TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendments to — COMAR 26.11.19.07 and New 

Regulation COMAR 26.11.19.07-2 Plastic Parts and 

Business Machines Coating

Purpose of Regulation 

The purpose of this action is to adopt the requirements of the EPA’s Control Techniques 

Guidelines (CTG) for miscellaneous metal and plastic parts coating. Existing standards 

for plastic parts and vinyl in COMAR 26.11.19.07 are being moved to COMAR 

26.11.19.07-2. EPA develops CTGs as guidance on control requirements for source 

categories. States can follow the CTGs or adopt more restrictive standards. MDE 

proposes to adopt new standards that will be set for business machines and plastic parts 

that are equivalent to the VOC content limits in the CTG. Application method and work 

practice requirements will also be adopted. These amendments affect coaters of business 

machines and plastic parts and products. 

Background 

EPA developed the CTG after reviewing the 1978 CTG, the 1988 NSPS for Surface 

Coating of Plastic Parts for Business Machines (40 CFR 60 Subpart TTT), the 1994 ACT 

for Surface Coating of Automotive/Transportation and Business Machine Plastic Parts, 

National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal Parts 

and Products 40 CFR 63 Subpart MMMM, and existing State and local VOC emission 

reduction approaches. The 1994 ACT provided analysis and options for alternative 

control technologies available for VOC emissions from the surface coating of plastic 

parts in the automotive and other transportation equipment and business machine 

industries without any recommendations for standards. The plastic parts and products 

category includes components that are used in fabricated metal products, small and large 

farm machinery, commercial and industrial machinery and equipment, automotive or 

transportation equipment, interior or exterior automotive parts, construction equipment, 

motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, 

pleasure craft (recreational boats), extruded aluminum components, railroad cars, heavier 

vehicles, lawn and garden equipment, business machines, laboratory and medical 

equipment, electronic equipment, and other industrial and household products. 

The plastic parts and products and business machines coating categories do not include 

coatings that are a part of other product categories listed under Section 183(e) of the Act 

for which CTGs have been published or included in other CTGs. 

California has implemented standards for plastic parts and products and business 

machines for several categories of coatings. The standards have undergone revisions 
based on reviews of industry practices and capabilities and have been reviewed by EPA 

as part of the basis for establishing the CTG. 

Several different types of application technologies are used to apply liquid coatings, and 

the selection of the application technology can have a significant effect on the amount of 

coating used and the resulting VOC emissions from the operation. The CTG requires that 

coatings can only be applied by coating applicators such as: air atomized spray coating, 

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

flow coating, roll coating, electrocoating,and autophoretic coating. Powder coatings can 

be applied through electrostatic spraying or dipping. 

Cleaning activities other than surface preparation also occur at plastic parts and business 

machines and components coating facilities. Additional requirements for cleaning 

materials and activities are covered under COMAR 26.11.19.02(I). 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 VOC containing solvents. 

Regulation Amendments

COMAR 26.11.19.07-2 is proposed to set VOC coating standards for a variety of plastic 

parts coating and business machine coating applications and includes plastic parts and 

vinyl coating standards and printing standards from the existing COMAR 26.11.19.07. 

Application methods for coatings are limited to: 

(1) Electrostatic application; 

(2) HVLP spray; 

(3) Flow coat; 

(4) Roller coat; 

(5) Dip coat including electrodeposition; 

(6) Brush coat; or 

(7) A coating application method capable of achieving a transfer efficiency equivalent to 

or better than the efficiency achieved by HVLP spraying. 

Sources Affected 

These proposed amendments affect coaters of plastic parts and products used in farm 

machinery, industrial machinery, automotive or transportation equipment, structural 

components, laboratory, medical and electronic equipment, motor vehicle accessories, 

bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational 

boats), railroad cars, heavier vehicles, lawn and garden equipment and business 

machines. 
Technology and Standards 

Development and application of lower VOC content coatings, powder coatings, higher 

solids coatings and waterborne coatings have reduced the organic solvent content of the 

coatings for plastic parts and business machine components. Work practice standards and 

procedures control fugitive VOC emissions. Higher transfer efficiency also reduces VOC 

emissions. 

Availability of powder coatings, waterborne coatings, higher solids coatings, UV 

coatings, electrocoatings, and autophoretic coatings has played a significant role in the 

establishment of standards and requirements. For certain performance requirements, 

conventional coatings or coatings with higher VOC content may be needed. With 

continued research and development new materials are undergoing tests to match the 

performance characteristics of conventional coatings. 

Work practice procedures are inherently specific to the industry, and can vary 

significantly in terms of requirements. COMAR 26.11.19.02 includes elements of work 

practice requirements suitable for plastic parts and business machine components. 

High atomizing air pressure method of application has transfer efficiency of 25 to 40 

percent. High volume low pressure atomization can achieve transfer efficiency of 65 

percent depending on shape, size and substrate. Electrostatic spraying achieves transfer 

efficiency of 90 percent or more. 

VOC emissions from plastic parts and business machines component surface coating 

operations can be reduced by the use of capture and control systems. These systems are 

rarely used as most operations are conducted in the spray booths that significantly dilute 

air for safety standards to reduce the flammability of the mixture. The low VOC 

concentration makes the control systems not cost effective. An effective system captures 

emissions and minimizes the capture of dilution air. 

Plastic parts and products and business machines coating operations use combustion, 

catalytic oxidation, adsorption and absorption devices. Combustion and catalytic 

oxidation systems are capable of achieving 95% control efficiency. Catalytic oxidation 

systems are capable of operating at lower temperatures. Energy consumption can be 

reduced by preheating the air with the help of regenerative or recuperative systems and 

primary and secondary heat recovery to reduce energy consumption. 

Commonly used adsorption systems are based on activated carbon with regenerable fixed 

beds. Such systems use imbalances of molecular forces on the surface of solids to adsorb 

VOCs and may use not only activated carbon but also organic resin polymer, and 

inorganic materials. 

Control efficiencies of adsorption systems are greater than 95 percent. Regeneration of 

carbon is done with the help of steam and is particularly effective for immiscible 

solvents. 
Absorption systems use liquid to dissolve and control the VOCs from the effluent. Such 

systems are rarely used for coating operations. 

Expected Emissions Reductions 

The proposed amendments set standards for coatings, application methods and work 

practices. Emissions of VOCs from plastic parts and products and business machines 

coating are expected to be reduced by 35 percent (nationally a reduction of 7,034 Mg/yr 

(7,738 tpy) of VOC) from the nonattainment area facilities above the recommended 6.8 

kg/day (15 lb/day) threshold). The maximum benefit will be provided during the ozone 

season when VOCs readily combine with NOx to from the pollutant ground level ozone. 

Health Effects and Ground-Level Ozone 

The maximum benefit from these amendments will be provided during the ozone season 

when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

The proposed new regulation adopts the requirements of the CTG for plastic parts and 

products and business machines. EPA estimated the economic impact of this regulation 

on a national level. Cost effectiveness is approximately $1,800/ton of VOC controlled. 

Revision to Maryland's SIP 

This action will be submitted to the U.S. EPA for approval as a revision to Maryland's 

State Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal reasonably available control technology standards for 

this category. Multiple facilities are covered under this CTG and each may be subject to 

additional federal requirements.

Comparison to Federal Standards 

There is a corresponding federal standard to this proposed action, but the proposed action 

is not more restrictive or stringent. 

References

Control Techniques Guidelines: Miscellaneous Metal and Plastic Parts Coatings EPA453/R-08-003 September 2008