1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

5 Post Office Square, Suite 100

Boston, MA 02109-3912

Date: May 18, 2015

Subject: Technical Support Document for Massachusetts VOC Control 

Regulations 

To: SIP file for docket # EPA-R01-OAR-2014-0631

Thru: Anne Arnold, Manager

Air Quality Planning Unit

From: Bob McConnell, Environmental Engineer

Air Quality Planning Unit

On June 1, 2010, and July 10, 2014, Massachusetts submitted 

formal revisions to its State Implementation Plan (SIP). This technical 

support document reviews the adequacy of the VOC control regulations 

made within these submittals. The June 1, 2010 SIP revision request 

contains an updated version of the Commonwealth’s consumer products 

rule, which will reduce volatile organic compound (VOC) emissions from 

consumer products and also architectural and industrial maintenance (AIM) 

coatings. The Commonwealth’s July 10, 2014 submittal contains a 

regulation limiting VOC emissions from adhesives and sealants. The 

Commonwealth’s consumer products regulation is discussed below within 

two separate sections; section I. discusses AIM coatings, and section II. 

discusses consumer products.

The product emission limits within the Commonwealth’s submittals 

were compared to limits previously adopted by EPA. The tables below 

provide the results of this detailed, product-by-product comparison.
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I. Aim Coatings

With regard to AIM coatings, the Commonwealth’s June 1, 2010 

submittal included an amendment to Chapter 310 of the Code of 

Massachusetts Regulations (CMR), section 7.25, Best Available Controls for 

Consumer Products. This regulation includes controls for AIM coatings, 

and EPA approved Massachusetts initial regulation for these coatings on 

December 19, 1995 (60 FR 65240), with a minor update approved on April 

11, 2000 (65 FR 19323). Table 1 provides a comparison of the coating 

emission VOC content limits, in grams/liter, within the Commonwealth’s 

amended rule and EPA’s limits for these coatings contained within 40 CFR 

Part 59, Appendix D, National VOC Emission Standards for Architectural 

Coatings. Within Table 1 and the tables that follow, an entry of “NA” under 

the “EPA” column indicates the coating category is not included within the 

federal rule. 

Table 1: AIM Coatings VOC Content Limits

Coating Category VOC Content Limit (grams/liter)

MA DEP EPA

General coatings

Flat coatings 100 250

Non-flat coatings 150 380

Non-flat high-gloss coatings 250 NA

Specialty coatings

Antenna coatings 530 530

Antifouling coatings 400 450

Bituminous roof coatings 300 500

Bituminous roof primers 350 500

Bond breakers 350 600
3

Calcimine recoater 475 475

Clear Wood Coatings:

1. Clear brushing lacquers

2. Lacquers (including lacquer sanding sealers)

3. Sanding sealers (other than lacquer sanding 

sealers)

4. Varnishes

680

550

350

350

NA

680

NA

450

Concrete curing compounds 350 350

Concrete surface retarders 780 780

Conversion varnishes 725 725

Dry fog coatings 400 400

Faux finishing coatings 350 700

Fire resistive coatings 350 850/450

Fire retardant coatings:

1. Clear

2. Opaque

650

350

850

450

Floor coatings 250 400

Flow coatings 420 450

Form-release compounds 250 450

Graphic arts coatings (sign paints) 500 500

High temperature coatings 420 650/4201

 

1 The federal AIM rule separates these coatings into high temperature coatings, with a VOC content limit 

of 650 grams per liter (g/l), and heat reactive coatings, with a limit of 420 g/l.
4

Impacted immersion coatings 780 780

Industrial maintenance coatings 340 450

Low-solids coatings 120 120

Magnesite cement coatings 450 600

Mastic texture coatings 300 300

Metallic pigmented coatings 500 500

Multi-color coatings 250 580

Nuclear coatings 450 450

Pretreatment wash primers 420 780

Primers, sealers, and undercoaters 200 350/4002

Quick dry enamels 250 450

Quick dry primers, sealers, and undercoaters 200 450

Recycled coatings 250 NA

Roof coatings 250 250

Rust preventative coatings 340 400

Shellacs3

1. Clear

2. Opaque

730

550

730

550

Specialty primers, sealers, and undercoaters 350 NA

Stains 250 550/3504

 

2 The federal AIM rule establishes a VOC content limit of 350 g/l for primers and undercoaters, and a limit 

of 400 g/l for sealers.

3 The Commonwealth defines “shellacs” more narrowly than the federal AIM rule; the former only 

includes coatings derived from the resinous secretions of the lac beetle, whereas the latter includes such 

coatings and also other similarly derived coatings.
5

Swimming pool coatings 340 600

Swimming pool repair and maintenance coatings 340 NA

Temperature-indicator safety coatings5 550 NA

Thermoplastic rubber coatings and mastics 550 550

Traffic marking coatings 150 150

Waterproofing sealers 250 600

Waterproofing concrete/masonry sealers 400 NA

Wood preservatives 350 550/550/550/3506

We note that a minor difference exists in how recycled coatings are 

treated within the Commonwealth’s AIM coating rule and the federal rule. 

The Commonwealth’s rule, as indicated in Table 1 above, establishes a VOC 

content limit of 250 grams per liter (g/l) for recycled coatings. The federal 

AIM rule employs use of a formula based on the percent of the coating that 

is from recycled materials, and then determines an adjusted VOC content 

that is compared to the normative standard for that product category. 

Therefore, it is conceivable that the Commonwealth’s regulation could 

provide a less stringent standard than the federal AIM rule would provide for 

product containing recycled materials. If this situation occurs, we note that 

the limits within the federal AIM rule would need to be met. Additionally, 

there are a number of product categories in the federal AIM rule that are not 

similarly named within the Commonwealth’s rule. Table 2 below identifies 

these product categories, and links them to the product category with the 

Massachusetts AIM rule that applies to them. In all cases the 

Commonwealth’s VOC content limits are either more stringent than, or 

equivalent to, those within the federal AIM rule.

 

4 The federal AIM rule separates this category into clear stains, which have a VOC content limit of 550 g/l, 

and semitransparent & opaque stains, which are held to a limit of 350 g/l.

5 The federal AIM rule covers these coatings under the limit for high temperature coatings.

6 The federal AIM rule separates this category into four parts with the following VOC content limits: below

ground wood treatment preservatives, clear wood preservatives, and semitransparent wood preservatives, 

550 g/l; opaque wood preservatives, 350 g/l.
6

Table 2: Cross-link between federal AIM rule and MA-DEP rule for certain 

coating categories

Federal AIM rule MA DEP rule

Coating category VOC content 

limit (g/l)

Corresponding MA-DEP 

category

VOC content 

limit (g/l)

Anti-graffiti coatings 600 Industrial maintenance 

coatings (permanent type)

340

Bituminous coatings and 

mastics

500 Flat or non-flat (for 

bituminous pavement 

sealers)

Bituminous roof coating

Bituminous roof primers

Industrial maintenance 

coatings

Metalic pigmented 

coatings (for bituminous 

aluminum roof coatings 

that meet the metallic 

pigmented coating 

definition)

100/150

300

350

340

500

Chalkboard resurfacers 450 Industrial maintenance 

coatings

340

Concrete curing and 

sealing compounds

700 Concrete curing 

compounds

Water proofing 

concrete/masonry sealers

350

400

Concrete protective 

coatings

400 Water proofing 

concrete/masonry sealers

400

Extreme high durability

coatings

800 Industrial maintenance 

coatings

340

Heat reactive coatings 420 Industrial maintenance 

coatings7

340

Nonferrous ornamental 

metal lacquers and 

surface protectants 

870 Rust preventative coatings 400

Repair and maintenance 

thermoplastic coatings

650 Industrial maintenance 

coatings

340

Stain controllers 720 Low solids 1208

Zone marking coatings 450 Traffic marking 150

 

7 The Commonwealth’s industrial maintenance coating VOC content limit applies to heat reactive coatings 

unless they are applied in the field.

8 Including water and exempt coatings
7

Massachusetts’ revised requirements for AIM coatings contains a 

“sell through” provision which enabled coating manufacturers to sell 

coatings manufactured before the effective date of these requirements to be 

sold for up to three years from the rule’s January 1, 2009 compliance date. 

The rule also includes labeling and recordkeeping requirements that are 

consistent with EPA’s requirements. Coating manufacturers must maintain 

coating production records for a minimum of 5 years, and make these 

records available upon request. 

Additional updates to the Commonwealth’s previously SIP-approved 

requirements for AIM coatings include the following items:

1. The requirement at 7.25(4) regarding a prohibition against 

specifying non-compliant AIM products for work to be done 

within Massachusetts was moved to 7.25(11) because it pertains 

to AIM coatings, and does not apply to consumer and 

commercial products.

2. A provision explaining that possible future emission standards 

promulgated by EPA would override existing Massachusetts 

standards was removed. We note, however, that any future EPA 

standards that are more stringent that the comparable 

Massachusetts standard would indeed need to be complied with.

3. Requirements for products registered pursuant to the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA) were 

moved from 7.25(6) to 7.25(11) and (12). 

4. The existing innovative products exemption was moved from 

7.25(7) to 7.25(12);

5. The requirement at 7.25(8) that compliance certifications be 

submitted to the Massachusetts Department of Environmental 

Protection (MA-DEP) was removed, but the obligation for 

sources to prepare and maintain this information on site, and 

submit it to MA-DEP upon request, was retained. 

The updates Massachusetts has made to its existing AIM coatings 

regulation strengthen the rule and are consistent with the Clean Air Act, and 
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we therefore I recommend approving them as revisions to the 

Commonwealth’s SIP.

II. Consumer products requirements.

The Commonwealth’s updated consumer product requirements 

became effective January 1, 2009, by which time other OTC states, and 

California, had adopted similar limits. This enables manufacturers to 

achieve compliance by using product reformulations that are similar to the 

available compliant products in other jurisdictions. Table 3 below contains 

the VOC content limits within Massachusetts’ updated regulation and the 

federal requirements located at 40 CFR 59, Subpart C, “National VOC 

Emission Standards for Consumer Products.” In Table 3, “NA” entries 

within the EPA column indicates that product category is not contained 

within the federal rule.

The consumer products provisions of 310 CMR 7.25 contain a 

number of flexibility provisions, including the three year sell through 

provision mentioned earlier with regard to the AIM coating requirements. 

The rule also allows an entity to apply for a variance that would postpone 

compliance upon a successful showing of an economic hardship due to the 

tightened limits within the rule. A manufacturer may apply directly to the 

MA-DEP for such an exemption, or alternatively, may request that an 

exemption awarded by CARB be used for compliance in Massachusetts. In 

the latter case, the CARB issued exemption must be shown to be based on 

data that is valid in the Commonwealth. In order for a variance to be 

granted, a source must meet a number of requirements including a 

demonstration that compliance would result in extraordinary economic 

hardship, and submittal of a compliance report indicating that the source will 

meet the rule’s requirements as expeditiously as possible. Additionally, the 

rule requires that any such request for a variance be subject to a public 

hearing, and must also be approved by EPA before becoming effective.

 

The Commonwealth initially chose to not allow alternative 

compliance plans (ACPs) within its regulation, but changed course and 

adopted provisions allowing for them within amendments made on March 6, 

2009, in part due to comments from industry requesting this flexibility. The 

provision allows manufacturers to average VOC emissions among products 
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to meet overall VOC emission limits, and is used by other OTC states and by 

CARB within their consumer products rules. After consulting with other 

states on their experience offering this flexibility, the Commonwealth 

determined that it was appropriate to allow this with its consumer products 

regulation. EPA commented that any such ACP would need to be approved 

into the Massachusetts SIP, and within its response to comments the 

Commonwealth committed to submit any such ACP it receives to EPA for 

approval into the Massachusetts SIP.

 

Table 3: Consumer Products VOC Content Limits

Consumer Product Category VOC Content Limit (g/l)

MA DEP EPA

Adhesive removers

Floor or wall covering 5 NA

Gasket or thread locking 50 NA

General purpose 20 NA

Specialty 70 NA

Adhesives

Aerosols:

 Mist spray

 Web spray

65

55

75

Special purpose spray adhesives:

 Mounting; automobile engine 

compartment; flexible vinyl

 Polystyrene foam and automobile 

70

65

NA

NA
10

headliner

 Polyolefin and laminate 

repair/edgebanding

60 NA

Contact:

 General purpose

 Special purpose

55

80

80

Construction, panel, floor covering 15 40

General purpose 10 10

Structural, waterproof 15 15

Air fresheners

Single-phase aerosol 30 70

Double-phase aerosol 25 30

Dual purpose freshener/disinfectant 60 NA

Liquids/pump spray 18 18

Solids/gels 3 3

Antiperspirants

Aerosol 40 HVOC9

10 MVOC10

60 HVOC

NA

Non-aerosol 0 HVOC

0 MVOC

NA

Anti-static (non-aerosol) 11 NA

 

9 HVOC (High volatility organic compound) means a VOC that exerts a vapor pressure greater than 80 

millimeters (mm) of Mercury (Hg) when measured at 20 degrees centigrade.

10 MVOC (Medium volatility organic compound) means a VOC that exerts a vapor pressure greater than 2 

mm Hg and less than or equal to 80 mm Hg when measure at 20 degrees centigrade.
11

Automotive brake cleaners 45 NA

Automotive rubbing or polishing 

compound

17 NA

Automotive wax, polish, sealant or 

glaze

Hard paste waxes 45 NA

Instant detailers 3 NA

All other forms 15 NA

Automotive windshield washer fluid 35 35

Bathroom and tile cleaners

Aerosols 7 7

All other forms 5 5

Bug and tar remover 40 NA

Carburetor and choke cleaners 45 75

Carpet and Upholstery Cleaners

Aerosols 7 NA

Non-aerosols (dilutables) 0.1 NA

Non-aerosols (ready-to-use) 3.0 NA

Cooking spray aerosols 18 18

Deodorants

Aerosol 0 HVOC

10 MVOC

20 HVOC

Non-aerosol 0 HVOC NA
12

0 MVOC

Dusting aides

Aerosols 25 35

All other forms 7 7

Engine degreasers

Aerosols 35 75

Non-aerosols 5 75

Electrical cleaner 45 NA

Electronic cleaner 75 NA

Fabric protectants 60 75

Fabric refresher

Aerosol 15 NA

Non-aerosol 6 NA

Floor polishes/waxes

Products for flexible flooring materials 7 7

Products for non-resilient flooring 10 10

Wood floor wax 90 90

Floor wax strippers11

For removal of light or medium build-up 

of polish

3 (as applied) NA

For removal of heavy build-up of polish 12 (as applied) NA

 

11 The label of each non-aerosol floor wax stripper must specify a dilution ratio for light, medium, or heavy 

build-up of polish.
13

Foot ware of leather care products

Aerosol 75 NA

Solid 55 NA

All other forms 15 NA

Furniture maintenance products

Aerosol 17 25

All other forms except solid or paste 7 NA

Graffiti remover

Aerosol 50 NA

Non-aerosol 30 NA

General purpose cleaners 10

Aerosols 10

Non-aerosols 4

General purpose degreasers

Aerosols 50 NA

Non-aerosols 4 NA

Glass cleaners

Aerosols 12 12

All other forms 4 8

Hair mousses 6 16

Hair shines 55 NA

Hair sprays 55 80

Hair styling gels 6 6
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Hair styling products

Aerosol and pump sprays 6 NA

All other forms 2 NA

Heavy-duty hand cleaners or soaps 8

Insecticides

Crawling bug 40

 Aerosol 15

 All other forms 20

Flea and tick 25 25

Flying bug 35

 Aerosol 25

 All other forms 35

Foggers 45 45

Lawn and garden 20

 Non-aerosol 3

 All other forms 20

Wasp and hornet 40 NA

Laundry prewash

Aerosol/solids 22 22

All other forms 5 5

Laundry starch products 5 5

Metal polishes/cleaners 30 NA

Multi-purpose lubricant (Excluding 50 NA
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solid or semi-solid products)

Nail polish removers 75 85

Non-selective terrestrial herbicide; 

non-aerosols

3 NA

Oven Cleaners

Aerosols/pump sprays 8 8

Liquid 5 5

Paint remover or stripper 50 NA

Penetrants 50 NA

Rubber and vinyl protectants

Non-aerosol 3 NA

Aerosol 10 NA

Sealants and caulking compounds 4 NA

Shaving creams 5 5

Shaving gel 7 NA

Silicone-based multi-purpose 

lubricants (excluding solid or semi-solid 

products)

60 NA

Spot removers NA

Aerosols 25

Non-aerosols 8

Tire sealants and inflators 20 NA

Toilet/urinal care products NA
16

Aerosols 10

Non-aerosols 3

Wood cleaners NA

Aerosols 17

Non-aerosols 4

Undercoatings – aerosols 40 NA

 

The VOC content limits within Table 3 indicate that in all instances 

the Commonwealth’s limits are equal to, or more stringent than, the 

comparable EPA limit. Our review of these amendments to Massachusetts’ 

consumer products regulation finds that they act to substantially strengthen 

them and will help to further reduce VOC emissions, and we are therefore 

approving them into the Commonwealth’s SIP.

III. Adhesives and sealants regulation

The Commonwealth’s adhesives and sealants regulation imposes 

VOC content limits or other controls on a number of products, and is based 

on similar control measures that many California air districts, and other 

states in the Northeast, have adopted. In particular, Massachusetts based its 

regulation on a 2006 OTC model rule, which in turn was based on earlier 

requirements adopted in California, and on EPA’s 2008 document, “Control 

Techniques Guidelines for Miscellaneous Adhesives.” EPA develops 

Control Technique Guidelines (CTGs) to assist states with determining the 

appropriate level of control for sources subject to RACT. Due to its 

inclusion within the Ozone Transport Region, the Commonwealth is 

required to ensure that RACT is applied to industrial sources in the state 

pursuant to section 184(b)(1)(B) of the CAA. In 2006, 2007, and 2008, EPA 

published final CTGs for a number of VOC emitting activities, and 

Massachusetts’ adoption of this regulation satisfies the states obligation to 

adopt regulations for this particular CTG. 

Although Massachusetts’ existing Consumer Products regulation at 

310 CMR 7.25(12) regulates “household” adhesives and sealants, it exempts 

such products sold in containers and volumes more than 16 fluid ounces or 
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weighing more than 1 pound. Many of these exempted items would be 

covered by the Commonwealth’s adhesives and sealants rule. The 

compliance date within the Commonwealth’s adhesives and sealants rule is 

January 1, 2015 with regard to a manufacturer of products sold in the state. 

Additionally, the compliance date is September 1, 2015, for any person who 

sells, supplies, or offers for sale any covered product in Massachusetts, and 

May 1, 2016 for any person who uses, applies, or solicits the use of covered 

products in Massachusetts. 

Table 4 below provides the VOC content limits contained within 

the rule for the covered product categories, which are adhesives, sealants, 

adhesive primers, and sealant primers, and Table 5 contains the VOC 

content limits for adhesives applied to particular substrates. The 

Commonwealth’s adhesives and sealants rule also contains testing, labeling, 

and recordkeeping requirements for entities subject to the rule.

Table 4: VOC Content Limits from the Massachusetts Adhesives and Sealants rule

Product Category VOC Content Limit (as applied)

(grams/liter)

Adhesives

ABS welding 400

Ceramic tile installation 130

Computer diskette jacket manufacturing 850

Contact 250

Cove base installation 150

CPVC welding 490

Indoor floor covering installation 150

Metal to urethane/rubber molding or casting 850
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Multipurpose construction 200

Non-membrane roof installation/repair 300

Outdoor floor covering installation 250

Perimeter bonded sheet vinyl flooring 

installation

660

Plastic cement welding (non-ABS) 500

PVC welding 510

Sheet rubber lining installation 850

Single-ply roof membrane installation/repair 250

Structural glazing 100

Thin metal laminating 780

Tire retread 100

Waterproof resorcinol glue 170

Sealants

Architectural 250

Marine deck 760

Non-membrane roof installation/repair 300

Roadway 250

Single-ply roof membrane 450

Other 420

Adhesive Primers

Automotive glass 700

Plastic cement welding 650
19

Single-ply roof membrane 250

Traffic marking tape 150

Other 250

Sealant Primers

Non-porous architectural 250

Porous architectural 775

Marine deck 760

Other 750

Table 5: VOC Content Limit for Adhesives Applied to Particular Substrates

Substrate Category VOC Content Limit as Applied 

(grams/liter)

Flexible Vinyl 250

Fiberglass 200

Metal 30

Porous Material 120

Reinforced plastic composite 200

Rubber 250

Wood 30

Other substrates 250
20

The Massachusetts rule contains VOC content limits that are equal 

to, or more stringent than, the comparable limits within EPA’s CTG. EPA’s 

CTG contains VOC content limits for “motor vehicle adhesives” and “motor 

vehicle weather-strip adhesives,” two product categories not directly 

addressed in the Commonwealth’s rule. In its response to comments 

document prepared for the adhesives and sealants rulemaking, 

Massachusetts notes this difference and indicates that adhesives that fall 

under these two categories will be regulated under the applicable category 

limits for adhesives applied to particular substrates. These limits have a 

maximum VOC content of 250 grams/liter and are at least as stringent as the 

limits for motor vehicle adhesives and motor vehicle weather-strip adhesives 

within EPA’s CTG. 

The Commonwealth’s adhesives and sealants rule also contains 

testing, labeling, and recordkeeping requirements for entities subject to the 

rule. We are approving the Commonwealth’s adhesives and sealants 

regulation as meeting the requirements of RACT as outlined within EPA’s 

2008 CTG for this category of VOC emitting products.