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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Notice of Proposed Rulemaking for the

California State Implementation Plan

South Coast Air Quality Management District Rule 1113, 

Architectural Coatings 

Prepared by Sona Chilingaryan and Nicole Law

September 2010 
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Agency: South Coast Air Quality Management District (SCAQMD) 

SIP Approved Rule: Rule 1113, Architectural Coatings, adopted November 8, 1996, 

submitted November 27, 1996, EPA approved June 21, 1999 (64 FR 33018) 

Superseded Submittals: Four different submittals adopted December 6, 2002, December 

5, 2003, July 9, 2004, and June 9, 2006, all submitted on December 29, 2006 

Subject of this TSD: Rule 1113, Architectural Coatings, amended July 12, 2007, 

submitted March 7, 2008 

Rule Summary

SCAQMD Rule 1113 controls volatile organic compound (VOC) emissions from 

architectural coatings by establishing VOC limits on manufacture, distribution and use of 

various coatings. SCAQMD first adopted it in September 1977 and has amended it 

several times since initial adoption. 

Changes from the SIP Approved Rule

Changes to the SIP approved version of Rule 1113 include the following: 

Definitions were added for aluminum roof coatings, bituminous roof primers, 

clear brushing lacquers, floor coatings, formulation data, high temperature 

industrial maintenance coatings, industrial maintenance coatings, interior stains, 

nonflat coatings, nonflat high gloss coatings, post-consumer coatings, product 

line, recycled coatings, rust preventative coatings, secondary (rework) coatings, 

specialty primers, waterproofing concrete/masonry sealers, and zinc-rich 

industrial maintenance primers. (Section (b))

The definitions for concrete curing compounds, fire retardant coatings, metallic 

pigmented coatings, quick dry enamels, roof coatings, shellac, volatile organic 

compounds, and waterproofing sealers were amended, and the definition for 

industrial maintenance primers and topcoats was removed. (Section (b))

The following categories have more stringent limits (Section (c)(2)): 

o varnishes (275 vs. 350 g/L), 

o sanding sealers (275 vs. 350 g/L), 

o concrete-curing compounds (100 vs 350 g/L),

o dry-fog coatings ( 150 vs. 400 g/L) , 

o pre-treatment wash primers (420 vs. 780 g/L), 

o primers, sealers, and undercoaters (100 vs. 350 g/L), 

o quick-dry enamels (50 vs. 400 g/L), 

o roof coatings (100 vs. 350 g/L),

o stains (100 g/L for stains and 250 g/L for interior stains vs. 300 g/L for 

stains), 

o swimming pool coatings- repair (340 vs. 650 g/L), 

o traffic coatings (100 vs. 250 g/L), and 
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o waterproofing sealers (100 vs. 400 g/L). 

The following categories were added to the Table of Standards (Section (c)(2)):

o Clear brushing lacquer (275 g/L; coatings in this category were required 

to comply with the 275 g/L Clear Wood Finishes Lacquer category in the 

SIP approved rule),

o concrete-curing compounds for roadways and bridges (350 g/L limit; 

coatings in this category were required to comply with the 350g/L 

concrete-curing compounds category in the SIP approved rule), 

o industrial maintenance coatings (100 g/L limit; coatings in this category 

were required to comply with the 420 g/L industrial maintenance category 

in the SIP approved rule), 

o high temperature industrial maintenance coatings (420 g/L limit; coatings 

in this category were required to comply with the 420 g/L industrial 

maintenance category in the SIP approved rule), 

o zinc-rich industrial maintenance primers (100 g/L limit; coatings in this 

category were required to comply with the 420 g/L industrial maintenance 

category in the SIP approved rule), 

o nonflat coatings (50 g/L limit; coatings in this category were required to 

comply with the 250 g/L limit in paragraph (c)(1) in the SIP approved 

rule),

o nonflat high gloss (50 g/L limit; coatings in this category were required to 

comply with the 250 g/L limit in paragraph (c)(1) in the SIP approved 

rule), 

o quick dry primers, sealers, and undercoaters (100 g/L limit; coatings in 

this category were required to comply with the 350 g/L primers, sealers, 

and undercoaters category in the SIP approved rule), 

o recycled coatings (250 g/L limit; coatings in this category were required to 

comply with the 250 g/L limit in paragraph (c)(1) in the SIP approved 

rule), 

o roof coatings- aluminum (100 g/L limit; coatings in this category were 

required to comply with the 300 g/L roof coatings category in the SIP 

approved rule), 

o roof primers- bituminous (350 g/L limit; coatings in this category were 

required to comply with the 420 g/L bituminous coatings materials 

category in the SIP approved rule), 

o rust preventative coatings (100 g/L limit; coatings in this category were 

required to comply with the 420 g/L industrial maintenance coating 

category in the SIP approved rule, the 400 g/L quick dry enamel category 

in the SIP approved rule, or the 350 g/L primer, sealer, and undercoater 

category in the SIP approved rule), 

o specialty primers (100 g/L limit; coatings in this category were required to 

comply with the 350 g/L primers, sealers, and undercoaters category in 

SIP approved rule), 

o stains- interior (250 g/L limit; coatings in this category were required to 

comply with the 350 g/L stains category in SIP approved rule), and
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o waterproofing concrete/masonry sealers (100 g/L limit; coatings in this 

category were required to comply with the 400g/L waterproofing sealers 

category in SIP approved rule). 

The following industrial maintenance sub-categories were removed from the 

Table of Standards: alkyds, catalyzed epoxy, bituminous coating materials, 

inorganic polymers, vinyl chloride polymers, chlorinated rubber, acrylic 

polymers, urethane polymers, silicones, and unique vehicles. (Section (c)(2))

A sell-through provision was added that allows coatings that were manufactured 

prior to the effective date of the applicable limit that have a VOC content that’s 

above the limit in the Table of Standards (but is not above the limit in effect on 

the date of manufacture), to be sold, supplied, offered for sale, or applied for up to 

three years after the specified effective date. (Section (c)(4))

The averaging compliance option (ACO) was expanded to include the following 

coating categories: floor coatings, primers, sealers and undercoaters, quick-dry 

primers, sealers and undercoaters, quick-dry enamels, rust preventative coatings, 

roof coatings, specialty primers, stains, waterproofing sealers, industrial 

maintenance coatings, flats and nonflats (excluding recycled coatings), 

bituminous roof primers, fire-retardant coatings, high-gloss nonflats, metallic 

pigmented coatings, zinc-rich industrial maintenance primers, interior stains, 

waterproofing concrete/masonry sealers, varnishes, and sand sealers. (Section 

(c)(6)(A) and (B))

An added requirement for manufacturers to not include in an ACO program any 

coating with a VOC content in excess of the maximum VOC content in effect 

immediately prior to July 1, 2001 or the VOC content limits specified in the 

National VOC Emission standard, whichever is less. (Appendix A: (A))

An added requirement that for every single compliance period of the ACO 

program, the manufacturer submit to the Executive Officer a mid-term report 

listing all coatings subject to averaging during the first half of the compliance 

period, detailed analysis of the actual and allowable emissions at the end of the 

mid-term, and if actual emissions exceed allowable emissions an explanation as to 

how the manufacturer intends to achieve compliance by the end of the compliance 

period. (Appendix A: (D)1.)

A provision that allows an affected manufacturer to base its averaging on prior 

limits on a coating until the end of the compliance period immediately following 

the date of adoption if the VOC limits of a coating listed in the ACO Program are 

amended such that its effective date is less than one year from the date of 

adoption. (Appendix A: (H))

An added requirement for each container of any coating in an ACO Program that 

exceeds the applicable VOC limits in the Table of Standards to be labeled with 

“This product is subject to the averaging provisions of SCAQMD Rule 1113” or a 

substitute symbol specified by the Executive Officer. (Appendix A: (I))

An added clarification that the exceedance of the allowable emissions at the end 

of any ACO Program compliance period shall constitute a separate violation for 

each coating product line that is over the VOC limit specified in the Table of 

Standards for each day of the compliance period. (Appendix A: (J))
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An added sell through provision for coatings included in an approved ACO 

Program that do not comply with specified limits in the Table of Standards. Such 

coatings can be sold, supplied, offered for sale, or applied for up to three years 

after the end of the compliance period if the coating container displays the 

statement “This product is subject to architectural coatings averaging provisions 

of the SCAQMD Rule 1113” or a substitute symbol specified by the Executive 

Officer. (Appendix A: (K))

EPA Evaluation

The following criteria were used to evaluate the submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies, 

EPA Region 9, August 21, 2001) were used to help evaluate compliance with the 

CAA §110(a)(2)(A) requirement for enforceability. 

2. Rule stringency – EPA’s National Volatile Organic Compound Emission Standard 

for Architectural Coatings (40 CFR Part 59 Subpart D), CARB’s Suggested 

Control Measures for Architectural Coatings (October 26, 2007), and other state 

and local rules for this category were used to help evaluate the rule stringency. 

3. SIP Relaxation - Where previous versions of rules have been SIP approved, new 

submittals must comply with CAA Section 110(l) and Section 193 regarding SIP 

relaxations.

4. Economic Incentive Program - Because Rule 1113 includes an averaging

provision, EPA considers this program an economic incentive program. EPA’s 

guidance contained in the document entitled, “Improving Air Quality with 

Economic Incentive Programs,” EPA-452/R-01-001, January 2001, 

(http://www.epa.gov/ttncaaa1/t1/meta/m1201.html), frequently referred to as the 

EIP Guidance, was used to evaluate the economic incentive program.

The submitted rule has VOC limits more stringent than EPA’s rule for architectural 

coatings, CARB’s suggested control measure, and other California District rules for this 

category. As a result, we have determined that this rule is sufficiently stringent. The 

labeling, recordkeeping and other requirements generally ensure that the submitted rule 

can be enforced. Lastly, the submitted rule is more stringent than the version previously 

approved into the SIP, so the submitted rule does not relax the SIP and complies with 

Section 110(l) and Section 193. 

Rule Evaluation Discussion

Several specific issues are discussed below.
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Rule 1113 section (b)(59), the definition for volatile organic compound, exempts tertiary 

butyl acetate (TBAc) as a VOC in the architectural coating category of industrial 

maintenance coatings. EPA’s definition of a VOC requires TBAc be regarded as a VOC 

for the purposes of recordkeeping, emissions reporting, photochemical dispersion 

modeling and inventory requirements. (see 40 CFR 51.100(s)(5)) Generally, EPA has

not required recordkeeping and reporting on exempt compounds, but did require it for 

TBAc to better determine if potential widespread usage of "negligibly reactive" 

compounds may contribute significantly to ozone formation, and to continue efforts to 

assess long-term potential health risks. (See 69 FR 69298). 

According to SCAQMD emissions data from 2008 and CARB’s architectural coatings 

survey from 2005, the industrial maintenance coatings make up only 2% of the total

architectural coatings. Conversations with CARB staff revealed that the State reports

inventory and emissions from the category of architectural coatings. Therefore, it 

appears that the State is prepared to fulfill the obligations set forth in 40 CFR 51.100 (s) 

(5) and this provision does not need to be in a district rule. Because TBAc is not 

considered a VOC for the purpose of NAAQS attainment demonstrations, because 

industrial maintenance coatings make up a very small percentage of the overall 

architectural coatings category, and because emissions and inventory reporting 

requirements are performed by the State, we do not believe this exemption of TBAc 

justifies a disapproval of SCAQMD Rule 1113 at this time.

Section 4.3 of the EIP guidance requires that EIPs such as the emissions averaging option 

in section (c)(6) demonstrate environmental benefit. For example, averaging provisions 

can discount emission reductions by at least 10%. Section (c)(6) requires that actual 

emissions from averaged coatings be less than or equal to the allowable emissions. 

Therefore, Rule 1113 does not explicitly require a 10% discount of emissions reductions. 

EPA believes, however, that Rule 1113 Section (c)(6) still fulfills the EIP’s 

environmental benefit because the averaging provision was important in enabling 

SCAQMD to adopt VOC limits for 10 categories which are lower than the national and 

existing local architectural coating regulations. SCAQMD emissions data from 2008 and 

CARB’s architectural coatings survey from 2005 indicate that one of those low-VOC 

categories, nonflat coatings, accounts for approximately 30% of all architectural coatings 

sold in the SCAQMD and California. Nonetheless, we recommend that SCAQMD 

discount emission reductions by at least 10%.

In addition, Section 16.13 of the EIP guidance generally limits averaging periods to no 

more than 30 days. In contrast, Rule 1113 allows averaging periods between 6 months 

and one year. SCAQMD should revise Rule 1113 to restrict averaging to no more than 

30 days. 

Additional Recommendations for the Next Rule Revision 

The following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended.
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1. Although tertiary butyl acetate (TBAc) is exempt as a VOC in industrial maintenance 

coatings, include a recordkeeping requirement for materials containing TBAc 

pursuant with 40 CFR 51.100(s)(5).

2. Include a 10% environmental benefit into the averaging compliance option as 

recommended in the EIP guidance.

3. Reduce the averaging period to 30 days or less as recommended in the EIP guidance.

EPA Action

EPA staff recommends full approval of Rule 1113 pursuant to §110(k)(3) of the CAA, 

and its inclusion in the California SIP for the South Coast Air Quality Management 

District. 

Attachments1. SCAQMD Rule 1113, Architectural Coatings, as submitted on March 7, 2008.

2. SCAQMD Rule 1113, Architectural Coatings, changed copy, as submitted on 

March 7, 2008.

3. SCAQMD Rule 1113, Architectural Coatings, as approved into the SIP on June 

21, 1999.

Additional References -

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” 

(a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

3. “Suggested Control Measure for Architectural Coatings,” CARB, October 2007.

http://www.arb.ca.gov/coatings/arch/Approved_2007_SCM.pdf 

4. “Improving Air Quality with Economic Incentive Programs,” EPA-452/R-01-001, 

January 2001, (http://www.epa.gov/ttncaaa1/t1/meta/m1201.html).

5. “2005 Architectural Coatings Survey Final,” CARB, December 2007.

6. “South Coast Architectural coatings sales data.” E-mail from Heather Farr 

(SCAQMD) to Nicole Law (USEPA). July 15, 2010.