Amendments to Rule 442, Architectural Coatings

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

8. 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

9. 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

10. 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.

11. 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)

12. 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)

13. 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

14. Changes to VOC Limits (common categories)

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

16. 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

17. 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

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