What is the Ozone Transport Commission (OTC)?

  • Multi-state organization responsible for advising EPA on regional solutions to reduce air pollution.
  • OTC members: Connecticut, Delaware, the District of Columbia, Maine, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and Virginia.

Why is the OTC developing regulations?

  • Pollution generated in the Midwest drifts to the east causing high levels of pollutants.
  • EPA has mandated strict air quality standards for the Northeast Region that currently are not being met.
  • OTC has amended one Model Rule and developed another to address this issue.
  • Model Rules are based on regulations currently in effect in California.
  • Purpose: To reduce VOC emissions through sale and manufacture restrictions that limit the VOC content of specified adhesives, sealants and primers sold in each state.

Which Model Rules will specifically affect ITW Polymers Sealants finished products?

  • Model Rule for Consumer Products
  • Most Northeast states already have a consumer regulation in effect
  • Amendments were proposed to further reduce VOC emissions
  • Model Rule for Adhesives and Sealants
  • New rule implementing VOC limits on adhesives and sealants depending on application.

What is a Consumer Adhesive Product?

  • Consumer Product Definition: a chemically formulated product used by household and institutional consumers including, but not limited to, detergents, cleaning compounds, polishes, floor finishes, cosmetics, personal care products, home, lawn and garden products, disinfectants, sanitizers, aerosol paints, and automotive specialty products. Includes Aerosol Adhesives used for consumer, industrial or commercial uses.
  • Contact adhesives – one (1) gallon or less
  • Other Adhesives – 16 fluid ounces or less or one (1) pound or less
  • Maximum VOC content in percent (%) by weight
  • Banned Substances:
    • Methylene Chloride
    • 1,1,1-Trichloroethylene
    • Perchloroethylene


What is a VHAP?
  • EPA regulates 189 toxic chemicals as Hazardous Air Pollutant (HAP)
  • 189 List includes non-volatile compounds, such as heavy metals (lead, mercury, etc.)
  • A VHAP is a volatile hazardous air pollutant
Who regulates VHAPs?
  • Federal and State Environmental Agencies only
    • Environmental Protection Agency (EPA)
    • State Department of Environmental Protection (DEP), or DEC, or DNR
How are VHAPs regulated?
  • EPA developed standards under the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for specific manufacturing industries.
  • Subpart JJ regulates the Wood Furniture Manufacturing Industry.
  • Emission limit set for contact adhesives for the following two categories of major source:
    • Existing facilities – 1.0 lb VHAP per lb Solid
    • New facilities – 0.2 lb VHAP per lb Solid
What does “major source” mean?
  • EPA defines facilities based on emissions as either major or minor
  • Major source is a facility that emits:
    • > 10 tons per year of one HAP (roughly, assuming 40% HAP, 7600 gal adhesives or 138 drums)
    • > 25 tons per year of the aggregate HAP
What is a “wood furniture manufacturing” company?
  • Wood Furniture – any product made of wood, a wood product such as ratten or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes (SIC) – 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599 or 5712.
  • Wood Furniture Component – means any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops. 
  • Wood Furniture Manufacturing Operations – the finishing, gluing, cleaning
What is considered to be a “new” facility?
  • Subpart JJ promulgated December 7, 1995
  • Any wood furniture manufacturing company constructed after 12/07/1995
  • Any existing wood furniture manufacturing company that becomes a major source (exceeds limits above)
  • Any reconstructed wood furniture manufacturing company
What is the difference between a VOC and a VHAP?
  • A compound can be both a VOC and a VHAP (e.g. Methyl Ethyl Ketone or Toluene).
  • A compound can be VHAP but not a VOC (e.g. Methylene Chloride – Exempt compound on VOC list)
What records am I required to keep to show compliance for my contact adhesives?
  • Certified Product Data Sheet (CPDS) for each contact adhesive used in the facility listing the lb VHAP per lb Solid
  • CPDS provided and certified by manufacturer of adhesive (i.e. TACC)
Where can I find out more information?
  • EPA web site – links to the federal regulations (i.e. Subpart JJ)
  • State Environmental Agencies – links to all 50 state agencies
  • ITW Polymers Sealants Customer Service – to obtain a Certified Product Data Sheet (CPDS)


Basic Definitions:
VOC – Volatile Organic Compound – any compound containing carbon.
HAP – Hazardous Air Pollutant – EPA designated 189 compounds to be “Hazardous Air Pollutants”
VHAP – Volatile Hazardous Air Pollutant – the compounds on the 189 List that will volatilize. The 189 List contains heavy metals and  toxic inorganic compounds
NESHAP – Nation Emission Standard for Hazardous Air Pollutants – Federal limits for HAP emissions – EPA Rules
Where can I find the VOC limit in the regulations?
For Federal, VOC limits are found in the Air Regulations:
Click the EPA link  get to the home page
Click “Laws & Regulations”
Under “Regulatory Information by Environmental Topic”, click “Air”
Click “Air and Radiation: Regulation and Statute” to find a list of all Air programs regulated by the EPA
      For State Information:
Click on the State Environmental Agency link
Find the state of interest, this will bring you directly to that specific State Environmental Agency Homepage
Find key words such as Laws & Regulations or Air Programs to get to the regulations containing VOC regulatory information
Each state’s home page varies, the links to the Air regulations will be different
Try to find the Table of Contents for the Air regulations to help get you to the specific citation faster
Where can I find the VOC information on an MSDS?
Under Section 9: Physical & Chemical Properties, the VOC is listed in grams per liter. ITW Polymers Sealants North America has calculated the amount of VOC in each finished product by EPA Method 24 and by Photochemically Reactive Only.
EPA Method 24 is the required method of calculation for some specific State VOC limits, the calculation subtracts out exempt compounds and water.
Photochemically Reactive Only includes water and exempt compounds in the total volume of the product, typically this number is less than EPA Method 24.
If your state does not specifically require you to use EPA Method 24 calculation, use Photochemically Reactive Only.
How do I get rid of old, unused, expired or leftover adhesive, sealant, glue, caulk?
Check the label on the container to identify the product. Once you have identified the product number or name, obtain the most recent Material Safety Data Sheet (MSDS) by clicking into Product Lines. Check local Yellow Pages for licensed hazardous waste hauler, who could provide guidance for your specific region/area. The waste hauler will require a copy of the MSDS.What do I do with empty canisters?
As a greener alternative, we suggest that you return all empty canisters to the distributor that you purchased them from. ITW Polymers Sealants North America has a recycling program set up with distributors whereby the canisters are returned to a reclamation facility to be cleaned/recycled or are scrapped in a responsible manner.