UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

Santa Barbara County Air Pollution Control District, 

Rule 353, Adhesives and Sealants

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

May 2013
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Agency: Santa Barbara County Air Pollution Control District

(SBCAPCD)

SIP Approved Rule: Rule 353– Adhesives and Sealants

Adopted – August 19, 1999

Submitted – October 29, 1999

EPA Approved – April 5, 2000 (65 FR 17771)

Subject of this TSD: Rule 353– Adhesives and Sealants

Revised – June 21, 2012

Submitted – September 21, 2012

RULE SUMMARY – SBCAPCD Rule 353, Adhesives and Sealants, was amended 

to clarify exemptions and add exemptions for low-VOC solvents and for products 

subject to the consumer products regulation of the California Code of Regulations 

(CCR) Title 17. Several new provisions were exempted from the new more 

stringent solvent, surface preparation and coating stripper use requirements. The 

majority of revisions are for further clarification of terms and an expansion of 

descriptions. Rule 353 was also amended to lower VOC limits of a number of 

adhesives and substrate adhesives to comply with the federal reasonably available 

control technology (RACT) established in the 2008 Control Technique Guideline 

(CTG) for Miscellaneous Industrial Adhesives,

1

and the State of California Air 

Resources Board (CARB) Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives 

 

1. EPA-453/R-08-005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives, 

September 2008.
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and Sealants.

2 The compliance provision and test methods section was amended to 

include more EPA approved test methods. A compliance schedule, application 

equipment requirements, coating stripper requirements, reporting requirements and 

solvent cleaning machine requirements were added in this amendment. Santa 

Barbara is currently in attainment for ozone and PM 2.5 so this rule is not required 

to fulfill federal RACT requirements.

The modifications to Rule 353, Adhesives and Sealants, include:

1. Clarified the Section A, Applicability, to include distribution of adhesive 

products and associated solvents. 

2. Revised several portions in Section B, Exemptions:

a. Removed the exemption for plaque laminating operations.

b. Clarified several existing exemptions to include associated solvents.

c. Added an exemption for cleaning with a solvent containing less than 

two percent Reactive Organic Compounds (ROC).

d. Added an exemption for consumer products regulated by CCR section 

94507.

e. Removed the requirements for cleanup solvents and methods, for 

surface preparation and for coating stripper use for a number of 

specialized items and processes involving adhesives and solvents.

3. Revised Section C to add definitions for the following: Adhesive Product, 

Airless Spray, Associated Solvent, Bench Scale Project, Coating, Compliant 

Material, Control, Control System, Dip Coat Application, Electrodisposition, 

Flow Coat Application, Hand Application Method, Noncompliant Material, 

Sealant Product, Solvent, Solvent Cleaning, Solvent Cleaning Machine, 

Stripper and Viscosity. Definitions for Aerosol Adhesives, Contact Bond 

Adhesive, Contact Bond Adhesive Specialty Substrates or Specialty Contact 

 

2. State of California Air Resources Board (CARB) Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants, 

December 1998.
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Adhesive, Fiberglass, Flexible Vinyl, Grams of Reactive Organic Compound 

per liter of Adhesive or Sealant Less Water and Less Exempt Compounds, 

Outdoor Floor Covering Installation Adhesive, Percent Reactive Organic 

Compound by Weight, Sealant Solid, Surface Preparation Solvent, Thin 

Metal Laminating Adhesive, Tire Retread Adhesive and Volatile Organic 

Compound (VOC) were revised for clarity. Definitions for Adhesive Bonding 

Primer, Any Other Primer, Exempt Compound, and Grams of Reactive 

Compound Per Liter of Material were deleted.

4. Revised the Tables in Sections D and E to lower ROC limits 12 months after 

the date of amended rule adoption for the following categories: Metal to 

urethane/rubber molding or casting, Multi-purpose Construction (except cove 

base installation), Other plastic cement welding, PVC Welding and 

Fiberglass and Porous Material Substrates. 

5. Clarified the Requirements for Aerosol Adhesives ROC Limit, Cleanup 

Solvents and/or Cleanup Method, Surface Preparation Solvent and 

Alternative Compliance Provisions in Sections F, G, H and I.

6. Changed Section J’s title from Storage of Reactive Organic Compound 

Containing Materials to Requirements – General Operating. Clarified storage 

and disposal of ROC-containing materials and added the following: 

a. Installation, ventilation and operation of application equipment

b. Handling of waste solvent

c. Methods for reducing evaporation of ROC–containing materials

d. Handling, transfer and storage of coatings, strippers and solvents

7. Clarification of Requirements for the Prohibition of Sale, Manufacturer 

Compliance Statement and Labeling and Prohibition of Specification in 

Sections K, L and M.

8. Changed title of Section N from Monitoring to Requirements – Compliance 

Provisions and Test Methods. Revised the following:

a. Included several additional test methods, using the correct titles 

and EPA approved dates, for determining the ROC content, exempt 
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compounds, ROC content in aerosol containers, of plastic welding 

adhesives and primers, of capture efficiency and control device 

efficiency. 

b. Removed the composite vapor pressure equation and replaced it with 

an ASTM method for measuring. 

c. Clarified active and passive solvent losses from spray gun cleaning 

and determination of reactive diluents test methods. 

d. Added test methods for determining transfer efficiency, capture 

efficiency, control device efficiency, viscosity, measurement of 

emission of ROC from control system exhaust.

9. Revised the Recordkeeping Requirement in Section O to:

a. Clarify the type of information required for ROC-containing adhesive 

and sealant products materials and emission control equipment 

parameters.

b. Include requirements for purchase and disposal records at stationary 

sources.

c. Establish a daily recording of noncompliant material usage and a 

monthly recording of compliant material usage.

10. Added Sections P, Compliance Schedule, Q, Requirement – Adhesive and 

Sealant Application Equipment, R, Requirements – Coating Stripper Use, S, 

Reporting Requirements and T, Requirements – Solvent Cleaning Machine to 

provide clarity and completeness. 

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988), the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 
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Plans, General Preamble for the Implementation of Title I of the Clean Air 

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help 

evaluate compliance with the CAA §110(a)(2)(A) requirement for 

enforceability. 

2. Stringency – The EPA’s CTGs titled Miscellaneous Industrial Adhesives, 

(EPA 453/R-08-005, September 2008) and Industrial Cleaning Solvents 

(EPA 453/R-06-001, September 2006) and CARB’s Determination of 

Reasonable Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) for Adhesives and Sealants (December 1998)

were used to establish RACT for adhesives and sealants. Other districts’

analogous rules for this category were used as the basis for RACT including:

South Coast Air Quality Management District (SCAQMD) Rule 1168, 

Adhesive and Sealant Applications, amended January 7, 2005, and San 

Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4653, 

Adhesives and Sealants, amended September 16, 2010.

3. SIP Relaxation – We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the 

Act (CAA §110(l)) or modify, in a nonattainment area, any SIP-approved 

control requirement in effect before November 15, 1990 (CAA §193).

Enforceability - The recordkeeping requirements for Rule 353 are very detailed and 

have clear time frames. Generally, they are analogous to that of SCAQMD’s rule 

1168, SJVUAPCD’s rule 4653 and CARB’s Determination of RACT and BARCT for 

Adhesives and Sealants. All test methods resemble the CARB’s Determination of 

RACT and BARCT for Adhesives and Sealants. Capture, Overall and Transfer 

efficiencies are adequately defined and the minimum Overall efficiency percentage of 

85 percent is equal to that of the 2008 CTG and SJVUAPCD’s rule. Therefore, we 

propose to determine that submitted Rule 353 is sufficiently clear and enforceable.
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Stringency – We believe Rule 353 generally meets federal RACT requirements 

although that is not currently required in Santa Barbara. Overall, it is as stringent as, 

and in many cases more stringent than, the 2008 CTG and CARB’s 1998 

“Determination of RACT and BARCT for Adhesives and Sealants”. SBCAPCD’s Rule 

353 closely resembles SCAQMD’s Rule 1168 and AVAQMD’s Rule 1168 for VOC 

limits for adhesives, adhesive primers, sealants and sealant primers and for solvent 

cleaning activities. SBCAPCD’s Rule 353 also addresses limits for adhesive strippers 

which the CTG, CARB determination and other district rules do not. 

The exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit,

but is not as stringent as other SIP rules are:

 Ceramic Tile (wall and floor) Adhesive with a limit of 130 grams/liter: 

Although the CTG and CARB Determination of RACT and BARCT indicate a

130 grams/liter limit, SCAQMD Rule 1168, AVAQMD Rule 1168 and 

SJVUAPCD 4653 have 65 grams/liter limits for these same categories. 

 Computer Diskette Jacket Manufacturing adhesive, with a limit of 850 

grams/liter: This limit resembles the limit in the CARB Determination of RACT 

and BARCT, but both SCAQMD Rule 1168 and AVAQMD Rule 1168 have 

350 grams/liter limits for this same category. 

 Contact Adhesive with a limit of 250 grams/liter: This corresponds to the 250 

grams/liter limit of the CTG and the 850/250 grams/liter of the CARB 

Determination of RACT and BARCT. However, SCAQMD Rule 1168, AVAQMD 

Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 74.20 all 

propose a much lower limit of 80 grams/liter. 

 Cove Base adhesive, with a limit of 150 grams/liter: SCAQMD Rule 1168,

AVAQMD Rule 1168 and SJVUAPCD Rule 4653 have 50 grams/liter limits 

for this same category. 

 Indoor Floor Covering Installation, with a limit of 150 grams/liter: SCAQMD 

Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 74.20 all 

propose a much lower limit of 50 grams/liter. 
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 ABS Welding with a limit of 400 grams/liter: Although this limit resembles the 

limits in the CTG and the CARB Determination of RACT and BARCT, both 

SCAQMD Rule 1168 and AVAQMD Rule 1168 have 325 grams/liter limits for 

this same category. 

 Other Plastic Welding with a limit of 500 grams/liter: SBAPCD Rule 353, 

SCAQMD Rule 1168, SJVUAPCD Rule 4653 and AVAQMD Rule 1168 have 

established limits of 250 grams/liter for this category.

 Plastic Welding Primer with a limit of 650 grams/liter: While this limit is 

equivalent to that of the CTG, it exceeds the 510 grams/liter limit of the 

CARB Determination of RACT and BARCT, is considerably higher than the 

400 grams/liter limit for proposed PCAPCD Rule 235 and for SJVUAPCD 

Rule 4653 and is somewhat higher than the 550 grams/liter limit of 

SCAQMD Rule 1168 and AVAQMD Rule 1168. 

 Contact Bond Specialty Substrate with a limit of 400 grams/liter: SCAQMD 

Rule 1168, SJVUAPCD Rule 4653 have limits of 250 grams/liter and 

PCAPCD Rule 235 proposes a 200 grams/liter limit. 

Considering that the 2008 CTG limits have generally been met, we propose to 

determine that submitted Rule 353 is sufficiently stringent.

SIP Relaxation – The new submittal generally complies with CAA §110(l) and §193 

regarding SIP relaxations. In this revision, two categories of adhesives; Metal to 

Urethane /rubber Molding or Casting and Multipurpose Construction, two categories 

of plastic welding products; PVC welding and Other Plastic cement welding and two 

substrate/applications; Fiberglass and Porous Material have lowered limits. The 

category of “strippers” has been added to the recordkeeping requirements. Effective

June 21, 2013, Solvents will be required to contain no more than 25 grams/liter 

ROCs. In addition, recordkeeping requirements have been clarified and now include 

recordkeeping of all control system parameters. Therefore, we propose to determine 

that submitted Rule 74.20 has not relaxed the SIP rule in violation of CAA sections 

110(l) or 193.
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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. Section D, Requirements – Reactive Organic Compound Limits for Specific 

Applications of Adhesive Products or Sealant Products,: We recommend that 

the following limits be considered as discussed above: 

a. 65 grams/liter for Ceramic Tile Adhesive

b. 350 grams/liter for Computer Diskette Jacket Manufacturing Adhesive

c. 80 grams/liter for Contact Adhesive

d. 50 grams/liter for Cove Base Adhesive

e. 50 grams/liter for Indoor Floor Covering Installation Adhesive

f. 150 grams/liter for Outdoor Floor Covering Installation Adhesive

g. 325 grams/liter for ABS Welding 

h. 400 grams/liter for Plastic Welding Primer

i. 200 grams/liter for Contact Bond-Specialty Substrate

2. Section E, Requirements – Reactive Organic Compound Limits for 

Nonspecific Applications of Adhesive Products or Sealant Products Onto 

Substrates, Consider modifying the substrate “Metal” to “Metal to Metal.”

2. Section N, Test Methods:

Subsections 7 and 14 – The correct title for ARB Test Method 422 is 

“Determination of Volatile Organic Compounds in Emissions from Stationary 

Sources.” 

3. The July 21, 2013 compliance date specified in Subsection P-1 and P-4 

should be included in Section J and T respectively. 

EPA ACTION - EPA staff recommends a full approval of SBCAPCD Rule 353

pursuant to CAA §110(k)(4) and §301(a). 
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ADDITIONAL REFERENCES –

1. SBCAPCD Rule 353, Adhesives and Sealants, Adopted August 19, 1999.

2. SBCAPCD Rule 353, Adhesives and Sealants, Revised June 21, 2012.

http://www.sbcapcd.org/rules/download/rule353.pdf

3. SCAQMD Rule 1168, Adhesive and Sealant Applications, amended January 

7, 2005. http://www.aqmd.gov/rules/reg/reg11/r1168.pdf

4. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 

2010. http://www.valleyair.org/rules/currntrules/r4653.pdf

5. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 

453/R-08-005, September 2008

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200809_v

oc_epa453_r-08-005_miscellaneous_industrial_adhesives.pdf

6. Control Techniques Guidelines: Industrial Solvents, EPA-453/R-06-001, 

September 2006.

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v

oc_epa453_r-06-001_ind_cleaning_solvents.pdf

7. State of California Air Resources Board Determination of Reasonably 

Available Control Technology and Best Available Retrofit Control Technology 

for Adhesives and Sealants, December 1998.

http://www.arb.ca.gov/ractbarc/adhfinal.pdf

8. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” 

(a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

9. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf