SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

FINAL STAFF REPORT

Proposed Amended Rule 1151 - Motor Vehicle And Mobile Equipment Non-Assembly 

Line Coating Operations

September 2014

Deputy Executive Officer,

Planning, Rule Development, and Area Sources

Elaine Chang, Dr.PH

Assistant Deputy Executive Officer,

Planning, Rule Development, and Area Sources

Philip M. Fine, Ph.D.

Planning and Rules Manager,

Planning, Rule Development, and Area Sources

Naveen Berry

AUTHOR: Don Hopps AQ Specialist

REVIEWED BY: David Ono Program Supervisor

Karin Manwaring Senior Deputy District Counsel

CONTRIBUTORS: Barbara Radlein AQ Specialist/CEQA

Shah Dabirian AQ Specialist/Socioeconomics
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

CHAIRMAN: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee

VICE CHAIRMAN: DENNIS YATES

Mayor, Chino

Cities of San Bernardino

MEMBERS:

MICHAEL D. ANTONOVICH 

Supervisor, Fifth District

County of Los Angeles

BEN BENOIT

Mayor Pro Tem, Wildomar

Cities of Riverside County

JOHN J. BENOIT

Supervisor, Fourth District

County of Riverside

JOE BUSCAINO

Councilmember, Fifteenth District

City of Los Angeles 

MICHAEL A. CACCIOTTI

Councilmember, South Pasadena

Cities of Los Angeles County/Eastern Region

JOSIE GONZALES

Supervisor, Fifth District

County of San Bernardino

JOSEPH K. LYOU, PH. D.

Governor’s Appointee

JUDITH MITCHELL

Mayor, Rolling Hills Estates

Cities of Los Angeles County/Western Region

SHAWN NELSON

Supervisor, Fourth District

County of Orange

DR. CLARK E. PARKER, SR.

Senate Rules Appointee

MIGUEL A. PULIDO

Mayor, Santa Ana

Cities of Orange County

EXECUTIVE OFFICER: BARRY R. WALLERSTEIN, D. ENV.
TABLE OF CONTENTS

EXECUTIVE SUMMARY

EXECUTIVESUMMARY ..................................................................................................................................................... ES-1

CHAPTER 1 – BACKGROUND ON PROPOSED AMENDED RULE 1151

INTRODUCTION ....................................................................................................................................................................... 1-1

REGULATORYHISTORY....................................................................................................................................................... 1-1

AFFECTEDFACILITIES .......................................................................................................................................................... 1-1

PROCESSDESCRIPTION ........................................................................................................................................................ 1-2

SPRAYGUNTECHNOLOGYANDTRANSFEREFFICIENCY .................................................................................... 1-3

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1151

OVERVIEW:PROPOSEDAMENDMENTSTORULE1151 ........................................................................................... 2-1

REMOVEOBSOLETERULELANGUAGE ........................................................................................................................ 2-1

SUBDIVISION(A)PURPOSE.................................................................................................................................................. 2-1

SUBDIVISION(B)APPLICABILITY .................................................................................................................................... 2-2

SUBDIVISION(C)DEFINITIONS .......................................................................................................................................... 2-2

SUBDIVISION(D)REQUIREMENTS................................................................................................................................... 2-7

SUBDIVISION(E)PROHIBITIONOFSALES,SPECIFICATIONANDSALE ......................................................... 2-10

SUBDIVISION(F)RECORDKEEPINGREQUIREMENTS ........................................................................................... 2-13

SUBDIVISION(G)ADMINISTRATIVEREQUIREMENTS.......................................................................................... 2-14

SUBDIVISION(H)TESTMETHODS .................................................................................................................................. 2-15

SUBDIVISION(I)RULE442APPLICABILITY ................................................................................................................ 2-17

SUBDIVISION(J)EXEMPTIONS ........................................................................................................................................ 2-17

CHAPTER 3: IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1151

EMISSION IMPACT ASSESSMENT ................................................................................................................................................. 3-1

COST ANALYSIS ............................................................................................................................................................................ 3-1

INCREMENTAL COST-EFFECTIVENESS ....................................................................................................................................... 3-1

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ........................................................................................................ 3-1

SOCIOECONOMIC IMPACT ASSESSMENT .................................................................................................................................... 3-2

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 40727 ........................................................................ 3-2

COMPARATIVE ANALYSIS ........................................................................................................................................................... 3-2

DRAFT CONCLUSIONS AND RECOMMENDATIONS ................................................................................................................... 3-3

PUBLIC COMMENTS AND RESPONSES ........................................................................................................................................ 3-3

REFERENCES ........................................................................................................................... R-1

LIST OF TABLES

TABLE 1-PERMIT FACILITIES AND PERCENTAGE DISTRIBUTION ......................................................................................... 1-2

TABLE 2–TABLE OF STANDARDS .............................................................................................................................................. 2-7

i
RULE 1151 – MOTOR VEHICLE AND MOBILE EQUIPMENT NON-ASSEMBLY LINE 

COATING OPERATIONS

EXECUTIVE SUMMARY
Executive Summary Final Staff Report

EXECUTIVE SUMMARY

Rule 1151 - Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations - is a 

source specific rule that was adopted to reduce Volatile Organic Compound (VOC) emissions, 

toxic air contaminants, stratospheric ozone-depleting compounds, and global-warming 

compound emissions from automotive coating operations performed on motor vehicles, mobile 

equipment and associated parts or components for motor vehicles and mobile equipment.

The prior amendment to the rule was on December 2, 2005, which effectively split Rule 1151 

into two parts with two subsequent effective dates for compliance. The first part of Rule 1151, 

the original rule, became effective on December 2, 2005, and remained in effect through June 30, 

2008. The second part of Rule 1151, identified as Appendix A to the rule, became effective on 

July 1, 2008, superseding and making obsolete the first part of the rule. The two part structure of 

Rule 1151 currently contains 18 pages of obsolete language immediately followed by 16 pages 

of currently effective rule language, Appendix A. This structure continues to cause confusion to 

the regulated community.

The proposed amendment seeks to make administrative changes to the rule to enhance the 

understanding of current applicable rule requirements by removing obsolete rule language and 

making minor revisions and editorial corrections. The proposed amendment also adds new 

definitions to promote clarity and consistency, and further aligns the transfer efficiency 

equivalency section with the state Suggested Control Measure (SCM). This staff proposal is 

administrative in nature and will not affect the current VOC limits or existing work practices. It 

is not expected to yield additional VOC reductions or increases. No socioeconomic impacts are 

anticipated from this proposal.

Proposed Amended Rule 1151 ES-1 September 2014
RULE 1151 – MOTOR VEHICLE AND MOBILE EQUIPMENT NON-ASSEMBLY LINE 

COATING OPERATIONS

CHAPTER 1: BACKGROUND ON PROPOSED AMENDED RULE 1151

ο INTRODUCTION

ο REGULATORY HISTORY

ο AFFECTED FACILITIES

ο PROCESS DESCRIPTION

ο SPRAY GUN TECHNOLOGY AND TRANSFER EFFICIENCY 

REQUIREMENTS
Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

INTRODUCTION

Rule 1151 - Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations - is a 

source specific rule that was adopted to reduce Volatile Organic Compound (VOC) emissions, 

toxic air contaminants, stratospheric ozone-depleting compounds, and global-warming

compound emissions from automotive coating operations performed on motor vehicles, mobile 

equipment and associated parts or components for motor vehicles and mobile equipment.

REGULATORY HISTORY

Rule 1151 was adopted on July 8, 1988, and has been subsequently amended twelve times. The 

most recent amendment was on December 2, 2005, which incorporated portions of the 2003 

AQMP Control Measure CTS-10 and portions of the state Suggested Control Measure (SCM). 

The amendment included reductions in VOC limits for certain coating categories, a prohibition 

of possession, an exemption for Tertiary Butyl Acetate (TBAc) as a VOC for formulated 

coatings, except for color and clear coatings, and modified certain categories such as combining 

Group I and Group II vehicles, combining all primer subcategories into a general primer 

category, and eliminating the specialty coating category. The 2005 amendment revised Rule 

1151 into a two part rule based on effective dates. The first part of Rule 1151 was effective from 

December 2, 2005, through June 30, 2008. The second part of Rule 1151, identified as 

“Appendix A” to the rule, became effective on July 1, 2008, thus superseding the first part of 

Rule 1151. The two part structure of Rule 1151 currently contains 18 pages of obsolete language 

immediately followed by 16 pages of currently effective rule language, Appendix A. This 

structure continues to cause confusion to the regulated community.

AFFECTED INDUSTRIES

Rule 1151 is applicable to any person who supplies, sells, offers for sale, manufactures, or 

distributes any automotive coating or associated solvent for use within the District, as well as any 

person who uses, applies, or solicits the use or application of any automotive coating or 

associated solvent within the District. To determine how many facilities are affected by Rule 

1151, staff researched the CLeanClean Air Support System (Class) database using Standard 

Industrial Classification code (SIC) 7532 - Top, Body, and Upholstery Repair Shops and Paint 

Shops as the search criteria. The CLASS database contains 1,079 Rule 1151 facilities. This

database identifies required air permits which are typically for paint spray booths. Table 1 -

Permit And Percentage Distribution shows the distribution of these facilities in the four county 

areas. At a recent meeting with the California Autobody Association (CAA), representatives

reported to staff that there are approximately 7,000 active body shops in California, statewide,

with approximately 3,150 of those facilities in the southern California area, as estimated based 

on population. Staff believes the difference between the SCAQMD identified number of 

facilities and CCA’s estimation reflects the presence of facilities that conduct auto body repair

work but without a paint spray booth and facilities that may not be exclusively conducting auto 

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Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

body and paint operations such as car dealerships, fleet operators, and truck body builders, that 

do not fall under SIC code 7532. 

TABLE 1 – FACILITIES AND PERCENTAGE DISTRIBUTION

COUNTY

ACTIVE 

FACILITIES

(CLASS)

PERCENTAGE

Los Angeles County 700 65%

Orange County 196 18%

Riverside County 83 8%

San Bernardino County 100 9%

AQMD Jurisdiction 1,079 100%

PROCESS DESCRIPTION

Rule 1151 is applicable to all automotive and mobile equipment (such as trains, railcars and 

truck trailers) refinishing operations that are not a part of a motor vehicle assembly line coating 

operation. Rule 1151 should not be confused with Rule 1115 - Motor Vehicle Assembly Line 

Coating Operations which is applicable to all assembly line coating operations conducted during 

the manufacturing of new motor vehicles [with the exception of facilities subject instead to Rule 

1132 – Further Control Of VOC Emissions From High-Emitting Spray Booth Facilities, which 

applies to larger operations, e.g. Toyota Auto Body California (TABC)]. 

Automotive refinishing products are used during the repair process to address damage during 

manufacture, transit or during the service life of the vehicle, and are also used in the restoration, 

color change and customization of the vehicle as well. Automotive coatings are used in 

automotive refinishing operations to form a film that serves to beautify, preserve, repair or 

protect the surface of a motor vehicle, mobile equipment or associated parts and components. 

Automotive refinishing can be grouped into five broad categories: auto body repair/paint shops, 

production auto body paint shops, new car dealer repair/paint shops, fleet operators repair/paint 

shops, and truck body-builders.

Automotive refinishing is typically performed on vehicles that have sustained exterior body 

damage by conditions such as road hazards or collision. Many damaged vehicles are repaired by 

a process known as spot repair or for larger afflicted areas, panel repair. Spot repairs can be as 

small as a door ding and panel repairs are typically larger areas that may require a complete 

panel replacement, such as a front fender or a door. Less common refinishing operations may

include a complete repainting of the entire vehicle, to either renew weathered paint, complete a 

color change, an automotive restoration, or vehicle customization. The process for the repair 

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work for a damaged vehicle would include the physical repair of the damaged area, such as dent 

removal, application of body fillers, conditioning of substrate for subsequent coatings, and the 

application of an undercoat followed by the topcoat(s). 

Automotive refinishing coatings are typically grouped into two different classes, undercoats and 

topcoats. Undercoats primarily prepare the substrate for subsequent coatings. Undercoats 

include adhesion promoters for plastic parts, pretreatment coatings for bare metal surface 

etching, and primers, primer sealers, primer surfacers, and weld-through primers which are used 

to undercoat the surface prior to application of the topcoat(s). Top coats are typically applied 

onto prepared primed surfaces and include single-stage coatings, color and clear coat coating 

systems, and multi-color coatings. Uniform finish coatings are used for blending a spot repair 

into the surrounding areas for proper color match. Other coating types include underbody 

coatings which are used on the underside of the exterior body such as inner fender-well and 

chassis paint which is typically used on floor boards and frame rails. Bed liner coatings are used 

to coat the bed of pick-up trucks but have also been used as underbody coatings due to their 

higher resistance to damage.

After a motor vehicle, mobile equipment or associated parts and components have been 

refinished, the coating will need to cure. Non-assembly line coating operations may use several 

methods to achieve curing including air dry, forced air dry, infrared heat lamps or a forced air 

heater. The assembly line coating operations use ovens that thermally cure the coating, a method 

that cannot be accomplished by non-assembly line coating operations due to the damage the heat 

would cause to plastic parts such as headlights, tail lights, instrument panels and gauges, cloth or 

leather interior materials, and rubber parts such as weather-stripping and tires. 

When the repainted motor vehicle, mobile equipment or associated parts and components have 

fully cured, the final stage in automotive refinishing entails detailed sanding of the new finish (in 

some cases), polishing the finish and reassembly of any components that were removed from the 

vehicle to facilitate access to the body work. The vehicle is then cleaned, waxed and detailed in 

preparation for the final presentation for the customer.

SPRAY GUN TECHNOLOGY AND TRANSFER EFFICIENCY REQUIREMENTS

Spray guns are the preferred application equipment used by the automotive coatings industry to 

apply automotive coatings. The typical spray gun is a pistol shaped device that employs a trigger 

lever to release the compressed air source to atomize the automotive coating into a sprayable 

material. The spray gun typically comes in two different coating feed systems. The gravity feed, 

where a paint cup is fixed on top of the spray gun allows the coating to feed down via gravity to 

the gun body where the coating is then atomized with supplied compressed air. The second type 

of spray gun is the siphon feed, or suction feed, where the paint cup is fixed below the gun body 

and, when ready to spray, the compressed air source is forced through the gun body and creates a 

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Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

venturi effect thus drawing the paint from the paint cup. The spray gun has relatively few 

working parts: a trigger lever, which activates the spray gun for spray painting; a fluid needle, 

which restricts the flow of the coating through the spray gun; a fluid orifice, where the coating is 

expelled from the spray gun to atmosphere; and, an air cap, which typically has two air horns, 

one on each side of the fluid orifice, thus allowing compressed air to directly impact the coating 

material stream expelled from the fluid orifice to form the desired fan spray pattern. The mixing 

of the compressed air and coating is known as atomization. Paint spray guns have been in use 

since the early 1920s to spray finishes on a multitude of substrates including automobiles. High 

Volume, Low Pressure spray equipment or HVLP came to the forefront in regulated areas due to 

its ability to transfer more atomized coating onto the substrate than what went to atmosphere. 

When comparing conventional spray technology to HVLP technology, when using a the 

conventional spray gun, results in approximately one third of the atomized coating goes onto the 

substrate and two thirds goes to atmosphere. When spraying with a HVLP technology, two 

thirds of the atomized coating goes onto the substrate and one third of the atomized coating goes 

to atmosphere. The substrate that is spray coated is also a factor as a large flat surface will 

absorb more of a sprayed coating compared to a wrought iron gate which consists of multiple 

round bars with open space between the bars. Overspray is the sprayed coating that does not 

land on the substrate but rather becomes entrained in the air where the solvents readily evaporate 

and add to the already polluted air of southern California. 

Prior to 1924, automobiles were hand painted by using a brush to apply shellacs and varnishes. 

The shellacs and varnishes were time consuming to apply and it was difficult to completely 

brush out all the brush marks before the finish dried. Nitrocellulose lacquer was later introduced 

for automotive finishes however, the nitrocellulose lacquer also dried too quickly for hand 

applications. A new application process was introduced, air atomized spray guns, which could 

spray the nitrocellulose coatings on a vehicle about 10 times faster than hand application and it 

produced a higher quality finish. Today there are several technologies for spray application and 

they are discussed below.

Conventional

Conventional spray guns are high pressure, high volume technology and are still manufactured 

by industry and are sold in areas where strict air pollution rules have not been implemented. 

This spray gun technology will not meet the transfer efficiency requirements for SCAQMD and 

are not compliant for use to spray automotive coatings under the purview of SCAQMD Rule 

1151.

Electrostatic Spray Application

Electrostatic spray application is another method of coating application where an electrostatic 

attraction is created between the part to be coated and the paint particles. This process is similar 

to powder coating and requires specialized application equipment. The electrostatic application 

Proposed Amended Rule 1151 1-4 September 2014
Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

is facilitated by inducting an electric charge into the liquid paint prior to spraying the paint onto a 

grounded object using a spray gun specific to electrostatic application. The high transfer 

efficiency of this system, up to 98% claimed by some manufacturers, is accomplished by the 

attraction of paint particles to the surface of the grounded object. Manufacturers claim that the 

charged paint particles can actually change direction in mid air, even up to 180 degrees, before 

attracting to a grounded object. A typical useTypical uses for electrostatic application are new 

replacement automotive body panels such as replacement fenders, hoods, truck lids and patch 

panels.

High Volume Low Pressure (HVLP)

HVLP spray guns are the staple of spray guns and were created to meet the transfer efficiency 

requirements of governmental agencies, including the SCAQMD. HVLP spray guns can meet 

the high transfer efficiency requirement and operate at less than 10 psi at the air cap. HVLP 

spray guns are used in the South Coast Air Basin to spray coatings for a multitude of categories 

including automotive coatings, metal coatings, wood coatings, industrial coatings and marine 

coatings.

Low Volume Low Pressure (LVLP)

LVLP spray guns are a subset of non-conventional spray guns and may be used in the spraying 

of automotive coatings provided they meet the transfer efficiency requirements as 

stipulatedidentified in Rule 1151 clause (d)(6)(A)(iv) or clause (d)(6)(A)(v). LVLP offers an 

alternative to HVLP because they have less air flow requirements and can be used with a smaller 

compressor. This makes LVLP appealing for mobile painters and applicators that use a small air 

compressor. Manufacturers of LVLP spray guns state that LVLP can operate at less than 10 psi 

at the air cap and achieve transfer efficiencies equivalent to HVLP application. The working 

speed of LVLP is not as fast as HVLP spray guns.

Low Volume Medium Pressure (LVMP)

LVMP spray guns are a subset of the non-conventional spray guns and may be used in the 

spraying of automotive coatings provided the requirements in Rule 1151 clause (d)(6)(A)(v) for 

transfer efficiency are met including achieving equivalent or better transfer efficiency to HVLP 

using the test method protocols prescribed in Rule 1151 to determine transfer efficiency, and 

obtaining written approval from the Executive Officer prior to use. 

Reduced Pressure (RP)

RP spray guns are a subset of non-conventional spray guns and may be used in the spraying of 

automotive coatings provided the requirements in Rule 1151 clause (d)(6)(A)(v) for transfer 

efficiency are met including achieving equivalent or better transfer efficiency to HVLP using the 

test method protocols prescribed in Rule 1151 to determine transfer efficiency, and obtaining 

written approval from the Executive Officer prior to use. RP spray guns also use smaller air 

Proposed Amended Rule 1151 1-5 September 2014
Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

compressors because they need less air flow requirements than HVLP spray guns which makes 

RP attractive for mobile painters. RP can be an alternative to HVLP and has a fast working 

speed comparable to HVLP guns.

Pressure Fed (PF)

PF spray guns are unique as compared to the other types of spray guns in that they are equipped 

with auxiliary containers used for holding larger quantities of coating product. PF spray guns 

can be used in the spraying of automotive coatings provided all the requirements in Rule 1151 

clause (d)(6)(A)(v) for transfer efficiency are met including achieving equivalent or better 

transfer efficiency to HVLP using the test method protocols prescribed in Rule 1151 to 

determine transfer efficiency, and obtaining written approval from the Executive Officer prior to 

use.

New Conventional (NC)

Staff has identified an additional subset of conventional spray guns being marketed as New 

Conventional (NC) which appears to be new technology. Manufacturers of such spray guns 

claim the NC spray guns offer the same wide pattern (spray) as the old conventional spray guns 

but have better transfer efficiency, and have the ability to spray thick fluids. This technology 

could be used for spraying automotive coatings but only if the spray gun meets all the 

requirements in Rule 1151 clause (d)(6)(A)(v) for transfer efficiency including achieving 

equivalent or better transfer efficiency to HVLP using the test method protocols prescribed in 

Rule 1151 to determine transfer efficiency, and obtaining written approval from the Executive 

Officer prior to use.

Transfer Efficiency Requirements

Rule 1151 has transfer efficiency requirements for applying an automotive coating to nonassembly line coating operations to a motor vehicle, mobile equipment, or their associated parts 

and components. The transfer efficiency requirement for spray application is use of electrostatic,

HVLP spray equipment, and other spray guns that meet the HVLP definition of definition of 

paragraph (c)(17) in design and use. Demonstration must be based on the manufacturer’s 

published technical material on the design of the spray gun and by demonstration of the 

operation of the spray gun using an air pressure tip gauge from the manufacturer of the spray gun

[See clause (d)(6)(A)(iv)].

Brush and roller coating are applied directly from the paint brush bristles or the roller to the 

substrate and have a very high coating to substrate transfer efficiency. Dip coatings are simply a 

container filled with paint where an object is dipped into the coating which also provides a very 

high coating to substrate transfer efficiency. Brush, roller and dip coating processes are 

proposed to be included as compliant transfer efficiency processes as specified in clause 

Proposed Amended Rule 1151 1-6 September 2014
Chapter 1: Background on Proposed Amended Rule 1151 Final Staff Report

(d)(6)(A)(iii) of the transfer efficiency requirements in order to be to be consistent with the 

Coating Application Methods provision in the state Suggested Control Measure.

In addition, Rule 1151 provides for two test methods for spray guns that do not meet the HVLP 

definition in design and use to determine if such spray guns can meet the transfer efficiency 

requirements, SCAQMD method “Spray Equipment Transfer Efficiency Test Procedure for 

Equipment User, May 24, 1989” and SCAQMD “Guidelines for Demonstrating Equivalency 

With District Approved Transfer Efficiency Spray Gun September 26, 2002” [See clause 

(h)(1)(F)]. Any spray gun used in the SCAQMD jurisdiction must meet the criteria for these test 

methods to qualify as a compliant transfer efficient spray gun for use in the SCAQMD 

jurisdiction.

Automotive Graphic Arts Operations and Brush, Roller, Dip

Automotive Graphic Arts Operations include artistic designs such scenic murals, custom 

lettering, and other custom paint effects such as tablecloth lace designs, scallops, flames, and 

multi-hued designs typically used on customized vehicles. Pinstriping is a custom paint 

technique that can be used to separate different colors or to just add custom pin-thin design 

graphics to a vehicle. These paint tricks are performed with a multitude of application methods 

such as modified paint brushes, specialized dagger style brushes specific to pinstriping, and

various types of roller applications. In some cases, custom painters may even use a sponge to 

achieve a desired effect. Dip coatings are simply a container filled with paint that an object is 

dipped into to receive its coating.Automotive graphic arts operations are proposed to be exempt 

under paragraph (j)(4) from the transfer efficiency requirements in order to be consistent with the 

Coating Application Methods provision in the state Suggested Control Measure.

Truck Bed Liner and Underbody Coatings

Truck bed liner and underbody coatings are thicker viscosity coatings that may require 

specialized application equipment for application. Truck bed liner coatings are typically 

rubberized coatings that are sprayed into the truck bed cavity to protect the cavity of pick-up 

trucks from scrapes and scratches when hauling cargo. Underbody coatings are typically 

“rubberized asphaltic” coatings and are used for sound deadening or corrosion protection and are 

typically applied to areas such as wheel wells, the inside of door panels or fenders, the underside 

of a truck or hood or the underside of the vehicle itself. Truck bed liner and underbody coatings 

are also being proposed to be exempt under paragraph (j)(4) from the transfer efficiency 

requirements in order to be to be consistent with the Coating Application Methods provision in 

the state Suggested Control Measure. 

Proposed Amended Rule 1151 1-7 September 2014
RULE 1151 – MOTOR VEHICLE AND MOBILE EQUIPMENT NON-ASSEMBLY LINE 

COATING OPERATIONS

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1151

ο OVERVIEW: PROPOSED AMENDMENT TO RULE 1151

ο REMOVE OBSOLETE RULE LANGUAGE

ο SUBDIVISION (A) PURPOSE

ο SUBDIVISION (B) APPLICABILITY

ο SUBDIVISION (C) DEFINITIONS

ο SUBDIVISION (D) REQUIREMENTS

ο SUBDIVISION (E) PROHIBITIONOF SALES, SPECIFICATION AND SALE

ο SUBDIVISION (F) RECORDKEEPING REQUIREMENTS

ο SUBDIVISION (G) ADMINISTRATIVE REQUIREMENTS

ο SUBDIVISION (H) TEST METHODS

ο SUBDIVISION (I) RULE 442 APPLICABILITY

ο SUBDIVISION (J) EXEMPTIONS
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

OVERVIEW: PROPOSED AMENDMENT TO RULE 1151

Proposed Amended Rule (PAR) 1151 – Motor Vehicle and Mobile Equipment Non-Assembly 

Line Coating Operations is a source specific rule that regulates the automotive coating industry 

through limiting various automotive coating categories with prescribed VOC content limits and 

through the implementation of work practices. In an effort to enhance the understanding of 

current applicable rule requirements, the proposed amendment seeks to make administrative 

changes to the rule by removing obsolete rule language, and by making minor revisions and 

editorial corrections. The proposed amendment also adds new definitions to promote clarity and 

consistency, and further aligns the transfer efficiency equivalency requirements with the state 

Suggested Control Measure (SCM). This staff proposal is administrative in nature and will not 

affect the current VOC limits or work practices impacted by the rule.

The December 2, 2005 amendment effectively split Rule 1151 into two parts with two 

subsequent effective dates for compliance. The first part of Rule 1151, the original rule, became 

effective on December 2, 2005 and remained in effect through June 30, 2008. The second part of 

Rule 1151, identified as Appendix A, became effective on July 1, 2008 and superseded the first 

part of the rule, which is now obsolete.

REMOVE OBSOLETE RULE LANGUAGE

Staff recognizes that the two part structure of the existing rule is rather cumbersome and has 

often been confusing to the regulated community. The current version of Rule 1151 requires 

familiarity with the rule structure in general and requires diligence in reading since the first part 

of the rule is comprised of 18 pages of obsolete rule language immediately followed by 16 more 

pages of Appendix A, which is the operative portion of the rule. The current format may result 

in the reader referring to the VOC content limits in the first part of the rule instead of the more 

stringent VOC content limits in Appendix A. This could result in potential compliance issues 

with selection of appropriate coatings. Staff is proposing to delete the obsolete portion of Rule 

1151 and retain the currently applicable Appendix A language. Additionally, staff intends to 

make minor revisions to the purpose, applicability, rule definitions, table of standards formatting, 

requirements, and other subdivisions of the current rule language and include clarifications and 

editorial corrections as necessary. The proposed rule amendment is outlined below, identified by 

rule subdivision.

SUBDIVISION (A) PURPOSE

Staff is proposing to make minor revisions to this paragraph to improve the clarity of the purpose 

of the rule and by adding the additional text “associated parts and components.”

“The purpose of this rule is to limit reduce volatile organic compound (VOC) emissions, toxic 

air contaminants, stratospheric ozone-depleting compounds, and global-warming compound 

emissions from automotive coatings operations associated with the coating of applications 

onto motor vehicles, and mobile equipment, and associated parts and components.” 

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SUBDIVISION (B) APPLICABILITY

Staff is proposing to make minor revisions to this paragraph to improve clarity.

“This rule is applicable to any person who supplies, sells, offers for sale, markets,

manufactures, blends, packages, repackages, possesses or distributes any automotive coating 

or associated solvent or associated solvent for use within the District, as well as any person 

who uses, applies, or solicits, the use or application of any automotive coating or associated 

solvent within the District.”

SUBDIVISION (C) DEFINITIONS

Subdivision (c) contains the definitions to Rule 1151 and this proposed amendment includes 

three types of revisions: three new definitions are being proposed to be added to promote clarity 

and consistency; edits and corrections are being proposed to certain existing definitions to 

improve clarity; and, three unnecessary definitions are being proposed for deletion.

Proposed new definitions to be added to Rule 1151

The following new definitions are proposed to address automotive graphic arts operations, make 

a reference to Rule 1171 – Solvent Cleaning Operations to be consistent with other SCAQMD 

rules and to address stakeholder inquiries related to appropriate categorization of weld-through 

primers as a defined primer.

“(7) AUTOMOTIVE GRAPHIC ARTS OPERATION means the application of logos, letters, 

designs, numbers, or graphics to a painted surface by brush, roller or airbrush.”

“(25) SOLVENT CLEANING OPERATIONS is as defined in rule 1171 – Solvent Cleaning 

Operations.”

“(33) WELD-THROUGH PRIMER means an automotive coating designed and labeled 

exclusively to provide a bridging or conducting effect for corrosion protection 

following welding.”

Proposed revisions to existing Definitions

The proposed amendment adds new definitions to promote clarity and consistency. Revisions 

are proposed for a number of existing definitions:

(1) ADHESION PROMOTER means a any automotive coating, which is specifically

labeled and formulated to be applied to uncoated plastic surfaces to facilitate bonding 

of subsequent automotive coatings, and on which, a subsequent automotive coating is 

applied.

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Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

(2) AEROSOL COATING PRODUCT means a 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.

(4) ASSOCIATED PARTS AND COMPONENTS means structures, devices, pieces, 

modules, sections, assemblies, subassemblies, or elements of any motor vehicles or 

mobile equipment that are designed to be a part of any motor vehicles or mobile 

equipment but which are not attached to any motor vehicles or mobile equipment at the 

time of the application of an automotive coating to such the structure, device, piece, 

module, section, assembly, subassembly, or element. The Associated parts and 

components definition does do not include circuit boards.

(5) AUTOMOTIVE COATING means any coating or coating component used or 

recommended for use in motor vehicles, or mobile equipment or associated parts and

components in refinishing, service, maintenance, repair, restoration, or modification, 

except metal plating activities. Any reference to automotive refinishing or automotive 

coating made by a person on the container or in product literature constitutes a 

recommendation for use in motor vehicle, or mobile equipment and associated parts

and components refinishing.

(6) AUTOMOTIVE COATING COMPONENT means any portion of a coating, including, 

but not limited to, a reducer or thinner, toner, hardener, and additive, which is 

recommended by any person to distributors or end-users for use in an automotive 

coating, or which is used in an automotive coating. The raw materials used to produce 

the components are not considered automotive coating components.

(10)(9) CLEAR COATING means any automotive coating that contains no pigments is

formulated with materials that do not impart color and is specifically labeled and 

formulated for application over a color coating or clear coating.

(12)(11) COLOR COATING means any pigmented automotive coating, excluding automotive

adhesion promoters, primers, and multi-color coatings, that requires a subsequent 

clear coating and which is applied over primer, or adhesion promoter or color coating. 

Color coatings include metallic/iridescent color coatings.

(13)(12) ELECTROSTATIC SPRAY APPLICATION means any method of spray application of 

automotive coatings where an electrostatic attraction is created between the part to be 

coated and the paint particles.

Proposed Amended Rule 1151 2-3 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

The proposed amended language for definitions #1415 and #1516 are shown below in part, less 

equations language. There are no changes to either equation.

(16)(15) GRAMS OF VOC PER LITER OF COATING LESS WATER AND LESS EXEMPT

COMPOUNDS, OR REGULATORY VOC, is the weight of voc per combined volume of 

voc and coating solids and shall be calculated by the following equation:

(17)(16) GRAMS OF VOC PER LITER OF MATERIAL, OR ACTUAL VOC, is the weight of 

VOC per volume of material and shall be calculated by the following equation:

The following revisions are proposed for the remainder of the existing definitions:

(18)(17) HIGH-VOLUME, LOW-PRESSURE (HVLP) means spray application equipment 

designed to atomize 100 percent by air pressure only and is operated between 0.1 and 

10 pounds per square inch, gauge, (psig) air atomizing pressure measured dynamically 

at the center of the air cap and at the air horns.

(19)(18) METALLIC/IRIDESCENT COLOR COATING means any automotive coating that 

contains more than 0.042 pounds per gallon (5 grams per liter) of metal or iridescent 

particles as applied, where such particles are visible in the dried film.

(21)(20) MOTOR VEHICLE means any self-propelled vehicle, including, but not limited to, 

motorcycles, passenger cars, light-duty trucks and vans, medium-duty and heavy duty 

vehicles as defined in Section 1900, Title 13, of the California Administrative Code. 

Additional examples include, but are not limited to, buses, golf carts, vans, 

motorcycles, tanks, and armored personnel carriers.

(22)(21) MULTI-COLOR COATING means any automotive coating that exhibits more than 

one color in the dried film after a single application, is packaged in a single container, 

and hides surface defects on areas of heavy use, and which is applied over a primer or 

adhesion promoter.

(23)(22) PRETREATMENT COATING means any automotive coating that contains a 

minimum of one-half (0.5) percent acid by weight and not more than 16 percent solids 

by weight necessary to provide surface etching and that is specifically labeled and 

formulated for application directly to bare metal surfaces to provide corrosion 

resistance and adhesion.

(24)(23) PRIMER means any automotive coating, which that is specifically labeled and 

formulated for application to a substrate to provide 1) a bond between the substrate 

Proposed Amended Rule 1151 2-4 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

and subsequent coats, 2) corrosion resistance, 3) a smooth substrate surface, or 4) 

resistance to penetration of subsequent coats, and on which a subsequent coating is 

applied. Primers may be pigmented and include weld-through primers.

(25)(24) SINGLE-STAGE COATING means any pigmented automotive coating, (excluding 

automotive adhesion promoters, primers and multi-color coatings) specifically labeled 

and formulated for application without a subsequent clear coatcoating and applied 

over primer, adhesion promoters, or color coating. Single-stage coatings include 

single-stage metallic/iridescent coatings.

(26) SPOT REPAIR means repair of an area on a motor vehicle, piece of mobile equipment, 

or associated parts or components of less than 1 one square foot (929 square 

centimeters).

(27) TEMPORARY PROTECTIVE COATING means any automotive coating which is

specifically labeled and formulated for the purpose of temporarily protecting areas 

from overspray or mechanical damage.

(28) TRANSFER EFFICIENCY means the amount of coating solids adhering to the object 

being coated divided by the total amount of automotive coating solids sprayed, 

expressed as a percentage.

(29) TRUCK BED LINER COATING means any automotive coating, excluding color, 

multi-color, and single stage coatings, specifically labeled and formulated for 

application to a truck bed to protect it from surface abrasion.

(30) UNDERBODY COATING means any automotive coating specifically labeled and 

formulated for application to wheel wells, the inside of door panels or fenders, the 

underside of a trunk or hood, or the underside of the motor vehicle.

(31) UNIFORM FINISH COATING means any automotive coating specifically labeled and 

formulated for application to the area around a spot repair for the purpose of blending 

a repaired area’s color or clear coat to match the appearance of an adjacent area’s 

existing coating.

Rule 1151 includes an allowance for tertiary butyl acetate (TBAc) for automotive coating

formulations in which TBAc is considered a non-VOC except for color coatings and clear 

coatings. The December 2, 2005 amendment to Rule 1151 included a requirement for a 

technical assessment on the use of TBAc as a non-VOC by July 1, 2007. However, staff did not 

find any automotive coatings that contained TBAc to conduct the review and staff continues to 

Proposed Amended Rule 1151 2-5 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

reviewevaluate the issue. Staff recently received correspondence from the Office of 

Environmental Health Hazards Assessment (OEHHA) indicating that they intend to complete 

their toxicity review for TBAc towards the end of 2014 or spring 2015. Staff proposes to 

incorporate OEHHA findings as part of the technical assessment for Rule 1151 with a revised 

completion date of December 31, 2016, provided there are automotive coatings that contain 

TBAc available to conduct the assessment:

(33)(32) VOLATILE ORGANIC COMPOUND (VOC) is as defined in Rule 102-Definition of 

TERMS. For the purpose of this rule, tertiary butyl acetate (TBAc) is not a VOC when 

used in automotive coatings other than color coatings and clear coatings.

“The Executive Officer shall conduct a technical assessment on the use of TBAc as a 

non-VOC by July 1, 2007December 31, 2016. In conducting the technical assessment, 

the Executive Officer shall consider all information available to the SCAQMD on TBAc 

including, toxicity, carcinogenic and health risk assessment studies. The Executive 

Office shall report to the Governing Board as to the appropriateness of maintaining 

TBAc as a non-VOC.”

Definitions to be deleted from Rule 1151

There are three definitions in the current rule that are proposed for deletion. Definition #9, 

Cleaning Operations, is proposed to be deleted in favor of definition #24, Solvent Cleaning 

Operations (moved to maintain alphabetical ordering). The Solvent Cleaning Operations is a 

definition contained within many coating rules and it will be proposed for inclusion to Rule 1151 

as well for consistency.

Staff proposes to delete the current definition of CLEANING OPERATIONS in paragraph (c)(9) 

and replace it with SOLVENT CLEANING OPERATIONS as paragraph (c)(25).

(9) CLEANING OPERATIONS means the removal of loosely held uncured adhesives, inks, 

coatings, or contaminants, including, but not limited to, dirt, soil, or grease, from 

motor vehicles, mobile equipment, associated parts and components, substrates, parts, 

products, tools, machinery, equipment, or general work areas.

The second and third definitions, #8 and #32, are not necessary to keep in the rule. These 

definitions are not used in other SCAQMD coating rules therefore staff proposes to remove these 

definitions for consistency.

(8) CARB means the California Air Resources Board.

(32) U.S. EPA means the United States Environmental Protection Agency.

Proposed Amended Rule 1151 2-6 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

SUBDIVISION (D) REQUIREMENTS

In an effort to enhance the understanding of current applicable rule requirements, the proposed 

amendment seeks to make administrative changes to the rule by removing obsolete rule 

language, and making minor revisions and editorial corrections.

Paragraph (d)(1)

“A person shall not apply any automotive coating to a motor vehicle, mobile equipment, or 

associated parts or components, of a motor vehicle or mobile equipment that have a contains 

VOC content in excess of the limits contained in Table A of this paragraphin excess of the 

limits specified in the Table of Standards below. Compliance with the applicable VOC content 

limits shall be based on VOC content, including any VOC material added to the original 

automotive coating supplied by the manufacturer, less water and exempt compounds, as 

applied, to the vehicle, mobile equipment or parts and components less water and exempt 

compounds.”

VOC Content Limit Compliance Table

The current version of Rule 1151 contains a table in subdivision (d) under the heading of “Table 

A – Coating Categories and VOC limits.” This table shows obsolete VOC limits for several 

coating categories typically used in automotive coating operations. Staff proposes to reformat 

the table and show only the current VOC content limits.

TABLE OF STANDARDS

VOC CONTENT LIMITS

Grams per Liter of Coating, Less Water and Less Exempt Compounds

AUTOMOTIVE COATING 

CATEGORIES

Current Limit

g/L Lb/Gal

Adhesion Promoter 540 4.5

Clear Coating 250 2.1

Color Coating 420 3.5

Multi-Color Coating 680 5.7

Pretreatment Coating 660 5.5

Primer 250 2.1

Single-Stage Coating 340 2.8

Temporary Protective Coating 60 0.5

Truck Bed Liner Coating 310 2.6

Underbody Coating 430 3.6

Uniform Finishing Coating 540 4.5

Any Other Coating Type 250 2.1

Proposed Amended Rule 1151 2-7 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Paragraph (d)(2) – Most Restrictive VOC Limit

Staff is proposing to make minor revisions by differentiating “coatings” as “automotive 

coatings” and making editorial corrections.

“If any representation on or information on the container of any automotive coating, or any 

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

supplied by a person that indicates that the automotive coating meets the definition of or is 

recommended for use for more than one of the automotive coating categories listed in 

paragraph (d)(1), then the lowest VOC content limit shall apply.”

Paragraph (d)(3) - VOC Limits Compliance Dates

Paragraph (d)(3) contains a compliance date requirement that has expired. Staff proposes to 

remove the obsolete rule language and renumber the subsequent paragraphs in subdivision (d).

VOC Limits Compliance Dates

The VOC limits in effect as of December 2, 2005 shall be applicable until superceded by the 

VOC limits and effectives dates in Table A of paragraph (d)(1).

“Paragraph (d)(3) – Alternative Compliance”

(A) Emission Control System

“A person may comply with the provisions of paragraph (d)(1), by using an approved emission 

control system, consisting of collection and control devices, that isprovided such emission 

control system is has been approved pursuant to Rule 203 – Permit to Operate, in writing, by 

the Executive Officer for reducing emissions of VOC. The Executive Officer shall approve 

such emission control system only if the VOC emissions resulting from the use of noncompliant automotive coatings will be reduced to a level equivalent to or lower than that which 

would have been achieved by the compliance with the terms of paragraph (d)(1). [...]

VOCLWn,Max = Maximum VOC content of non-compliant 

automotive coating used in conjunction with 

a control device, less water and exempt 

compounds.

Dn,Max = Density of VOC solvent, reducer, or thinner 

contained in the non-compliant automotive

coating containing the maximum VOC.

Dc = Density of corresponding VOC solvent, 

reducer, or thinner used in the compliant 

automotive coating system = 880 g/L.

Proposed Amended Rule 1151 2-8 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Paragraph (d)(4) – Exempt Compounds

“A person shall not manufacture, sell, offer for sale, distribute for use in the District, or apply 

any automotive coating which contains any Group II Exempt Compounds as defined in Rule 

102.”

Paragraph (d)(5) – Carcinogenic Materials

“A person shall not manufacture the automotive coatings for use in the SCAQMD in which 

cadmium or hexavalent chromium was introduced as a pigment or as an agent to impart any 

property or characteristic to the automotive coatings during manufacturing, distribution, or 

use of the applicable automotive coatings.”

Paragraph (d)(6) – Transfer Efficiency

Staff is proposing to augment the current language in paragraph (d)(6) by including the term 

“automotive coatings” and including additional language for “application of automotive coatings 

to a motor vehicle, mobile equipment or any associated parts or components to a motor vehicle 

or mobile equipment”. In addition, staff is also proposing new language to address the current 

HVLP requirements for spray guns that are used to apply automotive coatings.

(A) A person shall not apply automotive coatings to any motor vehicle, mobile equipment 

or any associated parts or components to a motor vehicle or mobile equipment except 

by the use of one of the following methods:

(i) electrostatic application, or 

(ii) high-volume, low-pressure (HVLP) spray, or

(iii) brush, dip, or roller, or

(iv) Spray gun application, provided the owner or operator demonstrates that the 

spray gun meets the HVLP definition in paragraph (c)(17) in design and use. 

A satisfactory demonstration must be based on the manufacturer’s published 

technical material on the design of the spray gun and by a demonstration of 

the operation of the spray gun using an air pressure tip gauge from the 

manufacturer of the spray gun.

(iiiv) Any such other automotive coating application methods as are demonstrated, 

in accordance with the provisions of subparagraph (h)(1)(EF), to be capable 

of achieving equivalent or better transfer efficiency than the automotive 

coating application method listed in clause (d)(6)(A)(ii), and for 

whichprovided written approval is obtained of from the Executive Officer has

been obtainedprior to use.

(B) A person shall not apply any automotive coatings by any of the methods listed in 

subparagraph (d)(6)(A) unless the automotive coating is applied with properly 

operating equipment, operated according to procedures recommended by the 

manufacturer and in compliance with applicable permit conditions, if any.”

Proposed Amended Rule 1151 2-9 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

SUBDIVISION (E) PROHIBITION OF POSSESSION, SPECIFICATION AND SALE

Staff is proposing to make minor revisions to following subdivision by differentiating coatings as 

automotive coatings and making editorial corrections.

Paragraph (e)(1)

“For the purpose of this rule, no person that applies automotive coatings subject to this rule

shall posses possess any automotive coating that is not in compliance with requirements of 

paragraph (d)(1), unless one or more of the following conditions apply:”

(A) The automotive coating is located for use at a facility that utilizes an approved 

emission control device pursuant to subparagraph (d)(43)(A), and the coating meets 

the limits specified in permit conditions.

(B) The automotive coating is located for use at a facility that operates in compliance with 

an approved Alternative Emissions Control Plan pursuant to subparagraph (d)(43)(B), 

and the automotive coating is specified in the plan.

(C) The automotive coating is located for use at a training center and the automotive

coating is used for educational purposes, provided that the VOC emissions from 

automotive coatings not meeting the VOC limits of paragraph (d)(1) do not exceed 

twelve (12) pounds per day.

(D) “The automotive topcoat coating is located for use at a prototype motor vehicle 

manufacturing facility and the automotive coating is supplied by an assembly-line 

motor vehicle manufacturer specifically for use in the refinishing of a prototype motor 

vehicle, provided that the VOC emissions from all automotive coatings not meeting the 

VOC limits of paragraph (d)(1) do not exceed twenty-one (21) pounds per day and 930 

pounds in any one calendar year.”

Paragraph (e)(2)

“(2) For the purpose of this rule, no person shall solicit from, specify, or require any other 

person to use in the District any automotive coating which, when applied as supplied or 

thinned or reduced according to the manufacturer's recommendation for application, 

does not meet the:”

Subparagraph (e)(2)(A)

“applicable Applicable VOC limits required by paragraph (d)(1) for the specific application 

unless:”

Proposed Amended Rule 1151 2-10 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Clause (e)(2)(A)(i)

“(i) The automotive coating is located at a facility that utilizes an approved emission 

control device pursuant to subparagraph (d)(43)(A), and the automotive coating meets 

the limits specified in permit conditions; or,”

Clause (e)(2)(A)(ii)

“(ii) The automotive coating is coating is located at a facility that operates in compliance 

with an approved Alternative Emissions Control Plan pursuant to subparagraph 

(d)(43)(B), and the automotive coating is specified in the plan; or”

Clause (e)(2)(A)(iii)

“(iiiii) the The automotive coating is specifically exempt pursuant to subdivision (ij) of this 

rule.”

Subparagraph (e)(2)(B)

“theThe requirements of paragraphs (d)(54) and (d)(65).”

Paragraph (e)(3)

“No For the purpose of this rule, no person shall supply, sell, offer for sale, market, blend, 

package, repackage or distribute for use in the District any automotive coating for use within 

the District subject to the provisions in this rule which, when applied as supplied or thinned or 

reduced according to the manufacturer's recommendation for application, does not meet the:”

Clause (e)(3)(A)(i)

“The automotive coating is located for use at a facility that utilizes an approved emission 

control device pursuant to subparagraph (d)(43)(A), and the coating meets the limits specified 

in permit conditions; or,”

Clause (e)(3)(A)(ii)

“The automotive coating is specifically exempt under subdivision (ij) of this rule; or,”

Clause (e)(3)(A)(iii)

“The automotive coating is coating is located for use at a facility that operates in compliance 

accordance with an approved Alternative Emissions Control Plan pursuant to subparagraph 

(d)(43)(B), and the automotive coating is specified in the plan; and,”

Clause (e)(3)(A)(iv)

“The person that offers for supplies, sells, offers for sale, markets, blends, packages,

repackages sale or distributes the automotive coating keeps the following records for at least 

five years and makes them available to the Executive Officer upon request:”

Proposed Amended Rule 1151 2-11 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Subclause (e)(3)(A)(iv)(I)

“Automotive coating Coating name and manufacturer;”

Subclause (e)(3)(A)(iv)(II)

“Application method as recommended;”

Subclause (e)(3)(A)(iv)(III)

“Automotive coating Coating category and mix ratio specific to the automotive coating;”

Subclause (e)(3)(A)(iv)(IV)

“VOC content of the automotive coating;”

Subclause (e)(3)(A)(iv)(V)

“Documentation such as manufacturer specification sheets, material safety data sheets, 

technical data sheets, or any other air quality data sheets that demonstrate that the material is 

intended for use as a an automotive coating;”

Subclause (e)(3)(A)(iv)(VI)

“Current manufacturer specification sheets, material safety data sheets, technical data sheets, 

or air quality data sheets, which list the VOC content of each ready-to-spray automotive 

coating (based on the manufacturer’s stated mix ratio) and automotive coating components 

and VOC content of each solvent;”

Subclause (e)(3)(A)(iv)(VII)

“Purchase records identifying the automotive coating category, name, and volume of 

automotive coatings; and”

Subclause (e)(3)(A)(iv)(VIII)

“The In addition, for sale to an end-user, the name and address of the person purchasing 

receiving the automotive coating, a statement of the basis an acknowledgement warranting that

the sale to an end-user purchase will comply with this paragraph, including if use is for outside 

the District, and acknowledgement by the purchaser that this statement is correct.”

Subparagraph (e)(3)(B)

“or does not meet the The requirements of paragraphs (d)(54) and (d)(65).”

Proposed Amended Rule 1151 2-12 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Paragraph (e)(4)

“No For the purpose of this rule, no person shall solicit from, specify, require, offer for sale to, 

sell to, or distribute to any other person for use in the District any automotive coating 

application equipment which does not meet the requirements of subparagraph (d)(76)(A).”

Paragraph (e)(5)

Staff is proposing to add clarifying language to the prohibition of sale requirements for HVLP 

guns by specifically identifying that the required information to be provided with the sale shall 

be based on published technical material on the design and demonstration of the air pressure. 

The demonstration is a requirement for the manufacturer in preparing the required information 

distributed in conjunction with a sale − it is not intended as a field demonstration prior to each 

individual HVLP gun sale. 

“No For the purpose of this rule, no person shall offer for sale, sell, supply, market, offer for 

sale or distribute an HVLP spray gun for use within the SCAQMD unless the person offering 

for sale, selling, marketing or distributing the HVLP spray gun for use within the SCAQMD

provides accurate information to the spray gun recipient on the maximum inlet air pressure to 

the spray gun which would result in a maximum air pressure of 10 pounds per square inch 

gauge (psig) air pressure measured dynamically at the center of the air cap and at the air 

horns based on the manufacturer’s published technical material on the design of the spray 

application equipment and by a demonstration of the operation of the spray application 

equipment using an air pressure tip gauge from the manufacturer of the gun. The information 

shall either be permanently marked on the gun, or provided on the company's letterhead or in 

the form of technical literature which clearly identifies the spray gun manufacturer, the 

salespersonseller, or the distributor.”

Paragraph (e)(6)

“The For the purpose of this rule, the requirements of paragraphs (e)(1), (e)(2), (e)(3), (e)(4)

or (e)(45) or (e)(4) shall apply to all written or oral agreements executed and entered into 

under the terms of which an automotive coating or an automotive coating application 

equipment shall be used at any location within the District.”

SUBDIVISION (F) RECORDKEEPING REQUIREMENTS

Staff intends to clarify the recordkeeping requirements for automotive coatings that are 

formulated with TBAc. The proposed definition for VOC allows TBAc in the formulation of 

non-color and non-clear coatings where TBAc is considered a non-VOC when determining the 

VOC of the coating for compliance purposes with subparagraph (d)(1). This gives automotive 

coating manufacturers the ability to formulate non-color and non-clear coatings using TBAc to 

meet the VOC requirements in the proposed Table of Standards in paragraph (d)(1). Staff is 

proposing to make minor revisions to the following paragraph as follows:

Proposed Amended Rule 1151 2-13 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Paragraph (f)(1) Recordkeeping For VOC Emissions

“(1) Recordkeeping for VOC Emissions

Records of automotive coating usage shall be maintained pursuant to SCAQMD Rule 109 –

Recordkeeping for Volatile Organic Compound Emissions, and shall at a minimum include the 

following information:”

“ (C) Automotive coating Coating category and mix ratio specific to the coating;

(D) VOC actualActual VOC and regulatory VOC, for the automotive coating;

(E) Documentation such as manufacturer specification sheets, material safety data sheets, 

technical data sheets, or any other air quality data sheets that demonstrate that the 

material is intended for use as aan automotive coating or solvent;

(F) Current manufacturer specification sheets, material safety data sheets, technical data 

sheets, or air quality data sheets, which list the actual VOC actual for coatings and 

VOC regulatory VOC, for coatings of each ready-to-spray automotive coating (based 

on the manufacturer’s stated mix ratio), and automotive coating components used and 

the VOC content of for each solvent used; and,

(G) Purchase records identifying the automotive coating category, name, and the total

volume of all coatings and solvents used.”

SUBDIVISION (G) ADMINISTRATIVE REQUIREMENTS

Staff is proposing to make minor revisions to following subdivision by differentiating coatings as 

automotive coatings and making editorial corrections.

Subdivision (g) – Add Automotive to Coating Manufacturer

“(g) Administrative Requirements for Automotive Coating Manufacturers”

Paragraph (g)(1) – Compliance Statement Requirement

“For each individual automotive coating, automotive coating component, and ready to spray 

mixture (based on the manufacturers stated mix ratio), the manufacturer shall include the 

following information on a product data sheet, or an equivalent medium:

(A) The actual VOC and regulatory VOC for automotive coatings (in grams per liter);”

Paragraph (g)(2) – Labeling Requirements

“(A) The manufacturer of automobile automotive coatings or automotive coating 

components, including hardeners, with the exception of solvents such as reducers and 

thinners, shall include on all containers the applicable use automotive coating 

categorycategory(ies), and the VOC actual VOC and regulatory VOC, for coatings, as 

supplied (in grams of VOC per liter of material) and in grams of VOC per liter of 

material, less water and less exempt compounds).”

Proposed Amended Rule 1151 2-14 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

“(B) The manufacturer of solvents, including reducers and thinners, subject to this rule shall 

include on all containers the actual VOC content for solvents, as supplied (in grams of 

VOC per liter of material).”

SUBDIVISION (H) TEST METHODS

Staff is proposing to make minor revisions to following subdivision by differentiating coatings as 

automotive coatings and making editorial corrections.

Subparagraph (h)(1)(A)

Add the word “automotive” to “coatings”: “VOC Content of Automotive Coatings”

Clause (h)(1)(A)(i)

“(i) United States Environmental Protection Agency (“U.S. EPA”) Reference Test Method 

24, (Determination of Volatile Matter Content, Water Content, Volume Solids and 

Weight Solids of Surface Coatings, Code of Federal Regulations, Title 40 Code of 

Federal Regulations, Part 60, Appendix A). The exempt compounds’ content shall be 

determined by South Coast Air Quality Management District (SCAQMD) Laboratory 

Test Method 303 (Determination of Exempt Compounds) contained in the SCAQMD 

"Laboratory Method of Analysis for Enforcement Samples" manual; or SCAQMD 

Method 304 [Determination of Volatile Organic Compounds (VOC’s) in various 

materials} contained in the SCAQMD “Laboratory Methods of Analysis for 

Enforcement Samples” manual.”

Staff will be moving reference to test method, SCAQMD Method 304 as a new clause, 

(h)(1)(A)(ii):

“(ii) SCAQMD Method 304 [Determination of Volatile Organic Compounds (VOCs) in 

Various Materials] contained in the SCAQMD “Laboratory Method of Analysis for 

Enforcement Samples” manual.”

Subparagraph (h)(1)(B) – Exempt Perflourocarbon Compounds.

Staff proposes to reformat this rule language to provide the list of classes of compounds in a 

semi-bullet format consistent with other SCAQMD rules.

The following classes of compounds: cyclic, branched, or linear, completely fluorinated 

alkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; 

cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations; and 

sulfur containing perfluorocarbons with no unsaturations and with sulfur bonds only to 

carbon and fluorine,

“The following classes of compounds: 

Proposed Amended Rule 1151 2-15 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

cyclic, branched, or linear, completely fluorinated alkanes; 

cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; 

cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations;

and 

sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to 

carbon and fluorine,

shall be analyzed as exempt compounds for compliance with paragraph (d)(1), only at such 

time as manufacturers specify which individual compounds are used in the formulation of the 

automotive coatings and identify the test methods, which have been approved by the U.S. EPA, 

CARB and the District SCAQMD prior to such analysis, that can be used to quantify the 

amounts of each exempt compound.”

Subparagraph (h)(1)(D) – Add Automotive to Pretreatment Coatings.

“(h)(1)(D) - Acid Content in Pretreatment Automotive Coatings”

“The acid content of pretreatment automotive coatings shall be determined by ASTM Test 

Method D1613-06 (2012) (Acidity in Volatile Solvents and Chemical Intermediates Used in 

Paint, Varnish, Lacquer, and related products.”

Subparagraph (h)(1)(E) – Add Automotive to Coatings and be more specific on test method.

“Subparagraph (h)(1)(E) - Reflectance of Anti-Glare Safety Automotive Coatings”

“The reflectance of anti-glare automotive safety coatings shall be measured determined by 

ASTM Test Method D-523-08 (Specular Gloss).”

Subparagraph (h)(1)(F) – Transfer Efficiency

“The transfer efficiency of alternative automotive coating application methods, as defined by 

clause (d)(76)(A)(iiiv), shall be determined in accordance with the SCAQMD method "Spray 

Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989," and 

SCAQMD “Guidelines for Demonstrating Equivalency With District Approved Transfer 

Efficiency Spray Gun September 26, 2002.”

Subparagraph (h)(1)(G) - Equivalent Test Methods

“Other test methods determined to be equivalent after review by the staffs of the Districtby the 

Executive Officer, CARB, and the U.S. EPA, and approved in writing by the District Executive 

Officer may also be used for methods of analysis.”

Subparagraph (h)(2)(A) – Determination of Efficiency of Emission Control System

“The efficiency of the collection device of an emission control system as specified in 

subparagraph (d)(43)(A) shall be determined by the methods specified in clauses (h)(2)(A)(i), 

(h)(2)(A)(ii), or (h)(2)(A)(iii).below:”

Proposed Amended Rule 1151 2-16 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

Clause (h)(2)(A)(iii)

“any Any other method approved by the United States Environmental Protection AgencyU.S. 

EPA, the California Air Resources BoardCARB, and the District Executive Officer.”

Subparagraph (h)(2)(B)

“The efficiency of the control device of an emission control system as specified in 

subparagraph (d)(43)(A) and the VOC content in the control device exhaust gases, measured 

and calculated as carbon, shall be determined by USEPA Test Methods 25, 25A, or SCAQMD 

Method 25.1 (Determination of Total Gaseous Non-Methane Organic Emissions as Carbon) as 

applicable. U.S. EPA Test Method 18, or CARB Method 422 shall be used to determine 

emissions of exempt compounds.”

Paragraph (h)(3) - Multiple Test Methods

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

violation of any requirement of this ruleof this rule documentation established by any one of 

the specified test methods or set of test methods shall constitute a violation of the rule.”

SUBDIVISION (I) - RULE 442 APPLICABILITY

Staff is proposing to add a new subdivision to the rule to include Rule 1151 - Usage of Solvents 

to make Rule 1151 consistent with the other Regulation XI rules that already include Rule 442 

applicability language. The new rule language will be under subdivision (i) which will replace 

the exemptions subdivision (i), and the exemptions subdivision then becomes subdivision (j). 

The new rule language is as follows:

“Rule 442 Applicability

Any automotive coating, automotive coating operation or facility which is exempt pursuant to 

subdivision (j) from all or a portion of the VOC limits of subdivision (d) shall comply with the 

provisions of Rule 442 – Usage of Solvents.”

SUBDIVISION (J) EXEMPTIONS

Staff is proposing the following editorial clarifications to the exemptions to the rule requirements 

to improve clarity.

“Paragraph (j)(1) – This rule shall not apply to:”

(A) Any automotive coating applied to motor vehicles or mobile equipment, or their 

associated parts and components, during manufacture on an assembly line that areis

subject to Rule 1115 – Motor Vehicle Assembly Line Coating Operations.;”

Proposed Amended Rule 1151 2-17 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

“ (C) Any aerosol coating product; and

(D) Any coating that is sold, supplied, sold, or offered for sale, marketed manufactured, 

blended, packaged or repackaged for use in the District in 0.5 fluid ounces or smaller 

containers.”

Paragraph (j)(2):

“(2) The requirements of paragraph (d)(1) shall not apply to automotive coatings applied 

for educational purposes at automotive coating training centers, which are owned 

and operated by automotive coating manufacturers, provided that the VOC emissions 

emitted at a automotive coating training center from automotive coatings not 

complying with paragraph (d)(1) doesdo not exceed twelve (12) pounds per day.”

Paragraph (j)(3):

“(3) The requirements of paragraph (d)(1) shall not apply to automotive coatings supplied 

by an assembly-line motor vehicle manufacturer for use by a prototype motor vehicle 

manufacturing facility in the finishing of a prototype motor vehicle, provided that the 

VOC emissions at the prototype motor vehicle manufacturing facility from such 

topcoats doesdo not exceed 21 pounds in a calendar day and 930 pounds in a 

calendar year.

Paragraph (j)(4) – Exemptions

Paragraph (i)(4) (current rule) contains a compliance date requirement for color and clear 

coatings that has expired. Staff proposes to remove the obsolete rule language.

“(j)(4) Color and clear coatings that are manufactured prior to the effective date of July ,1, 

2008, that have a VOC content above the limit specified in Table A of paragraph 

(d)(1), but not above the applicable limit on the date of manufacture may be 

possessed, sold, supplied, offered for sale, or applied up to December 31, 2008.”

Staff has received ongoing questions about whether or not custom graphics such as pin-striping, 

murals and other special effects type painting are compliant with the transfer efficiency 

requirements of Rule 1151. Staff reviewed the transfer efficiency requirements of the SCM and 

proposes to align the requirements by adding a new definition for automotive graphic arts 

operations and then exempt automotive graphic arts operations, truck bed liner coating 

operations and underbody coating operations from the transfer efficiency requirements of 

subparagraph (d)(6)(A) as follows:

Proposed Amended Rule 1151 2-18 September 2014
Chapter 2: Summary of Proposed Amended Rule 1151 Final Staff Report

“(j)(4) The requirements of subparagraph (d)(6)(A) shall not apply to automotive graphic 

arts operations, truck bed liner coatings or underbody coatings.”

Proposed Amended Rule 1151 2-19 September 2014
RULE 1151 – MOTOR VEHICLE AND MOBILE EQUIPMENT NON-ASSEMBLY LINE 

COATING OPERATIONS

CHAPTER 3: IMPACT ASSESSMENT OF PROPOSED AMENDED RULE 1151

ο EMISSION IMPACT ASSESSMENT

ο COST ANALYSIS

ο INCREMENTAL COST-EFFECTIVENESS

ο CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

ο SOCIOECONOMIC IMPACT ASSESSMENT

ο DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

40727

ο COMPARATIVE ANALYSIS

ο DRAFT CONCLUSIONS AND RECOMMENDATIONS

ο PUBLIC COMMENTS AND RESPONSES
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

EMISSION IMPACT ASSESSMENT

Staff does not anticipate any emissions reductions or increases since the proposed amendment 

does not change any VOC content limits or standards and is administrative in nature.

COST ANALYSIS

The proposed amendment to Rule 1151 is not expected to have a net cost impact since industry 

will be able to continue business as usual and operate their equipment subject to Proposed 

Amended Rule 1151 in a similar manner to the current rule. 

INCREMENTAL COST-EFFECTIVENESS

Under Health and Safety Code § 40920.6, the SCAQMD is required to perform an incremental 

cost analysis when adopting a Best Available Retrofit Control Technology (BARCT) rule or 

feasible measure required by the California Clean Air Act. To perform this analysis, the 

SCAQMD must (1) identify one or more control options achieving the emission reduction 

objectives for the proposed rule, (2) determine the cost effectiveness for each option, and (3) 

calculate the incremental cost effectiveness for each option. To determine incremental costs, the 

SCAQMD must “calculate the difference in the dollar costs divided by the difference in the 

emission reduction potentials between each progressively more stringent potential control option 

as compared to the next less expensive control option.” Staff reviewed the (October 20, 2005) 

state control measure Suggested Control Measure along with other current standards throughout 

the state and determined that PAR 1151 represents BARCT for Motor Vehicle And Mobile 

Equipment Non-Assembly Line Coating Operations because there are no other more stringent 

limits available. PAR 1151 will not result in emission reductions and therefore no incremental 

cost analysis is required under Health and Safety Code § 40920.6.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)

The SCAQMD has reviewed the proposed project pursuant to CEQA Guidelines §15002 (k)(1) -

General Concepts, the first step of a three-step process for deciding which document to prepare 

for a project subject to CEQA. The SCAQMD has determined that that it can be seen with 

certainty that there is no possibility that the proposed project may have any significant effects on 

the environment, and is therefore, exempt pursuant to CEQA Guidelines §15061 - Review for 

Exemption, paragraph (b)(3) – “general rule” exemption.

A Notice of Exemption has been prepared pursuant to CEQA Guidelines §15062 - Notice of 

Exemption. If the proposed project is approved, the Notice of Exemption will be filed with the 

county clerks of Los Angeles, Orange, Riverside and San Bernardino counties.

Proposed Amended Rule 1151 3-1 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

SOCIOECONOMIC IMPACT ASSESSMENT

The proposed amendments codify existing practices at Motor Vehicle and Mobile Equipment 

Non-Assembly Line Coating Operations that are subject to Rule 1151. As such, there will be no 

additional costs or other socioeconomic impacts.

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 40727

The draft findings include necessity, authority, clarity, consistency, non-duplication and 

reference, as defined in Health and Safety Code Section §40727. The draft findings are as 

follows:

Necessity - The AQMD Governing Board finds and determines that Proposed Amended Rule 

1151, Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations, is 

necessary to enhance readability and provide clarity of rule language.

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

and regulations from Health and Safety Code §§ 40000, 40001, and 40440.

Clarity - The AQMD Governing Board finds and determines that Proposed Amended Rule 1151

is written and displayed so that the meaning can be easily understood by persons directly 

affected by it.

Consistency – The AQMD Governing Board finds and determines that Rule 1151 is in harmony 

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

state regulations.

Non-Duplication – The AQMD Governing Board has determined that Rule 1151 does not 

impose the same requirement as any existing state or federal regulation, and the proposed 

amendment is necessary and proper to execute the powers and duties granted to, and imposed 

upon, the AQMD.

Reference - In adopting this proposed amendment, the AQMD Governing Board references the 

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

Safety Code Sections 40001 and 40440.

COMPARATIVE ANALYSIS

California Health and Safety Code Section 40727.2 requires the comparative analysis with any 

federal or other AQMD rules that apply to the same equipment or source type as the proposed 

amendments. There are no federal requirements for these small emitting types of 

equipmentsources. 

Proposed Amended Rule 1151 3-2 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

DRAFT CONCLUSIONS AND RECOMMENDATIONS

Staff recommends that Rule 1151 - Motor Vehicle and Mobile Equipment Non-Assembly Line 

Coating Operations be amended as proposed.

PUBLIC COMMENTS AND RESPONSES

The public comments and staff responses shown below are from the May 28, 2014, public 

workshop and from the comment letters that were received from May 28, 2014, through June 6, 

2014.

Responses to comments from the public workshop

The following comments were made during the public workshop and staff responses to those 

comments are shown below.

Comment #1:

The proposed rule language for the purpose of the rule [subdivision (a)] now focuses on the 

supplier. The focus should remain on the operation and not move to the supplier.

Response:

Staff disagrees that the purpose of the rule changed focus and believes the revisions to the purpose 

section of the rule [subdivision (a)] reflects current implementation of the rule. The rule’s purpose is

to reduce volatile organic compound emissions, toxic air contaminates, stratospheric ozonedepleting compounds, and global-warming compound emissions from automotive coating 

applications performed on motor vehicles, mobile equipment, and associated parts and components.

Comment #2:

The CARB Consumer Products definition for Aerosol Coating Product and Weld-Through 

Primers should be used in Rule 1151.

Response:

After consultation and concurrence from CARB staff, staff has revised the proposed language to be 

consistent with the Consumer Products Regulation.

Comment #3:

The inclusion of “Associated Parts and Components” appears to be overly broad and may loop in 

many coatings that otherwise would not normally be considered to be part of an auto refinishing 

operation, such as the reflective lens coating on a headlight.

Proposed Amended Rule 1151 3-3 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

Response:

Staff revised the language for the Associated Parts And Components definition by designating 

“coatings” as “automotive coatings” to clarify that the scope of the requirement does not extend to 

original equipment manufacturer (OEM) applications.

Comment #4:

The Clear Coating definition should accommodate materials that don’t impart color that 

manufacturers loosely refer to as “pigments”, even though they are not technically pigments. 

Examples include flattening agents and nanopigments.

Response:

Staff agrees and has revised the definition for clear coatings as suggested.

Comment #5:

The commenter recommends removal of Low Volume, Low Pressure (LVLP) definition and all 

references to LVLP from the proposed amended rule. The commenter said this could open a 

loop hole and bring many offshore so-called LVLP PSGs to southern California. There is no 

way to conduct third party testing on LVLP spray guns since they are predominantly turbine. 

The introduction of LVLP technology as an acceptable method has downstream effects on 

literature, training, etc. SATA has a “reduced pressure” gun (exceeds the 10 psig, but has an 

approved equivalency). SATA would prefer the District maintain the requirement for equipment 

testing rather than add LVLP as an acceptable method. Introducing a new method could create a 

loophole that other gun manufacturers could use to produce guns that may not meet the transfer 

efficiency requirements of the rule, but take advantage of either improperly marketed equipment 

or equipment that would be difficult to test. The commenter inquired if LVLP was a branded 

name and wanted to know where the name came from.

Response:

LVLP has been around for long time and both CARB and U.S. EPA have been using the “LVLP” 

designation for spray guns for many years. Nonetheless, based on the comment, staff has removed 

the LVLP definition from the originally proposed amended rule, and included a discussion of LVLP 

and several other spray gun variants in the staff report. LVLP spray guns must meet the transfer 

efficiency requirements in clause (d)(6)(A)(iv) or (d)(6)(A)(v) in order to be considered compliant 

with Proposed Amended Rule 1151. 

Comment #6:

The last sentence in the definition for the Single-Stage Coating definition should be stricken. 

The single-stage coating definition does not appear limited enough to exclude various specialty 

coatings that do not use a subsequent clear coat (example: underbody coating). Combined with 

the more restrictive limit, these specialty coatings would be subject to the single stage coating 

limit.

Proposed Amended Rule 1151 3-4 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

Response:

Staff revised the definition by designating “coatings” as “automotive coatings” and clarifying that 

these coatings are specifically labeled and formulated for application without a subsequent clear 

coating and are applied over primer, adhesion promoter, or a color coating. Staff believes that it is

relevant to the definition to keep single-stage metallic/iridescent coatings and will retain the last 

sentence in the definition.

Comment #7:

A copy of the 2007 TBAc technical assessment that was due on July 1, 2007 as shown in the 

December 2, 2005 amendment should be distributed as part of the proposed amendment. 

Response:

The technical assessment that was due on July 1, 2007, pursuant to the definition for VOC 

[paragraph (c)(33)] was not conducted because tertiary butyl acetate containing products were not 

and still are not used for automotive refinishing uses. CEQA staff conducted an offsite analysis on 

TBAc as part of the 2005 amendment and found the estimated carcinogenic risk to be five in one 

million, which is lower than the significance threshold of 10 in one million for CEQA. The 

December 2, 2005 amendment to Rule 1151 included a requirement for a technical assessment on the 

use of TBAc as a non-VOC by July 1, 2007. However, staff did not find any automotive coatings that 

contained TBAc to conduct the review and staff continues to review the issue. Staff proposes to 

incorporate another technical assessment for Rule 1151 with a revised completion date of December 

31, 2016, provided there are automotive coatings that contain TBAc available to conduct the 

assessment.

Comment #8:

If no one is using TBAc why not just remove it from the rule entirely.

Response:

The allowance for TBAc was set in place to provide formulation options to facilitate achievement of 

VOC content limits and meet consumer demands in a flexible manner. See also response to comment 

#7.

Comment #9:

(d)(1) refers to VOC content limit, “...including any VOC material...”. Because the VOC 

content is dependent on as applied, which includes both VOC containing materials and non-VOC 

containing materials, the term “VOC material” should be changed to “material”.

Response:

Staff agrees and paragraph (d)(1) has been revised accordingly.

Proposed Amended Rule 1151 3-5 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

Comment #10:

The first sentence in paragraph (d)(2) reads, in part, “If any representation on information...” but 

it should be changed to read “If any representation on of information...”. In addition, the text 

“supplied by a person” should be removed from the paragraph because it is not necessary.

Response:

Staff incorporated the following revision into paragraph (d)(2) “If any representation on or 

information...”. Replace the word “on” with the word “or”. The text “supplied by a person” 

has been removed.

Comment #11:

The transfer efficiency methods in paragraph (d)(6) should be consistent with other Regulation 

XI rules and include roller and brush methods. Hand application (brush, roller, wipe) should be 

included as part of the compliant methods under the transfer efficiency section (especially for 

components, which can be dip coated or coated with a hand wipe).

Response:

Staff referred to the state Suggested Control Measure (SCM) and found that brush, dip, or roller 

application methods were listed as suggested coating application methods. Therefore, staff will 

include brush, dip and roller application methods to paragraph (d)(6) transfer efficiency to further 

align with the SCM.

Comment #12:

The proposed language for HVLP flow rates is too high. Actual spray gun performance 

represents much lower flow rates for HVLP spray guns. Field verification would be challenging.

Response:

The flow rate values have been removed from the proposed amended HVLP definition. If the spray 

gun manufacturer can demonstrate that a pressure feed spray gun can meet the transfer efficiency 

requirement pursuant to Rule 1151 Paragraph (h)(1)(F) or (h)(1)(G) and these type spray guns 

operate with a air atomization pressure of no more than 10 pounds per square inch at the center of 

the air cap and at the air horns, they would be an acceptable spray gun to apply automotive 

coatings.

Comment #13:

Recordkeeping under (e)(3)(A) would be difficult for upstream distributors and manufacturers 

for tracking coating use as compared to “intended for use” or “specified” or “marketed for use”, 

and the words “as recommended” should be added to (e)(3)(A)(iv)(II) for additional clarity. In 

addition, the requirement to maintain documentation that “a material is a coating” is unclear, and 

the “documentation” itself required for subparagraph (e)(3)(A)(iv)(V) and (f)(1)(E) is also 

Proposed Amended Rule 1151 3-6 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

unclear. A distributor removed from the final sale to an end user may not know or realize that 

the requirements in (e)(3)(A)(iv)(VIII) apply to them.

Response:

The documentation that a material is a coating is to confirm the material was intended for use as an 

automotive coating. Documentation could include the technical data sheets or the MSDS. Subclause 

(e)(3)(A)(iv)(V) and subparagraph (f)(1)(E) has been expanded to refer to manufacturer specification 

sheets, material safety data sheets, technical data sheets or any other air quality data sheets that 

demonstrate that the material is intended for use as an automotive coating The requirements of 

(e)(3)(A)(iv)(VIII) has been updated to limit the applicability to sale to an end user. Staff has also 

incorporated the additional clarifying language related to “intended for use” and “for use” as 

indicated by your comment.

Comment #14:

(e)(3)(A)(i) should be changed from “The automotive coating is located at a ...” to “The 

automotive coating is located for use at a...”. In addition for (e)(3)(A)(iii) the proposed rule 

language shows “The automotive coating is located at a ...” which should be changed to “The 

automotive coating is located for use at a...”. The words “as recommended” should be added to 

(e)(3)(A)(iv)(II) for additional clarity.

Response:

Staff has included the suggested revision to the proposed amended rule.

Comment #15:

The wording of paragraph (g)(2)(A) referring to components can include thinners, reducers, and 

other solvents, although solvents are not defined in the rule. In addition, components do not 

have a coating category. The labeling requirement under (g)(2)(A) for automotive coating 

components to include the applicable use coating categories may be too exhaustive for thinners 

or reducers (which are defined as components).

Response:

In follow up discussions in regard to this topic, staff revised the rule language in subparagraph 

(g)(2)(A) and proposes to add new language to exclude solvents such as reducers and thinners from 

the labeling requirements for identifying automotive coatings or automotive coating component

categories.

Responses to comments after the public workshop

The following comments were made after the public workshop prior to the June 6, 2014,

deadline and staff responses to those comments are shown below.

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Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

Comment #16 {Institute for Research and Technical Assistance}:

I am writing with comments on the proposed changes to Rule 1151 “Motor Vehicle and Mobile 

Equipment Non-Assembly Line Coating Operations.” I am Director of the Institute for Research 

and Technical Assistance (IRTA), an environmental technical nonprofit organization that 

develops and demonstrates low-VOC, low toxicity alternatives, primarily in solvent applications. 

Rule 1151 has included an exemption for tertiary-butyl acetate (TBAC) from VOC regulations 

for many years.

TBAC forms a metabolite, tert-butyl alcohol (TBA), which is a carcinogen. Several years ago, 

the Hazard Evaluation System and Information Service (HESIS) calculated the risk to workers 

using TBAC at the current Occupational Safety and Health Administration (OSHA) PEL of 200 

ppm and provided the results to the California Air Resources Board (CARB). IRTA supplied the 

calculation to the District staff during an earlier proposed modification for SCAQMD Rule 1107. 

The values show that the risk posed to workers when the TBAC level is at the PEL is estimated 

at between 74,000 in one million and 380,000 in one million. The District also has information 

from the Office of Environmental Health Hazard Assessment (OEHHA) stating that OEHHA 

stands by a toxicity evaluation they conducted in 2006 for CARB that concluded TBAC should 

be considered a potential human carcinogen.

SCAQMD Rule 1168 “Adhesive and Sealant Applications” is currently being amended by staff. 

The rule originally included a proposed exemption for TBAC from VOC regulations. Based on 

the recent information from OEHHA and the SCAQMD CEQA staff’s risk calculations for onsite workers, off-site workers and surrounding community members, the proposed exemption 

was removed from the rule. The risk values demonstrated that TBAC poses a high risk in all 

cases. 

In 2005, when Rule 1151 was last amended, the rule included a requirement that the District staff 

perform a technology assessment in 2007 to reassess the risk from TBAC and to determine if the 

exemption was still needed. I am requesting a copy of that assessment. The technology 

assessment that was conducted in 2007 may not have taken into account the OEHHA evaluation 

of TBAC that was available at the time. At this stage, given OEHHA’s recent letter reaffirming 

toxicity of TBAC and the fact that use of the chemical in any application poses a high risk, the 

District should remove the exemption in Rule 1151 during this amendment process.

The exemption in Rule 1151 applies only to auto body primers and the District staff has 

indicated over the last few years that no or very few suppliers rely on TBAC in their coatings. 

Since this is the case, there are clearly non-TBAC primers available to the industry and they are 

apparently widely used. This further demonstrates there is no need for the exemption.

Proposed Amended Rule 1151 3-8 September 2014
Chapter 3: Impact Assessment for Proposed Amended Rule 1151 Final Staff Report

The District’s mission is to protect public health. The exemption for TBAC in Rule 1151 clearly 

does not protect the health of workers who use it or off-site workers and community members 

who are in the vicinity of the operations. I am requesting that the District eliminate the 

exemption from the rule.

Response:

During the rulemaking efforts for the December 2, 2005 rule amendment, CEQA Staff conducted an 

offsite analysis on TBAC and found the estimated carcinogenic risk to be five in one million, which is 

lower than the significance threshold of 10 in one million for CEQA. Staff provided a limited use for 

tertiary Butyl Acetate (TBAc) for the primer category however at that time no known TBAc

containing primers had been identified. The December 2, 2005 amendment for Rule 1151 considered 

TBAc to be a VOC only for color and clear coatings. The purpose of this amendment is 

administrative; it entails the removal of the obsolete rule language in the first part of the rule that 

sunset on June 30, 2008 and clarifications to the existing rule language in Appendix A, which 

continues as the effective portion of the rule.

The technical assessment was to have been conducted by July 1, 2007. However, staff did not find 

any coatings that were formulated with TBAc in order to conduct the assessment. Staff plans to 

conduct a future technical assessment on the continued use of TBAc in automotive coatings, with the 

excluded exception of color and clearing coatings. Staff recently received correspondence from the 

Office of Environmental Health Hazards Assessment (OEHHA) indicating that they intend to 

complete their toxicity review for TBAc towards the end of 2014 or early 2015. Staff proposes to 

incorporate OEHHA finings as part of the technical assessment for Rule 1151 with a revised 

completion date of December 31, 2016, provided there are automotive coatings that contain TBAc 

available to conduct the assessment.

Comment #17 {DeVilbiss Automotive Finishes}:

Thank you for sending me copies of PAR-1151. I have reviewed the proposed changes and have 

one area I would like to offer some input. In the definition section, you have added additional 

info for HVLP.

HIGH-VOLUME, LOW-PRESSURE (HVLP) means spray application equipment that has a 

typical volume flow rate between 30 to 200 cubic feet per minute (cfm), and is designed to 

atomize 100% by air pressure only and operated between 0.1 and 10 pounds per square inch, 

gauge, (psig) air atomizing pressure measured dynamically at the center of the air cap and at the 

air horns.

In this definition, you state that HVLP typical air flow is between 30 to 200 cubic feet per minute 

(CFM). From my experience, this is air flow rate is extremely high. I have reviewed some of our 

test data for various HVLP spray guns, both ones that we manufacture, as well as some of our 

Proposed Amended Rule 1151 3-9 September 2014
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competitors, and have listed this info below. In general, full size HVLP guns have an air flow 

rate between 10 and 20 SCFM and touch HVLP guns have a flow rate between 5 and 10 SCFM. 

I have seen some HVLP set ups use up to 25 SCFM in the past, but anything more than this starts 

to be a lot of air, and most compressors in the body shops would have a problem of maintaining 

the necessary air pressure to maintain the performance.

Perhaps you have pulled this air flow range from manufacturer’s data that make HVLP guns that 

are supplied by air turbines, not shop compressed air. Many years ago, when DeVilbiss had an 

HVLP gun that was supplied by an air turbine, I discovered that many of the manufacturers of air 

turbines had very misleading technical data. They would list the maximum pressure and the 

maximum air flow the air turbine is capable of producing. These ended up being 2 points on a 

graph, the maximum air flow was at zero pressure, and the maximum pressure was a zero air 

flow. The only gun listed below that I have test data on that is supplied by an air turbine was the 

Accuspray 10G. As you can see from this, they are in the typical 10 to 20 SCFM air flow range.

Also, you give the units as cubic feet per minute (CFM). When measuring air flow through a 

spray gun all air flow should be corrected to standard temperature and pressure. The units are 

then SCFM.

I would recommend that the air flow rate for HVLP be changed in the definition of HVLP. 10 to 

20 SCFM would be typical for most full size spray guns. I believe that the definition of LVLP 

would still be valid, as they typically have less air flow than HVLP.

Response:

Staff has revisited the initially proposed new language and proposes to maintain just one compliance 

parameter based on the dynamic air pressure measured at the center of the air cap and at the air 

horns. Staff reviewed several HVLP spray guns and found the volume flow rates typically vary 

between 10 and 15 standard cubic feet per minute (scfm) and has removed the volume flow rate 

values from the proposed amended rule definition. Additionally, Staff has removed the proposed 

definition for Low Volume, Low Pressure (LVLP) from the proposed amended rule and has provided

a detailed discussion of LVLP, Reduced Pressure and Pressure fed spray guns in the Staff Report and 

the transfer efficiency requirements based on the dynamic air pressure measured at the center of the 

air cap and at the air horns.

Comment #18 {SATA GmbH & Co, KG}:

Proposed new definition of “HVLP” atomization technology – as per § (c)(17):

At present, the term “HVLP” is only defined by one parameter, namely dynamic air cap 

PRESSURE of max. 10 psi. With the proposed new definition of the term “HVLP”, a SECOND, 

ADDITIONAL, parameter would be added, i.e. the AIR FLOW RANGE between 30 to 200 cfm.

Proposed Amended Rule 1151 3-10 September 2014
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First consequence: ALL currently existing HVLP SPRAY GUNS used in the collision repair 

industry would become ILLEGAL, If the new “HVLP” definition came into force. Why? –

Because all current HVLP spray guns are operated with max. 15 cfm or less.

Second consequence: Spray guns complying with the new “HVLP” definition would be afflicted 

by a dramatically reduced “Transfer Efficiency (TE) leading to MUCH HIGHER AIR 

POLLUTION. Why? – Because the much higher air flow will lead to much higher overspray 

and consequently to that much lower TE.

Third consequence: ALL collision repair paint materials currently available in the market can no 

longer be applied with spray guns complying with the new “HVLP” definition. Why? – Because 

the application will be extremely dry leading to totally unacceptable, absolutely non-sellable 

finishes, due to the high air flow volume.

Fourth consequence: ALL technical data sheets (TDS) of the paint industry and ALL training 

manuals / training procedures / training certificates of the paint industry as well as of education 

bodies such as I-CAR would become obsolete from one day to the next. Why? – Because ALL 

documentation and procedures will not be in compliance with new “HVLP” term and 

consequently would have to be adapted in the next step.

Addition of “LVLP” atomization technology complementing the new definition of “HVLP” 

atomization technology – as per § (c)(18)”

A newly introduced “LVLP” atomization technology as per proposed definition, i.e. dynamic air 

cap pressure of max. 10 psi and an air flow range of 13.5 to 130 cfm (i.e. 45% to 65% of the 

above 30 to 200 cfm) would WIDELY OVERLAP with the air flow range of the new “HVLP” 

definition.

First consequence: As soon as any “LVLP” labeled gun is operated with more than 15 cfm air 

flow, ALL of the above mentioned four consequences will also become effective.

Second consequence: MOST of the current HVLP spray guns would become illegal. Why? –

Because MOST of the current HVLP spray guns are operated with an air flow which is lower 

than 13.5 cfm.

Approval of use of non- “HVLP” and non- “LVLP” spray guns as they are defined by the new 

proposed RULE 1151 legislation - see § (d)(6)(A)(iv)

Based on the new proposed RULE 1151 legislation, there are currently NO HVLP SPRAY 

GUNS available on the market which can be used as a benchmark for the SCAQMD approval 

process as currently existing and known.

First consequence: There is NO POSSIBILITY to OBTAIN APPROVAL FOR COMPLIANT 

GUNS anymore.

Proposed Amended Rule 1151 3-11 September 2014
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Second consequence: ALL existing COMPLIANT SPRAY GUNS will become ILLEGAL, as 

ALL existing APPROVALS will become INVALID.

Conclusions:

The proposed amendments will cause undue burdens and incalculable risks for

the painters

the bodyshops

the paint manufacturers

the spray gun manufacturers

and SCAQMD as rule-executing and monitoring body.

The proposed amendments will not improve but – on the contrary – will negatively impact on the 

environmental protection, due to higher, not lower pollution.

The proposed amendments will not only affect the SCAQMD mandated area, but ALL other 

mandated areas, counties and states in the USA as well as the national 6H EPA RULE, with the 

SCAQMD approvals being the reference for all other approval processes.

The proposed amendments will also obsolete the current definition of terms “HVLP” and 

“Transfer Efficiency” as currently being used as an official standard terms on a WORLDWIDE 

basis for almost 26 years.

Response:

Please see response to Comment #17.

Comment #19 (a) & (b) {SATA GmbH & Co, KG}:

SATA recommendations in regard to spray guns and coating application:

The current regulations of RULE 1151 in regard to spray guns and coating application must 

basically remain unchanged – as it is an accepted applicable and proven standard in the collision 

repair industry – with two exceptions:

a. The exemptions as listed in (i)(1) should be amended with an additional section (C):

SPOT REPAIR [as defined in (b)(41)].

Reason: The material consumption and the level of pollution created by overspray depend 

primarily on the size of the spot repair area with almost no influence from the spray gun 

employed.

b. The exemptions as listed in (i)(1) should be amended with an additional section (D):

PRESSURE FED SPRAY GUNS FOR COMMERCIAL VEHICLES.

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Reason: The material consumption and the level of pollution created by overspray depend 

primarily on the spraying distance. In addition, there is no affordable and practically working 

device available to monitor and control the material flow pressure on the gun during application. 

These issues are the very reason why it has not been possible to approve any pressure fed spray 

gun according to § (e)(4)(A)(iii).

Response (a):

Eliminating the transfer efficiency requirement for all spot repair operations would be considered 

backsliding on emissions reductions. Both the EPA and CARB have legislation requiring air 

pollution control districts and the air quality management districts to require HVLP application 

equipment for air atomization for all automotive coatings products.The EPA’s Control Techniques 

Guidelines for Automobile and Light-Duty Truck Assembly Coatings and CARB’s the state Suggested 

Control Measure both recommend that the air pollution control districts and air quality management 

districts require transfer efficiency requirements for spray application equipment for all automotive 

coating products. Rule 1151 has had the HVLP requirement for spray guns as far back as the

December 9, 1994, amendment. Spot repair and panel repair operations are the bulk of automotive 

collision repair work in the South Coast Air Basin and this is where the bulk of the VOCs are 

generated by each automotive collision repair shop. Staff believes that regulating spot repair 

operations by requiring high transfer efficient processes is necessary for ongoing VOC reductions.

Response (b):

Staff disagrees because exempting pressure fed spray guns for the transfer efficiency requirements 

that are used for larger scale commercial vehicles like buses, tractor truck and trailers and railcars 

would be considered backsliding on VOC emission reductions. For the reasons explained in staff 

response (a), staff believes the transfer efficiency requirement for pressure fed spray guns is 

necessary for VOC reductions. Furthermore, Rule 1151 has required HVLP as far back as the 

December 9, 1994 amendment when staff introduced HVLP as a significant strategy in the reduction 

of VOC emission sources in the South Coast Air Basin.

Comment #20 {American Coatings Association}:

Since this rule is administrative in nature our comments on the proposed changes are in line with 

this stated purpose. Since the OEHHA review of TBAc is still underway, we agree with 

SCAQMD that this is not the appropriate time to discuss expanding or restricting the existing 

exemption. If SCAQMD intends to expand the scope of the rule to include additional coating 

categories we respectfully request that the established “Cavity Wax” category be considered.

Response:

Staff does not intend to expand the scope of the rule to include additional coating categories as part 

of this amendment, which is primarily administrative and aimed principally to remove obsolete 

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language and rule clarification. Staff amended Rule 1151 on December 2, 2005, to implement the 

state Suggested Control Measure (SCM) for automotive coatings. The EPA issued their Control 

Techniques Guidelines (CTG) for automobile and light duty truck assembly coatings in September 

2008. In that CTG, the EPA provided suggested VOC content limits for several miscellaneous 

coatings which include cavity wax. However, these are suggested VOC content limits for automobile 

and light duty truck assembly coatings, which are conducted in automobile and light duty truck 

manufacturing facilities. Rule 1151 does not apply to automobile and light duty truck assembly 

operations; Rule 1115 – Motor Vehicle Assembly Line Coating Operations specifically applies to this 

type operation. Rule 1151 – Motor Vehicle and Mobile Equipment Non-Assembly Line Coating 

Operations applies to the industry that repairs such vehicle after they have been sold by the 

manufacturers. Staff believes that the underbody coating category effectively captures cavity wax 

type applications and allows a VOC content limit of no more than 430 grams per liter [3.6 pounds 

per gallon] of VOC.

Comment #21 {American Coatings Association}:

In section (a) Purpose, the change from "...from coatings operations associated with the coating 

of motor vehicles...." to "...from coating applications on motor vehicles..." changes the 

applicability of the rule from the coating operation to the coating itself. Historically, SCAQMD 

Rule 1151 has applied to the use of coatings in an auto body shop. This change places the 

requirements of Rule 1151 on the manufacturer of the coating. Although, manufacturers of auto 

refinish coatings often provide training to ensure proper use, it is impossible to ensure these 

products are used as instructed, as body shops are independent from the coatings manufacturer. 

ACA requests that SCAQMD retain the current language “...from coatings operations associated 

with the coatings of motor vehicles...” in the purpose section.

Response:

Please see response to Comment #1.

Comment #22 {American Coatings Association}:

ACA suggests that SCAQMD align the definition of Aerosol Coating Product with the CARB 

Aerosol Products Regulation definition.

Response:

The proposed language has been updated to reflect the updated definition in the consumer products 

regulation.

Comment #23 {American Coatings Association}:

ACA believes that the proposed changes to the automotive coating definition expand the scope 

of the rule and are inconsistent with the state SCM for automotive coatings. For example, 

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terming an automotive coating “any material” could expand the rule to include products that are 

applied and “form a film” but are removed (e.g. car wax). The choice of word “material” could 

be confusing since other jurisdictions (including Sacramento Metropolitan Air Quality 

Management District) have a separate category of “vehicle materials” that include cavity wax, 

gasket sealer, deadener, and lubricating wax. In order to remain consistent with CARB and 

avoid confusion with other jurisdictions ACA suggests that the current definition of “automotive 

coating” remain intact.

Response:

The word material has been removed from the proposed definition for “Automotive Coating”, 

consistent with the SCM.

Comment #24 {American Coatings Association}:

A clear coating may contain pigments, but the pigments do not impart color. Therefore, ACA 

recommends that the definition be revised to read as follows:

“CLEAR COATING means any automotive coating that contains no pigments that impart color that 

is specifically labeled and formulated for application over a color coating or clear coating.”

Response:

Staff had several discussions with stakeholders, including CARB, over the issue that a clear coating 

may have pigments that do not impart color. Staff believes that the added language that the clear 

coating may have pigments that do not impart color does not change the meaning of the definition. 

Therefore staff has revised the proposed language accordingly.

Comment #25 {American Coatings Association}:

The definition of single-stage coating is extremely broad and given the “most restrictive VOC 

limit” requirement the definition should be amended to exclude coatings that may meet the 

definition of a “single-stage coating” but are properly classified under another coating category. 

ACA recommends the definition of single stage coating read as follows: 

“SINGLE STAGE COATING means any pigmented automotive coating, excluding, for example, 

primers, multi-color coatings, and any coatings specifically covered by a defined coating category.”

Response:

Based on discussions with CARB, staff has revised the proposed amended definition for single-stage 

coating as follows:

“SINGLE-STAGE COATING means any pigmented automotive coating, excluding automotive 

adhesion promoters, primers and multi-color coatings, specifically labeled and formulated for 

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application without a subsequent clear coating and are applied over primer, adhesion promoter, or 

a color coating. Single-stage coatings include single-stage metallic/iridescent coatings.”

Comment #26 {American Coatings Association}:

ACA suggests that SCAQMD align the definition of Weld-Through Primer with the CARB 

Aerosol Products rule definition.

Response:

Based on discussions with CARB, staff believes that the definition for Weld-Through Primer from the 

CARB Aerosol Products Regulation is applicable. However, consistent with other comments 

concerning applicability, staff proposes to qualify weld-through primers as those that are used as an 

automotive coating.

Comment #27 {American Coatings Association}:

ACA suggests that the following language be added to section (d)(1): 

“...Compliance with the applicable VOC content limits shall be based on VOC content, 

including any VOC material or non-VOC material (e.g. solids) added to the original automotive 

coating supplied by the manufacturer, less water and exempt compounds, as applied to the motor 

vehicle, mobile equipment or associated parts or component.”

Response:

Please see response to Comment #9.

Comment #28 {American Coatings Association}:

Due to complexities in the distribution chain it is unlikely that a coating manufacturer sells 

automotive coating products directly to the end user (auto body shop). Consequently, the seller 

is not aware of a multitude of provisions that must be met to be in compliance with Rule 1151, 

notably the application method (see section (e)(3)(A)(vi)(II)). ACA also suggests changing the 

language in section (e)(3)(A)(i) & (iii)“...located in a facility...” to “...for use at a facility...” 

ACA would like clarification in the rule language regarding what type(s) of documentation 

would satisfy section (e)(3)(A)(iv)(V).

Response:

The requirements of subparagraph (e)(3)(A) only apply to sales of materials intended for use in the 

District that do not meet the VOC content limits of the rule. Sales of compliant material into the 

District for use in the District are not subject to subparagraph (e)(3)(A). Consistent with other 

SCAQMD VOC rules, the seller is responsible for validating compliant sales, including compliant

sales to end-users, of otherwise non-compliant materials into the District for use in the District. 

Please also see response to Comment #13.

Proposed Amended Rule 1151 3-16 September 2014
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Comment #29 {American Coatings Association}:

ACA suggests that section (g)(2)(A) be amended to read as follows: 

“The manufacturer of automotive coatings or automotive coating components shall include on all 

containers the applicable use category(ies), and the actual and regulatory VOC for automotive

coatings, as supplied (in grams per liter), except solvents, and hardeners. Additionally, Section 

(g)(2)(B) should be amended to include hardeners.

Response:

Staff agrees that subparagraph (g)(2)(A) could benefit from additional clarity and will specifically 

identify the applicable use category(ies) as applicable use automotive category. The revised rule 

language is as follows: “The manufacturer of automotive coatings or automotive coating 

components including hardeners, with the exception of solvents such as reducers and thinners,

shall include on all containers the applicable use automotive coating category, and the actual 

VOC and regulatory VOC content, as supplied (in grams of VOC per liter of material and in 

grams of VOC per liter of material, less water and exempt compounds)”.

Comment #30 {American Coatings Association}:

If SCAQMD intends to expand the scope of the rule to include additional coating categories, 

ACA respectfully requests that the established “Cavity Wax” category be considered. While the 

product may meet the definition of an Underbody Coating because the product is used in/on 

these areas it is not an Underbody Coating. Underbody coatings are meant to resist mechanical 

abrasion as the vehicle is used. Cavity Wax, on the other hand, provides corrosion protection to 

the main parts of the vehicle. The level of corrosion protection cavity wax provides is needed to 

restore a vehicle to its original factory condition.

It is important to note that although a vehicle may be operated in California today (in this case in 

SCAQMD), it may not be there for the life of its operation. Corrosion protection is not only 

critical for outer panels (fenders and doors) but is also important for structural members that 

have been replaced. Failure to properly protect internal sections of welded steel panels subjects 

them to corrosion, which may compromise structure and safety. This is an issue of passenger 

safety and maintaining corrosion protection even if the car leaves California for another 

jurisdiction.

There are aerosol versions of this product covered by the Aerosol Coatings Rule currently 

available in California. The aerosol version of the product does not provide adequate coverage 

for the hard to reach parts of the vehicle that require this type of protection. The aerosol product 

does not provide a 360 degree pattern that the liquid product does. The tool used with the liquid 

product allows the product to cover hard to reach places in the vehicle like frame rails, which are 

imperative to safety. The tool is a long thin hose that can get to hard to reach places of the 

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vehicle and provide a large enough volume to provide corrosion protection. The aerosol version 

cannot do this.

Response:

Please see response to comment #20.

Responses to additional comments after the public workshop

The following additional comments were submitted following the June 6, 2014 deadline and staff 

responses to those comments are shown below.

Comment #31 :

After reading the Rule 1151, version 9, and an intensive discussion with SATA`s independent 

importer in the US (Dan Am, Spring Valley) we do have some comments and suggestions for 

changes in regard to the amended § (c)17, (d)(6)(A) and (d)(6)(A).

A. Page 4, § (c)17 (as presently amended)

High-Volume, Low-Pressure (HVLP means spray application equipment designed to atomize 

100% by air pressure only and is operated between 0.1 and 10 pounds per square inch, gauge, 

(psig) air atomizing pressure measured dynamically at the center of the air cap and at between the 

air horns.

The attached picture shows a test air cap with gauges in the center of the air cap as well in one of 

the horns very close to the horn air outlet bore to measure the internal air cap pressure in the 

center as well in the horns (test air cap commercial available in the market). If the gauge would 

be positioned between the horns as amended, than this gauge would be located in the center of 

the air cap also. With such kind of test air cap nobody would be able to measure the internal air 

cap horn pressure. The gauge have to be still located at the horn.

Therefore this §(c)17 should be remain as before valid and should read: (....) atomizing pressure 

measured dynamically at the center of the air cap and at between the air horns.

Response:

Staff agrees and will revise the definition to show “...measured dynamically at the center of the air 

cap and at the air horns.”

B. Page 10, § (d)(6)(A) (as presently amended)

A person shall not apply automotive coatings to any motor vehicle, mobile equipment or any 

associated parts or components to a motor vehicle or mobile equipment except by the use of one 

of the following methods:

(ii) high-volume, low pressure (HVLP) spray, or

(iv) Spray gun application, provided the owner or operator demonstrates that the spray gun 

meets the HVLP definition in § (c)(17) in design and use. A satisfactory demonstration must be 

based on the manufacturer`s published technical material on the design of the spray gun and by a 

Proposed Amended Rule 1151 3-18 September 2014
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demonstration of the operation of the spray gun using an air pressure tip gauge from the 

manufacturer of the spray gun.

As in (iv) there is no definition for the air pressure tip gauges (where the gauges have to be 

positioned at the air cap) and the demonstration for meeting the HVLP requirements have to be 

done in accordance to §(c)17, we suggest that such kind of air pressure tip gauge have to have a 

gauge in the center as well at the horns of the air cap like in the attached picture. 

Response:

See response to Comment #31A.

C. Page 14, §(d)(6)(A) (as presently amended)

No For the purpose of this rule, no person shall offer for sale, sell, supply, market, offer for sale 

or distribute an HVLP spray gun for use within the SCAQMD unless the person is offering for 

sale, selling, marketing or distributing the HVLP spray gun for use within the SCAQMD 

provides accurate information to the spray gun recipient on the maximum inlet air pressure to the 

spray gun which would result in a maximum air pressure of 10 pounds per square inch gauge 

(psig) air pressure measured dynamically at the center of the air cap and between the air horns 

based on the manufacturer`s published technical material on the design of the spray application 

equipment and by a demonstration of the operation of the spray equipment using an air pressure 

tip gauge from the manufacturer of the gun. The information shall either be permanently marked 

on the gun, or provided on the company’s letterhead or in the form technical literature which 

clearly identifies the spray gun manufacturer, the sales person or the distributor.

In §(e)(3)(B)(5) it is mentioned, the air pressure measured dynamically between the air horns 

like in § (c)17. Like § (c)17 between have to be deleted and at the horns have to be added in this 

§ in the same manner like in (c)17.

It has to be clarified that, (....) and by a demonstration of the operation of the spray equipment 

using an air pressure tip gauge from the manufacturer of the gun. (....), have to be done only via 

the sales or offering persons of the spray gun manufacturer or spray gun dealers but not with the 

end users e.g. painters or body shop owners. If each individual purchase of a spray gun have to be 

guided with a test air cap, that would bring up a very high economic burden for the painters or 

body shop owners. It would be a waste of money, as for testing all guns of a body shop there 

would be need of only one test air cap and not of multiple test air caps.

Response:

See response to Comment #31A.

D. Page 20, §(j)(4)(as presently amended)

The requirements of subparagraph (d)(6)(A) shall not apply to any automotive graphic arts 

operation.

As already suggested in our comments dated June 5th, 2014, this paragraph should extended to 

spot repair as well (spot repair, see (c)(26)). Reason: The material consumption and the level of 

possible pollution created by overspray depend primarily on the size of the spot repair area with 

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almost no influence from the spray gun being employed. Therefore this paragraph should be 

amended as below:

The requirements of subparagraph (d)(6)(A) shall not apply to any automotive graphic arts 

operation and any spot repair.

Response:

Both the EPA Control Techniques Guidelines (CTG) and state Suggested Control Measure (SCM) 

contain the transfer efficiency requirement which does not include an exception for spot repair. The 

SCAQMD is required to be at least as stringent as CARB and EPA but can never be less stringent. 

In addition, the applicability to spot repair is a part of the existing rule requirements and relaxation 

of the requirement would be considered to be backsliding. However, staff has also reviewed the 

allowances for truck bed liners and underbody coatings and has extended the exemption from 

transfer efficiency, consistent with the SCM. 

Comment #32 {Sherwin-Williams}:

These comments are organized in the same manner as the proposed rule and are based on a 

comparison of my comments on the previous draft proposed rule to the current draft.

A. Definitions

Definitions 5 and 7, automotive coating and clear coating, have been revised, consistent with my 

recommendations.

Definitions 15 and 16 have been revised, adding the terms “regulatory VOC” and “actual VOC”, 

which are used elsewhere in the rule and thus, it is helpful to have the terms defined. However, it 

was my understanding from the initial discussions for amending Rule 1113, that the District may 

be going away from the term “regulatory VOC.”

Response:

Those preliminary discussions for Rule 1113 – Architectural Coatings are simply considerations 

until the Board adopts amendments, and specifically include a possible regulatory standard based on 

“Material VOC’ in place of “Regulatory VOC”. This may be a consideration in future rule making 

associated with Rule 1151.

B. I noted that the definition for LVLP, low volume, low vapor pressure, application equipment has 

been removed. Also, the definition for HVLP has been changed and no longer refers to a specific 

volume: do these two changes still allow the use of LVLP equipment, since no specific volume 

is defined for HVLP? 

Response:

LVLP is discussed in detail in the staff report. SCAQMD will consider equivalency (to HVLP) for 

HVLP variants such as LVLP and LVMP provided these variants meet all the transfer efficiency 

requirements in Rule 1151. Please also see response to comment #17.

C. Definition 24 – single stage coating – has been revised and I believe it is now acceptable since it 

specifies that these coatings are applied over adhesion promoters, primers, or color coatings. 

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Thus, there should not be overlap with truck bed liners, underbody coatings, or uniform finish 

coatings. I am uncertain whether there is overlap with multicolor coatings.

Response:

Staff intends to keep the existing language “Single-stage coatings include single-stage 

metallic/iridescent coatings” in the definition for Single-stage Coatings to be consistent with CARB’s 

Suggested Control Measure which also includes this language.

D. Noting that another technical assessment on the use of tBAC is proposed with a completion date 

of December 31, 2016, the question of whether there will be any additional information by then 

arises. Perhaps a later date might be more appropriate to insure the data is complete?

Response:

Staff anticipates an update from OEHHA by the end of this year in regard to significant toxic risk for 

TBAc. Staff will then determine an appropriate course of action to the finding which may include 

extending date of technical assessment.

E. The changes to the definition of weld-through primer are not acceptable. It is my understanding 

that weld-through primers are applied prior to welding, as the previous definition indicated. I 

recommend either return to the previous definition, or include in the definition the concept that 

these coating are applied prior to welding.

Response:

Staff discussed the previous definition for “Weld-Through Primers” with several stakeholders during 

the May 28, 2014, public workshop for PAR 1151. The stakeholders requested PAR 1151 use the 

same definition for “Weld-Through Primers” as the CARB Aerosol Product Regulation. In 

subsequent discussions with CARB staff, SCAQMD rules staff and CARB staff concluded that the 

definition used for “Weld-Through Primers” in the CARB Aerosol Product Regulation was 

appropriate for use in PAR 1151.

F. Requirements

The revision to section (d)(1) is acceptable, with one minor edit to the last sentence: instead of 

this statement:

“Compliance with the applicable VOC content limits shall be based on VOC content, 

including any material added to the original automotive coating supplied by the 

manufacturer, less water and exempt compounds, as applied to the motor vehicle, mobile 

equipment or associated parts and components.”

It would make more sense to say 

“Compliance with the applicable VOC content limits shall be based on VOC content, 

including any material added to the original automotive coating supplied by the 

manufacturer, as applied to the motor vehicle, mobile equipment or associated parts and 

components, less water and exempt compounds.”

Or even 

“Compliance with the applicable VOC content limits shall be based on VOC content, 

including any material added to the original automotive coating supplied by the 

manufacturer, as applied, less water and exempt compounds.”

Proposed Amended Rule 1151 3-21 September 2014
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Response:

The following suggested revision has been incorporated into the proposed amended rule:

“Compliance with the applicable VOC content limits shall be based on VOC content, including any 

material added to the original automotive coating supplied by the manufacturer, as applied, less 

water and exempt compounds.”

G. Section (d) (2) - Most restrictive Limit

Section (d) (2) provides the restriction that when a coating meets more than one definition or is 

recommended to fit more than one coating category, then the lower limit listed must apply. 

However, there are certain exceptions which may be needed: pretreatment coatings and weldthrough primers seem to meet the definition for primers [that is, they provide corrosion 

resistance]: are either of these defined coatings supposed to meet 250 g/l limit for primers?

Response:

Pretreatment primers are required to be specifically labeled and formulated for application directly 

to bare metal surfaces to provide corrosion resistance and adhesion. “Weld-through Primers”, 

although having a stand-alone definition, for the purposes of this rule are considered to be a subset 

of the “Primer” category and subject to the Primer VOC content limit. If a material is specifically 

labeled and formulated for both pretreatment and non-pretreatment primer use, it would be subject 

to the more restrictive limit. Staff does not believe that pretreatment primers would be labeled and 

formulated for use as a non-pretreatment primer.

H. Section (d) (4) – Exempt Compounds

Section (d) (4) needs to be amended to specify automotive coatings. This can be accomplished as 

shown below:

“A person shall not manufacture, sell, offer for sale, distribute for use in the

District, or apply any automotive coating which contains any Group II Exempt

Compounds as defined in Rule 102.”

Response:

Staff has included the suggested revision to the proposed amended rule.

I. Section (e) (3) (A) – Prohibition of Sale of Noncompliant Coatings

Section (e) (3) (A) (iv) (VIII) prohibits the sale of noncompliant coatings unless certain 

provisions are met. Subpart (iv) (VIII) provides the requirements when sale is to an end user. It 

requires the name and address of the person receiving the noncompliant automotive coating and 

the basis upon which the sale is being made, and a statement that the statement made by the end 

user about this basis is correct. This paragraph could be clarified by removing the supply and 

distribution concepts: it should be sufficient to simply cover “for sale to end users.” [In addition, 

receiving was spelled incorrectly.]

Response:

Staff has included the suggested revision to the proposed amended rule.

J. Section (f) (1) (E) – Recordkeeping

Section (f) (1) (E) covers recordkeeping and still requires we provide documentation that 

demonstrates the material is an automotive coating. The documentation listed may state that a 

coating is an automotive coating, or may imply it by the directions for use. However, such 

Proposed Amended Rule 1151 3-22 September 2014
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documentation will not really demonstrate that a coating is an automotive coating. Perhaps 

changing the word “demonstrate” to “states” would clarify the meaning of this paragraph, as 

follows:

“Documentation such as manufacturer specification sheets, material safety data sheets, 

technical data sheets, or any other air quality data sheets that demonstrate indicate that the 

material is intended for use as an automotive coating or solvent”

Response:

Staff has included the suggested revision to the proposed amended rule.

Comment #33 {American Coatings Association}:

A. In the Clear Coating definition, it makes no sense to put a clear over a clear. By changing the 

definition to a “base” coating, you now could put this over a primer which in not necessarily 

considered a color coating. ACA recommends the following change:

“CLEAR COATING means any automotive coating that contains no pigments is formulated with 

materials that do not impart color and is specifically labeled and formulated for application over 

a color coating or clear base coating.”

Response:

Other stakeholders also had concerns that a clear coat wasn’t meant to be applied over a clear coat 

with the possible exception of applying a clear over a properly prepared weathered clear coat for 

restoration purposes. Staff revised the definition for clear coating as follows:

“CLEAR COATING means any automotive coating that is formulated with materials that do not 

impart color and is specifically labeled and formulated for application over a color coating or clear 

coating.”

Staff believes the current definition for a clear coating captures the intent of what a clear coating is 

used for. The original definition for “Clear Coating” in Rule 1151 was mirrored from CARB’s State

the state Suggested Control Measure, as approved by their Board on October 20, 2005, and since 

then all the other Air Pollution Control Districts and Air Quality Management Districts in the state 

of California have been using the same or similar definition.

B. Under the definition of VOC, TBAc is not a VOC when used in automotive coatings other than 

color coatings and clear coatings. However, under the proposed recordkeeping requirements 

(f)(1)(D) VOC, actual and regulatory, for the automotive coating, for the purposes of 

recordkeeping, TBAc shall be considered a VOC for any automotive coating and TBAc shall be 

included in the VOC, actual and regulatory, for the automotive coating. The way this is phrased, 

it would bring primers, and all other categories back into treating TBAc as a VOC. ACA 

recommends the following change: 

“...TBAc shall be considered a VOC for any automotive coating refinish color coating and clear 

coating and TBAc shall be included in the VOC, actual and regulatory, for the automotive 

coating refinish color coating and clear coating.”

Proposed Amended Rule 1151 3-23 September 2014
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Response:

Staff has removed the recordkeeping requirement for TBAc as a VOC to subparagraph (f)(1)(D) of 

the proposed amended rule based on a follow-up review of EPA’s evaluation for the 2005 

amendment to the rule.

C. Also in the recordkeeping section, under prohibition of sale (see page 13), ACA noted that 

recordkeeping is being expanded from “...the person that offers for sale, or distributes...” to 

“...the person that supplies, sells, offers for sale, markets, blends, repackages, or distributes...” 

This could impact distribution down the entire supply chain. In particular, inclusion of the term 

“repackages” could draw in toll processors who might be hired to fill small containers from bulk 

packages supplied by a coating manufacturer. In that case the toll company would likely be 

operating under an air permit and their operation is not dependent on whether the product to be 

repackaged is refinish, deco, AIM, etc. Unless such an operation is “selling” directly to 

customers (wholesalers or body shops) which is unlikely, they are simply a toll processor and 

should not be covered under the refinish rule.

Response:

Please see response to Comment #28.

Proposed Amended Rule 1151 3-24 September 2014
References Final Staff Report

REFERENCES

SCAQMD Staff Report, Proposed Rule 1151 – Motor Vehicle and Mobile Equipment NonAssembly Line Coating Operations, December 2005

Websites:

DeVilbiss Automotive Refinishing

http://www.autorefinishDeVilbiss.com/aboutus.aspx

Sata GmbH & Co., KG

http://www.sata.com/index.php?id=rppistolen&L=11

Sharpe

http://www.sharpe1.com/sharpe/sharpe.nsf/Page/RAZOR+LVLP

Spray Gun World

http://www.spraygunworld.com/products/DeVilbiss/Compacts/CompactCViPOutifts.html

Spray Painting

http://en.wikipedia.org/wiki/Spray_painting

The History of Spray guns

http://www.bodyshopbusiness.com/issue/article.aspx?contentid+4109

Electrostatic Paint Application

http://spraygunindustry.com/Information2/Electro%20Static/Electrostatic%20Start.html

http://www.hppindustrialsales.com/pages/accessa.asp

Proposed Amended Rule 1151 R-1 September 2014