Amendments to Rule 442, Architectural Coatings Kevin J. Williams, Ph.D. Sacramento Metropolitan Air...
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Transcript of Amendments to Rule 442, Architectural Coatings Kevin J. Williams, Ph.D. Sacramento Metropolitan Air...
Amendments toRule 442, Architectural
Coatings
Kevin J. Williams, Ph.D.Sacramento Metropolitan
Air Quality Management District
October 12, 2015
Overview• Health effects of ozone• What are architectural coatings?• Why did we amend the rule?• How did CARB develop the SCM?• Rule development process• Who does Rule 442 affect?• Summary of changes• Emission reductions• Costs• Rule implementation• RCMA comments
Health Effects of Ozone
• Sacramento has the 5th worst ozone air quality in U.S. (2015 State of the Air: Amer. Lung Assoc.)
• Sacramento is a severe ozone nonattainment area for the federal standards
• VOCs and NOx react in sunlight to form ground level ozone
• Ozone health effects− Decreased lung function− Development and aggravation of asthma− Increased risk of cardiovascular problems− Increased hospitalizations and emergency room visits− Premature deaths
What are Architectural Coatings?• Paints, primers, sealers, stains, roof coatings, concrete
curing compounds, clear wood finishes, etc. for:
Does not include coatings applied in manufacturing or refinishing shops
Why did we amend the rule?• Reductions in VOC emissions are needed to help achieve
state and federal ozone standards− Architectural Coatings are the 5th largest VOC emission
source in Sacramento County
• CARB’s Suggested Control Measure (SCM) will produce substantial emission reductions− Lower VOC limits are feasible because of advances in
coating technology− Compliant products are already available on the market
• Adopting the SCM makes the rule consistent with other major districts across the state− Aids compliance by manufactures, distributors, and
retailers
How did CARB develop the SCM?• Originally developed in 1977 – updated in 1985, 1989, 2000,
and 2007
• CARB conducts survey of architectural coatings sold in California (last in 2005, another in progress)
• For 2007 update, CARB considered:− Recent amendments to South Coast AQMD Rule 1113,
Architectural Coatings− 2005 survey of architectural coatings sold in California – identified
compliant products that meet proposed VOC limits− Technology assessment for all coating categories− Economic and environmental impacts
• CARB met with stakeholders:− Meetings with air quality districts, EPA, industry trade groups, and
manufacturers− Three public workshops
Rule Development Process
• Evaluated SCM requirements− Determined need for any deviations
• Developed draft rule and analysis document
• July 7, 2015 – published draft materials for public comment
• August 5, 2015 – held public workshop
• Considered public comments and made appropriate changes
• August 25, 2015 – published final proposal, announced public hearing
• September 24, 2015 – Board adopted the rule
Who does Rule 442 affect?• Do-it-yourself consumers • Construction trades people including:
- Painting contractors − Cabinet refinishers
- Flooring contractors − Swimming poolpainters
-Concrete workers − Roofers-Roadway striping − Deck and fencing
companies installers- Industrial and commercial maintenance
operations
• Coating manufacturers, distributors and retailers
Summary of Changes
• Rule Applicability− Added blenders and repackagers of architectural
coatings for use within the District (Section 102.2)
• Exemptions− Small container exemption (≤ 1 liter) will explicitly
exclude containers bundled or intended to be used in combined volumes > 1 liter (Section 110.3)
• Revised VOC limits (Section 301)− Added and eliminated several specialty coating
categories− Reduced VOC limits for many coating categories
(summarized later in the presentation)− Effective date is March 24, 2016.
Summary of Changes
• 3-year sell-through for coatings that meet the 2001 VOC limits− Coatings manufactured before March 24, 2016 can be
sold, supplied, or offered for sale until March 24, 2019.− Coatings manufactured before March 24, 2016 may be
used indefinitely if they were purchased prior to that date− Coating container must be labeled with manufactured date
(Section 303)
• Early Compliance Provision− Allows early compliance with the amended rule if a coating
meets all provisions of the rule that are effective on March 24, 2016 (Section 309)
continued
Summary of Changes
• Administrative Requirements− For multi-component products, the VOC content
must be displayed as mixed or catalyzed (Section 401.3)
− Labeling requirements added for new or revised coating categories (Sections 401.10 – 401.14)
− Manufacturers must provide sales data to ARB upon request (Section 501.1)
continued
Summary of Changes
• Eliminated Specialty Coating CategoriesAntenna AntifoulingClear Brushing Lacquer Fire RetardantFlow LacquerQuick Dry Enamel Sanding SealerQuick Dry Primer/Sealer/Undercoater VarnishSwimming Pool Repair/Maintenance Temperature-Indicator SafetyWaterproofing Concrete/Masonry Sealer Waterproofing Sealer
• New Specialty Coating CategoriesAluminum Roof Basement Specialty
Concrete/Masonry Sealers Driveway Sealers
Reactive Penetrating Sealers Stone Consolidants
Tub and Tile Refinish Waterproofing Membranes
Wood Coatings Zinc-Rich Primers
continued
Coating Category (* Indicates new category)
VOC Regulatory Limit (grams/liter)Current Effective
3/24/16
Flat 100 50
Nonflat 150 100
Nonflat – High Gloss 250 150
Aluminum Roof * 500 400
Bituminous Roof (Bituminous Primer Unchanged at 350 g/l) 300 50
Mastic Texture 300 100
Primers, Sealers, Undercoaters (PSU) 200 100
Roof (Other than Bituminous) 250 50
Rust Preventative 400 250
Waterproofing Membranes * 250 or 400 250
Wood Coatings * 350, 550, or 680 275
Changes to VOC Limits(common categories)
Emission Reductions• Architectural Coatings are 5th largest VOC source in
Sacramento County• Lower VOC limits reduce emissions by 1.4 tons per day
Reduction
Costs• In 2007, CARB estimated a cost increase of
$1.38 per gallon, on average, if manufacturers passed costs on to consumers
• Manufacturers’ costs for reformulation already incurred− Compliant products are available now
• Overall rule cost effectiveness: $1.28 per pound of VOC reduced− Previously adopted District rules have ranged
from $1 to $21 per pound reduced
Rule Implementation• September 24, 2015 – March 23, 2016:
Early Compliance provision is in effect• March 24, 2016: New rule requirements
take effect− Rule will be republished without
expired provisions• March 24, 2019: 3-year sell-through
period ends
RCMA Comments• Definition of Roof Coatings• Tertiary Butyl Acetate (TBAC)
exemption status
Coating Category (* Indicates new category)
VOC Regulatory Limit (grams/liter)Current Effective 3/24/16
Flat 100 50
Nonflat 150 100
Nonflat – High Gloss 250 150
Aluminum Roof * 500 400
Basement Specialty * 250 or 400 400
Bituminous Roof (Bitum. Primer Unchanged at 350 g/l)
300 50
Concrete/Masonry Sealers * 250 or 400 100
Driveway Sealers * Flat, Non-flat, or High Gloss 50
Dry Fog 400 150
Floor 250 100
Mastic Texture 300 100
Primers, Sealers, Undercoaters (PSU) 200 100
Reactive Penetrating Sealers * 250 or 400 350
Roof (Other than Bituminous) 250 50
Rust Preventative 400 250
Specialty PSU 350 100
Stone Consolidants * 250 or 400 450
Traffic Marking 150 100
Tub and Tile Refinish * Flat, Non-flat, or High Gloss 420
Waterproofing Membranes * 250 or 400 250
Wood Coatings * 350, 550, or 680 275
Zinc-Rich Primers * 500 340