OTC MERR MVMERR model rule comparison Hoyle.doc September 17, 2008
Internal use only – not for distribution
(Based on Laura Scatena’s 9_4_2008 call notes and comparison document)
Comparison between
OTC 2002 MERR MR and CARB 2005 SCM/OTC 2008 MVMERR MR for Automotive Refinish Coatings
Definitions
· Several definitions are different between the OTC 2002 MERR model rule and the CARB 2005 SCM and need to be combined or separated.
(Hoyle note: see separate file for comparison of all terms from CARB 2005 SCM and OTC 2002 MERR MR)
Table 1. Comparison of definitions between the OTC 2002 MERR model rule and CARB 2005 SCM for automotive coatings (*have standards listed in MERR Table III or CARB SCM section 4.1).
Term / CARB 2005 SCM Definition / OTC 2002 MERR DefinitionAdhesion Promoter* / A coating, which is labeled and formulated to be applied to uncoated plastic surfaces to facilitate bonding of subsequent coatings, and on which, a subsequent coating is applied. / Included in the definition of the term “automotive specialty coating*”
Clear Coating* / Any coating that contains no pigments and is labeled and formulated for application over a color coating or clear coating. / Assuming part of “automotive topcoat*”
Color Coating* / Any pigmented coating, excluding adhesion promoters, primers, and multi-color coatings, that requires a subsequent clear coating and which is applied over a primer, adhesion promoter, or color coating. Color coatings include metallic/iridescent color coatings. / Assuming part of “automotive topcoat*”
Multi-Color Coating* / Any coating that exhibits more than one color in the dried film after a single application, is packaged in a single container, and hides surface defects on areas of heavy use, and which is applied over a primer or adhesion promoter. / Automotive multi-colored topcoat* — A topcoat that exhibits more than one color, is packaged in a single container, and camouflages surface defects on areas of heavy use, such as cargo beds and other surfaces of trucks and other utility vehicles.
Pretreatment Coating* / Any coating that contains a minimum of
one-half (0.5) percent acid by weight and not more than 16 percent solids by weight necessary to provide surface etching and is labeled and formulated for application directly to bare metal surfaces to provide corrosion resistance and adhesion. / Automotive pretreatment* — A primer that contains a minimum of 0.5% acid, by weight, that is applied directly to bare metal surfaces of mobile equipment and mobile equipment components to provide corrosion resistance and to promote adhesion of subsequent coatings.
Primer* / Any coating, which is labeled and formulated for application to a substrate to provide 1) a bond between the substrate and
subsequent coats, 2) corrosion resistance, 3) a smooth substrate surface, or 4) resistance to penetration of subsequent coats, and on which a subsequent coating is applied. Primers may be pigmented. / Automotive pretreatment*—A primer that contains a minimum of 0.5% acid, by weight, that is applied directly to bare metal surfaces of mobile equipment and mobile equipment components to provide corrosion resistance and to promote adhesion of subsequent coatings.
Automotive primer-sealer*—A coating applied to mobile equipment and mobile equipment components prior to the application of a topcoat for the purpose of providing corrosion resistance, promoting adhesion of subsequent coatings, promoting color uniformity, and promoting the ability of the undercoat to resist penetration by the topcoat.
Automotive primer-surfacer*—A coating applied to mobile equipment and mobile equipment components prior to the application of topcoat for the purpose of: filling surface imperfections in the substrate; providing corrosion resistance; or
promoting adhesion of subsequent coatings.
Single-Stage Coating* / Any pigmented coating, excluding primers and multi-color coatings, labeled and formulated for application without a subsequent clear coat. Single-stage coatings include single-stage metallic/iridescent coatings. / Assuming part of “automotive topcoat*”
Temporary Protective Coating* / Any coating which is labeled and formulated for the purpose of temporarily protecting areas from overspray or mechanical damage. / Could not determine a match – topcoat or specialty???
Truck Bed Liner Coating* / Any coating, excluding clear, color,
multi-color, and single stage coatings, labeled and formulated for application to a truck bed to protect it from surface abrasion. / Assuming part of “Automotive multi-colored topcoat*”
Underbody Coating* / Any coating labeled and formulated for
application to wheel wells, the inside of door panels or fenders, the underside of a trunk or hood, or the underside of the motor vehicle. / Assuming part of “Automotive specialty coating*”
Uniform Finish Coating* / Any coating labeled and formulated for
application to the area around a spot repair for the purpose of blending a repaired area’s color or clear coat to match the appearance of an adjacent area’s existing coating. / Assuming part of “Automotive specialty coating*”
Any other coating type* / Coating - a material which is applied to a surface and forms a film in order to beautify, preserve, repair, or protect such a surface. / No “other” categories
· OTC recommendation: Use consumer products rule as model for VOC definition and “Alternative Compliance” language:
o Draft OTC 2008 MVMERR MR VOC definition uses the CARB consumer products definition as included in CARB 2005 SCM
o Consumer Products rule (OTC 2009 MR) VOC definition:
§ Option 1: OTC state-specific definition
§ Option 2: Federal definition at 40 CFR 51.100
§ Option 3: CARB definition at Title 17, California Code of Regulations, Division 3, Chapter 1, Subchapter 8.5, Article 2, Consumer Products (which differs from the Federal definition)
o Consumer Products rule (OTC 2002 MR) VOC definition: same as 2008 draft model rule, except for tBAc
Purpose/Applicability
· The OTC 2002 MERR MR applies only to a person applying the coatings
· The draft OTC 2008 MVMERR MR applies to a person who supplies, sells, manufactures, or distributes the coatings, as well as a person who uses, applies, or solicits the use or application of an automotive coating or associated solvent.
Standards
· Calculations for determining VOC content are the same between OTC 2008 and 2002 model rules.
· How to reorganize coating categories based upon new model rule? For example, there is no “other” category in the OTC 2002 MERR model rule.
· “Most restrictive VOC limit” is defined in the CARB 2005 SCM/OTC 2008 MVMERR MR but not addressed in OTC 2002 MERR MR.
· VOC content limits for coating categories differ between OTC 2008 and 2002 model rules.
Coating Type (2008/2002) / g/L (lbs/gal)CARB 2005 SCM/
OTC 2008 MVMERR / g/L (lbs/gal)
OTC 2002 MERR
Adhesion Promoter
(Automotive specialty) / 540 (4.5) / 840 (7.0)
Clear Coating
(2 stage basecoat/clearcoat)
(3 or 4-stage basecoat/clearcoat) / 250 (2.1) / 600 (5.0)
625 (5.2)
Color Coating
(single stage-topcoat)
(2 stage basecoat/clearcoat)
(3 or 4-stage basecoat/clearcoat) / 420 (3.5) / 600 (5.0)
600 (5.0)
625 (5.2)
Multi-Color Coating
(Automotive multi-colored topcoat) / 680 (5.7) / 680 (5.7)
Pretreatment Coating
(Automotive pretreatment primer) / 660 (5.5) / 780 (6.5)
Primer
(Automotive pretreatment primer)
(Automotive primer-sealer)
(Automotive primer-surfacer) / 250 (2.1) / 780 (6.5)
550 (4.6)
575 (4.8)
Single-Stage Coating
(single stage-topcoat) / 340 (2.8) / 600 (5.0)
Temporary Protective Coating / 60 (0.5) / ???? N/A
Truck Bed Liner Coating
(Automotive multi-colored topcoat) / 310 (2.6) / 680 (5.7)
Underbody Coating
(Automotive specialty coating) / 430 (3.6) / 840 (7.0)
Uniform Finish Coating (Automotive specialty coating) / 540 (4.5) / 840 (7.0)
Any other coating type / 250 (2.1) / N/A
· “Alternative Compliance”
o OTC recommendation: Use consumer products rule as model for VOC definition and “Alternative Compliance” language
o OTC 2009 Consumer products model rule:
§ "Alternative Control Plan or ACP" means any emissions averaging program approved by the (OTC STATE AGENCY) pursuant to the provisions of this regulation.
· No “Prohibition of Possession” provision in the OTC 2002 MERR MR.
· No “Prohibition of Sale or Manufacture” provision in the OTC 2002 MERR MR.
· No “Prohibition of Specification” provision in the OTC 2002 MERR MR.
· Coating Application Methods:
Table 2. A comparison of approved coating application methods between the OTC model rules (2008 vs. 2002) for autobody refinishing.
Method / 2008 / 2002Brush, dip, or roller / x / x
Electrostatic spray / x / x
High-volume Low-Pressure (HVLP) spray equipment / x / x
Flow/curtain coating / x
Cotton-tipped swab application / x
Electrodeposition coating / x
Airless spray / x
Approved alternative method / x / x
Table 3. A comparison of exemptions to approved coating application methods between the OTC model rules (2008 vs. 2002) for autobody refinishing.
Method or Coatings Exempt / 2008 / 2002Underbody coatings / x
Graphic arts operations
(Use of airbrush application methods for stenciling, lettering, and other identification markings) / x / x
Truck bed liner coatings / x
Any coating use of less than one (1) fluid ounce (29.6 mL) / x
Application of automotive touch-up repair finish materials / x
Application of coatings sold in nonrefillable aerosol containers / x
Table 4. A comparison of solvent limits and evaporative loss minimization (housekeeping) requirements between the OTC model rules (2008 vs. 2002) for autobody refinishing.
Solvent limit; Evaporative Loss Minimization (Housekeeping) requirement / 2008 / 2002Each solvent present at any automotive refinishing facility shall not exceed a VOC content of 25 g/l as calculated pursuant to section 3.35.3 (CARB SCM) / x / No solvent limits
Solvent-laden materials shall be stored in closed containers / x / x
MERR 2(g)(2)
All automotive coating components, automotive coatings, and solvents shall be stored in closed vapor-tight containers. / x / x
MERR 2(h)(1)
No person shall clean spray equipment unless a closed system is used. / x / x
MERR 2(g)
All waste automotive coating components, automotive coatings, and solvents shall be stored in closed vapor-tight containers, except while adding to or removing them from the containers. / x / x
MERR 2(h)(1)
Handling and transfer procedures shall minimize spills during the transfer of coatings, solvents, and cleaning solvents. / x
MERR 2(h)(3)
Ensure that a person who applies mobile equipment repair and refinishing coatings has completed training in the proper use and handling of the mobile equipment repair and refinishing coatings, solvents and waste products in order to minimize the emission of air contaminants and to comply with this section. / *The new model rule does not have any provisions for training as discussed in the 2002 model rule. / x
MERR 2(h)(4)
· Spray gun provisions are different – 2002 has specifications for cleaning only, whereas 2008 has provisions for design and use of the spray gun – SCM 4.7.4 – requirement for use of air cap pressure gauge to measure air tip pressure.
Administrative Requirements
· These are administrative requirements in the CARB 2005 SCM/ OTC 2008 MVMERR MR that are not in the OTC 2002 MERR MR:
o Compliance statement (product data sheet)
o Labeling
o Maintenance of records
o Recordkeeping requirements for coatings
o Recordkeeping requirements for emission control systems
o Recordkeeping requirements for prohibition of sale
o Test methods
Test Methods
· These are test methods listed in the CARB 2005 SCM/ OTC 2008 MVMERR MR that are not in the OTC 2002 MERR MR:
o ASTM D6133-02 (exempt content)
o ASTM D1613-03 (acid content)
o EPA Method 24 (VOC content)
o EPA Method 25, 25A, or 25B (Control efficiency)
o SCAQMD Method 318-95 (Metallic content)
o Alternative methods approved by [OTC state] and EPA
Follow-up – Seth, please clarify the dates and desired timeline for the Model Rule approval process
· OTC Workgroup Call – Wednesday, October 1, 2008, 10 – 11 am. – discuss next draft of OTC 2008 MVMERR MR
o October 15, 2008 – Air Directors Planning Meeting to prepare for the November 18, 19, 2008 Public Meeting
o November 18, 19, 2008 – OTC Public Meeting with Stakeholders
o Date – Air Directors vote on Model Rule
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