1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Rule 4653 (Adhesives and Sealants) 

September 16, 2010 

Prepared by: Anna Myers, Air Quality Specialist 

Reviewed by: Colette Kincaid, Senior Air Quality Specialist 

 Joven R. Nazareno, Senior Air Quality Engineer 

 George Heinen, Rule Development Supervisor 

 Michael Carrera, Compliance Manager 

 Errol Villegas, Strategies and Incentives Program Manager 

 Samir Sheikh, Director of Strategies and Incentives 

 

I. SUMMARY 

The purpose of Rule 4653 (Adhesives) is to reduce emissions of VOCs from the 

application of adhesive products and associated solvent cleaning operations. This 

source category includes any person who supplies, sells, offers for sale, or applies any 

adhesive product, or associated solvents, for use within the San Joaquin Valley Air 

Basin (SJVAB). 

The San Joaquin Valley Unified Air Pollution Control District (District) Governing Board 

adopted the Eight-Hour 2007 Ozone Plan (Ozone Plan). One of the commitments 

within the Ozone Plan is to amend Rule 4653 and take those amendments to the 

Governing Board for public hearing and adoption by the third quarter of 2010. However, 

the Environmental Protection Agency (EPA) promulgated a Control Techniques 

Guideline (CTG) for Miscellaneous Industrial Adhesives (EPA-453/R-08-005) in 

September of 2008. Therefore, as required by the Federal Clean Air Act (CAA), the 

District amended Rule 4653 in September 2009 to incorporate CTG requirements. 

Amendments included VOC content limits for certain adhesives categories and new 

requirements for work practices. The effective date of the new VOC content limits 

adopted per the EPA CTG is January 1, 2011. 

The purpose of this rule-amending project is to amend Rule 4653 (Adhesives) to fulfill 

commitments in the Ozone Plan. During this rule-amending project, District staff 

considered the more stringent VOC limits for adhesives currently enforced in other air 

districts, and explored the possibility of the addition of sealant products, to ensure this 

rule is as stringent as other air districts in California. 
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A. Reasons for Rule Development and Implementation 

The EPA and the California Air Resources Board (ARB) classified the SJVAB as 

extreme and severe non-attainment area for federal and state ozone standards, 

respectively. In accordance with CAA requirements for non-attainment areas, the 

District adopted the 2007 Ozone Plan to establish the strategy for attaining the federal 

eight-hour ozone standard. 

The District’s 2007 Ozone Plan includes control measure S-SOL-6 (Adhesives & 

Sealants) as part of the listed VOC control measures. As such, this rule development 

project is subject to the CAA and the California Health and Safety Code (CH&SC) 

requirements. This rule-amendment project will seek to obtain as much VOC emissions 

reduction from the source category as is expeditiously practicable, technologically 

feasible, and economically reasonable, as determined by the District's Governing Board. 

Furthermore, the District intends to satisfy the requirements identified in Table 1 below. 

Table 1 Ozone Plan Commitments

Subject Reference Requirement 

BACM Federal Register 

8/18/94 

Provisions in attainment plans should include the 

application of best available control measures (BACM) 

to existing major stationary sources. 

BARCT CH&SC 40919(a)(3) 

2007 Ozone Plan 

 Ozone attainment plan should provide for best 

available retrofit technology (BARCT) for existing 

permitted sources. - 

Deadlines Ozone Plan Adoption of rule amendments by the 3rd quarter of 

2010. 

Feasible 

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasiblecontrol measures." 

RACT CAA 182(b)(2) and 

182(f) 

Ozone attainment plans shall assure that reasonably

available control technology (RACT) for oxides of 

nitrogen (NOx) and volatile organic compounds (VOC)

is in use at sources and on source categories at or

above the RACT threshold. 

RACT 

Threshold 

70 Federal Register 

30592-30596 

5/26/05 

The applicable RACT threshold for control measures 

shall be the threshold in effect on June 15, 2004. The 

Districts threshold on June 15, 2004 was 10 tons per 

year (tpy) for NOx or VOC. 

Reductions Ozone Plan Emissions reduction will be calculated during the rule 

development process. 

Timeline CAA Section 

172(c)(1) 

Ozone attainment plans shall implement control 

measures as expeditiously as practicable, and provide 

for attainment. 
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B. Climate Change 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce green house gas (GHG) emissions in California, with the 

goal of restoring emissions to 1990 levels by 2020. In the coming years, the ARB and 

the Legislature will be developing policies and programs to implement Assembly Bill 32 

(AB 32). There are many win-win strategies that can reduce both GHG and 

criteria/toxic pollutant emissions. However, the District’s primary mission remains to 

achieve attainment with air quality standards to protect public health. Therefore, when 

situations that involve tradeoffs between GHG and criteria or toxic pollutants arise, the 

District will give precedence to reducing criteria or toxic pollutant emissions due to the 

more immediate public health concerns associated with such pollutants. 

C. Description of Project 

The 2007 Ozone Plan commitment includes pursuing the lowering of the VOC content 

of adhesives to match limits in other air districts, with a 3% reduction of the baseline 

emissions. It is important to note that Rule 4653 was amended in September of 2007 to 

implement new solvent cleaning requirements effective on and after September 2008. 

As such, current solvent cleaning requirements are the most stringent limits in California 

at this time. Therefore, emission reductions will come from more stringent VOC limits 

for adhesives and the addition of sealants and sealant primers to rule language. 

D. Rule Development Process 

As part of the rule development process, District staff conducted two public workshops, 

one on February 11, 2010 and one on July 13, 2010, at which time a draft version of 

Rule 4653 and a draft staff report were available. District staff presented the objectives 

of the proposed rulemaking project, reviewed draft amendments, explained the District’s 

rule development process, solicit suggestions from affected stakeholders on how best to 

achieve the emission reductions, and informed all interested parties about comment 

periods, and the tentative date for the public hearing for the adoption of the draft 

amendments. A two-week public comment period followed each workshop; comments 

received from the public, ARB, and EPA were incorporated into the draft rule and draft 

staff report as appropriate. 

The proposed amendments to Rule 4653, the Final Draft Staff Report will be published 

and made available for review and comment prior to the public hearing to consider the 

adoption of the amendments by the District's Governing Board. Comments received 

were incorporated into the proposed rule amendments as appropriate District staff 

intends to submit the proposed rule amendments to the District Governing Board for 

consideration of adoption during the third quarter of 2010. 
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II. DISCUSSION 

A. Sealants 

Some air districts in California have prohibitory requirements for sealants and sealant 

primers included within their adhesives rules. Bay Area Air Quality Management District 

(BAAQMD) Rule 8-51 defines sealant product as any material with adhesive properties 

used primarily to fill, seal, waterproof, or weatherproof gaps or joints between two 

surfaces. Sealant products include sealant primers and caulk. Ventura County APCD 

(VCAPCD) Rule 74.20 defines a sealant primer as any product intended by the 

manufacturer to be applied to a substrate, prior to the application of a sealant, to 

enhance the bonding surface. Further discussion regarding sealant products and VOC 

content limits for sealant products is provided in Section III (Current and Proposed 

Regulations) of this final draft staff report. 

B. Adhesives 

BAAQMD Rule 74.20 defines an adhesive product as any material which is applied for 

the primary purpose of bonding two surfaces together by surface attachment. 

Adhesives are usually used during assembly processes to join surfaces. Adhesives 

allow for faster assembly speeds, less labor input, and more ability for joining dissimilar 

materials than other fastening methods. The classifications of adhesives include 

solution/waterborne, solvent-borne, solid, pressure sensitive and reactive. 

C. Application 

The process of adhesive and sealant application occurs by applying the product to a 

substrate, followed by curing or drying. The product may be in an aerosol or a liquid, 

with application techniques including spraying, rolling, or dipping. There are several 

different types of application technologies available for application and the selection of 

the application technology can significantly affect the amount of product used and the 

resulting VOC emissions from the application process. 

The most common application methods include air atomized spray, airless spray, 

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

brush or roll coating, electro-coating, and hand application. Spray application 

operations generally occur in a spray booth by manual or automated means. Spray 

booths capture overspray, keep solvent vapors away from employees, and keep 

external contaminants out of the application operation. Airflow in a booth equipped with 

a filter generally passes from the spray applicator, over the substrate, and through a 

filter bank. A series of baffles located in front of the filters collects overspray, and in 

some cases, the collected overspray is recycled. 
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Conventional Air Spray 

Conventional air spray application uses compressed air at high pressure (30 to 90 psi) 

to pull the product from a reservoir and atomize it. The mixture of air and atomized 

product then deposits onto the substrate. Conventional air spray has a relatively low 

transfer efficiency compared to other application methods because the high pressure of 

air causes a majority of the product to not land on the substrate and become overspray 

waste. 

Airless Spray 

With airless spray, a pump forces the product through an atomizing nozzle at high 

pressure (1,000 to 6,000 psi). Airless spray is ideal for rapid coverage of large areas 

when a heavy film build is required. The size of airless spray droplets is larger making 

the spray cloud less turbulent. The transfer efficiency of airless spray is typically 

superior to conventional air spray. 

Electrostatic Spray

Reports indicate that electrostatic spray systems have the highest transfer efficiency of 

all the spray application techniques. In electrostatic spray application, the product and 

substrate are oppositely charged. The grounded substrate attracts the negatively 

charged particles, resulting in minimal overspray, resulting in lower VOC emissions. 

HVLP Systems 

HVLP systems use low air pressure (generally not more than 10 psi), and utilize 

specialized nozzles. The specialized nozzles provide better air and fluid flow at the 

lower air pressure, shape the air/spray pattern, and guide the atomized particles to the 

substrate. Lower air pressures result in greater transfer efficiency compared to 

conventional air atomized spray systems. 

Dip Coating 

Typically used for large complicated parts where it would be difficult to use other 

methods, dip coating has high transfer efficiencies. Dip coating occurs by dipping the 

substrate into a tank containing the product, and then draining off the excess. Typically, 

systems have some means of recirculation of tank contents, filters to remove sediment 

and contaminants, and a means for controlling the viscosity of the fluid. Solvent losses 

occur from the large surface area of the tank. Thinner is added to the tank (water or 

solvent thinner, depending on the product used) to maintain the desired viscosity. 

Flow Coating 

Flow coating is similar to dip coating but involves conveying the substrate over an 

enclosed sink. Low-pressure streams, or flows applying the product as the item passes 

under a series of nozzles. Excess product drains back into the sink, is filtered, and 

pumped back into a holding tank. A typical flow coater tank is enclosed and is smaller 

than the equivalent dip coating tank. As a result, a smaller quantity of product is used 

and less solvent evaporates than would during dip tank operations. 
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Other Methods

High viscosity product applications include roll coating, brush coating, electro-coating, 

and hand coating techniques. Electro-coating, also called electrodeposition is a 

specialized form of dip coating. The product and the substrate have opposite electric 

charges. The product is adhered to the part by electrical attraction, which produces a 

uniform application on the substrate. 

D. Available Controls and Regulatory Approaches 

The primary source of VOC emissions from adhesive and sealant product application is 

evaporation from the products during and after application of adhesives, sealants, and 

associated cleaning products. Control techniques for reducing VOC emissions from 

application processes include pollution prevention and emission capture and control 

systems. Pollution prevention is the most prevalent control technique in use at facilities 

operating adhesive application processes. Add-on capture and control systems are 

available to industry, but few facilities utilize this control technique, as it can be very 

costly. The following is a summary of the available control options for reducing these 

VOC emissions. 

1. Pollution Prevention Measures 

Pollution prevention measures include product substitution/reformulation, work practice 

procedures, and equipment substitution. 

a. Product Substitution/Reformulation 

An effective pollution prevention measure is to substitute higher-solvent products with 

waterborne products, higher solids products, and reactive products as these products 

contain little or no solvents. Manufacturers are continuing to develop waterborne 

formulations that replace conventional organic solvent-borne products. These products 

are generally available, and many application processes are capable of converting to 

these products. 

b. Work Practices 

Work practice procedures are physical actions, specific to an industry, intended to affect 

emission reductions. Work practices can effectively reduce the waste generated during 

adhesive and sealant material preparation, application, and equipment cleaning. Waste 

may be reduced by effectively controlling material preparation, maximizing the amount 

of product transferred to the substrate via application methods with higher transfer 

efficiencies, improved spray technique, and proper equipment maintenance. 

Requirements were added to rule language for work practice requirements during the 

previous rule-amending project to adopt EPA CTG requirements. 

c. Equipment Substitution 

Technologies such electrostatic and high volume low-pressure (HVLP) spray equipment 

achieves higher transfer efficiencies than many conventional methods. Increased 

transfer efficiency translates to decreased usage of VOC containing materials. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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Electrostatic spraying may achieve transfer efficiencies of up to 90 percent depending 

on the product shape, size, and substrate. HVLP systems use reduced air pressure 

and increases transfer efficiency. HVLP spray systems can achieve transfer efficiencies 

of up to 65 percent under optimal conditions and with good operator technique. 

2. Emission Capture and Control Systems 

When combined with an add-on control system that destroys or recovers VOC from 

exhaust streams, capture systems reduce VOC emissions from adhesive and sealant 

application processes. Although capture systems and add-on control devices are 

available to facilities, they are generally not used due to cost considerations. Operators 

will typically use lower VOC products and alternative application methods. Although 

add-on controls can control VOC emissions in spray booth exhaust, it is generally not 

cost effective to do so because of the large volume of air that needs to be treated 

compared to the low concentration of VOC. 

a. Capture Systems 

Capture systems, such as hoods, floor air sweeps, and enclosures, collect solventladen air from process vents and/or fugitive emissions, and direct the captured air to a 

control device. The design of the capture system contributes to the overall VOC control 

efficiency. An efficient capture system maximizes the capture of emissions and 

minimizes the capture of dilution air. Spray booth design and air management can 

reduce the volume of exhaust air and maximize 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. 

b. Add-on Control Systems 

Add-on Control Systems reduce the amount of VOC emissions by either destruction or 

recovery (with or without recycling) of VOC emission in the exhaust streams. The two 

categories of add-on control devices include combustion (thermal or catalytic oxidation) 

and recovery (adsorption and absorption). The following summary discusses those 

control devices in known use with adhesive application processes including oxidation, 

adsorption, and absorption. 

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 can achieve 

destruction efficiencies of greater than 95 percent as applied to application operations 

with high and constant concentrations of VOC. 
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Adsorption occurs when the unbalanced molecular forces on the surface of solids (the 

adsorbant) attract and retain gases and particulate matter that meet the solid. Adhesive 

application operations most commonly utilize carbon adsorbers. In a typical carbon 

adsorber, VOC-laden air passes through a fixed bed of granular activated carbon. To 

avoid interruption of VOC control, adsorber beds are operated in parallel. In this 

arrangement, when the adsorption capacity of one bed is exhausted, the bed is 

removed from service, and a second adsorber bed is 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 in preparation to be put back into service. Carbon adsorption 

systems can achieve control device efficiencies equal to or greater than 95 percent. 

Carbon adsorption captures but does not destroy the VOC it removes from the air 

stream. Carbon adsorbers are thermally regenerated by passing steam through the 

carbon beds. The VOC is desorbed, removed from the carbon, and transferred to the 

exhaust or recovery steam. The VOC-containing steam is then condensed, and the 

VOC solvent is separated from the water. If the operator so chooses, the recovered 

solvent is then decanted for sale or reuse. Regeneration can also be performed via hot 

air. Hot-air regeneration can be quite attractive when dealing with water-soluble 

solvents. Carbon adsorption is most amenable to coatings that use a single solvent; if 

adsorbers collect solvent mixtures, the solvent could be distilled for reuse. 

Absorption is the process by which a gas stream is dissolved in a liquid by adjoining the 

gas stream to a liquid. Water is the most common absorbent, but organic solvents may 

also be used. The addition of reactive chemical additives to the absorbent will increase 

solubility of the absorbed pollutant, thereby enhancing removal efficiency. 

3. Available Controls for VOC Emissions from Cleaning Materials 

Pollution prevention is the most common emission control technique for reducing VOC 

emissions from cleaning operations. The pollution prevention measures applicable to 

adhesive and sealant application processes include product substitution or 

reformulation, and work practice procedures. Cleaning materials with low or no VOC 

content 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. 

Add-on control technologies are not in use specifically to reduce VOC emissions from 

cleaning operations associated with miscellaneous adhesive or sealant application 

processes. However, in some instances, cleaning operations occur within a capture 

system that ducts to an add-on control system, such as a hood routed to a thermal 

oxidizer, where the VOC emissions from the cleaning operations are destroyed. 
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III. CURRENT AND PROPOSED REGULATIONS 

A. Current Regulations 

District Rule 4653 (Adhesives) currently sets limits for VOC emissions from the 

application of adhesive products and associated organic solvent cleaning operations. 

Rule language also provides operators with an option to alternatively control VOC 

emissions from coating operations by using a VOC emission control system in lieu of 

complying with the VOC content limits. 

1. Existing State VOC Requirements 

In 1998, ARB issued a guidance document that included ARB’s determination of 

reasonably available control technology (RACT) and best available retrofit control 

technology (BARCT) for Adhesives and Sealants. ARB based the majority of its RACT 

determination on limits already in effect in South Coast Air Quality Management District 

(SCAQMD), BAAQMD, and Ventura County APCD, and concluded that the VOC limits 

for adhesives and sealants presented in its RACT determination were achievable and 

cost-effective. Furthermore, ARB stated in its RACT determination that most of the 

adhesive and sealant products sold in 1998 were already compliant with the VOC limits 

that were determined to be RACT. 

2. Existing Local Adhesive and Sealant Requirements 

Thirteen air districts in California have established rules specifically for adhesives. The 

various district adhesives rules do not all contain the same adhesive categories and 

limits as the ARB RACT guidance. Among these districts, the South Coast AQMD has 

generally adopted the most stringent VOC content limits for adhesives. If add-on 

controls are used, South Coast Rule 1168 requires that the control system capture at 

least 80 percent of the VOC emissions. Several air districts require the use of specific 

types of high-efficiency adhesive application methods to reduce VOC emissions. At 

least seven other District’s rules that regulate emissions from adhesives are similar to 

South Coast Rule 1168 in that they also require that sources use methods that achieve 

high transfer efficiency. 

Air districts in California that regulate the VOC emissions generated from cleaning 

materials used in adhesive application processes require a combination of work practice 

and equipment standards and limits on the VOC content, boiling point, or composite 

vapor pressure of the solvent. Additionally, some District rules allow the use of add-on 

controls as an alternative to the VOC content/boiling point/vapor pressure limits for 

cleaning materials. The work practice and equipment standards that have been 

adopted by California Districts include, for example, using closed containers for storing 

solvent and solvent containing wipes and rags, using enclosed and automated spray 

gun washing equipment, and prohibiting atomized spraying of solvent during spray gun 

cleaning. 
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Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

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Of the air districts that include sealant product requirements as a part of their adhesives 

rules, most share the same VOC content limits for said sealants and sealant primers 

categories, with the following few exceptions. Placer County Air Pollution Control 

District has a sealant limit for PVC welding sealants with a VOC content limit of 480 

grams per liter, the other Districts do not. BAAQMD does not have a VOC content limit 

specific to marine deck sealant primers. SCAQMD has a VOC content limit of 500 

grams per liter specified for modified bituminous sealant primers, the other districts do 

not. The shared sealant and sealant primer categories and corresponding VOC content 

limits are displayed in Tables 2 and 3 below. 

Table 2 Sealant Limits (Various Districts)

Category VOC content (grams/liter) 

Architectural 250 

Marine Deck 760 

Nonmembrane Roof 300 

Roadway 250 

Single-Ply Roof Membrane 450 

Other Sealants 420 

Table 3 Sealant Primer Limits (Various Districts)

Category VOC content (grams/liter) 

Architectural Nonporous 250 

Architectural Porous 775 

Marine Deck 760 

Other Sealant Primers 750 

B. Proposed Amendments 

Proposed amendments would include the following changes. 

Section 1.0 Purpose 

Section 1.0 would be amended to incorporate sealants products. 

Section 2.0 Applicability 

Section 2.0 would be amended to include sealant products to the applicability of this 

rule. 

Section 3.0 Definitions 

The “Definitions” section would be expanded from 97 definitions to 141definitions. 

Several definitions would be added to clarify current rule requirements as well as 

provide for the addition of sealants, sealant primers, and new adhesives categories to 

rule language. 
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Section 4.0 Exemptions 

Section 4.0 would be amended for clarity and to include sealant products. 

Section 5.0 Requirements 

Section 5.1.1 Adhesive VOC content limits would be amended to make the limits as 

stringent as adhesive VOC limits in other air districts, and to add several new adhesive 

categories that were not previously regulated or were previously regulated under 

another adhesive category with a higher VOC content limit. The following is a 

discussion of the adhesive categories and proposed amendments and additions to the 

adhesive categories and limits. 

Multipurpose Construction Adhesive

Multipurpose Construction Adhesive is a current adhesive category for Rule 4653. The 

current VOC limit for this adhesive category is 200 g/l. Effective on and after January 1, 

2012, the Multipurpose Construction Adhesive VOC content limit would become 70 g/l. 

The new VOC content limit will make this VOC limit as stringent as the VOC content 

limit for this adhesive category in the adhesives rules in the SCAQMD, VCAPCD, and 

the San Diego Air Pollution Control District (SDAPCD). 

Ceramic Tile Adhesive

Ceramic Tile Adhesive is a current adhesive category for Rule 4653. The current VOC 

limit for this adhesive category is 130 g/l. Effective on and after January 1, 2012, the 

VOC content limit would become 65 g/l. The new VOC content limit will make this VOC 

limit as stringent as the VOC content limit for this adhesive category in the adhesives 

rules in SCAQMD, VCAPCD, and SDAPCD. This category would be presented twice in 

Table 2 of proposed rule language for organizational purposes. 

Cove Base Installation Adhesive

Cove Base Installation Adhesive is a current adhesive category for Rule 4653. The 

current VOC limit for this adhesive category is 250 g/l, but will become 150 g/l effective 

on and after January 1, 2011 due to a previous rule-amending project to adopt EPA 

CTG standards. Effective on and after January 1, 2012, the VOC content limit would 

become 50 g/l. The new VOC content limit of 50 g/l will make this VOC limit as 

stringent as the VOC content limit for this adhesive category in the adhesives rules in 

SCAQMD, VCAPCD, and SDAPCD. 

Dry Wall Adhesive

Dry Wall Adhesives are adhesives intended by the manufacturer to be used during the 

installation of gypsum dry wall to studs or solid surfaces. Effective on and after January 

1, 2012, the Dry Wall Adhesive category would be a new category to rule language. 

Adhesives in this category are currently regulated as Multipurpose Construction 

Adhesive with a VOC content limit of 200 g/l. However, this new adhesives category 

would have a VOC content limit of 50 g/l to make it as stringent as the VOC content 

limits for this category in the adhesives rules in SCAQMD and VCAPCD. 
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Panel Adhesive

Panel Adhesive is an adhesive intended by the manufacturer to be used for the 

installation of plywood, pre-decorated hardboard (or tileboard), fiberglass, reinforced 

plastic, and similar pre-decorated hardboard or non-decorated panels to studs or solid 

surfaces using an adhesive formulated for that purpose. The definition of Panel 

Installation Adhesive was added to rule language during the previous rule-amending 

project to add EPA CTG requirements to rule requirements. Effective on and after 

January 1, 2012, the Panel Adhesive category would be a new category to rule 

language. Adhesives in this category are currently regulated as Multipurpose 

Construction Adhesive with a VOC content limit of 200 g/l. However, this new 

adhesives category would have a VOC content limit of 50 g/l to make it as stringent as 

the VOC content limits for this category in the adhesives rules in SCAQMD and 

VCAPCD. 

Floor Covering Installation Adhesive

Floor Covering Installation Adhesive is a current adhesive category for Rule 4653, with 

a current VOC limit of 150 g/l. There are no proposed amendments for this adhesive 

category at this time. 

Ceramic Floor Tile Installation Adhesive 

Ceramic Tile Adhesive is a current adhesive category for Rule 4653. The current VOC 

limit for this adhesive category is 130 g/l. Effective on and after January 1, 2012, the 

VOC content limit would become 65 g/l. The new VOC content limit will make this VOC 

limit as stringent as the VOC content limit for this adhesive category in the adhesives 

rules in the SCAQMD, VCAPCD, and SDAPCD. This category would be presented 

twice in Table 2 for organizational purposes. 

Indoor Carpet Adhesive

Indoor Carpet Adhesives are adhesives used during the installation of a carpet that is in 

an enclosure and is not exposed to ambient weather conditions during normal use. 

Effective on and after January 1, 2012, the Indoor Carpet Adhesives category would be 

a new category to rule language. Adhesives in this category are currently regulated as 

Floor Covering Installation adhesives with a VOC content limit of 150 g/l. However, this 

new adhesives category would have a VOC content limit of 50 g/l to make it as stringent 

as the VOC content limits for this category in the adhesives rules in SCAQMD, 

VCAPCD, and SDAPCD. 

Carpet Pad Adhesive

Carpet Pad Adhesives are adhesives used for the installation of a carpet pad (or 

cushion) beneath a carpet. Effective on and after January 1, 2012, the Indoor Carpet 

Pad Adhesive category would be a new category to rule language. Adhesives in this 

category are currently regulated as Floor Covering Installation adhesives with a VOC 

content limit of 150 g/l. However, this new adhesives category would have a VOC 

content limit of 50 g/l to make it as stringent as the VOC content limits for this category 

in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD. 
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Outdoor Carpet Adhesive

Outdoor Carpet Adhesives are adhesives used during the installation of carpet that is 

not in an enclosure and is exposed to ambient weather conditions during normal use. 

Effective on and after January 1, 2012, the Indoor Carpet Adhesive category would be a 

new category to rule language. Adhesives in this category are currently regulated as 

Floor Covering Installation adhesives with a VOC content limit of 150 g/l. This new 

adhesives category would be created to provide consistency in coating categories, 

clarifying the difference between indoor and outdoor carpet adhesives. This adhesive 

category would have a VOC content limit of 150 g/l which is consistent with its current 

VOC limit, as it is as stringent as the VOC content limits for this category in the 

adhesives rules in SCAQMD, VCAPCD, and SDAPCD. 

Rubber Flooring Adhesive

Rubber Flooring Adhesives are adhesives used for the installation of flooring material in 

which both the back and the top surface are made of synthetic rubber, and which may 

be in sheet or tile form. Effective on and after January 1, 2012, the Rubber Flooring 

Adhesive category would be a new category to rule language. Adhesives in this 

category are currently regulated as Floor Covering Installation Adhesives with a VOC 

content limit of 150 g/l. However, this new adhesive category would have a VOC 

content limit of 60 g/l to make it as stringent as the VOC content limits for this category 

in the adhesives rules in SCAQMD, VCAPCD, and SDAPCD. 

Perimeter Bonded Sheet Flooring Installation Adhesive

Perimeter Bonded Sheet Flooring Installation Adhesive is a current adhesive category 

for Rule 4653, with a current VOC limit of 660 g/l. There are no proposed amendments 

for this adhesive category at this time. 

Subfloor Adhesive

Subfloor Adhesives are used for the installation of subflooring material over floor joists. 

Effective on and after January 1, 2012, the Subfloor Adhesive category would be a new 

category to rule language. Adhesives in this category are currently regulated as 

Multipurpose Construction Adhesive with a VOC content limit of 200 g/l. However, this 

new adhesives category will have a VOC content limit of 50 g/l to make it as stringent as 

the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, 

and SDAPCD. 

VCT and Asphalt Tile Adhesive

VCT and Asphalt Tile Adhesives are any adhesives intended by the manufacturer for 

the installation of vinyl composite tile or asphalt tile flooring. Effective on and after 

January 1, 2012, the VCT and Asphalt Tile Adhesive category would be a new category 

to rule language. Adhesives in this category are currently regulated as Floor Covering 

Installation Adhesive with a VOC content limit of 150 g/l. However, this new adhesives 

category will have a VOC content limit of 50 g/l to make it as stringent as the VOC 

content limits for this category in the adhesives rules in SCAQMD, VCAPCD, and 

SDAPCD. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

14 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Wood Flooring Adhesive

Wood Flooring Adhesives are adhesives intended by the manufacturer to be used to 

install a wood floor surface, including but not limited to parquet tiles and wood planks. 

Effective on and after January 1, 2012, the Wood Flooring Adhesive category would be 

a new category to rule language. Adhesives in this category are currently regulated as 

Floor Covering Installation Adhesive with a VOC content limit of 150 g/l. However, this 

new adhesives category will have a VOC content limit of 100 g/l to make it as stringent 

as the VOC content limits for this category in the adhesives rules in SCAQMD, 

VCAPCD, and SDAPCD. 

Single-Ply Roof Material Installation Adhesive

Single-Ply Roof Material Installation Adhesive is a current adhesive category for Rule 

4653, with a current VOC limit of 250 g/l. There are no proposed amendments for this 

adhesive category at this time. 

Non-Membrane Roof Adhesive

Non-Membrane Roof Adhesives are adhesives intended by the manufacturer to be used 

for the installation or repair of non-membrane roofs. This category includes plastic or 

asphalt roof cement, asphalt roof coatings and cold application cement. Effective on 

and after January 1, 2012, the Non-Membrane Roof Adhesive category would be a new 

category to rule language. It is important to note that this adhesive category is new to 

regulation. This product is currently being sold in the SJVAB as either a consumer 

product, an unregulated product, or in small containers. Effective on and after January 

1, 2012, the VOC content limit for Non-Membrane Roof Adhesives would be 300 g/l. 

This VOC content limit will be as stringent as the VOC content limits for this category in 

the adhesives rules in SCAQMD, VCAPCD, and SDAPCD. 

Structural Glazing

Structural Glazing is a current adhesive category for Rule 4653, with a current VOC limit 

of 100 g/l. There are no proposed amendments for this adhesive category at this time. 

Structural Wood Member Adhesive

Structural Wood Member Adhesives are used for the construction of any load bearing 

joints in wooden joists, trusses, or beams. Effective on and after January 1, 2012, the 

Structural Wood Member Adhesives category would be a new category to rule 

language. Adhesives in this category are currently regulated as Multipurpose 

Construction Adhesive with a VOC content limit of 200 g/l. However, this new 

adhesives category would have a VOC content limit of 140 g/l to make it as stringent as 

the VOC content limits for this category in the adhesives rules in SCAQMD, VCAPCD, 

and SDAPCD. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

15 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Contact Adhesive

Contact Adhesive is a current adhesive category for Rule 4653. The current VOC limit 

for this adhesive category is 250 g/l. Effective on and after January 1, 2012, the VOC 

content limit would be 80 g/l. The new VOC content limit will make this VOC limit as 

stringent as the VOC content limit for this adhesive category in the adhesives rules in 

the SCAQMD, VCAPCD, and SDAPCD. 

Contact Adhesive – Specialty

Contact Adhesive – Specialty is a current adhesive category for Rule 4653, with a 

current VOC limit of 250 g/l. There are no proposed amendments for this adhesive 

category at this time. 

Rubber Vulcanization Adhesive/Primer

Rubber Vulcanization Adhesive/Primer is a current adhesive category for Rule 4653, 

with a current VOC limit of 850 g/l. There are no proposed amendments for this 

adhesive category at this time. 

Tire Retread

Tire Retread is a current adhesive category for Rule 4653, with a current VOC limit of 

100 g/l. This category was originally added to rule language as tire repair, but 

comments from EPA clarified that the category should be Tire Retread, therefore the 

proposed amendment to this category is to correct the name of the adhesive category 

There are no proposed amendments for the VOC content of this adhesive category at 

this time. 

Motor Vehicle Adhesive

Motor Vehicle Adhesive is a current adhesive category for Rule 4653. It was added to 

rule language during the previous rule-amending project to adopt EPA CTG 

requirements. The VOC content limit for Motor Vehicle Adhesives is 250 g/l. There are 

no proposed amendments for this adhesive category at this time. 

Motor Vehicle Weatherstrip Adhesive

Motor Vehicle Weatherstrip Adhesive is a new adhesive category for Rule 4653. The 

definition was added to rule language during the previous rule amending project to 

adopt EPA CTG requirements. However, a VOC content limit was not assigned to this 

adhesive at the time of adoption. Effective on and after January 1, 2012, the VOC 

content limit would be 750 g/l to make it as stringent as the EPA CTG. Staff had 

originally left this category with an unassigned VOC content limit so it would be subject 

to the default limit of 250 g/l, however, staff have been unsuccessful in finding an 

existing product with a VOC content limit that could meet the 250 g/l VOC content limit. 

In an effort to avoid imposing a potentially technologically infeasible VOC content limit 

for this adhesive category, staff recommends adopting a VOC content limit consistent 

with the EPA CTG standards. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

16 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Traffic Marking Tape Adhesive/Primer

Traffic Marking Tape Adhesive Primer is an adhesive primer intended by the 

manufacturer to be applied to the substrate prior to the installation of traffic marking 

tape. Effective on and after January 1, 2012, the Traffic Marking Tape Adhesive Primer 

category would be a new category to rule language. Adhesives in this category are 

currently regulated as Adhesive Primers with a VOC content limit of 250 g/l. However, 

this new adhesives category will have a VOC content limit of 150 g/l to make it as 

stringent as the VOC content limits for this category in the adhesives rules in SCAQMD, 

VCAPCD, and SDAPCD and the BAAQMD. 

Top and Trim Adhesive 

Top and Trim Adhesive intended by the manufacture to be used to install automotive 

and marine trim, including, but not limited to headliners, vinyl tops, vinyl trim, sunroofs, 

dash covering, door covering, floor covering, panel covering, and upholstery. Effective 

on and after January 1, 2012, the Top and Trim Adhesive category would be a new 

category to rule language. It is important to note that this adhesive category is new to 

regulation. This product is currently being sold in the SJVAB as either a consumer 

product, an unregulated product, or in small containers. Effective on and after January 

1, 2012, the VOC content limit for Top and Trim Adhesives would be 540 g/l. This VOC 

content limit will be as stringent as the VOC content limits for this category in the 

adhesives rules in BAAQMD, VCAPCD, and SDAPCD. 

Waterproof Resorcinol Glue

Waterproof Resorcinol Glue is a current adhesive category for Rule 4653, with a current 

VOC limit of 170 g/l. There are no proposed amendments for this adhesive category at 

this time. 

Staple and Nail Manufacturing Adhesive 

Staple and Nail Manufacturing Adhesive is a current adhesive category for Rule 4653, 

with a current VOC limit of 100 g/l. There are no proposed amendments for this 

adhesive category at this time. 

Thin Metal Laminating Adhesive

Thin Metal Laminating Adhesive is any adhesive intended by the manufacturer for use 

in bonding multiple layers of metal to metal or metal to plastic on the production of 

electronic or magnetic components in which the thickness of the bonded line(s) is less 

than 0.25 millimeters. Thin Metal Laminating Adhesive is a new adhesive category for 

Rule 4653. The definition was added to rule language during the previous ruleamending project to adopt EPA CTG requirements. However, a VOC content limit was 

not assigned to this adhesive at the time of adoption. Effective on and after January 1, 

2012, the VOC content limit would be 780 g/l to make it as stringent as the EPA CTG, 

BAAQMD, and SDAPCD. Staff had originally left this category with an unassigned VOC 

content limit so it would be subject to the default limit of 250 g/l, however, staff have 

been unsuccessful in finding an existing product with a VOC content limit that could 

meet the 250 g/l VOC content limit. In an effort to avoid imposing a potentially 
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Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

17 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

technologically infeasible VOC content limit for this adhesive category, staff 

recommends adopting a VOC content limit consistent with the EPA CTG, BAAQMD, 

and SDAPCD standards. 

Elastomeric Adhesive

Elastomeric Adhesive is a rubber or thermoplastic based adhesive intended by the 

manufacturer to be used in the manufacture of life preserving equipment including, but 

not limited to, aircraft float systems, life rafts, and life jackets; or other personal or 

equipment protection products. Effective on and after January 1, 2012, the Elastomeric 

Adhesive category would be a new category to rule language. It is important to note 

that this adhesive category is new to regulation. If this product is currently being sold in 

the SJVAB it is as either a consumer product, an unregulated product, or in small 

containers. Effective on and after January 1, 2012, the VOC content limit for 

Elastomeric Adhesives would be 750 g/l. This VOC content limit will be as stringent as 

the VOC content limits for this category in the adhesives rule in SDAPCD. 

Flexible Vinyl Adhesive

Flexible Vinyl Adhesive is a new adhesive category for Rule 4653, with a current VOC 

limit of 250 g/l. Flexible Vinyl Adhesive was added to rule language during the previous 

rule-amending project to adopt EPA CTG requirements. However, because the VOC 

content limit is equal to the default limit, the category was not added to the Table 1 with 

the other adhesive categories. However, for the sake of clarity of rule requirements, 

Flexible Vinyl Adhesives will be added to Table 2, maintaining the VOC content limit of 

250 g/l. 

ABS Welding Adhesive

ABS Welding Adhesive is a current adhesive category for Rule 4653. The current VOC 

limit for this adhesive category is 400 g/l. Effective on and after January 1, 2012, the 

VOC content limit would become 325 g/l. The new VOC content limit will make this 

VOC limit as stringent as the VOC content limit for this adhesive category in the 

adhesives rules in the SCAQMD. 

Cellulosic Plastic Welding Adhesive

Cellulosic Plastic Welding Adhesives are adhesives intended for use with cellulosic 

plastics which are any plastic containing the naturally occurring polymer or 

polysaccharide, cellulose. Effective on and after January 1, 2012, the Cellulosic Plastic 

Welding Adhesive category would be a new category to rule language. It is important to 

note that this adhesive category is new to regulation. If this product is currently being 

sold in the SJVAB, it is as either a consumer product, an unregulated product, or in 

small containers. Effective on and after January 1, 2012, the VOC content limit for 

Cellulosic Plastic Welding Adhesives would be 100 g/l. This VOC content limit will be 

as stringent as the VOC content limits for this category in the adhesives rule in 

VCAPCD. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

18 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

CPVC Welding Adhesive

CPVC Welding Adhesive is a current adhesive category for Rule 4653, with a current 

VOC limit of 490 g/l. There are no proposed amendments for this adhesive category at 

this time. 

PVC Welding Adhesive

PVC Welding Adhesive is a current adhesive category for Rule 4653, with a current 

VOC limit of 510 g/l. Effective January 1, 2011 the VOC content limit will change to 500 

g/l per the previous rule-amending project to adopt EPA CTG requirements. 

During the rule-amending process, staff received one stakeholder comment. The 

commenter expressed concern regarding the feasibility of PVC welding adhesives with 

the 500 g/l VOC content limit. In response to the comment, staff further researched the 

availability of PVC welding adhesives at 500 g/l VOC content and the feasibility of 

manufacturing it. During the research process, staff had conversations with 

representatives from EPA Region IX office, the SCAQMD, and the Antelope Valley 

AQMD. Conversations with staff from EPA Region IX indicated that the 500 g/l VOC 

content limit in the CTG for PVC welding adhesives may have been an oversight and is 

not technologically feasible at this time. EPA now concurs with the CARB 

RACT/BARCT analysis for PVC welding adhesives with a VOC content limit of 510 g/l 

and recommends the District adopt this limit. 

Antelope Valley AQMD had amended their Rule 168 from 285g/l to 510 g/l while 

adopting CTG limits and to mirror SCAQMD in January 2010. El Dorado APCD Rule 

236 Adhesives has not updated VOC content limit, which was based on an earlier 

SCAQMD limit. SCAQMD now has a limit of 510 g/l in their rule for this category. 

Changing the VOC content limit for PVC welding adhesives will make this limit as 

stringent as other air districts in California with the exception of El Dorado APCD who 

currently have the old SCAQMD limit in their rule. 

No emission reductions were claimed from this adhesive category during the 2009 ruleamending project. Because the VOC content limit has yet to take effect and no 

emissions reductions were claimed, there will be no increase in emissions from this 

rule-amending project. The 500 g/l VOC limit has not been approved into the District’s 

SIP by EPA, and this proposed action would thus not constitute a SIP relaxation. 

Styrene-Acrylonitrile Welding Adhesive

Styrene-Acrylonitrile Welding Adhesive is an adhesive intended by the manufacturer to 

weld styrene-acrylonitrile co-polymer plastics. Effective on and after January 1, 2012, 

the Styrene-Acrylonitrile Welding Adhesive category would be a new category to rule 

language. It is important to note that this adhesive category is new to regulation. If this 

product is currently being sold in the SJVAB it is as either a consumer product, an 

unregulated product, or in small containers. Effective on and after January 1, 2012, the 

VOC content limit for Styrene-Acrylonitrile Welding Adhesive would be 100 g/l. This 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

19 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

VOC content limit will be as stringent as the VOC content limits for this category in the 

adhesives rules in VCAPCD. 

Plastic Cement Welding Adhesive Primer

Plastic Cement Welding Adhesive Primer is a current adhesive category for Rule 4653. 

The current VOC limit for this adhesive category is 650 g/l. Effective on and after 

January 1, 2012, the VOC content limit would become 400 g/l. The new VOC content 

limit will make this VOC limit as stringent as the VOC content limit for this adhesive 

category in the adhesives rules in the Sacramento Metro Air Quality Managemetn 

District (SCAQMD). 

Other Plastic Cement Welding Adhesive

Other Plastic Cement Welding Adhesive is a current adhesive category for Rule 4653. 

The current VOC limit for this adhesive category is 450 g/l. Effective on and after 

January 1, 2012, the VOC content limit would become 250 g/l. The new VOC content 

limit will make this VOC limit as stringent as the VOC content limit for this adhesive 

category in the adhesives rules in the SCAQMD. 

Automotive Glass Primer

Automotive Glass Primer is a new adhesive category for Rule 4653. The definition was 

added to rule language during the previous rule amending project to adopt EPA CTG 

requirements. However, a VOC content limit was not assigned to this adhesive at the 

time of adoption. The CTG recommended a VOC content limit of 900 g/l, however, 

effective on and after January 1, 2012, the VOC content limit would be 700 g/l to make it 

as stringent as adhesives of the same category in the BAAQMD, VCAPCD, and 

SDAPCD. Staff had originally left this category with an unassigned VOC content limit 

so it would be subject to the default limit of 250 g/l, however, staff have been 

unsuccessful in finding an existing product with a VOC content limit that could meet the 

250 g/l VOC content limit. In an effort to avoid imposing a potentially technologically 

infeasible VOC content limit for this adhesive category, staff recommends adopting a 

VOC content limit consistent with the EPA CTG standards. 

Adhesive Primer

Adhesive Primer is a current adhesive category for Rule 4653, with a current VOC limit 

of 250 g/l. There are no proposed amendments for this adhesive category at this time. 

Section 5.1.2 would be amended to add fiberglass as a category for Adhesive Products 

with a VOC content of 80 grams per liter (g/l). The VOC content limit for Porous 

Materials and Plastic Foam would both become more stringent, they would each be 

changed from 120 g/l VOC to 50 g/l VOC effective on and after January 1, 2012. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

20 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Section 5.1.4 would be added to rule language to provide VOC content limits for sealant 

products. Below, in table 4, is a summary of the proposed sealant categories and VOC 

content limits that would be effective on and after January 1, 2012. 

Table 4 Sealant Product Categories

VOC Limit Sealant Product (g/l) 

Architectural Sealant 250 

Architectural Non Porous Sealant Primer 250 

Architectural Porous Sealant Primer 775 

Marine Deck Sealant and Sealant Primer 760 

Modified Bituminous Sealant Primer 500 

Non-Membrane Roof Sealant 300 

Single-Ply Roof Sealant 450 

Roadway Sealant 250 

Other Sealants 420 

Other Sealant Primers 750 

Section 5.1.5 would be amended to include sealant products. 

Section 5.2 Application Equipment 

Section 5.2 would be amended to include sealant products. 

Section 5.2.8 would be amended for clarity. 

Section 5.3 Work Practices 

Section 5.3 would be amended to include sealant products and for clarity of rule 

requirements by consolidating the work practices for adhesives and sealants into one 

location in rule requirements. 

Section 5.4 VOC Emission Control System Requirements 

There are no proposed amendments recommended for Section 5.4 at this time. 

Section 5.5 Organic Solvent Cleaning Requirements 

Section 5.5 would be amended to include sealant products. 

Section 5.6 Solvent Storage and Disposal Requirements (Previous) 

The language in Section 5.6 would be relocated from this section to Sections 5.3 and 

the new Section 5.6, in order to clarify rule requirements. 
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Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

21 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Section 5.6 Work Practices for Solvent Cleaning 

Section 5.6 would be amended for clarity by consolidating work practices for solvent 

cleaning into one location. 

Section 5.7 Prohibition of Sale 

Section 5.7 would be amended to include sealant products. 

Section 5.8 Sell Through 

This section would be added to rule language to provide a sell through period of 12 

months after the effective date of new VOC content limits to provide an opportunity for 

manufacturers and retailers to sell through stock on hand. This section would also allow 

the application of adhesive products and sealant products for up to 24 months after the 

specified effective date of new VOC content limits. In order to an operator to participate 

in the sell through provision the product must be labeled to display the date or date 

code indicating when the product was manufactured and that product must comply with 

the standards in effect at the time the product was manufactured. 

Other air districts in California do not generally have a labeling requirement in adhesive 

and sealant rules, therefore the labeling requirement mentioned above is not mandatory 

for all products, only for products that the manufacturer wishes to participate in the new 

sell through provision of this rule. 

Section 5.9 Prohibition of Specification 

Section 5.9 would be added to rule language to provide a requirement that no person 

shall solicit, require for use, or specify the application of any adhesive products or 

sealant products, if such use of application results in a violation of the provisions of the 

rule. 

Section 6.0 Administrative Requirements 

Section 6.0 would be amended to incorporate recordkeeping requirements. Labeling 

requirements, and test methods for sealant products. 

Section 6.1 would be amended to remove the requirement to maintain daily records of 

adhesives used at the facility. This requirement would be removed in order to 

streamline recordkeeping requirements, as there are no prohibitions in rule language to 

justify this recordkeeping requirement. 

Section 6.5 Version of Test Methods 

Section 6.5 would be removed from rule language to reduce redundant language. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

22 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

IV. EMISSION REDUCTION ANALYSIS 

The Ozone Plan identifies the annual emissions from the Rule 4653 source category 

with current controls have a 2008 baseline emission inventory of 3.3 tons of VOC per 

day. The Ozone Plan commits the District to reduce VOC emissions from this source 

category by 3% by 2012. The VOC emission reduction is from this rule-amending 

project is 18% of the ARB emission inventory for this source category, which is 0.12 

tons per day. The estimated emission reductions from this rule-amending project 

exceed Ozone Plan commitments. The emission reduction analysis is in Appendix B of 

this final draft staff report. 

V. COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC section 40920.6(a), a cost effectiveness analysis is required for rules 

that implement BARCT. The purpose of the cost effectiveness analysis is to evaluate the 

economic reasonableness of a new rule or rule amendments. The analysis also serves as 

a guideline for developing the control requirements of the rule. The cost effectiveness 

analysis is in Appendix C of this final draft staff report. 

VI. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC 40728.5, “whenever a district intends to propose the adoption, 

amendment, or repeal of a rule or regulation that will significantly affect air quality or 

emissions limitations, that agency shall, to the extent data is available, perform an 

assessment of the socioeconomic impacts of the adoption, amendment, or repeal of the 

rule or regulation.” 

The adhesives and sealants source category is applicable to any person who supplies, 

sells, offers for sale, or applies any adhesive product or sealant product, or associated 

solvents, for use within the SJVAB. As such, the requirements of Rule 4653 can apply 

to a wide variety of sources ranging from an individual to a large company. This ruleamending project, if adopted, would make the VOC content limits more stringent for 

certain types of adhesives, as well as add sealant products to rule language. 

Affected sources could be impacted by the more stringent VOC content limits for 

adhesives as well as by the addition of sealants to rule language making it a newly 

regulated category. Additionally, sources could be impacted by the new work practice 

requirements that would be imposed on the newly regulated sealant products. 

Proposed VOC content limits for adhesive products and sealant products are currently 

enforced in other air districts, and have been in rule language of adhesives rules in 

other air districts for the past five to ten years. As such, staff believes compliant 

adhesives and sealants are readily available and are currently being sold in the SJVAB. 

Work practice requirements include keeping containers closed at all times, except when 
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Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

23 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

depositing or removing the contents of the containers or when the container is empty, 

minimizing spills, and conveying products and waste in closed containers. Compliance 

with new work practice requirements for sealants would not require the operator to 

purchase new materials, because operators are already complying with these standards 

as it would reduce waste and prevent accidental spillage of product, which would waste 

the product, thus costing the operator more money to replace lost product. 

This rule-amending project is not expected to have significant, if any, costs associated 

with it. Further discussion of the cost effectiveness analysis is presented in Appendix C 

of this final draft staff report. As there would be no costs associated with this ruleamending project, therefore no additional socio-economic impacts. 

VII. RULE CONSISTENCY ANALYSIS 

Pursuant to CH&SC 40727.2, District staff has prepared a rule consistency analysis that 

compares the elements of amendments with the corresponding elements of other 

District rules, federal regulations and guidelines that apply to the same source category 

or type of equipment. District staff found that the proposed amendments and 

requirements of this rule would not conflict with federal rules, regulations, or policies 

covering similar stationary sources. The rule consistency analysis is presented in 

Appendix D of the Final Draft Staff Report. 

VIII. ENVIRONMENTAL IMPACT ANALYSIS 

Pursuant to the California Environmental Quality Act (CEQA), staff investigated the 

possible environmental impacts of the proposed amendments to Rule 4653. Based on 

the lack of evidence to the contrary, District staff has concluded that the proposed 

amendments to the rule will not have any significant adverse effects on the 

environment. As such, staff recommends filing a Notice of Exemption under the 

provisions of Public Resource Code 15061(b)(3). 

IX. RACT ANALYSIS 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall 

assure that RACT for volatile organic compounds (VOC) is applied at certain sources. 

A RACT analysis requires an examination of a rule against Federal rules, regulations, 

and technology guidelines as well as comparing it against rules from other Districts in 

California. District Rule 4653 was compared to federal and state regulations and 

guidance. The following is a discussion of that analysis. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

24 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

A. EPA – Control Technique Guidelines (CTG) 

Since 1975, EPA staff has issued more than 35 CTGs covering a variety of VOC 

emission sources. One CTG promulgated by EPA has an impact on Rule 4653. 

CTG for Miscellaneous Industrial Adhesives (EPA 453/R-08-005) 

This CTG applies to industrial adhesives applications located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 

extreme ozone nonattainment areas. The emission standards recommended by EPA in 

the CTG has been previously included in Rule 4653, therefore the proposed 

amendments are not in conflict or inconsistent with the CTG. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for adhesives. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS document for adhesives. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAPs/MACT document for adhesives. 

District staff compared District Rule 4653 with the rules of other California Ozone nonattainment air districts’ rules (listed below) for adhesives operations. The results of the 

analysis are discussed below. 

A. South Coast Air Quality Management District (SCAQMD) Rule 1168 – Adhesive 

and Sealant Applications (Amended January 7, 2005) 

B. Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 51 -

Adhesive and Sealant Products (Amended July 17, 2002) 

C. Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 460 -

Adhesives and Sealants (Amended November 30, 2000) 

D. Ventura County Air Pollution Control District (VCPCD) Rule 74.20 – Adhesives 

and Sealants (Amended January 1, 2005) 

The following tables identify the adhesive and sealant product comparisons for 

SJVAPCD current or proposed VOC content limits with those in other Districts in 

California. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

25 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table 5 General Adhesive Products 

Material Bonded SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Metal to Metal 30 30 30 30 30 

Porous Materials 50 50 120 120 50 

Plastic Foam 50 50 120 50 

Wood 30 30 30 

Pre-formed Rubber Products 250 250 250 

Reinforced Plastic Composite 200 

Fiberglass 80 80 200 80 

All Other Substrates 250 250 250 

Table 6 Specialty Adhesive Products 

Adhesive Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Multipurpose Construction 70 70 200 200 70 

Ceramic Tile Installation 65 65 130 130 65 

Cove Base Installation 50 50 150 150 50 

Dry Wall and Panel 50 50 50 

Floor Covering Installation 150 150 150 150 

Ceramic Floor Tile Installation 65 65 130 130 65 

Indoor Carpet Adhesive 50 50 150 150 50 

Carpet Pad Adhesive 50 50 

Outdoor Carpet Adhesive 150 150 250 150 150 

Rubber Flooring 60 60 60 

Permiter Bonded Sheet 

Flooring Installation 

660 

 660 660 

Subfloor Adhesive 50 50 50 

VCT and Asphalt Tile 50 50 50 

Wood Flooring 100 100 100 

Single-Ply Roof material 

Installation 

250 

250 250 250 250 

Non-Membrane Roof 300 300 300 300 

Structural Glazing 100 100 100 100 100 

Structural Wood Member 

Adhesive 

140 

140 140 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

26 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table 6 Specialty Adhesive Products (continued) 

Adhesive Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Contact Adhesive 80 80 250 250 80 

Contact Adhesive - Specialty 250 250 400 250 250 

Rubber Vulcanization 

Adhesive/Primer 850 850 850 850 

Tire Retread 100 100 100 100 100 

Motor Vehicle Adhesive 250 

Motor Vehicle Weatherstrip 

Adhesive 750 

Traffic Marking Tape 

Adhesive/Primer 150 150 150 150 150 

Top and Trim Adhesive 540 540 540 540 

Waterproof Resorcinol Glue 170 170 170 

Staple and Nail Manufacturing 640 

Thin Metal Laminating 780 780 780 

Elastomeric 750 

Flexible Vinyl 250 250 250 

ABS Welding 325 325 400 400 400 

Cellulosic Plastic Welding 100 100 

CPVC Welding 490 490 490 490 490 

PVC Welding 510 510 510 510 510 

Styrene-Acrylonitrile Welding 100 100 

Plastic Cement Welding 

Adhesive Primer 400 550 650 400 650 

Other Plastic Cement Welding 250 250 500 450 500 

Automotive Glass Primer 700 700 700 700 

Adhesive Primer 250 250 250 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

27 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table 7 Sealant Products 

Sealant Product SJVAPCD SCAQMD BAAQMD SMAQMD VCAPCD

Architectural 250 250 250 250 250 

Marine Deck 760 760 760 760 760 

Nonmembrane Roof 300 300 300 300 300 

Roadway 250 250 250 250 250 

Single-Ply Roof 

Membrane 450 450 450 450 450 

Other 420 420 420 420 420 

Sealant Primer 

Architectural nonporous 250 250 250 250 250 

Architectural porous 775 775 775 775 775 

Modified Bituminous 500 500 not listed not listed 

Marine Deck 760 760 not listed 760 760 

Other 750 750 750 750 750 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4653 (Adhesives and Sealants) September 16, 2010 

28 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

IX. REFERENCES 

 

1. Antelope Valley AQMD. Rule 1168 Adhesive Applications. April 11, 1997. 

2. ARB. Almanac Emission Projection Data, and Cleaning and Surface Coating 

Methodologies Section 3.7 – Adhesives and Sealants. 2009. 

3. Bay Area AQMD. Regulation 8 Organic Compounds Rule 51 Adhesive and Sealant 

Products. July 17, 2002. 

4. El Dorado County AQMD. Rule 236 Adhesives. July 25, 1995. 

5. EPA. “EPA-453/R-08-005. CTG for Miscellaneous Industrial Adhesives”. 

September 2008. http://www.epa.gov/ttn/naaqs/ozone/ctg_act/index.htm

6. EPA. The Little Bluebook. 

7. Placer County APCD. Rule 235 Adhesives. April 10, 1997. 

8. Sacramento Metropolitan AQMD. Rule 460 Adhesives and Sealants. November 30, 

2000. 

9. San Diego County APCD. Rule 67.21 Adhesive Material Application Operations. 

November 14, 2008. 

10. Santa Barbara County APCD. Rule 353 Adhesives and Sealants. August 19, 1999. 

11. Shasta County AQMD. Rule 3:32 Adhesives and Sealants. July 26, 2005. 

12. South Coast AQMD. Rule 1168 Adhesive and Sealant Applications. January 7, 

2005. 

13. Tehama County APCD. Rule 4:40 Adhesives and Sealants. April 1, 2003. 

14. Ventura County APCD. Rule 74.20 Adhesives and Sealants. January 11, 2005. 

15. Yolo-Solano AQMD. Rule 2.33 Adhesive Operations. May 14, 2008.