Technical Support Document 

Department of the Environment 

Amendments and 

New Adhesives and Sealants Regulations

Background 

 Adhesives, sealants, adhesive primer, and sealant primer are used in manufacturing, 

packaging, construction, and installation of disparate materials such as metal, wood, rubber, 

plastic, ceramics, fiberglass and composites. An adhesive is any material used to bond two 

surfaces. A sealant is a material with adhesive properties that is used primarily to fill and seal 

durably, openings between two surfaces. Volatile organic compound (VOC) emissions result 

from evaporation of solvents during surface preparation, transfer, application, drying and 

cleaning operations. The solvents are mostly needed to solubilize the adhesive, sealant, or primer 

material for application. The solvents prepare the surface to provide a stronger bond. In plastic 

pipe bonding, the solvent dissolves the polyvinyl chloride pipe and reacts with the pipe to form a 

bond. Solvents used to clean the surface before bonding and to clean the application equipment 

after bonding also contribute to VOC emissions. VOC emissions from adhesives and sealants are 

primarily from industrial and commercial operations such as general manufacturing, wood 

product manufacturing, upholstery shops, adhesives retailers and architectural trades, such as 

building construction, floor covering installation and roof repair. 

 

COMAR 26.11.19.15 Paint, Resin, and Adhesive Manufacturing and Adhesive 

Application, has standards for honeycomb core manufacturing, footwear manufacturing and 

spiral tube impregnating operations. Under COMAR 26.11.19.15C(4), General Emission 

Standards, up to 50 pounds per day of VOC emissions are allowed. A source that emits 50 

pounds or more of VOC emissions must meet 3.8 pounds per gallon VOC limit or 80 percent 

overall control requirements. The Ozone Transport Commission (OTC) model rule for adhesives 

and sealants applies to the sources that are covered by the general emission standards. 

 COMAR 26.11.19.30 Control of Volatile Organic Compounds from Chemical 

Production and Polytetrafluoroethylene Operations contains requirements for the control of 

emissions from installations and also exempts small source emissions from controls. Under this 

regulation, different control requirements apply if the emissions exceed either 20 or 50 lbs/day. 

At higher than 20 lbs/day emission level, a VOC standard becomes applicable. Above 50 

lbs/day, controls are required to be installed. 

Purpose of Amendments and New Regulations 

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 The primary purpose of this action is to: 1) amend COMAR 26.11.19.15 Paint, Resin, 

and Adhesive Manufacturing and Adhesive Application and remove Section C(4) of this 

regulation; 2) amend COMAR 26.11.19.30 Control of Volatile Organic Compounds from

Chemical Production and Polytetrafluoroethylene Operations to apply the regulations to fluoro 

polymer materials and exempt very small operations that emit less than 400 pounds a year from

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Martin O’Malley, Governor | Anthony G. Brown, Lt. Governor | Shari T. Wilson, Secretary 
adhesive application; and 3) propose new regulations under COMAR 26.11.35 Control of VOC 

Emissions from Adhesives and Sealants. The OTC 2006 model rule for adhesives and sealants is 

based on the reasonably available control technology (RACT) and best available retrofit control 

technology (BARCT) determination by the California Air Resources Board (CARB) developed 

in 1998. The proposed regulations have the following requirements: 

A. Regulate the application of adhesives, sealants, adhesive primers and sealant 

primers by providing options for appliers to either use a product with a VOC content equal to or 

less than a specified limit or to use add-on controls; 

B. Standards for adhesives and sealants; 

C. Standards for adhesive and sealant primers; 

D. Standards for adhesives applied to listed and other substrates; 

E. Standards for cleanup solvents; 

F. A VOC limit for surface preparation solvents; 

G. An alternative add-on control system requirement of at least 85 percent overall 

control efficiency (capture and destruction), by weight; 

H. Provide exemptions for certain operations such as medical, aerospace 

components, undersea-based ship and weapons systems components, electronic systems and 

subsystems for defense and homeland security and small containers; 

I. Require records of materials used and VOC content to be maintained for 5 years. 

J. VOC containing materials must be stored or disposed of in closed containers; 

K. Prohibit the sale of any adhesive, sealant, adhesive primer or sealant primer 

which exceeds the VOC content limits; 

L. Manufacturers must label containers with the maximum VOC content as supplied, 

as well as the maximum VOC content on an as-applied basis when used in accordance with the 

manufacturer’s recommendations regarding thinning, reducing, or mixing with any other 

VOC containing material; and 

M. Prohibit the specification of any adhesive, primer, or sealant that violates the 

provisions of the proposed regulations. 

Exemptions 

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Several adhesive and sealant applications and products are exempt from the proposed 

regulations: tire repair, assembly and manufacturing of undersea-based ship and weapons 

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Martin O’Malley, Governor | Anthony G. Brown, Lt. Governor | Shari T. Wilson, Secretary 
systems components, specialty electronic systems and subsystems for defense and homeland 

security, testing and evaluation associated with research and development, solvent welding 

operations for medical devices, plaque laminating operations, products or processes subject to 

other State rules, low-VOC products (less than 20 g/l), and small container adhesives subject to 

the consumer products regulations. Additionally, the proposed regulations provide an exemption 

for adhesive application operations at stationary sources that use less than 55 gallons per 

calendar year of noncomplying adhesives and for stationary sources that emit not more than 200 

pounds per calendar year of VOCs. A facility can claim exemption for one of the two options, 

granted that the facility meet the requirements. Adhesives and sealants used by contractors at a 

facility that do not meet the standards have to be included in this total for exemption. This 

exemption has been retained to allow facilities limited use of adhesives and sealants that do not 

meet the standards for specific purposes. Additionally, small containers are exempt from the 

regulations as they are regulated under the consumer products regulations and are mostly used by 

homeowners and not commercial, industrial or institutional operations. 

Sources that are subject to the requirements of COMAR 26.11.19.15C(4) General 

Emission Standards and will be exempt from the requirements of COMAR 26.11.35 after the 

regulations become effective would have to meet the RACT requirements as established by the 

Department. RACT requirements will be developed for specialty electronics systems and 

subsystems for defense and homeland security. Facilities that fall under SICs for electronic 

systems such as 3671, 3672, 3812 and 3825 will be covered under the review. 

Consumer products regulated under COMAR 26.11.32 have standards for adhesives and 

sealants in small containers that are exempt from COMAR 26.11.35. 

Medical devices subject to COMAR 26.11.19.31 Control of Medical Device 

Manufacturing are exempt from the requirements of COMAR 26.11.35 since they already meet 

the RACT requirements in COMAR 26.11.19.31. 

Affected Sources 

The proposed regulations apply to any person who, on or after January 1, 2009, sells, 

supplies, offers for sale or manufactures for sale in the State any adhesive, sealant, adhesive 

primer or sealant primer for use in the State. They also apply to any person who uses or applies 

for compensation any adhesive, sealant, adhesive primer or sealant primer within the State. 

Sources subject to COMAR 26.11.19.30 Control of Volatile Organic Compounds from 

Chemical Production and Polytetrafluoroethylene Operations are exempt from COMAR 

26.11.35. RACT requirements for these operations are in COMAR 26.11.19.30 along with the 

exempt operations such as the ones that emit less than 400 pounds a year from adhesive 

application. These sources have to meet the requirements of the regulations for the general 

application of adhesives and sealants. 

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Medical devices subject to COMAR 26.11.19.31 Control of Medical Device 

Manufacturing are exempt from the requirements of COMAR 26.11.35 since they already meet 

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Martin O’Malley, Governor | Anthony G. Brown, Lt. Governor | Shari T. Wilson, Secretary 
the RACT requirements in COMAR 26.11.19.31. Requirements of COMAR 26.11.35 apply for 

general uses of adhesives and sealants. 

 Sources that are subject to the requirements of COMAR 26.11.19.15C(4) General 

Emission Standards and are exempt from the requirements of COMAR 26.11.35 after the 

regulations become effective would have to meet the RACT requirements. 

Record Keeping Requirements 

Record keeping requirements include VOC content data, purchase records and quantity 

used for compliant products, research and development and for 55 gallon usage exemption. More 

detailed records are required when non-compliant products are used for the 200 pounds per year 

exemption. These limits apply facility wide. Adhesives and sealants used by contractors at a 

facility need to be included in the total estimate of the facility. Work conducted by contractors 

independently is accounted for in the total for the contractor. If emissions exemption is being 

used, it will be necessary to keep the detailed records to justify compliance. 

Control Technology 

VOC emissions from industrial adhesives and sealants can be controlled by reformulation 

of adhesives, sealants, and cleanup solvents. If reformulation is not feasible then the use of addon control is required. Reformulation is a significantly more cost-effective control method for 

VOC emissions from adhesives and sealants than add-on controls. Reformulation requires either 

an increase in the solids content or replacement of VOCs with water or exempt solvents. The 

RACT VOC limits for adhesives and sealants are based on products that have been used for 

application in the industry. Low-VOC and water-based adhesives sometimes require additional 

drying time, additional equipment and special technical requirements. The low-VOC and waterbased adhesives may have slightly different performance characteristics. To meet certain 

performance characteristics, some applications may require the use of add-on control equipment 

to continue using noncomplying products. The most commonly used methods of controlling 

VOCs are carbon adsorption and incineration. Control equipment is required to meet an 85 

percent overall control efficiency, which is the product of capture and destruction efficiency. 

Carbon adsorption and incineration systems achieve high control efficiencies but have large 

capital and operating costs. 

Emissions Estimates and Reductions 

 EPA's 2002 inventory is documented in "Solvent Mass Balance Approach for Estimating 

VOC Emissions from Eleven Nonpoint Solvent Source Categories." The methodology for 

industrial adhesives is described in this report. Appendix E, page E-7, shows that the 2002 VOC 

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emissions for Maryland to be 6.65 tons/day for industrial adhesives and sealants. This is the 

value used as the starting point. The 2002 emissions were projected to 2009 taking into account 

anticipated employment and population growth. The growth factor for emissions was taken into 

account, and the 2009 VOC emissions from Maryland industrial adhesives were calculated to be 

7.26 tons/day. 

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Martin O’Malley, Governor | Anthony G. Brown, Lt. Governor | Shari T. Wilson, Secretary 
The technical analysis conducted through the OTC estimated that the model rule would 

achieve emission reductions corresponding to about 64 to 78 percent reduction from uncontrolled 

levels. The emission reduction estimate for Maryland based on the lower end of this range is 5.66 

tons/day of VOC in 2009. 

Economic Impact 

 The cost of complying with the new requirements includes the cost of using alternative 

formulations of low-VOC or water-based adhesives, sealants, adhesive primers, and sealant 

primers and cleanup products. CARB determined that the cost-effectiveness of their adhesives 

regulations ranges from a savings of $1,060 per ton to a cost of $2,320 per ton of VOC reduced. 

These costs are likely to be less in this region because some of the costs are one-time research 

and reformulation costs that have already been incurred by manufacturers for products sold in 

California. CARB also estimates a cost-effectiveness of $9,000 to $110,000 per ton of VOC 

reduced for the use of add-on control equipment to comply. 

L:\AQPlanning and Monitoring\Regulation Development Division\Model Rules\Adhesives and 

Sealants\TSD\26-11-35 A&S TSD 12-12-07.doc 

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Martin O’Malley, Governor | Anthony G. Brown, Lt. Governor | Shari T. Wilson, Secretary 

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