1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: July 19, 2011

SUBJECT: Technical Support Document for Maryland’s Adoption of Plastic Parts and 

Business Machines Coating Standards

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) 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 

sources of volatile organic compound (VOC) emissions covered by a control techniques 

guidelines (CTG) document issued after November 15, 1990 and prior to the area’s 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. 

CTGs are intended to provide state and local air pollution control authorities information that 

should assist them in determining RACT for VOCs from various sources, including 

miscellaneous metal product and plastic parts surface coating operations. In developing these 

CTGs, EPA, among other things, evaluated the sources of VOC emissions from this 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 VOCs from miscellaneous metal product and plastic parts surface coating.

In June 1978, EPA published a CTG for controlling VOC emissions from surface coating of 

miscellaneous metal and plastic products (EPA-450/2-78-015). This CTG discusses the nature 
2

of VOC emissions from this industry, available control technologies for addressing such 

emissions, the costs of available control options, and other items. EPA also published a national 

emission standard for hazardous air pollutants (NESHAP) for surface coating of miscellaneous 

metal parts and products surface coating (40 CFR part 63, subpart MMMM) and a NESHAP for 

plastic parts and products surface coating in 2004 (40 CFR 63, subpart PPPP).

In 2008, after conducting a review of currently existing state and local VOC emission reduction 

approaches for this industry, reviewing the 1978 CTG and the NESHAP for this industry, and 

taking into account the information that has become available since then, EPA developed a new 

CTG for surface coating of miscellaneous metal and plastic parts products, entitled Control 

Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (Publication No. 

EPA 453/R-08-003).

Description of Miscellaneous Metal and Plastic Parts Coatings

The miscellaneous metal product and plastic parts surface coatings categories under section 

183(e) of the CAA includes the coatings that are applied to the surfaces of a varied range of 

metal and plastic parts and products. Such parts or products are constructed either entirely or 

partially from metal or plastic. The CTG applied to manufacturers of miscellaneous metal and 

plastic parts that surface-coat the parts they produce. The CTG also applies to facilities that 

perform surface coating of miscellaneous metal and plastic parts on a contract basis. 

Miscellaneous metal product and plastic parts surface coatings serve decorative, protective, and 

functional purposes. Coatings protect metal parts from corrosion by providing resistance to 

moisture, heat, and sometimes the outdoor elements. Plastic parts may be coated to provide 

color, texture, or protection, thus improving appearance and durability, and can also function to 

attenuate electromagnetic interference/radio frequency interference signals, and to conceal mold 

lines and flaws in substrate surface.

The miscellaneous metal product and plastic parts surface coating process may be divided into 

three main unit operations: (1) surface preparation, (2) coating application operations, and (3) 

cleaning activities. These three types of activities utilize VOC-containing compounds (i.e., 

coatings, thinners, and/or cleaning materials). The CTG provides control recommendations for 

reducing VOC emissions from the use of these activities. 

The VOC emissions from miscellaneous metal product and plastic parts surface coating 

processes result from the evaporation of the volatile components of the coatings and cleaning 

materials used in these operations. In most cases, VOC emissions from surface preparation, 

storage, handling, and waste/wastewater operations are relatively small. 

EPA’s Recommended Control Options for Miscellaneous Metal and Plastic Parts Coatings

EPA issued a CTG for miscellaneous metal and plastic parts coatings in September 2008

(Publication No. EPA 453/R-08-003). EPA recommends that the control approaches outlined 

below apply to each miscellaneous metal product and plastic parts surface coating unit at a 
3

facility where the total actual VOC emissions from all miscellaneous metal product and plastic 

parts surface coating operations, including related cleaning activities, at that facility are equal to 

or exceed 6.8 kilograms (kg)/day (15 pounds (lbs)/day), or an equivalent level of 2.7 tons per 12-

month rolling period, before consideration of controls. 

The Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings

document recommends emission limits for various metal and plastic coatings and those emission 

limits that apply to this particular State Implementation Plan (SIP) revision are as follow:

Table 1. VOC Content Limits

Plastic Parts Coatings

Coating Category kg VOC/liter coating lbs VOC/gallon coating

General One Component 0.28 2.3

General Multi Component 0.42 3.5

Electric Dissipating Coatings 

and Shock-Free Coatings

0.80 6.7

Extreme Performance 0.42 (2-pack coatings) 3.5 (2-pack coatings)

Metallic 0.42 3.5

Military Specification 0.34 (1 pack)

0.42 (2 pack)

2.8 (1 pack)

3.5 (2 pack)

Mold-Seal 0.76 6.3

Multi-Colored Coatings 0.68 5.7

Optical Coatings 0.80 6.7

Vacuum-Metalizing 0.80 6.7

Business Machine Coatings

Primers 0.35 2.9

Topcoat 0.35 2.9

Texture Coat 0.35 2.9

Fog Coat 0.26 2.9

Touchup and repair 0.35 2.9

B. STATE SUBMITTAL

On June 22, 2011, Maryland Department of the Environment (MDE) submitted to EPA a SIP 

revision concerning the adoption of the emission limits for plastic parts and business machines 

coatings, part of the EPA miscellaneous metal and plastic parts coatings CTG. EPA develops 

CTGs as guidance on control requirements for source categories. States can follow the CTGs or 

adopt more restrictive standards. The State of Maryland has adopted EPA’s CTG standards for 

plastic parts and business machine coating processes. These regulations are in COMAR 

26.11.19, Volatile Organic Compounds from Specific Processes. Specifically, this revision 

amends the existing regulation at Section 26.11.19.07 by moving existing VOC coating 

standards for plastic parts and vinyl from Section 26.11.19.07 to new Section 26.11.19.07-2, 

Plastic Parts and Business Machines Coating. Additionally, coating standards for plastic parts 

and business machines from EPA’s CTG are being adopted into COMAR 26.11.19.07-2. Work 

practice procedures for coating can be found in COMAR 26.11.19.02. Specifically, 
4

requirements for cleaning activities can be found in COMAR 26.11.19.02(I) and these have 

previously been approved into Maryland’s SIP.

The following changes are being made to COMAR 26.11.19:

The title of Section 26.11.19.07 is being changed from “Paper, Fabric, Vinyl, and Other Plastic 

Parts” to “Paper, Fabric, Film, and Foil Coating.”

Existing definitions in section 26.11.19.07(A) and standards in Section 26.11.19.07(C)(3) 

pertaining to plastic parts and vinyl are being moved to new Section 26.11.19.07-2.

Section 26.11.19.07-2, entitled Plastic Parts and Business Machines Coatings, is added. The 

following definitions are included in Section 26.11.19.07-2(A), Definitions: business machine, 

business machine coating, electric dissipating coating, extreme performance coating, fog coating, 

metallic coating, military specification coating, mold seal coating, multi-colored coating, multicomponent coating, one-component coating, optical coating, plastic part, plastic part coating, 

prime coat, shock-free coating, standard industrial classification code (SIC code), texture coat, 

touch-up and repair coat, vacuum-metalizing coatings, and vacuum metalizing process.

Section 26.11.19.07-2(B), Standards for Coating Installations, includes VOC emission limits for 

plastic parts coating standards, business machines coating standards, and printing standards (see 

Tables 2-4).

Section 26.11.19.07-2(C), Application Methods, lists the application methods subject to this 

regulation. They are: electrostatic application, high volume low pressure (HVLP) spray, flow 

coat, roller coat, dip coat including electrodeposition, brush coat, or a coating application method 

capable of achieving a transfer efficiency equivalent to or better than the efficiency achieved by

HVLP spraying.

Table 2. Plastic Parts Coating Standards

Coating Installation Applicability (lbs of 

VOC per day)

Pounds of VOC Per 

Gallon of Coating 

(as applied minus 

water)

Kilograms of VOC 

Per Liter of Coating 

(as applied minus 

water)

Decorative coating of 

other plastic parts

20 5.9 0.70

General, onecomponent

15 2.3 0.28

General, multicomponent

15 3.5 0.42

Electric dissipating 

coatings and shockfree coatings

15 6.7 0.80

Extreme 

performance

15 3.5 0.42
5

Metallic 15 3.5 0.42

Military 

specification, onecomponent

15 2.8 0.34

Military 

specification, multicomponent

15 3.5 0.42

Mold seal 15 6.3 0.76

Multi-colored 

coatings

15 5.7 0.68

Optical coatings 15 6.7 0.80

Plastic vehicle parts 20 3.0 0.36

Vacuum-metalizing 15 6.7 0.80

Vinyl 20 3.8 0.45

Table 3. Business Machines Coating Standards

Coating Installation Applicability (lbs of 

VOC per day)

Pounds of VOC Per 

Gallon of Coating 

(as applied minus 

water)

Kilograms of VOC 

Per Liter of Coating 

(as applied minus 

water)

Prime coat 15 2.9 0.35

Topcoat 15 2.9 0.35

Texture coat 15 2.9 0.35

Fog coat 15 2.9 0.26

Touchup and repair 15 2.9 0.35

Table 4. Printing Standards

Printing Installation Applicability (lbs of 

VOC per day)

Pounds of VOC Per 

Gallon of Coating 

(as applied minus 

water)

Kilograms of VOC 

Per Liter of Coating 

(as applied minus 

water)

Plastic other than 

vinyl

Non-major source 5.8 0.69

Plastic other than 

vinyl

Major source as 

defined in COMAR 

26.11.19.01B(4)

3.8 0.45

Vinyl 20 3.8 0.45

C. EPA EVALUATION

MDE has adopted the standards and requirements of the CTG for a variety of plastic parts 

coatings and business machine coating applications and is amending the Maryland SIP to reflect 

these amendments. The maximum benefit from these amendments will be provided during the 

ozone season when VOCs readily combine with nitrogen oxides (NOx) to form ground-level 

ozone. Specifically, emissions of VOCs from plastic parts and products and business machines 
6

coating are expected to be reduced by 35 percent nationally from facilities above the 

recommended 6.8 kg/day threshold as a result of this rulemaking, but because Maryland already 

has regulations in place which have reduced VOC emissions from plastic parts coating, the 

reduction is expected to be less than that on a national level. Nonetheless, this revision will help 

Maryland attain and maintain the National Ambient Air Quality Standards (NAAQS) for ozone. 

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for plastic parts coatings and business machines 

coating standards by the State of Maryland will result in the reduction of VOC emissions from 

plastic parts and business machines coatings. EPA’s approval of the SIP revision is 

recommended.