Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives
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EPA-453/R-08-005 

September 2008 

Control Techniques Guidelines for 

Miscellaneous Industrial Adhesives 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC
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TABLE OF CONTENTS 

I. Introduction............................................................................................................................. 1 

II. Background and Overview ..................................................................................................... 2 

III. Applicability ....................................................................................................................... 3 

IV. Process Description and Sources of VOC Emissions......................................................... 4 

A. Process Description............................................................................................................. 5 

1. Surface Preparation......................................................................................................... 5 

2. Adhesive Application...................................................................................................... 5 

3. Cleaning Activities.......................................................................................................... 7 

B. Sources of VOC Emissions................................................................................................. 7 

1. Adhesives........................................................................................................................ 8 

2. Cleaning Materials.......................................................................................................... 8 

V. Available Controls and Regulatory Approaches..................................................................... 9 

A. Available Controls for VOC Emissions from Adhesives ................................................... 9 

1. Pollution Prevention Measures ....................................................................................... 9 

2. Emission Capture and Add-on Control Systems .......................................................... 10 

B. Available Controls for VOC Emissions from Cleaning Materials ................................... 13 

1. Product Substitution/Reformulation ............................................................................. 13 

2. Work Practice Procedures............................................................................................. 13 

C. Existing Federal, State, and Local Recommendations or Regulations ............................. 14 

1. Existing State and Local VOC Requirements............................................................... 14 

VI. Recommended Control Options........................................................................................ 15 

A. Adhesive and Adhesive Primer Emission Limits ............................................................. 17 

B. Adhesive Application Methods......................................................................................... 19 

C. Add-on Controls for Adhesive Application Operations ................................................... 19 

D. Work Practices for Adhesive-Related Activities .............................................................. 19 

E. Work Practices for Cleaning Materials............................................................................. 20 

VII. Cost Effectiveness of Recommended Control Options .................................................... 20 

VIII. References......................................................................................................................... 21 

LIST OF APPENDICES 

Appendix A - Definitions 

Appendix B - Summary of State and Local Requirements for VOC Emissions from Adhesives 

and Adhesive Primers 

Appendix C - Summary of State and Local Requirements for Application Method and 

Efficiency 
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I. Introduction

Clean Air Act (CAA) section 172(c)( 1) provides that state implementation plans (SIPs) 

for nonattainment areas must include “reasonably available control measures” (RACM), 

including “reasonably available control technology” (RACT), for sources of emissions. Section 

182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs to 

include RACT for each category of volatile organic compound (VOC) sources covered by a 

control techniques guidelines (CTG) document issued between November 15, 1990 and the date 

of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest 

emission limitation that a particular source is capable of meeting by the application of control 

technology that is reasonably available considering technological and economic feasibility.” 44 

FR 53761 (September 17, 1979). In subsequent Federal Register notices, EPA has addressed 

how States can meet the RACT requirements of the CAA. 

Clean Air Act section 183(e) directs EPA to list for regulation those categories of 

products that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, 

from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., ozone 

nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list 

periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR 

69759 (Nov. 17, 2005); 64 FR 13422 (March 18, 1999). Miscellaneous Industrial Adhesives are 

included on the current section 183(e) list. 

This CTG is intended to provide State and local air pollution control authorities 

information that should assist them in determining RACT for VOCs from miscellaneous 

industrial adhesive application processes. In developing this CTG, EPA, among other things, 

evaluated the sources of VOC emissions from miscellaneous industrial adhesives application 

processes and the available control approaches for addressing these emissions, including the 

costs of such approaches. Based on available information and data, EPA provides 

recommendations for RACT for miscellaneous industrial adhesives. 

States can use the recommendations in this CTG to inform their own determination as to 

what constitutes RACT for VOCs for miscellaneous industrial adhesive application processes in 

their particular nonattainment areas. The information contained in this document is provided 

only as guidance. This guidance does not change, or substitute for, requirements specified in 

applicable sections of the CAA or EPA’s regulations; nor is it a regulation itself. This document 

does not impose any legally binding requirements on any entity. It provides only 

recommendations for State and local air pollution control agencies to consider in determining 

RACT. State and local pollution control agencies are free to implement other technically-sound 

approaches that are consistent with the CAA and EPA’s implementing regulations. 

The recommendations contained in this CTG are based on data and information currently 

available to EPA. These general recommendations may not apply to a particular situation based 

upon the circumstances of a specific source. Regardless of whether a State chooses to implement 

the recommendations contained herein through State rules, or to issue State rules that adopt 
2 

different approaches for RACT for VOCs from miscellaneous industrial adhesives, States must 

submit their RACT rules to EPA for review and approval as part of the SIP process. 

EPA will evaluate the rules and determine, through notice and comment rulemaking in 

the SIP approval process, whether the submitted rules meet the RACT requirements of the CAA 

and EPA’s regulations. To the extent a State adopts any of the recommendations in this 

guidance into its State RACT rules, interested parties can raise questions and objections about 

the substance of this guidance and the appropriateness of the application of this guidance to a 

particular situation during the development of the State rules and EPA’s SIP approval process. 

Clean Air Act section 182(b)(2) requires that a CTG issued between November 15, 1990, 

and the date of attainment include the date by which States subject to section 182(b) must submit 

SIP revisions in response to the CTG. Accordingly, EPA is providing in this CTG a one-year 

period for the required submittal. Pursuant to section 182(b)(2), States required to submit rules 

consistent with section 182(b) must submit their SIP revisions within one year of the date of 

issuance of the final CTG for miscellaneous industrial adhesives. 

II. Background and Overview

There are no previous EPA actions that affect miscellaneous industrial adhesive 

application operations. 

In 1998, the California Air Resources Board (ARB) issued a guidance document that 

includes ARB’s determination of Reasonably Available Control Technology (RACT) and Best 

Available Retrofit Control Technology (BARCT) for Adhesives and Sealants1

. The 1998 ARB 

document presented RACT and BARCT for controlling VOC emissions from the commercial 

and industrial application of adhesives and sealants. The ARB RACT determination prescribes 

VOC emission limits for various industrial adhesives and sealants and was developed based on 

eight existing California air pollution control district rules for adhesives and sealants that were in

effect in 1998. Those eight districts included Bay Area (BAAQMD), El Dorado County 

(EDCAPCD), Placer County (PCAPCD), Sacramento Metropolitan (SMAQMD), South Coast 

(SCAQMD), Ventura County (VCAPCD), Yolo-Solano (YSAQMD), and San Diego County 

(SDCAPCD). 

Since the development of the ARB RACT determination, five additional California air 

pollution control districts have adopted rules based on the ARB RACT standards, resulting in a 

total of 13 air pollution control districts in California having established rules for adhesives. 

In 2007, the Ozone Transport Commission issued its Model Rule for Adhesives and 

Sealants.2 The model rule was based almost entirely on the 1998 California ARB RACT 

determination. The model rule is designed for adoption by member states in 2009. To date, only 

Maryland has adopted an adhesives rule based on the OTC model rule. Connecticut, Delaware, 

District of Columbia, Maine, Massachusetts, New Hampshire, New Jersey, New York, 

Pennsylvania, Rhode Island, Vermont, and Virginia are all either currently in various stages of 

formal rule adoption or are developing a proposed rule. 

At least eight California Districts and Maryland regulate cleaning materials used in 

adhesive application processes. These regulations require a combination of work practice, 

equipment standards, and limits on the VOC content, boiling point, or composite vapor pressure 
3 

of the solvent. Some California District rules allow the use of add-on controls as an alternative 

to the VOC content/boiling point/vapor pressure limits for cleaning materials. 

EPA developed the recommended approaches contained in this document after reviewing 

the existing State and local VOC emission reduction approaches. 

The remainder of this document is divided into six sections. Section III describes the 

scope of sources to which the control recommendations in this CTG could apply. Section IV 

describes the miscellaneous industrial adhesives, including the types of adhesive materials and 

the application processes, and identifies the sources of VOC emissions from those processes. 

Section V describes the available control approaches for addressing VOC emissions from this 

product category and summarizes State and local approaches for addressing such emissions. 

Section VI provides our recommendations for RACT for miscellaneous industrial adhesives 

application processes. Section VII discusses the cost-effectiveness of the recommended control 

approaches. Section VIII contains a list of references. 

III. Applicability

This CTG provides control recommendations for reducing VOC emissions from 

miscellaneous industrial adhesives and adhesive primer application processes. Please see section 

IV of this CTG for a description of the miscellaneous industrial adhesives category under section 

183(e) of the CAA. This section addresses EPA's recommendations as to the scope of entities to 

which the RACT recommendations in this CTG should apply. As explained above, this 

document is a guidance document and provides information for States to consider in determining 

RACT. When State and local pollution control agencies develop RACT rules, they may elect to 

adopt control approaches that differ from those described in this document and/or promulgate 

applicability criteria that differ from those recommended here. 

In terms of applicability, we recommend that the control approaches discussed in section 

VI of this CTG apply to each miscellaneous industrial adhesive application process1

 at a facility 

where the total actual VOC emissions from all miscellaneous industrial adhesive application 

processes, including related cleaning activities, at that facility are equal to or exceed 6.8 kg/day 

(15 lb/day), or an equivalent level such as 3 tons per 12-month rolling period, before 

consideration of controls. We do not recommend these control approaches for facilities that emit 

below this level because of the very small VOC emission reductions that can be achieved. The 

recommended threshold level is equivalent to the evaporation of approximately two gallons of 

solvent per day. Such a level is considered to be an incidental level of solvent usage that could 

be expected even in facilities that use very low-solvent adhesives, such as radiation cured 

adhesives (these adhesives will be discussed in more detail in section IV.B.1 of this document). 

Furthermore, based on the 2002 NEI data and the 2004 ozone nonattainment designations, 

facilities emitting below the recommended threshold level collectively emit less than 6 percent of 

the total reported VOC emissions from miscellaneous industrial adhesive application processes 

in ozone nonattainment areas. For these reasons, we did not extend our recommendations in this 

CTG to these low-emitting facilities. For purposes of determining whether a facility meets our 

 

1

 An application process consists of a series of one or more adhesive applicators and any associated drying area 

and/or oven wherein an adhesive is applied, dried, and/or cured. An application process ends at the point where the 

adhesive is dried or cured, or prior to any subsequent application of a different adhesive. It is not necessary for an 

application process to have an oven or flash-off area. 
4 

recommended applicability threshold, aggregate emissions, before consideration of control, from 

all miscellaneous industrial adhesive application processes (including related cleaning activities) 

at a given facility are included. 

In developing their RACT rules, State and local agencies should consider carefully the 

facts and circumstances of the affected sources in their States. As noted above, States can adopt 

the above recommended 6.8 kg/day (15 lb/day) actual VOC emissions or an equivalent 

applicability threshold, or they can develop other applicability criteria that they determine are 

appropriate considering the facts and circumstances of the sources in their particular 

nonattainment areas. EPA will review the State RACT rules in the context of the SIP revision 

process. 

The 2002 National Emission Inventory (NEI) was used as the source of emissions data 

and other information concerning facilities operating miscellaneous industrial adhesive 

application processes. 

In developing this CTG, the 2002 NEI database was queried for facilities likely 

performing miscellaneous industrial adhesive application based on Source Classification Code 

(SCC) 40200701, 40200706, 40200707, 40200710, 40200711, and 40200712. This activity 

resulted in 1,048 facilities with miscellaneous industrial adhesive application processes in the 

2002 NEI, and VOC emissions totaled an estimated 8,660 Mg/yr (9,546 tpy) from adhesive 

application processes. Of the 1,048 facilities identified in the 2002 NEI, 720 facilities were 

located in ozone nonattainment areas and 180 of the facilities located in ozone nonattainment 

areas emit more than the 6.8 kg/day (15 lb/day) VOC applicability threshold described above. 

These 180 facilities emitted an estimated 4,428 Mg (4,881 tons) of VOC in 2002 from adhesive 

application processes. 

IV. Process Description and Sources of VOC Emissions

The miscellaneous industrial adhesives product category includes adhesives (including 

adhesive primers used in conjunction with certain types of adhesives) used at industrial 

manufacturing and repair facilities for a wide variety of products and equipment that operate 

adhesives application processes. 

The miscellaneous industrial adhesives product category does not include adhesives that 

are addressed by CTGs already issued for categories listed under CAA Section 183(e) or by 

earlier CTGs. These include the CTGs issued under Section 183(e) for aerospace coatings; metal 

furniture coatings; large appliance coatings; flat wood paneling coatings; paper, film, and foil 

coatings; offset lithographic printing and letterpress printing; and flexible package printing. Coil 

coating, fabric coating, and rubber tire manufacturing were not listed under CAA Section 183(e), 

however, they were the subject of earlier CTGs which address adhesives used in those processes. 

Motor vehicle adhesives, glass bonding primers, and weatherstrip adhesives that are used 

at a facility that is not an automobile or light-duty truck assembly coatings facility, are addressed 

in this CTG for miscellaneous industrial adhesives. Please see section VI of this CTG for our 

VOC control recommendations for these motor vehicle materials. The VOC control 

recommendations for these motor vehicle materials in the CTG for miscellaneous industrial 

adhesives are the same as the VOC control recommendations for similar materials used at 
5 

automobile and light-duty truck assembly coating facilities, which are addressed in the final 

automobile and light-duty truck assembly coatings CTG. 

A. Process Description

Adhesives are used for joining surfaces in assembly and construction of a large variety of 

products. Adhesives allow for faster assembly speeds, less labor input, and more ability for 

joining dissimilar materials than other fastening methods. Although there are a wide variety of 

adhesives formulated from a multitude of synthetic and natural raw materials, all adhesives can 

be generally classified as solution/waterborne, solvent-borne, solventless or solid (e.g., hot melt 

adhesives), pressure sensitive, hot-melt, or reactive (e.g., epoxy adhesives and ultraviolet-curable 

adhesives). Adhesives can also be generally classified according to whether they are structural 

or nonstructural. Structural adhesives are commonly used in industrial assembly processes and 

are designed to maintain product structural integrity. 

1. Surface Preparation 

The vast majority of adhesives require the application of a primer to the substrate before 

the adhesive is applied. Adhesive primers are usually applied in very thin films, and serve to wet 

the substrate surface and provide improved bonding capability for the adhesive. Adhesive 

primers are commonly solvent-borne materials3

. 

2. Adhesive Application 

Adhesive application is accomplished by applying an adhesive to a substrate, followed by 

curing or drying the adhesive. The adhesive itself may be in the form of an aerosol applied by 

spraying, or liquid applied by spraying, rolling, or dipping. 

There are several different types of applicators that may be used to apply adhesives, and 

are generally similar or identical to surface coating application techniques. The most common 

types of applicators include: air atomized spray, electrostatic spray, high volume/low pressure 

(HVLP) spray, dip coating, flow coating, brush or roll coating, electrocoating, and hand 

application. 

Spray application operations are typically performed in a spray booth by manual or 

automated (e.g., robotic) means to capture overspray, remove solvent vapors from the workplace, 

and to keep the application operation from being contaminated by dirt from other operations. In 

some instances, productivity is maximized by using automated application followed by manual 

touchup. Typically, overspray is collected within the booth on either dry filter media or a 

waterwash booth. Air flow in a booth equipped with dry filter media generally passes from the 

spray applicator, over the substrate, and through a dry filter bank. Waterwash booths are less 

commonly used than dry filter booths. In a waterwash booth, air is drawn through a continuous 

curtain of moving water and overspray is removed by contact with the water. In booths equipped 

with dry filters and in waterwash booths, the overspray can be collected on a series of baffles in 

front of the dry filters or waterwash, and, in some cases, the collected overspray can be reused. 

This recycling method substantially reduces both air emissions and waste (including spent dry 

filters) generated by the adhesive application operation. 
6 

Several different types of application technologies are used to apply adhesives, and the 

selection of the application technology can significantly affect the amount of adhesive used and 

the resulting VOC emissions from the application process. 

Conventional air spray application uses compressed air at high pressure (e.g., 30 to 90 

pounds per square inch, psi) to pull the adhesive from a reservoir and atomize the adhesive as it 

is expelled from the spray gun tip. The mixture of air and atomized adhesive then deposits the 

adhesive on the substrate. Because of the high pressure of air used, most of the adhesive does 

not land on the substrate and is carried away from the substrate as overspray and is wasted. The 

fraction of adhesive solids that reaches the substrate is termed transfer efficiency, and 

conventional air spray has a relatively low transfer efficiency compared to other application 

methods. Therefore, many application processes have adopted other types of spray application 

to use adhesives more efficiently. 

Airless Spray. With airless spray, a pump forces the adhesive through an atomizing 

nozzle at high pressure (1,000 to 6,000 psi). Airless spray is ideal for rapid coverage of large 

areas and when a heavy film build is required. The size of airless spray adhesive droplets is 

larger, the spray cloud is less turbulent, and the transfer efficiency is typically superior to 

conventional air spray. 

 Air-Assisted Airless Spray. An air-assisted airless system combines the benefits of 

conventional air spray and airless spray. The system consists of an airless spray gun with a 

compressed air jet at the gun tip to atomize the adhesive. It uses lower fluid pressures than 

airless spray and lower air pressures than conventional air spray (e.g., 5 to 20 psi versus 30 to 

90 psi). This fluid/air pressure combination delivers a less turbulent spray than conventional air 

systems and applies a more uniform finish than airless systems. However, the amount of time 

needed to apply adhesives is greater because of the lower fluid and air pressure. 

Electrostatic Spray. In electrostatic spray application, the adhesive and substrate are 

oppositely charged. The substrate is grounded and attracts the negatively charged adhesive 

particles. Electrostatic spray systems are reported to have the highest transfer efficiency of any 

of the spray application techniques because of minimal overspray, which also results in lower 

adhesive loss and lower VOC emissions. 

HVLP systems use lower air pressures (generally not more than 10 psi at the spray cap) 

and greater volumes than conventional air atomized spray systems. Specialized nozzles provide 

better air and fluid flow at the lower air pressure, and shape the air/spray pattern and guide the 

atomized adhesive particles to the substrate. The lower air pressures result in greater transfer 

efficiency compared to conventional air atomized spray systems. 

Dip coating is another available method for applying liquid adhesives. It is typically 

used for large complicated parts where it would be difficult to use other methods. The substrates 

are manually or automatically dipped into a tank containing the adhesive. The substrates are 

then withdrawn from the tank and any excess adhesive is allowed to drain, thus achieving very 

high transfer efficiencies. Typical systems have some means of recirculation of the tank 

contents, filters to remove paint sediment and solid contaminants, and means for controlling the 

viscosity of the fluid. Because the tank opening exposes a large surface area of liquid adhesive, 
7 

solvent losses occur from the tank. To maintain the desired adhesive viscosity in the tank, these 

losses are compensated by adding thinner (water or solvent, depending on the adhesive used). 

Flow coating is similar to dip coating and involves conveying the substrate over an 

enclosed sink, where the adhesive is applied at low pressure as the item passes under a series of 

nozzles. Excess adhesive drains back into the sink, is filtered, and pumped back into a holding 

tank. A typical flow coater tank is enclosed and is smaller than the equivalent dip coating tank. 

As a result, less adhesive is used and less solvent is evaporated than in dip tank operations. This 

application method results in an increase in production rate. 

Roll coating, brush coating, and hand application are often used for high viscosity 

adhesives and for application onto small surface areas. 

Electrocoating (electrodeposition) is a specialized form of dip coating where opposite 

electric charges are applied to the waterborne adhesive and the substrate. The adhesive is 

deposited on the part by means of electrical attraction, which produces a more uniform 

application on the substrate than traditional dip application. 

After each of the adhesive application operations described above, the applied adhesive is 

usually air dried or cured. For liquid spray and dip coating operations, the substrate is typically 

first slowly moved through a flash-off area after the adhesive is applied. The adhesive is either 

then allowed a specified drying time to allow tackification before bonding, or the substrate is 

immediately bonded. 

3. Cleaning Activities 

Cleaning activities other than surface preparation and priming also occur at facilities 

operating miscellaneous industrial adhesive application processes. Cleaning materials are used 

during these activities to remove adhesive residue or other unwanted materials from equipment 

related to application operations, as well as the cleaning of spray guns, transfer lines (e.g., tubing

or piping), tanks, and the interior of spray booths. These cleaning materials are typically 

mixtures of VOC-containing solvents. 

B. Sources of VOC Emissions

The VOC emissions from miscellaneous industrial adhesives result from evaporation of 

the solvents contained in many of the primers, adhesives and cleaning materials during adhesive 

application and drying processes, as well as during surface preparation and cleaning processes 

associated with adhesives application. The primary VOC emissions from miscellaneous 

industrial adhesives occur during application and flash-off. 

A lesser amount of emissions occur from mixing and as the adhesive dries. Essentially 

all of the remaining VOC in the organic solvent contained in the adhesives is emitted during the 

drying process. The VOC emissions from mixing of adhesives occur from displacement of 

VOC-laden air in containers used to mix adhesives containing solvents (thinners) prior to 

adhesive application. The displacement of VOC-laden air can also occur during filling of 

containers and can be caused by changes in temperature, changes in barometric pressure, or 

agitation during mixing. 
8 

The following discussion describes these primary emission sources (adhesives and 

cleaning materials). 

1. Adhesives 

The VOC emissions from adhesive application occur when solvent evaporates from the 

adhesive as it is being applied to the substrate. The transfer efficiency (the percent of adhesive 

solids deposited on the substrate) of an application method affects the amount of VOC emitted 

during application. The more efficient an application method is in transferring adhesives to the 

substrates, the lower the volume of adhesives (and therefore solvents) needed per given amount 

of production; thus resulting in lower VOC emissions. 

Conventional air atomized spray equipment utilizes high atomizing air pressure with 

typical transfer efficiencies of 25 to 40 percent. The transfer efficiency of a dip coater is very 

high (approximately 90 percent); however, some VOC is emitted from the liquid coating bath 

due to its large exposed surface area. For liquid adhesives, electrostatic spray coating is more 

efficient than conventional air atomized spray, with transfer efficiency typically ranging from 60 

to 90 percent. 

After adhesives are applied by any of the typical application methods, the adhesive is 

usually allowed a drying period. Immediately after application, a fraction of the solvents in the 

adhesives flash-off. The amount of VOC emissions from flash-off depends on the type of 

adhesive used, how quickly the substrate moves through the flash-off area, and the distance 

between the application area and the drying area. 

In spray application operations, the majority of VOC emissions occur in the spray booth. 

For liquid spray applications, it is estimated that 65-80 percent of the volatiles are emitted during 

the application and flash-off operations, and the remaining 20-35 percent from the drying/curing 

operation. 

The trend in controlling VOC emissions from solvent-borne adhesives is not to control 

through a specific control technology, but rather to replace them with low VOC adhesives, some 

of which can perform as well as solvent-borne adhesives. Since the late 1970’s, adhesive 

formulations that eliminate or reduce the amount of solvent in the formulations have been 

increasing, thus reducing VOC emissions per unit amount of adhesive used. 

Various types of low solvent adhesive include waterborne, hot-melt, solventless twocomponent, and radiation-cured adhesives. Hot-melt adhesives are the most widely used of these 

alternative processes. 

2. Cleaning Materials 

Cleaning materials are another source of VOC emitted by miscellaneous industrial 

adhesive application processes. The VOC are emitted when solvents evaporate from the 

cleaning materials during use. 

Cleaning materials with low-VOC composite vapor pressure and/or low-VOC content 

generate less VOC emissions than materials with higher VOC vapor pressure and/or content. 

The VOC composite vapor pressure of a cleaning material is a weighted average of the vapor 
9 

pressures of the VOC components of that cleaning material. The vapor pressure of each VOC 

component is weighted by the mole fraction of that VOC component in the whole cleaning 

material, including non-VOC components such as water or exempt compounds.2

 Water and 

exempt compounds thereby reduce the VOC composite vapor pressure of cleaning materials in 

which they are present. 

Although use of lower vapor pressure cleaning materials may reduce VOC emissions, 

these materials may not be feasible with the broad range of adhesives used in miscellaneous 

industrial adhesive application processes. Similarly, cleaning materials with low VOC content 

would generate less VOC emissions than materials with high VOC content, but may not be 

feasible with the broad range of adhesives used in miscellaneous industrial adhesive application 

processes. 

V. Available Controls and Regulatory Approaches

As previously mentioned, there are two main sources of VOC emissions from 

miscellaneous industrial adhesive application processes: (1) evaporation of VOC from the 

adhesives and adhesive primers; and (2) evaporation of VOC from the cleaning materials. This 

section summarizes the available control options for reducing these VOC emissions and existing 

State, and local VOC recommendations or requirements that address these emissions. 

A. Available Controls for VOC Emissions from Adhesives

There are two general emission control techniques for reducing VOC emissions from 

miscellaneous industrial adhesive application processes: pollution prevention measures, and 

emission capture and add-on control systems. Pollution prevention is the most prevalent control 

technique being used by facilities operating miscellaneous industrial adhesive application 

processes. Add-on control systems are available to industry, but few facilities utilize this control 

technique. Provided below is a summary of these control techniques. 

1. Pollution Prevention Measures 

Pollution prevention measures that are applicable to miscellaneous industrial adhesive 

application processes, including product substitution/reformulation, work practice procedures, 

and equipment substitution, may be used to decrease VOC emissions from adhesive application 

operations. Lower VOC content adhesives, higher solids adhesives and waterborne adhesives, 

may be used to reduce VOC emissions by reducing or eliminating the organic solvent present in 

the adhesive. Work practice procedures may also result in VOC emission reductions during the 

application process by reducing waste. The use of efficient application equipment can reduce 

VOC emission by increasing the adhesive transfer efficiency (i.e., the percentage of adhesive 

solids used that is deposited onto the substrate) and reducing the amount of adhesive used and 

wasted as overspray. 

 

2

 Exempt compounds are those classified by EPA as having negligible photochemical reactivity as listed in 40 CFR 

51.100(s). Exempt compounds are not considered to be VOC. 
10 

Product Substitution/Reformulation 

One pollution prevention measure is to substitute higher-solvent adhesives with adhesives 

containing little or no solvents. As previously discussed, these adhesives include waterborne 

adhesives, higher solids adhesives, and reactive adhesives. Manufacturers have developed and 

are continuing to develop waterborne and reactive formulations that replace conventional organic 

solvent-borne adhesives. These adhesives are generally available. Conversion to waterborne 

adhesives (for example) can lower VOC emissions greatly, and many miscellaneous industrial 

adhesive application processes are capable of converting to these adhesives. However, the 

currently available low-VOC adhesives or adhesives with no solvents do not meet the 

performance requirements of some industrial manufacturing applications and therefore are not 

viable options for these operations. 

Work Practices 

Work practice procedures are physical actions intended to affect emission reductions. 

Because work practice procedures are specifically tailored to an industry, they may vary from a 

few manual operations to a complex program. 

Waste is generated during adhesive material preparation, application, and equipment 

cleaning. If waste is reduced, overall VOC emissions from application processes will be reduced 

because less VOC adhesive material will be needed for production. Adhesive waste may be 

reduced by effectively controlling material preparation, maximizing the amount of adhesive 

transferred to the substrate through the use of application methods with higher transfer 

efficiencies and improved spray technique, and using proper equipment maintenance procedures. 

Equipment Substitution 

The use of the more effective application equipment also reduces VOC emissions. 

Conventional air atomized spray application systems utilize high atomizing air pressure with 

typical transfer efficiencies of 25 to 40 percent. 

More modern technologies, such electrostatic and HVLP spray equipment, can achieve 

much higher transfer efficiencies. The increase in transfer efficiency translates to a decrease in 

usage of materials containing VOC. 

In electrostatic spraying, the adhesive is charged and the substrate is grounded, thereby 

attracting the atomized adhesive to the substrate. Transfer efficiencies of up to 90 percent may 

be achieved depending on the product shape, size, and substrate. 

HVLP systems use reduced air pressure to atomize adhesives and the reduced air reduces 

turbulence at the part surface and increases transfer efficiency. HVLP spray systems can 

achieve transfer efficiencies of up to 65 percent under optimal conditions of part size and shape, 

and with good operator technique. 

2. Emission Capture and Add-on Control Systems 

In addition to pollution prevention measures, VOC emissions from miscellaneous 

industrial adhesive application processes can be reduced by the use of capture systems, in 
11 

conjunction with add-on control systems that either destroy or recover the VOC in the exhaust 

streams. As stated previously, although capture systems and add-on control devices are available 

to facilities operating miscellaneous industrial adhesive application processes, they are generally 

not used when low VOC adhesives and alternative application methods can be used to reduce 

VOC emissions. The majority of VOC emissions from miscellaneous industrial adhesive 

application processes occur in the spray booth. Spray booths typically exhaust a high volume of 

air to dilute the concentration of VOC for safety reasons to reduce potential worker exposure to 

solvent vapors and to reduce the flammability of the air-vapor mixture. Although VOC 

emissions in spray booth exhaust can be controlled with add-on controls, it is generally not cost 

effective to do so because of the large volume of air that must be treated and the low 

concentration of VOC. 

Capture Systems 

Capture systems, such as hoods and enclosures, collect solvent-laden air from process 

vents (e.g., spray booth vents) and/or fugitive emissions (e.g., flash-off area) and direct the 

captured air to a control device. The majority of VOC emissions from miscellaneous industrial 

adhesive application processes occur in the spray booth. These emissions can be ducted from the 

spray booth directly to the control device. In addition, hoods, floor air sweeps or enclosures can 

be used to collect fugitive emissions from solvents that evaporate in flash-off areas and route 

them to a control device. 

The design of the capture system can greatly contribute to the overall VOC control 

efficiency. An efficient capture system maximizes the capture of emissions and minimizes the 

capture of dilution air. Spray booth design and air management can reduce the volume of 

exhaust air and maximize the VOC concentration of the exhaust air which can reduce the cost of 

control. Facilities may combine several captured VOC-laden streams and duct them to a single 

control device Add-on Control Systems Add-on controls reduce the amount of VOC emissions by 

either destruction or recovery with or without recycling of VOC emission in the exhaust streams. 

Two categories of add-on control devices can be used by miscellaneous industrial adhesive 

application facilities: combustion (thermal or catalytic oxidation) and recovery (adsorption and 

absorption). While many control devices can be used to reduce VOC emissions, the following 

summary covers those control devices known to be used with adhesive application processes: 

oxidation, adsorption, and absorption. In addition, there are other control measures known to 

reduce VOC emissions, but are not currently being widely used in facilities operating 

miscellaneous industrial adhesive application processes. These alternative control technologies 

are also discussed below. 

Oxidation destroys VOC emissions in an exhaust stream by exposing the stream to an 

oxidizing atmosphere at high temperatures. Oxidizers may be of thermal or catalytic design and 

combust VOC-containing exhaust streams. Catalytic oxidizers are similar to thermal oxidizers 

but employ a catalyst to aid in the oxidation reaction. As a result, catalytic oxidizers operate at 

lower combustion temperatures relative to that required in thermal oxidizers. Both types of 

oxidizers generally utilize either regenerative or recuperative techniques to preheat inlet gas in 

order to decrease energy costs associated with high oxidation temperatures. They may also use 

primary or secondary heat recovery to reduce energy consumption. In general, oxidizers may 

achieve destruction efficiencies of greater than 95 percent as applied to adhesive application 

operations with high and constant concentrations of VOC. 
12 

Adsorption occurs when the unbalanced molecular forces on the surface of solids (the 

adsorbant) attract and retain gases and particulate matter that come in contact with the solid. 

Several materials are widely used as the adsorbent, such as activated carbon, organic resin 

polymer, and inorganic materials. Each has substantial surface area per unit volume. Carbon 

adsorbers are most commonly used in adhesive application processes. 

In a carbon adsorber, activated carbon is used as the adsorbent in a regenerable fixed bed. 

In a typical carbon adsorber, VOC-laden air is passed through a fixed bed of granular activated 

carbon. Adsorber beds are typically operated in parallel to avoid interruption of VOC control. 

In this arrangement, when the adsorption capacity of one bed is exhausted, it can be removed 

from service and a second adsorber bed can be put into service, ensuring that a control device is 

operating at all times. The spent carbon bed in the first adsorber bed is then regenerated and can 

be put into service again. 

Carbon adsorption systems can achieve control device efficiencies greater than 95 

percent. In contrast to combustion, carbon adsorption does not destroy the VOC it removes from 

the air stream. Carbon adsorbers used in miscellaneous industrial adhesive application processes 

are thermally regenerated, usually by passing steam through the carbon beds. The VOC are 

removed from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is 

then condensed, and the VOC solvent is separated from the water. The recovered solvent can 

then be decanted for sale or reuse. Regeneration can also be achieved with hot air. Hot-air 

regeneration can be quite attractive when dealing with water soluble solvents. Carbon adsorption 

is most amenable to coatings that use a single solvent; if solvent mixtures are collected by 

adsorbers, they usually are distilled for reuse. 

There are two options for disposing recovered solvents that cannot be reused. The first is 

to sell the material back to the solvent supplier or an independent firm that specializes in 

reclaiming contaminated solvents. The other option is to use the recovered solvent as a fuel in 

coating ovens or in boilers. However, many coating ovens and boilers are gas-fired and would 

require burner modifications to burn solvent. Carbon adsorption is generally economically 

attractive only if the recovered solvent can be reused directly. 

Carbon adsorbers are most suitable for solvents that are immiscible with water, such as 

toluene and xylene, but are not recommended for water-soluble VOC, such as methyl ethyl 

ketone and methyl isobutyl ketone. In the case where a water-soluble VOC is present, the water 

vapor will be adsorbed and desorbed along with the VOC vapor, and the VOC may require 

subsequent purification if it is to be reused. 

The presence of solid particles or polymerizable substances in the inlet air stream to a 

carbon adsorber may require pretreatment of the inlet air. In addition, adsorption is usually used 

for adhesive application exhaust streams at ambient temperature up to approximately 38°C 

(100°F). Therefore, cooling and dehumidification may also be required as pretreatment in some 

cases. Adding equipment, such as a dehumidification system, increases the costs associated with 

the use of a carbon adsorption system. 

Absorption is the process by which a gas stream is contacted with a liquid so that one or 

more of the components of the gas stream will dissolve in the liquid. Water is the most common 

absorbent, but organic solvents may also be used. Removal efficiency can be enhanced by the 
13 

addition of reactive chemical additives to the absorbent to increase solubility of the absorbed 

pollutant or change the equilibrium. 

Alternative control technologies, such as condensation, biodegradation, and UV oxidation 

are applicable for control of VOC emissions from adhesives. However, EPA is not aware of any 

miscellaneous industrial adhesive application facilities currently using these types of control 

technologies. 

B. Available Controls for VOC Emissions from Cleaning Materials

Pollution prevention is the most common emission control technique for reducing VOC 

emissions from cleaning materials. The pollution prevention measures applicable to 

miscellaneous industrial adhesive application processes include product substitution or 

reformulation, and work practice procedures. Cleaning materials with low or no VOC content or 

low-VOC composite vapor pressure may be used to reduce or eliminate VOC emissions from 

using these materials. Work practice procedures may also reduce VOC emission during cleaning 

operations by reducing the amount of VOC that can evaporate due to exposure to air. 

No add-on control technologies are being used specifically for reducing VOC emissions 

from cleaning operations associated with miscellaneous industrial adhesive application 

processes. However, if cleaning operations are performed within a capture system that is ducted 

to an add-on control system, such as a hood routed to a thermal oxidizer, the VOC emissions 

from the cleaning operations would be reduced by destruction in the thermal oxidizer. 

1. Product Substitution/Reformulation 

Reducing the composite VOC vapor pressure or VOC content of the cleaning material 

used, either by substitution or reformulation, is one pollution prevention measure that is used to 

reduce VOC emissions from cleaning operations. However, little information is available 

regarding the types of low-VOC or VOC-free cleaning materials that could be used in 

miscellaneous industrial adhesive application processes and whether they are feasible for the 

broad types of adhesives used. 

2. Work Practice Procedures 

Work practice procedures are commonly used in industry to reduce VOC emissions from 

cleaning operations. The following work practice procedures are used to reduce VOC emissions 

from miscellaneous industrial adhesive application processes: 

C Cover mixing and storage vessels for VOC-containing cleaning materials, and 

cleaning waste materials except when adding, removing, or mixing contents. 

C Use closed containers or pipes to store and convey VOC-containing cleaning and 

cleaning waste materials. 

C Minimize spills of VOC-containing cleaning and cleaning waste materials. 

C Minimize VOC emissions during cleaning operations. 
14 

C. Existing Federal, State, and Local Recommendations or Regulations

The following discussion is a summary of State and local regulations that address VOC 

emissions from miscellaneous industrial adhesive application processes. In addition, Appendices 

B and C summarize the State and local provisions for adhesive VOC content limits and 

application equipment requirements. There are no previous EPA actions that address 

miscellaneous industrial adhesives. 

1. Existing State and Local VOC Requirements 

In 1998, the California Air Resources Board (ARB) issued a guidance document that 

included ARB’s determination of Reasonably Available Control Technology (RACT) and Best 

Available Retrofit Control Technology (BARCT) for Adhesives and Sealants. This document 

presented RACT and BARCT for controlling VOC emissions from the commercial and industrial 

application of adhesives and sealants. The ARB RACT determination prescribes VOC emission 

limits for various industrial adhesives and sealants and was developed based on eight existing 

California air pollution control district rules for adhesives and sealants that were in effect in 

1998. Those eight districts included Bay Area Air Quality Management District (AQMD), El 

Dorado County Air Pollution Control District (APCD), Placer County APCD, Sacramento 

Metropolitan AQMD, South Coast AQMD, Ventura County APCD, Yolo-Solano AQMD, and 

San Diego County APCD. 

The ARB based the majority of its RACT determination on limits already in effect in 

South Coast AQMD, Bay Area AQMD, and Ventura County APCD, and concluded that the 

VOC limits for adhesives and sealants presented in its RACT determination were achievable and 

cost-effective. Furthermore, the ARB stated in its RACT determination that most of the adhesive 

and sealant products being sold in 1998 were already compliant with the VOC limits that were 

determined to be RACT. 

Since the development of the ARB RACT determination, 5 additional California air 

pollution control districts have adopted rules based on the ARB RACT standards. 

In 2007, the Ozone Transport Commission issued a Model Rule for Adhesives and 

Sealants. The Model Rule was based almost entirely on the 1998 CARB RACT determination. 

The Model Rule is for adoption by member states in 2009. To date, only Maryland has adopted 

an adhesives rule based on the OTC model rule. Maine and New Jersey are either currently 

considering adopting or are in the process of adopting the model rule. 

Some states regulate VOC emissions from adhesives as part of their regulations for 

specific surface coating operations. 

A total of 13 air pollution control districts in California have established rules specifically 

for adhesives. The various district adhesives rules do not all contain the same categories and 

limits as the ARB RACT guidance. Among these districts, the South Coast AQMD has 

generally adopted the most stringent VOC content limits for the adhesives categories included in 

SCAQMD Rule 1168 and in other districts with similar categories. If add-on controls are used, 

South Coast Rule 1168 requires that the control system capture at least 80 percent of the VOC 

emissions. 
15 

Several California air districts require the use of specific types of high-efficiency 

adhesive application methods to further reduce VOC emissions. For example, in addition to 

limiting the VOC contents in the adhesives, South Coast Rule 1168 requires the use of one of the 

following types of application equipment: electrostatic application; flow coating; dip coating; 

roll coating; hand application; high-volume, low-pressure (HVLP) spray; or an alternative 

method that is demonstrated to be capable of achieving a transfer efficiency equal to or better 

than HVLP spray. Alternative methods must be approved by the District based on actual transfer 

efficiency measurements in a side-by-side comparison of the alternative method and an HVLP 

spray gun. At least seven other District’s rules that regulate emissions from adhesives are similar 

to South Coast Rule 1168 in that they also require that sources use methods that achieve high 

transfer efficiency. 

At least eight Districts in California and Maryland regulate cleaning materials used in 

adhesive application processes. These regulations require a combination of work practice and 

equipment standards and limits on the VOC content, boiling point, or composite vapor pressure 

of the solvent. Some District rules allow the use of add-on controls as an alternative to the VOC 

content/boiling point/vapor pressure limits for cleaning materials. The work practice and 

equipment standards that have been adopted by California Districts include, for example, using 

closed containers for storing solvent and solvent containing wipes and rags, using enclosed and 

automated spray gun washing equipment, and prohibiting atomized spraying of solvent during 

spray gun cleaning. However, the cleaning material VOC content/boiling point/vapor pressure 

limits, overall control efficiency requirements, and work practices vary by District. 

VI. Recommended Control Options

Based on a review of the current State and local requirements discussed above, we are 

recommending various options, such as the use of low VOC content adhesives, specified 

application methods and control devices, for controlling the VOC emissions from the adhesives 

used by facilities operating miscellaneous industrial adhesive application processes. We are also 

recommending work practices to further reduce VOC emissions from adhesives as well as to 

minimize emissions from cleaning materials used in miscellaneous industrial adhesive 

application processes. 

To provide flexibility to facilities, we are recommending various options for controlling 

VOC emissions from miscellaneous industrial adhesives. We recommend specific VOC 

emission limits based on application processes (i.e., the types of adhesives and substrates). We 

recommend two options for achieving the recommended emission limits: (1) through the use of 

low-VOC content adhesives and specified application methods with good adhesive transfer 

efficiency; or (2) through the use of a combination of low-VOC adhesives, specified application 

methods, and add-on controls. As an alternative to the emission limits, we recommend an 

overall control efficiency of 85 percent. This alternative provides facilities the operational 

flexibility to use high efficiency add-on controls instead of low-VOC content adhesives and 

specified application methods, especially when the use of high VOC adhesives is necessary or 

desirable for product efficacy. We expect the 85 percent control efficiency recommendation to 

result in VOC emission reduction that is equivalent to or exceed the reduction from our 

recommended emission limits. Both the emission limits and the control efficiency 

recommendations reflect what we have concluded to be reasonably available VOC control 
16 

measures for miscellaneous industrial adhesives based on our review of Maryland’s adhesives 

rule, the OTC model rule, and the various California air district rules. 

As mentioned above, we are recommending the use of adhesive application methods with 

good adhesives transfer efficiency in conjunction with the use of low-VOC content adhesives. 

Specifically, we recommend the following application methods: electrostatic spray, HVLP spray, 

flow coat, roll coat, dip coat (including electrodeposition), airless spray, air-assisted airless 

spray, or other coating application method capable of achieving good transfer efficiency. 

We are recommending that the VOC emission limits and 85% control efficiency 

described above not be applied to the following types of adhesives and adhesives primer 

application processes: 

C Adhesives or adhesive primers being tested or evaluated in any research and 

development, quality assurance, or analytical laboratory. 

C Adhesives or adhesive primers used in the assembly, repair, or manufacture of 

aerospace or undersea-based weapon systems. 

C Adhesives or adhesive primers used in medical equipment manufacturing 

operations. 

C Cyanoacrylate adhesive application processes. 

C Aerosol adhesive and aerosol adhesive primer application processes.3

C Processes using polyester bonding putties to assemble fiberglass parts at fiberglass 

boat manufacturing facilities and at other reinforced plastic composite 

manufacturing facilities. 

C Processes using adhesives and adhesive primers that are supplied to the 

manufacturer in containers with a net volume of 16 ounces or less, or a net weight 

of one pound or less. 

We recommend, however, that the work practices recommended in this CTG be 

implemented to reduce VOC emissions during these types of adhesives and adhesives primer 

application processes. 

Our recommended emission limits are based on the OTC Model Rule for Adhesives and 

Sealants. As previously mentioned, the emission limits in the OTC rule were California ARB 

RACT standards, which were based on numerous California District rules and adopted by other 

California District rules. Furthermore, the OTC model rule is intended for adoption by States. 

In light of the above, we consider the limits in the OTC model rule to be representative of what 

sources in nonattainment areas nationwide can achieve technically and economically and have 

therefore adopted these VOC limits as our recommendations in the CTG. 

 

3

 Aerosol adhesives are regulated under EPA’s VOC Emission Standards for Consumer Products at 40 CFR 59

subpart C. Aerosol adhesive primers are regulated as “primers” under EPA’s VOC Emission Standards for Aerosol 

Coatings at 40 CFR 59 subpart E. 
17 

The recommended VOC emission limits can be met by averaging the VOC content of 

materials used on a single application unit for each day (i.e., daily within-application unit 

averaging). We do not recommend the use of cross-application unit averaging (i.e., averaging 

across multiple application units) to meet the VOC emission limits recommended in the CTG. 

However, we have previously provided guidance on cross-line averaging.4

 The guidance is 

directed to State and local agencies that elect to adopt a discretionary economic incentive 

program (EIP) and includes guidance on the use of cross-line averaging. 

For cleaning materials, we are recommending work practices for use with all three of the 

control options to reduce VOC emissions. We are not recommending the application of add-on 

controls in conjunction with these work practices for the same reasons stated above for adhesive 

application. The use of add-on controls to reduce emissions from cleaning operations at 

miscellaneous industrial adhesive application facilities would be a costly alternative because the 

area to be controlled is quite large and a large volume of air would be captured and directed to a 

control device. We are also not recommending the use of a VOC content or VOC composite 

vapor pressure limit for cleaning materials. We do not have information available regarding 

current VOC content or VOC composite vapor pressure usage to determine a RACT limit for 

cleaning materials used in miscellaneous industrial adhesive application processes. 

The following discussion summarizes our specific recommendations, including the 

recommended VOC emission limits, application methods, add-on controls, and work practices 

during miscellaneous industrial adhesive application and related cleaning processes. 

A. Adhesive and Adhesive Primer Emission Limits

We are recommending separate sets of emission limits for general adhesive application 

processes, specialty adhesive application processes, and adhesive primer application processes. 

Provided in Table 1 are the recommended emission limits expressed in terms of mass of VOC per 

volume of adhesive or adhesive primer (excluding water and exempt compounds, as applied). We 

are recommending that all VOC-containing materials used by each miscellaneous industrial 

adhesive application process be included when determining the emission rate of the application 

process. 

We also recommend that the VOC content of adhesives, other than reactive adhesives, 

used at facilities operating miscellaneous industrial adhesive application processes be determined 

using EPA Method 24. We recommend that the procedure for reactive adhesives in Appendix A 

of the NESHAP for surface coating of plastic parts (40 CFR part 63, subpart PPPP) be used to 

determine the VOC content of reactive adhesives. In addition, we recommend that 

manufacturer’s formulation data be accepted as an alternative to these methods. If there is a 

disagreement between manufacturer's formulation data and the results of a subsequent test, we 

recommend that States use the test method results unless the facility can make a demonstration to 

the States' satisfaction that the manufacturer's formulation data are correct. 

General adhesive application processes are those processes that are not specifically 

identified in Table 1 below as specialty adhesives application processes. Table 1 below includes 

 

4

 Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection Agency. 

Research Triangle Park, NC. EPA-452/R-01-001. January 2001. 
18 

recommended VOC emission limits for general adhesives application processes based on the 

substrates that are being bonded during these processes. For general adhesive application 

processes using an adhesive to bond dissimilar substrates, we recommend that the highest VOC 

emission limit apply. Appendix A contains definitions of each of the application processes 

identified in Table 1 below.

Table 1. Recommended VOC Emission Limits for General and Specialty Adhesive 

Application Processes 

Recommended VOC Emission Limit1,2

General Adhesive Application Processes (g/l) (lb/gal) 

Reinforced Plastic Composite 200 1.7 

Flexible vinyl 250 2.1 

Metal 30 0.3 

Porous Material (Except Wood) 120 1.0 

Rubber 250 2.1 

Wood 30 0.3 

Other Substrates 250 2.1 

Recommended VOC Emission Limit1

Specialty Adhesive Application Processes 

(g/l) (lb/gal) 

Ceramic Tile Installation 130 1.1 

Contact Adhesive 250 2.1 

Cove Base Installation 150 1.3 

Floor Covering Installation (Indoor) 150 1.3 

Floor Covering Installation (Outdoor) 250 2.1 

Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 660 5.5 

Metal to Urethane/Rubber Molding or Casting 850 7.1

Motor Vehicle Adhesive 250 2.1 

Motor Vehicle Weatherstrip Adhesive 750 6.3 

Multipurpose Construction 200 1.7 

Plastic Solvent Welding (ABS) 400 3.3 

Plastic Solvent Welding (Except ABS) 500 4.2 

Sheet Rubber Lining Installation 850 7.1 

Single-Ply Roof Membrane Installation/Repair (Except EPDM) 250 2.1 

Structural Glazing 100 0.8 

Thin Metal Laminating 780 6.5 

Tire Repair 100 0.8 

Waterproof Resorcinol Glue 170 1.4 

Recommended VOC Emission Limit1

Adhesive Primer Application Processes (g/l) (lb/gal) 

Motor Vehicle Glass Bonding Primer 900 7.5 

Plastic Solvent Welding Adhesive Primer 650 5.4 

Single-Ply Roof Membrane Adhesive Primer 250 2.1 

Other Adhesive Primer 250 2.1 

1

 Emission limits are mass of VOC per volume of adhesive or adhesive primer excluding water and exempt 

compounds, as applied. 

2

 If an adhesive is used to bond dissimilar substrates together, then the applicable substrate category with the 

highest VOC emission limit is recommended as the limit for such application. 
19 

B. Adhesive Application Methods

In addition to the VOC emission limits in Section A, we recommend that one of the 

following application methods be used in conjunction with using low-VOC adhesives or 

adhesive primers: 

C Electrostatic spray. 

C HVLP spray. 

C Flow coat. 

C Roll coat or hand application, including non-spray application methods similar to 

hand or mechanically powered caulking gun, brush, or direct hand application. 

C Dip coat (including electrodeposition). 

C Airless spray. 

C Air-assisted airless spray. 

C Other adhesive application method capable of achieving a transfer efficiency 

equivalent to or better than that achieved by HVLP spraying. 

C. Add-on Controls for Adhesive Application Operations

Should product performance requirements or other needs dictate the use of higher-VOC 

materials than those that would meet the recommended emission limits, a facility could choose to 

use add-on control equipment with an overall control efficiency of 85 percent. Alternatively, a 

facility could use a combination of adhesives and add-on control equipment on an application 

unit to meet the recommended mass of VOC per volume of adhesive or adhesive primer limits. 

Add-on devices include, for example, oxidizers, adsorbers, absorbers, and concentrators. Addon devices coupled with capture systems to collect the VOC being released at the affected facilities 

can achieve an overall control efficiency of 85 percent. This control option, like the options 

noted above, applies to all adhesives and adhesive primers applied in miscellaneous adhesive 

application processes. 

D. Work Practices for Adhesive-Related Activities

In addition to the control options above, this CTG recommends work practices to further 

reduce VOC emissions from miscellaneous industrial adhesive application-related activities. 

Although VOC reductions achieved by implementing the recommended work practices may not 

be quantifiable, they are beneficial to the overall goal of reducing VOC emissions. We 

recommend work practices for storage, mixing operations, and handling operations for 

adhesives, thinners, and adhesive-related waste materials. We recommend these practices for 

use with all three of the control options described above. 

Specifically, we recommend the following work practices: (1) store all VOC-containing 

adhesives, adhesive primers, and process-related waste materials in closed containers; (2) ensure 

that mixing and storage containers used for VOC-containing adhesives, adhesive primers, and 
20 

process-related waste materials are kept closed at all times except when depositing or removing 

these materials; (3) minimize spills of VOC-containing adhesives, adhesive primers, and 

process-related waste materials; and (4) convey VOC-containing adhesives, adhesive primers, 

and process-related waste materials from one location to another in closed containers or pipes. 

E. Work Practices for Cleaning Materials

This CTG recommends work practices to reduce VOC emissions from cleaning materials 

used in miscellaneous industrial adhesive application processes. These cleaning materials 

include both materials used to clean surfaces before adhesive or adhesive primer application 

(surface preparation) and to clean application equipment. Although VOC reductions achieved by 

implementing the recommended work practices may not be quantifiable, they are beneficial to 

the overall goal of reducing VOC emissions. We recommend work practices for storage, mixing 

operations, and handling operations for cleaning materials. We recommend these practices for 

use with all three of the control options described above 

Specifically, we recommend that, at a minimum, the work practices include the 

following: (1) store all VOC-containing cleaning materials and used shop towels in closed 

containers; (2) ensure that storage containers used for VOC-containing cleaning materials are 

kept closed at all times except when depositing or removing these materials; (3) minimize spills of 

VOC-containing cleaning materials; (4) convey VOC-containing cleaning materials from one 

location to another in closed containers or pipes; and (5) minimize VOC emission from cleaning 

of application, storage, mixing, and conveying equipment by ensuring that equipment cleaning is 

performed without atomizing the cleaning solvent and all spent solvent is captured in closed 

containers. 

VII. Cost Effectiveness of Recommended Control Options

We used the 2002 National Emissions Inventory (NEI) database to estimate the number 

of facilities operating miscellaneous industrial adhesive application processes. Based on the 

2002 NEI, we estimated that there are a total of 1,048 such facilities in the U.S. Using the 2004 

ozone nonattainment designations, we estimated that a total of 720 of these facilities are in ozone 

nonattainment areas. Based on the NEI VOC emissions data, 180 of the 720 facilities in ozone 

nonattainment areas emitted at or above the 6.8 kg/day (15 lb/day) recommended VOC 

emissions applicability threshold from miscellaneous industrial adhesive application processes. 

These 180 facilities emitted a total of about 4,428 Mg/yr of VOC (4,881 tpy), or an average of 

about 25 Mg/yr (27 tpy) of VOC per facility. 

As previously mentioned, we are recommending in this CTG the VOC limits in the OTC 

rule. We also mentioned earlier that the emission limits in the OTC rule were the California 

ARB RACT standards, which were based on eight California Districts’ adhesives rules 

(including the Ventura County APCD regulation) and have been adopted by other California 

Districts and Maryland. The ARB based its cost effectiveness estimate on an analysis performed 

by Ventura County APCD in 19934

 for a facility that manufactures commercial furniture. We 

therefore use the cost analyses by Ventura County APCD and the California ARB scaled to 2007 

dollars to estimate the cost effectiveness of our recommendations in this CTG. These cost 

estimates are relevant to this CTG’s recommended levels of control because they are based on 
21 

the use of similar control measures (i.e., product substitution/reformulation and work practices) for 

miscellaneous industrial adhesive application processes. 

In our analysis of the impacts of implementing the recommended levels of control in this 

CTG, we have assumed that all miscellaneous industrial adhesive application facilities will 

choose to utilize the low-VOC adhesive materials alternative. We made this assumption for two 

reasons. First, since facilities are meeting equivalent State and local limits, we believe that lowVOC adhesives that can meet the recommended control levels in this CTG are already available 

at a cost that is not significantly greater than the cost of adhesives with higher VOC contents. 

Secondly, the use of add-on controls to reduce emissions from typical adhesive application 

processes is a more costly alternative. 

According to the 1993 Ventura County APCD Rule 74.20 Staff Report and the 1998 

California ARB RACT determination, the annualized cost for a facility to convert to waterborne 

adhesives was estimated to be $2,300 (1993$). Using the producer price index for adhesive 

manufacturing and scaling the 1993 annualized cost to 2007, we estimate the annualized cost to 

be $3,356. We believe that this estimate also represents the cost of implementing this CTG’s 

recommended VOC limits because the Ventura County APCD regulation and the ARB RACT 

determination is based on similar control measures. We assume that facilities in California and 

Maryland are already implementing the recommended measures in this CTG. For the facilities 

we identified as emitting more than 6.8 kg/day (15 lb/day) in ozone nonattainment areas outside 

of California and Maryland, we estimate the total annual cost to be $603,997, based on the use of 

low-VOC content adhesives. We estimate that the recommendations in this CTG will reduce 

VOC emissions from miscellaneous industrial adhesives application processes by about 64 

percent. This is a reduction of 2,070 Mg/yr (2,281 tpy of VOC) from these facilities. Therefore, 

we estimate the cost effectiveness to be $292 per Mg ($265 per ton) of VOC emission reduction. 

We believe that the work practice recommendations in this CTG will result in a net cost 

savings. Implementing work practices reduces the amount of cleaning materials used by 

reducing the amount that evaporates and is wasted. Similarly, we also believe that the 

recommendation to use the specified adhesive application methods will also result in net cost 

savings. Increasing the transfer efficiency of adhesive application to reduce VOC emissions will 

also reduce adhesive consumption and costs. However, these cost savings cannot be accurately 

estimated. 

VIII. References

1. State of California Air Resources Board. Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Adhesives and Sealants. 

December 1998. 

2. Ozone Transport Commission. Model Rule for Adhesives and Sealants. Available at 

http://www.otcair.org/projects_details.asp?FID=99&fview=stationary# 

3. State of California Air Resources Board. Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology for Adhesives and Sealants. 

December 1998. 
22 

4. Ventura County Air Pollution Control District. Staff Report Rule 74.20, Adhesives and 

Sealants. June 8, 1993. 
Appendix A 

Definitions 
This page intentionally left blank 
A-1 

Definitions 

Acrylonitrile-butadiene-styrene or ABS welding means any process to weld 

acrylonitrile-butadiene-styrene pipe. 

Adhesive means any chemical substance that is applied for the purpose of bonding two 

surfaces together other than by mechanical means. 

Adhesive primer means any product intended by the manufacturer for application to a 

substrate, prior to the application of an adhesive, to provide a bonding surface. 

Aerosol adhesive or adhesive primer means an adhesive or adhesive primer packaged 

as an aerosol product in which the spray mechanism is permanently housed in a non-refillable 

can designed for handheld application without the need for ancillary hoses or spray equipment. 

Ceramic tile installation adhesive means any adhesive intended by the manufacturer for 

use in the installation of ceramic tiles. 

Chlorinated polyvinyl chloride plastic or CPVC plastic welding means a polymer of 

the vinyl chloride monomer that contains 67% chlorine and is normally identified with a CPVC 

marking. 

Chlorinated polyvinyl chloride welding or CPVC welding means an adhesive labeled 

for welding of chlorinated polyvinyl chloride plastic. 

Contact bond adhesive means an adhesive that: (i) is designed for application to both 

surfaces to be bonded together, and (ii) is allowed to dry before the two surfaces are placed in 

contact with each other, and (iii) forms an immediate bond that is impossible, or difficult, to 

reposition after both adhesive-coated surfaces are placed in contact with each other, and (iv) does 

not need sustained pressure or clamping of surfaces after the adhesive-coated surfaces have been 

brought together using sufficient momentary pressure to establish full contact between both 

surfaces. Contact adhesive does not include rubber cements that are primarily intended for use 

on paper substrates. Contact adhesive also does not include vulcanizing fluids that are designed 

and labeled for tire repair only. 

Cove base means a flooring trim unit, generally made of vinyl or rubber, having a 

concave radius on one edge and a convex radius on the opposite edge that is used in forming a 

junction between the bottom wall course and the floor or to form an inside corner. 

Cove base installation adhesive means any adhesive intended by the manufacturer to be 

used for the installation of cove base or wall base on a wall or vertical surface at floor level. 

Cyanoacrylate adhesive means any adhesive with a cyanoacrylate content of at least 95 

percent by weight. 
A-2 

EPDM roof membrane means a prefabricated single sheet of elastomeric material 

composed of ethylene propylenediene monomer and that is field applied to a building roof using 

one layer or membrane material. 

Flexible vinyl means non-rigid polyvinyl chloride plastic with at 5 percent by weight 

plasticizer content. 

Indoor floor covering installation adhesive means any adhesive intended by the 

manufacturer for use in the installation of wood flooring, carpet, resilient tile, vinyl tile, vinyl 

backed carpet, resilient sheet and roll or artificial grass. Adhesives used to install ceramic tile 

and perimeter bonded sheet flooring with vinyl backing onto a non-porous substrate, such as 

flexible vinyl, are excluded from this category. 

Laminate means a product made by bonding together two or more layers of material. 

Metal to urethane/rubber molding or casting adhesive means any adhesive intended 

by the manufacturer to bond metal to high density or elastomeric urethane or molded rubber 

materials, in heater molding or casting processes, to fabricate products such as rollers for 

computer printers or other paper handling equipment. 

Motor vehicle adhesive means an adhesive, including glass bonding adhesive, used at a 

facility that is not an automobile or light-duty truck assembly coating facility, applied for the 

purpose of bonding two vehicle surfaces together without regard to the substrates involved. 

Motor vehicle glass bonding primer means a primer, used at a facility that is not an 

automobile or light-duty truck assembly coating facility, applied to windshield or other glass, or 

to body openings, to prepare the glass or body opening for the application of glass bonding 

adhesives or the installation of adhesive bonded glass. Motor vehicle glass bonding primer 

includes glass bonding/cleaning primers that perform both functions (cleaning and priming of the 

windshield or other glass, or body openings) prior to the application of adhesive or the 

installation of adhesive bonded glass. 

Motor vehicle weatherstrip adhesive means an adhesive, used at a facility that is not an 

automobile or light-duty truck assembly coating facility, applied to weatherstripping materials 

for the purpose of bonding the weatherstrip material to the surface of the vehicle. 

Multipurpose construction adhesive means any adhesive intended by the manufacturer 

for use in the installation or repair of various construction materials, including but not limited to 

drywall, subfloor, panel, fiberglass reinforced plastic (FRP), ceiling tile and acoustical tile. 

Outdoor floor covering installation adhesive means any adhesive intended by the 

manufacturer for use in the installation of floor covering that is not in an enclosure and that is 

exposed to ambient weather conditions during normal use. 

Panel installation means the installation of plywood, pre-decorated hardboard (or 

tileboard), fiberglass reinforced plastic, and similar pre-decorated or non-decorated panels to 

studs or solid surfaces using an adhesive formulated for that purpose. 
A-3 

Perimeter bonded sheet flooring installation means the installation of sheet flooring 

with vinyl backing onto a nonporous substrate using an adhesive designed to be applied only to a 

strip of up to four inches wide around the perimeter of the sheet flooring. 

Plastic solvent welding adhesive means any adhesive intended by the manufacturer for 

use to dissolve the surface of plastic to form a bond between mating surfaces. 

Plastic solvent welding adhesive primer means any primer intended by the 

manufacturer for use to prepare plastic substrates prior to bonding or welding. 

Plastic foam means foam constructed of plastics. 

Plastics means synthetic materials chemically formed by the polymerization of organic 

(carbon-based) substances. Plastics are usually compounded with modifiers, extenders, and/or 

reinforcers and are capable of being molded, extruded, cast into various shapes and films, or 

drawn into filaments. 

Polyvinyl chloride plastic or PVC plastic means a polymer of the chlorinated vinyl 

monomer that contains 57% chlorine. 

Polyvinyl chloride welding adhesive or PVC welding adhesive means any adhesive 

intended by the manufacturer for use in the welding of PVC plastic pipe. 

Porous material means a substance that has tiny openings, often microscopic, in which 

fluids may be absorbed or discharged, including, but not limited to, paper and corrugated 

paperboard. For the purposes of this CTG, porous material does not include wood. 

Reinforced plastic composite means a composite material consisting of plastic 

reinforced with fibers. 

Rubber means any natural or manmade rubber substrate, including but not limited to, 

styrene-butadiene rubber, polychloroprene (neoprene), butyl rubber, nitrile rubber, 

chlorosulfonated polyethylene and ethylene propylene diene terpolymer. 

Sheet rubber lining installation means the process of applying sheet rubber liners by 

hand to metal or plastic substrates to protect the underlying substrate from corrosion or abrasion. 

These operations also include laminating sheet rubber to fabric by hand. 

Single-ply roof membrane means a prefabricated single sheet of rubber, normally 

ethylene-propylenediene terpolymer, that is field applied to a building roof using one layer of 

membrane material. For the purposes of this CTG, single-ply roof membrane does not include 

membranes prefabricated from ethylene-propylenediene monomer (EPDM). 

Single-ply roof membrane installation and repair adhesive means any adhesive 

labeled for use in the installation or repair of single-ply roof membrane. Installation includes, as 

a minimum, attaching the edge of the membrane to the edge of the roof and applying flashings to 

vents, pipes and ducts that protrude through the membrane. Repair includes gluing the edges of 
A-4 

torn membrane together, attaching a patch over a hole and reapplying flashings to vents, pipes or 

ducts installed through the membrane. 

Single-ply roof membrane adhesive primer means any primer labeled for use to clean 

and promote adhesion of the single-ply roof membrane seams or splices prior to bonding. 

Structural glazing means a process that includes the application of adhesive to bond 

glass, ceramic, metal, stone or composite panels to exterior building frames. 

Subfloor installation means the installation of subflooring material over floor joists, 

including the construction of any load bearing joists. Subflooring is covered by a finish surface 

material. 

Thin metal laminating adhesive means any adhesive intended by the manufacturer for 

use in bonding multiple layers of metal to metal or metal to plastic in the production of electronic 

or magnetic components in which the thickness of the bond line(s) is less than 0.25 millimeters. 

Tire repair means a process that includes expanding a hole, tear, fissure or blemish in a 

tire casing by grinding or gouging, applying adhesive and filling the hole or crevice with rubber. 

Waterproof resorcinol glue means a two-part resorcinol-resin-based adhesive designed 

for applications where the bond line must be resistant to conditions of continuous immersion in 

fresh or salt water. 
Appendix B 

Summary of State and Local Requirements for VOC Emissions from 

Adhesives and Adhesive Primers 
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B-1 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District Antelope Valley Bay Area El Dorado County Placer County Sacramento Metropolitan 

Rule Citation Rule 1168 Rule 8-51 Rule 236 Rule 235 Rule 460 R

General Adhesive Application Processes Fiberglass 200 200 200 200 Flexible vinyl 250 250 Flexible vinyl to other substrate 250 Metal 30 30 30 30 30 Other Substrates 250 250 250 Plastic Foams 120 120 120 120 Porous Material 120 120 Porous Material (e.g. wood, plastic foam, but not a plastic) 120 Porous Material (except wood and plastic foam) Porous Material (except wood) 120 120 Rubber 250 250 250 Wood 30 30 30 Specialty Adhesive Application Processes ABS Welding 400 400 350 400 400 Adhesive Primer for Plastic 250 250 Carpet Pad Installation 150 150 Cellulosic plastic welding (except ethyl cellulose)Ceramic Tile Installation 130 130 130 130 130 Computer Diskette Manufacturing 350 850 350 850 850 Contact Adhesive - General Contact Adhesive - Special Contact Adhesive - Specialty Substrate 250 Contact Adhesive 200 250 Cove Base Installation 150 150 150 150 150 CPVC Welding 270 490 250 490 490 Dry Wall and Panel Installation 200 200 Elastomeric Adhesive Floor covering installation (except ceramic tile) 
B-2 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District Antelope Valley Bay Area El Dorado County Placer County Sacramento Metropolitan 

Rule Citation Rule 1168 Rule 8-51 Rule 236 Rule 235 Rule 460 R

Floor covering installation Immersible Product Manufacturing 650 Indoor Carpet Adhesives Indoor Floor Covering Installation 150 150 150 Metal to Urethane/Rubber Molding or Casting Adhesive 250 250 Multipurpose Architectural (except cove base installation) Multipurpose Construction 200 200 200 

Nonmembrane Roof Installation/Repair 300 300 300 Non-Vinyl Backed Indoor Carpet Installation 150 150 

Other Plastic Cement Welding Adhesive 450 450 Other Plastic Welding 500 Outdoor Floor Covering Installation 350 250 250 Perimeter Bonded Sheet Vinyl Flooring Installation 660 660 Plastic Cement Welding 250 250 PVC Welding 285 510 250 510 510 Rubber Floor Installation 150 150 Rubber Vulcanization Bonding 850 Sheet rubber lining installation adhesive Single-Ply Roof Material Installation/Repair 250 Single-Ply Roof Membrane Installation/Repair Adhesive 250 250 Solvent welding adhesive Staple and Nail Manufacturing Structural Glazing 100 100 100 Structural Wood Member Adhesive Styrene-acrylonitrile welding adhesive Subfloor Installation 200 200 Thin Metal Laminating 780 250 780 
B-3 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District Antelope Valley Bay Area El Dorado County Placer County Sacramento Metropolitan 

Rule Citation Rule 1168 Rule 8-51 Rule 236 Rule 235 Rule 460 R

Tire Retread 100 100 100 Top and Trim Installation 540 Traffic Marking Tape Adhesive VCT and Asphalt Tile Installation 150 150 Waterproof Resorcinol Glue 170 170 170 Wood Flooring Installation 150 150 Adhesive Primer Application Processes Automotive Glass 700 700 700 Plastic Cement Welding 650 650 400 Single-Ply Roof Membrane 250 Traffic Marking Tape 150 150 150 Other 

Included 

Above 

250 

Included 

Above 

250 250 

Natural gas pipeline tape adhesive primer 
B-4 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District / State 

Santa 

Barbara 

County 

Shasta 

County South Coast Tehama County Ventura County Yo

Rule Citation Rule 353 Rule 3:32 Rule 1168 Rule 4:40 Rule 74.20 R

General Adhesive Application Processes Fiberglass 200 200 80 200 200 Flexible vinyl 250 250 250 250 Flexible vinyl to other substrate 250 250 250 Metal 30 30 30 30 30 Other Substrates 250 250 250 250 Plastic Foams 120 50 120 120 Porous Material 120 Porous Material (e.g. wood, plastic foam, but not a plastic) 120 120 Porous Material (except wood and plastic foam) 150 Porous Material (except wood) 50 Rubber 250 250 250 Wood 30 30 Specialty Adhesive Application Processes ABS Welding 400 400 325 400 400 Adhesive Primer for Plastic Carpet Pad Installation 50 Cellulosic plastic welding (except ethyl cellulose) 100 Ceramic Tile Installation 130 130 65 130 130 Computer Diskette Manufacturing 850 850 350 850 Contact Adhesive - General Contact Adhesive - Special 250 Contact Adhesive - Specialty Substrate 400 250 250 200 Contact Adhesive 250 250 80 250 200 Cove Base Installation 150 150 50 150 150 CPVC Welding 490 490 490 490 490 Dry Wall and Panel Installation 50 Elastomeric Adhesive 
B-5 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District / State 

Santa 

Barbara 

County 

Shasta 

County South Coast Tehama County Ventura County Yo

Rule Citation Rule 353 Rule 3:32 Rule 1168 Rule 4:40 Rule 74.20 R

Floor covering installation (except ceramic tile) 150 Floor covering installation Immersible Product Manufacturing Indoor Carpet Adhesives 50 Indoor Floor Covering Installation 150 150 150 Metal to Urethane/Rubber Molding or Casting Adhesive 850 250 250 Multipurpose Architectural (except cove base installation) 200 Multipurpose Construction 200 200 70 200 

Nonmembrane Roof Installation/Repair 300 300 300 300 Non-Vinyl Backed Indoor Carpet Installation 

Other Plastic Cement Welding Adhesive 510 450 450 Other Plastic Welding 500 Outdoor Floor Covering Installation 250 250 150 250 Perimeter Bonded Sheet Vinyl Flooring Installation 660 660 660 Plastic Cement Welding 250 PVC Welding 510 510 510 510 510 Rubber Floor Installation 60 Rubber Vulcanization Bonding Sheet rubber lining installation adhesive 850 850 Single-Ply Roof Material Installation/Repair Single-Ply Roof Membrane Installation/Repair Adhesive 250 250 250 250 250 Solvent welding adhesive Staple and Nail Manufacturing Structural Glazing 100 100 100 100 100 Structural Wood Member Adhesive 140 Styrene-acrylonitrile welding adhesive 100 Subfloor Installation 50 
B-6 

Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Ad

California District / State 

Santa 

Barbara 

County 

Shasta 

County South Coast Tehama County Ventura County Yo

Rule Citation Rule 353 Rule 3:32 Rule 1168 Rule 4:40 Rule 74.20 R

Thin Metal Laminating 780 780 780 Tire Retread 100 100 100 100 100 Top and Trim Installation 540 250 540 Traffic Marking Tape Adhesive 150 VCT and Asphalt Tile Installation 50 Waterproof Resorcinol Glue 170 170 170 Wood Flooring Installation 100 Adhesive Primer Application Processes Automotive Glass 700 700 700 700 Plastic Cement Welding 650 650 400 650 Single-Ply Roof Membrane 250 250 250 250 Traffic Marking Tape 150 150 150 Other 250 250 

Included 

Above 

250 250 

Natural gas pipeline tape adhesive primer 
Appendix C 

Summary of State and Local Requirements for Application Method and 

Control Efficiency 
This page intentionally left blank 
C-1 

Appendix C. Summary of State and Local Requirements for Application Method and Effic

California District Antelope Valley Bay Area El Dorado County Placer County Sacramento Metropolitan S

Rule Citation Rule 1168 Rule 8-51 Rule 236 Rule 235 Rule 460 R

Adhesive Application MethodAerosol Cans x x Air-Assisted Airless Spray x Air-Atomized (for contact adhesives) Airless Spray, Air-Assisted Airless Spray, AirAtomized Spray (for contact adhesives) x x Airless Spray, Air-Assisted Airless Spray, AirAtomized Spray (for viscosity 200 cp or grater) x Brush or Roll Coat x x x x Dip Coat x x x x Electrodeposition x x x Electrostatic Spray x x x x Flow Coat x x x x Hand Application x x x x HVLP Spray x x x x LVLP Spray x x x Other, Transfer Efficiency Minimum 65% x, none specified Add-On Control EfficiencyCapture Efficiency 90% by wt 90% by wt Control Efficiency 95% by wt 95% by wt Overall Efficiency 85% 85% Overall VOC Reduction Efficiency 80% by wt 
C-2 

Appendix C. Summary of State and Local Requirements for Application Method and Effic

California District / State 

Santa 

Barbara 

County 

Shasta 

County South Coast Tehama County Ventura County Yo

Rule Citation Rule 353 Rule 3:32 Rule 1168 Rule 4:40 Rule 74.20 R

Adhesive Application MethodAerosol Cans x x Air-Assisted Airless Spray Air-Atomized (for contact adhesives) Airless Spray, Air-Assisted Airless Spray, AirAtomized Spray (for contact adhesives) x x Airless Spray, Air-Assisted Airless Spray, AirAtomized Spray (for viscosity 200 cp or grater) x Brush or Roll Coat x x x Dip Coat x x x Electrodeposition x x Electrostatic Spray x x x Flow Coat x x x Hand Application x x x HVLP Spray x x x LVLP Spray x x Other, Transfer Efficiency Minimum x, none specified 65% x, none specified 

s

Add-On Control EfficiencyCapture Efficiency 90% by wt 90% by wt Control Efficiency 95% by wt 95% by wt Overall Efficiency 85% by wt 85% by wt Overall VOC Reduction Efficiency 80% 8
United States 

Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC 

Publication N