AQ-2024-002-RULE 335-REPORT TO THE BOARD OF SUPERVISORS.PDF
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Executive Summary of the Report to the Board of Supervisors
Prepared by Maricopa County Air Quality Department
Board Hearing Date:
December 11, 2024
Case Number/Title:
AQ-2024-002-Rule 335 (Architectural Coatings)
Agenda Item:
(Pending)
Supervisor Districts:
All Districts
The Maricopa County Air Quality Department (MCAQD) complied with all statutory and county
policies throughout this rulemaking process. Per the Enhanced Regulatory Outreach Program
(EROP) Policy: “In addition to the required staff report, an executive summary of the report
including an overview of stakeholder input and staff responses will be provided to the Board
of Supervisors at least one week prior to any Board of Supervisors’ public hearing.”
Overview of the Report to the Board of Supervisors:
On November 7, 2022, the U.S. Environmental Protection Agency (EPA) reclassified portions
of Maricopa County from “marginal” to “moderate” nonattainment with respect to the 2015
National Ambient Air Quality Standard (NAAQS) for ozone. Sections 172(c) and 182(b) of the
Clean Air Act (CAA) require jurisdictions that are classified as moderate or higher
nonattainment to submit a state implementation plan (SIP) revision to provide for volatile
organic compound (VOC) emission reductions to attain the ozone NAAQS by the applicable
attainment date. The SIP revision must include provisions addressing reasonable further
progress, an attainment demonstration, and contingency measures amongst other provisions.
MCAQD identified the manufacture and application of architectural coatings as processes
where potential emission reductions of VOCs could be achieved to assist towards attainment
of the ozone NAAQS. Architectural coatings are coatings applied to stationary structures or
their appurtenances at the site of installation, to portable buildings at the site of installation,
to pavements, or to curbs. During the architectural coating application and manufacturing
processes, VOCs are emitted which contribute to ground-level ozone formation.
MCAQD is proposing to revise Rule 335 (Architectural Coatings) to lower many of the VOC
content limitations in the rule and to add additional coating VOC content limitations to the rule
Page 2 of 2
to reflect standards in the Ozone Transport Commission Model Rule “Architectural and
Industrial Maintenance (AIM) Coatings”.
In addition, MCAQD is proposing to update the rule as it has not undergone a significant
revision since its adoption in 1988. Proposed revisions include clarifying the applicability of
the rule and restructuring the rule to ensure consistency within the Maricopa County Air
Pollution Control Regulations.
Revised Rule 335 will be considered a contingency measure for achieving the 2015 NAAQS for
ozone as required by Section 172(c)(9) of the CAA. As such, the revised rule will become
effective upon a determination by the EPA that either the Phoenix-Mesa nonattainment area
failed to attain the 2015 ozone NAAQS by the attainment date or failed to make reasonable
further progress.
Overview of Stakeholder Input and Staff Responses:
MCAQD has received written feedback from two (2) stakeholders. The stakeholders did not
express support nor opposition to the rulemaking. MCAQD evaluated the comments and
drafted responses. The stakeholders’ comments and the MCAQD’s responses are included
under Section 9 of the attached Draft Notice of Final Rulemaking. Copies of the
stakeholders’ written feedback and comments are attached to this report.
Maricopa County
Air Quality Department
Planning and Analysis Division
Report to the
Board of
Supervisors
Rule 335 (Architectural
Coatings)
December 2024
Board of Health Meeting Date:
October 28, 2024
Board Hearing Date:
December 11, 2024
Case Number/Title:
AQ-2024-002-Rule 335 (Architectural Coatings)
Agenda Item:
(Pending)
Supervisor Districts:
All Districts
Applicant:
Staff
Request:
Approve revision of Maricopa County Air Pollution Control
Regulations, Rule 335 (Architectural Coatings) and approve
submission of the revised rule as a revision to the Arizona
State Implementation Plan (SIP).
Rule 335 establishes limits for emissions of volatile organic
compounds (VOCs) from architectural coatings. Rule 335
applies to any person who supplies, sells, offers for sale, or
manufacturers any architectural coating for use within
Maricopa County, as well as any person who applies or
solicits the application of any architectural coating within
Maricopa County. The rule was adopted in July 1988 and has
gone through one revision in September 2013.
On November 7, 2022, the U.S. Environmental Protection
Agency (EPA) reclassified portions of Maricopa County from
“marginal” to “moderate” nonattainment with respect to the
2015 National Ambient Air Quality Standard (NAAQS) for
ozone. Sections 172(c) and 182(b) of the Clean Air Act
(CAA) require jurisdictions that are classified as moderate or
higher nonattainment to submit a state implementation plan
(SIP) revision to provide for VOC emission reductions to
attain the ozone NAAQS by the applicable attainment date.
The SIP revision must include provisions addressing
reasonable further progress, an attainment demonstration,
and contingency measures amongst other provisions.
MCAQD identified the manufacture and application of
architectural coatings as processes where potential
emission reductions of VOCs could be achieved to assist
towards attainment of the ozone NAAQS. Architectural
coatings are coatings applied to stationary structures or
their appurtenances at the site of installation, to portable
buildings at the site of installation, to pavements, or to curbs.
During the architectural coating application and
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 4 of 109
manufacturing processes, VOCs are emitted which
contribute to ground-level ozone formation.
In order to achieve emission reductions from these
processes, MCAQD is proposing to lower many of the VOC
content limitations in Rule 335 and to add additional coating
VOC content limitations to the rule to reflect standards in the
Ozone Transport Commission Model Rule “Architectural and
Industrial Maintenance (AIM) Coatings”. The Ozone
Transport Commission (OTC) is a multi-state organization
created under the CAA that is responsible for advising the
EPA on transport issues and for developing and
implementing regional solutions to address the ground-level
ozone problem in the Northeast and Mid-Atlantic regions.
The standards in the OTC Model Rule have been
implemented in other districts such as Ohio, Michigan,
Connecticut, and Colorado with the same ozone
nonattainment status as Maricopa County.
MCAQD is also proposing to update the rule as it has not
undergone a significant revision since its adoption in 1988.
Proposed revisions include clarifying the applicability of the
rule and restructuring the rule to ensure consistency within
the Maricopa County Air Pollution Control Regulations.
Revised Rule 335 will be considered a contingency measure
for achieving the 2015 NAAQS for ozone as required by
Section 172(c)(9) of the CAA. As such, the revised rule will
become effective upon a determination by the EPA that
either the Phoenix-Mesa nonattainment area failed to attain
the 2015 ozone NAAQS by the attainment date or failed to
make reasonable further progress.
Support/Opposition:
During the rulemaking process, MCAQD has received written
feedback from two (2) stakeholders. The stakeholders did
not express support nor opposition to the rulemaking.
MCAQD evaluated the comments and drafted responses.
The stakeholders’ comments and MCAQD’s responses are
included under Section 9 of the attached Draft Notice of
Final Rulemaking. Copies of the stakeholders’ written
feedback and comments are attached to this report.
Staff
Recommendation:
Approve
Board of Health
Recommendation:
Approve
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 5 of 109
Additional Comments:
This regulatory change is following the Enhanced Regulatory
Outreach Program (EROP) Policy and workflow process. The
County Manager briefed the Board of Supervisors regarding
this rulemaking in February 2024. One Stakeholder
Workshop was held on April 4, 2024.
The Board of Health approved initiation of regulatory change
on April 22, 2024, and a Notice of Proposed Rulemaking was
posted on the EROP website on September 20, 2024. On
October 28, 2024, the Board of Health made a
recommendation to the Board of Supervisors to approve the
revisions to Rule 335.
A newspaper notice of the Board of Supervisors public
hearing will be published in the Arizona Business Gazette on
November 7, 2024, and November 14, 2024. This regulatory
change will take effect immediately upon approval by the
Board of Supervisors.
Presented By:
Philip A. McNeely, R.G., Director
Prepared By:
Planning and Analysis Division
Attachments:
Preamble required by Arizona Revised Statutes (A.R.S.) §
49-471.07 (See the Draft Notice of Final Rulemaking)
Summary of the proposed regulatory change (See Item 4 of
the Draft Notice of Final Rulemaking)
Analysis of input received during the process and how that
input was responded to (See Item 9 of the Draft Notice of
Final Rulemaking)
Language of proposed regulatory change or amendment
(See the Draft Notice of Final Rulemaking)
Strikethrough/underlined version of Draft Rule 335
Clean version of Draft Rule 335
Minutes from Board of Health meeting
Copies of all written and electronic Stakeholder input
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 6 of 109
Maricopa County
Air Quality Department
Planning and Analysis Division
Draft Notice of
Final
Rulemaking
Rule 335
(Architectural
Coatings)
December 2024
Draft Notice of Final Rulemaking
Maricopa County Air Pollution Control Regulations
Regulation III – Control of Air Contaminants
Rule 335 (Architectural Coatings)
The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 335
(Architectural Coatings). The Control Officer is posting this Draft Notice of Final Rulemaking
on the Maricopa County Enhanced Regulatory Outreach Program (EROP) website as part of the
Report to the Board of Supervisors, in accordance with the Maricopa County EROP Policy. This
notice includes the preamble, as prescribed in Arizona Revised Statutes (A.R.S.) § 49-471.05,
and the full text of the rule, including the intended actions to make new sections or amend,
repeal, or renumber the sections of the rule. This notice also includes a list of all previous
notices posted on the Maricopa County EROP website addressing the proposed rule and the
concise explanatory statement prescribed in A.R.S. § 49-471.07(B).
Preamble
1.
Statutory authority for the rulemaking (A.R.S. § 49-471.05(1)):
A.R.S. §§ 49-112, 49-474, 49-479 and 49-480
2.
Name and address of department personnel with whom persons may communicate
regarding the rulemaking (A.R.S. § 49-471.05(2)):
Name:
Hannah Luke or Kimberly Butler
Maricopa County Air Quality Department
Planning and Analysis Division
Address:
301 W. Jefferson St., Suite 410
Phoenix, AZ 85003
Telephone:
602-506-6010
Fax:
602-506-6179
Email:
AQPlanning@maricopa.gov
Online:
Submit a Comment
3.
Rulemaking process (A.R.S. § 49-471.05(3)):
This rulemaking is following procedures identified in state statutes and the Maricopa
County EROP Policy.
County Manager Briefing:
February 5, 2024
Return to list of attachments
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 8 of 109
Stakeholder Workshop:
April 4, 2024
Board of Health Meeting to Initiate Regulatory
Change:
April 22, 2024
Notice of Proposed Rulemaking:
September 20, 2024
Board of Health Meeting to Recommend Approval
to the Board of Supervisors:
October 28, 2024
Board of Supervisors Formal Meeting to Set the
Public Hearing:
November 6, 2024
Board of Supervisors Public Hearing:
December 11, 2024
4.
Explanation of the rule, including the control officer's reasons for initiating the
rulemaking (A.R.S. § 49-471.05(4)):
The purpose of Rule 335 (Architectural Coatings) is to limit volatile organic compound
(VOC) emissions from architectural coatings. The rule was adopted in July 1988 and
has gone through one revision in September 2013.
On November 7, 2022, the U.S. Environmental Protection Agency (EPA) reclassified
portions of Maricopa County from “marginal” to “moderate” nonattainment with respect
to the 2015 National Ambient Air Quality Standard (NAAQS) for ozone. Sections 172(c)
and 182(b) of the Clean Air Act (CAA) require jurisdictions that are classified as
moderate or higher nonattainment to submit a state implementation plan (SIP) revision
to provide for VOC emission reductions to attain the ozone NAAQS by the applicable
attainment date. The SIP revision must include provisions addressing reasonable
further progress, an attainment demonstration, and contingency measures amongst
other provisions.
MCAQD identified the manufacture and application of architectural coatings as
processes where potential emission reductions of VOCs could be achieved to assist
towards attainment of the ozone NAAQS. Architectural coatings are coatings applied to
stationary structures or their appurtenances at the site of installation, to portable
buildings at the site of installation, to pavements, or to curbs. During the architectural
coating application and manufacturing processes, VOCs are emitted which contribute
to ground-level ozone formation.
In order to achieve emission reductions from these processes, MCAQD is proposing to
lower many of the VOC content limitations in Rule 335 and to add additional coating
VOC content limitations to the rule to reflect standards in the Ozone Transport
Commission Model Rule “Architectural and Industrial Maintenance (AIM) Coatings”. The
Ozone Transport Commission (OTC) is a multi-state organization created under the CAA
that is responsible for advising the EPA on transport issues and for developing and
implementing regional solutions to address the ground-level ozone problem in the
Return to list of attachments
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 9 of 109
Northeast and Mid-Atlantic regions. The standards in the OTC Model Rule have been
implemented in other districts such as Ohio, Michigan, Connecticut, and Colorado with
the same ozone nonattainment status as Maricopa County.
MCAQD also plans to update the rule as it has not undergone a significant revision
since its adoption in 1988. Proposed revisions include clarifying the applicability of the
rule and restructuring the rule to ensure consistency within the Maricopa County Air
Pollution Control Regulations (MCAPCR).
Revised Rule 335 will be considered a contingency measure for achieving the 2015
NAAQS for ozone as required by Section 172(c)(9) of the CAA. As such, the revised rule
will become effective upon a determination by the EPA that either the Phoenix-Mesa
nonattainment area failed to attain the 2015 ozone NAAQS by the attainment date or
failed to make reasonable further progress.
5.
Studies relied on in the control officer's evaluation of or justification for the rule and
where the public may obtain or review the studies, all data underlying the studies, any
analysis of the studies and other supporting material (A.R.S. § 49-471.05(5)).
The following documents were relied on in the Control Officer’s evaluation of the rule:
(a) Model Rule: Architectural and Industrial Maintenance (AIM) Coating, June 21,
2011, Ozone Transport Commission.
(b) Report on Estimated Emission Reductions and Cost Impacts of Revising MCAQD
Rule 335 for Architectural and Industrial Maintenance Coatings, September 16,
2024, prepared by Eastern Research Group Inc. (ERG)
6.
An economic, small business and consumer impact statement (A.R.S. § 49-
471.05(6)):
The following discussion addresses each of the elements required for an economic,
small business and consumer impact statement, as prescribed by A.R.S. §§ 41-1055,
subsections A, B and C, and 41-1035:
An identification of the proposed rulemaking, including all of the following (A.R.S. §
41-1055(A)(1)):
The purpose of this rulemaking is to revise Rule 335 in order to obtain emission
reductions of VOCs to assist in achieving attainment of the ozone NAAQS. Examples of
proposed revisions include lowering many of the existing VOC content limitations and
adding additional coating VOC content limitations to reflect standards in the OTC Model
Rule. MCAQD also plans on updating the rule by clarifying the applicability, adding
definitions, incorporating common standards (i.e., thinning, painting practices, container
labeling requirements), updating recordkeeping requirements, and providing specific
coating test methods.
(a) The conduct and its frequency of occurrence that the rule is designed to change
(A.R.S. § 41-1055(A)(1)(a)).
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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MCAQD is proposing to revise Rule 335 to obtain emission reductions of VOCs to
assist in achieving attainment of the ozone NAAQS while also modernizing the rule.
(b) The harm resulting from the conduct the rule is designed to change and the
likelihood it will continue to occur if the rule is not changed (A.R.S. § 41-
1055(A)(1)(b)).
Due to Maricopa County being reclassified as a moderate nonattainment area with
respect to the 2015 8-hour ozone NAAQS, Sections 172(c) and 182(b) of the CAA
require jurisdictions that are classified as moderate or higher nonattainment to
submit a SIP revision to provide for VOC emission reductions to attain the ozone
NAAQS by the applicable attainment date. Revised Rule 335 will be considered a
contingency measure for achieving the 2015 NAAQS for ozone as required by
Section 172(c)(9) of the CAA. As such, the revised requirements will become
effective upon a determination by the EPA that either the Phoenix-Mesa
nonattainment area failed to attain the 2015 ozone NAAQS by the attainment date or
failed to make reasonable further progress. Failure to provide contingency
measures, including the Rule 335 revisions, could result in sanctions and imposition
of a Federal Implementation Plan (FIP) under the CAA which could adversely affect
Maricopa County.
(c) The estimated change in frequency of the targeted conduct expected from the rule
change (A.R.S. § 41-1055(A)(1)(c)).
MCAQD is proposing to revise Rule 335 to obtain emission reductions of VOCs to
assist in achieving attainment of the ozone NAAQS while also modernizing the rule.
A brief summary of the information included in the economic, small business and
consumer impact statement (A.R.S. § 41-1055(A)(2)).
The economic, small business and consumer impact statement addresses each of the
elements required for an economic, small business and consumer impact statement, as
prescribed by A.R.S. §§ 41-1055, subsections A, B, C, and 41-1035.
Name and address of agency employees who may be contacted to submit or request
additional data on the information included in the economic, small business and
consumer impact statement (A.R.S. § 41-1055(A)(3)).
Name:
Hannah Luke or Kimberly Butler
Maricopa County Air Quality Department
Planning and Analysis Division
Address:
301 W. Jefferson St., Suite 410
Phoenix, AZ 85003
Telephone:
602-506-6010
Fax:
602-506-6179
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 11 of 109
Email:
AQPlanning@maricopa.gov
Online:
Submit a Comment
An identification of the persons who will be directly affected by, bear the costs of or
directly benefit from the proposed rulemaking (A.R.S. § 41-1055(B)(2)).
This rulemaking will directly affect any person who supplies, sells, offers for sale, or
manufacturers any architectural coating for use within Maricopa County, as well as any
person who applies or solicits the application of any architectural coating within
Maricopa County except those exempt per Section 103 of the draft rule.
It is important to note that Rule 200 (Permit Requirements) of the MCAPCR exempts
application equipment and processes used exclusively to apply coatings to stationary
structures and/or their appurtenances at the site of installation, to portable buildings
including mobile homes at the site of installation, to pavement or to curbs, excluding
asphalt kettles from requiring an air quality permit. Based on the definition for
“Architectural Coating” in draft Rule 335 included in this document, this permit
exemption applies to people applying architectural coatings; however, this exemption
does not exempt them from the requirements of the rule.
There are architectural coating manufacturers within Maricopa County that have an air
quality permit with Rule 335 provisions. Examples include The Sherwin-Williams
Company and Dunn-Edwards. Paint manufacturers typically obtain an air quality permit
for VOC emissions and occasionally PM10 emissions, however it is possible that an air
quality permit would not be required if the paint manufacturer is making only ultra-low
VOC paint. Because all paint manufacturing operations will emit some VOCs, they may
also be required to submit an emissions inventory survey.
Paint manufacturing equipment used to make water-borne coatings can also be used to
make VOC-solvent borne coatings. If a permit was waived because the paint
manufacturing operations was making only low-VOC water-borne coatings, the paint
manufacturer must inform MCAQD in advance before making solvent-borne coatings. In
such a case, the paint manufacturer may be required to apply for a permit.
A cost benefit analysis of the following:
(a) The probable costs and benefits to the implementing agency and other agencies
directly affected by the implementation and enforcement of the proposed
rulemaking (A.R.S. § 41-1055(B)(3)(a)).
This rulemaking should not impose any new costs on MCAQD or on any other
agencies affected by the proposed rulemaking.
(b) The probable costs and benefits to a political subdivision of this state directly
affected by the implementation and enforcement of the proposed rulemaking
(A.R.S. § 41-1055(B)(3)(b)).
This rulemaking may impose new costs on political subdivision of this state;
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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however, it is difficult to quantify the exact impact on political subdivisions since
there are no political subdivisions that have an air quality permit with Rule 335 cited
in their permit. There is a possibility some political subdivisions using architectural
coatings that do not meet the proposed VOC content limits may be affected by a
potential cost increase on certain products as discussed in the next section.
(c) The probable costs and benefits to businesses directly affected by the proposed
rulemaking, including any anticipated effect on the revenues or payroll
expenditures of employers who are subject to the proposed rulemaking (A.R.S. §
41-1055(B)(3)(c)).
MCAQD employed Eastern Research Group, Inc. (ERG) to investigate the impacts of
revising Rule 335 to adopt more stringent VOC content limits for architectural
coatings sold and used in Maricopa County. ERG generated a report titled: “Report
on Estimated Emission Reductions and Cost Impacts of Revising MCAQD Rule 335 for
Architectural and Industrial Maintenance Coatings” with detailed explanations of their
findings. The report included findings from a voluntary survey that was conducted to
collect information on the volume and VOC content of architectural coatings sold
and likely used in Maricopa County. MCAQD received responses from seven
companies through the survey which showed that approximately 8.8 million gallons,
equivalent to approximately 700 tons per year (TPY) of VOC emissions, of
architectural coatings were sold in 2023 in Maricopa County. This data is estimated
to reflect approximately 88% of the expected volume of coatings sold in Maricopa
County.
Approximately 71% of the reported products sold in Maricopa County have a VOC
content already compliant with the proposed VOC content limits. The remaining 29%
of reported products, which are from three of the seven companies that responded
to the survey, are not compliant with the proposed VOC content limits but many of
the products have likely already been reformulated to comply with more stringent
requirements in other jurisdictions or are more appropriately regulated by another
rule within the MCAPCR. The three survey respondents with noncompliant products
are companies with significant net sales and either national or international
locations. Research of their product catalogs and discussions with company
representatives reflected that there are alternative compliant coatings for many of
the products that utilize exempt solvents to meet the proposed VOC content
limitations. Exempt solvents are compounds which have been determined to have
negligible photochemical reactivity as listed in 40 CFR 51.100(s) and are exempt
from the regulatory definition of VOC.
Among the architectural coating categories reported in the survey, products under
six coating categories were observed to be noncompliant with the proposed VOC
content limitations in Rule 335.
Concrete/Masonry Sealers
There was one product out of the five products reported for this category that
exceeded the proposed limit in Rule 335. It is estimated that alternative compliant
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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concrete/masonry sealers would have no impact on the cost per gallon for both the
manufacturer and consumer to comply with the lower VOC content limit in proposed
Rule 335.
Industrial Maintenance Coatings
There were 29 products out of the 109 products reported for this category that
exceed the proposed limit in Rule 335. Additional information was obtained from the
two companies that reported the 29 noncompliant coatings to determine whether
there would be the need to reformulate or if the two companies have alternative
compliant industrial maintenance coatings. Both companies confirmed that there
are alternative compliant coatings available and there would be no need to
reformulate. For example, one company stated that they have compliant alternative
industrial maintenance coatings that rely on the use of exempt solvents.
However, the alternative compliant coatings do have a higher cost. It was reported
that the cost increase per gallon of industrial maintenance coating would be due to
the higher cost of exempt solvents. It is important to note that industrial
maintenance coatings are typically more expensive than flat and non-flat coatings
and it is not uncommon for them to cost between $100 to $250 per gallon.
Therefore, the estimated cost increase of $15.91 per gallon does not represent a
large percentage price increase when considering the average cost per gallon to
consumers.
Low-Solids Coatings
There was one product reported for this category from one survey respondent that
exceeded the proposed limit in Rule 335. The data reported in the voluntary survey
reflected 55 gallons of the product were sold in 2023. The company that sells the
product was contacted for further information. A company representative stated
they do not have a lower-VOC alternative for the coating, which is used in wood
finishing. They also stated they could not estimate the cost to reformulate a lower-
VOC coating but predicted significant research and development would be needed
to lower the VOC content.
Primers, Sealers, and Undercoaters
There were five products out of the 39 products reported for this category that
exceeded the proposed limit in Rule 335. Primers, sealers, and undercoaters are
coatings used when creating cohesive layers. Due to these products being used by a
wide variety of industries, it is difficult to categorize a specific industry who primarily
uses these products. The cost analysis reflected that this category would see an
estimated 15% cost increase per gallon to consumer, which is equivalent to
approximately $3.81 per gallon, for those products that are not compliant with the
proposed limits.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Stains
There were 53 products out of the 113 reported for this category that exceeded the
proposed limit in Rule 335. The company that reported the 53 products provided
additional information on their strategy to comply with proposed Rule 335, stating
that they would consider limiting the sale of stains to only wood furniture and wood
product shops. A representative with the company stated that most of their coatings
are intended as shop applied coatings. Rule 335 regulates coatings and stains that
are applied in a field setting while MCAPCR Rule 342 (Coating Wood Furniture and
Fixtures) applies to shop applied wood coatings and stains. This means the stains
are regulated under MCAPCR Rule 342 rather than Rule 335, thus not needing to
comply with the proposed VOC content limitation in draft Rule 335.
Wood Coatings
There were 36 products out of the 49 reported for this category from one survey
respondent that exceeded the proposed limit in Rule 335. A representative with the
company provided additional information on their strategy to comply with proposed
Rule 335, stating that they would limit the sale of wood coatings to only wood
furniture and wood product shops. Rule 335 regulates coatings and stains that are
applied in a field setting while MCAPCR Rule 342 (Coating Wood Furniture and
Fixtures) applies to shop applied wood coatings and stains. This means the stains
are regulated under MCAPCR Rule 342 rather than Rule 335, thus not needing to
comply with the proposed VOC content limitation in draft Rule 335.
A general description of the probable impact on private and public employment in
businesses, agencies and political subdivisions of this state directly affected by the
proposed rulemaking (A.R.S. § 41-1055(B)(4)).
This rulemaking should have no impact on private or public employment in businesses,
agencies, and political subdivisions of this state.
A statement of the probable impact of the proposed rulemaking on small businesses.
(a) An identification of the small businesses subject to the proposed rulemaking
(A.R.S. § 41-1055(B)(5)(a)).
Small businesses subject to this rulemaking are those facilities in Maricopa County
that use or sell VOC-containing architectural coatings which do not fall under the
exemptions in Section 103 of the draft rule included in this notice.
(b) The administrative and other costs required for compliance with the proposed
rulemaking (A.R.S. § 41-1055(B)(5)(b)).
For small businesses currently selling or using an architectural coating that is
noncompliant with the proposed VOC content limitations in draft Rule 335, there
may be potential costs associated with the use of alternative compliant coatings
using exempt solvents as detailed below. The use of exempt solvents in coatings
can result in higher costs, though it is believed that these compliant products are
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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already available by businesses manufacturing architectural coatings. For small
businesses who are selling or using an architectural coating that is compliant with
the proposed VOC content limitations in draft Rule 335, there will be no additional
cost.
(c) A description of the methods that the agency may use to reduce the impact on
small businesses (A.R.S. § 41-1055(B)(5)(c)).
MCAQD has a business assistance program that provides administrative and
technical assistance to business owners related to air quality rules and regulations.
Courtesy site visits, on-site training, rule interpretation, and compliance assistance
are offered to small businesses at no charge.
i. Establish less stringent compliance or reporting requirements in the rule for
small businesses (A.R.S. § 41-1035(1)).
This rulemaking proposes lowering the VOC content limit for most of the
architectural coatings categories in Rule 335 and adding new architectural
coating categories. However, it was determined that approximately 71% of the
reported products sold in Maricopa County have a VOC content already
compliant with the proposed VOC content limits and would not need to be
reformulated. This data is estimated to reflect approximately 88% of the
expected volume of coatings sold in Maricopa County.
Based on the voluntary survey results and analysis conducted by ERG, proposed
limits in three coating categories may have an economic impact on small
businesses: industrial maintenance coatings, low-solid coatings and primers,
sealers, and undercoaters.
Industrial maintenance coatings are typically used/applied by larger businesses
so the impact of the proposed limits on small businesses will probably be
minimal. Examples of industries that utilize industrial maintenance coatings
include but are not limited to storage and process tanks used in the gas and oil
industry, utilities infrastructure, mining activities, and transportation
infrastructures including traffic surfaces, highways, airports, and railroads. In
addition, it is important to note the majority of the industrial maintenance
coatings reported are already compliant with the proposed limits.
Small businesses may be affected by the proposed revision to the VOC content
limit for low-solid coatings but the company that sells the one product that does
not meet the proposed VOC content limit could not provide a cost for developing
a product to comply with the limit.
Additionally, small businesses may be affected by the proposed revision to the
VOC content limit for primers, sealers, and undercoaters. This coating category is
a group of common products used by a wide variety of industries. As previously
mentioned, the cost analysis conducted by ERG reflected that this category
would see an estimated 15% cost increase per gallon to consumer, which is
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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equivalent to approximately $3.81 per gallon, for those products that are not
compliant with the proposed limits. In addition, it is important to note the
majority of the primers, sealers, and undercoaters reported are already compliant
with the proposed limits.
Outreach with stakeholders has been conducted, including one stakeholder
workshop, one voluntary informational survey, citizen comment opportunities,
and the proposed revisions presented at the Board of Health meeting on April 22,
2024.
During the rulemaking process, MCAQD has received two citizen comments. The
first commentor requested a more stringent VOC content limitation on the form-
release compounds category, and the second commentor requested MCAQD
adhere to a one-year compliance schedule from the effective date of the final
rule. There have been no further citizen comments notifying MCAQD that there
would be any significant impact on small businesses due to the proposed
revisions.
ii. Establish less stringent schedules or deadlines in the rule for compliance or
reporting requirements for small businesses (A.R.S. § 41-1035(2)).
This rulemaking does not impose any significant new compliance schedules or
deadlines on small businesses.
The proposed rule adoption date is December 11, 2024. Although the rule will
locally be adopted, the proposed effective date of the rule is contingent upon a
determination made by the EPA that either the Phoenix-Mesa nonattainment area
failed to attain the 2015 ozone NAAQS by the attainment date or failed to make
reasonable further progress. Once the determination is made by the EPA, the
revised rule will be immediately effective.
MCAQD will be providing a period of one year from the effective date for the
applicable persons regulated by Section 301 of draft Rule 335 to utilize any
products that complied with the standards effective at the time the product was
obtained.
For architectural coating manufacturers, there will be a period of three years from
the effective date specified in Table 335-1 of draft Rule 335 that will allow the
sale, supply, or offer for sale (referenced as sell-through of coatings) any product
that complied with the standards effective at the time the product was
manufactured.
These compliance schedules are mirroring provisions in the OTC Model Rule for
AIM Coatings and other jurisdictions who have implemented the same
standards.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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iii. Consolidate or simplify the rule's compliance or reporting requirements for
small businesses (A.R.S. § 41-1035(3)).
All businesses to which the rule applies are subject to the same compliance and
reporting requirements (e.g., VOC content limitations).
iv. Establish performance standards for small businesses to replace design or
operational standards in the rule (A.R.S. § 41-1035(4)).
All businesses to which the rule applies are subject to the same performance
standards (e.g., VOC content limitations).
v. Exempt small businesses from any or all requirements of the rule (A.R.S. § 41-
1035(5)).
This rulemaking contains exemptions as outlined in Section 103 of the draft rule.
(d) The probable cost and benefit to private persons and consumers who are directly
affected by the proposed rulemaking (A.R.S. § 41-1055(B)(5)(d)).
Depending on the alternative compliant coatings available by each company, it is
possible that the coating manufacturers may absorb some of the costs associated
with the proposed revisions. However, there is still a possibility for consumers to be
impacted. As previously mentioned, 71% of products reported in the voluntary survey
were compliant with the proposed revisions and would result in no impact to
consumers. The remaining 29% of reported products were noncompliant and would
require alternative strategies by the coating supplier. Examples include offering
alternative compliant coatings that utilize exempt solvents or directing sales to
shop-applied scenarios that would no longer be applicable to Rule 335. Coatings
with exempt solvents may reflect a price increase to the consumer depending on the
specific coating. Additionally, the reported products that were noncompliant with the
proposed VOC content limitations reflect only a small portion of all coating
categories listed in draft Rule 335.
A statement of the probable effect on state revenues (A.R.S. § 41-1055(B)(6)).
There is no significant projected change in consumer purchase patterns and, thus, no
significant impact on state revenues from sales taxes is expected.
A description of any less intrusive or less costly alternative methods of achieving the
purpose of the proposed rulemaking, including the monetizing of the costs and
benefits for each option and providing the rationale for not using nonselected
alternatives (A.R.S. § 41-1055(B)(7)).
The purpose of this rulemaking is to revise Rule 335 (Architectural Coatings) in order to
obtain emission reductions of VOCs to assist in achieving attainment of the ozone
NAAQS. Due to Maricopa County being reclassified as a moderate nonattainment area
with respect to the 2015 8-hour ozone NAAQS, Sections 172(c) and 182(b) of the CAA
require jurisdictions that are classified as moderate or higher nonattainment to submit a
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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SIP revision to provide for VOC emission reductions to attain the ozone NAAQS by the
applicable attainment date. Failure to do so could result in sanctions and imposition of
a FIP under the CAA which could adversely affect Maricopa County.
A description of any data on which a rule is based with a detailed explanation of how
the data was obtained and why the data is acceptable data (A.R.S. § 41-1055(B)(8)).
Not applicable.
7.
The proposed effective date of the rule (A.R.S. § 49-471.05(7)):
The estimated rule adoption date is December 11, 2024. However, the proposed
effective date of the rule is contingent upon a determination made by the EPA that
either the Phoenix-Mesa nonattainment area failed to attain the 2015 ozone NAAQS by
the attainment date or failed to make reasonable further progress.
8.
Such other matters as are prescribed by statute and that are applicable to the county
or to any specific rule or class of rules (A.R.S. § 49-471.05(8)):
Under A.R.S. § 49-479(C), a county may not adopt a rule or ordinance that is more
stringent than the rules adopted by the Director of the Arizona Department of
Environmental Quality (ADEQ) for similar sources unless it demonstrates compliance
with the applicable requirements of A.R.S. §49-112.
§ 49-112 County regulation; standards
§ 49-112(A)
When authorized by law, a county may adopt a rule, ordinance or regulation that is more
stringent than or in addition to a provision of this title or rule adopted by the director or
any board or commission authorized to adopt rules pursuant to this title if all of the
following requirements are met:
1. The rule, ordinance or regulation is necessary to address a peculiar local condition.
2. There is credible evidence that the rule, ordinance or regulation is either;
(a) Necessary to prevent a significant threat to public health or the environment that
results from a peculiar local condition and is technically and economically
feasible.
(b) Required under a federal statute or regulation, or authorized pursuant to an
intergovernmental agreement with the federal government to enforce federal
statutes or regulations if the county rule, ordinance or regulation is equivalent to
federal statutes or regulation.
3. Any fee or tax adopted under the rule, ordinance or regulation does not exceed the
reasonable costs of the county to issue and administer the permit or plan approval
program.
§ 49-112(B)
When authorized by law, a county may adopt rules, ordinances or regulations in lieu of a
state program that are as stringent as a provision of this title or rule adopted by the
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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director or any board or commission authorized to adopt rules pursuant to this title if
the county demonstrates that the cost of obtaining permits or other approvals from the
county will approximately equal or be less than the fee or cost of obtaining similar
permits or approvals under this title or any rule adopted pursuant to this title. If the state
has not adopted a fee or tax for similar permits or approvals, the county may adopt a
fee when authorized by law in the rule, ordinance or regulation that does not exceed the
reasonable costs of the county to issue and administer that permit or plan approval
program.
MCAQD is in compliance with A.R.S. §§ 49-112(A) and (B). Rule 335 meets A.R.S. § 49-
112(A)(1) by demonstrating that the rule is necessary to address a peculiar local
condition, in that Maricopa County fails to meet the 8-hour NAAQS for ozone. As there is
no new fee or tax associated with this proposed rulemaking, MCAQD also affirms that
Rule 335 meets the requirements of A.R.S. § 49-112 (A)(3) and A.R.S § 49-112 (B).
9.
List of all previous notices posted to the Maricopa County EROP website addressing
the proposed rule and a concise explanatory statement, as prescribed by A.R.S. § 49-
471.07(B):
a. List of all previous notices posted to the Maricopa County EROP website
addressing the proposed rule:
Notice
Date of Posting
Briefing Notification to County Manager:
February 9, 2024
Notice of Stakeholder Workshop:
March 21, 2024
Notice of First Board of Health Meeting:
April 8, 2024
Notice of Proposed Rulemaking:
September 20, 2024
Notice of Second Board of Health Meeting:
October 14, 2024
b. The following discussion addresses each of the elements required for a concise
explanatory statement, as prescribed by A.R.S. § 49-471.07(B):
i. A description of any change between the proposed rule or ordinance, the
final rule or ordinance or notice of final supplemental rule or ordinance.
The following changes were made after the Notice of Proposed Rulemaking
was published on September 20, 2024:
1. Revised the exemption in Section 103.4(b). The language now reads as
follows:
“Multiple containers of one liter or less that are packaged and shipped
together with no intent or requirement to ultimately sell as individual
units of one liter or less.”
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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2.
Added subsection 103.5(c) and adjusted the numbering in Section 103.5
as a result of the added subsection. This subsection reads as follows:
“Cutback and emulsified asphalt use and application (Rule 340).”
3.
Removed the labeling requirement previously listed under Section
308.4(g)(4) stating “For excessively chalky substrates.”
4.
Added proposed effective date for current VOC content limits of
December 31, 2025, to Table 335-1 columns that previously stated
“Effective until (date)”.
5.
Added proposed effective date for new VOC content limits of January 1,
2026, to Table 335-1 columns that previously stated “Effective (date)”.
6.
Added proposed effective date of January 1, 2026, to the language in
Section 307 “Rust Preventive Coatings”.
7.
Removed the VOC content limits in Table 335-1 for Bituminous Roof
Coatings, Bituminous Roof Primers, and Driveway Sealers under the
columns labeled “Effective until December 31, 2025”. The VOC content
limits now state “N/A”. The previously listed VOC content limits for
these coatings were inadvertently included in Table 335-1.
8.
Revised the language in Section 308.3 to include “or pounds of VOC per
gallon”. The language now reads as follows:
“Each container of any coating subject to this rule shall display one of
the following values in either grams of VOC per liter or pounds of VOC
per gallon of coating.”
9.
Revised the language in Section 501.8(f) to include “or pounds per
gallon”. The language now reads as follows:
“VOC Actual content and VOC Regulatory content in either grams per
liter or pounds per gallon. If thinning is recommended, list the VOC
Actual content and VOC Regulatory content after maximum
recommended thinning. If containers less than one liter have a different
VOC content than containers greater than one liter, list separately. If the
coating is a multi-component product, provide the VOC content as
mixed or catalyzed.”
ii. A summary of the comments and arguments for and against the notice and
the county’s response to the comments and arguments.
The following discussion evaluates the arguments for and against the rule
and includes responses to comments received on the proposed rule or the
preamble in the Notice of Proposed Rulemaking. MCAQD received written
comments from two stakeholders. All of the comments were reviewed and
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Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 21 of 109
evaluated by MCAQD. A link to a copy of the stakeholder comments is
provided.
Stakeholder #1: Comment #1 submitted on April 5, 2024
Comment #1:
At the stakeholder meeting yesterday WR Meadows suggested that the
Maximum VOC content for the form release category in the new version of
Rule 335 be reduced from 250 g/l to 100 g/l. I have attached two SDS’s for
products WR Meadows currently sells. Note the VOC contents are less than
100 g/l.
Many years ago a winter-grade form release was sold in the market. This
product typically had a diesel fuel component to enhance application in
colder weather. Those products are no longer sold and with the climate in
Maricopa County I don’t think they would ever be needed.
Thanks for your consideration.
Response #1:
MCAQD evaluated your comment and will maintain the proposed VOC
content limit of 250 g/L for form-release compounds. Rule 335 has not gone
through a significant revision since 1988. The main objective of this
rulemaking is to match the VOC content limits in the Ozone Transport
Commission (OTC) AIM Coating Model Rule. Lowering the VOC content limit
even further could be burdensome to affected businesses who have not
been impacted by a rule revision in over 30 years. Therefore, the proposed
VOC content limits will not be revised further to be more stringent at this
time.
Stakeholder #2: Comment #2 submitted on April 9, 2024
Comment #2:
The American Coatings Association (ACA) submits the following preliminary
comments to the Maricopa County Air Quality Department (MCAQD)
regarding its proposed revisions to Rule 335 (Architectural Coatings). ACA is
a voluntary, nonprofit trade association working to advance the needs of the
paint and coatings industry and the professionals who work in it. The
organization represents paint and coatings manufacturers, raw materials
suppliers, distributors, and technical professionals. ACA serves as an
advocate and ally for members on legislative, regulatory, and judicial issues,
and provides forums for the advancement and promotion of the industry
through educational and professional development services. ACA
appreciates the opportunity to comment and looks forward to working with
MCAQD throughout the rulemaking process.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 22 of 109
ACA encourages MCAQD to consider adopting a compliance date of one
year from the date of adoption of the final rule. The effective date for the
new VOC limits is not listed in Table 335-1, yet. As a general matter, the paint
and coatings industry requires sufficient lead time to adjust formulations
and supply chain processes in order to ensure compliance with new VOC
limits, labeling, and reporting requirements. Industry also needs sufficient
time to adjust production, labeling, and distribution networks to effectively
and efficiently implement the new rule requirements.
Manufacturers, distributors, and retail stores employ extensive computer
systems that require upgrades to incorporate new formulations and ensure
non-compliant products are not sold into jurisdictions with new VOC limits.
Furthermore, manufacturing and labeling costs are generally expensive, and
coatings manufacturers tend to manage formulation changes to their
products to minimize costs stemming from obsolete products and labels.
Additionally, manufacturers will need sufficient time to properly
communicate these changes to their distributors and retail customers to
ensure compliance with new VOC limits. Finally, most companies wait until a
rule is finalized and its requirements are certain before implementing
changes to ensure compliance because it helps minimize costs. This means
that companies will not implement changes during the early parts of a
rulemaking and will need adequate time after finalization of a new rule to
make appropriate changes. As such, industry typically needs at least a year
to properly implement the necessary changes to comply with the new rule
requirements.
Thank you for your consideration of ACA's preliminary comments. We may
have additional comments after the proposed rule is formally issued after
the Board of Health Meeting on April 22. Please do not hesitate to contact
me if you have any questions or require additional clarification.
Response #2:
MCAQD evaluated your comment and determined the effective date for the
new VOC content limits in Table 335-1 will be January 1, 2026. This
timeframe will provide approximately one year for businesses to comply with
the new limits, depending on when the EPA makes a determination that
either the Phoenix-Mesa nonattainment area failed to attain the 2015 ozone
NAAQS by the attainment date or failed to make reasonable further progress.
Exact Wording of the Rule
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Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 23 of 109
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 335 (ARCHITECTURAL COATINGS)
INDEX
SECTION 100 – GENERAL
101
PURPOSE
102
APPLICABILITY OF MULTIPLE STANDARDS
103
EXEMPTIONS
SECTION 200 – DEFINITIONS
201
ACRYLIC POLYMERS
201
ADHESIVE
202
AEROSOL COATING PRODUCT
202
ALKYDS
203
ALUMINUM ROOF COATING
204
APPURTENANCES
203
205
ARCHITECTURAL COATING
206
BASEMENT SPECIALITY COATING
204
BELOW GROUND WOOD PRESERVATIVES
207
BITUMENS
205
BITUMINOUS COATING MATERIALS
208
BITUMINOUS ROOF COATING
209
BITUMINOUS ROOF PRIMER
206
210
BOND BREAKERS
211
CALCIMINE RECOATER
207
CATALYZED EPOXY
209
CHLORINATED RUBBER
212
COATING
213
COLORANT
208
214
CONCRETE CURING COMPOUNDS
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Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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215
CONCRETE/MASONRY SEALER
216
CONCRETE SURFACE RETARDER
217
CONJUGATED OIL VARNISH
218
CONVERSION VARNISH
219
DRIVEWAY SEALER
210
220
DRY FOG COATINGS
211
221
ENAMEL UNDERCOATERS
222
EXEMPT COMPOUND
223
FAUX FINISHING COATING
224
FIRE-RESISTIVE COATING
212
FIRE RETARDANT COATINGS
213
225
FLAT COATINGS
226
FLOOR COATING
227
FORM-RELEASE COMPOUND
214
GENERAL PRIMERS
215
GENERAL SEALERS
216
GENERAL UNDERCOATERS
217
228
GRAPHIC ARTS COATINGS (SIGN PAINTS)
229
HIGH-TEMPERATURE COATING
230
IMPACTED IMMERSION COATING
218
INDUSTRIAL MAINTENANCE PRIMERS
219
INDUSTRIAL MAINTENANCE TOPCOATS
231
INDUSTRIAL MAINTENANCE COATING
220
INORGANIC POLYMERS
221
232
LACQUERS
233
LOW-SOLIDS COATING
234
MAGNESITE CEMENT COATING
235
MANUFACTURER’S MAXIMUM RECOMMENDATION
222
236
MASTIC TEXTURE COATINGS
237
MEDIUM DENSITY FIBERBOARD (MDF)
238
METALLIC PIGMENTED COATING
223
METALLIC PIGMENTED PAINTS
224
239
MULTI-COLORED COATINGS
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Page 25 of 109
225
240
NON-FLAT COATINGS
241
NON-FLAT HIGH GLOSS COATING
242
NUCLEAR COATING
226
243
OPAQUE STAINS
227
244
OPAQUE WOOD PRESERVATIVES
228
ORGANIC COMPOUND
245
PARTICLEBOARD
246
PEARLESCENT
247
PLYWOOD
248
POST-CONSUMER COATING
249
PRE-TREATMENT WASH PRIMER
250
PRIMER, SEALER, AND UNDERCOATER
229
251
QUICK-DRY ENAMELS
230
QUICK-DRY PRIMERS AND SEALERS
252
REACTIVE PENETRATING CARBONATE STONE SEALER
253
REACTIVE PENETRATING SEALER
254
RECYCLED COATING
255
RESIDENTAL
231
256
ROOF COATINGS
257
RUST PREVENTATIVE COATING
258
SECONDARY INDUSTRIAL MATERIALS
259
SEMI-TRANSPARENT COATING
232
260
SEMI-TRANSPARENT STAINS
233
261
SEMI-TRANSPARENT WOOD PRESERVATIVES
234
262
SHELLACS
263
SHOP APPLICATION
235
SILICONES
264
SOLICIT
236
265
SPECIALTY FLAT PRODUCTS
237
266
SPECIALTY PRIMERS, SEALERS, AND UNDERCOATERS
267
STAIN
268
STATIONARY STRUCTURE
269
STONE CONSOLIDANT
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238
270
SWIMMING POOL COATINGS
271
THERMOPLASTIC RUBBER COATING AND MASTIC
272
TINT BASE
239
TILE-LIKE GLAZE COATINGS
240
273
TRAFFIC MARKING COATINGS
274
TUB AND TILE REFINISH COATING
241
UNIQUE VEHICLES
242
URETHANE POLYMERS
243
275
VARNISHES
276
VENEER
244
VINYL CHLORIDE POLYMERS
277
VIRGIN MATERIALS
278
VOC ACTUAL
279
VOC CONTENT
280
VOC REGULATORY
281
VOLATILE ORGANIC COMPOUND (VOC)
245
282
WATERPROOFING MASTIC COATINGS
283
WATERPROOFING MEMBRANE
246
284
WATERPROOF SEALERS
285
WOOD COATING
286
WOOD PRESERVATIVE
287
WOOD SUBSTRATE
288
ZINC-RICH PRIMER
SECTION 300 – STANDARDS
301
VOC CONTENT LIMITS PROHIBITION-BITUMINOUS PAVEMENT SEALERS
302
COATING CATEGORIZATION INTERIM LIMITS - NON-FLAT ARCHITECTURAL
COATINGS
303
MOST RESTRICTIVE VOC CONTENT LIMIT FINAL LIMITS - NON-FLAT
ARCHITECTURAL COATINGS
304
SELL-THROUGH OF COATINGS LIMITS - FLAT ARCHITECTURAL COATINGS
305
THINNING LIMITS - SPECIALTY COATINGS
306
PAINTING PRACTICES EXEMPTIONS - SPECIFIC-USE COATINGS
307
RUST PREVENTATIVE COATINGS EXEMPTIONS - SMALL CONTAINERS
308
CONTAINER LABELING REQUIREMENTS
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SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE)
401
LABELING REQUIRED
402
MANUFACTURE DATE REQUIRED
SECTION 500 – MONITORING AND RECORDS
501
RECORDKEEPING AND REPORTING DETERMINATION OF COMPLIANCE
502
COMPLIANCE DETERMINATION
503
TEST METHODS INCORPORATED BY REFERENCE
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 28 of 109
Adopted 07/13/88; Revised 09/25/13; Revised MM/DD/YYYY
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 335 (ARCHITECTURAL COATINGS)
SECTION 100 – GENERAL
101
PURPOSE: To limit the emissions of volatile organic compounds (VOCs) from the sale,
manufacture, and/or application of architectural coatings. This rule has been revised as
a contingency measure for achieving the 2015 National Ambient Air Quality Standard
(NAAQS) for ozone as required by Section 172(c)(9) of the Clean Air Act (CAA) under 42
United States Code (U.S.C.) 7502.
102
APPLICABILITY OF MULTIPLE STANDARDS: This rule applies to any person who
supplies, sells, offers for sale, or manufacturers any architectural coating for use within
Maricopa County, as well as any person who applies or solicits the application of any
architectural coating within Maricopa County.
102.1 The revised requirements of this rule as adopted on [revision date] shall become
effective upon a determination by the U.S. Environmental Protection Agency
(EPA) that either of the following triggering events has occurred:
a. The Phoenix-Mesa 2015 ozone NAAQS nonattainment area failed to attain the
2015 ozone NAAQS by the Moderate area attainment date; or
b. The Phoenix-Mesa 2015 ozone NAAQS nonattainment area failed to make
reasonable further progress under the 2015 ozone NAAQS.
102.2 In addition to this rule, facilities may be subject to New Source Performance
Standards (NSPS) in Rule 360 and/or to National Emission Standards for
Hazardous Air Pollutants (NESHAP) in Rule 370 of the Maricopa County Air
Pollution Control Regulations (MCAPCR). In any instance where more than one of
the standards set forth in this rule may be applicable, the most restrictive
standard shall apply.
103
EXEMPTIONS: This rule shall not apply to the following:
103.1 Any architectural coating that is supplied, sold, offered for sale, or manufactured
for use outside of Maricopa County or for shipment to other manufacturers for
reformulation or repackaging.
103.2 Any aerosol coating product.
103.3 Any facility which applies coatings to test specimens for purposes of research
and development of those coatings.
307
103.4 EXCEPTION - SMALL CONTAINERS: The provisions of this rule shall not apply to
Architectural coatings supplied in containers having capacities of one liter (1.057
quart) or less, including kits containing containers of different colors, types, or
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 29 of 109
categories of coatings and two component products. This exemption does not
include:
a. Bundling of containers one liter or less, which are sold together as a unit, or
any type of marketing which implies that multiple containers one liter or less
be combined into one container; and
b. Multiple containers of one liter or less that are packaged and shipped
together with no intent or requirement to ultimately sell as individual units of
one liter or less.
103.5 Activities that are more specifically regulated by another source-specific rule
within the MCAPCR, as listed below:
a. Product painting or pre-installation painting of structures (Rule 336).
b. Re-coating of a structural part, which has been removed from the structure
prior to re-coating (Rule 336).
c. Cutback and emulsified asphalt use and application (Rule 340).
d. Surface preparation and coating of wood furniture and fixtures (Rule 342).
e. Surface preparation and coating of wood millwork (Rule 346).
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions
shall apply, in addition to those definitions found in Rule 100 (General Provisions and
Definitions) of these rules. In the event of any inconsistency between any of the rules within
the Maricopa County Air Pollution Control Regulations (MCAPCR), the definitions in this rule
take precedence.
201
ACRYLIC POLYMERS: Polymers resulting from the polymerization of derivatives of
acrylic acids, including esters of acrylic acids, methacrylic acid, acrylonitrile, and their
copolymers. Also known as acrylic resins and acrylate resins.
201
ADHESIVE: Any chemical substance that is applied for the purpose of bonding two
surfaces together other than by mechanical means.
202
AEROSOL COATING PRODUCT: A pressurized coating product containing pigments or
resins that dispenses product ingredients by means of a propellant and is packaged in a
disposable can for hand-held application, or for use in specialized equipment for ground
traffic/marking applications.
202
ALKYDS: Synthetic resins formed by the condensation of polyhydric alcohols with
polybasic acids.
203
ALUMINUM ROOF COATING: A coating labeled and formulated exclusively for
application to roofs and containing at least 84 grams of elemental aluminum pigment
per liter of coating (at least 0.7 pounds per gallon). Pigment content shall be determined
in accordance with South Coast Air Quality Management District (SCAQMD) Method
318-95, incorporated by reference in Section 503.8.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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204
APPURTENANCES: Any accessory to a stationary structure coated at the site of
installation, whether installed or detached, including but not limited to the following:
204.1 Bathroom and kitchen
fixtures.
204.2 Cabinets.
204.3 Concrete forms.
204.4 Doors.
204.5 Elevators.
204.6 Fences.
204.7 Hand railings.
204.8 Heating equipment.
204.9 Air conditioning equipment.
204.10 Other fixed mechanical
equipment.
204.11 Stationary tools.
204.12 Lampposts.
204.13 Partitions.
204.14 Pipes and piping systems.
204.15 Rain gutters and downspouts.
204.16 Stairways.
204.17 Fixed ladders.
204.18 Catwalks and fire escapes.
204.19 Window screens.
203
205
ARCHITECTURAL COATING: Any A coating to be applied to stationary structures and or
their appurtenances at the site of installation, including but not limited to the structures
or appurtenances listed in Section 205.1 through 205.5 of this rule. Coatings applied in
shop applications or to non-stationary structures such as airplanes, ships, boats,
railcars, and automobiles, as well as adhesives are not considered architectural
coatings for the purposes of this rule. to mobile homes, to pavements, or to curbs.
205.1 Mobile homes.
205.2 Portable buildings.
205.3 Manufactured buildings of either modular or unitary design.
205.4 Pavement.
205.5 Curbs.
206
BASEMENT SPECIALTY COATING: A clear or opaque coating that is labeled and
formulated for application to concrete and masonry surfaces to provide a hydrostatic
seal for basements and other below-grade surfaces. Basement Specialty Coatings must
meet the following criteria:
206.1 Coating must be capable of withstanding at least 10 psi of hydrostatic pressure,
as determined in accordance with American Society for Testing and Maintenance
(ASTM) D7088-17, incorporated by reference in Section 503.7; and
206.2 Coating must be resistant to mold and mildew growth and must achieve a
microbial growth rating of 8 or more (10 is no growth), as determined in
accordance with ASTM D3273-16 and ASTM D3274-09 (2017), incorporated by
reference in Section 503.10.
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204
BELOW GROUND WOOD PRESERVATIVES: Heavy duty coatings formulated solely for the
purpose of protecting below ground wood from decay or insect attack and which
contain a wood preservative.
207
BITUMENS: Black or brown materials including, but not limited to, asphalt, tar, pitch and
asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons that are
obtained from natural deposits or as residues from the distillation of crude petroleum or
coal.
205
BITUMINOUS COATING MATERIALS: Black or brownish materials, soluble in carbon
disulfide, consisting mainly of hydrocarbons and which are obtained from natural
deposits, or as residues from the distillation of crude petroleum oils or of low grades of
coal.
208
BITUMINOUS ROOF COATING: A coating which incorporates bitumens that is labeled
and formulated exclusively for roofing for the primary purpose of preventing water
penetration.
209
BITUMINOUS ROOF PRIMER: A primer which incorporates bitumens that is labeled and
formulated exclusively for roofing and intended for the purpose of preparing a
weathered or aged surface or improving the adhesion of subsequent surfacing
components.
206
210
BOND BREAKERS: A coating labeled and formulated for application between layers of
concrete to prevent a freshly poured top layer of concrete from bonding to the layer over
which it is poured. Coatings whose sole purpose, when applied between layers of
concrete, is to prevent the freshly poured top layer of concrete from bonding to the
substrate on which it is poured.
211
CALCIMINE RECOATER: A flat solvent-borne coating formulated and recommended
specifically for recoating calcimine-painted ceilings and other calcimine-painted
substrates.
207
CATALYZED EPOXY: Crosslinking resins made by the reaction of epoxides with other
material such as amines, alcohols, phenols, carboxylic acids and unsaturated
compounds.
209
CHLORINATED RUBBER: Resin formed by the reaction of rubber with chlorine.
212
COATING: A material applied onto or impregnated into a substrate for protective,
decorative, or functional purposes. Such materials include, but are not limited to, paints,
varnishes, sealers, and stains.
213
COLORANT: A concentrated pigment dispersion in water, solvent, and/or binder that is
added to an architectural coating after packaging in sale units to produce the desired
color.
208
214
CONCRETE CURING COMPOUNDS: Coatings whose sole purpose is to retard the
evaporation of water from the surface of freshly cast concrete, thereby strengthening it.
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A coating labeled and formulated for application to freshly poured concrete to perform
one or more of the following functions:
214.1 Retard the evaporation of water; or
214.2 Harden or dustproof the surface of freshly poured concrete.
215
CONCRETE/MASONRY SEALER: A clear or opaque coating that is labeled and
formulated primarily for application to concrete and masonry surfaces to perform one
or more of the following functions:
215.1 Prevent penetration of water; or
215.2 Provide resistance against abrasion, alkalis, acids, mildew, staining, or ultraviolet
light; or
215.3 Harden or dustproof the surface of aged or cured concrete.
216
CONCRETE SURFACE RETARDER: A mixture of retarding ingredients such as extender
pigments, primary pigments, resin, and solvent that interact chemically with the cement
to prevent hardening on the surface where the retarder is applied, allowing the retarded
mix of cement and sand at the surface to be washed away to create an exposed
aggregate finish.
217
CONJUGATED OIL VARNISH: A clear or semi-transparent wood coating, labeled as
such, excluding lacquers or shellacs, based on a natural occurring conjugated vegetable
oil (Tung oil) and modified with other natural or synthetic resins; a minimum of fifty
percent of the resin solids consisting of conjugated oil. Supplied as a single component
product, conjugated oil varnishes penetrate and seal the wood. Film formation is due to
polymerization of the oil. These varnishes may contain small amounts of pigment to
control the final gloss or sheen.
218
CONVERSION VARNISH: A clear acid curing coating with an alkyd or other resin blended
with amino resins and supplied as a single component or two-component product.
Conversion varnishes produce a hard, durable, clear finish designed for professional
application to wood flooring. This film formation is the result of an acid-catalyzed
condensation reaction, affecting transetherification at the reactive ethers of the amino
resins.
219
DRIVEWAY SEALER: A coating labeled and formulated for application to worn asphalt
driveway surfaces to perform one or more of the following functions:
219.1 Fill cracks; or
219.2 Seal the surface to provide protection; or
219.3 Restore or preserve the appearance.
210
220
DRY FOG COATINGS: Coatings which are formulated so that when sprayed, overspray
droplets dry before falling on floors and other surfaces. A coating labeled and
formulated only for spray application such that overspray droplets dry before
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subsequent contact with incidental surfaces in the vicinity of the surface coating
activity.
211
221
ENAMEL UNDERCOATERS: A coatings which are is designed to be applied to a new
surface over a primer or over a previous coat of paint, in order to improve the seal,
provide better adhesion and make a smooth base for non-flat coatings.
222
EXEMPT COMPOUND: The federally listed non-precursor organic compounds, which
have been determined to have negligible photochemical reactivity as listed in 40 CFR
51.100(s)(1) and in Appendix G (Incorporated Materials) of the MCAPCR.
223
FAUX FINISHING COATING: A coating labeled and formulated to meet one or more of
the following criteria:
223.1 A glaze or textured coating used to create artistic effects including, but not
limited to: dirt, suede, old age, smoke damage, and simulated marble and wood
grain;
223.2 A decorative coating used to create a metallic, iridescent, or pearlescent
appearance that contains at least 48 grams of pearlescent mica pigment or other
iridescent pigment per liter of coating as applied (at least 0.4 pounds per gallon);
223.3 A decorative coating used to create a metallic appearance that contains less
than 48 grams of elemental metallic pigment per liter of coating as applied (less
than 0.4 pounds per gallon), when testing in accordance with SCAQMD Method
318-95, incorporated by reference in Section 503.8;
223.4 A decorative coating used to create a metallic appearance that contains greater
than 48 grams of elemental metallic pigment per liter of coating as applied
(greater than 0.4 pounds per gallon) and which requires a clear topcoat to
prevent the degradation of the finish under normal use conditions. The metallic
pigment content shall be determined in accordance with SCAQMD Method 318-
95, incorporated by reference in Section 503.8; or
223.5 A clear topcoat to seal and protect a Faux Finishing coating that meets the
requirements in Sections 223.1 through 223.4. These clear topcoats must be
sold and used solely as part of a Faux Finishing coating system and must be
labeled in accordance with Section 308.4(a).
224
FIRE-RESISTIVE COATING: A coating labeled and formulated to protect the structural
integrity by increasing the fire endurance of interior or exterior steel and other structural
materials. The Fire Resistive category includes sprayed fire resistive materials and
intumescent fire resistive coatings that are used to bring structural materials, into
compliance with federal, state, and local building code requirements. The Fire-Resistive
coating and testing agency must be approved by building code officials. The Fire-
Resistive coating shall be tested in accordance with ASTM E119-18ce1, incorporated by
reference in Section 503.5.
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212
FIRE RETARDANT COATINGS: Coatings which are designed to retard fires and which will
significantly:
212.1 Reduce the rate of flame spread on the surface of a material to which such a
coating has been applied; or
212.2 Resist ignition when exposed to high temperature; or
212.3 Insulate a substrate to which such a coating has been applied and prolong the
time required for the substrate to reach ignition temperature.
213
225
FLAT COATINGS: A coating that is not defined under any other definition in this rule and
that registers gloss less than 15 on an 85-degree meter or less than five on a 60-degree
meter according to ASTM D523-14 (2018), incorporated by reference in Section 503.6.
Coatings which register gloss less than 15 on an 85° meter or less than 5 on a 60°
meter, or which is labeled as a flat coating.
226
FLOOR COATING: An opaque coating that is labeled and formulated for application to
flooring, including, but not limited to, decks, porches, steps, garage floors, and other
horizontal surfaces, which may be subjected to foot traffic.
227
FORM-RELEASE COMPOUND: A coating labeled and formulated for application to a
concrete form to prevent the freshly poured concrete from bonding to the form. The
form may consist of wood, metal, or some material other than concrete.
214
GENERAL PRIMERS: Coatings which are intended to be applied to a surface to provide a
firm bond between the substrate and subsequent coats.
215
GENERAL SEALERS: Coatings which are intended for use on porous substrates to
protect the substrate, to prevent subsequent coatings from being absorbed by the
substrate, or to prevent harm to subsequent coatings by materials in the substrate.
216
GENERAL UNDERCOATERS: Coating which are designed to provide a smooth surface
for subsequent coats.
217
228
GRAPHIC ARTS COATINGS (SIGN PAINTS): A coating labeled and formulated for hand-
application by artists using brush, airbrush or roller techniques to indoor and outdoor
signs (excluding structural components) and murals including letter enamels, poster
colors, copy blockers, and bulletin enamels. Coatings which are marketed solely for
application to indoor and outdoor signs and include lettering enamels, poster colors and
bulletin colors.
229
HIGH-TEMPERATURE COATING: A high-performance coating labeled and formulated
for application to substrates exposed continuously or intermittently to temperatures
above 400° F (204° C).
230
IMPACTED IMMERSION COATING: A high-performance maintenance coating
formulated and recommended for application to steel structures subject to immersion
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in turbulent, debris-laden water. These coatings are specifically resistant to high-energy
impact damage by floating ice or debris.
218
INDUSTRIAL MAINTENANCE PRIMERS: Coatings which are intended to be applied to a
surface prior to the application of an industrial maintenance topcoat, to provide a firm
bond between the substrate and subsequent coats.
219
INDUSTRIAL MAINTENANCE TOPCOATS: High performance coatings which are
formulated for the purpose of heavy abrasion, water immersion, chemical, corrosion,
temperature, electrical or solvent resistance.
231
INDUSTRIAL MAINTENANCE COATING: A high-performance architectural coating,
including primers, sealers, undercoaters, intermediate coats, and topcoats, formulated
for application to substrates, including floors, exposed to one or more of the following
extreme environmental conditions listed below and labeled as specified in Section
308.4(b):
231.1 Immersion in water, wastewater, or chemical solutions (aqueous and non-
aqueous solutions), or chronic exposures of interior surfaces to moisture
condensation; or
231.2 Acute or chronic exposure to corrosive, caustic, or acidic agents, or to chemicals,
chemical fumes, or chemical mixtures or solutions; or
231.3 Frequent exposure to temperatures above 250° F (121° C); or
231.4 Frequent heavy abrasion, including mechanical wear and frequent scrubbing with
industrial solvents, cleansers, or scouring agents; or
231.5 Exterior exposure of metal structures and structural components.
220
INORGANIC POLYMERS: Substances whose principle structural features are made of
homopolar inter-linkages between multivalent elements other than carbon. This does
not preclude the presence of carbon-containing groups in the side branches, or as inter-
linkages between principle structural members. Examples of such polymers are ethyl
and butyl silicates.
221
232
LACQUERS: Clear or pigmented opaque wood coatings, including clear lacquer sanding
sealers, formulated with nitrocellulose or synthetic resins to dry by evaporation without
chemical reaction and to provide a quick drying, solid, protective film.
233
LOW-SOLIDS COATING: A coating containing 1 pound or less of solids per gallon (0.12
kilogram or less of solids per liter) of coating material as recommended for application
by the manufacturer. The VOC content for Low-Solids Coatings shall be calculated in
accordance with Section 502.5.
234
MAGNESITE CEMENT COATING: A coating labeled and formulated for application to
magnesite cement decking to protect the magnesite cement substrate from erosion by
water.
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235
MANUFACTURER’S MAXIMUM RECOMMENDATION: The maximum recommendation
for thinning that is indicated on the label or lid of the coating container.
222
236
MASTIC TEXTURE COATINGS: A coating labeled and formulated to cover holes and
minor cracks and to conceal surface irregularities and is applied in a single coat of at
least 10 mils (at least 0.010 inch) dry film thickness. Coatings, except weatherproof
mastic coatings, which are formulated to cover holes, minor cracks and to conceal
surface irregularities.
237
MEDIUM DENSITY FIBERBOARD (MDF): A composite wood product, panel, molding, or
other building material composed of cellulosic fibers (usually wood) made by dry
forming and pressing of resonated fiber mat.
238
METALLIC PIGMENTED COATING: A coating that is labeled and formulated to provide a
metallic appearance. Metallic Pigmented coatings must contain at least 48 grams of
elemental metallic pigment (excluding zinc) per liter of coating as applied (at least 0.4
pounds per gallon), when tested in accordance with SCAQMD Method 318-95,
incorporated by reference in Section 503.8. The Metallic Pigmented Coating category
does not include Roof Coatings or Zinc-Rich Primers.
223
METALLIC PIGMENTED PAINTS: Any coatings which are formulated with metallic
pigment and which contain more than 10 grams of metal particles per liter of coating
(0.08 lb/gal) as applied where such metal particles are visible in the dried film.
224
239
MULTI-COLORED COATINGS: A coating that is packaged in a single container and that
is labeled and formulated to exhibit more than one color when applied in a single coat.
Coatings which exhibit more than one color when applied and which are packaged in a
single container and applied in a single coat.
225
240
NON-FLAT COATINGS: A coating that does not meet the criteria under any other
definition in this rule and that registers a gloss of 15 or greater on an 85-degree meter
and 5 or greater on a 60-degree meter according to ASTM D523-14 (2018), incorporated
by reference in Section 503.6. Coatings which register gloss of 15 or greater on an 85°
meter or 5 or greater on a 60° meter, or which are identified on the label as gloss, semi-
gloss, or eggshell enamel coatings.
241
NON-FLAT HIGH GLOSS COATING: A non-flat coating that registers a gloss of 70 or
greater on a 60-degree meter according to ASTM D523-14 (2018), incorporated by
reference in Section 503.6. Non-Flat High Gloss coatings must be labeled in accordance
with Section 308.4(c).
242
NUCLEAR COATING: A protective coating formulated and recommended to seal porous
surfaces such as steel (or concrete) that otherwise would be subject to intrusion by
radioactive materials. These coatings must be resistant to long-term (service life)
cumulative radiation exposure according to ASTM D4082-02 (incorporated by reference
into Section 503.15), relatively easy to decontaminate, and resistant to various
chemicals to which the coatings are likely to be exposed according to ASTM D3912-95
(2001) (incorporated by reference into Section 503.16).
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226
243
OPAQUE STAINS: All stains that are not classified as semitransparent stains.
227
244
OPAQUE WOOD PRESERVATIVES: All wood preservatives that are not classified as
semitransparent wood preservatives.
228
ORGANIC COMPOUND: Any compound of carbon excluding carbon monoxide, carbon
dioxide, carbonic acid, metallic carbides and carbonates and ammonium carbonate.
245
PARTICLEBOARD: A composite wood product panel, molding, or other building material
composed of cellulosic material (usually wood) in the form of discrete particles, as
distinguished from fibers, flakes, or strands, which are pressed together with resin.
246
PEARLESCENT: Exhibiting various colors depending on the angles of illumination and
viewing, as observed in mother-of-pearl.
247
PLYWOOD: A panel product consisting of layers of wood veneers or composite core
pressed together with resin. Plywood includes panel products made by either hot or
cold pressing (with resin) veneers to a platform.
248
POST-CONSUMER COATING: Finished coatings generated by a business or consumer
that have served their intended end uses and are recovered from or otherwise diverted
from the waste stream for the purpose of recycling.
249
PRE-TREATMENT WASH PRIMER: A primer which contains at least one-half percent
acid, by weight, when tested in accordance with ASTM D1613-17 (incorporated by
reference in Section 503.1), that is labeled and formulated for application directly to
bare metal surfaces to provide corrosion resistance and to promote adhesion of
subsequent topcoats.
250
PRIMER, SEALER, AND UNDERCOATER: A coating labeled and formulated for one or
more of the following purposes:
250.1 To provide a firm bond between the substrate and the subsequent coatings;
250.2 To prevent subsequent coatings from being absorbed by the substrate;
250.3 To prevent harm to subsequent coatings by materials in the substrate;
250.4 To provide a smooth surface for the subsequent application of coatings;
250.5 To provide a clear finish coat to seal the substrate; or
250.6 To block materials from penetrating into or leaching out of a substrate.
229
251
QUICK-DRY ENAMELS: Non-flat coatings that is formulated to have which comply with
the following:
229.1
251.1 Should be capable of being applied directly from the container by brush or roller
when the ambient temperature is between 60° F and 80° F.
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229.2
251.2 When tested in accordance with ASTM D1640 (1999) they shall: set to touch in
two hours or less, dry hard in eight hours or less, and be tack-free in four hours or
less by the mechanical method test.
229.3
251.3 Shall have a 60-meter dried film gloss of no less than 70.
230
QUICK-DRY PRIMERS AND SEALERS: Primers, sealers and undercoaters which are
intended to be applied to a surface to provide a firm bond between the substrate and
subsequent coats and which are dry to the touch in one-half hour and can be recoated
in two hours (ASTM 1640).
252
REACTIVE PENETRATING CARBONATE STONE SEALER: A clear or pigmented coating
that is labeled and formulated for application to above-grade carbonate stone
substrates to provide protection from water and waterborne contaminants, including but
not limited to, alkalis, acids, and salts. Reactive Penetrating Carbonate Stone Sealers
must penetrate into carbonate stone substrates and chemically react to form covalent
bonds with naturally occurring minerals in the substrate. Reactive Penetrating
Carbonate Stone Sealers line the pores of carbonate stone substrates with a
hydrophobic coating, but do not form a surface film. Reactive Penetrating Carbonate
Stone Sealers must meet all the following criteria:
252.1 Must improve water repellency at least 80 percent after application on a
carbonate stone substrate. This performance must be verified on standardized
test specimens, in accordance with one or more of the following standards:
ASTM C67/C67M-18, or ASTM C97/C97M-18, or ASTM C140/C140M-18a
(incorporated by reference in Section 503.11);
252.2 Must not reduce the water vapor transmission rate by more than 10 percent after
application on a carbonate stone substrate. This performance must be verified
on standardized test specimens, in accordance with ASTM E96/E96M-16
(incorporated by reference in Section 503.12); and
252.3 Must be labeled as such, in accordance with the labeling requirements in Section
308.4(d).
253
REACTIVE PENETRATING SEALER: A clear or pigmented coating that is labeled and
formulated for application to above-grade concrete and masonry substrates to provide
protection from water and waterborne contaminants, including but not limited to, alkalis,
acids, and salts. Reactive Penetrating Sealers must meet all the following criteria:
253.1 Line the pores of concrete and masonry substrates with a hydrophobic coating,
but do not form a surface film.
253.2 Penetrate into concrete and masonry substrates and chemically react to form
covalent bonds with naturally occurring minerals in the substrate.
253.3 Improve water repellency at least 80 percent after application on a concrete or
masonry substrate. This performance must be verified on standardized test
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specimens per ASTM C67/C67M-18, or ASTM C97/C97M-18, or ASTM
C140/C140M-18a (incorporated by reference in Section 503.11); and
253.4 Not reduce the water vapor transmission rate by more than 2 percent after
application on a concrete or masonry substrate. This performance must be
verified on standardized test specimens, in accordance with ASTM E96/E96M-16
(incorporated by reference in Section 503.12); and
253.5 Products labeled and formulated for vehicular traffic surface chloride screening
applications must meet the performance criteria listed in the National
Cooperative Highway Research Report 244 (1981), incorporated by reference in
Section 503.13.
253.6 Must be labeled as such, in accordance with the labeling requirements in Section
308.4(e).
254
RECYCLING COATING: An architectural coating formulated such that it contains a
minimum of 50 percent by volume post-consumer coating, with a maximum of 50
percent by volume secondary industrial materials or virgin materials.
255
RESIDENTIAL: Areas where people reside or lodge, including, but not limited to, single
and multiple family dwellings, condominiums, mobile homes, apartment complexes,
motels, and hotels.
231
256
ROOF COATINGS: A non-bituminous coating labeled and formulated for application to
roofs and for the primary purpose of preventing penetration or reflecting heat and
ultraviolet radiation. Coatings which are formulated for the sole purpose of preventing
penetration of the substrate by water. These coatings include bituminous roof and
waterproof mastic coatings.
257
RUST PREVENTATIVE COATING: A coating formulated to prevent the corrosion of metal
surfaces for one or more of the following applications:
257.1 Direct-to-metal coating; or
257.2 Coating intended for application over rusty, previously coated surfaces.
257.3 The Rust Preventative category does not include the following:
a. Coatings that are required to be applied as a topcoat over a primer; or
b. Coatings that are intended for use or used on wood or any other nonmetallic
surface. Rust Preventative coatings are for metal substrates only and must be
labeled as such, in accordance with the labeling requirements in Section
308.4(f).
258
SECONDARY INDUSTRIAL MATERIALS: Products or by-products of the paint
manufacturing process that are of known composition and have economic value but
can no longer be used for their intended use.
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259
SEMI-TRANSPARENT COATING: A coating that contains binders and colored pigments
and is formulated to change the color of the surface, but not conceal the grain pattern
or texture.
232
260
SEMI-TRANSPARENT STAINS: Coatings which are formulated to change the color of a
surface but not conceal the surface.
233
261
SEMI-TRANSPARENT WOOD PRESERVATIVES: Wood preservative stains which are
formulated for the purpose of protecting exposed wood from decay or insect attack by
the addition of a wood preservative chemical and which change the color of a surface
but do not conceal the surface. These coatings perform their function by penetrating
into the wood.
234
262
SHELLACS: A clear or opaque coating formulated solely with the resinous secretions of
the lac beetle (Laciffer lacca) and formulated to dry by evaporation without a chemical
reaction. Clear or pigmented coatings formulated with natural resins (except
nitrocellulose resins), thinned with alcohol, formulated to dry by evaporation without a
chemical reaction and intended to provide stain blocking properties as well as a solid
protective film.
263
SHOP APPLICATION: Application of a coating to a product or a component of a product
in or on the premises of a factory or a shop as part of a manufacturing, production, or
repairing process (e.g., original equipment manufacturing coatings).
235
SILICONES: A resin containing silicon unlike organic resins, which all contain carbon.
The basic structure of silicones consist of silicon-oxygen linkages.
264
SOLICIT: To require for use or to specify, by written or oral contract.
236
265
SPECIALTY FLAT PRODUCTS: Self-priming flat products used only to perform one of
the following functions: repair fire, smoke, or water damage; neutralize odors; block
stains; or coat acoustical materials without affecting their acoustical abilities.
237
266
SPECIALTY PRIMERS, SEALERS, AND UNDERCOATERS: A coating that is formulated
for application to a substrate to block water-soluble stains resulting from: fire damage,
smoke damage, or water damage. Specialty Primers, Sealers, and Undercoaters must be
labeled in accordance with Section 308.4(g). Primers, sealers and undercoaters used
only to perform one of the following functions: repair fire, smoke or water damage;
neutralize odors; block stains; block efflorescence; condition chalky surfaces; or coat
acoustical materials without affecting their acoustical abilities.
267
STAIN: A semitransparent or opaque coating labeled and formulated to change the
color of a surface but not conceal the grain pattern or texture. Stains labeled and
formulated exclusively for use on interior surfaces are only subject to VOC limits for
Interior stains.
268
STATIONARY STRUCTURE: Structures that are designed to be stationary when
operating and are not designed or constructed to be moved from place-to-place.
Examples include but are not limited to:
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268.1 Bridges.
268.2 Curbs.
268.3 Factories.
268.4 Homes.
268.5 Large storage tanks.
268.6 Mobile homes.
268.7 Office buildings.
268.8 Pavement.
268.9 Racetracks.
268.10 Roadways.
268.11 Silos.
268.12 Transformers.
268.13 Utility towers.
269
STONE CONSOLIDANT: A coating that is labeled and formulated for application to
stone substrates to repair historical structures that have been damaged by weathering
or other decay mechanisms. Stone Consolidants must penetrate into stone substrates
to create bonds between particles and consolidate deteriorated material. Stone
Consolidants must be specified and used in accordance with ASTM E2167-01,
incorporated by reference in Section 503.14. Stone Consolidants are for professional
use only and must be labeled as such, in accordance with the labeling requirements in
Section 308.4(h).
238
270
SWIMMING POOL COATINGS: A coating labeled and formulated to coat the interior of
swimming pools and to resist swimming pool chemicals. Swimming pool coatings
include coatings used for swimming pool repair and maintenance. Coatings specifically
formulated to coat the interior of swimming pools and resist swimming pool chemicals.
271
THERMOPLASTIC RUBBER COATING AND MASTIC: A coating or mastic formulated
and recommended for application to roofing or other structural surfaces and that
incorporates no less than 40 percent by weight of thermoplastic rubbers in the total
resin solids and may also contain other ingredients including, but not limited to, fillers,
pigments, and modifying resins.
272
TINT BASE: An architectural coating to which colorant is added after packaging in sale
units to produce a desired color.
239
TILE-LIKE GLAZE COATINGS: Coatings which are formulated to provide a tough, extra-
durable coating system, which are applied as a continuous (seamless) highbuild film
and which cure to a hard glaze finish.
240
273
TRAFFIC MARKING COATINGS: A coating labeled and formulated for marking and
striping streets, highways, or other traffic surfaces including, but not limited to, curbs,
berms, driveways, parking lots, sidewalks, and airport runways. Coatings which are
formulated to be applied to public streets, highways, and other surfaces including, but
not limited to curbs, berms, driveways, and parking lots.
274
TUB AND TILE REFINISH COATING: A clear or opaque coating that is labeled and
formulated exclusively for refinishing the surface of a bathtub, shower, sink, or
countertop. Tub and Tile Refinish coatings must meet all of the following criteria:
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274.1 The coating must have a scratch hardness of 3H or harder and a gouge hardness
of 4H or harder. This must be determined on Bonderite 1000, in accordance with
ASTM D3363-05 (2011)e2, incorporated by reference in Section 503.21.
274.2 The coating must have a weight loss of 20 milligrams or less after 1000 cycles.
This must be determined with CS-17 wheels on Bonderite 1000, in accordance
with ASTM D4060-14, incorporated by reference in Section 503.19.
274.3 The coating must withstand 1000 hours or more of exposure with few or no #8
blisters. This must be determined on unscribed Bonderite, in accordance with
ASTM D4585-99 and ASTM D714-02, incorporated by reference in Section
503.22.
274.4 The coating must have an adhesion rating of 4B or better after 24 hours of
recovery. This must be determined on unscribed Bonderite, in accordance with
ASTM D4585-/D4585M-18 and ASTM D3359-17, incorporated by reference in
Section 503.20.
241
UNIQUE VEHICLES: Generic polymer components not defined by any of the coatings
listed in the category of industrial primers and topcoats in Section 305 of this rule, e.g.,
hypalon, phenoxy.
242
URETHANE POLYMERS: Coating vehicles containing a polyisocyanatemonomer reacted
in such a manner as to yield polymers containing any ratio, proportion, or combination
of urethane linkages, active isocyanate groups, or polyisocyanate monomer.
243
275
VARNISHES: Clear or pigmented coatings formulated with various resins to dry by
chemical reaction or exposure to air. These coatings are intended to provide a durable,
transparent or translucent, solid protective film.
276
VENEER: Thin sheets of wood peeled or sliced from logs for use in the manufacture of
wood products such as plywood, laminated veneer lumber, or other products.
244
VINYL CHLORIDE POLYMERS: Polymers made by the polymerization of vinyl chloride or
copolymerization of vinyl chloride with other unsaturated compounds, the vinyl chloride
being in greatest amount by weight.
277
VIRGIN MATERIALS: Materials that contain no post-consumer coatings or secondary
industrial materials.
278
VOC ACTUAL: The weight of VOC per volume of coating, as calculated acceding to the
formula in Section 502.5 of this rule. VOC Actual must include maximum amount of
thinning solvent recommended by the manufacturer.
279
VOC CONTENT: The weight of VOC per volume of coating. VOC Content is VOC
Regulatory, as defined in Section 280, for all coatings except those in the Low Solids
category. For coatings in the Low Solids category, the VOC Content is VOC Actual, as
defined in Section 278. If the coating is a multi-component product, the VOC content is
VOC Regulatory as mixed or catalyzed. If the coating contains silanes, siloxanes, or
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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other ingredients that generate ethanol or other VOCs during the curing process, the
VOC content must include the VOCs emitted during curing. VOC Content must include
maximum amount of thinning solvent recommended by the manufacturer. The term
VOC content is a general term used throughout the rule and includes VOC, VOC Actual,
and VOC Regulatory.
280
VOC REGULATORY: The weight of VOC per volume of coating, less the volume of water
and exempt compounds, as calculated according to the formula in Section 502.6 of this
rule. VOC regulatory includes maximum amount of thinning solvent recommended by
the manufacturer.
281
VOLATILE ORGANIC COMPOUND (VOC): See definition in MCAPCR Rule 100 (General
Provisions and Definitions).
245
282
WATERPROOFING MASTIC COATINGS: Weatherproof and waterproof coatings which
are formulated to cover holes and minor cracks and to conceal surface irregularities.
283
WATERPROOFING MEMBRANE: A clear or opaque coating that is labeled and
formulated for application to concrete and masonry surfaces to provide a seamless
waterproofing membrane that prevents any penetration of liquid water into the
substrate. Waterproofing Membranes are intended for the following waterproofing
applications: below-grade surfaces, between concrete slabs, inside tunnels, inside
concrete planters, and under flooring materials. Waterproofing Membranes must meet
the following criteria:
283.1 Coating must be applied in a single coat of at least 25 mils (at least 0.025 inch)
dry film thickness; and
283.2 Coatings must meet or exceed the requirements contained in ASTM
C836/C836M-18, incorporated by reference in Section 503.23.
283.3 The Waterproofing Membrane category does not include topcoats that are
included in the Concrete/Masonry Sealer category (e.g., parking deck topcoats,
pedestrian deck topcoats, etc.).
246
284
WATERPROOF SEALERS: Coatings which are formulated for the sole purpose of
protecting porous substrates by preventing the penetration of water.
285
WOOD COATING: Coatings labeled and formulated for application to wood substrates
only. The Wood Coatings category includes the following clear and semitransparent
coatings: lacquers; varnishes; sanding sealers; penetrating oils; clear stains; wood
conditioners used as undercoats; and wood sealers used as topcoats. The Wood
Coatings category also includes the following opaque wood coatings; opaque lacquers;
opaque sanding sealers; and opaque lacquer undercoaters. The Wood Coatings
category does not include the following: clear sealers that are labeled and formulated
for use on concrete/masonry surfaces; or coatings intended for substrates other than
wood. Wood Coatings must be labeled “For Wood Substrates Only”, in accordance with
Section 308.4(i).
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286
WOOD PRESERVATIVE: A coating labeled and formulated to protect exposed wood
from decay or insect attack, that is registered with both the EPA under the Federal
Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. Section 136, et. seq.) and with the
Arizona Department of Agriculture Pest Management Division.
287
WOOD SUBSTRATE: A substrate made of wood, particleboard, plywood, medium
density fiberboard, rattan, wicker, bamboo, or composite products with exposed wood
grain. Wood Products do not include items comprised of simulated wood.
288
ZINC-RICH PRIMER: A coating that meets all of the following specifications:
288.1 Coating contains at least 65 percent metallic zinc powder or zinc dust by weight
of total solids; and
288.2 Coating is formulated for application to metal substrates to provide a firm bond
between the substrate and subsequent applications of coatings; and
288.3 Coating is intended for professional use only and labeled as such, in accordance
with the labeling requirements in Section 308.4(j).
SECTION 300 – STANDARDS
301
VOC CONTENT LIMITS:
301.1 No person shall manufacture, blend, or repackage for sale within Maricopa
County any architectural coating with a VOC content in excess of the limits as
specified in Table 335-1.
301.2 No person shall supply, sell, or offer for sale within Maricopa County any
architectural coating with a VOC content in excess of the limits as specified in
Table 335-1, except as provided for in Section 304.
301.3 No person shall solicit for application or apply within Maricopa County any
architectural coating with a VOC content in excess of the limits as specified in
Table 335-1, except as provided for in Section 304.
301
PROHIBITION - BITUMINOUS PAVEMENT SEALERS: No person shall apply, sell, offer for
sale or manufacture for sale within Maricopa County any architectural coating
manufactured after July 13, 1988, which is recommended for use as a bituminous
pavement sealer unless it is an emulsion type coating.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Table 335-1: VOC Content Limits for Architectural Coatings1
Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Flat Coatings
250
2.1
50
0.4
Non-Flat Coatings
250
2.1
100
0.8
Non-Flat – High Gloss Coatings
N/A
N/A
150
1.3
Specialty Coatings
Aluminum Roof Coatings
N/A
N/A
450
3.8
Basement Specialty Coatings
N/A
N/A
400
3.3
Bituminous Roof Coatings
N/A
N/A
270
2.3
Bituminous Roof Primers
N/A
N/A
350
2.9
Bond Breakers
N/A
N/A
350
2.9
Calcimine Recoaters
N/A
N/A
475
4.0
Concrete Curing Compounds
350
2.9
350
2.9
Concrete/Masonry Sealers
N/A
N/A
100
0.8
Concrete Surface Retarders
N/A
N/A
780
6.5
Conjugated Oil Varnishes
N/A
N/A
450
3.6
Conversion Varnishes
N/A
N/A
725
6.1
Driveway Sealers
N/A
N/A
50
0.4
Dry Fog Coatings
420 (Flat)
400 (Non-Flat)
3.5 (Flat)
3.3 (Non-Flat)
150
1.3
Enamel Undercoaters
350
2.9
N/A
N/A
Faux Finishing Coatings
N/A
N/A
350
2.9
Fire-Resistive Coatings
N/A
N/A
350
2.9
Floor Coatings
N/A
N/A
100
0.8
1 Limits are expressed as VOC Regulatory, thinned to the manufacturer’s maximum thinning recommendation, excluding any colorant added to tint
bases.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Form-Release Compounds
N/A
N/A
250
2.1
Graphic Arts Coatings (Sign
Paints)
N/A
N/A
500
4.2
High-Temperature Coatings
N/A
N/A
420
3.5
Impacted Immersion Coatings
N/A
N/A
780
6.5
Industrial Maintenance Coatings
Primers and Topcoats
Alkyds
Catalyzed Epoxy
Bituminous Coating Materials
Inorganic Polymers
Chlorinated Rubbers
Acrylic Polymers
Silicones
Unique Vehicles
420
3.5
250
2.1
Lacquers
684
5.7
N/A
N/A
Low-Solids Coatings
N/A
N/A
120
1.0
Magnesite Cement Coatings
N/A
N/A
450
3.8
Mastic Texture Coatings
N/A
N/A
100
0.8
Metallic Pigmented Coatings
N/A
N/A
500
4.2
Multi-Color Coatings
N/A
N/A
250
2.1
Nuclear Coatings
N/A
N/A
450
3.8
Opaque Stains
350
2.9
N/A
N/A
Opaque Wood Preservatives
350
2.9
N/A
N/A
Pre-Treatment Wash Primers
N/A
N/A
420
3.5
General Primers, Sealers, and
Undercoaters
350
2.9
100
0.8
Quick-Dry Enamels
395
3.3
N/A
N/A
Reactive Penetrating Sealers
N/A
N/A
350
2.9
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Reactive Penetrating Carbonate
Stone Sealers
N/A
N/A
500
4.2
Recycled Coatings
N/A
N/A
250
2.1
Roof Coatings
300
2.5
250
2.1
Rust Preventative Coatings
N/A
N/A
250
2.1
Semi-Transparent Stains
350
2.9
N/A
N/A
Semi-Transparent and Clear Wood
Preservatives
350
2.9
N/A
N/A
Shellacs – Clear
N/A
N/A
730
6.1
Shellacs – Opaque
N/A
N/A
550
4.6
Specialty Flat Products
395
3.3
N/A
N/A
Specialty Primers, Sealers, and
Undercoaters
350
2.9
100
0.8
Stains, All
350
2.9
250
2.1
Stone Consolidants
N/A
N/A
450
3.8
Swimming Pool Coatings
N/A
N/A
340
2.8
Thermoplastic Rubber Coatings
and Mastics
N/A
N/A
550
4.6
Traffic Marking Coatings
Applied to Public Streets and
Highways
Applied to other Surfaces
Black Traffic Coatings
250
2.1
100
0.8
Tub and Tile Refinish
N/A
N/A
420
3.5
Varnishes
350
2.9
N/A
N/A
Waterproofing Mastic Coatings
300
2.5
N/A
N/A
Waterproofing Membranes
N/A
N/A
250
2.1
Waterproof Sealers
395
3.3
N/A
N/A
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Wood Coatings
N/A
N/A
275
2.3
Wood Preservatives Except Below
Ground
350
2.9
350
2.9
Zinc-Rich Primers
N/A
N/A
340
2.8
302
COATING CATEGORIZATION: For any coating that does not meet any of the definitions
for the specialty coatings categories listed in Table 335-1, the VOC content limit shall be
determined by classifying the coating as a Flat, Non-Flat, or Non-Flat High Gloss coating
based on its gloss, as defined in Section 200 and the corresponding Flat, Non-Flat or
Non-Flat High Gloss coating VOC content limit in Table 335-1 shall apply.
302
INTERIM LIMITS - NON-FLAT ARCHITECTURAL COATINGS: No person shall apply, sell,
offer for sale or manufacture for sale within Maricopa County any non-flat architectural
coating manufactured after July 13, 1989, which contains more than 3.2 lbs (380 g/l) of
volatile organic compounds per gallon of coating, excluding water and any colorant
added to tint bases. These limits do not apply to specialty coatings listed in Section 305
of this rule.
303
MOST RESTRICTIVE VOC CONTENT LIMIT: Except for the specialty coating categories
specified below, if a coating is recommended for use in more than one of the specialty
coating categories listed in Table 335-1, then the most restrictive (or lowest) specialty
coating VOC content limit shall apply. This requirement applies to usage
recommendations that appear on the coating container, anywhere on any label or
sticker affixed to the container, or in any sales, advertising, or technical literature
supplied by a manufacturer or anyone acting on their behalf.
303.1 Aluminum roof coatings.
303.2 Bituminous roof primers.
303.3 High-temperature coatings.
303.4 Industrial maintenance coatings.
303.5 Low-solids coatings.
303.6 Metallic pigmented coatings.
303.7 Pre-treatment wash primers.
303.8 Shellacs.
303.9 Specialty primers, sealers, and undercoaters.
303.10 Wood coatings.
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303.11 Wood preservatives.
303.12 Zinc-rich primers.
303
FINAL LIMITS - NON-FLAT ARCHITECTURAL COATINGS: No person shall apply, sell,
offer for sale or manufacture for sale within Maricopa County any non-flat architectural
coating manufactured after July 13, 1990, which contains more than 2.1 lbs (250 g/l) of
volatile organic compounds per gallon of coating, excluding water and any colorant
added to tint bases. These limits do not apply to specialty coatings listed in Section 305
of this rule.
304
SELL-THROUGH OF COATINGS: A coating manufactured prior to the effective date
specified for that coating in Table 335-1, and that complied with the standards in effect
at the time the coating was manufactured may be sold, supplied, or offered for sale for
up to three years after the specified effective date. In addition, a coating manufactured
before the effective date specified for that coating in Table 335-1 may be applied at any
time, both before and after the specified effective date, so long as the coating complied
with the standards in effect at the time the coating was manufactured. This Section
does not apply to any coating that does not display the date or date code required by
Section 308.
304
LIMITS - FLAT ARCHITECTURAL COATINGS: No person shall apply, sell, offer for sale or
manufacture for sale within Maricopa County any flat architectural coating
manufactured after July 13, 1989, which contains more than 2.1 lbs (250 g/l) of volatile
organic compounds per gallon of coating, excluding water and any colorant added to
tint bases. These limits do not apply to specialty coatings listed in Section 305 of this
rule.
305
THINNING: No person who applies or solicits the application of any architectural
coating shall apply a coating that is thinned to exceed the applicable VOC limit specified
in Table 335-1.
305
LIMITS - SPECIALTY COATINGS: No person shall apply, sell, offer for sale or
manufacture for sale within Maricopa County any architectural coating that exceeds the
following limits manufactured after the date listed below. Limits are expressed in
pounds of VOC per gallon of coating as applied, excluding water and any colorant added
to tint bases.
Effective Dates
7/13/89
7/13/90
7/13/91
COATING
(lb/gal)
Concrete Curing Compounds
-
-
2.9
Dry Fog Coating
Flat
4.6
-
3.5
Non-flat
3.5
-
3.3
Enamel Undercoaters
3.8
-
2.9
General
Primers,
Sealers
and
Undercoaters
3.3
-
2.9
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Industrial Maintenance Primers and
Topcoats
Alkyds
4.2
3.5
3.5
Catalyzed Epoxy
-
4.2
3.5
Bituminous Coating Materials
-
-
3.5
Inorganic Polymers
-
-
3.5
Vinyl Chloride Polymers
-
-
3.5
Chlorinated Rubbers
-
-
3.5
Acrylic Polymers
-
3.5
3.5
Urethane Polymers
-
3.5
3.5
Silicones
-
-
3.5
Unique Vehicles
-
-
3.5
Lacquers
-
-
5.7
Opaque Stains
3.3
-
2.9
Wood Preservatives
-
-
2.9
Quick Dry Enamels
-
-
3.3
Roof Coatings
-
-
2.5
Semi-transparent Stains
-
-
2.9
Semi-transparent and Clear Wood
Preservatives
-
-
2.9
Opaque Wood Preservatives
3.3
-
2.9
Specialty Flat Products
-
-
3.3
Specialty
Primers,
Sealers
&
Undercoaters
-
-
2.9
Stains, All
-
-
2.9
Traffic Coatings
Applied
to
Public
Streets
and
Highways
3.5
-
2.1
Applied to other Surfaces
2.1
-
2.1
Black Traffic Coatings
-
-
2.1
Varnishes
-
4.2
2.9
Waterproof Mastic Coating
-
-
2.5
Waterproof Sealers
-
-
3.3
Wood Preservatives Except Below
Ground
-
-
2.9
306
PAINTING PRACTICES: All architectural coating containers used to apply the contents
therein to a surface directly from the container by pouring, siphoning, brushing, rolling,
padding, ragging, or other means, shall be closed when not in use. These architectural
coatings containers include, but are not limited to, drums, buckets, cans, pails, trays, or
other application containers. Containers of any VOC-containing materials used for
thinning and cleanup shall also be closed when not in use.
306
EXEMPTIONS - SPECIFIC USE COATINGS: This rule shall not apply to architectural
coatings recommended by the manufacturer for use solely as one or more of the
following:
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 51 of 109
306.1 Below ground wood preservative coatings.
306.2 Bond breakers.
306.3 Fire retardant coatings.
306.4 Graphic arts coatings (sign paints).
306.5 Mastic texture coatings.
306.6 Metallic pigmented coatings.
306.7 Multi-colored paints.
306.8 Quick-dry primers, sealers and undercoaters.
306.9 Shellacs.
306.10 Swimming pool paints.
306.11 Tile-like glaze coatings.
307
RUST PREVENTATIVE COATINGS: No person shall apply or solicit the application of any
rust preventative coating, manufactured before January 1, 2026, for industrial use,
unless such a rust preventative coating complies with the industrial maintenance
coating VOC content limit specified in Table 335-1.
308
CONTAINER LABELING REQUIREMENTS: Each manufacturer of any architectural
coatings subject to this rule shall display the information listed below on the coating
container (or label) in which the coating is sold or distributed.
308.1 Date Code: The date the coating was manufactured, or a date code representing
the date, shall be indicated on the label, lid, or bottom of the container. If the
manufacturer uses a date code for any coating, the manufacturer shall file an
explanation of each code with the Control Officer.
308.2 Thinning Recommendations: A statement of the manufacturer's
recommendation regarding thinning of the coating shall be indicated on the label
or lid of the container. This requirement does not apply to the thinning of
architectural coatings with water. If thinning of the coating prior to use is not
necessary, the recommendation must specify that the coating is to be applied
without thinning.
308.3 VOC Content: Each container of any coating subject to this rule shall display one
of the following values in either grams of VOC per liter or pounds of VOC per
gallon of coating:
a. Maximum VOC Content as determined from all potential product
formulations; or
b. VOC Content as determined from actual formulation data; or
c. VOC Content as determined using the test methods in Section 502.2.
d. If the manufacturer does not recommend thinning, the container must display
the VOC Content, as supplied. If the manufacturer recommends thinning, the
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container must display the VOC Content including the maximum amount of
thinning solvent recommended by the manufacturer.
e. If the coating is a multi-component product, the container must display the
VOC content as mixed or catalyzed. If the coating contains silanes, siloxanes,
or other ingredients that generate ethanol or other VOCs during the curing
process, the VOC content must include the VOCs emitted during curing. VOC
Content shall be determined as defined in Section 200.
308.4 Labeling Requirements for Specific Coating Categories:
a. Faux Finishing Coatings: The labels of all clear topcoat Faux Finishing
Coatings shall prominently display the statement “This product can only be
sold or used as part of a Faux Finishing coating system.”
b. Industrial Maintenance Coatings: The labels of all Industrial Maintenance
Coatings shall prominently display at least one of the following statements:
(1) "For industrial use only" or;
(2) "For professional use only" or;
(3) "Not for residential use" or;
(4) "Not intended for residential use."
c. Non-Flat – High Gloss Coatings: The labels of all Non-Flat High-Gloss
Coatings shall prominently display the words "High Gloss."
d. Reactive Penetrating Carbonate Stone Sealers: The labels of all Reactive
Penetrating Carbonate Stone Sealers shall prominently display the statement
“Reactive Penetrating Carbonate Stone Sealer.”
e. Reactive Penetrating Sealers: The labels of all Reactive Penetrating Sealers
shall prominently display the statement “Reactive Penetrating Sealer.”
f. Rust Preventative Coatings: The labels of all Rust Preventative Coatings shall
prominently display the statement "For Metal Substrates Only."
g. Specialty Primers, Sealers, and Undercoaters: The labels of all Specialty
Primers, Sealers, and Undercoaters shall prominently display one or more of
the following descriptions:
(1) For fire-damaged substrates.
(2) For smoke-damaged substrates.
(3) For water-damaged substrates.
h. Stone Consolidants: The labels of all Stone Consolidants shall prominently
display the statement “Stone Consolidant – For Professional Use Only.”
i. Wood Coatings: The labels of all Wood Coatings shall prominently display the
statement “For Wood Substrates Only.”
j. Zinc Rich Primers: The labels of all Zinc Rich Primers shall prominently
display one or more of the following statements listed below:
(1) “For Professional Use Only”
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(2) “For Industrial Use Only”
(3) “Not for residential use” or “Not intended for residential use.”
SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE)
401
LABELING REQUIRED: Effective July 13, 1989, containers for all coatings subject to this
rule shall carry a statement of the manufacturer's recommendation regarding thinning
of the coatings. Data may be quantified with either English or metric units. This
requirement shall not apply to the thinning of the architectural coatings with water. The
recommendation shall specify that the coating is to be employed without thinning or
diluting under normal environmental and application conditions, unless the
recommended thinning for normal environmental and application conditions does not
cause the coating to exceed its applicable standard. Architectural coatings subject to
the Federal Insecticide, Fungicide and Rodenticide Act shall not be subject to the
labeling requirements of this rule.
402
MANUFACTURE DATE REQUIRED: Containers for all coatings subject to the provisions
of this rule shall display the date of manufacture of the contents or a code indicating the
date of manufacture. The manufacturers of such coatings shall file with the Control
Officer an explanation of each code.
SECTION 500 – MONITORING AND RECORDS
501
RECORDKEEPING AND REPORTING: Any person manufacturing, blending, and/or
repackaging architectural coatings subject to this rule shall comply with the following
recordkeeping requirements:
501.1 Records shall be retained for a period of five years.
501.2 Records shall be made available to the Control Officer no later than five business
days upon verbal or written request.
501.3 Records shall be made available to the Control Officer upon request by members
of the public using the County’s public records request process.
501.4 Records shall be kept on site at all times in a consistent and complete manner.
501.5 Current List: Maintain a current list of all VOC-containing materials subject to this
rule. The list shall express VOC content in one of the following forms:
a. Pounds VOC per gallon; or
b. Grams VOC per liter.
501.6 Monthly Usage Records: Maintain monthly records of the amount purchased or
used of all VOC-containing materials subject to this rule. Records shall be totaled
by the end of the month for the previous month.
501.7 Discarded Materials: Maintain monthly records of the type, amount, and method
of disposing of VOC-containing materials. Records of legal disposal include but
are not limited to shipping papers or quantity discharged to sewage treatment
works.
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Page 54 of 109
501.8 Sales Data: A responsible official from each manufacturer shall upon request of
the Control Officer, provide data concerning the distribution and sales of
architectural coatings. The responsible official shall within 180 days provide
information, including but not limited to:
a. Name and mailing address of the manufacturer;
b. Name, address, and telephone number of a contact person;
c. Name of the coating product as it appears on the label and the applicable
coating category;
d. Whether the product is marketed for interior or exterior or both;
e. Number of gallons sold in Maricopa County in containers greater than one
liter (1.057 quart) and equal to or less than one liter (1.057 quart);
f. VOC Actual content and VOC Regulatory content in either grams per liter or
pounds per gallon. If thinning is recommended, list the VOC Actual content
and VOC Regulatory content after maximum recommended thinning. If
containers less than one liter have a different VOC content than containers
greater than one liter, list separately. If the coating is a multi-component
product, provide the VOC content as mixed or catalyzed.
g. Names and Chemical Abstracts Service (CAS) numbers of the VOC
constituents in the product;
h. Names and CAS numbers of any exempt organic compounds in the product;
i. Whether the product is marketed as solvent-borne, waterborne or 100 percent
solids;
j. Description of resin or binder in the product;
k. Whether the coating is a single-component or multi-component product;
l. Density of the product in pounds per gallon;
m. Percent by weight of solids, all volatile materials, water, and any exempt
organic compounds;
n. Percent by volume of solids, water, and any exempt organic compounds.
501.9 All sales data listed above in Section 501.8 shall be maintained by the
responsible official for a minimum of three years. Sales data submitted by the
responsible official to the Control Officer may be claimed as confidential, and
such information shall be handled in accordance with MCAPCR Rule 100
(General Provisions and Definitions) Section 402.
DETERMINATION OF COMPLIANCE: Testing procedures to determine compliance with
prescribed VOC limits shall be consistent with Reference Methods 24 and 24A in the
Arizona Testing Manual for Air Pollutant Emissions.
502
COMPLIANCE DETERMINATION: When more than one test method is permitted for a
determination, an exceedance of the limits established in this rule determined by any of
the applicable test methods constitutes a violation of this rule.
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502.1 Calculation of VOC Content: For the purpose of determining compliance with the
VOC content limits in Table 335-1, the VOC content of a coating shall be
determined as defined in Section 200. The VOC content of a tint base shall be
determined without colorant that is added after the tint base is manufactured. If
the manufacturer does not recommend thinning, the VOC Content must be
calculated for the product as supplied. If the manufacturer recommends thinning,
the VOC Content must be calculated including the maximum amount of thinning
solvent recommended by manufacturer. If the coating is a multi-component
product, the container must display the VOC Content as mixed or catalyzed. If the
coating contains silanes, siloxanes, or other ingredients that generate ethanol or
other VOCs during the curing process, the VOC Content must include the VOCs
emitted during curing.
502.2 VOC Content of Coatings: The VOC content of coatings shall be determined by
the following:
a. To determine the physical properties of a coating in order to perform the
calculations in Sections 278 and 280, the reference method for VOC content
is EPA Method 24, incorporated by reference in Section 503.24, except as
provided in Sections 503 and 504.
b. An alternative method to determine the VOC content of coatings is SCAQMD
Method 304-91 (Revised 1996), incorporated by reference in Section 503.25.
c. The exempt compounds content shall be determined by SCAQMD Method
303-91 (Revised 1996), Bay Area Air Quality Management District (BAAQMD)
Method 43 (Revised 2005), or BAAQMD Method 41 (Revised 2005), as
applicable, incorporated by reference in Sections 503.2, 503.3, and 503.4.
d. To determine the VOC content of a coating, the manufacturer may use EPA
Method 24, or an alternative method as provided in Section 502.3, formulation
data, or any other reasonable means for predicting that the coating has been
formulated as intended (e.g., quality assurance checks, recordkeeping).
However, if there are any inconsistencies between the results of a Method 24
test and any other means for determining VOC content, the Method 24 test
results will govern, except when an alternative method is approved as
specified in Section 502.3.
e. To determine the VOC content of a coating with a VOC content of 150 g/L or
less, the manufacturer may use SCAQMD Method 313, incorporated by
reference in Section 503.26, ASTM D6886-18, incorporated by reference in
Section 503.27, or any other reasonable means for predicting that the coating
has been formulated as intended (e.g., quality assurance checks,
recordkeeping).
502.3 Alternative Test Methods: Other test methods demonstrated to provide results
that are acceptable for purposes of determining compliance with Section 502.2,
after review and approved by the Control Officer, and the EPA, may also be used.
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502.4 Methacrylate Traffic Coating Markings: Analysis of methacrylate mufti-
component coatings used as traffic marking coatings shall be conducted
according to a modification of EPA Method 24 (40 CFR 59, Subpart D, Appendix
A). This method has not been approved for methacrylate multicomponent
coatings used for other purposes than as traffic marking coatings or for other
classes of multicomponent coatings.
502.5 Formula for VOC Actual: Units of VOC Actual are in pounds of VOC per gallon (or
grams per liter) of material and shall be calculated using the following equation:
VOC Actual =
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚
Using consistently either English or metric measures in the calculations, where:
Ws =
weight of all volatile material in pounds (or grams), including
VOC, water, non-precursor organic compounds and dissolved
vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or
grams)
Vm =
volume of total material in gallons (or liters)
502.6 Formula for VOC Regulatory: Units of VOC Regulatory are in pounds of VOC per
gallon (or grams per liter) of material and shall be calculated using the following
equation:
VOC Regulatory =
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚−𝑉𝑉𝑤𝑤−𝑉𝑉𝑒𝑒𝑒𝑒
Using consistently either English or metric measures in the calculations, where:
Ws =
weight of all volatile material in pounds (or grams), including
VOC, water, non-precursor organic compounds and dissolved
vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or
grams)
Vm = volume of total material in gallons (or liters)
Vw = volume of water in gallons (or liters)
Ves = volume of all non-precursor organic compounds in gallons (or
liters)
503
TEST METHODS INCORPORATED BY REFERENCE: The following test methods are
approved for use for the purpose of determining compliance with this rule. The test
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methods are incorporated by reference in Rule 360 and Appendix G of the MCAPCR.
Alternative test methods as approved by the Administrator or other EPA-approved test
methods may be used upon prior written approval from the Control Officer. When more
than one test method is permitted for the same determination, an exceedance under
any method will constitute a violation. All test methods referenced in this rule shall be
the version most recently approved by the appropriate government entities.
503.1
Acid Content of Coatings: The acid content of a coating shall be determined
by ASTM D1613-17, “Standard Test Method for Acidity in Volatile Solvents
and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related
Products,” (See Section 249, Pre-Treatment Wash Primer).
503.2
Exempt Compounds – Siloxanes: Exempt compounds that are cyclic,
branched, or linear, completely methylated siloxanes, shall be analyzed as
exempt compounds for compliance with Section 502 by BAAQMD Method 43,
"Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks,
and Related Materials," BAAQMD Manual of Procedures, Volume III, adopted
November 6, 1996, (See Section 281, Volatile Organic Compounds, and
Section 502.2).
503.3
Exempt Compounds – Parachlorobenzotrifluoride (PCBTF): The exempt
compound parachlorobenzotrifluoride, shall be analyzed as exempt
compounds for compliance with Section 502 by BAAQMD Method 41,
“Determination of Volatile Organic Compounds in Solvent Based Coatings and
Related Materials Containing Parachlorobenzotrifluoride,” BAAQMD Manual of
Procedures, Volume III, adopted December 20, 1995, (See Section 281,
Volatile Organic Compounds, and Section 502.2).
503.4
Exempt Compounds: The content of compounds exempt under EPA Method
24 shall be analyzed by SCAQMD Method 303-91 (Revised 1996),
“Determination of Exempt Compounds,” SCAQMD Laboratory Methods of
Analysis for Enforcement Samples (See Section 281, Volatile Organic
Compounds, and Section 502.2).
503.5
Fire Resistance Rating: The fire resistance rating of a fire-resistive coating
shall be determined by ASTM E119-18ce1, “Standard Test Methods for Fire
Tests of Building Construction Materials,” (See Section 224, Fire-Resistive
Coating).
503.6
Gloss Determination: The gloss of a coating shall be determined by ASTM
D523-14 (2018), “Standard Test Method for Specular Gloss,” (See Section 225
- Flat Coating, Section 240 - Non-Flat Coating, and Section 241 - Non-Flat High
Gloss Coating).
503.7
Hydrostatic Pressure for Basement Specialty Coatings: ASTM D7088-17,
“Standard Practice for Resistance to Hydrostatic Pressure for Coatings Used
in Below Grade Applications Applied to Masonry” (See Section 206, Basement
Specialty Coating).
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503.8
Metal Content of Coatings: The metallic content of a coating shall be
determined by SCAQMD Method 318-95, ”Determination of Weight Percent
Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD “Laboratory
Methods of Analysis for Enforcement Samples,” (See Sections 203, 223, and
238; Aluminum Roof Coating, Faux Finish Coating, and Metallic Pigmented
Coating).
503.9
Methacrylate Traffic Marking Coatings: The VOC content of methacrylate
multicomponent coatings used as traffic marking coatings shall be analyzed
by the procedures in 40 CFR 59, Subpart D, Appendix A, "Determination of
Volatile Matter Content of Methacrylate Multicomponent Coatings Used as
Traffic Marking Coatings," (September 11, 1998), (See Section 502.4).
503.10
Mold and Mildew Growth for Basement Specialty Coatings: ASTM D3273-16,
“Standard Test Method for Resistance to Growth of Mold on the Surface of
Interior Coatings in an Environmental Chamber” and ASTM D3274-09 (2017),
“Standard Test Method for Evaluating Degree of Surface Disfigurement of
Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt
Accumulation” (See Section 206, Basement Specialty Coating).
503.11
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Water Repellency: ASTM C67/C67M-18, “Standard Test Methods for
Sampling and Testing Brick and Structural Clay Tile”, or ASTM C97/C97M-18,
“Standard Test Method for Absorption and Bulk Specific Gravity of Dimension
Stone”, or ASTM C140/C140M-18a, “Standard Test Methods for Sampling and
Testing Concrete Masonry Units and Related Units” (See Section 252,
Reactive Penetrating Carbonate Stone Sealer and Section 253, Reactive
Penetrating Sealer).
503.12
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Water Vapor Transmission: ASTM E96/E96M-16, “Standard Test
Method for Water Vapor Transmission of Materials” (See Section 252,
Reactive Penetrating Carbonate Stone Sealer and Section 253, Reactive
Penetrating Sealer).
503.13
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Chloride Screening Applications: National Cooperative Highway
Research Report 244 (1981), “Concrete Sealers for the Protection of Bridge
Structures” (See Section 252, Reactive Penetrating Carbonate Stone Sealer
and Section 253, Reactive Penetrating Sealer).
503.14
Stone Consolidant: ASTM E2167-01 (2008), “Standard Guide for Selection
and Use of Stone Consolidants” (See Section 269, Stone Consolidant).
503.15
Nuclear Coating: The radiation resistance of a nuclear coating shall be
determined by ASTM D4082-02 “Standard Test Method for Effects of Gamma
Radiation on Coatings for Use in Light-Water Nuclear Power Plants” (See
Section 242, Nuclear Coating).
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503.16
Nuclear Coating: The chemical resistance of nuclear coatings shall be
determined by ASTM D3912-95 (2001) “Standard Test Method for Chemical
Resistance of Coatings Used in Light-Water Nuclear Power Plants” (See
Section 242, Nuclear Coating).
503.17
Specialty Primer, Sealer and Undercoater – Surface Chalkiness: The
chalkiness of a surface shall be determined using ASTM D4214-98, “Standard
Test Methods for Evaluating the Degree of Chalkiness of Exterior Paint Films,”
(See Section 266, Specialty Primer, Sealer, and Undercoater).
503.18
Tub and Tile Refinish Coating – Absorption: Performance criteria for
penetration of dense tile shall be determined by ASTM C373-18 “Standard
Test Method for Water Absorption, Bulk Density, Apparent Porosity, and
Apparent Specific Gravity of Fired Whiteware Products, Ceramic Tiles and
Glass Tiles, “or by ASTM C97/C97M-18 “Standard Test Methods for
Absorption and Bulk Specific Gravity of Dimension Stone,” or by ASTM C642-
13 “Standard Test Method for Density, Absorption and Voids in Hardened
Concrete” (See Section 274, Tub and Tile Refinish Coating).
503.19
Tub and Tile Refinish Coating – Abrasion Resistance: ASTM D4060-14,
“Standard Test Method for Abrasion Resistance of Organic Coatings by the
Taber Abraser” (See Section 274, Tub and Tile Refinish Coating).
503.20
Tub and Tile Refinish Coating – Adhesion: ASTM D4585/4585M-18,
“Standard Practice for Testing Water Resistance of Coatings Using Controlled
Condensation” and ASTM D3359-17, “Standard Test Method for Measuring
Adhesion by Tape Test” (See Section 274, Tub and Tile Refinish Coating).
503.21
Tub and Tile Refinish Coating – Hardness: ASTM D3363-05 (2011)e2,
“Standard Test Method for Film Hardness by Pencil Test” (See Section 274,
Tub and Tile Refinish Coating).
503.22
Tub and Tile Refinish Coating – Water Resistance: ASTM D4585-99,
“Standard Practice for Testing Water Resistance of Coatings Using Controlled
Condensation” and ASTM D714-02 (2017), “Standard Test Method for
Evaluating Degree of Blistering of Paints” (See Section 274, Tub and Tile
Refinish Coating).
503.23
Waterproofing Membrane: ASTM C836/836M-18, “Standard Specification for
High Solids Content, Cold Liquid-Applied Elastomeric Waterproofing
Membrane for Use with Separate Wearing Course” (See Section 283,
Waterproofing Membrane).
503.24
VOC Content of Coatings: The VOC content of a coating shall be determined
by EPA Method 24 as it exists in Appendix A of 40 Code of Federal
Regulations (CFR) Part 60, "Determination of Volatile Matter Content, Water
Content, Density, Volume Solids, and Weight Solids of Surface Coatings," (See
Section 502.2).
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503.25
Alternative VOC Content of Coatings: The VOC content of coatings may be
analyzed either by EPA Method 24, or SCAQMD Method 304-91 (Revised
1996), “Determination of Volatile Organic Compounds (VOC) in Various
Materials,” SCAQMD “Laboratory Methods of Analysis for Enforcement
Samples,” (See Section 502.2).
503.26
VOC Content of Coatings: SCAQMD Method 313, “Determination of Volatile
Organic Compounds (VOC) by Gas Chromatography/Mass
Spectrometry/Flame Ionization Detection (GS/MS/FID),” (See Section 502.2).
503.27
VOC Content of Coatings: ASTM D6886-18, “Standard Test Method for
Determination of the Weight Percent Individual Volatile Organic Compounds
in Waterborne Air-Dry Coatings by Gas Chromatography,” (See Section 502.2).
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MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 335 (ARCHITECTURAL COATINGS)
INDEX
SECTION 100 – GENERAL
101
PURPOSE
102
APPLICABILITY
103
EXEMPTIONS
SECTION 200 – DEFINITIONS
201
ADHESIVE
202
AEROSOL COATING PRODUCT
203
ALUMINUM ROOF COATING
204
APPURTENANCES
205
ARCHITECTURAL COATING
206
BASEMENT SPECIALITY COATING
207
BITUMENS
208
BITUMINOUS ROOF COATING
209
BITUMINOUS ROOF PRIMER
210
BOND BREAKER
211
CALCIMINE RECOATER
212
COATING
213
COLORANT
214
CONCRETE CURING COMPOUND
215
CONCRETE/MASONRY SEALER
216
CONCRETE SURFACE RETARDER
217
CONJUGATED OIL VARNISH
218
CONVERSION VARNISH
219
DRIVEWAY SEALER
220
DRY FOG COATING
Return to list of attachments
Clean version of Draft Rule 335
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221
ENAMEL UNDERCOATER
222
EXEMPT COMPOUND
223
FAUX FINISHING COATING
224
FIRE-RESISTIVE COATING
225
FLAT COATING
226
FLOOR COATING
227
FORM-RELEASE COMPOUND
228
GRAPHIC ARTS COATING (SIGN PAINT)
229
HIGH-TEMPERATURE COATING
230
IMPACTED IMMERSION COATING
231
INDUSTRIAL MAINTENANCE COATING
232
LACQUER
233
LOW-SOLIDS COATING
234
MAGNESITE CEMENT COATING
235
MANUFACTURER’S MAXIMUM RECOMMENDATION
236
MASTIC TEXTURE COATING
237
MEDIUM DENSITY FIBERBOARD (MDF)
238
METALLIC PIGMENTED COATING
239
MULTI-COLOR COATING
240
NON-FLAT COATING
241
NON-FLAT HIGH GLOSS COATING
242
NUCLEAR COATING
243
OPAQUE STAIN
244
OPAQUE WOOD PRESERVATIVE
245
PARTICLEBOARD
246
PEARLESCENT
247
PLYWOOD
248
POST-CONSUMER COATING
249
PRE-TREATMENT WASH PRIMER
250
PRIMER, SEALER, AND UNDERCOATER
251
QUICK-DRY ENAMEL
252
REACTIVE PENETRATING CARBONATE STONE SEALER
253
REACTIVE PENETRATING SEALER
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254
RECYCLED COATING
255
RESIDENTAL
256
ROOF COATING
257
RUST PREVENTATIVE COATING
258
SECONDARY INDUSTRIAL MATERIALS
259
SEMI-TRANSPARENT COATING
260
SEMI-TRANSPARENT STAIN
261
SEMI-TRANSPARENT WOOD PRESERVATIVE
262
SHELLAC
263
SHOP APPLICATION
264
SOLICIT
265
SPECIALTY FLAT PRODUCT
266
SPECIALTY PRIMER, SEALER, AND UNDERCOATER
267
STAIN
268
STATIONARY STRUCTURE
269
STONE CONSOLIDANT
270
SWIMMING POOL COATING
271
THERMOPLASTIC RUBBER COATING AND MASTIC
272
TINT BASE
273
TRAFFIC MARKING COATING
274
TUB AND TILE REFINISH COATING
275
VARNISH
276
VENEER
277
VIRGIN MATERIALS
278
VOC ACTUAL
279
VOC CONTENT
280
VOC REGULATORY
281
VOLATILE ORGANIC COMPOUND (VOC)
282
WATERPROOFING MASTIC COATING
283
WATERPROOFING MEMBRANE
284
WATERPROOF SEALER
285
WOOD COATING
286
WOOD PRESERVATIVE
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287
WOOD SUBSTRATE
288
ZINC-RICH PRIMER
SECTION 300 – STANDARDS
301
VOC CONTENT LIMITS
302
COATING CATEGORIZATION
303
MOST RESTRICTIVE VOC CONTENT LIMIT
304
SELL-THROUGH OF COATINGS
305
THINNING
306
PAINTING PRACTICES
307
RUST PREVENTATIVE COATINGS
308
CONTAINER LABELING REQUIREMENTS
SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE)
SECTION 500 – MONITORING AND RECORDS
501
RECORDKEEPING AND REPORTING
502
COMPLIANCE DETERMINATION
503
TEST METHODS INCORPORATED BY REFERENCE
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Adopted 07/13/88; Revised 09/25/13; Revised MM/DD/YYYY
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS
REGULATION III – CONTROL OF AIR CONTAMINANTS
RULE 335 (ARCHITECTURAL COATINGS)
SECTION 100 – GENERAL
101
PURPOSE: To limit the emissions of volatile organic compounds (VOCs) from the sale,
manufacture, and/or application of architectural coatings. This rule has been revised as
a contingency measure for achieving the 2015 National Ambient Air Quality Standard
(NAAQS) for ozone as required by Section 172(c)(9) of the Clean Air Act (CAA) under 42
United States Code (U.S.C.) 7502.
102
APPLICABILITY: This rule applies to any person who supplies, sells, offers for sale, or
manufacturers any architectural coating for use within Maricopa County, as well as any
person who applies or solicits the application of any architectural coating within
Maricopa County.
102.1 The revised requirements of this rule as adopted on [revision date] shall become
effective upon a determination by the U.S. Environmental Protection Agency
(EPA) that either of the following triggering events has occurred:
a. The Phoenix-Mesa 2015 ozone NAAQS nonattainment area failed to attain the
2015 ozone NAAQS by the Moderate area attainment date; or
b. The Phoenix-Mesa 2015 ozone NAAQS nonattainment area failed to make
reasonable further progress under the 2015 ozone NAAQS.
102.2 In addition to this rule, facilities may be subject to New Source Performance
Standards (NSPS) in Rule 360 and/or to National Emission Standards for
Hazardous Air Pollutants (NESHAP) in Rule 370 of the Maricopa County Air
Pollution Control Regulations (MCAPCR).
103
EXEMPTIONS: This rule shall not apply to the following:
103.1 Any architectural coating that is supplied, sold, offered for sale, or manufactured
for use outside of Maricopa County or for shipment to other manufacturers for
reformulation or repackaging.
103.2 Any aerosol coating product.
103.3 Any facility which applies coatings to test specimens for purposes of research
and development of those coatings.
103.4 Architectural coatings supplied in containers having capacities of one liter
(1.057 quart) or less, including kits containing containers of different colors,
types, or categories of coatings and two component products. This exemption
does not include:
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a. Bundling of containers one liter or less, which are sold together as a unit, or
any type of marketing which implies that multiple containers one liter or less
be combined into one container; and
b. Multiple containers of one liter or less that are packaged and shipped
together with no intent or requirement to ultimately sell as individual units of
one liter or less.
103.5 Activities that are more specifically regulated by another source-specific rule
within the MCAPCR, as listed below:
a. Product painting or pre-installation painting of structures (Rule 336).
b. Re-coating of a structural part, which has been removed from the structure
prior to re-coating (Rule 336).
c. Cutback and emulsified asphalt use and application (Rule 340).
d. Surface preparation and coating of wood furniture and fixtures (Rule 342).
e. Surface preparation and coating of wood millwork (Rule 346).
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definitions
shall apply, in addition to those definitions found in Rule 100 (General Provisions and
Definitions) of these rules. In the event of any inconsistency between any of the rules within
the MCAPCR, the definitions in this rule take precedence.
201
ADHESIVE: Any chemical substance that is applied for the purpose of bonding
two surfaces together other than by mechanical means.
202
AEROSOL COATING PRODUCT: A pressurized coating product containing pigments or
resins that dispenses product ingredients by means of a propellant and is packaged in a
disposable can for hand-held application, or for use in specialized equipment for ground
traffic/marking applications.
203
ALUMINUM ROOF COATING: A coating labeled and formulated exclusively for
application to roofs and containing at least 84 grams of elemental aluminum pigment
per liter of coating (at least 0.7 pounds per gallon). Pigment content shall be determined
in accordance with South Coast Air Quality Management District (SCAQMD) Method
318-95, incorporated by reference in Section 503.8.
204
APPURTENANCES: Any accessory to a stationary structure coated at the site of
installation, whether installed or detached, including but not limited to the following:
204.1 Bathroom and kitchen
fixtures.
204.2 Cabinets.
204.3 Concrete forms.
204.4 Doors.
204.5 Elevators.
204.6 Fences.
204.7 Hand railings.
204.8 Heating equipment.
204.9 Air conditioning equipment.
204.10 Other fixed mechanical
equipment.
204.11 Stationary tools.
204.12 Lampposts.
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204.13 Partitions.
204.14 Pipes and piping systems.
204.15 Rain gutters and downspouts.
204.16 Stairways.
204.17 Fixed ladders.
204.18 Catwalks and fire escapes.
204.19 Window screens.
205
ARCHITECTURAL COATING: A coating to be applied to stationary structures or their
appurtenances at the site of installation, including but not limited to the structures or
appurtenances listed in Section 205.1 through 205.5 of this rule. Coatings applied in
shop applications or to non-stationary structures such as airplanes, ships, boats,
railcars, and automobiles, as well as adhesives are not considered architectural
coatings for the purposes of this rule.
205.1 Mobile homes.
205.2 Portable buildings.
205.3 Manufactured buildings of either modular or unitary design.
205.4 Pavement.
205.5 Curbs.
206
BASEMENT SPECIALTY COATING: A clear or opaque coating that is labeled and
formulated for application to concrete and masonry surfaces to provide a hydrostatic
seal for basements and other below-grade surfaces. Basement Specialty Coatings must
meet the following criteria:
206.1 Coating must be capable of withstanding at least 10 psi of hydrostatic pressure,
as determined in accordance with American Society for Testing and Maintenance
(ASTM) D7088-17, incorporated by reference in Section 503.7; and
206.2 Coating must be resistant to mold and mildew growth and must achieve a
microbial growth rating of 8 or more (10 is no growth), as determined in
accordance with ASTM D3273-16 and ASTM D3274-09 (2017), incorporated by
reference in Section 503.10.
207
BITUMENS: Black or brown materials including, but not limited to, asphalt, tar, pitch and
asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons that are
obtained from natural deposits or as residues from the distillation of crude petroleum or
coal.
208
BITUMINOUS ROOF COATING: A coating which incorporates bitumens that is labeled
and formulated exclusively for roofing for the primary purpose of preventing water
penetration.
209
BITUMINOUS ROOF PRIMER: A primer which incorporates bitumens that is labeled and
formulated exclusively for roofing and intended for the purpose of preparing a
weathered or aged surface or improving the adhesion of subsequent surfacing
components.
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210
BOND BREAKER: A coating labeled and formulated for application between layers of
concrete to prevent a freshly poured top layer of concrete from bonding to the layer over
which it is poured.
211
CALCIMINE RECOATER: A flat solvent-borne coating formulated and recommended
specifically for recoating calcimine-painted ceilings and other calcimine-painted
substrates.
212
COATING: A material applied onto or impregnated into a substrate for protective,
decorative, or functional purposes. Such materials include, but are not limited to, paints,
varnishes, sealers, and stains.
213
COLORANT: A concentrated pigment dispersion in water, solvent, and/or binder that is
added to an architectural coating after packaging in sale units to produce the desired
color.
214
CONCRETE CURING COMPOUND: A coating labeled and formulated for application to
freshly poured concrete to perform one or more of the following functions:
214.1 Retard the evaporation of water; or
214.2 Harden or dustproof the surface of freshly poured concrete.
215
CONCRETE/MASONRY SEALER: A clear or opaque coating that is labeled and
formulated primarily for application to concrete and masonry surfaces to perform one
or more of the following functions:
215.1 Prevent penetration of water; or
215.2 Provide resistance against abrasion, alkalis, acids, mildew, staining, or ultraviolet
light; or
215.3 Harden or dustproof the surface of aged or cured concrete.
216
CONCRETE SURFACE RETARDER: A mixture of retarding ingredients such as extender
pigments, primary pigments, resin, and solvent that interact chemically with the cement
to prevent hardening on the surface where the retarder is applied, allowing the retarded
mix of cement and sand at the surface to be washed away to create an exposed
aggregate finish.
217
CONJUGATED OIL VARNISH: A clear or semi-transparent wood coating, labeled as
such, excluding lacquers or shellacs, based on a natural occurring conjugated vegetable
oil (Tung oil) and modified with other natural or synthetic resins; a minimum of fifty
percent of the resin solids consisting of conjugated oil. Supplied as a single component
product, conjugated oil varnishes penetrate and seal the wood. Film formation is due to
polymerization of the oil. These varnishes may contain small amounts of pigment to
control the final gloss or sheen.
218
CONVERSION VARNISH: A clear acid curing coating with an alkyd or other resin blended
with amino resins and supplied as a single component or two-component product.
Conversion varnishes produce a hard, durable, clear finish designed for professional
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application to wood flooring. This film formation is the result of an acid-catalyzed
condensation reaction, affecting transetherification at the reactive ethers of the amino
resins.
219
DRIVEWAY SEALER: A coating labeled and formulated for application to worn asphalt
driveway surfaces to perform one or more of the following functions:
219.1 Fill cracks; or
219.2 Seal the surface to provide protection; or
219.3 Restore or preserve the appearance.
220
DRY FOG COATING: A coating labeled and formulated only for spray application such
that overspray droplets dry before subsequent contact with incidental surfaces in the
vicinity of the surface coating activity.
221
ENAMEL UNDERCOATER: A coating which is designed to be applied to a new surface
over a primer or over a previous coat of paint, in order to improve the seal, provide better
adhesion and make a smooth base for non-flat coatings.
222
EXEMPT COMPOUND: The federally listed non-precursor organic compounds, which
have been determined to have negligible photochemical reactivity as listed in 40 CFR
51.100(s)(1) and in Appendix G (Incorporated Materials) of the MCAPCR.
223
FAUX FINISHING COATING: A coating labeled and formulated to meet one or more of
the following criteria:
223.1 A glaze or textured coating used to create artistic effects including, but not
limited to: dirt, suede, old age, smoke damage, and simulated marble and wood
grain;
223.2 A decorative coating used to create a metallic, iridescent, or pearlescent
appearance that contains at least 48 grams of pearlescent mica pigment or other
iridescent pigment per liter of coating as applied (at least 0.4 pounds per gallon);
223.3 A decorative coating used to create a metallic appearance that contains less
than 48 grams of elemental metallic pigment per liter of coating as applied (less
than 0.4 pounds per gallon), when testing in accordance with SCAQMD Method
318-95, incorporated by reference in Section 503.8;
223.4 A decorative coating used to create a metallic appearance that contains greater
than 48 grams of elemental metallic pigment per liter of coating as applied
(greater than 0.4 pounds per gallon) and which requires a clear topcoat to
prevent the degradation of the finish under normal use conditions. The metallic
pigment content shall be determined in accordance with SCAQMD Method 318-
95, incorporated by reference in Section 503.8; or
223.5 A clear topcoat to seal and protect a Faux Finishing coating that meets the
requirements in Sections 223.1 through 223.4. These clear topcoats must be
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sold and used solely as part of a Faux Finishing coating system and must be
labeled in accordance with Section 308.4(a).
224
FIRE-RESISTIVE COATING: A coating labeled and formulated to protect the structural
integrity by increasing the fire endurance of interior or exterior steel and other structural
materials. The Fire-Resistive category includes sprayed fire resistive materials and
intumescent fire-resistive coatings that are used to bring structural materials, into
compliance with federal, state, and local building code requirements. The Fire-Resistive
coating and testing agency must be approved by building code officials. The Fire-
Resistive coating shall be tested in accordance with ASTM E119-18ce1, incorporated by
reference in Section 503.5.
225
FLAT COATING: A coating that is not defined under any other definition in this rule and
that registers gloss less than 15 on an 85-degree meter or less than five on a 60-degree
meter according to ASTM D523-14 (2018), incorporated by reference in Section 503.6.
226
FLOOR COATING: An opaque coating that is labeled and formulated for application to
flooring, including, but not limited to, decks, porches, steps, garage floors, and other
horizontal surfaces, which may be subjected to foot traffic.
227
FORM-RELEASE COMPOUND: A coating labeled and formulated for application to a
concrete form to prevent the freshly poured concrete from bonding to the form. The
form may consist of wood, metal, or some material other than concrete.
228
GRAPHIC ARTS COATING (SIGN PAINT): A coating labeled and formulated for hand-
application by artists using brush, airbrush, or roller techniques to indoor and outdoor
signs (excluding structural components) and murals including letter enamels, poster
colors, copy blockers, and bulletin enamels.
229
HIGH-TEMPERATURE COATING: A high-performance coating labeled and formulated
for application to substrates exposed continuously or intermittently to temperatures
above 400° F (204° C).
230
IMPACTED IMMERSION COATING: A high-performance maintenance coating
formulated and recommended for application to steel structures subject to immersion
in turbulent, debris-laden water. These coatings are specifically resistant to high-energy
impact damage by floating ice or debris.
231
INDUSTRIAL MAINTENANCE COATING: A high-performance architectural coating,
including primers, sealers, undercoaters, intermediate coats, and topcoats, formulated
for application to substrates, including floors, exposed to one or more of the following
extreme environmental conditions listed below and labeled as specified in Section
308.4(b):
231.1 Immersion in water, wastewater, or chemical solutions (aqueous and non-
aqueous solutions), or chronic exposures of interior surfaces to moisture
condensation; or
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231.2 Acute or chronic exposure to corrosive, caustic, or acidic agents, or to chemicals,
chemical fumes, or chemical mixtures or solutions; or
231.3 Frequent exposure to temperatures above 250° F (121° C); or
231.4 Frequent heavy abrasion, including mechanical wear and frequent scrubbing with
industrial solvents, cleansers, or scouring agents; or
231.5 Exterior exposure of metal structures and structural components.
232
LACQUER: Clear or opaque wood coatings, including clear lacquer sanding sealers,
formulated with cellulose or synthetic resins to dry by evaporation without chemical
reaction and to provide a solid, protective film.
233
LOW-SOLIDS COATING: A coating containing 1 pound or less of solids per gallon (0.12
kilogram or less of solids per liter) of coating material as recommended for application
by the manufacturer. The VOC content for Low-Solids Coatings shall be calculated in
accordance with Section 502.5.
234
MAGNESITE CEMENT COATING: A coating labeled and formulated for application to
magnesite cement decking to protect the magnesite cement substrate from erosion by
water.
235
MANUFACTURER’S MAXIMUM RECOMMENDATION: The maximum recommendation
for thinning that is indicated on the label or lid of the coating container.
236
MASTIC TEXTURE COATING: A coating labeled and formulated to cover holes and
minor cracks and to conceal surface irregularities and is applied in a single coat of at
least 10 mils (at least 0.010 inch) dry film thickness.
237
MEDIUM DENSITY FIBERBOARD (MDF): A composite wood product, panel, molding, or
other building material composed of cellulosic fibers (usually wood) made by dry
forming and pressing of resonated fiber mat.
238
METALLIC PIGMENTED COATING: A coating that is labeled and formulated to provide a
metallic appearance. Metallic Pigmented coatings must contain at least 48 grams of
elemental metallic pigment (excluding zinc) per liter of coating as applied (at least 0.4
pounds per gallon), when tested in accordance with SCAQMD Method 318-95,
incorporated by reference in Section 503.8. The Metallic Pigmented Coating category
does not include Roof Coatings or Zinc-Rich Primers.
239
MULTI-COLOR COATING: A coating that is packaged in a single container and that is
labeled and formulated to exhibit more than one color when applied in a single coat.
240
NON-FLAT COATING: A coating that does not meet the criteria under any other
definition in this rule and that registers a gloss of 15 or greater on an 85-degree meter
and 5 or greater on a 60-degree meter according to ASTM D523-14 (2018), incorporated
by reference in Section 503.6.
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241
NON-FLAT HIGH GLOSS COATING: A non-flat coating that registers a gloss of 70 or
greater on a 60-degree meter according to ASTM D523-14 (2018), incorporated by
reference in Section 503.6. Non-Flat High Gloss coatings must be labeled in accordance
with Section 308.4(c).
242
NUCLEAR COATING: A protective coating formulated and recommended to seal porous
surfaces such as steel (or concrete) that otherwise would be subject to intrusion by
radioactive materials. These coatings must be resistant to long-term (service life)
cumulative radiation exposure according to ASTM D4082-02 (incorporated by reference
into Section 503.15), relatively easy to decontaminate, and resistant to various
chemicals to which the coatings are likely to be exposed according to ASTM D3912-95
(2001) (incorporated by reference into Section 503.16).
243
OPAQUE STAIN: All stains that are not classified as semi-transparent stains.
244
OPAQUE WOOD PRESERVATIVE: All wood preservatives that are not classified as semi-
transparent wood preservatives.
245
PARTICLEBOARD: A composite wood product panel, molding, or other building material
composed of cellulosic material (usually wood) in the form of discrete particles, as
distinguished from fibers, flakes, or strands, which are pressed together with resin.
246
PEARLESCENT: Exhibiting various colors depending on the angles of illumination and
viewing, as observed in mother-of-pearl.
247
PLYWOOD: A panel product consisting of layers of wood veneers or composite core
pressed together with resin. Plywood includes panel products made by either hot or
cold pressing (with resin) veneers to a platform.
248
POST-CONSUMER COATING: Finished coatings generated by a business or consumer
that have served their intended end uses and are recovered from or otherwise diverted
from the waste stream for the purpose of recycling.
249
PRE-TREATMENT WASH PRIMER: A primer which contains at least one-half percent
acid, by weight, when tested in accordance with ASTM D1613-17 (incorporated by
reference in Section 503.1), that is labeled and formulated for application directly to
bare metal surfaces to provide corrosion resistance and to promote adhesion of
subsequent topcoats.
250
PRIMER, SEALER, AND UNDERCOATER: A coating labeled and formulated for one or
more of the following purposes:
250.1 To provide a firm bond between the substrate and the subsequent coatings;
250.2 To prevent subsequent coatings from being absorbed by the substrate;
250.3 To prevent harm to subsequent coatings by materials in the substrate;
250.4 To provide a smooth surface for the subsequent application of coatings;
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250.5 To provide a clear finish coat to seal the substrate; or
250.6 To block materials from penetrating into or leaching out of a substrate.
251
QUICK-DRY ENAMEL: Non-flat coating that is formulated to have the following:
251.1 Should be capable of being applied directly from the container by brush or roller
when the ambient temperature is between 60° F and 80° F.
251.2 When tested in accordance with ASTM D1640 (1999) they shall: set to touch in
two hours or less, dry hard in eight hours or less, and be tack-free in four hours or
less by the mechanical method test.
251.3 Shall have a 60-degree meter dried film gloss of no less than 70.
252
REACTIVE PENETRATING CARBONATE STONE SEALER: A clear or pigmented coating
that is labeled and formulated for application to above-grade carbonate stone
substrates to provide protection from water and waterborne contaminants, including but
not limited to, alkalis, acids, and salts. Reactive Penetrating Carbonate Stone Sealers
must penetrate into carbonate stone substrates and chemically react to form covalent
bonds with naturally occurring minerals in the substrate. Reactive Penetrating
Carbonate Stone Sealers line the pores of carbonate stone substrates with a
hydrophobic coating, but do not form a surface film. Reactive Penetrating Carbonate
Stone Sealers must meet all the following criteria:
252.1 Must improve water repellency at least 80 percent after application on a
carbonate stone substrate. This performance must be verified on standardized
test specimens, in accordance with one or more of the following standards:
ASTM C67/C67M-18, or ASTM C97/C97M-18, or ASTM C140/C140M-18a
(incorporated by reference in Section 503.11);
252.2 Must not reduce the water vapor transmission rate by more than 10 percent after
application on a carbonate stone substrate. This performance must be verified
on standardized test specimens, in accordance with ASTM E96/E96M-16
(incorporated by reference in Section 503.12); and
252.3 Must be labeled as such, in accordance with the labeling requirements in Section
308.4(d).
253
REACTIVE PENETRATING SEALER: A clear or pigmented coating that is labeled and
formulated for application to above-grade concrete and masonry substrates to provide
protection from water and waterborne contaminants, including but not limited to, alkalis,
acids, and salts. Reactive Penetrating Sealers must meet all the following criteria:
253.1 Line the pores of concrete and masonry substrates with a hydrophobic coating,
but do not form a surface film.
253.2 Penetrate into concrete and masonry substrates and chemically react to form
covalent bonds with naturally occurring minerals in the substrate.
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253.3 Improve water repellency at least 80 percent after application on a concrete or
masonry substrate. This performance must be verified on standardized test
specimens per ASTM C67/C67M-18, or ASTM C97/C97M-18, or ASTM
C140/C140M-18a (incorporated by reference in Section 503.11); and
253.4 Not reduce the water vapor transmission rate by more than 2 percent after
application on a concrete or masonry substrate. This performance must be
verified on standardized test specimens, in accordance with ASTM E96/E96M-16
(incorporated by reference in Section 503.12); and
253.5 Products labeled and formulated for vehicular traffic surface chloride screening
applications must meet the performance criteria listed in the National
Cooperative Highway Research Report 244 (1981), incorporated by reference in
Section 503.13.
253.6 Must be labeled as such, in accordance with the labeling requirements in Section
308.4(e).
254
RECYCLING COATING: An architectural coating formulated such that it contains a
minimum of 50 percent by volume post-consumer coating, with a maximum of 50
percent by volume secondary industrial materials or virgin materials.
255
RESIDENTIAL: Areas where people reside or lodge, including, but not limited to, single
and multiple family dwellings, condominiums, mobile homes, apartment complexes,
motels, and hotels.
256
ROOF COATING: A non-bituminous coating labeled and formulated for application to
roofs and for the primary purpose of preventing penetration or reflecting heat and
ultraviolet radiation.
257
RUST PREVENTATIVE COATING: A coating formulated to prevent the corrosion of metal
surfaces for one or more of the following applications:
257.1 Direct-to-metal coating; or
257.2 Coating intended for application over rusty, previously coated surfaces.
257.3 The Rust Preventative category does not include the following:
a. Coatings that are required to be applied as a topcoat over a primer; or
b. Coatings that are intended for use or used on wood or any other nonmetallic
surface. Rust Preventative coatings are for metal substrates only and must be
labeled as such, in accordance with the labeling requirements in Section
308.4(f).
258
SECONDARY INDUSTRIAL MATERIALS: Products or by-products of the paint
manufacturing process that are of known composition and have economic value but
can no longer be used for their intended use.
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259
SEMI-TRANSPARENT COATING: A coating that contains binders and colored pigments
and is formulated to change the color of the surface, but not conceal the grain pattern
or texture.
260
SEMI-TRANSPARENT STAIN: Coatings which are formulated to change the color of a
surface but not conceal the surface.
261
SEMI-TRANSPARENT WOOD PRESERVATIVE: Wood preservative stains which are
formulated for the purpose of protecting exposed wood from decay or insect attack by
the addition of a wood preservative chemical and which change the color of a surface
but do not conceal the surface. These coatings perform their function by penetrating
into the wood.
262
SHELLAC: A clear or opaque coating formulated solely with the resinous secretions of
the lac beetle (Laciffer lacca) and formulated to dry by evaporation without a chemical
reaction.
263
SHOP APPLICATION: Application of a coating to a product or a component of a product
in or on the premises of a factory or a shop as part of a manufacturing, production, or
repairing process (e.g., original equipment manufacturing coatings).
264
SOLICIT: To require for use or to specify, by written or oral contract.
265
SPECIALTY FLAT PRODUCT: Self-priming flat products used only to perform one of the
following functions: repair fire, smoke, or water damage; neutralize odors; block stains;
or coat acoustical materials without affecting their acoustical abilities.
266
SPECIALTY PRIMER, SEALER, AND UNDERCOATER: A coating that is formulated for
application to a substrate to block water-soluble stains resulting from: fire damage,
smoke damage, or water damage. Specialty Primers, Sealers, and Undercoaters must be
labeled in accordance with Section 308.4(g).
267
STAIN: A semi-transparent or opaque coating labeled and formulated to change the
color of a surface but not conceal the grain pattern or texture. Stains labeled and
formulated exclusively for use on interior surfaces are only subject to VOC limits for
interior stains.
268
STATIONARY STRUCTURE: Structures that are designed to be stationary when
operating and are not designed or constructed to be moved from place-to-place.
Examples include but are not limited to:
268.1 Bridges.
268.2 Curbs.
268.3 Factories.
268.4 Homes.
268.5 Large storage tanks.
268.6 Mobile homes.
268.7 Office buildings.
268.8 Pavement.
268.9 Racetracks.
268.10 Roadways.
268.11 Silos.
268.12 Transformers.
268.13 Utility towers.
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269
STONE CONSOLIDANT: A coating that is labeled and formulated for application to
stone substrates to repair historical structures that have been damaged by weathering
or other decay mechanisms. Stone Consolidants must penetrate into stone substrates
to create bonds between particles and consolidate deteriorated material. Stone
Consolidants must be specified and used in accordance with ASTM E2167-01,
incorporated by reference in Section 503.14. Stone Consolidants are for professional
use only and must be labeled as such, in accordance with the labeling requirements in
Section 308.4(h).
270
SWIMMING POOL COATING: A coating labeled and formulated to coat the interior of
swimming pools and to resist swimming pool chemicals. Swimming pool coatings
include coatings used for swimming pool repair and maintenance.
271
THERMOPLASTIC RUBBER COATING AND MASTIC: A coating or mastic formulated
and recommended for application to roofing or other structural surfaces and that
incorporates no less than 40 percent by weight of thermoplastic rubbers in the total
resin solids and may also contain other ingredients including, but not limited to, fillers,
pigments, and modifying resins.
272
TINT BASE: An architectural coating to which colorant is added after packaging in sale
units to produce a desired color.
273
TRAFFIC MARKING COATING: A coating labeled and formulated for marking and
striping streets, highways, or other traffic surfaces including, but not limited to, curbs,
berms, driveways, parking lots, sidewalks, and airport runways.
274
TUB AND TILE REFINISH COATING: A clear or opaque coating that is labeled and
formulated exclusively for refinishing the surface of a bathtub, shower, sink, or
countertop. Tub and Tile Refinish coatings must meet all of the following criteria:
274.1 The coating must have a scratch hardness of 3H or harder and a gouge hardness
of 4H or harder. This must be determined on Bonderite 1000, in accordance with
ASTM D3363-05 (2011)e2, incorporated by reference in Section 503.21.
274.2 The coating must have a weight loss of 20 milligrams or less after 1000 cycles.
This must be determined with CS-17 wheels on Bonderite 1000, in accordance
with ASTM D4060-14, incorporated by reference in Section 503.19.
274.3 The coating must withstand 1000 hours or more of exposure with few or no #8
blisters. This must be determined on unscribed Bonderite, in accordance with
ASTM D4585-99 and ASTM D714-02, incorporated by reference in Section
503.22.
274.4 The coating must have an adhesion rating of 4B or better after 24 hours of
recovery. This must be determined on unscribed Bonderite, in accordance with
ASTM D4585-/D4585M-18 and ASTM D3359-17, incorporated by reference in
Section 503.20.
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275
VARNISH: Clear or pigmented coatings formulated with various resins to dry by
chemical reaction or exposure to air. These coatings are intended to provide a durable,
transparent, or translucent, solid protective film.
276
VENEER: Thin sheets of wood peeled or sliced from logs for use in the manufacture of
wood products such as plywood, laminated veneer lumber, or other products.
277
VIRGIN MATERIALS: Materials that contain no post-consumer coatings or secondary
industrial materials.
278
VOC ACTUAL: The weight of VOC per volume of coating, as calculated acceding to the
formula in Section 502.5 of this rule. VOC Actual must include maximum amount of
thinning solvent recommended by the manufacturer.
279
VOC CONTENT: The weight of VOC per volume of coating. VOC Content is VOC
Regulatory, as defined in Section 280, for all coatings except those in the Low Solids
category. For coatings in the Low Solids category, the VOC Content is VOC Actual, as
defined in Section 278. If the coating is a multi-component product, the VOC content is
VOC Regulatory as mixed or catalyzed. If the coating contains silanes, siloxanes, or
other ingredients that generate ethanol or other VOCs during the curing process, the
VOC content must include the VOCs emitted during curing. VOC Content must include
maximum amount of thinning solvent recommended by the manufacturer. The term
VOC content is a general term used throughout the rule and includes VOC, VOC Actual,
and VOC Regulatory.
280
VOC REGULATORY: The weight of VOC per volume of coating, less the volume of water
and exempt compounds, as calculated according to the formula in Section 502.6 of this
rule. VOC regulatory includes maximum amount of thinning solvent recommended by
the manufacturer.
281
VOLATILE ORGANIC COMPOUND (VOC): See definition in MCAPCR Rule 100 (General
Provisions and Definitions).
282
WATERPROOFING MASTIC COATING: Weatherproof and waterproof coatings which are
formulated to cover holes and minor cracks and to conceal surface irregularities.
283
WATERPROOFING MEMBRANE: A clear or opaque coating that is labeled and
formulated for application to concrete and masonry surfaces to provide a seamless
waterproofing membrane that prevents any penetration of liquid water into the
substrate. Waterproofing Membranes are intended for the following waterproofing
applications: below-grade surfaces, between concrete slabs, inside tunnels, inside
concrete planters, and under flooring materials. Waterproofing Membranes must meet
the following criteria:
283.1 Coating must be applied in a single coat of at least 25 mils (at least 0.025 inch)
dry film thickness; and
283.2 Coatings must meet or exceed the requirements contained in ASTM
C836/C836M-18, incorporated by reference in Section 503.23.
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283.3 The Waterproofing Membrane category does not include topcoats that are
included in the Concrete/Masonry Sealer category (e.g., parking deck topcoats,
pedestrian deck topcoats, etc.).
284
WATERPROOF SEALER: Coatings which are formulated for the sole purpose of
protecting porous substrates by preventing the penetration of water.
285
WOOD COATING: Coatings labeled and formulated for application to wood substrates
only. The Wood Coatings category includes the following clear and semi-transparent
coatings: lacquers; varnishes; sanding sealers; penetrating oils; clear stains; wood
conditioners used as undercoats; and wood sealers used as topcoats. The Wood
Coatings category also includes the following opaque wood coatings; opaque lacquers;
opaque sanding sealers; and opaque lacquer undercoaters. The Wood Coatings
category does not include the following: clear sealers that are labeled and formulated
for use on concrete/masonry surfaces; or coatings intended for substrates other than
wood. Wood Coatings must be labeled “For Wood Substrates Only”, in accordance with
Section 308.4(i).
286
WOOD PRESERVATIVE: A coating labeled and formulated to protect exposed wood
from decay or insect attack, that is registered with both the EPA under the Federal
Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. Section 136, et. seq.) and with the
Arizona Department of Agriculture Pest Management Division.
287
WOOD SUBSTRATE: A substrate made of wood, particleboard, plywood, medium
density fiberboard, rattan, wicker, bamboo, or composite products with exposed wood
grain. Wood Products do not include items comprised of simulated wood.
288
ZINC-RICH PRIMER: A coating that meets all of the following specifications:
288.1 Coating contains at least 65 percent metallic zinc powder or zinc dust by weight
of total solids; and
288.2 Coating is formulated for application to metal substrates to provide a firm bond
between the substrate and subsequent applications of coatings; and
288.3 Coating is intended for professional use only and labeled as such, in accordance
with the labeling requirements in Section 308.4(j).
SECTION 300 – STANDARDS
301
VOC CONTENT LIMITS:
301.1 No person shall manufacture, blend, or repackage for sale within Maricopa
County any architectural coating with a VOC content in excess of the limits as
specified in Table 335-1.
301.2 No person shall supply, sell, or offer for sale within Maricopa County any
architectural coating with a VOC content in excess of the limits as specified in
Table 335-1, except as provided for in Section 304.
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301.3 No person shall solicit for application or apply within Maricopa County any
architectural coating with a VOC content in excess of the limits as specified in
Table 335-1, except as provided for in Section 304.
Table 335-1: VOC Content Limits for Architectural Coatings2
Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Flat Coatings
250
2.1
50
0.4
Non-Flat Coatings
250
2.1
100
0.8
Non-Flat – High Gloss Coatings
N/A
N/A
150
1.3
Specialty Coatings
Aluminum Roof Coatings
N/A
N/A
450
3.8
Basement Specialty Coatings
N/A
N/A
400
3.3
Bituminous Roof Coatings
N/A
N/A
270
2.3
Bituminous Roof Primers
N/A
N/A
350
2.9
Bond Breakers
N/A
N/A
350
2.9
Calcimine Recoaters
N/A
N/A
475
4.0
Concrete Curing Compounds
350
2.9
350
2.9
Concrete/Masonry Sealers
N/A
N/A
100
0.8
Concrete Surface Retarders
N/A
N/A
780
6.5
Conjugated Oil Varnishes
N/A
N/A
450
3.6
Conversion Varnishes
N/A
N/A
725
6.1
Driveway Sealers
N/A
N/A
50
0.4
Dry Fog Coatings
420 (Flat)
400 (Non-Flat)
3.5 (Flat)
3.3 (Non-Flat)
150
1.3
Enamel Undercoaters
350
2.9
N/A
N/A
Faux Finishing Coatings
N/A
N/A
350
2.9
Fire-Resistive Coatings
N/A
N/A
350
2.9
Floor Coatings
N/A
N/A
100
0.8
Form-Release Compounds
N/A
N/A
250
2.1
Graphic Arts Coatings (Sign
Paints)
N/A
N/A
500
4.2
High-Temperature Coatings
N/A
N/A
420
3.5
Impacted Immersion Coatings
N/A
N/A
780
6.5
Industrial Maintenance Coatings
420
3.5
250
2.1
Lacquers
684
5.7
N/A
N/A
Low-Solids Coatings
N/A
N/A
120
1.0
Magnesite Cement Coatings
N/A
N/A
450
3.8
Mastic Texture Coatings
N/A
N/A
100
0.8
2 Limits are expressed as VOC Regulatory, thinned to the manufacturer’s maximum thinning recommendation, excluding any colorant added to tint bases.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Coating Category
Effective until
December 31,
2025
Effective until
December 31,
2025
Effective
January
1, 2026
Effective
January 1,
2026
g VOC/l
lb VOC/gal
g VOC/l
lb VOC/gal
Metallic Pigmented Coatings
N/A
N/A
500
4.2
Multi-Color Coatings
N/A
N/A
250
2.1
Nuclear Coatings
N/A
N/A
450
3.8
Opaque Stains
350
2.9
N/A
N/A
Opaque Wood Preservatives
350
2.9
N/A
N/A
Pre-Treatment Wash Primers
N/A
N/A
420
3.5
Primers, Sealers, and Undercoaters
350
2.9
100
0.8
Quick-Dry Enamels
395
3.3
N/A
N/A
Reactive Penetrating Sealers
N/A
N/A
350
2.9
Reactive Penetrating Carbonate
Stone Sealers
N/A
N/A
500
4.2
Recycled Coatings
N/A
N/A
250
2.1
Roof Coatings
300
2.5
250
2.1
Rust Preventative Coatings
N/A
N/A
250
2.1
Semi-Transparent Stains
350
2.9
N/A
N/A
Semi-Transparent and Clear Wood
Preservatives
350
2.9
N/A
N/A
Shellacs – Clear
N/A
N/A
730
6.1
Shellacs – Opaque
N/A
N/A
550
4.6
Specialty Flat Products
395
3.3
N/A
N/A
Specialty Primers, Sealers, and
Undercoaters
350
2.9
100
0.8
Stains
350
2.9
250
2.1
Stone Consolidants
N/A
N/A
450
3.8
Swimming Pool Coatings
N/A
N/A
340
2.8
Thermoplastic Rubber Coatings
and Mastics
N/A
N/A
550
4.6
Traffic Marking Coatings
250
2.1
100
0.8
Tub and Tile Refinish
N/A
N/A
420
3.5
Varnishes
350
2.9
N/A
N/A
Waterproofing Mastic Coatings
300
2.5
N/A
N/A
Waterproofing Membranes
N/A
N/A
250
2.1
Waterproof Sealers
395
3.3
N/A
N/A
Wood Coatings
N/A
N/A
275
2.3
Wood Preservatives
350
2.9
350
2.9
Zinc-Rich Primers
N/A
N/A
340
2.8
302
COATING CATEGORIZATION: For any coating that does not meet any of the definitions
for the specialty coatings categories listed in Table 335-1, the VOC content limit shall be
determined by classifying the coating as a Flat, Non-Flat, or Non-Flat High Gloss coating
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based on its gloss, as defined in Section 200 and the corresponding Flat, Non-Flat or
Non-Flat High Gloss coating VOC content limit in Table 335-1 shall apply.
303
MOST RESTRICTIVE VOC CONTENT LIMIT: Except for the specialty coating categories
specified below, if a coating is recommended for use in more than one of the specialty
coating categories listed in Table 335-1, then the most restrictive (or lowest) specialty
coating VOC content limit shall apply. This requirement applies to usage
recommendations that appear on the coating container, anywhere on any label or
sticker affixed to the container, or in any sales, advertising, or technical literature
supplied by a manufacturer or anyone acting on their behalf.
303.1 Aluminum roof coatings.
303.2 Bituminous roof primers.
303.3 High-temperature coatings.
303.4 Industrial maintenance coatings.
303.5 Low-solids coatings.
303.6 Metallic pigmented coatings.
303.7 Pre-treatment wash primers.
303.8 Shellacs.
303.9 Specialty primers, sealers, and undercoaters.
303.10 Wood coatings.
303.11 Wood preservatives.
303.12 Zinc-rich primers.
304
SELL-THROUGH OF COATINGS: A coating manufactured prior to the effective date
specified for that coating in Table 335-1, and that complied with the standards in effect
at the time the coating was manufactured may be sold, supplied, or offered for sale for
up to three years after the specified effective date. In addition, a coating manufactured
before the effective date specified for that coating in Table 335-1 may be applied at any
time, both before and after the specified effective date, so long as the coating complied
with the standards in effect at the time the coating was manufactured. This Section
does not apply to any coating that does not display the date or date code required by
Section 308.
305
THINNING: No person who applies or solicits the application of any architectural
coating shall apply a coating that is thinned to exceed the applicable VOC limit specified
in Table 335-1.
306
PAINTING PRACTICES: All architectural coating containers used to apply the contents
therein to a surface directly from the container by pouring, siphoning, brushing, rolling,
padding, ragging, or other means, shall be closed when not in use. These architectural
coatings containers include, but are not limited to, drums, buckets, cans, pails, trays, or
other application containers. Containers of any VOC-containing materials used for
thinning and cleanup shall also be closed when not in use.
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307
RUST PREVENTATIVE COATINGS: No person shall apply or solicit the application of any
rust preventative coating, manufactured before January 1, 2026, for industrial use,
unless such a rust preventative coating complies with the industrial maintenance
coating VOC content limit specified in Table 335-1.
308
CONTAINER LABELING REQUIREMENTS: Each manufacturer of any architectural
coatings subject to this rule shall display the information listed below on the coating
container (or label) in which the coating is sold or distributed.
308.1 Date Code: The date the coating was manufactured, or a date code representing
the date, shall be indicated on the label, lid, or bottom of the container. If the
manufacturer uses a date code for any coating, the manufacturer shall file an
explanation of each code with the Control Officer.
308.2 Thinning Recommendations: A statement of the manufacturer's
recommendation regarding thinning of the coating shall be indicated on the label
or lid of the container. This requirement does not apply to the thinning of
architectural coatings with water. If thinning of the coating prior to use is not
necessary, the recommendation must specify that the coating is to be applied
without thinning.
308.3 VOC Content: Each container of any coating subject to this rule shall display one
of the following values in either grams of VOC per liter or pounds of VOC per
gallon of coating:
a. Maximum VOC Content as determined from all potential product
formulations; or
b. VOC Content as determined from actual formulation data; or
c. VOC Content as determined using the test methods in Section 502.2.
d. If the manufacturer does not recommend thinning, the container must display
the VOC Content, as supplied. If the manufacturer recommends thinning, the
container must display the VOC Content including the maximum amount of
thinning solvent recommended by the manufacturer.
e. If the coating is a multi-component product, the container must display the
VOC content as mixed or catalyzed. If the coating contains silanes, siloxanes,
or other ingredients that generate ethanol or other VOCs during the curing
process, the VOC content must include the VOCs emitted during curing. VOC
Content shall be determined as defined in Section 200.
308.4 Labeling Requirements for Specific Coating Categories:
a. Faux Finishing Coatings: The labels of all clear topcoat Faux Finishing
Coatings shall prominently display the statement “This product can only be
sold or used as part of a Faux Finishing coating system.”
b. Industrial Maintenance Coatings: The labels of all Industrial Maintenance
Coatings shall prominently display at least one of the following statements:
(1) "For industrial use only" or;
(2) "For professional use only" or;
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(3) "Not for residential use" or;
(4) "Not intended for residential use."
c. Non-Flat – High Gloss Coatings: The labels of all Non-Flat High Gloss
Coatings shall prominently display the words "High Gloss."
d. Reactive Penetrating Carbonate Stone Sealers: The labels of all Reactive
Penetrating Carbonate Stone Sealers shall prominently display the statement
“Reactive Penetrating Carbonate Stone Sealer.”
e. Reactive Penetrating Sealers: The labels of all Reactive Penetrating Sealers
shall prominently display the statement “Reactive Penetrating Sealer.”
f. Rust Preventative Coatings: The labels of all Rust Preventative Coatings shall
prominently display the statement "For Metal Substrates Only."
g. Specialty Primers, Sealers, and Undercoaters: The labels of all Specialty
Primers, Sealers, and Undercoaters shall prominently display one or more of
the following descriptions:
(1) For fire-damaged substrates.
(2) For smoke-damaged substrates.
(3) For water-damaged substrates.
h. Stone Consolidants: The labels of all Stone Consolidants shall prominently
display the statement “Stone Consolidant – For Professional Use Only.”
i. Wood Coatings: The labels of all Wood Coatings shall prominently display the
statement “For Wood Substrates Only.”
j. Zinc Rich Primers: The labels of all Zinc Rich Primers shall prominently
display one or more of the following statements listed below:
(1) “For Professional Use Only”
(2) “For Industrial Use Only”
(3) “Not for residential use” or “Not intended for residential use.”
SECTION 400 – ADMINISTRATIVE REQUIREMENTS (NOT APPLICABLE)
SECTION 500 – MONITORING AND RECORDS
501
RECORDKEEPING AND REPORTING: Any person manufacturing, blending, and/or
repackaging architectural coatings subject to this rule shall comply with the following
recordkeeping requirements:
501.1 Records shall be retained for a period of five years.
501.2 Records shall be made available to the Control Officer no later than five business
days upon verbal or written request.
501.3 Records shall be made available to the Control Officer upon request by members
of the public using the County’s public records request process.
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501.4 Records shall be kept on site at all times in a consistent and complete manner.
501.5 Current List: Maintain a current list of all VOC-containing materials subject to this
rule. The list shall express VOC content in one of the following forms:
a. Pounds VOC per gallon; or
b. Grams VOC per liter.
501.6 Monthly Usage Records: Maintain monthly records of the amount purchased or
used of all VOC-containing materials subject to this rule. Records shall be totaled
by the end of the month for the previous month.
501.7 Discarded Materials: Maintain monthly records of the type, amount, and method
of disposing of VOC-containing materials. Records of legal disposal include but
are not limited to shipping papers or quantity discharged to sewage treatment
works.
501.8 Sales Data: A responsible official from each manufacturer shall upon request of
the Control Officer, provide data concerning the distribution and sales of
architectural coatings. The responsible official shall within 180 days provide
information, including but not limited to:
a. Name and mailing address of the manufacturer;
b. Name, address, and telephone number of a contact person;
c. Name of the coating product as it appears on the label and the applicable
coating category;
d. Whether the product is marketed for interior or exterior or both;
e. Number of gallons sold in Maricopa County in containers greater than one
liter (1.057 quart) and equal to or less than one liter (1.057 quart);
f. VOC Actual content and VOC Regulatory content in either grams per liter or
pounds per gallon. If thinning is recommended, list the VOC Actual content
and VOC Regulatory content after maximum recommended thinning. If
containers less than one liter have a different VOC content than containers
greater than one liter, list separately. If the coating is a multi-component
product, provide the VOC content as mixed or catalyzed.
g. Names and Chemical Abstracts Service (CAS) numbers of the VOC
constituents in the product;
h. Names and CAS numbers of any exempt organic compounds in the product;
i. Whether the product is marketed as solvent-borne, waterborne or 100 percent
solids;
j. Description of resin or binder in the product;
k. Whether the coating is a single-component or multi-component product;
l. Density of the product in pounds per gallon;
m. Percent by weight of solids, all volatile materials, water, and any exempt
organic compounds;
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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n. Percent by volume of solids, water, and any exempt organic compounds.
501.9 All sales data listed above in Section 501.8 shall be maintained by the
responsible official for a minimum of three years. Sales data submitted by the
responsible official to the Control Officer may be claimed as confidential, and
such information shall be handled in accordance with MCAPCR Rule 100
(General Provisions and Definitions) Section 402.
502
COMPLIANCE DETERMINATION: When more than one test method is permitted for a
determination, an exceedance of the limits established in this rule determined by any of
the applicable test methods constitutes a violation of this rule.
502.1 Calculation of VOC Content: For the purpose of determining compliance with the
VOC content limits in Table 335-1, the VOC content of a coating shall be
determined as defined in Section 200. The VOC content of a tint base shall be
determined without colorant that is added after the tint base is manufactured. If
the manufacturer does not recommend thinning, the VOC Content must be
calculated for the product as supplied. If the manufacturer recommends thinning,
the VOC Content must be calculated including the maximum amount of thinning
solvent recommended by manufacturer. If the coating is a multi-component
product, the container must display the VOC Content as mixed or catalyzed. If the
coating contains silanes, siloxanes, or other ingredients that generate ethanol or
other VOCs during the curing process, the VOC Content must include the VOCs
emitted during curing.
502.2 VOC Content of Coatings: The VOC content of coatings shall be determined by
the following:
a. To determine the physical properties of a coating in order to perform the
calculations in Sections 278 and 280, the reference method for VOC content
is EPA Method 24, incorporated by reference in Section 503.24, except as
provided in Sections 503 and 504.
b. An alternative method to determine the VOC content of coatings is SCAQMD
Method 304-91 (Revised 1996), incorporated by reference in Section 503.25.
c. The exempt compounds content shall be determined by SCAQMD Method
303-91 (Revised 1996), Bay Area Air Quality Management District (BAAQMD)
Method 43 (Revised 2005), or BAAQMD Method 41 (Revised 2005), as
applicable, incorporated by reference in Sections 503.2, 503.3, and 503.4.
d. To determine the VOC content of a coating, the manufacturer may use EPA
Method 24, or an alternative method as provided in Section 502.3, formulation
data, or any other reasonable means for predicting that the coating has been
formulated as intended (e.g., quality assurance checks, recordkeeping).
However, if there are any inconsistencies between the results of a Method 24
test and any other means for determining VOC content, the Method 24 test
results will govern, except when an alternative method is approved as
specified in Section 502.3.
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e. To determine the VOC content of a coating with a VOC content of 150 g/L or
less, the manufacturer may use SCAQMD Method 313, incorporated by
reference in Section 503.26, ASTM D6886-18, incorporated by reference in
Section 503.27, or any other reasonable means for predicting that the coating
has been formulated as intended (e.g., quality assurance checks,
recordkeeping).
502.3 Alternative Test Methods: Other test methods demonstrated to provide results
that are acceptable for purposes of determining compliance with Section 502.2,
after review and approved by the Control Officer, and the EPA, may also be used.
502.4 Methacrylate Traffic Coating Markings: Analysis of methacrylate mufti-
component coatings used as traffic marking coatings shall be conducted
according to a modification of EPA Method 24 (40 CFR 59, Subpart D, Appendix
A). This method has not been approved for methacrylate multicomponent
coatings used for other purposes than as traffic marking coatings or for other
classes of multicomponent coatings.
502.5 Formula for VOC Actual: Units of VOC Actual are in pounds of VOC per gallon (or
grams per liter) of material and shall be calculated using the following equation:
VOC Actual =
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚
Using consistently either English or metric measures in the calculations, where:
Ws =
weight of all volatile material in pounds (or grams), including
VOC, water, non-precursor organic compounds and dissolved
vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or
grams)
Vm =
volume of total material in gallons (or liters)
502.6 Formula for VOC Regulatory: Units of VOC Regulatory are in pounds of VOC per
gallon (or grams per liter) of material and shall be calculated using the following
equation:
VOC Regulatory =
𝑊𝑊𝑠𝑠−𝑊𝑊𝑤𝑤−𝑊𝑊𝑒𝑒𝑒𝑒
𝑉𝑉𝑚𝑚−𝑉𝑉𝑤𝑤−𝑉𝑉𝑒𝑒𝑒𝑒
Using consistently either English or metric measures in the calculations, where:
Ws = weight of all volatile material in pounds (or grams), including VOC,
water, non-precursor organic compounds and dissolved vapors
Ww = weight of water in pounds (or grams)
Wes = weight of all non-precursor organic compounds in pounds (or grams)
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
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Using consistently either English or metric measures in the calculations, where:
Vm = volume of total material in gallons (or liters)
Vw = volume of water in gallons (or liters)
Ves = volume of all non-precursor organic compounds in gallons (or liters)
503
TEST METHODS INCORPORATED BY REFERENCE: The following test methods are
approved for use for the purpose of determining compliance with this rule. The test
methods are incorporated by reference in Rule 360 and Appendix G of the MCAPCR.
Alternative test methods as approved by the Administrator or other EPA-approved test
methods may be used upon prior written approval from the Control Officer. When more
than one test method is permitted for the same determination, an exceedance under
any method will constitute a violation. All test methods referenced in this rule shall be
the version most recently approved by the appropriate government entities.
503.1
Acid Content of Coatings: The acid content of a coating shall be determined
by ASTM D1613-17, “Standard Test Method for Acidity in Volatile Solvents
and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related
Products,” (See Section 249, Pre-Treatment Wash Primer).
503.2
Exempt Compounds – Siloxanes: Exempt compounds that are cyclic,
branched, or linear, completely methylated siloxanes, shall be analyzed as
exempt compounds for compliance with Section 502 by BAAQMD Method 43,
"Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks,
and Related Materials," BAAQMD Manual of Procedures, Volume III, adopted
November 6, 1996, (See Section 281, Volatile Organic Compounds, and
Section 502.2).
503.3
Exempt Compounds – Parachlorobenzotrifluoride (PCBTF): The exempt
compound parachlorobenzotrifluoride, shall be analyzed as exempt
compounds for compliance with Section 502 by BAAQMD Method 41,
“Determination of Volatile Organic Compounds in Solvent Based Coatings and
Related Materials Containing Parachlorobenzotrifluoride,” BAAQMD Manual of
Procedures, Volume III, adopted December 20, 1995, (See Section 281,
Volatile Organic Compounds, and Section 502.2).
503.4
Exempt Compounds: The content of compounds exempt under EPA Method
24 shall be analyzed by SCAQMD Method 303-91 (Revised 1996),
“Determination of Exempt Compounds,” SCAQMD Laboratory Methods of
Analysis for Enforcement Samples (See Section 281, Volatile Organic
Compounds, and Section 502.2).
503.5
Fire Resistance Rating: The fire resistance rating of a fire-resistive coating
shall be determined by ASTM E119-18ce1, “Standard Test Methods for Fire
Tests of Building Construction Materials,” (See Section 224, Fire-Resistive
Coating).
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503.6
Gloss Determination: The gloss of a coating shall be determined by ASTM
D523-14 (2018), “Standard Test Method for Specular Gloss,” (See Section 225
- Flat Coating, Section 240 - Non-Flat Coating, and Section 241 - Non-Flat High
Gloss Coating).
503.7
Hydrostatic Pressure for Basement Specialty Coatings: ASTM D7088-17,
“Standard Practice for Resistance to Hydrostatic Pressure for Coatings Used
in Below Grade Applications Applied to Masonry” (See Section 206, Basement
Specialty Coating).
503.8
Metal Content of Coatings: The metallic content of a coating shall be
determined by SCAQMD Method 318-95, ”Determination of Weight Percent
Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD “Laboratory
Methods of Analysis for Enforcement Samples,” (See Sections 203, 223, and
238; Aluminum Roof Coating, Faux Finish Coating, and Metallic Pigmented
Coating).
503.9
Methacrylate Traffic Marking Coatings: The VOC content of methacrylate
multicomponent coatings used as traffic marking coatings shall be analyzed
by the procedures in 40 CFR 59, Subpart D, Appendix A, "Determination of
Volatile Matter Content of Methacrylate Multicomponent Coatings Used as
Traffic Marking Coatings," (September 11, 1998), (See Section 502.4).
503.10
Mold and Mildew Growth for Basement Specialty Coatings: ASTM D3273-16,
“Standard Test Method for Resistance to Growth of Mold on the Surface of
Interior Coatings in an Environmental Chamber” and ASTM D3274-09 (2017),
“Standard Test Method for Evaluating Degree of Surface Disfigurement of
Paint Films by Microbial (Fungal or Algal) Growth or Soil and Dirt
Accumulation” (See Section 206, Basement Specialty Coating).
503.11
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Water Repellency: ASTM C67/C67M-18, “Standard Test Methods for
Sampling and Testing Brick and Structural Clay Tile”, or ASTM C97/C97M-18,
“Standard Test Method for Absorption and Bulk Specific Gravity of Dimension
Stone”, or ASTM C140/C140M-18a, “Standard Test Methods for Sampling and
Testing Concrete Masonry Units and Related Units” (See Section 252,
Reactive Penetrating Carbonate Stone Sealer and Section 253, Reactive
Penetrating Sealer).
503.12
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Water Vapor Transmission: ASTM E96/E96M-16, “Standard Test
Method for Water Vapor Transmission of Materials” (See Section 252,
Reactive Penetrating Carbonate Stone Sealer and Section 253, Reactive
Penetrating Sealer).
503.13
Reactive Penetrating Sealer and Reactive Penetrating Carbonate Stone
Sealer – Chloride Screening Applications: National Cooperative Highway
Research Report 244 (1981), “Concrete Sealers for the Protection of Bridge
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Structures” (See Section 252, Reactive Penetrating Carbonate Stone Sealer
and Section 253, Reactive Penetrating Sealer).
503.14
Stone Consolidant: ASTM E2167-01 (2008), “Standard Guide for Selection
and Use of Stone Consolidants” (See Section 269, Stone Consolidant).
503.15
Nuclear Coating: The radiation resistance of a nuclear coating shall be
determined by ASTM D4082-02 “Standard Test Method for Effects of Gamma
Radiation on Coatings for Use in Light-Water Nuclear Power Plants” (See
Section 242, Nuclear Coating).
503.16
Nuclear Coating: The chemical resistance of nuclear coatings shall be
determined by ASTM D3912-95 (2001) “Standard Test Method for Chemical
Resistance of Coatings Used in Light-Water Nuclear Power Plants” (See
Section 242, Nuclear Coating).
503.17
Specialty Primer, Sealer and Undercoater – Surface Chalkiness: The
chalkiness of a surface shall be determined using ASTM D4214-98, “Standard
Test Methods for Evaluating the Degree of Chalkiness of Exterior Paint Films,”
(See Section 266, Specialty Primer, Sealer, and Undercoater).
503.18
Tub and Tile Refinish Coating – Absorption: Performance criteria for
penetration of dense tile shall be determined by ASTM C373-18 “Standard
Test Method for Water Absorption, Bulk Density, Apparent Porosity, and
Apparent Specific Gravity of Fired Whiteware Products, Ceramic Tiles and
Glass Tiles, “or by ASTM C97/C97M-18 “Standard Test Methods for
Absorption and Bulk Specific Gravity of Dimension Stone,” or by ASTM C642-
13 “Standard Test Method for Density, Absorption and Voids in Hardened
Concrete” (See Section 274, Tub and Tile Refinish Coating).
503.19
Tub and Tile Refinish Coating – Abrasion Resistance: ASTM D4060-14,
“Standard Test Method for Abrasion Resistance of Organic Coatings by the
Taber Abraser” (See Section 274, Tub and Tile Refinish Coating).
503.20
Tub and Tile Refinish Coating – Adhesion: ASTM D4585/4585M-18,
“Standard Practice for Testing Water Resistance of Coatings Using Controlled
Condensation” and ASTM D3359-17, “Standard Test Method for Measuring
Adhesion by Tape Test” (See Section 274, Tub and Tile Refinish Coating).
503.21
Tub and Tile Refinish Coating – Hardness: ASTM D3363-05 (2011)e2,
“Standard Test Method for Film Hardness by Pencil Test” (See Section 274,
Tub and Tile Refinish Coating).
503.22
Tub and Tile Refinish Coating – Water Resistance: ASTM D4585-99,
“Standard Practice for Testing Water Resistance of Coatings Using Controlled
Condensation” and ASTM D714-02 (2017), “Standard Test Method for
Evaluating Degree of Blistering of Paints” (See Section 274, Tub and Tile
Refinish Coating).
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503.23
Waterproofing Membrane: ASTM C836/836M-18, “Standard Specification for
High Solids Content, Cold Liquid-Applied Elastomeric Waterproofing
Membrane for Use with Separate Wearing Course” (See Section 283,
Waterproofing Membrane).
503.24
VOC Content of Coatings: The VOC content of a coating shall be determined
by EPA Method 24 as it exists in Appendix A of 40 Code of Federal
Regulations (CFR) Part 60, "Determination of Volatile Matter Content, Water
Content, Density, Volume Solids, and Weight Solids of Surface Coatings," (See
Section 502.2).
503.25
Alternative VOC Content of Coatings: The VOC content of coatings may be
analyzed either by EPA Method 24, or SCAQMD Method 304-91 (Revised
1996), “Determination of Volatile Organic Compounds (VOC) in Various
Materials,” SCAQMD “Laboratory Methods of Analysis for Enforcement
Samples,” (See Section 502.2).
503.26
VOC Content of Coatings: SCAQMD Method 313, “Determination of Volatile
Organic Compounds (VOC) by Gas Chromatography/Mass
Spectrometry/Flame Ionization Detection (GS/MS/FID),” (See Section 502.2).
503.27
VOC Content of Coatings: ASTM D6886-18, “Standard Test Method for
Determination of the Weight Percent Individual Volatile Organic Compounds
in Waterborne Air-Dry Coatings by Gas Chromatography,” (See Section 502.2).
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 91 of 109
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 271-8374.
1
BOARD OF HEALTH MEETING MINUTES
April 22, 2024 | 3:00-5:00 pm
4041 N. Central Avenue, 14th Floor, Phoenix, AZ
Legal Advice - A.R.S. §38-431.03(A)(3)
The Board may vote to go into Executive Session for the purpose of discussion or consultation for legal advice with the attorney or
attorneys of the Board on any matter listed on the agenda pursuant to A.R.S. §38-431.03 (A)(3). Board of Health members will attend
in person or by telephone conference call. Members attending telephonically will be announced at the meeting. Agendas are available
within 24 hours of each meeting in the Public Health Administration office at 4041 N. Central Ave., 14th floor, Monday through Friday
between 8:00 a.m. and 5:00 p.m.
ITEM
TOPIC/ACTION
TYPE
PRESENTER
1.
Call to Order: The meeting was called to order at 3:08 pm.
A. Roll Call
Members Present: Supervisor Bill Gates, Cynthia Hardy, Robert
MacMillan, Veronica Oros, Joanne Osborne, Mary Schraven,
Stefanie Schroeder
Members Absent: Debra Baldauff, Matthew Farber, Lorenzo
Sierra
•
A quorum of (6) members was confirmed.
B. Call to the public: Unite Here, Local 11 Union, representative
Jordan Greenslade, spoke to inform the Board of Health of a
potential compliance issue with Maricopa County Environmental
Health Code regulations by SSP America.
Blanca Caballero, Environmental Services Executive Director, met
with all representatives from Unite Here to set up a meeting.
Action
President
Osborne
2.
Approval of Minutes
President Osborne asked the Board for a motion to approve the
January 22, 2024 minutes.
Motion: Robert MacMillan
Second: Stefanie Schroder
Motion status: Approved unanimously
Action
President
Osborne
Return to list of attachments
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 92 of 109
2
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
3.
Appointment of Dr. Stefanie Schroeder
Overview: Jeanene Fowler introduced and read Stefanie’s bio.
•
Graduated from Medical school in 1990
•
Board Certified in Emergency Medicine
•
10 years as a Physician at Banner Baywood Medical Center
•
16 years as ASU Chief of Medical Staff
Discuss
Jeanene Fowler
4.
Public Health Finance
Make a recommendation to the Board of Supervisors to approve the
Public Health Fiscal Year 2025 budget request as recommended by
the Maricopa County Budget Office.
•
Ms. Osborne requested clarification on the Special Revenue
Fee Fund. Jeanene explained the process to which Public
Health bills health plans for vaccinations and that often it
can take upwards of a year to receive reimbursement. Next
year’s budget is the best projection on how much we may be
reimbursed based on historical billing.
•
Ms. Schroder asked for clarification on “ARPA.” Jeanene
explained these are American Recue Plan Funds used for
projects related to the pandemic.
•
Ms. Osborne mentioned ARPA Fund needing to be used for
hiring. Jeanene confirmed the ARPA fund will end December
2026, but no jobs lost because of it.
Motion: Stefanie Schroder
Second: Mary Schraven
Motion status: Approved unanimously
Discuss/
Action
Ray Farrish
5.
Environmental Services Finance
Make a recommendation to the Board of Supervisors to approve the
Environmental Services Fiscal Year 2025 budget request as
recommended by the Maricopa County Budget Office
•
Ms. Donaldson called out a change to Fund 100 (since
budget letter was sent out to Board) – Expenditures dropped
from $13,523,785 to $10,897,837 due to risk management
lowering the assessment for the closed landfills Maricopa
County has.
•
Ms. Osborne asked for clarification on Fund 100. Ms.
Donaldson clarified $463,100 is all revenue from multiple
sources and then allocated out. $10,897,837 is spending
authority.
Discuss/
Action
Sylvie
Donaldson
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 93 of 109
3
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
•
Fund 290: Mr. MacMillan commented on current state of tire
sales. Ms. Donaldson stated tire sales are expected to
increase. There is a delayed revenue on tire sales. Won’t
come until following year.
•
Fund 506: Ms. Donaldson stated the entire budget is
reflected in the $26,317,620 that includes an increase of
county wide allocations that have gone up and assessments
from Central Services Cost Allocation.
Motion: Robert MacMillan
Second: Mary Schraven
Motion status: Approved unanimously
6.
Environmental Services Dept. Fee Waiver Applications
Request for Board of Health approval of Twenty-three (23) fee
waiver applicants – P1-P22 & C1
•
Ms. Osborne asked what the fee for Valley Life was for.
Supervisor Gates confirmed that the Fee Waiver for Valley
Life are start up fees for a new location.
Motion: Mary Schraven
Second: Stefanie Schroder
Motion status: Approved unanimously
Discuss/
Action
Robert
Stratman
7.
Air Quality Department
Approve initiation of regulatory change for the following rule:
A. AQ-2023-005
Rule 327 (Organic Material Processing)
The Maricopa County Air Quality Department (MCAQD) is proposing
to create Rule 327 to limit the emissions of volatile organic
compounds (VOCs) and ammonia from organic material processing
operations and prevent emissions of fine particulate matter (PM2.5)
and nitrogen oxides (NOx) from combustion of organic material
processing operations.
•
Mr. MacMillan asked if EPA is requiring this rule. Mr.
Verkamp stated they are seeking approval to begin the
process of revising the rule to gain more reductions of
ozone precursors. They are reviewing all kinds of measures
of hosting. Organic material processing is just one area to
comply with the National Ambient Air Quality.
Discuss/
Action
Gregory
Verkamp
Kimberly Butler
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 94 of 109
4
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
•
This rule will limit the emissions of volatile organic
compounds along with ammonia from organic material
processing operations and prevent emissions of fine particle
matter and nitrogen oxides as well.
•
Stakeholder workshop has been held March 2024. Feedback
was received and meetings have been held to get process in
motion. Plans are to have another Stakeholder workshop.
•
Exemptions that will be built into the rule:
- Farmers who use manure for composting and not selling it
- Residential neighborhoods gardening that are doing
composting
- There will be an applicability level built into the rule for
businesses that are selling compost
•
The rule will also include permitting thresholds –
example would be if a business emits a certain amount
of a particular pollution.
•
Rule will help reduce emissions by 60-70%. Reduction will
continue as industry grows.
•
Rule will only affect large businesses. No residential areas
will be affected.
•
Mr. MacMillan asked what the cost benefit would be. Ms.
Butler stated the Cost benefit has not been completed at
this time. It is estimated that there will be minimal cost to
the businesses verses 100’s of tons per year saved in VOC
emissions. Seeking to put fire management systems into
place as well as part of this rule.
•
Ms. Osborne asked if businesses would incur new fees
because of the new rule. Mr. Verkamp & Ms. Butler shared
that they are seeking to make it a general permit to avoid
additional new fees. Many businesses already have the Dust
Prevention Permit. Still working with the Permit group. This
would add provisions into an existing permit –
approximately $350/year.
•
Ms. Osborne asked if a business does have a fire, would
they get fined. Ms. Butler responded should a business have
a fire/situation, each incident is looked at individually and
reviewed under same permit. All paperwork is under same
Dust permit.
•
Ms. Osborne asked how many fires a year do we see from
this happening. Ms. Butler stated there is approximately one
major fire from composting every 18 months but cannot
state for sure.
•
Ms. Osborne asked how many businesses this will affect.
Ms. Butler stated as of right now the number of businesses
affected is still unknown as it is too early to tell.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 95 of 109
5
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
•
Ms. Osborne asked if Air Quality will be reaching out to the
Stakeholders. Mr. Verkamp stated, yes. They have sent out
emails to create a contact list. They reach out to the
stakeholders at each step of their process. They have one-
on-one meetings with them all the time to figure out proper
language, what is working and what isn’t.
•
Ms. Osborne asked for an example of what this rule affects
and how it will help. Ms. Butler responded that this rule will
directly affect the moderate ozone nonattainment we are
currently in. Within the next approximate year, we could
potentially be in serious nonattainment ozone. It will help
reduce precursors which in turn will help reduce the ozone.
Motion: Robert MacMillan
Second: Stefanie Schroder
Motion status: Approved unanimously
B. AQ-2024-002
Rule 335 (Architectural Coatings)
MCAQD is proposing to revise Rule 335 to assist towards
attainment of the ozone National Ambient Air Quality Standards by
lowering many of the architectural coating VOC content limitations
in the rule and adding additional coating VOC content limitations to
the rule to reflect standards in the Ozone Transport Commission
Model Rule “Architectural and Industrial Maintenance (AIM)
Coatings”.
•
Seeking emission reductions of volatile organic compounds
that lead to the creation of ozone.
•
Seeking to lower VOC content limitations in the rule and to
add additional VOC content limitations to the rule based off
the Ozone Transport Commission Model Rule.
•
Ms. Osborne asked what government level holds the Ozone
Transport Commission Model Rule. Mr. Verkamp stated it is
an organization created by the EPA to address ozone issues
in Northeast Ohio and other small eastern states. They have
already created rules that other parts of the country have
used. AQD would like to incorporate these standards into
other rule proposals.
•
Ms. Osborne asked for clarification on what ‘Architectural
Coating’ is. Mr. Verkamp confirmed it is paint. The strategy
of the rule is to go to paint manufacturers and require them
to change their blends, so the vault organic compound
content meets the rule.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 96 of 109
6
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
•
Ms. Osborne asked if such a product is already available or
would this rule cause a problem or cause an increase in the
product. Mr. Verkamp responded to say they are currently
looking into it by working with consultants to gauge what is
currently being sold in stores and to ensure they are meeting
OTC standards.
•
Mr. Verkamp stated if rule is adopted, it would give
manufacturers and sellers a year to come into compliance
by changing blends, labels, etc.
•
Ms. Osborne asked if any paint manufacturers are local. Mr.
Verkamp stated they are reaching to the American Coding
Association, who represents the businesses that attended
the workshop.
Motion: Mary Schraven
Second: Stefanie Schroder
Motion status: Approved unanimously
Air Quality Department
Approve expedited process rulemaking for the following rule:
C. AQ-2024-003
Ordinance P-21 (Vehicle Idling Restriction)
MCAQD is proposing to revise Ordinance P-21 to add provisions to
require all persons currently required to complete basic or
comprehensive dust control training to complete idle reduction
training. The training will be incorporated into existing training
programs that operators are already required to complete due to
fugitive dust training requirements in Rule 310 (Fugitive Dust from
Dust-Generating Operations) and Rule 316 (Nonmetallic Mineral
Processing).
•
Proposing to require those who already take the Dust
Control Training to also take an Idle Reduction Training.
•
This only calls for additional slides to be added to the
current PowerPoint presentation training slide deck for Dust
Control Training.
•
Ms. Osborne asked if public transportation is involved. Mr.
Verkamp confirmed this does not include public
transportation, only for heavy equipment vehicles.
Motion: Robert MacMillan
Second: Stefanie Schroder
Motion status: Approved unanimously
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 97 of 109
7
NOTICE OF ACCOMMODATIONS: Individuals with disabilities. Assistive listening devices, large-printed materials, special parking
arrangements, and other accommodations are available with 72 hours advance notice. If you require accommodations to participate
in the above meeting, please contact Nicole Harden (PHS) at (480) 281-8374.
8.
Air Quality Department
Revisions to Air Quality Enhanced Regulatory Outreach Program
Process Flow Charts
•
Ms. Osborne asked if any points in time are being taken
away from the public. Mr. Verkamp stated they over 90
days and can provide input until taken to the Board of
Supervisors. They are also allowed to attend the
workshop as well.
•
Mr. MacMillan suggested to add in an email verification
step of the EROP process informing businesses and
stakeholders of an upcoming change to a rule to keep
them more informed.
Discuss
Gregory
Verkamp
Kimberly Butler
9.
Maricopa County Department of Public Health
Heat Relief Update (PPT Presentation)
•
Goal 1 is to secure appropriate transportation and call
center support utilizing existing Promotora Program that
also provide call center services through Solari 211
•
Goal 2 is to increase awareness with signage for heat relief
locations
•
Goal 3 is to expand cooling center hours. Seeking to have a
minimum of one cooling/respite center open until 7pm
•
The question was posed what the transportation is going to
look like. Ms. Fowler responded that there is a contract with
Lyft, which is plan A. Working with Solari for a plan B.
•
Ms. Osborne asked if Opioid settlement funds can be used
for the cooling and respite centers. Ms. Fowler stated they
will be using the opioid settlements funds by putting
naloxone at all cooling centers.
•
Please see presentation for additional information
Discuss
Jeanene Fowler
10.
Adjournment:
•
Ms. Osborne requested an agenda item be added to the next
meeting to add an Executive Committee
•
The meeting adjourned at 4:53 pm
•
Motion to adjourn: Mary Schraven
•
Second: Stefanie Schroder
•
Motion status: Approved unanimously
Action
President
Osborne
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 98 of 109
Minutes from Board of Health meeting October 28, 2024
(Pending)
Return to list of attachments
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 99 of 109
2
From: Dave Carey <DaveCarey@wrmeadows.com>
Sent: Friday, April 5, 2024 10:41 AM
To: Hannah Luke (AQD) <Hannah.Luke@Maricopa.gov>
Subject: Rule 335
Good Afternoon Hannah, At the stakeholder meeting yesterday WR Meadows suggested that the Maximum VOC content for the form release category in the new version of Rule 335 be reduced from 250 g/l to 100 g/l. I have attached two SDS’s for
Good AŌernoon Hannah,
At the stakeholder meeƟng yesterday WR Meadows suggested that the Maximum VOC content for the
form release category in the new version of Rule 335 be reduced from 250 g/l to 100 g/l. I have aƩached
two SDS’s for products WR Meadows currently sells. Note the VOC contents are less than 100 g/l.
Many years ago a winter-grade form release was sold in the market. This product typically had a diesel
fuel component to enhance applicaƟon in colder weather. Those products are no longer sold and with
the climate in Maricopa County I don’t think they would ever be needed.
Thanks for your consideraƟon
Dave Carey
Dave Carey
Vice President, EH&S | W. R. Meadows, Inc.
Office: 847-214-2100 | Toll Free: 800-825-5976
Email: DaveCarey@wrmeadows.com | Web: https://www.wrmeadows.com
<image002.jpg>
This email and its attachments, if any, are intended for the personal use of the named recipient(s) and may contain
confidential, privileged, or proprietary information. If you are not a named recipient, or an agent responsible for
delivering it to a named recipient, you have received this email in error. In that event, please (a) immediately notify
me by reply email, (b) do not review, copy, save, forward, or print this email or any of its attachments, and (c)
immediately delete and/or destroy this email and its attachments and all electronic and physical copies thereof.
Thank you.
Copies of all written and electronic Stakeholder input
Return to list of attachments
Return to Stakeholder #1: Comment #1
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 100 of 109
Address:
|1|
|0|
|0|
| |
CAS
% by
SARA
Number
Weight
313
SAFETY DATA SHEET
Product Use:
Concrete Form Release Agent
Vapor Pressure
(mm Hg@20°C)
SAFE STORAGE: Keep containers closed when not in use.
SECTION 1: PRODUCT AND COMPANY IDENTIFICATION
Product:
Manufacturer:
DUOGARD®
W. R. Meadows®, Inc.
Telephone:
(847) 214-2100
Revision Date:
09/21/2023
Part Number: 3915000
Page 1 of 3
Hampshire, Illinois 60140
300 Industrial Drive
In case of emergency, dial (800) 424-9300 (CHEMTREC)
FLASHPOINT: 329 °F (Minimum)
EXTINGUISHING MEDIA: Water fog, foam, dry chemical, carbon dioxide.
SAFE HANDLING PROCEDURES: Avoid direct contact.
SKIN CONTACT: Wash affected areas with mild soap and water. Remove contaminated shoes/clothing. If symptoms
EYE CONTACT: Flush eyes with water for fifteen (15) minutes. If symptoms persist, seek medical attention.
Chemical Name:
1. None
SECTION 6: ACCIDENTAL RELEASE MEASURES
CHEMICAL/COMBUSTION HAZARDS: Carbon monoxide, carbon dioxide, and incomplete combustion products.
equipment.
SECTION 4: EMERGENCY AND FIRST AID PROCEDURES
SPILL OR LEAK PROCEDURES: Avoid direct contact. Dike and contain spilled material. Remove source of spill if safe to
do so. Apply absorbent and place clean-up material in sealed/marked containers for proper disposal. Clean-up
SECTION 7: HANDLING AND STORAGE
materials will be classified as non-hazardous waste.
PRECAUTIONS/PERSONAL PROTECTIVE EQUIPMENT: Avoid smoke inhalation. Use appropriate personal protective
(@25°C)
1966 (SARA) and 40 CFR Part 372, chemicals listed on the 313 List (40 CFR Part 373.65) are identified under the heading
SECTION 2: HAZARDS IDENTIFICATION/EXPOSURE LIMITS
HMIS
HAZARD STATEMENTS
WARNING!
PRECAUTIONARY STATEMENTS
INHALATION: Not expected to be an exposure route as supplied. If respiratory symptoms develop, seek
INGESTION: Dilute with liquid unless the victim is unconscious or very drowsy. Do not induce vomiting. If vomiting
SECTION 5: FIRE AND EXPLOSIVES HAZARDS
|Health|
|Flammability|
|Reactivity|
persist, seek medical attention.
medical attention.
MOST IMPORTANT SYMPTOMS/EFFECTS, ACUTE AND CHRONIC: See Section Eleven for Symptoms/Effects.
spontaneously occurs, prevent lung aspiration. Seek immediate medical attention.
Avoid direct contact.
|Personal Protection|
SECTION 3: HAZARDOUS COMPONENTS
Under the reporting requirements of Section 313 of Title III of the Superfund Amendments and Reauthorization Act of
"SARA 313."
LEL
Causes Mild skin irritation. (Category 3)
SAFETY DATA SHEET
Date of Preparation: 9/21/23
Page 2 of 3
3915000
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 101 of 109
PEL
PEL/CEILING
PEL/STEL
SKIN
TWA
TLV/STEL
SKIN
N/E
N/E
N/E
N/A
N/A
reduced lung function.
SECTION 10: STABILITY/REACTIVITY
STABILITY: Stable.
HAZARDOUS POLYMERIZATION: Will not occur.
CONDITIONS AND MATERIALS TO AVOID: Strong oxidizing agents.
HAZARDOUS DECOMPOSITION PRODUCTS: Carbon monoxide, carbon dioxide, and incomplete combustion products.
1. None
ENGINEERING CONTROLS: None required under normal use conditions.
PERSONAL PROTECTIVE EQUIPMENT: Safety glasses, chemical-resistant gloves.
PRODUCT APPEARANCE: Amber Liquid
ECOTOXICITY:
DEGRADABILITY:
SECTION 12: ECOLOGICAL INFORMATION
ODOR: Mild Organic
ODOR THRESHOLD: N/D
FLASH POINT: See Section 5
FLAMMABILITY: N/D
VAPOR PRESSURE: N/D
RELATIVE DENSITY: N/D
PARTITION COEFFICENT: N/D
VISCOSITY: N/D
MELTING/FREEZING POINT: N/D
HAZARDOUS/NON-HAZARDOUS MATERIAL: Not regulated by DOT.
SPECIAL PRECAUTIONS:
SECTION 15: REGULATORY INFORMATION
ENVIRONMENTAL HAZARDS: None recognized.
HAZARD CLASS:
UN PROPER SHIPPING NAME: N/A
UN NUMBER: None.
PACKING GROUP:
BULK TRANSPORTATION INFORMATION: None.
None recognized.
N/A: Not Applicable
include redness and swelling. Gastrointestinal irritation symptoms include nausea, vomiting, and abdominal discomfort.
SIGNS AND SYMPTOMS: Symptoms of eye irritation include tearing, reddening, and swelling. Symptoms of skin irritation
SECTION 11: TOXICOLOGICAL INFORMATION
EYE CONTACT: Direct contact may cause mild irritation.
SKIN CONTACT: Direct contact may cause slight skin irritation. Prolonged/repeated contact may result in irritation.
INHALATION: Not anticipated to be an exposure route.
INGESTION: Not anticipated to be an exposure route.
SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES
BOILING POINT: N/E
VAPOR DENSITY: N/A
EVAPORATION RATE: <1 (Ether=1)
N/A: Not Applicable N/D: Not Determined N/E: Not Established
pH LEVEL: N/A
WEIGHT PER GALLON: 7.25
SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION
OSHA
ACGIH
Chemical Name:
TLV/CEILING
AUTOIGNITION TEMPERATURE: N/D
% VOLATILE BY VOLUME: N/E
% VOLATILE BY WEIGHT: 100
VOC CONTENT: 82 g/L
UEL/LEL: N/D
SOLUBILITY: N/D
DECOMPOSITION TEMPERATURE: N/D
SAFETY DATA SHEET
Date of Preparation: 9/21/23
Page 3 of 3
3915000
OTHER REGULATORY CONSIDERATIONS: None recognized.
AGGRAVATED MEDICAL CONDITIONS: Pre-existing skin, eye, and respiratory disorders may be aggravated by exposure to
OTHER HEALTH EFFECTS: None recognized.
Symptoms of respiratory irritation include ruynny nose, sore throat, coughing, chest discomfort, shortness of breath, and
SOIL MOBILITY:
OTHER ADVERSE EFFECTS:
BIOACCUMULATIVE POTENTIAL: N/E
this product.
SECTION 13: WASTE DISPOSAL INFORMATION
WASTE DISPOSAL INFORMATION: Waste oil recycler or fuel recycling.
SECTION 14: TRANSPORTATION INFORMATION
None Recognized
N/E: Not Established
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 102 of 109
PREPARED BY:
Dave Carey
SECTION 16: OTHER INFORMATION
from the use thereof. We assume no responsibility for injury from the use of this product described herein.
The information contained herein is based on the data available to us and is believed to be correct. However,
we make no warranty, expressed or implied regarding the accuracy of this data or the results to be obtained
PREPARATION DATE:
09/21/2023
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 103 of 109
Address:
|1|
|1|
|0|
| |
% by
SARA
CAS Number
Weight
313
190 PA
PEL
PEL/CEILING
PEL/STEL
SKIN
TWA
TLV/STEL
SKIN
N/E
N/E
N/E
No
N/E
N/E
No
SECTION 2: HAZARDS IDENTIFICATION/EXPOSURE LIMITS
HMIS
HAZARD STATEMENTS
Causes skin irritation. (Categor
WARNING!
PRECAUTIONARY STATEMENTS
INHALATION: Not expected to be an exposure route as supplied. If respiratory symptoms develop, seek
INGESTION: Dilute with liquid unless the victim is unconscious or very drowsy. Do not induce vomiting. If vomiting
SECTION 5: FIRE AND EXPLOSIVES HAZARDS
|Health|
|Flammability|
|Reactivity|
persist, seek medical attention.
medical attention.
Avoid direct contact.
|Personal Protection|
SECTION 3: HAZARDS COMPONENTS
Under the reporting requirements of Section 313 of Title III of the Superfund Amendments and Reauthorization Act of
SECTION 1: PRODUCT AND COMPANY IDENTIFICATION
Product:
Manufacturer:
FORM OIL CITRUS
W. R. Meadows®, Inc.
Telephone:
(847) 214-2100
Revision Date:
06/23/2023
Part Number: 3980300
Page 1 of 2
Hampshire, Illinois 60140
300 Industrial Drive
In case of emergency, dial (800) 424-9300 (CHEMTREC)
AUTOIGNITION TEMPERATURE: N/D
DECOMPOSITION TEMPERATURE: N/D
VISCOSITY: N/D
Product Use:
Form Release Agent
FLASHPOINT: >200 °F (Minimum)
EXTINGUISHING MEDIA: Water fog, foam, dry chemical, carbon dioxide.
SAFE HANDLING PROCEDURES: Avoid direct contact.
SKIN CONTACT: Wash affected areas with mild soap and water. Remove contaminated shoes/clothing. If symptoms
EYE CONTACT: Flush eyes with water for fifteen (15) minutes. If symptoms persist, seek medical attention.
Chemical Name:
D-Limonene 5989-27-5 1-5 No
SECTION 6: ACCIDENTAL RELEASE MEASURES
CHEMICAL/COMBUSTION HAZARDS: Carbon monoxide, carbon dioxide, and incomplete combustion products.
equipment.
spontaneously occurs, prevent lung aspiration. Seek immediate medical attention.
0.7
SECTION 4: EMERGENCY AND FIRST AID PROCEDURES
MOST IMPORTANT SYMPTOMS/EFFECTS, ACUTE AND CHRONIC: See Section Eleven for Symptoms/Effects.
"SARA 313."
% VOLATILE BY VOLUME: N/E
% VOLATILE BY WEIGHT: 100
EVAPORATION RATE: <1 (Ether=1)
pH LEVEL: N/A
WEIGHT PER GALLON: 7.25
ODOR: Mild Organic Citrus
ODOR THRESHOLD: N/D
MELTING/FREEZING POINT: N/D
FLASH POINT: See Section 5
FLAMMABILITY: N/D
UEL/LEL: N/D
VAPOR PRESSURE: N/D
RELATIVE DENSITY: N/D
SOLUBILITY: N/D
PARTITION COEFFICENT: N/D
SAFETY DATA SHEET
SPILL OR LEAK PROCEDURES: Avoid direct contact. Dike and contain spilled material. Remove source of spill if safe to
do so. Apply absorbent and place clean-up material in sealed/marked containers for proper disposal. Clean-up
SECTION 7: HANDLING AND STORAGE
materials will be classified as non-hazardous waste.
PRECAUTIONS/PERSONAL PROTECTIVE EQUIPMENT: Avoid smoke inhalation. Use appropriate personal protective
N/A: Not Applicable N/E: Not Established N/D: Not Determined
VOC CONTENT: <100 g/L
PRODUCT APPEARANCE: Amber Liquid
Vapor Pressure
(mm Hg@20°C)
LEL
(@25°C)
1966 (SARA) and 40 CFR Part 372, chemicals listed on the 313 List (40 CFR Part 373.65) are identified under the heading
VAPOR DENSITY: N/A
SAFE STORAGE: Keep containers closed when not in use.
SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION
BOILING POINT: N/E
Chemical Name:
TLV/CEILING
PERSONAL PROTECTIVE EQUIPMENT: Safety glasses, chemical-resistant gloves.
SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES
ENGINEERING CONTROLS: None required under normal use conditions.
N/E
1. D-Limonene
OSHA
ACGIH
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 104 of 109
N/E
N/E
N/E
N/A
N/A
PREPARED BY:
Dave Carey
SECTION 10: STABILITY/REACTIVITY
STABILITY: Stable.
HAZARDOUS POLYMERIZATION: Will not occur.
CONDITIONS AND MATERIALS TO AVOID: Strong oxidizing agents.
HAZARDOUS DECOMPOSITION PRODUCTS: Carbon monoxide, carbon dioxide, and incomplete combustion products.
include redness and swelling. Gastrointestinal irritation symptoms include nausea, vomiting, and abdominal discomfort.
SIGNS AND SYMPTOMS: Symptoms of eye irritation include tearing, reddening, and swelling. Symptoms of skin irritation
SAFETY DATA SHEET
Date of Preparation: 6/23/2023
Page 2 of 2
3980300
SECTION 11: TOXICOLOGICAL INFORMATION
EYE CONTACT: Direct contact may cause mild irritation.
SKIN CONTACT: Direct contact may cause slight skin irritation. Prolonged/repeated contact may result in irritation.
INHALATION: Not anticipated to be an exposure route.
INGESTION: Not anticipated to be an exposure route.
use thereof. We assume no responsibility for injury from the use of this product described herein.
The information contained herein is based on the data available to us and is believed to be correct. However, we
make no warranty, expressed or implied regarding the accuracy of this data or the results to be obtained from the
HAZARDOUS/NON-HAZARDOUS MATERIAL: Not regulated by DOT.
SPECIAL PRECAUTIONS:
SECTION 15: REGULATORY INFORMATION
OTHER REGULATORY CONSIDERATIONS:
SECTION 16: OTHER INFORMATION
ENVIRONMENTAL HAZARDS: None recognized.
None recognized.
None recognized.
HAZARD CLASS:
UN PROPER SHIPPING NAME: N/A
UN NUMBER: None.
BULK TRANSPORTATION INFORMATION: None.
PACKING GROUP:
Symptoms of respiratory irritation include ruynny nose, sore throat, coughing, chest discomfort, shortness of breath, and
reduced lung function.
BIOACCUMULATIVE POTENTIAL: N/E
this product.
PREPARATION DATE:
06/23/2023
SOIL MOBILITY:
OTHER ADVERSE EFFECTS: None Recognized
ECOTOXICITY:
DEGRADABILITY:
SECTION 13: WASTE DISPOSAL INFORMATION
WASTE DISPOSAL INFORMATION: Waste oil recycler or fuel recycling.
SECTION 14: TRANSPORTATION INFORMATION
SECTION 12: ECOLOGICAL INFORMATION
AGGRAVATED MEDICAL CONDITIONS: Pre-existing skin, eye, and respiratory disorders may be aggravated by exposure to
OTHER HEALTH EFFECTS: None recognized.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 105 of 109
2
From: noreply@civicplus.com <noreply@civicplus.com>
Sent: Tuesday, April 9, 2024 10:58 AM
To: PND Regulatory <PNDRegulatory@maricopa.gov>; Kathy Semder (HSD) <Kathy.Semder@Maricopa.Gov>; Andy
Linton (ENV) <Andy.Linton@Maricopa.Gov>; Bill Leal (DOT) <Bill.Leal@Maricopa.Gov>; Kathryn Garcia (PND)
<Kathryn.Garcia@Maricopa.Gov>; Blanca Caballero (ENV) <Blanca.Caballero@Maricopa.gov>; Michele Ross (COA)
<Michele.Ross@maricopa.gov>
Subject: Online Form Submittal: Citizen Comments
Citizen Comments Each Regulatory Department is committed to providing opportunities for stakeholder input regarding the adoption and amendment of all regulatory requirements. Your input will be collected and forwarded to the appropriate department.
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This Message Is From an External Sender
This message came from outside your organization. Please use caution when corresponding outside the county.
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Citizen Comments
Each Regulatory Department is committed to providing opportunities for
stakeholder input regarding the adoption and amendment of all regulatory
requirements. Your input will be collected and forwarded to the appropriate
department. You will receive a written response from the applicable department
within two business days. We appreciate your comments and your time.
Case Number/Rule
AQ-2024-002-Rule 335 (Architectural Coatings)
Department
Air Quality
I would like to
Other
First Name
Rhett
Last Name
Cash
Organization
American Coatings Association
City
Washington
Zip
20001
Email
rcash@paint.org
Phone Number
(202) 774-6092
Phone Type
Mobile
Return to Stakeholder #2: Comment #2
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 106 of 109
3
Would you like someone to
contact you?
No
Comments
The American Coatings Association (ACA) submits the
following preliminary comments to the Maricopa County Air
Quality Department (MCAQD) regarding its proposed revisions
to Rule 335 (Architectural Coatings). ACA is a voluntary,
nonprofit trade association working to advance the needs of the
paint and coatings industry and the professionals who work in
it. The organization represents paint and coatings
manufacturers, raw materials suppliers, distributors, and
technical professionals. ACA serves as an advocate and ally
for members on legislative, regulatory, and judicial issues, and
provides forums for the advancement and promotion of the
industry through educational and professional development
services. ACA appreciates the opportunity to comment and
looks forward to working with MCAQD throughout the
rulemaking process.
ACA encourages MCAQD to consider adopting a compliance
date of one year from the date of adoption of the final rule. The
effective date for the new VOC limits is not listed in Table 335-
1, yet. As a general matter, the paint and coatings industry
requires sufficient lead time to adjust formulations and supply
chain processes in order to ensure compliance with new VOC
limits, labeling, and reporting requirements. Industry also needs
sufficient time to adjust production, labeling, and distribution
networks to effectively and efficiently implement the new rule
requirements.
Manufacturers, distributors, and retail stores employ extensive
computer systems that require upgrades to incorporate new
formulations and ensure non-compliant products are not sold
into jurisdictions with new VOC limits. Furthermore,
manufacturing and labeling costs are generally expensive, and
coatings manufacturers tend to manage formulation changes to
their products to minimize costs stemming from obsolete
products and labels. Additionally, manufacturers will need
sufficient time to properly communicate these changes to their
distributors and retail customers to ensure compliance with
new VOC limits. Finally, most companies wait until a rule is
finalized and its requirements are certain before implementing
changes to ensure compliance because it helps minimize
costs. This means that companies will not implement changes
during the early parts of a rulemaking and will need adequate
time after finalization of a new rule to make appropriate
changes. As such, industry typically needs at least a year to
properly implement the necessary changes to comply with the
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 107 of 109
4
new rule requirements.
Thank you for your consideration of ACA's preliminary
comments. We may have additional comments after the
proposed rule is formally issued after the Board of Health
Meeting on April 22. Please do not hesitate to contact me if you
have any questions or require additional clarification.
If applicable, attach
supporting documentation
associated with your
comment. The only file
types supported are MS
Office and Adobe Acrobat.
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Email not displaying correctly? View it in your browser.
Maricopa County • Air Quality Department • Rule 335 Report to the Board of Supervisors
Page 108 of 109
Maricopa County
Air Quality Department
Planning and Analysis Division
Maricopa.gov/AQ
Maricopa County
Air Quality Department
Planning and Analysis Division
Maricopa.gov/AQ