Automotive Coatings Rule Phases Out tBAc and PCBFT, Adds Regulatory Burdens
Rule 1151 – Motor Vehicle and Mobile Equipment Non-assembly Line Coating Operations aims to reduce volatile organic compound (VOC) emissions, toxic air contaminants, stratospheric ozone-depleting compounds and global-warming compound emissions from automotive coating applications performed on non-assembly line motor vehicles, mobile equipment and associated parts and components. The rule applies to “any person who supplies, sells, offers for sale, markets, manufactures, blends, packages, repackages, possesses or distributes any Automotive Coating, Automotive Coating Component or associated solvent for use within the District South Coast AQMD, as well as any person who uses, applies or solicits the use or application of any Automotive Coating or associated solvent within the South Coast AQMD.”
The South Coast Air Quality Management District (SCAQMD) has released a draft proposal that includes phasing out (eventually prohibiting) para-chlorobenzotrifluoride (pCBtF) and tert-butyl acetate (tBAc) and adds a host of recordkeeping, reporting and labeling requirements. The two solvents, currently exempt from the definition of a VOC, have been determined to have toxic endpoints. The district proposes to compensate by allowing a temporary increase in VOC limits, some as high as 840 grams/liter, “to allow time for manufacturers to reformulate automotive coatings to meet lower future effective VOC limits without pCBtF and t-Bac.”
The new recordkeeping and reporting requirements include:
- Material automotive coating and automotive coating component name and manufacturer;
- Application method, as recommended;
- Automotive coating category and mix ratio specific to the automotive coating;
- Actual VOC and regulatory VOC content of the automotive coating and automotive coating component;
- Documentation – such as manufacturer specification sheets, material safety data sheets, technical data sheets or any other air-quality data sheets – that indicate the material is intended for use as an automotive coating or solvent automotive coating component;
- Current manufacturer specification sheets, material safety data sheets, technical data sheets or air-quality data sheets that list the actual VOC and regulatory VOC content for each ready-to-spray automotive coating (based on the manufacturer’s stated mix ratio) and automotive coating components; and
- Purchase records identifying the automotive coating category and the total volume of all automotive coatings and solvents automotive coating components used.
The following must be included in the product label:
- Actual VOC and regulatory VOC content, as supplied (in grams of VOC per liter of material and in grams of VOC per liter of material, less water and exempt compounds)
- Date of manufacture or a code indicating the date of manufacture. The manufacturers shall file an explanation of each code with the District.
Additionally, manufacturers or private labelers will be obligated to submit “Quantity and Emission Reports (QER)” that must include information such as product manufacturer (as listed on the label), product name and code; actual VOC and regulatory VOC content, as well as whether the product is waterborne or solvent-based; and for any regulated product with VOC content higher than the applicable VOC content limits in paragraph (d)(1)of the rule, indicate whether the product has been sold under any of the following provisions: Sell-through provision, Exemption [pursuant to subdivision (k)] or Using Alternative Compliance options, among other items.
RadTech participated in the public workshops and, along several individual member companies, submitted formal written comments opposing the proposal. The Association argued that UV/EB/LED materials should not be subjected to the additional requirements for recordkeeping, while also requesting 1) that a definition for energy-curable materials be added to the rule, 2) an exemption from the transfer efficiency mandates and 3) that the test method for thin films (ASTM D7767-11) be recognized. Association representatives emphasized that UV/EB/LED materials not only meet, but far exceed, any proposed rule requirements. Any added flexibility to companies that choose these pollution-preventive processes will encourage voluntary emission reductions, thereby furthering the district’s mission. The rule is scheduled for adoption in November 2024.
