Two issues:
1. Our project specification is basing the VOC limits on the Current limits.
(Current Limits are substantially lower than the Ceiling Limit).
2.CAGBC Reference Guide 2009 and in this LEEDuser are showing the Ceiling LImits.
The SCAQMD Rule 1113 Table of Standards 1 shows Ceiling Limits and Current Limits for the category of paints and coatings. According to the table footnotes, it says the Ceiling Limits apply to "products sold under the Averaging Compliance Option." On page 1113-15, section 6. it provides the criteria for the Average Compliance Option. Do I need to obtain a letter from the manufacturer to confirm they are using this ACO option?
Dwayne Fuhlhage
Sustainability and Environment DirectorPROSOCO, Inc.
169 thumbs up
June 19, 2014 - 11:40 am
The ACO is a South Coast creation for coatings used in the District. It allows high volume paint houses to average low/zero VOC coatings to allow other coatings to have a higher limit than that stated in the category table - the Ceiling Limits are for certain categories allowed under averaging; others have no limit at all. For the purposes of credit as written, the categories and limits in the SCAQMD Rule 1113 in effect on January 1, 2004 would still apply. Alternatively, an interpretation from last year allows substitution of the CARB 2007 SCM limits.
In short, the limits are still the limits, regardless of the ACO option. I have not seen the CAGBC Reference Guide 2009 referencing the Ceiling Limits. I will caution that Canada has its own architectural coatings regulation based on the 2004 CARB Suggested Control Measure. By default, every coating must comply with national VOC regulations.
This would be a good question to route through GBCI and CAGBC. Again, from my perspective the referenced 2004 Rule 1113 limits would still apply for the credit as written and balloted.