Control Techniques Guidelines for 

Metal Furniture Coatings 

EPA 453/R-07-005 

September 2007 

Control Techniques Guidelines for 

Metal Furniture Coatings 

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.............................................. 5 

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

1. Surface Preparation.................................................................................................. 6 

2. Coating Application................................................................................................. 6 

3. Cleaning activities ................................................................................................... 8 

B. Sources of VOC Emissions ......................................................................................... 9 

1. Coatings ................................................................................................................... 9

2. Cleaning Materials................................................................................................. 11 

V. Available Controls and Regulatory Approaches.................................................. 11 

A. Available Controls for VOC Emissions from Coatings ............................................ 11 

1. Pollution Prevention Measures.............................................................................. 12 

2. Emission Capture and Add-on Control Systems ................................................... 13 

B. Available Controls for VOC Emissions from Cleaning Materials ............................ 15 

1. Product Substitution/Reformulation ...................................................................... 16 

2. Work Practice Procedures...................................................................................... 16 

C. Existing Federal, State, and Local Recommendations or Regulations...................... 16 

1. The 1977 CTG ....................................................................................................... 16 

2. The 1982 NSPS...................................................................................................... 19 

3. The 2003 NESHAP................................................................................................ 19 

4. Existing State and Local VOC Requirements ....................................................... 21 

VI. Recommended Control Options............................................................................. 22 

A. Emission Limit Based on Low-VOC Coatings ......................................................... 23 

B. Optional Add-on Controls for Coating Operations ................................................... 24 

C. Work Practices for Coating-Related Activities ......................................................... 25 

D. Work Practices for Cleaning Materials...................................................................... 25 

VII. Cost Effectiveness of Recommended Control Options......................................... 25 

VIII. References................................................................................................................. 26 

Appendix A: 1977 CTG for Metal Furniture Coating 

Appendix B: Summary of State and Local Regulations for Metal Furniture Coating (not 

including California) 

Appendix C: Summary of California Air District Regulations for Metal Furniture Coating 
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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 (Sept. 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 (Mar. 18, 1999). Metal Furniture 

coatings 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 metal furniture 

coating. In developing this CTG, EPA, among other things, evaluated the sources of VOC 

emissions from the metal furniture coating industry 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 metal furniture coating. 

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

as to what constitutes RACT for VOCs for metal furniture coatings in their particular 

nonattainment areas. There are several hazardous air pollutants (HAPs) that are also VOCs. 

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 
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State rules that adopt different approaches for RACT for VOCs from metal furniture 

coatings, 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 metal furniture coatings. States 

subject only to the RACT requirements in CAA section 172(c)(1) may take action in 

response to this CTG, as necessary to achieve attainment of the national primary ambient air 

quality standards. 

II. Background and Overview

 There have been three federal actions that affect metal furniture surface coating 

operations. In December 1977, EPA issued a CTG document (1977 CTG) for controlling 

VOC emissions from surface coating of metal furniture.1

 In October 1982, EPA 

promulgated the new source performance standards (NSPS) for surface coating of metal 

furniture (1982 NSPS).2

 In May 2003, EPA promulgated the National Emission Standards 

for Hazardous Air Pollutants: Surface Coating of Metal Furniture (2003 NESHAP).3

 

 The 1977 CTG, the 1982 NSPS and the 2003 NESHAP provide a thorough 

discussion of the metal furniture coating industry, the nature of VOC emissions (or in the 

case of the 2003 NESHAP, volatile HAP emissions) from this industry, available control 

technologies for addressing such emissions, the costs of available control options, and other 

items. The 1977 CTG recommends and the 1982 NSPS establishes VOC emissions limits, 

whereas the 2003 NESHAP establishes organic HAP emissions limits and does not address 

non-HAP VOC. 

 At least 36 States and several local jurisdictions have specific regulations that 

control VOC emissions from metal furniture coating (or for metal parts and products coating 

in general). A discussion of the applicability and control options found in the federal 

actions and State and local rules is presented in Section V of this document. 

 

 EPA developed the recommended approaches contained in this document after 

reviewing the 1977 CTG, the 1982 NSPS, and the 2003 NESHAP and existing State and 

local VOC emission reduction approaches. 
3 

 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 metal furniture surface coating industry, including the types of metal 

furniture products, the coating materials and the coating 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 

Federal, State and local approaches for addressing such emissions. Section VI provides our 

recommendations for RACT for metal furniture coating. Section VII discusses the costeffectiveness of the recommended control approaches. Section VIII contains a list of 

references. 

III. Applicability

This CTG provides control recommendations for reducing VOC emissions stemming 

from the use of coatings in metal furniture surface coating operations. Coatings include 

paints, sealants, caulks, inks, adhesives, and maskants.a

 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 metal furniture surface coating unitb

 at a facility where 

the total actual VOC emissions from all metal furniture coating operations, 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 coatings, such as powder or 

UV cure coatings (these coatings 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 4 percent of the total reported VOC emissions from metal furniture surface coating 

facilities 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 

 

a

 Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, or 

any combination of these substances are not considered metal furniture coatings. b

 A coating unit consists of a series of one or more coating applicators and any associated drying area and/or 

oven wherein a coating is applied, dried, and/or cured. A coating unit ends at the point where the coating is 

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

unit to have an oven or flash-off area. 
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whether a facility meets our recommended applicability threshold, aggregate emissions, 

before consideration of control, from all metal furniture coating operations (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) and a questionnaire sent to industry by 

EPA during the development of the 2003 NESHAP development (data requested by EPA in 

1997 and 1998) were used as the source of emissions data and statistical information 

concerning the metal furniture surface coating industry as a whole. There were several 

discrepancies in the number of facilities reported in the 2002 NEI versus the 1997 and 1998 

NESHAP questionnaires. 

Results from the NESHAP questionnaires indicated that there were approximately 

3000 facilities that produce metal furniture parts or products. These facilities were located 

throughout the U.S., with the highest concentration of facilities in California, Michigan, 

New York, Florida, and Illinois.4

 Although information regarding HAP emissions was the 

main focus of the NESHAP questionnaires, information regarding VOC emissions was 

submitted from 22 of the 85 facilities surveyed. These facilities reported actual VOC 

emissions totaling approximately 1,300 tpy for 1997/1998. This total only accounts for 

VOC emissions generated by these metal furniture facilities from coatings. 

In developing this CTG, the 2002 NEI database was queried for VOC emissions 

generated by facilities that were listed under the following SIC codes: 2514, 2522, 2531, 

2542, 2599, 3429, 3469, 3495, 3645, 3646, 3821, and 3843 (the SIC used for the 2003 

NESHAP development). This query resulted in 456 facilities as compared to the 3,000 

facilities identified during the development of the 2003 NESHAP. The VOC emissions 

from the 456 metal furniture surface coating facilities in the 2002 NEI totaled approximately 

7,980 tpy. This total accounts for all of the VOC emissions generated by these facilities and 

does not specify the amount generated by just metal furniture coating operations. Of the 456 

facilities identified in the 2002 NEI, 289 facilities were located in ozone nonattainment areas 

and 143 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 143 facilities emitted 

approximately 3,400 tons of VOC in 2002. 

As stated above, the information presented in BID for the 2003 NESHAP indicated 

that there are about 3,000 metal furniture facilities in the United States. This information 

was based on 1997 Census data for the Standard Industrial Classification (SIC) codes that 

describe the metal furniture industry. In contrast, the 2002 Census data (obtained using the 

North American Industry Classification (NAICS) codes that correspond to the previously 
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used SIC codes) indicated that there are about 1,000 metal furniture facilities. We have 

found that the NAICS codes are in some cases very broad in their description of applicable 

products. As a result, some of the NAICS codes include parts and products that are beyond 

the scope of the metal furniture industry as defined in this document. Thus, the 2002 Census 

data for the number of facilities listed under these NAICS tend to overestimate the number 

of metal furniture surface coating facilities by including facilities that do not manufacture 

metal furniture parts or products. Therefore, we believe that the NEI data most accurately 

predict the total number of metal furniture facilities. 

IV. Process Description and Sources of VOC Emissions

The metal furniture coatings product category under section 183(e) of the CAA 

includes the coatings that are applied to the surfaces of metal furniture. A metal furniture 

substrate is the furniture or components of furniture constructed either entirely or partially 

from metal. Metal furniture includes, but is not limited to, the following types of products: 

household, office, institutional, laboratory, hospital, public building, restaurant, barber and 

beauty shop, and dental furniture, as well as components of these products. Metal furniture 

also includes office and store fixtures, partitions, shelving, lockers, lamps and lighting 

fixtures, and wastebaskets. Metal furniture coatings include paints and adhesives and are 

typically applied without a primer. Higher solids and powder coatings are used extensively 

in the metal furniture surface coating industry. Metal furniture coatings provide a covering, 

finish, or functional or protective layer, and can also provide a decorative finish to metal 

furniture. 

A. Process Description

Metal furniture coatings serve decorative, protective and functional purposes. 

Coatings protect the metal from corrosion by providing resistance to moisture, heat, and 

sometimes the outdoor elements. Coatings for each type of metal furniture have special 

requirements and contain unique properties because each type will be exposed to somewhat 

different corrosive elements. The coating must also be durable and have excellent adhesion 

properties to avoid peeling or chipping. Finally, the coatings for many products provide 

decorative appeal. 

 

The metal furniture manufacturing process may be divided into four main unit 

operations: (1) raw material preparation, (2) surface preparation, (3) coating and adhesive 

application operations, and (4) assembly. In addition, cleaning activities are performed in 

support of the surface coating operation. The majority of the raw material preparation 

operations and assembly operations are mechanical in nature and involve no VOC 

emissions. Surface preparation, coating application operations, and cleaning activities 

utilize VOC-containing compounds (i.e., coatings, thinners, and/or cleaning materials) and 

are further described below. 
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1. Surface Preparation 

Before a metal furniture component or product can be coated, its surface must be 

thoroughly cleaned. The cleaning operation consists of the following basic processing steps: 

(1) alkaline or acid cleaning, (2) water rinse, (3) phosphate treatment (typically iron 

phosphate), (4) water rinse, and (5) pretreatment and/or water rinse. The last step involves 

drying the parts in an oven. In general, the cleaning chemicals used in this cleaning 

operation contain little VOC and therefore generate negligible emissions. 

In the alkaline or acid cleaning step, metal furniture components or products are 

sprayed with, or immersed in, a cleaning solution to dissolve and remove oil, grease, and 

dirt. This solution, which can be alkaline or acidic, typically includes one or more other 

ingredients such as surfactants or corrosion inhibitors. Generally, acid-based solutions are 

preferred for removing corrosion and scale from metal pieces. However, because alkaline 

formulations are generally somewhat milder, they are recommended for certain metal 

substrates when the corrosivity of acid solutions is a concern. 

The cleaning step is followed by a phosphate treatment. The purpose of this 

treatment is to provide corrosion resistance to the surface of the metal part. The final 

pretreatment step, if utilized, may be a rust inhibitor or adhesion promoter. 

Following each treatment step, the metal furniture component or product is typically 

sent through several rinse stages in series. A counterflow rinsing system is commonly 

utilized. A counterflow rinsing system is a sequence of rinse steps in which replenished 

rinse water moves in the opposite direction of the component or product flow. The 

components or products being cleaned progress from dirtier to cleaner rinse water. The 

system maximizes water use by adding fresh water only at the final rinse step in the 

sequence. Thus, the metal furniture components or products are exposed to the cleanest 

rinse water just before proceeding to the next treatment step. 

An alternate cleaning method prior to coating is an enclosed shot-blasting operation. 

The operation uses steel shot (fine particles) to abrasively remove dirt and grease, as well as 

to smooth rough edges and welds. The operation can also be used to remove cured coatings 

when parts require rework. Although the steel shot is recycled back to the enclosure 

containing the metal furniture parts or components, a small amount of particulate matter 

emissions is generated by this operation. However, the cleaning operation does not involve 

any liquid chemicals, and no wastewater discharge is produced. 

2. Coating Application 

Surface coating is accomplished by applying a coating to the metal part, followed by 

curing or drying the coating. The coating itself may be in the form of a liquid or powder, 

and may be applied by spraying or dipping. 

There are several different types of applicators that may be used to apply coatings. 

The most common types of coating applicators include: air atomized spray coating, 
7 

electrostatic spray coating, high volume/low pressure (HVLP) spray coating, dip coating, 

flow coating, roll coating, electrocoating, and autophoretic coating.4

 

Spray coating is an application process where coatings are spray applied in a booth 

by manual or automatic means. In some instances, productivity is maximized by using 

automatic 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 metal furniture 

component or product, and through a dry filter bank. Waterwash booths are less commonly 

used in the metal furniture industry. In a waterwash booth, air is drawn through a 

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

addition, overspray hits the booth walls and is washed down by the water flow. In booths 

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

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

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

dry filters) generated by the coating application operation. 

In electrostatic spraying, the coating is charged and the part is grounded thereby 

attracting the atomized coating to the part. Nearly all metal furniture spray coatings are 

electrostatically applied. 

HVLP systems have improved nozzles which provide better air and fluid flow, and 

allows for gentler atomization of the air stream. These nozzles or atomizers shape the 

air/spray pattern and guide the atomized coating particles to the product being coated. 

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

used on parts that do not require a high-quality appearance, such as interior components of a 

filing cabinet. The metal furniture components or products to be coated are manually or 

automatically dipped into a tank containing the coating. The metal furniture components or 

products are then withdrawn from the tank and any excess coating is allowed to drain, thus 

achieving very high coating 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 viscosity of the fluid. Because the tank opening exposes a large 

surface area of liquid coating, solvent losses occur from the tank. To maintain the desired 

coating viscosity in the tank, these losses are compensated by adding thinner (water or 

solvent, depending on the coating used). 

Flow coating is similar to dip coating and involves conveying the metal furniture 

component or product over an enclosed sink, where the coating is applied at low pressure as 

the item passes under a series of nozzles. Excess coating drains back into the sink, is 

filtered, and pumped back into a coating holding tank. A typical flow coater tank is 

enclosed and is smaller than the equivalent dip coating tank. As a result, less coating is used 

and less solvent is evaporated than in dip tank operations. This application method results in 

an increase in production rate. 
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Roll coating application is used for high viscosity coatings, particularly adhesives, 

and for small surface areas. In most instances, the adhesive is activated by pressure, not 

heat. The adhesive is typically spray applied to both the substrate and laminate, and then the 

two parts are assembled. 

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

opposite electric charges are applied to the waterborne coating and the part. The coating is 

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

coating on the part than traditional dip application. 

Autophoretic coating consists of a series of dip tanks in which the parts to be coated 

are immersed and cleaned. After cleaning, the coating solids are deposited on the surface of 

the parts via chemical reaction. The coating solids are then heat cured. The only reported 

use of autophoretic coatings for metal furniture applications was a black coating, which 

effectively limits its use to parts hidden from view. 

Powder coatings are applied almost exclusively by means of electrostatic spray in the 

metal furniture surface coating industry. The electrostatic spray gun directs the flow of 

powder to the product. If a powder recovery system is used, the oversprayed powder is 

recovered and recycled. Powder coatings may also be applied using a dip application 

operation. The part to be coated is first heated to a temperature above the powder's melting 

point. The hot part is then immersed in a fluidized bed of the powder, melting the powder in 

contact with it and forming a continuous coating on the part. 

After each of the liquid and powder coating applications described above, the applied 

coating is heat dried or cured or air dried or cured after application, with the exception of 

adhesives which are activated by pressure. For liquid spray and dip coating operation, the 

coated parts are typically first slowly moved through a flash-off area after the coating 

application operation to allow solvents in the coating to evaporate slowly and thus avoid 

bubbling of the coating while it is curing in the oven. After application of powder coatings, 

the coated metal furniture components or products are conveyed directly to an oven (there is 

no flash-off area for powder coatings) and heated to cure the powder. This curing process 

melts the powder, forming a continuous coating. Following the curing step, the final unit is 

assembled (if necessary) and packaged for shipment. 

3. Cleaning activities 

Cleaning activities other than surface preparation also occur at metal furniture 

surface coating facilities. Cleaning materials are used during these activities to remove 

coating residue or other unwanted materials from equipment related to coating 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 VOCcontaining solvents. 
9 

B. Sources of VOC Emissions

Primarily, VOC emissions from metal furniture surface coating processes result from 

the evaporation of the volatile components of the coatings and cleaning materials.c

 In most 

cases, VOC emissions from surface preparation, storage, handling, and waste/wastewater 

operations are relatively small. The following discussion describes these primary emission 

sources (coatings and cleaning materials). 

1. Coatings 

 The primary VOC emissions from metal furniture coatings occur during coating 

application/flash-off and drying/curing of the coatings. The remaining emissions are 

primarily from mixing and/or thinning. The VOC emissions from mixing and thinning of 

coatings occur from displacement of VOC-laden air in containers used to mix coatings 

containing solvents (thinners) prior to coating 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. 

 The VOC emissions from coating application occur when solvent evaporates from 

the coating as it is being applied to the part. The transfer efficiency (the percent of coating 

applied to the metal furniture component or product) of a coating application method affects 

the amount of VOC emitted during coating application. The more efficient a coating 

application method is in transferring coatings to the metal furniture component or product, 

the lower the volume of coatings (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.4

 After being coated by any of the typical coating methods (e.g., spray coating or dip 

coating), the metal furniture components or products are dried/cured. Prior to entering the 

ovens, solvents in the coatings evaporate slowly in the flash-off area to prevent bubble 

formation during curing. The amount of VOC emissions from the flash-off area depends on 

the type of coating used, how quickly the component or product moves through the flash-off 

area, and the distance between the application area and the bake oven. 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. 

 For powder coatings, the curing/drying step melts the powder and forms a 

continuous coating on the metal furniture component or product. For liquid coatings, this 

 

c

 In a previous notice, EPA identified specific categories, including metal furniture surface coating, the 

cleaning operations of which would not be covered by EPA’s 2006 CTG for industrial cleaning solvents 

(71 FR 44522, 44540, October 5, 2006). In the notice, EPA expressed its intention to address cleaning 

operations associated with these categories in the CTGs for these specified categories if the Agency determines 

that a CTG is appropriate for the respective categories. 
10 

step removes any remaining volatiles from the coating. The cured coatings provide the 

desired decorative and/or protective characteristics. The VOC emissions during the 

curing/drying process result from the evaporation of the remaining solvents in the dryer. 

 Until the 1970’s, conventional solvent-based coatings, with high VOC content, were 

the majority of coatings used in the metal furniture industry. Due to increased regulation at 

the State and federal level, the industry has steadily moved to lower VOC content coatings. 

These alternative coatings include powder coatings, waterborne coatings, higher solids 

coatings, and ultraviolet coatings. The following discussion summarizes each of these 

alternative coating formulations. 

Powder Coatings. The use of powder coating systems in the metal furniture 

manufacturing industry has increased. Many metal furniture manufacturing facilities have 

replaced existing liquid coating operations with powder coating operations. Compared to 

conventional liquid coating systems, powder coating produces minimal amounts of VOC 

emissions because powder coatings are applied as dried particles, no VOC are released 

during the application operation, and volatile emissions from the curing operation, if any, 

are generally much less than the volatile emissions from liquid coating systems. Powder 

coating is applied via powder delivery systems, which in most cases is an electrostatic spray. 

Particulate emissions resulting from the application of powder coatings can be minimized 

through the implementation of a recovery and recycling process (reuse of overspray). 

Depending on the powder formulation, some volatile emissions may occur when the powder 

is heated during the curing step. Powder coating applications are best suited for long 

production runs of consistently sized parts without color changes. 

Waterborne Coatings. Waterborne coatings produce minimal VOC emissions 

primarily because a large portion of the solvent carrier is replaced with water. The water 

component can constitute as much as 80 percent of the coating, with the remaining 20 

percent being the coating solids. Waterborne coatings are used widely in other industries, 

most often when there is a primer applied to the substrate prior to the waterborne coating. 

The use of waterborne coatings is limited in the metal furniture manufacturing industry 

because they tend to corrode mild steel and some stainless steels, and the primer keeps the 

water from contacting the metal substrate. Because primers are used only rarely in the metal 

furniture industry, the use of waterborne coatings is more limited in this industry. 

Higher Solids Coatings. These coatings contain at least 60 percent by volume of 

coating solids. VOC emissions are reduced through the use of these coatings because they 

contain less solvent per unit volume of solids than conventional solvent-based coatings. 

Thus, a lesser amount of VOC emissions are released during coating preparation, 

application, and curing to deliver a given amount of coating solids. 

Ultraviolet Coatings. Ultraviolet (UV) curable liquid and UV curable powder 

coatings are used for heat sensitive substrates as they allow for low curing temperatures. 

UV liquid coatings have been used for several decades on parts made of wood, composite, 

and metal, but are not commonly used in the metal furniture industry. Because the entire 

coating must be exposed to the UV light source to achieve complete curing of the UV 
11 

coating, UV curable coating applications present problems in the metal furniture industry. 

Pigmentation used in the majority of metal furniture coatings blocks the UV light. The 

shape of the metal furniture also presents curing problems. Metal furniture products 

typically have bends or are box-shaped, creating areas which would be shaded from the UV 

light source. 

2. Cleaning Materials 

 Cleaning materials are another source of VOC emitted by metal furniture surface 

coating operations. 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 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.d

 Water and exempt compounds thereby reduce the VOC composite vapor 

pressure of cleaning materials in which they are present. Although use of lower pressure 

cleaning materials may reduce VOC emissions, little information is available regarding the 

use of cleaning materials with low VOC composite vapor pressure in the metal furniture 

surface coating industry. Similarly, cleaning materials with low VOC content would 

generate less VOC emissions than materials with high VOC content; however, little 

information is available regarding the use of cleaning materials with low VOC content in 

this industry. 

V. Available Controls and Regulatory Approaches

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

furniture surface coating operations: (1) evaporation of VOC from the coatings; and (2) 

evaporation of VOC from the cleaning materials. This section summarizes the available 

control options for reducing these VOC emissions and existing federal, State, and local VOC 

recommendations or requirements that address these emissions. 

A. Available Controls for VOC Emissions from Coatings

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

metal furniture coatings: pollution prevention measures, and emission capture and add-on 

control systems. Pollution prevention is the most prevalent control technique being used by 

the metal furniture surface coating industry. Add-on control systems are available to the 

 

d

 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. 
12 

industry, but few facilities utilize this control technique. Provided below is a summary of 

these control techniques. 

1. Pollution Prevention Measures 

 Pollution prevention measures applicable to the metal furniture manufacturing 

industry, including product substitution/reformulation, work practice procedures, and 

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

operations. Lower VOC content coatings, such as powder coatings, higher solids coatings 

and waterborne coatings, may be used to reduce VOC emissions by reducing or eliminating 

the organic solvent present in the coating. Work practice procedures may also result in 

VOC emission reductions during the coating process by reducing coating waste. The use of 

efficient coating application equipment can reduce VOC emission by increasing the coating 

transfer efficiency (i.e., the percentage of coating solids used that is deposited onto the 

substrate). 

Product substitution/Reformulation 

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

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

powder coatings, waterborne coatings, higher solids coatings, UV coatings, electrocoatings, 

and autophoretic coatings. The use of higher solids, powder and waterborne coatings has 

increased since 1977. Manufacturers have developed and are continuing to develop 

waterborne and powder coating formulations that replace conventional organic solventborne coatings. These coatings are generally available and often are not produced and 

marketed specifically for metal furniture surface coating. Conversion to powder coatings 

(for example) can lower VOC emissions greatly, and most metal furniture coating operations 

are capable of converting to these coatings. However, the currently available low-VOC 

coatings or coatings with no solvents do not meet the performance requirements of some 

metal furniture and therefore are not viable options for these products' production. 

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. 

 Coating waste is generated during coating material preparation, coating application, 

and equipment cleaning. If coating waste is reduced, overall VOC emissions from coating 

operations will be reduced because less VOC coating material will be needed for production. 

Coating waste may be reduced by effectively controlling material preparation, maximizing 

the amount of coating transferred to the part through the use of application methods with 

higher transfer efficiencies and proper form (spray technique), and using proper equipment 

maintenance procedures. 
13 

Equipment Substitution

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

Conventional air atomized application systems utilize high atomizing air pressure with 

typical transfer efficiencies of 25 to 40 percent. 

More modern technologies, such electrostatic and high volume/low pressure (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 coating is charged and the part is grounded thereby 

attracting the atomized coating to the part. Transfer efficiencies of up to 90 percent may be 

achieved depending on the product shape, size, and substrate. Nearly all metal furniture 

spray coatings are electrostatically applied. 

HVLP systems have improved nozzles which provide better air and fluid flow, and 

allows for gentler atomization of the air stream. These nozzles or atomizers shape the 

air/spray pattern and guide the atomized coating particles to the product being coated. 

2. Emission Capture and Add-on Control Systems 

 In addition to pollution prevention measures, VOC emissions from metal furniture 

surface coating application operations can be reduced by the use of capture systems, in 

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 the metal furniture surface coating industry, EPA is aware of only a few 

cases where this control technology is utilized by the industry.4

 The majority of VOC 

emissions from metal furniture coating operations occur in the spray booth. Spray booths 

typically exhaust a high volume of air with a low concentration of VOC which can result in 

a high cost of control. 

Capture Systems 

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

process vents (e.g., spray booth or bake oven 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 

metal furniture surface coating occur in the spray booth. These emissions can be ducted 

from the spray booth directly to the control device. Similarly, bake oven exhaust can be 

ducted directly to the control device. Spray booths and bake ovens are the principal 

elements of the capture system. In addition, hoods, floor 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 and bake oven design and air management can 
14 

reduce the volume of exhaust air and increase 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 are typically used by the metal furniture surface coating industry: 

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 surface coating operations: oxidation, 

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

VOC emissions, but are not currently being used in the metal furniture surface coating 

industry. 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 coating application operations with high and constant 

concentrations of VOC. 

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 the metal furniture surface coating industry. 

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

from the air stream. Carbon adsorbers used in metal furniture surface coating are thermally 

regenerated, usually by passing steam through the carbon beds.6

 The VOC are removed 

from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is then 
15 

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.6

 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.7

 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.6

 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 coating 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.5

 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 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 coatings. However, EPA is not 

aware of any metal furniture surface coating facilities currently using these types of control 

technologies.4

 

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 

the metal furniture industry include product substitution/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. 
16 

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

emissions from cleaning operations associated with metal furniture surface coating. 

However, if cleaning operations are performed within a capture system that is ducted to an 

add-on control system, such as a PTE 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 the metal furniture industry. 

2. Work Practice Procedures 

 Work practice procedures are commonly used in the metal furniture industry to 

reduce VOC emissions from cleaning operations. The following work practice procedures 

are used to reduce VOC emissions from metal furniture cleaning operations: 

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

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

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

cleaning waste materials; 

• Minimize spills of VOC-containing cleaning and cleaning waste materials; and 

• Minimize VOC emissions during cleaning operations. 

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

 The following discussion is a summary of three EPA actions, as well as State and 

local regulations, that address VOC emissions from metal furniture coating processes. 

Table 1 outlines these Federal, State and local provisions and the bases for these provisions. 

In addition, appendices B and C summarize the State and local provisions. 

1. The 1977 CTG 

 

 The 1977 CTG recommended limiting VOC emissions from each metal furniture 

coating unit. A coating unit consists of a series of one or more coating applicators and any 

associated drying area and/or oven wherein a coating is applied, dried, and/or cured. A 

coating unit ends at the point where the coating is dried or cured, or prior to any subsequent 

application of a different coating. It is not necessary for a coating unit to have an oven or a 

flash-off area. 

 For each coating unit, the 1977 CTG recommended a daily volume-weighted average 

limit of 0.36 kg/l (3.0 lb/gal) of coating, excluding water and exempt compounds, as applied. 
17 

Table 1. Summary of Existing Requirements 

Existing Regulation Emission Limit Basis for Emission Limit 

Metal Furniture Coating CTG 

(December 1977) 

Recommended VOC emission 

limit of 3.0 lb VOC/gal of 

coating, excluding water and 

exempt compounds, as applied 

(daily volume-weighted average) 

(narrow definition of coating 

unit) 

Calculated based on the use of 

higher solids coatings (59.2 

percent by volume solids) with an 

assumed VOC density of 7.36 

lb/gal. Associated with a baseline 

transfer efficiency of 60 percent 

Metal Furniture NSPS 

(October 29, 1982) 

VOC emission limit of 7.5 lb 

VOC/gal of coating solids 

deposited from any surface 

coating operation on a metal 

furniture surface coating line 

(monthly volume-weighted 

average) (narrow definition of 

coating operation) 

Based on the use of higher solids 

coatings (62 percent by volume 

solids) with an assumed VOC 

density of 7.36 lb/gal and a 

baseline transfer efficiency of 60 

percent. 

Metal Furniture NESHAP 

(May 23, 2003) 

Existing sources: HAP emission 

limit of 0.83 lb organic HAP/ gal 

coating solids used 

MACT level of control based on 

1997/1998 survey of coating 

materials used in the industry 

California – South Coast Rule 

1107 (Originally adopted June 1, 

1979 with last amendment 

January 6, 2006) 

VOC emissions limits for the 

coating of metal parts and 

products (which includes metal 

furniture coating) of: (1) 2.3 

pounds of VOC per gallon (0.275 

kilograms per liter) of coating, 

excluding water and exempt 

compounds, as applied for 

general one component coatings 

(air-dried and baked) and general 

multi-component baked coatings; 

and (2) 2.8 pounds of VOC per 

gallon (0.34 kilograms per liter) 

of coating, excluding water and 

exempt compounds, as applied 

for general multi-component airdried coating. Includes specific 

limits for specialty coatings such 

as extreme high gloss, high 

temperature, and metallic 

coatings. Electrostatic 

application, flow coat, dip coat, 

roll coat, HVLP spray, hand 

application methods, or other 

coating application method 

capable of achieving a transfer 

efficiency equivalent or better 

than that achieved by HVLP 

spraying required. 

Similar to the 1977 CTG but 

using a coating with 69 percent 

volume solids for general onecomponent (air-dried and baked) 

coatings and for general multicomponent baked coatings, 62 

percent volume solids for general 

multi-component air-dried 

coatings and a transfer efficiency 

of 65 percent 
18 

Table 1. Summary of Existing Requirements 

Existing Regulation Emission Limit Basis for Emission Limit 

California – South Coast Rule 

1107 (Continued) 

Exempts coatings and operations 

such as stencil coatings, safetyindicating coatings, touch-up 

coatings and application with 

hand-held aerosol cans. 

Alternative to the emissions limit 

and operating equipment 

requirement allows the use of 

capture and control equipment to 

collect at least 90 percent by 

weight of the VOC emissions 

generated by the sources of VOC 

emissions (capture efficiency) 

and reduce VOC emissions from 

an emission collection system by 

at least 95 percent by weight 

(control efficiency). 

California - Bay Area Regulation 

8, Rule 14 

(Originally adopted 

March 7, 1979 with last 

amendment October 16, 2002) 

Method of coating application 

must have a transfer efficiency of 

65% or greater and then a VOC 

emission limit for baked coatings 

of 2.3 lb/gal (0.275 kg/l) of 

coating, excluding water and 

exempt compounds, as applied 

and for air-dried coatings of 2.8 

lb/gal (0.34 kg/l) of coating, 

excluding water and exempt 

compounds, as applied. Includes 

specific limits for specialty 

coatings such as extreme high 

gloss, high temperature, and 

metallic coatings. 

Similar to the 1977 CTG but 

using a coating with 69 percent 

volume solids for baked coatings 

and 62 percent volume solids for 

air-dried coatings and a transfer 

efficiency of 65 percent 

State Regulations: 

36 State and local jurisdiction 

rules specifically for metal 

furniture coating operations were 

identified 

VOC emission limit of 3.0 lb 

VOC/gal of coating, excluding 

water and exempt compounds, as 

applied, or an overall emission 

reduction of 90 percent by 

utilization of an add-on control 

device 

1977 CTG 
19 

The emission limit was based on the use of low VOC content coatings and is approximately 

equivalent to the use of conventional high solvent content coatings in conjunction with an 

add-on control system with an overall control efficiency (taking into account capture and 

control) of 81 percent. At the time, it was believed that most metal furniture facilities would 

seek to meet future regulations through the use of low-VOC coatings rather than using addon control technologies. Cleaning materials were not addressed in the 1977 CTG. 

 Equivalent solid-based limits for metal furniture coating operations were presented 

in A Guideline for Surface Coating Calculations” (EPA-340/1-86-016).8

 For metal 

furniture surface coating operations, the 1977 CTG-equivalent limit was 0.60 kg/l 

(5.1 lb/gal) of solids. These equivalent limits were calculated using an assumed VOC 

density of 0.88 kg/l (7.36 lb/gal). This assumed VOC density is the same as that used in 

calculating the limits recommended in the 1977 CTG. 

2. The 1982 NSPS 

 The 1982 NSPS applies to metal furniture surface coating operations that 

commenced construction, modification, or reconstruction after November 28, 1980. The 

1982 NSPS defines surface coating operations in the rule to include prime coat and topcoat 

operations, and the standards apply to the coating application station, flash-off area, and 

curing oven. Any metal furniture surface coating operation that uses less than 3,842 l /yr 

coating (as applied) is required to keep records of coating usage but is exempt from the other 

NSPS provisions. The 1982 NSPS establishes a monthly volume-weighted average VOC 

limit of 0.90 kg VOC/l (7.5 lb VOC/gal) coating solids deposited. This limit was based on 

the use of coatings with around 62 volume percent solids, applied at 60 percent transfer 

efficiency, and using an assumed VOC density of 0.88 kg/l (7.36 lb/gal). 

 The 1982 NSPS applies to the same metal furniture surface coating operations as the 

1977 CTG: the coating application area, the flash-off area, and the curing oven. Because the 

1982 NSPS VOC emission limit is in terms of coating solids deposited and the 1977 CTGequivalent limit is in terms of coating solids used, it is difficult to directly compare the two 

limits. During the implementation of the 1977 CTG, a baseline of 60 percent (i.e. 0.60 gal 

of coating solids deposited per gal coating solids used) 8 was used to estimate an as-applied 

CTG-equivalent limit. By applying the 60-percent transfer efficiency to the 1977 CTGequivalent limit of 0.60 kg VOC/l (5.1 lb VOC/gal) solids used, the CTG-equivalent limit 

would be 1.01 kg VOC/l (8.4 lb VOC/gal) coating solids deposited. Based on this baseline 

transfer efficiency, the 1982 NSPS limit is more stringent than the 1977 CTG-equivalent 

limit when converted to a solids deposited basis. Cleaning materials were not addressed in 

the 1982 NSPS. 

3. The 2003 NESHAP 

 The 2003 NESHAP applies to “major” sources of HAP emissions, which are 

stationary sources that emit or have the potential to emit 10 tpy or more of any one HAP, or 

25 tpy or more of any combination of HAP. In contrast to the 1977 CTG and the 1982 
20 

NSPS, the 2003 NESHAP covers the collection of all of the following operations and 

equipment at a facility: 

• coating operations (which are defined to include equipment used for surface 

preparation, coating application, and equipment cleaning); 

• storage containers and mixing vessels in which coatings, thinners, and cleaning 

materials are stored or mixed; 

• manual and automated equipment and containers and pumps and piping used for 

conveying coatings, thinners, and cleaning materials; and 

• storage containers, pumps and piping, and manual and automated equipment and 

containers used for conveying waste materials generated by a coating operation. 

 The 2003 NESHAP imposes an organic HAP emission limitation of 0.10 kg organic 

HAP/l (0.83 lb organic HAP/gal) of coating solids used for sources in operation on or before 

April 24, 2002 (existing sources), and no organic HAP emissions are allowed for new 

sources (sources which started up after April 24, 2002). For purposes of determining 

compliance, the organic HAP emissions are the total emissions from coatings, thinners, and 

cleaning materials. 

 Compliance with the 2003 NESHAP can be demonstrated by any of three methods: 

(1) compliant coatings option, where all coatings used have organic HAP contents that 

individually meet the organic HAP emission limit, and all thinners and cleaning materials 

contain no organic HAP; (2) emission rate without add-on controls option, where the 

monthly average organic HAP emission rate is equal to or less than the organic HAP 

emission limit; or (3) emission rate with add-on controls option, where the monthly 

emission rate, taking into account the emission reduction achieved through the use of one or 

more control devices, is equal to or less than the organic HAP emission limit. 

 If a facility is demonstrating compliance by using the emission rate with add-on 

controls option, the 2003 NESHAP requires the facility to develop a work practice plan to 

minimize organic HAP emissions from the storage, mixing, and conveying of coatings, 

thinners and cleaning materials used in the coating operations, as well as organic HAP 

emissions from waste materials generated by such operations. At a minimum, the work 

practice plan must include the following elements: 

• All organic-HAP-containing coatings, thinners, cleaning materials, and waste 

materials must be stored in closed containers. Ensure that these containers are kept 

closed at all times except when depositing or removing these materials from the 

containers. 

• Spills of organic-HAP-containing coatings, thinners, cleaning materials, and waste 

materials must be minimized. 

• Organic-HAP-containing coatings, thinners, cleaning materials, and waste materials 

must be conveyed from one location to another in closed containers or pipes. 

• Mixing vessels which contain organic-HAP-containing coatings and other materials 

must be closed except when adding to, removing, or mixing the contents. 
21 

• Emissions of organic HAP must be minimized during cleaning of storage, mixing, 

and conveying equipment. 

4. Existing State and Local VOC Requirements 

In addition to the EPA actions described above, at least 36 States and local 

jurisdictions have regulations that control VOC emissions from metal furniture coating (or 

for metal parts and products coating in general). The vast majority of these States (32 

States) have incorporated the 1977 CTG VOC emissions limit of 0.36 kg VOC/l (3.0 lb 

VOC/gal) of coating applied (minus water). Two States incorporated the CTG-equivalent 

limit of 0.60 kg VOC/l solids used. Appendix B summarizes the applicable rules for all 

States except California. The applicable rules for all of the California Districts are 

summarized in Appendix C. Generally, compliance with the State and local jurisdiction 

emission limits can be achieved using coatings that meet the VOC emission limits or by the 

installation of a capture and add-on control system. Some states specify the use of 

incinerators and/or carbon adsorbers. 

The California South Coast Air Quality Management District (South Coast) has 

adopted limits for metal furniture coating that are more stringent than the 1977 CTG 

recommendation. The VOC emission limits established by the South Coast for the surface 

coatings of metal parts and products (which includes metal furniture coating) are: (1) 275 

grams VOC per liter (g VOC/l) (2.3 lb VOC/gal) of coating, excluding water and exempt 

compounds, as applied for general one-component coatings (air-dried and baked) and 

general multi-component baked coatings; and (2) 340 g VOC/l (2.8 lb VOC/gal) of coating, 

excluding water and exempt compounds, as applied for general multi-component air-dried 

coatings. The South Coast Regulation also includes specific limits for specialty coatings, 

such as extreme high gloss, high temperature, and metallic coatings. The South Coast 

regulation specifies the use of the following application methods: electrostatic application, 

flow coat, dip coat, roll coat, HVLP spray, hand application methods, or other coating 

application method capable of achieving a transfer efficiency equivalent or better than that 

achieved by HVLP spraying. Coatings and operations such as stencil coatings, safetyindicating coatings, touch-up coatings and application with hand-held aerosol cans are 

exempt from the South Coast regulations. As an alternative to the emissions limit and 

operating equipment requirement, the South Coast regulation allows the use of capture and 

control equipment to collect at least 90 percent by weight of the VOC emissions generated 

by the sources of VOC emissions (capture efficiency) and to reduce VOC emissions from an 

emission collection system by at least 95 percent by weight (control efficiency). 

The California Bay Area Air Quality Management District (Bay Area) has also 

adopted limits for metal furniture coating that are more stringent than the 1977 CTG 

recommendation: (1) 275 g VOC/l (2.3 lb VOC/gal) of coating, excluding water and exempt 

compounds, as applied, for baked coatings; and (2) 340 g VOC/l (2.8 lb/gal) of coating, 

excluding water and exempt compounds, as applied, for air-dried coating. Like the South 

Coast regulations, the Bay Area regulations include specific limits for specialty coatings and 

exemptions for some coatings and coating operations. In addition, the Bay Area rule 

requires the use of coating application equipment that can meet a 65 percent or greater 
22 

transfer efficiency. Per the Bay Area regulation, compliance with the standard's 65 percent 

of greater transfer efficiency can be achieved by properly operated electrostatic application 

or HVLP spray, flow coat, roller coat, dip coat including electrodeposition, and brush coat. 

Several jurisdictions in California have requirements to regulate the VOC emissions 

from cleaning materials used in the metal furniture surface coating industry. These 

regulations are aimed at reducing VOC emissions from cleaning materials by combining 

work practice standards with limits on the VOC content or composite vapor pressure of the 

solvent being used. In some cases, the jurisdictions allow the use of add-on controls as an 

alternative to the VOC content/vapor pressure limits. The different air pollution control 

authorities in California have established similar work practice standards. However, the 

cleaning material VOC content/vapor pressure limits vary by jurisdiction, as do the overall 

control efficiency required when add-on controls are used as an alternative. 

There are ten States that have cleaning material regulations that apply to metal 

furniture surface coating operations. Of these, nine States do not limit the VOC 

content/vapor pressure of cleaning materials. Instead, they have established equipment 

standards, work practices, and/or recordkeeping requirements. There is one State that 

requires work practices as well as limiting the vapor pressure of the cleaning materials. 

VI. Recommended Control Options

Based on a review of the 1977 CTG, the 1982 NSPS, the 2003 NESHAP, and the 

current State and local requirements discussed above, we are recommending emission limits 

for controlling the VOC emissions from the coatings used by metal furniture manufacturing 

facilities and work practices to further reduce VOC emissions from coatings as well as to 

minimize emissions from cleaning materials used in metal furniture surface coating 

processes. 

To control VOC emissions from metal furniture surface coatings, we are 

recommending three alternatives: (1) emission limits that can be achieved through the use of 

low-VOC coatings; (2) equivalent emission limits that can be achieved through the use of 

low-VOC coatings or a combination of coatings and add-on controls; and (3) an overall 

control efficiency of 90 percent for add-on controls. The low-VOC coatings 

recommendation consists of emission limits in terms of mass of VOC per volume of coating, 

excluding water and exempt compounds, as applied and the use of specified application 

methods. The equivalent emission limit recommendation consists of emission limits in 

terms of mass of VOC per volume of coating solids, as applied, and the use of specific 

application methods. 

We estimate that these recommendations will reduce VOC emissions from metal 

furniture coating by about 35 percent (a reduction of 1,200 tpy of VOC) from the 

nonattainment area facilities above the recommended 6.8 kg/day (15 lb/day) threshold. In 

our analysis of the impacts of the recommended level of control, we have assumed that all 

facilities will choose to utilize the low-VOC coating materials alternative. We made this 

assumption for two reasons. First, we believe that complying low-VOC coating materials 
23 

are already widely available at a cost that is not significantly greater than the cost of coating 

materials with higher VOC contents. Secondly, the use of add-on controls to reduce 

emissions from typical spray coating operations would be a more costly alternative. 

For cleaning materials, we are recommending work practices 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 coating application, the use of 

add-on controls to reduce emissions from cleaning operations at metal furniture surface 

coating 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. However, as 

mentioned previously, any cleaning activities that occur within a capture system would be 

controlled by the associated control device. Furthermore, 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 metal furniture surface coating 

operations. Therefore, we are not recommending the use of a VOC content or VOC 

composite vapor pressure limit for cleaning materials 

The following discussion summarizes our specific recommendations for coating 

operations and cleaning materials used in metal furniture surface coating operations. 

A. Emission Limit Based on Low-VOC Coatings

 We are recommending emission limits for one-component and multi-component 

general purpose coatings. In addition, we are recommending specific emission limits for 

certain specialty coatings. For each of these coating types, we are recommending separate 

emission limits for baked and air-dried coatings. Provided below are our recommended 

emission limits expressed in terms of mass of VOC per volume of coating (excluding water 

and exempt compounds, as applied): 

Baked Air Dried Coating Type kg/l lb/gal kg/l lb/gal 

General, One Component 0.275 2.3 0.275 2.3 

General, Multi-Component 0.275 2.3 0.340 2.8 

Extreme High Gloss 0.360 3.0 0.340 2.8 

Extreme Performance 0.360 3.0 0.420 3.5 

Heat Resistant 0.360 3.0 0.420 3.5 

Metallic 0.420 3.5 0.420 3.5 

Pretreatment Coatings 0.420 3.5 0.420 3.5 

Solar Absorbent 0.360 3.0 0.420 3.5 

 

 The recommended emission limits can also be expressed in terms of mass of VOC 

per volume of coating solids, as applied. A facility could use low-VOC coatings or a 

combination of coatings and add-on control equipment on a coating unit to meet the 

recommended mass of VOC per volume of coating solids limits. Using an assumed VOC 

density of 7.36 pounds per gallon, the equivalent limits in terms of mass of VOC per volume 

of solids, as applied, are as follows: 
24 

Baked Air Dried Coating Type kg/l lb/gal kg/l lb/gal 

General, One Component 0.40 3.3 0.40 3.3 

General, Multi-Component 0.40 3.3 0.55 4.5 

Extreme High Gloss 0.61 5.1 0.55 4.5 

Extreme Performance 0.61 5.1 0.80 6.7 

Heat Resistant 0.61 5.1 0.80 6.7 

Metallic 0.80 6.7 0.80 6.7 

Pretreatment Coatings 0.80 6.7 0.80 6.7 

Solar Absorbent 0.61 5.1 0.80 6.7 

We are also recommending that the following types of coatings and coating 

operations be exempt from our recommended VOC content limits: 

• Stencil coatings 

• Safety-indicating coatings 

• Solid-film lubricants 

• Electric-insulating and thermal-conducting coatings 

• Touch-up and repair coatings 

• Coating application utilizing hand-held aerosol cans 

We are recommending that all VOC-containing materials (i.e., coatings and thinners) 

used by each metal furniture surface coating unit are included when determining the coating 

unit's emission rate. In addition, we are recommending the use of one or more of the 

following application methods: electrostatic application, HVLP spray, flow coat, roller coat, 

dip coat including electrodeposition, or other coating application method capable of 

achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying. 

The recommendations described above are based on the South Coast's metal parts and 

products coating regulation, which includes metal furniture. 

The VOC content limits can be met by averaging the VOC content of materials used 

on a single surface coating unit each day (i.e., daily within-coating unit averaging). We do 

not recommend the use of cross-coating unit averaging (i.e., averaging across multiple 

coating units) to meet the VOC content limits. However, we have previously provided 

guidance on cross-line averaging.9

 The guidance is directed to State and local agencies that 

elect to adopt a discretionary economic incentive programs (EIP) and includes guidance on 

the use of cross-line averaging.

B. Optional Add-on Controls for Coating Operations

Should product performance requirements or other needs dictate the use of higherVOC 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 90 

percent. Alternatively, a facility could use a combination of coatings and add-on control 

equipment on a coating unit to meet the recommended mass of VOC per volume of coating 
25 

solids limits. Add-on devices include oxidizers and solvent recovery systems, which 

coupled with capture systems to collect the VOC being released at the affected facilities, can 

achieve an overall control efficiency of 90 percent. This control option, like the options 

noted above, applies to all coatings and thinners applied to metal furniture components or 

products. 

C. Work Practices for Coating-Related Activities

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

further reduce VOC emissions from metal furniture surface coating-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 

coatings, thinners, and coating-related waste materials. Specifically, we recommend the 

following work practices: (1) store all VOC-containing coatings, thinners, and coatingrelated waste materials in closed containers; (2) ensure that mixing and storage containers 

used for VOC-containing coatings, thinners, and coating-related waste materials are kept 

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

of VOC-containing coatings, thinners, and coating-related waste materials; and (4) convey 

VOC-containing coatings, thinners, and coating-related waste materials from one location to 

another in closed containers or pipes. 

D. Work Practices for Cleaning Materials

This CTG recommends work practices to reduce VOC emissions from cleaning 

materials used in metal furniture surface coating operations. 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. 

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

cleaning materials and used shop towels in closed containers; (2) ensure that mixing and 

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 

storage, mixing, and conveying equipment. 

VII. Cost Effectiveness of Recommended Control Options 

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

number of metal furniture manufacturing facilities. Based on the 2002 NEI, we estimated 

that there are a total of 456 metal furniture facilities in the U.S. Using the 2004 ozone 

nonattainment designations, we estimated that a total of 289 of these facilities are in ozone 

nonattainment areas. Based on the NEI VOC emissions data, 143 of the 289 facilities in 

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

VOC emissions applicability threshold. These 143 facilities emitted a total of about 3,100 
26 

Mg of VOC per year (Mg/yr) (3,400 tons per year (tpy)), or an average of about 21 Mg/yr 

(23 tpy) of VOC per facility. 

 

As previously mentioned, the recommendations in this CTG are similar to the South 

Coast regulations governing metal furniture surface coating operations. The cost 

effectiveness related to the implementation of these regulations was not estimated during 

their development. Therefore, cost-effectiveness estimates for the recommended control 

levels were determined using the approach used during the 2003 NESHAP development. 

Although the 2003 NESHAP regulates organic HAP, the 2003 NESHAP cost estimates are 

relevant to this CTG’s recommended levels of control because they are based on the use of 

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

metal furniture coatings and cleaning materials as those recommended in this CTG. 

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

this CTG, we have assumed that all metal furniture surface coating facilities will choose to 

utilize the low-VOC coating materials alternative. We made this assumption for two 

reasons. First, we believe that low-VOC coating materials that can meet the levels of 

control recommended in this CTG are already widely available at a cost that is not 

significantly greater than the cost of coating materials with higher VOC contents. Secondly, 

the use of add-on controls to reduce emissions from typical spray coating operations is a 

more costly alternative. 

 According to studies performed for the development of the 2003 NESHAP, the cost 

averaged across all sizes of facilities, was as high as $1,670 per facility.4

 We believe that 

this estimate also represents the cost of implementing this CTG’s recommended VOC limits 

because the NESHAP is based on similar control measures. For the 143 facilities we 

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

therefore estimate the total annual cost to be $240,500. We estimate that the 

recommendations in this CTG will reduce VOC emissions from metal furniture coating by 

about 35 percent. This is a reduction of 1,100 Mg/yr (1,200 tpy of VOC) from the 143 

facilities. Therefore, we estimate the cost effectiveness to be about $220 per Mg ($200 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 cleaning materials used by 

reducing the amount that evaporates and is wasted. 

VIII. References

1. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume 

III: Surface Coating of Metal Furniture. Publication No. EPA-450/2-77-032. U. S. 

Environmental Protection Agency, Research Triangle Park, NC. December 1977. 

The 1977 CTG is included as Appendix A to this CTG. 

2. U.S. Environmental Protection Agency. Standards of Performance for Surface 

Coating of Metal Furniture. 40 CFR part 60, subpart EE. October 29, 1982. 
27 

3. U.S. Environmental Protection Agency. National Emission Standards for Hazardous 

Air Pollutants: Metal Furniture Surface Coating. 40 CFR part 63, subpart RRRR. 

May 23, 2003. 

 

4. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source 

Category: Metal Furniture Surface Coating – Background Information for 

Proposed Standards. Publication No. EPA-453/R-01-010. U.S. Environmental 

Protection Agency, Research Triangle Park, NC. October 2001. 

5. Handbook: Control Technologies for Hazardous Air Pollutants. EPA-625/6-91-014, 

U.S. Environmental Protection Agency, Cincinnati, Ohio. June 1991. 

6. Pressure Sensitive Tape and Label Surface Coating Industry--Background 

Information for Proposed Standards. EPA-450/3-80-003a, U.S. Environmental 

Protection Agency, Research Triangle Park, North Carolina. September 1980. pp. 3-

14 to 3-15. 

7. Compilation of Air Pollutant Emission Factors (AP-42), Volume I (Fifth Edition). 

U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. 

January 1995. p. 4.2.2.6-3. 

8. A Guideline for Surface Coating Calculations. U.S. Environmental Protection 

Agency, Washington, D.C. Publication No. EPA-340/1-86-016. July 1986. 

9. Improving Air Quality with Economic Incentive Programs. U.S. Environmental 

Protection Agency. Research Triangle Park, NC. EPA-452/R-01-001. January 

2001.
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Appendix A 

1977 CTG for Metal Furniture Coating 
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A-1 
A-2 

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Appendix B 

Summary of State and Local Regulations for Metal Furniture 

Coating (not including California) 
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Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-1 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Alabama (Jefferson County) 

Metal furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

(excluding water) 

For sources located in Jefferson County: 

1. use low solvent coating technology; or 2. a capture and control system that have an 

overall VOC emission reduction that meet the applicable emission limit each day; or 

3. use powder coating technology; or 4. average two or more coatings on a coating line 

that has no add-on VOC control equipment if: 

a. The coating is the same type of operation 

(source category) and is subject to the same limits; and 

b. the coatings are on the same coating line; and c. the coatings are averaged on the basis of 

pounds of VOC emitted per gallon of coating solids applied to the substrate; and 

d. The compliance demonstration is on a 24-

hour period (calendar day); and 

e. The VOC emissions shall be equal to or less 

than those emitted when all the surface coatings delivered to the application system comply with the applicable regulated VOC emission rate restriction. 

Exemption: 55 gallons of “low-use coatings” may be exempted on an annual rolling basis 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-2 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Alabama (except Jefferson County) 

Metal furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

(excluding water) 

For sources NOT located in Jefferson County: 

1. use low solvent coating technology; or 2. 90 percent emission reduction using 

incineration; or 

3. another equivalent control technology 

Exemptions: Sources with the potential to emit less than 100 ton VOC/yr 

AlaskaaArizona Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR Arizona/Pima Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR Arizona/Pinal Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 

a Alaska does not have applicable air regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-3 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Metal furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

Apply all coatings containing more than 240 g VOC/l (2 lb/gal), minus exempt cmpds using: 

1. Low pressure spray gun; or 2. An electrostatic system; or 3. hydraulic pressure atomizer (including airless 

and air assisted airless); or 

4. non-atomizing or non-spraying application 

methods; or 

5. alternate methods approved by regulatory 

authorities 

Use control systems meeting the following: 1. Prevent at least 85% of the VOC emitted, 

except as controlled using the alternative for very dilute streams (see 3 below) 

2. Use an 87% efficient capture system; 3. Use a 90% efficient control system or for VOC 

input less than 100 ppm – control to less than 20 mg VOC/M3 and the control system gets 

85% control 

Exemptions: Coatings and solvents with a VOC content less than 18g VOC/l (0.15 lb VOC/gal). Coatings containing less than 0.14 lb/gal VOC. 

Arizona/Maricopa 

Cleaning Materials 

35 mm Hg at 20oC Work practices to minimize emissions of 

applicable equipment 

Arkansasb

b Arkansas does not have applicable air regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-4 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Colorado Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 1. Use compliant coatings; 

2. Use emissions averaging; 3. Use a capture system approved by the 

authority or a system that meets the NSPS for Magnetic Tape 

4. Use an add-on control system to meet the limit 

Exemptions: metal furniture coating operations with uncontrolled actual emissions (including fugitives) are less than 6.8 kg/day (15 lb/day) and 1.4 kg/hr (3 lb/hr). No cleaning materials regulations. 

Connecticut Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

1. Compliant coatings; 2. Daily-weighted average coating content; 3. Install capture and control system that reduces emissions by 95 percent Exemptions: any premises with uncontrolled actual emissions from all coating units are less than 6.8 kg VOC per day (15 lb/day) combined No cleaning materials regulations. 

Delaware Metal 

furniture coating 

0.35 kg/l (2.9 lb/gal) 

as applied 

1. Compliant coatings; 2. Daily weighted average coating content 3. Install capture and control system that reduces 

emissions by 95 percent 

Exemptions: any coating unit with uncontrolled actual emissions from all coating units are less than 15 lb VOC/day 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-5 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Cleaning Materials 

 Does not apply to hand-wipe cleaning operations 

Use work practices to minimize emissions. Perform a solvent usage study to determine permit requirements. User-defined and operation specific. 

Florida Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

(excluding water) 

1. use of compliant coatings; 2. use of incineration that reduces VOC emissions by 90 percent. Exemptions: all emission units subject to the same limitation that emit less than 6.8 kg VOC per day (15 lb/day) and 1.4 kg/hr (3 lb/hr) combined 

No cleaning material regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-6 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Georgia Metal 

furniture coating 

3.0 lb/gal 

(excluding water) 

5.06 lb/gal coating 

solids as applied 

1. use low solvent compliant coating technology 2. use 24-hr weighted average of low solvent 

coating on a single coating line that meets 5.06 lb VOC/gal coating solids (averaging across coating lines is not allowed) 

3. use capture and control that reduces VOC 

emissions by 90 percent and overall VOC emissions do not exceed 5.06 lb VOC/gal coating solids 

Exemptions: Sources located outside Cherokee, 

Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, 

Forsyth, Fulton, Gwinnett, Henry, Paulding, and Rockdale counties with potential VOC emissions are less than 100 tons per year; Sources located 

within Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding, or Rockdale counties with actual VOC emissions are less than 15 lb/day; total use of coatings, inks and other VOC-containing materials is less than 55 gal/yr No cleaning materials regulations. 

HawaiicIdaho Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 

c Hawaii does not have applicable air regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-7 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Illinois (not including Chicago and Metro East areas) 

Metal furniture coating 

0.36 kg/l (3.0 lb/gal) 1. control emissions by an afterburner system 

which provides an overall 81% VOC emission from the coating line, and 90% of the nonmethane VOC (measured as total combustible carbon) which enters the afterburner. 

2. the combined actual emissions from selected 

coating lines (not including those constructed or modified after 7/1/79), is less than or equal to the combined allowable emissions calculated using the formula provided in the regulation. 

Exemptions: Coating plants in which uncontrolled VOC emissions are limited by the operating permit to 22.7 Mg/yr (25 tpy); or the total coating usage does not exceed 9,463 l/yr (2,500 gal/yr); or touch-up and repair coatings used by a coating source if the source-wide volume is less than 0.95 l (1 quart) per eight-hour period or exceeds 209 l/yr (55 gal/yr) for any rolling twelvemonth period. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-8 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Metal furniture coating, air dried 

Illinois (Chicago 0.34 kg/l (2.8 lb/gal)areas) 

Metal furniture coating, baked 

0.28 kg/l (2.3 lb/gal)

1. apply coatings that, during each day, do not 

exceed the daily-weighted average VOC content limit 

2. use a capture and control system which has an 

overall VOC emission reduction of 81% and the control device has a 90% efficiency 

3. capture and control system reduces VOC 

emissions to meet the applicable VOC emission limit. 

Exemptions: Coating plants in which combined actual uncontrolled VOC emissions do not exceed 6.8 kg/day (15 lb/day); or touch-up and repair coatings used by a coating source if the sourcewide volume is less than 0.95 l (1 quart) per eighthour period or exceeds 209 l/yr (55 gal/yr) for any rolling twelve-month period. No cleaning material regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-9 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Metal furniture coating, air dried 

Illinois (Metro 0.34 kg/l (2.8 lb/gal)East areas) 

Metal furniture coating, baked 

0.28 kg/l (2.3 lb/gal)

1. apply coatings that, during each day, do not 

exceed the daily-weighted average VOC content limit 

2. use a capture and control system which has an 

overall VOC emission reduction of 81% and the control device has a 90% efficiency 

3. capture and control system reduces VOC 

emissions to meet the applicable VOC emission limit. 

Exemptions: Coating plants in which combined actual uncontrolled VOC emissions do not exceed 6.8 kg/day (15 lb/day); or touch-up and repair coatings used by a coating source if the sourcewide volume is less than 0.95 l (1 quart) per eighthour period or exceeds 209 l/yr (55 gal/yr) for any rolling twelve-month period. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-10 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Indiana Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

(excluding water) 

1. use compliant coatings 2. carbon adsorption 3. incineration 4. higher solids coatings 5. waterborne coatings 6. equivalent emission limitation based on 

transfer efficiency 

Exemptions: Facilities existing before 1/1/80 not located in Clark, Elkhart, Floyd, Lake, Marion, Porter, and St. Joseph Counties which have potential emissions less than 90.7 Mg/yr (100 tpy); Facilities constructed after 1/1/80 located in any 

county with potential emissions less than 22.7 Mg/yr (25 tpy), Facilities existing before 7/1/90 and not located in Clark, Elkhart, Floyd, Lake, Marion, Porter, and St. Joseph Counties and facilities constructed after 7/1/90 and located in 

any county with actual uncontrolled emissions less than 15 lb VOC/day No cleaning material regulations. 

Iowa Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR Kansas Metal 

furniture coating 

3.0 lb/gal 1. use compliant coatings 

2. use coatings that meet limit on a daily weighted 

average basis 

3. capture and control system with an overall 

emission reduction of at least 90% 

Exemptions: Facility with facility-wide VOC PTE less than 3 tpy. Facilities located outside of ozone 

nonattainment areas. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-11 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Kentucky Metal 

furniture coating 

3.0 lb/gal for new 

sources or 15 % by 

weight of VOCs net 

input into the 

facility for existing 

sources 

Exemptions: Coatings with VOC content less than 0.36 kg/l (3.0 lb/gal). Facility with actual uncontrolled emissions less than 3 lb/hr; 15 lb/day; or 10 tpy based on maximum production and 8,760 hr/yr. Low use coating if plantwide consumption is less than or equal to 55 gal/previous 12 months. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-12 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Louisiana Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

(minus water and 

exempt solvent) 

1. capture system with at least 80% efficiency 2. Low solvent coating 3. incinerator with at least 90% control efficiency 4. carbon adsorption 

Exemptions: All emission units subject to the same limitation that emit less than 6.8 kg VOC per day (15 lb/day) and 1.3 kg/hr (3 lb/hr) combined. Surface coating facilities in Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and West Baton Rouge parishes that when controlled have a potential to emit a combined weight (total from the property) of VOCs less than 10 tons in any consecutive 12 calendar months are exempt from the provisions of Subsection C. Surface coating facilities on any property in parishes other than Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and West Baton Rouge that when uncontrolled have a potential to emit a combined weight of VOCs less than 100 pounds (45 kilograms) in any consecutive 24-hour period are exempt from the provisions of Subsection C. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-13 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Maine Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 1. Low solvent coating 

2. Capture and control system that gets 95% 

control or 4.9 lb/gal solids 

Exemptions: maximum theoretical VOC emissions from all coating units, lines or operations under the same surface coating category less than 10 tpy. Or Coating units, lines or operations whose total actual coatings usage from all coating units, lines or operations under the same surface coating 

category is less than 50 gal/yr of coatings. OR facilities that use powder coatings or other nonVOC coating methods. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-14 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Maryland Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 1. use low VOC coatings or adhesives; 

2. use a control device that, results in an emission 

reduction equal to or greater than the emission reduction that would have been achieved by complying low use VOC coatings 

3. reduce emissions by using water-based 

coatings, resins, inks, or similar products that contain less than 25 percent VOC by volume of the volatile portion of the product; or 

4. an alternative method approved by authority 

No cleaning materials regulations. 

Massachusetts Metal 

furniture coating 

5.1 lb/gal solids 

applied 

1. Use low/no solvent coatings 2. Use add-on controls 3. Use daily weighted averaging 

Exemptions: facilities for which the total amount of all coatings exempted is less than 55 gal on a 12-month rolling period and facilities with uncontrolled VOC emissions less than 15 lb/day Keep records of cleaning materials usage. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-15 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Michigan Metal 

furniture coating 

3.0 lb/gal (as 

applied, minus 

water), or 

8.4 lb/gal coating 

solids applied 

1. Use compliant coatings 2. Use volume weighted average emissions 

coating content 

3. Use add-on controls combined with volume 

weighted average 

Exemptions: Facilities with a combined actual 

VOC emission rate less than 100 lb/day or 2,000 lb/month and facilities may exclude low-use coatings that total 55 gallons or less per rolling 12-month period. No cleaning materials regulations. 

Minnesota Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR Mississippi Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR Missouri Metal 

furniture coating 

3.0 lb/gal (as 

applied, minus 

water) 

1. Comply with daily volume-weighted average, 

as applied, on a lb/gal coating basis

2. comply with daily volume-weighted average, 

as applied, on a lb/gal coating solids basis;

3. comply with a combination of capture and 

control system and daily volume-weighted average.

Exemptions: Does not apply to sources located 

outside of Clay, Jackson, and Platte counties. And sources with total uncontrolled potential VOC emissions is less than 6.8 kg/day (2.7 tpy) No cleaning materials regulations.

Montana Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-16 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Nebraska Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR NevadadNew Hampshire Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 1. use compliant coatings 

2. add-on control device or bubble and comply 

with solids-based emission rate 

Exemptions: Minor VOC sources with total VOC 

emissions less than 5 tpy. Sources that already meet or exceed RACT requirements. Facilities with VOC PTE less than 10 tpy. No cleaning materials regulations. 

New Jersey Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

(minus water) 

1. Control emissions by 90 percent 2. control emissions such that the hourly VOC 

emission rate does not exceed a calculated max hourly emission rate 

Exemptions: Total surface coating formulation 

containing VOC are applied at a rate less than 1⁄2 gallon per hour and 2 1⁄2 gallons per day. Surface coating operations with VOC PTE less than 3 lb/hr. No cleaning materials regulations. 

New Mexicoe Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 

d Nevada has no air regulations applicable to the Metal Furniture industry. e New Mexico has a local agency with air regulations, but they could not be accessed on the Internet. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-17 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

New York 3.0 lb/gal 1. Use a VOC incinerator that with 80% removal 

efficiency 

2. determine overall removal efficiency of an air 

cleaning device on a solids as applied basis unless the air cleaning device has an 85% removal efficiency 

Exemptions: Low-use coatings where the combined facility-wide usage is less than 55 gallons on a 12-month rolling average Use work practices to minimize VOC emissions from cleaning materials. 

North Carolina Metal 

furniture coating 

5.1 lb/gal coating 

solids, as applied or 

if using a control 

device, 3.0 lb/gal 

coating, as applied 

Exemptions: Sources with VOC emissions less than 15 lb/day No cleaning materials regulations. 

North Dakotaf Incorporation by Reference, 40 CFR 60, Subpart EE (NSPS) 

f North Dakota does not have applicable air regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-18 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Ohio (Ashtabula, Butler, Clark, Clermont, Cuyahoga, Delaware, Franklin, Geauga, Greene, Hamilton, Lake, Licking, Lorain, Lucus, Mahoning, Medina, Miami, Montgomery, Portage, Stark, Summit, Trumbull, Warren, and Wood Counties) 

Metal furniture coating 

3.0 lb/gal coating 

OR 

5.1 lb/gal solids (if 

using a control 

system) 

1. Use compliant coatings; or 2. Use a capture and control system that meets the 

5.1 lb VOC/gal solids limit; or 

3. Use a capture and control system with an 

overall VOC emission reduction greater than 81%, by weight, in the overall VOC emissions from the coating line; and the control equipment has an VOC emission reduction efficiency of 90% by weight; or 

4. An alternative emission limitation based upon 

a transfer efficiency (determined using a test method) greater than 60 percent. 

Exemptions: Total VOC emissions from coating operations are less than 15 lb/day before add-on control. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-19 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Ohio (remaining 64 counties) 

Metal furniture coating 

3.0 lb/gal coating 

OR 

5.1 lb/gal solids (if 

using a control 

system) 

1. Use compliant coatings; or 2. Use a capture and control system that meets the 

5.1 lb VOC/gal solids limit; or 

3. Use a capture and control system with an 

overall VOC emission reduction greater than 81%, by weight, in the overall VOC emissions from the coating line; and the control equipment has an VOC emission reduction efficiency of 90% by weight; or 

4. An alternative emission limitation based upon 

a transfer efficiency (determined using a test method) greater than 60 percent. 

Exemptions: Existing facilities (for which construction or modification commenced before October 19, 1979) and have the potential to emit less than 100 tpy VOC. Total VOC emissions from coating operations are less than 15 lb/day before add-on control. 

Oklahoma Attainment areas 

Metal furniture coating, various coating types 

4.8 – 6.5 lb/gal 1. compliant coatings 

2. incineration, absorption, adsorption, or other 

process so long as emissions are no more than they would be using compliant coatings 

Exemptions: sources that emit less than 100 lb/day of VOC. Include VOC emissions from cleanup in determining compliance 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-20 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Oklahoma Tulsa County 

Metal furniture coating, various coating types 

3.0 – 4.3 lg/gal 1. compliant coatings 

2. incineration, absorption, or other equipment so 

long as emissions are no more than they would be using compliant coatings, and at least 85% overall control efficiency 

Include VOC emissions from cleanup in determining compliance. 

Oregon Metal 

furniture coating 

3.0 lb/gal 

(as applied) 

1. Use low solvent coatings; 2. Use an incineration system that gets 90% 

control or 

3. An equivalent means of control 

Exemptions: Sources whose potential VOC 

emissions are less than 10 tpy (or 3 lb VOC/hr or 15 lb VOC/day actual). Keep records of cleaning materials usage. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-21 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Pennsylvania Metal 

furniture coating 

0.61 kg/l coating 

solids 

(5.06 lb/gal coating 

solids) 

1. Use compliant coatings, as applied. 2. Use combination of compliant coatings and 

capture and control systems 

Exemptions: A facility that has had actual VOC 

emissions less than 1.4 kg/hr (3 lb/hr), 7 kg/day (15 lb/day) or 2,455 kg/yr (2.7 tpy) during any calendar year since January 1, 1987 No cleaning materials regulations. 

Rhode Island 5.06 lb/gal coating 

solids or 

3.0 lb/gal coating 

(excluding water 

and exempt 

solvents) 

1. Reduce VOC emissions by 95% using a control 

system; 

2. Use compliant coatings; 3. Use control systems to meet coating content 

limits; 

4. Use daily-weighted averaging 5. Use an approved alternative method Exemptions: Actual uncontrolled VOC emissions are less than 15 lb/day since 12/31/89. Keep records of cleaning materials usage 

South Carolina Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

as applied 

1. Low solvent technology 2. incineration that reduces VOC emissions by 90 

percent 

3. carbon bed solvent recovery or 4. alternative technology 

Exemptions: plants with total potential VOC emissions less than 550 pounds (250 kilograms) in any one day (nominal size - 100 tons per year) or more than 150 pounds (68 kilograms) in any one hour. Keep records of cleanup materials. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-22 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

South Dakota Incorporated by Reference, 40 CFR 63, Subpart RRRR (NESHAP) Tennessee Metal 

furniture coating 

0.36 kg/l 

(3.0 lb/gal), 

excluding water 

and/or exempt 

compounds, as 

applied 

1. Use compliant coatings; 2. Meet limit using weighted average VOC 

content 

3. Reduce emissions by 95% using capture and 

control system

Exemptions: Facilities located in Davidson, Rutherford, Sumner, Williamson, or Wilson County with actual uncontrolled VOC emissions from all metal furniture coating operations less than 6.8 kg (15 lb) per day or whose max theoretical VOC emissions from all paper coating operations are less than 10 tpy. Facilities in Hamilton or Shelby County with potential VOC emissions from all metal furniture coating operations less than 25 tpy, Facilities located in any other county with potential VOC emissions from all metal furniture coating operations less than 100 tpy. No cleaning materials regulations. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-23 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

TexasgUtah Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

coating or 

5.1 lb/gal coating 

solids 

1. use low solvent technology coatings; 2. reduce VOC emissions by 90% using an 

incinerator 

3. use a carbon adsorber 4. use water-borne electrodeposition 5. use water-borne spray, dip, or flowcoat 6. use powder coatings 7. use higher solids coatings 

Exemptions: Sources whose VOC emissions are less than 6.8 kg (15 lb) in any 24 hour period, nor more than 1.4 kg (3 lb) in any one hour Work practices to minimize VOC emissions from cleaning materials.

Vermont Metal 

furniture coating, various coatings 

3.0 – 4.3 lb/gal 1. Daily weighted average of VOC content must 

comply with VOC limit. 

2. install capture and control device where the 

overall reduction efficiency is greater than or equal to the required reduction efficiency (an efficiency is not specified). 

Exemptions: Metal furnitue coating sources that 

have actual uncontrolled VOC emissions less than 5 lb/day. No cleaning materials regulations. 

g Could not access Texas air regulations website. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-24 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Virginia Metal 

furniture coating 

3.0 lb/gal, as 

applied (excluding 

water) 

1. Use of waterborne or electrodeposited 

waterborne coatings; 

2. Use of high-solids coatings; 3. Use of powder coatings; 4. Carbon adsorption; 5. Incineration; or 6. Any technology with an equivalent control 

efficiency when compared to the use of a coating complying with the VOC limit 

No cleaning materials regulations. 

Washington Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 

Metal furniture coating 

0.36 kg/l (3.0 lb/gal) 

coating 

1. Daily weighted emission limitation 2. use a capture and control system with an 

overall emission reduction of 95% 

Exemptions: coating operations at facilities with uncontrolled actual VOC emissions less than 6.8 kg (15 lb) per day. 

West Virginia 

Cleaning materials 

6.8 kg/day 

(15 lb/day) 

Use work practices to minimize emissions. Do not use VOCs for cleanup activities unless equipment is used to collect the cleaning compounds and to minimize their evaporation to the atmosphere. 
Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including Ca

B-25 

State/Locality 

Operations 

Covered 

VOC Numerical 

Limit (minus 

water and exempt 

compounds) Compliance Method 

Wisconsin Metal 

furniture coating 

0.36 kg/l (3.0 lb/gal) 

coating 

1. Use of low solvent coatings 2. Use a vapor recovery system 3. Use incinerator with a 90% emission reduction 

4. Daily volume-weighted average 

Exemptions: coating operations at facilities with 

uncontrolled actual VOC emissions less than 0.68 kg (15 lb) per day. No cleaning materials regulations. 

Wyoming Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR 
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Appendix C

Summary of California Air District Regulations for Metal Furniture 

Coating 
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Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-1 

Operation Material 

VOC 

limitation Compliance Requirements 

Antelope Valley Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g/l as 

applied (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l as 

applied (less 

water and 

exempt 

compounds) 

Specialty coatings (non-military), air dried 

Content limit 

of 420 g/l as 

applied (less 

water and 

exempt 

compounds) 

Specialty coatings (non-military), baked 

Content limit 

of 275-420 g/l 

as applied (less 

water and 

exempt 

compounds) 

Metal coating 

Solvent cleaning materials 

Content limit 

of 950 g/l 

(7.9l g/gal) and 

VOC 

composite 

partial pressure 

of 35 mm Hg 

@20oC (68oF) 

1. Use compliant coatings; or use an collection system that has a capture 

efficiency of at least 90%, by weight and the control device has an emission reduction efficiency of 95% by weight or to an outlet concentration of 50 ppmv (as carbon) 

2. Coatings must be applied using the following types of equipment: 

electrostatic attraction, flow, roll, dip, HVLP, or hand application. Alternative coating methods must be approved and achieve at least 65% transfer efficiency. 

3. Solvent cleaning must use one of the following: wipe cleaning; closed 

containers or hand held spray bottles w/out propellant-induced force; cleaning equipment which has a solvent container that is closed at all times (except when adding or removing parts or during repair); remote reservoir cleaner; non-atomized solvent flow where solvent is collected in a container or collection system that is closed at all times except for solvent collection and pressure relief (as needed) openings; and solvent flushing methods where solvent is collected in a container or collection system that is closed at all times except for solvent collection and pressure relief (as needed) openings (discharged solvent must be collected into containers without atomizing into the air and solvent may be flushed through the system by air or hydraulic pressure or by pumping). 

4. All VOC-containing solvents must be stored in non-absorbent, nonleaking containers which must be kept closed at all times, except when 

filling or emptying. Cloth and paper containing with VOC-laden solvents should be stored in closed, non-absorbent, non-leaking containers. 

5. Use closed containers for disposal of cloth or paper used in stripping 

cured coatings that are impregnated with solvent containing VOC 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-2 

Operation Material 

VOC 

limitation Compliance Requirements 

Bay Area Air Quality Management District 

Air dried coatings Content limit 

of 340 g/l 

(2.8 lb/gal), as 

applied (less 

water) 

Baked coatings Content limit 

of 275 g/l 

(2.3 lb/gal), as 

applied (less 

water) 

Specialty coatings, air dried 

Content limit 

of 420 g/l 

(3.5 lb/gal), as 

applied (less 

water) 

Metal furniture coating 

Specialty coatings, baked 

Content limit 

of 360-420 g/l 

(3.0-

3.5 lb/gal), as 

applied (less 

water) 

1. Use an approved control system. 2. Use low-solvent coatings that meet the content limit. 3. Use closed containers to store or dispose of cloth or paper laden with 

organic compounds that is used for surface preparation, cleanup or 

coating removal. 

4. Close containers of fresh solvent, coating, or catalyst when not in use. 

5. Materials used for cleanup of spray equipment and surface preparation 

must contain no more than 50 g/l (0.42 lb/gal) VOC. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-3 

Operation Material 

VOC 

limitation Compliance Requirements 

El Dorado County Air Quality Management District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Machinery, process, or operation with the potential to emit organic compounds 

Any that are conducted at or below ambient temperatures 

40 lb/day and 

8 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

1. Reduce VOC emissions by 85% or more; or equip process with BACT 2. Do not dispose or allow the release of organic compounds from 

storage or transfer operations of more than 1.5 gal of liquid (or equivalent amount of vapor). 

Exemptions: (1) stationary storage containers less than 250 gal; (2) any single use or operation which annually uses a total volume of VOC which is less than the emission limits, unless it is part of a large operation subject ot regulation; and (3) sources in existence before March 1, 1984. 

Solvents used on substrates during the manufacturing process or for surface preparation 

70 g VOC/l 

material 

Solvent Cleaners 

Solvents used for maintenance and repair 

900 g VOC/l 

material and a 

composite 

partial pressure 

of 20 mm Hg 

or less at 20oC 

(68oF) 

1. Use complaint cleaning materials AND Use one of the following 

cleaning devices or methods: a. Wipe cleaning; 

b. Non propellant spray bottles or containers 

c. Cleaning equipment which has a solvent container that can be, and 

is, closed during cleaning operations, except when depositing and removing objects, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself; 

d. Non-atomized solvent flow method where the cleaning solvent is 

collected in a container or a collection system which is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container; or 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-4 

Operation Material 

VOC 

limitation Compliance Requirements 

Solvents used for cleaning coatings or adhesives application equipment 

950 g VOC/l 

material and a 

composite 

partial pressure 

of 35 mm Hg 

or less at 20oC 

(68oF) 

Solvents used for cleaning polyester resin application equipment 

200 g VOC/l 

material; or 

1,100 g VOC/l 

and composite 

partial pressure 

of 1.0 mm Hg 

or less at 20oC 

(68oF) or 

solvent 

reclamation 

system 

e. Solvent flushing method where the cleaning solvent is discharged 

into a container which is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container. The discharged solvent from the equipment must be collected into containers without atomizing into the open air. The solvent may be flushed through the system by air or hydraulic pressure, or by pumping. 

2. Use a collection and control system that collects at least 90 percent 

of the emissions and reduces VOC emissions by at least 95 percent or 

has an outlet concentration less than 50 ppmw (as carbon) 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-5 

Operation Material 

VOC 

limitation Compliance Requirements 

Great Basin Unified Air Pollution Control District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day and 

8 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

Organic solvents or solvent containing materials 

Nonphotochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

3,000 lb/day 

and 450 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

1. Reduce VOC emissions by 85% or more 2. Control emissions by incineration with an emission reduction of 90% 

or use adsorption, or another approved method of control. 

Exemptions: (1) transport of storage of organic containing materials; (2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC, and does not come into contact with a flame; (3) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents and more than 50% by volume of VOC is evaporated prior to entering a chamber heated above ambient temperature, and does not come into contact with a flame; and (4) the solvent content is less than 5% by volume of non-photochemically reactive organic solvents, and does not come into contact with a flame. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-6 

Operation Material 

VOC 

limitation Compliance Requirements 

Imperial County Air Pollution Control District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Organic solvents or solvent containing materials 

Photochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day and 

8 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

1. Emissions from cleanup with photo-chemically reactive solvents must 

be included in compliance determination 

2. Reduce VOC emissions by 85% or more using a capture and control 

system (an incinerator must have an emission reduction of 90% or more). 

Exemptions: (1) transport of storage of organic containing materials; and (2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC, and does not come into contact with a flame; and (3) use, 

application, evaporation, or drying halogenated hydrocarbons or perchloroethylene. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-7 

Operation Material 

VOC 

limitation Compliance Requirements 

Kern County Air Pollution Control District 

General coatings, air dried 

Content limit 

of 420 g/l (3.5 

lb/gal) (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l (2.3 

lb/gal) (less 

water and 

exempt 

compounds) 

Specialty coatings, air dried 

Content limit 

of 340-420 g/l 

(2.8-3.5 lb/gal) 

(less water and 

exempt 

compounds) 

Specialty coatings, baked 

Content limit 

of 275-420 g/l 

(2.3-3.5 lb/gal) 

(less water and 

exempt 

compounds) 

Metal Coatings 

Surface cleaning and stripping materials 

Content limit 

of 200 g/l (1.7 

lb/gal) (less 

water and 

exempt 

compounds) 

1. Use compliant coatings. 2. Use air pollution control equipment with a capture efficiency of at 

least 85% and a control device efficiency of at least 90%. 

3. Coatings must be applied using electrostatic, electrodeposition, 

HVLP, brush, dip, roll, or other method that achieves at least 65% transfer efficiency. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-8 

Operation Material 

VOC 

limitation Compliance Requirements 

Coating application equipment cleaning materials 

Content limit 

of 950 g/l (7.9 

lb/gal) (less 

water and 

exempt 

compounds) 

and VOC 

partial pressure 

<35 mmHg at 

20 ̊C 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-9 

Operation Material 

VOC 

limitation Compliance Requirements 

Mojave Desert Air Quality Management District 

General coatings, air dried 

Content limit 

of 420 g/l (3.5 

lb/gal) (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 360 g/l (3.0 

lb/gal) (less 

water and 

exempt 

compounds) 

Specialty coatings (non-military), air dried 

Content limit 

of 420-520 g/l 

(3.5-4.3 lb/gal) 

(less water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings (non-military), baked 

Content limit 

of 275-420 g/l 

(2.3-3.5 lb/gal) 

(less water and 

exempt 

compounds) 

1. Use compliant coatings. 2. Use air pollution control equipment with combined capture and control 

efficiency of at least 85%. 

3. Cleanup solvent must be collected in closed container. 4. Coating application equipment must be disassembled and cleaned in an 

enclosed system. 

5. Coatings must be applied using electrostatic, HVLP, dip, hand 

application, or other equivalent method. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-10 

Operation Material 

VOC 

limitation Compliance Requirements 

Surface preparation and cleanup solvent 

Content limit 

of 200 g/l 

(1.67 lb/gal) 

(less water and 

exempt 

compounds); 

or 

Boiling point >

190 ̊C; or 

Total VOC 

vapor pressure 

<20 mmHg at 

20 ̊C 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-11 

Operation Material 

VOC 

limitation Compliance Requirements 

Monterey Bay Unified Air Pollution Control District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized at a temperature of 194oF (90oC) in 

the presence of O2

Organic 15 lb/day solvents or solvent containing materials 

Any that do not come into contact with a flame, or are not baked, heat cured, or heat-polymerized 

40 lb/day 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

1. Emissions from cleanup with solvents must be included in compliance 

determination 

2. Reduce VOC emissions by 85% or more using a capture and control 

system (an incinerator must have an emission reduction of 90% or more). 

Exemptions: (1) transport or storage of solvent materials; (2) any source in existing prior to March 19, 2001 with actual VOC emissions less than 15 lb/day (solvents that are baked, heat-cured, heat-polymerized or exposed to flame) or 40 lb/day (solvents that are not baked, heat-cured, heatpolymerized or exposed to flame) 

General coatings, air dried 

Content limit 

of 420 g/l (3.5 

lb/gal) (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 360 g/l (3.0 

lb/gal) (less 

water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings, air dried 

Content limit 

of 420-780 g/l 

(3.5-6.5 lb/gal) 

(less water and 

exempt 

compounds) 

1. Use compliant coatings. 2. Use air pollution control equipment with combined capture and control 

efficiency of at least 90%. 

Exemptions: facilities that use less than 55 gallons of coating per year 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-12 

Operation Material 

VOC 

limitation Compliance Requirements 

 Specialty 

coatings, baked 

Content limit 

of 360-780 g/l 

(3.0-6.5 lb/gal) 

(less water and 

exempt 

compounds) 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-13 

Operation Material 

VOC 

limitation Compliance Requirements 

Placer County Air Pollution Control District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2

15 lb/day and 

3 lb/hr 

Photochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day and 

8 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

Nonphotochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

3,000 lb/day 

and 450 lb/hr 

(emissions 

from air or 

heat drying for 

the first 12 

hours must be 

included) 

Organic solvents or solvent containing materials 

Phenolic resin coating 

1.75 lb 

VOC/gal 

coating as 

applied (except 

for water and 

exempt 

compounds) 

1. Reduce VOC emissions by 85% or more by incineration (if incinerator 

has an emission emission reduction of 90% or more), adsorption, or another approved method of control. 

3. Do not dispose or allow the release of organic compounds from storage 

or transfer operations of more than 1.5 gal of liquid (or equivalent amount of vapor). 

4. Emissions from cleanup with solvents must be included in compliance 

determination 

Exemptions: (1) transport of storage of organic containing materials; (2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% by volume of VOC, and does not come into contact with a flame; and (3) the solvent content is less than 20% by volume of non-photochemically reactive organic solvents, and does not come into contact with a flame. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-14 

Operation Material 

VOC 

limitation Compliance Requirements 

Solvents used on substrates during the manufacturing process or for surface preparation 

70 g VOC/l 

material 

Solvents used for maintenance and repair 

900 g VOC/l 

material and a 

composite 

partial pressure 

of 20 mm Hg 

or less at 20oC 

(68oF) 

Solvents used for cleaning coatings or adhesives application equipment 

950 g VOC/l 

material and a 

composite 

partial pressure 

of 35 mm Hg 

or less at 20oC 

(68oF) 

Solvent Cleaners 

Solvents used for cleaning polyester resin application equipment 

200 g VOC/l 

material; or 

1,100 g VOC/l 

and composite 

partial pressure 

of 1.0 mm Hg 

or less at 20oC 

(68oF) or 

solvent 

reclamation 

system 

1. Use complaint cleaning materials AND Use one of the following 

cleaning devices or methods: a. Wipe cleaning; 

b. Non propellant spray bottles or containers c. No spray discharge into open air 

2. Use a collection and control system that collects at least 90 percent of 

the emissions and reduces VOC emissions by at least 95 percent or has an outlet concentration less than 50 ppmw (as carbon) 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-15 

Operation Material 

VOC 

limitation Compliance Requirements 

Sacramento Metropolitan Air Quality Management District 

Air dried coatings Content limit 

of 340 g/l (2.8 

lb/gal) (less 

water and 

exempt 

compounds) 

Baked coatings Content limit 

of 275 g/l (2.3 

lb/gal) (less 

water and 

exempt 

compounds) 

Strippers Content limit 

of 200 g/l (1.7 

lb/gal) (less 

water and 

exempt 

compounds) 

Metal parts and products 

Solvent for cleanup of application equipment and surface preparation 

Content limit 

of 72 g/l (0.6 

lb/gal) (less 

water and 

exempt 

compounds) 

1. Use compliant coatings. 2. Use emission control equipment with an overall control efficiency of at 

least 85%. 

3. Use closed containers for disposal of cloth, paper, or sponges. 4. Do not use VOC-containing material for cleaning coating application 

equipment unless cleanup solvent VOC content limit is met or cleaning 

is performed in an enclosed cleaner. 

5. Coatings must be applied using roll, dip, electrostatic, flow, HVLP, 

LVLP, hand application, or other approved method. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-16 

Operation Material 

VOC 

limitation Compliance Requirements 

Solvent Cleaning Materials 

General cleaning activities, product cleaning during manufacturing or surface preparation for coatings, adhesives, sealants, or ink application; Repair and maintenance cleaning 

50 g VOC/l 

(0.42 lb/gal) 

3. Use complaint cleaning materials AND Use one of the following 

cleaning devices or methods: a. Wipe cleaning; 

b. Cleaning with closed containers or by using hand held spray 

bottles or containers without a propellant-induced force; 

c. Using cleaning equipment which has a solvent container that is 

closed during cleaning operations, except when depositing and removing objects, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself; 

d. Using a remote reservoir degreaser, non-vapor degreaser, or vapor 

degreaser used as required under Rule 454. 

e. Using solvent flushing method where the cleaning solvent is 

discharged into a container which is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container. The discharged solvent from the equipment must be collected into containers without atomizing into the open air. The solvent may be flushed through the system by air or hydraulic pressure, or by pumping. 

4. Use a collection and control system that collects at least 90 percent of 

the emissions and reduces VOC emissions by at least 95 percent or has an outlet concentration less than 50 ppmw (as carbon) 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-17 

Operation Material 

VOC 

limitation Compliance Requirements 

San Diego County Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g/l (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l (less 

water and 

exempt 

compounds) 

Specialty coatings, air dried 

Content limit 

of 420 g/l (less 

water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings, baked 

Content limit 

of 360-420 g/l 

(less water and 

exempt 

compounds) 

1. Use compliant coatings or reduce VOC emissions using a control 

system with a combined collection and abatement efficiency of 85% by 

weight or more. 

2. Cleaning of coating application equipment alternatively can be carried 

out in a manner that minimizes emissions or within enclosed equipment. 

Exemption: Any coating operation that uses less than 20 gallons of coating per consecutive 12-month period. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-18 

Operation Material 

VOC 

limitation Compliance Requirements 

Surface preparation and cleanup solvent 

Content limit 

of 200 g/l 

(1.67 lb/gal) 

(less water and 

exempt 

compounds); 

or 

Boiling point >

190 ̊C; or 

Total VOC 

vapor pressure 

<20 mmHg at 

20 ̊C 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-19 

Operation Material 

VOC 

limitation Compliance Requirements 

San Joaquin Valley Unified Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g/l (2.8 

lb/gal) (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l (2.3 

lb/gal) (less 

water and 

exempt 

compounds) 

Specialty coatings, air dried 

Content limit 

of 420 g/l (3.5 

lb/gal) (less 

water and 

exempt 

compounds) 

Specialty coatings, baked 

Content limit 

of 360-420 g/l 

(3.0-3.5 lb/gal) 

(less water and 

exempt 

compounds) 

Metal parts and products 

Surface preparation, repair, and maintenance solvents 

Content limit 

of 50 g/l (0.42 

lb/gal) (less 

water and 

exempt 

compounds) 

1. Use compliant coatings or reduce VOC emissions using a control 

system with a combined collection and abatement efficiency of 90% by weight or more. 

2. Cleaning of coating application equipment alternatively can be carried 

out in a manner that minimizes emissions or within enclosed equipment. 

3. Coatings must be applied using the following application equipment: 

electrostatic, electrodeposition, HVLP, flow, roll, dip, brush, continuous, or other method that achieves at least 65% transfer efficiency. 

Exemption: Any coating operation that uses less than 20 gallons of coating per consecutive 365-day period. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-20 

Operation Material 

VOC 

limitation Compliance Requirements 

Coating application equipment cleaning solvents 

Content limit 

of 550 g/l (4.6 

lb/gal) (less 

water and 

exempt 

compounds) 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-21 

Operation Material 

VOC 

limitation Compliance Requirements 

San Luis Obispo County Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g/l (2.8 

lb/gal) (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l (2.3 

lb/gal) (less 

water and 

exempt 

compounds) 

Specialty coatings, air dried 

Content limit 

of 340-800 g/l 

(2.8-6.7 lb/gal) 

(less water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings, baked 

Content limit 

of 275-800 g/l 

(2.3-6.7 lb/gal) 

(less water and 

exempt 

compounds) 

1. Must apply coatings using electrostatic, flow, dip, HVLP, or 

equivalent. 

2. VOC-containing materials must be stored in closed containers. 3. Cannot use VOC-containing materials for spray equipment cleanup 

unless an enclosed gun washer is used or a gun washer using a solvent with a vapor pressure less than 45 mmHg (0.87 psi) at 20 ̊C (68 ̊F). 

Exemptions: (1) coatings used in volumes of less than 20 gal/yr; (2) sources using not more than 4 gal/day (monthly average) of solventcontaining materials; (3) sources using a control device demonstrated to 

have the same emission reduction as this rule. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-22 

Operation Material 

VOC 

limitation Compliance Requirements 

Santa Barbara County Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g/l (less 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g/l (less 

water and 

exempt 

compounds) 

Industrial maintenance coatings, air dried 

Content limit 

of 420 g/l (less 

water and 

exempt 

compounds) 

Metal parts and products 

Powder coatings Content limit 

of 50 g/l (less 

water and 

exempt 

compounds) 

1. Use add-on control system with at least 90% capture efficiency and 

95% control efficiency. 

2. Apply coatings using the following methods: electrostatic, flow, dip, 

HVLP, electrodeposition, hand application, touch-up guns, or other approved method that achieves at least 65% transfer efficiency. 

3. Store reactive VOC-containing materials in closed containers. 4. Organics in coating thinners and reducers shall not be photochemically 

active. 

Exemptions: (1) coatings used in volumes less than 20 gal/day; total of all such coatings not to exceed 55 gal/yr. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-23 

Operation Material 

VOC 

limitation Compliance Requirements 

Shasta County Air Quality Management District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2 at temperatures above 400oF 

15 lb/day 

Photochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day 

Organic solvents or solvent containing materials 

Any photochemically reactive substance 

40 lb/day 

1. Reduce VOC emissions by 85% 2. Include emissions from the cleanup with photochemically reactive 

solvents in compliance determination 

Exemptions: (1) use, application, evaporation, or drying halogenated hydrocarbons or perchloroethylene. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-24 

Operation Material 

VOC 

limitation Compliance Requirements 

South Coast Air Quality Management District 

General coatings, one component (air-dried and baked) 

Content limit 

of 275 g/l as 

applied 

(excluding 

water and 

exempt 

compounds) 

General coatings, multicomponent, air dried 

Content limit 

of 340 g/l as 

applied (except 

water and 

exempt 

compounds) 

General coatings, multicomponent, baked 

Content limit 

of 275 g/l as 

applied 

(excluding 

water and 

exempt 

compounds) 

Specialty coatings, air dried and baked 

Content limit 

of 275-420 g/l 

as applied 

(excluding 

water and 

exempt 

compounds) 

Metal parts and products 

Cleaning materials 

Content limit 

of 25 g/l (0.21 

lb/gal) 

1. Use compliant materials ; or use an collection system that has a capture 

efficiency of at least 90% by weight and the control device has an emission reduction efficiency of 95% by weight or to an outlet concentration of 5 ppmv VOC. 

2. Coatings must be applied using hand application methods, HVLP 

spray, flow, roll, dip. Alternative coating methods must be approved. 

3. Containers and mixing tanks must be free from leaks and covered 

except when adding or removing materials, cleaning or when the container is empty. 

4. Solvent cleaning must use one of the following: wipe cleaning; closed 

containers or hand held spray bottles w/out propellant-induced force; cleaning equipment which has a solvent container that is closed at all times (except when adding or removing parts or during repair); remote reservoir cleaner; non-atomized solvent flow where solvent is collected in a container or collection system that is closed at all times except for 

solvent collection and pressure relief (as needed) openings; and solvent 

flushing methods where solvent is collected in a container or collection system that is closed at all times except for solvent collection and 

pressure relief (as needed) openings (discharged solvent must be collected into containers without atomizing into the air and solvent may be flushed through the system by air or hydraulic pressure or by pumping). 

5. All VOC-containing solvents must be stored in non-absorbent, nonleaking containers which must be kept closed at all times, except when 

filling or emptying. Cloth and paper containing with VOC-laden solvents should be stored in closed, non-absorbent, non-leaking containers. 

6. Use closed containers for disposal of cloth or paper used in stripping 

cured coatings that are impregnated with solvent containing VOC. 

7. Stripping materials limited to 200 g/l 

Exemption: Any application process that has VOC emissions less than 

14.3 lb (6.5 kg) per day 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-25 

Operation Material 

VOC 

limitation Compliance Requirements 

Tehama County Air Pollution Control District 

Any that come into contact with a flame, or are baked, heat cured, or heatpolymerized in the presence of O2 at temperatures above 400oF 

15 lb/day 

Photochemically reactive solvent (except solvents that are baked, heat cured or heatpolymerized) 

40 lb/day 

Organic solvents or solvent containing materials 

Any photochemically reactive substance 

40 lb/day 

1. Reduce VOC emissions by 85% 2. Include emissions from the cleanup with photochemically reactive 

solvents in compliance determination 

Exemptions: (1) use, application, evaporation, or drying halogenated hydrocarbons or perchloroethylene. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-26 

Operation Material 

VOC 

limitation Compliance Requirements 

Ventura County Air Pollution Control District 

General coatings, air dried 

Content limit 

of 340 g 

ROC/l (2.8 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g 

ROC/l (2.3 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings, air dried 

Content limit 

of 340-420 g 

ROC/l (2.8-3.5 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

1. Use compliant materials or reduce emissions by a combined capture 

and destruction efficiency of 85%. 

2. Apply coatings using electrostatic, flow, dip, HVLP, hand, or other 

approved method that achieves at least 65% transfer efficiency. 

3. Use enclosed gun washer and solvent with a vapor pressure of <45 

mmHg at 20 ̊C. 

Exemptions: (1) source that emits <200 lb ROC/rolling 12-month period; (2) Cleaning solvent ROC limit does not apply where total usage of noncomplying cleaners does not exceed 5 gal/rolling 12-month period. 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-27 

Operation Material 

VOC 

limitation Compliance Requirements 

Specialty coatings, baked 

Content limit 

of 275-420 g 

ROC/l (2.3-3.5 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

Surface preparation and cleanup solvents 

70 g ROC/l 

material used 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-28 

Operation Material 

VOC 

limitation Compliance Requirements 

Yolo-Solano Air Quality Management District 

General coatings, air dried 

Content limit 

of 340 g 

ROC/l (2.8 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

General coatings, baked 

Content limit 

of 275 g 

ROC/l (2.3 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

Metal parts and products 

Specialty coatings, air dried 

Content limit 

of 420 g 

ROC/l (3.5 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

1. Use capture and control system with overall control efficiency of at 

least 85%. 

2. Do not use VOC-containing materials for cleanup unless collected in a 

closed container or guns cleaned in an enclosed washer. 

3. Use closed container for disposal of cloth, paper, and other materials 

containing solvents. 

4. Apply coatings using electrostatic, HVLP, flow, dip, hand, or roll. 

Exemptions: (1) coatings used in volumes less than 55 gal/yr 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-29 

Operation Material 

VOC 

limitation Compliance Requirements 

Specialty coatings, baked 

Content limit 

of 360-420 g 

ROC/l (3.0-3.5 

lb/gal), as 

applied 

(excluding 

water and 

exempt 

compounds) 

Surface preparation solvents 

200 g/l 

Solvents used on substrates during the manufacturing process or for surface preparation 

200 g VOC/l 

material 

Solvents used for maintenance and repair 

900 g VOC/l 

material and a 

composite 

partial pressure 

of 20 mm Hg 

or less at 20oC 

(68oF) 

Solvent Cleaners 

Solvents used for cleaning coatings or adhesives application equipment 

950 g VOC/l 

material and a 

composite 

partial pressure 

of 35 mm Hg 

or less at 20oC 

(68oF) 

2. Use complaint cleaning materials AND Use one of the following 

cleaning devices or methods: a. Wipe cleaning; 

b. Spray bottles or containers with a maximum capacity of 16 fluid 

ounces without a propellant-induced force; 

c. Cleaning equipment which has a solvent container that can be, and 

is, closed during cleaning operations, except when depositing and removing objects, and is closed during non-operation with the exception of maintenance and repair to the cleaning equipment itself; 

d. Cleaning device or mechanism which has been determined by the 

Air Pollution Control Officer to result in equivalent or lower emissions; 

e. Remote reservoir cold cleaner used 

f. Non-atomized solvent flow method where the cleaning solvent is 

collected in a container or a collection system which is closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container; or 

g. Solvent flushing method where the cleaning solvent is discharged 

into a container which is closed except for solvent collection 
Table C-1. Summary of California Air District Regulations for Metal Furniture Coating 

C-30 

Operation Material 

VOC 

limitation Compliance Requirements 

Solvents used for cleaning polyester resin application equipment 

200 g VOC/l 

material; or 

1,100 g VOC/l 

and composite 

partial pressure 

of 1.0 mm Hg 

or less at 20oC 

(68oF) or 

solvent 

reclamation 

system 

openings and, if necessary, openings to avoid excessive pressure build-up inside the container. The discharged solvent from the equipment must be collected into containers without atomizing into the open air. The solvent may be flushed through the system by air or hydraulic pressure, or by pumping. 

3. Use a collection and control system that collects at least 90 percent of 

the emissions and reduces VOC emissions by at least 95 percent or has an outlet concentration less than 50 ppmw (as carbon) 

United States 

Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC 

Publication N