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Coatings and Composites Coordinated Rule Development (CCCR)


The Coatings and Consumer Products Group (CCPG) of EPA is currently engaged in the development of regulations for a number of categories of industrial surface coating operations and composite operations. The regulations under development are national emission standards for hazardous air pollutants (NESHAPs) under Section 112 of the Clean Air Act (commonly called MACT rules) and for some of the categories, national volatile organic compound (VOC) rules or control technique guidelines (CTG) under Section 183(e) of the Act. EPA has emphasized involvement of a wide variety of stakeholders interested in these rule makings. Information such as announcements of meetings, agendas, meeting minutes, and papers for review and comment can be accessed below for each active project. In addition, general information common to the source categories is available under the coordination section such as maps to meetings, local hotel information, lists of active participants, and cross-cutting issue papers.

The List of Categories

MACT Rule Section 183(e)
Automobile and Light Duty Truck Coating/Manufacturing Y Y
Boat Manufacturing Y Y
Fabric Coating, Printing, and Dyeing Y N
Wood Building Products (formerly Flatwood Paneling) Y Y
Large Appliances Y Y
Metal Can Y N
Metal Coil Y N
Metal Furniture Y Y
Miscellaneous Metal Parts and Products Y Y
Paper and Other Web (Film and Foil) Y Y
Plastic Parts and Products Y Y
Reinforced Plastic Composites Manufacturing Y N
Aerospace Coatings Y Y
Architectural Coatings N Y
Automobile Refinishing N Y
Consumer Products N Y
Shipbuilding Y Y
Wood Furniture Coatings Y Y


General information

The Coatings and Consumer Products Group of EPA is currently engaged in the development of regulations for a number of coating and composite categories under Sections 112 and 183(e) of the Clean Air Act. EPA's rule development effort is a coordinated effort to help promote consistency and joint resolution of issues common across the categories. EPA plans to integrate the processes followed to develop the Section 112 and 183(e) rules. Throughout the regulatory development process, coordination with stakeholders and the interested public will be a high priority.

The following section provides some introductory information about EPA's regulatory development process. Additional specific information is also contained on this web page, organized by coating and composite category.

  • What is a MACT standard? Why is EPA developing standards?
  • What does section 183(e) of the Clean Air Act require? How is EPA implementing these requirements?
  • What are the advantages of an integrated rulemaking effort?
  • What is a presumptive MACT? What are the benefits of developing this guidance?
  • For which coating/composite categories are standards currently being developed?
  • What are the major project milestones?
  • For which coating/composite categories are standards already developed?

What is a MACT standard? Why is EPA developing standards?

Under the Clean Air Act, as amended in 1990, EPA is required to regulate sources of listed hazardous air pollutants (HAPs) that are known or suspected to cause cancer or other serious health effects. On July 16, 1992, EPA published a list of industry groups (known as source categories) that emit one or more of these air toxics; several coating/composite categories were on this list. For listed categories of "major" sources (those that emit or have the potential to emit 10 tons/year or more of a listed pollutant or 25 tons/year or more of a combination of pollutants), the Clean Air Act directs EPA to develop National Emission Standards for Hazardous Air Pollutants (NESHAPs) that require the application of stringent air pollution reduction measures known as maximum achievable control technology (MACT). The law requires that MACT must not be less stringent than:

  • emission control that is achieved in practice by the best controlled similar source, for new sources; and

  • the average emission limitation achieved by the best performing 12 percent of the existing sources.

The Clean Air Act requires that EPA promulgate most of the industrial surface coating MACT standards by the year 2000. As noted above, the categories listed for regulation are major sources. During the development of these regulations, EPA will evaluate whether non-major or "area" sources of the same type should also be regulated in accordance with the law.

What does section 183(e) of the Clean Air Act require? How is EPA implementing these requirements?

Section 183(e) of the Clean Air Act requires EPA to regulate volatile organic compound (VOC)emissions from consumer and commercial products. VOC emissions contribute significantly to the formation of ground-level ozone (smog) which is associated with a wide variety of human health effects, agricultural crop loss, and damage to forests and ecosystems.

Section 183(e) requires EPA to study VOC emissions, to report to Congress the results of the study (See Study of VOC Emissions from Consumer and Commercial Products, EPA-453/R-94-066-A, March 1995), and to list for regulation products accounting for at least 80 percent of VOC emissions, on a reactivity-adjusted basis, resulting from use of such products in areas of the country that do not meet the national ambient air quality standard for ozone, known as nonattainment areas (see 60 FR 15264, March 23, 19 95). (Many of the product categories listed for regulation are the same as or similar to those source categories listed under Section 112.)

Regulations developed under section 183(e) must be based on "best available controls" (BAC). In the statute, BAC is defined as "The degree of emission reduction that the Administrator determines, on the basis of technological and economic feasibility, health, environmental, and energy impacts, is achievable through the application of the most effective equipment, measures, processes, methods, systems, or techniques, including chemical reformulation, product or feedstock substitution, repackaging, and directions for use, consumption, storage and disposal."

EPA also has discretion to issue a control techniques guideline (CTG) in lieu of a regulation if EPA determines that a CTG would be substantially as effective as a regulation in reducing VOC emissions which contribute to ozone levels in ozone nonattainment areas. Although not specifically defined in the Clean Air Act, a CTG is an EPA guidance document which triggers a responsibility under section 182(b)(2) for States to submit reasonably available control technology (RACT) rules for stationary sour ces of VOC as part of their State Implementation Plans (SIP's).

EPA plans to coordinate with many stakeholders (industry, state and local agencies, and environmental groups) to assure a common sense approach in conducting the comparison of the two regulatory options with regard to emission reduction potential and regulatory efficiency.

What are the advantages of an integrated rule making effort?

Integrating the effort to develop HAP and VOC requirements provides the following advantages:

  • These two sections of the Clean Air Act affect many of the same industrial processes and involve a similar set of stakeholders, so it is cost-effective for both industry and for the taxpayers to develop the two actions in parallel.

  • The two programs are on similar schedules. Many section 183(e) actions are due in 2001 and 2003, and it makes good sense to coordinate them with the MACT rulemaking to ensure an appropriate harmonization of requirements. A single regulatory development process will help EPA to take advantage of opportunities to streamline requirements.

  • Many of the chemical substances regulated as VOCs are also listed as HAPs.

For which coating/composite categories are standards currently being developed?

What are some typical major project milestones?

  • Coating Stakeholder Workshop - April 1997

  • Presumptive MACT Process Complete - September 1998

  • Data Gathering - ongoing

  • Data Analysis - early 1999

  • Proposal - November 1999

  • Promulgation - November 2000

Compliance Deadlines - Each NESHAP rule specifies the date by which the owner or operator must comply with the requirements. In general, the maximum amount of time allowed by statute for MACT standards is 3 years after the promulgation of the final rule for existing sources and upon start up for new sources.

For which coating categories are standards already developed?


EPA Resources External Resources

VOC Documents

February 1994 Alternative Control Techniques Document - Industrial Cleaning Solvents (EPA453/R-94-015) as scanned

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