1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: June 23, 2015

SUBJECT: Technical Support Document for Maryland’s Adoption of Control Techniques

Guidelines (CTG) for Metal Furniture and Miscellaneous Metal Parts Coatings

FROM: Ellen Schmitt

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) provides that State Implementation Plans (SIP) for 

nonattainment areas must include reasonably available control measures (RACM), including 

reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) 

provides that for certain nonattainment areas, states must revise their SIP to include RACT for 

sources of volatile organic compound (VOC) emissions covered by a control techniques

guideline (CTG) document issued after November 15, 1990 and prior to the Area’s date of 

attainment. The Environmental Protection Agency (EPA) defines RACT as “the lowest emission 

limitation that a particular source is capable of meeting by the application of control technology 

that is reasonably available considering technological and economic feasibility” (44 FR 53761, 

Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how states can meet 

the RACT requirements of the CAA. 

CTGs are documents issued by EPA that provide state and local air pollution control authorities 

information that should assist them in determining RACT for VOC from various sources. EPA 

may issue a CTG in lieu of a national regulation as RACT for a product category where EPA 

determines that the CTG will be substantially as effective as regulations in reducing emissions of 

VOC in ozone nonattainment areas. The recommendations in the CTG are based upon available 

data and information and may not apply to a particular situation based upon the circumstances. 

States can follow the CTG and adopt state regulations to implement the recommendations 

contained therein, or they can adopt alternative approaches. In either case, states must submit 

their RACT rules to EPA for review and approval as part of the SIP process. 

EPA will evaluate the rules and determine, through notice and comment rulemaking in the SIP 

approval process, whether the submitted rules meet the RACT requirements of the CAA and 

EPA’s regulations. 
2

Metal Furniture Coating CTG (EPA 453/R-07-005, September 2007)

In December 1977, EPA issued a CTG document for controlling VOC emissions from the 

coating of metal furniture. In October 1982, EPA promulgated the new source performance 

standards (NSPS) for the Surface Coating of Metal Furniture, and in May 2003, EPA 

promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the 

Surface Coating of Metal Furniture. After reviewing the 1977 CTG, the 1982 NSPS, and the 

2003 NESHAP, and existing state and local VOC emission reduction approaches, EPA 

developed a CTG entitled, “Control Technique Guidelines for Metal Furniture Coatings” (EPA 

453/R-07-005).

Coatings used in metal furniture coating operations include paints, sealants, caulks, ink, 

adhesives, and maskants.1 It is recommended that the control approaches discussed herein apply 

to each metal furniture coating unit2at a facility where the total actual VOC emissions from all 

metal furniture coating operations, including related cleaning activities, at that facility, are equal 

to or exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per 12-month rolling 

period, before consideration of controls. These control approaches are not recommended for 

facilities that emit below this level. 

The metal furniture coatings product category under section 183(e) of the CAA includes the 

coatings that are applied to metal furniture. A metal furniture substrate is the furniture or 

components of furniture constructed either entirely or partially from metal. Metal furniture 

includes, but is not limited to, the following types of products: Household, office, institutional, 

laboratory, hospital, public building, restaurant, barber and beauty shop, and dental furniture, as 

well as components of these products. Metal furniture also includes office and store fixtures, 

partitions, shelving, lockers, lamps and lighting fixtures, and wastebaskets. Metal furniture 

coatings include paints and adhesives and are typically applied without a primer. Higher solids 

and powder coatings are used extensively in the metal furniture coating industry. Metal furniture 

coatings provide a covering, finish, or functional or protective layer, and can also provide a 

decorative finish to metal furniture. 

Applicability

The September 2007 CTG for Metal Furniture coatings provides recommendations for reducing 

VOC emissions from the use of coatings applied to each metal furniture coating unit at a facility 

where the total actual VOC emissions from all metal furniture coating operations, including 

related cleaning activities, at that facility, are equal to or exceed 6.8 kg/day (15 lb/day), or an 

equivalent level such as 3 tons per 12-month rolling period, before consideration of controls. As 

mentioned previously, states can adopt the above recommended 6.8 kg/day (15 lb/day) actual 

 

1 Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, or any 

combination of these substances are not considered metal furniture coatings.

2 A coating unit consists of a series of one or more coating applicators and any associated drying area and/or oven 

wherein a coating is applied, dried, and/or cured. A coating unit ends at the point where the coating is dried or 

cured, or prior to any subsequent application of a different coating. It is not necessary for a coating unit to have an 

oven or flash-off area.
3

VOC emissions or an equivalent applicability threshold, or they can develop other applicability 

criteria that they determine are appropriate considering the facts and circumstances of the 

sources in their particular nonattainment areas. 

Sources of VOC Emissions

Primarily, emissions from metal furniture coating operations result from the evaporation of the 

VOC components of the coatings and cleaning materials. In most cases, VOC emissions from 

the surface preparation, storage, handling, and waste/wastewater operations are relatively small. 

The primary VOC emissions from metal furniture coatings occur during coating 

application/flash-off and drying/curing of the coatings. The remaining emissions are primarily 

from mixing and/or thinning. The VOC emissions from mixing and thinning of coatings occur 

from the displacement of VOC-laden air in containers used to mix coatings containing solvents 

(thinners) prior to coating application. The displacement of VOC-laden air can also occur during 

filling of containers and can be caused by changes in temperature, changes in barometric 

pressure, or agitation during mixing.

Coating Application

Surface coating of metal furniture is applied by applying a coating to the metal furniture 

component or product. After being coated by any of the typical coating methods (e.g., spray 

coating or dip coating), the metal furniture components or products are dried/cured. Prior to 

entering the ovens, solvents in the coatings evaporate slowly in the flash-off area to prevent 

bubble formation during curing. The coating itself may be in the form of a liquid or powder, and 

may be applied by spraying or dipping. The amount of VOC emissions from the flash-off area 

depends on the type of coating used, how quickly the component or product moves through the 

flash-off area, and the distance between the application area and the bake oven. For liquid spray 

applications, it is estimated that 65-80 percent of the volatiles are emitted during the application 

and flash-off operations, and the remaining 20-35 percent from the drying/curing operation.

For powder coatings, the curing/drying step melts the powder and forms a continuous coating on 

the metal furniture component or product. For liquid coatings, this step removes any remaining 

volatiles from the coating. The cured coatings provide the desired decorative and/or protective 

characteristics. The VOC emissions during the curing/drying process result from the evaporation 

of the remaining solvents in the dryer.

There are several different types of applicators that may be used to apply coatings. The most 

common types of coating applicators include: Air atomized spray coating, electrostatic spray 

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

electrocoating, and autophoretic coating.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from metal furniture coating 

operations: (1) evaporation of VOC from the coatings; and (2) evaporation of VOC from the 

cleaning materials. To control VOC emissions from metal furniture coatings, the CTG 
4

recommends three options: (1) emission limits that can be achieved through the use of low-VOC 

coatings; (2) equivalent emission limits that can be achieved through the use of low-VOC 

coatings or a combination of coatings and add-on controls; and (3) an overall control efficiency 

of 90 percent for add-on controls. The low-VOC coatings recommendation (Option 1) consists 

of emission limits in terms of mass of VOC per volume of coating, excluding water and exempt 

compounds, as applied, and the use of specified application methods. The equivalent emission 

limit recommendation (Option 2) consists of emission limits in terms of mass of VOC per 

volume of coating solids, as applied, and the use of specific application methods. Additionally, 

for cleaning materials, work practices are recommended to reduce VOC emissions. 

Specific recommendations for coating operations and cleaning materials used in metal furniture 

coating operations are summarized below.

Emissions Limits Based on Low-VOC Coatings-Option

The CTG recommends emission limits for one-component and multi-component general purpose 

coatings. In addition, specific emission limits for certain specialty coatings are recommended. 

For each of these coating types, separate emission limits are recommended for baked and airdried coatings. Table 1 provides the recommended emission limits expressed in terms of mass of 

VOC per volume of coating (excluding water and exempt compounds, as applied) for option 1, 

content limits based on low-VOC coatings.

3

Table 1. Metal Furniture Coating VOC Content Limits – VOC Content Limits are 

Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume (Liter (l) for Gallon (gal)) of 

Coating Less Water and Exempt Compounds, as Applied

Coatings Type Baked Air Dried

kg VOC/l

coating

lb VOC/gal

coating

kg VOC/l

coating

lb VOC/gal

coating

General, One Component 0.275 2.3 0.275 2.3

General, Multi-Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

The following types of coatings and coating operations are exempt from the recommended VOC 

content limits: Stencil coatings, safety-indicating coatings, solid-film lubricants, electricinsulating and thermal conducting coatings, touch-up and repair coatings, and coating 

applications utilizing hand-held aerosol cans.

 

3 Maryland used option 1, limits based on low-VOC coatings, from the control options listed in the Metal Furniture 

Coatings CTG (EPA 453/R-07-005, September 2007) and only the emission limits for option 1 are listed in this 

TSD. Further details of the other control options and the accompanying emission limits per coating type can be 

found in the CTG for metal furniture coatings. 
5

The CTG recommends that all VOC-containing materials used by each metal furniture coating 

unit be included when determining the coating unit’s emission rate. Additionally, the following 

application methods are recommended: Electrostatic application, HVLP spray, flow coat, roller 

coat, dip coat including electrodeposition, or brush coat.

Work Practices for Coating Operations and Cleaning Materials

Work practices to further reduce emissions from the coatings as well as minimize emissions from 

cleaning materials used for large appliance coating operations are recommended, and they are: 

store all VOC-containing coatings, thinners, and cleaning materials in closed containers; 

minimize spills of VOC-containing coatings, thinners, and cleaning materials; clean up spills 

immediately; convey any coatings, thinners, and cleaning materials in closed containers or pipes; 

close mixing vessels that contain VOC coatings and other materials, except when in use; and 

minimize usage of solvents during cleaning of storage, mixing, and conveying of equipment.

Miscellaneous Metal and Plastic Parts Coatings CTG (EPA 453/R-08-003, September 2008)

In June 1978, EPA issued a CTG document for controlling VOC emissions from the coating of 

miscellaneous metal parts and products. In January 1988, EPA promulgated the NSPS for the 

Surface Coating of Plastic Parts for Business Machines. In February 1994, EPA issued an 

Alternative Control Techniques (ACT) document for controlling VOC emissions from the 

coating of automotive/transportation and business machine plastic parts. In January 2004, EPA 

promulgated the NESHAP for Miscellaneous Metal Parts and Products Surface Coating. In 

April 2004, EPA promulgated the NESHAP for Plastic Parts and Products Surface Coating. 

After reviewing the 1978 CTG, the 1988 NSPS, the 1994 ACT, and existing state and local VOC 

emission reduction approaches, EPA developed a new CTG combining the requirements for 

miscellaneous metal and plastic parts coatings into a single CTG, entitled “Control Techniques

Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (EPA 453/R-08-003, September 

2008).4

Miscellaneous metal products parts coatings include, but are not limited to, the coatings that are 

applied to the surfaces of a varied range of metal parts. These parts or products are constructed 

either entirely or partially from metal. They include, but are not limited to, metal components of 

the following types of products as well as the products themselves: Fabricated metal products, 

small and large farm machinery, commercial and industrial machinery and equipment, 

automotive or transportation equipment, interior or exterior automotive parts, construction 

equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, 

pleasure craft (recreational boats)5, extruded aluminum structural components, railroad cars, 

heavier vehicles6, lawn and garden equipment, business machines, laboratory and medical 

 

4 Maryland previously submitted, and EPA approved, a SIP revision to meet the requirements to adopt RACT for 

plastic part coatings covered by the CTG for Miscellaneous Metal and Plastic Parts Coatings. See 76 FR 64020

(October 17, 2011).

5 Maryland previously submitted, and EPA approved, a SIP revision to meet the requirements to adopt RACT for 

pleasure craft coatings covered by the CTG for Miscellaneous Metal and Plastic Parts Coatings. See 78 FR 59240

(September 26, 2013). 

6 Heavier vehicles includes all vehicles that meet the definition of the term “other motor vehicles,” as defined in the 
6

equipment, electronic equipment, steel drums, metal pipes, and numerous other industrial and 

household products (hereinafter collectively referred to as “miscellaneous metal parts”). The 

CTG applies to manufacturers of miscellaneous metal parts that surface-coat the parts they 

produce. Miscellaneous metal parts coatings do not include coatings that are a part of other 

product categories listed under section 183(e) of the CAA for which CTGs have been published 

and/or coatings addressed by other CTGs. These other categories that are not part of the 

miscellaneous metal products coatings categories include shipbuilding and repair coatings; 

aerospace coatings; wood furniture coatings; metal furniture coatings; large appliance coatings; 

automobile and light-duty truck assembly coatings; flatwood paneling coatings; miscellaneous 

industrial adhesives; fiberglass boat manufacturing materials; and paper, film, and foil coatings. 

Can coatings, coil coatings, and magnet wire coatings were not listed under section 183(e) of the 

Act, but were addressed by earlier CTGs, and are also not included in the miscellaneous metal 

parts coatings categories addressed by this CTG.

Applicability

The September 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings provides 

recommendations for reducing VOC emissions from the use of coatings in a miscellaneous metal 

products coating unit at a facility where the total actual VOC emissions from all miscellaneous 

metal parts coating operations, including related cleaning activities, at that facility, are equal to

or exceed 6.8 kg/day, 15 lb/day, or an equivalent level of 2.7 tons per 12-month rolling period,

before consideration of controls. A coating unit consists of a series of one or more coating 

applicators and any associated drying area and/or oven where a coating is applied, dried, and/or 

cured. A coating unit ends at the point where the coating is dried or cured, or prior to any 

subsequent application of a different coating. As mentioned previously, states can adopt the 

above recommended 6.8 kg/day (15 lb/day) actual VOC emissions, or an equivalent applicability 

threshold, or they can develop other applicability criteria that they determine are appropriate 

considering the facts and circumstances of the sources in their particular nonattainment areas. 

EPA will review the state RACT rules in the context of the SIP revision process. For facilities 

that coat bodies and/or body parts for new heavier vehicles, EPA recommends that these 

facilities have the option of meeting either the state RACT requirements for miscellaneous 

metals parts coatings or the state RACT requirements for auto and light-duty truck coatings.7

Sources of VOC Emissions

Primarily, VOC emissions from miscellaneous metal products parts coating operations result 

from the evaporation of volatile components from the coatings and cleaning materials. The 

majority of VOC emissions from these materials occur during coating application/flash-off and 

drying/curing of the coatings. The remaining emissions are primarily from mixing and/or 

thinning. In most cases, VOC emissions from surface preparation, storage, handling, and 

waste/wastewater operations are relatively small.

 

National Emission Standards for Surface Coating of Automobile and Light-Duty Trucks at 40 CFR 63.3176.

7 Maryland’s SIP submission to meet requirements as recommended by the CTG for Miscellaneous Metal and 

Plastic Parts Coatings includes heavier vehicle coatings as a type of miscellaneous metal coating. 
7

Coating Application 

Surface coating of miscellaneous metal products parts surfaces is applied by applying a coating 

to the metal followed by curing or drying the coating. The coating itself may be in the form of a 

liquid or powder. Several different types of application technologies are used to apply liquid 

coatings, and the selection of the application technology can have a significant effect on the 

amount of coating used and the resulting VOC emissions from the operation. The most common 

types of liquid coating applicators include: Air atomized spray coating, electrostatic spray 

coating, HVLP spray coating, dip coating, flow coating, roll coating, electrocoating, and

autophoretic coating. Powder coatings can be applied through electrostatic spraying or dipping. 

An alternative to the coating techniques outlined in EPA’s CTG for this source category would 

need to be approved by the State and EPA.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from miscellaneous metal 

parts coating operations: (1) evaporation of the VOC components of the coatings; and (2) 

evaporation of VOC from the cleaning materials. To control VOC emissions from miscellaneous 

metal parts coatings, the CTG recommends these three options: (1) VOC content limits for each 

coating category based on the use of low-VOC content coatings and specified application 

methods to achieve good transfer efficiency; (2) equivalent VOC emission rate limits based on 

the use of a combination of low-VOC coatings, specified application methods, and add-on 

controls; or (3) an overall VOC control efficiency of 90 percent for facilities that choose to addon controls instead of low-VOC content coatings and specified application methods. The lowVOC coatings recommendation (Option 1) consists of VOC content limits in terms of mass of 

VOC per volume of coating, as applied, excluding water and exempt compounds, and the use of

specified application methods. The equivalent emission rate limit recommendation (Option 2) 

consists of emission rate limits in terms of mass of VOC emitted per volume of coating solids, as 

applied, and the use of specific application methods. This option is intended only for facilities 

using a combination of low-VOC coatings, specific application methods, and add-on control 

equipment on a coating unit to meet the recommended limits for mass of VOC emitted per 

volume of coating solids. 

In addition, it is recommended that one or more of the following coating application methods be 

used in conjunction with the use of low-VOC content coatings in Options 1 and 2: Electrostatic 

application, HVLP spray, flow coat, roller coat, dip coat (including electrodeposition), airless 

spray, air-assisted airless spray, or other coating application methods capable of achieving a 

transfer efficiency equivalent to or better than that achieved by HVLP spraying. Under an addon control option, (Option 3), a facility would use an emission capture system and add-on control 

device to achieve an overall emission capture and control efficiency of at least 90 percent. The 

facility would not have to limit the VOC content of the coating materials and would not need to 

use any particular coating application method. 
8

The first two options are expected to achieve equivalent VOC emission reductions. The third 

option provides facilities the flexibility to use a high efficiency add-on control in lieu of lowVOC coatings and specified application methods, especially when the use of high VOC coatings 

is necessary or desirable. The third option is expected to achieve an emission reduction at least 

as great as the first two options.

Additionally, work practices to further reduce VOC emissions from coatings as well as to 

minimize emissions from cleaning materials used in the coating process are recommended.

Consistent with the state rules which are the basis for the recommended VOC limits, the CTG 

recommends VOC limits and application methods not apply to certain types of coatings and 

coating operations. For all coating operations, it is recommended that the VOC limits and 

application methods not apply to aerosol coatings products or powder coatings. Aerosol coatings 

are a separate category under Section 183(e) of the CAA, and powder coatings are an inherently 

low-VOC alternative to many liquid coatings.

The CTG recommends that for all metal parts coatings, only the recommended work practices, 

but not the recommended VOC limits and application methods, apply to the following types of 

coatings and coating operations: Stencil coatings, safety indicating coatings, solid-film 

lubricants, electric-insulating and thermal-conducting coatings, magnetic data storage disk 

coatings, and plastic extruded onto metal parts to form a coating. In addition, for all metal parts 

coatings, it is recommended that the recommended application methods not apply to touch-up 

coatings, repair coatings, and textured finishes, but that the recommended VOC limits and work 

practices apply.

For cleaning materials, the CTG recommends that work practices be used with all three of the 

control options to reduce VOC emissions. The application of add-on controls in conjunction 

with these work practices is not recommended. In addition, the use of a VOC content or VOC 

composite vapor pressure limit for cleaning materials is not recommended.

Under option 1, VOC content limits based on low-VOC coatings, separate sets of emission limits 

for metal parts coatings, plastic parts coatings, automotive/transportation and business machine 

plastic parts, and pleasure craft coatings are recommended.8 Separate emission limits for baked 

and air-dried coatings is recommended. Table 2 provides the recommended emission limits 

expressed in terms of mass of VOC per volume of coating (excluding water and exempt 

compounds, as applied) for option 1.

 

8 Maryland used option 1 from the control options listed in the Miscellaneous Metal and Plastic Parts Coatings CTG 

(EPA 453/R-08-003, September 2008). Only the emission limits for option 1, and for metal parts coatings, are listed 

in this TSD. Further details of the other control options and the accompanying emission limits per coating type for 

miscellaneous metal parts can be found in the CTG. 
9

Table 2. Metal Parts and Products VOC Content Limits – VOC Content Limits are 

Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume (Liter (l) or Gallon (gal)) of 

Coating Less Water and Exempt Compounds, as Applied

Air Dried Baked

Coating Category kg VOC/l 

coating

lb VOC/gal 

coating

kg VOC/l 

coating

lb VOC/gal 

coating

General 

One Component 0.34 2.8 0.28 2.3

General 

Multi-Component

0.34 2.8 0.28 2.3

Camouflage 0.42 3.5 0.42 3.5

Electric-Insulating 

Varnish

0.42 3.5 0.42 3.5

Etching Filler 0.42 3.5 0.42 3.5

Extreme High-Gloss 0.42 3.5 0.36 3.0

Extreme Performance 0.42 3.5 0.36 3.0

Heat Resistant 0.42 3.5 0.36 3.0

High Performance 

Architectural

0.74 6.2 0.74 6.2

High Temperature 0.42 3.5 0.42 3.5

Metallic 0.42 3.5 0.42 3.5

Military Specification 0.34 2.8 0.28 2.3

Mold-Seal 0.42 3.5 0.42 3.5

Pan Backing 0.42 3.5 0.42 3.5

Prefabricated 

Architectural 

Multi-Component

0.42 3.5 0.28 2.3

Prefabricated 

Architectural 

One-Component

0.42 3.5 0.28 2.3

Pretreatment 

Coatings

0.42 3.5 0.42 3.5

Repair and Touch up 0.42 3.5 0.36 3.0

Silicone Release 0.42 3.5 0.42 3.5

Solar-Absorbent 0.42 3.5 0.36 3.0

Vacuum Metalizing 0.42 3.5 0.42 3.5

Work Practices for Coating Operations and Cleaning Materials

In addition to the control options mentioned above, the CTG recommends work practices to 

further reduce VOC emissions from miscellaneous metal parts coating-related activities. 

Specifically, at a minimum, the following work practices are recommended: (1) store all VOCcontaining coatings, thinners, and coating-related waste materials in closed containers; (2) ensure 

that storage containers used for VOC-containing cleaning materials are kept closed at all times 

except when depositing or removing these materials; (3) minimize spills of VOC-containing 

cleaning materials; (4) convey VOC-containing cleaning materials from one location to another 
10

in closed containers or pipes; and (5) minimize VOC emissions from cleaning of application, 

storage, mixing, and conveying equipment, by ensuring that equipment cleaning is performed 

without atomizing the cleaning solvent and all spent solvent is captured in closed containers.

B. STATE SUBMITTAL

On July 28, 2014, Maryland Department of the Environment (MDE) submitted a SIP revision to 

EPA adopting the requirements of EPA’s CTGs for metal furniture, and miscellaneous metal 

parts. EPA develops CTGs as guidance on control requirements for source categories. States 

can follow the recommendations of a CTG and adopt state regulations to implement the 

recommendations contained therein, or they can adopt alternative approaches. With one 

exception, MDE is adopting EPA’s CTG standards for the coating of miscellaneous metal, and 

metal furniture, and incorporating them into their Regulation .08 under COMAR 26.11.19. 

Maryland’s SIP submission included one alternative approach for meeting VOC RACT, by 

adding robotic application of heavy-duty engine coatings as an appropriate method for coating 

applications as long as the transfer efficiency is equivalent or better than the efficiency achieved 

by HVLP spraying. 

The following changes are being made to COMAR 26.11.19.08 in the Maryland SIP:

The title of section 26.11.19.08 is being changed from “Metal Furniture Coating” to “Metal Parts 

and Products Coating”

Definitions for the following are added in section 26.11.19.08(A): Adhesion promoter, air-dried 

coating, baked coating, camouflage coating, electric-insulating and thermal-conducting coating, 

electric-insulating varnish, etching filler, extreme high gloss coating, extreme performance 

coating, heat-resistant coating, high performance architectural coating, high temperature coating, 

magnetic data storage disk coating, metal parts and products coating, metallic coating, military 

specification coating, mold-seal coating, multi-component coating, one-component coating, panbacking coating, prefabricated architectural component coating, pretreatment coating, repair 

coating, robotic application of heavy-duty engine coatings, safety-indicating coating, silicone 

release coating, stencil coating, touch-up coating, and vacuum-metalizing coating. 

The existing section 26.11.19.08(B), Emission Standards, is being removed.

Section 26.11.19.08(B), Incorporation by Reference, is added, incorporating the following 

documents for incorporation by reference: AAMA 2604-05 Voluntary Specification, 

Performance Requirements and Test Procedures for High Performance Organic Coatings on 

Aluminum Extrusions and Panels; and AAMA 2605-05 Voluntary Specification, Performance 

Requirements and Test Procedures for Superior Performing Organic Coatings on Aluminum 

Extrusions and Panels. 

Section 26.11.19.08(C), Applicability and Exemptions, is added. Section 26.11.19.08(C) defines

to whom the regulation applies and in what instances it does not. In line with the 
11

recommendations found in the Metal Furniture and Miscellaneous Metal and Plastic Parts CTGs, 

Maryland’s regulation applies to those who own or operate a metal furniture coating installation, 

and to a metal parts and products coating operation at a premise where the total VOC emissions 

from all metal parts and products surface coating operations, including emissions from related 

cleaning activities, exceeds 15 lb/day (6.8 kg/day). This section clarifies that regulation .08 does 

not apply to those coatings for product categories which are already covered by previously in 

place state regulations. The product category coatings which are listed as not applying under 

regulation .08, and the applicable state regulation which covers each product category type, 

include the following: Automotive and light duty truck coating (COMAR 26.11.19.03), can 

coating (COMAR 26.11.19.04), coil coating (COMAR 26.11.19.05), large appliance coating 

(COMAR 26.11.19.06), paper, fabric, film, and foil coating (COMAR 26.11.19.07), plastic parts 

and business machine coatings (COMAR 26.11.19.07-2), cold and vapor degreasing (COMAR 

26.11.19.09), industrial solvent cleaning operations other than cold and vapor degreasing 

(COMAR 26.11.19.09-1), drum and pail coating (COMAR 26.11.19.13), aerospace coating 

(COMAR 26.11.19.13-1), brake shoe coating (COMAR 26.11.19.13-2), structural steel coating 

(COMAR 26.11.19.13-3), refinishing of motor vehicles (COMAR 26.11.19.23), marine vessel 

coating (COMAR 26.11.19.27), and pleasure craft coating (COMAR 26.11.19.27-1). 

Section 26.11.19.08(D), Emission Standards, is added and includes emission standards for the 

following metal furniture coatings: Extreme high gloss, extreme performance, one-component 

and multi-component general, metallic, pretreatment, and solar absorbent. Table 3 shows 

Maryland’s maximum applicable VOC emission standards (expressed in terms of mass VOC per 

volume coating excluding water and exempt compounds) allowed when applying one of the 

listed coating types to metal furniture. 

Table 3. Maryland’s Adopted Standards for Metal Furniture Coatings

Coating

Air-Dried Baked

kg VOC/l 

coating

lb VOC/l 

coating

kg VOC/l 

coating

lb VOC/l 

coating

Extreme high gloss 0.340 2.8 0.360 3.0

Extreme performance 0.420 3.5 0.360 3.0

General, multi-component 0.340 2.8 0.275 2.3

General, one-component 0.275 2.3 0.275 2.3

Metallic 0.420 3.5 0.420 3.5

Pretreatment 0.420 3.5 0.420 3.5

Solar absorbent 0.420 3.5 0.360 3.0

Maryland’s adopted maximum VOC emission standards for metal furniture coating types are all 

equal to or more stringent than the applicable recommended maximum coating standards found 

in the Metal Furniture Coatings CTG and in Table 1 of this document. 

Section 26.11.19.08(D), Emission Standards, also includes the emission standards for the 

following miscellaneous metal parts coatings: Adhesion promoter, camouflage, electric 

insulating varnish, etching filler, extreme high-gloss, extreme performance, one-component 

general, multi-component general, heat-resistant, high performance architectural, high 

temperature, military specification, metallic, mold-seal, pan backing, prefabricated architectural 
12

multi-component, prefabricated architectural one-component, pretreatment, repair coating, 

silicone release, solar absorbent, touch up coating, and vacuum-metalizing. Table 4 shows 

Maryland’s maximum applicable VOC emission standards (expressed in terms of mass VOC per 

volume coating excluding water and exempt compounds) allowed when applying one of the 

listed coating types to miscellaneous metal parts.

Table 4. Maryland’s Adopted Standards for Miscellaneous Metal Parts Coatings

Coating

Air-Dried Baked

kg VOC/l 

coating

lb VOC/l 

coating

kg VOC/l 

coating

lb VOC/l 

coating

Adhesion promoter 0.479 4.0 0.479 4.0

Camouflage 0.340 2.8 0.420 3.5

Electric insulating 

varnish 0.340 2.8 0.420 3.5

Etching filler 0.340 2.8 0.420 3.5

Extreme high-gloss 0.420 3.5 0.360 3.0

Extreme performance 0.420 3.5 0.360 3.0

General, multicomponent 0.340 2.8 0.275 2.3

General, one-component 0.340 2.8 0.275 2.3

Heat-resistant 0.420 3.5 0.360 3.0

High performance 

architectural 0.420 3.5 0.360 3.0

High temperature 0.340 2.8 0.420 3.5

Military specification 0.340 2.8 0.280 2.3

Metallic 0.340 2.8 0.420 3.5

Mold-seal 0.340 2.8 0.420 3.5

Pan backing 0.340 2.8 0.420 3.5

Prefabricated 

architectural

multi-component

0.420 3.5 0.280 2.3

Prefabricated 

architectural onecomponent

0.420 3.5 0.280 2.3

Pretreatment 0.340 2.8 0.420 3.5

Repair coating 0.420 3.5 0.360 3.0

Silicone release 0.340 2.8 0.420 3.5

Solar absorbent 0.420 3.5 0.360 3.0

Touch up coating 0.420 3.5 0.360 3.0

Vacuum-metalizing 0.340 2.8 0.420 3.5

Maryland’s adopted maximum VOC emission standards for miscellaneous metal parts coating 

types are all equal to or more stringent than the applicable recommended maximum coating 

standards found in the Miscellaneous Metal and Plastic Parts Coatings CTG and in Table 2 of 

this document. 
13

Section 26.11.19.08(E), Application Methods, is added and includes the following application 

methods as appropriate when applying a coating: Electrostatic application, HVLP, flow coat, 

roller coat, dip coat including electrodeposition, brush coat, or a coating application method 

capable of achieving a transfer efficiency equivalent to or better than the efficiency achieved by 

HLVP spraying. These application methods to do apply to repair coatings, touch-up coatings, 

coatings applied to create a textured finish, or robotic application of heavy-duty engine coatings. 

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. EPA’s evaluation shows that 

Regulation .08 under COMAR 26.11 contains the required elements for a federally enforceable 

rule: Emission limitations, compliance procedures and test methods, compliance dates and 

record keeping provisions. Maryland’s SIP revision contains special provisions that establishes 

definitions, specifies applicability, establishes standards, specifies exemptions, specifies control 

devices, and specifies general testing, compliance, recordkeeping, and reporting requirements. 

The amendments to Regulation .08 meet the applicable requirements of the CAA, and the 

applicable EPA regulations and policy and can be approved.

EPA approval of the SIP revision is recommended. The regulations reduce the VOC contents of 

currently regulated coatings, regulate additional coating categories, require the use of coating 

application equipment that provides for high transfer efficiency, and require that clean-up solvent 

emissions be included in regulatory applicability determinations. The reduction of VOC 

emissions will reduce the formation of ozone, and thereby protect public health and welfare.