UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

San Joaquin Valley Unified Air Pollution Control District, 

Rule 4653, Adhesives and Sealants

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

September 2011
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RULE IDENTIFICATION -

Agency: San Joaquin Valley Unified Air Pollution Control 

District (SJVUAPCD)

SIP Approved Rule: Rule 4653 – Adhesives 

Adopted –December 20, 2007

Submitted- March 7, 2008

EPA Approved – October 15, 2009 (74 FR 52894)

Previous Submitted Rule: Rule 4653 – Adhesives

Adopted – September 17, 2009

Submitted - May 17, 2010 

Subject of this TSD: Rule 4653 – Adhesives and Sealants

Amended – September 16, 2010

Submitted – April 5, 2011

RULE SUMMARY - SJVUAPCD Rule 4653, Adhesives and Sealants, is a rule 

amended to reduce emissions of volatile organic compounds (VOCs) from the 

application of adhesive products, sealant products and associated solvent 

cleaning operations. The rule describes related recordkeeping, reporting, and 

monitoring requirements and test methods for determining various VOC content 

and emissions. The submitted changes to Rule 4653 are largely made to adopt

the new content limits of the 2008 CTG prior to the effective date of January 1, 

2011. Changes from the approved SIP submittal include:

1. Changed the title from “Adhesives” to “Adhesives and Sealants” and 

included sealant products, as needed, in each section.

2. Added several definitions in Section 3.0 to clarify the current rule, to add 

sealant products and to include new adhesives categories to the rule 

language.

3. Clarified exemptions, added sealant exemptions and sales restrictions and 

included effective dates for complying with the rule limits in Section 4.0.

4. Revised Section 5.0 Table 1, adding columns for VOC limits for effective 

dates through December 31, 2010 and after January 1, 2011. 

5. Added Section 5.0 Table 2 indicating lower VOC limits for adhesives 

effective January 1, 2012.

6. Revised Section 5.0 Table 3 to include VOC limits for adhesives effective 

January 1, 2011 and January 1, 2012. Added Reinforced Plastic and 

Fiberglass categories. 

7. Included Section 5.0 Tables 4 and 5 for sealant and sealant primer limits.
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8. Added Airless Spray to the list of application in Section 5.2.

9. Revised the requirement for transfer efficiency of any new application 

methods to be equivalent to the efficiency of the HVLP method instead of 

at least 65%.

10. Added Section 5.3, Work Practices for Adhesive and Sealant Products.

11. Revised Table 6, VOC Limits for Organic Solvents Used in Cleaning 

Operations, to list only the September 21, 2008 limits.

12. Replaced the section for Solvent Storage and Disposal Requirements with 

a Work Practices for Solvent Cleaning. 

13. Added Section 5.8, Sell-through of Adhesives and Sealants and Section 

5.9, Prohibition of Specification.

14. Removed the requirement of daily records of all adhesives, primers and 

solvents used in each operation and added the requirement to record the 

VOC content of all sealant materials stored at a stationery source.

15. Clarified labelling requirements in Section 6.2 to include all three 

requirements and to add sealant products, effective January 1, 2012.

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

rule. 

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

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

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

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

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

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

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

enforceability. 

2. Stringency – EPA’s Control Technique Guideline (CTG) titled “Control 

Techniques Guidelines for Miscellaneous Industrial Adhesives” (EPA-453/R08-005, September 2008), CARB’s RACT/BARCT guidance titled, 

“Determination of Reasonably Available Control Technology and Best 

Available Retrofit Control Technology for Adhesives and Sealants” 

(December 1998), SJVUAPCD’s 2009 RACT SIP Demonstration (April 16, 

2009),and other state and local rules for this category were used to help 

evaluate the RACT requirements of CAA §182(b)(2).

3. SIP Relaxation - We have evaluated this SIP revision to determine whether 

it would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of 
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CAA §110(l) or modify any SIP-approved control requirement in effect 

before November 15, 1990 (CAA §193).

Enforceability – The recordkeeping of coatings and control system parameters, test 

methods and other requirements generally ensure that the submitted rule can be 

enforced. Since section 6.1.1 of the rule requires records of the VOC content of all

adhesive materials, solvents and sealant materials used and stored, we do not 

believe the absence of a requirement of a materials listing makes the rule 

unenforceable. However, Rule 4653 could be improved by adopting language 

similar to that of BAAQMD Rule 8-51 which specifies a requirement for 

manufacturer’s product number, mix ratios of components in the product used, and

final VOC content as applied. 

Stringency – Rule 4653 closely resembles the 2008 CTG for Miscellaneous 

Industrial Adhesives (EPA-453/R-08-005) and CARB’s Determination of RACT 

and BARCT for Adhesives and Sealants (December 1998), which we believe are

generally reliable sources for identifying RACT. In addition, several adhesive and 

sealant categories in Rule 4653 have VOC limits lower than the CTG. 

Further, Rule 4653 is generally as stringent as analogous requirements in Bay 

Area (BAAQMD Rule 8-51(7-16-02)) and South Coast (SCAQMD’s Rule 1168 (1-

7-2005)), and we are not aware of more stringent requirements adopted 

elsewhere. For these reasons, we believe Rule 4653 implements RACT and 

complies with CAA §182(b) (2).

SIP Relaxation – The VOC limits for several categories, effective January 1, 2012, 

were reduced significantly. These categories include Multi-purpose Construction 

Adhesive, Ceramic Tile Adhesive, Cove Base Installation, Single-ply Roof Material 

Installation and Contact Adhesive, ABS Welding Adhesive, Plastic Cement 

Welding Adhesive Primer, Other Plastic Cement Welding Adhesive and Plastic 

Foam. Consequently we believe that the submitted rule is more stringent than the 

version previously approved into the SIP. 

We propose to determine that our approval of the submittal would comply with 

CAA §193 and CAA §110 and part D requirements, because the SIP revision 

would not interfere with the on-going process for ensuring that the requirements for 

RFP and attainment of the NAAQS are met, and the submitted SIP revision is 

more stringent than the rule previously approved into the SIP.

RULE DEFICIENCIES – We have not identified any deficiency in Rule 4653

sufficient for EPA to propose less than a full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 
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1. Please consider making the following changes to definitions in Section 3.0:

a. CARB’s definition of airless spray in the 1991 Automobile 

Refinishing Coating compliance assistance program states that the 

Airless Spray operates under high fluid pressure between 1500 and 

3000 psi. Please verify if the larger range indicated in the definition 

in Subsection 3.9 is accurate.

b. Please clarify whether cove base should be included in the Floor 

Covering Installation definition of Subsection 3.43.

2. In Subsection 3.85, for accuracy, we recommend that you add “as 

determined by ASTM Method E260-96.” after “distensibility.” as SMAQMD 

has done in their definition of plasticizer. 

3. For clarity, please add the following statement to Subsection 4.1.6: 

Effective on and after January 1, 2011, users must comply with the 

applicable requirements of Section 4.2.

4. For completeness, and to be consistent with Section 5.7, please revise 

Subsection 4.3.2 to be: “Adhesive products and sealant products sold to 

any person who complies with the requirements of Section 5.1 or 5.4.” 

5. Consider the possibility of lowering the limits in Table 2 of Section 5.1:

a. The CARB Determination of RACT and BARCT for Adhesives and 

Sealants has a technology forcing standard limit of 250 g/l for the 

Sheet Applied Rubber Installation category. Since, by definition, this 

seems to be the same as Rule 4653’s category, Rubber 

Vulcanization Adhesive/Primer, consider the possibility of lowering 

this limit to 250 g/l. 

b. The Motor Vehicle Weatherstrip Adhesive should be included in the 

“All other Substrates” category of Table 3. Consider lowering this 

limit to the 250 g/l limit indicated on Table 3. 

c. BAAQMD’s Rule 8-51 limits the VOC for Immersible Product 

Manufacturing to 650 g/l. Since the definition of BAAQMD’s 

Immersible Product Manufacturing is comparable to SJVUAPCD’s 

Elastomeric Adhesive, it would seem possible that the limit for 

Elastomeric Adhesive can be lowered from 750 g/l to 650 g/l.

d. Consider lowering the limit for PVC Welding adhesive to 500 g/l 

which is consistent with the CTG. 
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6. Based on the Table in the 2009 SJUAPCD RACT SIP rule analysis (page 

3-309 through 4-311), SCAQMD’s Rule 1168 has lower limits in four 

categories:

a. Ceramic Tile Installation - SCAQMD has a 65 g/l limit compared to 

SJVUAPCD’s 130 g/l limit.

b. Cove Base Installation - SCAQMD has a 50 g/l limit compared to 

SJVUAPCD’s 150 g/l limit.

c. Multipurpose Construction - SCAQMD has a 70 g/l limit compared to 

SJVUAPCD’s 200 g/l limit.

d. Top and Trim Installation - SCAQMD has a 250 g/l limit compared to 

SJVUAPCD’s 540 g/l limit.

7. The VOC limit for the cleaning solvent for the Surface Preparation Prior to 

Rubber Vulcanization Process indicated in Table 6 of Section 5.5 is 850 g/l. 

The CARB Determination of RACT and BARCT for Adhesives and 

Sealants does not have a comparable category. We recommend the 

District consider lowering the limit for this category.

8. The CARB guidance recommends a material list complete with catalysts, 

reducers or other components used and the mix ratio. Please consider 

adding this in subsections 6.1.1.1, 6.1.1.2 and 6.1.1.3 to complete the 

information available. 

9. For clarity, please revise subsections 6.1.3.1 and 6.1.3.1 to include 

“adhesive products and sealant products...” in the recordkeeping 

requirements.

10. Please make the following changes for clarity and consistency as defined 

in the Little Bluebook:

a. Per CARB Determination of RACT/BARCT for Adhesives and 

Sealants, Test 24 is applicable for non-aerosol adhesives. Please 

consider adding “non-aerosol” before “adhesive products” in 

Subsection 6.3.1. 

b. CARB recommends SCAQMD Method 305-91, Determination of 

VOC in Aerosol Applications, June 1993, or ARB Method 310, 

Determination of VOC in Consumer Products and reactive Organic 

Compounds in Aerosol Coating Products, June 22, 2000, for 

determining the VOC content of aerosol adhesives. Please refer to 

these test methods for aerosol adhesive and sealant products in 

Section 6.3.

c. CARB recommends SCAQMD Method 316A-92, Determination of 

VOC in Materials Used for Pipes and Fittings, October 1996, for any 
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plastic cement adhesives or primers. Please refer to this test method 

for plastic cement adhesive products in Section 6.3.

d. The 2008 CTG recommends that the procedure for determining 

VOC content for reactive adhesives in Appendix A of the NESHAP 

for surface coating of plastic parts (40 CFR 63, PPPP) be used for 

reactive adhesives. The manufacturer’s formulation data is 

acceptable but, if there is a disagreement between manufacturer’s 

formulation data and the results of the subsequent test, the test 

results should be used unless the facility can demonstrate that the 

manufacturer’s data are correct. Please consider adding a test 

procedure for reactive adhesives, with the appropriate caveat for 

variations between test results and manufacturer’s data, in Section 

6.3.

e. In Subsection 6.3.3, the ARB method 422 reference should have the 

date of the EPA-approved version which is Sept. 12, 1990. 

EPA ACTION - EPA staff recommends a full approval of Rule 4653 pursuant to 

CAA §110(k) (3) and §301(a). 

ADDITIONAL REFERENCES –

1. SJVAPCD Rule 4653, Adhesives and Sealants, as submitted on

September 16, 2010.

2. SJVAPCD Rule 4653, Adhesives, as submitted on September 17, 2009.

3. Control Technique Guideline (CTG) titled “Control Techniques Guidelines 

for Miscellaneous Industrial Adhesives” (EPA-453/R-08-005, September 

2008) http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200809_voc_epa453_r08-005_miscellaneous_industrial_adhesives.pdf.

4. CARB’s RACT/BARCT guidance titled, “Determination of Reasonably 

Available Control Technology and Best Available Retrofit Control 

Technology for Adhesives and Sealants” (December 1998)

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

5. SJVUAPCD’s 2009 RACT SIP Demonstration (April 16, 2009).

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

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

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