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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: September 29, 2011

SUBJECT: Technical Support Document for Virginia‟s Regulations for the Control of 

Volatile Organic Compounds from Consumer and Commercial Products

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning 

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND 

On March 18, 2010, the Virginia Department of Environmental Quality (VADEQ) 

submitted a revision to the Virginia State Implementation Plan (SIP). The SIP revision 

adds a new chapter (9VAC5-45 – Consumer and Commercial Products) in order to

control volatile organic compounds (VOC) from portable fuel containers, consumer 

products, architectural and industrial (AIM) coatings, adhesives and sealants, and asphalt 

paving operations within the Northern Virginia and Fredericksburg VOC Emissions 

Control Areas. The SIP revision also includes new and revised documents incorporated 

into the Virginia regulation by reference (9VAC5-20-21 – Documents incorporated by 

reference) in order to support the new and revised regulations. The effective date of this 

regulation is March 17, 2010.

The standards and requirements contained in Virginia‟s consumer and commercial 

products regulations are consistent with the Ozone Transport Commission (OTC) model 

rules. The OTC consumer products model rule was based on the existing rules developed 

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

technology (RACT) determination. Implementing this model rule will result in SIP 

emission reductions in VOC to support the attainment demonstrations, and reductions in 

ground-level ozone in other areas of the OTR. The OTR consists of Delaware, Maine, 

New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island, New York, New 

Jersey, Pennsylvania, Maryland, the District of Columbia, and Virginia.

B. STATE SUBMITTAL:
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I. Documents incorporated by reference

This SIP revision amends 9VAC5-20-21 in order to make administrative changes for 

clarity, style, format, and renumbering. The revision adds sections to 9VAC5-20-21 in 

order to incorporate into the Virginia regulation by reference to support the new and 

revised regulations.

II. Consumer and Commercial Products

The Commonwealth of Virginia established a new chapter 9VAC5-45 in order to control 

VOC emissions from various consumer and commercial products within the Northern 

Virginia and Fredericksburg VOC Emissions Control Areas. The new chapter consists of 

general requirements that pertain to regulating consumer and commercial products, as 

well as, VOC content and emission limits for consumer and commercial products. 

9VAC5-45 also contains the control technology, testing, monitoring, administrative, 

recordkeeping, and reporting requirements necessary to determine compliance with each 

of the applicable standards. 

The SIP revision adds sections 9VAC5-45-10, 9VAC5-45-20, 9VAC5-45-30, 9VAC5-

45-40, and 9VAC5-45-50 in order to: (1) specify applicability to any product, owner, or 

other person subject to the provisions of Chapter 45; (2) establish compliance with the 

standards in Chapter 45; (3) establish emission tests for operations and products subject 

to the standards subject to the provisions of Chapter 45; (4) specify monitoring 

requirements; and (5) specify notification, records, and reporting requirements.

Portable Fuel Containers and Spouts Manufactured Before and After August 1, 

2010

The Commonwealth of Virginia established two articles in 9VAC5-45 in order to 

implement design, performance, and labeling standards for portable fuel containers and 

spouts before and after August 1, 2010, and to prohibit owners form manufacturing, 

distributing, and selling noncompliant products.

The following SIP revisions pertain to portable fuel containers and spouts manufactured 

before August 1, 2010:

The SIP revision adds section 9VAC5-45-60 in order to establish applicability to any 

person who sells, supplies, offers for sale, or manufactures for sale portable fuel 

containers and spouts within the Northern Virginia and Fredericksburg Volatile Organic 

Compound Emissions Control Areas.

The SIP revision also adds section 9VAC5-45-70 in order to specify exemptions for any

portable fuel container or spout manufactured, sold, supplied, or offered for sale within 

and used outside the Northern Virginia and Fredericksburg Volatile Organic Compound 

Emissions Control Areas.

The SIP revision adds the following definitions and terms in section 9VAC5-45-80: 
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“ASTM,” “CARB,” “Consumer,” “Distributor,” “Fuel,” “Manufacturer,” “Nominal 

capacity,” “Outboard engine,” “Permeation,” “Portable fuel container,” “Retail outlet,” 

“Retailer,” “Spill-proof spout,” “Spill-proof spout system,” “Spout,” and “Target fuel 

tank.”

The SIP revision adds sections 9VAC5-45-90, 9VAC5-45-100, 9VAC5-45-110, 9VAC5-

45-120, 9VAC5-45-130, 9VAC5-45-140, and 9VAC5-45-150 in order to: (1) specify 

performance standards for VOCs, (2) specify administrative requirements, (3) specify 

compliance procedures, (4) establish compliance schedules, (5) specify test methods and 

procedures, (6) specify monitoring applicability, and (7) specify notification, records, and 

reporting requirements.

The following SIP revisions pertain to portable fuel containers and spouts manufactured 

after August 1, 2010:

The SIP revision adds section 9VAC5-45-160 in order to establish applicability to any 

person who sells, supplies, offers for sale, or manufactures for sale portable fuel 

containers and spouts on or after within the Northern Virginia and Fredericksburg 

Volatile Organic Compound Emissions Control Areas.

The SIP revision also adds section 9VAC5-45-170 in order to specify exemptions for any 

portable fuel container or spout manufactured, sold, supplied, or offered for sale within 

and used outside the Northern Virginia and Fredericksburg Volatile Organic Compound 

Emissions Control Areas.

The SIP revision adds the following definitions and terms in section 9VAC5-45-180: 

“ASTM,” “CARB,” “CARB certification executive order,” “Consumer,” “Distributor,” 

“Fuel,” “Kerosene or kerosene,” “Manufacturer,” “Nominal capacity,” “Outboard 

engine,” “Permeation,” “Portable fuel container,” “Product category,” “Retail outlet,” 

“Retailer,” “Spill-proof spout,” “Spill-proof spout system,” “Spout,” and “Target fuel 

tank.”

The SIP revision adds sections 9VAC5-45-190, 9VAC5-45-200, 9VAC5-45-210, 

9VAC5-45-220, 9VAC5-45-230, 9VAC5-45-240, 9VAC5-45-250, 9VAC5-45-260, and 

9VAC5-45-270 in order to: (1) specify performance standards for VOCs on or after 

August 1, 2010, (2) specify certification procedures, (3) specify innovative products 

procedures, (4) specify administrative requirements, (5) specify compliance procedures, 

(6) establish compliance schedules, (7) specify test methods and procedures, (8) specify 

monitoring applicability, and (9) specify notification, records, and reporting 

requirements.

Consumer Products Manufactured Before, on, or After August 1, 2010

The Commonwealth of Virginia established two articles in 9VAC5-45 in order to 

implement VOC content standards for certain individual product categories before and 

after August 1, 2010 and to prohibit owners from manufacturing, distributing, 
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advertising, or selling noncompliant products.

The following SIP revisions pertain to consumer products manufactured before August 1, 

2010:

The SIP revision adds section 9VAC5-45-280 in order to establish applicability to any 

consumer product manufactured that contains VOCs within the Northern Virginia and 

Fredericksburg Volatile Organic Compound Emissions Control Areas.

The SIP revision also adds section 9VAC5-45-290 in order to set exemptions for the 

following: (1) products for shipment and use outside the Northern Virginia and 

Fredericksburg Volatile Organic Compound Emissions Control Areas, (2) antiperspirants 

and deodorants, (3) products registered under the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA), (4) air fresheners, (5) adhesives, (6) bait station insecticides, 

and (7) fragrances.

The SIP revision adds the following definitions and terms in section 9VAC5-45-300: 

“ACP (Alternative Control Plan) emissions,” “ACP limit,” “ACP product,” “ACP VOC 

standard,” “ASTM (American Society for Testing and Materials),” “adhesive,” “adhesive 

remover,” “aerosol adhesive,” “aerosol cooking spray,” “aerosol product,” “agricultural 

use,” air freshener,” “all other carbon-containing compounds,” “all other forms,” 

“alternative control plan or ACP,” “antimicrobial hand or body cleaner or soap,” 

“antiperspirant,” “architectural coating,” “ASTM,” “astringent or toner,” “automotive 

brake cleaner,” “automotive hard paste wax,” “automotive instant detailer,” “automotive 

rubbing or polishing compound,” “automotive wax, polish, sealant or glaze,” “automotive 

windshield washer fluid,” “bathroom and tile cleaner,” “bug and tar remover,” “CARB,” 

“carburetor or fuel-injection air intake cleaners,” “carpet and upholstery cleaner,” 

“certified emissions,” “certified use rate,” '”charcoal lighter material,” “colorant,” 

“compliance period,” “construction, panel and floor covering adhesive,” “consumer,” 

“consumer product,” “contact adhesive,”, “contact person,” “container or packaging,” 

“crawling bug insecticide,” “date-code,” “deodorant,” “device,” “disinfectant,” 

“distributor,” “double phase aerosol air freshener,” “dry cleaning fluid,” “dusting aid,” 

“electronic cleaner,” “enforceable sales,” “enforceable sales record,” “engine degreaser,” 

“exempt compound,” “fabric protectant,” “facial cleaner or soap,” “fat wood,” “FIFRA,” 

“flea and tick insecticide,” flexible flooring material,” “floor polish or wax,” “floor seam 

sealer,” “floor wax stripper,” “flying bug insecticide,” “fragrance,” “furniture coating,” 

“furniture maintenance product,” “gel,” “general purpose adhesive,” “general purpose 

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

cleaner,” “gross sales,” “hair mousse,” “hair shine,” “hair spray,” “hair styling gel,” 

“heavy-duty hand cleaner or soap,” “herbicide,” “high volatility organic compound or 

HVOC,” “household product,” “insecticide,” “insecticide fogger,” “institutional product 

or industrial and institutional (I&I) product,” “label,” “laundry prewash,” “laundry starch 

product,” “lawn and garden insecticide,” “liquid,” “lubricant,” “LVP (lower vapor 

pressure) content or lower vapor pressure content,” “LVP-VOC or lower vapor pressureVOC,” “manufacturer,” “medicated astringent/medicated toner,” “medium volatility 

organic compound or MVOC,” “metal polish or cleanser,” “missing data days,” “mist 
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spray adhesive,” “multipurpose dry lubricant,” “multipurpose lubricant,” “multipurpose 

solvent,” “nail polish,” “nail polish remover,” “nonaerosol product,” “noncarbon 

containing compound,” “nonresilient flooring,” “nonselective terrestrial herbicide,” 

“one-product business,” “oven cleaner,” “paint,” “paint remover or stripper,” “penetrant,” 

“pesticide,” “pre-ACP VOC content,” “pressurized gas duster,” “principal display panel 

or panels,” “product brand name,” “product category,” “product form,” “product line,” 

“propellant,” “pump spray,” “reconcile,” “reconciliation of shortfalls plan,” “responsible 

ACP party,” “responsible party,” “restricted materials,” “retail outlet,” “retailer,” “rollon- product,” „rubber and vinyl protectant,” „rubbing alcohol,” “sealant and caulking 

compound,” “semisolid,” “shaving cream,” „shortfall,” “silicone-based multipurpose 

lubricant,” “single phase aerosol air freshener,” “small business,” “solid,” “special 

purpose spray adhesive,” “spot remover,” “spray buff product,” “stick product,” 

“structural waterproof adhesive,” “surplus reduction,” “surplus trading,‟ „terrestrial,” „tire 

sealant and inflator,” “total maximum historical emissions,” “type A propellant,” “type B 

propellant,” “type C propellant,” “undercoating,‟ “usage directions,” “VOC content,” 

“volatile organic compound or VOC,” “wasp and hornet insecticide,” “waterproofer,” 

“wax,” “web spray adhesive,” “wood floor wax,” and “working day.”

The SIP revision adds section 9VAC5-45-310 in order to apply to any person who sells, 

supplies, offers for sale, or manufactures consumer products that contains VOCs in 

excess of the limits specified in Attachment A, on and after the applicable compliance 

dates in section 9VAC-45-360.

The SIP revision also adds section 9VAC45-310 in order to specify VOC content limits 

in percent VOCs by weight for consumer products with a compliance date specified in 

9VAC-45-360. The rule also contains requirements for the following: (1) products 

registered under FIFRA, (2) products requiring dilution, (3) sell-through of products, (4) 

aerosols adhesives, (5) charcoal lighter materials, (6) floor wax strippers, and (7) ozone 

depleting compounds.

The SIP revision adds section 9VAC45-320 in order to establish applicability for ACP 

for consumer products and criteria for innovative products exemption and requirements 

for waiver requests. ACP for consumer products are provided by allowing responsible 

parties the option to voluntarily enter into separate ACP agreements. 

The SIP revision also adds sections 9VAC45-5-330, 9VAC45-5-340, 9VAC45-5-350, 

9VAC45-5-360, 9VAC45-5-370, 9VAC45-5-380, and 9VAC45-5-390 in order to: (1) 

specify innovative products procedures, (2) specify administrative requirements, (3) 

specify compliance procedures, (4) establish compliance schedules, (5) specify test 

methods and procedures, (6) specify monitoring applicability, and (7) specify 

notification, records, and reporting requirements.

The following SIP revisions pertain to consumer products manufactured on or after 

August 1, 2010:

The SIP revision adds section 9VAC5-45-400 in order to establish applicability to any 
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consumer product manufactured that contains VOCs within the Northern Virginia and 

Fredericksburg Volatile Organic Compound Emissions Control Areas.

The SIP revision also adds section 9VAC5-45-410 in order to set exemptions for the 

following: (1) products for shipment and use outside the Northern Virginia and 

Fredericksburg Volatile Organic Compound Emissions Control Areas, (2) antiperspirants 

and deodorants, (3) products registered under the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA), (4) air fresheners, (5) adhesives, (6) bait station insecticides, 

and (7) fragrances.

The SIP revision adds the following definitions and terms in section 9VAC5-45-420: 

“ACP (Alternative Control Plan) emissions,” “ACP limit,” “ACP product,” “ACP VOC 

standard,” “ASTM (American Society for Testing and Materials),” “adhesive,” “adhesive 

remover,” “aerosol adhesive,” “aerosol cooking spray,” “aerosol product,” “agricultural 

use,” air freshener,” “all other carbon-containing compounds,” “all other forms,” 

“alternative control plan or ACP,” “antimicrobial hand or body cleaner or soap,” 

“antiperspirant,” “architectural coating,” “ASTM,” “astringent or toner,” “automotive 

brake cleaner,” “automotive hard paste wax,” “automotive instant detailer,” “automotive 

rubbing or polishing compound,” “automotive wax, polish, sealant or glaze,” “automotive 

windshield washer fluid,” “bathroom and tile cleaner,” “bug and tar remover,” “CARB,” 

“carburetor or fuel-injection air intake cleaners,” “carpet and upholstery cleaner,” 

“certified emissions,” “certified use rate,” '”charcoal lighter material,” “colorant,” 

“compliance period,” “construction, panel and floor covering adhesive,” “consumer,” 

“consumer product,” “contact adhesive,”, “contact person,” “container or packaging,” 

“crawling bug insecticide,” “date-code,” “deodorant,” “device,” “disinfectant,” 

“distributor,” “double phase aerosol air freshener,” “dry cleaning fluid,” “dusting aid,” 

“electronic cleaner,” “enforceable sales,” “enforceable sales record,” “engine degreaser,” 

“exempt compound,” “fabric protectant,” “facial cleaner or soap,” “fat wood,” “FIFRA,” 

“flea and tick insecticide,” flexible flooring material,” “floor polish or wax,” “floor seam 

sealer,” “floor wax stripper,” “flying bug insecticide,” “fragrance,” “furniture coating,” 

“furniture maintenance product,” “gel,” “general purpose adhesive,” “general purpose 

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

cleaner,” “gross sales,” “hair mousse,” “hair shine,” “hair spray,” “hair styling gel,” 

“heavy-duty hand cleaner or soap,” “herbicide,” “high volatility organic compound or 

HVOC,” “household product,” “insecticide,” “insecticide fogger,” “institutional product 

or industrial and institutional (I&I) product,” “label,” “laundry prewash,” “laundry starch 

product,” “lawn and garden insecticide,” “liquid,” “lubricant,” “LVP (lower vapor 

pressure) content or lower vapor pressure content,” “LVP-VOC or lower vapor pressureVOC,” “manufacturer,” “medicated astringent/medicated toner,” “medium volatility 

organic compound or MVOC,” “metal polish or cleanser,” “missing data days,” “mist 

spray adhesive,” “multipurpose dry lubricant,” “multipurpose lubricant,” “multipurpose 

solvent,” “nail polish,” “nail polish remover,” “nonaerosol product,” “noncarbon 

containing compound,” “nonresilient flooring,” “nonselective terrestrial herbicide,” 

“one-product business,” “oven cleaner,” “paint,” “paint remover or stripper,” “penetrant,” 

“pesticide,” “pre-ACP VOC content,” “pressurized gas duster,” “principal display panel 

or panels,” “product brand name,” “product category,” “product form,” “product line,” 
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“propellant,” “pump spray,” “reconcile,” “reconciliation of shortfalls plan,” “responsible 

ACP party,” “responsible party,” “restricted materials,” “retail outlet,” “retailer,” “rollon- product,” „rubber and vinyl protectant,” „rubbing alcohol,” “sealant and caulking 

compound,” “semisolid,” “shaving cream,” „shortfall,” “silicone-based multipurpose 

lubricant,” “single phase aerosol air freshener,” “small business,” “solid,” “special 

purpose spray adhesive,” “spot remover,” “spray buff product,” “stick product,” 

“structural waterproof adhesive,” “surplus reduction,” “surplus trading,‟ „terrestrial,” „tire 

sealant and inflator,” “total maximum historical emissions,” “type A propellant,” “type B 

propellant,” “type C propellant,” “undercoating,‟ “usage directions,” “VOC content,” 

“volatile organic compound or VOC,” “wasp and hornet insecticide,” “waterproofer,” 

“wax,” “web spray adhesive,” “wood floor wax,” and “working day.”

The SIP revision adds section 9VAC5-45-430 in order to apply to any person who sells, 

supplies, offers for sale, or manufactures consumer products that contains VOCs in 

excess of the limits specified in Attachment B.

The SIP revision also adds section 9VAC45-430 in order to specify VOC content limits 

in percent VOCs by weight for consumer products with a compliance date specified in 

9VAC-45-360. The rule also contains requirements for the following: (1) products 

registered under FIFRA, (2) products requiring dilution, (3) sell-through of products, (4) 

aerosols adhesives, (5) charcoal lighter materials, (6) floor wax strippers, and (7) ozone 

depleting compounds.

The SIP revision adds section 9VAC45-440 in order to establish applicability for ACP 

for consumer products and criteria for innovative products exemption and requirements 

for waiver requests. ACP for consumer products are provided by allowing responsible 

parties the option to voluntarily enter into separate ACP agreements. 

The SIP revision also adds sections 9VAC45-5-450, 9VAC45-5-460, 9VAC45-5-470, 

9VAC45-5-480, 9VAC45-5-490, 9VAC45-5-500, and 9VAC45-5-510 in order to: (1) 

specify innovative products procedures, (2) specify administrative requirements, (3) 

specify compliance procedures, (4) establish compliance schedules, (5) specify test 

methods and procedures, (6) specify monitoring applicability, and (7) specify 

notification, records, and reporting requirements.

Architectural and Industrial Maintenance Coatings

The Commonwealth of Virginia established an article in 9VAC5-45 in order to control 

VOC emissions from AIM, implement VOC content standards, and prohibit owners from 

manufacturing, distributing, selling, and using noncompliant products.

The SIP revision adds section 9VAC5-45-520 in order to apply to any owner or person 

who supplies, sells, offers for sale, or manufactures any architectural coating within the 

Northern Virginia and Fredericksburg Volatile Organic Compound Emissions Control 

Areas.

The SIP revision also adds section 9VAC5-45-530 in order to set exemptions for the 
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following: (1) any architectural coating sold or manufactured for use outside the 

Northern Virginia and Fredericksburg Volatile Organic Compound Emissions Control 

Areas, (2) aerosol coating product, and (3) any architectural coating that is sold in a 

container with a volume of one liter or less.

The SIP revision adds the following definitions and terms in section 9VAC5-45-540: 

“Adhesive,” “aerosol coating product,” “antenna coating,” “antifouling coating,” 

“appurtenance,” “architectural coating,” “ASTM,” “bitumens,” “Bituminous roof 

coating,” “bituminous roof primer,” “bond breaker,” “calcimine recoater,” “clear 

brushing lacquers,” “clear wood coatings,” “coating,” “colorant,” “concrete curing 

compound,” “concrete surface retarder,” “conversion varnish,” “dry fog coating,” 

“exempt compound,” “extreme durability coating,” “faux finishing coating,” “fireresistive coating,” “fire-retardant coating,” “flat coating,” “floor coating,” “flow coating,” 

“form-release compound,” “graphic arts coating or sign paint,” “high-temperature

coating,” “impacted immersion coating,” “ industrial maintenance coating,” “lacquer,” 

“low-solids coating,” “magnesite cement coating,” “mastic texture coating,” “metallic 

pigmented coating,” “multicolor coating,” “nonflat coating,” “nonflat high-gloss 

coating,” “nonindustrial use,” “nuclear coating,” “post-consumer coating,” “pretreatment 

wash primer,” “primer,” “quick-dry enamel,” “quick-dry primer sealer and undercoater,” 

“recycled coating,” “residence,” “roof coating,” “rust-preventive coating,” “sanding 

sealer,” “sealer,” “secondary coating (rework),” “shellac,” “shop application,” “solicit,” 

“specialty primer, sealer, and undercoater,” “stain,” “swimming pool coating,” 

“swimming pool repair and maintenance coating,” “temperature-indicator safety 

coating,” “thermoplastic rubber coating and mastic,” “tint base,” “traffic marking 

coating,” “undercoater,” “varnish,” “VOC content,” “waterproofing concrete/masonry 

sealer,” “waterproofing sealer,” and “wood preservative.”

The SIP revision adds section 9VAC5-45-550 in order to specify that no person or owner 

shall manufacture, blend, or repackage for sale, supply, sell, or offer for sale, or solicit for 

application or apply any architectural coating with VOC content in excess of the limits 

specified in Attachment C. Section 9VAC5-45-550 also established that the most 

restrictive VOC content limit shall apply to any coating that meets the definition of or is 

recommended for use for more than one of the coating categories specified in Attachment 

C. The rule also contains requirements for the following: (1) coating manufactured prior 

to the applicable compliance date specified in 9VAC5-45-580, (2) architectural coating 

containers, (3) application of any architectural coating, (4) rust preventive coating for 

industrial use, and (5) coating that does not meet any of the definitions for the specialty 

coatings categories specified in Attachment C.

The SIP revision also adds sections 9VAC45-5-560, 9VAC45-5-570, 9VAC45-5-580, 

9VAC45-5-590, 9VAC45-5-600, and 9VAC45-5-610 in order to: (1) specify 

administrative requirements, (2) specify compliance procedures, (3) establish compliance 

schedules, (4) specify test methods and procedures, (5) specify monitoring applicability, 

and (6) specify notification, records, and reporting requirements.

Adhesives and Sealants
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Adhesives, sealants, adhesive primer, and sealant primer are used in manufacturing, 

packaging, construction, and installation of disparate materials such as metal, wood, 

rubber, plastic, ceramics, fiberglass, and composites. An adhesive is any material used to 

bond two surfaces. A sealant is a material with adhesive properties that is used primarily 

to fill and seal durably, openings between two surfaces. VOC emissions result from 

evaporation of solvents during surface preparation, transfer, application, drying, and 

cleaning operations. The solvents are mostly needed to solubilize the adhesive, sealant, 

or primer material for application. The solvents prepare the surface to provide a stronger 

bond. In plastic pipe bonding, the solvent dissolves the polyvinyl chloride pipe and 

reacts with the pipe to form a bond. Solvents used to clean the surface before bonding 

and to clean the application equipment after bonding also contribute to VOC emissions. 

VOC emissions from adhesives and sealants are primarily from industrial and 

commercial operations such as general manufacturing, wood product manufacturing, 

upholstery shops, adhesives retailers and architectural trades, such as building 

construction, floor covering installation and roof repair.

The OTC States developed a Model Rule “OTC Model Rule For Adhesives and Sealants” 

dated 2006 which was based on the CARB RACT determination. This RACT 

determination applied to both the manufacture and use of adhesives, sealants, adhesive 

primers or sealant primers, in both industrial and manufacturing facilities and in the field. 

California Air Districts used this determination to develop regulations for this category. 

EPA addressed this source category with a Control Techniques Guideline (CTG)

document for Miscellaneous Industrial Adhesives dated September 2008. This CTG was 

developed in response to section 183(e) of the Clean Air Act (CAA) requirement for EPA 

to study and regulate consumer and commercial products, which is included in EPA‟s 

Report to Congress, “Study of Volatile Organic Compound Emissions from Consumer 

and Commercial Products – Comprehensive Emissions Inventory.” The section 183(e) 

miscellaneous industrial adhesives category was limited to adhesives and adhesive 

primers used in industrial and manufacturing operations and did not include products 

applied in the field. Therefore, the OTC Model Rule and State efforts in developing 

individual regulations preceded EPA‟s CTG for this source category and were broader in 

applicability. The OTC Model Rule for adhesives and sealants and Virginia‟s Regulation 

9VAC5-45 Article 6 – Emissions Standards For Adhesives and Sealants provisions 

compared to the CTG document for Miscellaneous Industrial Adhesives dated September 

2008 are discussed in Attachment D.

The Commonwealth of Virginia established an article in 9VAC5-45 in order to control 

VOC emissions from adhesives, adhesive primers, sealants, and sealant primers, 

implement VOC content limits, and prohibit owners from manufacturing, distributing, 

selling, or applying noncompliant products. 

The SIP revision adds section 9VAC5-45-620 in order to apply to any owner or person 

who supplies, sells, offers for sale, manufactures, uses, applies for compensation, solicits 

the use of, requires the use of, or specifies the application of, any adhesive, sealant, 

adhesive primer, or sealant primer that contains VOCs within the Northern Virginia and 
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Fredericksburg Volatile Organic Compound Emissions Control Areas.

The SIP revision also adds section 9VAC5-45-630 in order to set exemptions for specific 

products and compounds of adhesives, sealants, adhesive primers, or sealant primers.

The SIP revision adds the following definitions and terms in section 9VAC5-45-640: 

„„ABS welding adhesive or acrylonitrile-butadiene-styrene welding adhesive,‟‟ 

“adhesive,” “adhesive primer,” „„aerosol adhesive,‟‟ “aerosol component,” „„architectural 

sealant or primer,‟‟ “ASTM,” “CARB,” „„automotive glass adhesive primer,‟‟ „„CPVC 

plastic or chlorinated polyvinyl chloride plastic,‟‟ „„CPVC welding adhesive or 

chlorinated polyvinyl chloride welding adhesive,‟‟ „„ceramic tile installation adhesive,‟‟ 

„„cleanup solvent,‟‟ „„computer diskette jacket manufacturing adhesive,‟‟ „„contact bond 

adhesive,‟‟ „„cove base,‟‟ „„cove base installation adhesive,‟‟ “cyanoacrylate adhesive,” 

„„drywall installation,‟‟ „„fiberglass,‟‟ „„flexible vinyl,‟‟ „„indoor floor covering 

installation adhesive,‟‟ „„laminate,‟‟ „„low-solids adhesive, sealant or primer,‟‟ „„marine 

deck sealant or marine deck sealant primer,‟‟ „„medical equipment manufacturing,‟‟ 

„„metal to urethane/rubber molding or casting adhesive,‟‟ „„multipurpose construction 

adhesive,‟‟ „„nonmembrane roof installation/repair adhesive,‟‟ „„outdoor floor covering 

installation adhesive,‟‟ “ozone season,” „„PVC plastic or polyvinyl chloride plastic,‟‟ 

„„PVC welding adhesive or polyvinyl chloride welding adhesive,‟‟ „„panel installation,‟‟ 

„„perimeter bonded sheet flooring installation,‟‟ „„plastic cement welding adhesive,‟‟ 

„„plastic cement welding adhesive primer,‟‟ „„plastic foam,‟‟ „„plasticizer,‟‟ „„plastics,‟‟ 

„„porous material,‟‟ „„propellant,‟‟ „„reactive diluent,‟‟ „„roadway sealant,‟‟ „„rubber,‟‟ 

„„SCAQMD-South Coast Air Quality Management District,‟‟ “sealant,” „„sealant 

primer,‟‟ „„sheet rubber installation,‟‟ „„single-ply roof membrane,‟‟ „„single-ply roof 

membrane adhesive primer,‟‟ „„single-ply roof membrane installation and repair 

adhesive,‟‟ „„single-ply roof membrane sealant,‟‟ “solvent,” „„structural glazing 

adhesive,‟‟ „„subfloor installation,‟‟ „„surface preparation solvent,‟‟ „„thin metal 

laminating adhesive,‟‟ „„tire repair,‟‟ „„tire tread adhesive,‟‟ „„traffic marking tape,‟‟ 

„„traffic marking tape adhesive primer,‟‟ „„undersea-based weapons systems 

components,‟‟ “volatile organic compound,” and „„waterproof resorcinol glue.‟‟

The SIP revision adds section 9VAC5-45-650 in order to specify that no person or owner 

shall sell, supply, or offer for sale, or manufactured for sale any adhesive, sealant, 

adhesive primer or sealant primer on or after the applicable compliance date specified in 

9VAC5-45-700 with VOC content in excess of the limits specified in Attachment D. 

Section 9VAC5-45-650 also specifies requirements for owners or operators of a facility 

that uses or applies a surface preparation solvent or cleanup solvent or removes an 

adhesive, sealant, adhesive primer, sealant primer from the parts of spray application 

equipment and contains requirements for proper storage and disposal, work practices, 

surface preparation and cleanup solvent composition. 

As an alternative to the VOC limits established in Attachment D, section 9VAC5-45-660

establishes that operators or owners of a facility that use or apply adhesives, sealants, 

adhesive primers, sealant primers, surface preparation solvents or cleanup solvents have 

the option of using add-on pollution control equipment rather than complying with the 
11

Attachment D limits. Requirements applying to air pollution control equipment include: 

an overall capture and control efficiency of at least 85 percent, by weight; the continuous 

monitoring of combustion temperature, inlet and exhaust gas temperatures and control 

device efficiency, depending upon the type of add-on controls used; and the maintenance 

of operation records to demonstrate compliance.

The SIP revision also adds sections 9VAC45-5-670, 9VAC45-5-680, 9VAC45-5-690, 

9VAC45-5-700, 9VAC45-5-710, 9VAC45-5-720, 9VAC45-5-730, 9VAC5-45-740, and 

9VAC5-45-750 in order to: (1) specify standards for visible emissions, (2) specify 

administrative requirements, (3) specify compliance procedures, (4) establish compliance 

schedules, (5) specify test methods and procedures, (6) specify monitoring applicability, 

(7) specify notification, records, and reporting requirements, (8) specify registration 

provisions, and (9) specify facility and control equipment maintenance or malfunction 

provisions.

Asphalt Paving Operations

The Commonwealth of Virginia established an article in 9VAC5-45 in order to control 

VOC emissions from asphalt paving operations, which prescribes the use of emulsified 

asphalt coatings except for the purpose of coating residential driveways and prohibit the 

mixing, storage, and application of noncompliant products. 

The SIP revision adds section 9VAC5-45-760 in order to apply to any owner or person 

who manufactures, mixes, stores, uses, or applies any liquefied asphalt for paving 

operations within the Northern Virginia and Fredericksburg Volatile Organic Compound 

Emissions Control Areas.

The SIP revision adds the following definitions and terms in section 9VAC5-45-770:

“Asphalt,” “cutback asphalt,” “emulsified asphalt,” “paving operation,” and “penetrating 

prime coat.”

The SIP revision also adds section 9VAC5-45-780 in order to specify that no owner or 

person shall cause or permit the manufacture, mixing, storage, use, or application of 

liquefied asphalt for paving operations unless it is emulsified. Section 9VAC5-45-780 

also specifies the exceptions to the rule.

The SIP revision also adds sections 9VAC45-5-790, 9VAC45-5-800, 9VAC45-5-820, 

9VAC45-5-830, 9VAC45-5-840, and 9VAC45-5-850 in order to: (1) specify standards 

for visible emissions, (2) specify standards for fugitive dust/emissions, (3) specify 

compliance procedures, (4) specify test methods and procedures, (5) specify monitoring 

provisions, and (7) specify notification, records, and reporting requirements.

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. EPA evaluates that 

new chapter 9VAC5-45 contains the required elements for a federally enforceable rule: 
12

emission limitations, compliance procedures and test methods, compliance dates and 

record keeping provisions. The Commonwealth of Virginia has adopted the standards 

and requirements of the consumer and commercial products rule as recommended by the 

OTC model rule. Virginia‟s consumer and commercial products rule contains special 

provisions that specify general testing, monitoring, compliance, notification, 

recordkeeping, and reporting requirements, and establishes standards. The amendments 

to 9VAC5-20-21 – Documents incorporated by reference meets the applicable 

requirements of the CAA, and the applicable EPA regulations, guidance, and policy and 

can be approved.

The addition of the following regulations, adopted by the Commonwealth of Virginia, 

meet the applicable requirements of the CAA, and the applicable EPA regulations, 

guidance, and policy and can be approved: (1) Part I – Special Provisions, (2) Article 1 –

Emission Standards For Portable Fuel Containers And Spouts Manufactured Before 

August 1, (3) Article 2 – Emission Standards For Portable Fuel Containers And Spouts 

Manufactured On Or After August 1, 2010, (4) Article 3 – Emission Standards For 

Consumer Products Manufactured Before August 1, 2010, (5) Article 4 – Emission 

Standards For Consumer Products Manufactured On Or After August 1, 2010, (6) Article 

5 – Emission Standards For Architectural And Industrial Maintenance Coatings, (7) 

Article 6 – Emission Standards For Adhesives And Sealants, and (8) Article 7 – Emission 

Standards For Asphalt Paving Operations. 

EPA approval of the SIP revision is recommended. The regulations will control 

emissions of VOCs, which will reduce the formation of ozone, and thereby protect public 

health and welfare.

Attachment A
13

9VAC5-45-310 – Standard for volatile organic compounds

(percent volatile organic compounds by weight)

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

1/1/2009 

Adhesives: 

Aerosol Mist Spray 

Aerosol Web Spray 

Special Purpose Spray Adhesives: 

Mounting, Automotive Engine 

Compartment and Flexible Vinyl 

Polystyrene Foam and Automotive 

Headliner 

Polyolefin and Laminate Repair/ 

Edgebanding 

Construction, Panel and Floor 

Contact 

General Purpose 

Structural Waterproof 

65 

55 

70 

65 

60 

15 

80

10

15

N/A 

Cooking Spray, Aerosol 18 

Air Fresheners: 

Single-phase Aerosols 

Double-phase Aerosols 

Liquids/Pump Sprays 

Solids/Semisolids 

30 

25 

18

3

Antiperspirants: 

Aerosol 

Non-aerosol 

40 HVOC 

10 MVOC 

0 HVOC 

0 MVOC

Automotive Brake Cleaners 45

Automotive Rubbing or Polishing Compound 17

Automotive Wax, Polish, Sealant or Glaze: 

Hard Paste Waxes 

Instant Detailers 

All Other Forms 

45

3

15

Automotive Windshield Washer Fluids 35

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

5/1/2009 

Bathroom and Tile Cleaners 

Aerosols 

All Other Forms 

7

5

Bug and Tar Remover 40
14

Carburetor or Fuel-Injection Air Intake 

Cleaners 

45

Carpet & Upholstery Cleaners 

Aerosols 

Non-aerosols (dilutable) 

(ready-to-use): 

7

0.1

3.0

Charcoal Lighter Material See 

subsection 

9VAC5-45-

310F

Deodorants: 

Aerosol 

Non-aerosol 

0 HVOC

10 MVOC

0 HVOC

0 MVOC

Dusting Aids: 

Aerosol 

All other forms 

25

7 

Engine Degreasers: 

Aerosol 

Non-aerosol 

35

5

Fabric Protectants 60

Floor Polishes/waxes: 

Products for Flexible Flooring Materials 

Products for Non-Resilient Flooring 

Wood Floor Wax 

7 

10 

90 

Floor Wax Strippers, non-aerosol See 

subsection 

9VAC5-45-

310H

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

5/1/2009 

Furniture Maintenance Products: 

Aerosol 

All other forms except solid or paste 

17

7

General Purpose Cleaners: 

Aerosol 

Non-aerosol 

10

4
15

General Purpose Degreaser 

Aerosol 

Non-aerosol 

50

4

Glass Cleaners: 

Aerosol 

Non-aerosol 

12 

4

Hair Mousse 6

Hair Shine 55

Hair Spray 55

Hair Styling Gel 6 

Heavy Duty Hand Cleaner or Soap 8

Insecticide: 

Crawling Bug (aerosol) 

Crawling Bug (all other forms) 

Flea and Tick 

Flying Bug (aerosol) 

Flying Bug (all other forms) 

Foggers 

Lawn & Garden (all other forms) 

Lawn & Garden (non-aerosol) 

Wasp & Hornet 

15

20

25

25

35

45

20

3

40

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

5/1/2009 

Laundry Prewash: 

Aerosol/Solid 

All other forms 

22

5

Laundry Starch Product 5

Metal Polish/Cleanser 30

Multi-purpose Lubricant (excluding solid or 

semi-solid product) 50

Nail Polish Remover 75

Non-selective Terrestrial Herbicide 

Non-aerosol 

3

Oven Cleaner 

Aerosol/Pump spray 

Liquid 

8

5

Paint Remover or Stripper 50

Penetrants 50

Rubber & Vinyl Protectant 

Non-aerosol 

Aerosol 

3

10

Sealant & Caulking Compound 4
16

Shaving Cream 5

Silicone-based Multi-purpose Lubricants 

(excluding solid or semi-solid product) 

60

Spot Remover 

Aerosol 

Non-aerosol 

25

8

Tire Sealant and Inflators 20

Undercoating, Aerosol 40

Notes: N/A Not applicable on or after January 1, 2009 

Attachment B

9VAC5-45-430 – Standard for volatile organic compounds 

(percent volatile organic compounds by weight)
17

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

1/1/2009 

Adhesives: 

Aerosol Mist Spray 

Aerosol Web Spray 

Special Purpose Spray Adhesives: 

Mounting, Automotive Engine 

Compartment and Flexible Vinyl 

Polystyrene Foam and Automotive 

Headliner 

Polyolefin and Laminate Repair/ 

Edgebanding 

Construction, Panel and Floor 

Contact 

Contact, General Purpose 

Contact, Special Purpose

General Purpose 

Structural Waterproof 

65 

55 

70 

65 

60 

15 

80

10

15

N/A 

55 

80 

Adhesive Removers: 

Floor or Wall Covering 

Gasket or Thread Locking 

General Purpose 

Specialty 

5

50

20

70

Cooking Spray, Aerosol 18 

Air Fresheners: 

Single-phase Aerosols 

Double-phase Aerosols 

Liquids/Pump Sprays 

Solids/Semisolids 

30 

25 

18

3

Antiperspirants: 

Aerosol 

Non-aerosol 

40 HVOC 

10 MVOC 

0 HVOC 

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 

Instant Detailers 

All Other Forms 

45

3

15

Automotive Windshield Washer Fluids 35

Product Category VOC Content Limit 

Effective 

Date 

Effective Date 

5/1/2009 
18

1/1/2005 

Bathroom and Tile Cleaners 

Aerosols 

All Other Forms 

7

5

Bug and Tar Remover 40

Carburetor or Fuel-Injection Air Intake 

Cleaners 

45

Carpet & Upholstery Cleaners 

Aerosols 

Non-aerosols (dilutable) 

(ready-to-use): 

7

0.1

3.0

Charcoal Lighter Material See 

subsection 

9VAC5-45-

430E

Cooking spray, aerosol 18

Deodorants: 

Aerosol 

Non-aerosol 

0 HVOC

10 MVOC

0 HVOC

0 MVOC

Dusting Aids: 

Aerosol 

All other forms 

25

7 

Electrical Cleaner 45

Electronic Cleaner 75

Engine Degreasers: 

Aerosol 

Non-aerosol 

35

5

Fabric Protectants 60

Fabric Refresher: 

Aerosol 

Non-aerosol 

15

6

Floor Polishes/waxes: 

Products for Flexible Flooring Materials 

Products for Non-Resilient Flooring 

Wood Floor Wax 

7 

10 

90 

Floor Wax Strippers, non-aerosol See 

subsection 

9VAC5-45-

430G
19

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

5/1/2009 

Footwear or Leather Care Products: 

Aerosol 

Solid 

All other forms 

75

55

15

Furniture Maintenance Products: 

Aerosol 

All other forms except solid or paste 

17

7

General Purpose Cleaners: 

Aerosol 

Non-aerosol 

10

4

General Purpose Degreaser 

Aerosol 

Non-aerosol 

50

4

Glass Cleaners: 

Aerosol 

Non-aerosol 

12 

4

Graffiti Removers: 

Aerosol 

Non-aerosol 

50

30

Hair Mousse 6

Hair Shine 55

Hair Spray 55

Hair Styling Gel 6 

Hair Styling Products: 

Aerosol and Pump sprays 

All other forms 

6

2

Heavy Duty Hand Cleaner or Soap 8

Insecticide: 

Crawling Bug (aerosol) 

Crawling Bug (all other forms) 

Flea and Tick 

Flying Bug (aerosol) 

Flying Bug (all other forms) 

Foggers 

Lawn & Garden (all other forms) 

Lawn & Garden (non-aerosol) 

Wasp & Hornet 

15

20

25

25

35

45

20

3

40
20

Product Category VOC Content Limit 

Effective 

Date 

1/1/2005 

Effective Date 

5/1/2009 

Laundry Prewash: 

Aerosol/Solid 

All other forms 

22

5

Laundry Starch Product 5

Metal Polish/Cleanser 30

Multi-purpose Lubricant (excluding solid or 

semi-solid product) 50

Nail Polish Remover 75

Non-selective Terrestrial Herbicide 

Non-aerosol 

3

Oven Cleaner 

Aerosol/Pump spray

Liquid 

8

5

Paint Remover or Stripper 50

Penetrants 50

Rubber & Vinyl Protectant 

Non-aerosol 

Aerosol 

3

10

Sealant & Caulking Compound 4

Shaving Cream 5

Shaving Gel 7

Silicone-based Multi-purpose Lubricants 

(excluding solid or semi-solid product) 

60

Spot Remover 

Aerosol 

Non-aerosol 

25

8

Tire Sealant and Inflators 20

Toilet/Urinal Care: 

Aerosol 

Non-aerosol 

10

3

Undercoating, Aerosol 40

Wood Cleaner: 

Aerosol 

Non-aerosol 

17

4

Notes: N/A Not applicable on or after January 1, 2009 

Attachment C

9VAC5-45-550 – Standard for volatile organic compounds

Limits are expressed in grams of VOC per liter1of coating thinned to the manufacturer's 

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

colorant added to tint bases. "Manufacturers maximum recommendation" means the 
21

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

container. 

Coating Category VOC Content Limit

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

Conversion Varnishes 725

Varnishes 350

Concrete Curing Compounds 350

Dry Fog Coatings 400

Extreme durability coating 400

Faux Finishing Coatings 350

Fire Resistive Coatings 350

Fire-Retardant Coatings

Clear 650

Opaque 350

Floor Coatings 250

Flow Coatings 420

Form-Release Compounds 250

Graphic Arts Coatings (Sign Paints) 500

High-Temperature Coatings 420

Impacted Immersion Coating 780

Industrial Maintenance Coatings 340
22

Low-Solids Coatings 120

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

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

Swimming Pool Coatings 340

Swimming Pool Repair and Maintenance Coatings 340

Temperature-Indicator Safety Coatings 550

Thermoplastic Rubber Coating and Mastic 550

Traffic Marking Coatings 150

Waterproofing Sealers 250

Waterproofing Concrete/Masonry Sealers 400

Wood Preservatives 350

Conversion factor: one pound VOC per gallon (U.S.) = 119.95 grams per liter.

Attachment D

OTC Model Rule for Adhesives and Sealants and Virginia’s Article 6 –

Emission Standards for Adhesives and Sealants Provisions Compared to the 

Control Technique Guidelines for Miscellaneous Industrial Adhesives, 

September 2008
23

OTC Model Rule

The Ozone Transport Commission (OTC) developed a model rule as part of a regional 

effort to attain and maintain the eight-hour ozone standard and reduce eight-hour ozone 

levels. States opting to promulgate rules based on this model rule will utilize Statespecific administrative requirements and procedures. Virginia‟s adopted Article 6 of 

9VAC5-45 is based on the OTC model rule.

A reasonably available control technology (RACT) determination prepared by the 

California Air Resources Board (CARB) in 1998 forms the basis of the OTC model rule. 

In the years 1998-2001, the provisions of the CARB determination were adopted in 

regulatory form in various air pollution control districts in California including the Bay 

Area, Ventura County, Sacramento Metropolitan and San Joaquin Valley.

The provisions of this model rule limit emissions of VOCs from adhesives, sealants, 

adhesive primers and sealant primers. The model rule achieves VOC reductions through 

two basic components: (1) sale and manufacture restrictions that limit the VOC content 

of specified adhesives, sealants, adhesive primers and sealant primers sold in the state; 

and (2) use restrictions that apply primarily to commercial and industrial applications. 

By reducing the availability of higher VOC content adhesives and sealants within the 

State, the sales prohibition is also intended to address adhesive and sealant usage at area 

sources. Emissions from residential use of regulated products are addressed through the 

sales restrictions and simple use provisions. 

The associated emissions reductions will be used as part of the State‟s plan to attain and 

maintain the 8-hour ozone national ambient air quality standard (NAAQS).

Control Techniques Guideline

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.)

“This CTG is intended to provide State and local air pollution control authorities 

information that should assist them in determining RACT for VOCs from 

miscellaneous industrial adhesive application processes. In developing this CTG, 

EPA, among other things, evaluated the sources of VOC emissions from 

miscellaneous industrial adhesives application processes and the available control 

approaches for addressing these emissions, including the costs of such 

approaches. Based on available information and data, EPA provides 

recommendations for RACT for miscellaneous industrial adhesives. States can 

use the recommendations in this CTG to inform their own determination as to 

what constitutes RACT for VOCs for miscellaneous industrial adhesive 

application processes in their particular nonattainment areas. The information 

contained in this document is provided only as guidance. This guidance does not 
24

change, or substitute for, requirements specified in applicable sections of the 

CAA or EPA‟s regulations; nor is it a regulation itself. This document does not 

impose any legally binding requirements on any entity. It provides only 

recommendations for State and local air pollution control agencies to consider in 

determining RACT. State and local pollution control agencies are free to 

implement other technically-sound approaches that are consistent with the CAA 

and EPA‟s implementing regulations” (CTG page 1). 

“When State and local pollution control agencies develop RACT rules, they may 

elect to adopt control approaches that differ from those described in this document 

and/or promulgate applicability criteria that differ from those recommended here 

[in this CTG].” (CTG page 3).

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 from consumer and 

commercial products in ozone nonattainment areas, and to schedule those categories for 

regulation in four groups. Section 183(e)(3)(C) further provides that we may issue a 

CTG in lieu of a national regulation for a product category where we determine that the 

CTG will be “substantially as effective as regulations” in reducing emissions of VOC in 

ozone nonattainment areas. See for example, 64 FR 13422, March 18, 1999. EPA has 

revised the list several times. See 70 FR 69759, November 17, 2005; 64 FR 13422, 

March 18, 1999; and most recently, 71 FR 28320, May 16, 2006.

Under section 183(e), a regulation for consumer or commercial products is limited to 

measures applicable to manufacturers, processors, distributors, or importers of the 

solvents, materials, or products supplied to the consumer or industry. Section 183(e) 

does not authorize EPA to issue national regulations that would directly regulate endusers of these products. By contrast, CTG are guidance documents that recommend 

RACT measures that States can adopt and apply to the end-users of products. See 73 FR 

58481 at 58483, October 7, 2008. However, section 183(e) does not impose the same 

restrictions upon States, upon regulation of end-users and manufacturers, processors, 

distributors, or importers. Therefore, a State can regulate manufacturers, processors, 

distributors, or importers and end-users of a product category for which EPA has issued a 

CTG. 

I. Applicability

(1) 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. 
25

The OTC model rule is broader than the CTG and applies to processes below the 6.8 

kg/day recommendation. It also applies outside of stationary source facilities when the 

adhesives are applied in the field.

(2) The OTC model rule is also applicable to any person who: sells, supplies for sale, 

offers for sale or manufactures for sale any adhesive, sealant, adhesive primer or sealant 

primer. The CTG is not applicable to these people. 

II. Definitions

Generally the OTC model rule and CTG use the same terms and definitions for those 

terms. The OTC model rule contains additional definitions to address sealants and 

sealant primers and additional types of products. There are minor differences with some 

terms because the CTG focuses on the processes at a facility while the OTC model rule 

also incorporates prohibitions on selling, offering for sale and using products that can 

occur outside of a facility. There are some instances where the CTG and the OTC model 

rule use different terms for the same process/product, but these are substantively the 

same.

Specific examples:

There appears to be an inconsistency in the CTG with the category of tire repair and tire 

retread. Tire repair generally would not occur at a manufacturing facility, but at smaller 

operations in the field. The draft CTG used a term “tire retreading” which would be a 

process that occurs at a manufacturing facility. The OTC model rule and section 121.1 

regulate “tire retread” and defines the category in terms of manufacture and not the repair 

of a puncture. Section 121.1‟s definition is consistent with South Coast Air Quality 

Management District (SCAQMD) rule 1168‟s definition of “tire tread adhesive.” The 

CTG was developed based upon SCAQMD rule 1168 and similar rules. Therefore, with 

regards to “tire retread” and “tire repair” processes, the OTC model rule and 9VAC5-45-

640 are consistent with those rules upon which the CTG founded its recommendations.

The CTG does not distinguish between cleaning materials used for surface preparation 

and those used for cleaning application equipment, but the OTC model rule does make 

this distinction. 

The recommendations for roof membranes in the CTG do not extend to field applied 

materials, because: (1) field-applied adhesives are not part of the miscellaneous 

industrial adhesives category and are therefore not covered by this CTG, and (2) 

nonmembrane roof installation and repair adhesive, and ethylene propylene diene 

monomer (EPDM) described in the comments received on the draft CTG are field applied 

products and are therefore not included in the miscellaneous industrial adhesives 

category. To the extent the recommendations in the OTC model rule sets limits for 

EPDM single-ply roof membranes it makes a recommendation beyond those in the CTG. 

It appears that the inclusion of “motor vehicle glass bonding primer” in the CTG covers a 
26

slightly broader class of adhesives primers than “automotive glass adhesive primer.”

The OTC model rule includes wood in the definition of “porous material” while the CTG 

does not and has a separate limit for wood. The CTG‟s recommended definition was 

made in the absence of limits for sealants and sealant primers and specifically excludes 

wood from being considered a porous material. 

III. Requirements

(1) The OTC model rule applies to any person who sells, supplies or offers for sale any 

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

2009, or manufacture for sale any adhesive, sealant, adhesive primer or sealant primer in 

excess of the applicable VOC content limits specified in Table 1. The CTG does not 

apply to people who sell or manufacture these coatings.

(2) The OTC model rule applies to any person who uses or applies (for compensation)

any adhesive, sealant, adhesive primer or sealant primer that has an applicable VOC 

content limit specified in Table 1 that is not otherwise exempted. The CTG only 

recommends application of the limits and requirements 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 OTC model rule covers “field applied adhesives” which 

the CTG does not cover.

(3) Both the CTG and the OTC model rule have a table of content limits for the regulated 

products. See the comparison of table limits and discussion below.

(4) The CTG did not propose recommendations for VOC content or VOC composite 

vapor pressure limits for cleaning materials. The OTC model rule and Article 6 of 

9VAC5-45 contained the following limits for cleaning materials:

a. Limits the VOC content of the surface preparation solvent to less than 70 

grams per liter;

b. Limits the VOC content of surface preparation solvent used in applying 

single-ply roofing to a composite vapor pressure, excluding water and exempt 

compounds, not exceeding 45 mm Hg at 20 degrees Celsius;

c. Limits materials containing VOCs used to remove adhesives, sealants, or 

adhesive or sealant primers from surfaces unless the composite vapor pressure of 

the solvent used is less than 45 mm Hg at 20 degrees Celsius;

d. Requires spray application equipment be cleaned in enclosed cleaning systems 

using cleaning solvents with less than or equal to 70 grams of VOC per liter of 
27

material, or by soaking parts in closed systems using and a solvent if the 

composite vapor pressure of the solvent, excluding water and exempt compounds, 

is less than or equal to 9.5 mm Hg at 20 degrees Celsius.

(5) Both the CTG and OTC model rule provide for the use of add-on air pollution control 

equipment instead of meeting the solvent content limits. Both require that controls 

reduce VOC emissions by an overall capture and control efficiency of at least 85% by 

weight. The OTC model rule includes additional provisions to insure that the control 

equipment is operated properly.

(6) Both the CTG and OTC model rule require work practices to minimize emissions 

from cleaning operations. The CTG recommendations are more detailed while the OTC 

model rule is more general.

(7) The OTC model rule prohibitions the specification of non-complying adhesives, 

sealants, adhesive primers, sealant primers, surface preparation or clean-up solvents. 

(8) The CTG also recommends that adhesive and adhesive primers be applied using

application methods with good transfer efficiency in conjunction with the use of lowVOC 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. The OTC model rule does not address application methods.

IV. Exemptions and Exceptions

(1) CTG and OTC model rule have similar exemptions for the following:

a. Adhesives, sealants, adhesive primers or sealant primers being tested or 

evaluated in any research and development, quality assurance or analytical 

laboratory. 

b. Cyanoacrylate adhesives.

c. Adhesives, sealants, adhesive primers or sealant primers that are sold or 

supplied by the manufacturer or supplier in containers with a net volume of 16 

fluid ounces or less, or a net weight of one pound or less, except plastic cement 

welding adhesives and contact adhesives.

d. Processes using polyester bonding putties to assemble fiberglass parts at 

fiberglass boat manufacturing facilities and at other reinforced plastic composite 
28

manufacturing facilities.

e. In the assembly, repair and manufacture of aerospace or undersea-based 

 weapon systems.

f. Solvent welding operations used in the manufacture of medical devices.

(2) OTC model rule exemptions not in CTG:

a. Adhesives, sealants, adhesive primers and sealant primers that are subject to 

State consumer product regulation. State consumer product regulations generally 

regulate the same categories as the Federal Regulation (of 40 CFR Part 59). 

Under section 183(e) the consumer products regulated by 40 CFR Part 59 cannot 

be the same adhesive products and adhesive primers as those covered by the CTG, 

and, therefore this provision of the OTC model rule merely clarifies that here is 

no double regulation1.

b. Adhesives and sealants that contain less than 20 grams of VOC per liter of 

adhesive or sealant, less water and less exempt compounds, as applied. This limit

is less than any limit recommended by the CTG.

c. Contact adhesives that are sold or supplied by the manufacturer or supplier in 

containers with a net volume of one gallon or less. Some California Air Districts 

have a similar size exemption but with additional conditions.

d. Tire repair operations, provided the label of the adhesive states "For tire 

repair only." 

e. Plaque laminating operations in which adhesives are used to bond clear, 

polyester acetate laminate to wood with lamination equipment installed prior to 

July 1, 1992. Any person claiming exemption pursuant to this subparagraph shall 

record and maintain monthly operational records sufficient to demonstrate 

compliance with this exemption and in accordance with section (V) of this rule.

In addition, the CTG recommends that these sources be subject to the work practices 

recommendation. 

(3) The OTC model rule exempts total VOC emissions from all adhesives, sealants, 

adhesive primers and sealant primers used at a facility that are less than 200 pounds per 

calendar year, or an equivalent volume. Any person claiming exemption pursuant to this 

subparagraph shall record and maintain monthly operational records sufficient to 

demonstrate compliance. 

 

1 The latest listing of product categories regulated under section 183(e) of the CAA was published on May 

16, 2006 (71 FR 28320).
29

(4) The OTC model rule exempts adhesives, sealants, adhesive primers, sealant primers, 

cleanup solvents and surface preparation solvents provided the total volume of 

noncomplying adhesives, sealants, primers, cleanup and surface preparation solvents 

applied facility-wide does not exceed 55 gallons per calendar year. Any person claiming 

exemption pursuant to this subparagraph shall record and maintain monthly operational 

records sufficient to demonstrate compliance. This is equivalent to 400 pound per year, 

while the CTG applicability starts at 6.8 kg/day (15 lb/day) or an equivalent level such as 

3 tons (6000 pound) per 12-month rolling period.

(5) The OTC model rule exempts adhesive, sealant, adhesive primer or sealant primer 

intended for shipment and use outside of OTC States or in Article 6 of 9VAC5-45.

(6) The OTC model rule exempts any adhesive, sealant, adhesive primer or sealant 

primer that is controlled by add-on air pollution control equipment. 

V. Administrative Requirements

The OTC model rule contains detailed record keeping requirements for demonstrating 

compliance with the VOC content limits and recording the key operating parameters for 

the control equipment that must be maintained for five years. Any State rule for a CTG 

must contain monitoring and recordkeeping requirements. 

VI. Compliance Procedures and Test Methods

Both the CTG and OTC model rule contain the same primary test methods and 

compliance procedures. The OTC model rule contains additional references to other 

relevant standard test methods for both solvent analysis and for determining compliance 

of add-on control equipment. Any State rule for a CTG must contain test methods for 

determining compliance. 

VII. Container Labeling

The OTC model rule requires labeling of product container with the maximum or actual 

VOC content of the product along with information concerning thinning of the product.

VIII. Emission Limit Table

The table below provides an analysis of the CTG recommended VOC emission limits for 

general and specialty adhesive application processes compared to the OTC model rule 

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

adhesives applied to particular substrates. Where there is no comparable limit the column 

is left blank. In the CTG recommendation column, categories with brackets { } around 

them indicates there is a difference in a definition or provision which differs from the 

OTC model rule. Below the table are series of “Notes” which discuss some of the 
30

differences between the OTC model rule and the CTG and refer back to some of the 

California adopted rules (CARB model rule) for which the OTC model rule was based 

on. 

Both the CTG and the OTC model rule were based on the California rulemaking efforts 

for this category and the CTG also bases its recommended emission limits on the OTC 

model rule (see CTG page 16, last paragraph). The CTG also states “we consider the 

limits in the OTC model rule to be representative of what sources in nonattainment areas 

nationwide can achieve technically and economically and have therefore adopted these 

VOC limits as our recommendations in the CTG.” 

Table 1. VOC Content Limits for Adhesives, Sealants, Adhesive Primers, Sealant 

Primers and Adhesives Applied to Particular Substrates

OTC Model Rule CTG Recommendation

Category VOC content limit

(grams VOC per 

liter*)

Category Recommend

ed VOC 

Emission 

Limit1

(g/l)

Adhesives Specialty Adhesive 

Application Processes

ABS welding 400 {Plastic Solvent Welding 

(ABS)}

400

Ceramic tile installation 130 Ceramic Tile Installation 130

Computer diskette 

jacket manufacturing

850

Contact bond [Note C] 250 {Contact Adhesive} [Note C] 250

Cove base installation 150 Cove Base Installation 150

CPVC welding 490 {Plastic Solvent Welding 

(Except ABS)}

{500}

Indoor floor covering 

installation

150 Floor Covering Installation 

(Indoor)

150

Metal to 

urethane/rubber 

molding or casting

850 Metal to Urethane/Rubber 

Molding or Casting

850

Motor Vehicle Adhesive

[Note H]

250

Motor Vehicle Weatherstrip 

Adhesive [Note H]

750

Multipurpose 

construction

200 Multipurpose Construction 200

Nonmembrane roof 

installation/repair

300
31

OTC Model Rule CTG Recommendation

Other plastic cement 

welding

510 {Plastic Solvent Welding 

(Except ABS)}

{500}

Outdoor floor covering 

installation

250 Floor Covering Installation 

(Outdoor)

250

PVC welding 510 {Plastic Solvent Welding 

(Except ABS)}

{500}

Single-ply roof 

membrane 

installation/repair [Note 

G]

250 Single-Ply Roof Membrane 

Installation/Repair (Except 

EPDM)

250

Structural glazing 100 Structural Glazing 100

Thin metal laminating 780 Thin Metal Laminating 780

Tire Repair [Note A] 100

Tire retread [Note A] 100

Perimeter bonded sheet 

vinyl flooring installation

660 {Floor Covering Installation 

(Perimeter Bonded Sheet 

Vinyl)} [Note C]

660

Waterproof resorcinol 

glue

170 Waterproof Resorcinol Glue 170

Sheet-applied rubber 

installation

850 {Sheet Rubber Lining 

Installation} [Note C]

850

Sealants

Architectural 250

Marine deck 760

Nonmembrane roof 

installation/repair

300

Roadway 250

Single-ply roof 

membrane

450

Other 420

Adhesive Primers Adhesive Primer 

Application Processes

Automotive glass [Note 

G]

700

Motor Vehicle Glass 

Bonding Primer [Notes B 

and G]

900

Plastic cement welding 650 {Plastic Solvent Welding 

Adhesive Primer} [Note C]

650
32

OTC Model Rule CTG Recommendation

Single-ply roof 

membrane

250 Single-Ply Roof Membrane 

Adhesive Primer [Note B]

250

Traffic marking tape 150

Other [Note G] 250 Other Adhesive Primer 

[Note B]

250

Sealant Primers

Non-porous 

architectural

250

Porous architectural 775

Marine deck 760

Other 750

Adhesives Applied to 

the Listed Substrate

 [Notes E and H] General Adhesive 

Application Processes 2

[Note E]

Flexible vinyl [Note H] 250 Flexible vinyl 250

Fiberglass [Notes F & H] 200 

Reinforced plastic 

composite [Note F]

[Note F] 200

Metal [Note H] 30 Metal 30

Porous material 

(Including wood)

 [Note H] 120 Porous Material (Excluding 

Wood)

120

Rubber [Note H] 250 Rubber 250

Other substrates [Note H] 250 Other Substrates 250

Wood 30

* The VOC content is determined as the weight of volatile compounds, less water and exempt 

compounds as specified in Section VI of this rule.

1 Emission limits are mass of VOC per volume of adhesive or adhesive primer, excluding water and exempt 

compounds.

2 If an adhesive is used to bond dissimilar substrates together, then the applicable substrate category with 

the highest VOC emission limit is recommended as the limit for such application. The analogous provision 

in the OTC Model Rule is found in Section III. (3) of that rule.

Notes: 

A. The CTG is inconsistent with the State rules cited in Appendix B in that none 

of these rules set a limit for “tire repair” adhesives (as that term is defined in each of 

these rules) but rather set a limit for “tire retread(ing) adhesives” which is the same as the 

100 g VOC/liter limit in the OTC model rule (which is as expected since this rule is 

based upon one or more of the California rules). 

B. The CTG has the words “Adhesive Primer” in its table whereas in the OTC 

model rule this is to be understood from the sub-heading. 
33

C. The CTG and OTC Model Rule use slightly different terms to cover the same 

processes or products. 

- The CTG uses the term “Floor Covering Installation (Perimeter Bonded Sheet 

Vinyl)” to cover what the OTC Model Rule covers as “Perimeter Bonded Sheet 

Vinyl.” 

- The term “Sheet-applied rubber installation” in the OTC Model Rule means the 

same thing as “Sheet Rubber Lining Installation” in the CTG.

- “Contact bond” adhesive and ““Contact adhesive” would appear to be the same 

thing. Both the OTC Model Rule and the CTG definitions for “Contact bond 

adhesive” are the same and both use “Contact adhesive” within this definition to 

refine its scope.

- The OTC Model Rule uses “Plastic Cement Welding Adhesive Primer” where the 

CTG uses “Plastic Solvent Welding Adhesive Primer” for the same 

product/process.

D. The inclusion of the category “plastic adhesive primer” in the Draft CTG was 

an error. This category has been removed from the final CTG.

E. The OTC model rule uses the term “Adhesives Applied to the Listed 

Substrate” where the CTG uses the term “General Adhesive Application Processes.” 

F. The CTG covers more materials with the broader definition of “Reinforced 

plastic composite” than the OTC model rule if the latter considers “fiberglass” to means 

fine glass fibers in a plastic resin. But the OTC rule defines “fiberglass” as a material 

consisting of extremely fine glass fibers; thus, a “fiberglass substrate adhesive” could be 

interpreted as meaning an adhesives used to bond glass fibers together or to another listed 

substrate. The OTC definition is consistent with several California AQMD rules such as 

SCAQMD Rule 1168, Sacramento Metropolitan AQMD Rule 460; other California 

AQMDs do not define “fiberglass” – e.g., San Diego County AQMD rule 67.21; 

however, Ventura County AQMD Rule 74-20 defines fiberglass as “...any fiber 

reinforced plastic (FRP) surface that has fiber material set in a binding substance of 

plastic resins” which appears to be the functional equivalent of the final CTG‟s definition 

of “Reinforced plastic composite.”

G. To the extent the OTC Model Rule limit for “Automotive glass adhesive 

primers” and the recommendation in the final CTG for “Motor Vehicle Glass Bonding 

Primer” both cover the same material or process the recommendation in the OTC model 

rule is more stringent. To the extent that the definition of recommendation in the final 

CTG for “Motor Vehicle Glass Bonding Primer” covers more processes or operations the 

recommendation in the final CTG would be more stringent except the OTC model rule 

may cover any additional products under the other primer category. The 

recommendation in the OTC model rule for applying an “Automotive glass adhesive 
34

primer” to automotive glass is clearly more stringent. However, recommendation in the 

CTG for “Motor Vehicle Glass Bonding Primer” would cover primers applied to “body 

openings” prior to the application of glass bonding adhesives or the installation of 

adhesive bonded glass. Body openings may include substrates such as bare metal or 

plastic as well as the glass itself. To the extent the limit for “other adhesive primers” 

covers “Motor Vehicle Glass Bonding Primers” other than those when applied to 

automotive glass, the recommendation in the OTC model rule would seem to be more 

stringent.

H. Whether the recommendation in the OTC model rule is equal to, less stringent 

or more stringent than the recommendations in the CTG for these categories depends 

upon whether the OTC model rule covers these applications under the “Adhesives 

Applied to the Listed Substrate” and which limit applies. The applicable limit depends 

upon what substrates are involved. The OTC model rule allows compliance to the higher 

of two applicable substrate limits when bonding dissimilar substrates. In no case is an 

OTC limit for any “listed substrate” greater than that recommended in the CTG for 

“Motor Vehicle Adhesives” and “Motor Vehicle Weatherstrip Adhesives;”as such, the 

OTC model rule would seem to be more stringent. 

I. The OTC Model rule applies a limit to ethylene propylene diene monomer 

(EPDM) roof membranes. The CTG excluded EPDM membranes from the VOC 

recommendation for “Single-Ply Roof Membrane Installation/Repair” specialty adhesives 

based upon comment that such limits could not be met for field applied EPDM. Some 

OTC States have limited the CTG recommendation for May 1 to September 30 for two 

years and then set the limit year-round after that.

IX. Conclusions

The OTC Model rule and specifically, Article 6 of 9VAC5-45, for adhesives and sealants 

and the 2008 CTG for miscellaneous industrial adhesives were developed to address the 

emissions of VOC from adhesives. The CTG was developed with a restriction that it 

only applies to larger sources with manufacturing operations that use these types of 

products. Whereas, the OTC model rule includes these sources as well as smaller 

operations, operations performed in the field and also regulation of the manufacture, 

distribution and sale of the products themselves. The OTC model rule also regulates 

sealants and sealant primers which are not included in the CTG because they were not 

categorized with miscellaneous industrial adhesives under section 183(e).

The CTG and the OTC model rule exemption categories are very similar though some 

differences exist, but the CTG recommends that exempted operations be subject to work 

practices. The OTC model rule does not include work practices. The work practices

benefit cannot be quantified and in these instances, generally apply to lower usage source 

categories so very few emission reductions are missed by not including these 

requirements. The OTC model rule contains an exemption provision which is in fact a de 

facto applicability level that equates to 400 pounds per year of VOC emissions which is 

less than the CTG‟s yearly limit of 3 tons per year. The model rule‟s 400 pounds per 
35

year exclusion includes emissions from sealants and sealant primers and not just 

adhesives and their primers and therefore sets a lower numerical limit and includes more 

emissions subject to the applicability threshold. 

The CTG recommended work practices for cleaning materials included more activities 

than the OTC model rule. However, some of the OTC clean-up provisions are more 

stringent, i.e. limiting clean-up solvent vapor pressure and VOC content, and cleaning of 

spray application equipment; overall, the OTC requirements in terms of emission 

reductions are at least equivalent to or result in more emission reductions than the CTG.

The CTG makes recommendations for application methods be used in conjunction with 

the use of low-VOC content adhesives and adhesive primers to improve transfer 

efficiency. The OTC rule does not specify application methods. The CTG

recommendation goes to “stationary sources” above a cut-off level only. The OTC model 

rule was based on the CARB 1998 RACT and best available retrofit control technology 

(BARCT) determination for adhesives and sealants which did not include the requirement 

for application methods. Virginia‟s proposed rulemaking states that 96 percent of the 

adhesive and sealant VOC emissions in the OTC States fall into the area source category. 

This would appear to limit the benefit from improved transfer equipment. However, EPA 

recommends that when the States evaluate RACT as required by section 182(b) when 

implementing a revised 8 hour ozone standard2, that they review and evaluate the benefit 

of requiring improved methods for applying coatings regulated by the OTC model rule 

and specifically, Article 6 of 9VAC5-45.

Overall, the CTG and the OTC model rule emission limits are similar with the exception 

of general adhesive for wood applications. The CTG recommends a 30 g/liter limit for 

the wood substrate category whereas the OTC model rule covers wood under the “porous 

material” substrate category with a limit of 120 g/liter. It is recommended that when the 

States evaluate RACT as required by section 182 (b) when implementing a revised 8-

hour ozone standard, that they review the VOC content limit for wood adhesives.

The CTG does not require State rules to match the line-by-line, item-by-item because it 

stated: “When State and local pollution control agencies develop RACT rules; they may 

elect to adopt control approaches that differ from those described in this document and/or 

promulgate applicability criteria that differ from those recommended here.” (CTG page 

3.) For the most part the OTC Model rule and specifically, Article 6 of 9VAC5-45, 

match the CTG‟s recommendations item by item. The OTC Model rule and specifically,

Article 6 of 9VAC5-45, requires the emission limitations apply to a wider universe of 

sources and to manufacturers and distributors of adhesives and primers. The OTC Model 

rule and specifically, Article 6 of 9VAC5-45, sets standards for clean-up and surface 

preparation solvents in lieu of the application methods and all work practice 

recommendations in the CTG. Overall, EPA can conclude the OTC Model rule and 

 

2 See 75 FR 2938, January 19, 2010; In this proposed rule, March 2008, based upon reconsideration of the 

primary and secondary ozone standards, EPA proposed to set different primary and secondary standards 

than those promulgated in March 2008 to provide requisite protection of public health and welfare, 

respectively. 
36

specifically, Article 6 of 9VAC5-45, meets the requirement for RACT in this source 

category.