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? Rule development process Who does Rule 442 affect? Summary of changes Emission reductions Costs Rule implementation RCMA comments

Health Effects of Ozone Sacramento has the 5 th 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

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

Why did we amend the rule? Reductions in VOC emissions are needed to help achieve state and federal ozone standards −Architectural Coatings are the 5 th 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

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

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

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

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.

Summary of Changes 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, −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) continued

Summary of Changes 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 – ) −Manufacturers must provide sales data to ARB upon request (Section 501.1) continued

Summary of Changes Eliminated Specialty Coating Categories AntennaAntifouling Clear Brushing Lacquer Fire Retardant FlowLacquer Quick Dry EnamelSanding Sealer Quick Dry Primer/Sealer/Undercoater Varnish Swimming Pool Repair/Maintenance Temperature-Indicator Safety Waterproofing Concrete/Masonry Sealer Waterproofing Sealer New Specialty Coating Categories Aluminum RoofBasement Specialty Concrete/Masonry SealersDriveway Sealers Reactive Penetrating SealersStone Consolidants Tub and Tile RefinishWaterproofing Membranes Wood CoatingsZinc-Rich Primers continued

Coating Category (* Indicates new category) VOC Regulatory Limit (grams/liter) CurrentEffective 3/24/16 Flat Nonflat Nonflat – High Gloss Aluminum Roof * Bituminous Roof (Bituminous Primer Unchanged at 350 g/l) Mastic Texture Primers, Sealers, Undercoaters (PSU) Roof (Other than Bituminous) Rust Preventative Waterproofing Membranes * 250 or Wood Coatings * 350, 550, or Changes to VOC Limits (common categories)

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

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

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

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

Coating Category (* Indicates new category) VOC Regulatory Limit (grams/liter) CurrentEffective 3/24/16 Flat Nonflat Nonflat – High Gloss Aluminum Roof * Basement Specialty * 250 or Bituminous Roof (Bitum. Primer Unchanged at 350 g/l) Concrete/Masonry Sealers * 250 or Driveway Sealers * Flat, Non-flat, or High Gloss 50 Dry Fog Floor Mastic Texture Primers, Sealers, Undercoaters (PSU) Reactive Penetrating Sealers * 250 or Roof (Other than Bituminous) Rust Preventative Specialty PSU Stone Consolidants * 250 or Traffic Marking Tub and Tile Refinish * Flat, Non-flat, or High Gloss 420 Waterproofing Membranes * 250 or Wood Coatings * 350, 550, or Zinc-Rich Primers *