With the ink barely dry on the last round of new regulatory limits, paint and coating makers are in for more.
Sounding an early alarm, the American Coatings Association says the nation’s toughest VOC rules on field-applied paints and coatings could be tightening again soon. New restrictions on spray equipment and paint containers are also reportedly in the works.
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California's South Coast Air Quality Management District is expected to begin rulemaking procedures to modify Rule 1113, which governs VOC limits on architectural and industrial maintenance coatings.
California’s South Coast Air Quality Management District (SCAQMD) is “preparing to begin a significant rulemaking process” in June 2014 to amend its Rule 1113, which governs architectural and industrial maintenance and other coatings, ACA reports.
The revisions would be the rule's 28th since it was introduced in 1977, ACA says. The rule applies to "any architectural coating" that is "intended to be field-applied to stationary structures or their appurtenances," and to fields and lawns. Stationary structures include factories, roadways, pavement, bridges and office buildings.
New Limits Seen
The air district’s latest effort includes possibly reducing the VOC limits for flats, nonflats, and primers; limiting the sale/use of architectural coatings sold in one-liter containers or smaller; and imposing control efficiency requirements on spray equipment, ACA reports.
The agency is also considering limiting the types of faux finishes or glazes that are available on the market, according to the ACA.
A spokesman from ACA said the rule changes would likely be adopted in 2015 and take effect in 2018.
A SCAQMD representative said this week that the upcoming rulemaking efforts were a part of a control measure adopted as part of its 2012 Air Quality Management Plan, Appendix IV-A. Specifics may be found at this link, starting on page IV-A-50.
As of Wednesday, the district had not updated its Rule 1113 website to include any information regarding June 2014 rulemaking discussions.
In a “Rule and Control Measure Forecast” from December 2013, the agency noted that Rule 1113 could see the proposal of potential amendments in 2014 to “include administrative fixes and/or any clarifications that may arise due to compliance verification activities or manufacturer and public input.”
SCAQMD is authorized to regulate air pollution from stationary sources in the South Coast Air Basin, which includes all of Orange County and the non-desert regions of Los Angeles and Los Angeles County, San Bernardino County, and Riverside County.
The district's regulations are closely watched nationwide and often serve as a bellwether for regulatory action elsewhere in the United States.
The district’s amendments have included additional restrictions and lower VOC limits and, most recently in 2011, VOC limits on colorants added at the point of sale.
The new colorant VOC limits went into effect on Jan. 1.
ACA says the next rulemaking “will likely be very burdensome for both coating manufacturers and contractors.”
In a release, the group offered the following details about what SCAQMD may have in store next for the industry.
Lower Limits for Flats, Nonflats, and Primers
SCAQMD’s proposed control measure seeks to reduce VOC emissions from large volume coating categories, including flat, nonflat, and primer products, ACA says.
The air district will likely attempt to lower the current flat, nonflat, and primer VOC limits to 25 g/l from 50g/l, 50 g/l and 100 g/l, respectively, according to ACA.
While many current interior flat and nonflat coatings would likely meet the 25 g/l limit, exterior flat and nonflat coatings may not, according to the coatings manufacturers’ industry group. Further, while drywall primers may be able to meet the 25 g/l, other primers for metal and wood may not.
© flyfloor / iStock.com
The air district recently imposed VOC limits on colorants added at the point of sale, the first regulation of its kind in the United States.
“Primers are specifically designed for a wide range of substrates and exposure conditions and serve a critical functional purpose; it is extremely important that primers perform well in adhering to substrates because they are often applied as a last resort to solve difficult application challenges,” ACA relates.
Small Container Exemption
The air district may also seek to address the “Small Container Exemption” in Rule 1113 that allows manufacturers to sell certain types of coatings in liter-size or smaller containers without meeting the VOC limits, ACA says.
The group also noted that this exemption does not include select coatings categories such as Clear Wood Finishes and Lacquers.
In June, the district will evaluate various options for the small container exemption, including possibly phasing out of the exemption entirely; creating certain new categories with higher VOC limits; creating a maximum allowable VOC limit; or phasing out the small container exemption for certain coating categories.
ACA is concerned about the possible elimination of the exemption, calling it “critical, given the fact that the SCAQMD Rule 1113 limits are the most stringent in the United States.”
This exemption provides the only “safety valve” or “last-resort option that allows for the use of traditional products for challenging applications when the VOC limits in certain categories are ratcheted down or a category is eliminated,” ACA said.
Spray-Gun Efficiency Standards
ACA also warns that the district “intends to regulate the spray-gun equipment used by contractors to apply architectural and industrial maintenance coatings.”
SCAQMD will reportedly evaluate the feasibility of a two-phase approach to achieve greater transfer efficiency from the application of architectural coatings.
The new rules are likely to require improvements in transfer efficiency.
The first phase will be to incorporate laser paint targeting or other available technology into spray guns to increase transfer efficiency, according to ACA. This phase would require a retrofit by a certain date and incorporation into the design by a certain date.
The second phase would include transfer efficiency provisions requiring that architectural coatings be applied by hand applications such as brush, roller, sponge, or trowel; or by high-volume, low-pressure (HVLP) spray or other technology capable of achieving a transfer efficiency equivalent (65%) or better to HVLP spray, the group reports.
SCAQMD's current guidelines for spray-equipment transfer efficiency are available here.
Faux Finish Glazes
Finally, the regulators are also likely to address the definition of “Faux Finish Glazes” in Rule 1113.
Rule 1113 currently states that glazes are “coatings designed for wet-in-wet techniques used to create artistic effects, including… dirt, old age, smoke damage, simulated marble and wood grain finishes….”
Many glaze products on the market are labeled for application involving a glaze mixture over a dry, properly prepared, painted surface, ACA says. Faux techniques are then used to create the desired appearance.
“Even though the term ‘wet-in-wet’ has never been defined, SCAQMD now believes that the application instructions on most faux finish products do not meet the intent of the ‘wet-in-wet’ rule language,” ACA contends.
“SCAQMD intends to address this issue in the Rule 1113 amendment; however, until the SCAQMD adopts the amendments, it is likely that the sale of many glaze products in the region may be limited,” the ACA warns.