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Metal Coating Limits Honed

Friday, September 23, 2011

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Lower VOC limits, new rules for stripping operations, and new sales restrictions are likely in store for Southern California contractors, retailers and manufacturers involved in coating metal parts and products, under proposed rule revisions now being fine-tuned by the South Coast Air Quality Management District.

The proposed revisions to Rule 1107 (Coating of Metal Parts and Products) would be the first time the General coating category limit has changed in more than twelve years.

 Michigan DEQ

 Michigan DEQ

SCAQMD is hoping the rule will be ready for a public hearing by the spring.

Affected facilities would include factory paint shops that coat metal parts; operations that coat structural metal and hardware in a spray booth; and those that coat steel products and tools, boilers, tanks, shipping containers, and other metal products.

Catching Up to Technology

Many of the proposed revisions reflect changes that have already occurred in coatings formulations since the last VOC changes in 2005, SCAQMD representatives say.

“The technology has been developed and being used on its own,” air quality specialist Michael Morris said in an interview. “We’re basically catching up with the technology.”

At least two-thirds of facilities in the South Coast region that report data to the South Coast already comply with the proposed limits, said Naveen Berry, the agency’s planning and rules manager.

Coatings Makers Weigh In

Work on the revisions began about 10 months ago and has included considerable input from the American Coatings Association, which represents coatings makers, SCAQMD officials say. Although ACA has opposed tighter rules, a meeting Thursday (Sept. 22) found the parties “much closer in what the final proposal may look like,” Berry said.

As currently drafted, the changes would affect only a few of the 22 coatings categories now covered under Rule 1107.

The primary changes would be to the General category, with limits on multi-component coatings reduced to 150 gm/L from the current 340. In a novel bit of rulemaking, waterborne coatings would have a coating VOC limit of 275 gm/L, but a material VOC limit of 150 gm/L.

ACA and SCAQMD are still hashing out details on new provisions for Extreme High-Gloss Coatings, Berry said.

Key Provisions

The revisions would initially take effect Jan. 1, 2014, but full compliance would not be required until Jan. 1, 2017, with a brief grace period after that for products manufactured or in use before the deadline.

The proposal currently includes provisions to:

• Reduce VOC limits for certain metal coating categories;

• Include operations that do metal stripping only (the rule already applies to operations that strip and recoat);

• Prohibit the use of Group II Exempt Solvents in metal coatings or strippers;

• Ban the specification of non-compliant coatings and strippers; and

• Ban sales (with several exceptions) of metal coatings that exceed applicable VOC content limits.

Sales Ban

Coatings makers had expressed considerable concern about the sales ban, Berry said, given the array of complex distribution channels, uncontrollable habits of end users, and multiple potential uses of a single product.

That provision therefore includes a number of exceptions, including manufacture of coatings intended for sale outside the South Coast district and provisions for written notice of the rules to coatings customers who intend to repackage a formulation.

Similar sales prohibitions have long been part of SCAQMD’s venerable Rule 1113 on Architectural Coatings.

In addition to the new requirements for sales operations, specifiers would be held responsible for specifying compliant products. Contractors conducting shop coatings may also be held at least partly responsible if they apply a specified, but non-compliant, coating. 

The rule has been delayed several times; final passage was expected this month.

Now, SCAQMD officials think the rule will be ready for a public hearing in the first quarter of 2011. But they are optimistic that the lengthy discussions along the way with ACA will keep progress smooth.

Thursday’s meeting between the regulators and manufacturers raised no new concerns, Berry said.

He added: “We think we’re pretty close to reaching an agreement with them.”


Tagged categories: Protective coatings; SCAQMD Rule 1113; Shop-applied coatings; VOC content; VOC emissions

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