Reactivity-based VOC control for solvent products: More efficient ozone reduction strategies

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.