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Amendments to Rule 442, Architectural Coatings

Amendments to Rule 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?

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Amendments to Rule 442, Architectural Coatings

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  1. Amendments toRule 442, Architectural Coatings Kevin J. Williams, Ph.D. Sacramento Metropolitan Air Quality Management District October 12, 2015

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. Who does Rule 442 affect? • Do-it-yourself consumers • Construction trades people including: • Painting contractors − Cabinet refinishers • Flooring contractors − Swimming pool painters • Concrete workers − Roofers • Roadway striping − Deck and fencing companies installers • Industrial and commercial maintenance operations • Coating manufacturers, distributors and retailers

  9. 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.

  10. Summary of Changes continued • 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)

  11. Summary of Changes continued • 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)

  12. Summary of Changes continued • 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 Categories Aluminum Roof Basement Specialty Concrete/Masonry Sealers Driveway Sealers Reactive Penetrating Sealers Stone Consolidants Tub and Tile Refinish Waterproofing Membranes Wood Coatings Zinc-Rich Primers

  13. Changes to VOC Limits (common categories)

  14. Emission Reductions • Architectural Coatings are 5th largest VOC source in Sacramento County • Lower VOC limits reduce emissions by 1.4 tons per day Reduction

  15. 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

  16. 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

  17. RCMA Comments • Definition of Roof Coatings • Tertiary Butyl Acetate (TBAC) exemption status

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