The Challenges of OTC Regulations

By: Tom Wunderlin, Induron Sales Representative

The paint and coatings industries have made strides toward reducing air pollution dating back to the 1980s. Current regulations have lowered the amount of volatile organic compound (VOC) emissions from coatings products in different regions and will continue to do so in the future. This discussion is based on a regional or national standard for achieving these air quality goals.

The Ozone Transmission Commission (OTC) is a gathering of states in the Northeast that have coordinated and aligned their air pollution regulations. OTC’s purpose is to focus on and develop regional VOC regulations to address and reduce ground-level ozone.

The OTC states include; Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Washington, D.C.  and the Northern Virginia suburbs of D.C.

OTC regulations apply to all manufacturers, distributors and retailers of architectural and industrial coatings within the region. The VOC limits vary according to a variety of coating categories. The OTC defines approximately 50 of these coating categories, which include some of the following:

  • Non-flat coatings (150 grams per liter) Acrylics / Polyurethanes / Epoxies / Alkyds
  • Primers, Sealers and Undercoaters (200 grams per liter)
  • Industrial maintenance coatings (340 grams per liter) – Defined as primers and topcoats formulated for application to surfaces that are exposed to one or more of the following extreme environmental conditions:
    1. Exterior exposure of metal
    2. Immersion in water or chemicals, or chronic exposure to interior moisture or condensation
    3. Exposure to harsh chemicals or fumes
    4. Repeated heavy abrasion or scrubbing
    5. Repeated exposure to temperatures in excess of 250 degrees

Many manufacturers are addressing and adapting to the OTC regulations by re-formulating existing coatings with exempt solvents, formulating very high solids products and researching new technology with water-based resins.

However, there are several issues associated with complying to the new OTC regulations, such as cost increases, possible temperature limitations and application challenges. For instance, the exact same product manufactured using different solvents occasionally has very different rheology and flow. Likewise, new VOC-exempt solvents must be researched and tested for in-can stability and long-term corrosion protection. Plus, coatings manufacturers are faced with the cost of carrying more SKU’s of similar products for different regions and several other factors that regulating agencies have minimized. Consequently, the cost of the solvents themselves coupled with the challenge they present to the R&D departments of coatings companies will likely cause cost increases. Unfortunately, one cannot buy time, so how to best address the unproven history of new formulations must be recognized in order to adapt to the changes in VOC regulation.

New raw materials, such as ceramics, microspheres and nanoparticles, are making a difference by demonstrating positive results, while old raw materials do not lend themselves to the new OTC compliant regulations. Manufactures must contend with the higher cost for new raw materials and exempt solvents, as well as additional R&D and inventory costs. Eventually, a significant portion of these costs are going to be passed on to the customer.

All in all, the paint and coatings industries have worked tirelessly to reduce VOC content and improve air quality, but states still need better tools to meet air quality goals and standardize regulations. Ozone is a chemical reaction where VOC’s are only part of the equation. In most cases, they are NOT the limiting factor, but we will save the chemistry conversation for another time.

Manufacturers will continue creating the solutions that will allow for lower emissions and better air quality. However, these efforts will be enhanced by a reasonable approach to regulation. Going forward, will there continue to be regional rules? Or will there be a national standard? Only time will tell.

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