UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Antelope Valley Air Quality Management 

Rule 1174 Control of Volatile Organic Compound Emissions 

from the Ignition of Barbecue Charcoal

Prepared by: Stanley Tong

August 2013
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RULE IDENTIFICATION -

Agency: Antelope Valley Air Quality Management District (AVAQMD)

SIP Approved Rule: Rule 1174 – Control of Volatile Organic Compound 

Emissions from the Ignition of Barbecue Charcoal

Adopted – October 5, 1990

Submitted – May 13, 1991

EPA Approved – October 4, 1994 (59 FR 50498)

Subject of this TSD: Rule 1174 – Control of Volatile Organic Compound 

Emissions from the Ignition of Barbecue Charcoal

Rescinded – November 20, 2012

Submitted – April 22, 2013

BACKGROUND – On July 1, 1997 the Antelope Valley Air Pollution Control District 

(AVAPCD) was formed and assumed all air pollution control responsibilities from the 

South Coast Air Quality Management District (SCAQMD) for the areas of Los Angeles 

County outside the South Coast Air Basin.1 All SCAQMD rules in effect at the time, 

including Rule 1174, remained in effect under the newly formed AVAPCD. On January 

1, 2002, the Antelope Valley Air Quality Management District (AVAQMD) replaced the 

AVAPCD. 

On October 5, 1990, the SCAQMD adopted Rule 1174, Control of Volatile Organic 

Compound Emissions from the Ignition of Barbecue Charcoal. The rule applies to 

manufacturers, distributors, and/or retailers of charcoal lighter materials. On October 4, 

1994 (59 FR 50498) we approved SCAQMD Rule 1174 into the state implementation 

plan (SIP). When Antelope Valley was formed in 1997, the requirements in SCAQMD 

Rule 1174 became a part of Antelope Valley's SIP until such time the Antelope Valley 

amended or rescinded the rule and those amendments were approved into the SIP. 

Neither South Coast nor Antelope Valley AQMDs have amended Rule 1174 since it 

was adopted.

Shortly after SCAQMD adopted Rule 1174, the California Air Resources Board (CARB) 

adopted nearly identical VOC standards for charcoal lighter materials that would be 

applicable in all areas of California except in the SCAQMD. CARB's rule applied to any 

person who sold, supplied, offered for sale, or manufactured consumer products for use 

in the state of California.

In 1998 EPA promulgated a national consumer products rule which included nearly 

identical requirements as Antelope Valley Rule 1174 and CARB's regulations for 

 

1 Antelope Valley Air Quality Management District, Final Staff Report, Rescission of Rule 1174 – Control of 

Volatile Organic Compound Emissions from the Ignition of Barbecue Charcoal, Adopted on November 20, 

2012, page 1.
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charcoal lighter materials. The rule applied to manufacturers, importers and distributers. 

(See 40 CFR 59 subpart C)

RULE SUMMARY – Rule 1174 prohibits any person from supplying, selling, or offering 

for sale, any material and/or method used to ignite barbecue charcoal unless the VOC 

emissions are less than or equal to 0.02 pounds of VOC per start.

PURPOSE OF RULE RESCISSION – Antelope Valley is rescinding Rule 1174 because 

CARB and EPA have adopted similar regulations covering VOC standards for charcoal 

lighter materials. AVAQMD's staff report states Rule 1174 can be rescinded as it is 

duplicative of state and federal regulations and places a redundant regulation on this 

source.

EPA EVALUATION – There will be no effect on air pollution from rescinding Rule 1174 

since sources would still be subject to both CARB's SIP approved consumer products 

rule and EPA's national rule. CARB's and EPA's rules contain additional provisions 

beyond those found in AVAQMD Rule 1174, including initial notifications and product 

labelling requirements. While CARB's and EPA's Consumer Products rules contain an 

exemption which allows low vapor pressure (LVP) compounds to be excluded from a 

consumer product's VOC limit, the two rules clarify that this LVP exemption does not 

apply to the charcoal lighter material category.

2

EPA ACTION - EPA staff recommends approval of the rescission of AVAQMD Rule 

1174 pursuant to CAA §110(k)(3) and §301(a).

REFERENCES -

1. AVAQMD Rule 1174, Control of Volatile Organic Compound Emissions from the 

Ignition of Barbecue Charcoal, adopted October 5, 1990, submitted on May 13, 

1991.

2. 40 CFR 59 Subpart C—National Volatile Organic Compound Emission 

Standards for Consumer Products (7/1/2012 edition)

3. California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 8.5, 

Article 2. Consumer Products (Hearing September 24, 2009, amended August 6, 

2010, SIP approved February 13, 2012 77 FR 7535.

 

2 CARB's Consumer Products Rule – Section 94509(h)(2)(A) states "The provisions relating to 

LVP-VOC in sections 94508(a) [Definitions] and 94510(d) [LVP exemption] shall not apply to any 

charcoal lighter material subject to the requirements of sections 94509(a) [Table of Standards 

Percent Volatile Organic Compound by Weight] and (h) [Requirements for charcoal lighter 

materials].

For EPA's national Consumer Products Rule, 40 CFR 59. 203(f) states the VOC content limits in 

table 1 of the Consumer Products rule shall not include any VOC that has a vapor pressure less 

than 0.1 millimeters of mercury at 20 degrees Celsius. The VOC limit for charcoal lighter material 

is not part of table 1 of the national rule, but is found in 40 CFR 59.208(e)(2).