On September 26, 2013, the California Air Resources Board (CARB) unanimously adopted significant amendments to the Regulation for Reducing the Ozone Formed From Aerosol Coatings & the Tables of Maximum Incremental Reactivity Values (hereinafter the Aerosol Coatings Regulation & Table of MIR Values).1 The amendments include significantly reduced reactivity standards, a graduated schedule of effective dates, the addition of several new categories, refined definitions for categories and other important terms, new rules for the assignment of MIR Values, and more refined test methods and compliance verification strategies. The final rule, as adopted, will provide many challenges for formulators and manufacturers. A thorough review of the rule is essential in order to develop reliable compliance strategies. The Table of Reactivity Standards Although the rule begins with an applicability section and a long list of definitions, the Table of Reactivity Limits will grab your attention immediately. The changes are very obvious. Instead of two sections in the Table, there are now three, including the General Coatings, Specialty Coatings A and Specialty Coatings B. This new format is due to several considerations. First, the list of General Categories is absolutely essential. Unlike other air quality regulations, the CARB Aerosol Coatings Regulations applies to all aerosol coatings, even if there if the coating in question does not meet a Specialty definition. In this situation, where an aerosol coating does not meet any of the Specialty Coating definitions, it defaults to one of the General categories and 16 Spray January 2014 must meet the limit for the General Category. Therefore, it was essential to preserve the General Categories and the list of General Categories was not changed in these amendments. Second, the Specialty Coatings A Categories contains 10 categories of aerosol coatings that are either new categories included in the rule, or they are existing categories of fairly high volume, or they are categories that survey data indicated could be addressed. According to CARB, these combined 16 categories, the General Categories and Special Coatings A, represent over 90% of the aerosol coatings products emissions in the state of California. The survey data clearly supports conclusion, at least for the General Categories. According to the CARB 2010 Survey, the Non Flat category is the largest at 1,053 products reported. There are 225 products reported in the Flat category; 251 products reported in the Clear category and 226 reported in the Primer category. The last section in the Table of Reactivity Standards is Specialty Coatings B, which include all the remaining specialty categories in the rule with the addition of one new category. The Specialty Coatings B categories include those categories with fairly low sales volume and consequently, very little opportunities for gaining emission reductions. Consequently, CARB came to the conclusion that the best strategy for these categories was to evaluate the current technology reflected in the survey data and propose a new limit equal to the highest reported product-weighted maximum incremental reactivity limits (PWMIR). In this fashion, CARB established a “cap” on the reactivity limit for these specialty categories. Effective Dates of the New Standards In addition to the reactivity limits in the Table of Standards, note also the effective date for each of the sections. The newly adopted standards for both the General Categories 1 There was one abstention: Board member Sandy Berg abstained from this discussion and vote due to a conflict of interest. Ms. Berg is the owner of Ellis Paint Company in Los Angeles, California. By Heidi McAuliffe, Esq., Senior Counsel, Government Affairs, American Coatings Association (ACA) California significantly revises Aerosol Coatings Standards
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