Automotive Coatings Suggested Control Measure 

STAFF REPORT 

FOR THE 

PROPOSED SUGGESTED CONTROL MEASURE 

FOR AUTOMOTIVE COATINGS 

Stationary Source Division 

Measures Assessment Branch 

October 2005 
Automotive Coatings Suggested Control Measure 

State of California 

AIR RESOURCES BOARD 

STAFF REPORT 

FOR THE 

PROPOSED SUGGESTED CONTROL MEASURE 

FOR AUTOMOTIVE COATINGS 

To be considered by the Air Resources Board on October 20 and 21, 2005, at: 

California Environmental Protection Agency 

Headquarters Building 

1001 “I” Street 

Sacramento, California 

Stationary Source Division: 

Robert Fletcher, Chief 

Robert D. Barham, Assistant Chief 

Measures Assessment Branch: 

Barbara Fry, Chief 

Technical Development Section: 

Jose Gomez, Manager 

This report has been prepared by the staff of the Air Resources Board. Publication does not 

signify that the contents reflect the views and policies of the Air Resources Board, nor does 

mention of trade names or commercial products constitute endorsement or recommendation for 

use. 
Automotive Coatings Suggested Control Measure 

State of California 

AIR RESOURCES BOARD 

STAFF REPORT 

FOR THE 

PROPOSED SUGGESTED CONTROL MEASURE 

FOR AUTOMOTIVE COATINGS 

Contributing Authors

David Mehl (Lead) 

Nancy Adams 

Christian Hurley 

Marcia Jorgensen 

Reza Mahdavi, Ph.D. 

Gary Mouradian 

Lynna Negri 

Legal Counsel

Diane Kiyota, Esq., Office of Legal Affairs 

Robert Jenne, Esq., Office of Legal Affairs 
Automotive Coatings Suggested Control Measure 

Acknowledgements

We wish to acknowledge the participation and assistance of air pollution control and air 

quality management districts. In particular, we would like to thank the following district 

representatives that participated in the ARB/District Working Group: 

Dan Belik, Bay Area Air Quality Management District

Victor Douglas, Bay Area Air Quality Management District 

Bob McLaughlin, Butte County Air Quality Management District 

Dave Valler, Feather River Air Quality Management District 

Kevin Williams, Sacramento Metropolitan Air Quality Management District 

Steven Moore, San Diego County Air Pollution Control District 

Esteban Gutierrez, San Joaquin Valley Air Pollution Control District 

Scarlett Noguera, San Joaquin Valley Air Pollution Control District 

Laki T. Tisopulos, South Coast Air Quality Management District 

Larry Bowen, South Coast Air Quality Management District 

Ed Muehlbacher, South Coast Air Quality Management District 

Ricardo Rivera, South Coast Air Quality Management District 

Stan Cowen, Ventura County Air Pollution Control District 

Keith Duval, Ventura, San Joaquin Valley Air Pollution Control District 

Rebecca Geyer, Yolo Solano Air Quality Management District 

Francisco Donez, U.S. EPA Region IX 

We would also like to acknowledge the participation and assistance of:

Akzo Nobel 

BASF 

Bondo 

Cumberland 

DuPont 

Earl Scheib 

Ellis Paint 

Fibre Glass - Evercoat 

Hentzen 

Jones-Blair 

Magni 

Montana Products 

PPG 

Sherwin Williams 

Spies Hecker 

Standox 

Valspar 

 
Automotive Coatings Suggested Control Measure 

i 

TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY ES-1

 

I. BACKGROUND 

A. Overview I-1

B. Automotive Coatings Manufacturers I-2

C. Automotive Refinishing Facilities I-3

D. Regulatory Authority I-4

 1. District Rules in California I-4

 2. The National Automotive Coatings Rule I-6

 3. California Clean Air Act I-7

 

II. DEVELOPMENT PROCESS FOR SUGGESTED CONTROL MEASURE 

A. Automotive Coatings 2002 Survey II-1

B. Districts and U.S. EPA II-1

C. Public Process II-2

D. Evaluation of the District Rules and National Rule II-3

E. Technology Assessment II-3

F. Cost Analysis II-4

 

III. PROPOSED SUGGESTED CONTROL MEASURE 

A. Applicability III-1

B. Definitions III-1

C. Standards III-1

D. Administrative Requirements III-3

E. Test Methods III-4

IV. DESCRIPTION AND TECHNICAL ASSESSMENT OF THE COATING 

CATEGORIES AND SOLVENTS 

A. Introduction IV-1

B. Categories that are in the SCM IV-4

 1. Adhesion Promoter IV-4

 2. Clear Coating IV-6

 3. Color Coating IV-7

 4. Multi-Color Coating IV-8

 5. Pretreatment Coating IV-8

 6. Primer IV-10

 7. Single-Stage Coating IV-12

 8. Temporary Protective Coating IV-13

 9. Truck Bed Liner Coating IV-13

 10. Underbody Coating IV-14

 11. Uniform Finish Coating IV-14

 12. Any Other Coating Type IV-15

C. Solvents IV-17

 
Automotive Coatings Suggested Control Measure 

ii 

TABLE OF CONTENTS

PAGE

V. AMBIENT AIR QUALITY AND EMISSIONS 

A. Ambient Air Quality and the Need for Emission Reductions V-1

 1. Ozone V-1

 2. Fine Particulate Matter V-3

B. Estimated Emissions from Automotive Coatings V-9

 

VI. ENVIRONMENTAL IMPACTS 

A. Analysis of Reasonably Foreseeable Environmental Impacts of the Methods of 

Compliance 

VI-1

 1. Potential Wastewater Impacts VI-1

 2. Air Quality Impacts VI-2

 3. Potential Hazardous Waste Impacts VI-6

 4. Reasonably Foreseeable Feasible Mitigation Measures VI-7

 5. Alternatives to the Proposed SCM VI-8

B. Community Health and Environmental Justice VI-8

 

VII. ECONOMIC IMPACTS 

A. Introduction VII-1

 1. Summary of Economic Impact VII-1

 2. General Approach for Cost Estimation VII-2

 3. Sources and Treatment of Cost Data VII-3

B. Annual Costs and the Cost-Effectiveness (C.E.) of the Proposed SCM VII-4

 1. Introduction VII-4

 2. Methodology VII-4

 3. Assumptions VII-5

 4. Results VII-6

C. Economic Impacts on California Businesses VII-7

 1. Legal Requirements VII-7

 2. Potential Impact on California Businesses VII-7

 3. Affected Businesses VII-7

 4. Potential Impact on Employment VII-10

 5. Potential Impact on Business Creation, Elimination, or Expansion VII-10

 6. Potential Impact on Business Competitiveness VII-10

D. Potential Impacts on California State or Local Agencies VII-11

E. Potential Impacts on California Consumers VII-11

 
Automotive Coatings Suggested Control Measure 

iii 

APPENDICES

A: Proposed Suggested Control Measure for Automotive Coatings A-1

B: 2002 Automotive Coatings Survey B-1

C: Summary of Cost Analysis Methodology C-1

D: Categories that are not in the SCM D-1

 

TABLES 

ES-1 Proposed Coating Categories and VOC Limits ES-3

ES-2 Districts with Automotive Coatings Rules ES-6

ES-3 Chronology of the Automotive Coatings SCM Development ES-6

ES-4 Estimated Emission Reductions from Automotive Coatings ES-10

I-1 Top Seven Coatings Manufacturers I-2

I-2 Chronology of Development of Coating Technologies I-3

I-3 Distribution of Automotive Refinishing Facilities Grouped by Total Annual 

Revenue in 2002 

I-4

I-4 Estimated Number of Automotive Refinishing Facilities by District I-4

I-5 Existing District Rules I-5

I-6 Summary of VOC Limits I-6

II-1 List of Public Workshops and Meetings II-2

III-1 Proposed Coating Categories and VOC Limits III-2

IV-1 Compliance Summary IV-2

IV-2 Comparison of Coating Categories IV-3

IV-3 Basic Physical Parameters IV-15

IV-4 Technical Feasibility IV-16

V-1 Ambient Air Quality Standards for Ozone, PM10 and PM2.5 V-4

V-2 Summary of the 2002 Automotive Coatings Survey V-9

V-3 Estimated Emissions and Emission Reductions from Automotive Coatings V-10

VII-1 Changes in Return on Owner’s Equity (ROE) for Typical Businesses in the 

Automotive Refinishing Industry 

VII-9

FIGURES

V-1 Population-Weighted Exposure to Ozone Concentrations Above the State 

Ambient Air Quality Standard 

V-2

V-2 2004 Area Designations for State Ambient Air Quality Standards-Ozone V-6

V-3 2004 Area Designations for State Ambient Air Quality Standards – PM10 V-7

V-4 2004 Area Designations for State Ambient Air Quality Standards – PM2.5 V-8
Automotive Coatings Suggested Control Measure 

iv 

ACRONYMS

2002 Survey 2002 Automotive Refinish Survey 

APA Administrative Procedure Act 

AQMP Air Quality Management Plan 

ARB/Board Air Resources Board 

ATCM Airborne Toxic Control Measure 

BAAQMD Bay Area Air Quality Management District 

Cal/OSHA California Department of Industrial Relations, Division of Occupational 

Safety and Health Administration 

CAPCOA California Air Pollution Control Officers’ Association 

CCAA California Clean Air Act 

CCR California Code of Regulations 

C.E. Control Efficiency 

CESQG Conditionally Exempt Small Quantity Generators 

CEQA California Environmental Quality Act 

CFR Code of Federal Regulations 

CRF Capital Recovery Factor 

district Air Pollution Control or Air Quality Management District 

DTSC Department of Toxic Substances Control 

EU European Union 

FCAA Federal Clean Air Act 

g/l Grams Per Liter 

HAP Hazardous Air Pollutant 

HEPA High Efficiency Particulate Abatement 

HRA Health Risk Assessment 

HSC Health and Safety Code 

HVLP High Volume Low Pressure 

MEK Methyl Ethyl Ketone 

NAICS North American Industry Classification System

NAP Neighborhood Assessment Program 

NIOSH National Institute for Occupational Safety and Health 

NOx Nitrogen Oxides 

OEHHA Office of Environmental Health Hazard Assessment 

OEM Original Equipment Manufacturer 

PCBTF Parachlorobenzotrifluoride 

PEL Permissible Exposure Limit 

PM Particulate Matter 

PM10 Particulate Matter with an aerodynamic diameter less than or equal to 

10 microns 

PM2.5 Particulate Matter with an aerodynamic diameter less than or equal to 

2.5 microns 

ppm parts per million 

REL Reference Exposure Level 

ROE Return On Owner’s Equity 

RTS Ready To Spray 

SCAQMD South Coast Air Quality Management District 
Automotive Coatings Suggested Control Measure 

v 

ACRONYMS

SCM Suggested Control Measure 

SIC Standard Industrial Classification 

SIP State Implementation Plan 

SJVUAPCD San Joaquin Valley Unified Air Pollution Control District 

SMAQMD Sacramento Metropolitan Air Quality Management District 

SOA Secondary organic aerosols 

SRP Scientific Review Panel 

SWA Sales-Weighted Average 

TAC Toxic Air Contaminant 

TBAC Tertiary-Butyl acetate 

TCLP Toxicity Characteristic Leaching Procedure 

TE Transfer Efficiency 

tpd tons per day 

TSP Total Suspended Particulate 

ug Microgram 

ug/m3 Micrograms per Cubic Meter 

U.S. EPA United States Environmental Protection Agency 

VOC Volatile Organic Compound 

VOCact VOC in grams per liter of coating 

VOCreg VOC in grams per liter of coating, excluding water and exempt 

compounds 
Automotive Coatings Suggested Control Measure 

ES-1

EXECUTIVE SUMMARY 

In this executive summary, we provide a summary of the information provided in the 

staff report. The executive summary is written in “question and answer” format and 

includes: 

 Background; 

 SCM development process and evaluation of alternatives; 

 Summary of the proposed Suggested Control Measure (SCM); 

 Technical analysis of coating categories in the proposed SCM; 

 Environmental Impacts; 

 Economic Impacts; and 

 Future Plans. 

I. BACKGROUND 

What are automotive coatings? 

Automotive coatings, as defined in the SCM, are coatings that are applied to motor 

vehicles and mobile equipment. Automotive coatings are sold as components that 

must be mixed to be applied. The main coating categories include primers, color 

coatings, and clear coatings. These three broad categories of coatings account for 

about 84 percent of the sales reported in 2001. The remaining sales consist of a 

variety of coatings such as pretreatment coatings or adhesion promoters intended for 

use on bare metal or plastics. Automotive coatings, as defined in this SCM, do not 

include aerosol coatings (e.g., spray paint) or original equipment manufacturer coatings. 

What are the emissions from automotive coatings? 

The annual average volatile organic compound (VOC) emissions from automotive 

coatings are estimated to be about 20.7 tons per day in California in 2001 or about two 

percent of the total stationary source VOC emissions statewide. When automotive 

coatings are applied, the solvents that hold the coatings in suspension evaporate into 

the atmosphere and contribute to VOC emissions. 

VOC emissions are precursors to the formation of ozone and particulate matter (PM), 

California’s most serious air quality problems. VOCs react photochemically with oxides 

of nitrogen (NOx) to form ozone. Ozone is a strong oxidizer that irritates the human 

respiratory system, increases airway hyperreactivity, increases airway inflammation, 

and damages plant life and property. Exposure to ozone is also associated with 

premature death, hospitalization for cardiopulmonary causes, asthma episodes and 

restrictions in physical activity. VOCs also react in the atmosphere to form PM which 

consists of very small liquid and solid particles suspended in the air. PM includes 

particles smaller than 10 microns in size (PM10), as well as the subset of fine particles 

smaller than 2.5 microns in size (PM2.5). PM10 and PM2.5 are inhaled deeply into the 

lungs and reduce human pulmonary function. Premature deaths linked to PM10 and 
Automotive Coatings Suggested Control Measure 

ES-2

PM2.5 exposure are now at levels comparable to deaths from motor vehicles and second 

hand smoke. PM10 and PM2.5 may also contain toxic compounds. In the atmosphere, 

PM10 and PM2.5 reduce visibility. 

Who is responsible for controlling VOC emissions from automotive coatings? 

Control of emissions from automotive coatings is primarily the responsibility of the local 

air pollution control and air quality management districts (districts). However, the Air 

Resources Board (ARB) provides technical support to districts through the development 

of SCMs and other similar efforts. ARB staff, in cooperation with the districts, has 

developed the proposed SCM for automotive coatings. The SCM will serve as a model 

for districts when adopting and amending their automotive coatings rules. The 

proposed SCM, in part, relies upon the efforts of the Enforcement Managers Committee 

of the California Air Pollution Control Officers’ Association. The proposed SCM reflects 

nearly four years of study of automotive coatings, and was developed in cooperation 

with the districts, the United States Environmental Protection Agency (U.S. EPA), and 

the affected industry. 

Why are we proposing the SCM? 

We are proposing the SCM to promote consistency and uniformity among district rules 

and to achieve VOC emission reductions. The proposed SCM will also improve the 

enforceability of the rules by simplifying coating categories and establishing individual 

VOC limits for color coatings and clear coatings. 

The proposed SCM will achieve significant emission reductions from this category. 

Many of the facilities that use these coatings are located in or near residential areas 

and can create disproportionate impacts to neighborhoods. Reducing emissions in 

neigborhoods is part of the ARB’s Environmental Justice Policies and Goals. The 

emission reductions achieved by the SCM will help the districts meet state 

implementation plan (SIP) and California Clean Air Act (CCAA) plan requirements. 

How are emissions from automotive coatings controlled in the SCM? 

Automotive coatings contain solvents which evaporate when they are applied. Most of 

the solvents used in automotive coatings are VOCs that contribute to California’s air 

quality problems. The SCM controls VOC emissions by establishing limits on the VOC 

content of automotive coatings. These VOC limits are expressed in grams of VOC per 

liter of coating, less water and exempt compounds, and vary with each coating 

category. In general, manufacturers will meet the VOC limits by replacing some of the 

solvents in automotive coatings with water or other exempt compounds1

, or by 

increasing the amount of solids, such as resins and pigments or a combination of these 

approaches. 

 

1

 Solvents with low photochemical reactivity 
Automotive Coatings Suggested Control Measure 

ES-3

II. SUMMARY OF PROPOSED SUGGESTED CONTROL MEASURE (SCM) 

What automotive coating categories are in the proposed SCM? 

As shown in Table ES-1 below, the proposed SCM (see Appendix A) will establish VOC 

content limits for twelve coating categories of automotive coatings. Many of these 

automotive coating categories are similar to those in existing district rules. The SCM 

would lower VOC limits for many categories but would retain some VOC limits currently 

in effect in California. 

Table ES-1 - Proposed Coating Categories and VOC Limits 

VOC regulatory limit as applied 

Effective January 1, 2009 

Coating Category grams/liter (pounds per gallon*) 

Adhesion Promoter 540 4.5 

Clear Coating 250 2.1 

Color Coating 420 3.5 

Multi-Color Coating 680 5.7 

Pretreatment Coating 660 5.5 

Primer 250 2.1 

Single-Stage Coating 340 2.8 

Temporary Protective Coating 60 0.5 

Truck Bed Liner Coating 310 2.6 

Underbody Coating 430 (3.6 

Uniform Finish Coating 540 4.5 

Any other coating type 250 2.1 

* English units are provided for information only. VOC limits are expressed in grams VOC per liter of

coating, less water and exempt compounds. 

How does the proposed SCM differ from existing district rules? 

Current district rules have two sets of VOC limits for automotive coatings. The 

automotive coatings used on passenger cars typically have higher VOC limits than the 

automotive coatings used on large vehicles such as trucks and buses (commonly 

referred to as Group I and Group II vehicles). The district rules also have composite 

VOC limits for multi-stage systems that apply to the total VOC content of the color coat 

and clear coat combined. The proposed SCM would establish a single set of VOC 

limits for all automotive coatings and would eliminate the composite VOC limits for 

multi-stage systems. The key differences between the proposed SCM and the existing 

district rules are discussed below. 
Automotive Coatings Suggested Control Measure 

ES-4

The SCM: 

 Combines the Group I and Group II vehicle categories, and establishes the same 

VOC limits for passenger vehicles, heavy-duty vehicles, and mobile equipment. 

This would improve enforcement and simplify recordkeeping; 

 Eliminates the composite VOC limit for multi-stage systems, and replaces it with 

specific VOC limits for clear coatings and color coatings. This would improve 

enforcement; 

 Simplifies and combines district coating categories reducing the total number of 

categories from thirty-four to twelve. See Table IV-3 in Chapter IV for a list of 

coating categories typically found in district rules and the corresponding category 

in the proposed SCM; 

 Eliminates the specialty coatings category and replaces it with two specific 

category limits. The survey data indicate that several coating types qualifying for 

a high VOC limit under the districts’ specialty coatings category were not sold in 

California in 2001; 

 Establishes a prohibition of possession provision, which would prohibit any 

person from having, at any automotive refinishing facility, coatings or solvents 

that do not comply with the proposed VOC limits. Only one district rule currently 

has a prohibition of possession. This would improve enforcement; 

 Establishes a 25 grams per liter VOC limit for solvents used in cleaning 

operations, including surface preparation and spray gun cleaning. This limit is 

consistent with the most stringent district VOC limit for solvents which is in the 

South Coast Air Quality Management District (SCAQMD); 

 Improves recordkeeping and labeling. The SCM sets consistent recordkeeping 

requirements for the coating end user. The SCM also establishes labeling 

requirements for coating manufacturers which would improve enforcement; and 

 Exempts tertiary butyl acetate from the VOC definition to provide compliance 

flexibility. 

A more complete discussion of the requirements of the proposed SCM can be found in 

Chapter III. The proposed regulatory language is in Appendix A. These proposed 

changes would provide statewide consistency and increase the enforceability of district 

rules. 

Are any products exempt from the SCM? 

Yes. The SCM does not apply to original equipment manufacturer (OEM) automotive 

coatings that are covered by separate district rules. The SCM also does not apply to 
Automotive Coatings Suggested Control Measure 

ES-5

aerosol consumer products and aerosol coatings. However, these products are subject 

to the ARB’s statewide consumer products and aerosol coatings regulations, 

respectively. Products manufactured for use outside of the applicable district, or for 

shipment to other manufacturers for reformulation or repackaging are also exempt. 

. 

Who would be affected by the proposed SCM? 

If adopted by the districts, the proposed SCM would apply to anyone who sells, 

supplies, offers for sale, or manufactures any automotive coatings for use within the 

applicable district, as well as any person who applies or solicits the application of any 

automotive coating within the district. The primary impact would be on manufacturers 

and users of the coatings. Manufacturers would need to reformulate some products. 

Distributors of automotive coatings would also be impacted. 

Distributors and retailers who must ensure that they are selling or supplying products 

that comply with the new VOC limits will be impacted. Because of the competitive 

nature of this industry, some distributors may incur additional costs because they elect 

to absorb some of the cost to transition automotive refinishing facilities to using lower 

VOC coatings. Suppliers of resins, solvents, and other ingredients may be impacted, 

depending on whether demand for their products changes. Although determined to be 

small, the cost to consumers for vehicle refinishing may increase for some automotive 

coatings. 

Which districts are expected to adopt the proposed SCM? 

At a minimum, we expect the 20 districts that currently have automotive coatings rules 

to amend their rules based on the SCM. These districts are listed in Table ES-2 below. 

SCAQMD is expected to be the first district to adopt the SCM. 

We have worked closely with the districts in developing the SCM. As a result, we 

encourage districts to adopt the SCM without major changes. We recognize that 

districts have the authority to include limited and specific exemptions to meet local 

needs. However, we anticipate that VOC limits, definitions, and implementation dates 

will not be changed. This will help to achieve uniformity across the State. 

Districts without specific rules for automotive coatings may want to consider adopting 

the SCM to help them achieve the State and federal ambient air quality standards. 

Districts without specific automotive coatings rules will continue to be subject to the 

VOC limits in the U.S. EPA’s National Rule. 
Automotive Coatings Suggested Control Measure 

ES-6

Table ES-2 - Districts with Automotive Coatings Rules 

Antelope Valley APCD Sacramento Metropolitan AQMD 

Bay Area AQMD San Diego County APCD 

Butte County APCD San Joaquin Valley Unified APCD 

El Dorado County APCD San Luis Obispo County APCD 

Feather River AQMD Santa Barbara County APCD 

Glenn County APCD Shasta County AQMD 

Imperial County APCD South Coast AQMD 

Kern County APCD Tehama County APCD 

Mojave Desert AQMD Ventura County APCD 

Placer County APCD Yolo-Solano County AQMD 

III. SCM DEVELOPMENT PROCESS AND EVALUATION OF ALTERNATIVES 

How did ARB staff develop the proposed automotive coatings SCM? 

The SCM was developed in cooperation with districts, the U.S. EPA, the automotive 

coatings manufacturers, the collision repair industry, and other interested parties. The 

SCM development process included the following activities: (1) a comprehensive 

survey of automotive coatings manufacturers; (2) technical analyses of all the coating 

categories proposed in the SCM; (3) meetings with districts and U.S. EPA Region IX, 

and industry representatives; (4) an evaluation of potential environmental impacts; and 

(5) an analysis of the cost impacts. ARB staff also conducted six public workshops and 

several meetings and conference calls with individual manufacturers and other 

interested parties. Table ES-3 provides a chronology of the major meetings held during 

the SCM development process. 

Table ES-3 - Chronology of the Automotive Coatings SCM Development 

Date Meeting Location 

April 6, 2005 District Working Group Sacramento 

April 27, 2005 District Working Group Sacramento 

May 26, 2005 Industry and District 

Conference Call 

Sacramento 

June 8, 2005 Industry Symposium Contra Costa College 

June 11, 2005 Industry Meeting Anaheim 

June 14, 2005 District Working Group Sacramento 

June 28, 2005 Public Workshop Diamond Bar 

June 30, 2005 Public Workshop Sacramento 

August 9, 2005 Public Workshop Fresno 

August 11, 2005 Public Workshop Oakland 

August 23, 2005 Public Workshop Diamond Bar 

October 5, 2005 Public Workshop Sacramento 
Automotive Coatings Suggested Control Measure 

ES-7

Who has participated in the process? 

The districts, the U.S. EPA, automotive coatings manufacturers and marketers, trade 

associations, and representatives of automotive refinishing facilities have been active in 

the development of the proposed SCM. 

What information was gathered in the ARB’s 2002 Automotive Coatings Survey?

The ARB’s 2002 Automotive Coatings Survey (2002 Survey) collected detailed sales 

and formulation data from 17 manufacturers that sold automotive coatings in California 

in 2001. This information was collected by coating category, and was provided either 

on a product specific basis, or for a group of products in the case of color coatings. The 

2002 Survey also requested for each product, or group of products, the complete 

formulation (the speciation of the VOC ingredients, exempt solvents, and solids). See 

Appendix B for complete details of the type of information collected as part of the 2002 

Survey. The technical information gathered in the 2002 Survey was used, along with 

other information, to develop the proposed SCM.

Did ARB staff evaluate alternatives to the proposed SCM? 

Yes. Under the California Environmental Quality Act (CEQA), project alternatives 

should be identified in the Environmental Impact Assessment. Alternatives include 

measures for attaining the objectives of the proposed project. The alternatives analysis 

provides a means for evaluating the comparative merits of each alternative. An 

alternative evaluating the merits of not having the project must also be included. The 

alternatives considered feasible are then evaluated for potential environmental impacts 

that may result from their implementation. 

The following alternatives were considered, but were rejected in favor of the proposed 

SCM: 

1) No project, assuming that the SCM will not be adopted; and 

2) Extending the effective date from January 1, 2009 to January 1, 2010; 

The no project alternative was rejected because it would not achieve emission 

reductions necessary to attain the State and federal ambient air quality standards. The 

extended effective date alternative was rejected because compliant coatings are 

currently available or will be available before the proposed effective date of 

January 1, 2009. 
Automotive Coatings Suggested Control Measure 

ES-8

How were the proposed VOC limits in the SCM established? 

Although some of the VOC limits in the proposed SCM are equivalent to those in 

SCAQMD’s Rule 1151, ARB staff performed an independent analysis of each of the 

proposed VOC limits. These analyses are included in Chapter IV of the staff report. In 

proposing each of the VOC limits, ARB staff considered: (1) the results of the ARB’s 

2002 Survey; (2) the number of complying products currently on the market; 

(3) discussions with coating manufacturers, marketers and representatives of 

automotive refinishing facilities; and (4) trade journals and other literature related to the 

product category. As mentioned previously, the proposed VOC limits are the result of 

extensive interaction with the affected coatings industry, including discussions during 

six public workshops and several meetings and conference calls. Although each of the 

proposed limits is based on factors unique to each individual coating category, the 

following guiding principles were applied: 

 Technological and commercial feasibility - assuring that reformulation 

technologies will be available by the effective date for each proposed limit, and 

that the overall performance of complying products will be similar to that of 

noncomplying products. 

 Emission reductions achieved - assuring that our overall proposal will achieve 

the maximum feasible reduction in emissions. 

 Minimize the potential for the use of Toxic Air Contaminants (TAC) - assuring 

that the proposal can be met without a significant increased use of TACs. 

IV. COMPLIANCE WITH THE SCM PROPOSAL 

How will manufacturers reformulate their products to comply with the VOC 

limits? 

Manufacturers of coatings above the proposed VOC limits will need to reformulate 

some of their products to meet the applicable VOC limits. Manufacturers have the 

flexibility to choose any formulation that meets the applicable VOC limits and the 

reformulation options vary with each coating category (see Chapter IV of the staff 

report). In general, VOC solvents will need to be reduced by increasing the amount of 

water, exempt solvents, or coating solids. In solvent-borne products, VOC solvents 

may be partially replaced with exempt solvents such as acetone, 

parachlorobenzotrifluoride (PCBTF) or tertiary butyl acetate (if districts exempt TBAC 

from their VOC definitions). These changes may also require the use of different resin 

systems. For example, a higher solids formulation may need to use a less viscous 

resin system to improve flow and leveling. Solvent-borne products may also be 

reformulated to a water-borne system. As mentioned previously, ARB staff has 

proposed VOC limits that can be met without an increase in the use of TACs. 
Automotive Coatings Suggested Control Measure 

ES-9

For the color coating category, there are water-borne coatings available that meet the 

proposed VOC limit. Water-borne color coatings have been used in Europe for about 

ten years and are being mandated there as of January 1, 2007. Manufacturers’ 

literature for water-borne color coatings indicate that they perform as well as solventborne color coatings when applied properly. 

Manufacturers have stated that additional color development is required before the 

water-borne color coatings that are currently marketed in Europe can be fully introduced 

in California. While manufacturers have indicated that most likely they will meet the 

color coating limit with water-borne coatings, they do not rule out the possibility of a 

solvent-borne reformulation option. 

Are the VOC limits proposed in the SCM technologically and commercially 

feasible? 

Yes. Most of the VOC limits in the proposed SCM are based on coating technologies 

that have been available since 2001. ARB staff analyzed our 2002 Survey data, 

consulted with coating manufacturers, evaluated coatings being used in Europe, and 

reviewed technical literature to determine appropriate VOC limits. As explained in detail 

in Chapter IV of the staff report, staff believes all of the VOC limits in the proposed 

SCM are technologically and commercially feasible by the effective date. 

Our 2002 Survey results demonstrate that for nearly all the coating categories proposed 

in the SCM, products are currently available that comply with the proposed limits. Nine 

of the twelve categories for which we are proposing VOC limits have products that 

would meet the proposed limits. The complying marketshares vary with each coating 

category; however, this is not unexpected since the current VOC requirements also vary 

throughout the State. The coating category called “any other coating type” has no 

complying products because it was established as a catch-all category for which no 

products were reported in the 2002 Survey. Only two coating categories with reported 

products, adhesion promoters and pretreatment coatings, do not currently have 

compliant products in the marketplace. However, at least one coating manufacturer 

has indicated that they will sell compliant coatings in these categories prior to the 2009 

effective date. Staff will conduct a technology assessment approximately one year prior 

to the implementation date for all the VOC limits that are more stringent than existing 

district limits. This technology review is a standard practice for identifying any 

unanticipated problems prior to implementation of the proposed VOC limits. 

Will the reformulated products perform similar to existing products? 

Yes. ARB staff concluded that the performance of the compliant products would be 

similar to the performance of their higher VOC counterparts. This conclusion is based 

on: 

1) The current availability of complying products in the marketplace; 
Automotive Coatings Suggested Control Measure 

ES-10

2) ARB staff’s analyses of each product category, as detailed in Chapter IV; and 

3) The extended use of complying products both here and in Europe in the case of 

water-borne color coatings. 

What will the automotive refinishing facilities need to do to comply with the 

proposed SCM? 

Automotive refinishing facilities will need to use compliant coatings or use control 

devices to reduce VOC emissions from their operations. Currently, only a few 

automotive refinishing facilities use control devices to reduce VOC emissions. If 

manufacturers comply with the proposed VOC limit for color coatings with water-borne 

coatings, automotive refinishing facilities may need to purchase air movement 

equipment and may need to install heaters to accelerate drying. There are several 

technology options that can be used by automotive refinishing facilities depending on 

their specific needs and their current equipment configurations. Smaller facilities may 

be able to purchase less expensive air movement equipment and may not need to 

install heaters because they have a lower volume of production. Chapter VII and 

Appendix C present our analysis of the costs automotive refinishing facilities may incur 

to comply with the proposed SCM. 

What are the emission reduction benefits from the automotive coatings SCM 

proposal? 

The total emission reduction from statewide implementation of the proposed VOC limits 

is estimated to be about 13.4 tons per day (tpd) in California. This reduction equates to 

about a 63 percent reduction in the total VOC emissions from the coating categories in 

the SCM. 

Table ES-4 shows the estimated emission reductions by coating category. 

Table ES-4 - Estimated Emission Reductions from Automotive Coatings 

Coating Category Emission Reduction (tpd) 

adhesion promoter .02 

Clear coating 1.61 

Color coating 8.78 

Multi-color coating N/A 

Pretreatment coating .21 

Primer 1.01 

Single-stage coating 1.68 

temporary protective coating <.01 

Truck bed liner coating <.01 

underbody coating <.01 

uniform finish coating .05 

any other coating type N/A 

Total 13.4 
Automotive Coatings Suggested Control Measure 

ES-11

V. ENVIRONMENTAL IMPACTS 

Both CEQA and ARB policies require the ARB to evaluate the potential adverse 

environmental impacts of proposed projects. The ARB is authorized to prepare a plan 

or other written document (such as an environmental analysis chapter in the staff 

report) in lieu of an environmental impact report. Chapter VI presents a detailed 

analysis of the environmental impacts of the proposed SCM. 

What are the expected environmental benefits of the automotive coatings SCM? 

The primary environmental benefit of the SCM will be a reduction in the formation of 

tropospheric (ground level) ozone, PM10 and PM2.5 . It has long been known that 

exposure to ground level ozone, PM10 and PM2.5 have adverse impacts on public health. 

Research has shown that, when inhaled, ozone, PM10 and PM2.5 can cause respiratory 

problems, aggravate asthma, and impair the immune system. 

In the presence of sunlight, the VOCs from automotive coatings and other sources 

react with oxides of nitrogen (NOx) to form ozone. In addition, VOCs have been found

to be a source of PM10 and PM2.5, either through condensation of the VOCs or complex 

reactions of VOCs with other compounds in the atmosphere. Therefore, districts that 

adopt the SCM will reduce their VOC emissions and experience a positive impact on air 

quality and public health. The exact reductions in ozone, PM10 and PM2.5 cannot be 

accurately predicted due to the wide variety of factors that impact the formation of 

ozone, PM10 and PM2.5. These factors include atmospheric conditions, the ratio of 

VOCs to NOx in the atmosphere, and the reactivity (ozone formation potential) of the 

individual VOCs emitted. However, numerous scientific studies have shown that by 

reducing VOC emissions, ozone, PM10 and PM2.5 concentrations are reduced. 

Therefore, by reducing ozone and PM concentrations, this SCM would reduce the 

health risks posed by exposure to these pollutants.

Additionally, automotive coatings contain several known TACs such as toluene, 

xylenes, and methyl ethyl ketone (MEK). To the extent these are reduced by the 

reformulation to lower VOC coatings, there would be a decrease in TAC emissions. 

Currently, these compounds account for over 27 percent of the VOC emissions. If 

districts exempt TBAC from their VOC definitions, it may be used as a substitute for 

toluene, xylenes and MEK, which would decrease the use of these TACs. The extent of 

TBAC substitution could vary by coating category, however, it is believed that as much 

as 50 percent of the toluene, xylenes, and MEK could be replaced with TBAC. 

Because many automotive refinishing facilities are located in or near low-income 

residential areas, decreasing TAC emissions from automotive coatings would benefit 

environmental justice communities. 
Automotive Coatings Suggested Control Measure 

ES-12

Are there any potential significant adverse environmental impacts?

No. In Chapter VI, we examined the potential effect of the proposed SCM on air 

quality, water demand, water quality, public services (public facility maintenance, fire 

protection), transportation and circulation, solid waste/hazardous waste, and hazards to 

the public or the environment. Based on our analysis, we do not expect any significant 

adverse environmental impacts to result from the implementation of the proposed SCM. 

There is a slight potential for an adverse environmental impact if districts exempt TBAC 

from their VOC definitions. The Office of Environmental Health Hazard Assessment 

has determined that TBAC is a potential carcinogen because it metabolizes to tertiary 

butyl alcohol. Assuming under a worst-case scenario that TBAC is substituted for 

50 percent of the toluene, xylenes, and MEK in automotive coatings, the maximum 

potential cancer risk is estimated to be 2.8 excess lifetime cancer cases per million for a 

resident living near the largest known auto body shop (1,100 gallons per year). 

However, if the VOC limit for color coatings is met with water-borne coatings, the 

maximum potential cancer risk would be reduced to about 1.4 excess lifetime cancer 

cases per million. 

VI. ECONOMIC IMPACTS 

How did ARB staff evaluate the potential economic impacts of the proposed 

SCM? 

ARB staff evaluated the economic impacts of the proposed SCM by: 1) contacting 

coating manufacturers; 2) comparing the ingredient costs of typical low VOC 

formulations with higher VOC formulations; and 3) contacting spray booth equipment 

and air movement equipment manufacturers. The analysis assumes that all districts 

adopt the proposed SCM, including areas that are now subject to the U.S. EPA 

National Rule. As detailed below, this information was used to perform a business 

impacts analysis and a cost-effectiveness analysis for the SCM. 

How was the business impacts analysis conducted and what are the results? 

In our economic impact analysis, we evaluated the potential impact of the proposed 

VOC limits on profitability and other aspects of businesses subject to the limits. To 

conduct our analysis, we relied on information provided by coating manufacturers, 

ingredient costs for typical complying and noncomplying formulations, and information 

from manufacturers of spray equipment and air movement equipment. We then 

evaluated the impact of these costs on typical businesses using a combination of 

publicly available financial databases (Dun and Bradstreet and Ward’s Business 

Directory of United States Manufacturing Industries), industry journals/literature such as 

the Chemical Market Reporter, and discussions with industry representatives. 
Automotive Coatings Suggested Control Measure 

ES-13

We utilized the change in “return-on-owner’s equity” (ROE) as an indicator of the SCM’s 

potential impacts on business profitability. The cost to comply with the proposed SCM, 

through increased research and development, equipment purchases, and increased 

ingredients costs is presumed to impact a business’ ROE and therefore its profitability. 

Our analysis indicates that the total annualized cost to comply with the proposed SCM 

is about $14 million. The average annual cost to automotive coating manufacturers is 

estimated to be about $320,000. This results in an average estimated change in ROE 

of 0.07 percent. The average annual cost to automotive refinishing facilities is 

estimated to be about $3,400 resulting in an average change in ROE of 15 percent. 

This cost estimate assumes that coating manufacturers pass on all of their costs to the 

automotive refinishing facilities. The estimated change in ROE for automotive 

refinishing facilities would be significant if the costs are not passed on to the 

consumers. 

Our ROE analysis for the proposed SCM may overestimate the impact on businesses 

because it assumes that all of the costs of the proposed SCM will either be absorbed by 

the coating manufacturers or the automotive refinishing facilities. In reality, we expect 

that at least some of the investment costs to comply with the proposed VOC limits will 

be passed on to consumers. For example, an automotive refinishing facility could pass 

their entire costs on to consumers by adding $11 to an average repair cost. Adding $11 

to an average repair cost would increase the repair cost by only 0.5 percent. The 

analysis also does not quantify the extent of cost mitigation due to “technology-transfer” 

between product lines. 

While we expect that most businesses will be able to absorb the costs of the proposed 

limits without significant adverse impacts on their profitability, there is the possibility that 

some individual businesses will be adversely affected when districts adopt the proposed 

SCM. Therefore, it is possible that the proposed SCM may have a significant adverse 

impact on some businesses that are not in a market position to invest monies to 

develop new low VOC products, or to absorb the increased cost resulting from their 

compliance with the proposed SCM. 

Based on our analysis, we do not expect the proposed limits in the SCM to have a 

significant impact on employment, or business creation, elimination, or expansion. We 

also do not expect the proposed SCM to have a significant impact on the 

competitiveness of California businesses compared with those outside of California. 

This is because all companies that sell these products in the State would have to meet 

the proposed requirements, whether located in or outside of California. 

The VOC limits in the proposed SCM will primarily impact automotive coatings 

manufacturers and automotive refinishing facilities that use those coatings. However, 

we recognize that other industries could also be impacted to a lesser amount, which is 

difficult to quantify. These industries include distributors, retailers, and “upstream” 

suppliers who supply solvents and other chemicals used in automotive coatings. 
Automotive Coatings Suggested Control Measure 

ES-14

Distributors and retailers could be impacted because they need to ensure that 

noncomplying products are not sold after the implementation date. In addition, the 

current market dynamics are such that often distributors or manufacturers provide 

incentives to customers in order to obtain and maintain accounts. While this is the cost 

of doing business, the changes may require some new equipment that distributors 

would likely be expected to provide. However, we are unable to quantify the magnitude 

of such costs because industry wide data are not available nor are the incentives 

consistent across the industry. 

Upstream suppliers could be impacted because manufacturers will be purchasing some 

different solvents and other materials for their reformulated products. However, we do 

not expect these changes to result in a major impact on the affected industries because 

chemical companies generally supply many different industries, and because many of 

the upstream suppliers also provide the alternative products which will be used in the 

reformulated products. In fact, we expect some upstream suppliers will benefit since 

the proposed limits are likely to create new or increased demand for materials to be 

used in compliant formulations. 

Will the proposed SCM be cost-effective?

Yes. Cost-effectiveness is one measure of the SCM’s efficiency in reducing a given 

amount of pollutant (often reported in “dollars (to be) spent per pound of VOC 

reduced”). The methodology used to determine cost-effectiveness is well established 

and often used to compare a proposed regulation’s cost-efficiency with those of other 

regulations. To calculate the cost-effectiveness of the SCM, we divided the estimated 

total annual cost to manufacturers and automotive refinishing facilities by the total 

emission reduction. To conduct our analysis, we relied on specific formulation data 

from the 2002 Survey, industry journals/literature such as the Chemical Market 

Reporter for ingredient unit prices, and discussions with industry representatives. We 

estimate the cost-effectiveness weighted by emissions reductions across all the 

proposed limits to be about $1.43 per pound of VOC reduced. This estimated costeffectiveness value is within the typical range of costs of existing ARB control measures 

and district rules. 

Will automotive refinishing facilities have to pay more for automotive 

coatings subject to the proposed SCM?

Yes. Automotive refinishing facilities may have to pay more for some products subject 

to the automotive coatings SCM, depending on the extent to which manufacturers are 

able to pass along their costs to automotive refinishing facilities. While the raw material 

costs for compliant coatings is comparable or, in some cases, less costly than that of 

higher VOC coatings, typically there is a premium charged by paint manufacturers for 

new coatings. It is not possible to quantify the potential price increase per gallon of 

coating because most manufacturers did not provide cost data as part of the survey. 
Automotive Coatings Suggested Control Measure 

ES-15

Will consumers have to pay more for automotive repairs? 

Yes. As discussed in Chapter VII of the staff report, assuming that all the costs of the 

proposed SCM are passed along to the consumers who need automotive repairs, the 

average cost of a repair would increase by about $11. The average repair cost is 

estimated to be about $2,200. 

VII. FUTURE PLANS

What happens if the Board approves the proposed SCM? 

If the Board approves the proposed SCM, staff will assist the districts, if requested, as 

they embark in their own rulemakings to incorporate the SCM into their local rules. 

Will ARB staff track industry’s progress toward meeting the proposed VOC 

limits? 

Yes. Staff plans to conduct technology assessments for all of the proposed VOC limits 

that are more stringent than existing district limits at least one year prior to the 2009 

effective date. We believe that the proposed limits are feasible based on all the 

evidence available to us. However, it is standard practice for the ARB to conduct these 

reviews to ensure that unanticipated problems do not arise. 

VIII. RECOMMENDATION 

Staff recommends that the Board approve the proposed SCM and direct staff to 

transmit the SCM to the districts for consideration. 

 
Automotive Coatings Suggested Control Measure 

I-1

I. BACKGROUND 

In this staff report, we present the results of an evaluation of automotive coatings which 

led to our proposal for a Suggested Control Measure (SCM). The assessment included: 

a survey of automotive coatings sold in California in 2001; an examination of several 

compliance flexibility options; technical assessments for the various coating categories; 

an environmental impact assessment; and a cost impact analysis. The proposed SCM 

for automotive coatings is the first collaborative regulatory effort undertaken by the Air 

Resources Board (ARB/Board) staff, the air pollution control or air quality management 

districts (districts), and affected industry representatives for this coating category. The 

development of the SCM was the direct result of a request from the districts for ARB to 

provide technical assistance to improve the consistency and enforceability of existing 

rules. 

A. OVERVIEW 

Automotive coatings are coatings used, or recommended for use, in motor vehicles or 

mobile equipment refinishing, repair, or restoration. Typical automotive coatings include 

primers, color coatings and clear coatings. These coatings are used for refinishing 

vehicles such as: automobiles, trucks, buses, golf carts, vans, motorcycles, tanks, 

armored personnel carriers, trains, railcars, truck trailers, mobile cranes, bulldozers and 

street cleaners. The estimated volatile organic compound (VOC) emissions from 

automotive coatings in California were about 20.7 tons per day (tpd), on an annual 

average basis, in 2001. This represents about two percent of the total stationary source 

VOC emissions. 

VOCs are precursors to the formation of ozone and particulate matter (PM). Ozone and 

PM are two of the most serious air pollutants for which the State and national ambient 

air quality standards are exceeded in much of California. Ozone is formed from 

photochemical reaction of oxides of nitrogen and VOCs. Scientific studies show that 

exposure to ozone can result in reduced lung function, increased respiratory symptoms, 

increased airway hyperreactivity, and increased airway inflammation. Exposure to 

ozone is also associated with premature death, hospitalization for cardiopulmonary 

causes, asthma episodes and restrictions in physical activity. Ozone is a strong 

oxidizer and exposure to levels of ozone exceeding the current ambient air quality 

standards lead to a variety of adverse health effects, as well as a reduction of crop and 

timber production, and damage to plants and property. Emissions of VOCs also react in 

the atmosphere to form PM10 and PM2.5. Inhalation of PM10 and PM2.5 deep into the 

lungs reduces human pulmonary function. Premature deaths linked to PM10 and PM2.5 

exposure are now at levels comparable to deaths from motor vehicle accidents and 

second-hand smoke. Attaining the current State ambient air quality standards for PM10

and ozone would annually prevent approximately 6,500 premature deaths or three 

percent of all deaths in California. (ARB, 2002) 
Automotive Coatings Suggested Control Measure 

I-2

B. AUTOMOTIVE COATINGS MANUFACTURERS 

The automotive coatings market in California was estimated at approximately 

3.7 million gallons in 2001. Approximately 95 percent of the total sales for 2001 were 

supplied by seven manufacturers. Table I-1 lists the top seven manufacturers based on 

data reported in the 2002 Survey (ARB, 2005). 

Automotive coatings are normally supplied to automotive refinishing facilities through a 

network of distributors (jobbers). The distributors are generally independent businesses 

or may be owned by the coating manufacturer (e.g., Sherwin Williams). Most 

distributors sell coatings locally or regionally. 

Table I-1 - Top Seven Coatings Manufacturers 

Company Scope 

Akzo Nobel Global 

BASF Global 

DuPont Global 

Ellis Paint California 

PPG Global 

Sherwin Williams Global 

Standox/Spies Hecker Global 

Automotive coatings are formulated using solids and liquids. The solids consist of three 

main categories: (1) resins (polymers or binders) bind the pigments and additives 

together and form a film upon drying. Sometimes co-polymers are used to modify the 

properties of the primary resin. Some resins used in automotive coatings include 

alkyds, latex, oils, vinyl, acrylics, celluloses, epoxies, urethanes, and polyurethanes; 

(2) pigments are finely ground powders dispersed in the coating; pigments provide 

color, hide the underlying surface, and contribute other properties; and (3) additives or 

specialty chemicals which assist in manufacture and application, may improve the 

properties of the finished film. Examples of additives include preservatives, wetting 

agents, coalescing agents, freeze-thaw stabilizers, anti-foam agents, and thickeners. 

Liquids are usually solvents, which are the volatile carriers used to control the viscosity 

of the coating and provide application properties. Some typical solvents used are: 

aromatic or aliphatic hydrocarbons, ketones, esters, alcohols, glycols, glycol ethers, and 

water. 

Most automotive coatings are sold as components with a few available for use in readyto-use containers. The coating components are mixed in the automotive refinishing 

facility, as needed, by the painter, prior to use. Mixing ratios of components can vary 

depending on temperature and other factors. Generally, to make the coating ready to 

spray, the process requires combining the base product with a VOC solvent, water, or 

an exempt solvent depending upon the manufacturer’s specifications for reaching the 

correct viscosity for spraying application. Colors normally require inter-mixing various 

toners in order to achieve the desired color. 
Automotive Coatings Suggested Control Measure 

I-3

Table I-2 is a chronology of the development of automotive coatings technologies 

(Entec, 2000). Most automotive refinishing facilities have a “mixing bank”, and may use 

an automatic mixing machine to insure precise color formulations. Small operations use 

ready-to-spray (RTS) coatings or will acquire the mixed coatings from a supplier or 

jobber. 

Table I-2 - Chronology of Development of Coating Technologies

Date Coating Technology 

1920s Nitrocellulose Resins 

1950s Alkyd Resins 

1960s Thermoplastic Acrylic Resins 

1970s 2 Component Polyurethane-Acrylic Resins 

1990s High Solids Urethanes 

 

C. AUTOMOTIVE REFINISHING FACILITIES 

Automotive coatings operations are conducted at automotive refinishing facilities which 

include auto body repair/paint shops, production auto body paint shops, new car dealer 

repair/paint shops, fleet operator repair/paint shops and custom restoration facilities. 

Some of these facilities do collision repair and some do commercial vehicle refinish and 

repair. While we do not have a specific breakdown of facilities doing commercial (fleet) 

vehicle refinish only, we expect this group to be relatively small. Most of the facilities 

perform collision repair and refinishing for the passenger car segment with some 

performing mostly complete paint jobs (i.e., facilities such as MAACO and Earl Scheib). 

The total number of facilities involved in the repair and refinishing of vehicles is 

estimated to range from about 4,000 to over 6,000. (DuPont, 2005; DCA, 2005). Many 

of these operations do not have a district permit because they use relatively small 

volumes of coatings. Some districts do not require a permit if a facility uses less than a 

specified volume of coatings and cleaning solvents, typically one gallon per day. 

However, most districts require a permit if a facility has a spray booth, regardless of the 

volume of coatings and cleaning solvents used. 

The majority of automotive refinishing facilities are small businesses typically having 

from one to five employees. Table I-3 lists the number of facilities based on gross 

annual revenue. Over 70 percent of automotive refinishing facilities are estimated to 

have one million dollars or less in annual revenue (DuPont, 2005). Some of these 

facilities may be doing body repair work without painting the vehicle. We are aware that 

some facilities subcontract the painting portion of the repair job. However, we are 

unable to quantify the number of facilities involved only in body repair. 
Automotive Coatings Suggested Control Measure 

I-4

Table I-3 - Distribution of Automotive Refinishing Facilities Grouped by Total 

Annual Revenue in 2002 

Total Annual Revenue Number of Facilities Percent of Total

Less than $0.5 Million 2,074 50.4

$0.5 to $1 Million 878 21.3

>$1 to $2.5 Million 883 21.5

> $2.5 Million 278 6.8

Total Statewide 4,113 100

The automotive refinishing facilities vary greatly in size and level of sophistication. 

Some automotive refinishing facilities are medium to large, well run, relatively 

automated facilities while others are family-run shops, which may have one or two 

employees. Table I-4 shows the estimated number of automotive refinishing facilities in 

the larger districts. (DuPont, 2005) 

Table I-4 - Estimated Number of Automotive Refinishing Facilities by District 

District Number of 

Facilities 

South Coast Air Quality Management District (SCAQMD) 1,790 

Bay Area Air Quality Management District (BAAQMD) 934 

San Joaquin Valley Air Pollution Control District (SJUVAPCD) 330 

Sacramento Metropolitan Air Quality Management District (SMAQMD) 171 

Other Districts 888 

Total Statewide 4,113 

D. REGULATORY AUTHORITY 

In California, the districts have primary responsibility for controlling emissions from 

automotive refinishing facilities. In 1988, the districts began to develop regulations for 

automotive coatings and refinishing operations. 

1. District Rules in California 

Typically, the districts develop regulations that define coating categories and set VOC 

limits that affect manufacturers, suppliers, and users of automotive coatings. The rules 

establish VOC content limits to achieve the maximum feasible emission reductions. 

Coatings that are high in VOCs are either replaced with an existing low-VOC coating, or 

are reformulated to meet the VOC limits established in the rules. 

The ARB has authority to oversee the districts’ activities. In consultation with the 

districts, the affected industry and the U.S. EPA, ARB staff developed the proposed 

SCM. The SCM will be used as a model by the districts when adopting or amending 

their automotive coatings rules. The SCM will provide uniformity and enhance 

enforcement of district rules. In Chapter III, we provide a detailed description of the 

proposed SCM. 
Automotive Coatings Suggested Control Measure 

I-5

Twenty of the 35 districts in California have rules regarding automotive coatings. 

Currently, approximately 95 percent of the State’s population is covered by the existing 

district rules. Most of the rules have been included in the State’s Implementation Plan 

(SIP). Table I-5 lists the districts’ rules for this category. 

Table I-5 - Existing District Rules

District Rule Number Adopted Last Amended

Antelope Valley APCD 1151 7-8-88 7-20-99

Bay Area AQMD 8-45 6-7-89 7-1-99

Butte County APCD 235 6-19-97 8-22-02

El Dorado County APCD 230 9-27-94

Feather River AQMD 3-19 8-6-98

Glenn County APCD V-105 5-19-99

Imperial County APCD 427 9-14-99

Kern County APCD 410-4A 5-16-91 3-7-96

Mojave Desert AQMD 1116 3-2-92 4-12-99

Placer County APCD 234 11-3-94 4-9-98

Sacramento Metropolitan AQMD 459 12-7-95 10-2-97

San Diego County APCD 67-20 11-13-96 8-13-97

San Joaquin Valley APCD 4602 4-11-91 12-20-01

San Luis Obispo County APCD 423 2-23-88 11-13-02

Santa Barbara County APCD 339 8-13-97 4-17-19

Shasta County AQMD 3-25 4-1-97

South Coast AQMD 1151 7-8-88 12-11-98

Tehama County APCD 4-35 11-10-98

Ventura County APCD 74-18 1-28-92 9-10-96

Yolo-Solano County AQMD 2-26 8-13-97

Although there are some similarities in the district rules, the rules vary from district to 

district. Some of the differences include: definitions of terms, coating categories, VOC 

limits, exemptions allowed, and recordkeeping requirements. Table I-6 summarizes the 

key VOC limits from four district rules. 
Automotive Coatings Suggested Control Measure 

I-6

Table I-6 – Summary of VOC Limits 

SCAQMD 

Rule 1151 

SJUVAPCD 

Rule 4602 

SMAQMD 

Rule 459 

BAAQMD 

Rule 8-45 

Cars* Large** 

Vehicles 

Cars Large 

Vehicles 

Cars Large 

Vehicles 

Cars Large 

Vehicles 

Category g/l g/l g/l g/l g/l g/l g/l g/l 

Pretreatment 

Wash Primer 

780 780 780 780 780 780 780 780 

Precoat N/A N/A 600 600 600 600 580 580 

Primer/Primer 

Surfacer 

250 250 250 250 250 250 250 250 

Primer Sealer 340 250 420 340 420 250 420 340 

Topcoat 420 340 420 420 420 420 420 420 

Metallic 

Iridescent 

Topcoat 

420 340 520 420 520 420 520 420 

Multi-stage 

Topcoat 

420 340 540 N/A 540 N/A 540 N/A 

Specialty 

Coating 

840 840 840 840 840 840 840 840 

Camouflage N/A N/A N/A 420 N/A 420 N/A 420 

Multi-Colored 685 685 N/A N/A N/A N/A N/A N/A 

MultiColored 

Multistage 

420 N/A N/A N/A N/A N/A N/A N/A 

Rubberized 

Asphaltic 

Underbody 

N/A N/A N/A N/A 540 540 N/A N/A 

Temporary 

Protective 

Coating 

N/A N/A 60 60 60 60 N/A N/A 

* Passenger cars, small-sized trucks and vans, medium-sized trucks and vans, motor homes 

 and motorcycles.

** Large sized trucks, buses and mobile equipment 

2. The National Automotive Coatings Rule 

The districts that do not have their own rule for automotive coatings implement 

U.S. EPA’s national rule. In the 1990 Clean Air Act Amendments, the United States 

Congress enacted section 183(e), which established a new regulatory program for 

controlling VOC emissions from consumer and commercial products. Section 183(e) 

directs the U.S. EPA Administrator to determine the ozone forming potential of these 

products, and to prioritize the need for regulation of these products. 
Automotive Coatings Suggested Control Measure 

I-7

The U.S. EPA promulgated a final rule to control VOC emissions from automotive 

refinish coatings, such as primers and topcoats on August 14, 1998. The national rule 

was published in the Federal Register on September 11, 1998 (EPA, 1998). This rule 

was specifically aimed at manufacturers and importers of automotive coatings. 

However, the national rule had little effect on the rules already adopted by the districts. 

The VOC limits in the district rules are generally more stringent than those in the 

national rule. 

3. California Clean Air Act 

In addition to the federal planning requirements, the CCAA imposes a separate set of 

planning requirements on districts. The CCAA was enacted in 1988, and has the 

fundamental goal that all areas of California are to attain the State ambient air quality 

standards for ozone by the earliest practicable date. The Board sets the State ozone 

standards. In March 2005, the Board reviewed California’s 1-hour standard for ozone 

and determined that it alone was not sufficiently protecting human health. 

Consequently, ARB adopted a new 8-hour standard for ozone and retained the existing 

1-hour ozone standard. California’s ozone standards are: 

 1-hour average standard at 0.09 ppm, not to be exceeded 

 8-hour average standard at 0.070 ppm, not to be exceeded 

California’s new 8-hour ozone standard is more stringent than the federal 8-hour ozone 

standard of 0.08 ppm. The U.S. EPA recently eliminated the national 1-hour ozone 

standard of 0.12 ppm and replaced it with their 8-hour ozone standard. As specified in 

the CCAA, the ARB has designated areas of California to be in “attainment” or 

“nonattainment” for the State ozone standards. The districts that are nonattainment for 

the State ozone standards are required by the CCAA to prepare plans, which must be 

designed to achieve and maintain the standards by the earliest practicable date. Each 

nonattainment district is also required to update their plans every three years to include 

the latest technical information, and any changes in demographics or other relevant 

information. In developing their plans, each district determines which measures are 

necessary to include, as well as the specific details of each included measure. In many 

of the nonattainment districts, substantial additional emission reductions will be 

necessary in order to achieve and maintain the State ozone standards. By revising their 

existing rules to be consistent with the SCM, the districts can achieve greater emission 

reductions to help them attain the ozone standards.
Automotive Coatings Suggested Control Measure 

I-8

REFERENCES 

Air Resources Board. 2002 Automotive Refinishing Survey (ARB, 2005) 

Air Resources Board. 2001 Architectural Coatings Suggested Control Measure. 

(ARB, 2001) 

Air Resources Board. 2001 Airborne Toxic Control Measure for Emissions of 

Hexavalent Chromium and Cadmium from Motor Vehicle and Mobile Equipment 

Coatings. (ATCM, 2001) 

Air Resources Board and Office of Environmental Health Hazard Assessment. Staff 

Report: Public Hearing to Consider Amendments to the Ambient Air Quality Standards 

for Particulate Matter and Sulfates, May 2002. (ARB, 2002) 

Bay Area Air Quality Management District. Rule 8-24 – Motor Vehicle and Mobile 

Equipment Coatings Operations. January 6, 1999. (BAAQMD, 1999) 

Consumer Affairs. Licensed Automotive Refinish Operations in California. 

August 2005. Via the internet – http://www.dca.ca.gov (DCA, 2005) 

DuPont Corporation. Demographic Data Summary Regarding Automotive Refinishing 

Facilities In California. Via email from Emily Taylor, DuPont Corporation. 

August 8, 2005. (DuPont, 2005) 

European Commission, Reducing VOC Emissions From The Vehicle Refinishing 

Sector, Final Report August 2000. Entec UK and the Paint Research Association. 

(Entec, 2000) 

Sacramento Metropolitan Air Quality Management District. Rule 459 – Automotive. 

Truck and Heavy Equipment Refinishing Operations. October 2, 1997. (SMAQMD, 

1997) 

San Joaquin Valley Unified Air Pollution Control District. Rule 4602 – Motor Vehicle and 

Mobile Equipment Coatings Operations. December 20, 2001. (SJUVAPCD, 2001) 

South Coast Air Quality Management District. Rule 1151 – Motor Vehicle and Mobile 

Equipment Non-Assembly Line Coatings Operations. December 11, 1998. (SCAQMD, 

1998) 

South Coast Air Quality Management District. 1994 Air Quality Management Plan 1997 

AQMP Revision. 1997. (SCAQMD, 1997) 

U.S. Environmental Protection Agency. 40 CFR Part 59, National Volatile Organic 

Compound Emission Standards for Automobile Refinish Coatings (EPA, 1998). 
Automotive Coatings Suggested Control Measure 

II-1

II. DEVELOPMENT PROCESS FOR SCM 

Development of the SCM was initiated by ARB staff in cooperation with the districts. 

The key objectives of the SCM are to: (1) improve the overall effectiveness and 

enforceability of district rules; (2) improve consistency among district rules; and 

(3) achieve VOC emission reductions. 

Development of the SCM included the following activities: 

 Conducting a survey of automotive coatings manufacturers; 

 Conducting meetings with districts, U.S. EPA Region IX representatives, and 

representatives of the affected industry; 

 Reviewing existing district rules and the National Volatile Organic Compound 

Emission Standards for Automobile Refinish Coatings; 

 Holding public workshops and meetings with individual manufacturers, 

distributors, automotive refinishing facility owners, and other interested parties; 

 Assessing and evaluating existing coatings technologies for the categories; and 

 Preparing a comprehensive emissions and cost analysis. 

A. AUTOMOTIVE COATINGS 2002 SURVEY (2002 Survey) 

In 2001, ARB staff began working with manufacturers and industry groups to develop a 

new survey of automotive coatings sold in California. In 2002, ARB sent out the 

Automotive Refinish Survey seeking 2001 product ingredient and sales data. A draft 

2002 Survey report was made available to industry in March 2005. Appendix B is a 

copy of the survey. The 2002 Survey report can be obtained from the SCM webpage at 

http://www.arb.ca.gov/coatings/autorefin/scm/scm.htm. 

B. DISTRICTS AND U.S. EPA 

ARB staff formed a working group with districts and U.S. EPA staff to assist in the 

development of the SCM. The main objectives of the working group meetings were to 

discuss: 

 The needs of the districts regarding the implementation of the SCM; 

 The emission reductions achievable from automotive coatings; 

 Findings of the 2002 Survey; 

 Specific regulatory language; and 

 Flexibility options for manufacturers to comply with new automotive coatings 

regulations. 
Automotive Coatings Suggested Control Measure 

II-2

C. PUBLIC PROCESS 

A vital element of the SCM development process is the participation of members of the 

industry and other affected parties. The ARB staff held a series of public workshops. 

These workshops were attended by representatives from industry (e.g., manufacturers 

and suppliers of automotive coatings and components, ingredient manufacturers, 

automotive refinishing facility owners and trade associations), districts, the U.S. EPA, 

and other interested parties. In addition to the public workshops, ARB staff held 

meetings with individual manufacturers and distributors, as well as automotive 

refinishing facility owners to ascertain their concerns, and accept suggestions and 

necessary data. Table II -1 lists the public workshops and meetings staff conducted as 

part of the SCM development process. 

Table II-1 - List of Public Workshops and Meetings

Date Type of Meeting Location 

April 6, 2005 District Working Group Sacramento 

April 27, 2005 District Working Group Sacramento 

May 26, 2005 District Working Group Sacramento 

June 8, 2005 Industry Symposium Contra Costa College 

June 11, 2005 Industry Meeting Anaheim 

June 14, 2005 District Working Group Sacramento 

June 28, 2005 Public Workshop Diamond Bar 

June 30, 2005 Public Workshop Sacramento 

August 9, 2005 Public Workshop Fresno 

August 11, 2005 Public Workshop Oakland 

August 23, 2005 Public Workshop Diamond Bar 

October 5, 2005 Public Workshop Sacramento 

During the development of the SCM, a series of documents were created. The 

documents include: SCM draft regulatory language, working group invitations, public 

workshop notifications and meeting notices, as well as reports, and other 

correspondence and communication. In an effort to include all interested parties in the 

development process, an extensive mailing list of over 6,000 recipients was compiled 

that included manufacturers, suppliers, automotive refinishing facilities, district contacts, 

U.S. EPA contacts, trade associations, and other interested parties. Web and list serve 

pages dedicated to the SCM were developed. The webpage was used to post relevant 

documents, announcements, and staff contact information. The list serve page assisted 

in the distribution and assimilation of information regarding the development of the 

SCM. The function of the list serve was to inform over 165 subscribers of all additions 

and updates to the SCM webpage. 
Automotive Coatings Suggested Control Measure 

II-3

D. EVALUATION OF THE DISTRICT RULES AND NATIONAL RULE 

The motivation for developing the SCM was to provide consistency in district rules, 

increase rule enforceability, and achieve the maximum feasible reduction in VOC 

emissions. The national rule applies to manufacturers and importers of automotive 

coatings. In contrast, the SCM applies to suppliers, sellers, manufacturers, or anyone 

that distributes any automotive coating, the components, or associated solvent for use 

within the district, as well as any person who uses, applies, or solicits the use or 

application of any automotive coating or associated solvent within the district. Since the 

district rules have limits that are equal to, or lower than, the limits in the national rule, 

the objective of the SCM is to set limits that are at least or more stringent than those in 

existing district rules. The national rule specifically allows states or local governments 

to adopt more stringent emission limits. 

E. TECHNOLOGY ASSESSMENT 

An essential element of developing the SCM was to assess the technical feasibility of 

the proposed limits for the coatings categories. Staff conducted a technology 

assessment for all the coating categories included in the SCM. Some of the sources of 

information utilized in the technology assessment included: 

 The ARB 2002 Survey data; 

 Manufacturers’ brochures and product technical data sheets; 

 Product labels and material safety data sheets; 

 Internet websites; 

 Books and trade magazines; 

 Technical reports and training manuals; 

 Discussions with manufacturers, suppliers, and users of coatings; 

 District rules and discussions with district staff; and 

 Information from trade associations. 

The proposed VOC limits for the coating categories in the SCM are based on our 

assessment of detailed information from manufacturers on coatings sold in 2001. Staff 

evaluated technical data provided by the manufacturers for coatings in each category. 

Staff evaluated the coatings, solids content by volume, and VOC content, as well as 

other characteristics. The technology assessment for the SCM is discussed in 

Chapter IV. 
Automotive Coatings Suggested Control Measure 

II-4

F. COST ANALYSIS 

Although it is not required under the California Administrative Procedure Act (APA), the 

economic impact of the SCM on affected businesses and consumers was evaluated 

and quantified. In 2002, the ARB sent a survey to manufacturers of automotive 

coatings. The formulation data received from this survey was one of the sources of 

information used to perform a cost-effectiveness analysis and a business impacts 

analysis. The cost-effectiveness analysis measures how cost-efficient the proposed 

SCM will be in reducing VOCs relative to other regulatory programs. The business 

impacts analysis evaluates the impacts on profitability, employment, and 

competitiveness to California businesses, consumers, and government agencies. 

Staff used survey formulation data and performed research to identify typical noncomplying and complying formulations for the coating categories, and the relative cost 

of raw materials were estimated for these formulations. Examples of sources of 

information for the cost analysis were: the 2002 Survey; material safety data sheets; 

formulations data provided by coating manufacturers; equipment manufacturers; district 

staff; trade magazines; and Internet searches. Results of the cost analysis are reported 

in Chapter VII. 
Automotive Coatings Suggested Control Measure 

III-1

III. PROPOSED SUGGESTED CONTROL MEASURE 

In this chapter, we provide a plain English discussion of the staff’s proposed SCM for 

automotive coatings, which is contained in Appendix A. All sections of the proposed 

SCM are discussed below. Where applicable, key terms or concepts of the proposed 

SCM are discussed. 

Control of emissions from automotive coatings is primarily the responsibility of the 

districts. The proposed SCM may be used as a model by the districts when adopting 

and amending their local automotive coatings rules. Accordingly, throughout the staff 

report references are made to the most common or most restrictive district VOC limits, 

since the district rules are the enforceable regulations. 

A. APPLICABILITY 

The proposed SCM applies to manufacturers, distributors, sellers, and users of 

automotive coatings, but does not apply to aerosol coatings in containers of any size. 

The proposed SCM applies to coatings that are used to coat any part or component of 

motor vehicles (such as cars, buses, and golf carts) or mobile equipment (such as 

railcars and tractors). For the complete definitions of motor vehicle and mobile 

equipment, please see sections 3.19 and 3.20 of the proposed SCM. The proposed 

SCM also applies to manufacturers, distributors, sellers, and users of solvents used in 

cleaning operations. 

B. DEFINITIONS 

To help clarify and enforce the proposed SCM, section 3 of the proposed SCM provides 

definitions for terms used which are not self-explanatory. This section also provides 

equations to determine the VOC content of automotive coatings. 

C. STANDARDS 

The proposed SCM differs from the U.S. EPA’s national rule and current district rules by 

eliminating the composite VOC limit for basecoat (color) and clear coating systems. 

The composite VOC limit is being replaced with individual VOC limits for color coatings 

and clear coatings. A total of 12 VOC limits are proposed, which would become 

effective on or after January 1, 2009. 

The table of standards in the proposed SCM, reprinted below as Table III-1, contains 

the proposed limits for maximum VOC content in each category of automotive coatings. 

If the coating is represented in such a way that indicates it can be used in more than 

one of the coating categories listed in Table III-1, then the lowest, or most restrictive, 

VOC content limit will apply. 
Automotive Coatings Suggested Control Measure 

III-2

If a coating does not meet any of the definitions for the specific categories listed in 

Table III-1, that coating will fall into the category labeled “Any other coating type” and 

the VOC limit of 250 grams per liter (g/l) will apply. Limits are expressed in grams of 

VOC per liter of coating thinned to the manufacturer’s maximum recommendation, 

excluding the volume of any water and exempt compounds. 

Table III-1 - Proposed Coating Categories and VOC Limits 

VOC regulatory limit as applied 

Effective January 1, 2009 

Coating Category grams/liter (pounds per gallon*) 

Adhesion Promoter 540 4.5 

Clear Coating 250 2.1 

Color Coating 420 3.5 

Multi-Color Coating 680 5.7 

Pretreatment Coating 660 5.5 

Primer 250 2.1 

Single-Stage Coating 340 2.8 

Temporary Protective Coating 60 0.5 

Truck Bed Liner Coating 310 2.6 

Underbody Coating 430 (3.6 

Uniform Finish Coating 540 4.5 

Any other coating type 250 2.1 

* English units are provided for information only. VOC limits are expressed in grams VOC per liter of

coating, less water and exempt compounds. 

The proposed SCM also prohibits anyone from applying, manufacturing, blending, 

repackaging for sale, supplying, offering for sale, distributing, possessing (at an 

automotive refinishing facility) or selling any coating that does not meet the VOC limits 

listed in Table III-1, except when the coating is sold for use with an approved emission 

control system that is at least 85 percent efficient. It is a violation of the proposed SCM 

to solicit, require or specify the use of a coating that does not meet the VOC limits set 

forth in Table III-1, unless the coatings are used at a facility that complies with 

section 4.3 (alternative compliance provisions). 

The standards section specifies the manner in which coatings may be applied. With the 

exception of underbody coatings, truck bed liner coatings, coatings used in graphic arts 

and coatings of any type if less than one fluid ounce, the automotive coating must be 

applied by brushing, dipping, rolling, electrostatic spraying, or spraying with a highvolume, low-pressure spray (HVLP) gun or an approved equivalent. 

Section 4.8 of the proposed SCM also prohibits the use of solvents that exceed a VOC 

content of 25 g/l at an automotive refinishing facility, and specifies that any VOCcontaining materials or products must be stored in closed, vapor-tight containers when 

not in use. Spray guns must be cleaned in a closed system or its approved equivalent. 
Automotive Coatings Suggested Control Measure 

III-3

D. ADMINISTRATIVE REQUIREMENTS 

The proposed SCM requires each manufacturer to provide written data for each of their 

products that includes the physical properties of the coating, coating component, or 

solvent. For a complete description of what information must be included on the 

manufacturer data sheets, please see sections 5.1.1, 5.1.2, and 5.1.3 of the proposed 

SCM. Manufacturers must also clearly label all coatings and coating components with 

the applicable use categories listed in Table III-1 and the VOC content. Manufacturers 

must label solvents with the VOC content. 

The proposed SCM requires that those who use automotive coatings or solvents at 

automotive refinishing facilities keep records indicating the name and manufacturer of 

the coating or solvent, method of applying the coating or solvent, coating type and mix 

ratio, VOC content of the coating or solvent, and whether the product used is a coating 

or a solvent. This information, along with manufacturer’s data sheets or other written 

materials that provide the actual and regulatory VOC content and purchase records 

listing the coating type, name, and volume of coatings or solvents must be kept at the 

location where the coatings are applied for a minimum of three years. These records 

are to be made available for inspection upon request. 

Anyone using an approved emission control system per section 4.3 instead of using 

coatings that meet the VOC limits in Table III-1 must keep daily records, to be 

maintained for a minimum of three years. These records will prove continuous and 

correct use of the control system during the time that emissions are occurring. 

The proposed SCM specifies that no person shall manufacture, blend, repackage for 

sale, supply, sell, offer for sale, or distribute or apply any automotive coating or 

automotive coating component that does not meet the VOC limits in the proposed SCM. 

However, if the coating is for use exclusively within an emission control system or 

outside the district, a person may manufacture, blend, repackage for sale, supply, sell, 

offer for sale, or distribute an automotive coating or component that does not meet the 

VOC limits. In this situation, that person must keep records of the quantity 

manufactured, blended, repackaged, supplied, sold, offered for sale, or distributed; size 

and number of containers; VOC content; name, address, phone number, retail tax 

license number, and valid district permit number for the person to whom or for whom the 

coating or component was manufactured, blended, repackaged, supplied, sold, offered 

for sale or distributed; and whether the coating is for use in an approved emissions 

control system or outside the district. As with all records pertaining to the proposed 

SCM, this information must be kept for a minimum of three years and be made available 

for inspection upon request. 
Automotive Coatings Suggested Control Measure 

III-4

E. TEST METHODS 

Test methods for automotive coatings and solvents subject to the proposed SCM are 

provided in this section. These include tests for metallic and acid content, tests for the 

determination of various exempt compounds, a method for determining VOC content of 

solvents or coatings, tests to determine control and transfer efficiency, and a method to 

determine if a spray gun’s transfer efficiency is equivalent to that of a HVLP spray gun. 

Please see section 6 of the proposed SCM for complete descriptions and reference 

numbers for these test methods. 
Automotive Coatings Suggested Control Measure 

IV–1 

IV. DESCRIPTION AND TECHNICAL ASSESSMENT OF THE COATING 

CATEGORIES AND SOLVENTS 

A. INTRODUCTION 

To ensure that the proposed SCM is technologically and commercially feasible, we 

considered the following: 

1) The results of the 2002 Automotive Coatings Survey; 

2) Information from automotive coating manufacturers, solvent suppliers, and other 

industry groups; 

3) The existing VOC limits for automotive coatings and solvents; and 

4) The results of our technical analyses of all the coating categories proposed in the 

SCM. 

Based on the technical analyses, we believe that the overall performance of the 

reformulated products in each category will be similar to the performance of their higher 

VOC counterparts. Except for the adhesion promoter and pretreatment coating 

categories, complying products are commonly available and currently being used. 

However, we will conduct technology reviews for the proposed VOC limits that are lower 

than the most stringent limits in existing district rules prior to the effective date of those 

limits. 

In this chapter, we provide a discussion of the automotive coating categories and the 

solvents included in the proposed SCM. The coating categories are adhesion promoter, 

clear coating, color coating, multi-color coating, pretreatment coating (formerly called 

pretreatment wash primer), primer, single-stage coating (formerly called topcoat), 

temporary protective coating, truck bed liner coating, underbody coating, uniform finish 

coating, and any other coating type. 

Appendix D discusses categories that are currently in district rules or the national rule, 

but which are not specifically listed in the proposed SCM. These coating categories are 

multi-stage topcoat system, specialty coating, metallic/iridescent, primer sealer, primer 

surfacer, camouflage, precoat, extreme performance coatings, elastomeric material, 

anti-glare safety coating, impact resistant coating, water hold-out coating, weld-thru 

coating, bright metal trim repair, gloss flatteners, heat resistant, and jambing (cut-in) 

clear coat. 

The structure of the proposed SCM differs significantly from existing district rules. 

Currently, the district rules and the U.S. EPA automotive coatings rule allow for a 

composite VOC limit for “multi-stage topcoat” systems. The SCM replaces the 

composite VOC limit with specific VOC limits for clear and color coatings. 
Automotive Coatings Suggested Control Measure 

IV–2 

Also, the proposed SCM eliminates the distinction between Group I and Group II vehicle 

categories, and establishes the same VOC limits for coatings used on passenger 

vehicles, heavy-duty vehicles, and mobile equipment. The SCM will clarify and, where 

applicable, combine coating categories. The SCM eliminates the specialty coatings 

category and replaces it with specific category limits as needed. The 2002 Survey data 

indicated that several of the coating types currently allowed under the specialty coatings 

category are no longer sold in California. 

Most of the coatings have two or more individual components that are combined into 

one formulation. For example, a color coating may be a combination of up to ten 

individual toners plus hardeners, reducers, and specialty additives. As such, we cannot 

determine the volume applied of any single mixture. For an estimate of the emissions 

from each coating category, we assumed that an equal amount of base material was 

used in every formulation that could be made with that base material. 

ARB staff analyzed the survey data to propose appropriate VOC limits, as listed in 

Chapter III, Table III-1. Table IV-1 shows the number of companies that reported 

coatings that meet the proposed VOC limits in the SCM. Table IV-2 shows coating 

categories found in the existing district rules and their corresponding category in the 

proposed SCM. 

Table IV-1 - Compliance Summary

Coating Category 

Number of 

Companies 

that: 

Adhesion 

Promoter

Clear Color 

*** 

Multicolor

Pretreatment Primer Single 

Stage

*** 

Temporary 

Protective

Truck 

Bed 

Liner

Underbody Uniform 

Finish 

Sold type 

of coating 

in CA 

5 15 12 0 13 15 13 2 1 3 5 

Reported 

mixtures 

4 14 11 0 11 14 10 2 1 3 3 

Reported 

valid 

mixtures * 

4 14 11 0 11 14 10 2 1 3 3 

Reported 

compliant 

mixtures **

0 11 5 0 0 12 1 1 1 2 1 

17 companies responded to survey. 

* Mixtures are considered valid if ARB has all necessary information for all components of the 

mixture and the information for each component met ARB standards. 

** Mixtures that meet the VOC limits proposed in the SCM. 

*** Single-Stage and Color Coatings are reported for systems and not individual mixtures. 
Automotive Coatings Suggested Control Measure 

IV–3 

Table IV-2 - Comparison of Coating Categories

Existing District Categories SCM Categories 

Camouflage Color Coating 

Extreme Performance Primer, Color Coating, Clear 

Coating, Single-Stage Coating, or 

Underbody Coating 

General Topcoat Single-Stage Coating 

Metallic/Iridescent Topcoat Single-Stage Coating 

Multi-Color Multi-stage Multi-Color Coating 

Multi-Color Topcoat Multi-Color Coating 

Multi-stage Topcoat (aka Multi-stage Topcoat 

System) 

Color Coating & Clear Coating 

Precoat Primer 

Pretreatment Wash Primer (aka Pretreatment or 

Pretreatment Coating) 

Pretreatment Coating 

Primer Primer 

Primer Sealer Primer 

Primer Surfacer Primer 

Rubberized Asphaltic Underbody Underbody Coating 

Single-Stage Nonmetallic/Noniridescent Topcoat Single-Stage Coating 

Single-Stage Metallic/Iridescent Coating Single-Stage Coating 

Solid Color Topcoat Single-Stage Coating 

Temporary Protective Coating Temporary Protective Coating 

Topcoat (aka All Other Topcoats) Single-Stage Coating 

Specialty Coatings The generic category has been 

eliminated and replaced with specific 

categories for the various coatings 

previously grouped together and are 

addressed below. 

Adhesion promoter Primer or Adhesion Promoter 

Anti-glare Safety Coating (aka Antiglare/Safety 

Coatings) 

Clear Coating, Color Coating, or 

Single-Stage Coating 

Bright Metal Trim Repair Coating Any Other Coating Type 

Camouflage Color Coating 

Elastomeric Materials (aka Elastomeric 

Coatings) 

Primer, Color Coating, Clear 

Coating, Single-Stage Coating, or 

Underbody Coating 

Extreme Performance Primer, Color Coating, Clear 

Coating, Single-Stage Coating, or 

Underbody Coating 

Gloss Flatteners (aka Low-Gloss Coatings) Clear Coating 

Heat Resistant Primer, Color Coating, Clear 

Coating, or Single-Stage Coating 

Impact Resistant Coating Single-Stage Coating, Clear Coating, 
Automotive Coatings Suggested Control Measure 

IV–4 

Table IV-2 - Comparison of Coating Categories

Existing District Categories SCM Categories 

Underbody Coating, or Truck Bed 

Liner Coating 

Jambing (Cut-In) Clear Coats Clear Coating 

Multi-Color Coatings Multi-Color Coatings 

Rubberized Asphaltic Underbody Coating Underbody Coating 

Uniform Finish Blenders (aka Finish Blenders) Uniform Finish Coating 

Water Hold-Out Coating Primer 

Weld-Thru Coatings (aka Weld-Thru Primers 

and Weld-Through Primer) 

Primer 

B. CATEGORIES THAT ARE IN THE SCM 

This section describes each of the categories in the SCM. Chapter V, Table V-3, details 

the estimated emissions and anticipated emission reductions, in tpd, from each 

category in the proposed SCM. Table IV-3, at the end of this section, provides basic 

physical parameters for each coating category in the proposed SCM. Table IV-4 shows 

the number of compliant mixtures and complying marketshare for each coating category 

as of 2001. All averages expressed in this chapter are simple, arithmetic averages. 

1. Adhesion Promoter 

Adhesion promoters are coatings applied directly to uncoated plastic surfaces to 

facilitate bonding of subsequent coatings. All adhesion promoter mixtures reported in 

the 2002 Survey are solvent-borne coatings. None of the mixtures reported contain any 

water or exempt compounds. Other than resins, the solids include pigments and 

various other compounds. These include proprietary compounds, titanium dioxide, talc, 

and barium sulfate. 

The proposed VOC limit of 540 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date based on discussions with coating manufacturers. 

Manufacturers may increase the exempt compound content in order to comply with the 

proposed VOC limit. Five companies reported selling adhesion promoter coatings in the 

2002 Survey. None of the four companies that reported complete and valid information 

for adhesion promoters have coatings that meet the proposed limit. One coating 

manufacturer has stated that they expect to have a product that meets the proposed 

VOC limit in the market by 2008. 
Automotive Coatings Suggested Control Measure 

IV–5 

Issues: 

1. Issue: No product currently meets the proposed limit. 

 Response: Manufacturers may add exempt compounds to their coatings to meet 

the proposed VOC limit. 

 Below is a sample formulation of a compliant adhesion promoter. This is 

intended to illustrate how the VOC content could be lowered to meet the 

proposed VOC limit. In developing this formulation, we relied on nearly 

compliant formulations of existing mixtures and increased the amount of exempt 

compounds. The volume percent is derived from the weight percent and 

individual densities of compounds in the coating formulation. To protect data 

confidentiality, the formula below groups various solids and VOCs together. 

Ingredient Wt % Vol %

resin 19 17.4

solids 18 5.9

TBAC (or other exempts) 29.5 35.5

VOCs 33.5 41.2

total 100 100

solids 37 23.3

exempts 29.5 35.5

VOC 33.5 41.2

overall density (g/cm3) 1.04

VOC limit 540 g/l

VOCreg 539.0 g/l

VOCact 347.6 g/l

This is a small usage category, about 3,600 gallons in 2001. If compliant products are 

formulated with TBAC, the emissions of TBAC from this coating category would be only 

25 lbs per day statewide. Exempts other than TBAC could be used to achieve the same 

VOC content. 
Automotive Coatings Suggested Control Measure 

IV–6 

2. Clear Coating 

Clear coatings are coatings that contain no pigments and are applied over a color 

coating or clear coating. All clear coating mixtures reported in the 2002 Survey are 

solvent-borne coatings. The coatings employ a variety of solvents that manufacturers 

mix to vary the rate of evaporation of the carrier (solvent). Many of the mixtures 

reported contain trace to minor amounts of water. 

Over half of the mixtures reported contain exempt compounds. In those mixtures, the 

exempt content, by weight, ranges from about one-half percent up to sixty-six percent. 

Overall, the average exempt compound content is about nine percent by weight. 

The majority of the solid content of a clear coating is resin. Some clear coatings have 

materials such as talc and silica to disperse light and create a matted appearance. 

Other clear coatings have plasticizers or flexiblizing agents added to create an 

elastomeric coating. Other than resins, the solids include proprietary compounds, silica, 

ultra-violet light absorbers, light stabilizers, and many other compounds in minor 

amounts. 

The proposed VOC limit of 250 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. The SCAQMD Rule 1151 requires that all 

manufacturers who offer clear coatings for sale in the district offer at least one product 

line with a VOC content of 2.1 lbs/gal (250 g/l) or less. Fifteen companies reported 

selling clear coatings in the 2002 Survey. Eleven of the fourteen companies that 

reported complete and valid information for clear coatings have coatings that meet the 

proposed limit. 

Issues: 

1. Issue: Low gloss/matted clears need a higher VOC limit to accommodate the 

additives that are used to disperse light. 

 Response: Manufacturers currently add a flattening agent to a high gloss clear 

coating to achieve a low gloss coating. This formulation approach results in an 

unnecessarily high VOC content. The VOC content of low gloss clear coatings 

could be reduced to 250 g/l if products are formulated directly as low gloss 

products. 

Issue: Elastomeric clears need a higher VOC limit.

 Response: The ARB has been informed that elastomeric/flex additives are 

currently available at 1.9 lb/gal (228 g/l) which would enable an elastomeric clear 

coating to achieve the 250 g/l VOC limit. 
Automotive Coatings Suggested Control Measure 

IV–7 

3. Issue: Compliant solvent-borne clear coatings have not been tested for 

compatibility with water-borne color coatings. 

 Response: The ARB has found manufacturer data sheets that indicate that at 

least two companies market 250 g/l clear coatings that are compatible with their 

respective water-borne color coating systems. The PPG Corporation stated at 

the fourth public workshop in Oakland that it has a compliant solvent-borne clear 

coating that is marketed for use with its water-borne color coatings. 

3. Color Coating 

Color coatings are pigmented coatings, excluding adhesion promoters, primers and 

multi-color coatings, that require a subsequent clear coating. Color coatings include 

metallic/iridescent color coatings. These coatings were previously called basecoats and 

midcoats as part of the multi-stage systems in district rules. These coatings require a 

subsequent clear coating for protection, durability, and gloss. 

Two companies reported sales of water-borne systems in the 2002 Survey. Another 

company reported three specific water-borne mixtures. All other coatings in this 

category are solvent-borne. Many mixtures reported contain trace to minor amounts of 

water. Exempt compounds are in about half of the mixtures reported. In those mixtures 

with exempt compounds, the amount of exempt compounds ranged from one-tenth of a 

percent to seventy-three percent by weight. Overall, the average amount of exempt 

compounds was three percent by weight. 

 

This is the largest emitting category of automotive coatings. Color coatings account for 

about 60 percent of the VOC emissions from automotive coatings. Other than resins, 

the solids include pigments and various other compounds. These include titanium 

dioxide, mica, nickel compounds, iron compounds, rutile, aluminum, silica, carbon black, 

molybdenum compounds, tin compounds, barium sulfate, copper compounds, and 

numerous other compounds. 

Most of the major manufacturers have water-borne color coatings that have been 

developed to comply with European Union (EU) emission standards. The EU directive 

will require all manufacturers to meet a 420 g/l VOC limit for color coatings as of 

January 1, 2007. The EU does not allow the use of exempt compounds to comply with 

the VOC content limit. Consequently, manufacturers have developed water-borne 

technologies to meet the EU VOC limit. 
Automotive Coatings Suggested Control Measure 

IV–8 

Based on discussions with manufacturers, they intend to use these water-borne 

systems to comply with the proposed SCM VOC limit. Thus, the proposed VOC limit of 

420 g/l is technologically and commercially feasible by the January 1, 2009, effective 

date. Twelve companies reported selling color coatings in the 2002 Survey. Six of the 

eleven companies that reported complete and valid information for color coatings have 

solvent-borne systems that meet the proposed limit currently in use in California. 

However, these solvent-borne systems are only used for fleet vehicles, not for 

passenger vehicles that have greater performance demands. 

If manufacturers choose to comply with the color coating limit with water-borne coatings, 

this will be a significant change from the current use of high VOC solvent-borne 

coatings. It will likely require changes by the end users, including the addition of air 

movement equipment to quickly dry the water-borne coatings and perhaps heat to 

maintain current production levels. 

4. Multi-Color Coating 

Multi-color coatings are coatings that exhibit more than one color in the dried film after a 

single application, are packaged in a single container, and hide surface defects on 

areas of heavy use. These coatings are commonly called “splatter” coatings due to 

their appearance. They are more commonly used in industrial settings and on items 

such as small fishing boats. 

No coatings in this category were reported as being sold in California in 2001. We have 

found this type of coating marketed on the internet, with one of the listed uses being 

automotive. We have assumed that everyone who markets this coating is in 

compliance with the current national limit. 

The proposed VOC limit of 680 g/l is technologically and commercially feasible. The 

proposed limit is the same as the current limit of 680 g/l in the National Volatile Organic 

Compound Emission Standards for Automobile Refinish Coatings, 40CFR59, 

Sections 59.100 through 59.111, and Table 1 to Subpart B. 

5. Pretreatment Coating 

Pretreatment coatings contain a minimum of one-half (0.5) percent acid by weight to 

provide surface etching, and not more than 16 percent solids by weight. They are 

applied directly to bare metal surfaces to provide corrosion resistance and adhesion. 

The SCAQMD and Antelope Valley AQMD are the only districts that limit the solids 

content of pretreatment coatings. Limiting the solids content is intended to reduce film 

build from a pretreatment coating, thereby reducing the incentive to use a high VOC 

content material as a primer able to fill large scratches or voids. 
Automotive Coatings Suggested Control Measure 

IV–9 

All of the reported mixtures in the 2002 Survey are solvent-borne. Of the 57 reported 

mixtures, 48 mixtures contain negligible to minor amounts of water. Water content 

ranges up to almost four percent by weight. Of the 57 reported mixtures, 43 mixtures 

do not contain any exempt compounds. Six mixtures have about one percent exempt 

compounds by weight and the remainder of mixtures range from two percent up to 

15 percent exempt compounds by weight. Of the coatings that meet the solids content 

provision of the SCM, most do not use any exempts. The maximum exempt content 

found in the coatings that meet the solids content provision is approximately six percent. 

Other than resins, the solids include pigments and various other compounds. These 

include titanium dioxide, talc, zinc compounds, iron oxide, calcium carbonate, zinc 

phosphate, silica, and numerous other compounds. The primary acid used is 

phosphoric acid. 

ARB staff believes the proposed VOC limit of 660 g/l is technologically and 

commercially feasible by the January 1, 2009 effective date based on discussions with 

the coating manufacturers (current limit is 780 g/l). One coating manufacturer has 

stated that they expect to have a pretreatment coating that meets the proposed limit on 

the market by the end of 2005. 

One mixture reported in the 2002 Survey had a VOC content of 660 g/l, however, its 

solids content was greater than 16 percent, by weight. We believe it is possible for 

manufacturers to increase the exempt compound content in order to comply with the 

proposed VOC limit. Thirteen companies reported selling pretreatment coatings in the 

2002 Survey. Eleven companies reported complete and valid information for 

pretreatment coatings, however, none have coatings that meet the proposed limit. 

Issues: 

1. Issue: No product currently meets the proposed limit. 

 Response: ARB staff believes that the manufacturers have time to reformulate 

their coatings to meet the proposed limit. Because no products currently meet 

the proposed VOC limit, we will conduct a technology assessment approximately 

one year before the effective date of the limit. 

 Below is a sample formulation of a compliant pretreatment coating. This is 

intended to illustrate how the VOC content could be lowered to meet the 

proposed VOC limit. In developing this formulation, ARB staff relied on nearly 

compliant formulations of existing mixtures and increased the amount of exempt 

compounds. The volume percent is derived from the weight percent and 

individual densities of compounds in the coating formulation. To protect data 

confidentiality, the formula below groups various solids and VOCs together for 

display. 
Automotive Coatings Suggested Control Measure 

IV–10 

Ingredient Wt % Vol %

Resin 5.5 4.4

Solids 9.1 2.5

phosphoric acid 1.4 0.8

Acetone (or other exempts) 7.5 8.6

TBAC (or other exempts) 41.5 43.5

VOCs 35 40.3

Total 100 100

Solids 16 7.7

Exempts 49 52.1

VOC 35 40.3

overall density (g/cm3) 0.90

VOC limit 660 g/l

VOCreg 659.4 g/l

VOCact 316.0 g/l

This is a small usage category, about 45,000 gallons in 2001. If compliant products 

were formulated with TBAC, the emissions of TBAC from this coating category would be 

less than 400 lbs per day statewide. 

6. Primer 

The primer category currently exists in district rules. The SCM retains it and expands it 

to include the current district coating categories of primer surfacers and primer sealers. 

Most districts have the same VOC limit for primers and primer surfacers. Currently, the 

VOC limit for primer sealers is slightly higher (e.g., 340 g/l in SCAQMD). Primers are 

coatings applied to a substrate to provide: 

1) A bond between the substrate and subsequent coats; 

2) Corrosion resistance; 

3) A smooth substrate surface; or 

4) Resistance to penetration of subsequent coats. Some primers are pigmented to 

allow the painter to use less color coating to achieve the desired color. 

The vast majority of primers reported in the 2002 Survey are solvent-borne, with only 

a small percentage being water-borne. One mixture of primer, four mixtures of sealer, 

14 mixtures of surfacer, and one mixture of precoat are water-borne. All other mixtures 

reported are solvent-borne. 
Automotive Coatings Suggested Control Measure 

IV–11 

Almost 75 percent of the primers reported contain exempt compounds. For those 

mixtures with exempt compounds, the exempt content ranges from one-tenth of a 

percent to almost 64 percent, by weight, with the average exempt content being just 

under six percent. 

The resin content varies widely within the primer category depending upon usage and 

manufacturer, from a low of 0.2 percent to a high of 57 percent, by weight, both of which 

are in the surfacer subcategory. Most primers have approximately 20 to 29 percent 

resin, by weight. Other than resins, the solids include pigments and various other 

compounds. These include barium sulfate, talc, titanium dioxide, calcium carbonate, 

zinc phosphate, mica, clay, aluminum, iron oxide, magnesium carbonate, and numerous 

other compounds. 

The proposed VOC limit of 250 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. SCAQMD’s Rule 1151 already requires all primers, 

primer surfacers, and primer sealers used on large vehicles and mobile equipment to 

meet a VOC content of 250 g/l. Fifteen companies reported selling primers in the 2002 

Survey. Twelve of the 14 companies that reported complete and valid information for 

primers have coatings that meet the proposed limit. 

Issues: 

During the SCM development process, manufacturers requested a 340 g/l VOC limit for 

sealers. The reasons cited for the need for a higher VOC limit and our responses are 

discussed below. 

1. Issue: Sealers have a lower solids content than surfacers and therefore cannot 

meet the same limit. 

 Response: ARB staff analyzed the solids content of surfacers and sealers and 

found that while there were differences between the solids contents for any given 

manufacturer, the differences were insignificant when compared to the 

differences between manufacturers. The ranges for any given manufacturer 

overlapped, as well as between manufacturers. One manufacturer has stated 

that it will not be difficult to meet the proposed limit for sealers using exempts in 

the solvent mix. 

2. Issue: Sealers have less pigment and more resin than surfacers and therefore 

need a higher limit. 

 Response: ARB staff analyzed the types of solids in the sealers and surfacers 

and found that there is a lot of overlap between the ranges of the types of solids 

in sealers and surfacers. ARB staff believes that both products can meet the 

proposed limit. One manufacturer has stated that it will not be difficult to meet 

the proposed limit for sealers using exempts in the solvent mix. 
Automotive Coatings Suggested Control Measure 

IV–12 

7. Single-Stage Coating 

Single-stage coatings are pigmented coatings, excluding primers and multi-color 

coatings, for application without a subsequent clear coating. Single-stage coatings 

include metallic/iridescent single-stage coatings. This is an older coating technology 

that is diminishing in usage in the collision repair industry. It is being replaced by color 

coating/clear coating systems that use less material and provide a higher gloss with a 

more durable finish. Single-stage coatings are used mostly in production shops where 

the entire vehicle is painted, and a single coating can achieve the desired color, 

protection and durability in one application. 

All but two of the reported mixtures of single-stage coatings in the 2002 Survey are 

solvent-borne. Only about four percent of reported mixtures contain water. For most of 

these mixtures, the water content is negligible. Four mixtures contain significant 

amounts of water, ranging from 25 to 55 percent, by weight. 

Over half of the mixtures reported do not contain any exempt compounds. In the 

remaining mixtures the exempt content, on a mass basis, increases gradually from 

0.5 percent up to a maximum exempt content of 61 percent, by weight. 

Other than resins, the solids include pigments and various other compounds. These 

include mica, titanium dioxide, iron oxide, talc, copper compounds, aluminum, barium 

sulfate, carbon black, silica, nickel compounds, and numerous other compounds. 

The proposed VOC limit of 340 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. SCAQMD Rule 1151 currently requires all single-stage 

coatings used on large vehicles and mobile equipment to meet a VOC limit of 340 g/l. 

The proposed SCM extends the 340 g/l VOC limit in SCAQMD to all vehicles, including 

passenger cars. Thirteen companies reported selling single-stage coatings in the 

2002 Survey. One of the ten companies that reported complete and valid information 

for single-stage coatings has a complete single-stage system that meets the proposed 

limit. 

Issues: 

1. Issue: Metallic single-stage coatings at the proposed limit do not currently exist 

for the automotive market. 

 Response: There were some metallic single-stage coatings sold in 2001 that 

comply with the proposed VOC limit. One manufacturer has stated that they 

have a complete single-stage system, including metallics, that complies with the 

proposed limit. 
Automotive Coatings Suggested Control Measure 

IV–13 

However, based on discussions with manufacturers, it appears that single-stage 

coatings are not a good technology for metallic coatings. Currently, pearl or 

iridescent coatings are only achieved by using a color coating/clear coating 

technology. It appears that the best way to achieve a metallic coating is to use a 

color coating/clear coating technology. This is due to the way the paint film is 

created in single-stage coatings. The metallic flakes are not spread evenly 

throughout the film and reside only near the surface of the film making them 

more susceptible to damage, both mechanical and chemical. This would alter 

the appearance of the paint. Whereas in a color coating/clear coating system, 

the metallic flakes are fully protected by the clear coating. 

8. Temporary Protective Coating 

Temporary protective coatings are coatings used to temporarily protect areas from 

overspray or mechanical damage. These coatings are commonly used instead of 

taping off an area before painting another area or applied prior to shipping a vehicle. 

These coatings are removed after a primer or topcoat application, or after a vehicle 

reaches its destination. 

Both of the reported mixtures of temporary protective coatings in the 2002 Survey are 

water-borne. Neither of the mixtures reported contains any exempt compounds. Other 

than resins, the solids include pigments and various other compounds. 

The proposed VOC limit of 60 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. Several district rules currently require temporary 

protective coatings to meet a VOC limit of 60 g/l. Two companies reported selling 

temporary protective coatings in the 2002 Survey. One of the two companies that 

reported complete and valid information for temporary protective coatings has a coating 

that meets the proposed limit. 

9. Truck Bed Liner Coating 

Truck bed liner coatings are coatings for application to a truck bed to protect it from 

surface abrasion. These coatings do not include clear coatings, color coatings, multicolor coatings, or single-stage coatings. These coatings are often a rubbery type of 

coating that provides traction and keeps materials from dinging or scratching the bed. 

The one reported mixture of truck bed liner coatings in the 2002 Survey is solventborne. It contains no water or exempt compounds. Other than resins, the solids include 

pigments and various other compounds. 

The proposed VOC limit of 310 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. One company reported selling truck bed liner coatings 

in the 2002 Survey. The company reported complete and valid information, and the 

coating meets the proposed VOC limit. 
Automotive Coatings Suggested Control Measure 

IV–14 

10. Underbody Coating 

Underbody coatings (formerly called “rubberized asphaltic underbody coatings”) are 

applied to wheel wells, the inside of door panels or fenders, the underside of a trunk or 

hood, or the underside of the motor vehicle itself. The coatings are typically used for 

sound deadening or protection. ARB staff changed the name of the category to 

“Underbody Coating” and modified the definition to also include coatings with a similar 

purpose that do not contain rubberized asphalt. 

Only four districts define this type of coating, and some districts do not list it as a 

specialty coating in their specialty coating definition. Of the four districts that define this 

type of coating, three districts have it specifically listed as a specialty coating. 

Sacramento Metropolitan AQMD has a limit of 540 g/l for these coatings. 

Five of the six mixtures reported are solvent-borne; the remaining mixture is waterborne. None of the solvent-borne coatings contain any water. None of the reported 

mixtures, whether solvent-borne or water-borne, contain any exempt compounds. 

Other than resins, the solids include pigments and various other compounds. These 

include talc, calcium carbonate, titanium dioxide, and iron oxide. 

The proposed VOC limit of 430 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date based on data provided by the coating manufacturers. 

Three companies reported underbody coatings in the 2002 Survey. Three companies 

reported complete and valid information and two companies have coatings that meet 

the proposed limit. 

11. Uniform Finish Coating 

Uniform finish coatings are coatings applied to the area around a spot repair for the 

purpose of blending a repaired area’s color or clear coating to match the appearance of 

an adjacent area’s existing coating. While all districts except for one identify this as a 

specialty coating, only five districts and the national rule define the coating. 

All of the coatings reported as uniform finish coatings in the 2002 Survey are 

solvent-borne. None of the reported mixtures contain any water. Only two mixtures 

contain exempt compounds. Both of these mixtures contain about ten percent exempt 

compounds by weight. The non-resin portion of the solids is composed of pigment and 

other solids. 

The proposed VOC limit of 540 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date based on data provided by the coating manufacturers. 

Five companies reported uniform finish coatings in the 2002 Survey. Three companies 

reported complete and valid information and two of the companies have coatings that 

meet the proposed limit. 
Automotive Coatings Suggested Control Measure 

IV–15 

12. Any Other Coating Type 

This category is for any coating that does not fit into the specified coating categories. It 

was created so that if such a coating existed it would not be exempt from the VOC 

content limits. Currently, we are unaware of any coating that would be in this category. 

The proposed VOC limit of 250 g/l was set to preserve the emission reductions from the 

proposed SCM. 

Table IV-3 - Basic Physical Parameters 

Minimum Maximum Average 

Volume % Solids 1.1 35.8 14.3 

Weight % Solids 1.0 51.8 20.3 

Weight % Resin 1.0 12.5 3.6 

VOC actual (g/l) 579 857 745 

Adhesion 

Promoter 

VOC regulatory (g/l) 579 857 745 

Volume % Solids 2.7 72.3 41.5 

Weight % Solids 3.6 76.5 46.9 

Weight % Resin 3.4 73.9 37.4 

VOC actual (g/l) 29 840 429 

Clear Coating 

VOC regulatory (g/l) 82 840 464 

Volume % Solids 0.7 92.8 25.7 

Weight % Solids 2.7 94.0 34.3 

Weight % Resin 0.8 93.2 29.1 

VOC actual (g/l) 62 883 602 

Color Coating 

VOC regulatory (g/l) 63 883 626 

Multi-Color 

Coating 

No information was reported. 

Volume % Solids 2.9 17.8 11.6 

Weight % Solids 3.8 34.0 23.9 

Weight % Resin 1.4 13.9 6.2 

VOC actual (g/l) 579 933 721 

Pretreatment 

Coating 

VOC regulatory (g/l) 660 933 736 

Volume % Solids 3.8 85.8 38.8 

Weight % Solids 4.5 84.3 56.5 

Weight % Resin 0.2 56.7 25.4 

VOC actual (g/l) 5 831 477 

Primer 

VOC regulatory (g/l) 12 831 502 

Volume % Solids 7.6 82.0 33.6 

Weight % Solids 10.0 86.4 41.5 

Weight % Resin 8.2 73.2 28.3 

VOC actual (g/l) 69 797 543 

Single-Stage 

Coating 

VOC regulatory (g/l) 87 829 561 

Temporary 

Protective Coating 

This information is proprietary. 

Truck Bed Liner This information is proprietary. 
Automotive Coatings Suggested Control Measure 

IV–16 

Table IV-3 - Basic Physical Parameters 

Minimum Maximum Average 

Coating 

Volume % Solids 24.0 41.4 28.7 

Weight % Solids 31.9 55.0 39.7 

Weight % Resin 15.4 20.0 17.5 

VOC actual (g/l) 25 597 466 

Underbody 

Coating 

VOC regulatory (g/l) 46 597 469 

Volume % Solids 2.8 35.7 32.4 

Weight % Solids 3.7 41.0 36.9 

Weight % Resin 3.6 38.3 34.3 

VOC actual (g/l) 464 827 573 

Uniform Finish 

Coating 

VOC regulatory (g/l) 524 827 584 

Any Other Coating 

Type 

No information was reported. 

Table IV-4 - Technical Feasibility 

Number of Currently 

Complying Mixtures 

Estimated Currently 

Complying Market Share 

(percent) 

Adhesion Promoter 0 0 

Clear Coating 33 8 - 26 

Color Coating Systems 8 (6 fleet) 8 

Multi-Color Coating NA NA 

Pretreatment Coating 0 0 

Primer 99 40 - 45 

Single-Stage Coating Systems 1 NR 

Temporary Protective Coating P P 

Truck Bed Liner Coating P P 

Underbody Coating P P 

Uniform Finish Coating P P 

Any Other Coating Type NA NA 

NA - Information not available 

NR - Volumes not reported 

P - Proprietary information 
Automotive Coatings Suggested Control Measure 

IV–17 

C. SOLVENTS

Solvents, as the term is used in the SCM, are cleaning solutions that contain VOCs. 

While most districts regulate solvents used for cleaning operations in their automotive 

coating rules, a couple of districts (e.g., SCAQMD) have separate rules for cleaning 

solvents. ARB is addressing solvents used in automotive coating cleaning operations 

as part of the SCM. 

Most district rules divide solvents into two categories: surface preparation and cleanup, 

and application equipment cleaning. These solvent categories typically have different 

VOC limits, with application equipment cleaning being given a higher VOC limit. Some 

districts further divide surface preparation solvents into those used to clean plastic parts 

and all other surface preparation solvents. In these cases, the plastic parts cleaners are 

given higher VOC limits than the non-plastic parts cleaners. A few districts provide a 

separate and higher VOC limit for solvents applied from hand-held spray containers. A 

few districts provide a separate and higher VOC limit for solvents used to clean road tar, 

engine oil, grease, overspray, and adhesives. 

The proposed VOC limit of 25 g/l is technologically and commercially feasible by the 

January 1, 2009, effective date. The SCAQMD Rule 1171, requires all solvents used 

for cleaning at automotive coatings operations to meet a 25 g/l VOC limit as of 

July 1, 2005. There are solvents available that meet the 25 g/l VOC limit through the 

use of exempt compounds. The SCM would extend the existing SCAQMD limit to the 

rest of the State. 
Automotive Coatings Suggested Control Measure 

IV–18 

REFERENCES 

California Air Resources Board 2002 Automotive Coatings Survey data. 

Code of Federal Regulations Title 40 Part 59 – National Volatile Organic Compound 

Emission Standards for Consumer and Commercial Products, Sections 59.100 through 

59.111 and Table 1 to Subpart B. 

Antelope Valley Air Quality Management District Rule 1151 – Motor Vehicle and Mobile 

Equipment Coating Operations. 

Bay Area Air Quality Management District Regulation 8 – Organic Compounds, Rule 45 

– Motor Vehicle and Mobile Equipment Coating Operations. 

Butte County Air Quality Management District Rule 235 – Requirements for Vehicle and 

Mobile Equipment Coating Operations. 

El Dorado County Air Quality Management District Rule 230 – Automotive Refinishing 

Operations. 

Feather River Air Quality Management District Rule 3.19 – Vehicle and Mobile 

Equipment Coating Operations. 

Glenn County Air Pollution Control District Article IV Prohibitions, Section 105 – Vehicle 

and Mobile Equipment Coating Operations. 

Imperial County Air Pollution Control District Rule 101 – Definitions. 

Imperial County Air Pollution Control District Rule 427 – Automotive Refinishing 

Operations. 

Kern County Air Pollution Control District Rule 410.4A – Motor Vehicle and Mobile 

Equipment Refinishing Operations. 

Mojave Desert Air Quality Management District Rule 1116 – Automotive Refinishing 

Operations. 

Placer County Air Pollution Control District Rule 234 – Automotive Refinishing 

Operations. 

Sacramento Metropolitan Air Quality Management District Rule 459 – Automotive, Truck 

& Heavy Equipment Refinishing Ops. 

San Diego County Air Pollution Control District Rule 67.20 – Motor Vehicle and Mobile 

Equipment Refinishing Operations. 
Automotive Coatings Suggested Control Measure 

IV–19 

San Joaquin Valley Unified Air Pollution Control District Rule 4602 – Motor Vehicle and 

Mobile Equipment Coating Operations. 

San Luis Obispo County Air Pollution Control District Rule 423 – Motor Vehicle and 

Mobile Equipment Coating Operations. 

Santa Barbara County Air Pollution Control District Rule 339 – Motor Vehicle and 

Mobile Equipment Coating Operations. 

Shasta County Air Quality Management District Rule 3:25 – Vehicle and Mobile 

Equipment Coating Operations. 

South Coast Air Quality Management District Rule 1151 – Motor Vehicle and Mobile 

Equipment Non-Assembly Line Coating Operations. 

Tehama County Air Pollution Control District Rule 4:35 – Vehicle and Mobile Equipment 

Coating Operations. 

Ventura County Air Pollution Control District Rule 74.18 – Motor Vehicle and Mobile 

Equipment Coating Operations. 

Yolo-Solano Air Quality Management District Rule 2.26 – Motor Vehicle and Mobile 

Equipment Coating Operations. 

Confidential conversations with paint manufacturers regarding proprietary information 

related to product development. 
Automotive Coatings Suggested Control Measure 

V-1

V. AMBIENT AIR QUALITY AND EMISSIONS 

California’s extreme air quality problems require unique strategies for meeting federal 

and State ambient air quality standards. In this chapter, we provide an overview of 

these air quality problems and the need for significant emission reductions from all 

sources of air pollution. We also describe the need for the regulation of automotive 

coatings and provide a summary of the emissions from the coating categories proposed 

for regulation. 

A. AMBIENT AIR QUALITY AND THE NEED FOR EMISSION REDUCTIONS 

VOC emissions contribute to the formation of ozone, and fine particulate matter (PM). 

PM pollution consists of very small liquid and solid particles in the air. PM includes 

particles smaller than 10 microns in size (PM10), and particles smaller than 2.5 microns 

in size (PM2.5). Ozone formation in the lower atmosphere results from a series of 

chemical reactions between VOCs and nitrogen oxides in the presence of sunlight. 

PM10 and PM2.5 pollution result from both direct and indirect emissions. Direct sources 

of PM10 and PM2.5 include emissions from fuel combustion and wind erosion of soil. 

Indirect PM10 and PM2.5 result from the chemical reaction of VOCs, nitrogen oxides, 

sulfur oxides and other chemicals in the atmosphere. Federal and State ambient air 

quality standards for these contaminants have been established to protect California’s 

population from the harmful effects of ozone and PM. 

1. Ozone 

VOCs and nitrogen oxides (NOx) react in the presence of sunlight to form ozone. The 

rate of ozone generation is related closely to the amount and reactivity of VOC 

emissions as well as the amount of NOx emissions available in the atmosphere 

(U.S. EPA, 1996; Seinfeld and Pandis, 1998). Ozone is a colorless gas and the chief 

component of urban smog. It is one of the State’s more persistent air quality problems. 

As shown in Figure V-1, the population-weighted average exposure to ozone 

concentrations above the 1-hour State ambient air quality standard (of 0.09 ppm) in the 

South Coast Air Basin has been declining. However, despite this decline and nearly 

25 years of regulatory efforts, ozone continues to be an important environmental and 

health concern. 

It has been well documented that ozone adversely affects the respiratory functions of 

humans and animals. Human health studies show that short-term exposure to ozone 

injures the lung (ARB, 2000b, 1997; U.S. EPA, 1996). In some animal studies, 

permanent structural changes with long-term exposures to ozone concentrations 

considerably above ambient levels were noted; these changes remain even after 

periods of exposure to clean air (U.S. EPA, 1996). Ozone is a strong irritant that can 

cause constriction of the airways, forcing the respiratory system to work harder in order 

to provide oxygen to the body. Ozone is a powerful oxidant that can damage the 

respiratory tract, causing inflammation and irritation, and induces symptoms such as 

coughing, chest tightness, shortness of breath, and worsening of asthma symptoms 
Automotive Coatings Suggested Control Measure 

V-2

(U.S. EPA, 1996). Ozone in sufficient doses increases the permeability of lung cells, 

rendering them more susceptible to toxins and microorganisms. 

The greatest risk is to those who are more active outdoors during smoggy periods, such 

as children, athletes, and outdoor workers. Exposure to levels of ozone above the 

current ambient air quality standard leads to lung inflammation and lung tissue damage, 

and a reduction in the amount of air inhaled into the lungs. Recent evidence has, for 

the first time, linked the onset of asthma to exposure to elevated ozone levels in 

exercising children (McConnell et al., 2002). 

One requirement of The Children’s Environmental Health Protection Act is that the ARB, 

in consultation with OEHHA, review all of California's health-based ambient air quality 

standards by December 31, 2000 (Senate Bill 25, Escutia, 1999). The purpose of the 

review was to determine whether the standards adequately protect public health, 

especially the health of infants and children. The findings are summarized in the report, 

"Adequacy of California Ambient Air Quality Standards: Children's Environmental Health 

Protection Act" (ARB, 2000b). This report found that the standards for particulate 

matter, ozone, and nitrogen dioxide are inadequate to protect public health. The 

standards for particulate matter (PM10 and sulfates) were found to have the highest 

priority for revision. At the December 9, 2000, Public Meeting, the Board approved the 

report and urged staff to work as expeditiously as possible to present them with 

recommendations due to the serious impact of these pollutants on the health of 

Californians. In March 2005, the State adopted a new 8-hour standard for ozone, and 

retained the existing 1-hour ozone standard. 

Figure V-1 

Population-Weighted Exposure to Ozone Concentrations 

Above the State Ambient Air Quality Standard 

0

5

10

15

20

25

30

35

40

45

1983 1985 1987 1989 1991 1993 1995 1997 1999 2001

Total Annual Exposure 

(pphm-hrs/person)

South Coast
Automotive Coatings Suggested Control Measure 

V-3

Not only does ozone adversely affect human and animal health, but it also affects 

vegetation throughout most of California resulting in reduced yield and quality in 

agricultural crops, disfiguration or unsatisfactory growth in ornamental vegetation, and 

damage to native plants. During the summer, ozone levels are often highest in the 

urban centers in southern California, the San Joaquin Valley, and Sacramento Valley, 

which are adjacent to the principal production areas in the State’s multibillion-dollar 

agricultural industry. ARB studies indicate that ozone pollution damage to crops is 

estimated to cost agriculture over 300 million dollars annually (ARB, 1987). Similarly, 

the U.S. EPA estimates national agricultural losses to exceed 1 billion dollars annually 

(U.S. EPA, 1996). Elevated levels of ozone also cause damage to materials such as 

rubber, paints, fabric, and plastics. 

In 1997, the U.S. EPA promulgated a new 8-hour ozone ambient air quality standard 

(U.S. EPA, 1997). On April 15, 2004, U.S.EPA designated nonattainment areas for the 

new 8-hour ozone standard effective June 15, 2004 (U.S. EPA, 2004a, 2004b). In 

California, many of these areas are already designated nonattainment for the federal 

1-hour standard. New nonattainment areas include a number of rural Sierra foothill 

counties and additional parts of the Sacramento Valley. This action starts the transition 

from the 1-hour standard to the 8-hour standard. The federal 1-hour standard was 

revoked in June 2005. 

SIPs showing how each area will meet the federal 8-hour standard are due by 2007. 

In order to maintain progress towards clean air, the Clean Air Act prohibits backsliding 

on the control program. Since the federal 8-hour standard is more health-protective 

than the federal 1-hour standard, ARB expects that California will need to reduce 

emissions beyond the existing 1-hour SIP targets. All major urban areas in California 

continue to violate the federal and State ozone standards, and need additional emission 

reductions in ozone precursors – such as VOCs – to attain these health-based 

standards. 

2. Fine Particulate Matter 

PM is prevalent in the urban atmosphere (see, for example, Pandis et al., 1992), and 

ambient PM, especially PM2.5 is known to have negative impacts on human health 

(Schwartz et al., 1996; Moolgavkar and Leubeck, 1996). Like ozone, PM can be formed 

via atmospheric oxidation of organic compounds (Finlayson-Pitts and Pitts, 2000). 

According to the results from several recent studies, photochemically derived PM 

(i.e. secondary organic aerosol) could contribute up to 80 percent of the fine particle 

burden observed in severe air pollution episodes (Pandis et al., 1992; Turpin and 

Huntzicker, 1991, 1995). In urban PM, these secondary organic aerosols (SOA) could 

produce effects such as visibility degradation and toxicity (see, for example Atkinson 

and Arey, 1994). 
Automotive Coatings Suggested Control Measure 

V-4

The relative contribution of primary versus secondary PM also varies by region and by 

season. While only limited information is available on how much of the measured PM2.5

organic carbon component is SOAs, available studies suggest that in the South Coast 

on an annual average basis, SOAs may constitute six to 16 percent of PM2.5. In urban 

areas of the San Joaquin Valley during the winter, SOAs may contribute up to an 

average of eight percent of PM2.5 (ARB 2005c). 

Significant advances have been made in the theoretical and the experimental studies of 

the formation of SOAs (Pankow, 1994a, 1994b; Odum et al., 1996; Seinfeld and Pandis, 

1998; Harner and Bidleman, 1998; Kleindienst, et al.,1999; Yu et al., 1999). In addition, 

modeling techniques to determine the amount of ozone, as well as the amount of 

aerosol formed from a VOC have been established (Bowman et al., 1995), and the 

concept similar to maximum incremental reactivity is being applied to quantitatively 

assess the aerosol formation potential of a VOC (i.e. incremental aerosol reactivity) 

(Griffin et al., 1999). Based on the results of these studies, we now know that there is a 

mechanistic linkage between the ozone formation and SOA formation of a VOC. 

Although most organic compounds contribute to ozone formation (Carter, 2000), SOA is 

usually formed from photooxidation of organic compounds with carbon numbers equal 

to seven or more (Grosjean and Seinfeld, 1989; Wang et al.,1992). This observation is 

consistent with the fact that both reactivity and a product’s volatility need to be 

considered for evaluating the aerosol formation potential of a VOC (Odum et al., 1997). 

It has also been shown that aromatic compounds are more likely to participate in the 

formation of SOA than are alkenes (Grosjean, 1992; Pandis et al., 1992). Only 

chemicals which react fast enough in the atmosphere will generate sufficient amounts of 

low volatility products for forming aerosols. 

The federal and State ambient air quality standards for ozone and PM are shown in 

Table V-1. 

Table V-1 - Ambient Air Quality Standards for Ozone, PM10 and PM2.5

Pollutant Averaging Time State Standard National Standard

Ozone 1 hour 0.09 ppm 

(180 μg/m3) ------------ 

8 hour 0.070 ppm 

(137 μg/m3) 

0.08 ppm 

(157 μg/m3) 

PM10

24 hour Annual 

Annual Arithmetic Mean 

50 μg/m3 

20 μg/m3

150 μg/m3 

50 μg/m3

PM2.5

24 hour Annual 

Annual Arithmetic Mean 

--------- 

12 μg/m3

65 μg/m3 

15 μg/m3
Automotive Coatings Suggested Control Measure 

V-5

The U.S. EPA adopted standards for PM2.5 in addition to the PM10 standards (U.S. EPA, 

1997). PM2.5 consists of directly emitted particulate matter, and secondary particulate 

matter such as nitrates, sulfates and condensables that are formed in the atmosphere 

from precursors such as NOx, ammonia, SOx and complex hydrocarbons. Because 

PM2.5 is a subset of PM10, these precursors contribute to PM10 pollution as well. In 

2002, California established an annual average PM2.5 standard of 12 μg/m3, which is 

more health-protective than the federal standard (15 μg/m3). 

U.S. EPA set a February 15, 2004 deadline for states to provide their PM2.5

nonattainment designation recommendations based on ambient monitoring data from 

2000 through 2002. ARB submitted the data and recommendations on 

February 11, 2004. (ARB 2004) U.S. EPA finalized the PM2.5 designations in 

January 2005. Nonattainment areas for the federal PM2.5 standard include the South 

Coast Air Basin and the San Joaquin Valley Air Basin. The PM2.5 SIPs are due by 

April 2008. 

The vast majority of California’s population who live in urban areas breathe unhealthy 

air. Figures V-2, V-3, and V-4 show that unhealthy levels of ozone, PM10, and PM2.5

respectively, are not limited to urban areas, but can be found in nearly every county in 

California. As shown in these maps for 2004, 46 counties are currently designated as 

nonattainment (or nonattainment-transitional, which is a subcategory of nonattainment) 

for the State ozone standard, while 54 counties are designated as nonattainment for the 

State PM10 standard (ARB, 2004). Over 99 percent of California’s population lives in 

areas designated as nonattainment for the State ozone and PM10 standards, a clear 

indication of the magnitude of the air quality problems in California. (ARB, 2005a)

The California Clean Air Act requires districts that have been designated nonattainment 

for the State ambient air quality standards for ozone, carbon monoxide, sulfur dioxide, 

or nitrogen dioxide to prepare and submit plans for attaining and maintaining the 

standards (see Health and Safety Code § 40910 et seq.). In addition, the federal Clean 

Air Act requires that districts designated nonattainment for the federal ambient air 

quality standards prepare SIPs to demonstrate attainment with the federal standards. In 

some of these districts, substantial additional emission reductions will be necessary if 

attainment is to be achieved. In developing their plans, each district determines which 

measures are necessary to include, as well as the specific details of each included 

measure. 

The plans from various districts underscore the increasing role of pollution from areawide sources, including consumer products, architectural coatings, and automotive 

coatings. As emissions from facilities and vehicles are reduced, the area-wide sources 

become a larger part of the inventory, and are included as a more significant area for 

potential reductions of VOC emissions. It is estimated that without additional 

automotive coatings regulations, the inventory for automotive coatings emissions will 

increase due to population growth. 
Automotive Coatings Suggested Control Measure 

V-6

Figure V-2 
Automotive Coatings Suggested Control Measure 

V-7

Figure V-3 
Automotive Coatings Suggested Control Measure 

V-8

Figure V-4 
Automotive Coatings Suggested Control Measure 

V-9

B. ESTIMATED EMISSIONS FROM AUTOMOTIVE COATINGS 

Emissions from automotive coatings are estimated from the survey of automotive 

coatings that the ARB conducted in 2002. In June 2002, the ARB mailed survey 

questionnaires to companies that potentially sold automotive coatings products in 

California in 2001. A total of 17 companies submitted data. The survey collected data 

on the VOC contents of products, which were then used to estimate VOC emissions 

from automotive coatings. Estimated emissions from automotive coatings were 

7,631 tons per year or approximately 20.7 tpd in 2001, based on the survey data. 

These quantities do not include emissions from solvents used for surface preparation 

and cleanup because the 2002 Survey did not collect this data. Table V-2 summarizes 

key findings from the 2002 Survey data. 

The survey also collected information on speciation of VOCs. The quantity of VOC 

ingredients reported in the survey is close to the quantity of VOC emissions calculated 

using sales and VOC content data. This indicates a good correlation between the 

speciated ingredient data and the data that are used to calculate VOC emissions. 

Table V-2 - Summary of the 2002 Automotive Coatings Survey 

Total volume (gallons) 3,685,636 

Volume of water-based/solvent-based coatings (percent) 1/99 

Estimated emissions (tpd) 20.7 

Volume per capita (gallons) 0.11 

Emissions per capita (pounds) 0.44 

Total VOC emissions from stationary sources (including area-wide sources) in California 

were estimated to be about 1,336 tpd in 2001. VOC emissions from automotive 

coatings are estimated to be about 20.7 tpd based on ARB 2002 Survey data (ARB, 

2005b). This represents about two percent of the VOC emissions from stationary 

sources. 

Table V-3 presents the estimated emissions and emission reductions by category based 

on the coating information provided in the 2002 Survey. The emissions estimate 

accounts for the total volume of products sold. Because the 2002 Survey did not collect 

data on solvent usage for surface preparation and cleanup, we are unable to quantify 

the emission reduction from the 25 g/l VOC limit for solvents. However, the emission 

reduction from the 25 g/l VOC limit has already been accounted for in the SCAQMD 

under Rule 1171. Although not quantified, extending the 25 g/l VOC limit for solvents 

statewide would achieve emission reductions outside of the SCAQMD. 
Automotive Coatings Suggested Control Measure 

V-10

Table V-3 - Estimated Emissions and Emission Reductions from 

Automotive Coatings

Estimated 

Emission Baseline 

(tpd) 

Estimated 

Emission 

Reductions (tpd) 

Percent 

Reduction

Adhesion Promoter 0.03 0.02 78 

Clear Coating 2.70 1.61 60 

Color Coating 12.85 8.78 68 

Multi-color Coating 0.00 0.00 0 

Pretreatment Coating 0.36 0.21 59 

Primer 1.78 1.01 56 

Single-stage Coating 2.87 1.68 58 

Temporary Protective 

Coating <0.01 <0.01 43 

Truck Bed Liner 

Coating <0.01 <0.01 0 

Underbody Coating 0.01 <0.01 53 

Uniform Finish 

Coating 0.08 0.05 63 

Any Other Coating 

Type 0.00 0.00 0 

 

Total 20.7 13.4 65 
Automotive Coatings Suggested Control Measure 

V-11

REFERENCES 

Air Resources Board. California Almanac of Emissions and Air Quality, 2005. (ARB, 

2005a) 

Air Resources Board. The 2002 Automotive Coatings Survey Data. June 2005. (ARB, 

2005b) 

Air Resources Board, Staff Report. Effect of Ozone on Vegetation and Possible 

Alternative Ambient Air Quality Standards. March, 1987. (ARB, 1987) 

Air Resources Board. Characterization of Ambient PM10 and PM2.5 in California, 

Technical Report, June 2005. (ARB 2005c) 

Air Resources Board. Letter to Ms. Mary Nichols, United States Environmental 

Protection Agency. ARB Comments on U.S. EPA Proposals for New, National Clean 

Air Goals and Policies. March 11, 1997. (ARB, 1997) 

Air Resources Board. Final Program Environmental Impact Report Suggested Control 

Measure for Architectural Coatings, June 2000. (ARB, 2000a) 

Air Resources Board and Office of Environmental Health Hazard Assessment. 

Adequacy of California Ambient Air Quality Standards: Children's Environmental Health 

Protection Act. December 22, 2000, available at 

http://www.arb.ca.gov/research/aaqs/caaqs/ad-aaqs/ad-aaqs.htm (ARB, 2000b) 

Air Resources Board and Office of Environmental Health Hazard Assessment. Staff 

Report: Public Hearing to Consider Amendments to the Ambient Air Quality Standards 

for Particulate Matter and Sulfates, available at 

http://www.arb.ca.gov/research/aaqs/std-rs/pm-final/pm-final.htm. (ARB, 2002a) 

Air Resources Board. 2004 Area Designations and Maps. Available at 

http://www.arb.ca.gov/desig/adm/adm.htm. (ARB, 2004) 

Air Resources Board. The 2003 California Almanac of Emissions and Air Quality, 

available at http://www.arb.ca.gov/aqd/almanac/almanac03/toc03.htm. (ARB, 2003), 

Atkinson, R. and J. Arey. Atmospheric Chemistry of Gas-phase Polycyclic Aromatic 

Hydrocarbons: Formation of Atmospheric Mutagens. Environmental Health 

Perspectives, 102 (Supplement 4), 117-126. (Atkinson and Arey, 1994) 

Bowman, F.M., Pilinis, C. and Seinfeld, J.H. Ozone and aerosol productivity of reactive 

organics. Atmospheric Environment, 29, 579-589. (Bowman et al., 1995) 

Carter, W.P.L. Documentation of the SAPRC-99 Chemical Mechanism for VOC 

Reactivity Assessment. Final report to California Air Resources Board, Contract No. 92-

329 and No. 95-308. (Carter, 2000) 
Automotive Coatings Suggested Control Measure 

V-12

Finlayson-Pitts, B.J. and J.N. Pitts Jr. Chemistry of the Upper and Lower Atmosphere

Chapter 9, Academic Press, New York. (Finlayson-Pitts and Pitts, 2000) 

Griffin, R.J., Cocker III, D.R., and Seinfeld, J.H. Incremental aerosol reactivity: 

application to aromatic and biogenic hydrocarbons. Enviorn. Sci. Technol., 33, 

2403-2408. (Griffin et al., 1999) 

Grosjean, D. In situ organic aerosol formation during a smog episode: estimated 

production and chemical functionality. Atmospheric Environment, 26A, 953-963. 

(Grosjean, 1992) 

Grosjean, D. and J.H. Seinfeld. Parameterization of the Formation Potential of 

Secondary Organic Aerosols. Atmospheric Environment, 23, 1733-1747. (Grosjean 

and Seinfeld, 1989) 

Harner, T. and Bidleman, T.F. Octanol-air partition coefficient for describing particle/gas 

partitioning of aromatic compounds in urban air. Environ. Sci. Technol., 32, 1494-1502. 

(Harner and Bidleman, 1998) 

Kleindienst, T.E., Smith, D.F., Li, W., Edney, E.O., Driscoll, D.J., Speer, R.E., and 

Weathers, W.S. Secondary organic aerosol formation from the oxidation of aromatic 

hydrocarbons in the presence of dry submicron ammonium sulfate aerosol. 

Atmos. Enviorn., 33, 3669-3681. (Kleindienst et al., 1999) 

McConnell, R., K. Berhane, F. Gilliland, S.J. London, T. Islam, W.J. Gauderman, 

E. Avol, H.G. Margolis, and J.M. Peters. Asthma in exercising children exposed to 

ozone: A cohort Study. Lancet, 359:386-391. (McConnell et al., 2002) 

McConnell, R., K. Berhane, F.Gilliland, J. Molitor, D. Thomas, F. Lurmann, E. Avol, 

W.J. Gauderman, and J.M. Peters. Prospective study of air pollution and bronchitic 

symptoms in children with asthma. Am J Respir Crit Care Med, Vol 168, 790-797 

(McConnell et al., 2003) 

Moolgavkar, S.H. and Leubeck, E.G. A critical review of the evidence on particulate air 

pollution and mortality. Epidemiology, 7, 420-428. (Moolgavkar and Leubeck, 1996) 

Odum, J.R., T. Hoffmann, F. Bowman, D. Collins, R.C. Flagan, and J.H. Seinfeld. 

Gas/Particle Partitioning and Secondary Organic Aerosol Yields. Environmental 

Science & Technology, 30, 2580-2585. (Odum et al., 1996) 

Odum, J.R., T.W.P. Jungkamp, R.J. Griffin, H.J.L. Forstner, R.C. Flagan, and J.H. 

Seinfeld. Aromatics, Reformulated Gasoline, and Atmospheric Organic Aerosol 

Formation. Environmental Science & Technology, 31, 1890-1897. (Odum et al., 1997) 
Automotive Coatings Suggested Control Measure 

V-13

Pandis, S.N., R.A. Harley, G.R. Cass, and J.H. Seinfeld. Secondary Organic Aerosol 

Formation and Transport. Atmospheric Environment, 26A, 2269-2282. (Pandis et al.,

1992) 

Pankow, J.F. An absorption model of gas/particle partitioning of organic compounds in 

the atmosphere. Atmospheric Environment, 28, 185-188. (Pankow, 1994a) 

Pankow, J.F. An absorption model of the gas/aerosol partitioning involved in the 

formation of secondary organic aerosol. Atmospheric Environment, 28, 189-193. 

(Pankow, 1994b) 

Schwartz, J., Dockery, D.W., and Neas, L.M. Is daily mortality associated specifically 

with fine particles. J. Air Waste Manage. Assoc., 46, 927-939. (Schwartz et al., 1996) 

Seinfeld, John H., and Pandis, Spyros N. Atmospheric Chemistry and Physics-From Air 

Pollution to Climate Change. John Wiley & Sons, New York, 1998. (Seinfeld and 

Pandis, 1998) 

Senate Bill 25, Escutia, Stats. 1999, Ch 731 (Senate Bill 25, Escutia, 1999) 

Turpin, B.J. and Huntzicker, J.J. Secondary formation of organic aerosol in the Los 

Angeles basin: a descriptive analysis of organic and elemental carbon concentrations. 

Atmospheric Environment, 25A, 207-215. (Turpin and Huntzicker, 1991) 

Turpin, B.J. and Huntzicker, J.J. Identification of secondary organic aerosol episodes 

and quantitation of primary and secondary organic aerosol concentrations during 

SCAQS. Atmospheric Environment, 29, 3527-3544. (Turpin and Huntzicker,1995) 

United States Environmental Protection Agency. Air Quality Criteria for Ozone and 

Related Photochemical Oxidants. July, 1996, Volume I and III. (U.S. EPA, 1996) 

United States Environmental Protection Agency. National Ambient Air Quality 

Standards for Particulate Matter; Final Rule. Federal Register. July 18, 1997, 

Volume 62, Number 138, available at 

http://www.epa.gov/ttncaaa1/t1/fr_notices/pmnaaqs.pdf (U.S. EPA, 1997) 

United States Environmental Protection Agency. Final Rule to Implement the 8-Hour 

Ozone National Ambient Air Quality Standard – Phase 1, Federal Register: 69 23951 

(April 30, 2004), available at 

http://www.epa.gov/ozonedesignations/finalrule.pdf (U.S. EPA, 2004a) 

United States Environmental Protection Agency. Air Quality Designations and 

Classifications for the 8-Hour Ozone National Ambient Air Quality Standards; Early 

Action Compact Areas with Deferred Effective Dates. Federal Register: April 30, 2004, 

Volume 69, Number 84, Rules and Regulations, Page 23857-23951, available at 

http://www.epa.gov/fedrgstr/EPA-AIR/2004/April/Day-30/a9152.htm (U.S. EPA, 2004b) 
Automotive Coatings Suggested Control Measure 

V-14

Yu J., Cocker III, D.R., Griffin, R.J., Flagan, R.C., and Seinfeld, J.H. Gas-Phase Ozone 

Oxidation of Monoterpenes: Gaseous and Particulate Products. J. Atmos. Chem., 34, 

207-258. (Yu et al., 1999) 

Wang, S.C., S.E. Paulson, D. Grosjean, R.C. Flagan, and J.H. Seinfeld. Aerosol 

Formation and Growth in Atmospheric Organic/NOx Systems-I. Outdoor Smog 

Chamber Studies of C7- and C8-Hydrocabrons. Atmospheric Environment, 26A, 

403-420. (Wang et al., 1992) 
Automotive Coatings Suggested Control Measure 

VI-1 

VI. ENVIRONMENTAL IMPACTS 

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

to evaluate the potential adverse environmental impacts of proposed projects. The 

intent of the proposed SCM is to protect the public health by reducing the public’s 

exposure to potentially harmful emissions of VOCs. An additional consideration is the 

impact that the proposed SCM may have on the environment. Based on available 

information, the ARB has determined that no significant adverse environmental impacts 

should occur as a result of districts adopting the proposed SCM. This chapter 

summarizes the potential impacts that the proposed SCM may have on wastewater 

treatment, air quality, and hazardous waste disposal. 

A. ANALYSIS OF REASONABLY FORESEEABLE ENVIRONMENTAL IMPACTS 

OF THE METHODS OF COMPLIANCE 

1. Potential Wastewater Impacts 

Wastewater is regulated in California by the Water Resources Control Board. In 

California, wastewater containing hazardous substances is not allowed to be disposed 

of in the sewer system. Discharge of wastewater from automotive coatings facilities to a 

sanitary sewer can result in the solids portion of the coating accumulating in sewage 

treatment sludge, preventing its beneficial use. Some contaminants “pass through” and 

are discharged to lakes, rivers, bays, and oceans. Although the practice is illegal, 

facility operators may introduce hazardous substances to the sewer system by washing 

down areas containing over spray and allowing that water to enter the sewer system. 

Most waste paint is a result of over spray and is collected primarily on the paint booth 

exhaust filter or in floor sweepings. Coating facilities may also generate paintcontaminated disposable rags, masking tape and paper, disposable mixing cups and 

sticks, and disposable paint strainers. The dry paint related wastes are typically 

landfilled. The reduction of VOC content will reduce the amount of VOCs landfilled. 

The SCM is also not expected to adversely impact water quality. First, use of exempt 

solvents (solvents not considered to be VOCs, such as acetone and PCBTF) is 

expected to result in equivalent or fewer water quality impacts than currently used 

solvents (such as toluene, xylenes, mineral spirits, and methyl ethyl ketone), since the 

exempt solvents are less toxic. Second, because currently available compliant color 

coatings are already using water-based technology, no additional water quality impacts 

from future compliant water-based coatings are expected, although use of water-based 

coatings is expected to increase. The current manufacturing and clean-up practices 

associated with water-based coatings are not expected to change as a result of the 

SCM. Lastly, the SCM is not expected to promote the use of compliant coatings 

formulated with hazardous solvents that could create adverse water quality impacts. 
Automotive Coatings Suggested Control Measure 

VI-2 

Tertiary-Butyl acetate (CH3COOC(CH3)3) is the common name for acetic acid, 1,1-

dimethylethyl ester. Other names include t-butyl acetate, tert-butyl acetate, and 

informally, TBAC or TBAcTM. It is an effective viscosity reducer with an intermediate 

flash point and vapor pressure. Industrially, it can be used in a variety of coatings. ARB 

staff has recommended that the districts consider exempting TBAC from their VOC 

definitions. It is anticipated that this exemption will be granted, by some if not all 

districts, allowing TBAC to be substituted for non-exempt VOCs of higher reactivity 

when reformulating automotive coatings and potentially cleaning solvents. In ARB’s 

Draft Environmental Impact Assessment of Tertiary-Butyl Acetate (ARB, 2005), the staff 

determined that in automotive coating products, the compounds most likely to be 

replaced by TBAC are xylenes, toluene, and methyl ethyl ketone (MEK). 

(see http://www.arb.ca.gov/research/reactivity/tbac1.pdf) 

ARB’s assessment of TBAC also examined the potential impact on water of an 

increased use of TBAC. Based on information provided by the Lyondell Chemical 

Company and a literature search, the potential risk to surface waters of California is 

expected to be low, assuming the material is stored, used, and disposed of in 

accordance with hazardous materials regulations. 

2. Air Quality Impacts 

There are two basic kinds of air emissions from activities conducted at automotive 

refinishing facilities: VOCs and particulates (solids). Particulates make up the solid part 

of the paint that contains the binder, pigment, and other additives. To control 

particulates, painting should be performed inside a paint spray booth equipped with 

paint arrestors (filters) and a ventilation system sufficient to draw the air from the booth 

through the filters. Paint booth air emissions controls are limited to collection of paint 

particulates. Generally, no control of VOCs from the air exhausted from the paint booth 

is required or practiced. 

The adoption and implementation of the proposed SCM on a statewide basis is 

expected to produce substantial, long-term, VOC emission reductions. VOCs are 

regulated because they contribute to the formation of both ozone and PM10. Numerous 

VOCs have also been identified as toxic air contaminants and are regulated through the 

ARB’s Toxic Air Contaminant (TAC) Control Program. If the proposed VOC content 

limits in the SCM were implemented statewide, emissions would be reduced by 

approximately 13 tons per day beginning in 2009, a net air quality benefit. 

Based on ARB’s 2002 Survey, xylenes, toluene, and MEK account for approximately 

27.5 percent of the VOCs used in automotive coatings. As previously mentioned, 

ARB’s Draft Environmental Impact Assessment of Tertiary-Butyl Acetate indicates that 

these compounds are the most likely VOCs to be replaced by the use of TBAC. 

Assuming a replacement of 25 to 50 percent of these three VOCs, TBAC substitution 

would result in a potential use of TBAC of 1.4 to 2.9 tpd. However, color coatings 

account for about 63 percent of the total VOC emissions and about 50 percent of the 
Automotive Coatings Suggested Control Measure 

VI-3 

xylenes, toluene, and MEK emissions from automotive coatings. If, as expected, 

coating manufacturers choose to meet the VOC limit for color coatings with water-borne 

coatings, the potential emissions of TBAC would be reduced to about 1.5 tpd (assuming 

50 percent substitution for xylenes, toluene and MEK). 

The California Department of Industrial Relations, Division of Occupational Safety and 

Health Administration (Cal/OSHA) regulates the concentration of many TACs in the 

workplace environment. To protect worker safety, Cal/OSHA has established a 

permissible exposure limit (PEL) for many of these compounds (the PEL is the 

maximum, 8-hour, time-weighted average concentration for occupational exposure). 

The current Cal/OSHA PEL for TBAC is 200 ppm for an 8 hour time-weighted average. 

If TBAC is substituted for xylenes, toluene, and MEK, the worker’s TBAC exposure 

would not be expected to exceed the current workplace exposure standard. 

Workers in the automotive coatings industry are exposed to isocyanates, found in 

polyurethane sealers and some primers. Paper masks offer no protection against 

isocyanate exposure, only the most protective respirators should be used for situations 

involving exposures to isocyanates that have poor warning properties, are potent 

sensitizers, or may be carcinogenic. These respirators include: 

 any self-contained breathing apparatus with a full face piece operated in a 

pressure-demand or other positive-pressure mode, and 

 any supplied-air respirator with a full face piece operated in a pressure-demand 

or other positive-pressure mode in combination with an auxiliary self-contained 

breathing apparatus operated in a pressure-demand or other positive-pressure 

mode. 

A complete respiratory protection program should include: 

1) regular training and medical evaluation of personnel, 

2) fit testing, 

3) periodic environmental monitoring, 

4) periodic maintenance, inspection, and cleaning of equipment 

5) proper storage of equipment, and 

6) written standard operating procedures governing the selection and use of 

respirators. The program should be evaluated regularly. 

Some manufacturers and districts have expressed a concern over the possible 

increased worker exposure to glycol ethers and TBAC upon reformulation to lower VOC 

automotive coatings and cleaning solvents. Because of the history of isocyanate 
Automotive Coatings Suggested Control Measure 

VI-4 

exposure in the automotive refinish industry, available personal protection systems are 

sufficient to protect against worker exposure to glycol ethers and TBAC. 

In ARB’s Draft Environmental Impact Assessment of Tertiary-Butyl Acetate, it is 

estimated that a large body shop uses 3,000 gallons of automotive coatings per year, 

and assumes that the average amount of toluene, xylenes and MEK present in 

automotive coatings is 50 percent of the total VOC content of the coating. Under this 

worst-case scenario, a large automotive refinishing facility would emit more than 

6,500 pounds per year of TBAC if TBAC was substituted for toluene, xylenes, and MEK 

on a one-for-one basis. However, the SCAQMD has recently indicated that the largest 

automotive refinishing facility in their district uses no more than 1,100 gallons of 

coatings per year. Based on ARB’s 2002 Automotive Survey, xylenes, toluene, and 

MEK account for approximately 27.5 percent of the VOCs used in automotive coatings. 

Under this scenario, which we believe most accurately defines the worst-case scenario 

for a large automotive refinishing facility, the amount of TBAC emitted annually would 

be approximately 1,350 pounds if TBAC was substituted on a one-for-one basis for 

toluene, xylenes and MEK. 

The TBAC analysis also assesses the potential cancer risk from TBAC emissions from 

automotive refinishing facilities. The highest estimated cancer risk for a facility emitting 

2,692 pounds per year of TBAC was 11 excess lifetime cancer cases per million. 

Based on the updated emission estimate for a large facility and the substitution 

assumption of 50 percent, we estimate the maximum potential risk to be 2.8 excess 

lifetime cancer cases per million. However, if the VOC limit for color coatings is met 

with water-borne coatings, the potential cancer risk would be reduced to about 1.4 in a 

million. 

Staff also analyzed the potential for other air quality impacts. During past regulatory 

efforts affecting coatings, industry representatives have alleged that the use of low VOC 

coatings may create certain significant adverse air quality impacts. While similar 

concerns have not been raised during the development of this SCM, we examined the 

following issues in order to determine if any of these concerns were applicable to 

automotive coatings: 

 Will the use of lower VOC automotive coatings result in a thicker film coating?

No. In previous rulemakings on coatings, some industry representatives contended 

that lower VOC coatings are formulated with high solids contents and were therefore 

difficult to handle during application, tending to produce a thick film when applied. A 

thicker film supposedly indicates that a smaller surface area is covered with a given 

amount of material, thereby increasing VOC emissions per unit area covered as 

compared to higher VOC coatings. Although high solids, low VOC coatings are 

being used, the recommended film thickness for these coatings is similar to that for 

higher VOC coatings. Thus, a lower VOC coating would cover the same or larger 

surface area than a higher VOC coating. 
Automotive Coatings Suggested Control Measure 

VI-5 

 Will the use of lower VOC automotive coatings result in illegal thinning of 

the product?

Excessive thinning is not expected to be a problem because many of the 

coatings already comply with the SCM limits. Additionally, the VOC limit for color 

coatings is expected to be met with the use of water-borne formulations. Even if 

some thinning occurs, thinning would likely be done with water or exempt 

solvents. As a result, the potential for excessive thinning is minor and concerns 

about significant adverse air quality impacts are unfounded. 

 Will the use of lower VOC automotive coatings require additional priming 

for proper adhesion to the substrate?

No. Automotive coatings primers are currently solvent-borne coatings, and many 

already meet the VOC limits in the proposed SCM. Manufacturers’ data show 

that substrate preparation for low VOC color coatings is similar to substrate 

preparation for higher VOC color coatings. No instances of poor adhesion 

between primers and low VOC color coatings are expected. 

 Will the use of lower VOC automotive coatings require the use of more 

topcoats?

In previous rulemakings on coatings, some industry representatives have 

claimed that the proposed lower VOC limits would yield products that provide 

inferior coverage, resulting in the use of more coatings to provide the same 

coverage as their higher VOC counterparts. This is not the case with automotive 

coatings. In fact, some low VOC water-borne automotive coatings currently sold 

and used in the United States provide greater coverage than solvent-borne 

automotive coatings. Manufacturers and current users of water-borne 

automotive coatings have indicated that coverage is superior to that of solventborne coatings, and therefore do not require the application of additional coats to 

achieve the necessary coverage. 

 Will the use of lower VOC automotive coatings require more frequent 

recoating? 

No. Water-borne automotive coatings have been used successfully by the 

majority of the automobile manufacturers for several years; they are also used in 

manufacturer’s vehicle processing centers, where cars are touched up prior to 

distribution in the United States. Data from the automotive coatings sector do not 

support the claim that lower VOC automotive coatings require more frequent 

recoating. 
Automotive Coatings Suggested Control Measure 

VI-6 

 Will the use of lower VOC automotive coatings result in product 

substitution by the end-users? 

There are currently available low VOC automotive coatings with performance 

characteristics comparable to higher VOC automotive coatings, therefore it is not 

anticipated that spray technicians will substitute a product from a higher VOC 

category. Typically, manufacturers market coatings as a system and will not 

warranty the products’ performance if the user deviates from the recommended 

usage. Additionally, the products within each automotive coatings category are 

specific to certain applications, and do not lend themselves to use in another 

coating category. 

 Will the use of lower VOC automotive coatings result in coatings with 

higher reactivity?

Using the Maximum Incremental Reactivity (MIR) scale as the basis for 

comparing reactivities of VOCs it is true that, on a per gram basis, some VOCs 

used in water-borne coatings are more reactive than some VOCs used in 

solvent-borne coatings (Carter, 1999). For example, using the MIR scale as a 

basis, a typical VOC used in water-borne coatings, such as propylene glycol, is 

two to three times more reactive than a typical mineral spirits. However, less 

reactive solvents such as mineral spirits are not extensively used in automotive 

coatings. Automotive coatings tend to have solvents with higher reactivity such 

as xylenes and toluene. The reactivity of propylene glycol is approximately onethird the reactivity, on a gram for gram basis, of xylenes and toluene. 

Additionally, it is anticipated that manufacturers will incorporate the use of water 

and exempt solvents when formulating to meet the lower VOC limits of the 

proposed SCM. We have concluded, based on this information, that the total 

reactivity of the lower VOC automotive coatings will be less than the reactivity of 

the higher VOC automotive coatings.

 

3. Potential Hazardous Waste Impacts 

The Department of Toxic Substances Control (DTSC) is the lead agency in California 

for hazardous waste management. DTSC enforces the California's Hazardous Waste 

Control laws, issues permits to hazardous waste facilities, and mitigates contaminated 

hazardous waste sites. In California, all hazardous waste must be disposed of at a 

facility that is registered with DTSC. Under these programs, automotive coatings may 

be classified as hazardous waste if they contain substances listed as toxic or if they 

meet other hazard criteria. 

Many counties in California operate a Small Business Waste Program, providing lowcost programs for small businesses that qualify as Conditionally Exempt Small Quantity 

Generators (CESQG). In order to qualify as a CESQG, as defined in the California 

Health and Safety Code, section 25218.1, and the Code of Federal Regulations (40 
Automotive Coatings Suggested Control Measure 

VI-7 

CFR 261.5), the business must generate no more than 100 kilograms (220 pounds or 

approximately 27 gallons) of hazardous waste, or one kilogram (2.2 pounds) of 

extremely hazardous waste. The small business considered a CESQG must also store 

less than 2,200 pounds of all kinds of hazardous waste at any time. In order to 

encourage businesses to participate in their programs, many cities help subsidize 

disposal costs. Often times the disposal costs are tax deductible and the long-term 

liability of the materials is taken over by the county or city agency. 

It is difficult to determine the amount of liquid waste paint generated from automotive 

coatings since the waste paint is usually mixed with waste paint thinner. Waste paint 

thinner is usually generated when paint guns and other paint equipment are cleaned. 

The waste paint thinner is usually collected in a 55 gallon drum and is mixed with waste 

paint. In almost all cases, waste coatings in liquid form must be managed as hazardous 

waste. The reduction of solvents in automotive coatings is not expected to result in 

non-hazardous liquid waste coatings. Solvent-based automotive coatings waste will still 

be classified as hazardous due to ignitability characteristics. 

It is anticipated that resin manufacturers and coatings formulators will continue the trend 

of using less hazardous solvents such as Oxsol 100, and propylene glycol in their 

compliant coatings. It is expected that future compliant coatings will contain less 

hazardous materials, or nonhazardous materials, as compared to conventional 

coatings, resulting in a net benefit. Therefore, hazard impacts associated with the 

proposed SCM will be negligible. 

Coating facilities that have filter-type paint booths also generate paint booth exhaust 

filters. Paint booth exhaust filters are changed every few weeks to few months 

depending on the amount of painting being done. Waste paint filters need to be tested 

for ignitability and toxicity characteristics. The “Toxicity Characteristic Leaching 

Procedure” (TCLP) is used to determine if the filters contain toxic materials. It is rare 

that a paint booth filter will meet the definition of hazardous waste assuming that only 

typical automotive coatings have been used. Waste filters are typically thrown into the 

trash for disposal at the sanitary landfill. It is not anticipated that the proposed SCM will 

impact the quantity or toxicity of the paint booth exhaust filters currently being landfilled. 

4. Reasonably Foreseeable Feasible Mitigation Measures 

ARB is required to do an analysis of reasonably foreseeable mitigation measures. We 

have concluded that no significant adverse environmental impacts should occur from 

implementation of the proposed SCM. As a result, no mitigation measures would be 

necessary. 
Automotive Coatings Suggested Control Measure 

VI-8 

5. Alternatives to the Proposed SCM 

As alternatives to the proposed SCM, ARB staff evaluated taking no action and delaying 

the effective date. ARB staff determined that neither of these alternatives would be as 

effective at reducing VOC emissions from automotive coatings activities as the 

proposed SCM. The no action alternative was rejected because it would not achieve 

emission reductions necessary to attain the State and federal ambient air quality 

standards. The delayed effective date alternative was rejected because compliant 

coatings are currently available or will be available before the proposed effective date of 

January 1, 2009. 

B. COMMUNITY HEALTH AND ENVIRONMENTAL JUSTICE 

The ARB is committed to evaluating community impacts of proposed regulations, 

including environmental justice concerns. ARB's goal is to reduce or eliminate any 

disproportionate impacts of air pollution on low-income and minority populations so that 

all individuals in California can live, work, and play in a healthful environment. The 

proposed SCM is not expected to result in significant negative impacts in any 

community. The result of the proposed SCM will be reduced exposure to VOCs and 

toxic air contaminants (e.g., xylenes, toluene, and MEK) for California communities, 

including those with large populations of low-income and minority residents. 

As part of our Community Health and Environmental Justice Programs, we assess and 

reduce the localized impacts of pollution from multiple sources. The cumulative, multipollutant focus of this important program compels us to take a more comprehensive, 

integrated approach to defining the ARB’s overall control strategy. 

Many communities in California are composed of a mix of residential, commercial, and 

industrial sites. During and after World War II, these areas experienced tremendous 

development due to rapid population growth and capital investment in military and 

industrial complexes. This rapid growth and development did not allow for proper 

residential planning, therefore, residential areas and industrial zones may be integrated. 

As a result, parts of these communities exhibit an unhealthy mixture of homes, schools, 

and environmentally hazardous facilities. Homes within these neighborhoods may be in 

close proximity to multiple sources of air pollution, such as businesses, industries, 

storage facilities, and freeways. 

Automotive refinishing facilities, whose operations produce VOCs, are often among 

those types of small businesses located in low-income, minority communities. The 

higher than average incidence of asthma and other respiratory illnesses in children 

living in these communities may be related to poor air quality (U.S. EPA, 2000). 
Automotive Coatings Suggested Control Measure 

VI-9 

REFERENCES 

Air Resources Board, Staff Report. Draft Environmental Impact Assessment of TertiaryButyl Acetate. June, 2005 (ARB, 2005) 

United States Environmental Protection Agency Region 9. Fact Sheet: Barrio Logan 

Environmental Justice Project News Release 11/13/2000. (U.S. EPA 2000) 
Automotive Coatings Suggested Control Measure 

VII-1 

VII. ECONOMIC IMPACTS 

A. INTRODUCTION 

This chapter discusses the economic impacts ARB staff anticipates from statewide 

implementation of the SCM. In general, economic impact analyses are inherently 

imprecise, especially given the unpredictable behavior of companies in a highly 

competitive market. While we quantified the economic impacts to the extent feasible, 

some projections are necessarily qualitative or semi-quantitative and based on general 

observations about the automotive refinishing industry. This analysis, therefore, serves 

to provide a general picture of the economic impacts that typical businesses subject to 

the proposed SCM might encounter; we recognize that individual companies within 

each district may experience impacts different than those projected in this analysis. 

The overall projected impacts are summarized first, followed by a detailed discussion of 

specific aspects of the economic impacts in the sections listed below: 

B) Annual Costs and the Cost-Effectiveness of the Proposed SCM; 

C) Economic Impacts on California Businesses; 

D) Potential Impacts on California State or Local Agencies; and 

E) Potential Impacts on California Consumers. 

It is important to note that ARB staff conducted the economic impacts analysis, even 

though the analysis is not required under the Administrative Procedure Act for a SCM, 

such as the staff’s proposal. The analysis uses virtually the same methodology adopted 

by the Board in approving the 2000 Architectural Coatings SCM (ARB, 2000) and 

consumer product rulemakings since 1990 (ARB; 1990; ARB, 1991; ARB, 1997; ARB, 

1999). 

1. Summary of Economic Impact 

Our analysis shows that the cost-effectiveness of the proposed limits is similar to the 

cost-effectiveness of the existing consumer product regulations (Phase I-II and MidTerm Measures I-II), as well as other existing ARB regulatory programs. We estimate 

the overall cost-effectiveness of the proposed SCM to be $1.43 per pound of VOC 

reduced in current dollars. This cost-effectiveness is comparable in magnitude to that 

reported for other ARB consumer product regulations and measures, which generally 

have fallen within a range of no cost to about $6.90 per pound of VOC reduced. The 

architectural coatings SCM had an average cost-effectiveness of $3.20 per pound of 

VOC reduced. 

In this analysis, we considered the impact to manufacturers of automotive coatings and 

automotive refinishing facilities. Overall, most automotive refinishing facilities and 

coatings manufacturers would be able to absorb the cost of the proposed SCM with no 
Automotive Coatings Suggested Control Measure 

VII-2 

significant adverse impacts on their profitability. This finding is indicated by the staff’s 

estimated change in “return on owner’s equity” (ROE) analysis. The analysis found an 

average decrease in ROE of about 0.07 percent for coating manufacturers, and 

15 percent for automotive refinishing facilities. If all costs of the proposed SCM are 

absorbed by automotive refinishing facilities, the decrease in ROE exceeds the 

10 percent threshold typically used to indicate a potential for adverse impacts on 

profitability. However, we expect the costs incurred by manufacturers and automotive 

refinishing facilities to be passed on to consumers. If the entire cost of the proposed 

SCM were passed on to consumers, the average price for a repair would increase by 

about $11, which represents an increase of about 0.5% for a $2,200 repair. Because 

we expect most businesses to pass on their costs to consumers, we do not expect a 

noticeable change in employment; business creation, elimination or expansion; and 

business competitiveness in California. We also found no significant adverse fiscal 

impacts on any local or State agencies. 

To project the maximum potential impacts on consumers, we assume the opposite 

scenario relative to the business impacts analysis. That is, rather than determining 

whether businesses can absorb all costs incurred and not have a significant impact on 

their profitability, we assume for the consumer impacts analysis that coating 

manufacturers and automotive refinishing facilities are able to pass on all the costs to 

the consumers by raising the price of refinishing a vehicle. If the cost were passed on 

to consumers, most of the impact would probably be in the form of increased insurance 

premiums. For the purpose of this analysis, we assume that only consumers who have 

their vehicle repaired or refinished are impacted. With this assumption, we project an 

average cost increase of about $11 per vehicle repaired or refinished. 

2. General Approach for Cost Estimation 

The economic impacts analysis consists of several parts. First, we calculated the total 

annual costs of the proposal. An analysis was conducted to determine the impacts on 

the annual costs to manufacturers based on raw material costs of typical complying and 

noncomplying coatings. In addition, we estimated the cost to market and distribute 

coatings that comply with the limits of the proposed SCM based on discussions with 

manufacturers. Because the 2002 Survey did not collect data on cleaning solvents, the 

analysis does not include the potential costs of complying with the proposed VOC limit 

for solvents. However, solvent manufacturers marketing in the SCAQMD already 

incurred the costs to develop 25 g/l cleaning solvents because the limit is already in 

effect the SCAQMD. We then estimated the annual cost to automotive refinishing 

facilities to use complying coatings without loss of production. The projected annual 

costs then become the inputs for determining the three main outputs of the analysis: the 

cost-effectiveness, the business impacts, and the consumer impacts. 

The cost-effectiveness is presented to compare the proposal’s cost efficiency in 

reducing a pound of VOC relative to the cost-efficiency of other rules and control 

measures adopted by the districts and the ARB. The business impact analysis employs 

two scenarios under which all costs incurred to meet the proposal are absorbed by the 
Automotive Coatings Suggested Control Measure 

VII-3 

coating manufacturers, and then by assuming that all costs incurred by both the 

manufacturers and automotive refinishing facilities are absorbed by the automotive 

refinishing facilities. On the other hand, the consumer impact analysis operates under 

the hypothetical regime where all costs incurred to meet the proposal are passed on to 

the consumers in the form of increased cost to refinish a vehicle. These three parts of 

the analysis represent the boundaries of expected impacts, with the actual regulatory 

impacts from the proposal probably falling somewhere between these three extremes 

(i.e., some costs are absorbed by the manufacturer, some costs are absorbed by the 

automotive refinishing facilities, with the remaining costs passed on to consumers). 

Thus, the actual business impacts and price increases will likely be less than predicted 

in this analysis. 

Distributors of automotive coatings may also incur some costs if those costs cannot be 

passed on to the automotive refinishing facilities because of competitive pressures. 

Potential cost to these operations might include some cost sharing between the 

manufacturer and distributor to transition customers to new products such as waterborne color coats. Based on discussions with industry representatives, it appears that 

cost sharing arrangements can vary widely and are not available to all automotive 

refinishing facilities. Thus, staff is unable to assess the potential impacts to distributors. 

However, because all coating and solvent manufacturers are subject to the same VOC 

limits, any impacts to distributors should be similar regardless of what manufacturer’s 

products they market. 

3. Sources and Treatment of Cost Data 

The cost analysis relied on various sources of information. For cost information specific 

to manufacturers, we relied on estimates based on discussions with manufacturers of 

automotive coatings. Most manufacturers already market coatings that would comply 

with the limits in the SCM, and the estimated cost was primarily based on the cost for all 

manufacturers to market and distribute those coatings in California (Taylor, 2005). 

Compliant cleaning solvents are also currently marketed in California. 

For industry wide data on automotive refinishing facilities, we relied on the U.S. Census 

Bureau, industry organizations, the SCAQMD, and information from third party sources. 

To estimate the cost of equipment, training, and other services automotive refinishing 

facilities may need to comply with the SCM and maintain sufficient levels of production, 

we relied on discussions with distributors of automotive coatings, spray booth 

manufacturers, air movement manufacturers, and automotive refinishing facility 

operators (US Census, 2005; Henderson, 2005; SCAQMD, 2005; Taylor, 2005; Elders, 

2005; Ortiz, 2005; Hagan, 2005; Mac, 2005; Phillips, 2005). 

We assumed that operating and maintenance costs for new equipment and waste 

disposal for water-borne color coatings is five percent of the equipment costs. 
Automotive Coatings Suggested Control Measure 

VII-4 

B. ANNUAL COSTS AND THE COST-EFFECTIVENESS (C.E.) OF THE 

PROPOSED SCM 

1. Introduction 

In the following analysis, we present the anticipated annual costs and cost-effectiveness 

of the proposed SCM. Determining the proposal’s cost-effectiveness allows us to 

compare the efficiency of the proposed SCM in reducing a pound of VOC relative to 

other existing regulatory programs. To do this, we applied a well-established 

methodology for converting compliance costs, both nonrecurring and recurring costs, to 

an annual basis. We then report the ratio of the annual costs to the annual emission 

reductions in terms of “dollars (to be) spent per pound of VOC reduced.” To put the 

proposal’s cost-effectiveness into proper perspective, we compare the results of our 

analysis with the cost-effectiveness of other ARB regulations and control measures. 

2. Methodology 

As noted previously, the cost-effectiveness of a regulation is generally defined as the 

ratio of total dollars to be spent to comply with the regulation (as an annual cost) to the 

mass reduction of the pollutant(s) to be achieved by complying with that regulation (in 

annual pounds). Annual costs include annualized nonrecurring costs (e.g., total 

research and development (R&D), product and consumer testing, equipment 

purchases/modifications, one-time distributional/marketing changes, etc.) and annual 

recurring costs (e.g., increases or decreases in raw material costs, labeling, packaging, 

recordkeeping & reporting, etc.). Thus, the cost-effectiveness is calculated according to 

the following general equations: 

Cost-Effectiveness = Annualized Nonrecurring Costs + Annual Recurring Costs 

Annual Emission reductions 

where, 

Annualized Nonrecurring Costs = CRF x ∑ (Nonrecurring Costs)

Annual Recurring Costs = Raw Material Costs + Non Raw Material Costs 

The CRF is calculated as follows: 

 CRF

i i

i

n

= n

+

+ −

( )

( )

1

1 1

 

where, 

 CRF = Capital Recovery Factor 

 I = discount interest rate in real terms (assumed to be four 

percent) 

 n = project horizon or useful life of equipment 
Automotive Coatings Suggested Control Measure 

VII-5 

As shown above, we annualized the nonrecurring costs (i.e., one-time fixed costs such 

as R&D, equipment purchases, etc.) using the Capital Recovery Method, which is the 

recommended approach under California Environmental Protection Agency (Cal/EPA) 

guidelines. Using this method, we multiply the estimated total fixed costs to comply with 

each proposed limit by the Capital Recovery Factor (CRF) to convert these fixed costs 

into discounted, equal annual payments in current dollars over the selected project 

horizon (i.e., the projected useful life of the investment) (Cal/EPA, 1996). We then sum 

the annualized fixed costs with the annual recurring costs and divide that sum by the 

annual emission reductions to calculate the cost-effectiveness of each limit. 

3. Assumptions 

There are a number of assumptions made to determine the impact to automotive 

refinishing facilities. Due to the number and unique needs of automotive refinishing 

facilities in California, some of these businesses will incur costs which will be different 

than what we have estimated in this analysis. 

In determining the impact to automotive refinishing facilities as a worst case scenario, 

staff assumed that every facility will need to apply water-borne color coatings. 

Compliant color coatings may be developed with exempt solvents that would require 

little modification to existing equipment in automotive refinishing facilities. There are 

also some automotive refinishing facilities that only use single stage coatings which we 

expect to remain solvent-borne. We don’t expect these facilities to be impacted by the 

SCM. 

Coating manufacturers recommend additional air movement equipment to dry waterborne color coatings quickly. Heating equipment was suggested as an option that 

would allow automotive refinishing facilities to improve production levels. There are a 

number of solutions available to automotive refinishing facilities to meet air movement 

needs. These range from small hand held devices to fully integrated air movement 

systems. Although each automotive refinishing facility will evaluate the costs and 

benefits of air movement systems, we assumed that automotive refinishing facilities with 

high annual revenues will generally install the more expensive upgrades to their spray 

booths to maintain current production levels. We also assumed that automotive 

refinishing facilities with low annual revenues will install less expensive equipment to 

save on overall cost. The specific assumptions are discussed in Appendix C. 

ARB staff estimated there are about 4,100 automotive refinishing facilities in California. 

Staff estimated the average gross annual revenue for an automotive refinishing facility 

to be about one million dollars (Taylor, 2005). 

We assumed that 57 percent of all automotive refinishing facilities have a single spray 

booth. In the absence of industry wide statistics on the number of spray booths for 

automotive refinishing facilities in California, we used data from the SCAQMD to 

estimate the number of facilities with multiple booths (SCAQMD, 2005). Although there 

may be facilities in all revenue categories that have a single spray booth, staff assumed 
Automotive Coatings Suggested Control Measure 

VII-6 

that only automotive refinishing facilities with annual revenue of less than one million 

dollars have a single spray booth. We also assumed that 25 percent of the booths have 

heating equipment, based on data from the SCAQMD. We assumed that all facilities 

with greater than $2.5 million annual revenue have heating equipment, and all facilities 

with less than one million dollars annual revenue have no heating equipment. 

ARB staff conducted an analysis of raw material costs to manufacturers based on 

typical ingredients found in complying and noncomplying coatings. Staff determined 

that the raw material costs of products that comply with the limits of the proposed SCM 

are generally less than the raw material costs of products that do not comply with the 

proposed SCM. To be conservative, staff assumed there would be no cost savings to 

manufacturers or to automotive refinishing facilities from raw material prices. 

We also assumed that some small coating manufacturers would cease to sell products 

in California. According to the 2002 Automotive Coatings Survey, there were 

17 manufacturers that sold automotive coatings in California in 2001. Ten of these 

manufacturers account for about 98 percent of the total volume of automotive coatings 

sold in California in 2001. We assume that the remaining seven manufacturers that sell 

very low volumes of coatings in California will cease to sell their products here due to 

the cost of complying with the SCM. 

We also assumed a project horizon of five years and a real discount rate of four percent 

throughout the project horizon. The five year project horizon is appropriate because 

that is the generally accepted project horizon used in cost analyses involving chemical 

processing industries. In addition, five years is the number of years for a project horizon 

generally recommended by Cal/EPA when conducting a cost-effectiveness analysis 

(Cal/EPA, 1996, supra). With regard to the discount rate, Cal/EPA recommends two 

percent plus the current yield for a U.S. Treasury note of similar maturity to the project 

horizon (Id.), which in recent years has been about four percent (CNN, 2005). We also 

assumed a two percent inflation rate. 

4. Results 

The cost-effectiveness of the SCM is estimated to be $1.43 per pound of VOC reduced, 

which compares favorably with the cost-effectiveness of measures such as the 2000 

Architectural Coatings SCM ($3.20 per pound of VOC reduced). The average annual 

cost to automotive coating and solvent manufacturers is estimated to be about 

$320,000. The average annual cost to automotive refinishing facilities is estimated to 

be about $3,400. The total annualized cost to comply with the proposed SCM is 

estimated to be about $14 million. 
Automotive Coatings Suggested Control Measure 

VII-7 

C. ECONOMIC IMPACTS ON CALIFORNIA BUSINESSES 

1. Legal Requirements 

ARB staff conducted an economic impacts assessment although it is not legally 

required for the proposed SCM. Section 11346.3 of the Government Code requires 

State agencies to assess the potential for adverse economic impacts on California 

business enterprises and individuals when proposing to adopt or amend any 

administrative regulation. The assessment shall include a consideration of the impact of 

the proposed regulation on California jobs, business expansion, elimination or creation, 

and the ability of California business to compete with businesses in other states. 

Because the staff’s proposal is a SCM rather than an administrative regulation, the 

business impacts assessment is not required. However, ARB staff conducted the 

normally required business impacts assessment to provide the Board and districts a 

comprehensive evaluation of the potential cost impacts. Similarly, we also evaluated 

the SCM’s potential impacts to State and local agencies. Normally, State agencies are 

required to estimate the cost or savings to any State or local agency and school district 

in accordance with instructions adopted by the Department of Finance. The estimate 

shall include any nondiscretionary cost or savings to local agencies and the cost or 

savings in federal funding to the State. A major regulation is defined as a regulation 

that will have a potential cost to California business enterprises in an amount exceeding 

ten million dollars in any single year. 

2. Potential Impact on California Businesses 

Only one company, Ellis Paint, currently manufactures automotive coatings in the State. 

The impact on this company is expected to be minimal since they have coatings that 

meet the proposed limits in most categories. Additionally, Ellis Paint does not produce 

color coatings, which will require the most reformulation under the proposed SCM. Ellis 

Paint also manufactures cleaning solvents that meet the proposed VOC limit of 25 g/l. 

3. Affected Businesses 

Any person that uses, supplies, sells, offers for sale, manufactures, distributes, blends, 

or repackages for sale automotive coatings or associated solvents or performs 

automotive refinishing would potentially be affected by the proposed SCM. Also, 

potentially affected are businesses that manufacture air movement or heating 

equipment for spray booths; or supply resins, exempt solvents, or other ingredients and 

equipment to these manufacturers or marketers. 

The focus of this analysis, however, will be on coating manufacturers and automotive 

refinishing facilities because these businesses would be directly affected by the 

proposed SCM. Distributors of automotive coatings may also incur some cost if those 

costs cannot be passed on to the automotive refinishing facilities because of 

competitive pressures. However, ARB staff is unable to quantify these impacts. 

Potential costs to distributors might include some cost sharing between the 
Automotive Coatings Suggested Control Measure 

VII-8 

manufacturer and distributor to transition automotive refinishing facilities to new 

products such as water-borne color coatings. Staff does not have data on the extent to 

which such cost sharing might occur. 

Automotive coatings are manufactured or marketed by 17 companies nationwide, of 

which one is based in California, according to the 2002 Survey. The bulk of the sales 

volume in California was generated by a few companies; three manufacturers account 

for 65 percent of the volume, with the remaining 14 companies accounting for the other 

35 percent (ARB, 2005). The automotive coating manufacturers marketed about 

3.7 million gallons of coatings in California in 2001, of which an estimated one million 

gallons were compliant and 2.7 million gallons were noncompliant with the proposed 

SCM (Id.). 

Staff estimates there are approximately 4,100 automotive refinishing facilities in 

California. These businesses generated about $2.4 billion in annual revenue in 1997 

(U.S. Census, 2005). About half of these facilities have an annual revenue of less than 

$500,000 per year (Taylor, 2005). 

a. Study Approach

Sixteen of the 17 manufacturers of automotive coatings who responded to ARB’s 2002 

Survey sold coatings in California in 2001 that did not meet the proposed SCM limits. 

Staff did not have information on the 17th manufacturer to make this determination. In 

addition, for purposes of determining worse-case potential economic impact, staff 

assumes that all automotive refinishing facilities in California will need to incur costs to 

comply with the proposed SCM. This is a conservative estimate because facilities that 

use only single-stage color coatings would not need to invest in air movement 

equipment or heat because they would continue to use currently available, compliant 

solvent-borne coatings. The approach used in evaluating the potential economic impact 

of the proposed SCM on these businesses is outlined as follows: 

1) Compliance cost was estimated for manufacturers and automotive refinishing 

facilities; 

2) Estimated cost was adjusted for federal and State taxes; and 

3) The three-year average ROE was calculated for businesses by averaging the 

median ROEs for 2002 through 2004. Actual financial data were used for coating 

manufacturers where such data were available publicly. In case of the 

automotive refinishing facilities, however, actual financial data were not available 

publicly. Thus, we developed a financial profile of a typical California automotive 

refinishing facility with an annual revenue of $1 million using the Dun and 

Bradstreet financial ratios for the industry. 

ROE is calculated by dividing the net profit by the net worth. The adjusted cost was 

then subtracted from the net profit data. The results were used to calculate an adjusted 

three-year average ROE. The adjusted ROE was then compared with the ROE before 

the subtraction of the adjusted cost to determine the potential impact on the profitability 
Automotive Coatings Suggested Control Measure 

VII-9 

of the businesses. A reduction of more than 10 percent in profitability is considered to 

indicate a potential for significant adverse economic impacts. 

The threshold value of 10 percent has been used consistently by the ARB staff to 

determine impact severity (ARB, 1990; ARB, 1991; ARB, 1995; ARB, 1998). This 

threshold is consistent with the thresholds used by the U.S. EPA and others. 

b. Assumptions

The ROEs before and after the subtraction of the adjusted compliance costs were 

calculated for a typical business using financial data for 2002 through 2004. The 

calculations were based on the following assumptions: 

1) Selected businesses are representative of affected businesses; 

2) All affected businesses were subject to the highest federal and State corporate 

tax rates of 35 percent and 9.3 percent respectively; and 

3) Affected businesses are not able to increase the prices of their products, nor can 

they lower their costs of doing business through short-term cost-cutting 

measures. 

Given the limitation of available data, staff believes these assumptions are reasonable 

for most businesses at least in the short run. However, they may not be applicable to all 

businesses. 

c. Results

Table VII-1 shows the estimated change in ROE on affected industry groups. 

Table VII-1 Changes in Return on Owner’s Equity (ROE) for Typical 

Businesses in the Automotive Refinishing Industry

SIC Code and Category Change in ROE 

2851 Manufacturing - Paints, Varnishes, 

Lacquers, Enamels, And Allied Products 

0.07 percent 

7532 Automotive Repair - Top, Body, and 

Upholstery Repair facilities and Paint facilities

15 percent 

The estimated average decline in profitability of businesses is about 0.07 percent for 

manufacturers, and about 15 percent for automotive refinishing facilities. If the 

automotive refinishing facilities absorbed all costs, they would be adversely impacted by 

the proposed SCM. However, we expect automotive refinishing facilities to pass on the 

costs of the proposed SCM to consumers. If the entire cost of the proposed SCM were 

passed on to consumers, the average price for a repair or refinish would increase by 

about $11, which represents an increase of about 0.5% for a $2,200 repair. 

The performance of businesses may differ from year to year. Hence, the average 

financial data used may not be representative of an average year performance for some 

businesses. The estimated changes to ROEs may be high because affected 
Automotive Coatings Suggested Control Measure 

VII-10 

businesses probably would not absorb all of the increase in their costs of doing 

business. They might be able to either pass some of the cost on to consumers in the 

form of higher prices, reduce their costs, or do both. 

4. Potential Impact on Employment 

The paint or body repair facilities (NAICS 811121/SIC 7532) are defined as 

establishments engaged in repairing or customizing automotive vehicles, such as 

passenger cars, trucks, and vans, and all trailer bodies and interiors; and/or painting 

automotive vehicles and trailer bodies. It is estimated that there are 27,665 paid 

employees involved in the automotive body repair and refinishing services (U.S. 

Census, 2005). 

We expect the proposed SCM to have minimal impact on most employees that do 

automotive refinishing. While it is possible that some automotive refinishing facilities 

may experience higher costs than those estimated above, we believe that most will not 

be impacted adversely if districts adopt the proposed SCM. 

Cost impacts on coating manufacturers will be minimal. Most coating manufacturers 

are global companies and the proposed SCM would have minimal impact on their 

operations as indicated by the change in ROE. Thus, we do not expect any significant 

impact in the employment at these companies. 

5. Potential Impact on Business Creation, Elimination, or Expansion 

The proposed SCM should have no noticeable impact on the status of California 

businesses. This is because the costs are not expected to impose a significant impact 

on the profitability of businesses in California. However, some small automotive 

refinishing facilities with little or no margin of profitability may lack the financial 

resources to modify their facilities in a timely manner. Should the proposed measures 

impose a significant hardship on these businesses, temporary relief in the form of a 

compliance date extension under the local districts’ variance provision may be 

warranted.

While some individual businesses may be affected adversely, the proposed SCM may 

provide business opportunities for existing California businesses or result in the creation 

of new businesses. California businesses that produce air movement equipment for 

spray booths or provide consulting services to affected businesses may benefit from 

increased industry spending.

6. Potential Impact on Business Competitiveness 

The proposed SCM is not expected to have a significant impact on the ability of 

automotive refinishing facilities in California to compete with businesses from another 

state. Most automotive refinishing facilities are independent operations that compete for 

local business within their region and rarely seek business from outside the State. 
Automotive Coatings Suggested Control Measure 

VII-11 

The proposed SCM should have no significant impact on the ability of California 

manufacturers of automotive coatings to compete with businesses in other states. 

Because the proposed measures would apply to all businesses that manufacture or 

market automotive coatings for sale in California regardless of their location, the staff’s 

proposal should not present any economic disadvantages specific to California 

businesses. Of the 17 companies involved in manufacturing or marketing of automotive 

coatings in California, only one company is located in California. 

D. POTENTIAL IMPACTS ON CALIFORNIA STATE OR LOCAL AGENCIES 

We have identified no State or local agency that would be adversely affected by the 

proposed SCM. One State agency, the California Department of Transportation, 

performs touch-up work on their fleet vehicles with single-stage color coatings. Since 

many single-stage color mixtures already comply with the limits of the proposed SCM, 

we do not expect them to be adversely affected. Additionally, we expect single-stage 

color coatings to remain solvent-borne, thus there would not be a need for air 

movement equipment. There are cleaning solvents already available that meet the 

proposed VOC limit in the SCM. Thus, the solvent requirement is not expected to have 

an adverse impact on State or local agencies. 

E. POTENTIAL IMPACTS ON CALIFORNIA CONSUMERS 

The potential impact of the SCM on consumers depends upon the extent to which 

affected businesses are able to pass on the increased cost to consumers in terms of 

higher prices for their services. Given the small impact of the proposed SCM on the 

profitability of most automotive refinishing facilities, we do not expect a noticeable 

change in the price of services provided by these businesses. Since most repairs are 

paid directly by insurance companies, consumers may be impacted by higher insurance 

premiums. We anticipate the impact, if any, on consumers to be negligible. If the 

annual cost of the proposed SCM were divided among the total number of repairs in 

California per year, the average cost of a repair would increase by about $11. This 

represents a 0.5% increase in cost for a typical repair of $2,200. If the consumer is 

paying for the refinishing directly, he or she would have to absorb the entire cost. 
Automotive Coatings Suggested Control Measure 

 

VII-12 

REFERENCES 

Air Resources Board. Draft Report: 2002 Survey of Automotive coatings. June, 

2005. (ARB, 2005). 

Air Resources Board, Executive Summary and Technical Support Document. 

Initial Statement of Reasons for Proposed Amendments to the California 

Consumer Products Regulation. (a.k.a. Mid-Term Measures I). June 6, 1997. 

(ARB, 1997). 

Air Resources Board, Hearing Notice and Staff Report. Proposed Amendments 

to the California On-Road Motorcycle Regulation. October 1998. (ARB, 1998). 

Air Resources Board. Initial Statement of Reasons for a Proposed Statewide 

Regulation to Reduce Volatile Organic Compound Emissions from Aerosol 

Coating Products and Amendments to the Alternative Control Plan for Consumer 

Products. February 3, 1995. (ARB, 1995) 

Air Resources Board, Introduction and Executive Summary and Technical 

Support Document. Initial Statement of Reasons for Proposed Amendments to 

the California Consumer Products Regulation. (a.k.a. Mid-Term Measures II). 

September 10, 1999. (ARB, 1999). 

Air Resources Board staff discussions with Al Ortiz, Rely-On Spray Booth 

Company. August, 2005. (Ortiz, 2005). 

Air Resources Board staff discussions with Bob Henderson, Body Shop 

Business. August, 2005. (Henderson, 2005). 

Air Resources Board staff discussions with Cindy Elders, JunAir. July, 2005. 

(Elders, 2005). 

Air Resources Board staff discussions with Emily Taylor, DuPont. July, 2005. 

(Taylor, 2005). 

Air Resources Board staff discussions with Karl Hagan, Air Filtration Company. 

August, 2005. (Hagan, 2005). 

Air Resources Board staff discussions with Dave Harshbarger and Dave Luer, 

Mac Distributing. August, 2005. (Mac, 2005). 

Air Resources Board staff discussions with Peter Phillips, Trisk Company. July, 

2005. (Phillips, 2005). 

Air Resources Board staff discussions with South Coast Air Quality Management 

District Staff. August, 2005. (SCAQMD, 2005). 
Automotive Coatings Suggested Control Measure 

 

VII-13 

Air Resources Board, Technical Support Document. Proposed Amendments to 

the Statewide Regulation to Reduce Volatile Organic Compound Emissions from 

Consumer Products – Phase II. (a.k.a. Phase II Consumer Products Regulation). 

October 1991. (ARB, 1991).

Air Resources Board. Staff Report for the Suggested Control Measure for 

Architectural Coatings. June 6, 2000. (ARB, 2000). 

Air Resources Board, Technical Support Document. Proposed Regulation to 

Reduce Volatile Organic Compound Emissions from Consumer Products. (a.k.a. 

“Phase I Consumer Products Regulation). August 1990. (ARB, 1990). 

Air Resources Board, Technical Support Document. Suggested Control Measure 

for Architectural and Industrial Maintenance (AIM) Coatings. July 1989. (ARB, 

1989). 

California Environmental Protection Agency (Cal/EPA), Memorandum from Peter 

M. Rooney, Undersecretary, to Cal/EPA Executive Officers and Directors. 

Economic Analysis Requirements for the Adoption of Administrative Regulations. 

Appendix C (Cal/EPA Guidelines for Evaluating Alternatives to Proposed Major

Regulations). December 6, 1996. (Cal/EPA, 1996). 

Dun and Bradstreet, Financial Profile. Industry profile of Auto Body 

Repair/Painting Industry. September, 2005. (Dunn and Bradstreet, 2005). 

Online quote of the yield on a 10 year and 5 year treasury bond, www.cnn.com. 

September, 2005. (CNN, 2005). 

U.S. Census Bureau. Online query of industry statistics. www.census.gov. 

August, 2005. (U.S. Census, 2005). 
Automotive Coatings Suggested Control Measure 

A-1 

Appendix A 

Proposed Suggested Control Measure for 

Automotive Coatings 
Automotive Coatings Suggested Control Measure 

A-2 

California Air Resources Board 

Proposed Suggested Control Measure for Automotive Coatings 

1. Purpose 

The purpose of this rule is to limit volatile organic compound (VOC) emissions from 

coatings and solvents associated with the coating of motor vehicles, mobile equipment, 

and associated parts and components. 

2. Applicability 

2.1 Except as provided in section 2.2, this rule is applicable to any person who 

supplies, sells, offers for sale, manufactures, or distributes any automotive 

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

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

automotive coating or associated solvent within the District. 

2.2 This rule does not apply to: 

2.2.1 Any automotive coating or associated solvent that is offered for 

sale, sold, or manufactured for use outside of the District or for 

shipment to other manufacturers for reformulation or repackaging. 

2.2.2 Any aerosol coating product. 

2.2.3 Any automotive coating that is sold, supplied, or offered for sale in 

0.5 fluid ounce or smaller containers intended to be used by the 

general public to repair tiny surface imperfections. 

2.2.4 Any coating applied to motor vehicles or mobile equipment, or their 

associated parts and components, during manufacture on an 

assembly line. 

 

3. Definitions

3.1 “Adhesion promoter” means a coating, which is labeled and formulated to 

be applied to uncoated plastic surfaces to facilitate bonding of subsequent 

coatings, and on which, a subsequent coating is applied. 

3.2 “Aerosol Coating Product” means a pressurized coating product 

containing pigments or resins that dispenses product ingredients by 

means of a propellant, and is packaged in a disposable can for hand-held 

application, or for use in specialized equipment for ground traffic/marking 

applications. 

3.3 “Assembly Line” means an arrangement of industrial equipment and 

workers in which the product passes from one specialized operation to 

another until complete, by either automatic or manual means. 
Automotive Coatings Suggested Control Measure 

A-3 

3.4 “Associated Parts and Components” 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. “Associated parts 

and components” does not include circuit boards. 

3.5 “Automotive Coating” means any coating or coating component used or 

recommended for use in motor vehicle or mobile equipment refinishing, 

service, maintenance, repair, restoration, or modification, except metal 

plating activities. Any reference to automotive refinishing or automotive 

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

constitutes a recommendation for use in motor vehicle or mobile 

equipment refinishing. 

3.6 “Automotive Coating Component” means any portion of a coating, 

including, but not limited to, a reducer or thinner, toner, hardener, and 

additive, which is recommended by any person to distributors or end-users 

for use in an automotive coating, or which is supplied for or used in an 

automotive coating. The raw materials used to produce the components 

are not considered automotive coating components. 

3.7 “Automotive Refinishing Facility” means any shop, business, location, or 

parcel of land where motor vehicles or mobile equipment or their 

associated parts and components are coated, including autobody collision 

repair shops. “Automotive Refinishing Facility” does not include the 

original equipment manufacturing plant where the motor vehicle or mobile 

equipment is completely assembled. 

3.8 “CARB” means the California Air Resources Board. 

3.9 “Cleaning Operations” means the removal of loosely held uncured 

adhesives, inks, coatings, or contaminants, including, but not limited to, 

dirt, soil, or grease, from motor vehicles, mobile equipment, associated 

parts and components, substrates, parts, products, tools, machinery, 

equipment, or general work areas. 

3.10 “Clear Coating” means any coating that contains no pigments and is 

labeled and formulated for application over a color coating or clear 

coating. 

3.11 “Coating” means a material which is applied to a surface and forms a film 

in order to beautify, preserve, repair, or protect such a surface. 
Automotive Coatings Suggested Control Measure 

A-4 

3.12 “Color Coating” means any pigmented coating, excluding adhesion 

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

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

color coating. Color coatings include metallic/iridescent color coatings. 

3.13 “Electrostatic Spray Application” means any method of spray application of 

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

coated and the paint particles. 

3.14 “Emission Control System” means any combination of capture systems 

and control devices used to reduce VOC emissions from automotive 

coating operations. 

3.15 “Exempt Compounds” means, for the purposes of this rule, the 

compounds listed in sections 3.34.1 and 3.34.2. 

3.16 “Graphic Arts Operation” means the application of logos, letters, numbers, 

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

3.17 “High-Volume, Low-Pressure (HVLP)” means spray equipment 

permanently labeled as such and which is designed and operated 

between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing 

pressure measured dynamically at the center of the air cap and at the air 

horns. 

3.18 “Metallic/Iridescent Color Coating” means any coating that contains more 

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

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

3.19 “Mobile Equipment” means any device that may be drawn and/or driven 

on rails or a roadway including, but not limited to, trains, railcars, truck 

trailers, mobile cranes, bulldozers, street cleaners, and implements of 

husbandry or agriculture. 

3.20 “Motor Vehicle” means any self-propelled vehicle, including, but not limited 

to, cars, trucks, buses, golf carts, vans, motorcycles, tanks, and armored 

personnel carriers. 

3.21 “Multi-Color Coating” means any coating that exhibits more than one color 

in the dried film after a single application, is packaged in a single 

container, and hides surface defects on areas of heavy use, and which is 

applied over a primer or adhesion promoter. 

3.22 “Person” shall have the same meaning as defined in Health and Safety 

Code section 39047. 
Automotive Coatings Suggested Control Measure 

A-5 

3.23 “Pretreatment Coating” means any coating that contains a minimum of 

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

by weight necessary to provide surface etching and is labeled and 

formulated for application directly to bare metal surfaces to provide 

corrosion resistance and adhesion. 

3.24 “Primer” means any coating, which is labeled and formulated for 

application to a substrate to provide 1) a bond between the substrate and 

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

or 4) resistance to penetration of subsequent coats, and on which a 

subsequent coating is applied. Primers may be pigmented. 

3.25 “Single-Stage Coating” means any pigmented coating, excluding primers 

and multi-color coatings, labeled and formulated for application without a 

subsequent clear coat. Single-stage coatings include single-stage 

metallic/iridescent coatings. 

3.26 “Solvent” means a VOC-containing fluid used to perform cleaning 

operations. 

3.27 “Spot Repair” means repair of an area on a motor vehicle, piece of mobile 

equipment, or associated parts or components of less than 1 square foot 

(929 square centimeters). 

 

3.28 “Temporary Protective Coating” means any coating which is labeled and 

formulated for the purpose of temporarily protecting areas from overspray 

or mechanical damage. 

3.29 “Transfer Efficiency” means the amount of coating solids adhering to the 

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

expressed as a percentage. 

3.30 “Truck Bed Liner Coating” means any coating, excluding clear, color, 

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

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

3.31 “Underbody Coating” means any coating labeled and formulated for 

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

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

3.32 “Uniform Finish Coating” means any coating labeled and formulated for 

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

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

area’s existing coating. 

3.33 “U.S. EPA” means the United States Environmental Protection Agency. 
Automotive Coatings Suggested Control Measure 

A-6 

3.34 “Volatile Organic Compound (VOC)” means any volatile compound 

containing at least one atom of carbon, excluding carbon monoxide, 

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

ammonium carbonate, and excluding the following: 

3.34.1 methane; 

methylene chloride (dichloromethane); 

1,1,1-trichloroethane (methyl chloroform); 

trichlorofluoromethane (CFC-11); 

dichlorodifluoromethane (CFC-12); 

1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113); 

1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114); 

chloropentafluoroethane (CFC-115); 

chlorodifluoromethane (HCFC-22); 

1,1,1-trifluoro-2,2-dichloroethane (HCFC-123); 

2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124); 

1,1-dichloro-1-fluoroethane (HCFC-141b); 

1-chloro-1,1-difluoroethane (HCFC-142b); 

trifluoromethane (HFC-23); 

pentafluoroethane (HFC-125); 

1,1,2,2-tetrafluoroethane (HFC-134); 

1,1,1,2-tetrafluoroethane (HFC-134a); 

1,1,1-trifluoroethane (HFC-143a); 

1,1-difluoroethane (HFC-152a); 

cyclic, branched, or linear completely methylated siloxanes; 

the following classes of perfluorocarbons: 

(A) cyclic, branched, or linear, completely fluorinated alkanes; 

(B) cyclic, branched, or linear, completely fluorinated ethers with 

no unsaturations; 

(C) cyclic, branched, or linear, completely fluorinated tertiary 

amines with no unsaturations; and 

(D) sulfur-containing perfluorocarbons with no unsaturations and 

with the sulfur bonds only to carbon and fluorine; and 

3.34.2 the following low-reactive organic compounds which have been 

exempted by the U.S. EPA: 

acetone; 

ethane; 

parachlorobenzotrifluoride (1-chloro-4-trifluoromethyl benzene); 

perchloroethylene; 

methyl acetate; and 

tertiary butyl acetate (tBAc). 
Automotive Coatings Suggested Control Measure 

A-7 

3.35 VOC Content 

3.35.1 “VOC regulatory for Coatings” means VOC in grams per liter of 

coating, excluding water and exempt compounds, and shall be 

calculated by the following equation: 

 VOC regulatory content = Wv - Ww - Wec

 Vm - Vw - Vec 

3.35.2 “VOC actual for Coatings” means VOC in grams per liter of material 

shall be calculated using the following equation: 

 VOC actual content = Wv - Ww - Wec

 Vm 

3.35.3 “VOC content for Solvents” means VOC in grams per liter of 

material shall be calculated by the following equation: 

VOC content = Wv - Ww - Wec

 Vm 

Where: 

VOC content = amount of volatile organic compounds in grams/liter 

Wv = weight of volatiles in grams 

Ww = weight of water in grams 

Wec = weight of exempt compounds in grams 

Vm = volume of material (coating or solvent, as applicable) in liters 

Vw = volume of water in liters 

Vec = volume of exempt compounds in liters 
Automotive Coatings Suggested Control Measure 

A-8 

4. Standards 

4.1 Coating Limits. No person shall apply to any motor vehicle, mobile 

equipment, or associated parts and components, any coating with a VOC 

regulatory content, as calculated pursuant to section 3.35.1, in excess of 

the following limits, except as provided in section 4.3: 

Coating Category VOC regulatory limit, as applied, 

effective January 1, 2009 

in grams/liter (pounds per gallon*) 

Adhesion Promoter 540 (4.5) 

Clear Coating 250 (2.1) 

Color Coating 420 (3.5) 

Multi-Color Coating 680 (5.7) 

Pretreatment Coating 660 (5.5) 

Primer 250 (2.1) 

Single-Stage Coating 340 (2.8) 

Temporary Protective Coating 60 (0.5) 

Truck Bed Liner Coating 310 (2.6) 

Underbody Coating 430 (3.6) 

Uniform Finish Coating 540 (4.5) 

Any other coating type 250 (2.1) 

 *English units are provided for information only.

4.2 Most Restrictive VOC Limit. If anywhere on the container of any 

automotive coating, or any label or sticker affixed to the container, or in 

any sales, advertising, or technical literature supplied by a person, any 

representation is made that indicates that the coating meets the definition 

of or is recommended for use for more than one of the coating categories 

listed in section 4.1, then the lowest VOC content limit shall apply. 

4.3 Alternative Compliance. Instead of complying with the VOC content 

limits specified in section 4.1, a person may use an emission control 

system that has been approved, in writing, by the Executive Officer or Air 

Pollution Control Officer of the District and which achieves an overall 

control efficiency of at least 85 percent as determined pursuant to sections 

6.5 and 6.6. Any approved system emission control must be maintained 

and used at all times in proper working condition. 

4.4 Prohibition of Possession. No person shall possess at any automotive 

refinishing facility, any automotive coating that is not in compliance with 

section 4.1 or 4.3, as applicable, or any solvent with a VOC content 

greater than 25 grams per liter. 
Automotive Coatings Suggested Control Measure 

A-9 

4.5 Prohibition of Sale or Manufacture. No person shall manufacture, 

blend, repackage for sale, supply, sell, offer for sale, or distribute within 

the District any coating with a VOC content in excess of the limits 

specified in section 4.1. 

Notwithstanding the provisions of this section, a person may manufacture, 

blend, repackage for sale, supply, sell, offer for sale, or distribute a coating 

with a VOC content in excess of the limits specified in section 4.1 under 

the following circumstances and provided all of the requirements of 

section 5.6 are also met: 

4.5.1 The coating is for use exclusively within an emission control system 

as allowed in section 4.3, or 

4.5.2 The coating is for use outside the District. 

4.6 Prohibition of Specification. No person shall solicit or require the use 

of, or specify the application or use of any coating or solvent on a motor 

vehicle or mobile equipment, or associated parts and components, if such 

use or application results in a violation of this rule. This prohibition shall 

apply to all written or oral contracts, including, but not limited to, job 

orders, under the terms of which any coating or solvent that is subject to 

the provisions of this rule is to be used or applied. This prohibition shall 

not apply to coatings that meet the criteria specified in section 4.5. 

4.7 Coating Application Methods. No person shall apply any coating to any 

motor vehicle, mobile equipment, or associated parts and components 

unless one of the following application methods is used: 

4.7.1 Brush, dip, or roller. 

4.7.2 Electrostatic spray. 

4.7.3 High-Volume Low-Pressure (HVLP) spray equipment. 

4.7.4 Use of a spray gun: If a spray gun is used, the end user must 

demonstrate that the gun meets the HVLP definition in section 3.17 

in design and use. A satisfactory demonstration must be based on 

the manufacturer's published technical material on the design of the 

gun and by a demonstration of the operation of the gun using an air 

pressure tip gauge from the manufacturer of the gun. 
Automotive Coatings Suggested Control Measure 

A-10 

4.7.5 Any alternative method that achieves a transfer efficiency 

equivalent to, or higher than, the application methods listed in 

sections 4.7.1, 4.7.2, or 4.7.3 as determined per section 6.9. 

Written approval from the Executive Officer or Air Pollution Control 

Officer of the District shall be obtained for each alternative method 

prior to use. 

section 4.7 does not apply to underbody coatings, graphic arts operations, 

truck bed liner coatings, or any coating use of less than one (1) fluid ounce 

(29.6 milliliters). 

4.8 Solvent Limits and Evaporative Loss Minimization 

4.8.1 Each solvent present at any automotive refinishing facility shall not 

exceed a VOC content of 25 grams per liter as calculated pursuant 

to section 3.35.3. 

4.8.2 Solvent-laden materials shall be stored in closed containers. 

4.8.3 All automotive coating components, automotive coatings, and 

solvents shall be stored in closed vapor-tight containers. 

4.8.4 No person shall clean spray equipment unless a closed system is 

used. However, equivalent control equipment can be used if the 

Executive Officer or Air Pollution Control Officer of the District 

approves it in writing prior to use. 

4.8.5 All waste automotive coating components, automotive coatings, 

and solvents shall be stored in closed vapor-tight containers, 

except while adding to or removing them from the containers. 

5. Administrative Requirements 

5.1 Compliance Statement Requirement

5.1.1 For each individual automotive coating or automotive coating 

component, the manufacturer and repackager shall include the 

following information on product data sheets, or an equivalent 

medium: 

5.1.1.1 The VOC actual for coatings and VOC regulatory for 

coatings, expressed in grams per liter; 

5.1.1.2 The weight percentage of volatiles, water, and exempt 

compounds; 

5.1.1.3 The volume percentage of water and exempt compounds; 

and, 

5.1.3.4 The density of the material (in grams per liter). 
Automotive Coatings Suggested Control Measure 

A-11 

5.1.2 For each individual ready to spray mixture (based on the 

manufacturer’s and repackager’s stated mix ratio), the 

manufacturer and repackager shall include the following information 

on product data sheets, or an equivalent medium: 

5.1.2.1 The VOC actual for coatings and VOC regulatory for 

coatings, expressed in grams per liter; 

5.1.2.2 The weight percentage of volatiles, water, and exempt 

compounds; 

5.1.2.3 The volume percentage of water and exempt compounds; 

and, 

5.1.2.4 The density of the material (in grams per liter). 

5.1.3 The manufacturer and repackager of solvents subject to this rule 

shall include the VOC content as supplied, calculated pursuant to 

section 3.35.3, expressed in grams per liter, on product data sheets, 

or an equivalent medium. 

5.2 Labeling Requirements

5.2.1 The manufacturer and repackager of automotive coatings or 

automotive coating components shall include on all containers the 

applicable use category(ies), and the VOC actual for coatings and 

VOC regulatory for coatings, as supplied, expressed in grams per 

liter. 

5.2.2 The manufacturer and repackager of solvents subject to this rule 

shall include on all containers the VOC content for solvents, as 

supplied, expressed in grams per liter. 

5.3 Maintenance of Records. Records required by this rule shall be retained 

for a minimum of three years and made available for inspection by District 

personnel upon request. 

5.4 Record Keeping Requirements. Any person who uses coatings or 

solvents subject to this rule shall maintain and have available at all times, 

on site, the following: 

5.4.1 A current list of all coatings and solvents used that are subject to 

this rule. This list shall include the following information for each 

coating and solvent: 

5.4.1.1 material name and manufacturer 

5.4.1.2 application method 

5.4.1.3 coating type (as listed in section 4.1) and mix ratio specific 

to the coating 

5.4.1.4 VOC actual for coatings and VOC regulatory for coatings, 

as applied, or VOC content for solvent. 
Automotive Coatings Suggested Control Measure 

A-12 

5.4.1.5 whether the material is a coating or solvent. 

5.4.2 Current manufacturer specification sheets, material safety data 

sheets, technical data sheets, or air quality data sheets, which list 

the VOC actual for coatings and VOC regulatory for coatings of 

each ready-to-spray coating (based on the manufacturer’s stated 

mix ratio) and automotive coating components, and VOC content of 

each solvent. 

5.4.3 Purchase records identifying the coating type (as listed in 

section 4.1), name, and volume of coatings and solvents. 

5.5 Record Keeping Requirements for Emission Control Systems. Any 

person using an emission control system shall maintain daily records of 

key system operating parameters which will demonstrate continuous 

operation and compliance of the emission control system during periods of 

VOC emission producing activities. “Key system operating parameters” 

are those parameters necessary to ensure or document compliance with 

section 4.3, including, but not limited to, temperatures, pressure drops, 

and air flow rates. 

5.6 Record Keeping Requirements for Prohibition of Sale. Any person 

claiming an exception specified in section 4.5 shall keep a detailed log of 

each automotive coating component and automotive coating 

manufactured, blended, repackaged for sale, supplied, sold, offered for 

sale, or distributed showing: 

5.6.1 The quantity manufactured, blended, repackaged for sale, supplied, 

sold, offered for sale, or distributed, including size and number of 

containers; 

5.6.2 The VOC regulatory for coatings; 

5.6.3 The VOC actual for coatings; 

5.6.4 To whom they were supplied, sold, offered for sale, or distributed, 

or for whom they were manufactured, blended, or repackaged for 

sale including the name, address, phone number, retail tax license 

number, and valid district permit number; and, 

5.6.5 The specific exception being utilized under section 4.5. 

6. Test Methods. The following test methods are incorporated by reference herein, 

and shall be used to test coatings and solvents subject to the provisions of this 

rule. A source is in violation of this rule if any measurement by any of the listed 

applicable test methods exceeds the standards of this rule.
Automotive Coatings Suggested Control Measure 

A-13 

6.1 Methyl Acetate, Acetone, t-Butyl Acetate, and PCBTF Content. The 

quantity of methyl acetate, acetone, t-butyl acetate, and 

parachlorobenzotrifluoride (as specified in sections 3.15, 3.34, and 3.35) 

shall be determined by using ASTM Method D6133-02: “Standard Test 

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

Acetate Content of Solventborne and Waterborne Paints, Coatings, 

Resins, and Raw Materials by Direct Injection Into a Gas Chromatograph” 

(February 2003). 

6.2 Acid Content. Measurement of acid content (as specified in section 3.23) 

shall be determined by using ASTM D1613-03 “Standard Test Method for 

Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, 

Varnish, Lacquer, and Related Products” (October 2003). 

6.3 Alternative Test Methods. The use of other test methods which are 

determined to be equivalent or better and approved, in writing, by the 

Executive Officer or Air Pollution Control Officer of the District, CARB, and 

U.S. EPA may be used in place of the test methods specified in this rule. 

6.4 VOC Content of Coatings or Solvents. VOC content (as specified in 

sections 3.35, 4.1, and 4.8.1) shall be determined by U.S. EPA Method 24 

as set forth in Appendix A of Title 40 of the Code of Federal Regulations 

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

Content, Density, Volume Solids, and Weight Solids of Surface Coatings”. 

6.5 Control Efficiency. When either U.S. EPA Method 25, 25A, or 25B is 

used to determine VOC emissions, control device equivalency (as 

specified in section 4.3) shall be determined as specified in U.S. EPA’s 

“Guidelines for Determining Capture Efficiency,” (January 9, 1995) and 40 

CFR 51, Appendix M, Methods 204 –204f as applicable. 

6.6 Determination of Alternative Compliance. Alternative compliance (as 

specified in section 4.3) shall be determined by U.S. EPA Method 25, 25A, 

or 25B, Title 40 Code of Federal Regulations, Part 60, Appendix A as 

applicable. A source is in violation if the measured VOC emissions, as 

measured by any of the test methods, exceed the standards specified in 

section 4.3. 

6.7 Metallic Content. The metallic content of a coating (as specified in 

section 3.18) shall be determined by South Coast Air Quality Management 

District Method 318-95, "Determination of Weight Percent Elemental Metal 

in Coatings by X-ray” (July 1996). 
Automotive Coatings Suggested Control Measure 

A-14 

6.8 Exempt Compound Content. Exempt compound content, other than as 

determined pursuant to section 6.1, (as specified in sections 3.15, 3.34 

and 3.35) shall be determined by using CARB Method 432, “Determination 

of Dichloromethane and 1,1,1-Trichloroethane in Paints and 

Coatings”(September 12, 1998); CARB Method 422, “Determination of 

Volatile Organic Compounds in Emissions from Stationary Sources” 

(January 22, 1987); or, South Coast Air Quality Management District 

(SCAQMD) Method 303-91, “Determination of Exempt Compounds” 

(February 1993). 

6.9 Transfer Efficiency. Spray equipment transfer efficiency (as specified in 

sections 3.29 and 4.7.5) shall be determined by using South Coast Air 

Quality Management District “Spray Equipment Transfer Efficiency Test 

Procedure for Equipment User” (May 24, 1989). 

6.10 HVLP Equivalency. Spray equipment HVLP equivalency (as specified in

section 4.7.4) shall be determined by using South Coast Air Quality 

Management District “Guidelines for Demonstrating Equivalency with 

District Approved Transfer Efficient Spray Guns” (September 26, 2002). 

7. Construction of Headings. Section and subsection headings do not in any 

manner affect the scope, meaning, or intent of the provisions of this Suggested 

Control Measure. 

8. Severability. Each part of this Suggested Control Measure shall be deemed 

severable, and in the event that any part of this Suggested Control Measure is 

held to be invalid, the remainder of this Suggested Control Measure shall 

continue in full force and effect. 
Automotive Coatings Suggested Control Measure 

B-1 

Appendix B 

2002 Automotive Coatings Survey 

(Refinish Coatings Only) 
Automotive Coatings Suggested Control Measure 

B-2 

2002 Automotive Coatings Survey 

(Refinish Coatings Only) 

California Environmental Protection Agency 

Air Resources Board 
Automotive Coatings Suggested Control Measure 

B-3 

TABLE OF CONTENTS 

2002 AUTOMOTIVE COATINGS SURVEY 

SECTION AND TITLE PAGE 

I. PART A – SURVEY FORMS AND INSTRUCTIONS ............................... 1 

• Confidential Information Submittal Form ............................................. 2 

• Survey Forms............................................................................... 3 – 7 

• Survey Instructions ........................................................................ 8 – 15 

• Submitting Survey Forms or Data ...................................................... 16 

 

II. PART B – SUPPLEMENTAL INFORMATION ....................................... 17 

• Definitions .................................................................................. 18 – 22 

• VOC Calculations and Conversion Factors ............................................ 23 – 24 

• Reactivity Bin Numbers for Aliphatic and Aromatic Hydrocarbon Solvents ...... 25 

• U.S. Resident Population ................................................................. 26 

III. PART C – EXAMPLE OF COMPLETED SURVEY FORMS 27 - 32 

SUBMITTAL OF FORMS 

Please return the completed survey to the following address: 

Regular Mail Overnight

California Air Resources Board 

California EPA Headquarters Building 

Air Resources Board (6th Floor) 

P.O. Box 2815 1001 I Street 

Sacramento, CA 95812 Sacramento, CA 95814 

ATTN: SSD / Measures Assessment Branch 

 Automotive Coatings Survey 

ATTN: SSD / Measures Assessment Branch 

 Automotive Coatings Survey 

ELECTRONIC SUBMITTAL OPTIONS

Electronic submittal options are available. Details can be obtained by contacting the ARB or by visiting our web 

site at “www.arb.ca.gov/coatings/auto/survey/2002survey.htm.” Additional survey packages can also be 

downloaded from this site. 

QUESTIONS 

If you have any questions or other requests please contact any of the following staff: 

Name Phone Email 

Jose Gomez, Manager 916-324-8033 jgomez@arb.ca.gov 

Dave Mehl, Survey Lead 916-324-8177 dmehl@arb.ca.gov 

Gary Mouradian 916-324-8175 gmouradi@arb.ca.gov 

Mark Watkins 916-323-9687 mwatkins@arb.ca.gov 
Automotive Coatings Suggested Control Measure 

B-4 

2002 Automotive Coatings Survey 

PART A 

SURVEY FORMS 

AND 

INSTRUCTIONS 

DUE DATE: SEPTEMBER 30, 2002 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-5 

CONFIDENTIAL INFORMATION SUBMITTAL FORM 

If you wish to designate any information contained in your survey data as CONFIDENTIAL INFORMATION, please provide the data 

requested below and return it with your completed survey forms. 

In accordance with Title 17, California Code of Regulations (CCR), sections 91000 to 91022, and the California Public Records Act 

(Government Code Section 6250 et seq.), the information that a company provides to the Air Resources Board (ARB) may be released: 

(1) to the public upon request, except trade secrets which are not emission data or other information which is exempt from disclosure or 

the disclosure of which is prohibited by law; (2) to the Federal Environmental Protection Agency (EPA), which protects trade secrets as 

provided in Section 114(c) of the Clean Air Act and amendments thereto (42 USC 7401 et seq.) and in federal regulation; and, (3) to 

other public agencies provided that those agencies preserve the protections afforded information which is identified as a trade secret, or 

otherwise exempt from disclosure by law (Section 39660(e)). 

Trade secrets as defined in Government Code Section 6254.7 are not public records and therefore will not be released to the public. 

However, the California Public Records Act provides that air pollution emission data are always public records, even if the data comes 

within the definition of trade secrets. On the other hand, the information used to calculate air pollution emissions may be withheld from 

the public if the information is a trade secret. 

If any company believes that any of the information it provides is a trade secret or otherwise exempt from disclosure under any other 

provision of law, it must identify the confidential information as such at the time of submission to the ARB and must provide the 

name, address, and telephone number of the individual to be consulted if the ARB receives a request for disclosure or seeks to 

disclose the data claimed to be confidential. The ARB may ask the company to provide documentation of its claim of trade secret or 

exemption at a later date. Data identified as confidential will not be disclosed unless the ARB determines, in accordance with the above 

referenced regulations, that the data does not qualify for a legal exemption from disclosure. These regulations establish substantial 

safeguards before any such disclosure. 

In accordance with the provisions of Title 17, California Code of Regulations, sections 91000 to 91022, and the California Public Records 

Act (Government Code Sections 6250 et seq.), 

Company Name: _____________________________________________________________________ declares that only those portions 

specifically identified and submitted in response to the California Air Resources Board's information request on the survey are 

confidential "trade secret" information, and requests that it be protected as such from public disclosure. All inquiries pertaining to the 

confidentiality of this information should be directed to the following person: 

Name (please print): ______________________________________________________________________________ 

Signature: ______________________________________________________________________________ 

Title: ______________________________________________________________________________ 

Telephone #: ______________________________________________________________________________ 

Mailing Address: ______________________________________________________________________________ 

 ______________________________________________________________________________
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-6 

FORM 1 

General Information – Reporting Year 2001 

Company Name: Web Site: 

Division: 

Address: 

City: State: Zip: 

Contact Person: Position: 

Phone: FAX: e-mail: 

1) Did your company manufacture and distribute coatings in 2001 (for use in California) for motor vehicles or mobile equipment, or 

coatings that you know to be used in those types of applications? YES NO

 

2) Did your company distribute coatings in 2001 (for use in California) manufactured by another company, which are for motor 

vehicles or mobile equipment, or that you know are used in those types of applications? YES NO

 If yes, please list these companies along with a mailing address and contact person. (Please use a separate sheet of paper labeled as 

question 2.) 

3) Did your company manufacture coatings for another company to distribute in 2001 that are for motor vehicles or mobile 

equipment, or that you know are used in those types of applications? YES NO

 If yes, please list these companies along with a mailing address and contact person. (Please use a separate sheet of paper labeled as 

question 3.) 

4) Is your company a wholly owned subsidiary of another company? YES NO

 If yes, please list the name of the parent company along with a contact person’s name and position, complete mailing address, 

telephone and facsimile numbers, and an e-mail address for the contact person. (Please use a separate sheet of paper labeled as 

question 4.) 

If you answered “Yes” to question 1, 2 or 3 please complete the remainder of the survey prior to returning it to the ARB. If you 

answered “No” to all these questions, please return only this form. 

CERTIFICATION by Authorized Official 

I hereby certify that, to the best of my knowledge and belief, all information entered on Form 1 – General Information, Form 2 – 

Company Information, Form 3 – Product Information, Form 4 – Ingredient Information, and Form 5 Ready-To-Spray Information is 

complete and accurate. 

Name: Position: 

Signature: Date: 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-7 

FORM 2 

Company Information – Reporting Year 2001 

Type of Business (check all that apply) Company Marketing Classification (check one)

 Manufacturer  International 

 Importer  National 

 Retail Distributor  Regional (e.g., western U.S.) 

 Wholesale Distributor list: 

 Private Label Manufacturer  California Statewide 

 Toll Manufacturer  California Region (e.g. Southern California) 

 Other (Specify): list: 

Company – Gross Annual Receipts ($) for Calendar 

Year 2001 (check one)

Company – California Gross Annual Receipts ($) for 

Calendar Year 2001 (check one)

 Less than 500,000  Less than 500,000 

 500,000 to 1 million  500,000 to 1 million 

 >1 million to 2 million  >1 million to 2 million 

 >2 million to 5 million  >2 million to 5 million 

 >5 million to 10 million  >5 million to 10 million 

 >10 million to 100 million  >10 million to 100 million 

 >100 million to 1 billion  >100 million to 1 billion 

 >1 billion  >1 billion 

Automotive Coatings – Gross Annual Receipts ($) for

Calendar Year 2001 (check one)

Automotive Coatings – California Gross Annual Receipts 

($) for Calendar Year 2001 (check one)

 Less than 500,000  Less than 500,000 

 500,000 to 1 million  500,000 to 1 million 

 >1 million to 2 million  >1 million to 2 million 

 >2 million to 5 million  >2 million to 5 million 

 >5 million to 10 million  >5 million to 10 million 

 >10 million to 100 million  >10 million to 100 million 

 >100 million to 1 billion  >100 million to 1 billion 

 >1 billion  >1 billion 

Employees for Calendar Year 2001 (check one) Employees–California for Calendar Year 2001 (check one)

 Less than 10  Less than 10 

 10 to 99  10 to 99 

 100 to 249  100 to 249 

 250 to 499  250 to 499 

 500 or more  500 or more 

Automotive Coatings Employees for Calendar Year 

2001 (check one)

Automotive Coatings Employees – California for 

Calendar Year 2001 (check one)

 Less than 10  Less than 10 

 10 to 99  10 to 99 

 100 to 249  100 to 249 

 250 to 499  250 to 499 

 500 or more  500 or more 

How did you determine California Year 2001 Sales Volume? (check all that apply)

 Direct California retail sales  Prorated from national retail sales 

 Direct California wholesale distribution  Prorated from national wholesale distribution 

 Other (explain): 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-8 

FORM 3 

Product Information – Reporting Year 2001 

 Entry # : * 

Product Code: 

Product Name: 

Brand and Product Line(s):

Physical And Other Data 

Type Code 

(10 – 60) 

Specify 

(for codes 10, 20, 40 and 60 only) 

Coverage 

(ft2/gal) 

Recommended 

Thickness 

(mil) 

Water or 

Solvent Borne

(W or S) 

Density 

(lbs/gal) 

 

Weight Percent Volume Percent 

Solids Volatile 

Material Water Exempts Solids Volatile Material Water Exempts 

 

As Packaged 

VOC Actual VOC Regulatory - Less Water & Exempts 

(g/l) (g/l) 

2001 California Sales (gallons) 

* Note: This entry # must also appear on your corresponding FORM 4. 

Page ______ of ______ Enter the current page # out of the total pages submitted. 

NOTE: Each FORM 3 must have a corresponding FORM 4. 

Photocopy this page as necessary 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-9 

FORM 4 

Ingredient Information – Reporting Year 2001

Entry # from FORM 3: 

# Ingredient Bin # * CAS # wt 

%**

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 Aggregated ingredients < 0.1 wt. % N/A N/A 

 Total of All Ingredients 

(Must Equal 100%)

* For hydrocarbon solvents only. Refer to page 25 or contact solvent supplier for bin #. 

** Enter the weight percent for each ingredient that is at least 0.1% of the total mass of the product. Toxic air contaminants (e.g., lead 

and nickel) should be reported to lower than 0.1% if known. 

Page ______ of ______ Enter the current page # out of the total pages submitted. 

NOTE: Each FORM 4 must have a corresponding FORM 3. 

Photocopy this page as necessary 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-10 

FORM 5 

Ready-To-Spray (RTS) Information – Reporting Year 2001 

Note: RTS mixtures within a single product line may be grouped if the mixing ratios remain constant and all possible combinations are 

viable products. 

 For each combination of products listed in Form 3 that requires mixing to be RTS please list the following: 

Ready-To-Spray Mixture # 

Mixing Components Entry #: 

(from Form 3) 

Mixing Ratio: 

Recommended Thickness (mil) 

Production Cost ($/gal) 

Minimum Sales Weighted Average Maximum 

If grouping 4 or more RTS mixtures from the top table please complete both of the following tables. If reporting one RTS mixture or 

grouping 3 or less RTS mixtures, please complete just the appropriate number of columns of the first table. 

low median high Low median high 

VOC 

regulatory 

VOC 

actual 

Color Color 

Density Coverage 

Coverage Density 

VOC actual VOC 

regulatory 

Page ______ of ______ Enter the current page # out of the total pages submitted. 

Photocopy this page as necessary 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-11 

Form 1 Instructions 

General Information – Reporting Year 2001 

The information requested on Form 1 will be used by the California Air Resources Board to determine what 

companies distribute motor vehicle and mobile equipment coatings (automotive coatings) for sale in California. 

These companies will be required to complete the survey, based on the coatings sold in calendar year 2001. If 

your company is not a paint manufacturer, but is listed as “manufactured for” or “distributed by” on the product 

label, you are responsible for completing the requested information in this survey. You are encouraged to 

coordinate your responses with the appropriate manufacturer of your product to avoid double reporting of data. 

Holding companies or subsidiaries may also need to complete this survey. 

Company Name: The legal business name of your company. If you are completing this survey for more than one 

company, please submit different surveys for each company. 

Web Site: The company web site address, for example, www.paintcompany.com.

Division: If the company has multiple divisions, please specify which division this survey was completed for. 

Address: Enter street address or post office box of your company where mail is received. 

City: The city where mail is received. 

State: The state where mail is received. 

Zip: Enter the postal zip code at which mail is received 

Contact Person: Name of the person to be contacted if there are questions about survey responses. 

Position: Business position of the contact person. 

Phone: Telephone number of the contact person. 

Fax: Fax number of the contact person. 

e-mail: e-mail address of the contact person. 

Please answer questions 1 through 4. List requested information where appropriate. 

If you answered yes to question 1, 2 or 3, please also complete Forms 2, 3, 4 and 5. If you answered no to these 

questions, please return only the completed Form 1 to the ARB at the address listed on page 2. 

Certification: Please have a responsible company officer (President, Treasurer, Secretary, or Vice-President of a 

principle business function) certify that the General Information (Form 1), Company Information (Form 2), 

Product Information (Form 3), Ingredient Information (Form 4), and Ready-To-Spray Information (Form 5) is 

complete and accurate. This person is to clearly print or type his name and business position, and sign and date the 

form where indicated. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-12 

Form 2 Instructions 

Company Information – Reporting Year 2001 

Type of Business: Check all boxes that describe the types of business conducted by your company. 

Manufacturer – A company that produces, packages, or repackages motor vehicle or mobile equipment 

coatings for sale or distribution in California.

Importer – A company that brings motor vehicle or mobile equipment coatings into the United States for 

sale or distribution within California. 

Retail Distributor – A company who sells or supplies motor vehicle or mobile equipment coatings at the 

retail level. 

Wholesale Distributor - A company who sells or supplies motor vehicle or mobile equipment coatings for 

the purpose of resale or distribution in commerce at the wholesale level. 

Private Label Manufacturer – A company that manufactures motor vehicle or mobile equipment coatings 

for sale under another company’s name. 

Toll Manufacturer – A company that manufactures motor vehicle or mobile equipment coatings based on 

the formula of another company and places that company’s name on the product label. 

Company Marketing Classification: Check the box that best describes your company’s primary marketing 

classification. 

International – Two or more nations. For example, United States, Canada, and Mexico. 

National – All of the United States. 

Regional – A portion of the United States. For example, California, Oregon, and Arizona. 

California Statewide – All of California. 

California Local – A portion of California. For example, Southern California or the San Francisco Bay 

Area. 

The information on annual receipts and employees should be provided for both the company and the automotive 

coatings unit, as appropriate. 

Gross Annual Receipts: Check the box which identifies the gross annual receipts generated by your company. 

This means the total income of the company before expenses are deducted. 

Gross Annual Receipts - California: Check the box which identifies the gross annual receipts generated by your 

company in California. 

Employees: Check the box that indicates the total number of full-time equivalent employees of the company. 

Employees - California: Check the box that identifies the number of full-time equivalent employees in 

California. 

How did you determine California Year 2001 Sales Volume?: Check the box that best identifies the method 

used to determine California sales volume for use on Form 3. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-13 

Form 3 Instructions 

Product Information – Reporting Year 2001

Entry # : Each Form 3 completed must be numbered sequentially, beginning with “1.” This entry # must also 

appear on your corresponding Form 4 and will be used in completing Form 5. 

Product Code: Enter product code. 

Product Name: Enter the product / label name for the product code above. 

Product Line(s): Enter the product line(s) which the coating is used in. 

Type Code: Enter the code from the Type Code table, on page 11 that best describes the coating. 

Specify: If the Type Code entered was 10, 20, 40 or 60, please clarify/specify what type of coating it is. 

Coverage: Specify the coverage of the coating when applied at the recommended thickness, in terms of square 

feet per gallon of coating. 

Recommended Thickness: Specify the recommended thickness used in determining the coatings’ coverage, in 

mils. 

Water or Solvent Borne: Note if the coating is solvent (by marking “S”) or water (by marking “W”) borne. 

Density: Density of the coating in pounds per gallon (lbs/gal). 

Weight Percent of Solids: Solids content of the coating expressed as a percentage of total coating weight. 

Weight Percent of Volatile Material: Volatile material (VOC+water+exempts) content expressed as a 

percentage of total coating weight. See page 22 for the definition of VOC (volatile organic compound) and VOC 

content. 

Weight Percent of Water: Water content as a percentage of total coating weight. 

Weight Percent of Exempts: Exempt compounds content expressed as a percentage of total coating weight. See 

page 18 for definition of exempt compounds. 

Volume Percent of Solids: Solids content of the coating expressed as a percentage of total coating volume. 

Volume Percent of Volatile Material: Volatile material (VOC+water+exempts) content expressed as a 

percentage of total coating volume. See page 22 for the definition of VOC (volatile organic compound) and VOC 

content.

Volume Percent of Water: Water content expressed as a percentage of total coating volume. 

Volume Percent of Exempts: Exempt compounds content expressed as a percentage of total coating volume. See 

page 18 for definition of exempt compounds. 

VOC Actual: Also known as Material VOC. VOC content of coating, as supplied, in grams of VOC per liter of 

coating. This is the weight of all volatile materials less the weight of water and exempt compounds per the entire 

volume of the coating. This is NOT the same as VOC Regulatory. See “VOC Calculations” page 23.

VOC Regulatory (Less Water & Exempts): Also known as Coating VOC. VOC content of the coating, as 

supplied, in grams of VOC per liter of coating less water and exempt compounds. This may be determined from 

the formulation data or previously determined by EPA Method 24, 40 CFR Part 60, as amended in Federal 

Register Vol. 57, No. 133, July 10, 1992, or ASTM D 3960-92. See “VOC Calculations” page 23. 

2001 California Sales: The volume, in gallons, of the coating sold in California in 2001. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-14 

Form 3 Instructions, Continued

 Type Codes 

 

Coating Type Code 

Undercoat (specify) 10 

 primer 11 

 primer sealer 12 

 primer surfacer 13 

 pretreatment wash primer 14 

 precoat 15 

 ground coat 16 

 flexible primer 17 

 plastics primer 18 

 

Color coat (specify) 20 

 single-stage 21 

 single-stage multicolor 22 

 multi-stage color coat 23 

 multi-stage multicolor coat 24 

 camouflage 25 

 metallic/iridescent 26 

 

Clearcoat 30 

 

Additive (specify) 40 

 reducer 41 

 hardener 42 

 catalyst 43 

 activator 44 

 extender 45 

 flattener 46 

 plasticizer 47 

 fish eye eliminator 48 

 accelerator 49 

 

Truck bed coating 51 

Underbody coating 52 

Temporary protective coating 53 

Uniform finish coating 54 

Anti-glare/safety coating 55 

 

Other (specify) 60 

Please use the major category code if a coating does not fall within one of the more specific codes. For example, if a coating is an 

additive (uniform finish blender) which is not one of the specific additives listed, use code 40. “Uniform finish blender” would then be 

listed under “Specify.” 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-15 

Form 4 Instructions 

Ingredient Information – Reporting Year 2001

Form 4 requests product ingredient information. In this table provide all ingredients which are part of the product 

formulation. Complete one Form 4 for each Form 3 completed. 

Entry # From Form 3: Enter the Entry # from corresponding Form 3. 

#: Number each ingredient sequentially, beginning with “1.” 

Ingredient: Enter the standard (IUPAC) chemical name of the ingredient. Chemical names must be distinguished 

from trade names, by labeling trade names with an asterisk prior to the name . For example, the desired chemical 

name of SD 40 Alcohol or ethyl alcohol is ethanol. Only enter the trade name of the ingredient if the chemical 

name is unknown. If the ingredient is proprietary or a mixture (e.g., petroleum distillates) identify the trade name 

and manufacturer / primary supplier. 

Resin entries should be grouped by resin type instead of listing each specific resin composition. Report only the 

total weight percentage for each resin group. Please choose from the resin types in the table below. If the resin 

does not fit within one of these categories, please contact Dave Mehl at (916) 361-0342 or dmehl@arb.ca.gov to 

help you determine a resin type, for data consistency. 

Resin Types 

Acrylic Epoxy Silicone, Silane, Siloxane 

Acrylic Copolymer Oleoresin Styrene-butadiene 

Alkyd Phenolic Urethane, Polyurethane 

Amines, Amides Polyester (Not Alkyd) Polyvinyl Chloride (PVC) 

Cellulosic Polyvinyl Acetate (PVA) Vinyl Toluene 

Chlorinated Rubber Shellac Vinyl Acrylic Copolymer 

NOTE: The volatile portions of resin solutions, colorants or additives must be listed as separate ingredient 

entries. For example, do not include the volatile portion of a resin solution as a solid. 

Bin #: For aliphatic or aromatic hydrocarbon solvents enter the bin number that best represents the nature of the 

solvent from page 25. 

CAS#: Enter the Chemical Abstract Service (CAS) number for the ingredient. 

Weight % (of total material): Enter the percent by weight for each ingredient in the final product that is at least 

0.1% of the total mass of the product. Toxic air contaminants (e.g., lead and nickel) should be reported to lower 

than 0.1% if known. If an ingredient is a mixture of known components, list the components separately with their 

individual weight percentages in the final product. If the components of a mixture cannot be determined, list the 

ingredient as a single entity. For example, you may not know the weight percentage of individual ingredients of 

petroleum distillates, resins, or biocides. In cases such as these identify the weight percent of the mixture. 

Total of All Ingredients: The sum of all ingredients in the table must equal 100.00 percent by weight. If this 

value does not sum to 100.00, please recheck the information. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-16 

Form 5 Instructions 

Ready-To-Spray Information – Reporting Year 2001

Ready-To-Spray Mixture#: Number entries sequentially, beginning with “1.” 

Mixing Components: List entry #s from Form 3 for all components to be mixed together to create a Ready-ToSpray (RTS) coating, in the same order as the mixing ratio. RTS mixtures within a single product line may be 

grouped if the mixing ratios remain constant and all possible combinations are viable products. 

Tints from within a product line can be grouped together for reporting ready-to-spray mixtures, instead of 

reporting for each individual color combination. When grouping tints within a product line, the mixing component 

listed would be the name of the product line and “tints,” e.g. “Supernova tints.” Please identify the relevant Form 

3 entry #s for the “grouped” tints. 

Example: 

Ready-To-Spray Mixture # 2 

Mixing Components Entry #: 

(from Form 3) 

Supernova 

tints, 4 – 53 & 

56 – 60 

92 

Mixing Ratio: 2 1 

Other components of a RTS coating can also be grouped, i.e. reducers, hardeners, or even a main component, such 

as primers. More than one category can be grouped on one form. For example, if the first column is a clear coat, 

the second column could be the various hardeners and the third column the reducers, similar to the example below. 

However, every possible combination represented in the grouping matrix must be an actual marketed RTS product. 

Please remember that it is only possible to have grouping on this form if the mix ratios are identical for every 

possible combination. 

Example: 

Ready-To-Spray Mixture # 3 

Mixing Components Entry #: 

(from Form 3) 5 10, 11, 12 20, 21, 22 

Mixing Ratio: 4 1 1 

The above table would yield 9 different post-mixing combinations: 5-10-20, 5-10-21, 5-10-22, 5-11-20, 5-11-21, 

5-11-22, 5-12-20, 5-12-21, and 5-12-22. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-17 

If not all of the above combinations are actual marketed combinations, then it cannot be grouped as above. For 

example if 5-11-20 and 5-11-21 are not marketed combinations then at least 2 Form 5s would need to be 

submitted, such as 

Ready-To-Spray Mixture # 3 

Mixing Components Entry #: 

(from Form 3) 5 10, 11, 12 22 

Mixing Ratio: 4 1 1 

and 

Ready-To-Spray Mixture # 4 

Mixing Components Entry #: 

(from Form 3) 5 10, 12 20, 21 

Mixing Ratio: 4 1 1 

Mixing Ratio: The relative ratio, by volume, of each component to be mixed to create a ready-to-spray coating, 

in the same order as the mixing components. 

Recommended Thickness: Specify the recommended thickness used in determining the RTS coatings’ coverage, 

in mils. 

Production Cost, Minimum: Indicate the lowest production cost for a RTS mixture from the form, in dollars per 

gallon ($/gal). Production cost includes the cost of materials plus labor. 

Production Cost, Sales Weighted Average: Indicate the sales weighted average production cost of the RTS 

mixtures from the form, in dollars per gallon ($/gal). Production cost includes the cost of materials plus labor.

Production Cost, Maximum: Indicate the highest production cost for a RTS mixture from the form, in dollars per 

gallon ($/gal). Production cost includes the cost of materials plus labor. 

For VOC actual and VOC regulatory report your lowest, median, and highest color. For each color reported, 

report the corresponding information on the coverage, density, and either VOC actual or VOC regulatory as 

appropriate. If grouping 4 or more RTS mixtures from the first table, complete both of the tables. If reporting one 

RTS mixture or grouping 3 or less RTS mixtures, complete just the appropriate number of columns of the first 

table.

Coverage: Specify the coverage of the coating when applied at the recommended thickness, in terms of square 

feet per gallon of coating. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-18 

Density: Density of the coating in pounds per gallon (lbs/gal). 

VOC Actual: Also known as Material VOC. VOC content of coating, as supplied, in grams of VOC per liter of 

coating. This is the weight of all volatile materials less the weight of water and exempt compounds per the entire 

volume of the coating. This is NOT the same as VOC Regulatory. See “VOC Calculations” page 23. 

VOC Regulatory (Less Water & Exempts): Also known as Coating VOC. VOC content of the coating, as 

supplied, in grams of VOC per liter of coating less water and exempt compounds. This may be determined from 

the formulation data or previously determined by EPA Method 24, 40 CFR Part 60, as amended in Federal 

Register Vol. 57, No. 133, July 10, 1992, or ASTM D 3960-92. See “VOC Calculations” page 23. 
Automotive Coatings Suggested Control Measure 

2002 California Automotive Coatings Survey 

Air Resources Board, P.O. Box 2815 - Sacramento, CA 95812 - Attention: Stationary Source Division, Measures Assessment Branch 

Phone: 916.324.8023 FAX: 916.324.8026 www.arb.ca.gov/coatings/auto/survey/2002survey.htm 

B-19 

Submitting Survey Forms or Data 

Option 1: For each form type, assemble the pages in numerical entry order, beginning with Form 1 and 

continuing through Form 5. 

Option 2: Same as Option 1, except group each Form 4 with its corresponding Form 3. 

Option 3: Submit Data Electronically. 

 

Survey data may be submitted electronically. The file formats, in order of preference, are: 

1. Microsoft Access 

2. Microsoft Excel 

3. ASCII tab delimited file 

If you wish to submit survey data in any other electronic format, please contact us for additional 

information. 

To obtain information on file formats visit www.arb.ca.gov/coatings/auto/survey/2002survey.htm
Automotive Coatings Suggested Control Measure 

C-1

Appendix C 

Summary of Cost Analysis Methodology 
Automotive Coatings Suggested Control Measure 

C-2

Summary 

The total cost of the proposed SCM to affected businesses is estimated to be 

$65 million in nonrecurring costs and $5.7 million per year in recurring costs. This 

equates to $13.9 million dollars annually over the useful life of the control equipment. 

This represents the cost of raw materials, research and development, and changes to 

distribution for the manufacturers, and the cost of new equipment, training, and energy 

costs to automotive refinishing facilities. The annual average cost to a typical 

automotive coatings manufacturer is estimated to be $320,000. The annual average 

cost to a typical automotive refinishing facilities is estimated to be about $3,400. 

Methodology 

For this analysis, we considered the impact on two groups of businesses; coating 

manufacturers and automotive refinishing facilities. The total cost of the proposed SCM 

represents the combined costs to these two groups. Distributors of automotive coatings 

may also incur some costs if those costs cannot be passed on to the automotive 

refinishing facilities because of competitive pressures. However, we are unable to 

quantify these impacts. Potential costs to distributors include some cost sharing 

between the manufacturer and distributor to transition customers to new products such 

as water-borne color coatings. Staff does not have data on the extent to which such 

cost sharing might occur. 

Cost to Businesses 

The total cost to coating manufacturers is estimated to be $14.4 million in non-recurring 

costs. This equates to $3.2 million in annual cost. This estimate includes the cost to 

market and distribute compliant coatings in California, and is based on discussions with 

manufacturers (Taylor, 2005). 

The total cost to automotive refinishing facilities is estimated to be $65 million in nonrecurring costs and $5.7 million per year in recurring costs, assuming coating 

manufacturers pass on all their costs to automotive refinishing facilities. This equates to 

$13.9 million dollars annually. The non-recurring costs include the cost of obtaining air 

movement and heating equipment which may be necessary to use water-borne coatings 

and maintain the level of production, and equipment and training costs associated with 

switching from solvent-borne to water-borne coatings. 

Staff estimates there are about 4,100 automotive refinishing facilities in California. 

Since the large number of facilities makes it impractical to determine the impact on each 

facility, staff divided these facilities into general categories based on their annual 

revenue. Also, based on SCAQMD data, staff estimated the statewide number of 

heated spray booths and automotive refinishing facilities with multiple spray booths. 

Staff acknowledges that some facilities will experience cost impacts that differ from 

these estimates, but based on discussions with industry, the general assumptions are 

valid for typical facilities within each category. Table C-1 provides an overall summay of 

costs. Tables C-2 through C-4 summarize the estimated breakdown of costs for 
Automotive Coatings Suggested Control Measure 

C-3

automotive refinishing facilities (Elders, 2005; Decker, 2005; Phillips, 2005; SCAQMD, 

2005; Taylor, 2005; Hagan, 2005; Mac, 2005; Phillips, 2005). 

Table C-1 

Summary of Costs 

Annual Revenue Category 

Less Than 

1 Million 

Between 1 Million 

and 2.5 Million 

Greater Than 

2.5 Million Total 

Number of Facilities 2,952 883 278 4,113 

Facilities with One Booth/No Heat 2,332 

Non-Recurring Cost per Facility 6,600 

Annualized Cost 1,648 

Facilities with Two Booths/No Heat 620 503 1,123 

Non-Recurring Cost per Facility 8,200 42,000 

Annualized Cost 1,871 7,966 

Facilities with Two Booths/Existing Heat 380 69 449 

Non-Recurring Cost per Facility 16,000 48,000 

Annualized Cost 4,327 9,685 

Facilities with Three Booths/Existing Heat 209 209 

Non-Recurring Cost per Facility 68,000 

Annualized Cost 12,484 

Total Cost 20,475,200 27,206,000 7,524,000 65,205,200 

Total Annualized Cost 5,002,416 5,651,032 3,277,324 13,930,772 

 

Table C-2 

Estimated Cost for Facilities with Annual Revenue Less Than 1 Million 

Category Item 

Non-Recurring 

Costs 

Recurring 

Costs 

Annualized 

Cost* 

Air Movement Equipment 1,600 144

Other Equipment 1,500 185

Training 1,000 225

Material Loss 2,500 562

Operating and Maintenance Costs 155 155

Increased Cost of Coatings 378 378

Single 

Booth with 

No 

Heating 

Equipment

Total 6,600 1,648 

Air Movement Equipment 3,200 288

Other Equipment 1,500 185

Training 1,000 225

Material Loss 2,500 562

Operating and Maintenance Costs 235 235

Increased Cost of Coatings 378 378

Two 

Booths 

with No 

Heating 

Equipment

Total 8,200 1,871 
Automotive Coatings Suggested Control Measure 

C-4

Table C-3 

Estimated Cost for Facilities with Annual Revenue Between 1 Million and 2.5 Million 

Category Item 

Non-Recurring 

Costs 

Recurring 

Costs 

Annualized 

Cost* 

Air Movement Equipment 10,000 899 

Heating Equipment 26,000 2,338 

Other Equipment 1,500 185 

Training 2,000 449 

Material Loss 2,500 562 

Operating and Maintenance Costs 1,875 1,875 

Increased Cost of Coatings 1,657 1,657 

Two 

Booths 

with No 

Heating 

Equipment

Total 42,000 7,966 

Air Movement Equipment 10,000 899 

Other Equipment 1,500 185 

Training 2,000 449 

Material Loss 2,500 562 

Operating and Maintenance Costs 575 575 

Increased Cost of Coatings 1,657 1,657 

Two 

Booths 

with 

Existing 

Heating 

Equipment

Total 16,000 4,327 

Table C-4 

Estimated Cost for Facilities with Annual Revenue Greater Than 2.5 Million 

Category Item 

Non-Recurring 

Costs 

Recurring 

Costs Annualized Cost* 

Air Movement Equipment 40,000 3,598 

Other Equipment 1,500 185 

Training 4,000 899 

Material Loss 2,500 562 

Operating and Maintenance Costs 2,075 2,075 

Increased Cost of Coatings 2,367 2,367 

Two 

Booths 

with 

Existing 

Heating 

Equipment

Total 48,000 9,685 

Air Movement Equipment 60,000 5,396 

Other Equipment 1,500 185 

Training 4,000 899 

Material Loss 2,500 562 

Operating and Maintenance Costs 3,075 3,075 

Increased Cost of Coatings 2,367 2,367 

Three 

Booths 

with 

Existing 

Heating 

Equipment

Total 68,000 12,484 
Automotive Coatings Suggested Control Measure 

C-5

Impact on Businesses 

In evaluating the impact of the SCM on businesses, we assumed that all costs were 

either completely absorbed by coating manufacturers or by automotive refinishing 

facilities. This gives us a worst-case scenario for coating manufacturers and automotive 

refinishing facilities. In reality, it is likely that coating manufacturers and automotive 

refinishing facilities will absorb and pass on some of the cost, making the actual impact 

to businesses less than what is estimated here. 

To determine the maximum possible impact on coating manufacturers, we assumed 

they would absorb all costs relating to producing and marketing compliant coatings 

when calculating the change in “return on owner’s equity “(ROE). ROE is calculated by 

dividing the net profit by the net worth. 

To calculate the change in ROE, we subtracted the cost to manufacturers from profit 

data. The results were used to calculate an adjusted three-year average ROE. The 

adjusted ROE was then compared with the ROE before the subtraction of the adjusted 

cost to determine the potential impact on the profitability of the businesses. A reduction 

of more than 10 percent in profitability is considered to indicate a potential for significant 

adverse economic impacts. The analysis found an average decrease in ROE of about 

0.07 percent for coating manufacturers and 15 percent for automotive refinishing 

facilities. 

To determine the maximum impact on automotive refinishing facilities, we assumed that 

manufacturers would pass on all costs from the SCM to the automotive refinishing 

facilities. To project a worst-case scenario, we assumed the automotive refinishing 

facilities would absorb all costs that they directly incur, as well as all costs passed on by 

the manufacturers. As with the manufacturers, staff calculated the change in ROE for 

these automotive refinishing facilities. 

To determine the maximum impact on consumers, staff assumed that all costs from 

both the manufacturers and automotive refinishing facilities would be passed on to the 

consumers. If costs were passed on to the consumer, the impact would generally be in 

the form of higher insurance premiums and the total cost would be spread out among 

several million insured drivers in California. The impact to an individual consumer 

would be based on a number of factors such as type of insurance, driving history, and 

demographics. For this analysis, we assume costs would be directly passed on to 

consumers who need automotive refinishing. In this case, the average cost of having a 

vehicle refinished would increase by about $11. If the consumer is paying for the 

refinishing directly, he or she would have to absorb the entire cost. 

Annualized Costs 

We annualized non-recurring fixed costs using the Capital Recovery Method. Using this 

method, we multiplied the non-recurring fixed costs by the Capital Recovery Factor 
Automotive Coatings Suggested Control Measure 

C-6

(CRF) to convert these costs into equal annual payments over a project horizon at a 

discount rate. The Capital Recovery Method for annualizing fixed costs is 

recommended by Cal/EPA (Cal/EPA, 1996), and is consistent with the methodology 

used in previous cost analyses for ARB regulations (ARB, 2000a; ARB, 2000b). 

The CRF is calculated as follows: 

 CRF

i i

i

n

= n

+

+ −

( )

( )

1

1 1

 

where, 

 CRF = Capital Recovery Factor 

 i = discount interest rate in real terms (assumed to be 4%) 

 n = project horizon or useful life of equipment 

The costs of air movement and heating equipment for automotive refinishing facilities 

were annualized over 15 years, and all other equipment costs were annualized over 10 

years. These values are based on an estimate of the expected lifetime of the 

equipment. All other costs were annualized over 5 years. The total annualized cost 

was obtained by adding the annual recurring costs to the annualized fixed costs derived 

by the Capital Recovery Method. With regard to the discount rate, Cal/EPA 

recommends 2% plus the current yield for a U.S. Treasury Note of similar maturity to 

the project horizon. Treasury yields have been around 4% in recent years and when 

adjusted for an inflation rate of 2%, the corresponding discount rate is 4%. (CNN, 2005). 
Automotive Coatings Suggested Control Measure 

C-7

REFERENCES 

Air Resources Board. “Initial Statement of Reasons for Proposed Amendments to the 

Vapor Recovery Certification and Test Procedures for Gasoline Loading and Motor 

Vehicle Gasoline Refueling at Service Stations.” (ARB, 2000a). 

Air Resources Board. Staff Report for the Suggested Control Measure for Architectural 

Coatings. June 6, 2000. (ARB, 2000b). 

California Environmental Protection Agency, Memorandum from Peter M. Rooney, 

Undersecretary, to Cal/EPA Executive Officers and Directors. Economic Analysis 

Requirements for the Adoption of Administrative Regulations. Appendix C (Cal/EPA 

Guidelines for Evaluation Alternatives to Proposed Major Regulations).. December 6, 

1996. (Cal/EPA, 1996). 

Air Resources Board staff discussions with Al Ortiz, Rely-On Spray Booth Company. 

August, 2005. (Ortiz, 2005). 

Air Resources Board staff discussions with Cindy Elders, JunAir. July, 2005. (Elders, 

2005). 

Air Resources Board staff discussions with Emily Taylor, DuPont. July, 2005. (Taylor, 

2005). 

Air Resources Board staff discussions with Dave Harshbarger and Dave Luer, Mac 

Distributing. August, 2005. (Mac, 2005). 

Air Resources Board staff discussions with Greg Decker, Color Source Inc. July 14, 

2005. (Decker, 2005). 

Air Resources Board staff discussions with Karl Hagan, Air Filtration Company. August, 

2005. (Hagan, 2005). 

Air Resources Board staff discussions with Peter Phillips, Trisk Company. July, 2005. 

(Phillips, 2005). 

Air Resources Board staff discussions with South Coast Air Quality Management 

District Staff. August, 2005. (SCAQMD, 2005). 

Online quote of the yield on a 10 year and 5 year treasury bond, www.cnn.com. 

September, 2005. (CNN, 2005). 
Automotive Coatings Suggested Control Measure 

D-1 

Appendix D 

Categories that are not in the SCM 
Automotive Coatings Suggested Control Measure 

D-2 

The following district and U.S. EPA national rule categories have been 

reclassified into one or more of the categories included in the proposed SCM 

(see Table IV-1). 

Multi-Stage Topcoat System

The proposed SCM restructures the current district rules and establishes 

individual limits for the color and clear coatings. This restructuring is designed to 

enhance enforcement of district rules. Currently, most multi-stage systems 

consist of two stages, a color coating and a clear coating. The first stage of the 

finish, the basecoat or color coating, contains the pigments that give the finish 

the desired color. In the case of metallic finishes, the basecoat also contains the 

“metallic” flakes. The second stage of the finish is the clear coating, a durable 

finish that protects the basecoat. 

The purpose of the basecoat is to achieve the desired color tint and metallic 

appearance. Color coatings do not contain the additives needed to withstand 

chemical and ultraviolet deterioration, or the chemicals necessary to achieve a 

high gloss surface. Basecoats typically contain acrylic enamel, polyester, or 

urethane resins, and are designed to be easy spraying and quick drying to keep 

the base free of dirt and other contaminants. The quick-drying effect also locks 

the metallic flakes in position to achieve a mottle-free finish. 

To protect the basecoat, a durable clear coating is applied. This clear coating 

can often be applied over the color coating after only 15 to 30 minutes of cure 

time. Clear coatings typically contain acrylic urethane or polyurethane resins, 

although acrylic enamel and lacquer clears are also available. Clear coatings are 

designed to flow upon application, resulting in a smooth, glass-like finish in as 

few as two coats. 

Most districts allow for two- and three-stage systems, with some having a fourstage system as well. A two-stage system consists of a basecoat and a clear 

coating. Three-stage systems are a two-stage system with either a midcoat or 

groundcoat. Four stage systems are two stage systems with both a midcoat and 

a groundcoat. 

The basecoat is the main color coating. The clear coating provides gloss and 

durability. Groundcoats are typically tinted primers, however district definitions 

vary. Midcoats can be translucent color coatings (achieved by adding filler to a 

color coating to reduce the pigment density) or tinted clear coatings. 

ARB staff’s evaluation of the multi-stage topcoat system indicates that up to three 

of the four stages in a four-stage system may be color coatings. Alternatively, 

two stages of a three-stage system may consist of a clear coating and a modified 

clear coating. 
Automotive Coatings Suggested Control Measure 

D-3 

The composite VOC system was created to provide manufacturers flexibility in 

complying with lower VOC limits. To comply with the lower VOC limits, 

manufacturers have formulated lower VOC clear coatings and retained high VOC 

color coatings. 

The methodology for calculating the composite VOC limit for multi-stage systems 

assumes that the volume of clear coating applied is twice the volume of the color 

coating. The 2002 Survey data indicate this is not the case. The volume of color 

coating sold was about 2.5 times the volume of clear coating sold. 

Consequently, in consultation with the districts, ARB staff split the multi-stage 

system into two categories for analysis – color coatings and clear coatings. 

Most district rules currently specify a multi-stage system limit of 420 or 540 g/l. 

Because the composite VOC calculation method assumes two gallons of clear 

coating are applied for every gallon of color coating, manufacturers have focused 

on lowering the VOC content of the clear coatings. This compliance approach 

has enabled color coatings to retain a VOC content ranging from 600 to 800 g/l. 

The proposed SCM sets separate VOC limits for color coatings and clear 

coatings. 

Metallic/Iridescent

Metallic/Iridescent coatings are either a single-stage or multi-stage coating that 

contains more than 0.042 pounds per gallon (5 g/l) of metal or iridescent particles 

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

Metallic colors contain various sizes of aluminum flakes. These flakes have 

reflective properties and when used in various combinations and/or amounts, 

modify the optical characteristics of the color. Metallic pigment consists of thin 

opaque aluminum flakes (made by ball milling either a disintegrated aluminum 

foil or a rough metal powder and then polishing to obtain a flat, brilliant surface 

on each particle) or copper alloy flakes (known as bronze pigments). These 

coatings produce silvery and other metal-like effects. Iridescent coatings contain 

mica in various sizes to create what is called a pearlescent effect. 

Either a metallic or iridescent pigment is mixed with a base color to create the 

metallic or pearl color. There is no difference between the base color for a solid 

color and a metallic/iridescent color. They are mixed from the same tint bank at 

the auto body shop. Thus, metallic/iridescent coatings are included in the color 

and single-stage coating analyses above. 
Automotive Coatings Suggested Control Measure 

D-4 

Primer Sealer

Primer sealers are applied prior to the topcoat, if necessary. Sealers provide 

adhesion between the topcoat and the surface, provide a neutral colored base for 

easy coverage, seal sanded surfaces to prevent solvent penetration, and fill 

minor surface imperfections. Sealer types include lacquer sealers, enamel 

sealers, and urethane sealers. These sealers are intended to be coated by 

lacquer, enamel, and urethane topcoats, respectively, and generally require only 

one coat prior to application of the topcoat. In addition to general sealers, there 

are specialty sealers available for use on specific problem surfaces. 

Some sealers reported in the 2002 Survey comply with the proposed VOC limit. 

However, some manufacturers have stated that the 250 g/l sealers are intended 

for the fleet vehicle market and are not suitable for the collision repair industry. 

Other manufacturers have stated that that they can formulate sealers for the 

collision repair industry that comply with the proposed limit of 250 g/l. One 

manufacturer has marketed a compliant sealer to the collision repair industry for 

almost a year. Primer sealers are included in the primer category. We believe 

that primer sealers can be formulated to be in compliance with the proposed 

primer limit. We have included primer sealer in the primer analysis above. 

Primer Surfacer

Primer surfacers are typically high-solids automotive coatings applied over prep 

coats, such as pretreatment coatings, precoat, or adhesion promoters. Primer 

surfacers function to provide adhesion between the prep coat and the material to 

be applied over the primer surfacers. They provide corrosion protection, act as a 

filling material to cover minor surface flaws, and provide a surface that can be 

easily sanded to a smooth surface. District rules currently establish the same 

VOC limit for primer surfacers and primers. We propose to continue this in the 

proposed SCM. We have included primer surfacers in the primer category. 

Precoat

Precoats are coatings that are applied directly to bare metal primarily to 

deactivate the metal surface prior to application of a subsequent coating. 

Precoats commonly dry by oxidation or chemical polymerization. The SCAQMD 

treats these coatings as primers. Most other district rules allow for precoat usage 

at a higher VOC content than primers, but limit the amount of precoat that can be 

used. 

Approximately 65 percent of the coatings reported in the survey as precoats were 

also listed as plastic primers, which is in conflict with its defined purpose. 

Another nine percent were listed as surfacers and three percent were listed as 

ground coats. 
Automotive Coatings Suggested Control Measure 

D-5 

Based on this information, the precoat category is included in the primer 

category. The precoats were included in the primer analysis above. 

Camouflage

Camouflage is a pigmented coating used primarily by the military to make it more 

difficult for vehicles and equipment to be visually located by enemy forces. 

Camouflage coating can also be applied to hide vehicles and equipment from 

game by hunters. Camouflage is applied in patterns with different shades of a 

color. 

One district lists camouflage as a specialty coating. Some districts list 

camouflage as a distinct coating category. The districts that list it as a distinct 

category only do so for mobile equipment and not for motor vehicles, which are 

also painted by the military with camouflage. The districts that have this category 

give it the same VOC limit as their general topcoat limit. For motor vehicles they 

treat camouflage as any other topcoat. There is nothing in these districts’ 

definitions regarding any special physical properties for camouflage as opposed 

to any other color coating. Thus, camouflage coatings are included in the color 

coat analysis above. 

Extreme Performance Coatings

Eight districts list extreme performance coatings as a distinct coating category. 

These districts allow a VOC content of either 420 g/l or 750 g/l. There are four 

different definitions used in these eight districts. Five districts define extreme 

performance coatings as coatings which are exposed to extreme environmental 

conditions such as high temperatures, corrosive or erosional environments, 

during principal use. One district defines extreme performance coatings as 

coatings that are intended, during use, to be exposed to: 1) industrial grade 

detergents, cleaners, or abrasive scouring agents; 2) unprotected shipboard 

conditions; or 3) corrosive environmental conditions. Another district defines 

these products as coatings which during intended use are exposed to any of the 

following conditions: a) industrial grade detergents, cleaners, or abrasive 

scouring agents; b) extreme environmental conditions as determined by the Air 

Pollution Control Officer during the vehicle’s principal use; c) chronic exposure to 

corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical 

mixtures or solution; d) repeated exposure to temperatures in excess of 250 

degrees Fahrenheit; or e) repeated heavy abrasion, including mechanical wear 

and repeated scrubbing with industrial grade solvents, cleaners, or scouring 

agents. The last district defines these coatings as coatings which during 

intended use are exposed to any of the following conditions: a) chronic exposure 

to corrosive, caustic or acidic agents, chemicals, chemical fumes, chemical 

mixtures or solutions; b) repeated exposure to temperatures in excess of 250 

degrees Fahrenheit; c) repeated heavy abrasion, including mechanical wear and 
Automotive Coatings Suggested Control Measure 

D-6 

repeated scrubbing with industrial grade solvents, cleansers, or scouring agents; 

or d) exterior exposure of steel and non-ferrous metal structures. 

Only one district lists this type of coating as a specialty coating. This district 

defines extreme performance coatings as coatings that encounter acute or 

chronic exposure to salt water, corrosives, caustics, acids, oxidizing agents, 

wind- or ocean-driven debris, or electromagnetic pulses. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of anyone applying these coatings to vehicles in 

California. 

Specialty Coating

Specialty coatings are high VOC coatings (up to 840 g/l) that have historically 

been necessary due to unusual job performance requirements. Specialty 

coatings include, but are not limited to, truck bed liner coating, adhesion 

promoter, elastomeric materials, anti-glare/safety coatings, impact resistant 

coatings, rubberized asphaltic underbody, water hold-out coatings, weld-thru 

coatings, bright metal trim repair, camouflage, and extreme performance 

coatings. The U.S. EPA automotive coatings rule defines specialty coatings to 

include only adhesion promoters, low-gloss coatings, bright metal trim repair 

coatings, jambing (cut-in) clear coats, elastomeric coatings, impact resistant 

coatings, underbody coatings, uniform finish blenders, and weld-through primers. 

Three districts’ (SCAQMD, Antelope Valley AQMD, and Sacramento Metropolitan 

AQMD) definitions of specialty coating do not contain the “but not limited to” 

clause or an equivalent phrase. For these districts, only the listed coatings can 

be used as specialty coatings. One district, Sacramento Metropolitan AQMD, 

requires manufacturers to specifically designate their specialty coatings as such. 

For all other districts the definition is not specific. 

Specialty coating usage at body shops is limited to either five to ten percent of 

total coating usage depending upon the district. Some districts have a volume 

usage as an alternative to the percentage usage. These districts allow one 

gallon per day or three gallons per month of specialty coating use per facility. 

Because of the variability in district requirements, we evaluated each category 

listed in district rules as a specialty coating individually. ARB staff evaluated 

what special attributes or function each coating type provides, and what VOC 

content was necessary to provide said attributes or function. ARB staff then set 

individual category definitions and higher VOC content limits for categories as 

necessary. 
Automotive Coatings Suggested Control Measure 

D-7 

Elastomeric Material

Elastomeric materials are coatings that are formulated for application over 

flexible substrates such as plastic parts, elastomeric bumpers, and spoilers. All 

districts, except for one, and the national rule identify elastomeric materials as 

specialty coatings. However, only five districts and the national rule have a 

definition for “elastomeric materials.” Two types of products were listed in the 

2002 Survey as elastomeric materials. They are elastomeric primers and 

elastomeric clears. The elastomeric primer mixtures reported in the survey had a 

slightly higher VOC content than the 250 g/l VOC limit proposed for primers in 

the SCM. The elastomeric clear mixtures reported in the survey had a VOC 

content ranging from about 480 to 550 g/l. 

Many elastomeric materials are created by using plasticizing additives mixed with 

another mixture, as opposed to using an elastomeric base component. This 

allows for a wide variety of elastomeric materials while keeping the number of 

components to a minimum. 

Based on discussions with manufacturers, ARB staff determined that elastomeric 

additives have a VOC content less than 250 g/l. Therefore, addition of these 

additives to clear coatings or primers will not result in exceedances of the 250 g/l 

VOC limits proposed for these categories. Elastomeric clears are included in the 

clear coating category and elastomeric primers are included in the primer 

category. 

Anti-Glare Safety Coating

Anti-glare safety coatings are coatings that minimize light reflection for safety 

purposes. The commonly used standard is a reflectance of 25 or less on a 60 

degree gloss meter. Some districts restrict usage to the interior of a vehicle. All 

districts except one identify this as a specialty coating, however the district 

definitions vary regarding reflection allowed and vehicle application. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of these coatings being used in California. If these 

coatings are used in the future, they will be included in the clear coating, color 

coating, or single-stage coating category, as is appropriate, based on usage. 

Impact Resistant Coating

Impact resistant coatings are coatings designed to resist chipping caused by 

road debris. Typical usage for impact resistant coatings would be on rocker 

panels. While all districts except one identify this as a specialty coating, only four 

districts and the U.S. EPA national rule define these coatings. 
Automotive Coatings Suggested Control Measure 

D-8 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of these coatings being used in California. If these 

coatings are used in the future, they will be included in the clear coating or 

single-stage coating category, as is appropriate, based on usage. 

Water Hold-Out Coating

Water hold-out coating is a coating applied to the interior cavity of doors, quarter 

panels, and rocker panels for the purpose of corrosion resistance to prolonged 

water exposure. While all districts and the U.S. EPA national rule include this as 

a specialty coating, only three districts and the U.S. EPA national rule define the 

coating. This definition meets the existing district definition of a primer. 

Therefore, water hold-out coatings are included in the primer category. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of anyone applying these coatings to vehicles in 

California. 

Weld-Thru Coating

Weld-thru coatings are primers applied to metal immediately prior to welding to 

provide corrosion resistance. While all districts allow this as a specialty coating, 

only ten districts and the U.S. EPA national rule define these coatings. This 

definition meets existing districts’ definitions of a primer. Therefore, weld-thru 

coatings are included in the primer category. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of anyone applying these coatings to vehicles in 

California. 

Bright Metal Trim Repair

Bright metal trim repair is a coating applied directly to a metal-plated surface to 

restore the luster and texture of the plated surface. While districts include these 

products in the specialty coating category, only five districts have a definition for 

these coatings. The U.S. EPA national rule does not define this type of coating. 

Four of the five districts with definitions restrict the usage to chrome-plated metal 

surfaces. 

No products were reported in the 2002 Survey as bright metal trim repair. We 

have no knowledge of anyone applying these coatings to vehicles in California. 
Automotive Coatings Suggested Control Measure 

D-9 

Gloss Flattener

Low-gloss coatings, also called gloss flatteners, are coatings that exhibit a gloss 

reading less than or equal to 25 on a 60 degree gloss meter. The U.S. EPA 

national rule and 15 district rules include these products in the specialty coating 

category. However, only the U.S. EPA national rule defines these coatings. 

No coatings in this specific category were reported as being sold in California in 

2001. As discussed in the clear coating category section above, these coatings 

can comply with the clear coating VOC limit and do not need a higher VOC limit. 

Heat Resistant

Heat resistant coatings are coatings which, during normal use, must withstand 

temperatures of at least 400 degrees Fahrenheit. Only one district lists this type 

of coating as a specialty coating. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of anyone applying these coatings to vehicles in 

California. 

Jambing (Cut-In) Clear Coat

Jambing, or cut-in, clear coats are fast-drying, clear coatings applied to surfaces 

such as door jambs and trunk and hood edges to allow for quick closure. This 

coating is only referenced in the U.S. EPA national rule. No districts list this type 

of coating in their specialty coating definitions. 

No coatings in this category were reported as being sold in California in 2001. 

We have no knowledge of anyone applying these coatings to vehicles in 

California.