Developing Odor Control Regulations: Guidelines and Considerations

Abstract

The TT-4 Committee developed a position paper on odor control regulations. Present odor regulatory approaches are considered generally to be unsatisfactory. There are two basic needs: 1. develop sound administrative procedures for establishing the existence of a community odor nuisance, and 2. obtain reliable odor sensory data that can be related to community acceptance or annoyance of a particular odor. Specific issues regarding administrative procedures for odor regulations are presented. These include establishing the validity of odor complaints and the existence of a community odor nuisance, based upon a specified number of valid complaints being received within a fixed time period. The existence of a community odor nuisance should be established before a compliance program is applied to an odor source. Technological needs for odor regulations are discussed. These include the development and testing of improved odor sensory measurement techniques, critical evaluation of atmospheric dispersion models to predict ambient odor concentration and relating ambient odors to annoyance thresholds for different communities or zoned areas. A suggested approach to odor control regulations is detailed. Specific procedures are provided for validating complaints, for establishing the existence of a community odor nuisance, for locating the alleged source (s) causing the odor problem and applying a compliance program to the source.The TT-4 Committee of APCA is primarily concerned with basic odor technology: its measurement, control, and regulation. Many of its members have contributed technical articles on odor regulations in recent years. 1 " 4 At the APCA Annual Meeting held in June 1974, a Critical Review of Regulations for the Control of Odors was conductedin cooperation with the TT-4 Committee. As a result of the discussions of this critical review, the Committee decided it would be helpful to develop a position paper on odor control regulations that would provide guidelines to agencies desiring to adopt such regulations. Initially, voluntary comments were solicited from the Committee members regarding two basic questions: 1. With the present state of the art in odor sensory measurement and other technology including odor control, what specific type of odor regulations would be the most feasible? 2. If the desired odor sensory measurement and other technology is available, what specific type of odor regulation would be the most feasible? For both questions, the respondent was asked to cite specific examples of odor sensory measurement and other technology to support the choice of odor regulations. Many diverse comments were received and a variety of issues was raised. These comments were incorporated into a first draft of the position paper which was circulated among the Committee members for additional comment. A later draft resulted from these comments. Two special meetings of the Committee were held in early 1977 to review the later draft and possibly to reach a consensus on specific issues.The total input towar...

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