THE ADHESIVE AND SEALANT COUNCIL, INC
Ozone Transport Commission, VOCs and
What It All Means to You
What is the Ozone Transport Commission ?
When did OTC activities first start affecting Adhesives
What is the difference between the OTC Model and a
Why do some states have rules and other don’t?
What about other states?
What is the US EPA doing?
Ozone Transport Commission
District of Columbia
What is Ozone Transport Commission?
The OTC is a coalition of 13 states and the District of
Columbia’s environmental regulatory agencies
created by the 1990 Clear Air Act (CAA).
It is responsible for developing and implementing
regional solutions to reducing ground level ozone
through individual State implementation plans
When did OTC activities first start affecting
Adhesives & Sealants Industry?
In late 1990’s OTC began to look at consumer
products that were already being regulated by the
California Air Resources Board. A model was
developed based on the CARB’s Consumer Rule. A
series of workshops was held for industry to
comment and in early 2001 the model was
Differences between the OTC Model and a state
Once the model was completed by the OTC, states
had the discretion to adopt the language within
their individual regulatory codes.
While the formatting might vary from state to
state, the language and the rule intent are
expected to remain consistent.
Some states incorporated the model language into
regulation almost immediately; others took their time
or chose not to adopt the model as part of their state
Examples of different approaches:
In 2006 OTC made revisions to the Consumer
Model to reflect some reductions made by CARB
in their rule over time.
Implications for adhesives involved splitting the
“contact adhesives” category into “general contact
adhesives” and “specialty contact adhesives”.
In 2005 OTC began to consider how to control
adhesive and sealant VOCs in commercial and
Based their model rule on 1998 document created
by CARB: RACT/BARCT for Adhesives and Sealants.
OTC held a series of meetings with ASC and its
members regarding the proposed model. A
number of exemptions were updated. One
category of contention never resolved: “roof
Most states implementing this rule model have
made changes to roofing VOC limits through
extended compliance dates.
Lake Michigan Air Directors Consortium (LADCO)
Coalition is not as organized as OTC but some
states on their own have adopted or are going to
adopt consumer product VOC rules which mirror
limits in OTC model.
Michigan –January 2007
Ohio --- January 2009
Illinois --- July 2009
U.S. EPA Consumer Product VOC Rule
Agency adopted a rule in 1998 – no revision since
that time.VOC limits are much higher than present
CARB or OTC state rules. While EPA staff has
indicated that it is interested in reducing national
VOC limits, they have expressed concerns about
smaller manufacturers with limited R&D
capabilities that market regionally.
EPA CTG for Miscellaneous Industrial Adhesives
Last October finalized a Control Technology
Guideline (CTG) for industrial adhesives
applications. A CTG is not a rule but a guidance
document that states can use as necessary to meet
Like OTC model, EPA based their CTG on CARB’s
1998 RACT/BART document. A copy can be found at: