Ozone Transport Commission (OTC)

Regulatory Responsibility:

The Ozone Transport Commission (OTC) is a multi-state organization created under the federal Clean Air Act. It is responsible for advising the EPA on transport issues and for developing and implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions. OTC members include the states of Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. The OTC is a joint effort among its member states to establish recommended VOC emission limits for various types of emitters in the form of Model Rules. However, it is up to each state to individually adopt the Rules according to their priorities.

VOC Regulations:

The OTC has categorized several sectors which are sources for air pollution. Three of them are known emitters of VOCs: Consumer Products, Architectural and Industrial Maintenance (AIM) Coatings, and Solvent Degreasers. In 2004, OTC adopted VOC emission Model Rules 2002 for the typical product categories:

• MODEL RULE 2002- Architectural, Industrial and Maintenance Coatings (AIM)
• MODEL RULE 2002- Mobile Equipment Repair and Refinishing (MERR)
• MODEL RULE 2002- Solvents and Cleaners
• MODEL RULE 2002- Consumer Products (includes aerosols)

These Model Rules were patterned after the SCAQMD rules. Tables in these Rules specify VOC content limits for various categories of products. In 2009, MODEL RULE 2006 – Adhesives and Sealants was added. Over the years, the Model Rules were clarified and the VOC content limits were revised. New dates for adoption were established. As with other states, OTC appears to be following the rules developed by SCAQMD, although effective dates are in the future.

Model Rule Adoption Chart:

Beginning in 2010, OTC began to publish a Model Rule Adoption Chart which summarizes the progress of individual states in adopting the Model Rules. The most recent Model Rule Adoption chart was published in June, 2014. This chart reveals that in the Consumer Products, AIM Coatings, and Solvent Degreasers categories, only Delaware has adopted any rules, New Jersey may propose rules in 2014, and none of the states are actively developing rules. This is curious in that Massachusetts has developed and implemented many regulations on VOC emissions which the table does not show. Similarly, Michigan has adopted Model Rule 2002 for Consumer Products even though it is not a member of OTC. It is recommended that viewers check the regulations in each state in OTC; some, but not all of which are referenced in this site.