TCEQ Chapter 115: Texas VOC Rules for Coatings

TCEQ Chapter 115 sets VOC limits, work practices, and documentation requirements that directly affect how coatings are manufactured, sold, and used across Texas, especially in ozone nonattainment areas such as the Corpus Christi region. Understanding these rules helps facilities choose compliant products and application methods while still meeting performance expectations for architectural and industrial coatings.

What Chapter 115 Covers

TCEQ’s Chapter 115 rules on coatings fall under “Control of Air Pollution from Volatile Organic Compounds,” with surface coating processes addressed in Subchapter E, Divisions 2 and 5. These sections limit VOC content in coatings, define how coatings can be applied, and specify testing, monitoring, and recordkeeping for affected sources.

The rules are part of Texas’ State Implementation Plan to meet federal ozone standards, targeting VOC emissions because they contribute to ground-level ozone formation. As a result, many coating operations in areas with air quality concerns must follow stricter VOC requirements than similar operations in unregulated counties.

Areas and Facilities Affected

Surface coating rules apply in specific ozone nonattainment and near-nonattainment areas, including the Corpus Christi area (Nueces County), along with regions such as Dallas–Fort Worth, Houston–Galveston–Brazoria, Beaumont–Port Arthur, El Paso, Victoria, and parts of Northeast Texas. Facilities in these counties with qualifying surface coating operations must determine whether their processes fall within Chapter 115’s scope.

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Applicability depends on both location and process type, such as metal parts coating, paper/film/foil coating, or motor vehicle-related materials with certain VOC emissions potential. Many rules are triggered when uncontrolled VOC emissions or usage exceed specified ton-per-year thresholds, so understanding potential emissions is essential when planning or expanding operations.

VOC Limits for Coatings

Chapter 115 requires that affected surface coating processes meet VOC emission specifications expressed as content limits, often in grams of VOC per liter of coating minus water and exempt solvents. These limits vary by coating category, reflecting differences in performance demands and formulation needs for products like industrial maintenance coatings, primers, high-temperature coatings, and traffic markings.

For architectural and industrial maintenance-type applications, typical Texas limits include lower VOC caps for flat and non-flat coatings and more tailored limits for specialty coatings such as floor coatings, stains, varnishes, roof coatings, and fire-resistive materials. Manufacturers and end users must verify that coatings sold or applied in regulated Texas regions meet these numerical limits for each product category.

Methods and Work Practices

Beyond product formulation, Chapter 115 also restricts how coatings are applied at affected facilities, requiring specific application methods that reduce overspray and emissions. Approved methods often include electrostatic spray, high-volume low-pressure (HVLP) spray, or other techniques designed to improve transfer efficiency and minimize VOC release during use.

The rules also include work-practice standards for storage, mixing, and handling, such as keeping VOC-containing coatings and cleanup materials in closed containers and using closed conveyance systems where applicable. Good work practices not only improve compliance but also help reduce material loss and improve workplace conditions.

Testing, Monitoring, and Recordkeeping

To demonstrate compliance, Chapter 115 incorporates approved test methods for measuring VOC content, density, and emission rates from coating operations. These methods often reference EPA analytical procedures and require consistent sampling and calculation approaches to ensure accurate results.

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Facilities must maintain records documenting coating usage, VOC contents, application methods, and any control devices or alternative compliance strategies used. Proper recordkeeping supports inspections, helps facilities track their own emissions trends, and provides evidence that low-VOC or compliant products are being used as required.

Choosing Compliant Coatings

For businesses that buy and apply coatings, Chapter 115 makes product selection a regulatory as well as performance decision. Contractors, fabricators, and maintenance teams in regulated Texas counties need to confirm that their coatings meet applicable VOC content limits for the specific use and category.

Working with knowledgeable suppliers can simplify compliance by providing product data sheets, VOC values, and clear labeling that aligns with Texas coating categories. In many cases, low-VOC or reformulated coatings can deliver comparable durability and finish quality while keeping operations within Chapter 115 limits.

Local support in Corpus Christi, TX

Because Corpus Christi, TX falls within a regulated VOC area, coating users benefit from local guidance on selecting products that align with Chapter 115 requirements while still delivering the right performance in coastal and industrial environments.

Ashmore Paint Co., as a dedicated paint store, can help customers interpret VOC labeling, match coating categories, and choose compliant options for projects so that businesses and contractors stay aligned with Texas VOC rules while meeting everyday coating needs.​

If you have questions about choosing coatings that align with Texas VOC rules, reach out to Ashmore Paint today for local guidance.