While volatile organic compound (VOC) regulations have tightened over the years, there
continue to be compliant adhesive, cement, primer, and coating options available for the
installation and maintenance of asphalt roofing systems. Asphalt roofing systems—installed and
maintained with VOC-compliant adhesives, cements, primers, and coatings—continue to
provide long-term performance on the roof while achieving compliance with a wide variety of
VOC regulations that exist throughout North America.
Background on VOC Regulations
When exposed to sunlight, nitrogen oxides (NOx) and VOCs combine to produce ozone. The
U.S. Environmental Protection Agency (EPA) has prescribed National Ambient Air Quality
Standards (NAAQS) for ozone to protect the public health, with an adequate margin of safety,
including the health of at-risk populations, and protect the public welfare from adverse effects.
A region in which ground-level ozone is found to exceed the NAAQS is said to be in
“nonattainment.” Once a state or region is found to be in nonattainment, that area is required
to submit a State Implementation Plan (SIP) setting the regulatory actions that will be taken to
come into attainment.
Those regions and states in nonattainment often employ VOC regulations as part of their air
quality management program to achieve lower ground-level ozone concentrations. In several
areas of the country where there is widespread nonattainment, such as California and the
northeastern United States, regulatory bodies suggest model rules for governing VOCs. These
model rules can be adopted locally by states and regional districts as part of their ozonereduction programs. Additionally, the EPA has the authority to set VOC regulations for certain
product types that become applicable across the country.
Primary Rules Affecting Roofing System Components
The main regulations affecting the installation and maintenance of asphalt roofing system
components are the Architectural and Industrial Maintenance (AIM) Coatings Rules and the
Adhesive & Sealants Rules. Although regulations affecting these products may be introduced
anywhere in the US, there are geographic areas that have historically had high levels of VOC
regulatory activity. Regulatory bodies for these areas include:
• California Air Resources Board (CARB): CARB is the regulatory body that oversees
California’s statewide air quality initiatives and guides the regulatory activities of its 35
local air districts. In the case of AIM Coatings, CARB publishes “suggested control
measures” (SCMs) that the air districts may choose to adopt as part of their air quality
• Ozone Transport Commission (OTC): Comprised of the northeast states that are
included in the EPA-designated Ozone Transport Region (OTR), the OTC publishes Model
Rules that participating states typically use as a template for their state or regional air
• Lake Michigan Air Directors Consortium (LADCO): LADCO encompasses the Great
Lakes-area states. LADCO typically does not draft its own model rules, but recommends
to its participating states that they use the OTC Model Rules.
• South Coast Air Quality Management District (SCAQMD): One of the air districts in
California, the Los Angeles-area SCAQMD is typically at the forefront of creating and
implementing new VOC regulations. The VOC content limits and breadth of VOC
regulations in the SCAQMD far exceed those of anywhere else in the country;
additionally, SCAQMD regulations typically serve as a precursor to future CARB SCMs
and OTC Model Rules.
Complying with VOC Regulations
When a state or air district adopts a VOC rule, they have the choice to adopt a model rule as
written, to make certain modifications to a model rule, or to create an entirely new rule.
Therefore, it is essential that you work with the manufacturer of your asphalt roofing system
components to ensure that the system being specified will comply with all federal, state, and
local VOC regulations.
Adhesive, cement, primer, and coating manufacturers continue to make developments to their
products to ensure the effectiveness and longevity of each roofing system installed using these
components while also minimizing their potential impact on the environment. With everchanging air quality regulations, adhesive, cement, primer, and coating manufacturers have
many years of experience ensuring that products can comply with new regulations without
sacrificing those products’ proven long-term performance in a broad range of climatic regions.
Contact an ARMA Member today to hear more on the latest VOC-compliant adhesive, cement,
primer, and coating innovations available for your location. Refer to local jurisdictional codes,
regulations, and specific project site requirements that may apply to roofing and related