PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

RULE 235

ADHESIVES

PROPOSED RULE AMENDMENTS

October 11, 2012
Staff Report – Revision to Rule 235

September 11, 2012

Page 2

BACKGROUND

The Placer County Air Pollution Control District (District) jurisdiction is Placer County. Placer 

County is located in northern California, bordering Sacramento County to the west and the State 

of Nevada on the east. Placer County is divided into three different air basins: the Sacramento 

Valley Air Basin (SVAB); the Mountain Counties Air Basin (MCAB); and the Lake Tahoe Air Basin 

(LTAB). The portions of Placer County in the SVAB and MCAB are included in the Sacramento 

Federal Ozone Non-Attainment Area (SFONA). The` SFONA has been classified as “severe” 

non-attainment for the National Ambient Air Quality Standard (NAAQS) for eight-hour ozone, as 

well as non-attainment with the State of California Ambient Air Quality Standard for ozone. The 

U.S. Environmental Protection Agency’s (EPA) Phase 2 Ozone Rule – contained in 40 CFR 

51.912 and 70 FR 71612, in accordance with Clean Air Act (CAA) Amendments of 1990, Sections 

182(b)(2) and 182(f) – requires that areas that are classified as moderate non-attainment or 

higher must demonstrate in a State Implementation Plan (SIP) that their rules fulfill Reasonably 

Available Control Technology (RACT) requirements for volatile organic compound (VOC) and 

nitrogen oxides (NOx) which are ozone precursors. The implementation of RACT requires, at a 

minimum, District rules covering source categories with RACT guidance documents, which 

include all EPA-issued Control Technique Guidelines (CTG’s), where there are such sources that 

operate in the District.

District Rule 235, Adhesives, limits VOC emissions from adhesive and sealant products 

application and associated solvent cleaning operations. The Rule was originally adopted on June 

8, 1995, and approved into the SIP on July 18, 1996 (61 FR 37390). Rule 235 was later

amended on April 10, 1997, and last amended on April 8, 2004. Neither of these rule versions 

has been approved into the SIP. In September 2008, the EPA issued a CTG for Miscellaneous 

Industrial Adhesives (EPA-453/R-08-005). The 2004 version of our Rule did not meet all the CTG 

requirements, as per EPA’s comments received by the District on August 31, 2010. Thus, the 

District is proposing amendments to Rule 235 to meet RACT SIP obligations through 

implementation of all CTG requirements.

The proposed Rule amendments affect all those who buy, sell, offer to sale, or apply adhesive, 

adhesive primer, sealant and sealant primer products within the District. This includes a wide 

range of businesses, wholesale and retail stores, individuals, and permitted stationary sources.

Additionally, the District has one (1) permitted non-major source in the category of Adhesives

manufacturing. The business name for this source is:

• H.B. Fuller Company

DISCUSSION

Rule 235 amendments were made based on: (1) EPA’s 2008 CTG for adhesives; (2) EPA’s

comments that were received on August 31, 2010, in response of our submittal of the current 

April 2004 version of Rule 235 for SIP approval; and (3) Establishment of consistency with other 

local Air Districts’ adhesives and sealants rules.

The District reviewed Adhesives and Sealants Rules of other local Air Districts, including:

• El Dorado, Rule 236, Adhesives, last amended on July 25, 1995. 

• Sacramento, Rule 460, Adhesives and Sealants, last amended on November 11, 2000.

• San Joaquin, Rule 4653, Adhesives and Sealants, last amended on September 16, 2010.

• Yolo-Solano, Rule 2.33, Adhesive Operations, last amended May 14, 2008.
Staff Report – Revision to Rule 235

September 11, 2012

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We also reviewed rules from:

• San Diego, Rule 67.21, Adhesive Material Application Operations, last amended on May 

14, 2008.

• South Coast, Rule 1168, Adhesive Material Application Operations, last amended on 

January 7, 2005.

These Districts are designated as non-attainment areas for the Federal national ambient air 

quality standard for ozone. Thus, they also are required to implement CTGs in their rules.

Proposed Rule amendments, in underline/strikeout format, are shown in Attachment #1. Specific 

changes to the Rule include:

Section 100. General

Section 102. Applicability. Subsections 102.1 and 102.2 are consolidated into one section. 

Section 104.2 Exemptions. The exemption for contact adhesives is modified to be 

consistent with the requirements of the EPA Consumer Product Safety Commission 

regulations contained in the U.S. Code of Federal Regulations, Title 16, Part 1302. Additions 

include a flash point requirement and clarification that the exemption only applies to 

consumer products contact adhesives that are used at a home, construction site, or at any 

location other than a stationary source.

Section 104.8. Exemptions. An exemption is added to exclude all adhesive materials that 

fall under other District rules.

Section 200. Definitions

Definitions that are eliminated include: Aerosol adhesive primer, Low-volume low-pressure 

(LVLP) application equipment, PolyVinyl Chloride (PVC) welding sealant, Volatile organic 

compound (VOC) as applied, Volatile organic compound (VOC) as supplied. Additionally, 

Solvent Welding definition is mistakenly listed twice; therefore, one of the definitions was 

deleted.

Definitions that are added include: Airless spray, Ethylene propylene diene monomer 

(EPDM), Motor vehicle, Motor vehicle adhesive, Motor vehicle weatherstrip adhesive, 

Perimeter bonded sheet flooring installation adhesive, Plastic foam, Reinforced plastic 

composite, Single-ply roof membrane adhesive, Single-ply roof membrane adhesive primer, 

Single-ply roof membrane sealant, Sheet rubber lining installation, VOC content, Indoor 

carpet adhesive, VCT and asphalt tile adhesive, Structural wood member adhesive, Rubber 

vulcanization bonding, Top and trim adhesive.

Definitions that are amended include: Adhesive, Architectural sealant/primer, Aerosol 

adhesive or Adhesive primer, Aerosol cleaning solvent, Contact adhesive, Cyanoacrylate 

adhesive, High-volume low-pressure (HVLP) application equipment, Household adhesive, 

Key system operating parameter, Indoor floor covering installation adhesive, Plastic cement 

welding adhesive, Porous material, Single-ply roof membrane.

Section 300. Standards

Section 301. Material Application Methods. Changes to the section include: 
Staff Report – Revision to Rule 235

September 11, 2012

Page 4

• Subsection 301.1.8, Low-volume low-pressure (LVLP), is removed because it is not 

allowed by the CTG.

• Subsections 301.1.10, 301.1.11, and 301.1.12 are consolidated into one subsection. 

Additionally, allowing the use of those methods for adhesives and sealants product 

with viscosity of 200 centipoise or greater is added.

Section 302. VOC Content Limits. Changes to the section include: 

• The following new adhesives sub-categories, and appropriate VOC content limits, is

added, used by the CTG and/or other Air Districts rules:

- Indoor Carpet or Carpet Pad

- Rubber Flooring

- Subfloor Installation

- VCT and Asphalt Tile Installation

- Structural Wood Member Glazing

- Rubber Vulcanization Bonding

- Motor Vehicle

- Motor Vehicle Weatherstrip

- Top and Trim

- Ceramic Tiles

- Dry Wall and/or Panel

- Plastic Foam

- Wood

- Reinforced Plastic Composite

• PVC Welding Sealant sub-category and VOC content limit is eliminated. The limit 

expired on April 8, 2002. This product is now included in the “other” sub-category. 

• Adhesive primers sub-categories – Automotive Glass, Plastic Cement Welding, 

Single-Ply Roof Membrane, Traffic Marking Tape, and Other – as listed in Table 302-

2 are moved to Table 302-1. Table 302-2 is deleted.

• Contact adhesive sub-categories as listed in Table 302-3 are moved to Table 302-1. 

Table 302-3 is deleted.

• Sealant sub-categories – Architectural, Marine Deck, Non-membrane Roof 

Installation/Repair, Roadway Sealant, Single-Ply Roof Membrane Sealant, and Other 

– as listed under Table 302-4 are moved to Table 302-1. Table 302-4 is deleted.

• Sealant primers categories – Architectural-Non-Porous, Architectural–Porous, Marine 

Deck, and Other, listed in Table 302-5 are moved to Table 302-1. Table 302-5 is

deleted.

• A few VOC content limits that were provided in pounds per gallon are corrected.

Section 303. Content Limits, Aerosol Adhesives and Adhesive Primers. The title of this 

section is changed to VOC Content Limits for Aerosol Adhesives. Aerosol Adhesive Primers

are eliminated from the title since there are no applicable VOC content limits for aerosol 

adhesives primers. Also, the following has been added to cite the origin of the standards 

provided for aerosol adhesives: “in the Air Resources Board consumer products regulation 

found in Title 17 of the California Code of Regulations, sections 94507 – 94517, and listed.” 
Staff Report – Revision to Rule 235

September 11, 2012

Page 5

Section 304. VOC Content Limits, Surface Preparation, Cleanup and Stripping Solvents. 

Changes to this section include:

• The sub-category titles are modified to add clarity. 

• The VOC content limit of Electronic Components and Medical Devices subcategories are revised to be as stringent as that for the same sub-categories in 

District Rule 240, Surface Preparation and Cleanup.

• The VOC content for Soaking Application Equipment in a Closed Container subcategory was corrected to 9.5 instead of .5 Partial Pressure Millimeters of Mercury at 

20°C. The 9.5 mm Hg composite partial pressure limit was the maximum allowable 

limit for this sub-category in our 1995 version of the Rule that was approved into the 

SIP on July 18, 1996. Therefore, the .5 mm Hg is believed to be a mistake occurred 

during the last amendment process of the Rule in 2004.

Section 305. Work Practices for Adhesive Products, Sealant Products and Solvent Cleaning

Materials. New provisions have been added for work practices requirements to meet those 

contained in the CTG.

Section 400. Administrative Requirements

Section 404. Operation and Maintenance Plan. This section is moved to Section 306.3. 

Section 405. Calculation for Determining VOC Content of Material Excluding Water and 

Exempt Compounds. This section is moved to Subsection 290.1.

Section 406. Calculation for Determining VOC Content of Material Including Water and 

Exempt Compounds. This section is moved to Subsection 290.2.

Section 407. Calculation of Percent of VOC by Weight. This section is moved to Subsection

290.3. 

Section 403. Labeling Requirements for Aerosol Adhesives. This section is moved to 

Section 405.

Section 403. HVLP Marking. New requirements for HVLP marking are added to Section 403. 

Section 409. Calculation for VOC Composite Partial Pressure. This section is moved to 

Section 288.

 

Section 410. Product Information Requirements for Sellers. The title of this section is

changed to Labeling Requirements, and new provisions are added to this section.

Section 500. Monitoring and Record

Section 502.5. Determination of Control Efficiency. Test methods to measure emissions of 

exempt compounds are added.

Section 502.12. Determination of Viscosity. Test methods to measure viscosity of adhesives 

are added. 

Further, applicable test methods references are updated to the most approved current 

versions.
Staff Report – Revision to Rule 235

September 11, 2012

Page 6

Miscellaneous

Additional miscellaneous changes are made for readability and conformance with the CTG

which have no impact on the compliance requirements of the Rule.

ANALYSIS

The following Analysis and the subsequent Findings are intended to address the requirements set 

forth in the California Health and Safety Code relating to adoption of a new or amended District Rule, 

as well as other State statutes referenced herein.

1. Cost-Effectiveness of a Control Measure

California Health & Safety Code (H&S) Section 40703 requires a District to consider and 

make public “the cost-effectiveness of a control measure”. The compliance costs of the 

proposed rule amendments are associated with purchasing adhesives and sealant products 

with complaint VOC content limits and meeting new work practices. Products that meet

proposed adhesive and sealant VOC content limits are well-established to be readily 

available at the same price points as adhesives products that will become non-complaint 

when the proposed amendments will become effective on October 11, 2013. Thus, staff 

concludes there will be no significant adverse impacts on the profitability of business 

affected by the Rule. The cost effectiveness is acceptable by the EPA and other Air Districts 

that have already implemented the CTG requirements.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic 

impact of any new or amended rule if air quality or emission limits are significantly affected. 

Numerous existing adhesive operations are already operating in compliance with the 

amended rule standards.

3. Environmental Review and Compliance

California Public Resources Code Section 21159 requires an environmental analysis of 

the reasonably foreseeable methods of compliance should be conducted. Compliance of 

the proposed rule amendment is expected to be achieved by the replacement of current 

coating products with compliant compounds. Application of these compliant compounds 

will generally result in less VOC emissions from the coating activities. Therefore, the 

proposed rule amendment will reduce emissions from sources and will not cause any 

significant adverse effects on the environment. Staff has concluded that no adverse 

environmental impacts will be caused by compliance with the proposed rule amendment.

According to the above conclusion, Staff finds that the proposed rule amendment is 

exempt from the California Environmental Quality Act (CEQA) because: (1) it can be 

seen with certainty that there is no possibility that the activity in question may have a 

significant adverse effect on the environment (CEQA Guidelines §15061(b)(3)), and (2) it 

is as an action by a regulatory agency for protection of the environment (Class 8 

Categorical Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity: The adoption of proposed amended Rule satisfies the objective of the District 

to implement “Control Technique Guidelines” for the reduction of VOCs to achieve

attainment with ambient air standards for ozone, and meets the District’s requirements to 

implement “every feasible measure” and “Best Available Retrofit Control Technology” as 

required under California Health and Safety Code Sections 40919 and 40914.
Staff Report – Revision to Rule 235

September 11, 2012

Page 7

B. Authority: California Health and Safety Code, Sections 40000, 40001, 40701, 40702, 

40716, 41010, and 41013, are provisions of law that provide the District with the authority 

to adopt this proposed amended Rule.

C. Clarity: There is no indication, at this time, that the proposed amended Rule is written in 

such a manner that persons affected by the Rule cannot easily understand them.

D. Consistency: The proposed amended Rule is in harmony with, and not in conflict with or 

contradictory to, existing statutes, court decisions, or state or federal regulations.

E. Non-duplication: The proposed amended Rule does not impose the same requirements 

as an existing state or federal regulation.

F. Reference: All statutes, court decisions, and other provisions of law used by the District

in interpreting this proposed amended Rule are incorporated into this analysis and this 

finding by reference.

SUMMARY

Rule 235, Adhesives, has been amended to address control guidance contained in the U.S. EPA’s CTG

for Miscellaneous Industrial Adhesives issued in 2008 (EPA-453/R-08-005).
ATTACHMENT #1

Subject:

Proposed Amended Rule 235, Adhesives

(Strikeout copy)