended for professional use only and is labeled as such, in accordance with 

the labeling requirements in Section E.1.k of this rule.

D. Standards

1. VOC Content Limits: 

a. Except as provided in Sections D.2 or D.3 of this rule, no person shall manufacture, 

blend, repackage, supply, sell or offer for sale, for use within the District, nor solicit for 

application or apply within the District any architectural coating that has a VOC Content 

in excess of any corresponding limit specified in Table 323.1-1.

b. For any coating that does not meet any of the definitions for the specialty coatings 

categories listed in Table 323.1-1, the VOC Content limit shall be determined by 

classifying the coating as a Flat coating, a Nonflat coating, or a Nonflat – High Gloss 

coating, based on its gloss, as determined by the method specified in Section G.5.b and 

the corresponding Flat, Nonflat, or Nonflat – High Gloss coating VOC limit shall apply.

2. Most Restrictive VOC Limit: If a coating meets the definition in Section C of this rule for one or 

more specialty coating categories that are listed in Table 323.1-1, then that coating is not required 

to meet the VOC limits for Flat, Nonflat, or Nonflat – High Gloss coatings, but shall meet the 

VOC limit for the applicable specialty coating listed in Table 323.1-1. 

With the exception of the specialty coating categories specified in Sections D.2.a through D.2.k, if 

a coating is recommended for use in more than one of the specialty coating categories listed in 
Santa Barbara County APCD Rule 323.1 323.1 - 13 [date of rule adoption]

Table 323.1-1, the most restrictive (or lowest) VOC Content limit shall apply. This requirement 

applies to: usage recommendations that appear anywhere on the coating container, anywhere on 

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

supplied by a manufacturer or anyone acting on their behalf. 

a. Aluminum roof coatings;

b. Bituminous roof primers;

c. High temperature coatings;

d. Industrial maintenance coatings;

e. Low solids coatings;

f. Metallic pigmented coatings;

g. Pretreatment wash primers;

h. Shellacs;

i. Wood coatings;

j. Wood preservatives; and

k. Zinc-rich primers.

3. Sell-Through of Coatings: 

A coating manufactured prior to January 1, 2015 may be sold, supplied, or offered for sale for up 

to three years after January 1, 2015, provided that the coating complied, at the time of 

manufacture, with all applicable provisions in Rule 323 as revised November 15, 2001. Such 

coating may also be applied at any time, both before and after January 1, 2015. This Section does 

not apply to any coating that does not display the date or date code required by Section E.1.a of 

this rule.

4. Painting Practices: 

All architectural coating containers used to apply the contents therein to a surface directly from the 

container by pouring, siphoning, brushing, rolling, padding, ragging or other means, shall be 

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

drums, buckets, cans, pails, trays or other application containers. Containers of any VOCcontaining materials used for thinning and cleanup shall also be closed when not in use.

5. Thinning: No person who applies or solicits the application of any architectural coating shall 

apply a coating that is thinned to exceed the applicable VOC limit specified in Table 323.1-1.

E. Container Labeling Requirements

1. Each manufacturer of any architectural coating subject to this rule shall display the information 

listed in Sections E.1.a through E.1.c on the coating container (or label) in which the coating is 

sold or distributed, and as applicable, the information in Sections E.1.d through E.1.k.

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

shall be indicated on the label, lid, or bottom of the container. If the manufacturer uses a 
Santa Barbara County APCD Rule 323.1 323.1 - 14 [date of rule adoption]

date code for any coating, the manufacturer shall file an explanation of each code with 

the Executive Officer of the California Air Resources Board.

b. Thinning Recommendations: A statement of the manufacturer’s recommendation 

regarding thinning of the coating shall be indicated on the label or lid of the container. 

This requirement does not apply to the thinning of architectural coatings with water. If 

thinning of the coating prior to use is not necessary, the recommendation shall specify 

that the coating is to be applied without thinning.

c. VOC Content: Each container of any coating subject to this rule shall display one of the 

following values in grams of VOC per liter of coating:

i. Maximum VOC Content as determined from all potential product formulations; 

or

ii. VOC Content as determined from actual formulation data; or

iii. VOC Content as determined using the test methods in Section G.2 of this rule.

If the manufacturer does not recommend thinning, the container shall display the VOC 

Content, as supplied. If the manufacturer recommends thinning, the container shall 

display the VOC Content, including the maximum amount of thinning solvent 

recommended by the manufacturer. If the coating is a multicomponent coating, the 

container shall display the VOC Content as mixed or catalyzed. If the coating contains 

silanes, siloxanes, or other ingredients that generate ethanol or other VOCs during the 

curing process, the VOC Content shall include the VOCs emitted during curing. VOC 

Content shall be determined as defined in Section C. 

d. Faux Finishing Coatings: The labels of all Clear Topcoats for Faux Finishing coatings 

shall prominently display the statement “This product can only be sold or used as part of 

a Faux Finishing coating system.”

e. Industrial Maintenance Coatings: The labels of all Industrial Maintenance coatings 

shall prominently display the statement “For industrial use only” or “For professional use 

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

f. Rust Preventative Coatings: The labels of all rust preventative coatings shall 

prominently display the statement “For Metal Substrates Only.”

g. Reactive Penetrating Sealers: The labels of all Reactive Penetrating Sealers shall 

prominently display the statement “Reactive Penetrating Sealer.”

h. Stone Consolidants: The labels of all Stone Consolidants shall prominently display the 

statement “Stone Consolidant - For Professional Use Only.”

i. Nonflat – High Gloss Coatings: The labels of all Nonflat – High Gloss coatings shall 

prominently display the words “High Gloss.”

j. Wood Coatings: The labels of all Wood Coatings shall prominently display the 

statement “For Wood Substrates Only.”

k. Zinc Rich Primers: The labels of all Zinc Rich Primers shall prominently display the 

statement “For industrial use only” or “For professional use only” or “Not for residential 

use” or “Not intended for residential use.”
Santa Barbara County APCD Rule 323.1 323.1 - 15 [date of rule adoption] 

F. Recordkeeping and Reporting Requirements 

1. Sales Data: A responsible official from each manufacturer shall upon request of the 

Executive Officer of the ARB, or his or her delegate, provide data concerning the 

distribution and sales of architectural coatings. The responsible official shall within 180 

days provide information, including, but not limited to: 

a. the name and mailing address of the manufacturer; 

b. the name, address and telephone number of a contact person; 

c. the name of the coating product as it appears on the label and the applicable coating 

category; 

d. whether the product is marketed for interior or exterior use or both; 

e. the number of gallons sold in California in containers greater than one liter (1.057 quart) 

and equal to or less than one liter (1.057 quart); 

f. the VOC Actual content and VOC Regulatory content in grams per liter. If thinning is 

recommended, list the VOC Actual content and VOC Regulatory content after maximum 

recommended thinning. If containers less than one liter have a different VOC content 

than containers greater than one liter, list separately. If the coating is a multicomponent 

product, provide the VOC content as mixed or catalyzed; 

g. the names and CAS numbers of the VOC constituents in the product; 

h. the names and CAS numbers of any compounds in the product specifically exempted 

from the VOC definition, as listed in Section C of this rule; 

i. whether the product is marketed as solventborne, waterborne, or 100% solids; 

j. description of resin or binder in the product; 

k. whether the coating is a single-component or multicomponent product; 

l. the density of the product in pounds per gallon; 

m. the percent by weight of: solids, all volatile materials, water, and any compounds in the 

product specifically exempted from the VOC definition, as listed in Section C of this 

rule; 

n. the percent by volume of: solids, water, and any compounds in the product specifically 

exempted from the VOC definition, as listed in Section C of this rule; and 

o. For any product containing tertiary-butyl acetate, the product’s tertiary-butyl acetate 

content in grams of tertiary-butyl acetate per liter, and the number of gallons per year 

sold in California. 

2. All sales data listed in Section F.1 above shall be maintained by the responsible official for a 

minimum of three years. Sales data submitted by the responsible official to the Executive Officer 

of the Air Resources Board may be claimed as confidential, and such information shall be handled 

in accordance with the procedures specified in Title 17, California Code of Regulations Sections 

91000-91022. 
Santa Barbara County APCD Rule 323.1 323.1 - 16 [date of rule adoption]

G. Compliance Provisions and Test Methods

1. Calculation of VOC Content: For the purpose of determining compliance with the VOC Content 

limits in Table 323.1-1, the VOC Content of a coating shall be determined using the procedure 

described in the appropriate Section C definition. The VOC Content of a tint base shall be 

determined without colorant that is added after the tint base is manufactured. If the manufacturer 

does not recommend thinning, the VOC Content shall be calculated for the product as supplied. If 

the manufacturer recommends thinning, the VOC Content shall be calculated including the 

maximum amount of thinning solvent recommended by the manufacturer. If the coating is a 

multicomponent coating, the VOC Content shall be calculated as mixed or catalyzed. If the 

coating contains silanes, siloxanes, or other ingredients that generate ethanol or other VOCs 

during the curing process, the VOC Content shall include the VOCs emitted during curing.

2. VOC Content of Coatings: To determine the physical properties of a coating in order to perform 

the calculations in the Section C definition for VOC Actual for low solids coatings or the Section 

C definition for VOC Regulatory for all other architectural coatings, the reference method for 

VOC Content is the Environmental Protection Agency Method 24, incorporated by reference in 

Section G.5.h, except as provided in Sections G.3 and G.4. An alternative method to determine the 

VOC Content of coatings is South Coast Air Quality Management District Method 304-91 

(Revised 1996), “Determination of Volatile Organic Compounds (VOC) in Various Materials,” 

incorporated by reference in Section G.5.i. The exempt compounds content shall be determined by 

South Coast Air Quality Management District Method 303-91 (Revised 1996), “Determination of 

Exempt Compounds,” or the Bay Area Air Quality Management District Method 43 (Revised 

2005), “Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks, and Related 

Materials,” or the Bay Area Air Quality Management District Method 41 (Revised 2005), 

“Materials Containing Parachlorobenzotrifluoride,” as applicable, incorporated by reference in 

Sections G.5.g, G.5.e, and G.5.f, respectively. To determine the VOC Content of a coating, the 

manufacturer may use the Environmental Protection Agency Method 24, or an alternative method 

as provided in Section G.3, formulation data, or any other reasonable means for predicting that the 

coating has been formulated as intended (e.g., quality assurance checks, recordkeeping). However, 

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

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

method is approved as specified in Section G.3. The Control Officer may require the manufacturer 

to conduct a Method 24 analysis.

3. Alternative Test Methods: Other test methods demonstrated to provide results that are acceptable 

for purposes of determining compliance with Section G.2, after review and approved in writing by 

the staffs of the District, the California Air Resources Board, and the Environmental Protection 

Agency, may also be used.

4. Methacrylate Traffic Marking Coatings: Analysis of methacrylate multicomponent coatings 

used as traffic marking coatings shall be conducted according to a modification of Environmental 

Protection Agency Method 24 (40 CFR part 59, subpart D, appendix A), incorporated by reference 

in Section G.5.j. This method has not been approved for methacrylate multicomponent coatings 

used for other purposes than as traffic marking coatings or for other classes of multicomponent 

coatings.

5. Test Methods: The following test methods are incorporated by reference herein, and shall be used 

to test coatings subject to the provisions of this rule:

a. Fire Resistance Rating: The fire resistance rating of a fire-resistive coating shall be 

determined by ASTM Designation E119-07, “Standard Test Methods for Fire Tests of 

Building Construction and Materials,” ASTM International (see Section C, Fire-Resistive 

Coating).
Santa Barbara County APCD Rule 323.1 323.1 - 17 [date of rule adoption]

b. Gloss Determination: The gloss of a coating shall be determined by ASTM Designation 

D523-89 (1999), “Standard Test Method for Specular Gloss,” ASTM International (see 

Section C, Flat Coating, Nonflat Coating, and Nonflat – High Gloss Coating).

c. Metal Content of Coatings: The metallic content of a coating shall be determined by 

South Coast Air Quality Management District Method 318-95, “Determination of Weight 

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

Methods of Analysis for Enforcement Samples (see Section C, Aluminum Roof, Faux 

Finishing, and Metallic Pigmented Coating).

d. Acid Content of Coatings: The acid content of a coating shall be determined by ASTM 

Designation D1613-06, “Standard Test Method for Acidity in Volatile Solvents and 

Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products,” ASTM 

International (see Section C, Pretreatment Wash Primer).

e. Exempt Compounds – Siloxanes: Exempt compounds that are cyclic, branched, or 

linear completely methylated siloxanes, shall be analyzed as exempt compounds for 

compliance with Section G by Bay Area Air Quality Management District Method 43 

(Revised 2005), “Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, 

Inks, and Related Materials,” BAAQMD Manual of Procedures, Volume III, adopted 

November 6, 1996 (see Section C, Volatile Organic Compound (VOC), and Section G.2).

f. Exempt Compounds – Parachlorobenzotrifluoride (PCBTF): The exempt compound 

parachlorobenzotrifluoride, shall be analyzed as an exempt compound for compliance 

with Section G by Bay Area Air Quality Management District Method 41 (Revised 

2005), “Determination of Volatile Organic Compounds in Solvent Based Coatings and 

Related Materials Containing Parachlorobenzotrifluoride,” BAAQMD Manual of 

Procedures, Volume III, adopted December 20, 1995 (see Section C, Volatile Organic 

Compound (VOC), and Section G.2).

g. Exempt Compounds: The content of exempt compounds shall be analyzed by South 

Coast Air Quality Management District Method 303-91 (Revised 1996), “Determination 

of Exempt Compounds,” SCAQMD Laboratory Methods of Analysis for Enforcement 

Samples (see Section C, Volatile Organic Compound (VOC), and Section G.2).

h. VOC Content of Coatings: The VOC Content of a coating (actual and regulatory) shall 

be determined by Environmental Protection Agency Method 24 as it exists in appendix A 

of 40 Code of Federal Regulations (CFR) part 60, “Determination of Volatile Matter 

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

Coatings” (see Section G.2).

i. Alternative VOC Content of Coatings: The VOC Content of coatings (actual and 

regulatory) may be analyzed either by Environmental Protection Agency Method 24 or 

South Coast Air Quality Management District Method 304-91 (Revised 1996), 

“Determination of Volatile Organic Compounds (VOC) in Various Materials,” SCAQMD 

Laboratory Methods of Analysis for Enforcement Samples (see Section G.2). 

j. Methacrylate Traffic Marking Coatings: The VOC Content of methacrylate 

multicomponent coatings used as traffic marking coatings shall be analyzed by the 

procedure in 40 CFR part 59, subpart D, appendix A, “Determination of Volatile Matter 

Content of Methacrylate Multicomponent Coatings Used as Traffic Marking Coatings” 

(June 30, 1999) (see Section G.4).

k. Hydrostatic Pressure for Basement Specialty Coatings: ASTM Designation D7088-

04, “Standard Practice for Resistance to Hydrostatic Pressure for Coatings Used in Below 
Santa Barbara County APCD Rule 323.1 323.1 - 18 [date of rule adoption]

Grade Applications Applied to Masonry,” ASTM International (see Section C, Basement

Specialty Coating).

l. Tub and Tile Refinish Coating Adhesion: ASTM Designation D4585-99, “Standard 

Practice for Testing Water Resistance of Coatings Using Controlled Condensation,” 

ASTM International, and ASTM D3359-02, “Standard Test Methods for Measuring 

Adhesion by Tape Test,” ASTM International (see Section C, Tub and Tile Refinish 

Coating).

m. Tub and Tile Refinish Coating Hardness: ASTM Designation D3363-05, “Standard 

Test Method for Film Hardness by Pencil Test,” ASTM International (see Section C, Tub 

and Tile Refinish Coating).

n. Tub and Tile Refinish Coating Abrasion Resistance: ASTM Designation D4060-07, 

“Standard Test Methods for Abrasion Resistance of Organic Coatings by the Taber 

Abraser,” ASTM International (see Section C, Tub and Tile Refinish Coating).

o. Tub and Tile Refinish Coating Water Resistance: ASTM Designation D4585-99, 

“Standard Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation,” ASTM International, and ASTM Designation D714-02e1, “Standard Test 

Method for Evaluating Degree of Blistering of Paints,” ASTM International (see Section 

C, Tub and Tile Refinish Coating).

p. Waterproofing Membrane: ASTM Designation C836-06, “Standard Specification for 

High Solids Content, Cold Liquid-Applied Elastomeric Waterproofing Membrane for 

Use with Separate Wearing Course,” ASTM International (see Section C, Waterproofing 

Membrane).

q. Mold and Mildew Growth for Basement Specialty Coatings: ASTM Designation 

D3273-00, “Standard Test Method for Resistance to Growth of Mold on the Surface of 

Interior Coatings in an Environmental Chamber,” ASTM International, and ASTM 

Designation D3274-95, “Standard Test Method for Evaluating Degree of Surface 

Disfigurement of Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt 

Accumulation,” ASTM International (see Section C, Basement Specialty Coating).

r. Reactive Penetrating Sealer Water Repellency: ASTM Designation C67-07, “Standard 

Test Methods for Sampling and Testing Brick and Structural Clay Tile,” ASTM 

International, or ASTM Designation C97-02, “Standard Test Methods for Absorption and 

Bulk Specific Gravity of Dimension Stone,” ASTM International, or ASTM Designation 

C140-06, “Standard Test Methods for Sampling and Testing Concrete Masonry Units and 

Related Units,” ASTM International (see Section C, Reactive Penetrating Sealer).

s. Reactive Penetrating Sealer Water Vapor Transmission: ASTM Designation 

E96/E96M-05, “Standard Test Method for Water Vapor Transmission of Materials,” 

ASTM International (see Section C, Reactive Penetrating Sealer).

t. Reactive Penetrating Sealer - Chloride Screening Applications: National Cooperative 

Highway Research Report 244 (1981), “Concrete Sealers for the Protection of Bridge 

Structures” (see Section C, Reactive Penetrating Sealer).

u. Stone Consolidants: ASTM Designation E2167-01, “Standard Guide for Selection and 

Use of Stone Consolidants,” ASTM International (see Section C, Stone Consolidant).

6. Environmental Protection Agency Test Method in Effect: The Environmental Protection 

Agency test methods in effect on [date of rule adoption] shall be the test methods used to meet the 

requirements of this rule.
Santa Barbara County APCD Rule 323.1 323.1 - 19 [date of rule adoption]

Table 323.1-1

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Limits are expressed as VOC Regulatory, thinned to the manufacturer’s maximum thinning recommendation, 

excluding any colorant added to tint bases. 

COATING CATEGORY VOC Content Limit

(Grams of VOC per 

Liter of Coating)

Flat Coatings 50

Nonflat Coatings 100

Nonflat – High Gloss Coatings 150

Specialty Coatings

Ablative Coatings 250

Aluminum Roof Coatings 400

Basement Specialty Coatings 400

Bituminous Roof Coatings 50

Bituminous Roof Primers 350

Bond Breakers 350

Concrete Curing Compounds 350

Concrete/Masonry Sealers 100

Driveway Sealers 50

Dry Fog Coatings 150

Faux Finishing Coatings 350

Fire-Resistive Coatings 350

Floor Coatings 100

Form-Release Compounds 250

Graphic Arts Coatings or Sign Paints 500

High Temperature Coatings 420

Industrial Maintenance Coatings 250

Low Solids Coatings3 120

Magnesite Cement Coatings 450

Mastic Texture Coatings 100

Metallic Pigmented Coatings 500

Multi-Color Coatings 250

Pretreatment Wash Primers 420

Primers, Sealers, and Undercoaters 100

Reactive Penetrating Sealers 350

Recycled Coatings 250

Roof Coatings 50

Rust Preventative Coatings 250

Shellacs:

 Clear

 Opaque

730

550

Stains 250

Stone Consolidants 450

Swimming Pool Coatings 340

Traffic Marking Coatings 100

 

3 Limit is expressed as VOC Actual.
COATING CATEGORY 

Tub and Tile Refinish Coatings 

Waterproofing Membranes 

Wood Coatings 

Wood Preservatives 

Zinc-Rich Primers 

VOC Content Limit 

(Grams ofVOC per 

Liter of Coating) 

420 

250 

275 

350 

340 

APPROVED AS TO FORM: 

MICHAEL C. GHIZZONI 

SANTA JBARACOUNTYCO ~/? 

By ~<Jd( Deputy ~~ · 

Attorneys for the Santa Barbara County 

Air Pollution Control District 

Santa Barbara County APCD Rule 323 .1 323 .1 - 20 [date of rule adoption]