UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: June 13, 2012 

SUBJECT: Technical Support Document for the Maryland State Implementation Plan 

Revision for the Control of Volatile Organic Compounds Emissions from Vehicle 

Refinishing

/s/

FROM: Emlyn Vélez-Rosa, Environmental Engineer

Office of Air Program Planning

TO: File

/s/

THRU: Donna Mastro, Acting Associate Director

Office of Air Program Planning 

A. INTRODUCTION

The U.S. Environmental Protection Agency (EPA) is taking action on a submittal made by the 

Maryland Department of the Environment (MDE) on May 8, 2012. The SIP revision amends 

Maryland’s COMAR 26.11.19.23 “Control of Volatile Organic Compounds Emissions from 

Vehicle Refinishing” to establish new volatile organic compounds (VOC) content limits for 

coating and cleaning solvents used in vehicle refinishing and standards for coating application, 

work practices, monitoring, and recordkeeping. 

B. BACKGROUND

Ground-level ozone, which is a major component of ‘‘smog,’’ is formed in the atmosphere by 

reactions of VOC and oxides of nitrogen (NOX) in the presence of sunlight. In order to reduce 

ground-level ozone levels, emissions of VOC and NOX must be reduced. Maryland was 

designated nonattainment with respect to the 1-hour ozone NAAQS in November 15, 1990, with 

several serious nonattainment areas, including: the Baltimore, Maryland area, the Maryland 

portion of the Philadelphia-Wilmington-Atlantic City area, and the Maryland portion of the 

Washington, DC area.1 Additionally, the entire State of Maryland corresponds to the ozone 

transport region (OTR), under section 184(a) of the Clean Air Act (CAA). As a result, the entire 

state is subject to the ozone nonattainment plan provisions of section 182 and the federal ozone 

measures of section 183 of the CAA. 

 

1 The 1-hour ozone standard was revoked effective June 15, 2005 for all areas in Maryland except the Washington 

County area where it was revoked effective April 15, 2009.
2

Section 182(c) of the CAA requires states with ozone nonattainment areas classified as moderate 

or above to submit a SIP revision that provides VOC emissions reductions of at least 15 percent 

from the baseline emissions of 1990. In Maryland, the 15 percent plans (the 15% rate-ofprogress plans) were required for the 1-hour ozone nonattainment areas. Pursuant to this 

requirement, Maryland revised its SIP on August 4, 1997 to adopt COMAR 26.11.19.23 

“Control of Volatile Organic Compounds Emissions from Vehicle Refinishing.” The regulation 

would achieve fully enforceable VOC emissions reductions from vehicle refinishing sources 

through the State of Maryland, which were creditable towards the 15% rate-of-progress plans. 

The rule, which followed EPA’s “Alternative Control Techniques (ACT) Document: Automobile

Body Refinishing” (EPA-453/R-94-031, April 1994), established standards for vehicle

refinishing based on VOC content of coatings, methods for calculating the VOC content of a 

coating system, and standards for operating, monitoring, reporting, and recordkeeping. The 

coating categories included: pretreatment coatings, precoatings, primer surfacers, primer sealers, 

topcoats, multi-stage coating systems, and specialty coatings.

Section 183(e) of the CAA requires EPA to study and report to U.S. Congress on VOC emissions 

from consumer and commercial products and their potential to contribute to nonattainment of the 

ozone NAAQS. In addition, section 183(e) requires EPA to list those categories of consumer 

and commercial products that account for at least 80 percent of the VOC emissions, on a 

reactivity-adjusted basis, in ozone nonattainment areas and establish priorities for their 

regulation. EPA submitted the Report to Congress on March 15, 1995 (“Consumer and 

Commercial Products Report to Congress,'' EPA-453/R-94-066-A), and on this same date 

established the priority list for future regulation of consumer and commercial products 

(published on March 23, 1995, at 56 FR 15264). Automobile refinish coatings were to be 

regulated by March 1997. A final rule entitled “National Volatile Organic Compound Emissions 

Standards for Automobile Refinish Coatings” (EPA’s National Rule) was published by EPA on 

September 11, 1998 under the authority of section 183(e) of the CAA (63 FR 48806), as 

identified in 40 CFR Part 59, subpart B. The federal rule applies to all automobile refinish 

coatings that are manufactured or imported for sale or distribution in the United States, and sets 

VOC content limits by automotive refinish category. See EPA’s August 1998 report “Volatile 

Organic Compound Emissions from Automobile Refinishing - Background Information for 

Promulgated Standards” (EPA-453/R-96-011b). 

On January 9, 2008, EPA published the final rule 40 CFR part 63 subpart HHHHHH “National 

Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface 

Coating Operations at Area Sources” (EPA’s 6H NESHAP), which includes automobile 

refinishing. This federal rule specifically applies to area sources that engage in paint stripping 

operations that use methylene chloride (MeCl) containing paint stripping formulations, and in 

spray application of coatings to motor vehicle and mobile equipment, plastic and or metal 

substrate, where the coatings contain compounds of chromium, lead, manganese, nickel, or 

cadmium. Motor vehicle or mobile equipment surface coating operations may petition the 

EPA’s Administrator for an exemption from this rule if the owner or operator can demonstrate, 

to the satisfaction of the EPA’s Administrator, that the spray applied does not include coatings 

containing any of these compounds. This rule establishes important requirements for these types 

of facilities, among the following: training certification of all new and existing personnel who 
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spray surface coatings, minimum training requirements, and installation to all facilities of a 

filtered spray booth and enclosed spray gun cleaner.

Maryland’s 1997 SIP-approved COMAR 26.11.19.23 “Control of Volatile Organic Compounds 

Emissions from Vehicle Refinishing” complies with the federal standards established in EPA’s 

rules. No changes were made to Maryland’s COMAR 26.11.19.23 until the 2011 amendments, 

which Maryland adopted in its regulations on March 26, 2012. EPA is proposing to approve 

these amendments into the Maryland SIP through this action. The proposed SIP revision is 

based on the 2009 “Model Rule for Motor Vehicle and Mobile Equipment Non-Assembly Line 

Coating Operations” (MVMERR) developed in conjunction with member states of the Ozone 

Transport Commission2(OTC). The MVMERR established requirements which comply with 

those established in EPA’s National Rule and 6H NESHAP. The proposed SIP revision will

replace the standards and requirements in the current SIP-approved regulation with new

standards and requirements, including VOC content limits in automotive coatings and cleaning 

solvents, controls on emissions from equipment cleaning, the use of coating application methods, 

recordkeeping, maintenance activities, and operator training.

Source Description 

Automobile refinishing includes the application of coatings following the manufacture of 

original equipment. “Automobile” or “vehicle” in this category refers to passenger cars, trucks, 

vans, motorcycles, and other mobile equipment capable of being driven on the highway. 

Automobile refinishing work typically consists of structural repair, surface preparation, and 

painting, and includes operations in auto body repair/paint shops, production auto body paint 

shops, new car dealer repair/paint shops, fleet operator repair/paint shops, and custom made car 

fabrication facilities. The steps involved in automobile refinishing include surface preparation, 

coating applications, and spray equipment. VOC emissions result from the evaporation of 

solvents during each of these processes, and can be controlled through the use of compliant 

coatings and solvents, the use of application equipment with increased transfer efficiency, and 

stringent work practice standards. 

The main categories of coatings are primers and topcoats. The primer category consists of 

pretreatment wash primers, primers, primer surfacers, and primer sealer. Topcoats are applied 

over the primer coats and provide the final color to the refinished area. Primers and coatings 

can be classified as lacquer, enamel, or urethane coatings. Each coating differs in its chemistry 

durability, and VOC content. Some additives and specialty coatings are necessary for unusual 

performance requirements, and are used in relatively small amounts to improve desirable 

properties. Additives and special coatings include adhesion promoters, uniform refinish 

 

2 The Ozone Transport Commission (OTC) is a multi-state organization created under the CAA, which is 

responsible for advising EPA on transport issues and for developing and implementing regional solutions to the 

ground-level ozone problem in the Northeast and Mid-Atlantic regions. The OTC has no rulemaking authority. 

Model rules and programs designed through the OTC process must then be taken by the individual states through 

their own rule adoption processes conforming to their state’s requirements.
4

blenders, elastomeric materials for flexible plastic parts, gloss flatteners, and anti-glare/safety 

coatings. For additional information, see EPA’s “Alternative Control Techniques (ACT) 

Document: Automobile Body Refinishing” (EPA-453/R-94-031, April 1994).

C. STATE’S SUBMITTAL 

Summary of SIP Revision

The proposed SIP revision establishes VOC content limits for automotive coatings and cleaning 

solvents used in the preparation, application, and drying phases of vehicle refinishing. The 

revision also establishes coating application standards, work practices, operator training 

standards, and compliance and recordkeeping standards. These standards and emissions limits

for control of VOC as established under Maryland’s COMAR 26.11.19.23 are to be effective for 

all affected sources as of July 1, 2013. Affected sources include: auto body and repair facilities, 

fleet operator repair and paint facilities, new and used auto dealer repair and paint facilities, and 

after-market auto customizing and detailing facilities located throughout the State of Maryland; 

manufacturers, suppliers, and distributors of coatings and cleaning solvents intended for use and 

application to motor vehicles, mobile equipment, and associated components within the State of 

Maryland; and manufacturers, suppliers, and distributors of application equipment and materials 

storage such as spray booths, spray guns, and sealed containers for cleaning rags for use within 

the State. 

The new regulation revises or adds new terms under its definitions. For instance, the definition 

of “mobile equipment” has being extended to include “automobile,” “truck cabs,” “truck 

bodies,” “buses,” “motorcycles,” “implements of husbandry or agriculture,” and “trains and 

railcars.” In addition to the use of automotive coatings or cleaning solvents, the applicability 

requirements have been extended to include any person who supplies, sell, offers for sale, 

distributes, and manufactures automotive coatings or cleaning solvents within the State of 

Maryland. Specific exemptions were incorporated into the regulation to exclude coatings and 

cleaning solvents for sale outside the State, assembly line coatings, aerosol coatings, coatings 

used in surface coating processes under COMAR 26.11.19.03 “Automotive and Light-Duty 

Truck Coating” and coatings sold in 0.5 fluid ounces or less.

The revision establishes specific VOC content limits, which exclude water and exempt 

compounds, for automotive coatings and cleaning solvents. As defined in COMAR 

26.11.01.01B(53), exempt VOC compounds are those which have been determined to have 

negligible photochemical reactivity by EPA and which are listed in 40 CFR 51.100(s), as 

amended. The limits are established in both pounds per gallon (lbs/gal) and grams per liter (g/L) 

for each of the 11 coating categories and two solvent categories. Several categories for coatings 

were added as part of this revision, including: adhesion promoter, clear coating, color coating, 

multicolor coating, single-stage coating, temporary coating, truck bed liner coating, and 

underbody coating. The VOC content limits for the automotive coatings and solvents established 

in section E of the regulation are provided in Table 1 and Table 2, respectively. 
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Table 1: VOC Content Limits for Automotive Coatings for Motor Vehicle and Mobile 

Equipment Refinishing and Recoating VOC Content Limit for Automotive Coatings

Coating Category Maximum VOC Content

lbs/gal g/L

Adhesion promoter 4.5 540

Automotive pretreatment coating 5.5 660

Automotive primer 2.1 250

Clear coating 2.1 250

Color coating, including metallic/iridescent 

color coating 

3.5 420

Multicolor coating 5.7 680

Other automotive coating type 2.1 250

Single-stage coating, including single-stage 

metallic/iridescent coating 

2.8 340

Temporary protective coating 0.5 60

Truck bed liner coating 1.7 200

Underbody coating 3.6 430

Table 2: VOC Content Limits for Cleaning Solvents for Motor Vehicle and Mobile Equipment 

Refinishing and Recoating VOC Content Limit for Cleaning Solvents

Solvent Category Maximum VOC Content

Cleaning solvent (other than bug and tar 

removers) 

0.21 lbs/gal 25 g/L

Bug and tar removers** 40% VOC by weight 

For determining compliance of the VOC content limits of each automotive coating, the VOC 

content should be determined using the following equations:

VOC regulatory content = (Wv - Ww - Wec) / (Vm - Vw - Vec);

VOC actual content = (Wv - Ww - Wec) / (Vm).

The VOC content for cleaning solvents, other than for bug and tar removal, must be determined 

using the following equation:

VOC content = (Wv - Ww - Wec) / (Vm) 

Where: 

VOC content (or actual) = grams of VOC per liter of coating; 

Wv = weight of total volatiles, in grams; 

Ww = weight of water, in grams; 

Wec = weight of exempt compounds, in grams; 
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Vm = volume of material (coating or cleaning solvent, including water, exempt 

compounds, and added solvent) in liters; 

Vw = volume of water, in liters; and 

Vec = volume of exempt compounds, in liters.

A list of test methods to be used for the purpose of demonstrating compliance with provisions of 

this regulation is provided in section B of the rule. Instead of complying with the VOC content 

limits specified in Tables 1 and 2 (section E of the regulation), a person subject to this regulation 

may use an emission control device that has been approved by MDE, which achieves an overall 

emission control efficiency of 85 percent or greater, as determined in accordance with EPA’s

Technical Document, “Guidelines for Determining Capture Efficiency” (January 1995), EPA

Methods 204 through 204F as described in 40 CFR part 51, appendix M, and EPA Reference

Methods 25, 25A, and 25 C. The approved emission control device must be maintained and used 

at all times in proper working condition.

All affected facilities must use at least one of following methods when applying an automotive 

coating: flow or curtain coating, dip coating, brush coating, cotton-tipped swab application, 

electrodeposition coating, high volume-low pressure (HVLP) spraying, electrostatic spraying, 

airless spraying, or an alternate spray equipment method approved by MDE. An alternate 

spraying method should achieve a transfer efficiency equivalent or higher than HVLP or 

electrostatic spray application methods, using the methods described under the South Coast Air 

Quality Management District (SCAQMD) Test Procedure, “Spray Equipment Transfer 

Efficiency Test Procedure for Equipment User” (May 1989) and SCAQMD Guidelines, 

“Guidelines for Demonstrating Equivalency with District Approved Transfer Efficiency Spray 

Guns” (September 2002), and based on the regulation specifications. The terms “electrostatic 

spraying” and “airless spraying” are defined in the regulation to be used in this context. 

Work practice standards include procedures for cleaning the spray gun equipment for applying 

automotive coatings. These procedures should be part of any training program implemented by 

the owners and operators of affected facilities. Affected facilities are also required to keep 

extensive records on the total amount of coating used, VOC actual and regulatory contents, 

purchase records, etc. Facilities using an emission control device must maintain a daily record of 

system operating parameters such as temperature, pressure drops, and air flow rates to 

demonstrate compliance.

Emissions Reductions

The use and implementation of compliant low-VOC automotive coatings and cleaning solvents 

coupled with stringent application and work practice standards is expected to reduce VOC 

emissions from vehicle refinishing operations in the State of Maryland through the use of 

coatings with less toxic compounds. Based upon calculations and emissions estimates by the 

MDE, the SIP revision should provide a statewide VOC emissions reduction potential of 65 

percent from the vehicle refinishing category of the current baseline emissions inventory. 

Maryland’s 2002 baseline emissions inventory indicates that VOC emissions from vehicle 

refinishing total 3.7 tons per day. This regulation is expected to reduce 2.4 tons per day of VOC 

emissions through implementation of the coating limits and standards established.
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D. EPA’S EVALUATION

Maryland has adopted most inclusive requirements as VOC content limits and standards in 

COMAR 26.11.19.23 “Control of Volatile Organic Compounds Emissions from Vehicle 

Refinishing,” which should continue to help reduce VOC emissions from the automobile 

refinishing facilities throughout the State of Maryland. The regulation includes the applicability, 

emissions limits, working standards, requirements for container labeling, monitoring, and 

reporting and recordkeeping recommended by the OTC model rule. 

E. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The Maryland SIP revision for the control of VOC emissions from vehicle refinishing under 

COMAR 26.11.19.23, as adopted by the State of Maryland on March 26, 2012, meets the 

applicable requirements of the CAA and the applicable EPA regulations. The SIP revision will 

help achieve VOC emissions reductions throughout the State of Maryland. EPA recommends 

approval of this SIP revision through rulemaking.