South Coast Air Quality Management District (SCAQMD)

Regulator Responsibility and Scope:

SCAQMD is the air pollution control agency for all of Orange County and the urban portions of Los Angeles, Riverside and San Bernardino counties in California. These districts have experienced severe episodes of urban smog in the US over the past several decades. Consequently SCAQMD has developed the most comprehensive and strictest restrictions in the US on the content and emission of Volatile Organic Compounds (VOCs), a prime precursor to ground-level smog formation. Many states have adopted SCAQMD’s regulations into their State Implementation Plans which are submitted to and approved by the EPA to reduce air pollution. Manufacturers of paints, coatings, adhesives, printing inks, and many other products use solvents in their processes. Solvents are the largest single emitters of VOCs. Because the solvent-using manufactured products may be sold in in California where SQAMD has jurisdiction, or in states adopting SCAQMD rules, manufacturers often choose to universally adopt the SCAQMD limits on VOC content. Consequently, the SCAQMD VOC rules, and any proposed changes receive close scrutiny well beyond the Los Angeles basin.

VOC Content Rules:

SCAQMD is the most aggressive Air Quality Management District in establishing VOC content limits for products made or sold in its area, exceeding in most cases those set by the state regulator, CARB, and the federal regulator, the EPA. The entire list of VOC content limits for products can be accessed at this site. The prominent Rules are listed below:

Rule 1106  Marine and Pleasure Craft Coatings Operations This link is to the substantial amendments to this Rule proposed in August, 2015.

Rule 1122   Solvent Degreasers The last amendment in 2009 restricted the VOC content of solvents used in degreasing applications to no more than 25 grams of VOC per liter.

Rule 1171   Solvent Cleaning Operations The last amendment in 2009 maintained the VOC content limit of solvents used in many cleaning applications to no more than 25 grams of VOC per liter, however, certain applications are afforded a higher limit. Rule 1122 and Rule 1171 are cited as key rules to use in determining eligibility for a Clean Air Solvent Certificate (see below).

Rule 1143    Consumer Paint Thinners and Multi-Purpose Solvents The VOC Content limit was reduced from 300 g/l to 25 g/l in 2011.  This rule has been incorporated into rules established by CARB (but only for SCAQMD and not any of the other 34 AQMDs in California) to close a loophole which allowed products to avoid Rule 1143 by creative labelling.

Rule 1107   Coating of Metal Parts and Products This rule has been amended frequently but not since 2006. A Proposed Amendment was issued in 2012, proposing stricter rules to come into effect January 1, 2015 and further restrictions on January 1, 2018.

Rule 1113   Architectural Coatings Rule 1113 compliance means that a product confirms to the strictest regulatory standard in the US. Amended multiple times; this link includes the amendments to this Rule proposed in August, 2015. Note: If a manufacturer claims Rule 1113 compliance, it should be registered under SCAQMD Rule 314 and pay the appropriate fee. Amendments to Rule 314 were proposed in August, 2015.

Rule 1130   Graphic Arts Last updated in May, 2014, this rules limits the VOC content of several substances used in the printing industry.

Rule 1136    Wood Products Coatings Last updated in 1996, the last rule changes came into effect in 2005. Several tables of VOC content limits for different types of products.

Rule 1168   Adhesive and Sealant Applications Last amended in 2005. SCAQMD has convened a working group to propose stricter regulations to come into effect in 2015 through 2019.

VOC Content Calculations

SCAQMD publishes a guide to calculate the VOC content of materials containing several components.  They discuss two calculation methods:  by regulation and actual VOC.

Rules under Review:

SCAQMD publishes a list of the rules under development or review: Proposed Rules and Proposed Amended Rules.  Regulations that hve changes within the last 12 months are also listed under Rules Recently Adopted, Amended, or Repealed.

VOC Exemptions:

VOC-exempt status or developing a zero (0) VOC solvent is the ultimate goal for solvent manufacturers and users. VOC-exempt status is granted only to chemical compounds deemed to be negligibly reactive in forming ground-level ozone. In SCAQMD, approval and listing as VOC-exempt means that when the VOC content of a product is calculated, the VOC-exempt components are not included in the overall VOC calculation.  VOC-exempt compounds have fewer restrictions on their use. To be classed as VOC-exempt, a product must be listed on either of the lists of VOC-exempt materials maintained by the EPA or by SCAQMD under Rule 102. A product may be classified as “zero-VOC” (0 VOC) (not “VOC-exempt”) if all of its components are VOC-exempt materials, which means that the product is considered to contribute no VOC emissions.  However, SCAQMD maintains its own list of VOC-exempt solvents which may or may not correspond with that of the EPA VOC-exempt solvent list. SCAQMD distinguishes between products used as diluents and cleaners and materials used in manufacturing.  Diluent and cleaning applications are governed by Rules 1122 and 1171 as noted above.  Manufacturing applications are governed under Rule 102.  In SCAQMD, a product may be considered “zero-VOC”  (0 VOC) when used in diluent and cleaning applications, if  when tested under SCAQMD VOC Test 313-91 the VOC content is measured as 0 g/l.  Similarly, in manufacturing applications governed under Rule 102, a product us determined to be “zero-VOC” (0 VOC) if the material measured using Test Method 313-91 (see below) shows zero VOC’s in the tested material. TBF’s ZemaSol™ is measured as 1.59 g/l VOC content for use in manufacturing under Rule 102, using Test Method 313-91. A product which is a blend of chemical compounds cannot be classified as VOC-exempt under SCAQMD or the EPA.  A blend of compounds, each of which is VOC-exempt, does not make the blend VOC-exempt, however, a blend may be considered zero VOC (0 VOC). In either case a VOC-exempt or zero VOC (0 VOC) material will not contribute any VOC’s to the manufactured product, cleaning process or when used as a diluent.

Clean Air Solvent Certificate:

However, there is another category under Rule 102 under which products may be certified as “Clean Air Solvents” even if they are not VOC-exempt. A Clean Air Solvent is defined under Rule 102: “CLEAN AIR SOLVENT is a VOC-containing material used to perform solvent cleaning, solvent finishing, or surface preparation operations or activities which:

(A) Contains no more than twenty-five (25) grams of VOC per liter of material, as applied; (B) Has a VOC composite partial vapor pressure less than 5 mm Hg at 20 oC (68 oF); (C) Reacts to form ozone at a rate not exceeding that of toluene; (D) Contains no compounds classified as Hazardous Air Pollutants (HAPs) by the Federal Clean Air Act, or Ozone Depleting Compounds (ODCs) and Global Warming Compounds (GWCs) as defined by the District; and (E) Has been certified by the District to meet the criteria stated in (A) through (D) according to test methods and procedures approved by the District.”

Upon application, SCAQMD will issue a Clean Air Solvent Certificate to confirm that a product meets the minimum requirements for VOC emissions under SCAQMD Rule 102. As noted above, satisfying Rules 1122 and 1171 which require VOC contents not exceeding 25 gm/liter is key. Note:  ZemaSol™ (pat. pending), developed by TBF Environmental Technology, is the first solvent not based on water or biomass to be Certified as a Clean Air Solvent by SCAQMD in over 20 years. TBF developed ZemaSol to replace Xylene, Toluene, ParaChloroBenzoTriFluoride (PCBTF or Oxsol) and Tertiary Butyl Acetate (TBAc).

Compliance Test Methods:

SCAQMD specifies three tests that may be used to confirm the VOC content of products:

EPA Reference Method 24 (Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids of Surface Coatings, Code of Federal Regulations Title 40, Part 60, Appendix A).

SCAQMD Method 304 [Determination of Volatile Organic Compounds (VOCs) in Various Materials] contained in the SCAQMD “Laboratory Methods of Analysis for Enforcement Samples” manual.

The VOC content of materials containing 50 g/l of VOC or less shall be determined by the most recent version of SCAQMD Method 313-91 (Determination of Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry) or any other alternative test methods approved by the USEPA, CARB, and the District.

EPA Method 24 is recognized everywhere and is the test used most frequently