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Technology Transfer Network - OAR Policy and Guidance


Control Techniques Guidelines in Lieu of Regulations for Paper, Film, and Foil Coatings; Metal Furniture Coatings; and Large Appliance Coatings

  • On June 29, 2007, the Environmental Protection Agency (EPA) proposed that control techniques guidelines (CTGs) would be substantially as effective as national regulations in reducing volatile organic compound emissions from three categories of consumer and commercial products.
  • CTGs contain recommended emissions control strategies that could be used to control emissions of volatile organic compounds (VOCs) from the industrial use of these products.  VOCs contribute to the formation of ground-level ozone.  The CTGs could be adopted by states to control VOC emissions in areas that do not meet the National Ambient Air Quality Standards for ground-level ozone.
  • EPA also is making available for review three draft CTGs.  These Guidelines would apply to commercial facilities using products including:
    1. paper, film, and foil coatings (example: adhesives used on tapes and labels,  etc.)
    2. metal furniture coatings (example: paints used in manufacturing chairs, tables, etc.)
    3. large appliance coatings (example: paints used in manufacturing washers and dryers)
  • EPA estimates that the cost-effectiveness of VOC reductions through implementing these CTGs to control VOC emissions would range as follows:
    1. paper, film, and foil coatings -- $1200/ton
    2. metal furniture coatings -- $118/ton
    3. large appliance coatings -- $500/ton
  • Applicability for the recommendations in these CTGs varies by category and by process.  In general, the measures apply to facilities with VOC emissions from the given category of at least 15 lb/day (2.7 tons/yr). 
  • EPA will accept comment on this proposed determination and the draft CTGs for 30 days after it is published in the Federal Register.  EPA will hold a public hearing on the determination if requested.  If a hearing is held, the comment period will remain open for 30 days following the hearing.  


  • The Clean Air Act (section 183(e)) directs EPA to list for regulation categories of consumer and commercial products that account for at least 80 percent of the VOC emissions in areas that violate the national ambient air quality standard (NAAQS) for ozone.  The Act further directs EPA to divide the list of categories to be regulated into four groups. 
  • EPA published the initial list in the Federal Register on March 23, 1995 (60 FR 15264).  Since then, EPA has revised the list several times, with the most recent being May 16, 2006 (71 FR 28320).  The three product categories covered by the draft CTGs now available for comment are included in Group III of the list.
  • EPA identified, or designated, areas that did not meet the NAAQS for 8-hour ground-level ozone in April 2004.  State, tribal and local air agencies responsible for these “nonattainment” areas are in the process of developing implementation plans showing how the area will meet and maintain the standard. 
  • The Clean Air Act requires these state implementation plans known as SIPs (Tribes may choose to develop tribal implementation plans – TIPs) to contain emission controls that are economically and technologically feasible.  Emissions control technologies that meet these criteria are known as “RACT” – reasonably available control technology.
  • Historically, EPA has provided State, tribal, and local air agencies with guidance for what types of controls could constitute RACT for a given type of facility or emissions source through a CTG.  States may follow the CTG and adopt regulations to implement the recommendations, or they can adopt alternative approaches.


  • Today's proposed action and other background information are also available either electronically in www.regulations.gov, EPA’s electronic public docket and comment system, or in hard copy at EPA’s Air and Radiation Docket and Information Center, Environmental Protection Agency, Room B102, 1301 Constitution Avenue, NW, Washington, DC (See specific Docket ID numbers below). The Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Public Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket and Information Center is (202) 566-1742.
  • HOW TO COMMENT: Comments will be accepted for 45 days beginning when this proposal is published in the Federal Register.   Comments should be submitted by one of the following methods:
    • www.regulations.gov;
    • E-mail (a-and-r-docket@epa.gov);
    • Facsimile (202) 566-1741;
    • Mail (Air and Radiation Docket and Information Center, Environmental Protection Agency, Mailcode: 6102T, 1200 Pennsylvania Avenue, NW, Washington, DC 20460); or
    • Hand delivery (Air and Radiation Docket and Information Center, Environmental Protection Agency, Room B102, 1301 Constitution Avenue, NW, Washington, DC).
  • Comments on EPA’s determination that CTGs will be substantially effective as national rules for these categories should be identified by Docket ID No. EPA- HQ-OAR-2007-0454.
  • For comments on the draft CTGs themselves, please direct comments to the individual Docket ID numbers listed for the individual categories as follows:
    • EPA-HQ-OAR-2007-0336 - Paper, Film, and Foil Coatings
    • EPA-HQ-OAR-2007-0334 - Metal Furniture Coatings
    • EPA-HQ-OAR-2007-0329 - Large Appliance Coatings
  • For further information about this action, contact Mr. Bruce Moore of the EPA's Office of Air Quality Planning and Standards by phone (919) 541-5460 or by e-mail at moore.bruce@epa.gov.


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