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New CA Plan Cuts Paint VOC Limits

Thursday, December 13, 2012

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The South Coast Air Quality Management District has approved its 2012 Air Quality Management Plan, which includes binding VOC emissions reductions for architectural coatings.

In announcing SCAQMD's ruling, the American Coatings Association (ACA) said the 2012 plan committed to a VOC reduction of two tons per day for architectural coatings. The plan includes three proposed control measures:

  • Reducing the volatile organic compound (VOC) content in flat, nonflat, and primers, sealers and undercoaters from 50 grams per liter to 25 grams per liter;
  • Evaluating potential changes or the elimination of the small container exemption; and
  • Increasing the transfer efficiency of paint spray guns.

SCAQMD's Governing Board approved the measures Dec. 7. They outline strategies for meeting the National Ambient Air Quality Standards for Fine Particles (PM2.5) and eight-hour ozone in the Los Angeles Air Basin.

South Coast Air Quality Management District
SCAQMD

The 2012 Air Quality Management Plan incorporates the latest scientific and technological information, according to the district.

"SCAQMD will not be amending the actual regulations for a few years," ACA said.

The California Resources Board will consider the 2012 AQMP for inclusion into the California State Implementation Plan in January 2013 as the next step in the process.

ACA Requests at Hearing

ACA, which has been involved in the development of the plan from the outset, attended the hearing and urged the governing body to "remove the proposed VOC reduction control measures (CTS-01, CTS-02, CTS-03, and CTS-04) from the plan."

Citing the paint and coating industry's strides in reducing its products' VOC emissions in the past, the industry group said the district should focus on other source categories for further emissions reductions instead of "unfairly targeting the coatings industry."

Los Angeles smog

SCAQMD's plan outlines strategies to help the Los Angeles Basin meet National Ambient Air Quality Standards. Coating makers said they were unfairly targeted.

ACA was successful in convincing SCAQMD to reduce its VOC reduction committments for architectural and industrial maintenance coatings from four tons per day to two tons per day, according to the industry group.

ACA also worked with district staff to consider a range of options for amending the small container exemption in the future, instead of the outright elimination of this critical compliance option for coatings manufacturers, ACA reports.

The district has added language to the plan to allow for flexibility in the future and has assured ACA that any specific numeric goals or targets may be adjusted during the course of future rulemakings based on technical and economic concerns.

The SCAQMD sets air-quality regulations on stationary (non-vehicular) sources in Los Angeles and adjacent areas, and has set the bar high in enacting the nation’s toughest rules on VOC content in paint and coatings. The district’s Rule 1113 imposes stringent VOC limits on a wide range of architectural and industrial maintenance coatings.

   

Tagged categories: Air quality; Health and safety; Regulations; SCAQMD; VOC emissions

Comment from Tim Race, (12/13/2012, 8:03 AM)

At what level of VOC do regulations become self-defeating? If more frequent recoating is necessary because of poor coating performance, then life-cycle and therefore total VOC emissions may increase.


Comment from Tim Allen, (12/13/2012, 10:17 AM)

I completely agree, Tim. I've been stating this point for some time now. They are further hindering the ability to formulate functional solvent-borne coatings by refusing to exempt t-Butyl Acetate from VOC regulation, although it has been exempted by the EPA for some time now. Reducing the VOC content to levels that destroy the coating's performance while removing tools from our formulation capability will increase the frequency of re-application, put applicators in high-risk situations (flashpoint of acetone), and dramatically increase the cost to the consumer. It's difficult enough to formulate coatings that perform when adhering to the nonsensical Method 24 VOC calculation without adding the extreme burden being imposed by SCAQMD.


Comment from Mark Schilling, (12/14/2012, 11:17 AM)

To Tim Race and Tim Allen - I agree completely. I've been gone from CA for some 14 or so years. We were having that very same argument in CA 25+ years ago. It's a simple question of metrics. There are people (bureaucrats) who don't know or really much care about what they are doing - but they think, they argue that they are doing a "good" job. In this case Tim Race nails it. The bureaucrats choose THEIR metric, VOC per gallon, and they seek to control the narrative - VOC per gallon is the only thing that really matters. Force the technology. That's THEIR metric. Real reality has often proved to play out very differently. Studies were done in the 80s. There were lawsuits. We saved another 10% on VOC per gallon but we are repainting more often - and it becomes a net loser as far as VOC goes (and overall cost to facility owners). Oh joy!! That was reasonably well documented back in the 80s. Paint manufacturers sell more paint and paint contractors are busier - so let me be clear that not everyone is unhappy with that situation. It's a complex issue. What are you really after? If your metric is lower VOC per gallon and that is all you can see, you are missing the big picture. Of that there is no doubt.


Comment from John Fauth, (12/17/2012, 12:38 PM)

The larger picture touched on by Mark, Tim and Tim... nobody is miraculously imbued with a special understanding of the world simply because they are elected local dog catcher... or legislator. Yet they act as if it were true, and pass legislation accordingly. "Doing good" is not nearly as important as "feeling good", and that is how they judge their own work. Don't confuse them with facts or reason.


Comment from Tatsuya Nakagawa, (12/17/2012, 6:31 PM)

Compliant coating do not all produce poor performance. There are many examples of quality compliant coating.


Comment from Mark Schilling, (12/19/2012, 8:01 AM)

To Tatsuya Nakagawa - I certainly agree with you. Not all VOC compliant coatings give poor performance - today. But that's not the point. There have been many case histories of problem products getting out of the lab too soon. The late 70s and into the 80s was a confusing and problematic time for the paint industry. The problem was primarily the simple strategy employed by air quality management districts. Some generic products were exempt. Certain solvents were exempt. And the rules (VOC restrictions) changed every few years. This incremental racheting down on the paint industry to force technology meant that many coatings were being reformulated every few years. (And of course there was also an effort to reduce or eliminate the use of Pb, Cr, asbestos, etc.) Much of the time the brand name and product number would remain the same (e.g., Acme 1000). Some times an HS would be added to indicate a high solids "version" of the former product (e.g., Acme 1000 HS). There were a lot of trial and error type coating failures. The paint manufacturers relied mostly on accelerated test methods because they didn't have time to get 3 to 5 years with real world case histories before they were forced to reformulate again. Consider a facility owner who spends a lot of effort and money to approve coatings. A few years later that information might be worthless. And if the owner has succesful case histories by then, they too may be worthless because those specific formulations are no longer availble (they became unlawful). And so I agree with you. Many VOC complient coatings work just fine, today. But I know how we got to this point. And at times that route was quite painful. And here we go with another round of ratcheting down. Will this assault on the paint industry ever end?


Comment from Tom Schwerdt, (12/19/2012, 9:39 AM)

Realistically, the time and money is probably better spent getting polluting vehicles either repaired or permanently taken out of service. I see a lot of construction equipment (and ships, and trains) which belch quite a bit of visible smoke - plus the "chip tuned" diesel pickup trucks. Saw one last month which blanketed 3 lanes of a highway with smoke every time he accelerated (which he did frequently.)


Comment from Tatsuya Nakagawa, (12/20/2012, 4:41 PM)

@Mark Schilling I understand your point of view. Thanks for letting me know.


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