SDAPCD Regulation IV -1- Rule 67.11.1 

9/25/02 

RULE 67.11.1 LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(Adopted & Effective 9/25/02) 

(a) APPLICABILITY

(1) Except as otherwise provided in Section (b), this rule is applicable to a 

stationary source where the combined uncontrolled emissions of VOCs from all wood 

product coating operations, including emissions from equipment cleaning, are greater 

than or equal to 25 tons in a calendar year. 

(2) Any coating operation subject to the requirements of Rules 67.0 or 67.18 

shall not be subject to this rule. 

(3) Rule 66 shall not apply to any coating operation which is subject to this 

rule. 

(b) EXEMPTIONS 

 (1) The provisions of Sections (d), (e), and (f) shall not apply to coatings 

applied using non-refillable handheld aerosol spray containers. 

 (2) The provisions of Subsection (d)(1) shall not apply to the following: 

 (i) Any coatings when applied by the use of air brushes with a coating 

capacity of two ounces (59.1 ml) of less. 

(ii) Any coatings when applied during touch-up operations. 

(3) The provisions of Subsection (d)(2) shall not apply to coatings applied to 

wooden musical instruments. 

(c) DEFINITIONS 

For the purposes of this rule, the following definitions shall apply: 

(1) "Adhesive" means a material applied to a wood surface for the sole 

purpose of bonding the wood surface with another wood or non-wood surface by 

attachment. 

(2) "Binder" means a non-volatile polymeric organic material, such as a resin, 

which forms the surface film during coating applications. 

(3) "Clear Sealer" means a coating which contains binders, but not opaque 

pigments, and is specifically formulated to seal wood surfaces prior to the application 

of subsequent coatings. 

(4) "Clear Topcoat" means a final coating which contains binders, but not 

opaque pigments, and is specifically formulated to form a transparent or translucent 
Regulation IV -2- Rule 67.11.1

solid protective film. Clear topcoats include clear lacquers and varnishes, but exclude 

conversion varnishes. 

(5) "Coating" means a material containing more than 20 grams per liter of 

VOC as applied, less water and exempt compounds, which can be applied as a thin 

layer to a substrate, and which either dries or cures to form a continuous solid film or 

impregnates a substrate for protection, decorative, or functional purposes. Such 

materials include, but are not limited to paints, varnishes, sealers, lacquers, inks, 

fillers, washcoats, toners and stains but exclude any adhesives. 

(6) "Coating Operation" means all steps involved in the application, drying 

and/or curing of surface coatings, including touch-up operations, and associated 

stripping, surface preparation and coating application equipment cleaning. 

(7) "Conversion Varnish" means a topcoat which is comprised of a 

homogeneous liquid (alkyd-amino resin), which when acid catalyzed and applied, 

hardens by evaporation and polymerization. 

(8) "Dip Coat" means a coating application method accomplished by dipping 

an object into the coating material. 

(9) "Electrostatic Spray" means a coating application method accomplished 

by charging atomized paint particles for deposition by electrostatic attraction. 

(10) "Exempt Compound" means the same as defined in Rule 2. 

(11) "Filler" means a material used to fill in cracks, grains and imperfections of 

wood before applying a coating. 

(12) "Flow Coat" means a coating application method accomplished by 

flowing a stream of coating over an object. 

(13) "Glaze Stain" means a semi-transparent tinted coating applied on a 

previously coated surface to produce a decorative effect. 

(14) "Hand-Application Method" means a coating application method 

accomplished by applying a coating by manually held, non-mechanically operated 

equipment. Such equipment includes paintbrushes, hand rollers, rags, and sponges. 

(15) "High-Solid Stain" means a stain containing more than one pound of 

solids per gallon of material. 

(16) "High-Volume Low-Pressure (HVLP) Spray" means a coating 

application method which uses pressurized air at a permanent pressure between 0.1 

and 10.0 psig, not to exceed 10.0 psig, measured at the air cap of the coating 

application system. 

(17) "Ink" means a liquid that contains dyes and/or colorants and is used to 

make markings, but not to protect surfaces. 
Regulation IV -3- Rule 67.11.1

(18) "Low-Solids Coating " means a coating containing one pound of solids or 

less per gallon of material, as supplied. 

 (19) "Low-Solids Stain" means a stain containing one pound of solids or less 

per gallon. 

 (20) "Medium Density Fiberboard (MDF) Coating" means the initial coating 

which is applied directly to the surface of MDF, which is a wood product composed of 

tightly compressed wood fibers bonded with resins, and has a density greater than 45 

pounds per cubic foot. 

(21) "Multi-Colored Coating" means a coating which exhibits more than one 

color when applied and which is packaged in a single container and applied in a single 

coat. 

(22) "Pigmented Primer, Sealer, and Undercoat" means opaque coatings 

which contain binders and colored pigments formulated to hide the wood surface, that 

are applied prior to the topcoat to provide a firm bond, level the wood product surface, 

or seal the wood product surface. 

(23) "Pigmented Topcoat" means a final opaque coating which contains 

binders and colored pigments, and is specifically formulated to hide the wood surface 

and form a solid protective film. 

(24) "Roll Coat" means a coating application method accomplished by rolling a 

coating onto a flat surface using a roll applicator. 

(25) "Stationary Source" means the same as defined in Rule 2. 

(26) "Stripper" means a liquid applied to remove a coating or coating residue. 

(27) "Toner" means a coating which contains not more than one pound of 

binders and dyes or pigments per gallon of coating and which is used to add tint to a 

coated surface. 

(28) "Touch-up Operation" means the portion of a coating operation which is 

incidental to the main coating process but necessary to cover minor imperfections or 

minor mechanical damage incurred prior to intended use, or to achieve coverage as 

required. 

(29) "Transfer Efficiency" means the ratio of the weight of coating solids 

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

process expressed as a percentage. 

(30) “Uncontrolled VOC Emissions” means VOC emissions from a wood 

products coating operation, which occurred or would have occurred in the absence of 

any air pollution control equipment added or process modification made on or after 

September 25, 2002. 
Regulation IV -4- Rule 67.11.1

(31) "Volatile Organic Compound (VOC)" means the same as defined in Rule 2. 

(32) "VOC Content Per Pound of Coating Solids" means the weight of VOC 

per weight of coating solids in any given coating volume of coating and can be 

calculated by the following equation: 

Cs = Ws – Ww –Wes

Wr 

where: 

Cs = VOC content per pound of coating solids 

Ws = Weight of volatile compounds, in pounds 

Ww = Weight of water, in pounds 

Wes = Weight of exempt compounds, in pounds 

Wr = Weight of coating solids, in pounds 

(33) "VOC Content Per Volume of Coating, Less Water and Exempt 

Compounds" means the same as defined in Rule 2. 

(34) "VOC Content Per Volume of Material" means the same as defined in 

Rule 2. 

(35) "Washcoat" means a coating containing not more than one pound of solids 

per gallon, which is used to seal wood surfaces, prevent undesired staining and control 

penetration. A washcoat may also be used to provide a barrier coat when paper 

laminates are applied to the wood surface, or when glazes are applied during the 

coating operation. 

(36) "Wood Products" means any objects that are made of or primarily 

fabricated with solid wood, wood composition, bamboo and/or rattan, including 

furnishings, art objects, tables, chairs, beds, sofas, and shutters and cabinets which are 

not permanently attached to stationary structures at the time of coating. 

(d) STANDARDS 

(1) Application Methods 

Except as provided in Subsection (b)(2), a person shall not apply coatings unless 

one of the following application methods is used: 

 (i) Hand-application method, or 

 (ii) Dip coat, or 

(iii) Roll coat, or 

(iv) Flow coat, or 

 (v) Electrostatic coat, or 

(vi) High-volume low-pressure (HVLP) coat, or 
Regulation IV -5- Rule 67.11.1

 (vii) Other coating application methods that are demonstrated to have a 

transfer efficiency at least equal to one of the above application methods, and 

which are operated in such a manner that the parameters under which they were 

tested are permanent features of the method. Such coating application methods 

shall be approved in writing by the Air Pollution Control Officer prior to use. 

 (2) VOC Limits 

(i) Except as provided in Section (b), a person shall not apply any 

coating to a new wood product with a VOC content in excess of the following 

limits, expressed as either grams of VOC per liter of coating (g/L), or pounds of 

VOC per gallon of material (lb/gal), as applied, less water and exempt 

compounds, or pounds of VOC per pound of solids (lb/lb), as applied: 

CATEGORY VOC LIMITS

 g/L lb/gal lb/lb

Clear Sealers 550 4.6 1.39 

Clear Topcoats 550 4.6 1.37 

Conversion Varnishes 550 4.6 1.37 

Fillers 500 4.2 0.66 

High-Solid Stains 550 4.6 1.23 

Inks 500 4.2 0.96 

Medium Density Fiberboard (MDF) Coatings 635 5.3 1.90 

Multi-Colored Coatings 685 5.7 2.60 

Pigmented Primers, Sealers & Undercoats 550 4.6 1.06 

Pigmented Topcoats 550 4.6 1.10 

Any Other Coatings 420 3.5 0.51 

 A person may add up to 10% by volume of VOC to a topcoat, primer, sealer or 

undercoat that contains acetone, if at the time of application the relative humidity is 

greater than 70% and the temperature is below 65o F, provided that 

(A) The coating is not applied during a period from April 1 to October 

31 of any year; and 

(B) Prior to the addition of VOC, the coating does not contain more than 

550 grams of VOC per liter of coating, less water and exempt compounds. 

(ii) Except as provided in Section (b), a person shall not apply the following 

coatings to a new wood product with a VOC content in excess of the following 

limits expressed either as grams of VOC per liter of material or pounds of VOC 

per gallon of material, as applied: 

CATEGORY VOC LIMITS

 g/L lb/gal

Low-Solids Stains, Toners, and Washcoats 480 4.0 

Any Other Low-Solids Coatings 480 4.0 

The requirements of Subsection (d)(2) may be met using an Alternative Emission 

Control Plan (AECP) that has been approved pursuant to Rule 67.1. 
Regulation IV -6- Rule 67.11.1

(3) Surface Preparation Materials 

A person shall not use VOC containing materials for surface preparation, 

including stripping, unless: 

(i) The material contains 200 grams or less of VOC per liter of material; or 

 (ii) The material has an initial boiling point of 190°C (374°F) or greater; or 

(iii) The total VOC vapor pressure of the material is 20 mm Hg or less at 

20°C (68oF). 

(4) Cleaning of Coating Application Equipment 

A person shall not use VOC containing materials for the cleaning of application 

equipment used in operations subject to this rule unless: 

(i) The cleaning material contains 200 grams or less of VOC per liter of 

material; or 

 (ii) The cleaning material has an initial boiling point of 190°C (374°F) or 

greater; or 

(iii) The cleaning material has a total VOC vapor pressure of 20 mm Hg or 

less at 20°C (68°F); or 

(iv) The cleaning material is flushed or rinsed through the application equipment in a contained manner that will minimize evaporation into the atmosphere; or 

 (v) The application equipment or equipment parts are cleaned in a container 

which is open only when being accessed for adding, cleaning, or removing 

application equipment or when cleaning material is being added, provided the 

cleaned equipment or equipment parts are drained to the container until dripping 

ceases; or 

(vi) A system is used that totally encloses the component parts being 

cleaned during the washing, rinsing, and draining processes; or 

(vii) Other application equipment cleaning methods that are demonstrated to 

be as effective as any of the equipment described above in minimizing the 

emissions of VOC to the atmosphere, provided that the device has been tested 

and approved in writing prior to use by the Air Pollution Control Officer. 

 (5) No person shall require for use or specify the application of a coating 

subject to this rule if such use or application results in a violation of this rule. This 

prohibition shall apply to all written or oral contracts under the terms of which any 

coating is applied to any wood product at any location within San Diego County. 
Regulation IV -7- Rule 67.11.1

(6) Spray application equipment shall not be used to dispose of waste coatings 

or solvents into the air. 

(e) CONTROL EQUIPMENT 

(1) In lieu of complying with the provisions of Subsections (d)(2), (d)(3), 

and/or (d)(4) of this rule, a person may use an air pollution control system which: 

 (i) Has been installed in accordance with an Authority to Construct; and 

 (ii) Includes an emission collection system which captures organic gaseous 

emissions, including emissions associated with applicable coating operations, 

and/or equipment cleaning and surface preparation operations, and transports the 

captured emissions to an air pollution control device; and 

 (iii) Has a combined emissions capture and control device efficiency of at 

least 85% by weight or an alternate emission control efficiency equivalent to or 

greater than the level of control achieved by complying with the applicable VOC 

limits specified in Subsections (d)(2), (d)(3), and (d)(4). The alternate emission 

control efficiency shall be calculated according to a procedure approved in 

advance by the Air Pollution Control Officer and U.S. Environmental Protection 

Agency (EPA); and 

 (iv) Has a continuous monitoring system installed, operated, calibrated and 

maintained, as approved by the Air Pollution Control Officer. The continuous 

monitoring system shall monitor and record all key system operating parameters 

necessary to ensure compliance with Subsection (e)(1)(iii) above at least every 

15 clock minutes or a shorter period of time as determined necessary by the Air 

Pollution Control Officer. Compliance with Subsection (e)(1)(iii) may be 

determined by VOC emissions source testing and/or evaluating continuous 

monitoring data. 

(2) A person electing to use an air pollution control system pursuant to Section 

(e)(1) shall submit to the Air Pollution Control Officer for approval an Operation and 

Maintenance plan for the proposed emission control device and emission collection 

system and receive approval prior to operation of the control equipment. Thereafter, 

the plan can be modified with Air Pollution Control Officer approval, as necessary, to 

ensure compliance. Such plan shall: 

(i) Identify all key system operating parameters. Key system operating 

parameters are those necessary to ensure compliance with Subsection (e)(1)(iii) 

such as temperature, pressure, and/or flow rate; and 

(ii) Include proposed inspection schedules, anticipated ongoing 

maintenance, and proposed recordkeeping practices regarding the key system 

operating parameters. 
Regulation IV -8- Rule 67.11.1

(3) Upon approval of the Air Pollution Control Officer, a person subject to the 

requirements of Section (e) shall implement the Operation and Maintenance plan and 

shall comply with the provisions of the approved plan thereafter. 

(f) RECORDKEEPING 

All records required by this rule shall be retained onsite for at least five years and be 

made available to the District upon request. 

(1) Any person subject to the provisions of Subsection (d)(2), (d)(3), 

and/or (d)(4) of this rule shall maintain records in accordance with the following: 

(i) Maintain a current list of coatings, strippers, surface preparation and 

cleaning materials in use which provides all of the VOC data necessary to 

evaluate compliance, including but not limited to: 

(A) The manufacturer name and identification for each coating or 

coating component for multi-component coatings (this includes any 

components such as bases, catalysts, thinners or reducers, when supplied in 

separate containers), stripper, surface preparation, and cleaning material; and 

(B) Mix ratio of components; and 

(C) VOC content expressed in either grams per liter, as applied, less 

water and exempt compounds, pounds per gallon, as applied, less water and 

exempt compounds, or pounds per pound of solids; vapor pressure; and/or 

initial boiling point, as applicable, for each coating, or coating component for 

multi-component coatings, stripper, surface preparation and cleaning 

material; and 

(D) For each coating or coating component that contains VOCs and 

water or exempt compounds and that is used in a mixture with other VOC 

containing materials, or is a low-solids stain, toner, washcoat, or other lowsolids coating, the weight of VOC per volume of material expressed in either 

grams per liter or pounds per gallon, volume percent water and exempt 

compounds; and 

(E) Other information that the Air Pollution Control Officer finds is 

necessary to determine compliance with the VOC content standards of 

Subsections (d)(2), (d)(3) or (d)(4) of this rule. 

(ii) Maintain current documentation to demonstrate applicability of any 

coating category pursuant to Subsection (d)(2) of this rule. 

(iii) At a minimum, maintain monthly records of the amount of each coating 

or each coating component for multi-component coatings used. 

(iv) At a minimum, maintain monthly records of the amount of each 

stripper, surface preparation and cleaning material used. 
Regulation IV -9- Rule 67.11.1

(v) Maintain records of the dates and amounts of material added to coating 

dip tanks. 

(2) For each material that is not in compliance with Subsections (d)(2), (d)(3), 

and (d)(4) maintain daily usage records for all coatings, thinners, and other VOC 

containing materials. 

(3) Any person using control equipment pursuant to Section (e) of this rule 

shall: 

 (i) Maintain records in accordance with Subsection (f)(1); and 

 (ii) For all coatings, strippers, surface preparation and/or cleaning materials 

not in compliance with Subsection (d)(2), (d)(3), or (d)(4) of this rule, maintain 

daily records of the amount of each coating or each coating component for multicomponent coatings, stripper, surface preparation and cleaning material used; and 

 (iii) Maintain records of all monitoring pursuant to Subsection (e)(1)(iv) and 

all other data necessary to demonstrate compliance with control requirements as 

determined by the Air Pollution Control Officer. 

(g) TEST METHODS 

(1) Perfluorocarbon (PFC) compounds shall be assumed to be absent from a 

coating, cleaning, or surface preparation material subject to this rule unless a 

manufacturer of the material or facility operator identifies the specific individual 

compound(s) and the amount(s) present in the material and provides an EPA and Air 

Resources Board approved test method which can be used to quantify the specific 

compounds. 

(2) Measurements of transfer efficiency subject to Subsection (d)(1)(vii) of this 

rule shall be conducted in accordance with the South Coast Air Quality Management 

District's "Spray Equipment Transfer Efficiency Test Procedure for Equipment User," 

as it exists on September 25, 2002. 

(3) Measurement of the VOC content of coatings, surface preparation and 

cleaning materials subject to Subsections (d)(2), (d)(3)(i), or (d)(4)(i) of this rule shall 

be conducted in accordance with EPA Test Method 24 (40 CFR 60, Appendix A). 

(4) Measurement of the VOC content of ultraviolet radiation-cured coatings 

subject to Subsection (d)(2) of this rule shall be conducted in accordance with ASTM 

Standard Test Method D5403-93 (1998), or its most current version. Measurement of 

the water content and exempt solvent content, if applicable, shall be conducted and 

reported in accordance with ASTM Standard Test Methods D3792-99, D4017-02 and 

D4457-02, or their most current versions. 
Regulation IV -10- Rule 67.11.1

(5) Measurement of the initial boiling point of cleaning and surface preparation 

materials subject to Subsections (d)(3)(ii) or (d)(4)(ii) of this rule shall be conducted in 

accordance with ASTM Standard Test Method D1078-01, or its most current version, 

for distillation range of volatile organic liquids. 

(6) Calculation of total VOC vapor pressure for materials subject to 

Subsections (d)(3)(iii) or (d)(4)(iii) of this rule shall be conducted in accordance with 

the District's "Procedures for Estimating the Vapor Pressure of VOC Mixtures." If the 

vapor pressure of the liquid mixture, as calculated by this procedure, exceeds the limits 

specified in Subsections (d)(3)(iii), or (d)(4)(iii)) the vapor pressure shall be 

determined in accordance with ASTM Standard Test Method D2879-97, or its most 

current version. The solvent composition shall be determined using ASTM Standard 

Practice E168-99, E169-99, or E260-96 (2001), or their most current versions. The 

fraction of water and exempt compounds in the liquid phase shall be determined by 

using ASTM Standard Test Methods D3792-99, or D4017-02 and D4457-02, or their 

most current versions, and shall be used to calculate the partial pressure of water and 

exempt compounds. The results of vapor pressure measurements obtained using 

ASTM Test Method D2879-97, or its most current version shall be corrected for 

partial pressure of water and exempt compounds. 

(7) Measurement of solvent losses from alternate application cleaning 

equipment subject to Subsection (d)(4)(vii) shall be conducted and reported in 

accordance with the South Coast Air Quality Management District's "General Test 

Method for Determining Solvent Losses from Spray Gun Cleaning Systems," as it 

exists on September 25, 2002. 

(8) Measurement of the emission collection system capture efficiency subject 

to Subsection (e)(1)(iii) of this rule shall be determined according to EPA Method 204 

and Method 204A-F "Capture Efficiency" (40 CFR 51, Appendix M) and EPA’s 

"Guidelines for Determining Capture Efficiency " dated January 9, 1995, using a 

protocol approved in writing by the Air Pollution Control Officer. Subsequent to the 

initial compliance demonstration period, applicable key system operating parameters, 

as approved by the Air Pollution Control Officer, may be used as verification that 

capture efficiency has not diminished. 

(9) Measurements of control device efficiency subject to Subsection (e)(1) of 

this rule shall be conducted in accordance with EPA Methods 25A and/or 18 (40 CFR 

60, Appendix A) and in accordance with a protocol approved in writing by the Air 

Pollution Control Officer. 

(10) Determination of the solids content of coatings shall be conducted in accordance 

with EPA Test Method 24 (40 CFR 60, Appendix A).