UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

Placer County Air Pollution Control District, 

Rule 235, Adhesives 

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

May 2013
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Agency: Placer County Air Pollution Control District (PCAPCD)

SIP Approved Rule: Rule 235– Adhesives 

Adopted – June 8, 1995

Submitted – October 13, 1995

EPA Approved – July 18, 1996 (61 FR 37390)

Subject of this TSD: Rule 235– Adhesives 

Amended – April 10, 1997

Amended – April 8, 2004

Amended – October 11, 2012

Submitted – February 6, 2013

RULE SUMMARY –The 1995 SIP approved PCAPCD Rule 235, Adhesives, was 

amended to clarify exemptions and add an exemption for adhesive materials that 

fall under other district rules. The majority of revisions concern further clarification of 

terms and an expansion of descriptions. Rule 235 was also amended to lower VOC 

limits for a number of adhesives, sealants and substrate adhesives to comply with 

the federal reasonably available control technology (RACT) requirements 

established in the 2008 Control Technique Guideline (CTG) for Miscellaneous 

Industrial Adhesives,

1

and the State of California Air Resources Board (CARB) 

Determination of Reasonably Available Control Technology and Best Available 

Retrofit Control Technology (BARCT) for Adhesives and Sealants.

2 The 

Recordkeeping section was expanded to reference the requirements of several other 

 

1. EPA-453/R-08-005 Control Techniques Guidelines for Miscellaneous Industrial Adhesives, 

September 2008.

2. State of California Air Resources Board (CARB) Determination of Reasonably Available Control 

Technology and Best Available Retrofit Control Technology (BARCT) for Adhesives and Sealants, 

December 1998.
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district rules and requirements for emission control equipment records were added. 

The test methods section was amended to include the determination of several 

more parameters. Placer County is currently in non-attainment for ozone and PM 

2.5.

The specific modifications to Rule 235, Adhesives, include:

1. Revised the Section 100, General, to include the purpose of the rule and a 

severability clause.

2. Added two new exemptions: 

a. 104.2 Consumer Products Contacts Adhesives, those products subject 

to 16 Code of Federal Regulations, Part 1302. 

b. 104.8 Materials Regulated Under other District Rules

3. Revised Section 200 to add definitions for the following: Adhesive or Sealant 

Product, Aerosol Adhesive or Adhesive Primer, Aerosol Cleaning Solvent, 

Airless Spray, Application Equipment, Architectural, Chlorinated Polyvinyl 

Chloride (CPVC) Welding Adhesive, Chlorinated Polyvinyl Chloride (CPVC) 

Plastic, Cleanup Solvent, Closed Container, Computer Diskette Jacket 

Manufacturing Adhesive, Control Device, Cured, Cyanoacrylate Adhesive, 

Drywall Installation, Enclosed Gun Cleaner, Ethylene Propylene Diene 

Monomer (EPDM) Roof Membrane, Fiberglass, Flexible Vinyl Adhesive, 

Hand Application, High Pressure Laminate, High-Volume, Low-Pressure 

(HVLP) Application Equipment, Indoor Carpet Adhesive, Indoor Floor 

Covering Installation Adhesive, Key System Operating Parameter, Leak, 

Low-Solids Material, Marine Deck Sealant/Sealant Primer, Material, Metal to 

Urethane/Rubber Molding or Casting Adhesive, Motor Vehicle, Motor Vehicle 

Weatherstrip Adhesive, Noncompliant Material, Outdoor Floor Covering 

Installation Adhesive, Panel Installation, Perimeter Bonded Sheet Flooring 

Installation Adhesive, Plastic Foam, Plasticizer, Propellant, Reactive 

Adhesive, Reinforced Plastic Composite, Roadway Sealant, Rubber, Rubber 

Flooring, Rubber Vulcanization Bonding, Sealant, Sealant Primer, Sheet 

Rubber Lining Installation, Single-ply Roof Membrane, Single-ply Roof 
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Membrane Installation and Repair Adhesive, Solvent Welding, Solid Material, 

Stationary Source, Stripper, Structural Wood Member Adhesive, Subfloor 

Installation, Substrate, Surface Preparation Solvent, Thin Metal Laminating 

Adhesive, Tire Retread Adhesive, Top and Trim Adhesive, Traffic Marking 

Tape Adhesive Primer, VCT and Asphalt Tile Adhesive and VOC Composite 

Partial Pressure. Definitions for Acrylonitrile-Butadiene-Styrene (ABS) 

Welding Adhesive, Adhesive, Aerosol Adhesive, Contact Adhesive, Cove 

Base Installation Adhesive, Exempt Organic Compounds, Flexible Vinyl, 

Household Adhesive, Multipurpose Construction Adhesive, Non-Membrane 

Roof Installation/Repair Adhesive/Sealant, Plastic Cement Welding, Plastic 

Cement Welding Adhesive, Porous Material, Single-ply Roof Membrane 

Adhesive Primer, Single-ply Roof Membrane Adhesive Sealant and Volatile 

Organic Compounds (VOC) were revised for clarity. Definitions for Carbon 

Adsorption, Catalytic Incineration, Floor Covering Installation Adhesive, 

Grams of VOC Per Liter of Adhesive, Less Water, Less Exempt Organic 

Compound, Low Emissions Spray Gin Cleaner, Sales Outlet, Sealant 

Products, Solvent, Substrate Surface Preparation and Thermal Incineration

were deleted.

4. Added Section 301, Material Application Methods. 

5. Revised several VOC Limits for Adhesives, Sealants or Primer table in 

Section 302. Several new Categories were added. The limits for Floor 

Covering Installation (Except Ceramic Tile), which was separated into indoor 

and outdoor flooring in this version, increased from 150 grams/liter to 250 

grams/liter. In addition, the PVC/CPVC Welding limit increased from 500 

grams/liter to 510 grams/liter. The 1998 limit for Thin Metal Laminating 

which was 250 grams/liter, noted as a technology forcing value, is now 

780 grams/liter. 

6. No values in the Adhesive Applications onto Substrates table were changed 

but the categories “Wood” and “Reinforced Plastic Compounds” were added

in Table 302-2. 
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7. Table 303-1 for VOC Limits or Aerosol Adhesives was added to Section 

303 and Table 304-1 for VOC Content Limits for Surface Preparation, 

Cleanup, and Stripper Solvents was added to Section 304. 

8. Sections 305, A Work Practices, and 306, Emission Control Equipment 

were added. Section 309, Adhesive Strippers, Section 310, Primers, 

Sealants or Adhesive Containers, Section 311, Prohibition of Specification, 

Section 312, Compliance Statement Requirement, and Section 313, 

Prohibition of Sales, were incorporated into several new sections. 

9. Section 400 was expanded to include Prohibition of Sales and Specification, 

to include the calculation for determining percent control efficiency and VOC 

mass emission rate and also to include labeling requirements. 

10. Section 500, Monitoring and Records was expanded to include several more 

test methods and to clarify the recordkeeping criteria.

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

rule. 

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

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

(Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001), and State Implementation 

Plans, General Preamble for the Implementation of Title I of the Clean Air 

Amendments of 1990 (57 FR 13498, April 16, 1992) were used to help 

evaluate compliance with the CAA §110(a)(2)(A) requirement for 

enforceability. 

2. Stringency – The EPA’s CTGs titled Miscellaneous Industrial Adhesives, 

(EPA 453/R-08-005, September 2008) and Industrial Cleaning Solvents 

(EPA 453/R-06-001, September 2006) and CARB’s Determination of 

Reasonable Available Control Technology (RACT) and Best Available Retrofit 

Control Technology (BARCT) for Adhesives and Sealants (December 1998)

were used to establish RACT for adhesives and sealants. Other districts’
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analogous rules for this category were used as the basis for RACT including:

South Coast Air Quality Management District (SCAQMD) Rule 1168, 

Adhesive and Sealant Applications, amended January 7, 2005, and San 

Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4653, 

Adhesives and Sealants, amended September 16, 2010.

3. SIP 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).

Enforceability - The recordkeeping requirements for Rule 235 are detailed and have 

clear time frames. Generally, they are analogous to that of SCAQMD’s rule 1168, 

SJVUAPCD’s rule 4653 and CARB’s Determination of RACT and BARCT for 

Adhesives and Sealants. Recordkeeping requirements have been strengthened and 

now include recordkeeping of key control system parameters and record retention has 

been increased to three years. All test methods resemble the CARB’s Determination 

of RACT and BARCT for Adhesives and Sealants. Capture, Overall and Transfer 

efficiencies are adequately defined and the minimum Overall efficiency percentage of 

85 percent is equal to that of the 2008 CTG and SJVUAPCD’s rule. Work Practices, 

Section 305, has been added to clearly define storage and conveyance requirements. 

Test Methods was revised to add testing for Determination of Collection Efficiency 

(502.6), Determination of VOC Content of Emissions (502.7), Determination of 

Plasticizer Content (502.8), Determination of VOC Content of Cyanoacrylate 

Adhesives (502.11) and Determination of Viscosity (502.12). Therefore, we propose 

to determine that submitted Rule 235 is sufficiently clear and enforceable.

Stringency – We believe Rule 235 generally meets RACT. Overall, it is as stringent 

as, and in many cases more stringent than, the 2008 CTG and CARB’s 1998 
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“Determination of RACT and BARCT for Adhesives and Sealants”. The only 

exception is the Plastic Solvent Welding (PVC) limit of 510 grams per liter which is 

slightly higher than the CTG 500 grams per limit for Plastic Solvent Welding (except 

ABS). PCAPCD’s Rule 235 resembles SCAQMD’s Rule 1168 and AVAQMD’s Rule 

1168 for VOC limits for adhesives, adhesive primers, sealants and sealant primers

and for solvent cleaning activities. PCAPCD’s Rule 235 also addresses limits for 

aerosol adhesives which the CTG, CARB determination and other district rules do 

not. 

The exceptions in which this rule meets the CTG or the CARB RACT/BARCT limit,

but is not as stringent as other SIP rules are:

 Ceramic Tile (wall and floor) Adhesive with a limit of 130 grams/liter: 

Although the CTG and CARB Determination of RACT and BARCT indicate 

a 130 grams/liter limit, SCAQMD Rule 1168, AVAQMD Rule 1168 and 

SJVUAPCD 4653 have 65 grams/liter limits for these same categories. 

 Computer Diskette Jacket Manufacturing adhesive, with a limit of 850 

grams/liter: This limit resembles the limit in the CARB Determination of 

RACT and BARCT, but both SCAQMD Rule 1168 and AVAQMD Rule 1168 

have 350 grams/liter limits for this same category. 

 Cove Base adhesive, with a limit of 150 grams/liter: SCAQMD Rule 1168,

AVAQMD Rule 1168 and SJVUAPCD Rule 4653 have 50 grams/liter 

limits for this same category. 

 Indoor Carpet and Indoor Floor Covering, with a limit of 150 grams/liter: 

SCAQMD Rule 1168, SJVUAPCD Rule 4653 and proposed Rule VCAPCD 

74.20 all propose a much lower limit of 50 grams/liter. 

 Multipurpose Architectural/Construction Adhesive, with a limit of 200 

grams/liter: Although this limit resembles the limits in the CTG and the 

CARB Determination of RACT and BARCT, both SCAQMD Rule 1168 and 

AVAQMD Rule 1168 have 70 grams/liter limits for this same category. 
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 Outdoor Carpeting/Outdoor Floor Covering Adhesive, with a limit of 250 

grams/liter: Although this limit resembles the limits in the CTG and the 

CARB Determination of RACT and BARCT, both SCAQMD Rule 1168 and 

AVAQMD Rule 1168 have 150 grams/liter limits for this same category. 

 Rubber Flooring, with a limit of 150 grams/limit: There is no analogous 

category in the CTG or in the CARB Determination of RACT and BARCT. 

However, SCAQMD Rule 1168 and SJVUAPCD Rule 4653 both have a 

limit of 60 grams/liter for this category.

 Top and Trim Adhesive, with a limit of 540 grams/liter: SCAQMD Rule 

1168 has a limit of 250 grams/liter for this category.

 ABS Welding with a limit of 400 grams/liter: Although this limit resembles 

the limits in the CTG and the CARB Determination of RACT and BARCT, 

both SCAQMD Rule 1168 and SJVUAPCD Rule 4653 have 325 

grams/liter limits for this same category. 

 Other Plastic Welding with a limit of 450 grams/liter: SCAQMD Rule 1168, 

SJVUAPCD Rule 4653 and AVAQMD Rule 1168 and proposed rule 

SBAPCD Rule 353 have established limits of 250 grams/liter for this 

category.

 Fiberglass Substrate with a limit of 200 grams/liter: SCAQMD Rule 1168, 

SJVUAPCD Rule 4653, AVAQMD Rule 1168 and proposed rule VCAPCD 

Rule 74.20 have established limits of 80 grams/liter for this category. 

 Plastic Foam and Porous Material Substrates with a limit of 120 

grams/liter: SCAQMD Rule 1168, SJVUAPCD Rule 4653 and proposed 

rule VCAPCD Rule 74.20 have limits of 50 grams/liter for those two 

categories. 

In addition to the adhesive and sealant categories, this rule has limits for various 

surface preparation, clean-up and stripper solvents which have VOC limits that range 

from 70 to 800 grams/liter. Several other substrate surface preparation solvents 

were added including those for Electronic Components, Medical Devices and 
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Pharmaceuticals and Solvent Stripping of Wood Substrates. Some districts have 

reduced the solvent limits for this usage to 25 grams/liter. However, the CTG for 

Industrial Cleaning Solvent3recommends that solvents used in adhesive application 

operations be excluded from the CTG’s strict 50 grams/liter VOC limit for solvents.

Since PCAPCD Rule 235 complies with the 2008 CTG, we propose to determine 

that submitted Rule 235 is sufficiently stringent.

SIP Relaxation – The new submittal generally complies with CAA §110(l) and §193 

regarding SIP relaxations.

Comparing this version with the SIP-approved rule, two categories of adhesives and 

primers; Indoor Floor Covering Installation and Plastic Cement Welding Primers have 

lowered limits. There is an increase in the VOC limit for Outdoor Floor Covering to 

250 grams/liter from the previous general Floor Covering category of a 150 

grams/liter limit. However the new limit for outdoor flooring adhesives meets RACT 

limits and other flooring adhesive limits are lower than RACT. There is also a slight 

increase in the VOC limit for ABS Welding to 400 grams/liter from the previous ABS 

Welding limit of 370 grams/liter. However the ABS welding meets RACT limits. 

There is also a significant increase in the Thin Metal Laminating category from 250 

grams/liter (effective January, 1998) to the 780 grams/liter in this rule. The 250 

grams/liter limit was stated to be technology forcing and the 780 grams/liter limit is 

analogous to CARB’s RACT/BARCT and to other district limits. Despite these three 

limit increases, the staff report states that the application of all the other lower limit 

compliant adhesives and sealants will generally result in lower VOC emissions. 

Therefore, we propose to determine that submitted Rule 74.20 has not relaxed the 

SIP rule.

 

3. EPA-453/R-06-001 Control Techniques Guidelines for Industrial Cleaning Solvents, September 

2006
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ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. Section 302, Requirements – VOC Limits, Adhesive, Adhesive Primers, 

Sealants and Sealant Primers, we recommend that the following limits be 

considered, based on the discussion above: 

a. 65 grams/liter for Ceramic Tile Adhesive

b. 350 grams/liter for Computer Diskette Jacket Manufacturing Adhesive

c. 80 grams/liter for Contact Adhesive

d. 50 grams/liter for Cove Base Adhesive

e. 50 grams/liter for Indoor Floor Covering Installation Adhesive

f. 70 grams/liter for Multipurpose Architectural/Construction Adhesive

g. 150 grams/liter for Outdoor Floor Covering Installation Adhesive

h. 60 grams/liter for Rubber Flooring Adhesive

i. 250 grams/liter for Top and Trim Adhesive

j. 50 grams/liter for VCT and Asphalt Tile

k. 325 grams/liter for ABS Welding 

l. 250 grams/liter for Other Plastic (cement) Welding 

m. 80 grams/liter for Fiberglass Substrate Applications

2. In Table 302-1, please correct “Structural Wood Member Glazing” to 

“Structural Wood Member Adhesive.” In Table 302-2, consider changing 

“Metal” to “Metal-to-Metal” if that is the correct substrate combination.

EPA ACTION - EPA staff recommends a full approval of PCAPCD Rule 235

pursuant to CAA §110(k) (4) and §301(a). 
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ADDITIONAL REFERENCES –

1. PCAPCD Rule 235, Adhesives, Adopted June 8, 1995.

2. PCAPCD Rule 235, Adhesives, Amended October 11, 2012.

http://www.placer.ca.gov/~/media/apc/documents/Rules/Reg%202/Rule

235Adhesives.ashx

3. SCAQMD Rule 1168, Adhesive and Sealant Applications, amended January 

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

4. SJVUAPCD Rule 4653, Adhesives and Sealants, amended September 16, 

2010. http://www.valleyair.org/rules/currntrules/r4653.pdf

5. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, EPA 

453/R-08-005, September 2008.

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200809_v

oc_epa453_r-08-005_miscellaneous_industrial_adhesives.pdf

6. Control Techniques Guidelines: Industrial Solvents, EPA-453/R-06-001, 

September 2006.

http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/200609_v

oc_epa453_r-06-001_ind_cleaning_solvents.pdf

7. State of California Air Resources Board Determination of Reasonably 

Available Control Technology and Best Available Retrofit Control Technology 

for Adhesives and Sealants, December 1998.

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

8. “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

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

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

http://www.epa.gov/region9/air/sips/littlebluebook2001.pdf