[UC Berkeley, Office of Environment, Health & Safety]

Guidelines for Control of Air Emissions from Surface Coating Operations

at the University of California, Berkeley

May 1, 2000

TABLE OF CONTENTS

1.0 Introduction

2.0 Overview of Surface Coating Operations

    2.1 General Surface Coating Operations
    2.2 Permit Applicable Surface Coating Operations
    2.3 Permit Exempt Surface Coating Operations
3.0 Guidelines for Purchasing and Use of Surface Coatings
    3.1 Purchasing Requirements
    3.2 General Use Requirements
    3.3 Special Use Requirements
4.0 Other EH&S Considerations
    4.1 Health and Safety
    4.2 Storage and Fire Safety
    4.3 Chemical Inventory
    4.4 Disposal and Waste Minimization
5.0 References
    5.1 BAAQMD Rules and Regulations
    5.2 EH&S Contact Information
APPENDICES

Download complete document including appendices in PDF format (68K)

1.0 INTRODUCTION

Surface coating operations, such as painting, are a common source of volatile organic compound (VOC) air emissions. These emissions contribute to the formation of ozone, an air pollutant that is regulated by federal, state, and regional laws and regulations because it poses a threat to public health and the environment. The Bay Area Air Quality Management District (BAAQMD), the regional regulatory agency responsible for air pollution control in the Bay Area Air Basin, minimizes the formation of ozone by limiting volatile organic compound emissions from sources such as refineries, automobiles, dry cleaners, printers, and surface coating operations.*

BAAQMD surface coating operations regulations minimize VOC emissions by
  • limiting the VOC content of surface coatings sold and used,
  • restricting application methods,
  • applying administrative measures.
The University of California, Berkeley, must comply with applicable BAAQMD regulations to ensure good air quality in the Bay Area Air Basin. Each department is responsible for knowing and complying with these regulations. To assist departments in meeting BAAQMD requirements, the Office of Environment, Health & Safety (EH&S) developed guidelines based on BAAQMD regulations, the campus Permit to Operate, and the campus Major Facility Review Permit (Title V Permit). Note: Printing operations must comply with separate regulations.

Notice: BAAQMD regularly inspects campus sources of air emissions. Failure to comply with air emissions regulations could lead to fines and/or restrictions in coating usage.



*Ozone and VOCs in the Bay Area: Surface coating operations contribute about 3 percent of the total VOC emissions on the Bay Area Air Basin (BAAQMD 1990 Emission Inventory Summary Report). A report for the summer of 1996 lists organic-compound evaporation emissions as 21.8 percent. These VOCs react with sunlight and oxides of nitrogen from sources such as automobiles and heating plants to produce ground level (as opposed to stratospheric) ozone. Ozone is a strong irritant that attacks the lungs, contributing to lung disease and to more than $800 million a year in damage to crops and materials in California. The Bay Area Air Basin is currently out of attainment with the California ozone standard (0.09 ppm).

2.0 OVERVIEW OF SURFACE COATING OPERATIONS

2.1 General Surface Coating Operations

Surface coating operations include painting buildings, building parts, furniture, equipment, wood, plastics, metals, and fabric; use of adhesives and sealant; and coating paper with presses, brushes, or spray devices. These guidelines apply to all surface coating operations at UC Berkeley, except for exempt operations (such as structural coating and research operations) and printing operations, which are regulated under separate BAAQMD requirements.

2.2 Permit Applicable Surface Coating Operations (Source 100)

Surface coating operations at UC Berkeley take place in a number of locations, mainly facilities maintenance and fabrication settings, such as shops (exhibit construction shops, paint shops, wood shops, and machine shops) and buildings (building and room construction and renovation). These operations usually require a Permit to Operate and must follow all relevant regulations.

2.3 Permit Exempt Surface Coating Operations

The following operations are exempt from BAAQMD regulations and do not need a Permit to Operate. However, in order to prevent air pollution, only complying solvents and coatings should be purchased and used. Typical exempt operations include
  • operations that use only non-refillable, hand-held, aerosol cans,
  • research and teaching laboratories, including art, architecture, and theater studios,
  • operations that apply coatings only to stationary structures or their appurtenances or to pavements or curbs. (Note: This exemption does not apply to the painting of components removed from structures or equipment. )

3.0 GUIDELINES FOR PURCHASE AND USE OF SURFACE COATINGS

3.1 Purchasing Requirements

BAAQMD surface coating regulations differ in allowable VOC content levels depending on the operation and substrate (wood, metal). Before purchasing a surface coating, make sure that the VOC content complies with the BAAQMD requirements. The VOC content is on the container and on the Material Safety Data Sheet (MSDS) or can be requested from the supplier. Most surface coatings for sale in California comply with the regulations as long as they are used on the substrate for which the surface coating was intended. Surface coatings with a VOC content of 250 grams/liter (2.1 pounds/gallon) or less comply with most regulations. In addition, some painting operation requirements allow a higher VOC content. To determine whether your paint VOC content complies with BAAQMD requirements, review the tables in Appendix 4, or call EH&S at 642-3073.

3.2 General Use Requirements

Surface coating operations that are not exempt from BAAQMD regulations (see Section 2.3 for a description of exempt sources) are required to obtain a Permit to Operate and to maintain certain coating usage records. (Forms for surface coating lists and coating logs are included in Appendices 1 and 2.) The following are operating requirements for all surface coating operations:
  • Permit to OperateÑAll UC Berkeley non-exempt surface coating sources are incorporated on the UC Berkeley campus-wide Source 100 Permit to Operate and Title V Permit. To be listed on the campus Permit to Operate, contact EH&S.

  • Permit postingÑPost the Permit to Operate at the surface coating operation or keep on site (e.g., in the Logbook).

  • Surface Coating List (form in Appendix 1)ÑA list of all surface coatings and solvents used in the surface coating operation and their VOC content is required and must be available for inspection by BAAQMD.

  • Daily Surface Coating and Monthly Summary Log (form in Appendix 2)Ñ Record each use of paint or adhesives. You can log each use or the contents of each used-up container. Summarize the log monthly. This log must be available for inspection by BAAQMD.

  • Record Keeping and Inspections---ÑSurface Coating Lists and Coating Logs must be maintained for five years. BAAQMD inspects campus sources at least annually. Records must be available for inspections.

3.3 Special Use Requirements

Surface coating operations using spray application equipment may be required by BAAQMD regulations to use high-transfer efficiency application methods such as o high-volume, low-pressure (HVLP) spray, o electrostatic spray, o detailing gun. Other spray methods may be used, provided a BAAQMD-approved abatement device is used. Contact EH&S for more information.

4.0 OTHER EH&S CONSIDERATIONS

4.1 Health and Safety: Respiratory ProtectionÑEngineering Controls and Personal Protective Equipment

Some paints,adhesives, and sealant may contain toxic chemicals, including volatile organic solvents and heavy metal pigments that could cause injury or illness from exposure through inhalation, skin absorption, or ingestion. To prevent exposure to these toxic chemicals, departments should address training, hazard communication (e.g., MSDS), engineering controls (e.g., ventilation), and personal protective equipment (e.g., respirators and gloves) for surface coating operations. Note: Some of this may be addressed in the departmentÕs Injury and Illness Prevention Program. For an assessment of respiratory protection needs or for more information, call the EH&S (642-3073).

4.2 Storage and Fire Safety

Many paints and solvents are flammable and toxic and should be stored properly to prevent fire or spills to the workplace or environment. In general, paints should be stored in earthquake-resistant cabinets or in spill containers that provide secondary containment in the event of a spill or leak. In addition, rags and clothes used during painting or cleanup are potentially flammable and should be kept in a fireproof (metal) self-closing container. For more information, call EH&S Fire Prevention Division (642-3073).

4.3 Chemical Inventory

Owing to the amount of surface coating done on the central campus, a Permit To Operate is required for operations that are not exempt and therefore fall under the campus permit, Source 100 (Condition #14090). An accurate inventory of surface coating products and their VOC content is essential to keep on site. This inventory must also be reported to EH&S and updated at least annually through the Campus Chemical Inventory Program. For more information, call EH&S or check the EH&S website. 4.4 Disposal and Waste Minimization In general, excess paint must be disposed of as hazardous waste. However, there are programs available to assist in waste minimization. For more information, read the Managing Surplus Paint and Painting Supplies Fact Sheet available from EH&S (642-3073).

5.0 REFERENCES

5.1 BAAQMD Rules and Regulations Pertaining to Surface Coating

BAAQMD Regulation 8 Rule 3 (Architectural Coatings)

BAAQMD Regulation 8 Rule 4 (General Solvent and Surface Coating Operations)

BAAQMD Regulation 8 Rule 11 (Metal Container, Closure, and Coil Coating)

BAAQMD Regulation 8 Rule 14 (Surface Coating of Large Appliances and Metal Furniture)

BAAQMD Regulation 8 Rule 19 (Surface Coating of Miscellaneous Metal Parts and Products)

BAAQMD Regulation 8 Rule 23 (Coating of Flat Wood Paneling and Wood Flat Stock)

BAAQMD Regulation 8 Rule 31 (Surface Coating of Plastic Parts and Products)

BAAQMD Regulation 8 Rule 32 (Wood Products Coatings)

BAAQMD Regulation 8 Rule 49 (Aerosol Paint Products)

BAAQMD Regulation 8 Rule 51 (Adhesive and Sealant Products)

 

5.2 EH&S Contact Information

Office of Environment, Health & SafetyÑMain Number 642-3073
EH&S Website: http://www.berkeley.edu/


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