7/06 Rule 74.30: 1

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

RULE 74.30 - WOOD PRODUCTS COATINGS 

(Adopted 5/17/94, Revised 9/10/96, 11/11/03, 6/27/06) 

A. Applicability 

 The provisions of this rule apply to any person who manufactures, supplies, uses, or 

specifies the use of wood products coatings for commercial use. 

B. Requirements 

1. For either a new wood product or new product made of simulated wood materials, 

no person shall use any coating that has an ROC (reactive organic compound) 

content, as applied, exceeding the applicable limit specified below: 

ROC LIMITS 

Grams Per Liter and 

Pounds per Gallon of Coating, 

Less Water and Exempt Compounds

 On and After 

 7/1/1996 

COATING (g/L) (lb/gal)

Clear topcoats..................................................................................275 (2.3) 

Filler................................................................................................275 (2.3) 

High-solid Stains.............................................................................240 (2.0) 

Inks..................................................................................................500 (4.2) 

Mold-seal Coating...........................................................................750 (6.3) 

Multi-colored Coating.....................................................................275 (2.3) 

Pigmented Coating..........................................................................275 (2.3) 

Sealer...............................................................................................240 (2.0) 

ROC LIMITS 

Grams Per Liter of Material

 On and After 

 7/1/1996 

COATING (g/L) (lb/gal)

Low-solids Stains, ..........................................................................120 (1.0) 

Toners, or Washcoats 
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2. For a refinishing operation necessary to repair, preserve, or restore a wood 

product, no person shall use any coating that has an ROC content, as applied, 

exceeding the applicable limit specified below: 

ROC LIMITS 

Grams Per Liter and 

Pounds per Gallon of Coating, 

Less Water and Exempt Compounds

 On and After 

 7/1/1995 

COATING (g/L) (lb/gal)

Clear topcoat ...................................................................................680 (5.7) 

Filler................................................................................................500 (4.2) 

High-solid Stains.............................................................................700 (5.8) 

Inks..................................................................................................500 (4.2) 

Mold-seal Coating...........................................................................750 (6.3) 

Multi-colored Coating.....................................................................680 (5.7) 

Pigmented Coating..........................................................................600 (5.0) 

Sealer...............................................................................................680 (5.7) 

ROC LIMITS 

Grams Per Liter of Material

 On and After 

 7/1/1995 

COATING (g/L) (lb/gal)

Low-solids Stains, Toners, or Washcoats .......................................480 (4.0) 

3. No person shall use any stripper on wood products unless: 

a. The ROC content is 350 grams per liter (2.9 lb/gal) of material or less; or 

b. The ROC composite partial pressure of the stripper is 

2 mm Hg (0.04 psia) or less at 20oC (68oF). 

4. No person shall apply coatings to wood products unless the coating is applied 

with properly operating equipment, according to proper operating procedures, and 

by the use of one of the following methods: 

a. electrostatic application, operated at a minimum of 60 KV; 

b. flow coat; 
7/06 Rule 74.30: 3 

c. dip coat; 

d. high-volume, low-pressure (HVLP) spray; 

e. paint brush; 

f. hand roller; 

g. roll coater; or 

h. such other coating application methods as are demonstrated to the APCO 

to be capable of achieving at least 65 percent transfer efficiency, and for 

which written approval of the APCO has been obtained. 

5. Surface Preparation and Cleanup Solvent 

a. After September 25, 2006, no person shall use a material for surface 

preparation that has an ROC content exceeding 25 grams per liter of 

material. 

 On or before September 25, 2006, no person shall use ROC-containing 

materials which have more than 200 grams of ROC per liter of material for 

surface preparation. 

b. After September 25, 2006, no person shall use a material for either spray 

equipment cleaning or cleanup that has an ROC content exceeding 25 

grams per liter of material. 

 On or before September 25, 2006, no person shall use ROC-containing 

materials for spray equipment cleaning unless: 

1) The system used: 

a) Is an enclosed gun washer or "low emission spray gun 

cleaner" that has been approved in writing by the APCO 

and is properly used for cleaning; or 

b) Has been demonstrated to the APCO to be as effective as 

the equipment described in the subparagraph above in 

minimizing the loss of the ROC-containing material to the 

atmosphere according the test method in Subsection E.4. 

2) The ROC composite partial pressure of organic solvent used is less 

than 45 mm Hg at a temperature of 20o

C. 
7/06 Rule 74.30: 4 

c. On or before September 25, 2006, no person shall use ROC-containing 

materials for cleanup unless the ROC composite partial pressure of organic 

solvent used is less than 45 mm Hg at 20o

C. 

6. In lieu of the requirements of Subsections B.1, B.2, B.3 and B.4, emissions of 

ROC, excluding emissions from clean up operations, may be controlled by an 

emission capture and control system, which reduces ROC emissions to the 

atmosphere, provided that: 

a. During any period of continuous operation not to exceed 24 hours, the 

capture and control system shall have a combined efficiency of at least 90 

percent, by weight. 

b. The collection system shall vent all drying oven exhaust to the control 

device and shall have one or more inlets for collection of fugitive 

emissions. 

c. During any period of operation of a thermal incinerator, combustion 

temperature shall be continuously monitored. 

d. During any period of operation of a catalytic incinerator, exhaust gas 

temperature shall be continuously monitored. 

e. Written approval for such equipment, in the form of an Authority to 

Construct and Permit to Operate, is received from the APCO. 

7. Storage of ROC-containing materials: All ROC containing materials, including, 

but not limited to surface coatings, cleanup solvents, or surface preparation 

materials shall be stored in closed containers which are nonabsorbent and do not 

leak. 

8. No person shall specify the use in the District of any coating to be applied to any 

wood products subject to the provisions of this rule that does not meet the limits 

and requirements of this rule. 

9. The manufacturer of any coating or stripper subject to this rule shall designate on 

the coating container or on separate data sheet(s) the maximum VOC content of 

the coating, as supplied. The VOC content, except for low-solids stains, toners, 

and washcoats, shall be expressed as grams per liter of coating (less water and less 

exempt organic compounds). 

10. Cleaning and Stripping Material Compliance Statement: The manufacturer of 

liquid cleaning materials or strippers subject to this rule shall designate on product 

labels or data sheets the ROC content and ROC Composite Partial Pressure of 

cleaning materials as supplied. This designation shall include recommendations 
7/06 Rule 74.30: 5 

regarding mixing with any other ROC containing materials, and express the 

cleaning material ROC content when used in accordance with the manufacturer's 

recommendations. All letters and numbers used to designate ROC or VOC 

content on product labels shall be visible and legible. (Effective September 10, 

1997) 

C. Exemptions 

1. The provisions of this rule shall not apply to aerosol coating products. 

2. Sections B.1, B.2, B.3, B.4, and B.5 of this rule, shall not apply to any stationary 

source that emits less than 200 pounds of ROC in every rolling period of 12 

consecutive calendar months from wood products coating operations. Any person 

claiming this exemption shall maintain monthly records to substantiate this claim. 

Emissions from aerosol products, cold cleaners, and vapor degreasers shall not be 

included in this determination. 

 3. This rule shall not apply to the coating of building appurtenances such as cabinets, 

shutters, fences and handrails coated at the site of permanent installation. 

 4. The limits in subsection B.1 and B.2 for Pigmented Coatings, Fillers, Washcoats, 

Sealers and Clear Topcoats shall not apply to the coating of wooden musical 

instruments. 

D. Recordkeeping Requirements. 

Any person subject to this rule shall: 

1. Maintain a current file for each coating in use and in storage. The file shall 

include a data sheet or material list giving material name, manufacturer 

identification, specific mixing instructions, and ROC content as applied. 

2. Maintain a current file for each solvent and stripper in use and in storage. The file 

shall include a data sheet or material list giving material name, manufacturer 

identification, ROC content and, if required, ROC composite partial pressure. 

3. Maintain records on a daily basis showing the amount of coatings, strippers, and 

solvents used. Itemize each coating, stripper, and solvent and use the specific 

ROC content and density value for each. If only compliant coatings, strippers and 

solvents are used, these records may be kept on a monthly basis. 

4. If compliance is achieved through the use of emission control equipment maintain 

daily records of key system operating parameters and maintenance procedures that 

demonstrate continuous operation and compliance of the emission control system 

during periods of emission producing activities. Key system operating parameters 
7/06 Rule 74.30: 6 

for emission control equipment are those necessary to ensure compliance with 

ROC content of coating requirements such as temperatures, pressures, and flow 

rates. 

5. Inventory, usage, and emission control equipment operation records shall be 

retained for a minimum of two years and shall be made available to District 

personnel upon request. 

E. Test Methods 

1. Measurement of the ROC content of coatings, strippers, and solvents shall be 

conducted and reported in accordance with EPA Reference Method 24, 

“Determination of Volatile Matter Content, Water Content, Density, Volume 

Solids, and Weight Solids of Surface Coatings,” and ARB Method 432, 

“Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and 

Coatings,” for determination of exempt compounds as necessary. 

2. ROC composite pressure shall be calculated using a widely accepted published 

source such as: Boublik, T., V. Fried and E. Hala, "The Vapor Pressure of Pure 

Substances," Elsevier Scientific Publishing Co., New York (1973), Perry's 

Chemical Engineer's Handbook, McGraw-Hill Book Company, CRC Handbook 

of Chemistry and Physics, Chemical Rubber Publishing Company (1986-87), and 

Lange's Handbook of Chemistry, John A. Dean, editor, McGraw-Hill Book 

Company (1985). The true vapor pressure of a component in a mix may be 

determined by ASTM Method D2879-86. The ROC composite pressure of a 

solvent mix consisting entirely of ROC may be determined by ASTM Method 

D2879-86. 

3. Transfer efficiency shall be determined in accordance with South Coast Air 

Quality Management District method Spray Equipment Transfer Efficiency Test 

Procedure for Equipment User, May 24, 1989. 

4. The active and passive solvent losses from spray gun cleaning systems shall be 

determined using South Coast Air Quality Management District's "General Test 

Method for Determining Solvent Losses from Spray Gun Cleaning Systems" dated 

October 3, 1989 or later. The test solvent for this determination shall be any 

lacquer thinner with a minimum ROC composite partial pressure of 105 mm Hg at 

20oC. The minimum test temperature shall be 15oC. 

5. Capture efficiency shall be determined according to EPA Guidelines for 

Determining Capture Efficiency, dated January 9, 1995, and 40 CFR 51, 

Appendix M, Methods 204-204F as applicable. Control system efficiency shall be 

determined by 40 CFR 60, Appendix A, Methods 18, 25 or 25A.
7/06 Rule 74.30: 7 

6. High Volume-Low Pressure (HVLP) equipment shall be identified by either test 

air cap measurements or an inlet pressure measurement that, when used with 

specifications published by the manufacturer, establishes that gun is being 

operated as specified in Subsection G.16. 

F. Violations 

Failure to comply with any provision of this rule, including recordkeeping requirements, 

shall constitute a violation of this rule. 

G. Definitions 

For the purposes of this rule, the following definitions shall apply: 

1. "Active Solvent Losses": The active solvent losses are the emissions during all 

steps of a spray gun equipment cleaning operation and are expressed in units of 

grams of solvent loss per cleaning cycle. 

 2. "Aerosol Coating Product"; A pressurized coating product containing pigments or 

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

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

equipment for ground traffic/marking applications. 

3. "Binders": Nonvolatile polymeric organic materials (resins) which form the 

surface film in coating applications. 

4. "Clear Topcoat": A final coating which contains binders, but not opaque 

pigments, and is specifically formulated to form a transparent or translucent solid 

protective film. 

 5. "Cleanup": The removal of uncured coating from any surface. 

6. "Coating": A material which is applied to a surface and which forms a film in 

order to beautify and/or protect such surface. 

7. "Dip Coat": Dip an object into a vat of coating material and drain off any excess 

coating. 

8. "Electrostatic Application": Charging of atomized paint droplets for deposition 

by electrostatic attraction. 

9. "Exempt Organic Compounds": As defined in Rule 2, Definitions, of these Rules. 

10. "Filler": A composition that hardens on drying used to fill pores, cracks, or holes 

in a wood product prior to finishing. 
7/06 Rule 74.30: 8 

11. "Flow Coat": Coat an object by flowing a stream of coating over an object and 

draining off any excess coating. 

12. "Grams of ROC per Liter of Coating, Less Water and Exempt Organic 

Compounds": The weight of ROC per combined volume of ROC and coating 

solids calculated using the following equation: 

Grams of ROC per Liter of Coating, Less 

Water and Exempt Organic Compounds = Ws - Ww - Wes

Vm - Vw - Ves 

Where: Ws = weight of volatile compounds in grams 

Ww = weight of water in grams 

Wes = weight of exempt organic compounds in grams 

Vm = volume of material in liters 

Vw = volume of water in liters 

Ves = volume of exempt organic compounds in liters 

13. "Grams of ROC per Liter of Material": The weight of ROC per volume of 

material shall be calculated by the following equation: 

Grams of ROC per Liter of Material = Ws - Ww - Wes

Vm 

Where: Ws = weight of volatile compounds in grams 

Ww = weight of water in grams 

Wes = weight of exempt organic compounds in grams 

Vm = volume of material in liters 

14. "Gun Washer": Electrically or pneumatically operated system that is designed to 

clean spray application equipment while enclosed. A gun washer may also be 

considered a gun cleaning system that consists of spraying solvent into an 

enclosed container using a snug fitting. 

15. "High-solids Stains": Stains containing more than 1 pound of solids per gallon, 

by weight, and can include wiping stains, glazes, and opaque stains. 

16. "High Volume-Low Pressure (HVLP)": Equipment used to apply coatings by 

means of a spray gun designed to be operated and operated between 0.1 and 10 

pounds per square inch gauge (psig) air pressure measured dynamically at the 

center of the air cap and at the air horns. 

17. "Ink": A fluid, containing dyes and/or colorants, used to make markings but not 

used to protect surfaces. 
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18. "Low Emission Spray Gun Cleaner": Any properly used spray equipment cleanup 

device which has passive solvent losses of no more than 0.6 grams per hour and 

has active solvent losses of no more than 15 grams per operating cycle as defined 

by the test method in Subsection E.4. 

19. "Low-solids Stains": Stains containing 1 pound of solids per gallon, or less, by 

weight. 

20. "Mold-seal Coating": The initial coating applied to a new mold or repaired mold 

to provide a smooth surface that, when coated with a mold release coating, 

prevents products from sticking to the mold. 

21. "Multi-colored Coating": A coating which exhibits more than one color when 

applied, and which is packaged in a single container and applied in a single coat. 

22. "New Wood Product": A wood product or simulated wood product which has not 

been previously coated and from which cured coatings have not been removed. A 

wood product or simulated wood product from which uncured coatings have been 

removed to repair flaws in initial coatings application is a new wood product. 

23. "Passive Solvent Losses": The passive solvent losses are the emissions from 

spray gun cleaning equipment when the equipment sits idle between cleaning 

cycles and are a result of natural evaporation from the equipment. 

24. "Pigmented Coatings": Opaque coatings which contain binders and colored 

pigments which are formulated to hide the wood surface, either as an undercoat or 

topcoat. 

25. "Reactive Organic Compound (ROC)": As defined in Rule 2, Definitions, of 

these rules. The term "volatile organic compound (VOC)" is equivalent to ROC. 

 26. ROC Composite Partial Pressure": The sum of the partial pressures of the 

compounds defined as ROCs. ROC composite partial pressure is calculated as 

follows: 

( )( )

( ) PP

W VP

MW

W

MW

W

MW

W

MW

c

i i

i i

n

w

w

e

e e

n i

i i

n = 



 



 + 



 



 + 



 





=

= =

∑

∑ ∑

1

1 1

 Where: 

 Wi = Weight of the "i"th ROC compound, in grams 

 Ww = Weight of water, in grams 

 We = Weight of the "e"th exempt organic compound, in grams 

 MWi = Molecular weight of the "i"th ROC compound, in g/(g-mole) 
7/06 Rule 74.30: 10 

 MWw = Molecular weight of water, in g/(g-mole) 

 MWe = Molecular weight of the "e"th exempt organic compound, in g/(g-mole) 

 PPc = ROC composite partial pressure at 20 C, in mm Hg 

 VPi = Vapor pressure of the "i"th ROC compound at 20 C, in mm Hg. 

27. "Refinishing Operation": The steps necessary to remove cured coatings and to 

repair, preserve, or restore a wood product. 

28. "Repair Coating": A coating used to recoat portions of a product which has 

sustained mechanical damage to the coating following normal painting operations. 

29. "Roll Coater": A series of mechanical rollers that forms a thin coating film on the 

surface of roller, which is applied to a substrate by moving the substrate 

underneath the roller. 

30. "Sealer": A coating, containing binders, which seals the wood prior to application 

of the subsequent coatings. 

31. "Simulated Wood Materials": Materials, such as formica, glass, metal, plastic, 

etc., that are made to give a wood-like appearance or are processed like a wood 

product. 

32. "Stencil Coating": An ink or a pigmented coating which is rolled or brushed onto 

a template or stamp in order to add identifying letters and/or numbers to wood 

products. 

33. "Stripper": A liquid used to remove cured coatings, cured inks, and/or cured 

adhesives. 

 34. "Surface Preparation": Cleaning of a substrate to remove dirt, oils, and other 

contaminants. Surface preparation does not include stripping. Surface 

preparation is typically done prior to the application of surface coatings, adhesive 

bonding materials, or sealants. 

35. "Toner": A wash coat which contains binders and dyes or pigments to add tint to 

a coated surface. 

36. "Touch up Coating": A coating used to cover minor coating imperfections 

appearing after the main coating operation. 

37. "Transfer Efficiency": The ratio of the weight of coating solids deposited on an 

object to the total weight of coating solids used in a coating application step, 

expressed as a percentage. 
7/06 Rule 74.30: 11 

38. "Wash Coat": A coating that contains no more than 1.0 pound of solids per 

gallon, by weight, which is used to seal wood surfaces, prevent undesired staining, 

and control penetration. 

39. "Wood Products": Those surface-coated room furnishings including cabinets 

(kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, and art objects; and 

any other coated objects made of solid wood, and/or wood composition, and/or 

made of simulated wood material used in combination with solid wood or wood 

composition. 

40. "Wood Product Coating Application Operations": A combination of coating 

application steps which may include use of spray guns, flash-off areas, spray 

booths, ovens, conveyors, and/or other equipment operated for the purpose of 

applying coating materials.