ATTACHMENT F 

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

Final Staff Report 

Proposed Amended Rule 1145 – Plastic, Rubber, Leather and Glass Coatings 

December 2009 

Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Elaine Chang, DrPH 

Assistant Deputy Executive Officer 

Planning, Rule Development, & Area Sources 

Laki Tisopulos, Ph.D., P.E. 

AUTHOR: Don Hopps - Air Quality Specialist 

REVIEWED BY: Andrew Lee, P.E. - Program Supervisor 

 William Wong – Principal Deputy District Counsel 
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT 

GOVERNING BOARD 

Chairman: DR. WILLIAM A. BURKE

Speaker of the Assembly Appointee 

Vice Chairman: DENNIS YATES 

 Mayor, Chino 

 Cities of San Bernardino 

MEMBERS: 

MICHAEL D. ANTONOVICH Supervisor, Fifth District 

County of Los Angeles 

MARION ASHLEY 

Supervisor, Fifth District 

County of Riverside 

MICHAEL A. CACCIOTTI 

Councilmember, South Pasadena 

Cities of Los Angeles County/Eastern Region 

BILL CAMPBELL 

Supervisor, Third District 

County of Orange 

JANE W. CARNEY 

Senate Rules Appointee 

JOSIE GONZALES 

Supervisor, Fifth District 

County of San Bernardino 

RONALD O. LOVERIDGE 

Mayor, Riverside 

Cities of Riverside County 

JOSEPH K. LYOU, Ph. D. 

Governor’s Appointee 

JAN PERRY 

Councilmember, Ninth District 

City of Los Angeles 

MIGUEL A. PULIDO 

Mayor, Santa Ana 

Cities of Orange County 

TONIA REYES URANGA 

Councilmember, City of Long Beach 

Cities of Los Angeles County/Western Region 

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env. 
i 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY ................................................................................................... ES-1 

CHAPTER 1: BACKGROUND 

Introduction ............................................................................................................................. 1-1 

Regulatory History ..................................................................................................................... 1-1 

Affected Industries ..................................................................................................................... 1-1 

CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1145 

Overview: Proposed Amendments to Rule 1145 ....................................................................... 2-1 

Proposed Amendment #1 ...................................................................................................................... 2-1 

Proposed Amendment #2 ...................................................................................................................... 2-1 

Proposed Amendment #3 ...................................................................................................................... 2-7 

Proposed Amendment #4 ...................................................................................................................... 2-8 

CHAPTER 3: IMPACT ASSESSMENT 

Introduction ................................................................................................................................ 3-1 

Emission Impact Assessment ..................................................................................................... 3-1 

Socioeconomic Impact Assessment ........................................................................................... 3-4 

Potential Environmental Impacts ............................................................................................... 3-4 

Draft Findings Under California Health and Safety Code 40727 .............................................. 3-5 

Comparative Analysis ................................................................................................................ 3-6 

Public Comments and Staff Responses ...................................................................................... 3-8 

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

APPENDIX: ............................................................. ADHESION BY TAPE TEST RESULTS 

∗ UV Coating Test Results (08/27/09 & 09/08/09) 

∗ Epoxy Ink Coating Test Results (09/17/09) 
EXECUTIVE SUMMARY 
Executive Summary Final Staff Report

Proposed Amended Rule 1145 ES-1 December 2009 

Executive Summary 

Rule 1145 – Plastic, Rubber, Leather, and Glass Coatings, was originally adopted by the 

South Coast Air Quality Management District Governing Board on July 8, 1983, to regulate 

Volatile Organic Compounds (“VOC”) emissions from plastic, rubber, and glass coating 

operations (leather substrates were added to the rule during the December 3, 2004 

amendment). At this time, the rule has been amended fifteen times since the adoption date of 

July 8, 1983. This proposed sixteenth amendment would, in part, implement control measure 

MCS-07 – Application of All Feasible Measures of the 2007 AQMP. 

This proposed amendment to Rule 1145 is designed to: (1) revise the VOC limit for the 

multi-color coatings category and bring it in line with the September 2008 U.S. EPA Control 

Techniques Guidelines (“CTG”), (2) establish a new coating category for a niche 

manufacturing process where a one inch wide border is coated onto glass panels during the 

manufacturing of refrigerated glass doors for refrigeration cabinets, for which a compliant 

product is currently not available, (3) update the rule with the deletion of paragraph (c)(3), 

where automotive coatings can be used in certain circumstances, and (4) make minor 

clarifications and editorial corrections to the rule. 

The first proposed amendment seeks to reduce the VOC limit for the multi-color category 

from 685 g/L VOC to 680 g/L VOC, to match the U.S. EPA CTG. Based on a 260 days per 

year work schedule, AQMD staff calculated the theoretical VOC reduction to be 

approximately 0.4 lbs/day. 

The second proposed amendment seeks to add a new coating category to the Table of 

Standards in Rule 1145. This new proposed coating category, refrigerated glass door 

coatings, will allow the continued operation for one facility that has been operating under a 

Hearing Board Variance for the last two years. As per conditions of the Hearing Board 

Variance, the facility was required to test VOC compliant coatings as part of their increments 

of progress requirement. AQMD staff agrees that the facility has been unable to locate a 

VOC compliant coating that would perform to the expected performance standards the 

refrigerated doors must adhere to. The current version of Rule 1145 would place this 

facility’s roll-coating operation into the two-component coating category which is currently 

limited to one pound of VOC per gallon. The proposed refrigerated glass door coating 

category will be limited to 4.0 pounds of VOC per gallon and would allow the facility to 

continue operating in compliance after their Hearing Board Variance expires. This new 

proposed coating category will result in a minor increase of VOC emissions forgone in 

relation to Rule 1145 but these emissions will only be from one facility. AQMD staff 
Executive Summary Final Staff Report

Proposed Amended Rule 1145 ES-2 December 2009 

calculated these emissions to be approximately 2.1 lbs/day of VOC forgone. It should be 

noted, however, that these forgone emissions are theoretical since the facility could legally 

apply their coatings through a screen printing process subject to Rule 1130.1 – Screen 

Printing Operations, which has a higher allowable VOC limit to that proposed under Rule 

1145. The proposed amendment not only will allow the facility to streamline its 

manufacturing process by switching from screen printing to a much simpler roll coating, it 

will also produce a marginal air quality benefit resulting from the elimination of emissions 

associated with the clean-up of the screens. 

The combined total emissions for the proposed amendments to the multi-color category and 

the addition of the refrigerated glass door coatings calculate to approximately 1.7 lbs/day of 

VOC emissions forgone. 

The third proposed amendment seeks to delete paragraph (c)(3) in Rule 1145 which allowed 

automotive coatings to be used on plastic, rubber, leather, and glass products to match the 

existing coating of motor vehicles provided that the applicator applied for and received 

written approval from the Executive Officer. Staff has determined that paragraph (c)(3) is 

now obsolete language based on recent July 1, 2008 provisions in Rule 1151 contained in its 

Appendix A. The new definition for Associated Parts and Components in the current 

version of Rule 1151 (Appendix A) includes parts and components that are not attached to a 

motor vehicle or mobile equipment. Therefore, paragraph (c)(3) in Rule 1145 should be 

removed since the current version of Rule 1151 addresses the issue of associated parts and 

components that are not attached to a motor vehicle or mobile equipment. 

The fourth proposed amendment will include minor clarifications and editorial corrections to 

the rule. The Table of Standards has obsolete dates for VOC limits in various coating 

categories that are no longer relevant and should be removed. This amendment will present 

the most current VOC limits. 

There is no expected cost increase associated with the reduction of the VOC limit for the 

multi-color coating category or the addition of a coating category for refrigerated glass door 

coatings. 
CHAPTER 1: BACKGROUND 

 INTRODUCTION 

 REGULATORY HISTORY 

 AFFECTED INDUSTRIES 
Chapter 1: Background Final Staff Report

Proposed Amended Rule 1145 1-1 December 2009

INTRODUCTION 

AQMD staff reviewed the September 2008 U.S. EPA CTG for Miscellaneous Metal and 

Plastic Parts Coatings and found a VOC limit discrepancy with the multi-color coating 

category in AQMD Rule 1145 – Plastic, Rubber, Leather, and Glass Coatings. The review 

found that the VOC limit in the current version of Rule 1145, for the multi-color coating 

category, was listed as 685 g/L of VOC whereas the CTG VOC limit, for the multi-color 

coating category, was listed as 680 g/L. AQMD staff proposes this amendment to Rule 1145 

to reduce the VOC limit for multi-color coating category and bring it in line with U.S. EPA’s 

current recommended VOC limit of 680 g/L. 

REGULATORY HISTORY 

Rule 1145 was originally adopted by the AQMD Governing Board on July 8, 1983 and has 

undergone fifteen subsequent adopted amendments. The multi-color coating category was 

adopted on February 14, 1997 and the maximum allowable VOC limit was listed as 685 g/L. 

On October 24, 2008, AQMD staff found the VOC limit out of alignment with the multicolor coating category of the CTG, while reviewing U.S. EPA’s CTG. The CTG specified a 

maximum allowable VOC limit of 680 g/L for the multi-color coating category contrary to 

the 685 g/L VOC limit shown in the AQMD Rule 1145 multi-color coating category. 

AFFECTED INDUSTRIES 

Approximately, 5% of the coatings subject to Rule 1145 fall into the multi-color coating 

category and the first proposed amendment is intended to align the allowable VOC limit in 

the multi-color coating category in AQMD Rule 1145 with the allowable VOC limit in the 

multi-color coating category in the September 2008 U.S. EPA’s CTG. AQMD staff does not 

expect this amendment to affect any facility under the purview of Rule 1145. 

There is one facility that would be impacted by the second proposed amendment which 

proposes to add a new coating category, the refrigerated glass door coating category. This 

facility currently operates under a two-year variance that will provide continued coverage 

until December 31, 2009. This facility has worked with AQMD planning and rules staff 

since February 2008 and has tried several coating chemistries to comply with the increments 

of progress required by the variance but has not found a coating system that can successfully 

meet the adhesion requirements for their niche operation. 
CHAPTER 2: SUMMARY OF PROPOSED AMENDED RULE 1145

 OVERVIEW: PROPOSED AMENDMENTS TO RULE 1145 

 PROPOSED AMENDMENT #1 

 PROPOSED AMENDMENT #2 

∗ Stationary Source Committee Meeting Held July 24, 2009 

∗ ASTM D3359-97 Technical Assessment 

 PROPOSED AMENDMENT #3 

 PROPOSED AMENDMENT #4 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-1 December 2009 

OVERVIEW: PROPOSED AMENDMENTS TO RULE 1145 

There are four recommended amendments proposed for Rule 1145. 

1. Reduce the VOC limit for the multi-color coating category from 685 g/L to 680 g/L 

2. Add one additional coating category for refrigerated glass doors to the Table of 

Standards in the rule 

3. Remove paragraph (c)(3) from Rule 1145; the July 1, 2008 version of Rule 1151 

provides language for associated parts and components not attached to a motor 

vehicle and mobile equipment 

4. Make minor clarifications and editorial corrections to the rule 

PROPOSED AMENDMENT #1 

The first proposed amendment addresses the multi-color coating category in Rule 1145. 

AQMD staff determined that the U.S. EPA CTG specified a maximum VOC of 680 g/L for 

multi-color coatings used on plastic parts. Rule 1145 currently lists the multi-color coating 

category with a maximum VOC limit at 685 g/L VOC. The first proposed amendment would 

be to align the VOC limit for the multi-color coating category in Rule 1145 with the CTG 

recommended VOC limit of 680 g/L. 

PROPOSED AMENDMENT #2 

The second proposed amendment requires additional discussion. AQMD staff proposes to 

add a new coating category to Rule 1145 to be known as the refrigerated glass door coating 

category. AQMD staff recognizes one facility that has a niche operation and cannot meet the 

current VOC limits in Rule 1145 for a two-component coating (the current two-component 

coating VOC limit is 1.0 lbs/gal). The facility filed and was granted a two-year variance by 

the AQMD Hearing Board and is allowed to continue operating using the existing coating 

products that were known to work, without adhesion failures, until December 31, 2009. The 

variance was granted on December 19, 2007 as a Hearing Board Action Item and it required 

the facility to meet increments of progress which included the testing of coatings that may be 

viable low-VOC compliant alternatives to their current coatings. AQMD staff has been 

working with the facility since February 2008 and has noted that of all the low-VOC 

alternate coatings they have tried, none have met all of the facility’s performance 

requirements for this niche operation; adhesion being one of the most important performance 

specifications, along with opaqueness, color variety, ease of application, etc. The coating 

used by the facility is hand roll-coated along the edges of a large glass pane, approximately 

one inch wide, which not only serves as an opaque border to hide the undesirable rough 

edges, hinges and related hardware of the glass panel, but also provides a substrate for the 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-2 December 2009 

spacer and sealant that is used to bond three glass panes together (in a sandwich-like 

configuration) to make one glass door assembly for refrigerated cabinets. These are the 

doors that are commonly seen at grocery stores in the frozen food aisles as well as the cold 

beverages aisles. If the coating fails to adhere to the glass substrate, the seal between the 

glass panels and the spacer will fail and the door will be subject to replacement by the 

facility under the conditions of their warranty. AQMD staff reviewed the Standard Industrial 

Classification (“SIC”) codes1

 for glass coatings and found that the facility conducting this 

operation is the only facility in the South Coast jurisdiction that conducts this type of 

operation. 

Prior to the current hand rolling operation, the facility used a screen printing process and was 

able to meet the much higher 600 g/L VOC limit specified in Rule 1130.1 – Screen Printing 

Operations. The facility, in an effort to streamline their process and produce less waste and 

reduce emissions, applied for and received their variance to roll coat their current epoxy ink 

coating in lieu of the screen printing operation. It should be recognized that by switching 

over to the much simpler roll coating operation, the facility was actually able to yield a 

marginal air quality benefit by eliminating the excess emissions associated with the extra 

coating required for the screen printing operation and the clean-up of the screens. 

The manufactured triple panel glass door assembly is sealed to provide moisture prevention 

between the glass panels. Several alternative coatings were tried as potential low-VOC 

replacements to the two current screen printing ink systems but none have adequately 

adhered to the glass substrate and as a result, the coating lost adhesion to the glass panels 

which then resulted in spacer and sealant failure between the glass panels. As a 

consequence, the glass door assembly was determined to be a defective door assembly that 

was rejected while in service and required replacement under warranty. The facility also 

tried powder coating applications in the past but this technology resulted in multiple 

rejections leading to multiple warranty issues. The facility informed AQMD staff that during 

the trials using powder coating, several refrigerated glass door assemblies failed resulting in 

$3,500,000 in warranty costs; these were costs the facility had to absorb. 

The facility states that it is imperative that the border coating stick to the glass substrate or 

the seal between the glass panels will fail to prevent moisture entering in between the 

individual glass panels and raise warranty issues. This is exacerbated by the constant 

opening and closing of the door while in service which dynamically stresses the seal and the 

border coating. The facility recently worked with a UV coating manufacturer to determine if 

 

1

 See reference section for SIC code references 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-3 December 2009 

a low-VOC Ultra-Violet (“UV”) cured coating could work for this particular niche operation. 

The UV coating manufacturer coated glass sample panels using the UV technology and upon 

testing for adhesion the facility commented that the UV coating appeared to be satisfactory. 

The facility requested a second round of testing from the UV coating manufacturer and upon 

inspection of these UV coated glass sample panels, it was observed that two out of three 

sample panels did not pass the facility’s adhesion requirements (i.e., did not meet the 

facility’s performance specification of 100% adhesion). The facility became concerned with 

the second round of tests after the UV coating manufacturer, when asked, informed them that 

they could not warranty the UV coatings. 

The facility uses ASTM D3359-97, the test method used to measure adhesion by tape. The 

test is a simple tape pull-off test that is performed by first inscribing 11 parallel lines in the 

coating all the way down to the substrate and then crosshatching 11 more lines, 

perpendicular to the first 11 lines, again all the way down to the substrate, in a cross-hatched 

pattern. A piece of masking tape is then applied directly over the cross-hatched pattern and a 

pencil eraser is used to rub the tape onto the surface. The tape is then pulled up at a constant 

rate, not in a jerky or a fast pull motion but in a uniform constant pull motion. A 100% 

successful test will reveal that the edges of the cuts are completely smooth and none of the 

squares of the lattice are detached. If there are small flakes of the coating detached along the 

cuts, or at the intersections of cuts, or the coating has flaked along the edges and on parts of 

the squares, the adhesion test is compared to Figure 1 in ASTM D 3359-97 to determine the 

percentage of the coating removed. The facility considers any detachment; including flaking 

on the cuts or ragged cut edges, to be unacceptable. 

AQMD staff contacted the UV coating manufacturer regarding the results of the second 

series samples and was informed that the adhesion strength could have been enhanced with a 

pretreatment such as a flame/plasma application treatment, this process is also known as pure 

or silicate flaming. This pretreatment operation is conducted in an oven where the flame 

application is applied onto the glass surface to raise the tensile strength of the glass surface to 

enhance the coatings adhesion to the glass. This type of equipment could be employed but at 

significant expense to the facility as well as producing increased NOx (oxides of nitrogen), 

CO (carbon monoxide), particulate emissions and increased greenhouse gases. In addition, 

the thermal effects impacted on the glass substrate would have to be considered in the 

manufacturing process of the refrigerated glass door assembly as they may potentially cause 

undesirable tempering that could alter the physical properties of the glass door panels. The 

UV coating manufacturer informed staff that given more research and development time, 

they may be able to develop a UV coating that would work for the facility’s niche coating 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-4 December 2009 

operation and satisfy all their adhesion requirements. However, the facility’s variance 

expires December 31, 2009. 

Stationary Source Committee meeting held July 24, 2009 

Immediately following the AQMD staff presentation of Proposed Amended Rule 1145, three 

members of the UV coating industry made comments in support that UV coatings would 

work for the facility’s niche coating operation despite the recent unacceptable (determined 

by the facility) results. The Stationary Source Committee recommended that one last 

adhesion test be conducted by the same UV coater that coated the previous samples and that 

data would then be used to determine if a UV coating would meet the coating performance 

requirements for the facility’s niche coating operation. The facility agreed to provide six (6) 

sample glass panels to the UV coater who would then apply the UV coating to the glass 

sample panels and ship them to AQMD. 

ASTM D 3359-97 Technical Assessment (Refer to Appendix for reports) 

AQMD staff contracted with a third party to conduct the adhesion by the tape pull-off tests 

using ASTM test method D 3359-97, the adhesion by tape pull-off test. The third party 

contractor ultimately conducted three different test series to determine the adhesion by tape 

pull-off for the coated sample glass panels in accordance with ASTM D 3359-97. 

The first test series was conducted at the recommendation of the Stationary Source 

Committee. On August 5, 2009, the facility e-mailed a descriptive list of criteria for their 

coating performance requirements and a list of questions to both the UV coater and AQMD 

staff. The facility also shipped six glass sample panels to the UV coater on the same day. 

On August 21, 2009, AQMD staff received the UV coated sample glass panel package from 

the UV coater. To avoid handling the glass panels, AQMD staff did not open the cardboard 

shipping container, but instead relinquished the cardboard shipping container on August 26, 

2009, to the third party tester who was contracted by AQMD to conduct the adhesion by tape 

pull-off tests. On August 27, 2009, the third party tester informed AQMD staff that there 

was only one UV coated glass sample panel in the cardboard shipping container and the 

adhesion by tape pull-off test results had been completed. The panel was divided into 

quadrants and the adhesion by tape pull-off tests were performed in each quadrant. The test 

results showed that each of the four tests areas on the UV coated panel rated 5B based on 

Figure 1 in ASTM D 3359-97, meaning that no material was removed from the test area 

(except for the sharp scribe lines). 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-5 December 2009 

The second test series was essentially an extension of the first test run since the facility 

voiced their concerns to the UV coater and AQMD staff that only one UV coated glass 

sample panel was submitted out of the six glass sample panels that they shipped. The UV 

coater requested the facility to ship another twelve sample glass panels for additional testing. 

On August 20, 2009, the facility shipped twelve additional glass sample panels and on 

August 21, 2009, the UV coater received them. The UV coater applied the UV coating to the 

glass sample panels and shipped them to AQMD on September 1, 2009. On September 3, 

2009, AQMD staff received the UV coated glass samples and again did not open the wooden 

shipping box they came in to avoid handling the sample glass panels. AQMD staff then 

relinquished the unopened wooden shipping box to the third party tester on the same day. 

On September 8, 2009, the third party tester informed AQMD staff that there were only six 

UV coated glass samples in the wooden shipping box and the adhesion by tape pull-off tests 

had been completed. The third party tester inquired if a different coating was used because 

the color was a lighter gray than the first UV coated glass sample. AQMD staff was not able 

to verify this despite multiple communications with the UV coater. The six UV coated glass 

samples were tested exactly the same way the one sample was in the first test run. Each UV 

coated sample glass panel was divided into quadrants and the adhesion by tape pull-off test 

was conducted inside each quadrant. There were a total of twenty-four adhesion by tape 

pull-off tests performed on the six UV coated glass samples and each test resulted in a 3B 

rating, the ratings are shown in Figure 1 of ASTM D 3359-97. The third party tester’s report 

explained that the UV coated glass sample panels were difficult to grade and that the ragged 

edges (the cuts made into the coating) put it in the 5 to 15% category which was why the 

panels were rated 3B. That means that up to 15% of the coating material was removed from 

the test area. AQMD staff observed the UV coated glass samples and observed jagged lines 

where the scribe tool crosshatched the coating as compared to sharp crisp crosshatched lines 

that were observed in the first test run. 

The third test series was conducted after AQMD staff met with the facility’s staff on 

September 11, 2009. Both parties agreed that the facility’s current epoxy ink system should 

be tested by the third party tester exactly the same way the UV coatings were tested. On 

September 15, 2009, the facility shipped five glass sample panels to AQMD that were coated 

with their existing epoxy ink. AQMD staff received the epoxy ink coated glass sample 

panels on September 16, 2009 and also did not open the wooden box that they were shipped 

in. On the same day, AQMD staff relinquished the wooden box to the third party tester. On 

September 17, 2009, the third party tester informed AQMD staff that the wooden shipping 

container contained five epoxy ink coated glass sample panels inside and the adhesion by 

tape pull-off tests had been completed. The epoxy ink coated glass panels were divided into 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-6 December 2009 

quadrants and the adhesion by tape pull-off test was performed inside each quadrant. There 

were a total of twenty adhesion by tape pull-off tests conducted on the five samples and each 

one was rated 5B, meaning that no material was removed from the test area (except for the 

sharp scribe lines) as shown in Figure 1 of ASTM D 3359-97. 

On September 18, 2009, the facility was visited by two representatives from an established 

and well known architectural and industrial maintenance finish manufacturer. The two 

representatives were shown the facility’s coating operation and according to the facility, they 

commented that in the immediate term, a UV coating would not be the best recommendation. 

Their additional comments included that a UV coating operation would require a defined UV 

end application process such as roll coating or screen printing and these types of coating 

operations would require additional research and development time to determine how they 

would affect the UV coatings curing process as well as the UV coatings adhesion properties. 

In addition, there would have to be research and development time necessary for color 

matching. On October 6, 2009, AQMD staff contacted the representative from the 

architectural and industrial maintenance finish manufacturer, identified by the facility, and 

inquired if they had a UV coating or a low-VOC alternate conventional coating that would 

work for the facility’s operation. The architectural and industrial maintenance finish 

manufacturer representative informed AQMD staff that “Based on their operations and their 

comments we don’t have anything to offer them”. “Our coating was not manufactured for 

something like that”. “This will require substantial testing”. AQMD Staff inquired about a 

two-part polyurethane coating and was informed “We do have a two-part polyurethane 6S 

series and it has 0.7 lbs/Gal of VOC”. “We can work with them (Anthony International) but 

their coating operation involves more than just a coating”. “They were very upfront with 

everything and we can’t offer a coating for that (their operation)”. 

AQMD staff concluded from the technical assessment, for this particular niche coating 

process, the adhesion by tape pull-off for the second series of testing for the UV coating had 

less adhesion to the glass substrate than the UV coating used in the first series and the epoxy 

ink that the facility currently uses. Staff further acknowledges that while the adhesion level 

achieved by the UV coating would be acceptable in most other applications, it did not quite 

meet the very stringent adhesion specifications required by this niche application. The 

facility specified that the adhesion by tape pull-off tests must rate no less than a 5B which 

means that no material must come off the glass substrate when the tape is pulled off the test 

area. The facility considers any detachment; including flaking on the cuts or ragged cut 

edges, to be unacceptable. AQMD staff does recognize that one UV coated glass sample 

from the first series adhesion by tape pull off test did rate a 5B in all four quadrants but all 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-7 December 2009 

the second series test samples rated a 3B, based on Figure 1 in ASTM D 3359-97. There 

were a total of twenty-eight adhesion by tape pull-off tests performed on the UV coated 

samples overall and twenty-four of those were rated 3B. The UV coated samples, based on 

the facility’s rating system, showed that 86% of the UV coating adhesion by tape pull-off 

tests did not perform to a 5B rating. In contrast, there were a total of twenty adhesion by 

tape pull-off tests performed on the epoxy ink coated glass sample panels. The epoxy ink 

coated glass sample panels had excellent adhesion as each of the twenty adhesion by tape 

pull-off tests showed a rating of 5B. The epoxy inks have been used by the facility for the 

last 15 years and are known to work well and have less than 1% failure in long term field 

testing, according to the interview AQMD staff had with the facility’s staff. In addition, the 

facility’s staff also commented that the refrigerated glass doors that use the epoxy ink have 

had a ten year warranty for the last six years and replacement costs under warranty for these 

type doors can range from $500 to $800 dollars per door depending on customer options. 

Based on the results from the technical assessment, the significant costs involved to install 

the UV coating equipment for production and employee training, the multiple low VOC 

alternate coatings that were tested but did not perform well enough for this niche coating 

operation and because the facility uses a small amount of coating that results in 2.1 pounds 

per day of VOC emissions, AQMD staff recommends amending the rule with the addition of 

a new refrigerated coating category that will allow the facility to continue to operate their 

coating system after their variance expires on December 31, 2009. 

PROPOSED AMENDMENT #3 

The third proposed amendment will delete paragraph (c)(3) from Rule 1145 since this 

paragraph is no longer necessary after the sunset date of June 30, 2008 for Rule 1151 - Motor 

Vehicle and Mobile Equipment Non-assembly Line Coating Operations. Rule 1151 was 

amended back on December 2, 2005 and the provisions of the rule were replaced with the 

provisions of Rule 1151, Appendix A, on July 1, 2008. AQMD Rule 1151 now includes a 

new definition for Associated Parts and Components which reads; “means structures, 

devices, pieces, modules, sections, assemblies, subassemblies, or elements of motor vehicles 

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

but which are not attached to motor vehicles or mobile equipment at the time of coating the 

structure, device, piece, module, section, assembly, subassembly, or element. The Associated 

parts and components definition does not include circuit boards. Any associated parts or 

components that are not attached to a motor vehicle or mobile equipment but are designed to 

be a part of a motor vehicle or mobile equipment is now governed under Rule 1151”. 
Chapter 2: Summary of Proposed Amended Rule 1145 Final Staff Report

Proposed Amended Rule 1145 2-8 December 2009 

PROPOSED AMENDMENT #4 

The fourth proposed amendment will include minor clarifications and editorial corrections to 

the rule. The Table of Standards has obsolete dates for the VOC limits in various coating 

categories that are no longer relevant and will be removed. Subparagraph (i)(1)(E) exempts 

individual coating categories using less than 50 gallons in any one year, if compliant coatings 

are not available, and provided that the total usage of all such coatings does not exceed 200 

gallons per year, per facility. Facilities that have opted for this exemption have been 

required to provide supporting documentation to AQMD to qualify for this exemption and 

were subject to the exemption if they received written approval from the Executive Officer. 

AQMD staff added the language “and for which written approval of the Executive Officer 

has been obtained” at the end of the subparagraph to provide enhanced clarification on this 

exemption. There will also be some other minor editorial clarifications in the rule as well. 
CHAPTER 3: IMPACT ASSESSMENT

 INTRODUCTION 

 EMISSION IMPACT ASSESSMENT 

 SOCIOECONOMIC IMPACT ASSESSMENT 

 POTENTIAL ENVIRONMENTAL IMPACTS 

 DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND 

SAFETY CODE SECTION 40727

 COMPARATIVE ANALYSIS 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-1 December 2009 

INTRODUCTION 

The current version of Rule 1145 applies to plastic, rubber, leather, and glass coating 

operations. There are approximately 115 facilities that fall under the purview of Rule 1145 

and these facilities include aerospace, automotive, electronic, and medical industries. 

There is no sales specific data available for the classification of the emission inventory in 

terms of specific coating categories for Rule 1145. For this reason, the model used in the 

2004 Staff Report for Rule 1145 will be implemented. The distribution of the emission 

inventory is based on the results of a survey that was conducted by AQMD in late 2002 and 

on other verbal information received by coatings suppliers. The 2002 survey included 58 

facilities representing a diverse group of industries that perform Rule 1145 coating 

operations and from this data it was determined that the multi-color coating category 

populated 5% of the total distribution studied for all the coating categories. AQMD staff 

believes that this distribution for the multi-color coating category continues to be relevant. 

The emissions inventory for the Rule 1145 universe was provided by the AQMD emissions 

reporting branch. The inventory was based on the year 2007 and the total emission inventory 

for Rule 1145, for 2007, was 0.49 tons per day (“tpd”) of VOC emissions. 

EMISSION IMPACT ASSESSMENT 

VOC Limit Modification for Multi-color Coating Category: 

The first proposed amendment seeks to reduce the VOC limit in Rule 1145 for the multicolor coating category from 685 g/L to 680 g/L of VOC which will yield a theoretical 

emission benefit that can be calculated. The estimated emissions inventory for multi-color 

coating category can be calculated by; 

0.49 tpd * 5% = 0.03 tpd = 49.0 lbs/day, (NOTE: Calculations shown using significant figures) 

Next, the gallons of the multi-color coating can be calculated, 

5.716 lbs/gal * X gal = 49.0 lb/day, and (Note: 685 g/L VOC = 5.716 lbs/gal VOC), 

X gal = 8.6 gallon/day so, 

Using 680 g/L VOC instead of 685 g/L VOC yields, 

5.675 lbs/gal * 8.6 gal/day = 48.6 lbs/day (Note: 680 g/L VOC = 5.675 lbs/Gal VOC), 

Therefore, the difference between the 680 and 685 g/L VOC calculations is the theoretical 

emission benefit, which calculates to 0.4 lbs/day (based on 260 working days per year). 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-2 December 2009 

Adding a New Coating Category for Refrigerated Glass Door Operations: 

The second proposed amendment seeks to add a new coating category to the Table of 

Standards in Rule 1145 to provide relief to one facility that is currently operating under a 

two-year variance but has not been able to find a lower VOC alternate coating that could be 

used successfully in their roll-coating application. In lieu of this, the new coating category, 

refrigerated glass door coatings, will be limited to 4 lbs/gal of VOC. The two coating 

systems currently used by the facility are actually screen printing inks and have been proven 

to provide satisfactory performance results for their refrigerated glass doors. 

Nazdar ADE Series Epoxy Screen Ink System: 

AQMD staff calculated the mix ratios for the Nazdar system and determined by using the 

facility’s usage records for CY2007 (“CY is for Calendar Year”) that on average 4.6 parts of 

ink were mixed with one part of catalyst. Staff then calculated the quantity of thinner used 

and found that on average 5.9 parts of the ink/catalyst mix were mixed with one part thinner. 

Using this information, staff calculated the VOC content of the Nazdar system, 

The ink mixed 4.6 parts ink to 1 part catalyst yields, 

{4.6*(3.1 lbs/gal) + 1*(4.15 lbs/gal)}/5.6 = {14.26 lbs/gal + 4.15 lbs/gal}/5.6 = 3.29 lbs/gal, 

[where the VOC of the ink = 3.1 lbs/gal and the VOC of the catalyst = 4.15 lbs/gal)], 

The ink/catalyst mixture is then mixed with 15% (of that mix) with the RE 190 Thinner, 

5.6 * 0.15 = 0.84 = 0.8 and, 

{5.6*(3.29 lbs/gal) + 0.8*(8.08 lbs/gal)}/6.4 = 3.89 lbs/gal 

[Where the VOC of the RE 190 Thinner = 8.08 lbs/gal] 

Based on this information staff recognizes that a VOC limit of 480 g/L (4.0 lbs/gal) will be 

appropriate for the new refrigerated glass door coatings category. 

AQMD staff determined, after review of the facility’s usage records that the largest quantity 

used for the Nazdar system was in CY2007; when 123.7 gallons of the Nazdar ADE Series 

Epoxy Screen Ink was used, 27.0 gallons of the ADE677 catalyst was used, and 25.4 gallons 

of the RE 190 Thinner was used. AQMD staff summed up the totals for the ink, catalyst and 

the thinner used in terms of pounds of emissions for CY2007 and found, 

123.7 gal*(3.1 lbs/gal) + 27.0 gal*(4.15 lbs/gal) + 25.4 gal*(8.08 lbs/gal) = 700.7 pounds of VOC 

The emissions forgone for the Nazdar system can be calculated by comparing the result of 

the equation above with the allowable limit in Rule 1145. This type of roll-coating operation 

would normally fall into the two-component coating category where the VOC limit is one 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-3 December 2009 

pound per gallon of VOC. Using the same volumes as the equation above and then 

calculating the pounds VOC, 

123.7 gal + 27.0 gal + 25.4 gal = 176.1 gallons, and 

176.1 gal * 1.0 lbs/gal = 176.1 pounds of VOC 

Therefore, the emissions forgone for the Nazdar system would be, 

700.7 pounds of VOC – 176.1 pounds of VOC = 524.6 pounds of VOC forgone. 

Enthone 50 Series Cat-L-Ink System: 

AQMD staff calculated the mix ratios for the Enthone system and determined by using the 

facility’s usage records for CY2007 that on average 10.4 parts of ink were mixed with one 

part of catalyst. Staff then calculated the quantity of thinner used and found that on average 

12.8 parts of the ink/catalyst mix were mixed with one part thinner. Using this information, 

staff calculated the VOC content of the Enthone system, 

{5.0*(3.64 lbs/gal) + 0.5*(0.83 lbs/gal)}/5.5 = {18.2 lbs/gal + 0.42 lbs/gal}/5.5 = 3.38 lbs/gal, 

[where the VOC of the ink = 3.64 lbs/gal and the VOC of the catalyst = 0.83 lbs/gal)], 

The ink/catalyst is then mixed with 6% (of that mix) with the Nazdar RE 190 Thinner, 

5.5 * 0.06 = 0.33 = 0.3 and, 

{5.5*(3.64 lbs/gal) + 0.3*(8.08 lbs/gal)}/5.8 = 3.87 lbs/gal 

[Where the VOC of the RE 190 Thinner = 8.08 lbs/gal] 

Based on this information staff recognizes that a VOC limit of 480 g/L (4.0 lbs/gal) will be 

appropriate for the new refrigerated glass door coating category. 

AQMD staff, after a thorough review of the facility’s usage records, also determined that the 

largest quantity of the Enthone system was in CY2007; when 5.0 gallons of the Enthone 50-

Series Cat-L-Link Epoxy Screen Ink was used, 0.5 gallons of the Enthone Catalyst 45 Part B 

was used and 0.4 gallons of the Nazdar RE 190 Thinner was used. AQMD staff summed up 

the totals for the ink, catalyst and the thinner used in terms of pounds of emissions for 

CY2007 and found, 

5.0 gal*(3.64 lbs/gal) + 0.5 gal*(0.83 lbs/gal) + 0.4 gal*(8.08 lbs/gal) = 21.8 pounds of VOC 

The emissions forgone for the Enthone system can be calculated by comparing the result of 

the equation above with the allowable limit in Rule 1145. This type of roll-coating operation 

would normally fall into the two-component coating category and the VOC limit is one 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-4 December 2009 

pound per gallon VOC. Using the same volumes as the equation above and then calculating 

the pounds VOC, 

5.0 gal + 0.5 gal + 0.4 gal = 5.9 gallons, and 

5.9 gallons * 1.0 lbs/gal = 5.9 pounds of VOC 

Therefore, the emissions forgone for the Enthone system would be, 

21.8 pounds of VOC – 5.9 pounds of VOC = 15.9 pounds of VOC forgone. 

Combining the emissions forgone for both the Nazdar and the Enthone systems yields, 

524.6 lbs VOC/CY2007 forgone + 15.9 lbs VOC/CY2007 forgone = 540.5 lbs VOC/CY2007 forgone 

The emissions for the first two amendments to this rule can now be calculated. The 

amendment to the multi-color category combined with the emissions forgone for the 

refrigerated glass door coatings yields, 

540.5 lbs/year VOC emissions forgone - 104 lbs/year VOC emission benefit = 436.5 lbs/year VOC = 1.7 

lbs/day (based on a 260 working days per year) of emissions, forgone. 

SOCIOECONOMIC IMPACT ASSESSMENT 

Since PAR 1145 does not significantly affect air quality or emissions limitations, a 

socioeconomic analysis is not required [H&SC 40440.8(a)]. Proposed Amended Rule 1145 

(PAR 1145) has four separate provisions. The first provision of PAR 1145 reduces the VOC 

limit for the multi-color coatings category from 685 g/L to 680 g/L to align it with the 

September 2008 U.S. EPA Control Techniques Guidelines (CTG). No additional costs from 

such alignment are expected. The second provision of PAR 1145 creates a new coating 

category for refrigerated commercial glass door coatings. The change provides additional 

flexibility for one facility with special manufacturing requirements, which would lead to 

savings for the facility. The third provision deletes paragraph (c)(3) that is obsolete 

language. The fourth provision of PAR 1145 will be to make editorial changes to the 

existing rule language that have no associated cost implications. 

In summary, PAR 1145 does not increase the cost of compliance for any facility and 

therefore will not have any significant socioeconomic impacts. 

POTENTIAL ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA) and SCAQMD Rule 110, an 

Environmental Assessment (EA) was prepared for proposed amended Rule 1145 and 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-5 December 2009 

circulated for public review from June 30, 2009 to July 29, 2009. Comments received during 

the review period were responded to and included in the Final EA. Copies of the Final EA 

can be obtained by calling the SCAQMD’s Public Information Center at (909) 396-2039. 

DRAFT FINDINGS UNDER CALIFORNIA HEALTH AND SAFETY CODE 

SECTION 40727 

Before adopting, amending or repealing a rule, the AQMD shall make findings of necessity, 

authority, clarity, consistency, non-duplication, and reference, as defined in Health and 

Safety Code Section 40727. The draft findings are as follows: 

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

1145 - Plastic, Rubber, Leather and Glass Coatings, is necessary in order to implement 

control measure MCS-07 – Application of All Feasible Measures of the 2007 AQMP. A new 

coating category for Refrigerated Glass Doors is necessary as there is no current compliant 

coating that will meet the performance specifications and the current rule VOC limits. 

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

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

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

1145, is written and displayed so that the meaning can be easily understood by persons 

directly affected by it. 

Consistency – The AQMD Governing Board finds and determines that Proposed Amended 

Rule 1145 is in harmony with, and not in conflict with or contradictory to, existing statutes, 

court decisions, or federal or state regulations. 

Non-Duplication – The AQMD Governing Board has determined that Proposed Amended Rule 

1145 does not impose the same requirement as any existing state or federal regulation, and the 

proposed amendments are necessary and proper to execute the powers and duties granted to, and 

imposed upon, the AQMD. 

Reference - In adopting these proposed amendments, the AQMD Governing Board 

references the following statutes which AQMD hereby implements, interprets or makes 

specific: Health and Safety Code Sections 40001 and 40440. 

Problem Finding – The AQMD Governing Board finds and determines that Proposed 

Amended Rule 1145 will reduce the VOC limit for the multi-color coating category to align 

it with the CTG recommended limit to promote the attainment or maintenance of state and 

federal ambient air quality standards.
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-6 December 2009 

COMPARATIVE ANALYSIS 

Health and Safety Code Section 40727.2 

As required by Health and Safety Code Section 40727.2, the purpose of this analysis is to 

identify and compare any other AQMD or federal regulations that apply to the same 

equipment or source type. The existing as well as the proposed VOC limits in Rule 1145 are 

not in conflict with the National Emission Standard for Hazardous Air Pollutants 

(“NESHAP”) for Surface Coating of Plastic Parts and Products (“Plastic Substrates”); 69 FR 

20990, April 19, 2004, Title 40, Subpart PPPP. The U.S. EPA CTG does have one conflict 

with the current version of AQMD Rule 1145 and that is the VOC limit for the multi-color 

coating category. This amendment seeks to align AQMD Rule 1145 multi-color coating 

category with the recommended VOC limit for that coating category in the CTG. 

The NESHAP for Plastic Substrates sets forth Hazardous Air Pollutants (“HAP”) emission 

limits for existing and new and reconstructed affected sources. Affected sources under this 

NESHAP are plastic coating operations that are major sources under federal law or are 

coating operations located within the confines of a federal major source. The NESHAP for 

plastics explicitly exempts non-major sources, operations regulated under another NESHAP, 

military installations, research facilities, and reinforced plastic composites. 

The CTG is intended to provide state and local air pollution authorities information that shall 

assist them in determining RACT for VOCs for metal and plastic parts surface coating 

operations. 

The proposed amendments to Rule 1145 will result in minor VOC emissions forgone, but 

Rule 1145 and the proposed amendments do not regulate HAP emissions directly. 

Therefore, the existing as well as the proposed VOC limits of Rule 1145 are not in conflict 

with federal regulations. 

A table (shown next page) has been prepared to show comparisons between AQMD Rule 

1145, the CTG and the NESHAP regulation. 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-7 December 2009 

CATEGORY SCAQMD 

RULE 1145

U.S.EPA CTG 

Metal & Plastic Parts 

USEPA NESHAP 

40 CFR 63 Sub-part PPPP 

Purpose 

Reduce VOC emissions 

from plastic, rubber, 

leather and glass 

coatings. 

The CTG is intended to 

provide state and local air 

pollution authorities 

information that shall assist 

them in determining RACT 

for VOCs for metal & plastic 

parts surface coating 

operations. 

Establishes National Emission 

Standards for Hazardous Air 

Pollutants for plastic parts & 

products surface coating facilities. 

Applicability 

Rule 1145 applies to any 

plastic, rubber, leather or 

glass coating operation. 

Applies to facilities that 

perform surface coating 

operations to metal & plastic 

parts. 

Applies to surface coating 

facilities & requires initial and 

continuous demonstration of 

compliance with emission limits. 

Averaging 

Provisions None None None 

Units 

Mass/Volume: 

Grams/Liter or 

Pounds/gallon. 

Mass/Volume: 

Kilogram VOC/Liter or 

Pounds VOC/Gallon. 

Mass fraction of coating solids: 

Kg organic HAP/Kg coating 

solids used. 

Operating 

Parameters 

Application equipment 

transfer efficiency 

requirements. 

Application equipment 

transfer efficiency 

requirements.

The NESHAP does not mention 

the use of HVLP type transfer 

efficiency for application 

equipment. 

Method to 

Determine 

VOC 

U.S.EPA Method 24 The CTG does not mention 

U.S.EPA Methods. U.S.EPA Method 24 

Capture 

Efficiency U.S.EPA Method 204 

The CTG does not mention 

U.S.EPA Methods. U.S.EPA Method 204 

Control Device 

Efficiency 

U.S.EPA Method 25 & 

25A 

The CTG does not mention 

U.S.EPA Methods. U.S.EPA Method 25 & 25A 

Work 

Practices 

Rule 1145 defers to Rule 

1171 for storage and 

disposal of VOC 

containing materials. 

VOC containing containers 

to be kept closed when not 

using. 

VOC containing containers to be 

kept closed when not using. 

Minimize spills of VOC 

containing materials. 

Minimize spills of VOC 

containing materials. 

Monitoring None None None 

Reporting None There is no mention for 

reporting in the CTG. 

Annual reporting period of 6 

months and 12 months. 

Recordkeeping 

Rule 1145 defers 

recordkeeping to Rule 

109, records to be kept 

annually. 

There is no mention for 

recordkeeping in the CTG. 

Comprehensive records required 

annually to support compliance 

with NESHAP for plastics. 

Other 

Elements 

Prohibition of sale for 

coatings that do not 

comply with the VOC 

limits in the rule. 

There is no mention of a 

prohibition of sale 

requirement in the CTG. 

The NESHAP does not mention a 

prohibition of sale for coatings. 

Exemptions provided for 

processes that would 

otherwise be deemed not 

compliant by the rule and 

do not have an alternate 

means to comply. 

The CTG recommends the 

exemptions in SCAQMD 

Rule 1145 and Michigan 

Rule 336.1632. 

The NESHAP offers one 

exemption and that is the 

presidential compliance 

exemption. 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-8 December 2009 

PUBLIC COMMENTS AND STAFF RESPONSES 

The public comments and staff responses shown below are numbered 1 through 11 and are 

from the June 25, 2009 public workshop. 

1. COMMENT: As AQMD staff is aware, we have diligently pursued a means to 

compliance short of rule amendment. The pursuit has included 

numerous inquiries to vendors and multiple tests of alternative 

coatings, including UV coatings. Moreover, the pursuit has 

required the commitment of significant time and resources. 

Unfortunately, the pursuit has yet to yield a viable solution to 

our compliance problems and SCAQMD staff has expressed its 

concurrence that no sufficient alternative coating is likely to 

become available in the near future. We sincerely hope the 

SCAQMD Governing Board will consider these facts as it 

moves toward a final decision on the Proposed Rule. Given the 

small quantity of VOC emissions that will be generated by 

adoption of the Proposed Rule, it does not make sense to force 

our niche operation to stop and move production. 

STAFF RESPONSE: AQMD staff agrees that the facility has tried several alternate 

coating technologies such as powder coating, silk-screening and 

UV coatings over the last 17 months and that all of them have 

yielded unsatisfactory results using the industry standard ASTM 

Test Method D3359-97, which showed unsatisfactory adhesion 

measurements. The facility has shown due diligence in 

complying with their variance commitments to try and facilitate 

new low VOC emitting technology. AQMD staff further 

recognizes that if a low VOC technology becomes available in 

the future that we will reassess this coating category for a lower 

VOC content, but at this time due to the expiration of their 

variance on December 31, 2009 it is recommended that a new 

coating category for refrigerated glass door coatings be made. 

2. COMMENT: Radtech disagrees with the District findings that UV and EB 

technology does not meet the adhesion test data. Does the 

District have data from the facility to verify these claims? 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-9 December 2009 

STAFF RESPONSE: Staff met with the facility back on February 24, 2009 and was 

presented with three UV coated glass sample panels that were 

tested under ASTM test method D3359-97, the test method used 

to measure adhesion by tape test. Staff documented the results 

and found that even though the first round of testing showed 

positive results, the second round of testing yielded two out of 

three adhesion test failures. AQMD staff observed the two glass 

sample panels where the UV coating flaked along the scribe 

lines. The facility staff informed AQMD staff that during the 

testing of the UV coating system they asked the UV coating 

manufacturer if they would warranty their coating to which the 

UV coating manufacturer informed them that they would not. 

The District also has progress reports from the facility that are 

required quarterly by the facility’s variance that requirement 

will show how the coatings they tried performed. 

3. COMMENT: What really strikes me is that the thinner used at the refrigerated 

glass door facility is at 890 g/L VOC content and recently the 

District board adopted Rule 1143 for the consumer paint 

thinners and I believe some of those limits were down to 25 g/L. 

So, it strikes me, as a consumer in my garage, I can’t have 

thinners above 25 g/L but in this particular rule there’s a 890 

g/L thinner. 

STAFF RESPONSE: Rule 1143 – Consumer Paint Thinners and Multi-purpose 

Solvents and Rule 1145 – Plastic, Rubber, Leather, and Glass 

Coatings are two different rules. The main difference is Rule 

1143 is intended for consumer product based paint thinners and 

multi-purpose solvents whereas Rule 1145 is intended for 

industrial source specific facilities. Rule 1145 does not regulate 

the VOC emissions from paint thinners and multi-purpose 

solvents rather it regulates the coating VOC, as applied to 

plastic, rubber, leather and glass applications. So, even though 

the thinner used by the refrigerated glass door facility has a 

high-VOC content of 969.7 g/L (8.08 lbs/Gal), not 890 g/L as 

stated by the commentator, the end result is that the coating 

would have to meet the VOC limit for its specific coating 

category even after thinning. The facility that is manufacturing 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-10 December 2009 

refrigerated glass doors for refrigeration cabinets is using the 

Nazdar coating system and they are following the recommended 

products for the coating system as specified on the Nazdar 

technical data sheet. The thinner is used at 15% by weight to 

reduce the viscosity of the ink coating. However, the amount of 

the coating used by the facility is rather small, which equates to 

just 2.1 pounds of VOC per day, based on a 260 working day 

year, of VOC emissions forgone. AQMD staff calculated the 

maximum VOC limit for the new proposed refrigerated glass 

door coating category by using the facility’s highest VOC 

constituents for the ink, catalyst and thinner. The proposed new 

coating category, refrigerated glass door coatings, will be 

limited to a maximum limit of 480 g/L of VOC, as applied. The 

consumer product rule, Rule 1143, will take effect on January 1, 

2010 and the VOC limit for the interim period will be 300 g/L of 

VOC followed by the final VOC limit of 25 g/L effective on 

January 1, 2011. Currently, these consumer product solvents 

are sold in large box stores and hardware stores and have VOC 

contents of 800 g/L and higher. 

4. COMMENT: Basically, the SCAQMD has concluded in this Rule 1145 staff 

report that UV coatings do not work for glass coating 

applications. We have been contacted by environmental groups 

to provide technical data on the feasibility of UV coatings for: 

 (1) Multi-colored coatings 

 (2) Glass coatings for refrigerated doors 

STAFF RESPONSE: AQMD staff did not conclude that UV coatings do not work for 

glass coating applications as stated in the paragraph above. 

AQMD staff acknowledges that the facility required a coating 

for their refrigerated glass doors and they did investigate UV 

coatings. AQMD staff contacted Radtech back on February 12, 

2009 and informed them of a facility that was not able to meet 

the VOC limit for Rule 1145. Radtech provided only one UV 

coating manufacturer contact that was the same contact that 

worked with the facility to test a UV coating that could meet all 

of the facility’s performance requirements. The coating 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-11 December 2009 

manufacturer that was provided by Radtech did prepare several 

glass panels samples that were coated using UV coatings 

however, there were some adhesion failures. The coating 

manufacturer informed the facility that they would not warranty 

their coatings. 

5. COMMENT: The adhesion problems cited in the staff report may be 

overcome with certain pre-treatment steps. The attached article 

by Petra Burger of Fusion UV (Glass worldwide, issue fourteen 

2007, Page 50) shows how a UV coating fails adhesion tests 

without pre-treatment and how the same coating gets 100 

percent adhesion with the proper pre-treatment. The same 

article illustrates that UV coatings are being used in glass 

bottles. Coatings on beverage containers have to withstand 

refrigeration by consumers. The article by Dawn Skinner (page 

S20 Annual ESMA Glass Publication 2009) talks about the 

importance of pre-treatment to achieve good adhesion results. 

STAFF RESPONSE: AQMD staff has had conversations with UV coating 

manufacturers and one topic that was discussed was glass 

pretreatment. One of the UV coating manufacturers stated that 

they did not know of any liquid pretreatments for glass but for 

plastics, the pretreatment is to simply wipe down the substrate 

with acetone. For glass, and in the case of large glass panels, a 

flame/plasma application treatment such as pure or silicate 

flaming will increase the adhesion characteristics of the UV 

coating. This operation is conducted in an oven where the 

flame application is applied onto the glass surface to raise the 

tensile strength of the glass surface to enhance the coatings 

adhesion to the glass. This type of equipment could be 

employed but at significant expense to the facility as well as 

increased NOx (oxides of nitrogen), CO (carbon monoxide), 

particulate emissions and greenhouse gases. In addition, the 

thermal application impacted on the glass substrate would have 

to be considered in the manufacturing process of the 

refrigerated glass door assembly as potential undesirable 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-12 December 2009 

tempering effects could alter the physical properties of the glass 

door panels. 

6. COMMENT: The South Coast Air Quality Management District (SCAQMD), 

is proposing amendments to their Rule 1145—Plastic, Rubber, 

Leather and Glass Coatings. According to the agency, the 

changes would mirror the requirements of the Environmental 

Protection Agency’s Control Techniques Guidelines and create 

some exemptions. There are approximately 115 facilities that 

fall under the purview of Rule 1145 involved in the following 

processes: 

• Aerospace 

• Automotive 

• Electronic and 

• Medical industries 

According to the rule staff report, the changes to Rule 1145 will 

result in an increase in emissions of 436.5 pounds per year from 

a single facility. This is mostly due to the creation of a new 

coating category “for a niche manufacturing process where 

coated glass panels are used in the manufacturing of refrigerated 

glass doors for refrigeration cabinets, for which a compliant 

product is currently not available. "The staff concluded that the 

facility should be allowed to continue to use its conventional 2 

component coating system which requires the use of a thinner 

with a VOC content of 890 grams/liter. Staff also accepted the 

facility’s claims that lower VOC coatings, including UV/EB 

coatings, failed adhesion tests by the facility. The report states 

that “AQMD staff has determined that the facility has been 

unable to locate a VOC compliant coating that would perform to 

the expected performance standards the refrigerated doors must 

adhere to.” AQMD staff calculated these emissions to be 

approximately 540.5 lbs/year (2.1 lbs/day) of VOC forgone. 

The emissions reduction in the rule can be attributed to an 

amendment changing the VOC limit for multi-colored coatings 

from 685 grams per liter to 680 grams per liter, as per the EPA’s 

CTG. The combined total emissions for the proposed 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-13 December 2009 

amendments to the multi-colored category and the addition of 

the refrigerated glass door coatings calculate to approximately 

436.5 lbs/year (1.7 lbs/day) of VOC emissions forgone. 

I wanted to let you know that Radtech members have met with 

district staff and provided data to show that UV coatings would 

work for the refrigerated doors. The district did not include any 

of our data in the report. We made comments yesterday at the 

workshop and requested the company's data as a matter of 

public record, that data which allegedly shows that UV coatings 

fail adhesion tests, was also not included in the report or 

provided at the workshop. 

STAFF RESPONSE: The first paragraph is not entirely accurate when stating that 

the rule changes would mirror the requirements of the 

Environmental Protection Agency’s Control Techniques 

Guidelines and create some exemptions. The proposed 

amendments to Rule 1145 do not include any additional 

exemptions. The proposed amendment does include an 

additional coating category for refrigerated glass door coatings 

which is intended to allow one facility to operate in compliance 

with Rule 1145 after their variance expires on December 31, 

2009. 

In the second paragraph Radtech states that AQMD staff 

accepted the facility’s claims. AQMD staff has worked with the 

facility since February 2008 and over the course of the testing 

period has been shown several glass panel samples where 

coatings, including UV coatings, did not meet the 5B adhesion 

level of ASTM test method D3359-97, the adhesion 

specifications required for this niche application. The adhesion 

requirements are two-fold for the facility’s operation. The 

coatings must adhere to the glass substrate not just for 

aesthetics but also as a substrate for the spacer and sealant that 

is used to seal the triplicate glass panels together to complete 

the refrigerated glass door assembly. The seal cannot fail; if it 

does the warranty requires a complete door replacement. The 

UV coating manufacturer informed the facility that they would 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-14 December 2009 

not warranty their coating. The facility has not found a readily 

available VOC compliant alternate coating that can meet the 

performance requirements for their product. The facility has 

shown their due diligence by complying with the requirements of 

their variance and by testing several low-VOC alternate 

coatings, but none have been found satisfactory. Subsequent 

testing conducted further corroborates earlier conclusions. 

7. COMMENT: We oppose the amendments to Rule 1145 – Plastic, Rubber, 

Leather and Glass Coatings. Several months ago, district staff 

contacted us to assist the facility manufacturing refrigerated 

glass doors in the conversion to compliant coatings. At a June 

10, 2009 meeting, we shared with district staff our 

disappointment that the facility did not appear committed to the 

prospect of conversion to UV technology, despite the fact that a 

viable UV coating was available to meet their performance 

needs as we understood them. The facility did not provide us 

with specifics such as product specifications and performance 

data. As a service to the industry and to support SCAQMD 

efforts, we made an exception to its charge policy for the 

facility. We conducted significant work and testing for the 

facility at no charge. We typically charge prospective 

customers for development work; a fee that was waived for the 

facility. We incurred a significant amount of cost with zero 

return, on behalf of the facility. The facility’s staff failure to 

provide a prompt response to us indicated that finding compliant 

coatings was not a priority for the facility and that the inquiry 

process they engaged us in was a mere formality. 

STAFF RESPONSE: AQMD staff appreciates all the assistance provided towards 

identifying a compliant product but disagrees with the 

commentator that a viable coating was available to meet the 

facility’s performance needs. AQMD staff has worked with the 

facility since February 2008 and has been privy to observe the 

UV coated glass panel samples. The facility admitted to the first 

round of testing having positive results but when the second 

round of testing was conducted, two out of the three UV coating 

glass panel samples were failures. In addition, the facility 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-15 December 2009 

stated that the coating manufacturer informed them that they 

would not warranty their UV coating. AQMD staff does not get 

involved with business arrangements between companies, and 

therefore, will not comment on research fees. Subsequent 

testing conducted further corroborates earlier conclusions. 

8. COMMENT: At a June 10, 2009 meeting, we shared with district staff our 

disappointment that the facility did not appear committed to the 

prospect of conversion to UV technology, despite the fact that a 

viable UV coating was available to meet their performance 

needs as we understood them. The facility did not provide us 

with specifics such as product specifications and performance 

data. The materials used in our process have negligible VOC’s. 

Therefore, the facility’s conversion to UV would render its 

process “super-compliant” with current district requirements. 

Our company services the glass coatings industry. The UV 

coatings used in the process meet the performance requirements 

specified by our customers, good adhesion to the substrate is 

one of those requirements. 

STAFF RESPONSE: AQMD staff recognizes and appreciates the efforts that the 

commentator continues to put forth toward developing a UV 

coating that could work successfully without failures and that 

would be a “super-compliant coating“. However, as it stands, 

the facility does not have a low-VOC alternate coating available 

that can perform without failures at this time. AQMD staff 

encourages the commentator to continue their efforts to develop 

and formulate a UV coating and field test it to ensure that it will 

meet the performance requirements for this niche coating 

operation. The facility requires a coating that must have 

complete opacity, permanently adhere to the glass and survive 

in its end-use environment where temperatures continually 

range between 35 to 70 degrees Fahrenheit. In addition, the 

coating must also serve as a substrate for the spacer and sealant 

that bonds the three glass panels together for the final 

refrigeration glass door assembly. 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-16 December 2009 

9. COMMENT: We are involved in Ultraviolet/Electron Beam technology. Our 

company is working towards a project to service the glass 

coatings industry. The UV coatings used in the process meet 

the performance requirements specified by our customers; good 

adhesion to the substrate is one of those requirements. The end 

goal of the continued development work on the formulations is 

for the materials used in the process to have negligible VOC’s. 

Under the current Rule 1145 proposal, a new category would be 

created to exempt refrigerated glass doors. The amendment 

would result in an unwarranted emissions increase to the basin 

because UV coatings can meet the VOC requirements. 

Furthermore, the staff report erroneously concluded that UV/EB 

coatings failed to adequately adhere to glass. Our company’s 

UV products show good adhesion to glass. We look forward to 

the incorporation of our company’s comment in the Rule 1145 

rulemaking. 

STAFF RESPONSE: AQMD staff appreciates you taking time to participate during 

the public workshop comment period. The proposed amendment 

for the refrigerated glass door coating category is intended to 

allow one manufacturer to continue operating in the South 

Coast District. AQMD staff did a comprehensive analysis and 

determined that the facility was the only facility in the AQMD 

jurisdiction that conducts the niche operation of applying a 

border coating to glass panels that not only has to meet 

customer satisfaction for aesthetics but also has to serve as a 

substrate for the spacer and sealant that bonds three of these 

large glass panels in a sandwich like configuration to complete 

the refrigerated glass door assembly. As of this time, the facility 

has not found a readily available low-VOC coating that will 

satisfy the performance requirements without failures. Based on 

this information, AQMD staff believes that the additional 

coating category for refrigerated glass doors should be included 

in the amendment and will continue to support UV coating 

manufacturers such as yours to continue development for a 

suitable UV coating that will be available as a low-VOC 

alternate coating for this niche operation. 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-17 December 2009 

10. COMMENT: Under the current Rule 1145 proposal, a new category would be 

created to exempt refrigerated glass doors based on one facility. 

The amendment would result in an unwarranted emissions 

increase to the basin because UV coatings can meet the VOC 

requirements. Furthermore, the staff report erroneously 

concluded that UV/EB coatings failed to adequately adhere to 

glass. Our company’s UV products show good adhesion to glass 

by the facility engineer’s own admission. AQMD’s exception 

for the facility is not reasonable and should not be approved. 

Furthermore, conventional glass coatings may contain heavy 

metals. We are not aware of the district taking this issue into 

consideration in its staff analysis. We supply compliant UV 

coatings that are essentially VOC free, with no toxics, and can 

meet industrial demands. We look forward to working with the 

district staff in the Rule 1145 rulemaking.

STAFF RESPONSE: The AQMD is not providing an additional exemption in the rule 

but is proposing a new coating category to be added to the 

Table of Standards. Please also note that the facility, prior to 

obtaining their variance, was operating under Rule 1130.1 

which allows for a much higher VOC limit. AQMD staff 

disagrees with the statement “the staff report erroneously 

concluded that UV/EB coatings failed to adhere to glass”. 

AQMD staff discussed the UV coatings with the facility in detail. 

The facility recognized that the first round of testing showed 

promise that the UV coatings had potential to work for their 

operation. However, after the second round of testing, the 

facility found that two out of the three UV coated glass panel 

samples did not meet the facility’s adhesion specification under 

ASTM test method D3359-97. AQMD staff observed these glass 

panel samples and noted that the scribe lines showed coating 

fragmentation. The facility informed AQMD staff that they were 

alarmed with this because for their manufacturing process, any 

portion of the coating that comes off on the tape pull off 

constitutes a failure. Therefore, AQMD’s proposed amendment 

for a refrigerated glass door coating is reasonable. AQMD staff 

reviewed the Nazdar coating line and did not find any 
Chapter 3: Impact Assessment Final Staff Report

Proposed Amended Rule 1145 3-18 December 2009 

specification of heavy metals in the material safety data sheets 

with the exception of one color, red, which contains 18-27% 

lead. Lead is considered a toxic metal in contrast to heavy 

metals which can include iron, cobalt, copper, manganese, 

molybdenum, and zinc, and are found in living organisms. 

11. COMMENT: We wish to express our continued support for Proposed 

Amended Rule 1145 titled: Plastic, Rubber, Leather and Glass 

Coatings (“the Proposed Rule”), and strongly urge the South 

Coast Air Quality Management District (“SCAQMD”) 

Governing Board to adopt the Proposed Rule at its September 

11, 2009 meeting. We have a niche operation that has been 

ongoing since 1990 but without adoption of the proposed rule, 

we will be unable to comply with applicable SCAQMD rules. 

The adoption of the proposed rule is crucial to our continued 

existence in this region. 

STAFF RESPONSE: AQMD staff appreciates your support of this rule amendment. 

AQMD staff believes that the proposal is needed to allow the 

facility to continue to operate while still looking for a low VOC 

technology that can be used in this niche operation for 

refrigerated glass door manufacturing. 
References Final Staff Report

Proposed Amended Rule 1145 R - 1 December 2009 

REFERENCES 

1. Helmy Sultan, Ph.D., Air Quality Specialist, Ricardo Rivera, Air Quality Specialist: 

“Draft Staff Report for Proposed Amended Rule 1145 – Plastic, Rubber, Leather and 

Glass Coatings”, SCAQMD Document, November 2, 2004. 

2 Nazdar coating system hyperlinks: 

Nazdar ADE Series Epoxy Screen Ink, Opaque Black link: 

http://www.nazdar.com/wv/private/document.aspx?prd=ADE52%7E%7EPDF%7E%7EMTR%7E%7ENAM

%7E%7EEN%7E%7E12/08/2008%7E%7EOpaque%20Black&language=d__EN&productID=ade

Nazdar ADE677 Catalyst MSDS link: 

http://www.nazdar.com/wv/private/document.aspx?prd=ADE677%7E%7EPDF%7E%7EMTR%7E%7ENA

M%7E%7EEN%7E%7E12/08/2008%7E%7ECatalyst&language=d__EN&productID=ade677

Nazdar RE-190 Thinner MSDS link: 

http://www.nazdar.com/wv/private/document.aspx?prd=RE190%7E%7EPDF%7E%7EMTR%7E%7ENAM

%7E%7EEN%7E%7E11/18/2008%7E%7EThinner&language=d__EN&productID=re190

3 Enthone coating system hyperlinks: 

http://enthonedata.cooksonelectronics.com/PWBChemistry/dsinforeq.nsf/InfoReq2?OpenForm

(Must inquire for links) 

4. Environmental Protection Agency, Hazardous Air Pollutants (NESHAP), for plastic parts, 

http://www.deq.state.mi.us/documents/deq-ess-caap-fedregister-plasticsfinalrule.pdf

5. South Coast AQMD Hearing Board, Case No. 4797-1, Petitioner granted on December 

19, 2007 

6. Standard Industrial Classification Manual, 1987, Executive Office of the President, 

Office of Management and Budget, National Technical Information Service, 5285 Port 

Royal Road, Springfield, Virginia 22161, Order no. 87-100012, pg 165, Industry Group 

No. 323, Industry No. 3231 – Glass Products, Made of Purchased Glass. 

7. North American Industrial Classification System, United States, 2007, Executive Office 

of the President of the United States, ISBN 978-1-59888-082-3 (NTIS Order Number: 

PB2007-100002),Published 2007 by Bernan, a division of The Kraus Organization 

Limited, 4611-F Assembly Drive, Lanham, MD 20706, (800) 274-4447, 

www.bernan.com, National Technical Information Service, 5285 Port Royal Road, 

Springfield, Virginia 22161, (800) 553-6847, info@ntis.gov, Pg 344, Subsector 327215 

– Glass Product Manufacturing Made of Purchased Glass. 
APPENDIX: ADHESION BY TAPE TEST RESULTS

The adhesion by tape test results are shown in this appendix. The adhesion by tape testing 

was recommended by the Stationary Source Committee (07/24/09) and were subsequent to 

the staff report for the set-hearing. 

 UV Coating Test Results (08/27/09 & 09/08/09) 

 Epoxy Ink Coating Test Results (09/17/09) 
V.C. BUD JENKINS 

WWW.COATINGSSCIENTIST.COM 

BS CHEMISTRY, MBA MARKETING, JD LAW 

CERTIFIED HAZARDOUS MATERIALS MANAGER 

CERTIFIED HAZARDOUS WASTE PRACTITIONER 

EXPERT WITNESS, COATINGS 

COATINGS INSTRUCTOR, CAL POLY UNIVERSITY POMONA

3366 Somis Drive, Riverside, CA 92507, email: vcbudjenkins@yahoo.com 

Phone/FAX 951-682-4023 Cell Phone: 909-260-4263 

August 27, 2009 

Subject: Cross Hatch Adhesion Test of UV-cure Gray Paint on Glass 

DECLARATION OF V.C. “BUD” JENKINS 

I, V.C. “Bud” Jenkins, declare: 

The facts set forth in this declaration are my personal knowledge and 

if called as a witness, I could competently testify to them. 

I am an instructor of Chemistry at California Polytechnic University, 

Pomona, specializing in Coatings Science (i.e., the science of paint and 

related coating products) and have held that position continuously since 

1994. At Cal Poly Pomona, I teach a 1-year course in Coatings Science, 

resulting in an industry-recognized certificate in Coatings Science. I have 

presented several technical papers at the annual Federation of Societies of 

Coatings Technology convention, including papers on coatings stability, 

color change with change of viewing angle, environmental problems in the 

coatings industry, and problems associated with paint overspray on bridges. 

In my capacity as a consultant, I have been retained and have testified as an 
expert witness in numerous civil law suits and two criminal actions 

involving coatings defects, application defects, corrosion protection, raw 

materials omissions, color matching problems, color changing problems, 

attempted murder and murder. I hold a Bachelor of Science in Chemistry 

from the University of California, Riverside, that I obtained in 1973; a 

Master of Business Administration from the University of California, 

Riverside, (1976); a Juris Doctorate from Western States University (1982), 

Certified Hazardous Materials Manager Certificate from the University of 

California, Riverside (1983); a Certified Hazardous Waste Practitioner 

Certificate from the University of California, Riverside (1985) and have 

successfully completed a coatings science course at Los Angeles City 

College as well as a Color Matching Course at Los Angeles Trade Technical 

College. I was President of the Los Angeles Society for Coatings 

Technology for two terms and have held several Chairperson positions 

during my more than 25 years with that organization, including Technology 

Committee Chair, Education Committee Chair, Publicity Committee Chair, 

Manufacturing Committee Chair, and Library Committee Chair. I have 

studied and organized nearly 100 seminars for UV Coatings, aerosol spray 

coatings, artist colors, wood coatings, and concrete coatings as well as the 

more familiar Architectural and Industrial Maintenance coatings. Among 
the industry classes I have attended are courses on polymers, crosslink 

density, waterborne formulation, inks, sealants, caulking, instrumental 

analysis, and furniture finishes. I presently sit as the only coating scientist 

on a committee of the Getty Museum to research ways to restore and protect 

murals all over the world. In addition, I have more than 40 years of 

experience in the paint and coatings industry, having worked as a painter for 

a paint crew, as the Operations Manager for a medium sized paint company 

and as a paint lab technician and lab manager for three large paint 

companies. Besides that, as a full time consultant, I have developed many 

coatings for coating companies and have resolved coating disputes in the 

field. 

On August 26, 2009, a glass coated panel was received from Mr. Don Hopps 

and Mr. Andrew Lee of the South Coast Air Quality Management District. 

It was wrapped in tissue paper and encased in two sheets of cardboard 

wrapped tightly in plastic packing tape and had not been opened. It 

remained in my control in my lab at Cal Poly Pomona and in my car for 2 

days. 

On August 28, 2009, it was carefully opened and laid on a sturdy table, 

painted side up. The panel was marked in quadrants marked A, B, C, and D. 
Testing was done in each quadrant. 

A Gardco PA-2000 kit with a PA-2054 1.5mm blade was used to make 

11x11 cuts in the film in accordance with ASTM D-3369 Standard Test 

Method for Measuring Adhesion by Tape Test. 

A straight edge was used to make sure the cuts were straight and at right 

angles to each other. A soft brush was used to remove any debris caused by 

the cutting. Two windings of Permacel tape were removed and discarded 

prior to using the tape for adhesion testing. The tape was smoothed onto the 

surface over the crosshatch area and pressed into place with a pencil eraser 

and allowed to set for 90 seconds. The tape was pulled rapidly (less than 

one second without jerking) at 180 degrees. The amount of paint removal 

was compared with the standard chart supplied with the ASTM test. 

RESULTS 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE 

D 5B 0% NONE 

Photos were taken each step of the way to show the progress of the test.

V.C. BUD JENKINS 

WWW.COATINGSSCIENTIST.COM 

BS CHEMISTRY, MBA MARKETING, JD LAW 

CERTIFIED HAZARDOUS MATERIALS MANAGER 

CERTIFIED HAZARDOUS WASTE PRACTITIONER 

EXPERT WITNESS, COATINGS 

COATINGS INSTRUCTOR, CAL POLY UNIVERSITY POMONA

3366 Somis Drive, Riverside, CA 92507, email: vcbudjenkins@yahoo.com 

Phone/FAX 951-682-4023 Cell Phone: 909-260-4263 

September 8, 2009 

Subject: Cross Hatch Adhesion Test of UV-cure Gray Paint on Glass 

DECLARATION OF V.C. “BUD” JENKINS 

I, V.C. “Bud” Jenkins, declare: 

The facts set forth in this declaration are my personal knowledge and 

if called as a witness, I could competently testify to them. 

I am an instructor of Chemistry at California Polytechnic University, 

Pomona, specializing in Coatings Science (i.e., the science of paint and 

related coating products) and have held that position continuously since 

1994. At Cal Poly Pomona, I teach a 1-year course in Coatings Science, 

resulting in an industry-recognized certificate in Coatings Science. I have 

presented several technical papers at the annual Federation of Societies of 

Coatings Technology convention, including papers on coatings stability, 

color change with change of viewing angle, environmental problems in the 

coatings industry, and problems associated with paint overspray on bridges. 

In my capacity as a consultant, I have been retained and have testified as an 
expert witness in numerous civil law suits and two criminal actions 

involving coatings defects, application defects, corrosion protection, raw 

materials omissions, color matching problems, color changing problems, 

attempted murder and murder. I hold a Bachelor of Science in Chemistry 

from the University of California, Riverside, that I obtained in 1973; a 

Master of Business Administration from the University of California, 

Riverside, (1976); a Juris Doctorate from Western States University (1982), 

Certified Hazardous Materials Manager Certificate from the University of 

California, Riverside (1983); a Certified Hazardous Waste Practitioner 

Certificate from the University of California, Riverside (1985) and have 

successfully completed a coatings science course at Los Angeles City 

College as well as a Color Matching Course at Los Angeles Trade Technical 

College. I was President of the Los Angeles Society for Coatings 

Technology for two terms and have held several Chairperson positions 

during my more than 25 years with that organization, including Technology 

Committee Chair, Education Committee Chair, Publicity Committee Chair, 

Manufacturing Committee Chair, and Library Committee Chair. I have 

studied and organized nearly 100 seminars for UV Coatings, aerosol spray 

coatings, artist colors, wood coatings, and concrete coatings as well as the 

more familiar Architectural and Industrial Maintenance coatings. Among 
the industry classes I have attended are courses on polymers, crosslink 

density, waterborne formulation, inks, sealants, caulking, instrumental 

analysis, and furniture finishes. I presently sit as the only coating scientist 

on a committee of the Getty Museum to research ways to restore and protect 

murals all over the world. In addition, I have more than 40 years of 

experience in the paint and coatings industry, having worked as a painter for 

a paint crew, as the Operations Manager for a medium sized paint company 

and as a paint lab technician and lab manager for three large paint 

companies. Besides that, as a full time consultant, I have developed many 

coatings for coating companies and have resolved coating disputes in the 

field. 

On August 26, 2009, a glass coated panel was received from Mr. Don Hopps 

and Mr. Andrew Lee of the South Coast Air Quality Management District. 

It was wrapped in tissue paper and encased in two sheets of cardboard 

wrapped tightly in plastic packing tape and had not been opened. It 

remained in my control in my lab at Cal Poly Pomona and in my car for 2 

days. 

On August 27, 2009, it was carefully opened and laid on a sturdy table, 

painted side up. It was labeled 3/16” THK GLASS #2. The panel was 
marked in quadrants marked A, B, C, and D. Testing was done in each 

quadrant. 

A Gardco PA-2000 kit with a PA-2054 1.5mm blade was used to make 

11x11 cuts in the film in accordance with ASTM D-3369 Standard Test 

Method for Measuring Adhesion by Tape Test. 

A straight edge was used to make sure the cuts were straight and at right 

angles to each other. A soft brush was used to remove any debris caused by 

the cutting. Two windings of Permacel tape were removed and discarded 

prior to using the tape for adhesion testing. The tape was smoothed onto the 

surface over the crosshatch area and pressed into place with a pencil eraser 

and allowed to set for 90 seconds. The tape was pulled rapidly (less than 

one second without jerking) at 180 degrees. The amount of paint removal 

was compared with the standard chart supplied with the ASTM test. 

TABLE 1 

3/16” THK GLASS #2 RESULTS 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE 

D 5B 0% NONE 
Photos were taken each step of the way to show the progress of the test. 

Conclusion: 

The adhesion of the #2 coating to the glass panel is outstanding. 

September 8, 2009 

TESTING OF SIX NEW PANELS IN THE SAME SERIES 

An unopened wooden box was received by the writer from Mr. Don Hopps, 

SCAQMD, on Thursday, September 3, 2009, containing 6 more coated glass 

panels for cross-hatch adhesion testing. They had etching in them as 

follows: 

1/8” THK GLASS #1, #4, #5, #9, #10 and #12. 

They were tested on September 8, 2009 in the same manner as the above 

August 27, 2009 #2 panel was tested. The results are found in the following 

tables: 

TABLE 2 

RESULTS PANEL 1 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 3B 5-15% 

B 3B 5-15% 

C 3B 5-15% 
D 3B 5-15% 

TABLE 3 

RESULTS PANEL 4 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 3B 5-15% 

B 3B 5-15% 

C 3B 5-15% 

D 3B 5-15% 

TABLE 4 

RESULTS PANEL 5 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 3B 5-15% 

B 3B 5-15% 

C 3B 5-15% 

D 3B 5-15% 
TABLE 5 

RESULTS PANEL 9 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 3B 5-15% 

B 3B 5-15% 

C 3B 5-15% 

D 3B 5-15% 

TABLE 6 

RESULTS PANEL 10 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 3B 5-15% 

B 3B 5-15% 

C 3B 5-15% 

D 3B 5-15% 

V.C. BUD JENKINS 

WWW.COATINGSSCIENTIST.COM 

BS CHEMISTRY, MBA MARKETING, JD LAW 

CERTIFIED HAZARDOUS MATERIALS MANAGER 

CERTIFIED HAZARDOUS WASTE PRACTITIONER 

EXPERT WITNESS, COATINGS 

COATINGS INSTRUCTOR, CAL POLY UNIVERSITY POMONA

3366 Somis Drive, Riverside, CA 92507, email: vcbudjenkins@yahoo.com 

Phone/FAX 951-682-4023 Cell Phone: 909-260-4263 

September 17, 2009 

Subject: Cross Hatch Adhesion Test of Epoxy Gray Paint on Glass 

DECLARATION OF V.C. “BUD” JENKINS 

I, V.C. “Bud” Jenkins, declare: 

The facts set forth in this declaration are my personal knowledge and 

if called as a witness, I could competently testify to them. 

I am an instructor of Chemistry at California Polytechnic University, 

Pomona, specializing in Coatings Science (i.e., the science of paint and 

related coating products) and have held that position continuously since 

1994. At Cal Poly Pomona, I teach a 1-year course in Coatings Science, 

resulting in an industry-recognized certificate in Coatings Science. I have 

presented several technical papers at the annual Federation of Societies of 

Coatings Technology convention, including papers on coatings stability, 

color change with change of viewing angle, environmental problems in the 

coatings industry, and problems associated with paint overspray on bridges. 

In my capacity as a consultant, I have been retained and have testified as an 
expert witness in numerous civil law suits and two criminal actions 

involving coatings defects, application defects, corrosion protection, raw 

materials omissions, color matching problems, color changing problems, 

attempted murder and murder. I hold a Bachelor of Science in Chemistry 

from the University of California, Riverside, that I obtained in 1973; a 

Master of Business Administration from the University of California, 

Riverside, (1976); a Juris Doctorate from Western States University (1982), 

Certified Hazardous Materials Manager Certificate from the University of 

California, Riverside (1983); a Certified Hazardous Waste Practitioner 

Certificate from the University of California, Riverside (1985) and have 

successfully completed a coatings science course at Los Angeles City 

College as well as a Color Matching Course at Los Angeles Trade Technical 

College. I was President of the Los Angeles Society for Coatings 

Technology for two terms and have held several Chairperson positions 

during my more than 25 years with that organization, including Technology 

Committee Chair, Education Committee Chair, Publicity Committee Chair, 

Manufacturing Committee Chair, and Library Committee Chair. I have 

studied and organized nearly 100 seminars for UV Coatings, aerosol spray 

coatings, artist colors, wood coatings, and concrete coatings as well as the 

more familiar Architectural and Industrial Maintenance coatings. Among 
the industry classes I have attended are courses on polymers, crosslink 

density, waterborne formulation, inks, sealants, caulking, instrumental 

analysis, and furniture finishes. I presently sit as the only coating scientist 

on a committee of the Getty Museum to research ways to restore and protect 

murals all over the world. In addition, I have more than 40 years of 

experience in the paint and coatings industry, having worked as a painter for 

a paint crew, as the Operations Manager for a medium sized paint company 

and as a paint lab technician and lab manager for three large paint 

companies. Besides that, as a full time consultant, I have developed many 

coatings for coating companies and have resolved coating disputes in the 

field. 

On September 16, 2009, a box containing 5 glass coated panels was received 

from Mr. Don Hopps of the South Coast Air Quality Management District. 

They were wrapped in tissue paper and encased in a wooden box. It 

remained in my control in my lab at Cal Poly Pomona and in my car until 

testing time on September 17, 2009. 

On September 17, 2009, it was carefully opened and the 5 panels were laid 

on a sturdy table, painted side up. The panels were marked panel 1, 2, 3, 4 

and 5 with the September 17, 2009 date written on them. Each panel was 
marked in quadrants marked A, B, C, and D. Testing was done in each 

quadrant. 

A Gardco PA-2000 kit with a PA-2054 1.5mm blade was used to make 

11x11 cuts in the film in accordance with ASTM D-3369 Standard Test 

Method for Measuring Adhesion by Tape Test. 

A straight edge was used to make sure the cuts were straight and at right 

angles to each other. A soft brush was used to remove any debris caused by 

the cutting. Two windings of Permacel tape were removed and discarded 

prior to using the tape for adhesion testing. The tape was smoothed onto the 

surface over the crosshatch area and pressed into place with a pencil eraser 

and allowed to set for 90 seconds. The tape was pulled rapidly (less than 

one second without jerking) at 180 degrees. The amount of paint removal 

was compared with the standard chart supplied with the ASTM test. 

RESULTS 

PANEL 1 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE 

D 5B 0% NONE 
PANEL 2 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE 

D 5B 0% NONE 

PANEL 3 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE 

D 5B 0% NONE 

PANEL 4 

QUADRANT CLASSIFICATION PERCENT AREA REMOVED 

A 5B 0% NONE 

B 5B 0% NONE 

C 5B 0% NONE