SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

FINAL STAFF REPORT FOR 

PROPOSED AMENDED RULE 1113 – ARCHITECTURAL COATINGS

July 2007 

Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, and Area Sources 

Laki Tisopulos, Ph.D., P.E. 

Planning and Rules Manager 

VOC Rule Development 

Larry M. Bowen, P.E. 

Author: Dan Russell Air Quality Specialist 

Reviewed by: Barbara Baird Principal Deputy District Counsel 

William Wong Senior Deputy District Counsel 

Naveen Berry Program Supervisor 

David DeBoer Senior Staff Specialist 

Contributors Heather Farr Air Quality Specialist 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: WILLIAM A. BURKE, Ed.D. 

Speaker of the Assembly Appointee 

Vice Chairman: S. ROY WILSON, Ed.D. 

Supervisor, Fourth District 

Riverside County Representative 

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District 

Los Angeles County Representative 

BILL CAMPBELL 

Supervisor, Third District

Orange County Representative 

JANE W. CARNEY 

Senate Rules Committee Appointee 

RONALD O. LOVERIDGE 

Mayor, City of Riverside 

Cities Representative, Riverside County 

GARY OVITT 

Supervisor, Fourth District 

San Bernardino County Representative 

JAN PERRY 

Councilmember, 9th District 

Cities Representative, Los Angeles County, Western Region 

MIGUEL PULIDO 

Mayor, City of Santa Ana 

Cities Representative, Orange County 

TONIA REYES URANGA 

Councilmember, City of Long Beach 

Cities Representative, Los Angeles County, Eastern Region 

VACANT 

Governor’s Appointee 

DENNIS YATES 

Mayor, City of Chino 

Cities Representative, San Bernardino County 

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env. 
TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY .......................................................................................................... 1

STAFF PROPOSAL ..................................................................................................................... 1

STAFF ASSESSMENT FOR THE PROPOSED AMENDMENTS ........................................ 2

EMISSIONS IMPACT, COST AND COST-EFFECTIVENESS ............................................ 2

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)............................................. 3

SOCIOECONOMIC ASSESSMENT ......................................................................................... 3

LEGISLATIVE AUTHORITY ................................................................................................... 3

AQMP AND LEGAL MANDATES............................................................................................ 3

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE ................... 3

CONCLUSION AND RECOMMENDATION .......................................................................... 4

REFERENCES.............................................................................................................................. 4

COMMENTS AND RESPONSES .............................................................................................. 4

ATTACHMENT A 
Final Staff Report 

Proposed Amended Rule 1113 1 July 13, 2007 

EXECUTIVE SUMMARY 

Rule 1113 – Architectural Coatings was first adopted in 1977 and has been amended numerous 

times. It is applicable to manufacturers, distributors, and end-users of architectural coatings. 

In November 1996, the South Coast Air Quality Management District (AQMD) Governing 

Board (Board) amended Rule 1113 - Architectural Coatings to include an averaging 

compliance provision as a flexibility option providing a more cost-effective and flexible 

approach for manufacturers to transition compliant product lines into the marketplace. To use 

the Averaging Compliance Option successfully, a manufacturer must be able to distribute 

sufficient volumes of products with VOC content below applicable limits in order to offset the 

excess emissions from products with VOC content above the limits. One limitation of using 

the ACO, requires a manufacturer to have a broad array of commercial products, with 

sufficient volume of sales of products that are below the applicable VOC limit. 

One manufacturer, affected by the limitation of the ACO described above, has recently 

requested that the Stationary Source Committee, a subcommittee of the Board, direct staff to 

prepare amendments to Rule 1113 by removing the specialty primer category from the ACO 

provision because they were at a competitive disadvantage. The Stationary Source Committee, 

as a result of these discussions, directed staff to propose an amendment to Rule 1113 – 

Architectural Coatings to remove specialty primers from the ACO provision. After staff 

commenced rule making and subsequent to the Stationary Source committee’s direction to 

staff, the manufacturer withdrew its request. The Stationary Source Committee then advised 

staff the requested rule amendment would not be necessary. 

However, during implementation of recent amendments to the rule, it became apparent that by 

adding mica to the definition of metallic pigmented coatings it is improperly less restrictive 

than the federal definition and a correction to delete mica from the definition is therefore 

necessary. Staff also became aware that the test method in the rule used to determine the metal 

content of metallic pigmented coatings was outdated. In addition, during the public outreach it 

was pointed out that a sentence in the Appendix to the Rule is obsolete and therefore it is 

proposed to be deleted. 

STAFF PROPOSAL 

Staff has withdrawn the proposal to amend the ACO provision but is continuing to propose the 

following amendments to clarify issues related to rule implementation: 

• Amend the definition of metallic pigmented coatings to make it consistent with the 

federal AIM rule by removing the words “mica particles or any combination of 

metallic pigments and mica particles.” 

• Update the Test Method used to determine the weight percent of elemental metal in 

metallic coatings, to reflect current practice. 

• Delete the following obsolete sentence from Appendix A, Section A of the rule: 

“Manufacturers that submitted an annual exemption report in 2002 for quick-dry 

primers, sealers and undercoaters and included those coatings in their most recent 

approved ACO Program, may continue to average those coatings until July 1, 2006, so 

long as these coatings do not exceed 450 grams of VOC per liter of coating less water 
Final Staff Report 

Proposed Amended Rule 1113 2 July 13, 2007 

and less exempt compounds, in lieu of the otherwise applicable VOC limit of 350 

grams per liter.” 

STAFF ASSESSMENT FOR THE PROPOSED AMENDMENTS 

Metallic Pigmented Coatings

Staff developed the metallic pigmented coating category with a VOC limit of 500 g/l for 

decorative coatings containing at least 0.4 pounds per gallon (48 grams/liter) of metal such as 

gold and silver. The category does not include coatings in other categories with much lower 

VOC limits such as industrial maintenance coatings, zinc primers, and roof coatings that might 

contain metals as well. In 2003, at the request of some manufacturers, staff added mica to the 

definition of metallic pigmented coatings to allow a wider range of metallic color choices. 

During the implementation phase of this definition, it became apparent, however, that the 

addition of mica made the definition of metallic pigmented coatings less restrictive than the 

federal definition for a metallic pigmented coating, which does not include mica under the 

“National Volatile Organic Compound Emission Standards for Architectural Coatings.” A 

local air district rule cannot be less stringent than a federal regulation, but may be more 

restrictive; therefore, the staff proposal will eliminate reference to mica making the definition 

consistent with the federal definition, but continue to exclude all industrial coatings and roof 

coatings from the metallic pigmented coating definition, which is more restrictive than the 

federal definition. On January 9, 2007, staff mailed a letter to architectural coating 

manufacturers and their association, clarifying that mica would not be considered as part of 

the metallic content standard of 0.4 pounds per gallon included in the definition. A copy of 

the letter is included as Attachment A. 

Test Method

Staff is recommending the test method referred to in Rule 1113 - Architectural Coatings 

paragraph (e)(3), AQMD Method 311 Determination of Percent Metal in Metallic Coatings by 

Spectrographic Method, be updated to AQMD Method 318 Determination of Weight Percent 

Elemental Metal in Coatings by X-Ray Diffraction to reflect the method used in current 

practice. Although AQMD Method 311 is a valid method, it is based on outdated technology 

and requires equipment that the AQMD does not have and can no longer obtain. The AQMD 

laboratory has developed Method 318, an improved method for the determination of the 

elemental metal content in coatings. Method 318 has been accepted by the U.S. EPA and 

adopted by other regulatory agencies throughout California and the rest of the Nation. The 

AQMD laboratory specifically developed Method 318 to address the analysis of elemental 

aluminum because that was the metal of interest in the majority of the coatings at the time of 

the test method development. The test method states that it is currently only validated for the 

determination of the weight percent of elemental aluminum but also states that it is applicable 

for the determination of other elemental metals or crystalline materials for which appropriate 

standards are available and reasonable performance has been demonstrated. Validation of 

Method 318 for other elemental metals could be completed as necessary. 

EMISSIONS IMPACT, COST AND COST-EFFECTIVENESS 

Since mica is not a VOC, mica’s removal from the definition of metallic pigmented coatings 

will not impact emissions. The other proposed change to update the test method will likewise 

not impact emissions but make the rule more enforceable. 
Final Staff Report 

Proposed Amended Rule 1113 3 July 13, 2007 

The updated test method is currently in use nation-wide as the standard and therefore, no 

additional costs are expected from its use. 

Since this is not an Air Quality Management Plan (AQMP) control measure and there is no 

change in emissions or costs from the proposed amendments, there is no requirement to 

conduct a Socioeconomic Impact Assessment. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) 

The proposed amendments to Rule 1113 - Architectural Coatings has been reviewed pursuant 

to CEQA and an appropriate CEQA document has been prepared and will be considered for 

certification concurrently with the consideration for adoption of PAR 1113. 

SOCIOECONOMIC ASSESSMENT 

The proposed amendments to Rule 1113 do not significantly affect air quality or emissions 

limitations and therefore, a socioeconomic impact analysis pursuant to Health and Safety Code 

Section 40440.8 is not required. 

LEGISLATIVE AUTHORITY 

The California Legislature created the AQMD in 1977 (The Lewis Presley Air Quality 

Management Act, Health and Safety Code Section 40400 et seq.) as the agency responsible for 

developing and enforcing air pollution controls and regulations in the Basin. By statute, the 

AQMD is required to adopt an AQMP demonstrating compliance with all state and federal 

ambient air quality standards for the Basin [California Health and Safety Code Section 

40440(a)]. Furthermore, the AQMD must adopt rules and regulations that carry out the AQMP 

[California Health and Safety Code Section 40440(a)] 

AQMP AND LEGAL MANDATES 

The California Health and Safety Code requires the AQMD to adopt an AQMP to meet state 

and federal ambient air quality standards in the South Coast Air Basin. In addition, California 

Health and Safety Code requires the AQMD to adopt rules and regulations that carry out the 

objectives of the AQMP. Although the proposed amendments do not result in emission 

reductions, the amendments are consistent with AQMP objectives. This proposal does not 

impose a new emission limit or standard, make an existing emission limit or standard more 

stringent or impose new or more stringent monitoring, reporting or recordkeeping requirements 

and therefore, is not subject to the comparative analysis provisions of Health and Safety Code 

Section 40727.2. 

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

Health and Safety Code Section 40727 requires that prior to adopting, amending or repealing a 

rule or regulation, the AQMD Governing Board shall make findings of necessity, authority, 

clarity, consistency, non-duplication, and reference based on relevant information presented at 

the hearing. The draft findings are as follows: 

Necessity - The AQMD Governing Board has determined that a need exists to amend Rule 

1113 - Architectural Coatings to amend the definition of metallic pigmented coatings, update 
Final Staff Report 

Proposed Amended Rule 1113 4 July 13, 2007 

the test method for metallic pigmented coatings and delete outdated text in Appendix A, 

Section A of the rule. 

Authority - The AQMD Governing Board obtains its authority to adopt, amend, or repeal rules 

and regulations from Health and Safety Code Sections 39002, 40000, 40001, 40440, 40702, 

and 41508. 

Clarity - The AQMD Governing Board has determined that the proposed amendments to Rule 

1113 - Architectural Coatings, are written and displayed so that the meaning can be easily 

understood by persons directly affected by them. 

Consistency - The AQMD Governing Board has determined that PAR 1113 - Architectural 

Coatings, is in harmony with, and not in conflict with or contradictory to, existing statutes, 

court decisions, federal or state regulations. 

Non-Duplication - The AQMD Governing Board has determined that the proposed 

amendments to Rule 1113 - Architectural Coatings do not impose the same requirement as any 

existing state or federal regulation, and the proposed amendments are necessary and proper to 

execute the powers and duties granted to, and imposed upon, the AQMD. 

Reference - In adopting these amendments, the AQMD Governing Board references the 

following statutes which the AQMD hereby implements, interprets or makes specific: Health 

and Safety Code Sections 40001 (rules to achieve ambient air quality standards), 40440(a) 

(rules to carry out the Air Quality Management Plan), and 40440(c) (cost-effectiveness), 40725 

through 40728 and Federal Clean Air Act Sections 171 et sq., 181 et seq., and 116. 

CONCLUSION AND RECOMMENDATION 

Staff recommends amendments to the definition of metallic pigmented coatings to be 

consistent with the federal definition, updating the test method to determine the weight of 

elemental metals in metallic pigmented coatings and deleting outdated language in Appendix 

A, Section A of Rule 1113. 

REFERENCES 

40 CFR Part 59, Subpart D – National Volatile Organic Compound Emission Standards for 

Architectural Coatings, September 11, 1998. 

COMMENTS AND RESPONSES 

During the rule making process, both oral and written questions, comments, and suggestions 

were received and reviewed by staff and are summarized in this section. After the review, staff 

revised the proposed amendments to reflect many of the comments and suggestions. If 

comments regarding the same topic were received from different individuals, staff summarized 

the topic into one comment and response. 

U.S EPA sent a rule review comment letter on the Proposed Amended Rule 1113, work 

shopped on April 19, 2007, and strongly support the removal of mica from the Rule 1113 

definition of metallic pigmented coatings so the definition will be as stringent as the metallic 

pigmented coating definition in the National AIM Rule in 40 CFR Part 59 Subpart D. 
Final Staff Report 

Proposed Amended Rule 1113 5 July 13, 2007 

Comment: Dry-fog coatings should be added to those categories allowed to be averaged in 

the Averaging Compliance Option of Rule 1113. The solvent-based dry-fog coatings do not 

require as much preparation prior to painting as the water-based dry-fog coatings, which do not 

adhere to dirty substrates found in areas such as industrial buildings. 

Response: Dry-fog (dry-fall) coatings are defined as coatings applied by spray 

application only so that the overspray droplets dry before falling on floors and other 

surfaces. After staff contacted and met with manufacturers of dry-fog coatings during 

amendments to Rule 1113 in 2006, the main issues discussed were potential slower dry 

times associated with low-VOC coatings especially during high humidity conditions 

and adherence of the coating to dirty surfaces. It was generally agreed that low-VOC 

dry-fog coatings might require more substrate preparation than a solventborne coating. 

However, waterborne acrylic dry-fog coatings are an environmentally acceptable 

alternative to traditional solvent-based ceiling coatings. They emit a very low odor 

during application, and have a low flash point. Waterborne acrylic dry-fog coatings 

are especially well suited for spaces with pre-cast concrete or steel beam ceilings. 

They can save time and make application easier in an occupied space. Staff’s 

technology assessment confirmed excellent market penetration and currently available 

dry-fog coatings at 150 g/l or less. The amendments resulted in lowering the VOC limit 

for dry-fog coatings from 400 g/l to 150 g/l effective July 1, 2007. At that time 

architectural coating manufacturers did not request that dry-fog coatings be added to 

the list of categories allowed to be averaged in the Averaging Compliance Option 

(ACO). 

California Air Resources Board (CARB) is proposing changes to the Architectural 

Coatings Suggested Control Measure for adoption in 2007. AQMD staff will be 

reviewing the adopted amendments along with the most recent California architectural 

coating sales and emission data provided by CARB, to further assess emission 

reductions for Rule 1113. At that time staff will also evaluate allowing additional 

coating categories to be averaged in the ACO.

Comment: CARB held a workshop on architectural coatings and they stated in that meeting 

that their Board does not want staff to encourage the exemption of carcinogens and they were 

referring to a question on Tertiary-Butyl Acetate (TBAc) that one of the industry people asked 

if it were going to be exempted in the industrial maintenance coatings. So CARB through their 

Board has decided not to consider exemptions for TBAc. I would like to request that the 

AQMD revisit the exemption of TBAc for industrial maintenance coatings. 

Response: The commentator made the same request during the 2006 amendments to 

Rule 1113 during which TBAc was exempted from the definition of volatile organic 

compounds (VOC) for use in industrial maintenance coatings (IM) only. A full review 

of comments both supporting the use of TBAc in architectural coatings and objections 

to its use along with staffs responses to comments may be read in the CEQA analysis 

and the comments and response section of the Staff Report for the June 2, 2006 Rule 

1113 amendments. 

Briefly, staff made the decision to exempt TBAc for IM coatings based on its risk 

assessment for use in IM Coatings, where applicators typically use Personal Protective 

Equipment (PPE) including respirators, and the distance to sensitive receptors is 
Final Staff Report 

Proposed Amended Rule 1113 6 July 13, 2007 

sufficient to mitigate the acute risks. The health risk analysis was prepared for AQMD 

staff using standard health risk protocol, health risk values provided by California’s 

Office of Environmental Health Hazard Assessment (OEHHA) staff and parameters 

used by CARB to estimate risk from TBAc. In the case of TBAc, there is little available 

information on the toxicity of TBAc, but there is some toxicity information available on 

one of its metabolites, tert-butyl alcohol (TBA). While there are studies that indicate 

tumors in rats and mice when exposed to high concentrations of TBA, TBA has not yet 

been classified as a human carcinogen. In analyzing TBAc’s impacts staff also 

considered CARB documents that assert TBAc’s ozone reduction benefits. Staff’s very 

conservative analysis from the use of TBAc based products only, indicates that the 

potential chronic cancer risk and acute risk is below the AQMDs significant risk 

threshold. Staff does not recommend expanding the exemption for TBAc to other 

categories because alternative compliant products that do not pose the added potential 

risk exist. By limiting the exemption for TBAc to IM coatings, the AQMD recognizes 

and limits the potential cancer risk exposure due to the use of TBAc while providing the 

coating manufacturers with flexibility in formulating products compliant with the future 

IM coatings limits in PAR 1113. Staff will continue to evaluate additional information 

relative to TBAc’s toxicity including toxicity studies conducted by the manufacturer of 

TBAc, as it becomes available and reevaluate its position as necessary. 

Comment: AQMD should consider a broader exemption of TBAc for other categories of 

architectural coatings during this amendment. 

Response: See the above response. 

Comment: The AQMD should reconsider the methodology by which you are trying to 

achieve your ends. To preclude the broad concept of industrial maintenance coatings from 

ever being a metallic pigmented coatings doesn’t make sense to me. Aluminum metallic 

pigmented coatings are both decorative and functional as a protective coating. The proposed 

definition would only allow the coating to be marketed as a decorative coating without 

functionality. The definition could say the coatings must have metallic appearance, they 

should look metallic, gold, silver, or bronze-like which would give the decorative appearance 

staff is looking for. Functionality should not be eliminated from the definition. 

Response: Staff’s primary issue with the definition of metallic pigmented coatings is to 

remove reference to mica particles in order to make the definition as stringent as the 

federal and state definition for this category. In response to several comments 

regarding the proposed changes to the definition of metallic pigmented coatings, staff 

will remove the word “decorative” recognizing that metallic pigmented coatings have 

both functionality and decorative characteristics. In addition, staff will also remove 

reference to the exclusion of “all industrial maintenance coatings” with a reminder 

that the most restrictive clause in the rule requires a coating to have the lower VOC 

limit if the coating is labeled or advertised to fall into two or more coating categories. 

Comment: Staff might want to consider whether the following sentence located in Appendix 

A, Section (A) is necessary: “Manufacturers that submitted an annual exemption report in 

2002 for quick-dry primers, sealers and undercoaters and included those coatings in their most 

recent approved ACO Program, may continue to average those coatings until July 1, 2006, so 
Final Staff Report 

Proposed Amended Rule 1113 7 July 13, 2007 

long as these coatings do not exceed 450 grams of VOC per liter of coating less water and less 

exempt compounds, in lieu of the otherwise applicable VOC limit of 350 grams per liter.” 

Response: Thank you for pointing out the obsolete language which staff is proposing 

to delete from Appendix A, Section A of Rule 1113. 

Comment: Several commentators strongly suggested that staff should not remove primers, 

sealers, undercoaters; quick-dry primers, sealers, undercoaters; and specialty primers from the 

Averaging Compliance Option. Allowing these categories to be in the averaging provision 

provides more flexibility to the manufacturers and does not affect emission reductions for the 

AQMD one way or the other. Some commentators expressed a need for the lower VOC 

primers in the averaging provision to offset emissions from high-VOC products in other 

categories. 

Response: The amendments to the ACO provision has been withdrawn from the staff 

proposal. The Stationary Source Committee Board members directed staff to propose 

an amendment to remove specialty primers from the Averaging Compliance Option at 

the request of an architectural coating manufacturer (as explained in this Staff Report) 

when it was determined the requesting manufacturer could not take advantage of the 

ACO as its competitors have been able to do. It is noted that since staff received that 

direction from the Stationary Source Committee, the manufacturer has withdrawn its 

request for the amendment. 

Comment: The proponent of the initial request to remove specialty primers from the 

Averaging Compliance Option has notified staff it wishes to withdraw that request. 

Subsequent to the last Stationary Source Committee meeting some unintended consequences 

were made apparent and therefore; the proponent has since submitted a letter to the AQMD 

requesting withdrawal of the initial request. All Board members of the Stationary Source 

Committee, the Chairman of the Governing Board and the Executive Officer have been made 

aware of the withdrawal request and discussion of this matter will be included on the next 

Stationary Source Committee Meeting agenda. 

Response: See the above comment and response. 

Comment: The averaging program provides a needed mechanism for the continued supply of 

effective architectural and industrial maintenance coatings in the face of ever more stringent 

reductions in the VOC content of the coatings mandated by Rule 1113. We oppose many of 

the VOC limits of the rule because we believe that they do not allow technologically feasible 

coatings to be manufactured with all of their necessary performance characteristics. We do not 

believe that the averaging program can fully compensate for these deficiencies in Rule 1113. 

Moreover, not all companies can avail themselves of the benefits of the program because they 

do not have a sufficiently large product mix to allow them to do so. 

Response: During litigation on the VOC limits specified in The Table of Standards for 

Rule 1113, the courts have validated staff’s technology assessments showing that lowVOC coating performance characteristics meet or exceed those of their higher-VOC 

counterpart. The current proposal does not change any VOC limits and staff does not 

recommend relaxing any VOC limits. Staff relies on a number of key sources of data 

and information for determining the availability and performance of coatings. These 

include: 
Final Staff Report 

Proposed Amended Rule 1113 8 July 13, 2007 

• CARB Surveys which provide sales, emission data, market penetration and VOC 

content of coatings actually sold in California. 

• Web-based searches where staff has found compliant and super-compliant lowVOC coatings verified by examining Technical Data Sheets and Material Safety 

Data Sheets. 

• Field Visits to New Construction Sites where staff visited more than 100 new 

construction sites in 2004 and 2005 in order to determine what products the 

contractors are using and whether they are working. Overall, most of the 

construction sites visited had applied architectural coatings that are much lower 

than the current specified limits in many different categories and had used many 

super-compliant products that meet the future limits in Rule 1113. Even with the 

super-compliant products, all of the contractors indicated that they were satisfied 

with their performance. 

• Performance studies by various public service agencies which have completed 

testing of low-VOC industrial maintenance coatings (some with the exempt solvent 

TBAc) in recent years and have found compliant products with acceptable 

performance. 

• Meetings with local manufacturers (large and small) to inquire about their 

successes and failures in preparing for the low-VOC limits. These manufacturers 

indicated that compliant products are available and that they exhibit acceptable 

performance for their markets. 

• A point of distribution survey of local store inventories. The primary purpose of the 

surveys was to obtain a snapshot of the currently available architectural products 

being sold from store shelves. This limited survey indicated that products meeting 

the 2006 VOC limits were available and being sold to consumers. 

• A review of select technical papers and articles on advancements in the coatings 

industry. Manufacturers of coatings rely heavily on the research and development 

efforts of the raw materials suppliers. Successful reformulation by individual 

coating companies requires different resins and additives. The 2005 Annual Status 

Report on architectural coatings provides excerpts from these articles that 

overwhelmingly indicate that there are ongoing technological achievements to 

support compliant product formulation. Papers presented at the recent Western 

Coatings Society Symposium and Show indicate the availability and support from 

resin and additive suppliers of low-VOC components that meet and exceed the 

future VOC limits in Rule 1113 and expected performance characteristics as 

compared to traditional higher VOC containing materials. 

• AQMD contracted performance studies with industry experts to conduct laboratory 

studies to assess the performance characteristics of low-VOC products. A review of 

these studies supports staff conclusions that overall super-compliant coatings meet 

or exceed expected characteristic performance standards when compared to 

products that have much higher VOC content. 

• Studies of alternate means of compliance provided by the rule by examining the 

number of manufacturers who have taken advantage of the Averaging Compliance 

Option and sell-through provisions as well as the small container exemption. 
ATTACHMENT A 

Letter to coating manufacturers, distributors and associations regarding metallic pigmented 

coatings