It has been almost 40 years since scientists and regulators
began to publicly recognize that volatile organic compounds
(VOCs) differ in their potential to form ozone. Since 1977, our
understanding of the mechanisms by which VOCs
contribute to ozone formation has grown substantially. An
assessment of the science indicates that we now have
sufficient understanding to develop and implement a more
efficient approach to VOC control policy that will promote
smarter, more cost-effective VOC controls. Furthermore, the
U.S. Environmental Protection Agency's recently published
Interim Guidance on Control of Volatile Organic Compounds
in Ozone State Implementation Plans “encourages States
to consider recent scientific information on the photochemical reactivity of volatile organic compounds (VOC)
in the development of State implementation plans (SIPs).”
As has been demonstrated by the California Air Resources
Board's Aerosol Coatings Rule and the recent experience in
Houston addressing high-reactivity VOCs, reactivity-based regulations may be more effective and efficient
than mass-based rules in many applications. It is time for
regulators, industry, and other stakeholders to work
together to accelerate efforts to bring about a new paradigm
in VOC control, in which the focus is on the ozone-forming potential of VOC emissions, rather than the mass
of VOCs emitted.