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Ozone Transport Commission (OTC Rule)

The Ozone Transport Commision (OTC) is a multi-state organization created under the Clean Air Act to develop and implement regional soluations to the ground-level ozone problem in the Northeast and Mid-Atlantic regions. Current members include: Conneticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and Virginia. The controls placed on Architectural and Industrial Maintenance (AIM) coatings have been implemented in the OTC in the form of model rules which define the VOC content of various coating categories. Currently two model rules are available: Model Rule 2002 and Model Rule 2009-12. Each participating state independently elects to adopt a model rule. All states have adopted Model Rule 2002 with the exception of Vermont which still follows the EPA National Rule and Virgina for which only select areas have adopted. No states have yet adopted Model Rule 2009-12.

OTC Model Rule Exemptions:

  • Small container exemption allows the sale of coatings above maximum VOC limits if packaged in containers of one liter or less.
  • Sell-through proviison allows the sale of catings above the maximum VOC limits if manufactured prior to the individual state rule's effective data. The sell through period may range from three years to indefinite.

For the most current information on the OTC Model rule, please visit

For the individual state rules please visit the specific state environmental protection agency website.

Coating Category*

Model Rule 2002

Model Rule 2009-12

VOC (g/L)VOC (g/L)
Non-Flat High Gloss250150
Industrial Maintenance General340250
Industrial Maintenance High Temp420420
Quick Dry Primer200100
Specialty Primer350100
Quick Dry Enamel250150
Rust Preventative400250
Dry Fog400150
Waterproofing Sealer - Wood250275
Waterproofing Sealer - Concrete400100

*Category names are for comparison purposes between the various air districts only.

The actual name listed in specific rules may vary.

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