The Household & Commercial Products Association’s (HCPA) Coordinator, Public Relations & Strategic Initiatives Manager, Jeremy Burke, provided comments on September 6 to the New Jersey Department of Environmental Protection (DEP) in Trenton, New Jersey.

In the comments, HCPA urged the DEP to use the Ozone Transport Commission (OTC) Consumer Products Model Rule Phase IV as the basis for any future amendments to the current Consumer Products Regulation.

Using the OTC Model Rule Phase IV, which is currently in place or being implemented in seven states, as the basis for future amendments to the New Jersey regulation will promote regional consistency and will enable the New Jersey DEP to achieve significant additional State Implementation Plan (SIP) creditable VOC emission reductions.

HCPA was an active stakeholder in the previous DEP rulemakings in 2003 and 2008. HCPA supports state regulations that are based on the OTC Model Rule as consistent regional regulatory standards enable improvements in air quality without impeding interstate commerce.

Please contact Joe Yost, Vice President, Strategic Alliances & Industry Relations, at for additional comments or questions.


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