Industrial Adhesives and Sealants VOC Update

Background

Industrial applications of adhesives and sealants are subject to air quality regulations in various states and local air districts in California. There is no national rule for industrial adhesives and sealants, but the U.S. Environmental Protection Agency (EPA) developed a Control Technique Guideline (CTG) for Miscellaneous Industrial Adhesives.

In California, the local air districts have jurisdiction over industrial processes while the Air Resources Board (CARB) has jurisdiction over consumer products. Consequently, CARB developed air quality standards for consumer adhesives and sealants and left the regulation of industrial adhesives and sealants to the local air districts. In the late 1990’s, in an effort to provide some guidance to the air districts for this source category, CARB developed and approved the RACT/BARCT Determination for Industrial Adhesives and Sealants. Most of the local air districts in California currently have a regulation focused on this source category. South Coast Air Quality Management District’s (SCAQMD) Rule 1168 remains the most stringent regulation for industrial adhesive and sealant applications, as it regulates the air quality in the greater-Los Angeles area.

In addition to the stringent regulations in California, other states and local air districts throughout the country have also adopted industrial adhesive and sealant rules. Recently, Nevada’s Clark County Department of Environment and Sustainability (DES) and the Texas Commission on Environmental Quality (TCEQ) initiated industrial adhesives rulemakings. Overall, industry supports rules that are consistent with U.S. EPA’s CTG for Miscellaneous Industrial Adhesives or align with standards in the California air districts.

ACA Action

In February 2024, Clark County DES issued a proposed rule for industrial adhesives and sealants. ACA submitted comments urging the department to adopt provisions consistent with U.S. EPA’s CTG. ACA also encouraged Clark County DES to add provisions for low-solid products and include a reasonable compliance date. A final rule is expected in mid-2024.

In December 2023, TCEQ issued proposed amendments to its air quality regulations (including Chapter 115 – Control of Air Pollution from VOCs). Notably, the proposal includes a contingency measure for owners or operators of a manufacturing operation using industrial adhesives and sealants in certain counties in the Dallas-Fort Worth (DFW) and Houston-Galveston-Brazoria (HGB) areas. In addition, the commission proposed to make the current industrial adhesives VOC RACT requirements applicable to affected sources in the Bexar County (San Antonio) area beginning on January 1, 2025. This effort is the result of U.S. EPA’s reclassification of these areas from marginal to moderate nonattainment or serious to severe nonattainment under the NAAQS for ozone. The proposed VOC limits in the contingency measure are based on SCAQMD Rule 1168, but not all categories from Rule 1168 are included in TCEQ’s proposal. The contingency measure would take effect in the DFW and HGB areas after a finding by EPA that the specified area failed to attain the applicable NAAQS for ozone (with appropriate notification). ACA will participate in this rulemaking effort in Texas to ensure industry’s input is taken into consideration.

ACA will also continue to monitor any other industrial adhesives and sealants rulemakings that transpire in states and local air districts throughout the country to ensure that they are consistent and reasonable for industry.

Lastly, ACA developed a list of industrial adhesives regulations by state and local air district with links to the applicable rules. This document is intended to be used as a resource to assist in industry’s compliance with the various industrial adhesives rules throughout the country. ACA will continue to update this resource for its members.

ACA Staff

Rhett Cash
Counsel, Government Affairs