Bay Area Air Quality Management District August 5, 2009 

 8-32-1 

REGULATION 8 

ORGANIC COMPOUNDS 

RULE 32 

WOOD PRODUCTS COATINGS 

INDEX 

8-32-100 GENERAL 

8-32-101 Description 

8-32-110 Deleted October 6, 1993 

8-32-111 Exemption, Non-commercial and Small Coating Operations 

8-32-112 Exemption, Specific Operations 

8-32-113 Exemption, Refinishing, Replacement and Custom Replica Furniture Operations 

8-32-114 Exemption, Stencil Coatings 

8-32-115 Exemption, Specific Finishes 

8-32-116 Exemption, Musical Instruments 

8-32-117 Limited Exemption, Polyester Resin Application 

8-32-118 Exemption, Patternmaking 

8-32-119 Limited Exemption, Extreme Environmental Conditions 

8-32-120 Recordkeeping Exemption, Low VOC Facilities 

8-32-200 DEFINITIONS 

8-32-201 Air Assisted Airless Spray 

8-32-202 Airless Spray 

8-32-203 Binders 

8-32-204 Clear Sealer 

8-32-205 Clear Topcoat 

8-32-206 Single Application Conversion Varnish 

8-32-207 Crackle Lacquer 

8-32-208 Custom Architectural Millwork 

8-32-209 Custom Cabinetry 

8-32-210 Custom Furniture 

8-32-211 Custom Replica Furniture 

8-32-212 Detailing or Touch-up Guns 

8-32-213 Electrostatic Air Spray 

8-32-214 Extreme Environmental Conditions 

8-32-215 Faux Finish 

8-32-216 Filler 

8-32-217 General Wood Products 

8-32-218 High-Solids Coating 

8-32-219 High Volume Low Pressure (HVLP) Spray 

8-32-220 Imitation Wood Grain 

8-32-221 Key System Operating Parameter 

8-32-222 Leaf Finish 

8-32-223 Low-Solids Coating 

8-32-224 Multi-colored Coating 

8-32-225 Pigmented Coatings 

8-32-226 Pigmented Primer, Sealer and Undercoater 

8-32-227 Pigmented Topcoat 

8-32-228 Sanding Sealer 

8-32-229 Solvent Cleaning Operation 

8-32-230 Stain 

8-32-231 Surface Preparation 
Bay Area Air Quality Management District August 5, 2009 

 8-32-2 

8-32-232 Toner 

8-32-233 Transfer Efficiency 

8-32-234 Volatile Organic Compound (VOC) 

8-32-235 Wash Coat 

8-32-236 Wood Furniture 

8-32-300 STANDARDS 

8-32-301 Spray Application Equipment Limitations 

8-32-302 General Wood Product Limits 

8-32-303 Wood Furniture, Custom Cabinetry and Custom Architectural Millwork Limits 

8-32-304 Custom Furniture Limits 

8-32-305 Prohibition of Specification 

8-32-306 Deleted August 5, 2009 

8-32-307 Alternate Compliance, Section 8-32-302, 303 and 304 

8-32-320 Solvent Evaporative Loss Minimization 

8-32-321 Surface Preparation Standards 

8-32-400 ADMINISTRATIVE REQUIREMENTS 

8-32-401 Deleted April 17, 1991 

8-32-402 Deleted June 19, 1996 

8-32-403 Extreme Environmental Conditions Petition 

8-32-404 Alternate Compliance Petition and Approval 

8-32-405 Low-VOC Facility Certification 

8-32-406 Labeling Requirements 

8-32-407 Compliance Statement 

8-32-408 Formaldehyde Emissions Information Requirement 

8-32-500 MONITORING AND RECORDS 

8-32-501 Recordkeeping Requirements 

8-32-502 Refinishing, Replacement and Custom Replica Furniture Operations Recordkeeping 

Requirements 

8-32-503 Custom Furniture, Custom Architectural Millwork, and Custom Cabinetry Recordkeeping 

Requirements 

8-32-600 MANUAL OF PROCEDURES 

8-32-601 Analysis of Samples 

8-32-602 Determination of Emissions Control Efficiency 

8-32-603 Emissions Averaging Procedure 

8-32-604 Calculation of Grams of VOC per liter for Low Solids Coatings 

8-32-605 Calculation of Grams of VOC per liter for High Solids Coatings 

8-32-606 Calculation of Grams of VOC per gram of solids for High Solids Coatings 

8-32-607 Determination of Coating Transfer Efficiency 
Bay Area Air Quality Management District August 5, 2009 

 8-32-3 

REGULATION 8 

ORGANIC COMPOUNDS 

RULE 32 

WOOD PRODUCTS COATINGS 

(Adopted September 21, 1983) 

8-32-100 GENERAL 

8-32-101 Description: The purpose of this Rule is to limit emissions of volatile organic compounds 

from the coating of wood products, including surface preparation, application of coatings, 

and cleanup. 

(Amended 4/17/91; 8/5/09) 

8-32-110 Deleted October 6, 1993 

8-32-111 Exemption, Non-commercial and Small Coating Operations: This Rule shall not apply 

to residential non-commercial operations or to facilities that use a total of less than 20 

gallons of coating per year. 

(Adopted 4/17/91; Amended 8/5/09) 

8-32-112 Exemption, Specific Operations: The provisions of this Rule shall not apply to the 

following specific coating operations: 

112.1 Coatings and adhesives applied to Flatwood Paneling and Wood Flat Stock subject 

to the provisions of Regulation 8, Rule 23. 

112.2 Coating applied to stationary structures and their appurtenances subject to the 

provisions of Regulation 8, Rule 3. 

112.3 Coating applied from aerosol cans subject to the provisions of 17 California Code of 

Regulations, commencing at §94520. 

112.4 Adhesive coating subject to the provisions of Regulation 8, Rule 51. 

(Adopted 4/17/91; Amended 11/18/92; 8/5/09) 

8-32-113 Exemption, Refinishing, Replacement and Custom Replica Furniture Operations: The 

provisions of Sections 8-32-302, 303, 304, 305 and 501 shall not apply to: any refinishing 

operation necessary for preservation of a wood product or, to return a wood product to its 

original condition; to the production of custom furniture to replace missing items from a 

matching set; or to the production of custom replica furniture. 

(Adopted 4/17/91; Amended 6/19/96; 8/5/09) 

8-32-114 Exemption, Stencil Coatings: The provisions of this Rule shall not apply to the application 

of coatings by template in order to add designs, letters or numbers to products. The 

application of stencil coatings is subject to the provisions of Regulation 8, Rule 4. 

(Adopted April 17, 1991) 

8-32-115 Exemption, Specific Finishes: The provisions of Sections 8-32-301, 302, 303, and 304 

shall not apply to coatings used to produce the following finishes, provided records are 

maintained as specified in Section 8-32-501: 

115.1 Crackle lacquers 

115.2 Leaf finishes 

115.3 Faux finishes 

115.4 Imitation wood grain 

 The application of coatings used to produce these specific finishes is subject to the 

provisions of Regulation 8, Rule 4. 

(Adopted 4/17/91; Amended 6/19/96) 

8-32-116 Exemption, Musical Instruments: The provisions of this Rule shall not apply to the 

application of coatings to musical instruments. 

(Adopted April 17, 1991) 

8-32-117 Limited Exemption, Polyester Resin Application: The application of polyester resin with 

a VOC content of less than 120 grams VOC per liter (1.0 pound VOC per gallon) shall be 

exempt from the spray application equipment limitations of Section 8-32-301. 

(Adopted 4/17/91; Amended 8/5/09) 

8-32-118 Exemption, Patternmaking: The provisions of this Rule shall not apply to the application 

of coating to wood patterns used as tooling for the foundry industry. The application of 

such coating is subject to the provisions of Regulation 8, Rule 4. 

(Adopted June 19, 1996) 
Bay Area Air Quality Management District August 5, 2009 

 8-32-4 

8-32-119 Limited Exemption, Extreme Environmental Conditions: Any wood product that will be 

subject to extreme environmental conditions shall be exempt from the requirements of 

Section 8-32-302, provided that the requirements of Section 8-32-304 and Section 8-32-403 

are satisfied. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-120 Recordkeeping Exemption, Low VOC Facilities: Any facility subject to this Rule, in 

which only low VOC coatings thinned exclusively with water are stored and used shall be 

exempt from sections 8-32-501.2, 501.4, 502.2, 502.3, and 503. For the purposes of this 

exemption, low-VOC coatings are high-solids coatings with a VOC content as calculated in 

8-32-605 of no more than 275 grams per liter (2.3 lb/gal), as applied (after thinning), and 

low-solids coatings with a VOC content as calculated in 8-32-604 of no more than 120 

grams per liter (1.0 lb/gal), as applied (after thinning). This exemption shall apply only if the 

requirements of Section 8-32-405 are satisfied. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-200 DEFINITIONS 

8-32-201 Air Assisted Airless Spray: Equipment used to apply coatings that uses fluid pressure to 

atomize the coating and air pressure between 0.1 and 50 psig to adjust the spray pattern. 

(Adopted 4/17/91; Amended 7/6/94; Amended and Renumbered 8/5/09) 

8-32-202 Airless Spray: Equipment used to apply coatings by use of fluid pressure without 

atomizing air, including heated airless spray. 

(Adopted 4/17/91; Renumbered 8/5/09) 

8-32-203 Binders: Non-volatile polymeric organic materials (resins) that form surface film in coating 

applications. 

(Amended and Renumbered August 5, 2009) 

8-32-204 Clear Sealer: A coating containing binders, but not opaque pigments, that seals the wood 

prior to application of, and provides a sandable surface for, the subsequent coatings. 

(Adopted August 5, 2009) 

8-32-205 Clear Topcoat: A final coating that contains binders, but not opaque pigments, and is 

formulated to form a transparent or translucent solid protective film. 

(Amended and Renumbered August 5, 2009) 

8-32-206 Single Application Conversion Varnish: A coating comprised of an alkyd or other resin 

blended with amino resin in a homogeneous liquid that, when acid-catalyzed and applied, 

hardens upon exposure to air or heat, by evaporation and polymerization, to form a 

continuous film that imparts protective or decorative properties to wood surfaces. This 

conversion varnish is used as a combined sealer and topcoat in one coating application. 

(Adopted August 5, 2009) 

8-32-207 Crackle Lacquer: A clear or pigmented topcoat designed to shrink and crack as it dries, 

creating a cracked or crazed appearance. 

(Adopted 4/17/91; Amended and Renumbered 8/5/09) 

8-32-208 Custom Architectural Millwork: Shop-finished wood products including custom designed 

interiors, the production of which is generally subject to North American Industry 

Classification System code 337212, which are intended for use as architectural 

components including panels, doors and trim and are individually produced items designed 

for a specific space and client. Custom trade show exhibits designed for a specific client 

shall be considered custom architectural millwork. 

(Adopted 4/17/91; Amended 6/19/96; Amended and Renumbered 8/5/09) 

8-32-209 Custom Cabinetry: Shop-finished wood products including cabinets, vanities and 

countertops, the production of which is generally subject to North American Industry 

Classification System code 337110, and which are individually produced items designed for 

a specific space and client. 

(Adopted August 5, 2009) 

8-32-210 Custom Furniture: Wood furniture individually designed and produced to order for a 

specific space and client as ordered by that client or a professional architect or designer. 

(Adopted 6/19/96; Amended and Renumbered 8/5/09) 

8-32-211 Custom Replica Furniture: Wood furniture individually produced for a specific client using 

methods of construction including materials, joinery and finishes authentic to the period and 

in keeping with the style of furniture. 

(Adopted 4/17/91; Amended and Renumbered 8/5/09) 
Bay Area Air Quality Management District August 5, 2009 

 8-32-5 

8-32-212 Detailing or Touch-up Guns: Small air spray equipment, including air brushes, that 

operates at no greater than 5 cfm air flow and no greater than 50 psig air pressure and is

used to coat small products or portions of furniture. 

(Adopted 4/17/91; Amended and Renumbered 8/5/09) 

8-32-213 Electrostatic Air Spray: Equipment used to apply coating by charging atomized particles 

that are deposited by electrostatic attraction. 

(Adopted 4/17/91; Renumbered 8/5/09) 

8-32-214 Extreme Environmental Conditions: Any of the following conditions to which a surfacecoated wood product may be exposed during its intended use: 

214.1 Repeated heavy abrasion, mechanical wear, or abrasive agents; 

214.2 Temperature extremes significantly in excess of normal ambient conditions; 

214.3 Chronic exposure to corrosive, caustic or acidic chemicals, solutions or agents. 

(Adopted 6/19/96; Amended and Renumbered 8/5/09) 

8-32-215 Faux Finish: A finish intended to simulate a surface other than wood, including stone, 

sand, slate, marble, metal, metal flake or leather. 

(Adopted 4/17/91; Renumbered 8/5/09) 

8-32-216 Filler: A material whose primary function is to fill voids. 

(Adopted 4/17/91; Renumbered 8/5/09) 

8-32-217 General Wood Products: Surface coated wooden objects for general sales to multiple 

customers, the production of which is generally subject to North American Industry 

Classification System codes 321911, 321918, 321999, 337110, 337129, and 337215, 

including cabinets, vanities, shutters, containers, frames, tools and ladders made of solid 

wood, wood composition or wood material, but excluding Wood Furniture, Custom 

Cabinetry, Custom Architectural Millwork and Custom Furniture. 

(Adopted 4/17/91; Amended 6/19/96; Amended and Renumbered 8/5/09) 

8-32-218 High-Solids Coating: A coating that contains at least 120 grams solids per liter (one 

pound solids per gallon) of coating. High-Solids Coating VOC content shall be calculated 

by excluding water and exempt compounds in accordance with Section 8-32-605 or 606. 

 (Amended 4/17/91, 6/19/96; Amended and Renumbered 8/5/09) 

8-32-219 High-Volume, Low-Pressure (HVLP) Spray: Equipment used to apply coatings by means 

of a gun that operates between 0.1 and 10 atomizing psig air pressure measured 

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

(Adopted 4/17/91; Amended 10/6/93; Amended and Renumbered 8/5/09) 

8-32-220 Imitation Wood Grain: A hand-applied finish that simulates the appearance of a specific 

natural wood grain. 

(Adopted 4/17/91; Renumbered 8/5/09) 

8-32-221 Key System Operating Parameter: An air pollution abatement equipment operating 

parameter, such as temperature, flow rate or pressure, that indicates whether operation of 

the abatement equipment is within manufacturer specifications and/or in compliance with 

the standards in Sections 8-32-302, 303, and 304. 

(Adopted 6/15/94; Amended 6/19/96; Amended and Renumbered 8/5/09) 

8-32-222 Leaf Finish: A finish used in conjunction with metal leaf or foil. 

(Adopted April 17, 1991) 

8-32-223 Low-Solids Coating: A coating that contains less than 120 grams solids per liter (1 pound 

solids per gallon) of coating. Low Solids Coating VOC content shall be calculated by 

including water and exempt compounds in the volume in accordance with Section 8-32-604. 

(Amended 4/17/91, 6/19/96; Amended and Renumbered 8/5/09) 

8-32-224 Multi-Colored Coating: A coating that is packaged in a single container and that is 

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

(Adopted August 5, 2009) 

8-32-225 Pigmented Coatings: Opaque coatings that contain binders and colored pigments and 

are formulated to hide the wood surface, either as an undercoat or topcoat. 

(Amended and Renumbered 8/5/09) 

8-32-226 Pigmented Primer, Sealer, and Undercoater: An opaque coating that contains binders 

and colored pigments formulated to hide the wood surface, that is applied prior to the 

topcoat to provide a firm bond, level the wood product surface, or seal the wood product 

surface. 

(Adopted August 5, 2009) 

8-32-227 Pigmented Topcoat: A final opaque coating that contains binders and colored pigments,

and is formulated to hide the wood surface and form a solid protective film. 

(Adopted August 5, 2009) 
Bay Area Air Quality Management District August 5, 2009 

 8-32-6 

8-32-228 Sanding Sealer: A high-solids wood coating containing binders formulated for application 

to bare wood to seal the wood prior to application of, and provide a sandable surface for 

subsequent coatings. 

(Amended 4/17/91; Amended and Renumbered 8/5/09) 

8-32-229 Solvent Cleaning Operation: The removal of uncured adhesives, inks, coatings, and 

contaminants including: dirt, soil, and grease from parts, products, tools, machinery, 

equipment, and general work areas. 

(Adopted August 5, 2009) 

8-32-230 Stain: A transparent or semitransparent solution or suspension of dyes or pigments 

formulated to enhance wood grain and change wood color without concealing the surface 

grain pattern or texture. 

(Adopted August 5, 2009) 

8-32-231 Surface Preparation: The cleaning of surfaces prior to coating, further treatment, sale, or 

intended use. Solvent cleaning operations subject to and in compliance with Regulation 8, 

Rule 16: Solvent Cleaning Operations, are not subject to this Rule. 

(Adopted August 5, 2009) 

8-32-232 Toner: A wash coat that contains binders and dyes or pigments to add tint to a coated 

surface. 

(Adopted August 5, 2009) 

8-32-233 Transfer Efficiency: The ratio of the weight of coating solids deposited on an object to the 

total weight of coating solids used in a coating application step, expressed as a percentage. 

(Amended 4/17/91; Renumbered 8/5/09) 

8-32-234 Volatile Organic Compound (VOC): Any organic compound (excluding methane, carbon 

monoxide, carbon dioxide, carbonic acid, metallic carbides, metallic carbonates and 

ammonium carbonate) that would be emitted during use, application, curing or drying of a 

solvent or coating. 

234.1 For purposes of calculating the VOC content of a high solids coating, any water or 

the following compounds: 

acetone 

parachlorobenzotrifluoride (PCBTF) 

cyclic, branched or linear, completely methylated siloxanes (VMS) 

shall not be considered a part of the coating. High solids coating VOC content is 

calculated as specified in 8-32-605 or 606. 

234.2 For purposes of calculating the VOC content of a low solids coating or solvent, any 

water or any of the non-precursor organic compounds listed in section 8-32-234.1, 

shall be considered part of the volume, but shall not be considered part of the VOC 

content of the coating or solvent. Low solids coating VOC content is calculated as 

specified in 8-32-604. 

(Adopted 4/17/91; Amended 12/20/95, 6/19/96; Amended and Renumbered 8/5/09) 

8-32-235 Wash Coat: A low-solids coating, containing binders, that penetrates into and seals wood, 

prevents undesired staining and seals in wood pitch. 

(Amended 4/17/91; Amended and Renumbered 8/5/09) 

8-32-236 Wood Furniture: Surface-coated wooden room furnishings for general sales to multiple 

customers, the production of which is generally subject to North American Industry 

Classification System codes 337121, 337122, 337125, 337127, and 337211 including 

tables, chairs, beds, sofas, dressers and standing screens, made of solid wood, wood 

composition or wood material. 

(Amended 4/17/91; Amended and Renumbered 8/5/09) 

08-32-300 STANDARDS 

8-32-301 Spray Application Equipment Limitations: Any person who utilizes spray application 

equipment to apply coatings to wood products shall use one or more of the following 

application methods: 

Airless spray 

Air assisted airless spray 

High Volume Low Pressure (HVLP) spray 

Electrostatic air spray 

Detailing or Touch-up Guns 
Bay Area Air Quality Management District August 5, 2009 

 8-32-7 

Other coating application methods demonstrated to the APCO to be capable of 

achieving at least 65 percent transfer efficiency as determined by the test method 

cited in 8-32-607, and for which written approval by the APCO has been obtained. 

(Amended 4/17/91; 8/5/09) 

8-32-302 General Wood Product Limits: No person shall apply to any general wood product, any 

coating with a VOC content in excess of the limits set forth below; expressed as grams 

VOC per liter (pounds VOC per gallon) of coating or grams VOC per gram of solids, as 

applied (after thinning), unless emissions to the atmosphere are controlled to an equivalent 

level by air pollution abatement equipment with an abatement device efficiency of at least 

85 percent that meets the requirements of Regulation 2, Rule 1. 

 Effective 

July 1, 1995 

Effective 

July 1, 2010 

 VOC limit 

g/l (lb/gal)

VOC limit 

g/l (lb/gal)

VOC limit 

g/g solids

Clear Sealer 275 (2.3) 0.36 

Clear Topcoat 275 (2.3) 275 (2.3) 0.35 

Sanding Sealer 550 (4.6) See clear or pigmented sealers 

Pigmented Coating 275 (2.3) See pigmented sealers or topcoats 

Pigmented Primer, Sealer 

and Undercoater 275 (2.3) 0.21 

Pigmented Topcoat 275 (2.3) 0.25 

High Solids Stain 700 (5.8) 350 (2.9) 0.42 

Filler 500 (4.2) 275 (2.3) 0.18 

Low Solids Stain* 480 (4.0) 120 (1.0) - 

Low Solids Toner and 

Wash-coat* 480 (4.0) 120 (1.0) - 

*Low-Solids Coatings VOC content is calculated including water and exempt compounds as set forth in Section 8-

32-604. High-Solids Coatings VOC content is calculated excluding water and exempt compounds as set forth in 

Sections 8-32-605 and 8-32-606.

 A person applying a coating subject to the standards effective July 1, 2010 will comply with 

this Section if the coating satisfies either of the alternative standards. Application of a 

coating exceeding one of the alternative standards applicable to that coating shall create a 

rebuttable presumption that the coating was applied in violation of this Section. The 

applicator may rebut the presumption of violation by demonstrating that the coating satisfies 

the other alternative standard. 

(Deleted 4/17/91; Re-adopted 6/19/96; Amended 8/5/09) 

8-32-303 Wood Furniture, Custom Cabinetry and Custom Architectural Millwork Limits: No 

person shall apply to any wood furniture, custom cabinetry or custom architectural millwork, 

any coating with a VOC content in excess of the limits set forth below; expressed as grams 

VOC per liter (pounds VOC per gallon) of coating or grams VOC per gram of solids, as 

applied (after thinning), unless emissions to the atmosphere are controlled to an equivalent 

level by air pollution abatement equipment with an abatement device efficiency of at least 

85 percent that meets the requirements of Regulation 2, Rule 1. 

 Effective 

Sept 1, 1996 

Effective 

July 1, 2010 

 VOC Limit 

g/l (lb/gal)

VOC Limit 

g/l (lb/gal)

VOC Limit 

g/g solids

Clear Sealer 275 (2.3) 0.36 

Clear Topcoat 550 (4.6) 275 (2.3) 0.35 

Single Application 

Conversion Varnish ** 550 (4.6) 0.36 
Bay Area Air Quality Management District August 5, 2009 

 8-32-8 

Sanding Sealer 550 (4.6) See clear or pigmented sealers 

Pigmented Coating 550 (4.6) See pigmented sealers or topcoats 

Pigmented Primer, Sealer 

and Undercoat 275 (2.3) 0.21 

Pigmented Topcoat 275 (2.3) 0.25 

Multi-colored Coating 275 (2.3) 0.33 

High Solids Stain 700 (5.8) 350 (2.9) 0.42 

Filler 500 (4.2) 275 (2.3) 0.18 

Low Solids Stain* 480 (4.0) 120 (1.0) - 

Toner and Wash-coat* 480 (4.0) 120 (1.0) - 

*Low-Solids Coatings VOC content is calculated including water and exempt compounds as set forth in Section 8-

32-604. High-Solids Coatings VOC content is calculated excluding water and exempt compounds as set forth in 

Sections 8-32-605 and 8-32-606.

**If more than one coating application is used, each sealer application must comply with the sealer VOC limits, and 

each topcoat application must comply with the topcoat VOC limits.

A person applying a coating subject to the standards effective July 1, 2010 will comply with 

this Section if the coating satisfies either of the alternative standards. Application of a 

coating exceeding one of the alternative standards applicable to that coating shall create a 

rebuttable presumption that the coating was applied in violation of this Section. The 

applicator may rebut the presumption of violation by demonstrating that the coating satisfies 

the other alternative standard. 

 (Adopted 4/17/91; Amended 10/6/93; 7/6/94; 6/19/96; 8/5/09) 

8-32-304 Custom Furniture Limits: No person shall apply to any custom furniture any coating with 

a VOC content in excess of the limits set forth below; expressed as grams VOC per liter 

(pounds VOC per gallon) of coating or grams VOC per gram of solids, as applied (after 

thinning), unless emissions to the atmosphere are controlled to an equivalent level by air 

pollution abatement equipment with an abatement device efficiency of at least 85 percent 

that meets the requirements of Regulation 2, Rule 1. 

 Effective 

July 1, 1997 

Effective 

July 1, 2010 

 VOC Limit 

g/l (lb/gal)

VOC Limit 

g/l (lb/gal)

VOC Limit 

g/g solids

Clear Sealer 275 (2.3) 0.36 

Clear Topcoat 550 (4.6) 550 (4.6) 0.36 

Sanding Sealer 550 (4.6) See clear or pigmented sealers 

Pigmented Coating 550 (4.6) See pigmented sealers or topcoats 

Pigmented Primer, Sealer 

and Undercoat 275 (2.3) 0.21 

Pigmented Topcoat 275 (2.3) 0.25 

Multi-colored Coating 275 (2.3) 0.33 

High Solids Stain 700 (5.8) 350 (2.9) 0.42 

Filler 500 (4.2) 275 (2.3) 0.18 

Low Solids Stain* 480 (4.0) 120 (1.0) - 

Toner and Wash-coat* 480 (4.0) 120 (1.0) - 
Bay Area Air Quality Management District August 5, 2009 

 8-32-9 

*Low-Solids Coatings VOC content is calculated including water and exempt compounds as set forth in Section 8-

32-604. High-Solids Coatings VOC content is calculated excluding water and exempt compounds as set forth in 

Sections 8-32-605 and 8-32-606.

A person applying a coating subject to the standards effective July 1, 2010 will comply with 

this Section if the coating satisfies either of the alternative standards. Application of a 

coating exceeding one of the alternative standards applicable to that coating shall create a 

rebuttable presumption that the coating was applied in violation of this Section. The 

applicator may rebut the presumption of violation by demonstrating that the coating satisfies 

the other alternative standard. 

 (Adopted 4/17/91; Amended 10/6/93; 7/6/94; 6/19/96; 8/5/09) 

8-32-305 Prohibition of Specification: No person shall require the use of or specify the application 

of a coating subject to this Rule if such use or application results in a violation of any of the 

provisions of this Rule. The prohibition of this Section shall apply to all written or oral 

contracts under the terms of which any coating is to be applied to any wood product at any 

physical location within the District. 

(Adopted 4/17/91; Amended 11/2/94; 8/5/09)

8-32-306 Deleted August 5, 2009 

8-32-307 Alternate Compliance, Section 8-32-302, 303 and 304: Upon written authorization as 

provided for in Section 8-32-404, a person may establish compliance with Section 8-32-

302, 303 or 304 by averaging the VOC emissions of any or all coatings and solvent usage 

related directly to the coating of wood products. Compliance must be demonstrated by 

averaging coatings used daily. Facilities must limit VOC emissions, when averaged, to 

10% less than the VOC emissions of compliant coatings. The procedure for averaging 

coatings to determine compliance with this provision is specified in 8-32-603. 

307.1 Any emissions reductions credited to this plan must not be the result of emissions 

reduced due to violation of any District rule, or to achieve compliance with a 

provision of this rule at the effective date of that provision. Reductions achieved 

prior to the effective date of any standards in this rule may be used until the 

effective date. 

307.2 Any emissions reductions shall not be used as credit pursuant to Regulation 2, 

Rule 4 or as contemporaneous offsets pursuant to Regulation 2, Rule 2. 

307.3 No emissions reductions shall be credited for organic compounds that are adopted 

as compounds exempt from the Determination of VOC Content as calculated in 

Section 8-32-604 or 605 if those compounds are present in the coatings or solvents 

used at the facility prior to the date the compound becomes exempt. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-320 Solvent Evaporative Loss Minimization: Unless emissions to the atmosphere are 

controlled by an approved emission control system with an overall abatement efficiency of 

at least 85%, any person using organic solvent for surface preparation and/or cleanup in 

connection with coating of wood products, and any person mixing, using or disposing of 

coating, adhesive or stripper containing organic solvent in connection with coating of wood 

products shall comply with the following requirements: 

320.1 The person shall use closed containers for the storage or disposal of cloth or paper 

used for solvent surface preparation and cleanup. 

320.2 The person shall store fresh or spent solvent in closed containers. 

320.3 The person shall not use organic compounds for the cleanup of mixing or storage 

equipment unless equipment for collecting the cleaning compounds and minimizing 

their evaporation to the atmosphere is used. 

320.4 The person shall not use organic solvent for the cleanup of spray equipment, 

including coating lines, with a VOC content in excess of 25 g/l (0.21 lb/gal) unless 

either 

(i) the solvent is pressurized through spray equipment with atomizing air off or 

dispensed from a small non-atomizing container, and collected and stored in a 

closed container until recycled or properly disposed of offsite, or 

(ii) a spray gun washer subject to and in compliance with the requirements of 

Regulation 8, Rule 16 is used. 

320.5 The person shall not leave containers of stripper, coating, adhesive, catalyst, 

solvent or thinner open to the atmosphere when not in use. 

 (Adopted 4/17/91; Amended 8/5/09) 
Bay Area Air Quality Management District August 5, 2009 

 8-32-10 

8-32-321 Surface Preparation Standards: Effective July 1, 2010, no person shall use a solvent 

with a VOC content that exceeds 25 g/l (0.21 lbs/gal), as applied, for surface preparation in 

any operation subject to this Rule unless emissions to the atmosphere are controlled to an 

equivalent level by an approved emission control system with an overall abatement efficient 

of at least 85 percent. 

(Adopted August 5, 2009) 

8-32-400 ADMINISTRATIVE REQUIREMENTS 

8-32-401 Deleted April 17, 1991

8-32-402 Deleted June 19, 1996 

8-32-403 Extreme Environmental Conditions Petition: A person seeking an exemption pursuant 

to Section 8-32-119 shall comply with the following requirements: 

403.1 The person shall submit a petition to the APCO containing the following information, 

as applicable: environmental conditions and coating performance requirements, 

volume of coating, and maximum VOC level necessary. 

403.2 If the APCO finds, based on the petition, that there is good reason to grant an 

exemption pursuant to Section 8-32-119, the APCO shall grant written approval for 

an exemption of a period of up to two years. The APCO may impose appropriate 

conditions on the approval, including limits on the amount and VOC content of 

coatings that may be used under the exemption. 

403.3 Upon receipt of written approval from the APCO, the person may use coatings that 

do not comply with the standards of Section 8-32-302, provided that the coatings 

comply with the standards of Section 8-32-304. The person must comply with all 

conditions of approval, and maintain records as required by Section 8-32-501. 

403.4 The person may renew the petition subject to approval by the APCO. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-404 Alternate Compliance Petition And Approval: Any person seeking to comply with this 

Rule pursuant to the averaging provisions of Section 8-32-307 shall submit to the APCO a 

petition containing information regarding all coatings and solvents to be included in the 

alternate compliance formula. Such information shall include the VOC content in grams (or 

pounds) per liter (or gallon), and in grams (or pounds) per gram (or pound) coating solid for 

high-solids coatings, the VOC content in grams (or pounds) per liter (or gallon) of coating 

for low-solids coatings and solvents, the expected quantity of each coating or solvent to be 

used, a description of the products or coating line for which the approval is sought. The 

APCO shall evaluate each petition submitted and will respond to each petition that meets 

the criteria of Section 8-32-307 with written approval. A petitioner is subject to the limits 

contained in Section 8-32-302, 303 or 304 until receipt of the written approval. Any change 

in operations from what is described in the petition terminates approval of the petition. A 

new petition submittal and written approval are required to continue to be eligible for the 

alternative compliance provisions of Section 8-32-307. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-405 Low VOC Facility Certification: In order to qualify for the recordkeeping exemption in 

Section 8-32-120, the owner or operator of a facility shall certify in writing to the APCO that 

all coatings comply with the provisions of Section 8-32-120. Such certification shall be 

provided annually, and if the facility is required to obtain a renewed permit on an annual 

basis, the certification shall be provided concurrent with permit renewal. 

(Adopted 6/19/96; Amended 8/5/09) 

8-32-406 VOC Labeling Requirements: Effective July 1, 2010, any manufacturer, re-packager and 

retailer of any wood coating, or organic solvent used for thinning, surface preparation or 

clean up subject to this Rule that is manufactured on or after July 1, 2010 shall identify on 

the container the VOC content for the coating or solvent expressed in grams per liter (or 

pounds per gallon), as calculated in Section 8-32-604 or 605. 

(Adopted August 5, 2009) 

8-32-407 Compliance Statement Requirement: Effective August 1, 1991, the manufacturer of 

coatings subject to this Rule shall provide on the coating container or as an accompanying 

specification a designation of VOC content (as defined in Section 8-32-234) expressed in 

grams per liter or pounds per gallon of coating, and expressed as grams VOC per gram 

solid or pounds VOC per pound solid. Effective July 1, 2010, any manufacturer, re-
Bay Area Air Quality Management District August 5, 2009 

 8-32-11 

packager and retailer of any wood coating, or organic solvent that is manufactured on or 

after July 1, 2010, and used for thinning, surface preparation or clean up used by wood 

products coating facilities subject to this Rule shall provide to users on product data sheets 

or an equivalent medium, the following information: 

407.1 The VOC content of the coating and solvent in grams per liter (or pounds per 

gallon), as calculated in Section 8-32-604, or 605; 

407.2 For high solids coatings, the VOC content of the coating in grams per gram (or 

pounds per pound), as calculated in Section 8-32-606; 

407.3 Any thinning recommendations for a coating, and the VOC content of the coating 

after thinning in grams per liter (or pounds per gallon) as calculated in Section 8-32-

604 or 605, and for high-solids coatings the VOC content of the coating after 

thinning in grams per gram (or pounds per pound) as calculated in Section 8-32-

606. 

(Adopted August 5, 2009) 

8-32-408 Formaldehyde Emissions Information Requirement: By July 1, 2012, each 

manufacturer with at least 1000 gallons of wood coatings sold or distributed into the District 

shall submit the following information for each of the wood coatings based on 2011 sales: 

408.1 The estimated volumes of each wood coating sold or distributed into the Bay Area. 

408.2 The estimated formaldehyde emitted during drying or curing (in grams) from each 

of the wood coatings sold or distributed into the Bay Area. 

408.3 The basis for the formaldehyde emissions estimate for each of the wood coatings 

sold or distributed into the Bay Area. 

(Adopted August 5, 2009) 

8-32-500 MONITORING AND RECORDS 

8-32-501 Recordkeeping Requirements: Any person subject to Section 8-32-302, 303, 304, or 307 

shall: 

501.1 Maintain a current list of coatings in use which provides all of the data necessary to 

evaluate compliance, including the following information, as applicable: 

a. coating, catalyst, reducer, or other thinner or solvent used 

b. manufacturer's recommended ratio of components 

c. VOC content of coating as applied after any thinning 

d. solids content of each high solids coating as applied after any thinning 

e. thinner or solvent used for cleaning or surface preparation 

501.2 Record the following information on a daily basis, as applicable: 

a. coating and mix ratio of components in the coating used 

b. quantity of each coating applied 

c. identification of coating category 

d. type and amount of solvent used for cleanup and surface preparation 

e. emissions averaging calculations if using the alternate compliance option 

provided in 8-32-307. 

501.3 Record air pollution abatement equipment key operating parameters on a daily 

basis where such equipment is installed to meet the requirements of Sections 8-32-

302, 303, and 304. 

501.4 Retain the records required by sections 501.2 and 501.3 for a period of 24 months 

and make them available for inspection by the APCO upon request. 

(Adopted 4/17/91; Amended 6/15/94; 6/19/96; 8/5/09)

8-32-502 Refinishing, Replacement and Custom Replica Furniture Operations Recordkeeping 

Requirements: Any person refinishing wood products, replacing missing furniture or 

producing custom replica furniture as described in 8-32-113 shall: 

502.1 Maintain a current list of coatings in use which provides the following information, 

as applicable: 

a. coating, catalyst, reducer, or other components used 

b. manufacturer's recommended mix ratio of components 

c. VOC content and solids content of coating or reducer as applied after any 

thinning recommended by the manufacturer 

502.2 Record on a monthly basis the following information, as applicable: 
Bay Area Air Quality Management District August 5, 2009 

 8-32-12 

a. amount of coating, catalyst, reducer, or other components used 

b. type and amount of solvent used for cleanup and surface preparation 

c. type and amount of stripper used 

502.3 Retain the records required by sections 502.1 and 502.2 for a period of 24 months 

and make them available for inspection by the APCO upon request. 

(Adopted 4/17/91; Amended 6/15/94, 8/5/09)

8-32-503 Custom Furniture, Custom Architectural Millwork and Custom Cabinetry 

Recordkeeping Requirements: In addition to the requirements of Section 8-32-501, any 

person producing custom furniture, custom architectural millwork and/or custom cabinetry 

shall maintain and make available for inspection by the APCO job orders, shop drawings or 

blueprints, or designer or architectural drawings as necessary to establish the custom 

nature of the work. 

(Adopted 4/17/91; Amended 6/19/96; 8/5/09) 

8-32-600 MANUAL OF PROCEDURES 

8-32-601 Analysis of Samples: For purposes of this Rule, VOC content of high-solids coatings shall 

be determined as prescribed in the Manual of Procedures, Volume III, Method 21 

(Determination Of Compliance Of Volatile Organic Compounds For Water Reducible 

Coatings) or Method 22 (Determination Of Compliance Of Volatile Organic Compounds For 

Solvent-Based Coatings, Inks, and Other Related Products). VOC content of low-solids 

coatings and surface preparation and clean-up solvents shall be determined as prescribed 

in the Manual of Procedures, Volume III, Method 31 (Determination Of Volatile Organic 

Compounds in Paint Strippers, Solvent Cleaners and Low Solids Coatings), or by South 

Coast Method 313.91 (Determination of Volatile Organic Compounds (VOC) by Gas 

Chromatography/Mass Spectrometry (GC/MS)). VOC content of coatings containing 

parachlorobenzotrifluoride shall be determined as prescribed in the Manual of Procedures, 

Volume III, Method 41 (Determination Of Volatile Organic Compounds in Solvent Based 

Coatings and Related Materials Containing Parachlorobenzotrifluoride). The VOC content 

of coatings containing acetone shall be determined by using ASTM Method D6133-02 

(Standard Test Method for Acetone, p-Chlorobenzotrifluoride, Methyl Acetate or t-Butyl 

Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw 

Materials by Direct Injection Into a Gas Chromatograph). When more than one test method 

or set of test methods are specified for any testing, a violation of any requirement of this 

rule established by any one of the specified test methods or set of test methods shall 

constitute a violation of the rule. 

 (Amended 4/17/91, 6/19/96, 8/5/09)

8-32-602 Determination of Emissions Control Efficiency: Emissions control efficiency of volatile 

organic compounds from source operations controlled by an emission control system shall 

be determined as follows: 

602.1 Capture efficiency shall be determined as specified in 40 CFR 51, Appendix M, 

Test Methods 204 – 204F, as applicable. 

602.2 Control device destruction efficiency shall be determined as specified in the Manual 

of Procedures, Volume IV, ST-7 or EPA Method 25 or 25A. 

602.3 For the determination of control device destruction efficiency, any non-precursor 

organic compound specified in Section 8-32-232 shall be included as a volatile 

organic compound. 

602.4 The overall efficiency of an emissions control system, expressed as a percentage, 

shall be calculated according to the following equation: 

OE = [CE x DE] 

Where: 

OE = Overall efficiency 

CE = Capture efficiency 

DE = Control device destruction efficiency 

602.5 A source shall be considered in violation if the VOC emissions exceed the 

standards of this rule as measured by any of the reference test methods. 

(Adopted 4/17/91; Amended 6/15/94; 6/19/96; 8/5/09) 
Bay Area Air Quality Management District August 5, 2009 

 8-32-13 

8-32-603 Emissions Averaging Procedure: The procedure for averaging VOC emissions of

coatings to determine compliance with Section 8-32-307 and sample calculations may be 

found in the Manual of Procedures, Volume I, Section 6. 

(Amended 6/19/96, 8/5/09) 

8-32-604: Calculation of Grams of VOC per liter for Low Solids Coatings: The VOC content of 

Low-Solids Coatings shall be calculated using the following equation: 

m

s w es

V

W W W VOC − − =

Where: 

Ws = Weight of volatile compounds (including water) in grams (or pounds). 

Ww = Weight of water in grams (or pounds). 

Wes = Weight of exempt compounds in grams (or pounds). 

Vm = Volume of material in liters (or gallons). 

(Adopted August 5, 2009) 

8-32-605: Calculation of Grams of VOC per liter for High Solids Coatings: The VOC content of 

High-Solids Coatings shall be calculated using the following equation: 

m w es

s w es

V V V

W W W VOC − −− − =

Where: 

Ws = Weight of volatile compounds (including water) in grams (or pounds). 

Ww = Weight of water in grams (or pounds). 

Wes = Weight of exempt compounds in grams (or pounds). 

Vm = Volume of material in liters (or gallons). 

Vw = Volume of water in liters (or gallons). 

Ves = Volume of exempt compounds in liters (or gallons). 

(Adopted August 5, 2009) 

8-32-606: Calculation of Grams of VOC per gram of solids for High Solids Coatings: The VOC 

content of High-Solids Coatings (grams per gram) shall be calculated using the following 

equation: 

r

s w es

W

W W W VOC − − =

Where: 

Ws = Weight of volatile compounds (including water) in grams (or pounds). 

Ww = Weight of water in grams (or pounds). 

Wes = Weight of exempt compounds in grams (or pounds). 

Wr = Weight of coating solids in grams (or pounds). 

(Adopted August 5, 2009) 

8-32-607: Determination of Coating Transfer Efficiency: The transfer efficiency of alternative 

coating application methods shall be determined in accordance with South Coast Air 

Quality Management District method “Spray Equipment Transfer Efficiency Test Procedure 

for Equipment User, May 24, 1989.” 

(Adopted August 5, 2009)