VOC Rulemaking Targets 12 Industry Sectors
The South Coast Air Quality Management District (SCAQMD) unveiled plans to pass new rules for 12 industry sectors. According to staff, the rule amendments seek to ban para-ChloroBenzotriFluoride (pCBtF) and tertiary-Butyl Acetate (tBAc), as well as lower VOC emissions “where feasible.” Past rule amendments with similar goals led to an overhaul of the regulatory language, standards and administrative procedures. In a public meeting, agency staff talked about the concept of rule “bundles,” where two or more rules would be taken to the Governing Board for approval simultaneously. This deviates from the traditional model of rulemaking.
The regulators propose to amend the following rules:
- Rule 1106 – Marine and Pleasure Craft Coatings
- Rule 1113 – Architectural Coatings
- Rule 1122 – Solvent Degreasers
- Rule 1125 – Metal Container, Closure and Coil Coating Operations
- Rule 1126 – Magnet Wire Coating Operations
- Rule 1128 – Paper, Fabric and Film Coating Operations
- Rule 1130 – Graphic Arts
- Rule 1130.1 – Screen Printing Operations
- Rule 1143 – Consumer Paint Thinners & Multi-Purpose Solvents
- Rule 1144 – Metalworking Fluids and Direct-Contact Lubricants
- Rule 1145 – Plastic, Rubber, Leather and Glass Coatings
- Rule 1162 – Polyester Resin Operations
The first proposed rule bundle will include Rule 1107, Rule 1124 and Rule 1136. A future second package would target Rule 1130 (Graphic Arts) and Rule 1130.1 (Screenprinting). RadTech participated in the public working group meeting and raised concerns regarding the list of rules involved that would make meaningful industry participation extremely challenging. The proposal generated opposition from other industry groups, such as PRINTING United Alliance and the American Coatings Association.
Staff acknowledged that phasing out of t-BAc and pCBtF presents challenges for reducing VOC emissions, as many coatings rely on the use of these compounds to comply with existing mass-based VOC limits. Staff is considering incorporating maximum incremental reactivity-based (MIR) VOC standards. MIR is a measure of the photochemical reactivity of a VOC, which estimates the weight of ozone produced from a weight of VOC. Staff is conducting surveys to “help staff gain a clearer picture” of VOC content, pCBtF and t-BAC ranges and percent waterborne/solvent-based for each category, as well as the share of the market that contains pCBtF and/or t-BAC.
RadTech submitted comments urging regulatory flexibility for UV/EB/LED processes as these materials typically are well below 50 grams/liter in VOC content and are not formulated with t-BAC or pCBtF. The association requested that the district include ASTM D7767-11 (RadTech-endorsed test method) in the rule. Currently, the “Multiple Test Methods” in most district rules does not specify a method for energy-curable materials, which could result in enforcement problems for RadTech members and their customers. “Since the impetus of the labeling requirements is to ensure that coatings are free of pCBtF or tBAc, we urge the district to spare UV/EB/LED materials of these requirements,” stated the RadTech public comment letter.
Hexavalent Chrome Phase-Out
SCAQMD proposes changes to its Rule 1469 – Hexavalent Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing Operations that would ban Hexavalent Chrome. According to the staff report, the amendments are needed to implement the Air Toxics Control Measure (ATCM) issued by the California Air Resources Board (CARB) in 2023 which call for the phase out of the use of hexavalent chromium for decorative chrome plating by January 1, 2030, and the phase out of the use of hexavalent chromium for functional chrome by January 1, 2039. The Chrome ATCM also prohibits new hexavalent chrome plating and chromic acid anodizing facilities that would be subject to Rule 1469, includes more stringent requirements for existing facilities that undergo a modification, and more stringent requirements beginning January 1, 2026, for functional chrome operations.
RadTech submitted written comments indicating that UV/EB/LED materials do not contain chrome and can be used in some operations as potential replacements for conventional materials. The association urged the district to provide incentives to companies that choose to reformulate their process and eliminate emissions of Hexavalent Chrome. During the consultation meeting, staff clarified that a UV/EB/LED chrome-free coating process at a facility performing Electroplating or Anodizing would not be subject to the rule, as said process would fall under one of the district’s coatings rules. Clarification of the rule was requested to ensure there is no confusion about the rule’s applicability.
Rita Loof
director of regional environmental affairs, RadTech International North America
rita@radtech.org
