State of California
AIR RESOURCES BOARD
State Office Building
107 S. Broadway
Los Angeles, CA
June 29, 1977
77-14-2 Decision Regarding Establishment of Sulfur Dioxide
Ambient Air Quality Standard.
77-14-3 Continuation of Public Hearing Regarding Adoption of
Regulations for ARB Administrative and Hearing Procedures
(continued to July, 1977).
77-14-4 Consideration of Model Organic Solvent Regulations 1
Applicable to Architectural Coatings.
77-14-5 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals
ITEM NO.: 77-14-4
Consideration of Model Organic Solvent Regulation Applicable to
Approve model rule and direct staff to transmit it to the air
pollution control districts in the San Francisco Bay Area, South
Central Coast, South Coast, San Diego, Sacramento Valley, San
Joaquin Valley, and Southeast Desert Air Basins for consideration
as an amendment to their rules and regulations.
The development of a rule to reduce emissions from the
application of architectural coatings is the initial effort of
the Organic Solvent (ORGSOL) Regulation Study Group, hereafter
referred to as the Study Group. This group is comprised of
members from the ARB staff; Bay Area and San Diego County Air
Pollution Control Districts; and the South Coast Air Quality
In Section VII of the staff report the Study Group finds that in
many cases, appropriate substitutes for solvent-borne coatings
(oil-based paints) exist in the increasingly popular waterborne
coatings, which are more commonly known as "water-based paints"
or "latexes". Such waterborne coatings are generally
characterized by a low-organic solvent content as compared to the
high solvent content of organic solvent-borne coatings.
For many applications, waterborne coatings can be used in place
of coatings that generate high amounts of organic emissions.
With this in mind, the Study Group developed a proposed model
rule that will limit the total amount of organic solvents in
architectural coatings without in any way restricting the type of
coating operations which are now occurring in California. The
model rule is presented in Section II of the staff report. A
discussion of the Rule is contained in Section III.
Architectural coatings are produced by firms which are part of a
larger industrial group classified as paints and allied products
manufacturers (Standard Industrial Classification group 285).
Many of the characteristics of the larger group are also true of
the firms that produce architectural coatings.
The flow of raw materials and products through the architectural
coatings industry reflects its complexity and diversity. Basic
raw materials come primarily from fossil fuels, minerals, and
other natural products and are made into various intermediate raw
materials such as pigments, carriers (solvents), and additives.
Complex technology is used to produce many diverse coating
products that are marketed for a wide variety of consumers who
range from individual homeowners to professional contractors.
The industry demands materials from and supplies products to a
large number of other entities. Because of this diversity, the
industry is very difficult to define statistically.
Using data from the 1972 Census of Manufacturers some further
characteristics of the industry can be identified. In California
there were 217 establishments classified as paints and allied
coatings manufacturers who employ a total of 7,800 individuals.
Of these firms, only 90 have 20 or more employees.
The data base upon which an architectural coating rule could be
developed was nonexistent prior to the Study Group activities in
this area. Recognizing the need for such a data base the Study
Group met with representatives of the industry to develop a
questionnaire that would identify not only the quantities of
architectural coatings sold in California, but also the organic
compositions of the coatings and the availability of waterborne
substitutes. Copies of the questionnaire were mailed to paint
manufacturers in November 1976, with requests that they be
returned by December 31, 1976. The date for return was
subsequently extended to March 1, 1977.
In an effort to acquire additional information the Study Group
held two workshops in early March. In the letter requesting
comments at the workshop a tentative proposed rule and a list of
12 possible coating category exemptions were presented. The
letter is attached as Appendix A to the staff report. The
industry was requested to present technical information
supporting claims for exemption. Over 500 people attended the
workshop sessions. Most industry representatives that made
comments at the workshop did not present the technical
information requested and claimed that insufficient time had been
provided to prepare the information requested even though over
three months were provided for the manufacturers to respond to
relatively basic questions. In an effort to gather technical
data on coating performance, the Study Group met individually
with coating manufacturers subsequent to the workshops and prior
to drafting the proposed rule.
The technical justification for the proposed model rule is
presented in the attached report of the Study Group.
The total potential emissions reductions for each coating
category are discussed in Section VIII of the staff report. The
total statewide potential emissions reduction from the
application of architectural coatings is 75 tons per day. An
additional potential reduction of 69 tons per day can be achieved
from the reduced need for solvent usage for thinning and cleanup
which results from the use of water-borne coatings. The total
potential statewide emissions reductions are 143 tons per day.
Estimated reductions in emissions of organic solvents from the
application of the model rule to the recommended categories are
presented in Table VIII-2 of the staff report. Reductions in
emissions due to the elimination of solvent usage for thinning
and cleaning up of solvent-borne coatings are included in the
table. The estimated emissions reductions achieved by adoption
of the model rule are 29 percent of the total emissions from
architectural coatings. The largest reductions will occur as a
result of regulating exterior and interior wall coatings, 12.5
and 21.4 tons per day respectively. Estimated emission reduction
in the South Coast, San Francisco Bay Area and San Diego Air
Basins are 25, 12, and four tons per day respectively.
The costs involved in implementing the proposed model rule are
difficult to quantify. Some coating users may experience net
cost reductions as the result of application of the proposed
rule. Some coating manufacturers, however, face increased costs
due to changes required in the equipment used to manufacture the
coatings they produce. These costs are discussed in the attached
report. To avoid substantial increases in costs to users, the
rule contains exemptions in those areas where satisfactory
waterborne coatings are presently unavailable.
The effect of the proposed rule is generally expected to be a
cost savings for both manufacturers and users. The cost of
solvents will increase along with the cost of other petroleum
products as oil prices rise. The cost of coatings which require
less solvent will, therefore, tend to increase less. The Study
Group investigated the impact of the proposed regulation on air,
water, and energy and found no adverse effects.