Architectural coatings are products that are applied to stationary structures and their accessories. They include house paints, stains, industrial maintenance coatings, traffic coatings, and many other products.
When these coatings are applied, volatile organic compounds (VOCs) are emitted from the coatings and from the solvents that are used for thinning the coatings and cleaning up application equipment.
Control of VOC emissions from architectural coatings is primarily the responsibility of the air districts. CARB serves as an oversight agency and provides assistance to the districts, such as developing a Suggested Control Measure (SCM) for architectural coatings. The SCM serves as a model rule that can be adopted by districts throughout California. CARB approved an SCM for architectural coatings in 1977 and updated it in 1985, 1989, 2000, 2007, and 2019. While CARB provides support to the districts by developing the SCM, the districts are ultimately responsible for adopting, implementing, and enforcing architectural coating rules in California.
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Section 39612 of the Health and Safety Code authorizes CARB to impose additional fees on nonvehicular sources (facilities) that emit 250 tons or more per year of any nonattainment pollutant or its precursors. Section 39613 authorizes fees for emissions from consumer products and architectural coatings sold in the state if a manufacturer's total sales will result in emissions of 250 tons or more per year of volatile organic compounds. These fees are used by the ARB to mitigate or reduce air pollution created by nonvehicular sources in the state.
The state of California is subdivided into 58 counties, 14 air basins, and 35 local districts. Currently, 22 of the 35 air districts have architectural coating rules; one is based on the SCM approved by the Board in 2019, 14 are based on the 2007 SCM, and six are based on the 2000 SCM. South Coast AQMD is covered by Rule 1113, which is more stringent than the 2019 SCM. The remaining 13 districts are covered by the United States Environmental Protection Agency (U.S. EPA) Architectural Coatings: National Volatile Organic Compounds Emission Standards (National Rule).
The rules in each district are dynamic and subject to change. CARB recommends that the air district be contacted if specific information is wanted on a particular rule. To be notified if rules in a particular air district are amended, ask to be placed on the district's mailing list. Although CARB promotes and encourages uniformity among rules in each district, due to the unique air pollution problems in each district, rules may be tailored to meet these conditions for each district. Hence, adjacent districts may have different rules.
To ensure compliance with district regulations, businesses who perform coating activities or provide coatings for use in one or more areas of California should contact the local district in each area that a facility is located or the coating will be used. The district(s) can help identify any requirements that may exist. The regulations/rules that have been adopted in each district apply only to the geographic boundaries of the district.
Annual Reporting Requirements for Architectural Coatings Manufacturers
Many local air pollution control districts in California amended their existing architectural coatings rules or adopted new rules based on CARB's 2000 Suggested Control Measure (SCM). These rules required an annual report from manufacturers of certain categories of coatings and an annual report of coatings that included perchloroethylene or methylene chloride.
After consultation with the local air districts, on March 2011, CARB staff decided to no longer require submission of this annual architectural coatings reporting. Accordingly, the last reporting year was 2009 data submitted in 2010
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