Statement of the Air and Radiation Management Administration 

Department of the Environment 

for the 

Public Hearing Relating to 

Proposed Adhesives and Sealants VOC Regulations 

under COMAR 26.11.35 and Amendments to Control of VOCs from Chemical Production 

and Polytetrafluoroethylene Installations under COMAR 26.11.19.30 

held on January 23, 2008 Baltimore, MD

My name is Husain Waheed. I am the Public Health Engineer of the Regulation 

Development Division of the Air and Radiation Management Administration, Department of the 

Environment. 

This public hearing is being held pursuant to the requirements of 40 CFR Section 51.102 

and Sections 2-301 et.seq. of the Environment Article, Annotated Code of Maryland. It is also 

being held in conformance with the State Administrative Procedures Act under the State 

Government Article, beginning at Section 10-101. 

Notice of this hearing appeared in the: 

Maryland Register on December 21, 2007; 

MDE's website from December 12, 2007 to January 23, 2008; 

Baltimore Sun on December 21, 2007; 

Saint Mary's Enterprise on December 21, 2007; 

Cumberland Times-News on December 21, 2007; 

Frederick News-Post on December 21, 2007; 

Salisbury Daily Times on December 21, 2007; and the 

Washington Post on December 20, 2007. 

Copies of these notices were submitted for the record. 

Copies of the proposed action and supporting documents were submitted for review to 

the State Clearinghouse and are also submitted at this time into the hearing record. Copies were 

also made available for public inspection at the Air and Radiation Management Administration 

offices in Baltimore, Cumberland, and Salisbury, and at all local health departments or local air 

quality control offices. 

 The purpose of today's hearing is to give the public an opportunity to comment on the 

new Regulations .01 - .07 under a new chapter, COMAR 26.11.35 Control of VOC Emissions 

from Adhesives and Sealants and proposed amendments to Regulation .30 under COMAR 

26.11.19 Control of Volatile Organic Compounds from Chemical Production and 

Polytetrafluoroethylene Installations. 

Summary 

1 
The proposed regulations, Control of VOC Emissions from Adhesives and Sealants under 

a new chapter COMAR 26.11.35, beginning January 1, 2009, accomplish the following: 

 

 A. Set standards for the application of adhesives, sealants, adhesive primers 

and sealant primers by providing options for appliers to either use a product with a VOC content 

equal to or less than a specified limit or to use add-on controls; 

B. Establish standards for cleanup solvents; 

C. Establish a VOC limit for surface preparation solvents; 

D. Provide for an alternative add-on control system requirement of at least 85 

percent overall control efficiency (capture and destruction), by weight; 

E. Provide exemptions for certain operations such as medical and defense 

equipment manufacturing and for small containers; 

 F. Require simplified records of materials used and VOC content to be 

maintained for 5 years. More detailed records are required for non-compliant products on 

material usage from persons who qualify for exemptions; 

G. Require that VOC-containing materials must be stored or disposed of in 

closed containers; 

 H. Prohibit the sale of any adhesive, sealant, adhesive primer or sealant 

primer that exceeds the VOC content limits; 

I. Require manufacturers to label containers with the maximum VOC 

content as supplied, as well as the maximum VOC content on an as-applied basis when used in 

accordance with the manufacturer’s recommendations regarding thinning, reducing, or mixing 

with any other VOC containing material; and 

 J. Prohibit the specification of any adhesive, primer, or sealant that violates 

the provisions of the proposed regulations. 

The basis for the adhesive and sealant regulations is a regional model rule developed by 

staff of member states, including Maryland, and the Ozone Transport Commission (OTC) in 

2006. The model rule itself was based in large part upon the reasonably available control 

technology (RACT) and best available retrofit control technology (BARCT) determination 

developed in 1998 by the California Air Resources Board (CARB). Based upon a review of 

those standards and comments received at public meetings, the OTC states finalized a model rule 

suitable for implementation in the Northeast in early 2007. The proposed adhesive and sealant 

regulations reflect amendments to the OTC model rule made by the Department in response to 

comments received during the Maryland stakeholder process. 

Amendments to COMAR 26.11.19.30 expand the regulation to include fluoropolymer 

materials and establish an exemption level for the applicability of standards under COMAR 

26.11.35 for adhesive application. 

 

Maryland’s State Implementation Plan (SIP)

These amendments and new regulations will be submitted to the U.S. Environmental 

Protection Agency as a revision to Maryland’s State Implementation Plan. 

Consideration of Comments 

2 
The Department will consider all comments before making a decision to adopt these 

amendments and new regulations. 

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