When fully implemented, the regulations will require companies with Title V or FEDOP permits to assess their use of 191 chemicals or compound categories. If the risk from exposure exceeds one-in-a-million additional cancer deaths for any one chemical, the company will be required to install T-BAT (best available control technology for toxics). T-BAT would also apply if the aggregate risk from all chemicals exceeds 7.5 in a million. Title V sources have until the end of 2006 to perform this analysis on the first category of emissions.

The STAR package became effective July 1, and there are at least three requirements that need the immediate attention of coatings manufacturers. The regulatory package is on the district's Web site at www.apcd.org.

NPCA is concerned about the implications of the regulations throughout the United States. NPCA's position is that given not only the stringency of the regulations and the broad implementation discretion allocated to the district's staff and board members, but also the method with which they were enacted, with minimal notice and unresponsiveness to industry concerns and input, these regulations set a bad precedent. NPCA fears that other states and local air districts may now look to STAR as a model. NPCA members can contact Alison Keane at akeane@paint.org for more information.