New VOC Restrictions for Field-Applied Coatings

by John Miller and Mike Bauer, Tnemec Co.


new rules affect most coatings

VOC Restrictions for Architectural and Maintenance Coatings 

Products affected by new rules 


In September of 1999, the Federal EPA implemented new Volatile Organic Compound (VOC) regulations for field-applied architectural and industrial coatings. The National AIM (Architectural and Industrial Maintenance) Coating Rules are much more complex than previous VOC regulations, with VOC limits varying greatly among the 61 categories and sub-categories.

For example, if a coating system is desired for masonry, the following categories (plus others) could apply:

  • Primers/Undercoaters (including Block Fillers) – 2.9 lbs./gallon
  • Flat coatings – 2.1 lbs./gallon
  • Non-Flat Coatings – 3.2 lbs./gallon
  • Clear and Transparent Stains – 4.6 lbs./gallon
  • Waterproofing Treatments – 5.0 lbs./gallon
  • Industrial Maintenance Coatings – 3.8 lbs./gallon

Key Points to Remember

Flat Coatings and Non-Flat Coatings are default categories. In other words, if the intended use of a coating does not meet the definition of any of the other categories it is automatically placed in the most restrictive Flat or Non-Flat category, depending on gloss.

Perhaps the most difficult information to understand is the allowances (VOC limits) for coatings that by definition may fall into more than one intended use category.

An example of a coating category that can overlap into several other categories is Industrial Maintenance Coating. This category refers to high performance coatings that are subject to specified environmental exposures. The VOC limit for this category is 3.8 lbs./gallon. (Many architectural settings such as natatoriums, locker rooms, clean rooms, and exterior steel fall into this category. See “Industrial Maintenance Coating” definition for more information.)

A partial list of these exposures include:

  1. Immersion in water or chronic exposure of interior surfaces to moisture condensation;
  2. Exposure to corrosive, caustic, or acidic agents, or to chemical fumes, mixtures or solutions;
  3. Repeated exposure to temperatures above120 C (250 F);
  4. Frequent heavy abrasion, including mechanical wear or scrubbing with industrial cleansers;
  5. Exterior exposure of metal structures and structural components.

One of the overlap categories listed for Industrial Maintenance Coating is the Primer category. Primer is defined as a coating formulated and recommended to create a bond between the substrate and subsequent coatings. The VOC limit for this category is 2.9 lbs./gallon.

If a specific primer meets both the Industrial Maintenance Coating definition (e.g., is recommended for exterior exposed metals) and the Primer definition then it is only required to meet the less restrictive VOC limit for Industrial Maintenance Coating (3.8 lbs/gal). However, if a specific primer meets the Primer definition only (e.g. an interior wood primer) then the VOC limit for the Primer category (2.9 lbs/gal) applies.

The purpose of this article is to provide general information to specification writers on recently adopted VOC regulations that govern coating applications for a variety of substrates and exposure conditions. This information may serve as an introduction to the new regulations. Several special categories such as anti-graffiti coatings, faux finishes, and fire retardant coatings also exist. It is important to review your existing specifications with your manufacturer’s representative or an individual familiar with the regulations. General questions regarding the regulations or specific applications may be sent to To download a compliance guide containing the National AIM Rule go to then click on 7/99 Small Entity Compliance Guide.

Send questions to John at

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