In lieu of creating a National Industrial Adhesives rule, the U.S. Environmental Protection Agency (EPA) adopted in 2008 the Industrial Adhesives and Sealants regulation as a Control Technology Guideline (CTG). The regulation empowers states to adopt their own regulations, especially in ozone non-attainment areas. Such regulations could have a huge impact on how rubber-to-substrate adhesive users conduct their business—today and in the future.
A recent change involves the creation of a new Ozone Non-Attainment Area (3745-21-28) VOC Rule for Cleveland, Ohio. This new regulation is based on and is
consistent with the EPA’s CTGs for Miscellaneous Industrial Adhesive Application Operations. The control requirements regulating miscellaneous industrial adhesive application operations in the former Cleveland-Akron-Lorain eight-hour ozone non-attainment area will apply to businesses if the combined VOC emissions from all sources are equal to or exceed 3.0 tons per 12-month rolling period.
If impacted, adhesive application operations must comply with either the specific VOC content limitations, depending on the application or the substrate being bonded (e.g., 0.3 lbs VOC per gal of adhesive for bonding metal), or install an emissions control system that reduces VOC emissions by at least 85%. Specific adhesive application methods (e.g., electrostatic spray) and work practices may also be required to meet the new regulations. Additional recordkeeping requirements are also now mandated to ensure applicability and compliance with the new regulations.
The new ruling may also drive changes in other ozone non-attainment areas in the U.S., as already experienced in Pennsylvania, New Jersey, and much of the Northeast and California. As these regulations are adopted in additional areas, adhesive applicators have several options to consider:
• Install incineration or abatement equipment
• Outsource adhesive application to a custom coater
• Use lower VOCs and HAP-compliant materials
• Use aqueous adhesives
• Exit the business
Selecting the right solution requires a careful review of specific objectives and a close partnership with key suppliers.