South Coast AQMD Looks At Tightening Paint Rule

On June 5, the South Coast Air Quality Management District (SCAQMD) held an initial Working Group meeting to discuss possible measures that would drastically reduce the VOC solvent content of paints sold and used in the District. The SCAQMD covers all or most of four counties in Southern California, an area home to almost half the population of California. Rule 1113, the District's architectural coatings regulation, has often been seen as setting the standard for other jurisdictions, despite being designed for the region's uniquely mild climate.

Following up on a proposed "control measure" included in the SCAQMD 2012 Air Quality Management Plan, District staff are looking at the possibility of reducing VOC limits on the major, high-volume categories: Flat Coatings, Non-Flat Coatings, and Primers, Sealers & Undercoaters. The target mentioned was 25 grams per liter – half the current limit for Flats and Non-Flats, and a quarter of the current limit for Primers, Sealers & Undercoaters. Such drastic reductions provoked a great deal of concern on the part of paint industry representatives at the meeting.

The industry consensus was that an across-the-board 25 grams per liter limit would impair the performance of many coatings – such as semi-gloss and gloss paints (especially for exterior use), and numerous specialized primers, sealers and undercoaters. The necessity of the limit was questioned, since the District's own data on coatings sold over the past five years show a trend toward lower overall VOC content, even in the absence of significant new limits. Also, further reductions from VOC limits on colorants have yet to be accounted for. Finally, it was suggested that further regulation would not be cost-effective, since the reductions would be small while the costs of reformulation would be tremendous.

One proposal was of particular interest to painting contractors: improving transfer efficiency of spray application by requiring "laser pointers" to be attached to spray guns for the purpose of improving aim at surfaces to be painted. Staff was apparently under the impression that transfer efficiency of airless spray equipment is currently around 50 percent – that is, out of every 100 gallons applied with airless spray equipment, 50 gallons would be wasted in overspray. Laser-equipped guns, they said, could raise transfer efficiency to 65 percent (meaning: only 35 gallons out of every 100 would be wasted). Industry representatives, including several painting contractors, protested that transfer efficiency was already well above 65 percent (probably above 90 percent), and the suggested new equipment would not raise it further.

After analyzing comments made at the meeting, District staff will schedule the next meeting of the Working Group for sometime in early Fall, possibly September or October. Staff is also working on developing a new VOC determination test method, since the current official method (EPA Test Method 24) is known to be highly unreliable for waterborne coatings with VOC contents below 50 grams per liter, and thus impractical for enforcement purposes. Ultimately, adoption of lower limits may depend on having a new test method approved by the EPA.

So far, no other agencies have expressed interest in revising the test method, or in adopting the radically low limits under consideration. SCAQMD, however, has been influential not just with governmental agencies, but also with numerous private organizations that develop voluntary standards in the green building industry, such as the U.S. Green Building Council and its LEED program.