Santa Barbara County APCD Rule 337 337 - 1 October 20, 1994[date of amended rule adoption]

RULE 337. SURFACE COATING OF AIRCRAFT OR AEROSPACE VEHICLES PARTS AND 

PRODUCTSCOMPONENTS. (Adopted 7/10/1990, revised 7/24/1990, and 10/20/1994, and 

[date of amended rule adoption]) 

A. Applicability

 This rule is applicable to any person who manufactures, any aerospace vehicle coating or aerospace 

component coating for use within the District, as well as any person who uses, applies, or specifies solicits 

the use or application of any aerospace vehicle or component surface coatings or associated solvent within 

the Districtfor aircraft or aerospace vehicle parts and products. Rule 337 does not apply to electronic 

components. 

B. Exemptions

 1. The provisions of Section D.1 shall not apply to any non-complying coatings with separate 

formulations used in volumes of less than 20 gallons of each non-complying formulation per 

stationary source in any calendar year. provided that To qualify for this exemption from Section 

D.1, the total volume of non-complying coatings used at a stationary source does not exceed 200 

gallons annually. Coatings used for operations that are exempt per Sections B.2, and B.3, B.6, 

B.8, B.11, B.12, and B.13 shall not be included in calculating the volume of coatings used under 

this exemption. Any person claiming this exemption shall maintain on a monthly daily basis an 

annual running total of the volume of each separate formulation of coating used under this 

exemption records consistent with Section H.7 and make them available to the District for review 

upon request. These coatings shall be subject to the records required by Section H.

 2. The provisions of Section E. and H shall not apply to touch-up and repair, provided Section D.1 

limits are met and records are maintained pursuant to a Permit to Operate. 

 3. The provisions of this rule shall not apply to coatings (including adhesive products and sealant 

products) supplied in non-refillable as aerosol products in non-refillable containers with capacities 

of 18 ounces or less. 

 4. Any coating and associated solvent subject to the requirements of this rule shall be exempt from 

the requirements of Rule 317, Organic Solvents, and Rule 322, Metal Surface Coating Thinner and 

Reducer. Any coating exempt from this rule shall comply with all other applicable District Rules. 

5. This rule shall not apply to any cleaning performed with a solvent (including emulsions) that 

contains two percent by weight or less of each of the following: 

a. Reactive organic compounds, and 

b. Toxic air contaminants (as determined by generic solvent data, solvent manufacturer’s 

composition data or by a gas chromatography test and a mass spectrometry test). 

c. Any person claiming this exemption shall maintain the records specified in Sections 

H.1.a and H.1.f in a manner consistent with Section H.9 and make them available for 

review. 

6. This rule shall not apply to coatings that contain less than 20 grams of reactive organic compound 

per liter (0.17 pounds of reactive organic compound per gallon) of coating, less water and less 

exempt compounds, as applied. 

7. Section D.2 and J.1.a shall not apply to solvents and strippers used in space vehicle manufacturing 

and rework. 
Santa Barbara County APCD Rule 337 337 - 2 October 20, 1994[date of amended rule adoption]

8. This rule shall not apply to chemical milling and electrodeposition (except for electrodeposition of 

coatings). 

9. Section J.1.a shall not apply to any of the following: 

a. Cleaning of encasements, including decoy shells or box casings, for electronic 

components that have a total surface area that is less than 2 square feet; 

b. Cleaning of parts, subassemblies, or assemblies that are exposed to strong oxidizers or 

reducers (e.g., nitrogen tetroxide, liquid oxygen, or hydrazine); 

c. Cleaning of aircraft transparencies, polycarbonate, or glass substrates; 

d. Cleaning of solar cells, coated optics, laser hardware, scientific instruments, highprecision optics, telescopes, microscopes, avionic equipment, military fluid systems, and 

thermal control surfaces; 

e. Wipe cleaning during the manufacture, assembly, installation, maintenance, or testing of 

components of breathing oxygen systems that are exposed to the breathing oxygen; 

f. Wipe cleaning and surface activation prior to adhesive bonding; 

g. Wipe cleaning of aircraft and ground support equipment fluid systems that are exposed to 

the fluid, including air-to-air heat exchangers and hydraulic fluid systems; 

h. Wipe cleaning of fuel cells, fuel tanks, and confined spaces.

10. Section E shall not apply to any of the following: 

a. Any situation that normally requires the use of an airbrush or an extension on the spray 

gun to properly reach limited access spaces; 

b. The use of airbrush application methods for stenciling, lettering, and other identification 

markings. 

11. The chemical milling maskant limits in Section D.1, Table 337-1, shall not apply to any of the 

following: 

a. Touch-up of scratched surfaces or damaged maskant; 

b. Touch-up of trimmed edges. 

12. Section D.1 shall not apply to electric- and radiation-effect coatings that have been designated as 

“classified” by the United States Department of Defense. 

13. This rule shall not apply to coatings (including adhesive products and sealant products) subject to 

the Air Resources Board consumer products regulation found in Title 17 of the California Code of 

Regulations, section 94507 et seq. 

14. Sections D.2 and J.1.a shall not apply to any of the following: 

a. Cleaning or stripping of coating overspray from personal protective equipment; 

b. Wipe cleaning or stripping during fabrication, assembly, installation, and maintenance of 

upholstery, curtains, carpet, and other textile materials used in the interior of the aircraft; 
Santa Barbara County APCD Rule 337 337 - 3 October 20, 1994[date of amended rule adoption]

c. Wipe cleaning or stripping of metallic and nonmetallic materials used in honeycomb 

cores during the manufacture or maintenance of these cores, and cleaning of the 

completed cores used in the manufacture of aerospace vehicles or components. 

C. Definitions 

 See Rule 102, Definitions, for definitions not restricted to interpretation of limited to this rule. Definitions 

specific to this rule are listed below. For purposes of this rule, the following definitions shall apply:

“Ablative Coating” means any coating that chars when exposed to open flame or extreme temperatures, as 

would occur during the failure of an engine casing or during aerodynamic heating. The ablative char 

surface serves as an insulative barrier, protecting adjacent components from the heat or open flame. 

“Adhesion Promoter” means any very thin coating applied to a substrate to promote wetting and form a 

chemical bond with the subsequently applied material. 

“Adhesive” means any substance that is used to bond one surface to another surface by attachment or fused 

union. Adhesives are a type of specialty coating. 

1. “Adhesive Bonding Primer” means any coating primer applied in a very thin film to aircraft or 

aerospace parts or products components for the primary purpose of providing a primer for a subsequent 

coat of structural adhesive corrosion inhibition and increased adhesive bond strength by attachment. 

“Adhesive Product” means any adhesive, glue, cement, mastic, adhesive bonding primer, adhesive primer, 

adhesive primer for plastics, and any other adhesive primer. Adhesive products are a type of coating. 

“Aerospace Vehicle or Component” means any fabricated part, processed part, assembly of parts, or 

completed unit, with the exception of electronic components, of any aircraft including but not limited to 

airplanes, helicopters, missiles, rockets, and space vehicles includes satellites. 

2. “Aircraft or Aerospace Vehicle” means a fabricated part, assembly of parts or completed unit of 

any aircraft, helicopter, missile or space vehicle. 

“Aircraft Fluid Systems” mean those systems that handle hydraulic fluids, fuel, cooling fluids, or oils. 

“Aircraft Transparency” means the aircraft windshield, canopy, passenger windows, lenses and other 

components which are constructed of transparent materials. 

“Airless Spray” means a spray method in which a pump forces the adhesive through an atomizing nozzle 

at high pressure (1,000 to 6,000 pounds per square inch). 

“Antichafe Coating” means any coating applied to areas of moving aerospace components that may rub 

during normal operations or installation. 

“Associated Solvent” means any solvent used in a solvent cleaning machine or for solvent cleaning 

performed in association with surface coating of any aerospace vehicle or aerospace component.

“Barrier Coating” means any coating applied in a thin film to fasteners to inhibit dissimilar metal 

corrosion and to prevent galling. 

“Bearing Coating” means any coating applied to an antifriction bearing, a bearing housing, or the area 

adjacent to such a bearing in order to facilitate bearing function or to protect base material from excessive 

wear. A material shall not be classified as a bearing coating if it can also be classified as a dry lubricative 

material or a solid film lubricant. 
Santa Barbara County APCD Rule 337 337 - 4 October 20, 1994[date of amended rule adoption]

“Bonding Maskant” means any temporary coating used to protect selected areas of aerospace parts from 

strong acid or alkaline solutions during processing for bonding. 

“Caulking and Smoothing Compounds” mean semi-solid materials which are applied by hand 

application methods and are used to aerodynamically smooth exterior vehicle surfaces or fill cavities such 

as bolt hole accesses. A material shall not be classified as a caulking and smoothing compound if it can 

also be classified as a sealant. 

“Chemical Agent-Resistant Coating” means any exterior topcoat designed to withstand exposure to 

chemical warfare agents or the decontaminants used on these agents. 

“Chemical Milling Maskant” means any coating that is applied directly to aluminum components to 

protect surface areas when chemical milling the component with a Type I or Type II etchant. Type I 

chemical milling maskants are used with a Type I etchant and Type II chemical milling maskants are used 

with a Type II etchant. This definition does not include bonding maskants, critical use and line sealer 

maskants, and seal coat maskants. Additionally, maskants that must be used with a combination of Type I 

or II etchants and any of the above types of maskants (i.e., bonding, critical use and line sealer, and seal 

coat) are not included. Maskants that are defined as specialty coatings are not included under this 

definition. Section C provides definitions of Type I and Type II etchants. 

“Cleaning Operation” means collectively spray-gun, hand-wipe, and flush cleaning operations. 

“Cleaning Solvent” means any liquid material used for hand-wipe, spray gun, or flush cleaning. This 

definition does not include any solution that contains no reactive organic compounds and no toxic air 

contaminants. 

“Clear Coating” means a transparent coating usually applied over a colored opaque coating, metallic 

substrate, or placard to give improved gloss and protection to the color coat. In some cases, a clear coat 

refers to any transparent coating without regard to substrate. 

“Coating” means any material that is applied to the surface of an aerospace vehicle or component to form 

a decorative, protective, or functional solid film, or the solid film itself. Adhesives, sealants, and 

lubricative material are types of specialty coatings. 

“Commercial Exterior Aerodynamic Structure Primer” means any primer used on aerodynamic 

components and structures that protrude from the fuselage, such as wings and attached components, control 

surfaces, horizontal stabilizers, vertical fins, wing-to-body fairings, antennae, and landing gear and doors, 

for the purpose of extended corrosion protection and enhanced adhesion. 

“Commercial Interior Adhesive” means any material used in the bonding of passenger cabin interior 

components. These components must meet the Federal Aviation Administration fireworthiness 

requirements. 

“Compatible Substrate Primer” includes two categories: “compatible epoxy primer” and “adhesive 

primer.” “Compatible epoxy primer” means any primer that is compatible with the filled elastomeric 

coating and is epoxy based. The compatible substrate primer is an epoxy-polyamide primer used to 

promote adhesion of elastomeric coatings such as impact-resistant coatings. “Adhesive primer” means 

any coating that (1) inhibits corrosion and serves as a primer applied to bare metal surfaces or prior to 

adhesive application, or (2) is applied to surfaces that can be expected to contain fuel. Fuel tank coatings 

are excluded from this category. 

“Compliant Material” means any coating, stripper, or solvent that has a reactive organic compound 

content or composite partial pressure that complies with the applicable limit in Sections D.1, D.2, or J.1 

“Confined Space” means any space that (1) is large enough and so configured that an employee can bodily 

enter and perform assigned work; (2) has limited or restricted means for entry or exit (for example, fuel 
Santa Barbara County APCD Rule 337 337 - 5 October 20, 1994[date of amended rule adoption]

tanks, fuel vessels, and other spaces that have limited means of entry); and (3) is not suitable for continuous 

employee occupancy. 

“Contact Bond Adhesive” or “Contact Adhesive” means any adhesive intended by the manufacturer to 

adhere to itself instantaneously upon contact. The adhesive is applied to both adherends and allowed to 

become dry, which develops a bond when the adherends are brought together without sustained pressure. 

for application to both surfaces to be bonded together, is allowed to dry before the two surfaces are placed 

in contact with each other, forms an immediate bond that is impossible, or difficult, to reposition after both 

adhesive-coated surfaces are placed in contact with each other, and does not need sustained pressure or 

clamping of surfaces after the adhesive-coated surfaces have been brought together using sufficient 

momentary pressure to establish full contact between both surfaces. Contact adhesive does not include 

rubber cements that are primarily intended for use on paper substrates. Contact adhesive also does not 

include vulcanizing fluids that are designed and labeled for tire repair only. 

“Contact Bond Adhesive-Specialty Substrates” or “Specialty Contact Adhesive” means any contact 

adhesive that is intended by the manufacturer to be used for the bonding of nonporous substrates to each 

other, the bonding of decorative laminate in post-forming application, the bonding of decorative laminate to 

metal, melamine-covered board, or curved surfaces, or the bonding of any substrate to metal, rubber, rigid 

plastic, or wood veneer not exceeding 1/16 inch in thickness. 

“Control” means the reduction, by destruction or removal, of the amount of affected pollutants in a gas 

stream prior to discharge to the atmosphere. 

 

“Control System” means any combination of pollutant capture system(s) and control device(s) used to 

reduce discharge to the atmosphere of reactive organic compound or toxic air contaminant emissions 

generated by a regulated operation. 

“Corrosion Prevention System” means any coating system that provides corrosion protection by 

displacing water and penetrating mating surfaces, forming a protective barrier between the metal surface 

and moisture. Coatings and compounds containing oils or waxes are excluded from this category. 

“Critical Use and Line Sealer Maskant” means any temporary coating, not covered under other maskant 

categories, used to protect selected areas of aerospace parts from strong acid or alkaline solutions such as 

those used in anodizing, plating, chemical milling and processing of magnesium, titanium, or high-strength 

steel, high-precision aluminum chemical milling of deep cuts, and aluminum chemical milling of complex 

shapes. Materials used for repairs or to bridge gaps left by scribing operations (i.e., line sealer) are also 

included in this category. 

“Cryogenic Flexible Primer” means any primer designed to provide corrosion resistance, flexibility, and 

adhesion of subsequent coating systems when exposed to loads up to and surpassing the yield point of the 

substrate at cryogenic temperatures (minus 275 degrees Fahrenheit and below). 

“Cryoprotective Coating” means any coating that insulates cryogenic or subcooled surfaces to limit 

propellant boil-off, maintain structural integrity of metallic structures during ascent or re-entry, and prevent 

ice formation. 

“Cyanoacrylate Adhesive” means any fast-setting, single component adhesive that cures at room 

temperature. Also known as "super glue." 

“Depainting” means the removal of a permanent coating from the outer surface of an aerospace vehicle or 

component. 

“Depainting Operation” means the use of a chemical agent, media blasting, or any other technique to 

remove permanent coatings from the outer surface of an aerospace vehicle or components. The depainting 

operation includes washing of the aerospace vehicle or component to remove residual stripper, media, or 

coating residue. 
Santa Barbara County APCD Rule 337 337 - 6 October 20, 1994[date of amended rule adoption]

3. “Detailing or Touch-up Guns” mean any are small air spray equipment, including air brushes, 

that operate at no greater than 5 CFM cubic feet per minute air flow and no greater than 50 pounds per 

square inch gauge (Psig) air pressure and are used to coat small products or portions of products.

“Dip Coat Application” means any process in which a substrate is immersed in a solution (or dispersion) 

containing the coating material, and then withdrawn. 

“Dry Lubricative Material” means any coating consisting of lauric acid, cetyl alcohol, waxes, or other 

non-cross linked or resin-bound materials which act as a dry lubricant. 

4. “Interior Topcoat” means a topcoat used in habitable interior spaces of aircraft.

5. “Electric-/ or Radiation -Effect Coatings” means an electrically conductive or insulative 

coating, or coatings used on radar and antennae enclosuresany coating or coating system engineered to 

interact, through absorption or reflection, with specific regions of the electromagnetic energy spectrum, 

such as the ultraviolet, visible, infrared, or microwave regions. Uses include, but are not limited to, 

lightning strike protection, electromagnetic pulse protection, and radar avoidance. 

“Electrodeposition” means the application of a coating using a water-based electrochemical bath process.

The component being coated is immersed in a bath of the coating. An electric potential is applied between 

the component and an oppositely charged electrode hanging in the bath. The electric potential causes the 

ionized coating to be electrically attracted, migrated, and deposited on the component being coated. 

“Electrostatic Discharge and Electromagnetic Interference Coating” means any coating applied to 

space vehicles, missiles, aircraft radomes, and helicopter blades to disperse static energy or reduce 

electromagnetic interference. 

6. “Electrostatic Application” means using a sufficient charging of atomized paint droplets to cause 

deposition by electrostatic attraction. This application requires a minimum 60kV power supply. 

“Elevated-Temperature Skydrol-Resistant Commercial Primer” means any primer applied primarily to 

commercial aircraft (or commercial aircraft adapted for military use) that must withstand immersion in 

phosphate-ester (PE) hydraulic fluid (Skydrol 500b or equivalent) at the elevated temperature of 150 

degrees Fahrenheit for 1,000 hours. 

“Epoxy Polyamide Topcoat” means any coating used where harder films are required or in some areas 

where engraving is accomplished in camouflage colors. 

7. “Exempt Organic Compounds” means those compounds listed as exceptions in the definition of 

“Reactive Organic Compounds” in Rule 102.

“Exterior Primer” means the first layer and any subsequent layers of identically formulated coating 

applied to the exterior surface of an aerospace vehicle or component where the component is used on the 

exterior of the aerospace vehicle. Exterior primers are typically used for corrosion prevention, protection 

from the environment, functional fluid resistance, and adhesion of subsequent exterior topcoats. Coatings 

that are defined as specialty coatings are not included under this definition. 

8. “Extreme Performance Interior Topcoat” means a topcoat used in interior spaces of aircraft 

areas requiring a fluid, stain, or nicotine barrier. 

“Fastener Manufacturer” means any stationary source that coats aircraft fasteners, such as pins, collars, 

bolts, nuts, and rivets, with solid-film lubricants for distribution. 

“Fastener Sealant” means any sealant applied to a device used to join two or more parts together. 
Santa Barbara County APCD Rule 337 337 - 7 October 20, 1994[date of amended rule adoption]

9. “Fire Insulation-Resistant (Interior) Coating” means: a coating used to provide a layer of 

insulation in the event of an aircraft or engine fire. 

1. For civilian aircraft, any coating used on passenger cabin interior parts that are subject to 

the Federal Aviation Administration fireworthiness requirements. 

2. For military aircraft, any coating used on parts that are subject to the flammability 

requirements of MIL-STD-1630A and MIL-A-87721. 

3. For space applications, any coating used on parts that are subject to the flammability 

requirements of SE-R-0006 and SSP 30233. 

“Flexible Primer” means any primer that meets flexibility requirements such as those needed for adhesive 

bond primed fastener heads or on surfaces expected to contain fuel. The flexible coating is required 

because it provides a compatible, flexible substrate over bonded sheet rubber and rubber-type coatings as 

well as a flexible bridge between the fasteners, skin, and skin-to-skin joints on outer aircraft skins. This 

flexible bridge allows more topcoat flexibility around fasteners and decreases the chance of the topcoat 

cracking around the fasteners. The result is better corrosion resistance. 

“Flight Test Coating” means any coating applied to aircraft other than missiles or single-use aircraft prior 

to flight testing to protect the aircraft from corrosion and to provide required marking during flight test 

evaluation. 

“Flow Coat Application” means any coating application system, with no air supplied to the nozzle, where 

paint flows over the part and the excess coating drains back into the collection system. 

“Flush Cleaning” means the removal of contaminants such as dirt, grease, oil, and coatings from an 

aerospace vehicle or component or application equipment by passing solvent over, into, or through the item 

being cleaned. The solvent may simply be poured into the item being cleaned and then drained, or be 

assisted by air or hydraulic pressure, or by pumping. Hand-wipe cleaning operations where wiping, 

scrubbing, mopping, or other hand actions are used are not included. 

“Fuel Tank Adhesive” means any adhesive used to bond components exposed to fuel and must be 

compatible with fuel tank coatings. 

10. “Fuel Tank Coating” means any coating applied to the interior of a fuel tank components or to 

fuel wetted areas of aircraft to protect it from for the purpose of corrosion and/or bacterial growth inhibition 

and to assure sealant adhesion in extreme environmental conditions. 

11. “Grams of ROC Reactive Organic Compound per Liter of Coating, Less Water and Less 

Exempt Compounds” means the weight of ROC reactive organic compound per combined volume of 

ROC reactive organic compound and coating solids and can be calculated by the following equation: 

 Ws - Ww - Wes

Grams(lb) of ROC / l(gal) of coating = 

 Vm - Vw - Ves

 

Grams of reactive organic compounds Ws - Ww - Wes

per liter of coating, less water and less = 

exempt compounds Vm - Vw - Ves

 Where: Ws = Weight of volatile compounds (including water) 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 
Santa Barbara County APCD Rule 337 337 - 8 October 20, 1994[date of amended rule adoption]

 Ves = Volume of exempt organic compounds in liters 

For aerospace coatings that contain reactive diluents, the grams of reactive organic compound per liter of 

coating, less water and less exempt compounds, shall be calculated by the following equation: 

Grams of reactive organic compounds Wrs - Wrw - Wre

per liter of coating, less water and less = 

exempt compounds Vrm - Vrw - Vre

 Where: Wrs = Weight of volatile compounds not consumed during curing in grams 

 Wrw = Weight of water not consumed during curing in grams 

Wre = Weight of exempt compounds not consumed during curing in grams 

Vrm = Volume of material not consumed during curing in liters 

Vrw = Volume of water not consumed during curing in liters 

Vre = Volume of exempt compounds not consumed during curing in liters 

12. “Hand Application Method” means the application of a surface coating by manually held nonmechanically operated equipment. Such equipment includes paint brush, hand-roller, trowel, spatula, 

dauber, rag or sponge. 

“Hand-Wipe Cleaning Operation” means the removal of contaminants such as dirt, grease, oil, and 

coatings from an aerospace vehicle or component by physically rubbing it with a material such as a rag, 

paper, or cotton swab that has been moistened with a cleaning solvent. 

13. “High Temperature Coating” means any coating that, during normal use, must designed to 

withstand temperatures in excess of more than 350 °F degrees Fahrenheit. 

14. “High Volume Low Pressure Spraying” means using spray equipment with air pressure between 

0.1 and 10.0 psi and air volume greater than 15.5 cfm per spray gun. 

“Insulation Covering” means any material that is applied to foam insulation to protect the insulation from 

mechanical or environmental damage. 

“Interior Topcoat” means any topcoat used inhabitable interior spaces of aircraft. 

“Intermediate Release Coating” means any thin coating applied beneath topcoats to assist in removing 

the topcoat in depainting operations and generally to allow the use of less hazardous depainting methods. 

“Lacquer” means any clear or pigmented coating formulated with a nitrocellulose or synthetic resin to dry 

by evaporation without a chemical reaction. Lacquers are resoluble in their original solvent. 

“Limited Access Space” means any internal surfaces or passages of an aerospace vehicle or component 

that cannot be reached without the aid of an airbrush or a spray gun extension for the application of 

coatings. 

15. “Maskant-Chemical Processing” means a coating applied directly to a part to protect surface 

areas when chemical milling, anodizing, aging, bonding, plating, etching and/or performing other chemical 

operations on the surface of the part. 

“Long Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the aircraft 

manufacturers’ required performance characteristics following 6,000 hours testing, used for metal to 

structural core bonding, and with an adhesive that is specified to be cured at a temperature of 350 degrees 

Fahrenheit plus or minus 10 degrees Fahrenheit.

“Metalized Epoxy Coating” means any coating that contains relatively large quantities of metallic 

pigmentation for appearance and/or added protection. 
Santa Barbara County APCD Rule 337 337 - 9 October 20, 1994[date of amended rule adoption]

“Mold Release” means any coating applied to a mold surface to prevent the molded piece from sticking to 

the mold as it is removed. 

“Natural Draft Opening” means any opening in a room, building, or total enclosure that remains open 

during operation of the facility and that is not connected to a duct in which a fan is installed. The rate and 

direction of the natural draft through such an opening is a consequence of the difference in pressures on 

either side of the wall containing the opening. 

“Non-Complying Coating” means a coating with a reactive organic compound content above a limit 

specified in Section D.1. 

“Noncompliant Material” means any coating, stripper, or solvent that has a reactive organic compound 

content or composite partial pressure that does not comply with the applicable limit in Sections D.1, D.2, or 

J.1. 

 

“Nonstructural Adhesive” means any adhesive that bonds nonload bearing aerospace components in 

noncritical applications and is not covered in any other specialty adhesive categories. 

“Optical Anti-Reflective Coating” means any coating with a low reflectance in the infrared and visible 

wavelength ranges that is used for antireflection on or near optical and laser hardware. 

“Part Marking Coating” means any coatings or inks used to make identifying markings on materials, 

components, and/or assemblies. These markings may be either permanent or temporary. 

16. “Pretreatment Wash PrimerCoating” means a any organic coating which that contains a small 

quantity of at least 0.5 percent acids by weight for surface etching and is applied directly to metal or 

composite surfaces to provide surface etching, corrosion resistance, adhesion, and ease of stripping. 

17. “Primer” means a the first layer and any subsequent layers of identically formulated coating 

applied directly to a part for purposes of to the surface of an aerospace vehicle or component. Primers are 

typically used for corrosion prevention, protection from the environment, functional fluid resistance, and/or

adhesion of subsequent coatings. Primers that are defined as specialty coatings are not included under this 

definition. 

“Radome” means the nonmetallic protective housing for electromagnetic transmitters and receivers (e.g., 

radar, electronic countermeasures, etc.). 

“Rain Erosion-Resistant Coating” means any coating or coating system used to protect the leading edges 

of parts such as flaps, stabilizers, radomes, engine inlet nacelles, etc. against erosion caused by rain impact 

during flight. 

“Reactive Diluent” means a liquid which is a reactive organic compound during application and one in 

which, through chemical and/or physical reactions, such as polymerization, 20 percent or more of the 

reactive organic compound becomes an integral part of a finished material.

“Remanufactured Commercial Aircraft Part” means any aerospace component that is built as a spare 

part or replacement part subject to an existing commercial aircraft specification. 

18. “Repair” means recoating of previously coated product due to damage to the coating following 

normal painting operations. 

“Rocket Motor Bonding Adhesive” means any adhesive used in rocket motor bonding applications. 

“Rocket Motor Nozzle Coating” means any catalyzed epoxy coating system used in elevated temperature 

applications on rocket motor nozzles. 
Santa Barbara County APCD Rule 337 337 - 10 October 20, 1994[date of amended rule adoption]

“Rubber-Based Adhesive” means any quick setting contact cement that provides a strong, yet flexible 

bond between two mating surfaces that may be of dissimilar materials. 

“Scale Inhibitor” means any coating that is applied to the surface of a part prior to thermal processing to 

inhibit the formation of scale. 

“Screen Print Ink” means any ink used in screen printing processes during fabrication of decorative 

laminates and decals. 

“Seal Coat Maskant” means any overcoat applied over a maskant to improve abrasion and chemical 

resistance during production operations. 

19. “Sealant” means any coating material used to prevent the intrusion applied for the purpose of 

filling voids and providing a barrier against penetration of water, fuel, air, or other fluids or vaporsliquids 

or solids from certain areas of aerospace vehicles or components. There are two categories of sealants: 

extrudable/rollable/brushable sealants and sprayable sealants. Sealants are a type of specialty coating. 

20. “Sealant Bonding Primer” means a coating applied in a very thin film to a part or product for the 

purpose of providing a primer for a subsequent coat of silicone sealant. 

“Sealant Product” means any sealant and sealant primer. Sealant products are a type of coating. 

21. “Self PrimingSelf-Priming Topcoat” means any coating topcoat that is applied directly to a part 

or product that is not subsequently overcoatedan uncoated aerospace vehicle or component for purposes of 

corrosion prevention, environmental protection, and functional fluid resistance. More than one layer of 

identical coating formulation may be applied to the vehicle or component. 

“Short Term Adhesive Bonding Primer” means any adhesive bonding primer that has met the 

manufacturers’ required performance characteristics following 1,000 hours testing, used for metal to metal 

and metal to structural core bonding, and with an adhesive which is specified to be cured at a temperature 

of 350 degrees Fahrenheit plus or minus 10 degrees Fahrenheit. 

“Silicone Insulation Material” means any insulating material applied to exterior metal surfaces for 

protection from high temperatures caused by atmospheric friction or engine exhaust. These materials differ 

from ablative coatings in that they are not “sacrificial.”

“Solid Film Lubricant” means any very thin coating consisting of a binder system containing as its chief 

pigment material one or more of the following: molybdenum, graphite, polytetrafluoroethylene (PTFE), or 

other solids that act as a dry lubricant between faying surfaces. 

“Solids” mean the non-volatile portion of the coating which after drying makes up the dry film. 

“Solvent” means any liquid containing any reactive organic compound or any toxic air contaminant, which 

is used as a diluent, thinner, dissolver, viscosity reducer, cleaning agent, drying agent, preservative, or other 

similar uses. 

“Solvent Cleaning” means any activity, operation, or process (including, but not limited to, surface 

preparation, cleanup, or wipe cleaning) performed outside of a solvent cleaning machine, that uses solvent 

to remove uncured adhesives, uncured coatings, uncured inks, uncured polyester resin material, uncured 

sealant, or other contaminants, including, but not limited to, dirt, soil, oil, lubricants, coolants, moisture, 

fingerprints, and grease, from parts, products, tools, machinery, application equipment, and general work 

areas. Cleaning spray equipment used for the application of coating, adhesive, ink, polyester resin material, 

or sealant is also considered to be solvent cleaning irrespective of the spray material being cured. 

“Solvent Cleaning Machine” means any device or piece of equipment that uses solvent liquid or vapor to 

remove soils, moisture, or other contaminants from the surfaces of materials. Types of solvent cleaning 
Santa Barbara County APCD Rule 337 337 - 11 October 20, 1994[date of amended rule adoption]

machines include, but are not limited to, batch cold, batch vapor, in-line cold, in-line vapor, remote 

reservoir, and gas-path solvent cleaners. Buckets, pails, and beakers with capacities of 3.785 liters (1.00 

gallon) or less are not considered solvent cleaning machines. However, the use of such a container or 

similar containers (e.g., hand-held spray bottles) with a liquid solvent for cleaning is considered to be 

solvent cleaning. Any device or piece of equipment used exclusively for stripping shall not be considered 

to be a solvent cleaning machine. 

“Sonic and Acoustic Applications” means the use of aerospace materials on aerospace components that 

are subject to mechanical vibration and/or sound wave cavitation. 

22. “Space Vehicle Coating” means any coating applied to vehicles designed to travel beyond the 

earth's atmosphere. 

“Specialized Function Coating” means any coating that fulfills extremely specific engineering 

requirements that are limited in application and are characterized by low volume usage. This category 

excludes coatings covered in other Specialty Coating categories. 

“Specialty Coating” means any coating that, even though it meets the definition of a primer, topcoat, or 

self-priming topcoat, has additional performance criteria beyond those of primers, topcoats, and selfpriming topcoats for specific applications. These performance criteria may include, but are not limited to, 

temperature or fire resistance, substrate compatibility, antireflection, temporary protection or marking, 

sealing, adhesively joining substrates, or enhanced corrosion protection. The reactive organic compound 

content limit for the individual specialty coatings are listed in Section D.1, Table 337-2. Definitions for 

each specialty coating category are provide in Section C. 

“Spray Gun” means any device that atomizes a coating or other material and projects the particulates or 

other material onto a substrate. 

23. “Stripper” means a precursor organic compound applied to remove temporary coating, maskant 

for chemical processing, paint or residue any liquid that is applied to a surface to remove cured or dried 

coatings such as primers, adhesives (e.g., debonding or unglueing), topcoats, and temporary protective 

coatings. 

24. “Structural Autoclavable Adhesive” means any coating adhesivewhich is applied for the 

purpose of bonding structural components together used to bond load-carrying aerospace components that 

is cured by heat and pressure in an autoclave. 

“Structural Nonautoclavable Adhesive” means any adhesive cured under ambient conditions that is used 

to bond load-carrying aerospace components or for other critical functions, such as nonstructural bonding 

in the proximity of engines. 

“Surface Preparation” means the removal of contaminants from the surface of an aerospace vehicle or 

component or the activation or reactivation of the surface in preparation for the application of a coating. 

25. “Temporary Protective Coating” means any coating applied to a part to protect it from 

mechanical and environmental damage during manufacturing provide scratch or corrosion protection 

during manufacturing, storage, or transportation. Two types include peelable protective coatings and 

alkaline removable coatings. These materials are not intended to protect against strong acid or alkaline 

solutions. Coatings that provide this type of protection from chemical processing are not included in this 

category.

“Thermal Control Coating” means any coating formulated with specific thermal conductive or radiative 

properties to permit temperature control of the substrate. 
Santa Barbara County APCD Rule 337 337 - 12 October 20, 1994[date of amended rule adoption]

26. “Topcoat” means any coating applied over a primer or intermediary coating on an aerospace 

vehicle or component for purposes such as appearance, identification, camouflage, or protection. Coatings 

that are defined as specialty coatings are not included under this definition.

27. “Touch up-Up” means that portion of the coating operation which is separate from the main 

coating process but necessary to cover minor imperfections or to achieve coverage as required. 

“Touch-Up and Repair” means that portion of the coating operation that is the incidental application of 

coating used to cover minor imperfections in the coating finish or to achieve complete coverage. This 

definition includes out-of-sequence or out-of-cycle coating. 

28. “Transfer Efficiency” means the ratio of the weight of coating solids adhering to the object being 

coated to the weight of coating solids used in the application process, expressed as a percentage.

“Type I Chemical Milling Maskant” see the “Chemical Milling Maskant” definition.

“Type II Chemical Milling Maskant” see the “Chemical Milling Maskant” definition.

“Type I Etchant” means any chemical milling etchant that contains varying amounts of dissolved sulfur 

and does not contain amines. 

“Type II Etchant” means any chemical milling etchant that is a strong sodium hydroxide solution 

containing amines. 

“Viscosity” means the internal friction of a liquid that makes it resistant to flow. 

“Wet Fastener Installation Coating” means any primer or sealant applied by dipping, brushing, or 

daubing to fasteners that are installed before the coating is cured. 

29. “Wing Coating” means any corrosion-resistant coating that is resilient enough to withstand the 

flexing of the aircraft wings. 

D. Requirements -– Reactive Organic Compound (ROC) Limits

 1. A No person shall not apply any coating or specify solicit the use of any coating on any aerospace 

vehicle or component subject to the provisions of this rule, which, as applied, emits or may emit 

contains reactive organic compounds into the atmosphere in excess of the limits shown in the 

tables below. These limits are expressed in grams of reactive organic compound per liter or 

pounds per gallon of coating, less water and less exempt organic compounds: 

 

Table 337-1: Reactive Organic Compound Content Limits for Coatings Other than Specialty Coatings 

(Grams of Reactive Organic Compound per Liter, Less Water and Less Exempt Compounds) 

Coating Type ROC Limit 

Effective [date of amended 

rule adoption] 

Exterior Primer 350 

Primer 350 

Self-Priming Topcoat 420 

Topcoat 420 

Type I Chemical Milling 

Maskant 

250 

Type II Chemical Milling 

Maskant 

160 
Santa Barbara County APCD Rule 337 337 - 13 October 20, 1994[date of amended rule adoption]

Table 337-2: Reactive Organic Compound Content Limits for Specialty Coatings 

(Grams of Reactive Organic Compound per Liter, Less Water and Less Exempt Compounds)

 

Coating Type ROC Limit 

g/l Effective 

Before [24 months 

after the date of 

amended rule 

adoption]

lb/gal Effective On 

and After [24 months 

after the date of 

amended rule 

adoption]

Ablative Coating 600 600

Adhesion Promoter 850 250 

Adhesive Bonding Primers: 250 2.1 

 New Commercial Aircraft 250 250

 All Military Aircraft 805 805

 Remanufactured Commercial Aircraft Parts 805 805

 Sonic and Acoustic Applications 805 805

 Long Term 250 250

 Short Term 250 250

Adhesives:

 Commercial Interior Adhesive 760 760

 Cyanoacrylate Adhesive 1020 1020

 Fuel Tank Adhesive 620 620

 Nonstructural Adhesive 250 250

 Rocket Motor Bonding Adhesive 890 890

 Rubber-Based Adhesive 850 850

 Structural Autoclavable Adhesive 50 50

 Structural Nonautoclavable Adhesive 850 850

Antichafe Coating 600 420

Barrier Coating 420 420

Bearing Coating 620 620

Caulking and Smoothing Compounds 850 850

Chemical Agent-Resistant Coating 550 550

Clear Coating 520 520

Commercial Exterior Aerodynamic Structure 

Primer

350 350

Compatible Substrate Primer 350 350

Corrosion Prevention System Compound 710 710

Cryogenic Flexible Primer 350 350

Cryoprotective Coating 600 600

Dry Lubricative Material 

 Fastener Manufacturing 120 1120

 Nonfastener Manufacturing 675 5.6675

Electric- /or Radiation- Effect 800 6.7800

Electrostatic Discharge and Electromagnetic 

Interference Coating 

800 800 

Elevated-Temperature Skydrol-Resistant 

Commercial Primer 

350 350 

Epoxy Polyamide Topcoat 660 660 

Extreme Performance Interior Topcoat 420 3.5420

Fastener Sealant 675 600 
Santa Barbara County APCD Rule 337 337 - 14 October 20, 1994[date of amended rule adoption]

Coating Type ROC Limit 

g/l Effective 

Before [24 months 

after the date of 

amended rule 

adoption]

lb/gal Effective On 

and After [24 months 

after the date of 

amended rule 

adoption]

Fire Insulation Coating 600 5

Fire-Resistant (Interior) Coating 600 600

Flexible Primer 350 350

Flight-Test Coatings:

 Missile or Single Use Aircraft 420 420

 All Other 600 600

Fuel Tank Coating (Excluding Fuel Tank 

Adhesive)

720 

420

6 

420

High -Temperature Coating 720 6720

Interior Topcoat 340 2.8340

Insulation Covering 740 740

Intermediate Release Coating 750 750

Lacquer 830 830

Maskant-Chemical Processing 600 5

Maskants:

 Bonding Maskant 1,230 1,230

 Critical Use and Line Sealer Maskant 1,020 1,020

 Seal Coat Maskant 1,230 1,230

Metallized Epoxy Coating 700 700

Mold Release 780 780

Optical Anti-Reflective Coating 700 700

Part Marking Coating 850 850

Pretreatment Wash PrimerCoating 400 

780

3.3 

780

Primer 350 2.9

Rain Erosion-Resistant Coating 600 600

Rocket Motor Nozzle Coating 660 660

Scale Inhibitor 880 880

Screen Print Ink 840 840

Sealant 600 5

 Extrudable/Rollable/Brushable Sealant 280 280 

 Sprayable Sealant 600 600 

Sealant Bonding Primer 720 6

Self Priming Topcoat 420 3.5

Silicone Insulation Material 850 850

Solid Film Lubricants 

 Fastener Manufacturing 250 250

 Fastener Installation 880 880

 Nonfastener Manufacturing 880 880

Space Vehicle Coating: 

 Electrostatic-Discharge 800 6.7800

 Other 1,000 8.31,000

Specialized Function Coating 890 890

Temporary Protective Coating 250 2.1250
Santa Barbara County APCD Rule 337 337 - 15 October 20, 1994[date of amended rule adoption]

Coating Type ROC Limit 

g/l Effective 

Before [24 months 

after the date of 

amended rule 

adoption]

lb/gal Effective On 

and After [24 months 

after the date of 

amended rule 

adoption]

Topcoat 420 3.5

Thermal Control Coating 800 800

Wet Fastener Installation Coating 675 675

Wing Coating 750 6.3750

 

 2. A No person shall notapply any stripper or specify solicit the use of any stripper unless it complies 

with one or both of the following: 

 a. The stripper contains less than 400 300 grams/ of reactive organic compound per liter of 

ROC of material (2.50 pounds of reactive organic compound per gallon). 

 b. The stripper has a true vapor reactive organic compound composite partial pressure of 

less than 10 mm Hg equal to or less than 9.5 millimeters of mercury at actual usage 

temperature20 degrees Celsius. 

 3. Sources A person may elect to use an add-on exhaust control equipment system to achieve as an 

alternative to meeting the requirements compliance with the provisions of Sections D.1, D.2, E, 

and J, provided that the control equipment meets all of the applicable requirements of sections a. 

and b. below are met. Such control equipment must be approved in advance by the Control 

Officer. Any person choosing to install such control equipment shall obtain an Authority to 

Construct from the District prior to installation. 

 a. The control device shall reduce emissions from an emission collection system by at least 

95 percent by weight. 

 b. The emission collection system which collects and transports emissions to an air 

pollution control device shall collect at least 90 percent by weight of the emissions 

generated by the sources of emissions.

a. The overall efficiency (the capture efficiency multiplied by the control device efficiency) 

of the total system shall not be less than 85.5 percent, by weight. Alternatively, the 

control device reactive organic compound exhaust concentration shall not exceed 10 parts 

per million by volume as propane or other limit approved by the Environmental 

Protection Agency, the Air Resources Board, and the Control Officer. 

b. Combustion temperature shall be continuously monitored when operating a thermal 

incinerator. 

c. Inlet and exhaust gas temperatures shall be continuously monitored when operating a 

catalytic incinerator. 

d. Control device efficiency shall be continuously monitored when operating a carbon 

adsorber or a control device other than a thermal or catalytic incinerator. 

e. Compliance through the use of an add-on control system shall not result in affected 

pollutant emissions in excess of the affected pollutant emissions that would result from 

compliance with Sections D.1, D.2, E, and J.
Santa Barbara County APCD Rule 337 337 - 16 October 20, 1994[date of amended rule adoption]

E. Requirements -– Application Equipment

A No person shall not apply coatings subject to the provisions of this rule except by using properly 

operated unless the application is performed with equipment and by operating according to the 

manufacturers operating guidelines. In addition, except as provided in Section D.3, the application method 

employed shall be one of the following: 

 1. Electrostatic spray application, or 

 2. Flow coat application, or 

 3. Dip coat application, or 

4. Roll coater, or 

45. High volume, low pressure spraying (HVLP) equipment, or 

56. Electrodeposition, or 

67. Hand application methods, or 

78. Detailing or touch-up guns, or 

89. Any other coating application method that approved by the Control Officer, the Air Resources 

Board, and the Environmental Protection Agency, achieves that has a coating transfer efficiency of 

at least equivalent to or greater than 65 percent efficiency as demonstrated measured by using the 

test method specified in Section I.4.

10. Except as otherwise provided in Section E.11, air-atomized spray may only be used for the 

application of contact adhesives or specialty contact adhesives. 

11. For adhesive products and sealant products with an as applied viscosity of 200 centipoise or 

greater, airless spray, air-assisted airless, and air-atomized spray may be used. 

F. Requirements -– Closed ContainersGeneral Operating

Any person who owns, operates, or uses any surface coating or depainting equipment for any aerospace 

vehicle or component coating operation shall meet the following requirements: 

1. All ROC reactive organic compound-containing materials, used or unused, including but not 

limited to surface coatings, thinners, cleanup solvents, strippers, or surface preparation materials 

shall be stored and disposed of in closed nonabsorbent and nonleaking containers equipped with 

tight-fitting covers. All covers shall be in place unless adding material to or removing material 

from the containers, and opened only during extraction or introduction of material for mixing, use 

or storage the containers are empty, or doing maintenance/inspection of the containers. 

2. All application equipment, ventilation system, and emission control equipment shall be installed, 

operated, and maintained consistent with the manufacturer’s specifications.

3. Waste solvent, waste solvent residues, and any other waste material that contains reactive organic 

compounds shall be disposed of by one of the following methods:

a. A commercial waste solvent reclamation service licensed by the State of California. 

b. At a facility that is federally or state licensed to treat, store or dispose of such waste. 
Santa Barbara County APCD Rule 337 337 - 17 October 20, 1994[date of amended rule adoption]

c. Recycling in conformance with Section 25143.2 of the California Health and Safety 

Code. 

4. All covers, valves, drain plugs, and other closure devices designed to reduce surface coating, 

stripper, or solvent evaporation shall not be removed or opened except to process work or to 

perform monitoring, inspections, maintenance, or repairs that require the removal of the covers or 

other closure devices. 

5. Any surface coating, stripper, or solvent spills shall be wiped up immediately and the used 

absorbent material (e.g., cloth, paper, sand, sawdust, etc.) shall be stored in closed containers that 

are handled in accordance with Section F.1. 

6. The handling and transfer of coatings, strippers, and cleaning solvents to or from enclosed 

systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or 

spent coatings, strippers, and cleaning solvents shall be conducted in such a manner to minimize 

spills. 

7. Containers used to store coating, solvent, or any waste material that contains reactive organic 

compounds subject to this rule shall be marked or clearly labeled indicating the name of the 

material they contain. 

G. Requirements -– Manufacturer Labeling

 1. Each container of any coating subject to this rule shall display the date on which the contents were 

manufactured or a code indicating the date of manufacture. Each manufacturer of such coatings 

shall file with the Air Pollution Control Officer and the Executive Officer of the California Air 

Resources Board an explanation of each code. 

 2. Each container of any coating subject to this rule shall display a statement of the manufacturer's 

recommendation regarding thinning of the coating. This recommendation shall not apply to the 

thinning of coatings with water. The recommendation shall specify that the coating is to be 

employed without thinning or diluting under normal environmental and application conditions 

unless any thinning recommended on the label for normal environmental and application 

conditions does not cause a coating to exceed its applicable standard for reactive organic 

compound content. 

 3. Each container of any coating subject to this rule shall display the maximum ROCreactive organic 

compound content of the coating, as applied, and after any thinning as recommended by the 

manufacturer. ROC Reactive organic compound content shall be displayed as g/lgrams per liter or 

lb/galpounds per gallon of coating, less water and less exempt organic compounds. The VOC 

volatile organic compound content may be displayed instead of the ROC reactive organic 

compound content as long as the manufacturer's definition of VOC volatile organic compound is 

consistent with the definition of ROC reactive organic compound contained in District Rule 102, 

Definitions. ROC Reactive organic compound content displayed may be calculated using product 

formulation data and the formula in Section C, or may be determined using the test method in 

Section I.1. 

H. Requirements -– Recordkeeping

Any Persons person subject to this rule shall comply with the following requirements. Any owner or 

operator of any stationary source comprised of more than one facility may comply with the following 

requirements on a facility basis. 

 1. Maintain a current listingfile of all ROCreactive organic compound-containing materials in use at 

their facilitythe stationary source subject to this rule. This listing shall include: The file shall 
Santa Barbara County APCD Rule 337 337 - 18 October 20, 1994[date of amended rule adoption]

provide all of the data necessary to evaluate compliance and shall include the following 

information, as applicable:

 a. material name and manufacturer identification (e.g., brand name, stock identification 

number);

 b. application method;

 c. material type, and manufacturer’s specific use instructions (e.g., specific use for which 

the material is intended), type operation (e.g., coating, stripping, or solvent cleaning), 

and, for coating operations, the coating type from Table 337-1 or Table 337-2 and 

equipment coated;

d. specific mixing ratiodata (e.g., component volumes or weights) of each component for 

each batch sufficient to determine the mixture’s reactive organic compound content; 

e. the corresponding reactive organic compound limit(s) from Sections D.1, D.2, and J.1 

and the maximum actual as applied ROCreactive organic compound content of coating

used. If complying using the “reactive organic compound composite partial pressure” 

method only, provide the actual reactive organic compound composite partial pressure of 

the materials used less water and less exempt compounds as applied (including thinning 

solvents).; and 

f. current coating, stripper, and solvent manufacturer specification sheets, Material Safety 

Data Sheets, product data sheets, or air quality data sheets, which list the reactive organic 

compound content of each material in use at the stationary source subject to this rule. 

Compliance with this provision may be done by ensuring the manufacturer’s 

specifications are listed on the product container. 

 

2. Current coating manufacturer specification sheets, Material Safety Data Sheets or current air 

quality data sheets, which list the ROC content of each material in use at their facility, shall be 

available for review on site. 

32. Maintain purchase records identifying the type or name and the volume of material purchased for 

each ROCreactive organic compound-containing material purchased for use at the stationary 

source. The records shall include, but not be limited to, the following: 

a. material name and manufacturer identification (e.g., brand name, stock identification 

number); and 

b. material type (e.g., coating type from Table 337-1 or Table 337-2, cleanup solvent, 

stripper, etc.). 

3. Maintain records of the disposal method each time waste solvent, waste solvent residue, or other 

waste material that contain reactive organic compounds is removed from the stationary source for 

disposal. 

 4. Maintain For each material maintained in response to Section H.1.a, maintain at a minimum, on a 

monthly basis for compliant material and on a daily basis for noncompliant material, a record of 

the following: 

a. volume used (gallons per day, gallons per month),; 

b. ROCreactive organic compound content (grams per liter or pounds per gallon); and 
Santa Barbara County APCD Rule 337 337 - 19 October 20, 1994[date of amended rule adoption]

c. and resulting ROCreactive organic compound emissions (pounds per day, pounds per 

month)of each ROC-containing material used.

These records shall be summarized for each calendar year and submitted to the District by March 

1 of the following year. 

 5. Operators of facilities For any stationary source that uses non-compliant coating materials with 

compliance achieved through the operation of emission control equipment as an alternative to 

meeting the requirements of Sections D.1, D.2, E, or J, shall maintain daily records of key 

operating parameter values and maintenance procedures which that demonstrate continuous 

operation and compliance of the emission control device system during periods of emission 

producing activities shall be maintained. These parameters shall include, but not be limited to: 

a. Hours of operation; 

b. All maintenance work that requires the emission control system to be shut down; 

c. All information needed to demonstrate continuous compliance with Section D.3, such as 

temperatures, pressures, and/or flow rates. 

 6. All Any records required by to be maintained pursuant to this rule shall be kept on site for at least 

2 years unless a longer retention period is otherwise required by state or federal regulation(s). 

Such records shall be readily available for shall be retained and available for inspection by the 

Control Officer or designated representative upon request for the previous 36 month period and 

review by the District. 

 

7. Any person claiming an exemption under Section B.1 shall maintain: 

a. Daily records of the volumes in gallons of non complying coating materials used by each 

separate formulation at the stationary source. 

b. Annual running totals, from January 1 of each calendar year, of the volume in gallons of 

non-complying coating materials used at the stationary source for: 

1) Each separate formulation. 

2) All formulations. 

I. Requirements – Compliance Provisions and Test Methods

 1. ROC content of a coating Coatings and solvent reactive organic compound content shall be 

determined measured using EPA by the Environmental Protection Agency Reference Method 24, 

its constituent methods, or an equivalent method approved by the Control Officer, ARB and EPA 

Environmental Protection Agency, the Air Resources Board, and the Control Officer. The 

determination of exempt compounds shall be performed in accordance with ASTM D 4457-

851991, “Standard Test Method for Determination of Dichloromethane and 1,1,1-Trichloroethane 

in Paints and Coatings by Direct Injection into a Gas Chromatograph,” ASTM International. 

Alternatively, determination of exempt compounds may be performed in accordance with the 

South Coast Air Quality Management District Method 303-91, “Determination of Exempt 

Compounds,” August 1996. The reactive organic compound content of materials containing 50 

grams of reactive organic compound per liter or less shall be determined by the South Coast Air 

Quality Management District Method 313-91, “Determination of Volatile Organic Compounds by 

Gas Chromatography-Mass Spectrometry,” June 1993, or any other test methods approved by the 

Environmental Protection Agency, the Air Resources Board, and the Control Officer. 

 
Santa Barbara County APCD Rule 337 337 - 20 October 20, 1994[date of amended rule adoption]

 2. Compliance with Section D.3.a The control device efficiency for reactive organic compound 

emissions shall be determined by using ARB Method 100 or EPA Environmental Protection 

Agency Test Methods 25, 25A, the South Coast Air Quality Management District Method 25.1, 

“Determination of Total Gaseous Non-Methane Organic Emissions as Carbon,” February 1991, or 

the South Coast Air Quality Management District Method 25.3, “Determination of Low 

Concentration Non-Methane Non-Ethane Organic Compound Emissions from Clean Fueled 

Combustion Sources,” March 2000, as applicable. Environmental Protection Agency Test Method 

18 or Air Resources Board Method 422, “Exempt Halogenated VOCs in Gases,” September 12, 

1990, shall be used to determine emissions of exempt compounds. or a method determined to be 

equivalent and approved by the Control Officer, ARB, and EPA. 

 3. Compliance with Section D.3.b The capture efficiency for reactive organic compound emissions 

shall be based on EPA Guidelines for Developing Capture Efficiency Protocols from 55 FR 

26865, July 1, 1990determined by verifying the use of a Permanent Total Enclosure and 100 

percent capture efficiency as defined by Environmental Protection Agency Method 204, “Criteria 

for and Verification of a Permanent or Temporary Total Enclosure.” Alternatively, if an 

Environmental Protection Agency Method 204 defined Permanent Total Enclosure is not 

employed, capture efficiency shall be determined using a minimum of three sampling runs subject 

to data quality criteria presented in the Environmental Protection Agency technical guidance 

document “Guidelines for Determining Capture Efficiency, January 9, 1995.” Individual capture 

efficiency test runs subject to the Environmental Protection Agency technical guidelines shall be 

determined by: 

a. The Temporary Total Enclosure approach of Environmental Protection Agency Methods 

204 through 204F; or 

b. The South Coast Air Quality Management District “Protocol for Determination of 

Volatile Organic Compounds (VOC) Capture Efficiency,” May 1995. 

 

 4. Compliance with Section E.8 Application equipment coating transfer efficiencies shall be 

determined measured using South Coast Air Quality Management District Method “Spray 

Equipment Transfer Efficiency Test Procedure of for Equipment User,” May 24, 1989. 

5. Compliance with Section D.2 Reactive organic compound composite partial pressures shall be 

determined measured using ASTM D 2879-861997,“Standard Test Method for Vapor PressureTemperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope,” 

ASTM International, in combination with the formula in the Rule 102 definition of “reactive 

organic compound composite partial pressure,” manufacturer's specified vapor reactive organic 

compound composite partial pressure, or an accepted scientific reference approved the 

Environmental Protection Agency, the Air Resources Board, and the Control Officer. 

6. The control device efficiency for toxic air contaminant emissions that are not reactive organic 

compounds shall be determined using: 

a. an Environmental Protection Agency approved test method or methods, or 

b. in the case where there is no Environmental Protection Agency approved test method, a 

District approved detection method applicable for each target toxics specie. 

c. the Control Officer may require more than one test method on any emission control 

device where necessary to demonstrate that the overall efficiency is at least 85.5 percent 

by weight in reducing emissions of reactive organic compounds and/or toxic air 

contaminants. Any technique to convert “parts per million by volume” test method 

results to either 1) “parts per million by weight,” or 2) “mass emission rates” (e.g., 

pounds per hour) shall first be approved by the Control Officer and, if such approval is 

not provided, then the technique shall not be used to show compliance with this rule. 
Santa Barbara County APCD Rule 337 337 - 21 October 20, 1994[date of amended rule adoption]

7. The capture efficiency for toxic air contaminant emissions that are not reactive organic 

compounds shall be determined by using the methods described in Section I.3 modified in a 

manner approved by the District to quantify the mass of liquid or gaseous reactive organic 

compounds and/or toxic air contaminants. 

8. 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. The test solvent for this 

determination shall be any lacquer thinner with a minimum reactive organic compound composite 

partial pressure of 105 millimeters of mercury at 20 degrees Celsius, and the minimum test 

temperature shall be 15 degrees Celsius. 

9. Viscosity shall be determined by ASTM D 1084-88, “Standard Test Methods for Viscosity of 

Adhesives,” ASTM International.

10. Emissions of reactive organic compounds from the exhaust of an emission control system shall be 

measured by the Environmental Protection Agency Method 25, in combination with 

Environmental Protection Agency Method 18 or the California Air Resources Board Method 422, 

“Exempt Halogenated VOCs in Gases,” September 12, 1990 (to determine emissions of exempt 

compounds). 

11. When more than one test method or set of test methods are specified for any testing, a test result 

showing an exceedance of any limit of this rule shall constitute a rule violation. 

12. The Environmental Protection Agency test methods in effect on [date of amended rule adoption] 

shall be the test methods used to meet the requirements of this rule. 

J. Requirements – Solvent Cleaning Associated with Surface Coating of Aerospace Vehicles and 

Components

Section J requirements shall apply to any person performing solvent cleaning associated with surface 

coating of aerospace vehicles or components, including, but not limited to, use of wipe cleaning cloths, 

hand-held spray bottles, squirt bottles, aerosol products, and the cleaning of application equipment. The 

following requirements become effective [one year from the date of amended rule adoption] and are in 

addition to the general operating requirements specified in Section F. 

1. Solvent Requirements 

Except when using an emission control system that meets the requirements of Section D.3, no 

person shall use any solvent to perform solvent cleaning which exceeds the following limits: 

a. When Performing Surface Preparation for Coating Application and Cleanup (Other 

than Spray Application Equipment Cleaning):

1) 200 grams of reactive organic compound per liter (1.67 pounds of reactive 

organic compound per gallon) of material, or 

2) reactive organic compound composite partial pressure of 45 millimeters of 

mercury at 20 degrees Celsius. 

b. When Performing Solvent Cleaning of Spray Application Equipment: 25 grams of 

reactive organic compounds per liter (0.21 pounds of reactive organic compound per 

gallon) of material. In lieu of meeting the reactive organic compound-content limit, a 

person may use an enclosed cleaning system, or equipment that is proven to the 

satisfaction of the Control Officer to be equally effective as an enclosed cleaning system 
Santa Barbara County APCD Rule 337 337 - 22 October 20, 1994[date of amended rule adoption]

at controlling emissions. “Equal effectiveness” of an alternative cleaning system shall be 

determined by the test method referenced in Section I.8 of this rule. If an enclosed 

cleaning system is used, it shall totally enclose spray guns, cups, nozzles, bowls, and 

other parts during washing, rinsing, and draining procedures, and it shall be used 

according to the manufacturer’s recommendations and be closed when not in use.

2. Cleaning Devices and Methods. Except for solvent cleaning of spray application equipment, any 

person performing solvent cleaning with a solvent containing more than 25 grams of reactive 

organic compounds per liter of material shall use one or more of the following cleaning devices or 

methods: 

a. Wipe cleaning where solvent is dispensed to wipe cleaning materials from containers that 

are kept closed to prevent evaporation, except while dispensing solvent or replenishing 

the solvent supply, and where wipes are stored in closed containers to prevent 

evaporation when not in use; 

b. Application of solvent from hand-held spray bottles, squirt bottles, or other closed 

containers with a capacity of one liter or less; or 

c. Non-atomized solvent flow, dip, or flush cleaning method where pooling on surfaces 

being cleaned is prevented or drained, and all solvent runoff is collected in a manner that 

enables solvent recovery or disposal. The collection system shall be kept closed to 

prevent evaporation except while collecting solvent runoff or emptying the collection 

system. 

K. Compliance Schedule

Any person who owns, operates, or uses any application equipment to surface coat any aerospace vehicles 

or components shall meet the following compliance schedule: 

1. By [30 days from the date of amended rule adoption], comply with Section F, Requirements - 

General Operating. 

2. By [six months from the date of amended rule adoption], comply with the recordkeeping 

provisions in the following Sections: 

a. H.1.d - mixing data, 

b. H.1.e - reactive organic compound content data, 

c. H.2 - purchase records, 

 

d. H.3 - waste disposal records, and 

e. H.4 - daily records for noncompliant materials. 

3. By [one year from the date of amended rule adoption], comply with the Section J and Section M 

requirements. 

4. By [date of amended rule adoption], comply with all other provisions of this rule. 

L. Reporting Requirements 

Submittal of an annual report to the District is required if: 

• A person holds a permit for equipment subject to the requirements of this rule, or 
Santa Barbara County APCD Rule 337 337 - 23 October 20, 1994[date of amended rule adoption]

• A person is subject to the requirements of this rule and applies non-complying coatings. 

The annual report shall be due March 1 and it shall contain the following information for the previous 

calendar year: 

1. monthly totals (gallons) of compliant and noncompliant material used based on the records 

required by Section H.4, 

2. annual totals (gallons) based on each of the coating’s, solvent’s, and stripper’s monthly data, 

3. if claiming the Rule 337.B.1 exemption, annual totals (gallons) of non-complying coatings for 

each separate formulation and all formulations, per Section H.7.b, and 

4. if permitted, name and address of the company or agency, and the Permit to Operate number that 

the surface coating equipment is subject to. 

M. Requirements - Solvent Cleaning Machine

Any person who owns, operates, or uses any solvent cleaning machine shall comply with the applicable provisions 

of Rule 321, Solvent Cleaning Machines and Solvent Cleaning.

 APPROVED AS TO FORM: 

 

 DENNIS A. MARSHALL 

 SANTA BARBARA COUNTY COUNSEL 

 By____________________________ 

 Deputy 

 Attorneys for the Santa Barbara County 

 Air Pollution Control District