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U.S. efforts underway to regulate AIM VOC.

Efforts to regulate volatile organic compound (VOC) emissions from Architectural and Industrial Maintenance (AIM) coatings are expected to continue unabated for the foreseeable future at the state, regional, and now federal levels. California, including the South Coast Air Quality Management District (SCAQMD), as well as the other major California air districts; the Ozone Transport Commission; (OTC); the Lake Michigan Air Directors Consortium (LADCO); and the U.S. Environmental Protection Agency (EPA) are all either developing or actively considering revising AIM regulations.

The following provides an update on current AIM VOC activity throughout the United States.


Most importantly, on June 6, 2008, SCAQMD adopted an AIM coatings fee regulation--Rule 314--which imposes a fee to cover the cost of the current and future "enhanced" AIM enforcement program. The fee is bifurcated: approximately $0.04 per gallon and $246 per ton of VOC emissions. However, the American Coatings Association convinced SCAQMD to phase-in the fee over a period of three years. As of April 1, 2010, coatings manufacturers were required to report 2009 sales of AIM products in SCAQMD and pay a fee on those reported sales.

On March 6, 2009, SCAQMD adopted Rule 1143-Consumer Paint Thinners and Multi-Purpose Solvents--which limits the level of volatile organic compounds in paint thinners and multipurpose solvents sold in the Los Angeles area. This includes paint thinning and paint application equipment cleaning solvents that are sold at hardware stores, home improvement centers, and paint supply stores that are used by consumers, contractors, and surface coating operations. A lawsuit was filed against SCAQMD in December 2009 and the Court ruled that the district violated the California Environmental Quality Act when it adopted Rule 1143. It appears that settlement negotiations have been unsuccessful, and the manufacturer has asked the court to vacate the rule. Should this happen, the CARB Paint Thinner rule would apply, instead.

South Coast is in the process of developing an amendment to their AIM rule 1113. It is expected that these amendments will be proposed in late 2010 and could include lower limits for several AIM categories and the regulation of the VOC content of colorants.


On October 25, 2007, the California Air Resources Board (CARB) approved the AIM Coatings Suggested Control Measure (SCM) which will serve as a model AIM VOC limits rule for the individual California air districts. The SCM includes a number of stringent limits based on current SCAQMD limits. Although considering use of SCAQMD limits as a starting point, CARB adopted less stringent limits and allowed additional time for aluminum roof coatings, industrial maintenance coatings, non-flat coatings, non-flat high-gloss coatings, rust preventative coatings, specialty primers, and exterior stains. Over the next two years, the various California air districts will adopt the 2007 CARB AIM SCM limits. So far, Bay Area, San Joaquin, Ventura, Kern, and imperial air districts have adopted the 2007 SCM. Similar to SCAQMD, CARB adopted its Paint Thinner and Multi-Purpose Solvent rulemaking on September 24, 2009. As with SCAQMD Rule 1143, this regulation would restrict the paint thinning and paint application equipment cleaning solvents that are sold at hardware stores, home improvement centers, and paint supply stores that are used by consumers, contractors, and surface coating operations.



The Ozone Transport Commission (OTC) is comprised of the northeastern states from Maine to Virginia and it is in the process of developing the "Phase II" OTC Model rule which will be based on the 2007 CARB AIM SCM limits. The more stringent AIM VOC limits will possibly take effect sometime in 2013; a model rule is expected Spring 2010. ACA recently provided suggested regulatory language to OTC and it appears that the OTC is receptive to adopting much of this language.


Lake Michigan Air Directors Consortium (LADCO), made up of clean air agency representatives from Michigan, Illinois, Indiana, Wisconsin, and Ohio, is tasked with developing coordinated regional clean air strategies and programs. Several LADCO states are currently revising their AIM rules based on the current OTC Model rule. Ohio and Illinois have adopted revisions to their AIM rules; Indiana is in the final stages of adopting their AIM rule.


The U.S. Environmental Protection Agency (EPA) is revising the National AIM coatings VOC rule that will be based on the OTC Phase I model rule. While EPA has been working on this rulemaking for nearly three years, a proposed rule is not expected until late 2010 and a final rule in 2011. ACA will work with the U.S. EPA to ensure that the revisions are technically sound and fair.

Contact ACA's David Darling ( or Alison Keane ( for more information.
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Title Annotation:ACA Issues In-Depth
Publication:JCT CoatingsTech
Date:May 1, 2010
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