SAN DIEGO AIR POLLUTION CONTROL DISTRICT

Regulation IV -1- Rule 67.4

RULE 67.4. METAL CONTAINER, METAL CLOSURE AND METAL COIL

COATING OPERATIONS (Effective 5/9/79: Rev. Adopted & Effective 

5/15/96; Rev. Adopted and Effective 11/09/11)

(a) APPLICABILITY

(1) This rule applies to all metal container, metal closure and metal coil coating 

operations in which volatile organic compounds (VOCs) are employed.

(2) Operations subject to this rule shall not be subject to Rule 66.1 or 67.3.

(b) RESERVED

(c) DEFINITIONS

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

(1) "Cleaning Material" means a VOC containing material used for cleaning 

hands, tools, application equipment and work area.

(2) "Closure" means any metal component which is used to close or seal a container.

(3) "Coating Line" means an operation or process for applying, drying or oven 

baking and/or curing surface coatings, together with associated equipment including a 

coating applicator, flash-off area and oven.

(4) "Coil" means any flat metal sheets or strips that have been formed into rolls or 

in concentric rings for further industrial or commercial use.

(5) "Container" means any can, pail or drum.

(6) "Drum" means any manufactured or reconditioned cylindrical metal container 

that has a capacity larger than 12 gallons but smaller than 110 gallons. 

(7) "End" means a part of a container which is used for its closure after the 

container is filled with a product.

(8) "End Sealing Compound" means a compound which is coated onto a container 

closure and which functions as a gasket when the closure is assembled onto the container.

(9) "Exempt Compound" means the same as defined in Rule 2. 

(10) "Exterior Base Coating" means a coating applied to the exterior of a 

container, body, closure or flat sheet to provide a protection to the metal or to provide 

background for any lithographic operation.

(11) "Exterior Body Spray" means a coating sprayed on the exterior of the 

container body to provide a decorative or protective finish.
Regulation IV -2- Rule 67.4

(12) "Food/Beverage Container" means a metal container in which food or 

beverages intended for human consumption are packaged.

(13) “High-Volume Low-Pressure (HVLP) Spray” means a coating application 

method using a spray applicator and pressurized air which is designed to be operated and 

which is operated at an atomizing pressure between 0.1 and 10.0 psig, measured 

dynamically at the center of the applicator’s air cap and at the applicator’s air horns.

(14) "Interior Base Coating" means a coating applied to the interior of a container 

body or end or flat sheet to provide a protective lining between the product and the 

container.

(15) "Interior Body Spray" means a coating sprayed on the interior of the 

container to provide a protective film between the product and the container.

(16) "Letterpress Coating" means an acrylate-based topcoat which is used for 

coating letterpress printing plates during the manufacture of such plates.

(17) "Lid" means a reusable closure.

(18) "Metal Container, Metal Closure, and Metal Coil Coating" means any 

coating containing VOCs applied by spray, roller or other means to the inside and/or 

outside of metal containers, drums, pails, lids, closures or to the surface of flat sheets, rolls, 

or coil for further industrial or commercial use.

(19) "Overvarnish" means a coating applied directly over a design coating to 

reduce the coefficient of friction, to provide gloss and to protect the finish against abrasion 

and corrosion.

(20) "Pail" means any manufactured or reconditioned cylindrical metal container 

with a capacity between one and 12 gallons, and constructed of 29 gauge material or 

heavier.

(21) "Pet Food Container" means a metal container in which food for animal (nonhuman) consumption is packaged.

(22) "Stationary Source" means the same as defined in Rule 2.

(23) "Three-Piece Container Side-Seam Spray" means a coating sprayed on the 

exterior and/or interior of a welded, cemented or soldered seam to protect the exposed 

metal.

(24) "Two-Piece Container Exterior End Spray" means a coating sprayed on the 

exterior bottom end of a container to provide protection to the metal.

(25) "Volatile Organic Compound (VOC)" means the same as defined in Rule 2.
Regulation IV -3- Rule 67.4

(26) "VOC Content per Volume of Coatings, Less Water and Exempt Compounds" means the same as defined in Rule 2.

(27) "VOC Content per Volume of Cleaning Material" means the same as 

defined in Rule 2, “VOC Content per Volume of Material”.

(d) STANDARDS

(1) VOC Limits

Except as provided for in Section (e), a person shall not use or apply coatings on any 

coating line of the type designated below which contains VOCs in excess of the following 

limits at the point of application:

(i)

Metal Container or Closure Coating Lines

Grams of VOC per liter 

of coating (less water 

and exempt compounds)

Sheet base coat (exterior and interior) and 

overvarnish

180

Two-piece container exterior base coat and 

overvarnish, and end spray

250

Container exterior body spray and exterior closure 

spray 250

Three-piece container side seam spray 660

End sealing compound:

Food/Beverage Container:

Pet Food Container

Non-Food Container

20

20

20

Container interior body spray:

Two-piece container

Three-piece container

420

310

Reconditioned drums, pails and lids:

Exterior spray

Interior spray

420

510

New drums, pails and lids:

Exterior spray

Interior spray

340

420

(ii)

Coil Coating Line

Grams of VOC per liter 

of coating (less water 

and exempt compounds)

(A) Letterpress coatings 200

(B) Other coil coatings 200
Regulation IV -4- Rule 67.4

(2) Coating Application Equipment

A person shall conduct coating operations subject to this rule by using only the 

following coating application methods:

(i) Electrostatic spray application; or

(ii) Flow coat application; or

(iii) Dip coat application; or

(iv) Roll coat; or

(v) Hand application methods; or

(vi) High-volume low-pressure (HVLP) spray. Facilities using an HVLP 

spray gun shall have available on site pressure gauges in proper operating condition 

to measure the air cap pressure or have available manufacturer’s technical 

information regarding the correlation between the handle air inlet pressure and the air 

cap pressure. If the correlation option is used to demonstrate compliance, a handle air 

inlet pressure gauge will be required on site in proper operating condition to measure 

the handle air inlet pressure; or

(vii) Other coating application methods that are demonstrated to have transfer 

efficiency at least equal to one of the above application methods, and which are used 

in such a manner that the operating parameters under which they were demonstrated 

to achieve such transfer efficiency are permanent features of the method. Such 

coating application methods shall be approved in writing by the Air Pollution Control 

Officer prior to use.

(3) Cleaning of Coating Application Equipment

A person shall not use VOC containing materials for the cleaning of coating 

application equipment used in operations subject to this rule unless:

(i) The VOC content of cleaning material is 25 grams or less per liter of 

material; or

(ii) The cleaning material is flushed or rinsed through the application equipment in a contained manner that will minimize evaporation into the atmosphere; or

(iii) The application equipment or equipment parts are cleaned in a container 

which is open only when being accessed for adding, cleaning, or removing 

application equipment or when cleaning solvent is being added, provided the cleaned 

equipment or equipment parts are drained to the container until dripping ceases; or

(iv) A system is used that totally encloses the component parts being cleaned 

during the washing, rinsing, and draining processes.
Regulation IV -5- Rule 67.4

(e) CONTROL EQUIPMENT

(1) In lieu of complying with the provisions of Subsection (d)(1) and (d)(3) a 

person may use an air pollution control system which:

(i) has been installed in accordance with an Authority to Construct; and

(ii) includes an emission collection system which captures and transports 

organic gaseous emissions to an air pollution control device; and

(iii) has a combined VOC emissions capture and control device efficiency of at 

least 85 percent by weight.

(2) A person subject to the requirements of this section shall submit to the Air 

Pollution Control Officer for approval an Operation and Maintenance (O&M) plan for the 

proposed emission control device and emission collection system. Such plan shall:

(i) identify all key system operating parameters. Key system operating 

parameters are those necessary to ensure compliance with Subsection (e)(1)(iii) such 

as temperature, pressure, and/or flow rate, and

(ii) include proposed inspection schedules, anticipated ongoing maintenance, 

and proposed recordkeeping practices regarding the key system operating parameters.

(3) The Operation and Maintenance plan must be submitted to the Air Pollution 

Control Officer and receive approval prior to operation of the air pollution control 

equipment. A person subject to the requirements of this section shall implement the plan 

on approval of the Air Pollution Control Officer.

(f) RECORD KEEPING

Any person subject to the requirements of this rule shall maintain records in 

accordance with the following:

(1) Coating and Cleaning Materials

Any person subject to the requirements of Subsections (d)(1) and/or (d)(3) shall:

(i) Maintain a current list of coatings and cleaning materials in use. This list 

shall provide all the data necessary to evaluate compliance, including, but not limited 

to:

(A) Material name, manufacturer and manufacturer identification;

(B) Type and applicable coating category of each coating used

 as specified in Subsection (d)(1)(i) and (d)(1)(ii);

(C) VOC content, less water and exempt compounds, of coatings, as 

applied and VOC content of cleaning materials, as used.
Regulation IV -6- Rule 67.4

(ii) Maintain monthly or daily records showing the amount of each coating, 

the applicable coating category and cleaning material used. 

(2) Any person using control equipment pursuant to Section (e) of this rule shall:

(i) For all materials not in compliance with Subsection (d)(1) of this rule, 

maintain daily records of the amount of each material used; and

 (ii) Maintain daily records sufficient to document continuous compliance 

with Subsection (e)(1)(iii), including records of key system operating parameters as 

approved in the Operation and Maintenance plan.

All records shall be retained on site for at least three years, and shall be made 

available to the District upon request.

(g) TEST METHODS

When more than one test method or set of test methods are specified in this Section, a 

violation of any requirement of this rule established by any one of the specified test methods or 

set of test methods shall constitute a violation of the rule.

(1) The VOC content of coatings containing more than 50 grams of VOC per liter 

and subject to Subsections (d)(1)(i) and (d)(1)(ii)(B) shall be determined by the 

Environmental Protection Agency (EPA) Reference Method 24 (Determination of Volatile 

Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface 

Coatings, 40 CFR Part 60, Appendix A), dated 9/11/1995, or by the South Coast Air 

Quality Management District (SCAQMD) Method 304 (Determination of Volatile 

Organic Compounds in Various Materials), dated February 1, 1996.

(2) Measurements of VOC content of coatings subject to Subsection (d)(1)(ii)(A) 

of this rule shall be conducted in accordance with San Diego Air Pollution Control 

District's Method 24D for Determination of Density, Total Volatile Matter Content, and 

Weight Solids of Surface Coatings Containing Photosensitive Reactive Diluents, dated 

July 1993.

(3) The VOC content of coatings containing 50 grams of VOC per liter or less, or 

cleaning materials shall be determined by the SCAQMD Method 313-91 (Determination 

of Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry), dated July 

1991, or the SCAQMD Method 308-91 (Quantitation of Compounds by Gas 

Chromatography), dated February 1993.

(4) The content of methyl acetate, acetone and parachlorobenzotrifluoride 

shall be determined in accordance with the ASTM Test Method D6133-02 (2008) 

(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). 
Regulation IV -7- Rule 67.4

(5) Measurements of exempt compound content, other than determined in 

accordance with Subsection (g)(4), shall be conducted in accordance with the SCAQMD 

Test Method 303-91 (Determination of Exempt Compounds), dated August 1996.

(6) Measurements of transfer efficiency pursuant to Subsection (d)(2)(vii) of this 

rule shall be conducted in accordance with the SCAQMD "Spray Equipment Transfer 

Efficiency Test Procedure for Equipment User" approved by EPA on May 24, 1989. The 

equivalency of coating application equipment pursuant to Subsection (d)(2)(vii) shall be 

determined by the SCAQMD “ Guidelines for Demonstrating Equivalency with District 

Approved Transfer Efficient Spray Guns”, dated September 26, 2002.

(7) The overall control efficiency of air pollution control equipment operated 

pursuant to Subsection (e)(1)(iii) shall be determined by multiplying the capture efficiency 

of the emission collection system by the control efficiency of the air pollution control 

device. The control efficiency of the air pollution control device shall be determined using 

EPA Test Methods 25A and/or 18 (40 CFR Part 60, Appendix A) and in accordance with a 

protocol approved by the Air Pollution Control Officer. Capture efficiency of an emission 

collection system pursuant to Subsection (e)(1)(ii) shall be determined according to EPA 

Test Methods 204 and 204A through 204 F (51 CFR Appendix M), as applicable, and 

technical document, “Guidelines for Determining Capture Efficiency,” dated January 9, 

1995. Subsequent to the initial compliance demonstration period, appropriate key system 

operating parameters as approved by the Air Pollution Control Officer may be used as 

indicators of the performance of the emission control system.

(8) Other test methods which are determined to be equivalent to the test methods 

specified in this rule and approved, in writing, by the Air Pollution Control Officer, 

California Air Resources Board, and EPA may be used in place of the test methods 

specified in this rule.