CA Product Survey May Bring VOC Cuts


California has announced its largest product survey initiative ever—a multiyear paint- and coating-focused data collection that could presage new reductions in VOC emissions.

That is the word from U.S. coating makers, who have raised concerns about the plan to gather sales and formulation data on architectural and industrial maintenance (AIM) coatings, consumer and commercial products, and aerosol coatings sold in or supplied to California.

According to the American Coatings Association, the impending initiative by the California Air Resources Board (CARB) "will require manufacturers’ and suppliers’ participation in a multi-year data collection, whereby sales and product ingredient data, including information on volatile organic compound (VOC) content, will be required."

CARB will use the survey results to "update the state's inventory of emissions of VOCs and low-vapor-pressure VOCs (LVP-VOCs), after which it will determine the feasibility of further reducing VOC emissions," according to ACA.

CARB says the data are needed "to establish the scientific basis for the clean air plans and related rulemaking to address the stricter national standards for ozone and fine particulates,” according to ACA.

No information about the survey could be immediately located on CARB's website, and a request for more information was not immediately returned.

California's coatings regulations are closely watched nationwide and frequently serve as a bellwether for changes elsewhere around the country.

The Plan

The survey encompasses seven categories:

  1. Adhesives, sealants and related products;
  2. Household and institutional products; 
  3. Personal care products; 
  4. Pesticide products; 
  5. Solvents and thinning-related products; 
  6. Vehicle and marine vessel aftermarket products; and
  7. Aerosol coating products.

Companies will have until March 1, 2015, to submit sales and detailed formulation data for products used by households or institutional consumers sold in or supplied to California during 2013, according to ACA. Sales data also must be reported in 2014 and 2015, "but only for formulations with VOC contents that have a weight change greater than 0.5 percent."

CARB will allow grouping of similar products for reporting "as long as the variation in VOC composition is less than 0.5 percent by weight and variance of non-VOC ingredients is less than 1 percent," ACA says. Different sizes of products with the same formula may also be grouped, as can some products with different colors or botanical extracts.

ACA's Concerns

ACA says it and other industries "raised several concerns" about the survey at a Aug. 27 stakeholder meeting hosted by CARB.

CARB Survey Aerosols
Custom Pak

Aerosol coating products are just one of seven products for which CARB will require sales and product data in its new survey.

ACA said the March 1, 2015, deadline would be difficult for the many companies that must complete all three surveys: AIM, Consumer Products, and Aerosol Coatings. The groups also noted that several other major regulatory reporting requirements will come due about the same time.

Those include a June 1, 2015, deadline for labeling changes to comply with the Occupational Safety and Health Administration's (OSHA) adoption of the Globally Harmonized System of Classification and Labelling of Chemicals.

ACA said it had "also opposed the proposed survey requirement to submit all product labels, since product labels are constantly changing."

"Given the GHS relabeling effort, ACA maintained that the CARB reporting requirements are too burdensome for very little benefit."

CARB contends that the data are necessary and, for now, the plan stands, according to ACA.


ACA said that due to its efforts, companies supplying and selling aerosol coatings and aerosol adhesive products need to report sales data only for 2013. "ACA was successful in convincing CARB to delay further survey for this category of products until 2017," the group said.

The aerosol coatings and consumer and commercial products survey is scheduled to be released on Sept.1, 2015, and manufacturers of aerosol coatings and consumer and commercial products will be able to start uploading data on Jan. 1, 2015, according to ACA.

LA Skyline
Massimo Catarinella / Wikimedia Commons

As CARB surveys coatings statewide, California’s South Coast Air Quality Management District has been weighing tougher regulations on coatings in its jurisdiction.

All 2013 data are due to CARB by March 1, 2015. All 2014 consumer products data are due Nov. 1, 2015, and all 2015 data are due Nov. 1, 2016.

According to ACA, details of the AIM coatings survey are still being worked out, but the tentative survey release date is Oct. 15, 2014.

Contact ACA’s  Heidi McAuliffe for more information related to aerosol coatings, and consumer and commercial products.

Contact ACA’s David Darling or Tim Serie for more information related to AIM coatings.

Other Action

CARB is not the only California agency taking a new look at coating VOC emissions. In April, ACA warned that the nation’s toughest VOC rules on field-applied paints and coatings could be changing again soon.

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 coatings, ACA reported.

The revisions would be the rule's 28th since it was introduced in 1977, ACA says.


Tagged categories: Aerosol coatings; Air quality; American Coatings Association (ACA); California Air Resources Board; Coatings Technology; North America; SCAQMD Rule 1113; Solvents; VOC emissions

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