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  • Writer's pictureTom Petersen

New Regulations for Surface Coating Operations

Updated: Aug 28, 2023

Does your facility (or your clients’ facility) have surface coating operations? Want to know about recent changes in regulations for these surface coating operations? Read on for further details …

Under Section 112 of the Clean Air Act, the Environmental Protection Agency (EPA) must monitor and control emissions of chemicals known as Hazardous Air Pollutants (HAPs). This has been accomplished through the development of industry-specific Maximum Achievable Control Technology (MACT) standards. For the sub-set of HAPs that are also organic solvents, this effort has been coordinated with Section 183(e) requirements. Section 183(e) primarily requires the EPA to regulate Volatile Organic Compound (VOC) emissions from consumer and commercial products.

The EPA program known as the Coatings and Composites Coordinated Rule Development (CCCR) allows for coordination of the Section 112 and Section 183(e) requirements.

If your type of industry is listed below and your company has the potential to emit at least 10 tons per year of a HAP or 25 tons per year of a combination of HAPs, you must comply with a new MACT standard by the given compliance deadline.

*Industries that must comply with VOC rules in addition to MACT standards.

The following is a summarized list of the requirements common to each regulation.

  • Reduced HAP emissions through:

  • the use of “as purchased” compliant coating materials

  • effective capture and control (98% overall control efficiency)

  • the use of “as applied” compliant coating materials

Additional testing and monitoring requirements:

  • Initial notification

  • Performance test notification

  • Compliance status notification

Additional reporting and documentation requirements:

  • Periodic reports

  • Startup, Shutdown, Malfunction reports

EES can help you meet the requirements of the new MACT standards and VOC rules.

Contact Tom Petersen of EES at (215) 704-1506 or



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