UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

Antelope Valley Air Quality Management District, Rule 1168, 

Adhesive and Sealant Applications

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

May, 2012
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Agency: Antelope Valley Air Quality Management District 

(AVAQMD)

SIP Approved Rule: South Coast Air Quality Management District 

(SCAQMD) Rule 1168, Adhesive and Sealant 

Applications

Adopted - January 7, 2005

Submitted – April 29, 2009

EPA approved – December 21, 2009 (74 FR 67821)

Subject of this TSD: Rule 1168 - Adhesive and Sealant Applications

Adopted – September 20, 2011

Submitted – February 23, 2012

RULE SUMMARY - AVAQMD Rule 1168, Adhesive and Sealant Applications, is 

a rule designed to limit volatile organic compounds (VOC) and to eliminate 

emissions of chloroform, ethylene dichloride, methylene chloride, perchlorethylene 

and trichloroethylene from the application of adhesives, adhesive primers, sealants, 

sealant primers or any other primer used in commercial and industrial applications 

and sales. Definitions are included in Section (B), VOC limits for applicable general 

adhesives, specialized adhesives, adhesive primers, sealants and sealant primers

are tabulated in Section (C) in addition to application methods and alternative 

compliance methods. Section (D) refers to the recordkeeping pursuant to AVAQMD 

Rule 109, Recordkeeping for Volatile Organic Compound Emissions. Sections (E) 

and (F) cover methods of analysis including procedures for determining VOC 

content and exempt compounds, and test methods for determining control device 

efficiency and VOC content as well as viscosity and exempt compounds. Sections 

(G) and (H) explain the prohibition of specifications, sales and use of noncomplying adhesives, sealants and primers. Solvents used in the application of 

adhesives, sealants and primers are referred to AVAQMD Rule 442 in Section (I) 

and exemptions are listed in Section (J).

EPA EVALUATION CRITERIA- The following criteria were used to evaluate the 

submitted rule. 
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Enforceability - The Bluebook (Issues Relating to VOC Regulation Cutpoints, 

Deficiencies, and Deviations, EPA, May 25, 1988) and the Little Bluebook 

(Guidance Document for Correcting Common VOC & Other Rule Deficiencies,

EPA Region 9, August 21, 2001) were used to evaluate compliance with the CAA 

§110(a)(2)(A) requirement for enforceability.

Stringency – EPA’s Control Technique Guidelines (CTG) titled, “Control Techniques 

Guidelines for Miscellaneous Industrial Adhesives” (EPA-453/R-08-005), dated 

September 2008, State of California Air Resources Board’s (CARB) “Determination 

of Reasonably Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) for Adhesives and Sealants” dated December, 1998,

and other state and local rules for this category were used to help evaluate the 

RACT requirements of CAA §182(c)(1). 

Rule Relaxation –We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of the Act 

(CAA 110(l)) or modify, in a nonattainment area, any SIP-approved control 

requirement in effect before November 15, 1990 (CAA 193).

EPA EVALUATION – The following is the EPA evaluation of the rule based on 

previously identified criteria.

Enforceability – Sections (D) Recordkeeping Requirements, (G) Prohibition of

Specifications and (F) Prohibitions of Sales and Use and other requirements of Rule 

1168 generally ensure that the submitted rule is adequately clear and enforceable.

Section (E) Methods of Analysis and (F) Test Methods provide the basis for 

evaluating the VOC content in order to keep accurate records and determine the 

VOC content, exempt compound content and control device efficiency to realize the 

enforceability of the rule.

Stringency - We believe Rule 1168 generally meets RACT. Overall, it is as stringent 

as, and in some cases, more stringent than the 2008 CTG. The only exception is 

the Plastic Solvent Welding (PVC) limit of 500 grams per liter which is slightly 

higher than the RACT 510 grams per limit. Rule 1168 is also generally as stringent 
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as, and in some cases, more stringent than CARB’s 1998 “Determination of RACT

and BARCT for Adhesives and Sealants”. The exceptions are:

 Metal to Urethane/Rubber Molding or Casting for which CARB has 250 

grams per liter limit. AVAQMD Rule 1168 has a limit of 850 grams per liter 

which corresponds to the CTG limit.

 Sheet Rubber Lining Installation for which CARB has 250 grams per liter 

limit. AVAQMD Rule 1168 has a limit of 850 grams per liter which

corresponds to the CTG limit.

 Perimeter Bonded Sheet Vinyl for which CARB has 100 grams per liter limit.

AVAQMD Rule 1168 has a limit of 660 grams per liter which corresponds to 

the CTG limit.

 Automotive Glass Adhesive Primers for which CARB has 700 grams per liter 

limit. AVAQMD Rule 1168 has a limit of 900 grams per liter which 

corresponds to the CTG limit. 

The Metal to Urethane/Rubber Molding or Casting, Sheet Rubber Lining Installation

and Perimeter Bonded Sheet Vinyl category limits are considered by CARB to be 

technology forcing. In addition, the BARCT requirements exceed what is required for 

this district as adopted by the California Air Resources Board (CARB). 

SIP Relaxation - The submitted is a new addition to the SIP, strengthening the 

requirements of the SIP. Therefore, we propose to determine that our approval of 

the submittal would comply with CAA § 110(l) and § 193 regarding SIP relaxation

because the submitted SIP rule ensures VOC emissions equivalent to or greater 

than those of the applicable SIP rule for the area, South Coast Air Quality 

Management District (SCAQMD) Rule 1168 as adopted in 2005. In addition, for 

all categories, the rule limits are less than or equal to those limits in the CTG. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

The following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended: 

1. Please consider making the following revisions to the definitions in section 

(B):

a. In subsection (2), Adhesive, please remove the term Adhesive 

Bonding Primer as this category is not used in the rule. 
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b. Subsection (3), Adhesive Bonding Primer, should be deleted as this 

category is not used in the rule.

c. In subsection (36), Grams of VOC per Liter of Adhesive, Less 

Water and Less Exempt Compounds, please add the term “or 

sealant” after Adhesives in the equation since this equation is for 

adhesives and sealants. 

d. In subsection (50), Motor Vehicle Glass Bending Adhesive Primer, 

please delete the word “Adhesive” in the title since that is not a 

category in Table 1 and since the word, adhesive, is even excluded 

in the definition.

e. In subsection (78), Sheet Rubber Lining Installation Adhesive, 

please preface the definition, which presently is for the process of 

sheet rubber lining installation, with “Adhesive used in...”

f. In subsection (91), Tire Repair Adhesive, please replace the 

definition, which presently is for the process of tire repair, with 

“Adhesive used after expanding of a hole, tear, fissure or blemish in 

a tire casing by grinding or gouging and filling the hole or crevice 

with rubber.”

2. For clarity, revise subsection (C) (5) (g) to read “Such other Adhesive 

application methods as are demonstrated to the APCO Officer to be 

capable of achieving a transfer efficiency no less efficiency that is equal to 

or greater than that of the HVLP method and for which prior written 

approval of the APCO has been obtained; or”

3. To avoid conflict with (C) (6), please consider adding a caveat to 

subsection (C) (7): A Person may comply with the provision of subsection 

(C) (1) and subsection (C) (2) by means of an Alternative Emission 

Control Plan pursuant to District Rule 108, Alternative Emission Control 

Plans, except for the 20% emission reduction requirements which are not 

in compliance with the 85% reduction using the approved air pollution 

control equipment described in (C) (6).

4. Per The Little Blue Book, in Sections (E), Methods of Analysis and (F) 

Test Methods please provide titles and EPA approved dates for all ASTM 

methods and all other state or local methods.

a. In subsection (E) (1) use:

i. ASTM D2369-95, Standard Test Method for Volatile Content 

of Coatings.

ii. SCAQMD Method 304-91, Determination of Volatile Organic 

Compounds in Various Materials, February 1996.

iii. Consider adding Appendix A of 40 CFR 63, subpart PPPP 

for VOC Reactive Adhesives for Plastic Parts.

b. In subsection (E) (2) use:

i. SCAQMD Method 302-91, Distillation of Solvents for Paints, 

Coatings and Ink, February 1993.

ii. SCAQMD Method 303-91, Determination of Exempt 

Compounds, August 1996.
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iii. ASTM D4475-85 (91), Test method for Determination of 

Dichloromethane and 1, 1, 1-Trichloroethane in Paints and 

Coatings by Direct Injection Into a Gas Chromatograph.

c. In subsection (E) (3) use:

i. SCAQMD Method 316A-92, Determination of Volatile 

Organic Compounds in Materials Used for Pipes and 

Fittings, October 1996.

d. In subsection (E) (4) use:

i. SCAQMD Method 316B-97, Determination of Volatile 

Organic Compounds in Adhesives Containing 

Cyanoacrylates 1996.

e. In subsection (F)(1) use:

i. CARB Method 422, Exempt Halogenated Volatile Organic 

Compounds in Gases, September 12, 1990.

ii. SCAQMD Method 25.1, Determination of Total Gaseous 

Non-Methane Organic Emissions as Carbon, February 1991.

iii. SCAQMD Method 25.3, Determination of Low Concentration 

Non-Methane Non-Ethane Organic Emissions From Clean 

Fueled Combustion Sources, March 2000.

f. In subsection (F) (2) use:

i. ASTM D1084-08, Standard Test Methods for Viscosity of 

Adhesives.

5. Section (I) indicates that any adhesive, sealant, adhesive or Sealant 

application, operation of person which is exempt from this rule shall 

comply with the applicable provisions of district Rule 442, Usage of 

Solvents. Rule 442 only regulates solvents so it is not likely that any part 

of it, except solvents, will apply to the exempt adhesives and sealants. For 

clarity, Refer to Rule 442 for solvent use applicable to adhesives and 

sealants.

6. Adhesives used in tire repair are exempt in subsection (J) (1) (a). However 

this specific type of adhesive has an assigned VOC limit in subsection (C) 

(1). This seems contradictory and the intent is not clear. 

EPA ACTION - Rule 1168 fulfills the relevant CAA §110 and part D 

requirements. EPA staff recommends a full approval of Rule 1168 pursuant to 

CAA §110(k) (3) and §301(a).

ATTACHMENTS -

1. AVAQMD Rule 1168, Adhesive and Sealant Applications, Amended 

September 20, 2011.
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ADDITIONAL REFERENCES –

1. EPA’s Control Technique Guidelines (CTG) titled, “Control Techniques 

Guidelines for Miscellaneous Industrial Adhesives” EPA-453/R-08-005, 

September 2008.

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r-08-

005_miscellaneous_industrial_adhesives.pdf

2. State of California Air Resources Board’s (CARB) “Determination of 

Reasonably Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) for Adhesives and Sealants” dated December, 

1998 http://www.arb.ca.gov/ractbarc/adhfinal.pdf

3. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

4. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf

5. SCAQMD Rule 1168, Adhesive and Sealant Applications, Amended 

January 7, 2005 http://www.aqmd.gov/rules/reg/reg11/r1168.pdf

6. AVAQMD Rule 108, Alternative Emission Control Plans, Amended May 17, 

2005http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documenti

d=905

7. AVAQMD Rule 109, Recordkeeping For Volatile Organic Compound 

Emissions, Amended April 20, 2010 

http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=90

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8. AVAQMD Rule 442, Usage of Solvents, Amended November 15, 2005 

http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=85

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