UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: January 18, 2013

SUBJECT: Technical Support Document for District of Columbia’s Volatile Organic 

Compounds Emissions Reductions Regulations

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Donna Mastro, Acting Associate Director /s/

Office of Air Program Planning

A. BACKGROUND: 

On March 15, 2012, the District Department of the Environment (DDOE) submitted a revision to 

the District of Columbia (District) State Implementation Plan (SIP). The SIP revision pertains to 

Chapters 1 and 7 of Title 20 (Environment) of the District of Columbia Municipal Regulations

(DCMR). The revision amends portions of Chapters 1 and 7 in order to add or remove sections 

from the SIP to reduce further volatile organic compound (VOC) emissions in the District. On 

January 26, 2010 and March 24, 2011, DDOE submitted a negative declaration to EPA for the 

following VOC source categories: (1) auto and light-duty truck assembly coatings; (2) fiberglass 

boat manufacturing materials; (3) paper, film and foil coatings; and (4) flatwood paneling. The 

negative declaration was submitted to EPA to fulfill the requirement that, in the absence of 

sources in any source category, the District must revise its SIP or submit a negative declaration 

pursuant to section 182(b)(2)(A) of the Clean Air Act (CAA).

The Washington Metropolitan Area, which includes the District, is designated nonattainment for 

the 2008 eight-hour national ambient air quality standards (NAAQS) for ozone. As a result, the 

District is required to adopt measures to reduce ozone levels, including precursor emissions of 

VOCs. The standards and requirements contained in the District’s regulations to reduce VOCs 

and precursors of ozone incorporate the level of control recommended in the Ozone Transport 

Commission (OTC) model rules. The OTC model rules are based on the existing rules developed 

by the 1998 California Air Resources Board (CARB) reasonably available control technology 

(RACT) determination. Implementing the model rules will result in VOC emission reductions in 

VOC at least as stringent as any applicable control technique guidelines (CTG) and will support 

the attainment demonstrations and reductions in ground-level ozone in other areas of the Ozone 

Transport Region (OTR). The District has adopted RACT regulations consistent with the level 

of control recommended by the requirements of the following OTC model rules into regulations: 
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(1) consumer products, (2) adhesives and sealants, (3) architectural and industrial maintenance, 

(4) portable fuel containers and spouts, and (5) solvent cleaning.

In addition to adopting RACT regulations consistent with the level of control recommended by

the OTC model rules, the District also adopted the requirements of several CTGs published by 

the U.S. Environmental Protection Agency (EPA). Section 172(c)(1) of the Clean Air Act 

(CAA) provides that SIPs for nonattainment areas must include reasonably available control 

measures (RACM), including 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 

VOC emissions covered by a CTG document issued after November 15, 1990 and prior to the 

Area’s date of attainment. 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 intended to provide state and local air pollution control 

authorities information that should assist them in determining RACT for VOC from various 

sources. The District has adopted RACT regulations consistent with the level of control 

recommended by the requirements of the following CTGs into regulations: (1) flexible 

packaging and printing; (2) large appliance coatings; (3) metal furniture coatings, and 

miscellaneous metal products and plastic parts coatings; (4) lithographic and letterpress printing; 

(5) miscellaneous industrial adhesives; and (6) industrial cleaning solvents. 

B. STATE SUBMITTAL:

I. Amendments to Title 20 DCMR (Environment), Subtitle A (Air Quality), Chapter 1 –

General Provisions

The SIP revision amended subsection 100.4 in order to allow for the English system of 

measurement to become the official system of measurement since it is the most commonly used 

measurement in VOC controls.

The SIP revision amended section 199 in order to replace one definition and remove specific 

definitions from Chapter 1 and move them to section 799 which was a more appropriate location 

for them. The revision removes the following definitions and terms in section 199: “Control 

technique guideline,” “Cylinder-wipe,” “Gravure,” “Heatset,” “Inking cylinder,” “Intaglio,” 

“Letterpress,” “Letterset,” “Offset printing process,” “Paper-wipe,” “Photochemically reactive 

solvent,” “Plate,” “Printing,” “Printing operation,” “Printing unit,” “Water-based solvent,” and 

“Wipe cleaning.” The revision also repealed “Volatile organic compounds” and replaced it with 

a new definition for VOCs. The new definition for VOCs is any compound of carbon, other than 

those organic compounds that are defined in 40 Code of Federal Regulations (CFR) part 51.
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II. Amendments to Title 20 DCMR (Environment), Subtitle A (Air Quality), Chapter 7 –

Volatile Organic Compounds

A. Section 700

The revision amended section 700 in order to repeal and change the title from “Organic 

Solvents” to “Miscellaneous Volatile Organic Compounds” to more accurately establish and 

expand the subject of the regulation. Section 700.1 was amended to extend the catch-all to all 

subsequent sections in Chapter 7 not previously included in section 700.1. Section 700.2 was 

amended in order to increase the overall control efficiency requirement from 85 percent to 90 

percent. The revision also changed the term “photochemically reactive solvents” in section 700.2 

to “volatile organic compounds” in order to reflect the true focus of Chapter 7 and the term 

“overall capture and control efficiency” was added to the end of section 700.2 to clarify the intent 

of the emissions reduction option. Section 700.3 was amended in order to move

“nonphotochemically reactive solvents” to section 708, because nonphotochemically reactive 

solvents are not technically VOCs. However, the section remains in 20 DCMR Chapter 7 to 

avoid backsliding.

B. Section 707

The revision amended section 707 in order to repeal “Perchloroethylene Dry Cleaning” because

perchloroethylene (“perc”), a chemical solvent used in dry cleaning, is no longer defined as a 

VOC. 

C. Section 708

The revision repeals section 708, “Solvent Cleaning” because all of the standards from this 

particular section are addressed with more detail in OTC’s model rule on solvent cleaning in 

sections 763 through 769. 

D. Section 710

The revision amended section 710, “Intaglio, Flexographic, and Rotogravure Printing” in order to 

specify applicability to intaglio printing units and intaglio printing operations. Section 710 also 

established applicability for any individual flexographic or rotogravure package printing press, 

after January 1, 2012, with the theoretical potential to emit from the dryer before controls of at 

least 25 tons per year (tpy) of VOC from inks, coatings and adhesives combined. Section 710 

established that the use of inks, wiping solutions, and fountain solutions in connection with 

printing units shall comply with the limits on the percentage content of VOCs of the inks, wiping 

solutions and fountain solutions for the respective types of printing units. The District also 

amended section 710 in order to incorporate the control recommendations and emission limits 

from EPA’s Flexible Package Printing CTG since flexible package printing uses both 

flexographic and rotogravure printing presses, and at least one of the District’s major sources 

does operate a rotogravure press. The District incorporated the limits listed in Appendix 7-1, and 

then Appendix 7-1 was repealed. The CTG controls are for inks, adhesives, and sealants used in 

presses with a potential to emit (PTE) 25 tons or more of VOCs per year. 
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EPA’s Flexible Package Printing CTG

The CTG for flexible package printing is intended to provide state and local air pollution control 

authorities information that should assist them in determining RACT for VOCs from flexible 

package printing facilities. Based on available information and data, EPA provides 

recommendations for RACT for VOCs from flexible package printing facilities. In December 

1978, EPA published a CTG for graphic arts (rotogravure printing and flexographic printing) that 

included flexible package printing. The 1978 CTG discusses the flexible package printing 

industry, the nature of VOC emissions from that industry, available control technologies for 

addressing such emissions, the costs of available control options, and other items. In September 

2006, after conducting a review of currently existing state and local VOC emission reduction 

approaches for flexible package printing, reviewing the 1978 CTG and the 1996 NESHAP for the 

printing and publishing industry (40 CFR Part 60, Subpart KK), and taking into account the 

information that has become available since then, EPA developed a new CTG for flexible 

package printing entitled Control Techniques Guidelines for Flexible Package Printing

(Publication No. EPA 453/R-06-003). Recommendations for controlling VOC emissions from 

inks, coatings, adhesives and cleaning materials used in flexible package printing operations are 

outlined in the CTG and are as follows: 

• 65 percent overall control for a press that was first installed prior to March 14, 1995 and 

that is controlled by an add-on air pollution control device (APCD) whose first 

installation date was prior to the effective date of the State RACT rule. 

• 70 percent overall control for a press that was first installed prior to March 14, 1995 and 

that is controlled by an add-on APCD whose first installation date was on or after the 

effective date of the State RACT rule. 

• 75 percent overall control for a press that was first installed on or after March 14, 1995 

and that is controlled by an add-on APCD whose first installation date was prior to the 

effective date of the State RACT rule. 

• 80 percent overall control for a press that was first installed on or after March 14, 1995 

and that is controlled by an add-on APCD whose first installation date was on or after 

the effective date of the State RACT rule. 

As an alternative to emission reduction percentages specified above, EPA also recommends 

providing the following two equivalent VOC content limits which can be met by use of low VOC 

content materials or combinations of materials and controls as follows: (1) 0.8 kg VOC/kg solids 

applied, or (2) 0.16 kg VOC/kg materials applied. These VOC content limits are consistent with 

an 80 percent overall emissions reduction level and reflect similar control levels as the capture 

and control option. The VOC content limits can be met by averaging the VOC content of 

materials used on a single press, i.e., within a line.

The SIP revision also amended section 710 in order to: (1) establish test methodologies, and (2) 

re-codify section due to changes in provisions.

E. Section 714
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The District amended section 714 in order to repeal and change the title from “Controls and 

Prohibitions on Gasoline Volatility” to “Control Techniques Guidelines (CTGs).” The District 

made this amendment in order to address three of EPA’s CTGs for the following source 

categories: miscellaneous metal product and plastic parts coatings, large appliance coatings, and 

metal furniture coatings. CTG applicability is based on actual emission thresholds from the 

aggregation of units within a CTG category. The catch-all CTG rule requires a presumptive 90 

percent overall control efficiency for any person who owns, operates, or leases any combination 

of articles, machines, units, equipment, or other contrivances at a facility whose actual VOC 

emissions before control devices from all units within the miscellaneous metal and plastic parts 

coatings, large appliance coatings, and metal furniture coatings CTG categories are more than 15 

pounds (lbs) in any one day, or more than 3 lbs in any hour. 

EPA’s Miscellaneous Metal and Plastic Parts Coatings CTG

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

coating of miscellaneous metal parts and products. EPA developed a new CTG combining the 

requirements for miscellaneous metal and plastic parts coatings into a single CTG, entitled

“Control Technique Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (EPA 

453/R-08-003, September 2008). The CTG applies to manufacturers of miscellaneous metal and 

plastic parts that surface-coat the parts they produce. 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 and miscellaneous plastic 

parts surface coating unit at a facility where the total actual VOC emissions from all 

miscellaneous metal product and plastic parts surface coating operations, including related 

cleaning activities, at that facility, are equal to or exceed 6.8 kilograms a day (kg/day), 15 pounds 

a day (lb/day), or an equivalent level of 2.7 tons per 12-month rolling period, before 

consideration of controls. To control VOC emissions from miscellaneous metal and plastic parts 

surface coatings, the CTG recommends an option of an overall VOC control efficiency of 90 

percent for facilities that choose to add-on controls instead of low-VOC content coatings and 

specified application methods.

EPA’s Large Appliance Coatings CTG 

In December 1977, EPA published a final CTG for large appliance coatings, entitled “Control of 

Volatile Organic Emissions from Existing Stationary Sources, Volume V, Surface Coating of 

Large Appliances,” EPA-450/2-77-034 (December 1977). EPA developed a new CTG for 

surface coating of large appliances, entitled “Control Techniques Guidelines for Large Appliance 

Coatings,” EPA 453/R-07-004 (September 2007). Recommendations for controlling VOC 

emissions from large appliance coatings are outlined in the CTG. One option, should product 

performance requirements or other needs dictate the use of higher VOC materials than those that 

would meet the recommended emission limits, a facility could choose to use add-on control 

equipment to meet an overall efficiency of 90 percent. 

EPA’s Metal Furniture Coatings CTG 

In December 1977, EPA issued a CTG document for controlling VOC emissions from the 
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surface coating of metal furniture. EPA developed a new CTG for the Surface Coating of Metal 

Furniture entitled, “Control Technique Guidelines for Metal Furniture Coatings” (EPA 453/R07-005). Coatings used in metal furniture surface coating operations include paints, sealants, 

caulks, ink, adhesives, and maskants. It is recommended that the controls apply to each metal 

furniture surface 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. To control VOC emissions from metal furniture coatings, the 

CTG recommends an option of an overall control efficiency of 90 percent for add-on controls.

 

Section 714 was also amended to define the term “source” for each CTG category as follows: (1) 

Miscellaneous Metal Product and Plastic Parts Surface Coatings, where a source performs 

surface coating of miscellaneous metal and plastic parts at a manufacturing facility or on a 

contract basis; (2) Large Appliance Coatings, where a source uses paints, topcoats, basecoats, 

sealants, caulks, inks, primers, enamels, adhesives, maskants, and other such materials in the 

manufacture of large appliance parts or products at a large appliance coatings facility; and (3) 

Metal Furniture Coatings, where a source applies coatings to metal furniture surface coating units 

at a metal furniture manufacturing facility.

The SIP revision also amended section 714 in order to: (1) establish a “once in, always in” 

provision, (2) establish work practice and record-keeping requirements, (3) establish sourcespecific RACT analysis applicability requirements, and (4) establish procedures and schedules 

for persons who own, operate or lease a source and would prefer to comply with a different 

option.

F. Section 715

The District amended section 715 in order to repeal and change the title from “Reasonably 

Available Control Technology” to “Major Source and Case-By-Case Reasonably Available 

Control Technology (RACT).” The District made this amendment in order to address the 

applicability and requirements for sources with the theoretical potential to emit (PTE) of 25 tons 

per year or greater of plant-wide emissions. The theoretical PTE of 25 tons per year or greater is 

the major source threshold established under the District’s 1-Hour Ozone SIP, which is the basis 

for the 8-Hour Ozone SIP limits. Section 182 (d) of the CAA requires severe nonattainment 

areas to submit revisions to the SIP in order to lower threshold for definition of “Major” source 

requiring controls to 25 tons per year.

Section 715 was also amended to: (1) specify how to calculate “theoretical potential to emit” 

based on VOC RACT and new source review, (2) specify what is required in a RACT analysis, 

and (3) specify how the District will handle source-specific RACT analyses when issuing or 

modifying permits.

G. Section 716
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The District amended section 716 in order to repeal and change the title from “Offset 

Lithography” to “Offset Lithography and Letterpress Printing,” in order to include the 

requirements of the Offset Lithography and Letterpress Printing CTG. The District amended 

section 716 to establish applicability for any person who owns, operates, or leases an offset

lithography printing operation that is part of any stationary source which emits, or has the 

theoretical PTE 25 tons per year (tpy) of VOCs or greater. Section 716 also establishes

applicability for any offset lithography or letterpress printing operation which emits VOCs at a 

rate less than, equal to, or greater than 15 pounds per day actual emissions of VOC after January 

1, 2012. Section 716 was also amended in order to: (1) address the requirements for dampening 

and fountain solutions, (2) address the requirements for cleaning solutions, (3) address the 

requirements for cover dryers or inks and heatset ovens for major sources only, and (4) specify 

calculations, record-keeping requirements, and compliance.

EPA’s Offset Lithography and Letterpress Printing CTG

The CTG is intended to provide state and local air pollution control authorities information that 

should assist them in determining RACT for VOCs for offset lithographic printing and letterpress 

printing. On November 8, 1993, EPA published a draft CTG for offset lithographic printing. (58 

FR 59261). EPA developed a new CTG for the offset lithographic printing and letterpress 

printing entitled, “Control Techniques Guidelines for Offset Lithographic Printing and 

Letterpress Printing” (EPA 453/R-06-002, September 2006). This CTG provides control 

recommendations for reducing VOC emissions stemming from the use of fountain solutions, 

cleaning materials and inks in offset lithographic printing and cleaning materials and inks in 

letterpress printing. In terms of applicability, the CTG recommend that the control 

recommendations for cleaning materials and fountain solutions apply to any offset lithographic 

printing operation where the emissions associated with all aspects of that operation equal or 

exceed 6.8 kg/day (15 lb/day) actual emissions of VOC, or an equivalent level, before 

consideration of controls.

Recommendations for controlling VOC emissions from heatset inks, fountain solution, and 

cleaning materials used in offset lithographic printing operations, and for controlling VOC 

emissions from heatset inks and cleaning materials used in letterpress printing operations are as 

follows:

 The recommended level of control for VOC emissions from heatset dryers is 90 percent 

control efficiency for a control device whose first installation date was prior to the 

effective date of a State RACT rule issued after the date of this CTG and 95 percent 

control efficiency for a control device whose first installation date was on or after the 

effective date of a State RACT rule issued after the date of this CTG. Applicability is 

based on individual heatset web offset lithographic printing presses and individual heatset 

web letterpress printing presses with potential to emit from the dryer, prior to controls, of 

at least 25 tpy of VOC (petroleum ink oil). 
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 The recommended level of control for VOC emissions from on-press (as-applied) 

fountain solution for heatset web offset lithographic printing is 1.6 percent alcohol (by 

weight) in the fountain or equivalent. The recommended level of control for VOC 

emissions from on-press (as-applied) fountain solution for sheet-fed printing is equivalent 

to 5 percent alcohol (by weight) in the fountain or equivalent. The recommended level of 

control for VOC emissions from fountain solution for coldset web is 5 percent alcohol 

substitute or less (by weight) on-press (as-applied) and no alcohol in the fountain 

solution.

 The recommendations for the control of VOC emissions from cleaning solutions apply to 

blanket washing, roller washing, plate cleaners, metering roller cleaners, impression 

cylinder cleaners, rubber rejuvenators, and other cleaners used for cleaning a press, press 

parts, or to remove dried ink from areas around a press. In addition, the 

recommendations for cleaning materials provided do not apply to cleaners used on 

electronic components of a press, pre-press cleaning operations (e.g., platemaking), postpress cleaning operations (e.g., binding), cleaning supplies (e.g., detergents) used to clean 

the floor (other than dried ink) in the area around a press, or cleaning performed in parts 

washers or cold cleaners. EPA recommends using cleaning materials with a VOC 

composite vapor pressure less than 10 mm Hg at 20 oC or cleaning materials containing 

less than 70 weight percent VOC. EPA recommends excluding 110 gallons per year of 

cleaning materials which meet neither the low VOC composite vapor pressure

recommendation nor the lower VOC content recommendation because a small number of 

cleaning tasks cannot be carried out with low VOC composite vapor pressure cleaning 

materials or reduced VOC content cleaning materials. EPA also recommends keeping 

cleaning materials and used shop towels in closed containers. Using cleaning materials 

with a VOC composite partial vapor pressure less than 10 mm Hg at 20 oC in conjunction 

with good work practices would result in an emission reduction that is comparable to 

using cleaning materials that contain less than 30 weight percent VOC.

H. Section 719

Section 719, Consumer Products – General Requirements was amended to read as follows to 

include new VOC standards for certain consumer products in sections 719 through 737: (1) 

establish applicability to any person who sells, supplies, offers for sale, or manufactures 

consumer products on or after the applicable compliance dates in section 720, “Table of 

Standards. Percent volatile organic compounds by weight,” (Attachment A), and (2) for any 

definitions in section 799 applicable to sections 719 through 737, the District incorporates by 

reference rules and test methods from the California Air Resource Board (CARB), the South 

Coast Air Quality Management District, and the American Society for Testing and Materials.

I. Section 720

Section 720, Consumer Products – VOC Standards was amended in order to establish exceptions 

and requirements that no person shall sell, supply, offer for sale, or manufacture for sale in the 

District any consumer product, manufactured on or after the effective date in Attachment A.
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J. Section 721

Section 721, Consumer Products – Exemptions from VOC Standards was amended to set

exemptions from the VOC limits established in section 720 for the following: (1) products for 

shipment and use outside the District, (2) antiperspirants and deodorants, (3) air fresheners, (4) 

adhesives, (5) bait station insecticides, (6) fragrances, (7) low-vapor-pressure VOC, and (8) any 

consumer product where the manufacture has been granted an Alternative Control Plan (ACP) 

agreement, an innovative product exemption, or a variance.

K. Section 722

Section 722, Consumer Products – Registered Under FIFRA was amended to establish an 

effective date of one year after the date specified in Attachment A for consumer products 

registered under the Federal Insecticide, Fungicide, and Rodenticide Act.

L. Section 723

Section 723, Consumer Products – Products Requiring Dilution was amended to specify VOC 

limit requirements for consumer products requiring dilution with water or non-VOC solvent 

before usage as established in Attachment A.

M. Section 724

Section 724, Consumer Products – Ozone Depleting Compounds was amended to (1) establish 

VOC limits for any consumer product for which standards are specified in Attachment A, (2) 

specify requirements that no person shall sell, supply, offer for sale, or manufacture for sale in 

the District of Columbia any consumer product, which may contain a variety of ozone depleting 

compounds, and (3) establish exemptions.

N. Section 725

Section 725, Consumer Products – Aerosol Adhesives was amended to (1) establish VOC limits 

for all uses of aerosol adhesives, including consumer, industrial, and commercial uses as 

specified in Attachment A, (2) specify that no person shall sell, supply, offer for sale, use, or 

manufacture for sale in the District any aerosol adhesive which, at the time of sale, use, or 

manufacture, contains VOCs in excess of the standards specified in Attachment A, (3) specify 

requirements to be classified as a special purpose spray adhesive, and (4) specify labeling 

requirements.

O. Section 726

Section 726, Consumer Products – Antiperspirants Or Deodorants was amended to specify that 

no person shall sell, supply, offer for sale, or manufacture for sale in the District any 

antiperspirant or deodorant which contains any compound that has been identified by CARB as a 

toxic air contaminant.

P. Section 727 

The District amended section 727 in order to repeal and change the title from “Consumer 

Products – Charcoal Lighter Materials” to “Consumer Products – Contact Adhesives, Electronic 
10

Cleaners, Footwear And Leather Care Products, And General Purpose Degreasers.” Section 727 

was also amended to specify requirements that no person shall sell, supply, offer for sale, or 

manufacture for use in the District any contact adhesive, electronic cleaner, footwear or leather 

care product, or general purpose degreaser that contains methylene chloride, perchloroethylene, 

or trichloroethylene effective January 1, 2012. However, the abovementioned consumer products 

manufactured before January 1, 2012 may be sold, supplied or offered for sale until May 1, 2012. 

Section 727 also specifies exemptions.

Q. Section 728

The District amended section 728 in order to repeal and change the title from “Consumer 

Products – Floor Wax Strippers” to “Consumer Products – Adhesive Removers, Electrical 

Cleaners, And Graffiti Removers.” Section 728 was also amended to specify requirements that 

no person shall sell, supply, offer for sale, or manufacture for use in the District any adhesive 

remover, electrical cleaner, or graffiti remover that contains methylene chloride, 

perchloroethylene, or trichloroethylene effective January 1, 2012. However, the abovementioned 

consumer products manufactured before January 1, 2012 may be sold, supplied or offered for 

sale until May 1, 2012. Section 728 also specifies exemptions.

R. Section 729

The District amended section 729 in order to repeal and change the title from “Consumer 

Products – Labeling Of Contents” to “Consumer Products – Solid Air Fresheners And 

Toilet/Urinal Care Products.” Section 729 was also amended to specify requirements that no 

person shall sell, supply, offer for sale, or manufacture for use in the District any solid air 

fresheners or toilet/urinal care products that contain para-dichlorobenzene effective January 1, 

2012. However, the abovementioned consumer products manufactured before January 1, 2012 

may be sold, supplied or offered for sale until May 1, 2012. 

S. Section 730

The District amended section 730 in order to repeal and change the title from “Consumer 

Products – Reporting Requirements” to “Consumer Products – Charcoal Lighter Materials.” 

Section 730 was also amended to specify requirements and applicability for the sale, supply, or 

offer for sale any charcoal lighter material product. Section 730 was amended to specify 

exemptions, testing procedures and certifications.

T. Section 731

The District amended section 731 in order to repeal and change the title from “Consumer 

Products – Test Methods” to “Consumer Products – Floor Wax Strippers.” Section 731 was also 

amended to specify requirements that no person shall sell, supply, offer for sale, or manufacture 

for use in District any floor wax stripper unless the labels have certain dilution ratios for light, 

medium, or heavy build-up of polish that results in an as-used VOC concentration limit.

U. Section 732

The District amended section 732 in order to repeal and change the title from “Consumer 
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Products – Alternative Control Plans” to “Consumer Products – Labeling Of Contents.” Section 

732 was also amended in order to specify labeling requirements and exemptions for 

manufacturers of consumer products.

V. Section 733

The District amended section 733 in order to repeal and change the title from “Consumer 

Products – Innovative Products Exemption” to “Consumer Products – Reporting Requirements.”

Section 733 was also amended to establish reporting requirements for any consumer products or 

products the District may specify.

W. Section 734

The District amended section 734 in order to repeal and change the title from “Consumer 

Products – Variance Requests” to “Consumer Products – Test Methods.” Section 734 was also 

amended to establish testing methods necessary to determine compliance with consumer products 

requirements.

X. Section 735

The District amended section 735 in order to repeal and change the title from “Portable Fuel 

Containers And Spouts” to “Consumer Products – Alternative Control Plans.” Section 735 was 

also amended to provide an alternate method to comply with the standards specified in 

Attachment A. The alternative is provided to allow responsible parties the option of voluntarily 

entering into separate ACP Agreements for consumer products. Section 735 was amended to (1) 

specify exemptions, (2) establish procedures for submitting an ACP Agreement request, and (3) 

specify penalties for any person who commits a violation of the ACP Agreement.

Y. Section 736

The District amended section 736 in order to repeal and change the title from “Portable Fuel 

Containers And Spouts – Performance Standards” to “Consumer Products – Innovative Products 

Exemption.” Section 736 was also amended in order to: (1) establish the requirements and 

procedures for claiming an innovative products exemption, and (2) specify criteria and options 

for manufacturers of consumer products that have not been granted an exemption by CARB.

Z. Section 737

The District amended section 737 in order to repeal and change the title from “Portable Fuel 

Containers And Spouts – Exemptions From Performance Standards” and replaced with 

“Consumer Products – Variance Requests.” Section 737 was also amended in order to: (1) 

specify the criteria for applying for a variance request, (2) specify the criteria necessary for the 

District to grant a variance request, and (3) specify the penalty for failure to comply with the 

variance requirements.

AA. Section 738

The District repealed section 738 entitled, “Portable Fuel Containers And Spouts – Labeling 

Requirements.”
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BB. Section 739

The District repealed section 739 entitled, “Portable Fuel Containers And Spouts – Testing.”

CC. Section 740

The District repealed section 740 entitled, “Portable Fuel Containers And Spouts – Innovative 

Product Exemption.”

DD. Section 741

The District repealed section 741 entitled, “Portable Fuel Containers And Spouts – Variance.”

EE. Section 742

The District repealed section 742 entitled, “Solvent Cleaning – General Requirements.”

FF. Section 743

The District amended section 743 in order to repeal and change the title from “Solvent Cleaning 

– Cold Cleaning” to “Adhesives And Sealants – General Requirements.” Section 743 was also 

amended in order to: (1) establish applicability to any person who, on or after January 1, 2012, 

supplies, sells, offers for sale, manufactures for sale, or uses or applies adhesives, sealants, or 

adhesive or sealant primers, and (2) for any definitions in section 799 applicable to sections 743 

through 749, the District incorporates by reference rules and test methods from CARB, the South 

Coast Air Quality Management District, and the American Society for Testing and Materials.

GG. Section 744

Section 744, Adhesives and Sealants – VOC Standards was amended in order to establish 

requirements that no person shall sell, supply, offer for sale, or manufacture for sale in the 

District any adhesive, sealant, adhesive primer or sealant primer manufactured on or after 

January 1, 2012 in excess of the applicable VOC content limits specified in Attachment B. 

Section 744 was also amended to establish requirements that no person shall use or apply any 

adhesive, sealant, adhesive primer, or sealant primer manufactured on and after January 1, 2012, 

within the District in excess of the applicable VOC content limits specified in Attachment B. 

Section 744 was amended in order to establish requirements for the following: (1) adhesives 

applied to particular substrates, (2) any person using a surface preparation or cleanup solvent, (3)

using add-on air pollution control equipment, (4) storing and disposal of adhesives, sealants, 

adhesive primers, sealant primers, or surface preparation or cleanup solvents, and (5) in the event 

of a violation.

EPA’s Miscellaneous Industrial Adhesive CTG

The Environmental Protection Agency (EPA) addressed a portion of this category, adhesives and 

adhesive primers, in a Control Techniques Guideline (CTG) document - “Control Techniques 

Guidelines for Miscellaneous Industrial Adhesive, EPA-453/R-08-005” in September 2008. (See 

Docket number EPA-HQ-OAR-2008-0460). EPA issued the CTG pursuant to the authority and 

to meet a requirement set by section 183(e) of the CAA. Section 183(e) directed EPA to list for 

regulation, those categories of products that account for at least 80 percent of the VOC emissions 
13

from consumer and commercial products in ozone nonattainment areas, and to schedule those 

categories for regulation in four groups. In terms of applicability, the scope of the CTG is 

focused on industrial adhesive application processes at facilities, i.e., stationary sources. The 

limits and requirements apply to facilities where the total actual VOC emissions from all 

miscellaneous industrial adhesive application processes, 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.

The CTG does not propose recommendations for VOC content or VOC composite vapor 

pressure limits for cleaning materials. The CTG provides for the use of add-on air pollution 

control equipment instead of meeting the solvent content limits and requires that controls reduce 

VOC emissions by an overall capture and control efficiency of at least 85% by weight. The CTG 

also recommends that adhesive and adhesive primers be applied using application methods with 

good transfer efficiency in conjunction with the use of low-VOC content adhesives. Specifically, 

the CTG recommends the following application methods: electrostatic spray, HVLP spray, flow 

coat, roll coat or hand application including non-spray application methods similar to hand or 

mechanically powered caulking gun, brush, or direct hand application), roll coat, dip coat 

(including electrodeposition), airless spray, air-assisted airless spray, or other coating application 

method capable of achieving good transfer efficiency. (Final CTG, Section VI.B., page 19). The 

CTG recommends application methods with good transfer efficiencies for stationary facilities 

and does not make recommendations for field applied adhesives and sealants.

HH. Section 745

The District amended section 745 in order to repeal and change the title from “Solvent Cleaning 

– In-Line Vapor Cleaning” to “Adhesives and Sealants – Exemptions and Exceptions.” Section 

745 was also amended in order to establish exemptions for the following: (1) the use or sale of 

adhesives, sealants, adhesive primers, or sealant primers being tested or evaluated in any research 

and development, quality assurance or analytical laboratory, provided records are maintained, (2) 

the use of adhesives, sealants, adhesive primers, sealant primers, or surface preparation and 

cleanup solvents in the specific operations, (3) a person who uses or applies any adhesive, 

sealant, adhesive primer, and sealant primer at a stationary source if the total VOC emissions 

from all adhesives, sealants, adhesive primers, and sealant primers used at the stationary source 

are less than two hundred pounds (200 lb.) per calendar year, or an equivalent volume, (4) the use 

of any adhesives, sealants, adhesive primers, sealant primers, cleanup solvents, and surface 

preparation solvents, provided the total volume of non-complying adhesives, sealants, primers, 

cleanup and surface preparation solvents applied facility-wide at a stationary source does not 

exceed fifty-five gallons (55 gal.) per calendar year, (5) any adhesive, sealant, adhesive primer, or 

sealant primer that is sold, supplied, or offered for sale by any person to a retail outlet in the 

District, (6) and for not complying with the requirements of sections 743 through 749.

II. Section 746

The District amended section 746 in order to repeal and change the title from “Solvent Cleaning 

– Airless And Air-Tight Cleaning” to “Adhesives And Sealants – Administrative Requirements.” 
14

Section 746 was also amended in order to establish requirements and procedures for recordkeeping.

JJ. Section 747

The District amended section 747 in order to repeal and change the title from “Solvent Cleaning 

– Alternative Compliance” to “Adhesives And Sealants – Compliance Procedures And Test 

Methods.” Section 747 was also amended in order to establish the test methods and procedures 

for the following: (1) non-aerosol adhesives, adhesive primers, surface preparation solvents, and 

cleanup solvents, (2) organic content of exempt organic compounds, (3) any plastic welding 

cement adhesive or primer, (4) the composite vapor pressure of organic compounds in cleaning 

materials, (5) the vapor pressure of a single component compound, (6) the active and passive 

solvent losses from spray gun cleaning systems, (7) adhesives that do not contain reactive 

diluents, and (8) adhesives that contain reactive diluents.

KK. Section 748

The District amended section 748 in order to repeal and change the title from “Solvent Cleaning 

– Recordkeeping And Monitoring” to “Adhesives And Sealants – Container Labeling.” Section 

748 was also amended to specify labeling requirements and exemptions for manufacturers of an 

adhesive, sealant, adhesive primer, or sealant primer.

LL. Section 749

The District amended section 749 in order to repeal and change the title from “Architectural And 

Industrial Maintenance Coating – General Requirements” to “Adhesives and Sealants –

Application Methods.” Section 749 was also amended in order to establish the application 

methods necessary for applying a VOC-containing adhesive, adhesive primer, sealant, or sealant 

primer at a stationary source.

 

MM. Section 750

The District repealed section 750 entitled, “Architectural And Industrial mMaintenance Coating 

– Standards.” 

NN. Section 751

The District amended section 751 in order to repeal and change the title from “Architectural And 

Industrial Maintenance” to “Portable Fuel Containers And Spouts – General Requirements.” 

Section 751 was also amended in order to: (1) establish applicability to any person who sells, 

supplies, offers for sale, advertises, or manufactures a portable fuel container or spout for use in 

the District, (2) establish the criteria for when a person can sell, supply, offer for sale, advertise, 

or manufacture for sale in the District a portable fuel container or spout, or combination portable 

fuel container and spout, and (3) for any definitions in section 799 applicable to sections 752 

through 758, the District incorporates by reference rules and test methods from the Code of 

Federal Regulations, CARB, and Title 13, California Code of Regulations.

OO. Section 752
15

The District amended section 752 in order to repeal and change the title from “Architectural And 

Industrial Maintenance – Labeling Requirement” to “Portable Fuel Containers And Spouts –

Performance Standards And Test Procedures.” Section 752 was also amended in order to specify 

certification requirements for every portable fuel container, spout, or combination portable fuel 

container and spout, produced thirty (30) days after the effective date, December 23, 2011, that is 

manufactured for sale, advertised for sale, sold, or offered for sale in the District or that is 

introduced, delivered, or imported into the District. Section 752 was amended in order to: (1) 

establish the criteria for obtaining certification, including all test procedure for determining 

certification and compliance, (2) specify that spill-proof systems or spill-proof spouts are not 

exempt from compliance with performance standards, and (3) specify requirements for portable 

fuel container, spout, or combination portable fuel container and spout manufactured before 

thirty (30) days after the effective date, December 23, 2011.

PP. Section 753

The District amended section 753 in order to repeal and change the title from “Architectural And 

Industrial Maintenance – Reporting Requirements” to “Portable Fuel Containers And Spouts –

Exemptions.” Section 753 was also amended in order to establish exemptions for the following: 

(1) any portable fuel container or spout manufactured in the District for shipment, sale, and use 

outside of the District, (2) a manufacturer or distributor who sells, supplies, or offers for sale in 

the District of Columbia, a portable fuel container or spout or combination portable fuel 

container and spout, (3) safety cans, (4) portable fuel containers with a nominal capacity less than 

or equal to one quart, (5) rapid refueling devices with nominal capacities greater than or equal to 

four gallons, (6) portable fuel tanks manufactured specifically to deliver fuel through a hose 

attached between the portable fuel tank and the outboard engine for the purpose of operating the 

outboard engine, and (7) closed-system portable fuel containers that are used exclusively for 

fueling remote control airplanes.

QQ. Section 754

The District amended section 754 in order to repeal and change the title from “Architectural And 

Industrial Maintenance – Testing Requirements” to “Portable Fuel Containers And Spouts –

Labeling Requirements.” Section 754 was also amended in order to establish labeling 

requirements for the following: (1) manufacturer of a portable fuel container or portable fuel 

container and spout subject to and complying with section 752, (2) manufacturer of a spout 

subject to and complying with section 752, (3) and exemptions for manufacturers of portable fuel 

containers or portable fuel containers and spouts not subject to or not in compliance with section 

752.

RR. Section 755

The District added section 755 entitled, “Portable Fuel Containers And Spouts – Certification 

And Compliance Test Procedures.” Section 755 was also added in order to establish testing 

procedures to determine compliance with section 752 and specify the procedure necessary to 

allow the approval of alternative testing methods.
16

SS. Section 756

The District added section 756 entitled, “Portable Fuel Containers And Spouts – Enforcement.” 

Section 756 was also added in order to establish enforceability if the District finds any 

manufacturer, distributor, or retailer manufacturing for sale, advertising for sale, selling, or 

offering for sale in the District a portable fuel container or spout, or both portable fuel container 

and spout that does not comply with the requirements set forth by the portable fuel container and 

spouts regulations.

TT. Section 757

The District added section 757 entitled, “Portable Fuel Containers And Spouts – Innovative 

Product Exemption.” Section 757 was also added in order to: (1) establish the requirements and 

procedures for claiming an innovative products exemption, (2) specify criteria and options for 

manufacturers of portable fuel containers, spouts, or combination portable fuel containers and 

spouts that have been granted an exemption by CARB, (3) establish exemptions for 

manufacturers of portable fuel container or spout who demonstrate that the use of the product 

will result in cumulative VOC emissions below the highest emitting representative spill-proof 

system or representative spill-proof spout in its product category as determined from applicable 

testing, (4) specify the Districts’ process for review and approval of exemption requests, and (5) 

specify the Districts’ process in the event that a portable fuel container or spout for which an 

exemption has been granted no longer meets the criteria for an innovative product.

UU. Section 758

The District added section 758 entitled, “Portable Fuel Containers And Spouts – Variance.” 

Section 758 was also added in order to: (1) establish exemptions from the requirements in 

section 752 for portable fuel containers, spouts, or combination portable fuel containers and 

spouts, which have been granted a variance by CARB, (2) specify the criteria for applying for a 

variance request, (3) specify the criteria necessary for the District to grant a variance request, and 

(4) specify the penalty for failure to comply with the variance requirements.

VV. Section 763

The District added section 763 entitled, “Solvent Cleaning – General Requirements.” Section 

763 was also added in order to: (1) establish applicability to any person who sells, supplies, 

offers for sale, or manufactures any solvent on or after January 1, 2005, for use in the District, 

and (2) for any definitions in section 799 applicable to sections 763 through 769, the District 

incorporates by reference rules and test methods from CARB, the South Coast Air Quality 

Management District, and the American Society for Testing and Materials.

WW. Section 764

The District added section 764 entitled, “Solvent Cleaning – Cold Cleaning.” Section 764 was 

also added in order to establish the following: (1) applicability to all cold cleaning machines that 

process metal parts and contain more than one liter of VOC, (2) requirements for immersion cold 

cleaning machines and remote reservoir cold cleaning machines, (3) operational procedures, (4) 

vapor pressure limits, and (5) reporting and recording requirements. 
17

XX. Section 765

The District added section 765 entitled, “Solvent Cleaning – Batch Vapor Cleaning.” Section 

765 was also added in order to establish the following: (1) applicability to batch vapor cleaning 

machines that process metal parts, (2) how batch vapor cleaning machines must be equipped, (3) 

requirements for operators of a batch vapor cleaning machine with a solvent/air interface area of 

thirteen square feet or less/greater, and (4) operational requirements and procedures.

YY. Section 766

The District added section 766 entitled, “Solvent Cleaning – In-Line Vapor Cleaning.” Section 

766 was also added in order to establish the following: (1) applicability to in-line vapor cleaning 

machines, (2) how in-line vapor cleaning machines must be equipped, and (3) operational 

requirements and procedures.

ZZ. Section 767

The District added section 767 entitled, “Solvent Cleaning – Airless And Air-Tight Cleaning.” 

Section 767 was also added in order to establish the following: (1) applicability to airless 

cleaning machines and air-tight cleaning machines that process metal parts, (2) recording 

requirements for operators of each machine, (3) demonstration that the emissions from each 

machine, on a three month rolling average, are equal to or less than the allowable limit specified 

in Attachment C, (4) operational requirements and procedures, and (5) recording requirements.

AAA. Section 768

The District added section 768 entitled, “Solvent Cleaning – Alternative Compliance.” Section 

768 was also added in order to: (1) specify an alternative for operators of a solvent cleaning

machine to demonstrate compliance, (2) establish recording and compliance requirements, (3) set 

emission limits for cleaning machines with a solvent/air interface specified in Attachment D, (4) 

set emission limits for cleaning machines that is a batch vapor cleaning machine and does not 

have a solvent/air interface specified in Attachment C, and (5) set emission limits for cleaning 

machines with a cleaning capacity less/greater or equal to 2.95 cubic meters.

BBB. Section 769

The District added section 769 entitled, “Solvent Cleaning – Recordkeeping and Monitoring.” 

Section 769 was also added to establish monitoring and record-keeping requirements for 

operators of a solvent cleaning machine.

CCC. Section 770

The District added section 770 entitled, “Miscellaneous Industrial Solvent Cleaning Operations.”

The District added this section in order to address EPA’s CTG for Industrial Cleaning Solvents. 

Section 770 established the following after January 1, 2012: (1) applicability to any person who 

uses any industrial cleaning solvent in a solvent cleaning operation in or on the premises of a 

factory or a shop as part of a manufacturing, production, or repairing process where the facility 

emits at least or less than fifteen pounds (15 lb.) of VOC emissions in any one day from all solvent 

cleaning operations, (2) applicability to any person who sells, supplies, offers for sale, or 
18

manufactures any industrial cleaning solvent for use in the District, (3) a “once in, always in” 

provision, (4) for any definitions in section 799 applicable to section 770, the District 

incorporates by reference rules and test methods from CARB, the South Coast Air Quality 

Management District, and the American Society for Testing and Materials, (5) testing methods 

for VOC content and vapor pressure of industrial cleaning solvents, (6) reporting requirements 

for a person who sells or offers for sale any solvent containing VOCs for use in a solvent 

cleaning operations, and (7) recording and compliance requirements. Section 770 also 

establishes exemptions for any person who owns, operates, or leases certain specific industrial 

solvent cleaning operations and products on or after January 1, 2012. Section 770 was added to 

establish requirements that on and after January 1, 2012, no person may use any industrial 

cleaning solvent in a solvent cleaning operation unless: (1) a person uses an industrial cleaning 

solvent that meets at least a content limit of fifty grams VOC per liter as applied including water 

and exempt compounds or composite vapor pressure of less than or equal to eight millimeters of 

mercury at twenty degrees Celsius or sixty-eight degrees Fahrenheit, and (2) a person controls 

VOC emissions from the solvent cleaning operation with an emission control system with an 

overall control efficiency of at least eight-five percent (85%).

DDD. Section 771

The District added section 771 entitled, “Miscellaneous Cleaning And VOC Materials Handling 

Standards.” The District also added this section in order to address portions of EPA’s CTG for 

Industrial Cleaning Solvents. Section 771 established the following on or after January 1, 2012: 

(1) applicability to any person who owns, operates, or leases any solvent cleaning operation 

subject to section 770, (2) applicability to any person who uses any process that applies coatings, 

inks, or adhesives to flexible packaging where the facility emits more or less than fifteen pounds 

of VOC emissions in any one day before consideration of controls from all processes involved in 

applying coatings, inks, or adhesives to flexible packaging, including related clean-up activities, 

(3) a “once in, always in” provision, (4) exceptions to the usage, handling, storage or disposal of

VOC containing materials coatings, solvents, industrial cleaning solvents, inks, adhesives and 

waste materials, and (5) record-keeping requirements.

EPA’s Miscellaneous Industrial Cleaning Solvents CTG

EPA addressed this category, industrial cleaning solvents, in a CTG document - “Control 

Techniques Guidelines for Industrial Cleaning Solvents, EPA 453/R-06-001” in September 2006. 

EPA issued the CTG to cover all industrial cleaning operations. EPA believes that all categories 

of industrial cleaning operations are represented or can be classified under one of nine cleaning 

categories: (1) spray gun cleaning, (2) spray booth cleaning, (3) large manufactured components 

cleaning, (4) parts cleaning, (5) equipment cleaning, (6) line cleaning, (7) floor cleaning, (8) tank 

cleaning, and (9) small manufactured components cleaning. In terms of applicability, the scope 

of the CTG is focused on industries that have to use organic solvent for cleaning unit operations 

such as mixing vessels (tanks), spray booths, and parts cleaners, where a facility emits at least 6.8 

kg/day (15 lb/day) of VOC before consideration of controls in an ozone nonattainment area.
19

The recommended measures for controlling emissions of VOC from the use, storage, and 

disposal of industrial cleaning solvents includes work practice standards, limitations on VOC 

content of the cleaning materials, and an optional alternative limit on composite vapor pressure 

of the cleaning materials. They also include the use of add-on controls with an overall emission 

reduction of at least 85 percent by mass. The recommended VOC content limit is 50 grams VOC 

per liter (0.42 1b/gal) of cleaning material unless emissions are controlled by an emission control 

system with an overall control efficiency of at least 85 percent. In addition to the recommended 

VOC content limit, EPA recommends inclusion of a composite vapor pressure limit of 8 

millimeters of mercury at 20 degrees Celsius, as (1) a replacement for the 50 g/l VOC content 

limit entirely; or (2) an alternative limit that may be used in lieu of the 50 g/l VOC content limit 

for specific operations as determined by the State.

EEE. Section 773

The District added section 773 entitled, “Architectural And Industrial Maintenance Coating –

General Requirements.” Section 773 was also added in order to establish the following general 

requirements for sections 773 through 778: (1) any person who supplies, sells, offers for sale, 

manufactures, applies, blends, repackages, or solicits the application of any architectural coating 

on or after January 1, 2005, within the District, and (2) for any definitions in section 799 

applicable to sections 773 through 778, the District incorporates by reference rules and test 

methods from United States Environmental Protection Agency, the Code of Federal Regulations, 

CARB, the South Coast Air Quality Management District, the Bay Area Air Quality 

Management District, and the American Society for Testing and Materials.

FFF. Section 774

The District added section 774 entitled, “Architectural And Industrial Maintenance Coating –

Standards.” Section 774 was also added to establish the following: (1) requirements that no 

person shall manufacture, blend, supply, sell, offer for sale, apply, or solicit the application of 

any architectural coating with a VOC content in excess of the corresponding limit specified in

Attachment E, (2) applicability of the most restrictive VOC content limit if there is any 

indication that the architectural coating meets the definition of or is recommended for use for 

more than one of the coating categories listed in Attachment E, (3) exceptions for coating 

categories that are not required to apply the most restrictive VOC content limit, (4) storage 

requirements, (5) requirements that no person who applies or solicits the application of any 

architectural coating shall apply a coating that is thinned to exceed the applicable VOC limit 

specified in Attachment E, (6) requirements that no person shall apply or solicit the application 

of any rust preventive coating for industrial use, unless such a rust preventive coating complies 

with the industrial maintenance coating VOC limit specified in Attachment E, (7) requirements 

that any coating not meeting any of the definitions for the specialty coatings categories listed in

Attachment E, VOC content limit shall be determined by classifying the coating as a flat coating 

or a non-flat coating, based on its gloss, as defined in section 799, and the corresponding flat or 

non-flat coating limit shall apply, and (8) process for requesting the application of an industrial 

maintenance coating with a VOC content greater than three hundred forty gallons per liter (340 

g./L). Section 774 establishes that a person or facility may add up to ten percent (10%) by 
20

volume of VOC to a lacquer to avoid blushing of the finish during days with relative humidity 

greater than seventy percent (70%) and temperature below sixty-five degrees Fahrenheit (65° F) 

or eighteen degrees Celsius (18o C) at the time of application, provided that the coating contains 

acetone and no more than five hundred fifty grams (550 g.) of VOC per liter of coating, less 

water and exempt compounds, before the addition of VOC.

GGG. Section 775

The District added section 775 entitled, “Architectural And Industrial Maintenance Coating –

Exemptions.” Section 775 was also added in order to establish exemptions for the following: (1)

any architectural coating that is sold or manufactured for use outside of the District of Columbia 

or for shipment to other manufacturers for reformulation or repackaging, (2) any aerosol coating 

product, and (3) any architectural coating that is sold in a container with a volume of one liter (1 

L) or one and fifty-seven hundredths quarts (1.057 q.) or less.

HHH. Section 776

The District added section 776 entitled, “Architectural And Industrial Maintenance Coating –

Labeling Requirement.” Section 776 was also added in order to specify labeling requirements for

manufacturers of any architectural coating.

III. Section 777

The District added section 777 entitled, “Architectural And Industrial Maintenance Coating –

Reporting Requirements.” Section 777 was also added in order to specify reporting requirements 

for the following: (1) any manufacturer of clear brushing lacquers, (2) any manufacturer of rust 

preventive coatings, (3) any manufacturer of specialty primers, sealers, and undercoaters, (4) any 

manufacturer of architectural coating that contains perchloroethylene or methylene chloride, (5) 

any manufacturer of recycled coatings, and (6) any manufacturer of bituminous roof coatings or 

bituminous roof primers.

JJJ. Section 778

The District added section 778 entitled, “Architectural And Industrial Maintenance Coating –

Testing Requirements.” Section 778 was also added in order to establish testing procedures for 

the purpose of determining compliance with the VOC content limits in Attachment E, and to 

determine the physical properties of a coating. Section 778 also establishes alternative testing 

methods for determining compliance, incorporate by reference various test methods used to test 

coatings, and specify exemptions from test methods.

KKK. Section 779

The District amended section 779 entitled, “Definitions” to update definitions and terms to read 

as follows: “ACP agreement,” “ACP emissions,” “ACP limit,” “ACP product,” “ACP 

reformulation or ACP reformulated,” “ACP standard,” “ACP VOC standard,” “Acrylonitrilebutadiene-styrene (ABS) welding adhesive,” “Adhesive,” “Adhesive primer,” “Adhesive 

remover,” “Aerosol adhesive or adhesive primer,” “Aerosol coating product,” “Aerosol cooking 

spray,” “Aerosol product,” “Aerospace component,” “Agricultural use,” “Air freshener,” “Airless 
21

cleaning system,” “Airless spray,” “Air-tight cleaning system,” “Alcohol,” “Alcohol substitutes,” 

“All other carbon-containing compounds,” “All other forms,” “Alternative control plan or ACP,” 

“Antenna coating,” “Antifouling coating,” “Antimicrobial hand or body cleaner or soap,” 

“Antiperspirant,” “Antique motor vehicle,” “Anti-static product,” “Applicable CTG document, 

“Appurtenance,” “Architectural coating,” “Architectural sealant / primer,” “ASTM,” 

“Astringent/toner,” “Automatically close,” “Automatic closure,” “Automotive brake cleaner,” 

“Automotive elastomeric coating,” “Automotive glass adhesive primer,” “Automotive hard paste 

wax,” “Automotive impact-resistant coating,” “Automotive instant detailer,” “Automotive 

jambing clearcoat,” “Automotive lacquer,” “Automotive low-gloss coating,” “Automotive multicolored topcoat,” “Automotive pretreatment,” “Automotive primer-sealer,” “Automotive primersurfacer,” “Automotive rubbing or polishing compound,” “Automotive specialty coating,” 

“Automotive topcoat,” “Automotive touch-up or repair,” “Automotive wax, polish, sealant or 

glaze,” “Automotive windshield washer fluid,” “Available control options,” “Batch vapor 

cleaning machine,” “Bathroom and tile cleaner,” “Bitumens,” “Bituminous roof coating,” 

“Bituminous roof primer,” “Bond breaker,” “Bug and tar remover,” “Calcimine recoater,” 

“CARB,” “Carbon absorber,” “Carburetor or fuel-injection air intake cleaner,” “Carpet and 

upholstery cleaner,” “Ceramic tile installation adhesive,” “Charcoal lighter material,” 

“Chlorinated polyvinyl chloride (CPVC) plastic,” “Chlorinated polyvinyl chloride (CPVC) 

welding adhesive,” “Classic motor vehicle,” “Cleaning solution,” “Cleanup solvent,” “Clear 

brushing lacquers,” “Clear wood coatings,” “Coating,” “Coating unit,” “Cold cleaning machine,” 

“Colorant,” “Compliance period,” “Computer diskette jacket manufacturing adhesive,” 

“Concrete curing compound,” “Concrete surface retarder,” “Conjugated oil varnish,” 

“Construction, panel, and floor covering adhesive,” “Consumer,” “Consumer product,” “Contact 

adhesive/contact bond adhesive,” “Contact adhesive – general purpose,” “Contact adhesive –

special purpose,” “Contact person,” “Container/packaging,” “Control techniques guideline 

(CTG),” “Conventional air spray,” “Conversion varnish,” “Cove base,” “Cove base installation 

adhesive,” “Crawling bug insecticide,” “CTG,” “Curtain coating,” “Cyanoacrylate adhesive,” 

“Cylinder-wipe,” “Date-code,” “Day,” “Deodorant,” “Deodorant body spray,” “Department,” 

“Device,” “dip coating,” “Disinfectant,” “Distributor,” “District of Columbia gross sales,” 

“District of Columbia sales,” “Double-phase aerosol air freshener,” “Dry cleaning fluid,” “Dry 

fog coating,” “Drywall installation,” “Dusting aid,” “Dwell,” “Dwell time,” “Electrical and 

electronic components,” “Electrical cleaner,” “electron beam ink,” “electronic cleaner,” 

“Electrostatic application,” “Energized electrical cleaner,” “Enforceable sales,” “ Enforceable 

sales record,” “Engine degreaser,” “Exempt compound,” “Exempt perfluorocarbon compounds,” 

“Existing product,” “o F,” “Fabric protectant,” “Fabric refresher,” “Facial cleaner or soap,” “Fat 

wood,” “Faux finishing coating,” “Federally enforceable,” “Fiberglass,” “Fire-resistive coating,” 

“Fire-retardant coating,” “First installation date,” “Flat coating,” “Flea and tick insecticide,” 

“flexible flooring material,” “Flexible packaging,” “Flexible vinyl,” “Flexographic package 

printing,” “Flexographic package printing press,” “Floor coating,” “Floor polish or wax,” “Floor 

seam sealer,” “Floor wax stripper,” “Flow coating,” “Flying bug insecticide,” “Footwear and 

leather care product,” “Form-release compound,” “Fountain solution,” “Fountain solution 

reservoir,” “Fragrance,” “Freeboard ration,” “Freeboard refrigeration device,” “Fuel,” “Furniture 

coating,” “Furniture maintenance product,” “Gel,” “General purpose adhesive,” “General 
22

purpose cleaner,” “General purpose degreaser,” “General-use hand or body cleaner or soap,” 

“Glass cleaner,” “Graffiti remover,” “Graphic arts coating or sign paint,” “Gravure,” “Hair 

mousse,” “Hair shine,” “Hairspray,” “Hair styling gel,” “Hair styling product,” “Hand application 

methods,” “Heatset,” “Heatset dryer,” “Heavy-duty hand cleaner or soap,” “Herbicide,” “High 

precision optic,” “High-temperature coating,” “High volatility organic compound (HVOC),” 

“High-volume low-pressure (HVLP) spray,” “High volume-low pressure spray,” ‘Household 

product,” “Immersion cold cleaning machine,” “Impacted immersion coating,” “Indoor floor 

covering installation adhesive,” “Industrial cleaning solvent,” “Industrial maintenance coating,” 

“Inking cylinder,” “In-line vapor cleaning machine,” “Insecticide,” “Insecticide fogger,” 

“Institutional product or industrial and institutional (I & I) product,” “Intaglio,” “Janiotrial 

cleaning,” “janitorial products,” “Kerosene,” “Label,” “Lacquer,” “Laminate,” “Large appliance 

coatings,” “Large appliance part,” “Large appliance product,” “Laundry prewash,” “Laundry 

starch product,” “Lawn and garden insecticide,” “Letterpress,” “Letterset,” “Liquid,” 

“Lithography,” “Low-solids coating, adhesive, sealant, or primer,” “Lubricant,” “LVP content,” 

“LVP-VOC,” “Magnesite cement coating,” “Magnet wire,” “Manufacturer,” “Marine deck 

sealant or marine deck sealant primer,” “Maskant,” “Mastic texture coating,” “Medical 

equipment manufacturing,” “Medicated astringent/medicated toner,” “Medium volatility organic 

compound (MVOC),” “Metal furniture coatings,” “Metal furniture substrate,” “Metallic 

pigmented coating,” “Metal polish/cleanser,” “Metal to urethane/rubber molding or casting 

adhesive,” “Miscellaneous metal product and plastic parts surface coatings,” “Miscellaneous 

metal products facility,” “Missing data days,” “Mist spray adhesive,” “Mobile equipment,” 

“Motor vehicle adhesive,” “Motor vehicle glass bonding primer,” “Motor vehicle weatherstrip 

adhesive,” “Multi-color coating,” “Multi-purpose construction adhesive,” “Multi-purpose dry 

lubricant,” “Multi-purpose lubricant,” “Multi-purpose solvent,” “Nail polish,” “Nail polish 

remover,” “Nominal capacity,” “Non-aerosol product,” “Non-carbon containing compound,” 

“non-flat coating,” “Non-flat high gloss coating,” “Non-heatset,” “Non-industrial use,” “Nonmembrane roof installation/repair adhesive,” “Non-membrane roof installation/repair solvent,” 

“Non-resilient flooring,” “Non-selective terrestrial herbicide,” “Nuclear coating,” “Off-line 

cleaning,” “Offset printing process,” “One-product business,” “Outboard engine,” “Outdoor floor 

covering installation adhesive,” “Oven cleaner,” “Paint,” “Paint remover or stripper,” “Panel 

installation,” “Paper-wipe,” “Penetrant,” “Percent VOC by weight,” ‘Perimeter bonded sheet 

flooring installation,” “Permeation,” “Personal fragrance product,” “Pesticide,” “Pharmaceutical 

products,” “Photochemically reactive solvent,” “Plastic cement welding adhesive,” “Plastic 

cement welding adhesive primer,” “Plastic foam,” “Plasticizer,” “Plastics,” “Plastic part,” 

“Plate,” “Polyvinyl chloride (PVC) plastic,” “Polyvinyl chloride (PVC) welding adhesive,” 

“Porous material,” “Portable fuel container,” “Post-consumer coating,” “Pre-ACP VOC content,” 

“Pressurized gas duster,” “Pre-treatment wash primer,” “Primer,” “Principal display panel or 

panels,” “Printing,” “Printing operation,” “Printing press,” “Printing unit,” “Product brand 

name,” “Product category,” “Product line,” “Propellant,” “Pump spray,” “Quick-dry enamel,” 

“Quick-dry primer sealer and undercoater,” “RACT,” “Reactive diluents,” “Reactive Penetrating 

Carbonate Stone Sealer,” “Reasonably Available Control Technology,” “Reconcile or 

reconciliation,” “Reconciliation of shortfalls plan,” “Recycled coating,” “Reduced room draft,” 

“Reinforced plastic composites,” “Remote reservoir cold cleaning machine,” “Residence,” 
23

“Responsible ACP party,” “Responsible party,” “Restricted materials,” “Retailer,” “Retail 

outlet,” “Roadway sealant,” “Roller coating,” “Roll-on product,” “Roof coating,” “Rotogravure 

package printing,” “Rotogravure package printing press,” “Rubber,” “Rubber and vinyl

protectant,” “Rubbing alcohol,” “Rust preventive coating,” “Sanding sealer,” “SCAQMD,” 

“Screen printing,” “Sealant,” “Sealant and caulking compound,” “Sealant primer,” “Sealer,” 

“Secondary coating (rework),” “Semisolid,” “Shaving cream,” “Shaving gel,” “Sheet-applied 

rubber installation,” “Sheet-fed,” “Shellac,” “Shop application,” “Shortfall,” “Silicone-based 

multi-purpose lubricant,” “Single-phase aerosol air freshener,” “Single-ply roof membrane,” 

“Single-ply roof membrane installation or repair adhesive,” “Single-ply room membrane 

sealant,” “Small business,” “Solicit,” “Solid,” “Solvent,” “Solvent/air interface,” “Solvent 

cleaning machine,” “Solvent cleaning machine automated parts handling system,” “Solvent 

cleaning machine down time,” “Solvent cleaning machine idle time,” “Solvent cleaning 

operation,” “Solvent cleaning tanks or related equipment,” “Solvent flushing,” “Special purpose 

spray adhesive,” “Specialty flexographic printing,” “Specialty primer, sealer, and undercoater,” 

“Spill-proof spout,” “Spill-proof system,” “Spot remover,” “Spout,” “Spray buff product,” 

“Stain,” “Stick product,” “Stone consolidant,” “Stripping,” “Structural glazing adhesive,” 

“Structural glazing adhesives,” “Structural waterproof adhesive,” “Subfloor installation,” 

“Superheated vapor system,” “Surface preparation,” “Surface preparation solvent,” “Surplus 

reduction,” “Surplus trading,” “Swimming pool coating,” “Swimming pool repair and 

maintenance coating,” “Table B compound,” “Target fuel tank,” “Temperature-indicator safety 

coating,” “Terrestrial,” “Thermoplastic rubber coating and mastic,” “Thin metal laminating 

adhesive,” “Tint base,” “Tire repair,” “Tire sealant and inflation,” “Tire retread adhesive,” 

“Toilet/urinal care product,” “Total maximum historical emissions (TMHE), “Traffic marking 

coating,” “Traffic marking tape,” “Traffic marking tape adhesive primer,” “Type A propellant,” 

“Type B propellant,” “Type C propellant,” “Ultraviolet ink,” “Undercoater,” “Undercoating,” 

“Undersea-based weapons systems components,” “Usage directions,” “Vapor cleaning machine,” 

“Vapor cleaning machine primary condenser,” “Vapor up control switch,” “Varnish,” 

“Vinyl/Fabric/Leather/Polycarbonate coating,” “VOC composite partial vapor pressure,” “VOC 

content,” “Wasp and hornet insecticide,” “Water-based solvent,” “Waterproofer,” 

“Waterproofing concrete/masonry sealer,” “Waterproofing sealer,” “Waterproof resorcinol glue,” 

“Wax,” “Web,” “Web spray adhesive,” “Wiping solution,” “Wood cleaner,” “Wood floor wax,” 

“Wood preservative,” “Working day,” “Working mode cover,” and “Year.”

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. The amendments and 

additions to portions of Chapters 1 and 7 of Title 20 (Environment) of the District of Columbia 

Municipal Regulations meet the applicable requirements of the CAA, and the applicable EPA 

regulations, guidance, and policy and strengthen the SIP. The District of Columbia has adopted 

the standards and requirements as recommended by the CTGs and OTC model rules by including 

applicability, standards, exemptions, requirements for labeling, monitoring, testing, and reporting 

and recordkeeping. These regulations conform to the CTGs issued by EPA in order to reflect 

technology developments and expand VOC emission controls; as well as, reflect the RACT 
24

requirements recommended in EPA’s CTGs and OTC model rules. This SIP revision satisfies all 

requirements for an acceptable SIP and for RACM/RACT. EPA approval of the SIP revision is 

recommended.
25

ATTACHMENT A

720 - CONSUMER PRODUCTS - VOC STANDARDS

Table of Standards. Percent VOC by weight:

Product Category Effective date 

1/1/2005

Effective date 

1/1/2012

Adhesive Removers:

 Floor and wall Covering 5

 Gasket or thread locking 50

 General purpose 20

 Specialty 70

Adhesives:

 Aerosol mist spray 65

 Aerosol web spray 55

 Special Purpose Spray Adhesives:

 Mounting, automotive engine

 compartment, and flexible vinyl 70

 Polystyrene foam and automotive

 Headliner 65

 Polylolefin and laminate repair /

 Edgebanding 60

 Construction, panel, and floor 15

 Contact 80 NA

 Contact General Purpose 55

 Contact Special Purpose 80

 General purpose 10

 Structural waterproof 15

Air Fresheners:

 Single-phase aerosols 30

 Double-phase aerosols 25

 Liquids / pump sprays 18

 Solids / semisolids 3

Antiperspirants:

 Aerosol 40 HVOC

 Aerosol 10 MVOC

 Non-aerosol 0 HVOC

 Non-aerosol 0 MVOC

Anti-Static Product, non-aerosol 11

Automotive Brake Cleaners 45

Automotive Rubbing or Polishing Compound 17

Automotive Wax, Polish, Sealant or Glaze

 Hard paste waxes 45

 Instant detailers 3
26

Product Category Effective date 

1/1/2005

Effective date 

1/1/2012

 All other forms 15

Automotive Windshield Washer Fluids 35

Bathroom and Tile Cleaners:

 Aerosols 7

 All other forms 5

Bug and Tar Remover 40

Carburetor or Fuel-Injection Air Intake Cleaners 45

Carpet and Upholstery Cleaners:

 Aerosols 7

 Non-aerosols (dilutables) 0.1

 Non-aerosols (ready-to-use) 3.0

Charcoal Lighter Material see §730

Cooking Spray:

 Aerosols 18

Deodorants:

 Aerosol 0 HVOC

 Aerosol 10 MVOC

 Non-aerosol 0 HVOC

 Non-aerosol 0 MVOC

Dusting Aids:

 Aerosols 25

 All other forms 7

Electrical Cleaner 45

Electronic Cleaner 75

Engine Degreasers:

 Aerosol 35

 Non-aerosol 5

Fabric Protectants 60

Fabric Refresher: 

 Aerosol 15

 Non-aerosol 6

Floor Polishes / Waxes:

 Products for flexible flooring materials 7

 Products for non-resilient flooring 10

 Wood floor wax 90

Floor Wax Strippers: 

 Non-Aerosol see §731

Footwear or Leather Care Products: 

 Aerosol 75

 Solid 55
27

Product Category Effective date 

1/1/2005

Effective date 

1/1/2012

 Other forms 15

Furniture Maintenance Products:

 Aerosols 17

 All other forms except solid or paste 7

General Purpose Cleaners:

 Aerosols 10

 Non-aerosols 4

General Purpose Degreasers:

 Aerosols 50

 Non-aerosols 4

Glass Cleaners:

 Aerosols 12

 Non-aerosols 4

Graffiti Remover: 

 Aerosols 50

 Non-aerosols 30

Hair Mousses 6

Hair Shines 55

Hairsprays 55

Hair Styling Gels 6

Hair Styling Products: 

 Aerosol and pump sprays 6

 All other forms 2

Heavy-Duty Hand Cleaners or Soaps 8

Insecticides:

 Crawling bug (aerosol) 15

 Crawling bug (all other forms) 20

 Flea and tick 25

 Flying bug (aerosol) 25

 Flying bug (all other forms) 35

 Foggers 45

 Lawn and garden (all other forms) 20

 Lawn and garden (non-aerosol) 3

 Wasp and hornet 40

Laundry Prewashes:

 Aerosols / solids 22

 All other forms 5

Laundry Starch Products 5

Metal Polishes / Cleansers 30
28

Product Category Effective date 

1/1/2005

Effective date 

1/1/2012

Multi-Purpose Lubricants (excluding solid or semisolid products) 50

Nail Polish Removers 75

Non-Selective Terrestrial Herbicides: 

 Non-aerosols 3

Oven Cleaners:

 Aerosols / pump sprays 8

 Liquids 5

Paint Remover or Strippers 50

Penetrants 50

Rubber and Vinyl Protectants:

 Non-aerosols 3

 Aerosols 10

Sealants and Caulking Compounds 4

Shaving Creams 5

Shaving Gel 7

Silicone-Based Multi-Purpose Lubricants 

(excluding solid or semi-solid products) 60

Spot Removers:

 Aerosols 25

 Non-aerosols 8

Tire Sealants and Inflators 20

Toilet/Urinal Care:

 Aerosols 10

 Non-aerosol 3

Undercoatings: 

 Aerosols 40

Wood Cleaner: 

 Aerosol 17

 Non-Aerosol 4

Note: NA = Not applicable after January 1, 2012
29

ATTACHMENT B

744 – ADHESIVES AND SEALANTS - VOC STANDARDS

Table of Standards. VOC Content Limits for Adhesives, Sealants, Adhesive Primers, 

Sealant Primers and Adhesives Applied to Particular Substrates.

Adhesive, sealant, adhesive primer or sealant primer category

VOC content 

limit (grams 

VOC per liter*)

CATEGORY 1: ADHESIVES VOC Limits

(g/L)

ABS welding 400

Ceramic tile installation 130

Computer diskette jacket manufacturing 850

Contact or contact bond 250

Cove base installation 150

CPVC welding 490

Indoor floor covering installation 150

Metal to urethane/rubber molding or casting 850

Motor vehicle 250

Motor vehicle weatherstrip 750

Multi-purpose construction 200

Non-membrane roof installation/repair 300

Outdoor floor covering installation 250

Plastic cement welding (except ABS, PVC or CPVC) 510

PVC welding 510

Single-ply roof membrane installation/repair 250

Structural glazing 100

Thin metal laminating 780

Tire retread 100

Perimeter bonded sheet vinyl flooring installation 660

Waterproof resorcinol glue 170

Sheet-applied rubber installation 850

CATEGORY 2: SEALANTS VOC Limits in 

(g/L)

Architectural 250

Marine deck 760

Non-membrane roof installation / repair 300

Roadway 250

Single-ply roof membrane 450

Other 420

CATEGORY 3: ADHESIVE PRIMERS VOC Limits in 

(g/L)

Automotive glass 700

Motor vehicle glass bonding 900
30

Adhesive, sealant, adhesive primer or sealant primer category

VOC content 

limit (grams 

VOC per liter*)

Plastic cement welding 650

Single-ply roof membrane 250

Traffic marking tape 150

Other 250

CATEGORY 4: SEALANT PRIMERS VOC Limits in 

(g/L)

Architectural – non-porous material 250

Architectural – porous material 775

Marine deck 760

Other 750

CATEGORY 5: ADHESIVES APPLIED TO PARTICULAR 

SUBSTRATES

VOC Limits in 

(g/L)

Flexible vinyl 250

Fiberglass 200

Reinforced plastic composite 200

Metal 30

Porous material (other than wood) 120

Rubber 250

Wood 30

Other substrates 250

* The VOC content is determined as the weight of VOCs,

less water and exempt compounds as specified in §747.
31

ATTACHMENT C

767 – SOLVENT CLEANING –AIRLESS AND AIR-TIGHT CLEANING

Emission Limits for Cleaning Machines without a Solvent/Air Interface 

Cleaning 

Capacity

(m3)

3-Month rolling 

average monthly 

emission limit 

(kilograms/month)

Cleaning 

Capacity

(m3)

3-Month rolling 

average monthly 

emission limit 

(kilograms/month)

Cleaning 

Capacity

(m3)

3-Month rolling 

average monthly 

emission limit 

(kilograms/month)

0.00 0 1.00 330 2.00 500

0.05 55 1.05 340 2.05 508

0.10 83 1.10 349 2.10 515

0.15 106 1.15 359 2.15 522

0.20 126 1.20 368 2.20 530

0.25 144 1.25 377 2.25 537

0.30 160 1.30 386 2.30 544

0.35 176 1.35 395 2.35 551

0.40 190 1.40 404 2.40 558

0.45 204 1.45 412 2.45 565

0.50 218 1.50 421 2.50 572

0.55 231 1.55 429 2.55 579

0.60 243 1.60 438 2.60 585

0.65 255 1.65 446 2.65 592

0.70 266 1.70 454 2.70 599

0.75 278 1.75 462 2.75 605

0.80 289 1.80 470 2.80 612

0.85 299 1.85 477 2.85 619

0.90 310 1.90 485 2.90 625

0.95 320 1.95 493 2.95 632
32

ATTACHMENT D

768 – SOLVENT CLEANING – ALTERNATIVE COMPLIANCE

Emission limits for Batch Vapor and In-Line Solvent Cleaning Machines with a 

Solvent/Air Interface

Solvent Cleaning Machine

Three (3) Month 

Rolling Average

(kg/m2/month)

Monthly Emission 

Limit:

(lb/ft2/month)

Solvent cleaning machines 

batch vapor

150 30.7

Existing in-line solvent 

cleaning machines

153 31.3

New in-line solvent cleaning 

machines 99 20.2
33

ATTACHMENT E

774 – ARCHITECTURAL AND INDUSTRIAL MAINTEANCE COATING –

STANDARDS

Table of Standards. VOC Content Limits for Architectural Coatings.

1

Coating Category VOC Content Limit

(Grams VOC per liter)2

Flat coatings 100

Non-flat coatings 150

Non-flat high gloss coatings 250

Specialty Coatings

Antenna coatings 530

Antifouling coatings 400

Bituminous roof coatings 300

Bituminous roof primers 350

Bond breakers 350

Calcimine recoater 475

Clear wood coatings:

• Clear brushing lacquers 680

• Lacquers (including lacquer sanding sealers) 550

• Sanding sealers (other than lacquer sanding 

sealers)

350

• Varnishes 350

Concrete curing compounds 350

Concrete surface retarders 780

Conjugated oil varnish 450

Conversion varnish 725

Dry fog coatings 400

Faux finishing coatings 350

Fire-resistive coatings 350

Fire-retardant coatings

• Clear 650

• Opaque 350

Floor coatings 250

 

1

Limits are expressed in grams of VOC per liter of coating thinned to the manufacturer's 

maximum recommendation, excluding the volume of any water, exempt compounds, or colorant 

added to tint bases. Manufacturer’s maximum recommendation means the maximum 

recommendation for thinning that is indicated on the label or lid of the coating container. 

2 Conversion factor: one pound VOC per gallon (U.S.) is equivalent to one hundred nineteen and 

ninety-five one hundredths grams per liter (119.95 g/L).
34

Coating Category VOC Content Limit

(Grams VOC per liter)2

Flow coatings 420

Form-release compounds 250

Graphic arts coatings (sign paints) 500

High-temperature coatings 420

Industrial maintenance coatings 340

Impacted immersion coatings 780

Low-solids coatings3120

Magnesite cement coatings 450

Mastic texture coatings 300

Metallic pigmented coatings 500

Multi-color coatings 250

Nuclear coatings 450

Pre-treatment wash primers 420

Primers, sealers, and undercoaters 200

Reactive penetrating carbonate stone sealer 600

Quick-dry enamels 250

Quick-dry primers, sealers and undercoaters 200

Recycled coatings 250

Roof coatings 250

Rust preventative coatings 400

Shellacs

• Clear 730

• Opaque 550

Specialty primers, sealers, and undercoaters 350

Stains 250

Stone consolidants 450

Swimming pool coatings 340

Swimming pool repair and maintenance 

coatings

340

Temperature-indicator safety coatings 550

Thermoplastic rubber coatings and mastics 550

Traffic marking coatings 150

Waterproofing sealers 250

Waterproofing concrete/masonry sealers 400

Wood preservatives 350

 

3 Units for this coating are grams of VOC per liter (pounds of VOC/gallon) of coating, including 

water and exempt compounds.