Kern County Air Pollution Control District 

Rule 410.1A 

ARCHITECTURAL COATING CONTROLS 

FINAL STAFF REPORT 

April 5, 2010 

Prepared by 

Jeremiah Cravens 

Air Quality Specialist II 

Reviewed by 

David L. Jones 

Air Pollution Control Officer

Glen Stephens 

Senior Air Quality Engineer 

Kern County Air Pollution Control District 

2700 “M” Street, Suite 302 

Bakersfield, California 93301 

(661) 862-5250  www.kernair.org
Table of Contents

I. BOARD ADOPTION......................................................... 1 

II. INTRODUCTION.............................................................. 1 

III. DEFINITION OF ARCHITECTURAL COATING...................... 2 

IV. EMISSIONS FROM ARCHITECTURAL COATINGS................ 2 

V. REDUCTIONS IN VOC EMISSIONS.................................... 2 

VI. RULE 410.1A ARCHITECTURAL COATING CONTROLS......... 3 

VII. EXEMPTIONS.................................................................. 3 

VIII. CHANGES IN CATEGORIES AND DEFINITIONS................... 3 

IX. EXCLUDED CATEGORIES AND DEFINITIONS..................... 4 

X. CHANGES IN VOC CONTENT LIMITS................................. 6 

XI. PROVISIONS THAT HAVE BEEN EXCLUDED...................... 7 

XII. NEW REQUIREMENTS..................................................... 8 

XIII. CHANGES TO REQUIREMENTS........................................ 8 

XIV. CHANGES TO ADMINISTRATIVE REQUIREMENTS............... 9 

XV. COST EFFECTIVENESS ................................................... 9 

XVI. VOC REDUCTIONS ACCOMPLISHED BY RULE 410.1A......... 10 

XVII. ECONOMIC IMPACTS ...................................................... 11 

XVIII. ENVIRONMENTAL IMPACTS............................................. 12 

XIX. SOCIOECONOMIC IMPACTS............................................. 13 

XX. REFERENCES..................................................................14 

APPENDIX A ADOPTED RULE 410.1A, ARCHITECTURAL 

COATING CONTROLS 

APPENDIX B STRIKEOUT UNDERLINE OF ADOPTED RULE 

410.1A, ARCHITECTURAL COATING CONTROLS, 

REFLECTING CHANGES MADE AFTER THE 

10/28/2009 WORKSHOP 

APPENDIX C RESPONSE TO COMMENTS 
410.1A Final Staff Report 

I. BOARD ADOPTION 

Rule 410.1A, Architectural Coating Controls was adopted by the Kern County Air 

Pollution Control District’s Governing Board on March 11, 2010 at the March 2010 

Board meeting. Although Rule 410.1A has been adopted, it will not become 

effective until January 1, 2011. Rule 410.1 Architectural Coatings (the District’s 

current architectural coatings rule) was rescinded on March 11, 2010 but will 

remain effective through December 31, 2010. On January 1, 2011 Rule 410.1A, 

Architectural Coating Controls will become effective and supersede Rule 410.1 

Architectural Coatings. 

II. INTRODUCTION 

This staff report presents the changes made to the rule designed to regulate 

architectural coatings. Initially Kern County Air Pollution Control District 

(KCAPCD) staff intended to revise the current architectural coatings rule, Rule 

410.1, Architectural Coatings. However, after realizing the extent of the proposed 

revisions, staff believed it would be more efficient to draft and adopt a new rule 

rather than revise the current rule. Rule 410.1A will substantially reduce VOC 

emissions that result from the application of architectural coatings. 

On October 28, 2009 KCAPCD held a public workshop for proposed draft Rule 

410.1A at the Mojave Veteran’s Hall in Mojave, Ca. In response to the workshop, 

KCAPCD received comments and suggested changes from the U.S. EPA (EPA), 

the California Air Resources Board (ARB), and interested coatings and chemical 

manufacturers. KCAPCD considered all comments and suggested changes. Staff 

incorporated all EPA and ARB suggested changes along with industry suggested 

changes that would not modify the intent or VOC Content Limits of the Rule. 

A revised version of proposed draft Rule 410.1A was submitted to the EPA and 

ARB for review and approval. Upon receiving written approval of Draft Rule 

410.1A, KCAPCD brought the Rule before the KCAPCD Governing Board for 

adoption. 

Appendix A is the clean version of adopted Rule 410.1A Architectural Coating 

Controls. 

Appendix B is a strikeout underline version of adopted Rule 410.1A Architectural 

Coating Controls showing all changes made to the rule after the workshop. 

Appendix C is the Response to Comments that followed the October 28, 2009 

workshop. 

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KCAPCD 1 Draft 4/5/2010 
410.1A Final Staff Report 

III. DEFINITION OF ARCHITECTURAL COATING 

Architectural coatings are products that are applied to stationary structures and 

their accessories. They include house paints, stains, industrial maintenance 

coatings, traffic coatings, and many other products. When these coatings are 

applied, VOCs are emitted from the coatings and from solvents that are used for 

thinning and clean-up. 

IV. EMISSIONS FROM ARCHITECTURAL COATINGS 

Architectural coatings represent a significant source of VOC emissions 

throughout California. In the presence of sunlight, VOCs and nitrogen oxides 

(NOx) undergo a series of chemical reactions to form ozone. Ozone is a strong 

oxidizer that irritates the respiratory system, leading to a variety of adverse health 

effects. It also damages plant life and property. VOC emissions from architectural 

coatings can also lead to the formation of particulate matter (PM). Particulate 

matter less than 10 microns in diameter can be inhaled deep into the lungs. PM 

exposure has been associated with a wide range of adverse health impacts, 

including hospitalization and premature death. Ozone and PM are two of the 

most serious air pollutants in California. To protect California’s population from 

the harmful effects of exposure to ozone and PM, the ARB and the U.S. EPA 

have established air quality standards for these contaminants. 

VOC emissions from the use of architectural coatings in California are estimated 

to be about 118 tons per day (tpd) in 2004. This includes 95 tpd from coatings, 

and about 23 tpd from associated cleanup solvents, thinners, and additives. Total 

emissions from architectural coatings and associated materials represent almost 

10 percent of the VOC emissions from stationary and area sources, and almost 5 

percent of the total VOC emissions statewide. The VOC emissions from 

architectural coatings are more than the combined VOC emissions from 

petroleum refining and marketing, and are comparable to the emissions from 

approximately 5 million passenger cars. 

V. REDUCTIONS IN VOC EMISSIONS 

Based on survey data collected by the ARB, the sales volume for architectural 

coatings increased from more than 98 million gallons in 2000, to more than 110 

million gallons in 2004. However, the total statewide VOC emissions for 

architectural coatings decreased from 110 to 95 tpd from 2000 to 2004. The VOC 

reduction occurred due to the implementation of rules with lower VOC limits. 

Please note that these VOC emissions do not include emissions from thinning 

solvents, cleanup solvents, or additives. 

The survey data also indicates that architectural coatings in California are 

continuing to shift toward waterborne products. From 2000 to 2004, the percent 

of total sales volume attributed to waterborne coatings increased from 83 to 88 

KCAPCD 2 Draft 4/5/2010 
410.1A Final Staff Report 

percent. During this same time period, the architectural coating emissions per 

capita and the average amount of VOCs per gallon of coating decreased more 

than 20 percent. 

VI. RULE 410.1A ARCHITECTURAL COATING CONTROLS

The provisions of Rule 410.1A, Architectural Coatings Controls are based on 

ARB’s 2007 SCM for architectural coatings. Rule 410.1A will be applicable to 

architectural coatings as defined in this staff report and to any person who 

manufactures, blends, repackages, supplies, sells, offers for sale, solicits, or 

applies any architectural coating for use within the Kern County Air Pollution 

Control District. 

VII. EXEMPTIONS 

The Exemptions Section of the Rule has been moved up to Section IV 

immediately after Severability and directly before Definitions. Section IV.A.2 has 

been added, which allows any aerosol coating product to be exempt from the 

provisions of the Rule. 

Several manufacturers requested KCAPCD to allow the use of Tertiary Butyl 

Acetate (t-butyl acetate) TBAC or TBAc as an exempt organic compound in Rule 

410.1A. After reviewing the U.S. EPA’s delisting of TBAc as a VOC for purposes 

of VOC emissions limitations and VOC content requirements, the KCAPCD has 

added TBAc to Rule 102 (Definitions) as an exempt organic compound. 

VIII. CHANGES IN CATEGORIES AND DEFINITIONS 

To enhance clarity, enforcement, and to limit the types of products that qualify for 

inclusion into each specific category of Rule 410.1A, Section V of the rule 

provides definitions for new or revised terms that are not self-explanatory. 

To maintain consistency with other air district architectural coatings rules 

definitions for Gonioapparent and Metallic have been deleted from 410.1A 

Definitions for the following new product categories have been added to 410.1A 

 Aluminum Roof 

 Basement Specialty Coating 

 Concrete/Masonry Sealer 

 Driveway Sealer 

 Maximum Thinning 

 Medium Density Fiberboard 

 Particleboard 

 Pearlescent 

 Reactive Penetrating Sealer 

 Semitransparent 

 Stone Consolidant 

 Tub and Tile Refinish 

 Veneer 

 Virgin Materials 

 Waterproofing Membrane 

 Wood Coatings 

KCAPCD 3 Draft 4/5/2010 
410.1A Final Staff Report 

 Plywood 

 Primer, Sealer, and Undercoater 

 Wood Substrate 

 Zinc-Rich Primer 

The following categories have revised definitions in 410.1A. 

 Bituminous Roof Primer 

 Concrete Curing Compound 

 Faux Finishing Coating 

 Fire-Resistive Coating 

 Fire-Retardant Coating 

 Floor Coating 

 Graphic Arts 

 Industrial Maintenance 

 Low Solids Coating 

 Metallic Pigmented 

 Multi-Color Coating 

 Nonflat – High Gloss 

 Post-Consumer Coating 

 Primers, Sealers, and Undercoaters 

 Recycled Coating 

 Roof Coating 

 Rust Preventative Coating 

 Secondary Industrial Materials 

 Shellac 

 Specialty Primers, Sealers, and 

Undercoaters 

 Stain 

 Swimming Pool Coating 

 VOC Content 

Faux Finishing Coating has been expanded to include the following provision: 

A decorative coating used to create a metallic appearance that contains greater 

than 48 grams of elemental metallic pigment per liter of coating as applied 

(greater than 0.4 pounds per gallon) and which requires a clear topcoat to 

prevent the degradation of the finish under normal use conditions. The metallic 

pigment content shall be determined in accordance with SCAQMD Method 318-

95, incorporated by reference in subsection VII.C.10. 

ARB requested that the following language be added to Fire-Retardant Coating: 

A coating labeled and formulated to retard ignition and flame spread, that has 

been fire tested and rated by a testing agency approved by building code officials 

for use in bringing building and construction materials into compliance with 

federal, state and local building code requirements. The fire-retardant coating 

and the testing agency must be approved by building code officials. The fireretardant coating shall be tested in accordance with ASTM Designation E 84-07, 

incorporated by reference in subsection VII.C.7. Effective January 1, 2011, the 

Fire Retardant coating category is eliminated and... 

“Air brush” has been added to the Graphic Arts definition. 

“Application to floors” has been added to the Industrial Maintenance Coating

definition and “Antenna” and “Antifouling” have been deleted. “Antenna” and 

“Antifouling” coatings automatically default to the IM category and do not 

specifically need to be called-out. 

IX. EXCLUDED CATEGORIES AND DEFINITIONS 

The following categories and definitions have been deleted from Rule 410.1A 

because they were found unnecessary, or were replaced by new categories. 

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410.1A Final Staff Report 

Products from deleted categories have been moved to an appropriate previously 

existing category, are now included within a new category, or will default to the 

most closely related category if not called-out in a definition. 

 Antenna Coating 

 Antifouling Coating 

 Clear Brushing Lacquers 

 Clear Wood Coating 

 Flow Coating 

 Lacquer 

 Nonindustrial Use 

 Primer 

 Quick Dry Enamel 

 Quick Dry Primer, Sealer, 

and Undercoater 

 Sanding Sealer 

 Sealer 

 Swimming Pool Repair and 

Maintenance 

 Temperature Indicator Safety 

Coating 

 Undercoater 

 Varnish 

 Waterproofing Concrete/Masonry 

Sealer 

 Waterproofing Sealer 

Table 1 displays the new or existing category that each deleted category or 

product will now fall under. 

TABLE 1 

NEW CATEGORY DELETED CATEGORY 

Basement Specialty Coatings:  Waterproofing Concrete/Masonry Sealers, 

 Waterproofing Sealers 

Concrete/Masonry Sealers:  Waterproofing Concrete/Masonry Sealers 

Flat, Nonflat, Nonflat-High Gloss:  Fire Retardant Coatings Clear and Opaque, 

 Quick Dry Enamels 

High Temperature Coatings:  Temperature-Indicator Safety Coatings 

Industrial Maintenance: 

 Antenna Coatings, 

 Antifouling Coatings, 

 Flow Coatings, 

 Quick Dry Primers, Sealers & Undercoaters 

Reactive Penetrating Sealers:  Waterproofing Concrete/Masonry Sealers, 

 Waterproofing Sealers 

Swimming Pool Coatings:  Swimming Pool Repair and Maintenance 

Waterproofing Membranes:  Waterproofing Sealers 

Wood Coatings: 

 Clear Brushing Lacquers, 

 Lacquers (including lacquer sanding sealers),

 Sanding Sealers (other than lacquer sanding sealers),

 Varnishes 

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KCAPCD 5 Draft 4/5/2010 
410.1A Final Staff Report 

X. CHANGES IN VOC CONTENT LIMITS 

Table 2 displays the reductions in VOC Content limits between the effective 

dates of Rule 410.1 and Rule 410.1A. 

TABLE 2 

Coating Category Effective 

Until 1/1/2011 

Effective 

1/1/2011 

Effective 

1/1/2012 

Flat Coatings 100 50 

Nonflat Coatings 150 100 

Nonflat - High Gloss Coatings 250 150 

Specialty Coatings 

Aluminum Roof Coatings 400 

Antenna Coatings 530 See Table 1 

Antifouling Coatings 400 See Table 1 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 300 50 

Bituminous Roof Primers 350 350 

Bond Breakers 350 350 

Clear Wood Coatings 

 Clear Brushing Lacquers

 Lacquers (including lacquer sanding sealers)

 Sanding Sealers (other than lacquer sanding sealers)

 Varnishes

680 

550 

350 

350 

See Table 1 

Concrete Curing Compounds 350 350 

Concrete/Masonry Sealers 100 

Driveway Sealers 50 

Dry Fog Coatings 400 150 

Faux Finishing Coatings 350 350 

Fire Resistive Coatings 350 350 

Fire Retardant Coatings 

 Clear 

 Opaque 

650 

350 

See Table 1 

Floor Coatings 250 100 

Flow Coatings 420 See Table 1 

Form-Release Compounds 250 250 

Graphic Arts Coatings (Sign Paints) 500 500 

High Temperature Coatings 420 420 

Industrial Maintenance Coatings 250 250 

Low Solids Coatings 120 120 

Magnesite Cement Coatings 450 450 

Mastic Texture Coatings 300 100 

Metallic Pigmented Coatings 500 500 

Multi-Color Coatings 250 250 

Pre-Treatment Wash Primers 420 420 

Primers, Sealers, and Undercoaters 200 100 

Quick Dry Enamels 250 See Table 1 

Quick Dry Primers, Sealers & Undercoaters 200 See Table 1 

Reactive Penetrating Sealers 350 

Recycled Coatings 250 250 

Roof Coatings 250 50 

Rust Preventative Coatings 400 400 250 

Shellacs: 

 Clear 

 Opaque 

730 

550 

730 

550 

Specialty Primers, Sealers, and Undercoaters 350 350 100 

Stains 250 250 

Stone Consolidants 450 

Swimming Pool Coatings 340 340 

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410.1A Final Staff Report 

TABLE 2 

Continued 

Coating Category Effective 

Until 1/1/2011 

Effective 

1/1/2011 

Effective 

1/1/2012 

Swimming Pool Repair and Maintenance Coatings 340 See Table 1 

Temperature-Indicator Safety Coatings 550 See Table 1 

Traffic Marking Coatings 150 100 

Tub and Tile Refinish Coatings 420 

Waterproofing Concrete/Masonry Sealers 400 See Table 1 

Waterproofing Membranes 250 

Waterproofing Sealers 250 See Table 1 

Wood Coatings 275 

Wood Preservatives 350 350 

Zinc-Rich Primers 340 

XI. PROVISIONS THAT HAVE BEEN EXCLUDED 

The following is a list of provisions found in Rule 410.1 that have been excluded 

from Rule 410.1A. 

 Annual reports have been deleted for the following: Clear Brushing 

Lacquers; Rust Preventative Coatings; Specialty Primers, Sealers, and 

Undercoaters; Toxic Exempt Compounds (perchloroethylene and 

methylene chloride); Recycled Coatings; Bituminous Roof Coatings; and 

Bituminous Roof Primers. 

 Rule 410.1 specifically prohibited the use of Rust Preventative Coatings 

for industrial use, unless they complied with the 250 g/l VOC limit for 

Industrial Maintenance Coatings. Since Rust Preventative and Industrial 

Maintenance Coatings have the same proposed VOC limit, it is no longer 

necessary to maintain the prohibition provision and it is proposed for 

elimination. 

 Rule 410.1 Architectural Coatings contained a special provision for 

Lacquers that allowed a person to add VOC to a lacquer to avoid blushing 

of the finish, if certain conditions were met. In Rule 410.1A, products that 

were formerly classified as Lacquers are now included in the new Wood 

Coatings category and the VOC limit is lowered from 550 g/l to 275 g/l. 

ARB staff has evaluated formulations and manufacturer information for 

Lacquers that comply with the proposed 275 g/l limit and have determined 

that the lacquer blushing provision is no longer necessary. 

 Rule 410.1 contained an averaging compliance option, which expired in 

2005. While averaging is a viable option for a few large businesses, it is 

difficult for small businesses to participate because they have fewer 

products. ARB staff has worked extensively with stakeholders to develop 

categories and VOC limits that are technologically feasible, without the 

need for an averaging program. Averaging has been eliminated. 

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410.1A Final Staff Report 

 The petition process has been deleted which allows for the use of 340 g/l 

Industrial Maintenance Coatings in areas with persistent fog and cold 

temperatures. This petition process was eliminated because it was only 

used once. ARB staff determined that it was no longer necessary. 

 The test method for determining drying times has been deleted because 

the Quick Dry categories have been eliminated and there is no need to 

verify drying times. The test method for determining surface chalkiness 

has also been deleted because chalkiness has been removed from the 

criteria in the Specialty Primers, Sealers, and Undercoaters category. 

XII. NEW REQUIREMENTS 

Rule 410.1A contains a new requirement of sales data submittal of architectural 

coatings. A responsible official from each manufacturer shall upon request of the 

Executive Officer of the ARB, or his or her delegate, provide data concerning the 

distribution and sales of architectural coatings. The responsible official shall 

provide all requested sales data within 180 days of request. Failure to do so 

could result in the issuance of a Notice of Violation or a Notice to Comply from 

the KCAPCD. Collection of these data is authorized in the California Health and 

Safety Code, which requires submission of data to estimate emissions. 

Rule 410.1A includes other requirements which are similar to those found in Rule 

410.1 but with slight modifications. 

These requirements include the following: 

 Container labeling requirements regarding the date of manufacture, VOC 

content, thinning recommendations, and labeling specific to selected 

coating categories; 

 A “painting practices” provision designed to limit VOC emissions from 

open paint containers; 

 A thinning provision specifying allowable thinning practices; and 

 A “sell-through” provision allowing three years to sell products 

manufactured prior to the effective date of a VOC limit. 

XIII. CHANGES TO REQUIREMENTS 

Section VI.C. Sell-Through/Existing Stock of Coatings has been revised as 

follows: 

A coating manufactured prior to the VOC Content limit effective date(s) specified 

for that coating in the Table of Standards, that complied with the VOC Content 

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410.1A Final Staff Report 

limit in effect at the time the coating was manufactured, may be sold, supplied, or 

offered for sale for up to three years after the specified VOC Content limit 

effective date(s) listed in the Table of Standards. Such a coating may be applied 

at any time, both before and after the specified effective date. This subsection 

VI.C does not apply to any coating that does not display the date or date-code 

required by subsection VII.A.1. 

XIV. CHANGES TO ADMINISTRATIVE REQUIREMENTS 

The following changes have been made to Section VII Administrative 

Requirements: 

“Clear topcoats” has been added to Section VII.A.4. 

The terms “Not for residential use” and “Not intended for residential use” have 

been added to Section VII.A.5. 

The following provision has been added to VII.C Test Methods: 

Calculation of VOC Content: For the purpose of determining compliance with the 

VOC content limits in the Table of Standards, the VOC content of a coating shall 

be determined as defined in subsection V.JJJ, V.KKK, or V.LLL. The VOC 

content of a tint base shall be determined without colorant that is added after the 

tint base is manufactured. If the manufacturer does not recommend thinning, the 

VOC content must be calculated for the product as supplied. If the manufacturer 

recommends thinning, the VOC content must be calculated including the 

maximum amount of thinning solvent recommended by the manufacturer. If the 

coating is a multi-component product, the VOC content must be calculated as 

mixed or catalyzed. If the coating contains silanes, siloxanes, or other ingredients 

that generate ethanol or other VOCs during the curing process, the VOC content 

must include the VOCs emitted during curing. 

Gonioapparent Characteristics for Coatings has been deleted from VII.C Test 

Methods because it is no longer needed. 

XV. COST EFFECTIVENESS 

ARB staff conducted a cost effectiveness analysis of each proposed limit as a 

separate, stand-alone regulation. Treating each proposed limit as a separate 

regulation prevents very cost-effective limits (e.g., those with large emission 

reductions coupled with low costs) from “masking” relatively cost-ineffective 

limits. The total cost of the proposed limits is estimated to be 12.3 million dollars 

per year in 2007 dollars. The overall average cost-effectiveness of the proposed 

limits is estimated to be $1.12 per pound of VOC reduced. This compares 

favorably with the cost effectiveness of similar regulations.

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Table 3 shows the cost-effectiveness of individual limits ranging from net savings 

to a net cost of $13.90 per pound of VOC reduced. The $13.90 per pound value 

for Floor Coatings is due to a large number of non-complying products being sold 

in small volumes. Staff believes that it is appropriate for Floor Coatings 

manufacturers to reformulate their products to meet the proposed limit because 

85 percent of the Floor Coatings manufacturers have already reformulated their 

coatings to meet the proposed VOC limit. 

TABLE 3 

Coating Category 

Individual CostEffectiveness for 

Each Limit 

($ per Pound VOC 

Reduced) 

Calculated Cost per 

Gallon to 

Consumers 1 

($ per Gallon)

Cost Increase Per 

Gallon to 

Consumers 

($ per Gallon)

Aluminum Roof $0.41 $14.63 $1.16 

Bituminous Roof $1.02 $11.84 $6.43 

Concrete Masonry Sealer -$0.36 $14.09 -$0.88 

Dry Fog -$0.52 $34.86 -$3.96 

Flat -$0.69 $17.81 -$0.33 

Floor $13.90 $16.96 $27.30 

Mastic Texture $2.38 $17.72 $8.61 

Non Flat $7.03 $19.44 $4.40 

Non Flat High Gloss -$1.38 $23.96 -$3.39 

PSU $2.73 $16.90 $2.51 

Roof $1.38 $29.94 $1.95 

Rust Prevention -$0.46 $30.30 -$2.51 

Specialty PSU -$0.71 $25.19 -$6.32 

Traffic Marking $4.76 $14.18 $4.00 

Waterproofing Membrane $6.55 $33.38 $17.00 

Wood Coatings -$1.13 $38.70 -$6.34 

Cost-Effectiveness 

($ Per Lb VOC Reduced) 

Cost per Gallon 

($ Per Gallon) 

Cost Increase 

($ Per Gallon) 

Overall Results $1.12 $19.20 $1.21 

1. Costs per gallon were calculated based on raw material costs, and do not necessarily 

reflect actual retail prices. 

XVI. VOC REDUCTIONS ACCOMPLISHED BY RULE 410.1 

The implementation of Rule 410.1A is expected to produce substantial long-term 

VOC emission reductions. Rule 410.1A will contribute to a multi-district (outside 

of South Coast AQMD), total VOC reduction of up to 28 percent. This is 

equivalent to a VOC emission reduction of approximately 15.2 tons per/day 

(approximately 0.101 tpd in KCAPCD) by the year 2012. 

Table 4 below shows the expected combined multi-district 15.2 tons per/day of 

VOC emission reductions outside of the South Coast AQMD. Table 4 lists only 

the categories that will have lower VOC limits beginning January 1, 2011. 

Although there are emission reductions from 19 categories, 95 percent of the 

emission reductions are from nine categories, which account for 80 percent of 

total emissions. These nine categories are highlighted in boldface in Table 4. 

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TABLE 4 

Total VOC emissions reductions for categories with 2011 lower VOC limits 

(Large containers only from multi-districts, excluding South Coast AQMD) 

Coating Category 

Current 

VOC Limit 

(g/l) 

2011 

VOC Limit 

(g/l) 

California 

market share 

outside of 

SCAQMD 

Emissions 

Reductions 

excluding 

SCAQMD 

Aluminum Roof 500 400 31% 0.19

Bituminous Roof 300 50 90% 0.17

Concrete/Masonry Sealer1 250-400 100 41% 0.54 

Driveway Sealer 100 50 100% 0.00

Dry Fog 400 150 42% 0.31 

Flat 100 50 7% 3.12 

Floor 250 100 85% 0.07

Mastic Texture 300 100 79% 0.10

Nonflat - High Gloss 250 150 28% 0.91 

Nonflat2 150 100 28% 2.77 

Primers, Sealers, and 

Undercoaters 200 100 36% 1.12 

Reactive Penetrating Sealer1 250-400 350 93% 0.00

Roof 250 50 83% 0.07

Rust Preventative 400 2504 3% 1.57 

Specialty Primers, Sealers, 

and Undercoaters 350 1004 22% 2.62 

Traffic Marking 150 100 74% 0.09

Waterproofing Membranes1 250-400 250 68% 0.09

Wood Coatings1 250-680 275 50% 1.41 

Zinc-Rich Primer 500 340 54% 0.01

Total (tons/day) 15.2

1. These are new categories that include coatings from various categories from Rule 410.1. 

The “Current VOC Limit” for these categories represents the range of VOC limits of the 

coatings that were combined into the new categories. 

2. As of January 1, 2011, the Fire Retardant coating categories are eliminated and coatings 

with fire retardant properties will be subject to the VOC limit of their primary category 

(e.g., Flat, Nonflat, etc.). To estimate emission reductions, it was assumed that Fire 

Retardant would be classified as Nonflat with a VOC limit of 100 g/l, because the majority 

of the reported coatings were nonflat. 

3. Boldface indicates the nine categories that account for 95 percent of the VOC emission 

reductions. 

4. Lower VOC limits do not apply until January 1, 2012 for Rust Preventative Coatings and 

Specialty Primers, Sealers, and Undercoaters. 

XVII. ECONOMIC IMPACTS 

The economic impacts are quantified to the extent feasible, but economic impact 

analyses can be inherently imprecise by nature. Therefore, some projections are 

necessarily qualitative or semi-quantitative, based on general observations about 

the architectural coatings industry. The economic impacts analysis for the 

proposed Rule provides a general picture of the economic impacts that typical 

businesses might encounter, but staff recognizes that individual companies may 

experience impacts different than those projected in this analysis. 

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Typical California businesses will be affected by the proposed SCM to the extent 

that the additional costs imposed by the proposed requirements would change 

their profitability. ARB estimated profitability impacts by calculating the decline in 

the return on owner’s equity (ROE). Assuming that coating manufacturers will 

have to absorb all of the costs associated with the SCM, the proposed SCM is 

expected to result in an average ROE decline of 2.1 percent, which is not 

considered to be a significant impact on the profitability of affected businesses. 

ARB’S analysis shows that most affected businesses would be able to absorb 

the costs of the proposed SCM with no significant adverse impacts on their 

profitability. However, the proposed SCM may impose economic hardship on 

some businesses with small or no margin of profitability. Because the proposed 

amendments would not alter significantly the profitability of most businesses, 

ARB does not expect a noticeable change in employment; business creation, 

elimination or expansion; and business competitiveness in California. 

If businesses are unable to reduce their costs of doing business, they would pass 

their cost increases on to consumers. If all costs were passed on to the 

consumer ARB estimates an average potential increase of about $1.21 per 

gallon. 

ARB stated in their Architectural Coatings 2007 SCM that consumers who do not 

wish to purchase these reformulated coatings would still be able to buy the 

currently available complying coatings at current prices. These products will still 

be available with no expected price increase. The competition from these existing 

compliant coatings will likely constrain any price increases for the reformulated 

coatings. This would keep most manufacturers from passing their total increased 

costs onto the consumers. Thereby, making the actual retail price increases less 

than the likely projections. 

Furthermore, companies that supply resins, solvents, or other chemicals and 

equipment for use in reformulating architectural coatings would potentially benefit 

from the proposed SCM as they experience an increase in demand for their 

products. 

XVIII. ENVIRONMENTAL IMPACTS 

Both the California Environmental Quality Act (CEQA) and ARB policy require an 

evaluation of the potential adverse environmental impacts of proposed projects. 

In June 2000, ARB staff prepared a formal environmental impact report (EIR) for 

the 2000 Suggested Control Measures (SCM) for architectural coatings. The EIR 

included an analysis of potential environmental impacts that could result 

throughout California (excluding the South Coast AQMD) from implementation of 

the 2000 SCM. ARB staff investigated six main areas of potential environmental 

impacts which include: air quality; water demand and quality; public services; 

transportation and circulation; solid and hazardous waste; and health hazards. 

KCAPCD 12 Draft 4/5/2010 
410.1A Final Staff Report 

The analysis concluded that implementing the SCM would have no significant 

adverse impacts, but would have a net air quality benefit. 

In September 2007, ARB released a staff prepared Technical Support Document 

(TSD) designed to accompany the proposed 2007 SCM for architectural 

coatings. Chapter 6 of the TSD describes the potential environmental impacts 

associated with adoption of the 2007 SCM. The TSD explains that there will be 

no significant adverse environmental impacts associated with adopting the 2007 

SCM. In addition, adoption and implementation of the 2007 SCM is expected to 

produce substantial long-term VOC emission reductions. Based on the analysis 

of potential direct and indirect air quality effects associated with a multi-district 

implementation of the 2007 SCM, the overall Statewide (excluding South Coast 

AQMD) VOC emissions reduction will be approximately 15 tpd by the year 2012.

ARB staff believes that districts can use the 2007 TSD and the 2000 EIR to 

support their environmental impact analyses when they adopt local rules based 

on the proposed 2007 SCM for architectural coatings. 

KCAPCD’s initial study for Rule 410.1A found that all potentially significant 

effects have been analyzed adequately in ARB’s previous EIR and in Chapter 6 

of the 2007 TSD to the SCM. All impacts have been avoided or mitigated 

pursuant to that earlier EIR and no new impacts found. Therefore, KCAPCD is 

referencing the ARB EIR study and subsequent ARB analysis of the revised 

SCM. Nothing further is required under CEQA. 

A complete copy of the Final Program Environmental Impact Report and the 

Technical Support Document can be obtained by mail from: 

California Air Resources Board 

Cal EPA Building 1001 I St. P.O. Box 2815, Sacramento, CA 95812 

Or on the ARB website: 

EIR: http://www.arb.ca.gov/coatings/arch/CEQA/FEIR.htm 

TSD: http://www.arb.ca.gov/coatings/arch/TSD_Chapters_5-8.pdf 

XIX. SOCIOECONOMIC IMPACTS 

CHSC Section 40728.5 exempts districts with a population of less than 500,000 

persons from the requirement to assess the socioeconomic impacts of proposed 

rules. Eastern Kern County population is below 500,000 persons. 

REMAINDER OF PAGE INTENTIONALLY LEFT BLANK 

KCAPCD 13 Draft 4/5/2010 
410.1A Final Staff Report 

KCAPCD 14 Draft 4/5/2010 

XX. REFERENCES 

Air Resources Board. “2001 Architectural Coatings Survey, Final Reactivity 

Analysis.” March, 2005. 

Air Resources Board. “2005 Architectural Coatings Survey, Draft Report.” 

September, 2006. 

Air Resources Board. “2005 Architectural Coatings Survey, Draft Reactivity 

Analysis.” January, 2007. 

Air Resources Board. “Environmental Impact Assessment of Tertiary-Butyl 

Acetate.” January, 2006. 

Air Resources Board. “Final Program Environmental Impact Report.” June, 2000. 

Air Resources Board. “Staff Report for Proposed Amendments to the Suggested 

Control Measure for Architectural Coatings.” September, 2007. 

Air Resources Board. “Technical Support Document for Proposed Amendments 

to the Suggested Control Measure for Architectural Coatings.” September, 2007. 

U.S. EPA. “Definitions of VOC and ROG.” November, 2004. 

REMAINDER OF PAGE INTENTIONALLY LEFT BLANK 
APPENDIX A: 

ADOPTED RULE 410.1A 

ARCHITECTURAL COATING CONTROLS 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-1 Draft 4/5/2010 

RULE 410.1A Architectural Coating Controls Adopted 3/11/10 Effective as of 

1/1/2011

I. Purpose

 The purpose of this rule is to limit VOC emissions from architectural coatings. This rule 

specifies VOC Content limits, storage, cleanup, and labeling requirements for 

architectural coatings. 

II. Applicability

Except as provided in subsection IV, the provisions of this rule are applicable to 

architectural coatings as defined in this rule and to any person who manufactures, blends, 

repackages, supplies, sells, offers for sale, solicits, or applies any architectural coating for 

use within the District. 

III. Severability

 Each provision of this rule shall be deemed severable, and in the event that any provision 

of this rule is held to be invalid, the remainder of this rule shall continue in full force and 

effect. 

IV. Exemptions

A. Provisions of this Rule shall not apply to: 

1. Any architectural coating that is supplied, sold, offered for sale, or 

manufactured for use outside of the District or for shipment to other 

manufacturers for reformulation or repackaging. 

2. Any aerosol coating product. 

B. Provisions of section VI and subsection VII.A shall not apply to any architectural 

coating sold in a container with a volume of one liter (1.057 quarts) or less. 

V. Definitions

A. Adhesive: Any chemical substance applied for the purpose of bonding two surfaces 

together other than by mechanical means. 

B. Aerosol Coating Product: 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. 

C. Aluminum Roof Coating: A coating labeled and formulated exclusively for 

application to roofs and containing at least 84 grams of elemental aluminum pigment 

per liter of coating (at least 0.7 pounds per gallon). Pigment content shall be 

determined in accordance with SCAQMD Method 318-95, incorporated by reference 

in subsection VII.C.10. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-2 Draft 4/5/2010 

D. Appurtenance: Any accessory to a stationary structure coated at the site of 

installation, whether installed or detached, including but not limited to: bathroom and 

kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand railings; 

heating equipment, air conditioning equipment and other fixed mechanical equipment 

or stationary tools; lampposts; partitions; pipes and piping systems; rain gutters and 

downspouts; stairways, fixed ladders, catwalks and fire escapes; and window screens. 

E. Architectural Coating: A coating to be applied to stationary structures or their 

appurtenances at the site of installation, to portable buildings at the site of installation, 

to pavements, or to curbs. Coatings applied in shop applications or to nonstationary 

structures such as airplanes, airships, ships, boats, locomotives, railcars and 

automobiles, and adhesives are not considered architectural coatings for the purposes 

of this Rule. 

F. Basement Specialty Coating: A clear or opaque coating that is labeled and 

formulated for application to concrete and masonry surfaces to provide a hydrostatic 

seal for basements and other below-grade surfaces. Basement Specialty Coatings 

must meet the following criteria: 

1. Coating must be capable of withstanding at least 10 psi of hydrostatic 

pressure, as determined in accordance with ASTM D7088-04, which is 

incorporated by reference in subsection VII.C.15; 

2. Coating must be resistant to mold and mildew growth and must achieve a 

microbial growth rating of 8 or more, as determined in accordance with 

ASTM D3273-00 and ASTM D3274-95, incorporated by reference in 

subsection VII.C.21. 

G. Bitumens: Black or brown materials including, but not limited to, asphalt, tar, pitch 

and asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons and 

are obtained from natural deposits or as residues from distillation of crude petroleum 

or coal. 

H. Bituminous Roof Coating: A coating which incorporates bitumens that is labeled and 

formulated exclusively for roofing. 

I. Bituminous Roof Primer: A primer which incorporates bitumens that is labeled and 

formulated exclusively for roofing and intended for the purpose of preparing a 

weathered or aged surface or improving the adhesion of subsequent surfacing 

components. 

J. Bond Breaker: A coating labeled and formulated for application between layers of 

concrete to prevent a freshly poured top layer of concrete from bonding to the layer 

over which it is poured. 

K. Coating: A material applied onto or impregnated into a substrate for protective, 

decorative or functional purposes. Such materials include, but are not limited to, 

paints, varnishes, sealers and stains. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-3 Draft 4/5/2010 

L. Colorant: A concentrated pigment dispersed in water, solvent and/or binder that is 

added to an architectural coating after packaging in sale units to produce the desired 

color. 

M. Concrete Curing Compound: A coating labeled and formulated for application to 

freshly poured concrete to perform one or more of the following functions: 

1. Retard the evaporation of water; or 

2. Harden or dustproof the surface of freshly poured concrete. 

N. Concrete/Masonry Sealer: A clear or opaque coating that is labeled and formulated 

primarily for application to concrete and masonry surfaces to perform one or more of 

the following functions: 

1. Prevent penetration of water; or 

2. Provide resistance against abrasion, alkalis, acids, mildew, staining, or 

ultraviolet light; or 

3. Harden or dustproof the surface of aged or cured concrete. 

O. Driveway Sealer: A coating labeled and formulated for application to worn asphalt 

driveway surfaces to perform one or more of the following functions: 

1. Fill cracks; or 

2. Seal the surface to provide protection; or 

3. Restore or preserve the appearance. 

P. Dry Fog Coating: A coating labeled and formulated only for spray application such 

that overspray droplets dry before subsequent contact with incidental surfaces in the 

vicinity of the surface coating activity. 

Q. Exempt Compound: A compound identified as exempt pursuant to the definition of 

Volatile Organic Compound (VOC), Subsection V. III. Exempt compounds content 

of a coating shall be determined by U.S. EPA Method 24 or South Coast Air Quality 

Management District (SCAQMD) Method 303-91 (Revised August 1993), 

incorporated by reference in Subsection VII.C.12. 

R. Faux Finish Coating: A coating labeled and formulated to meet one or more of the 

following criteria: 

1. A glaze or textured coating used to create artistic effects including, but not 

limited to: dirt, suede, old age, smoke damage, and simulated marble or wood 

grain; or 

2. A decorative coating used to create a metallic, iridescent, or pearlescent 

appearance that contains at least 48 grams of pearlescent mica pigment or 

other iridescent pigment per liter of coating as applied (at least 0.4 pounds per 

gallon); or 

3. A decorative coating used to create a metallic appearance that contains less 

than 48 grams of elemental metallic pigment per liter of coating as applied 

(less than 0.4 pounds per gallon), when tested in accordance with SCAQMD 

Method 318-95, incorporated by reference in subsection VII.C.10; or 

4. A decorative coating used to create a metallic appearance that contains greater 

than 48 grams of elemental metallic pigment per liter of coating as applied 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-4 Draft 4/5/2010 

(greater than 0.4 pounds per gallon) and which requires a clear topcoat to 

prevent the degradation of the finish under normal use conditions. The 

metallic pigment content shall be determined in accordance with SCAQMD 

Method 318-95, incorporated by reference in subsection VII.C.10; or 

5. A clear topcoat to seal and protect a Faux Finishing coating that meets the 

requirements of subsection IV.R.1, IV.R.2, IV.R.3, or VR.4. These clear 

topcoats must be sold and used solely as part of a Faux Finishing coating 

system, and must be labeled in accordance with subsection VII.A.4. 

S. Fire Resistive Coating: A coating labeled and formulated to protect structural 

integrity by increasing fire endurance of interior or exterior steel and other structural 

materials. The Fire Resistive category includes sprayed fire resistive materials and 

intumescent fire resistive coatings that are used to bring structural materials into 

compliance with Federal, State and local building code requirements. Any fire 

resistive coating and a testing agency must be approved by building code officials. 

Any fire resistive coating shall be tested in accordance with ASTM Designation E 

119-07, incorporated by reference in Subsection VII.C.8. 

T. Fire Retardant Coating: A coating labeled and formulated to retard ignition and 

flame spread, that has been fire tested and rated by a testing agency approved by 

building code officials for use in bringing building and construction materials into 

compliance with federal, state and local building code requirements. The fireretardant coating and the testing agency must be approved by building code officials. 

The fire-retardant coating shall be tested in accordance with ASTM Designation E 

84-07, incorporated by reference in subsection VII.C.7. Effective January 1, 2011, 

the Fire Retardant coating category is eliminated and coatings with fire retardant 

properties will be subject to the VOC limit of their primary category (e.g., Flat 

Nonflat, ECT.). 

U. Flat Coating: A coating not defined under any other definition in this Rule and that 

registers gloss less than 15 on an 85 degree meter or less than five on a 60 degree 

meter according to ASTM Designation D 523-89 (1999), incorporated by reference in 

Subsection VII.C.9. 

V. Floor Coating: An opaque coating labeled and formulated for application to flooring, 

including, but not limited to, decks, porches, steps, garage floors, and other horizontal 

surfaces which may be subject to foot traffic. 

W. Form-Release Compound: A coating labeled and formulated for application to a 

concrete form to prevent freshly poured concrete from bonding to the form. The form 

may consist of wood, metal or some material other than concrete. 

X. Graphic Arts Coating or Sign Paint: A coating labeled and formulated for handapplication by artists using brush, air brush, or roller techniques to indoor and outdoor 

signs (excluding structural components) and murals including lettering enamels, 

poster colors, copy blockers and bulletin enamels. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-5 Draft 4/5/2010 

Y. High-Temperature Coating: A high performance coating labeled and formulated for 

application to substrates exposed continuously or intermittently to temperatures above 

204°C (400°F). 

Z. Industrial Maintenance Coating: High performance architectural coatings including 

primers, sealers, undercoaters, intermediate coats, and topcoats formulated for 

application to substrates, including floors, exposed to one or more of the following 

extreme environmental conditions listed in Subsections V.Z.1. through V.Z.5. and 

labeled as specified in Subsection VII.A.5 

1. Immersion in water, wastewater or chemical solutions (aqueous and nonaqueous solutions), or chronic exposure of interior surfaces to moisture 

condensation; 

2. Acute or chronic exposure to corrosive, caustic or acidic agents or to 

chemicals, chemical fumes or chemical mixtures or solution; 

3. Frequent exposure to temperatures above 121°C (250°F); 

4. Frequent heavy abrasion, including mechanical wear and frequent scrubbing 

with industrial solvents, cleansers or scouring agents; or 

5. Exterior exposure of metal structures and structural components. 

AA. Low Solids Coating: A coating containing 0.12 kilogram or less of solids per liter (1 

pound or less of solids per gallon) of coating material as recommended for 

application by the manufacturer. The VOC content for Low Solids Coatings shall be 

calculated in accordance with section V.JJJ. 

BB. Magnesite Cement Coating: A coating labeled and formulated for application to 

magnesite cement decking to protect the magnesite cement substrate from erosion by 

water. 

CC. Manufacture’s Maximum Thinning Recommendations: The maximum 

recommendation for thinning that is indicated on the label or lid of the coating 

container. 

DD. Mastic Texture Coating: A coating labeled and formulated to cover holes and minor 

cracks and to conceal surface irregularities, and applied in a single coat of at least 10 

mils (at least0.010 inch) dry film thickness. 

EE. Medium Density Fiberboard (MDF): A composite wood product, panel, molding, or 

other building material composed of cellulosic fibers (usually wood) made by dry 

forming and pressing a resinated fiber mat. 

FF. Metallic Pigmented Coating: A coating that is labeled and formulated to provide a 

metallic appearance. Metallic Pigmented coatings must contain at least 48 grams of 

elemental metallic pigment (excluding zinc) per liter of coating as applied (at least 0.4 

pounds per gallon), when tested in accordance with SCAQMD Method 318-95, 

incorporated by reference in Subsection VII.C.10. The Metallic Pigmented Coating 

category does not include coatings applied to roofs or Zinc-Rich Primers. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-6 Draft 4/5/2010 

GG. Multicolor Coating: A coating packaged in a single container and that is labeled and 

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

HH. Nonflat Coating: coating not defined under any other definition in this Rule and that 

registers a gloss of 15 or greater on an 85 degree meter and 5 or greater on a 60 

degree meter according to ASTM Designation D 523-89 (1999), incorporated by 

reference in Subsection VII.C.9. 

II. Nonflat - High Gloss Coating: A nonflat coating that registers a gloss of 70 or above 

on a 60 degree meter according to ASTM Designation D 523-89 (1999), incorporated 

by reference in Subsection VII.C.9. Nonflat - High Gloss coatings must be labeled in 

accordance with subsection VII.A.10. 

JJ. Particleboard: A composite wood product panel, molding, or other building material 

composed of cellulosic material (usually wood) in the form of discrete particles, as 

distinguished from fibers, flakes, or strands, which are pressed together with resin. 

KK. Pearlescent: Exhibiting various colors depending on the angles of illumination and 

viewing, as observed in mother-of-pear. 

LL. Plywood: A panel product consisting of layers of wood veneers or composite core 

pressed together with resin. Plywood includes panel products made by either hot or 

cold pressing (with resin) veneers to a platform. 

MM. Post Consumer Coating: Finished coatings generated by a business or consumer that 

have served their intended end uses, and are recovered from or otherwise diverted 

from the waste stream for the purpose of recycling. 

NN. Pre-Treatment Wash Primer: A primer that contains a minimum of 0.5 percent acid, 

by weight, when tested in accordance with ASTM Designation D 1613-06, 

incorporated by reference in Subsection VII.C.11. labeled and formulated for 

application directly to bare metal surfaces to provide corrosion resistance and to 

promote adhesion of subsequent topcoats. 

OO. Primer, Sealer, and Undercoater: A coating labeled and formulated for one or more 

of the following purposes: 

1. To provide a firm bond between the substrate and the subsequent coatings; or 

2. To prevent subsequent coatings from being absorbed by the substrate; or 

3. To prevent harm to subsequent coatings by materials in the substrate; or 

4. To provide a smooth surface for the subsequent application of coatings; or 

5. To provide a clear finish coat to seal the substrate; or 

6. To block materials from penetrating into or leaching out of a substrate. 

PP. Reactive Penetrating Sealer: A clear or pigmented coating that is labeled and 

formulated for application to above-grade concrete and masonry substrates to provide 

protection from water and waterborne contaminates, including but not limited to 

alkalis, acids, and salts. Reactive Penetrating Sealers must penetrate into concrete and 

masonry substrates and chemically react to form covalent bonds with naturally 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-7 Draft 4/5/2010 

occurring minerals in the substrate. Reactive Penetrating Sealers line the pores of 

concrete and masonry substrates with a hydrophobic coating, but do not form a 

surface film. Reactive Penetrating Sealers must meet all of the following criteria: 

1. The Reactive Penetrating Sealer must improve water repellency at least 80 

percent after application on a concrete or masonry substrate. This performance 

must be verified on standardized test specimens, in accordance with one or 

more of the following standards, incorporated by reference in subsection 

VII.C.22: ASTM C67-07, or ASTM C97-02, or ASTM C140-06; and 

2. The Reactive Penetrating Sealer must not reduce the water vapor transmission 

rate by more than 2 percent after application on a concrete or masonry 

substrate. This performance must be verified on standardized test specimens, 

in accordance with ASTM E96/E96M-05, incorporated by reference in 

subsection VII.C.23; and 

3. Products labeled and formulated for vehicular traffic surface chloride 

screening applications must meet the performance criteria listed n the National 

Cooperative highway Research Report 244 (1981), incorporated by reference 

in subsection VII.C.24; and 

4. Reactive Penetrating Sealers must be labeled in accordance with subsection 

VII.A.8. 

QQ. Recycled Coating: An architectural coating formulated such that it contains a 

minimum of 50% by volume post-consumer coating, with a maximum of 50% by 

volume secondary industrial materials or virgin materials. 

RR. Residential: Areas where people reside or lodge, including, but not limited to, single 

and multiple family dwellings, condominiums, mobile homes, apartment complexes, 

motels and hotels. 

SS. Roof Coating: A non-bituminous coating labeled and formulated for application to 

roofs for the primary purpose of preventing water penetration, reflecting ultraviolet 

light, or reflecting solar radiation. 

TT. Rust Preventative Coating: A coating formulated to prevent corrosion of metal 

surfaces for one or more of the following applications: 

1. Direct-to-metal coating; or 

2. Coating intended for application over rusty, previously coated surfaces. 

The Rust Preventative category does not include the following: 

3. Coatings that are required to be applied as a topcoat over a primer; or 

4. Coatings that are intended for use on wood or any other nonmetallic surface. 

Rust Preventative coatings are for metal substrates only and must be labeled as such, 

in subsection VII.A.6. 

UU. Secondary Industrial Materials: Products or by-products of the paint manufacturing 

process that are of known composition and have economic value but can no longer be 

used for their intended purpose. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-8 Draft 4/5/2010 

VV. Semitransparent Coating: A coating that contains binders and colored pigments and 

is formulated to change the color of the surface, but not conceal the grain pattern or 

texture. 

WW.Shellac: A clear or opaque coating formulated solely with resinous secretions of the 

lac beetle (Laciffer lacca), and formulated to dry by evaporation without a chemical 

reaction. 

XX. Shop Application: Application of a coating to a product or a component of a product 

in or on the premises of a factory or a shop as part of a manufacturing, production or 

repairing process (e.g., original equipment manufacturing coatings). 

YY. Solicit: To require for use or to specify, by written or oral contract. 

ZZ. Specialty Primer, Sealer and Undercoater: A coating that is formulated for 

application to a substrate to block water-soluble stains resulting from: fire damage; 

smoke damage; or water damage. Specialty Primers, Sealers, and Undercoaters must 

be labeled in accordance with subsection VII.A.7. 

AAA. Stain: A semitransparent or opaque coating labeled and formulated to change the 

color of a surface but not conceal grain pattern or texture. 

BBB. Stone Consolidant: A coating that is labeled and formulated for application to stone 

substrates to repair historical structures that have been damaged by weather or other 

decay mechanisms. Stone Consolidants must penetrate into substrates to create bonds 

between particles and consolidate deteriorated material. Stone Consolidants must be 

specified and used in accordance with ASTM E2167-01, incorporated by reference in 

subsection VII.C.25. 

Stone Consolidants are for professional use only and must be labeled as such, in 

accordance with the labeling requirements in subsection VII.C.10. 

CCC. Swimming Pool Coating: A coating labeled and formulated to coat the interior of 

swimming pools and to resist swimming pool chemicals. Swimming pool coatings 

include coatings used for swimming pool repair and maintenance. 

DDD. Tint Base: An architectural coating to which colorant is added after packaging in sale 

units to produce a desired color. 

EEE. Traffic Marking Coating: A coating labeled and formulated for marking and striping 

streets, highways or other traffic surfaces including, but not limited to, curbs, berms, 

driveways, parking lots, sidewalks and airport runways. 

FFF. Tub and Tile Refinish Coating: A clear or opaque coating that is labeled and 

formulated exclusively for refinishing the surface of a bathtub, shower, sink, or 

countertop. Tub and Tile Refinish coatings must meet all of the following criteria: 

1. The coating must have a scratch hardness of 3H or harder and a gouge 

hardness of 4H or harder. This must be determined on bonderite 1000, in 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-9 Draft 4/5/2010 

accordance with ASTM D3363-05, incorporated by reference in subsection 

VII.C.17; and 

2. The coating must have a weight loss of 20 milligrams or less after 1000 

cycles. This must be determined with CS-17 wheels on bonderite 1000, in 

accordance with ASTM D4060-07, incorporated by reference in subsection 

VII.C.18; and 

3. The coating must withstand 1000 hours or more of exposure with few or no #8 

blisters. This must be determined on unscribed bonderite, in accordance with 

ASTM D4585-99, and ASTM D714-02e1, incorporated by reference in 

subsection VII.C.19; and 

4. The coating must have an adhesion rating of 4B or better after 24 hours of 

recovery. This must be determined on unscribed bonderite, in accordance with 

ASTM D4585-99 and ASTM D3359-02, incorporated by reference in 

subsection VII.C.16. 

GGG. Veneer: Thin sheets of wood peeled or sliced from logs for use in the manufacture of 

wood products such as plywood, laminated veneer lumber, or other products. 

HHH. Virgin Materials: Materials that contain no post-consumer coatings or secondary 

industrial materials. 

III. Volatile Organic Compound (VOC): Any volatile compound containing at least one 

atom of carbon, excluding Exempt Compounds as listed in Rule 102 Definitions. 

JJJ. VOC Actual: VOC Actual is the weight of VOC per volume of coating and it is 

calculated with the following equation: 

VOC Actual = (Ws – Ww – Wec)

 (Vm) 

Where: 

VOC Actual = the grams of VOC per liter of coating (also known 

 as Material VOC) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

KKK. VOC Content: The weight of VOC per volume of coating. VOC content is VOC 

Regulatory, as defined in section V.LLL, for all coatings except those in the Low 

Solids category. For all coatings in the Low Solids category, the VOC Content is 

VOC Actual, as defined in section V.JJJ. If the coating is a multi-component product, 

the VOC content is VOC Regulatory as mixed or catalyzed. If the coating contains 

silanes, siloxanes, or other ingredients that generate ethanol or other VOCs during the 

curing process, the VOC content must include the VOCs emitted during curing. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-10 Draft 4/5/2010 

LLL. VOC Regulatory: VOC Regulatory is the weight of VOC per volume of coating, less 

the volume of water and exempt compounds. It is calculated with the following 

equation: 

VOC Regulatory = (Ws – Ww – Wec)

(Vm – Vw – Vec) 

Where: 

VOC Regulatory = grams of VOC per liter of coating, less water and 

 exempt compounds (also known as Coating VOC) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

Vw = volume of water, in liters 

Vec = volume of exempt compounds, in liters 

MMM.Waterproofing Membrane: A clear or opaque coating that is labeled and formulated 

for application to concrete and masonry surfaces to provide a seamless waterproofing 

membrane that prevents any penetration of liquid water into the substrate. 

Waterproofing Membranes are intended for the following waterproofing applications: 

below-grade surfaces, between concrete slabs, inside tunnels, inside concrete planters, 

and under flooring materials. Waterproofing Membranes must meet the following 

criteria: 

1. Coating must be applied in a single coat of at least 25 mils (at least 0.025 

inch) dry film thickness; and 

2. Coatings must meet or exceed the requirements contained in ASTM C836-

06, incorporated by reference in subsection VII.C.20. 

The Waterproofing Membrane category does not include topcoats that are included in 

the Concrete/Masonry Sealer category (e.g., parking deck topcoats, pedestrian deck 

topcoats, etc.). 

NNN. Wood Coatings: Coatings labeled and formulated for application to wood substrates 

only. The Wood Coatings category includes the following clear and semitransparent 

coatings: lacquers; varnishes; sanding sealers; penetrating oils; clear stains; wood 

conditioners used as undercoats; and wood sealers used as topcoats. The Wood 

Coatings category also includes the following opaque wood coatings: opaque 

lacquers; opaque sanding sealers; and opaque lacquer undercoaters. The Wood 

Coatings category does not include the following: clear sealers that are labeled and 

formulated for use on concrete/masonry surfaces; or coatings intended for substrates 

other than wood. 

Wood Coatings must be labeled “For Wood Substrates Only”, in accordance with 

subsection VII.A.11. 

OOO. Wood Preservative: A coating labeled and formulated to protect exposed wood from 

decay or insect attack, registered with both the U.S. EPA under the Federal 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-11 Draft 4/5/2010 

Insecticide, Fungicide, and Rodenticide Act (7 United States Code (U.S.C.) Section 

136, et seq.) and with the California Department of Pesticide Regulation. 

PPP. Wood Substrates: A substrate made of wood, particleboard, plywood, medium 

density fiberboard, rattan, wicker, bamboo, or composite products with exposed wood 

grain. Wood Products do not include items comprised of simulated wood. 

QQQ. Zinc-Rich Primer: Is a coating that meets all of the following specifications: 

1. Coating contains at least 65 percent metallic zinc powder or zinc dust by 

weight of total solids; and 

2. Coating is formulated for application to metal substrates to provide a firm 

bond between the substrate and subsequent applications of coatings; and 

3. Coating is intended for professional use only and is labeled as such, in 

accordance with the labeling requirements in subsection VII.A.12. 

VI. Requirements

A. VOC Content Limits: No person except as provided in Subsections VI.B.and VI.C., 

shall: 

1. Manufacture, blend, or repackage for sale within the District; 

2. Supply, sell or offer for sale within the District; or 

3. Solicit for application or apply within the District, any architectural coating 

with a VOC content in excess of the corresponding VOC Content limit 

specified in the Table of Standards, after the specified effective date in the 

Table of Standards. Limits are expressed as VOC Regulatory, thinned to the 

manufacture’s maximum thinning recommendation, excluding any colorant 

added to tint bases. 

B. Most Restrictive VOC Limit: If a coating meets the definition in Section V for one 

or more specialty coating categories that are listed in the Table of Standards, then that 

coating is not required to meet the VOC limits for Flat, Nonflat, or Nonflat – High 

Gloss coatings, but is required to meet the VOC limit for the applicable specialty 

coating listed in the Table of Standards. 

With the exception of the specialty coating categories specified in subsections VI.B.1 

through VI.B.12, if a coating is recommended for use in more than one of the 

specialty coating categories listed in the Table of Standards, the most restrictive (or 

lowest) VOC content shall apply. This requirement applies to: usage 

recommendations that appear anywhere on the coating container, anywhere on any 

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

literature supplied by a manufacturer or anyone acting on their behalf. 

1. Metallic pigmented coatings. 

2. Shellacs. 

3. Pretreatment wash primers. 

4. Industrial maintenance coatings. 

5. Low-solids coatings. 

6. Wood preservatives. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-12 Draft 4/5/2010 

7. High-temperature coatings. 

8. Bituminous roof primers. 

9. Specialty primers, sealers and undercoaters. 

10. Aluminum roof coatings. 

11. Zinc-rich primers. 

12. Wood Coatings. 

C. Sell-Through/Existing Stock of Coatings: A coating manufactured prior to the VOC 

Content limit effective date(s) specified for that coating in the Table of Standards, 

that complied with the VOC Content limit in effect at the time the coating was 

manufactured, may be sold, supplied, or offered for sale for up to three years after the 

specified VOC Content limit effective date(s) listed in the Table of Standards. Such a 

coating may be applied at any time, both before and after the specified effective date. 

This subsection VI.C does not apply to any coating that does not display the date or 

date-code required by subsection VII.A.1. 

D. Painting Practices: All architectural coating containers used to apply the contents 

therein to a surface directly from the container by pouring, siphoning, brushing, 

rolling, padding, ragging or other means, shall be closed when not in use. Such 

architectural coating containers include, but are not limited to, drums, buckets, cans, 

pails, trays or other application containers. Containers of any VOC-containing 

materials used for thinning and cleanup shall also be closed when not in use. 

E. Thinning: No person who applies or solicits application of any architectural coating 

shall apply a coating thinned to exceed the applicable VOC limit specified in the 

Table of Standards. 

F. Coatings Not Listed in the Table of Standards: For any coating that does not meet 

any of the definitions for specialty coatings categories listed in the Table of 

Standards, the VOC content limit shall be determined by classifying the coating as a 

Flat, Nonflat, or Nonflat-High Gloss coating, based on its gloss, as defined in 

Subsections V.U., V.HH. and V.II. and the corresponding Flat, Nonflat, or NonflatHigh Gloss VOC limit in the Table of Standards shall apply. 

REMAINDER OF PAGE INTENTIONALLY LEFT BLANK 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-13 Draft 4/5/2010 

TABLE OF STANDARDS 

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Coating Category Effective 1/1/2011 Effective 1/1/2012 

Flat Coatings 50 

Nonflat Coatings 100 

Nonflat - High Gloss Coatings 150 

Specialty Coatings: 

Aluminum Roof Coatings 400 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 50 

Bituminous Roof Primers 350 

Bond Breakers 350 

Concrete Curing Compounds 350 

Concrete/Masonry Sealers 100 

Driveway Sealers 50 

Dry Fog Coatings 150 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Floor Coatings 100 

Form-Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatings2 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 100 

Metallic Pigmented Coatings 500 

Multi-Color Coatings 250 

Pre-Treatment Wash Primers 420 

Primers, Sealers, and Undercoaters 100 

Reactive Penetrating Sealers 350 

Recycled Coatings 250 

Roof Coatings 50 

Rust Preventative Coatings 400 250 

Shellacs: 

 Clear 

 Opaque 

730 

550 

Specialty Primers, Sealers, and Undercoaters 350 100 

Stains 250 

Stone Consolidants 450 

Swimming Pool Coatings 340 

Traffic Marking Coatings 100 

Tub and Tile Refinish Coatings 420 

Waterproofing Membranes 250 

Wood Coatings 275 

Wood Preservatives 350 

Zinc-Rich Primers 340 

1. Limits are expressed as VOC Regulatory thinned to the manufacturer’s maximum thinning 

recommendation, excluding any colorant added to tint bases. 

2. Limit is expressed as VOC Actual. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-14 Draft 4/5/2010 

VII. Administrative Requirements

A. Labeling Requirements: Each manufacturer of any architectural coating subject to 

this Rule shall display information listed in Subsections VII.A.1. through VII.A.12 on 

coating container (or label) in which coating is sold or distributed. 

1. Date Code: The date coating was manufactured, or date code representing 

date, shall be indicated on label, lid or bottom of container. If manufacturer 

uses a date code for any coating, manufacturer shall file an explanation of 

each code with the Executive Officer of the ARB. 

2. Thinning Recommendations: A statement of manufacturer's recommendation 

regarding thinning of coating shall be indicated on label or lid of container. 

This requirement does not apply to thinning of architectural coatings with 

water. If thinning of coating prior to use is not necessary, recommendation 

must specify coating is to be applied without thinning. 

3. VOC Content: Each container of any coating subject to this rule shall display 

one of the following values in grams of VOC per liter of coating: 

a.Maximum VOC Content as determined from all potential product 

formulations; or 

b.VOC Content as determined from actual formulation data; or 

c.VOC Content as determined using the test methods in subsection 

VII.C.2. 

If the manufacturer does not recommend thinning, the container must display 

the VOC Content, as supplied. If the manufacturer recommends thinning, the 

container must display the VOC Content including the maximum amount of 

thinning solvent recommended by the manufacturer. If the coating is a multicomponent product, the container must display the VOC content as mixed or 

catalyzed. If the coating contains silanes, siloxanes, or other ingredients that 

generate ethanol or other VOCs during the curing process, the VOC content 

must include the VOCs emitted during curing. VOC Content shall be 

determined as defined in subsections V.JJJ, V.KKK, and V.LLL. 

4. Faux Finishing Coatings: The labels of all clear topcoat Faux Finishing 

coatings shall prominently display the statement “This product can only be 

sold or used as part of a Faux Finishing coating system.” 

5. Industrial Maintenance Coatings: The labels of all Industrial Maintenance 

coatings shall prominently display the statement “For industrial use only” or 

“For professional use only” or “Not for residential use” or “Not intended for 

residential use”. 

6. Rust Preventative Coatings: The labels of all rust preventative coatings shall 

prominently display statement “For Metal Substrates Only”. 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-15 Draft 4/5/2010 

7. Specialty Primers, Sealers and Undercoaters: Until January 1, 2012, the labels 

of all specialty primers, sealers and undercoaters shall prominently display 

one or more of following descriptions: 

a. For fire damaged substrates; 

b. For smoke damaged substrates; 

c. For water damaged substrates; or 

8. Reactive Penetrating Sealers: The labels of all Reactive Penetrating Sealers 

shall prominently display the statement “Reactive Penetrating Sealer”. 

9. Stone Consolidants: The labels of all Stone Consolidants shall prominently 

display the statement “Stone Consolidant – For Professional Use Only”. 

10. Nonflat-High Gloss Coatings: The labels of all nonflat-high gloss coatings 

shall prominently display words “High Gloss”. 

11. Wood Coatings: The labels of all Wood Coatings shall prominently display 

the statement “For Wood Substrates Only”. 

12. Zinc Rich Primers: The labels of all Zinc Rich Primers shall prominently 

display one of the following statements “Not For Residential Use” or “Not 

Intended For Residential Use” or “For Industrial Use Only” or “For 

professional use only”. 

B. Reporting Requirements

1. Sales Data: A responsible official from each manufacturer shall upon request 

of the Executive Officer of the ARB, or his or her delegate, provide data 

concerning the distribution and sales of architectural coatings. The responsible 

official shall within 180 days provide information including, but not limited 

to: 

a. The name and mailing address of the manufacturer; 

b. The name, address and telephone number of a contact person; 

c. The name of the coating product as it appears on the label and the 

applicable coating category; 

d. Whether the product is marketed for interior or exterior use or both; 

e. The number of gallons sold in California in containers greater than one 

liter (1.057 quart) and equal to or less than one liter (1.057 quart); 

f. The VOC Actual content and VOC Regulatory content in grams per 

liter. If thinning is recommended, list the VOC Actual content and 

VOC Regulatory content after maximum recommended thinning. If 

containers less than one liter have a different VOC content than 

containers greater than one liter, list separately. If the coating is a 

multi-component product, provide the VOC content as mixed or 

catalyzed; 

g. The names and CAS numbers of the VOC constituents in the product; 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-16 Draft 4/5/2010 

h. The names and CAS numbers of any compounds in the product 

specifically exempted from the VOC definition, as listed in Rule 102 

Definitions; 

i. Whether the product is marketed as solventborne, waterborne, or 

100% solids; 

j. Description of resin or binder in the product; 

k. Whether the coating is a single-component or multi-component 

product; 

l. The density of the product in pounds per gallon; 

m. The percent by weight of: solids, all volatile materials, water, and any 

compounds in the product specifically exempted from the VOC; 

definition, as listed in Rule 102 Definitions 

n. The percent by volume of: solids, water, and any compounds in the 

product specifically exempted from the VOC definition, as listed in 

Rule 102 Definitions. 

2. All sales data listed in subsection VII.B.1.a to VII.B.1.n shall be maintained 

by the responsible official for a minimum of three years. Sales data submitted 

by the responsible official to the Executive Officer of the ARB may be 

claimed as confidential, and such information shall be handled in accordance 

with the procedures specified in Title 17, California Code of Regulations 

Sections 91000-91022. 

C. Test Methods

1. Calculation of VOC Content: For the purpose of determining compliance with 

the VOC content limits in the Table of Standards, the VOC content of a 

coating shall be determined as defined in subsection V.JJJ, V.KKK, or 

V.LLL. The VOC content of a tint base shall be determined without colorant 

that is added after the tint base is manufactured. If the manufacturer does not 

recommend thinning, the VOC content must be calculated for the product as 

supplied. If the manufacturer recommends thinning, the VOC content must be 

calculated including the maximum amount of thinning solvent recommended 

by the manufacturer. If the coating is a multi-component product, the VOC 

content must be calculated as mixed or catalyzed. If the coating contains 

silanes, siloxanes, or other ingredients that generate ethanol or other VOCs 

during the curing process, the VOC content must include the VOCs emitted 

during curing. 

2. VOC Content of Coatings: To determine physical properties of a coating in 

order to perform calculations in Subsections V.LLL. or V.JJJ., the reference 

method for VOC content shall be U.S. EPA Method 24, except as provided in 

Subsections VII.C.3 and VII.C.4. An alternative method to determine VOC 

content of coatings is SCAQMD Method 304-91 (Revised 1996), incorporated 

by reference in Subsection VII.C.4. The exempt compounds content shall be 

determined by SCAQMD Method 303-91 (Revised 1993), BAAQMD Method 

43 (Revised 1996), or BAAQMD Method 41 (Revised 1995), as applicable, 

incorporated by reference in Subsection VII.C.12, VII.C.13, and VII.C.14, 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-17 Draft 4/5/2010 

respectively. To determine VOC content of a coating, the manufacturer may 

use U.S. EPA Method 24, or an alternative method as provided in Subsection 

VII.C.3., formulation data, or any other reasonable means for predicting 

coating has been formulated as intended (e.g., quality assurance checks, 

recordkeeping). However, if there are any inconsistencies between results of 

a Method 24 test and any other means for determining VOC content, Method 

24 test results will govern, except when an alternative method is approved as 

specified in Subsection VII.C.3. The District Air Pollution Control Officer 

(APCO) may require manufacturer to conduct a Method 24 analysis. 

3. Alternative Test Methods: Other test methods demonstrated to provide results 

acceptable for purposes of determining compliance with Subsection VII.C.2., 

after review and approved in writing by the staffs of District, ARB and U.S. 

EPA, may also be used. 

4. Alternative VOC Content of Coatings: The VOC content of coatings may be 

analyzed either by U.S. EPA Method 24 or SCAQMD Method 304-91 

(Revised 1996), “Determination of Volatile Organic Compounds (VOC) in 

Various Materials”, “SCAQMD Laboratory Methods of Analysis for 

Enforcement Samples” (see Subsection VII.C.2.). 

5. VOC Content of Coatings: The VOC content of a coating shall be determined 

by U.S. EPA Method 24 as it exists in Appendix A of 40 Code of Federal 

Regulations (CFR) Part 60, “Determination of Volatile Matter Content, Water 

Content, Density, Volume Solids and Weight Solids of Surface Coatings” (see 

Subsection VII.C.2.). 

6. Methacrylate Traffic Marking Coatings: The VOC content of methacrylate 

multicomponent coatings used as traffic marking coatings shall be analyzed 

by procedures in 40 CFR Part 59, Subpart D, Appendix A, “Determination of 

Volatile Matter Content of Methacrylate Multicomponent Coatings Used as 

Traffic Marking Coatings”. (This method has not been approved for 

methacrylate multicomponent coatings used for other purposes than traffic 

marking coatings or for other classes of multicomponent coatings). 

7. Flame Spread Index: The flame spread index of a fire retardant coating shall 

be determined by ASTM E 84-07, “Standard Test Method for Surface Burning 

Characteristics of Building Materials” (see Subsection V.T., Fire Retardant 

Coating). 

8. Fire Resistance Rating: The fire resistance rating of a fire resistive coating 

shall be determined by ASTM E 119-07, “Standard Test Methods for Fire 

Tests of Building Construction Materials” (see Subsection V.S., Fire Resistive 

Coating). 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-18 Draft 4/5/2010 

9. Gloss Determination: Gloss of a coating shall be determined by ASTM D 

523-89 (1999), “Standard Test Method for Specular Gloss” (see Subsections 

V.U., V.HH., and V.II. Flat Coating, Nonflat Coating, and Nonflat-High Gloss 

Coating). 

10. Metal Content of Coatings: Metallic content of a coating shall be determined 

by SCAQMD Method 318-95, “Determination of Weight Percent Elemental 

Metal in Coatings by X-Ray Diffraction,” SCAQMD Laboratory Methods of 

Analysis for Enforcement Samples (see Subsections V.C., V.R., and V.FF; 

Aluminum Roof, Faux Finishing, and Metallic Pigmented Coating). 

11. Acid Content of Coatings: The acid content of a coating shall be determined 

by ASTM D 1613-06, “Standard Test Method for Acidity in Volatile Solvents 

and Chemical Intermediaries Used in Paint, Varnish, Lacquer and Related 

Products” (see Subsection V.NN., Pretreatment Wash Primer). 

12. Exempt Compounds: The content of compounds pursuant to U.S. EPA 

Method 24 shall be analyzed by SCAQMD Method 303-91 (Revised 1993), 

“Determination of Exempt Compounds”, “SCAQMD Laboratory Methods of 

Analysis for Enforcement Samples” (see Subsection V.III., Volatile Organic 

Compound and Subsection VII.C.2.). 

13. Exempt Compounds–Siloxanes: Exempt compounds that are cyclic, branched 

or linear completely methylated siloxanes, shall be analyzed as exempt 

compounds for compliance with Section VIII by BAAQMD Method 43, 

“Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks, 

and Related Materials”, “BAAQMD Manual of Procedures”, Volume III, 

adopted 11/6/96 (see Subsection V.III., Volatile Organic Compound and 

Subsection VII.C.2.). 

14. Exempt Compounds– Parachlorobenzotrifluoride (PCBTF): The exempt 

compound parachlorobenzotrifluoride shall be analyzed as an exempt 

compound for compliance with Section VIII by BAAQMD Method 41, 

“Determination of Volatile Organic Compounds in Solvent-Based Coatings 

and Related Materials Containing Parachlorobenzotrifluoride”, “BAAQMD 

Manual of Procedures”, Volume III, adopted 12/20/95 (see Subsection V.III., 

Volatile Organic Compounds and Subsection VII.C.2.). 

15. Hydrostatic Pressure for Basement Specialty Coatings: ASTM D7088-04, 

“Standard Practice for Resistance to Hydrostatic Pressure for Coatings Used 

in Below Grade Applications Applied to Masonry” (see section V.F., 

Basement Specialty Coating). 

16. Tub and Tile Refinish Coating Adhesion: ASTM D 4585-99, “Standard 

Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation” and ASTM D3359-02, “Standard Test Methods for Measuring 

Adhesion by Tape Test” (see section V.FFF., Tub and Tile Refinish Coating). 
410.1A Final Staff Report – Adopted Rule 

Appendix A A-19 Draft 4/5/2010 

17. Tub and Tile Refinish Coating Hardness: ASTM D 3363-05, “Standard Test 

Method for Film Hardness by Pencil Test” (see section V.FFF., Tub and Tile 

Refinish Coating). 

18. Tub and Tile Refinish Coating Abrasion Resistance: ASTM D 4060-07, 

“Standard Test Methods for Abrasion Resistance of Organic Coatings by the 

Taber Abraser” (see section V.FFF., Tub and Tile Refinish Coating). 

19. Tub and Tile Refinish Coating Water Resistance: ASTM D 4585-99, 

“Standard Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation” and ASTM D714-02e1, “Standard Test Method for Evaluating 

Degree of Blistering of Paints” (see section V.FFF., Tub and Tile Refinish 

Coating). 

20. Waterproofing Membrane: ASTM C836-06, “Standard Specification for High 

Solids Content, Cold Liquid-Applied Elastomeric Waterproofing Membrane 

for Use with Separate Wearing Course” (see section V.MMM., Waterproofing 

Membrane). 

21. Mold and Mildew Growth for Basement Specialty Coatings: ASTM D3273-

00, “Standard Test Method for Resistance to Growth of Mold on the Surface 

of Interior Coatings in an Environmental Chamber” and ASTM D3274-95, 

“Standard Test Method for Evaluating Degree of Surface Disfigurement of 

Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt 

Accumulation” (see section V.F., Basement Specialty Coating). 

22. Reactive Penetrating Sealer Water Repellency: ASTM C67-07, “Standard 

Test Methods for Sampling and Testing Brick and Structural Clay Tile”; or 

ASTM C97-02, “Standard Test Methods for Absorption and Bulk Specific 

Gravity of Dimension Stone”; or ASTM C140-06, “Standard Test Methods 

for Sampling and Testing Concrete Masonry Units and Related Units” (see 

section V.PP., Reactive Penetrating Sealer). 

23. Reactive Penetrating Sealer Water Vapor Transmission: ASTM E96/E96M05, “Standard Test Method for Water Vapor Transmission of Materials” (see 

section V.PP., Reactive Penetrating Sealer). 

24. Reactive Penetrating Sealer - Chloride Screening Applications: National 

Cooperative Highway Research Report 244 (1981), “Concrete Sealers for the 

Protection of Bridge Structures” (see section V.PP., Reactive Penetrating 

Sealer). 

25. Stone Consolidants: ASTM E2167-01, “Standard Guide for Selection and 

Use of Stone Consolidants” (see section V.BBB., Stone Consolidant). 
APPENDIX B: 

ADOPTED RULE 410.1A 

ARCHITECTURAL COATING CONTROLS 

STRIKEOUT UNDERLINE WORKSHOP VERSION 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-1 Draft 4/5/2010 

RULE 410.1A Architectural Coating Controls Adopted 3/11/10 Effective as of 

1/1/2011

I. Purpose

 The purpose of this rule is to limit VOC emissions from architectural coatings. This rule 

specifies VOC Content limits, storage, cleanup, and labeling requirements for 

architectural coatings. 

II. Applicability

Except as provided in subsection IV, the provisions of this rule are applicable to 

architectural coatings as defined in this rule and to any person who manufactures, blends, 

repackages, supplies, sells, offers for sale, solicits, or applies any architectural coating for 

use within the District. 

III. Severability

 Each provision of this rule shall be deemed severable, and in the event that any provision 

of this rule is held to be invalid, the remainder of this rule shall continue in full force and 

effect. 

IV. Exemptions

A. Provisions of this Rule shall not apply to:

1. Any architectural coating that is supplied, sold, offered for sale, or 

manufactured for use outside of the District or for shipment to other 

manufacturers for reformulation or repackaging.

2. Any aerosol coating product.

B. any architectural coating that is supplied, sold, offered for sale, or manufactured for 

use outside of the District or for shipment to other manufacturers for reformulation or 

repackaging.

B. Provisions of section VI and subsection VII.A shall not apply to any architectural 

coating sold in a container with a volume of one liter (1.057 quarts) or less.

C.Provisions of section VI and subsection VII.A shall not apply to any architectural 

coating sold in a container with a volume of one liter (1.057 quarts) or less.

IVV. Definitions

A. Adhesive: Any chemical substance applied for the purpose of bonding two surfaces 

together other than by mechanical means. 

B. Aerosol Coating Product: A pressurized coating product containing pigments or 

resins that dispenses product ingredients by means of a propellant and are is packaged 

in a disposable can for hand-held application, or for use in specialized equipment for 

ground traffic/marking applications. 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-2 Draft 4/5/2010 

C. Aluminum Roof Coating: A coating labeled and formulated exclusively for 

application to roofs and containing at least 84 grams of elemental aluminum pigment 

per liter of coating (at least 0.7 pounds per gallon). Pigment content shall be 

determined in accordance with SCAQMD Method 318-95, incorporated by reference 

in subsection VII.C.910. 

D. Appurtenance: Any accessory to a stationary structure coated at the site of 

installation, whether installed or detached, including but not limited to: bathroom and 

kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand railings; 

heating equipment, air conditioning equipment and other fixed mechanical equipment 

or stationary tools; lampposts; partitions; pipes and piping systems; rain gutters and 

downspouts; stairways, fixed ladders, catwalks and fire escapes; and window screens. 

E. Architectural Coating: A coating to be applied to stationary structures or their 

appurtenances at the site of installation, to portable buildings at the site of installation, 

to pavements, or to curbs. Coatings applied in shop applications or to nonstationary 

structures such as airplanes, airships, ships, boats, locomotives, railcars and 

automobiles, and adhesives are not considered architectural coatings for the purposes 

of this Rule. 

F. Basement Specialty Coating: A clear or opaque coating that is labeled and 

formulated for application to concrete and masonry surfaces to provide a hydrostatic 

seal for basements and other below-grade surfaces. Basement Specialty Coatings 

must meet the following criteria: 

1. Coating must be capable of withstanding at least 10 psi of hydrostatic 

pressure, as determined in accordance with ASTM D7088-04, which is 

incorporated by reference in subsection VII.C.1415; 

2. Coating must be resistant to mold and mildew growth and must achieve a 

microbial growth rating of 8 or more, as determined in accordance with 

ASTM D3273-00 and ASTM D3274-95, incorporated by reference in 

subsection VII.C.2021. 

G. Bitumens: Black or brown materials including, but not limited to, asphalt, tar, pitch 

and asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons and 

are obtained from natural deposits or are as residues from distillation of crude 

petroleum or coal. 

H. Bituminous Roof Coating: A coating which incorporates bitumens that is labeled and 

formulated exclusively for roofing. 

I. Bituminous Roof Primer: A primer which incorporates bitumens that is labeled and 

formulated exclusively for roofing and intended for the purpose of preparing a 

weathered or aged surface or improving the adhesion of subsequent surfacing 

components. 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-3 Draft 4/5/2010 

J. Bond Breaker: A coating labeled and formulated for application between layers of 

concrete to prevent a freshly poured top layer of concrete from bonding to the layer 

over which it is poured. 

K. Coating: A material applied onto or impregnated into a substrate for protective, 

decorative or functional purposes. Such materials include, but are not limited to, 

paints, varnishes, sealers and stains. 

L. Colorant: A concentrated pigment dispersed in water, solvent and/or binder that is 

added to an architectural coating after packaging in sale units to produce the desired 

color. 

M. Concrete Curing Compound: A coating labeled and formulated for application to 

freshly poured concrete to perform one or more of the following functions: 

1. Retard the evaporation of water; or 

2. Harden or dustproof the surface of freshly poured concrete. 

N. Concrete/Masonry Sealer: A clear or opaque coating that is labeled and formulated 

primarily for application to concrete and masonry surfaces to perform one or more of 

the following functions: 

1. Prevent penetration of water; or 

2. Provide resistance against abrasion, alkalis, acids, mildew, staining, or 

ultraviolet light; or 

3. Harden or dustproof the surface of aged or cured concrete. 

O. Driveway Sealer: A coating labeled and formulated for application to worn asphalt 

driveway surfaces to perform one or more of the following functions: 

1. Fill cracks; or 

2. Seal the surface to provide protection; or 

3. Restore or preserve the appearance. 

P. Dry Fog Coating: A coating labeled and formulated only for spray application such 

that overspray droplets dry before subsequent contact with incidental surfaces in the 

vicinity of the surface coating activity. 

Q. Exempt Compound: A compound identified as exempt pursuant to the definition of 

Volatile Organic Compound (VOC), Subsection IV. KKKIII. Exempt compounds 

content of a coating shall be determined by U.S. EPA Method 24 or South Coast Air 

Quality Management District (SCAQMD) Method 303-91 (Revised August 

19961993), incorporated by reference in Subsection VII.C.1112. 

R. Faux Finish Coating: A coating labeled and formulated to meet one or more of the 

following criteria: 

1. A glaze or textured coating used to create artistic effects including, but not 

limited to: dirt, suede, old age, smoke damage, and simulated marble or wood 

grain; or 

2. A decorative coating used to create a metallic, iridescent, or pearlescent 

appearance that contains at least 48 grams of pearlescent mica pigment or 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-4 Draft 4/5/2010 

other iridescent pigment per liter of coating as applied (at least 0.4 pounds per 

gallon); or 

3. A decorative coating used to create a metallic appearance that contains less 

than 48 grams of elemental metallic pigment per liter of coating as applied 

(less than 0.4 pounds per gallon), when tested in accordance with SCAQMD 

Method 318-95, incorporated by reference in subsection VII.C.910; or 

4. A decorative coating used to create a metallic appearance that contains greater 

than 48 grams of elemental metallic pigment per liter of coating as applied 

(greater than 0.4 pounds per gallon) and which requires a clear topcoat to 

prevent the degradation of the finish under normal use conditions. The 

metallic pigment content shall be determined in accordance with SCAQMD 

Method 318-95, incorporated by reference in subsection VII.C.10; or

5. A clear topcoat to seal and protect a Faux Finishing coating that meets the 

requirements of subsection IV.R.1, IV.R.2, IV.R.3, or VR.4. These clear 

topcoats must be sold and used solely as part of a Faux Finishing coating 

system, and must be labeled in accordance with subsection VII.A.4.

S. Fire Resistive Coating: A coating labeled and formulated to protect structural 

integrity by increasing fire endurance of interior or exterior steel and other structural 

materials. The Fire Resistive category includes sprayed fire resistive materials and 

intumescent fire resistive coatings that are used to bring structural materials into 

compliance with Federal, State and local building code requirements. Any fire 

resistive coating and a testing agency must be approved by building code officials. 

Any fire resistive coating shall be tested in accordance with ASTM Designation E 

119-07, incorporated by reference in Subsection VII.C.78. 

T. Fire Retardant Coating: A coating labeled and formulated to retard ignition and 

flame spread, that has been fire tested and rated by a testing agency approved by 

building code officials for use in bringing building and construction materials into 

compliance with federal, state and local building code requirements. The fireretardant coating and the testing agency must be approved by building code officials. 

The fire-retardant coating shall be tested in accordance with ASTM Designation E 

84-07, incorporated by reference in subsection VII.C.7. Effective January 1, 2011, 

the Fire Retardant coating category is eliminated and Coatings coatings with fire 

retardant properties will be subject to the VOC limit of their primary category (e.g., 

Flat Nonflat, ECT.). Any fire retardant coating shall be tested in accordance with 

ASTM Designation E 84-99, incorporated by reference in Subsection VII.C.6.

U. Flat Coating: A coating not defined under any other definition in this Rule and that 

registers gloss less than 15 on an 85 degree meter or less than five on a 60 degree 

meter according to ASTM Designation D 523-89 (1999), incorporated by reference in 

Subsection VII.C.89. 

V. Floor Coating: An opaque coating labeled and formulated for application to flooring, 

including, but not limited to, decks, porches, steps, garage floors, and other horizontal 

surfaces which may be subject to foot traffic. 
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W. Form-Release Compound: A coating labeled and formulated for application to a 

concrete form to prevent freshly poured concrete from bonding to the form. The form 

may consist of wood, metal or some material other than concrete. 

X.Gonioapparent: A change in appearance with a change in the angle of illumination or 

the angle of view, as defined according to ASTM E-284-06b, incorporated by 

reference in subsection VII.C15.

Y.X. Graphic Arts Coating or Sign Paint: A coating labeled and formulated for handapplication by artists using brush, air brush, or roller techniques to indoor and outdoor 

signs (excluding structural components) and murals including lettering enamels, 

poster colors, copy blockers and bulletin enamels. 

Z.Y. High-Temperature Coating: A high performance coating labeled and formulated 

for application to substrates exposed continuously or intermittently to temperatures 

above 204°C (400°F). 

AA.Z. Industrial Maintenance Coating: High performance architectural coatings 

including antenna, antifouling, intermediate coats, primers, sealers, undercoaters, 

intermediate coats, and topcoats, and undercoaters formulated for application to 

substrates, including floors, exposed to one or more of the following extreme 

environmental conditions listed in Subsections IV.AAZ.1. through IV.AAZ.5. and 

labeled as specified in Subsection VII.A.5

1. Immersion in water, wastewater or chemical solutions (aqueous and nonaqueous solutions), or chronic exposure of interior surfaces to moisture 

condensation; 

2. Acute or chronic exposure to corrosive, caustic or acidic agents or to 

chemicals, chemical fumes or chemical mixtures or solution; 

3. Frequent exposure to temperatures above 121°C (250°F); 

4. Frequent heavy abrasion, including mechanical wear and frequent scrubbing 

with industrial solvents, cleansers or scouring agents; or 

5. Exterior exposure of metal structures and structural components. 

BB.AA. Low Solids Coating: A coating containing 0.12 kilogram or less of solids per liter 

(1 pound or less of solids per gallon) of coating material as recommended for 

application by the manufacturer. The VOC content for Low Solids Coatings shall be 

calculated in accordance with section V.LLLJJJ. 

CC.BB. Magnesite Cement Coating: A coating labeled and formulated for application to 

magnesite cement decking to protect the magnesite cement substrate from erosion by 

water. 

DD.CC. Manufacture’s Maximum Thinning Recommendations: The maximum 

recommendation for thinning that is indicated on the label or lid of the coating 

container. 
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Appendix B B-6 Draft 4/5/2010 

EE.DD. Mastic Texture Coating: A coating labeled and formulated to cover holes and 

minor cracks and to conceal surface irregularities, and applied in a single coat of at 

least 10 mils (at least0.010 inch) dry film thickness. 

FF.EE. Medium Density Fiberboard (MDF): A composite wood product, panel, molding, 

or other building material composed of cellulosic fibers (usually wood) made by dry 

forming and pressing a resinated fiber mat. 

GG.Metallic: Similar to the appearance of a gonioapparent material, as defined herein, 

containing metal flakes.

HH.FF. Metallic Pigmented Coating: A coating that is labeled and formulated to provide 

a metallic appearance. Metallic Pigmented coatings must contain at least 48 grams of 

elemental metallic pigment (excluding zinc) per liter of coating as applied (at least 0.4 

pounds per gallon), when tested in accordance with SCAQMD Method 318-95, 

incorporated by reference in Subsection VII.C.910. The Metallic Pigmented Coating 

category does not include coatings applied to roofs or Zinc-Rich Primers. 

II.GG. Multicolor Coating: A coating packaged in a single container and that is labeled 

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

JJ.HH. Nonflat Coating: coating not defined under any other definition in this Rule and 

that registers a gloss of 15 or greater on an 85 degree meter and 5 or greater on a 60 

degree meter according to ASTM Designation D 523-89 (1999), incorporated by 

reference in Subsection VII.C.89. 

KK.II. Nonflat - High Gloss Coating: A nonflat coating that registers a gloss of 70 or 

above on a 60 degree meter according to ASTM Designation D 523-89 (1999), 

incorporated by reference in Subsection VII.C.89. Nonflat - High Gloss coatings must 

be labeled in accordance with subsection VII.A.910. 

LL.JJ. Particleboard: A composite wood product panel, molding, or other building 

material composed of cellulosic material (usually wood) in the form of discrete 

particles, as distinguished from fibers, flakes, or strands, which are pressed together 

with resin. 

MM.KK.Pearlescent: Exhibiting various colors depending on the angles of illumination 

and viewing, as observed in mother-of-pear. 

NN.LL. Plywood: A panel product consisting of layers of wood veneers or composite 

core pressed together with resin. Plywood includes panel products made by either hot 

or cold pressing (with resin) veneers to a platform. 

OO.MM.Post Consumer Coating: Finished coatings generated by a business or consumer 

that have served their intended end uses, and are recovered from or otherwise diverted 

from the waste stream for the purpose of recycling. 
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PP.NN. Pre-Treatment Wash Primer: A primer that contains a minimum of 0.5 percent 

acid, by weight, when tested in accordance with ASTM Designation D 1613-9606, 

incorporated by reference in Subsection VII.C.1011. labeled and formulated for 

application directly to bare metal surfaces to provide corrosion resistance and to 

promote adhesion of subsequent topcoats. 

QQ.OO. Primer, Sealer, and Undercoater: A coating labeled and formulated for one or 

more of the following purposes: 

1. To provide a firm bond between the substrate and the subsequent coatings; or 

2. To prevent subsequent coatings from being absorbed by the substrate; or 

3. To prevent harm to subsequent coatings by materials in the substrate; or 

4. To provide a smooth surface for the subsequent application of coatings; or 

5. To provide a clear finish coat to seal the substrate; or 

6. To block materials from penetrating into or leaching out of a substrate. 

RR.PP. Reactive Penetrating Sealer: A clear or pigmented coating that is labeled and 

formulated for application to above-grade concrete and masonry substrates to provide 

protection from water and waterborne contaminates, including but not limited to 

alkalis, acids, and salts. Reactive Penetrating Sealers must penetrate into concrete and 

masonry substrates and chemically react to form covalent bonds with naturally 

occurring minerals in the substrate. Reactive Penetrating Sealers line the pores of 

concrete and masonry substrates with a hydrophobic coating, but do not form a 

surface film. Reactive Penetrating Sealers must meet all of the following criteria: 

1. The Reactive Penetrating Sealer must improve water repellency at least 80 

percent after application on a concrete or masonry substrate. This performance 

must be verified on standardized test specimens, in accordance with one or 

more of the following standards, incorporated by reference in subsection 

VII.C.22: ASTM C67-07, or ASTM C97-02, or ASTM C140-06; and 

2. The Reactive Penetrating Sealer must not reduce the water vapor transmission 

rate by more than 2 percent after application on a concrete or masonry 

substrate. This performance must be verified on standardized test specimens, 

in accordance with ASTM E96/E96M-05, incorporated by reference in 

subsection VII.C.23; and 

3. Products labeled and formulated for vehicular traffic surface chloride 

screening applications must meet the performance criteria listed n the National 

Cooperative highway Research Report 244 (1981), incorporated by reference 

in subsection VII.C.24; and 

4. Reactive Penetrating Sealers must be labeled in accordance with subsection 

VII.A.8. 

SS.QQ. Recycled Coating: An architectural coating formulated such that it contains a 

minimum of 50% by volume post-consumer coating, with a maximum of 50% by 

volume secondary industrial materials or virgin materials. 

TT.RR. Residential: Areas where people reside or lodge, including, but not limited to, 

single and multiple family dwellings, condominiums, mobile homes, apartment 

complexes, motels and hotels. 
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UU.SS. Roof Coating: A non-bituminous coating labeled and formulated for application 

to roofs for the primary purpose of preventing water penetration, reflecting ultraviolet 

light, or reflecting solar radiation. 

VV.TT. Rust Preventative Coating: A coating formulated to prevent corrosion of metal 

surfaces for one or more of the following applications: 

1. Direct-to-metal coating; or 

2. Coating intended for application over rusty, previously coated surfaces. 

The Rust Preventative category does not include the following: 

3. Coatings that are required to be applied as a topcoat over a primer; or 

4. Coatings that are intended for use on wood or any other nonmetallic surface. 

Rust Preventative coatings are for metal substrates only and must be labeled as such, 

in subsection VII.A.6. 

WW.UU. Secondary Industrial Materials: Products of or by-products of the paint 

manufacturing process that are of known composition and have economic value but 

can no longer be used for their intended purpose. 

XX.VV. Semitransparent Coating: A coating that contains binders and colored pigments 

and is formulated to change the color of the surface, but not conceal the grain pattern 

of or texture. 

YY.WW. Shellac: A clear or opaque coating formulated solely with resinous 

secretions of the lac beetle (Laciffer lacca), and formulated to dry by evaporation 

without a chemical reaction. 

ZZ.XX. Shop Application: Application of a coating to a product or a component of a 

product in or on the premises of a factory or a shop as part of a manufacturing, 

production or repairing process (e.g., original equipment manufacturing coatings). 

AAA.YY. Solicit: To require for use or to specify, by written or oral contract. 

ZZ. Specialty Primer, Sealer and Undercoater: A coating that is formulated for 

application to a substrate to block water-soluble stains resulting from: fire damage; 

smoke damage; or water damage. Specialty Primers, Sealers, and Undercoaters must 

be labeled in accordance with subsection VII.A.7. 

CCC.AAA. Stain: A semitransparent or opaque coating labeled and formulated to 

change the color of a surface but not conceal grain pattern or texture. 

DDD.BBB. Stone Consolidant: A coating that is labeled and formulated for 

application to stone substrates to repair historical structures that have been damaged 

by weather or other decay mechanisms. Stone Consolidants must penetrate into 

substrates to create bonds between particles and consolidate deteriorated material. 

Stone Consolidants must be specified and used in accordance with ASTM E2167-01, 

incorporated by reference in subsection VII.C.25. 
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Appendix B B-9 Draft 4/5/2010 

Stone Consolidants are for professional use only and must be labeled as such, in 

accordance with the labeling requirements in subsection VII.C.1210. 

EEE.CCC. Swimming Pool Coating: A coating labeled and formulated to coat the interior of 

swimming pools and to resist swimming pool chemicals. Swimming pool coatings 

include coatings used for swimming pool repair and maintenance. 

FFF.DDD. Tint Base: An architectural coating to which colorant is added after packaging in 

sale units to produce a desired color. 

GGG.EEE.Traffic Marking Coating: A coating labeled and formulated for marking and 

striping streets, highways or other traffic surfaces including, but not limited to, curbs, 

berms, driveways, parking lots, sidewalks and airport runways. 

HHH.FFF. Tub and Tile Refinish Coating: A clear or opaque coating that is labeled and 

formulated exclusively for refinishing the surface of a bathtub, shower, sink, or 

countertop. Tub and Tile Refinish coatings must meet all of the following criteria: 

1. The coating must have a scratch hardness of 3H or harder and a gouge 

hardness of 4H or harder. This must be determined on bonderite 1000, in 

accordance with ASTM D3363-05, incorporated by reference in subsection 

VII.C.17; and 

2. The coating must have a weight loss of 20 milligrams or less after 1000 

cycles. This must be determined with CS-17 wheels on bonderite 1000, in 

accordance with ASTM D4060-07, incorporated by reference in subsection 

VII.C.18; and 

3. The coating must withstand 1000 hours or more of exposure with few or no #8 

blisters. This must be determined on unscribed bonderite, in accordance with 

ASTM D4585-99, and ASTM D714-02e1, incorporated by reference in 

subsection VII.C.19; and 

4. The coating must have an adhesion rating of 4B or better after 24 hours of 

recovery. This must be determined on unscribed bonderite, in accordance with 

ASTM D4585-99 and ASTM D3359-02, incorporated by reference in 

subsection VII.C.16. 

III.GGG.Veneer: Thin sheets of wood peeled or sliced from logs for use in the 

manufacture of wood products such as plywood, laminated veneer lumber, or other 

products. 

JJJ.HHH. Virgin Materials: Materials that contain no post-consumer coatings or 

secondary industrial materials. 

KKK.III. Volatile Organic Compound (VOC): Any volatile compound containing at least 

one atom of carbon, excluding Exempt Compounds as listed in Rule 102 Definitions. 

LLL.JJJ. VOC Actual: VOC Actual is the weight of VOC per volume of coating and it is 

calculated with the following equation: 

VOC Actual = (Ws – Ww – Wec)
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Appendix B B-10 Draft 4/5/2010 

 (Vm) 

Where: 

VOC Actual = the grams of VOC per liter of coating (also known 

 as Material VOC) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

MMM.KKK. VOC Content Calculation: The weight of VOC per volume of coating.

VOC content is VOC Regulatory, as defined in section IV.NNNLLL, for all coatings 

except those in the Low Solids category. For all coatings in the Low Solids category, 

the VOC Content is VOC Actual, as defined in section IV.LLLJJJ. If the coating is a 

multi-component product, the VOC content is VOC Regulatory as mixed or 

catalyzed. If The the coating contains silanes, siloxanes, or other ingredients that 

generate ethanol or other VOCs during the curing process, the VOC content must 

include the VOCs emitted during curing. 

NNN.LLL.VOC Regulatory: VOC Regulatory is the weight of VOC per volume of coating, 

less the volume of water and exempt compounds. It is calculated with the following 

equation: 

VOC Regulatory = (Ws – Ww – Wec)

(Vm – Vw – Vec) 

Where: 

VOC Regulatory = grams of VOC per liter of coating, less water and 

 exempt compounds (also known as Coating VOC) 

Ws = weight of volatiles, in grams 

Ww = weight of water, in grams 

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

Vw = volume of water, in liters 

Vec = volume of exempt compounds, in liters 

OOO.MMM. Waterproofing Membrane: A clear or opaque coating that is labeled and 

formulated for application to concrete and masonry surfaces to provide a seamless 

waterproofing membrane that prevents any penetration of liquid water into the 

substrate. Waterproofing Membranes are intended for the following waterproofing 

applications: below-grade surfaces, between concrete slabs, inside tunnels, inside 

concrete planters, and under flooring materials. Waterproofing Membranes must meet 

the following criteria: 

1. Coating must be applied in a single coat of at least 25 mils (at least 0.025 

inch) dry film thickness; and 

2. Coatings must meet or exceed the requirements contained in ASTM C836-06, 

incorporated by reference in subsection VII.C.20. 
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Appendix B B-11 Draft 4/5/2010 

The Waterproofing Membrane category does not include topcoats that are included in 

the Concrete/Masonry Sealer category (e.g., parking deck topcoats, pedestrian deck 

topcoats, etc.). 

PPP.NNN. Wood Coatings: Coatings labeled and formulated for application to wood 

substances substrates only. The Wood Coatings category includes the following clear 

and semitransparent coatings: lacquers; varnishes; sanding sealers; penetrating oils; 

clear stains; wood conditioners used as undercoats; and wood sealers used as 

topcoats. The Wood Coatings category also includes the following opaque wood 

coatings: opaque lacquers; opaque sanding sealers; and opaque lacquer undercoaters. 

The Wood Coatings category does not include the following: clear sealers that are 

labeled and formulated for use on concrete/masonry surfaces; or coatings intended for 

substrates other than wood. 

Wood Coatings must be labeled “For Wood Substrates Only”, in accordance with 

subsection VII.A.11. 

QQQ.OOO. Wood Preservative: A coating labeled and formulated to protect exposed 

wood from decay or insect attack, registered with both the U.S. EPA under the 

Federal Insecticide, Fungicide, and Rodenticide Act (7 United States Code (U.S.C.) 

Section 136, et seq.) and with the California Department of Pesticide Regulation. 

RRR.PPP. Wood Substrates: A substrate made of wood, particleboard, plywood, medium 

density fiberboard, rattan, wicker, bamboo, or composite products with exposed wood 

grain. Wood Products do not include items comprised of simulated wood. 

SSS.QQQ. Zinc-Rich Primer: Is a coating that meets all of the following specifications: 

1. Coating contains at least 65 percent metallic zinc powder or zinc dust by 

weight of total solids; and 

2. Coating is formulated for application to metal substrates to provide a firm 

bond between the substrate and subsequent applications of coatings; and 

3. Coating is intended for professional use only and is labeled as such, in 

accordance with the labeling requirements in subsection VII.A.12. 

V. Exemptions

A.Provisions of this Rule shall not apply to any architectural coating that is supplied, 

sold, offered for sale, or manufactured for use outside of the District or for shipment 

to other manufacturers for reformulation or repackaging.

B.Provisions of section VI and subsection VII.A shall not apply to any architectural 

coating sold in a container with a volume of one liter (1.057 quarts) or less.

VI. Requirements

A. VOC Content Limits: No person except as provided in Subsections VI.B., .and VI.C., 

and VI.H. shall: 

1. Manufacture, blend, or repackage for sale within the District; 
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Appendix B B-12 Draft 4/5/2010 

2. Supply, sell or offer for sale within the District; or 

3. Solicit for application or apply within the District, any architectural coating 

with a VOC content in excess of the corresponding VOC Content limit 

specified in the Table of Standards, after the specified effective date in the 

Table of Standards. Limits are expressed as VOC Regulatory, thinned to the 

manufacture’s maximum thinning recommendation, excluding and any

colorant added to tint bases. 

B. Most Restrictive VOC Limit: If a coating meets the definition in Section IV for one 

or more specialty coating categories that are listed in the Table of Standards, then that 

coating is not required to meet the VOC limits for Flat, Nonflat, or Nonflat – High 

Gloss coatings, but is required to meet the VOC limit for the applicable specialty 

coating listed in the Table of Standards. 

With the exception of the specialty coating categories specified in subsections VI.B.1 

through VI.B.12, if a coating is recommended for use in more than one of the 

specialty coating categories listed in the Table of Standards, the most restrictive (or 

lowest) VOC content shall apply. This requirement applies to: usage 

recommendations that appear anywhere on the coating container, anywhere on any 

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

literature supplied by a manufacturer or anyone acting on their behalf. 

1. Metallic pigmented coatings. 

2. Shellacs. 

3. Pretreatment wash primers. 

4. Industrial maintenance coatings. 

5. Low-solids coatings. 

6. Wood preservatives. 

7. High-temperature coatings. 

8. Bituminous roof primers. 

9. Specialty primers, sealers and undercoaters. 

10. Aluminum roof coatings. 

11. Zinc-rich primers. 

12. Wood Coatings. 

C. Sell-Through/Existing Stock of Coatings: A coating manufactured prior to the VOC 

Content limit effective date(s) specified for that coating in the Table of Standards,

that complied with the VOC Content limit in effect at the time the coating was 

manufactured, may be sold, supplied, or offered for sale for up to three years after the 

specified VOC Content limit effective date(s) listed in the Table of Standards. In 

addition, a Such a coating manufactured before the effective date specified for that 

coating in the Table of Standards may be applied at any time, both before and after 

the specified effective date. , so long as the coating complied with the standards in 

effect at the time the coating was manufactured. This subsection VI.C does not apply 

to any coating that does not display the date or date-code required by subsection 

VII.A.1. 
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Appendix B B-13 Draft 4/5/2010 

D. Painting Practices: All architectural coating containers used to apply the contents 

therein to a surface directly from the container by pouring, siphoning, brushing, 

rolling, padding, ragging or other means, shall be closed when not in use. Such 

architectural coating containers include, but are not limited to, drums, buckets, cans, 

pails, trays or other application containers. Containers of any VOC-containing 

materials used for thinning and cleanup shall also be closed when not in use. 

E. Thinning: No person who applies or solicits application of any architectural coating 

shall apply a coating thinned to exceed the applicable VOC limit specified in the 

Table of Standards. 

F. Coatings Not Listed in the Table of Standards: For any coating that does not meet 

any of the definitions for specialty coatings categories listed in the Table of 

Standards, the VOC content limit shall be determined by classifying the coating as a 

Flat, Nonflat, or Nonflat-High Gloss coating, based on its gloss, as defined in 

Subsections IV.U., IV.LLHH. and IV.MMII. and the corresponding Flat, Nonflat, or 

Nonflat-High Gloss VOC limit in the Table of Standards shall apply. 

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Appendix B B-14 Draft 4/5/2010 

TABLE OF STANDARDS 

VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Coating Category Effective 1/1/2011 Effective 1/1/2012 

Flat Coatings 50 

Nonflat Coatings 100 

Nonflat - High Gloss Coatings 150 

Specialty Coatings: 

Aluminum Roof Coatings 400 

Basement Specialty Coatings 400 

Bituminous Roof Coatings 50 

Bituminous Roof Primers 350 

Bond Breakers 350 

Concrete Curing Compounds 350 

Concrete/Masonry Sealers 100 

Driveway Sealers 50 

Dry Fog Coatings 150 

Faux Finishing Coatings 350 

Fire Resistive Coatings 350 

Floor Coatings 100 

Form-Release Compounds 250 

Graphic Arts Coatings (Sign Paints) 500 

High Temperature Coatings 420 

Industrial Maintenance Coatings 250 

Low Solids Coatings2 120 

Magnesite Cement Coatings 450 

Mastic Texture Coatings 100 

Metallic Pigmented Coatings 500 

Multi-Color Coatings 250 

Pre-Treatment Wash Primers 420 

Primers, Sealers, and Undercoaters 100 

Reactive Penetrating Sealers 350 

Recycled Coatings 250 

Roof Coatings 50 

Rust Preventative Coatings 400 250 

Shellacs: 

 Clear 

 Opaque 

730 

550 

Specialty Primers, Sealers, and Undercoaters 350 100 

Stains 250 

Stone Consolidants 450 

Swimming Pool Coatings 340 

Traffic Marking Coatings 100 

Tub and Tile Refinish Coatings 420 

Waterproofing Membranes 250 

Wood Coatings 275 
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Wood Preservatives 350 

Zinc-Rich Primers 340 

1. Limits are expressed as VOC Regulatory thinned to the manufacturer’s maximum thinning 

recommendation, excluding any colorant added to tint bases. 

2. Limit is expressed as VOC Actual. 

VII. Administrative Requirements

A. Labeling Requirements: Each manufacturer of any architectural coating subject to 

this Rule shall display information listed in Subsections VII.A.1. through VII.A.12 on 

coating container (or label) in which coating is sold or distributed. 

1. Date Code: The date coating was manufactured, or date code representing 

date, shall be indicated on label, lid or bottom of container. If manufacturer 

uses a date code for any coating, manufacturer shall file an explanation of 

each code with the Executive Officer of the ARB. 

2. Thinning Recommendations: A statement of manufacturer's recommendation 

regarding thinning of coating shall be indicated on label or lid of container. 

This requirement does not apply to thinning of architectural coatings with 

water. If thinning of coating prior to use is not necessary, recommendation 

must specify coating is to be applied without thinning. 

3. VOC Content: Each container of any coating subject to this rule shall display 

one of the following values in grams of VOC per liter of coating: 

a. Maximum VOC Content as determined from all potential product 

formulations; or 

b. VOC Content as determined from actual formulation data; or 

c. VOC Content as determined using the test methods in subsection 

VII.C.12. 

If the manufacturer does not recommend thinning, the container must display 

the VOC Content, as supplied. If the manufacturer recommends thinning, the 

container must display the VOC Content including the maximum amount of 

thinning solvent recommended by the manufacturer. If the coating is a multicomponent product, the container must display the VOC content as mixed or 

catalyzed. If the coating contains silanes, siloxanes, or other ingredients that 

generate ethanol or other VOCs during the curing process, the VOC content 

must include the VOCs emitted during curing. VOC Content shall be 

determined as defined in subsections IV.LLLJJJ, IV.MMMKKK, and 

IV.NNNLLL. 

4. Faux Finishing Coatings: The labels of all clear topcoat Faux Finishing 

coatings shall prominently display the statement “This product can only be 

sold or used as part of a Faux Finishing coating system.” 

5. Industrial Maintenance Coatings: The labels of all Industrial Maintenance 

coatings shall prominently display the statement “For industrial use only” or 
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Appendix B B-16 Draft 4/5/2010 

“For professional use only” or “Not for residential use” or “Not intended for 

residential use”. 

6. Rust Preventative Coatings: The labels of all rust preventative coatings shall 

prominently display statement “For Metal Substrates Only”. 

7. Specialty Primers, Sealers and Undercoaters: Until January 1, 2012, the labels 

of all specialty primers, sealers and undercoaters shall prominently display 

one or more of following descriptions: 

a. For fire damaged substrates; 

b. For smoke damaged substrates; 

c. For water damaged substrates; or 

8. Reactive Penetrating Sealers: The labels of all Reactive Penetrating Sealers 

shall prominently display the statement “Reactive Penetrating Sealer”. 

9. Stone Consolidants: The labels of all Stone Consolidants shall prominently 

display the statement “Stone Consolidant – For Professional Use Only”. 

10. Nonflat-High Gloss Coatings: The labels of all nonflat-high gloss coatings 

shall prominently display words “High Gloss”. 

11. Wood Coatings: The labels of all Wood Coatings shall prominently display 

the statement “For Wood Substrates Only”. 

12. Zinc Rich Primers: The labels of all Zinc Rich Primers shall prominently 

display one of the following the statements “For Professional Use Only” “Not 

For Residential Use” or “Not Intended For Residential Use” or “For Industrial 

Use Only” or “For professional use only”.

B. Reporting Requirements

1. Sales Data: A responsible official from each manufacturer shall upon request 

of the Executive Officer of the ARB, or his or her delegate, provide data 

concerning the distribution and sales of architectural coatings. The responsible 

official shall within 180 days provide information including, but not limited 

to: 

a. The name and mailing address of the manufacturer; 

b. The name, address and telephone number of a contact person; 

c. The name of the coating product as it appears on the label and the 

applicable coating category; 

d. Whether the product is marketed for interior or exterior use or both; 

e. The number of gallons sold in California in containers greater than one 

liter (1.057 quart) and equal to or less than one liter (1.057 quart); 

f. The VOC Actual content and VOC Regulatory content in grams per 

liter. If thinning is recommended, list the VOC Actual content and 

VOC Regulatory content after maximum recommended thinning. If 

containers less than one liter have a different VOC content than 
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Appendix B B-17 Draft 4/5/2010 

containers greater than one liter, list separately. If the coating is a 

multi-component product, provide the VOC content as mixed or 

catalyzed; 

g. The names and CAS numbers of the VOC constituents in the product; 

h. The names and CAS numbers of any compounds in the product 

specifically exempted from the VOC definition, as listed in Subsection 

IV.KKKRule 102 Definitions; 

i. Whether the product is marketed as solventborne, waterborne, or 

100% solids; 

j. Description of resin or binder in the product; 

k. Whether the coating is a single-component or multi-component 

product; 

l. The density of the product in pounds per gallon; 

m. The percent by weight of: solids, all volatile materials, water, and any 

compounds in the product specifically exempted from the VOC;

definition, as listed in Subsection IV.KKK; andRule 102 Definitions

n. The percent by volume of: solids, water, and any compounds in the 

product specifically exempted from the VOC definition, as listed in 

Subsection IV.KKK.Rule 102 Definitions.

2. All sales data listed in subsection VII.B.1.a to VII.B.1.n shall be maintained 

by the responsible official for a minimum of three years. Sales data submitted 

by the responsible official to the Executive Officer of the ARB may be 

claimed as confidential, and such information shall be handled in accordance 

with the procedures specified in Title 17, California Code of Regulations 

Sections 91000-91022. 

C. Test Methods

1. Calculation of VOC Content: For the purpose of determining compliance with 

the VOC content limits in the Table of Standards, the VOC content of a 

coating shall be determined as defined in subsection V.JJJ, V.KKK, or 

V.LLL. The VOC content of a tint base shall be determined without colorant 

that is added after the tint base is manufactured. If the manufacturer does not 

recommend thinning, the VOC content must be calculated for the product as 

supplied. If the manufacturer recommends thinning, the VOC content must be 

calculated including the maximum amount of thinning solvent recommended 

by the manufacturer. If the coating is a multi-component product, the VOC 

content must be calculated as mixed or catalyzed. If the coating contains 

silanes, siloxanes, or other ingredients that generate ethanol or other VOCs 

during the curing process, the VOC content must include the VOCs emitted 

during curing.

1.2.VOC Content Determinationof Coatings: To determine physical properties of 

a coating in order to perform calculations in Subsections IV.NNNLLL. or 

IV.LLLJJJ., the reference method for VOC content shall be U.S. EPA Method 

24, except as provided in Subsections VII.C.2 3 and VII.C.34. An alternative 

method to determine VOC content of coatings is SCAQMD Method 304-91 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-18 Draft 4/5/2010 

(Revised 1996), incorporated by reference in Subsection VII.C.34. The 

exempt compounds content shall be determined by SCAQMD Method 303-91 

(Revised 1993), BAAQMD Method 43 (Revised 1996), or BAAQMD Method 

41 (Revised 1995), as applicable, incorporated by reference in Subsection 

VII.C.1112, VII.C.1213, and VII.C.1314, respectively. To determine VOC 

content of a coating, the manufacturer may use U.S. EPA Method 24, or an 

alternative method as provided in Subsection VII.C.23., formulation data, or 

any other reasonable means for predicting coating has been formulated as 

intended (e.g., quality assurance checks, recordkeeping). However, if there 

are any inconsistencies between results of a Method 24 test and any other 

means for determining VOC content, Method 24 test results shall will govern, 

except when an alternative method is approved as specified in Subsection 

VII.C.23. The District Air Pollution Control Officer (APCO) may require 

manufacturer to conduct a Method 24 analysis. 

2.3.Alternative Test Methods: Other test methods demonstrated to provide results 

acceptable for purposes of determining compliance with Subsection VII.C.12., 

after review and approved in writing by the staffs of District, ARB and U.S. 

EPA, may also be used. 

3.4.Alternative VOC Content of Coatings: The VOC content of coatings may be 

analyzed either by U.S. EPA Method 24 of or SCAQMD Method 304-91 

(Revised 1996), “Determination of Volatile Organic Compounds (VOC) in 

Various Materials”, “SCAQMD Laboratory Methods of Analysis for 

Enforcement Samples” (see Subsection VII.C.12.). 

4.5.VOC Content of Coatings: The VOC content of a coating shall be determined 

by U.S. EPA Method 24 as it exists in Appendix A of 40 Code of Federal 

Regulations (CFR) Part 60, “Determination of Volatile Matter Content, Water 

Content, Density, Volume Solids and Weight Solids of Surface Coatings” (see 

Subsection VII.C.12.). 

5.6.Methacrylate Traffic Marking Coatings: The VOC content of methacrylate 

multicomponent coatings used as traffic marking coatings shall be analyzed 

by procedures in 40 CFR Part 59, Subpart D, Appendix A, “Determination of 

Volatile Matter Content of Methacrylate Multicomponent Coatings Used as 

Traffic Marking Coatings”, incorporated by reference in Subsection VII.C.3. 

(This method has not been approved for methacrylate multicomponent 

coatings used for other purposes than traffic marking coatings or for other 

classes of multicomponent coatings). 

6.7.Flame Spread Index: The flame spread index of a fire retardant coating shall 

be determined by ASTM E 84-07, “Standard Test Method for Surface Burning 

Characteristics of Building Materials” (see Subsection IV.T., Fire Retardant 

Coating). 

7.8.Fire Resistance Rating: The fire resistance rating of a fire resistive coating 

shall be determined by ASTM E 119-07, “Standard Test Methods for Fire 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-19 Draft 4/5/2010 

Tests of Building Construction Materials” (see Subsection IV.S., Fire 

Resistive Coating). 

8.9.Gloss Determination: Gloss of a coating shall be determined by ASTM D 

523-89 (1999), “Standard Test Method for Specular Gloss” (see Subsections 

IV.U., IV.JJHH., and IV.KKII. Flat Coating, Nonflat Coating, and NonflatHigh Gloss Coating). 

9.10. Metal Content of Coatings: Metallic content of a coating shall be 

determined by SCAQMD Method 318-95, “Determination of Weight Percent 

Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD Laboratory 

Methods of Analysis for Enforcement Samples (see Subsections IV.C., IV.R., 

and IV.HHFF; Aluminum Roof, Faux Finishing, and Metallic Pigmented 

Coating). 

10.11. Acid Content of Coatings: The acid content of a coating shall be 

determined by ASTM D 1613-06, “Standard Test Method for Acidity in 

Volatile Solvents and Chemical Intermediaries Used in Paint, Varnish, 

Lacquer and Related Products” (see Subsection IV.PPNN., Pretreatment Wash 

Primer). 

11.12. Exempt Compounds: The content of compounds pursuant to U.S. EPA 

Method 24 shall be analyzed by SCAQMD Method 303-91 (Revised 

19961993), “Determination of Exempt Compounds”, “SCAQMD Laboratory 

Methods of Analysis for Enforcement Samples” (see Subsection IV.KKKIII., 

Volatile Organic Compound and Subsection VII.C.12.). 

12.13. Exempt Compounds–Siloxanes: Exempt compounds that are cyclic, 

branched or linear completely methylated siloxanes, shall be analyzed as 

exempt compounds for compliance with Section VIII by BAAQMD Method 

43, “Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, 

Inks, and Related Materials”, “BAAQMD Manual of Procedures”, Volume 

IVIII, adopted 11/6/96 (see Subsection IV.KKKIII., Volatile Organic 

Compound and Subsection VII.C.12.). 

13.14. Exempt Compounds– Parachlorobenzotrifluoride (PCBTF): The exempt 

compound parachlorobenzotrifluoride shall be analyzed as an exempt 

compound for compliance with Section VIII by BAAQMD Method 41, 

“Determination of Volatile Organic Compounds in Solvent-Based Coatings 

and Related Materials Containing Parachlorobenzotrifluoride”, “BAAQMD 

Manual of Procedures”, Volume IVIII, adopted 12/20/95 (see Subsection 

IV.KKKIII., Volatile Organic Compounds and Subsection VII.C.12.). 

14.15. Hydrostatic Pressure for Basement Specialty Coatings: ASTM D7088-04, 

“Standard Practice for Resistance to Hydrostatic Pressure for Coatings Used 

in Below Grade Applications Applied to Masonry” (see section IV.F., 

Basement Specialty Coating). 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-20 Draft 4/5/2010 

15.Gonioapparent Characteristics for Coatings: ASTM E-284-07, “Standard 

Terminology of Appearance” (see section IV.X., Gonioapparent).

16. Tub and Tile Refinish Coating Adhesion: ASTM D 4585-99, “Standard 

Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation” and ASTM D3359-02, “Standard Test Methods for Measuring 

Adhesion by Tape Test” (see section IV.HHHFFF., Tub and Tile Refinish 

Coating). 

17. Tub and Tile Refinish Coating Hardness: ASTM D 3363-05, “Standard Test 

Method for Film Hardness by Pencil Test” (see section IV.HHHFFF., Tub and 

Tile Refinish Coating). 

18. Tub and Tile Refinish Coating Abrasion Resistance: ASTM D 4060-07, 

“Standard Test Methods for Abrasion Resistance of Organic Coatings by the 

Taber Abraser” (see section IV.HHHFFF., Tub and Tile Refinish Coating). 

19. Tub and Tile Refinish Coating Water Resistance: ASTM D 4585-99, 

“Standard Practice for Testing Water Resistance of Coatings Using Controlled 

Condensation” and ASTM D714-02e1, “Standard Test Method for Evaluating 

Degree of Blistering of Paints” (see section IV.HHHFFF., Tub and Tile 

Refinish Coating). 

20. Waterproofing Membrane: ASTM C836-06, “Standard Specification for High 

Solids Content, Cold Liquid-Applied Elastomeric Waterproofing Membrane 

for Use with Separate Wearing Course” (see section IV.OOOMMM., 

Waterproofing Membrane). 

21. Mold and Mildew Growth for Basement Specialty Coatings: ASTM D3273-

00, “Standard Test Method for Resistance to Growth of Mold on the Surface 

of Interior Coatings in an Environmental Chamber” and ASTM D3274-95, 

“Standard Test Method for Evaluating Degree of Surface Disfigurement of 

Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt 

Accumulation” (see section IV.F., Basement Specialty Coating). 

22. Reactive Penetrating Sealer Water Repellency: ASTM C67-07, “Standard 

Test Methods for Sampling and Testing Brick and Structural Clay Tile”; or 

ASTM C97-02, “Standard Test Methods for Absorption and Bulk Specific 

Gravity of Dimension Stone”; or ASTM C140-06, “Standard Test Methods 

for Sampling and Testing Concrete Masonry Units and Related Units” (see 

section IV.RRPP., Reactive Penetrating Sealer). 

23. Reactive Penetrating Sealer Water Vapor Transmission: ASTM E96/E96M05, “Standard Test Method for Water Vapor Transmission of Materials” (see 

section IV.RRPP., Reactive Penetrating Sealer). 

24. Reactive Penetrating Sealer - Chloride Screening Applications: National 

Cooperative Highway Research Report 244 (1981), “Concrete Sealers for the 
410.1A Final Staff Report – Strikeout and Underline Adopted Rule 

Appendix B B-21 Draft 4/5/2010 

Protection of Bridge Structures” (see section IV.RRPP., Reactive Penetrating 

Sealer). 

25. Stone Consolidants: ASTM E2167-01, “Standard Guide for Selection and 

Use of Stone Consolidants” (see section IV.DDDBBB., Stone Consolidant). 

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APPENDIX C: 

ADOPTED RULE 410.1A 

ARCHITECTURAL COATING CONTROLS 

RESPONSE TO COMMENTS 
410.1A Final Staff Report - Response to Comments 

Appendix C C-1 Draft 4/5/2010

I. ARB & EPA COMMENTS 

The California Air Resources Board (ARB) and U.S. EPA (EPA) had very similar 

comments regarding draft Rule 410.1A. Both ARB and the EPA supported each 

other’s suggested changes to the Rule. KCAPCD incorporated ARB and EPA’s 

comments and suggested changes into the revised version of draft Rule 410.1A. 

In addition to minor typographical errors that have been addressed, the revised 

version of draft Rule 410.1.A reflects the following changes made in response to 

the comments and suggested changes made by the ARB and EPA: 

 Definitions 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, the following provision has been added to Subsection 

V.R.4 of the Faux Finish Coating definition: “A decorative coating used to create 

a metallic appearance that contains greater than 48 grams of elemental metallic 

pigment per liter of coating as applied (greater than 0.4 pounds per gallon) and 

which requires a clear topcoat to prevent the degradation of the finish under 

normal use conditions. The metallic pigment content shall be determined in 

accordance with SCAQMD Method 318-95, incorporated by reference in 

subsection VII.C.10.” 

It was recommended to combine Subsections V.R.4 and V.R.5 of the Faux Finish 

Coating definition of into one Subsection. KCAPCD has combined the two 

sections. Subsection V.R.5 now reads: “A clear topcoat to seal and protect a 

Faux Finishing coating that meets the requirements of subsection IV.R.1, IV.R.2, 

IV.R.3, or IV.R.4. These clear topcoats must be sold and used solely as part of a 

Faux Finishing coating system, and must be labeled in accordance with 

subsection VII.A.4.” 

 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, the following changes have been made to Section V.T, 

Fire Retardant Coating: “A coating labeled and formulated to retard ignition and 

flame spread, that has been fire tested and rated by a testing agency approved 

by building code officials for use in bringing building and construction materials 

into compliance with federal, state and local building code requirements. The 

fire-retardant coating and the testing agency must be approved by building code 

officials. The fire-retardant coating shall be tested in accordance with ASTM 

Designation E 84-07, incorporated by reference in subsection VII.C.7. Effective 

January 1, 2011, the Fire Retardant coating category is eliminated and Coatings

coatings with fire retardant properties will be subject to the VOC limit of their 

primary category (e.g., Flat Nonflat, ECT.). Any fire retardant coating shall be 

tested in accordance with ASTM Designation E 84-99, incorporated by reference 

in Subsection VII.C.6.”
410.1A Final Staff Report - Response to Comments 

Appendix C C-2 Draft 4/5/2010

As recommended, “airbrush” has been added to Section V.X, Graphic Arts 

Coating or Sign Paint. 

As recommend, Section V.Z, Industrial Maintenance Coating has been changed 

as follows: “High performance architectural coatings including antenna, 

antifouling, intermediate coats, primers, sealers, undercoaters, intermediate 

coats, and topcoats, and undercoaters formulated for application to substrates, 

including floors, exposed to one or more of the following extreme environmental 

conditions listed in Subsections V.Z.1. through V.Z.5. and labeled as specified in 

Subsection VII.A.5.” 

As recommend, Section V.NN, Pre-Treatment Wash Primer Coating has been 

changed as follows: “A primer that contains a minimum of 0.5 percent acid, by 

weight, when tested in accordance with ASTM Designation D 1613 96 06, 

incorporated by reference in Subsection VII.C.11. labeled and formulated for 

application directly to bare metal surfaces to provide corrosion resistance and to 

promote adhesion of subsequent topcoats.” 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, Sections IV.X, Gonioapparent, and IV.GG, Metallic have 

been deleted. 

As recommended, “Calculation” has been deleted from the title of Section V.KKK, 

VOC Content Calculation. Section V.KKK now reads “VOC Content.”

As recommended, the word “substances” has been replaced with the word 

“substrates” in Section V.NNN, Wood Coatings. The first sentence of Section 

V.NNN now reads: “Coatings labeled and formulated for application to wood 

substrates only.” 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, “accordance with the labeling requirements in” has been 

added to Subsection V.QQQ.3 of the Zinc-Rich Primer definition. Subsection 

V.QQQ.3 now reads: “Coating is intended for professional use only and is 

labeled as such, in accordance with the labeling requirements in subsection 

VII.A.12.” 

Exemptions 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, Subsection IV.A.2 “Provisions of this Rule shall not apply 

to any aerosol coating product” has been added to Section IV Exemptions. 

Administrative Requirements 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, “clear topcoat” has been added to Subsection VII.A.4, 
410.1A Final Staff Report - Response to Comments 

Appendix C C-3 Draft 4/5/2010

Faux Finishing Coatings. Subsection VII.A.4 now reads: “The labels of all clear 

topcoat Faux Finishing coatings shall prominently display the statement ‘This 

product can only be sold or used as part of a Faux Finishing coating system.’” 

To maintain consistency with other districts adopting ARB’s 2007 SCM for 

Architectural Coatings, the following provision has been added to Subsection 

VII.C.1 Test Methods: “Calculation of VOC Content: For the purpose of 

determining compliance with the VOC content limits in the Table of Standards, 

the VOC content of a coating shall be determined as defined in subsection V.JJJ, 

V.KKK, or V.LLL. The VOC content of a tint base shall be determined without 

colorant that is added after the tint base is manufactured. If the manufacturer 

does not recommend thinning, the VOC content must be calculated for the 

product as supplied. If the manufacturer recommends thinning, the VOC content 

must be calculated including the maximum amount of thinning solvent 

recommended by the manufacturer. If the coating is a multi-component product, 

the VOC content must be calculated as mixed or catalyzed. If the coating 

contains silanes, siloxanes, or other ingredients that generate ethanol or other 

VOCs during the curing process, the VOC content must include the VOCs 

emitted during curing.” 

Section VII.C.15, Gonioapparent Characteristics for Coatings has been deleted 

from the Rule because it is no longer needed after deleting Section IV.X, 

Gonioapparent. 

II. INDUSTRY COMMENTS 

KCAPCD evaluated all comments and suggested changes made by the Coatings 

Industry in regarding draft Rule 410.1A. Many of the comments were very similar 

to what ARB and EPA proposed. Industry comments and suggested changes to 

the Rule that are similar in nature to those previously addressed in the ARB EPA 

Comments section of Appendix C, will not be mentioned again in this section. 

Suggested changes that would aid the Coatings Industry with compliance without 

modifying the intent or VOC Content Limits of the Rule were incorporated into 

draft Rule 410.1A. Some of Industry’s suggested changes were not incorporated 

into the Rule because they were: infeasible and would alter the intent of the Rule, 

inapplicable to the Rule, or KCAPCD believed there was no benefit in making the 

change. 

An industry official at the workshop stated that creating and adopting a new 

architectural coatings rule instead of amending the current rule may create 

confusion and allow sources to decide which rule to follow. KCAPCD does not 

believe that this will be an issue of concern because the current architectural 

rule, Rule 410.1 will sunset when the new rule, Rule 410.1A becomes effective. 

Sources will not have the choice of which rule to follow because there will only be 

one architectural coatings rule in effect at any given time. 
410.1A Final Staff Report - Response to Comments 

Appendix C C-4 Draft 4/5/2010

Exemptions 

KCAPCD was commended by industry for updating the Exempt Compounds list 

in Rule 102 Definitions to include Tertiary Butyl Acetate (t-butyl acetate) 

informally known as TBAC or TBAc along with Dimethyl Carbonate and 

Propylene Carbonate which are compounds used in various coatings. 

As requested, the Exemptions Section has been moved up from Section V to 

Section IV, immediately after Severability and directly before Definitions. 

Requirements 

Industry noted an inadvertent error in the Section VI.C. “Sell-Through” provision. 

As written, the condition that a coating must have “complied with the standards in 

effect at the time the coating was manufactured” relates only to that part of the 

provision allowing coatings to be “applied at any time,” and not to that part 

allowing coatings to be “sold, supplied, or offered for sale...” 

Section VI.C has been changed to the following: Sell-Through/Existing Stock of 

Coatings: A coating manufactured prior to the VOC Content limit effective 

date(s) specified for that coating in the Table of Standards, that complied with the 

VOC Content limit in effect at the time the coating was manufactured, may be 

sold, supplied, or offered for sale for up to three years after the specified VOC 

Content limit effective date(s) listed in the Table of Standards. Such a coating 

may be applied at any time, both before and after the specified effective date. 

This subsection VI.C does not apply to any coating that does not display the date 

or date-code required by subsection VII.A.1. 

Table of Standards 

It was recommended that KCAPCD push the VOC Content limit requirements for 

certain coatings back one year to give manufacturers extra time to develop 

formulas that would comply with the regulation. KCAPCD sought ARB’s input on 

this matter and received this response from ARB: “We (ARB) would not support 

Dunn-Edwards’ request to delay the flat and PSU effective dates. We believe the 

SCM VOC limits are feasible without averaging. In fact, that’s why we have 

higher limits than the SCAQMD’s rule 1113 in some categories. We believe a 

36% complying market share for PSUs back in 2004 is good evidence that the 

limit is feasible without averaging. And although the flat complying market share 

was low in 2004 (7%), there is significant consensus that that is the easiest 

category to formulate at low VOC levels. They have made this request to both 

BAAQMD and SJVAPCD and both districts decided against their request”.

It has been suggested that the effective date of several categories of coatings 

(Tub and Tile Refinish; Stone Consolidants; Reactive Penetrating Sealers and 
410.1A Final Staff Report - Response to Comments 

Appendix C C-5 Draft 4/5/2010

Basement Specialty Coating among others) be set at the time of adoption since 

these are new and needed “niche” categories. As such, these categories have 

higher VOC content limits than the default categories and are currently only 

available in small containers. 

KCAPCD has decided not to include a provision that would allow the VOC 

Content limits of The Table of Standards to become effective at the date of 

adoption for the following reasons: 

1. Rule 410.1 (the current architectural coatings rule) is not being amended to 

include “New Categories”; 

2. Proposed Rule 410.1A along with the VOC Content Limits listed in the Table 

of Standards is structured to not go into effect until 1/1/2011 regardless of an 

earlier Rule adoption date. 

The Table of Standards and Effective Dates of the VOC Content limits will be 

unchanged and remain the same as originally stated in the September 21, 2009 

draft of Rule 410.1A, Architectural Coatings Controls. 

Administrative Requirements 

As requested, KCAPCD added the terms “Not for residential use” or “Not 

intended for residential use” to Section VII.A.5, Industrial Maintenance Coatings. 

Section VII.A.5 now reads: “The labels of all Industrial Maintenance coatings 

shall prominently display the statement “For industrial use only” or “For 

professional use only” or “Not for residential use” or “Not intended for residential 

use.’” 

III. PUBLIC COMMENTS 

There were no comments made by the general public. 

IV. ARB & EPA RULE REVIEW RESULTS 

KCAPCD submitted the Final Revised Draft of Rule 410.1A Architectural Coating 

Controls to ARB and EPA for a 30-day review period. At the close of the 30-day 

review period ARB and EPA each stated that there were no additional 

comments. 

V. UPDATE TO SECTION VII.A.12, ZINC RICH PRIMERS 

After public notice was give for Rule adoption, the American Coatings 

Association (ACA) requested that KCAPCD update Section VII.A.12, Zinc Rich 
410.1A Final Staff Report - Response to Comments 

Appendix C C-6 Draft 4/5/2010

Primers of Rule 410.1A to include the following provisions: “Not For Residential 

Use”, “Not Intended For Residential Use” or “For Industrial Use Only.” KCAPCD 

considered this change to be a minor correction to the rule that was overlooked 

in the draft and will not be a significant change. ARB staff has been consulted 

and agrees. 

KCAPCD added the terms “Not For Residential Use” or “Not Intended For 

Residential Use” or “For Industrial Use Only” to Section VII.A.12, Zinc Rich 

Primers. Section VII.A.12 now reads: “The labels of all Zinc Rich Primers shall 

prominently display one of the following the statements “For Professional Use 

Only” “Not For Residential Use” or “Not Intended For Residential Use” or “For 

Industrial Use Only” or “For professional use only.’”

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