Amendments toRule 442, Architectural

Coatings

Kevin J. Williams, Ph.D.Sacramento Metropolitan

Air Quality Management District

October 12, 2015

Overview• Health effects of ozone• What are architectural coatings?• Why did we amend the rule?• How did CARB develop the SCM?• Rule development process• Who does Rule 442 affect?• Summary of changes• Emission reductions• Costs• Rule implementation• RCMA comments

Health Effects of Ozone

• Sacramento has the 5th worst ozone air quality in U.S. (2015 State of the Air: Amer. Lung Assoc.)

• Sacramento is a severe ozone nonattainment area for the federal standards

• VOCs and NOx react in sunlight to form ground level ozone

• Ozone health effects− Decreased lung function− Development and aggravation of asthma− Increased risk of cardiovascular problems− Increased hospitalizations and emergency room visits− Premature deaths

What are Architectural Coatings?• Paints, primers, sealers, stains, roof coatings, concrete

curing compounds, clear wood finishes, etc. for:

Does not include coatings applied in manufacturing or refinishing shops

Why did we amend the rule?• Reductions in VOC emissions are needed to help achieve

state and federal ozone standards− Architectural Coatings are the 5th largest VOC emission

source in Sacramento County

• CARB’s Suggested Control Measure (SCM) will produce substantial emission reductions− Lower VOC limits are feasible because of advances in

coating technology− Compliant products are already available on the market

• Adopting the SCM makes the rule consistent with other major districts across the state− Aids compliance by manufactures, distributors, and

retailers

How did CARB develop the SCM?• Originally developed in 1977 – updated in 1985, 1989, 2000,

and 2007

• CARB conducts survey of architectural coatings sold in California (last in 2005, another in progress)

• For 2007 update, CARB considered:− Recent amendments to South Coast AQMD Rule 1113,

Architectural Coatings− 2005 survey of architectural coatings sold in California – identified

compliant products that meet proposed VOC limits− Technology assessment for all coating categories− Economic and environmental impacts

• CARB met with stakeholders:− Meetings with air quality districts, EPA, industry trade groups, and

manufacturers− Three public workshops

Rule Development Process

• Evaluated SCM requirements− Determined need for any deviations

• Developed draft rule and analysis document

• July 7, 2015 – published draft materials for public comment

• August 5, 2015 – held public workshop

• Considered public comments and made appropriate changes

• August 25, 2015 – published final proposal, announced public hearing

• September 24, 2015 – Board adopted the rule

Who does Rule 442 affect?• Do-it-yourself consumers • Construction trades people including:

- Painting contractors − Cabinet refinishers

- Flooring contractors − Swimming poolpainters

-Concrete workers − Roofers-Roadway striping − Deck and fencing

companies installers- Industrial and commercial maintenance

operations

• Coating manufacturers, distributors and retailers

Summary of Changes

• Rule Applicability− Added blenders and repackagers of architectural

coatings for use within the District (Section 102.2)

• Exemptions− Small container exemption (≤ 1 liter) will explicitly

exclude containers bundled or intended to be used in combined volumes > 1 liter (Section 110.3)

• Revised VOC limits (Section 301)− Added and eliminated several specialty coating

categories− Reduced VOC limits for many coating categories

(summarized later in the presentation)− Effective date is March 24, 2016.

Summary of Changes

• 3-year sell-through for coatings that meet the 2001 VOC limits− Coatings manufactured before March 24, 2016 can be

sold, supplied, or offered for sale until March 24, 2019.− Coatings manufactured before March 24, 2016 may be

used indefinitely if they were purchased prior to that date− Coating container must be labeled with manufactured date

(Section 303)

• Early Compliance Provision− Allows early compliance with the amended rule if a coating

meets all provisions of the rule that are effective on March 24, 2016 (Section 309)

continued

Summary of Changes

• Administrative Requirements− For multi-component products, the VOC content

must be displayed as mixed or catalyzed (Section 401.3)

− Labeling requirements added for new or revised coating categories (Sections 401.10 – 401.14)

− Manufacturers must provide sales data to ARB upon request (Section 501.1)

continued

Summary of Changes

• Eliminated Specialty Coating CategoriesAntenna AntifoulingClear Brushing Lacquer Fire RetardantFlow LacquerQuick Dry Enamel Sanding SealerQuick Dry Primer/Sealer/Undercoater VarnishSwimming Pool Repair/Maintenance Temperature-Indicator SafetyWaterproofing Concrete/Masonry Sealer Waterproofing Sealer

• New Specialty Coating CategoriesAluminum Roof Basement Specialty

Concrete/Masonry Sealers Driveway Sealers

Reactive Penetrating Sealers Stone Consolidants

Tub and Tile Refinish Waterproofing Membranes

Wood Coatings Zinc-Rich Primers

continued

Coating Category (* Indicates new category)

VOC Regulatory Limit (grams/liter)Current Effective

3/24/16

Flat 100 50

Nonflat 150 100

Nonflat – High Gloss 250 150

Aluminum Roof * 500 400

Bituminous Roof (Bituminous Primer Unchanged at 350 g/l) 300 50

Mastic Texture 300 100

Primers, Sealers, Undercoaters (PSU) 200 100

Roof (Other than Bituminous) 250 50

Rust Preventative 400 250

Waterproofing Membranes * 250 or 400 250

Wood Coatings * 350, 550, or 680 275

Changes to VOC Limits(common categories)

Emission Reductions• Architectural Coatings are 5th largest VOC source in

Sacramento County• Lower VOC limits reduce emissions by 1.4 tons per day

Reduction

Costs• In 2007, CARB estimated a cost increase of

$1.38 per gallon, on average, if manufacturers passed costs on to consumers

• Manufacturers’ costs for reformulation already incurred− Compliant products are available now

• Overall rule cost effectiveness: $1.28 per pound of VOC reduced− Previously adopted District rules have ranged

from $1 to $21 per pound reduced

Rule Implementation• September 24, 2015 – March 23, 2016:

Early Compliance provision is in effect• March 24, 2016: New rule requirements

take effect− Rule will be republished without

expired provisions• March 24, 2019: 3-year sell-through

period ends

RCMA Comments• Definition of Roof Coatings• Tertiary Butyl Acetate (TBAC)

exemption status

Coating Category (* Indicates new category)

VOC Regulatory Limit (grams/liter)Current Effective 3/24/16

Flat 100 50

Nonflat 150 100

Nonflat – High Gloss 250 150

Aluminum Roof * 500 400

Basement Specialty * 250 or 400 400

Bituminous Roof (Bitum. Primer Unchanged at 350 g/l)

300 50

Concrete/Masonry Sealers * 250 or 400 100

Driveway Sealers * Flat, Non-flat, or High Gloss 50

Dry Fog 400 150

Floor 250 100

Mastic Texture 300 100

Primers, Sealers, Undercoaters (PSU) 200 100

Reactive Penetrating Sealers * 250 or 400 350

Roof (Other than Bituminous) 250 50

Rust Preventative 400 250

Specialty PSU 350 100

Stone Consolidants * 250 or 400 450

Traffic Marking 150 100

Tub and Tile Refinish * Flat, Non-flat, or High Gloss 420

Waterproofing Membranes * 250 or 400 250

Wood Coatings * 350, 550, or 680 275

Zinc-Rich Primers * 500 340