Department of the Environment

Facts About...

COMAR 26.11.19.26-1 Fiberglass Boat 

Manufacturing 

03/02/2015

PURPOSE OF NEW REGULATION AND AMENDMENT

The new regulation COMAR 26.11.19.26-1, Control of Volatile Organic Compounds 

from Fiberglass Boat Manufacturing, adopts the requirements of the EPA’s Control 

Techniques Guidelines (CTG) for this category. EPA develops CTGs as guidance on 

control requirements for source categories. States can follow the CTGs or adopt more 

restrictive standards. MDE proposes to adopt new volatile organic compound (VOC) 

limits, standards for application methods, and work practice requirements which are 

consistent with the most recent CTG recommendations applicable to fiberglass boat 

manufacturing. The new regulation affects manufacturers of fiberglass boats. COMAR 

26.11.19.26, Control of Volatile Organic Compounds from Reinforced Plastic 

Manufacturing, is amended to exempt fiberglass boat manufacturing.

Background

The EPA first published an assessment of VOC emissions from fiberglass boat

manufacturing in 1990. This assessment evaluated VOC emissions from fiberglass boat 

manufacturing and potential control options.

The National Emission Standards for Hazardous Air Pollutants for Boat Manufacturing, 

40 CFR part 63, subpart VVVV (2001 NESHAP) were promulgated in 2001.

Emission standards under the 2001 NESHAP were for organic hazardous air pollutants

(HAPs) based on low-HAP resins and gel coats and low-emitting resin application 

technology.

California and several other states have specific regulations that control VOC emissions 

from fiberglass boat manufacturing operations, as part of their regulations for limiting 

VOC emissions from polyester resin operations. 

In July 2008, the EPA published a new CTG for Fiberglass Boat Manufacturing 

Materials. The CTG was developed based on the 1990 VOC assessment, the 2001 

NESHAP, existing state VOC emission reduction approaches, and in consideration of

information obtained since the issuance of the 2001 NESHAP.

Requirements 

Resins containing styrene and gel coats containing both styrene and methyl methacrylate 

(MMA) are the main contributors of VOC emissions at fiberglass boat manufacturing 
facilities. The proposed standards are designed to reduce VOC emissions during

fiberglass boat manufacturing operations. Not all the VOCs in the materials used are 

emitted to the atmosphere, as some of the VOCs are used in cross linking reactions of 

polymers and are retained in the finished material. Thus, an overall reduction of VOC 

content in production materials reduces potential emissions from extraneous VOCs 

during the manufacturing process.

Cleaning activities other than surface preparation also occur at facilities engaged in 

fiberglass boat manufacturing. Cleaning materials are used to remove residue or other 

unwanted materials from equipment related to manufacturing operations such as molds 

and prototypes, as well as the cleaning of application equipment, transfer lines and other 

ancillary equipment. These cleaning materials are typically mixtures of VOC containing

solvents. The proposed regulation includes emission control requirements for cleaning 

materials consistent with those in the CTG. 

Affected Sources 

The proposed regulation affects fiberglass boat manufacturers. 

New Regulation and Amendment

COMAR 26.11.19.26-1 is proposed to set the following standards for a fiberglass boat 

manufacturing facility with actual VOC emissions of 15 pounds or more per day:

Operation Application Method Monomer content 

(percent by weight)

Total Resin

VOC Content

(percent by weight)

Production resin Atomized resin 

application (spray)

28 33

Production resin Nonatomized resin 

application

35 40

Pigmented gel coat Atomized or 

nonatomized resin 

application

33 38

Clear gel coat Atomized or 

nonatomized resin 

application

48 53

Tooling resin Atomized resin 

application (spray)

30 35

Tooling resin Nonatomized resin 

application

39 44

Tooling gel coat Atomized or 

nonatomized resin 

application

40 45
These monomer content limits are the same as those in the 2001 NESHAP. The 

regulation also provides an alternative option of emission rates for monomers and non 

monomers and exemptions for certain specific applications. 

The work practice requirements establish standards and record keeping requirements for 

the usage of all VOC containing materials.

COMAR 26.11.19.26 Control of Volatile Organic Compounds from Reinforced Plastic 

Manufacturing is amended to exempt fiberglass boat manufacturing. 

Impact on Ambient Air Quality

The proposed regulation sets standards for fiberglass boat manufacturing operations. 

Emissions of VOCs from fiberglass boat manufacturing operations are expected to be 

reduced by approximately 40 percent nationally. Maryland only has one known source 

that may, on occasion, assemble fiberglass boats from pre-manufactured hulls and decks. 

Therefore Maryland VOC emission benefits will be negligible. The coatings industry 

already has products available to meet VOC standards contained in the CTG and 

proposed regulation. The maximum benefit from VOC reductions will be provided during 

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

level ozone. 

Economic Impact 

The proposed new regulation adopts the requirements of the CTG for fiberglass boat

manufacturing. EPA estimated the economic impact of this regulation on a national level. 

Cost effectiveness is approximately $ 4,200/ton of VOC controlled. Due to the limited 

number of affected sources, the economic impact in MD will be small.

Small Business 

The proposed regulation affects fiberglass boat manufacturers. At a national level, EPA 

estimates the economic impact of using reformulated materials on small businesses is 

low.

Submission to EPA as Revision to Maryland's SIP (or 111(d) Plan, or Title V 

Program) 

The proposed regulation will be submitted to the U.S. EPA for approval as a revision to 

Maryland's State Implementation Plan.

Are there other State or federal requirements that apply to these sources? 

The amendments and proposed regulation adopt the requirements in EPA’s CTG for

Fiberglass Boat Manufacturing, July 2008. There are no other federal reasonably 

available control technology standards for this category.