A Study of the
 SOCIAL AND ECONOMIC
    IMPACT OF ODORS
          Phase III
  Final Report Prepared for the
ENVIRONMENTAL PROTECTION AGENCY
        February 1973
   COPIEY INTERNATIONAL CORPORATION

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SOCIAL AND ECONOMIC IMPACT OF ODORS
               Phase III

  DEVELOPMENT AND EVALUATION OF A
   MODEL ODOR CONTROL ORDINANCE
            Prepared for the

 ENVIRONMENTAL PROTECTION AGENCY
      Under Contract No. 68-02-0095
                  By
 COPLEY INTERNATIONAL CORPORATION
          7817 Herschel Avenue
        La Jolla, California 92037
  Contributions to this report were made by

    POPE, EVANS AND ROBBINS, INC.
            564 Market Street
     San Francisco, California 94104
             February 1973

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                 ACKNOWLEDGMENTS AND CONTRIBUTIONS
ACKNOWLEDGMENTS

       Copley International Corporation is grateful to the technical and legal staffs
of the following agencies and particularly to the persons identified for their valuable
assistance in supervising the application and evaluation of the "Procedures for the
Identification and Assessment of Community Odor Problems" and a tentative form
of the model odor control ordinance.

       * Messrs. John R. Valentine, Chief of Field Operations; and Victor N.
         Howard, Director; of the Pollution Control Division, City of Houston
         (Texas) Department of Public Health; and Mr. F. William Colburn,
         Senior Assistant City Attorney.

       • Miss Melinda Holland, Environmental Specialist; and Messrs.
         Robert H.  Mackenzie, Attorney; and Roger P.  Stewart, Director;
         of the Hillsborough County (Florida) Environmental Protection
         Commission.

       • Messrs. John E. Core,  Chief of Laboratory Services; Emory J. Crofoot,
         General Counsel; and Richard E. Hatchard,  Program Director; of the
         Columbia-Willamette (Oregon) Air Pollution Authority.

       • Messrs. Win. David Kebschull,  Section Head; and George P. Ferreri,
         Acting Director; of the Bureau of Air Quality Control,  State of Maryland
         Department of Health and Mental Hygiene; and Mr. Martin A. Ferris,
         Special Assistant, Attorney General.

       CIC acknowledges the cooperation of many private citizens of the jurisdic-
tions served by these agencies who gave generously of their time by participating
in personal interviews.  Without their wholehearted cooperation, this report would
not have been possible.

       CIC is especially grateful to Mr. Richard C. Dickerson of the Environmental
Protection Agency for his counsel and assistance  in the development and conduct of
the study, and to Dr. Donald G. Gillette and Mr.  Norman A. Huey of the same
Agency for their suggestions relating to previous phases of the research.

       The work upon which this report is based  was performed pursuant to
Contract No. 68-02-0095 with the Environmental  Protection Agency.


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CONTRIBUTIONS

       The overall responsibility of this study was undertaken by Mr. R. David
Flesh, Director, Environmental Economics, Copley International Corporation.
Others who contributed to this reported included:

       •  Dr. Amos Turk, Project Consultant and Professor, City College of
         the City University of New York.

       •  Messrs. James C. Burns,  Senior Staff Chemist; and P.M. Cohn,
         Vice President; of Pope, Evans and Robbins, Inc.

       •  Mrs. Marian O. Doscher,  Senior Industrial Economist; Mr. R. Paul
         Weddell, Senior Economist and Statistician; and Mmes. Linda E.
         Hanson and Victoria A. Jones, Manuscript Typists; of Copley
         International Corporation.
                                    -ii-

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                    TABLE OF CONTENTS
ACKNOWLEDGMENTS AND CONTRIBUTIONS	    i

LIST OF TABLES	    v

LIST OF FIGURES	   vii

CHAPTER

    I      INTRODUCTION	    1

              FIRST AND SECOND PHASES OF RESEARCH	    2
              DEVELOPMENT AND EVALUATION OF A MODEL
                 ORDINANCE	    4
              REFERENCES	    7

    II      DEVELOPMENT OF A MODEL ORDINANCE	    9

              LOGICAL EXTREMES OF ODOR CONTROL	    9
              PROCEDURES FOR THE ESTABLISHMENT OF A
                 VIOLATION	   11
              STEPS IN THE DEVELOPMENT OF A MODEL
                 ORDINANCE	   16
              NOTES	   18
              REFERENCES	   19

   III      EVALUATION OF A MODEL ORDINANCE	   21

              SELECTION OF THE AGENCIES	   21
              PERIOD AND RESULTS OF FIELD ACTIVITIES	   22
              EVALUATION OF THE PROCEDURES AND
                 TENTATIVE MODEL ORDINANCE	   30
              NOTES	   40
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                 TABLE OF CONTENTS (Cont'd)
CHAPTER

   IV     CONCLUSIONS AND RECOMMENDATIONS	   41

              CONCLUSIONS PERTAINING TO THE PROCEDURES . .   41
              CONCLUSIONS PERTAINING TO THE MODEL
                 ORDINANCE	   47
              OTHER CONCLUSIONS	   49
              RECOMMENDATIONS	   50
              REFERENCES	   53

APPENDICES	   55

APPENDIX

   A     SUMMARY OF ODOR CONTROL REGULATIONS
              ENFORCED BY 203 STATE AND LOCAL
              AIR POLLUTION CONTROL AGENCIES	   57

   B     REQUIREMENTS FOR AGENCY PARTICIPATION	  Ill

   C     INTERVIEW EXAMPLES USED TO TRAIN AGENCY
              PERSONNEL	  115

   D     EVALUATION FORM	  123

PROCEDURE MANUAL	  145
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                           LIST OF TABLES
Table

            CHAPTER III
            Comparison of socioeconomic characteristics of test and
            control areas surveyed by participating agencies	    24

            Public attitude survey information obtained by partic-
            ipating agencies for problem identification purposes  ....    25

            Number of odor complaints to participating agencies
            against sources suspected by agencies of causing odor
            problems  in test areas  (January 1972 through September
            1972)	    26
            CHAPTER IV

            Sequential sampling plan based on the proportion of
            residents in a combination of Houston control areas
            who stated they were bothered by odors (AOL = 0.233,
            OPL = 0.433, a  = 0.05, B = 0.05)	   43

            Sequential sampling plan based on the proportion of
            residents in a combination of Hillsborough County
            control areas who stated they were bothered by odors
            (AOL = 0.086, OPL = 0.247, a  = 0.05,  B = 0.05)	   43

            Sequential sampling plan based on the proportion of
            residents in a combination of Oregon control areas
            who stated they were bothered by odors (AOL = 0.167,
            OPL = 0.353, a =0.05,  3 = 0.05)	   44

            Sequential sampling plan based on the proportion of
            residents in a combination of Maryland control areas
            who stated they were bothered by  odors (AOL = 0.097,
            OPL = 0.260, a  = 0.05, 6 = 0.05)	   44
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                      LIST OF TABLES (Cont'd)
Table                                                              Page

            CHAPTER IV (Cont'd)

  8         Time that could have been saved by the use of a sequen-
            tial sampling technique in surveying test areas in which
            community odor problems were identified	   45
                                 -vi-

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                           LIST OF FIGURES
Figure

            CHAPTER II
            Stages of odor development	    12

            Tentative form of a model odor control ordinance (March
            1972 revision)	    17
            CHAPTER III

            Location of industrial complex and test area where City
            of Houston Department of Public Health conducted odor
            judgment panel evaluations	    28

            Mean odor intensity isopleths obtained by Hillsborough
            County Environmental Protection Commission by deploy-
            ment of an odor judgment panel in a small test area near
            Tampa, Florida	    29

            Modified scentometer system devised by the City of
            Houston Department of Public Health	    34
            CHAPTER IV

            Comparison of median home value and percent of respon-
            dents who were bothered by odors in test areas surveyed
            by the participating agencies	    51

            Comparison of median home value and percent of respon-
            dents who were bothered by odors in control areas surveyed
            by the participating agencies	    51

            Comparison of the percentage of respondents who noticed
            odors with the percentage of respondents who were bothered
            by odors in test areas surveyed by Copley International
            Corporation and the participating agencies	    52
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                                 CHAPTER I
                               INTRODUCTION
       Since the 1950's many advances have been made in the development of air
pollution controls,  with legal controls preceding and often forcing the development
of technological controls.  In this sequence of events the effectiveness of the legal
controls is the critical thing. It rests largely on the availability of equipment to
measure concentrations of pollutants and the existence of methodology to quantify
the  impact of these pollutants on human health and welfare.  Legal controls are
particularly effective when equipment can measure pollutants to concentrations
at which impact is determined to be unlikely.

       Progress toward the development of controls over all forms of air pollution
has not been consistent.  For example, the development of odor controls has been
encumbered by two major obstacles arising from the very nature of odor percep-
tion:

       (1)     The lack of equipment capable of measuring low concentra-
              tions of more than a few odorous substances and, coupled
              with this, the lack of methodology for translating known
              concentrations of such substances into odor intensities.

       (2)     The lack of methodology for quantifying impact in terms of
              odor intensities.

       These obstacles have been particularly frustrating to enforcement author -
ities whose job it is to relieve countless localized and widespread community odor
problems.  The magnitude of their frustration can be imagined with knowledge that
in many jurisdictions the number of complaints  about odors has approached the
number of complaints about all other forms of air pollution.  In all but a few juris -
dictions, however, research against these obstacles has been left for the federal
government to undertake.

       Under the Air Quality Act of 1967 and the Clean Air Amendments of 1970,
the  federal government embarked on a program to amass information relating to
the  sources, effects, measurements, and controls of odors and other acknowledged
air  pollutants. Numerous studies have already been performed under this program,
including the national survey of the odor problem, conducted in 1969; a study of the
social and economic impact of odors, conducted in  1970 and 1971; and the present
study,  conducted in 1972.  These studies investigated methods of identifying and
assessing community odor problems and culminated in the preparation of a model
odor control ordinance based on measurable impact.  The studies were conducted
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by Copley International Corporation for the Environmental Protection Agency under
contracts CPA 22-69-50, CPA 70-116,  and 68-02-0095.
FIRST AND SECOND PHASES OF RESEARCH

National Survey of the Odor Problem

       The overall objective of the first phase of research was an assessment of
the national odor problem using projections of the results of investigations in a
selected sample of potential odor problem areas. The presence of an odor prob-
lem was found to be dependent upon the existence of an odorous substance (or sub-
stances) emitted by a source (or sources),  an odor receptor population, and a
mechanism to transport the former to the latter. Thus,  in order to assess the
national odor problem, it was necessary to identify populated areas throughout
the United States with coincidence of high levels of three  basic factors:

       (1)     Industrial odor producing potential, represented by the
              number of operating industrial plants weighted by relative
              size of plant and detectability of odorants produced.

       (2)     Potential extent of odor reception, represented by the size
              of the population affected.

       (3)     Atmospheric vulnerability, represented by a composite of
              the major causes of impaired atmospheric dilution capacity.

       A sample of seven metropolitan areas was selected from a list of 31 found
to rank high in these factors.  The selection process took into consideration the
need for nationwide representation of the study results and detailed information on
likely odor problems solicited from the  local air pollution control agencies. At
least one community in each of the seven metropolitan areas was evaluated using
ambient air dilution devices called scentometers to measure the intensity and areal
extent of odors detected.  In one of the seven metropolitan areas — Philadelphia,
PA — an odor judgment panel was employed to determine intensity patterns of
odors caused by an oil refinery and an animal rendering plant.

       Lengthy public attitude surveys were conducted as an exploratory approach
to determine how community odors affect people. The surveys were designed to
determine if people are generally aware of odors in their communities,  if the pub-
lic is interested in the abatement of odors, if people believe they have suffered
socially or economically because of odors, and if differences in opinion about
odors exist between people living and working in suspected odor problem commu -
nities (test areas) and those living and working in odor free communities (control
areas).
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       The results of the study indicated that, although industrial odor producing
potential exists in most metropolitan areas of the United States, the probability
of encountering community odor problems is greater in the urban portions of the
Appalachian and Rocky Mountain Regions and the California Coastal Zone. Pro -
jecting the results of the attitude surveys to the nation as a whole suggested that
as many as 25 million residents perceived community odors as problems.

Social and Economic Impact of Odors

       The main objective of the second phase of research was the development of
procedures to identify community odor problems and to assess their social and
economic impact.  As in the first phase, a metropolitan area was selected from
the list of potential odor problem areas.  The areas were  established near a vari-
ety of sources to permit a comparison of the effects of odors having vastly different
qualities.

       Public attitude surveys and technical field studies were conducted in
December 1970, March 1971, and June 1971.  The public attitude  surveys were
designed to obtain data relative to the influence of odors on the attitudes of resi-
dents .  Small sample sizes were used to determine whether the survey method
could be used to obtain qu^ick and decisive answers about the existence of a variety
of possible odor problems.  The technical field studies were to employ sensory
techniques to systematically measure the intensity,  duration, frequency, and tem-
poral variation of odors for correlation with the results of the quarterly surveys
and to further compare the operational features of the techniques used in the
Philadelphia investigation.

       It was expected that the  national survey of the odor problem and the study of
the social and economic impact of odors would provide a series of relationships
that could be used in the development of legal controls over odors.  Yet, as this
and other research progressed, it became evident that the only measurable impact
associated with a vast majority of odor problems was annoyance and that a proper
means for dealing with such problems must consider the measurement of annoy-
ance as central to success.  Public attitude surveys were recommended as the
proper means for doing so.

       To simplify the requirements for odor problem identification, considera-
tion was given to the elimination of surveys in control areas.  The best possibility
of doing so was found by combining the results from the control areas previously
investigated.  Preliminary attempts indicated that the same combined results
could be used to reduce the effort required to survey test areas.  This reduction
of survey effort seems possible through sequential analysis under which one of
three decisions can be made:

       (1)    That an odor problem is identified.
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       (2)     That an odor problem does not exist.

       (3)     That the results are inconclusive and that an additional inter-
              view must be completed.

Availability of Final Reports

       Further details of the first and second phases of research may be obtained
by reference  to the final reports listed at the conclusion of this chapter.
DEVELOPMENT AND EVALUATION OF A MODEL ORDINANCE

Objectives and Methodology

       The ultimate objective of the present study was the preparation of a model
odor control ordinance that could be adopted and applied effectively by enforcement
authorities throughout the United States. To meet this objective the following tasks
were undertaken:

       (1)     Preparation of a tentative form of a model ordinance.

       (2)     Selection of four air pollution control agencies to evaluate
              the procedures developed in the second phase of research
              along with the model ordinance.

       (3)     Instruction of employees of the selected agencies in the
              proper use of the procedures in relation  to the model
              ordinance.

       (4)     Guidance of selected agencies'  project related field activities.

       (5)     Refinement of the procedures and the model ordinance for
              submission to the Environmental Protection Agency.

       The tentative form of the model odor control ordinance was prepared from
the responses of enforcement authorities solicited during the first and second
phases of research, a thorough review of pertinent legal controls proposed in
recent literature, and an analysis of existing and proposed odor control regula-
tions obtained from 203 jurisdictions.  Following the conclusions of the study of
the social and economic impact of odors, it was intended that the model ordinance
be made consistent with public nuisance law.

       Selection of the agencies for participation in the study was based on level
of government, geographic location, and interest in the study and control of odor
                                      -4-

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problems.  In addition, the officials in charge had to agree to complete minimal
requirements as described in a detailed work plan.  Final selection included:

       • City of Houston (Texas) Department of Public Health

       • Hillsborough County (Florida) Environmental Protection
         Commission

       • Columbia-Willamette (Oregon) Air Pollution Authority

       • State of Maryland Bureau of Air Quality Control

       Prior to the beginning of the field activities,  representatives of Copley
International Corporation and Pope, Evans and Robbins,  Inc., instructed agency
employees,  especially in the conduct of public attitude surveys and the use of sen-
sory techniques.  The field activities were continued for a period of eight months
and were directed by agency officials alone.  CIC and PER maintained advisory roles.
Questions posed by any of the agencies, along with the responses of CIC and PER,
were communicated to all of the agencies through a  series of project letters.

       Upon conclusion of the field activities, the procedures were evaluated by
agency employees in terms of ease of use, the information obtained in relation to
agency needs, and the costs involved.  The structure and content of the tentative
form of the  model ordinance were  examined by agency attorneys.

Principal Findings of the Present Study

       All modifications to the procedures and tentative model ordinance recom-
mended by the four participating agencies were considered. Many involved simple
refinements and were implemented without comment. Others, such as the following,
are discussed at length in this report.

       The  agencies held different opinions  about various aspects of  the applicabil-
ity of the procedures .  However, most of the agencies felt that the procedures
were not applicable to sparsely populated communities in which only  a few homes
are affected and to the measurement of the undesirable effects of odor on commer-
cial or industrial groups. Most of the agencies also felt that some of the tasks,
particularly the delineation of test and control areas and the training and deployment
of an odor judgment panel, are too cumbersome for routine application.

       The  first of these points is acknowledged. Without resorting  to a complex
analysis of small sample sizes, the residents of at least 20 (and preferably 30)
homes in each area must be successfully interviewed.  The second point is not
considered a shortcoming.  Based  on the  results of the national survey of the odor
problem, the procedures were designed for  use in measuring the undesirable
effects of odor on the most sensitive community group — residents.  It is further
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acknowledged that certain tasks are too cumbersome for purposes of routine sur-
veillance of chronic situations. However, three conditions were written into the
procedures (and the tentative model ordinance) to limit their use to possible odor
problems.

       The agencies had more critical comments about the tentative form of the
model ordinance.  For example, it was felt the model ordinance does not protect
small portions of the population and does not  provide for the accused to be con-
fronted by his accusers. One of the agencies felt that the  need to compare areas
of "similar socioeconomic characteristics" may give rise to discriminatory
application of the law among different socioeconomic classes.

       That the model  ordinance is not applicable to small portions of the popula-
tion, i.e.,  to residents of less than 20 homes, is again acknowledged.  The model
ordinance is  consistent with public nuisance law if it can be agreed that "any con-
siderable number of persons" must include the residents of at least 20 homes.  It
was not intended for the model ordinance to be applied for private means. The
difficulty of getting many test area residents  to appear in court as accusers seem-
ingly would be inversely related to the magnitude of the odor problem in their
community.  It may be partly or totally avoided by the use of a sequential sampling
technique or by adoption of the model ordinance as a statute, rather than enactment
as a form of public nuisance law.

       The need to match a control area to a test area by reference to the socio-
economic characteristics of the test area is only to insure that the population of
the control area would  be a reasonable representation of the population of the test
area. As a consequence, a measurement of the attitudes of the residents of the
control area  as a group would be a reasonable representation of the attitudes of
the residents of the test area as a group, except for any effect on the attitudes of
the latter group that is due to the presence of odors in the test area.  The possi-
bility that such a comparison may give rise to discriminatory application is aca-
demic in this context.

       Conclusions based on the experiences of all four agencies include the
following.  Although the procedures cannot be applied,  without modification, to
possible odor problems in residential areas of less than 20 homes or in commer-
cial or industrial areas, it is estimated that they can be successfully applied to at
least 80 percent of all possible odor problems.  Much time can be saved in apply-
ing the procedures by use of a professional real estate appraiser in the location
of suitable control areas and by use of a sequential sampling technique when
conducting public attitude surveys.  The use of an odor judgment panel is best
left to special circumstances where legal liability or compliance questions require
explicit documentation  of odorous emissions.

       From the evaluations of the participating agencies  and from a review of
the odor control regulations of 203 jurisdictions, it is concluded that a model
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ordinance cannot be drafted that is compatible with the legalistic approach to con-
trolling air pollution preferred by every jurisdiction. Thus,  emphasis in the
development of the recommended form of the model ordinance was given to a
conceptual framework that would promote the most efficient solutions to commu-
nity odor problems given the existing state of knowledge.
REFERENCES

Copley International Corporation. National Survey of the Odor Problem.  Publica-
       tion No. PB-194 376. Springfield, Virginia: U.  S. Department of Commerce,
       National Technical Information Service, 1970.

Copley International Corporation. National Survey of the Odor Problem:  Appendix.
       Publication No. PB-194 377.  Springfield, Virginia:  U.S. Department of
       Commerce, National Technical Information Service, 1970.

Copley International Corporation. A Study of the Social and Economic Impact of
       Odors, Phase II.  Publication No. PB-205 936. Springfield, Virginia: U.S.
       Department of Commerce, National Technical Information Service,  1971.
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                                 CHAPTER II
                  DEVELOPMENT OF A MODEL ORDINANCE
       This chapter is divided into three sections concerned with the composition
of an odor control ordinance.  The initial section presents a brief discussion of two
theses which represent the logical extremes of odor control and which are believed
to be appropriate for consideration in any highly developed society:

       (1)     That odor is not acceptable.
       (2)     That undesirable effects of odor are not acceptable.

Five procedures for the establishment of a violation are then compared in the sec-
ond section of this chapter:

       (1)     Measurement of odor intensity at the source.
       (2)     Measurement of key odorants at the source.
       (3)     Measurement of odor intensity in the ambient air.
       (4)     Measurement of key odorants in the ambient air.
       (5)     Measurement of the undesirable effects of odor.

The  final section outlines  the steps in the development of a model ordinance based
on the latter thesis under  the present study.
LOGICAL EXTREMES OF ODOR CONTROL

       As was reported at length in the national survey of the odor problem, en-
forcement authorities throughout the nation have urgent need for an effective odor
control ordinance.  Most of them were quick to admit this need and equally quick
to suggest what would be an "effective" odor law:

       (1)     It would be clear in intent.

       (2)     It would be applicable to all odor sources, with provisions for
              exceptions to be handled individually.

       (3)     It would specify a procedure for the establishment of a violation
              that would be not only simple and inexpensive to administer,
              but also recognized by the courts as a means for obtaining con-
              clusive information.
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       (4)     It would provide all potential offenders with a specific goal
              for compliance.

In short, an effective odor law would promote administrative efficiency. Although
idealistic as a whole, this suggestion reflects the reality that resources are scarce
for use in any comprehensive air quality control program.

       Considering this suggestion, it is not surprising that enforcement authorities
have rejected numerous proposals by researchers, which require complex and labo-
rious investigations and which, in the final analysis, seem arbitrary for deciding
whether or not human health or welfare has been impaired.  Neither is it surpris -
ing that they have discredited the use of complaint information which is often
unreliable and, instead, have turned toward the thesis that odor is not acceptable
to society.

       The advantages of a no-odor ordinance are obvious.  It is clear in intent
and universally applicable.  One regulatory agency employee or, at worst, a small
panel of agency representatives can be used to  decide whether or not a violation
exists.  Dilution equipment may be required, but only  if odors are to be evaluated
from  stack samples rather than in the ambient  air.  It provides  a specific goal for
compliance.

       The drawbacks of a no-odor ordinance are not so obvious. Most important-
ly, the validity of the thesis has never been established.  In addition, the courts
must  permit discretionary application; otherwise, resources must be consumed
in the investigation of every alleged odor in town.

       That it is difficult to develop an effective odor control ordinance might be
imagined by noting the variety of existing and proposed regulations summarized
in Appendix A of this report.  It is felt that part of this difficulty is due to a wide-
spread misconception of odor itself, which is manifest hi the classification of odor
as a form of air pollution. Odor is not a form  of air pollution; it is an effect of
air pollution.  Thus, odor was defined at a recent international symposium on
environmental health as "the product of the activation of the sense of smell, an
olfactory experience," caused by "any chemical compound which can stimulate
the olfactory (smell) sense. "z

       It is felt that a further part of this difficulty is  the tendency of many persons
to equate the perception of odor with the existence of a problem.  Rather, it is per-
sonal evaluations of those who perceive odor, not the mere activation of the sense
of smell, which may give rise to the problem dimension.  This distinction is neces-
sary to explain why some odors are considered pleasant,  while other odors or the
same odors experienced under different conditions are considered unpleasant even
to the extent of causing undesirable (secondary) effects such as feelings of annoy-
ance.
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       As the study of the social and economic impact of odors and other research
progressed, it became evident that the most measurable impact associated with a
vast majority of odor problems was annoyance.   In fact, while bother from odors
was found in some test areas? without other undesirable effects being detected, the
reverse was never encountered.  This evidence suggested that a proper means for
dealing with such problems would be a law developed on the thesis that undesirable
effects of odor are unacceptable to society.  The measurement of annoyance would
serve as a convenient indicator of the existence of undesirable effects and, thus,
as a basis for deciding whether or not a violation exists.

       There are several advantages to a no-ill-effects ordinance.  Although the
intent of such an ordinance  may be more difficult to understand, it is universally
applicable.  Measurements would be aimed at the problem dimension. Since at
least the fifteenth century A.D., sources of annoyance  to any considerable number
of persons have been recognized by the courts as illegal under the tenets of public
nuisance law. The focus of technological controls on the annoyance threshold rather
than the odor threshold would very likely result in more efficient solutions when
taking into account the societal consideration that the added cost of control should
equal the added benefit derived from that control.

       There are also several drawbacks to such an ordinance.  Most regulatory
agencies would have to acquire new skills in the use of  behavioral science tech-
niques .  While these techniques are no more complex than many traditional tech-
niques used in the evaluation of odors or  odorous  substances, they are not yet
recognized by the courts as a means for obtaining conclusive information. In
addition, the adoption of this thesis would not give offending sources a specific
goal for compliance.
PROCEDURES FOR THE ESTABLISHMENT OF A VIOLATION

       Regardless of the odor control thesis adopted, a procedure must be speci-
fied for the establishment of a violation.  As shown in Figure 1, there are three
distinct stages in the series of events beginning with the production of odorous
substances (odorants) at a given source and ending with the culmination of effects
on the people in the neighboring community. Five  such procedures, involving
measurements at the stages depicted, are discussed below. Each has the scien-
tific endorsement of various researchers.

       Other possible procedures exist, such as the  use of complaint information,
which may be simpler and cheaper to administer but  lack scientific merit.  These
possibilities are not included in this report.
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Figure 1.    Stages of odor development.
   Atmosphere:  transport mechanism in which
   diffusion and chemical reactions take place
       Source
Stage 1:  Production
of odorants
                                    _V
   Ambient air
   in neighboring
   community
  Minds of the
  people exposed
Stage 2:  Perception
of odor
Stage 3:  Evaluation
of odor
Measurements at the Source (Stage 1)

       Procedures involving measurements at the source do not provide a direct
appraisal of any undesirable effects arising in Stage 3.  Ideally,  such procedures
are used with knowledge of what levels of odorants are associated with the occur-
rence of undesirable effects in the neighboring community.

       Diffusion modeling has been employed to predict the dilution between Stages
1 and 2 under various conditions. In doing so, it has been necessary to  consider
the interactions between different emissions as well as average stack height, aver-
age distance from source to community,  and average meteorological conditions.
From these inputs,  average dilution figures have been obtained.  Diffusion model-
ing has also been employed to provide more precise dilution figures for  a given
source under given sets of input conditions.

       Because odors are often encountered well beyond the distances predicted by
the diffusion models,  safety factors have often been included in the estimates of
dilution capacity. The disparities between empirical results and the diffusion
models are thought to be due to reactions of the odorants in transit, such as ad-
sorption on particulates, or to transient peaks that initiate nuisance responses.

       Despite the limitations alluded to above, measurements at the source offer
special advantages.  They are closest to the point at which odor abatement equip-
ment usually operates.  Thus, they provide the fastest and most  direct feedback
information for abatement purposes.  In addition, although an emission may contain
many chemical substances, only a few may contribute to any odor the emission may
cause.  The identification and continued monitoring of key odorants may be possible
from concentrated samples obtained at the source, while it may not yet be possible
to do so from less concentrated samples taken from the ambient  air.
                                     -12-

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       Measurement of Odor Intensity at the Source.   This procedure requires
the collection of a sample for sensory evaluation.  Although direct sensory evalu-
ation of emissions is precluded because of the high odor intensities, high temper-
atures, and toxicity of the emissions that are usually encountered, indirect
measurement of odor intensity can be achieved safely through the controlled
distribution of a sample. The benefit of this safety feature may be offset, how-
ever, by chemical and physical reactions that occur within the sample.

       The odor characteristics of a sample may change because of the inherent
instability of many highly odorous substances, the interactions of the odorants
with the container walls or with other substances  that may be present, or physical
changes such as cooling which may produce condensation and draw some odorants
into solution.  To avoid,  or at least to minimize these changes, the sampling pro-
cess must be carefully chosen and monitored.  One popular method of monitoring
is chromatographic analysis which is performed immediately upon collection of
the sample and repeated just before subsequent dilution for sensory evaluation.

       After a sample is collected, a measurement of odor intensity is obtained
in an odor free environment by a panel of trained  judges.  The panelists have been
previously screened with reference standards to establish that they possess  an
adequate sense of smell and a high degree of reproducibility in judging odors of
similar quality to those caused by the source under investigation.  The measure-
ment is performed either by computing the number of volumes of odor free air
necessary to  reach the recognition odor threshold (i.e.,  the lowest intensity at
which a panelist can positively identify the odor quality of the sample) or by com-
paring the sample to an odor intensity reference standard scale.  When this  is
completed, the amount of dilution with odor free air necessary to reduce the odor
intensity of the sample to a desired level can be determined.

       Either static or dynamic  dilution to threshold techniques  can be used in this
work.  Static techniques involve  the preparation of fixed dilutions for separate pre-
sentation to the panelists.  Dynamic techniques employ a device for selected mixing
of deodorized air with a collected sample for almost continuous presentation to the
panelists or to the operators of the device. ^

       It is noted that the adoption of procedures  for the measurement of odor
intensities at the source is a fairly recent occurrence.  However, sensory evalu-
ations  have been performed occasionally for many years in connection with the
odor reduction efficiency of certain abatement devices.

       Measurement of Key Qdorants at the Source.  This approach is more
attractive to regulatory agencies and industry  since sensory evaluations are not
involved. Instrumentation can be adapted to deal  with high temperatures,  and
instruments are unaffected by high odor intensities or toxicity.   However, this
approach suffers from not dealing with odors directly and from reliance on two
que stionable as sumptions:
                                      -13-

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       (1)     That the composition of an emission is fairly constant and,
              as a result, the substances identified as key odorants and
              selected for monitoring remain the key odorants at all times.

       (2)     That any equipment used to abate the key odorants will be
              equally effective in removing the minor odorants entrained
              in the  emission.

       Considerable  exploratory work must be done unless the emissions of the
source under investigation are well known. Once the key odorants and their con-
centrations have been identified, analytical methods must be developed to measure
them without obtaining erroneous results due  to interferences from other substances
that may be present. If the analytical method devised is suitable for automation,
the key odorants can  be monitored continuously with minimum attention.  However,
in many cases this is not possible and more tedious wet-chemical analyses give the
only alternative.  In  such cases, the attractiveness of the approach is seriously
diminished.

       To date,  this  procedure has been adopted by only one agency for use begin-
ning in Fall  1973.  Consequently,  its effectiveness must be reported here as
unknown.

Measurements in the Ambient Air (Stage 2)

       Ambient odor measurements are generally direct sensory evaluations un-
hindered by high intensity, high temperature, and toxicity constraints.  However,
such measurements still do not reflect any undesirable effects arising in Stage 3.
Procedures involving such measurements are best used with knowledge of what
levels of odors are associated with the occurrence of undesirable effects in the
neighboring community.

       Measurement of Odor Intensity in the Ambient Air. This  procedure also
depends on sensory evaluation.  Once again, the measurement is performed either
by computing the number of volumes of odor free air necessary to reach the recog-
nition odor threshold or by comparing the intensity of the odor to a reference stan-
dard scale.  To date, most ambient air investigations have used the  dilution to
threshold option. 6

       The way in which the dilution is performed is particularly important with
ambient odor measurements because of the transient nature of the odors.  The
diffusion which occurs between the source and the neighboring community often
causes the odorants to be distributed in the air in a manner that a trained judge
placed in the area  perceives the odor as a series of pulses, each lasting only a
few seconds, even when the emissions from the source are continuous and fairly
constant  in composition and concentration.
                                     -14-

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       Thus, when choosing a dilution method it is important to consider whether
average or peak values are to be obtained.  If average values are of importance,
the air must be sampled over a significant period of time.  The sample is then
used for sensory evaluation.  If peak values are of importance, a dilution device
must be set to permit mixing of large volumes of deodorized air with ambient air
so that only the presence or absence of peaks can be detected. The detection of
peaks rather than the measurement of average values is preferred in communities
where transient odors are encountered.

       A practical procedure for using a dilution device to establish violations of
prescribed ambient odor  limits is to adjust the device so that only one dilution
level is used,  which would permit the detection of any odor of an intensity beyond
that prescribed.  By monitoring the diluted  air in this manner, a violation is re-
corded whenever odor is  perceived.  Several  enforcement authorities presently
use this approach.

       The option of comparing ambient odor intensities to a reference standard
scale is best suited for use with transient odors.  In this way, the measurement
of peak values can be  achieved without the danger that odors of constant intensity
might cause a reduction in the sensitivity of the panel of trained judges. Because
of the ability of judges to respond to abrupt changes in odor intensity,  this method
has been used successfully to describe odor distribution patterns in test areas.
However, this approach has not been used for the establishment of a violation
because of the additional work involved in preparing reference standards. Fear
of uncertainty in accurately evaluating odor intensities away from the laboratory
environment in the variable background conditions which are encountered in test
areas has also been a factor.

       Measurement of Key Odorants in the Ambient Air.   Research is being
conducted into methods for measuring ambient concentrations of various chemical
substances. A procedure for the measurement of key odorants in the ambient air
seems possible for odorants that can be measured down to concentrations corre-
sponding to the odor recognition threshold.  At present, no such procedure exists.

Measurement of Undesirable Effects (Stage 3)

       Undesirable (secondary) effects of substances that activate the sense of
smell include feelings of annoyance, discomfort, and repulsion.  These are ex-
hibited in complaints and, in extreme cases,  more costly actions such as seeking
medical assistance, refusing to conduct business in a community, or moving away
from a community.  As mentioned above  with regard to previous research, while
annoyance due to odors was found in some test areas without other undesirable
effects being detected, the reverse was never encountered.  The measurement of
annoyance would serve as a convenient indicator of the existence of undesirable
effects and, thus, a procedure for the measurement of annoyance would provide a
means for deciding whether or not a violation exists.
                                      -15-

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       A few approaches have been advanced,  especially by regulatory agencies,
for gauging malcontent in communities affected by odors.  However, to the extent
that they rely on certain numbers of voluntary complaints from persons who pur-
port to be bothered by odor or to the extent that they specify an arbitrary percentage
of persons in a community to be bothered by odors for a violation to be established,
such approaches are without scientific support.  Although the  techniques of mea-
surement are chosen with a proper concern for viewing the problem dimension at
Stage 3, they do  not provide assurance that any outcomes attained reflect the true
feelings of those who have complained or of those who may have been polled.  In
short, they produce outcomes that are totally subjective .  There is, however,  a
procedure for the measurement of annoyance that, within a known probability of
error, does provide scientific support in the establishment of a violation. Major
aspects of this procedure are described in the remaining chapters of this report.
STEPS IN THE DEVELOPMENT OF A MODEL ORDINANCE

       A tentative model ordinance against undesirable effects of odor was pre-
pared under the present study from the following sources of information:

       • The responses of regulatory agencies to questions relating to odor
         control measures that were collected by Copley International
         Corporation under the first phase of research.

       • The opinions and suggestions of regulatory agency officials
         expressed informally to representatives of CIC and Pope,
         Evans and Robbins, Inc., during the second phase of research.

       • A thorough review of proposed odor control ordinances pub-
         lished in recent literature.

       • A thorough review of existing and proposed odor control ordi-
         nances obtained from 203 state and local air pollution control
         agencies throughout the nation.

       It was from the latter  source  of information that the tentative structure was
formulated. Copies  of existing and proposed ordinances were obtained by  mail.  A
summary of the conditions) necessary for violation and the prohibitions) and con-
trol requirements) specified  in the ordinances supplied by these agencies  is pre-
sented in Appendix A.

       As shown in Figure 2, the tentative structure contained three sections
stating definitions, the general provision, and the procedural establishment of a
violation.  Three of the six definitions  — viz., "chronic situation," "community
odor problem, " and "odor free community" — were aimed at the specialized ter-
minology of the "Procedures for the Identification and Assessment of Community
                                     -16-

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Figure 2.   Tentative form of a model odor control ordinance (March 1972 revision).	

SECTION I - DEFINITIONS

Chronic Situation - A causation of odors to  persons beyond the property limits of a source occurring more
       than once or lasting more than one day in any three month period.  Causation shall infer continued
       emission of odorous substances into the atmosphere by the source, not merely a result of impaired
       atmospheric dilution capacity.

Community Odor Problem  - A condition which is  said to exist when it has been determined,  by public  attitude-
       surveys of randomly selected samples of  residents, that a significantly greater proportion of respon-
       dents in a community state they were bothered by odors than respondents of an odor free community
       of similar socioeconomic characteristics.

Odor - Perception of smell, referring to the experience.

Odor Free Community  - A community from which no odor  complaints have been received by local authorities
       and in which no odors have been detected  by  local authorities during the past twelve  months.

Odorous  Substance - A substance that stimulates the olfactory  receptors and, thus,  causes  odor.

Person -Any person, firm, association, organization, partnership, business trust, corporation, company,
       contractor, supplier, installer, user, or owner, or any state or local governmental agency or public
       district, or any officer, agent, or employee thereof.

SECTION II - GENERAL PROVISION

       No person shall permit, cause, suffer, or allow the emission of odorous  substances into the atmos-
phere that would result in a community odor problem from any source under his  control.

SECTION III - PROCEDURAL ESTABLISHMENT OF A VIOLATION

       Violation of this ordinance shall be established by identification of a community odor problem. Such
identification shall be undertaken by the air quality enforcement agency serving this jurisdiction in accordance
with the "Procedures for the Identification and Assessment of Community Odor Problems/'  prepared for the
Environmental Protection Agency under Contract No. CPA  70-116, dated November  1971.*

       Odor problem identification  shall require:

       (A)     the existence of a chronic situation as defined in SECTION I of this ordinance,  and

       (B)     the existence of any of the following conditions:

              (1)     if one or more odor complaints are initiated by residents of a community and
                     verified by local authorities after the first day of the first occurrence in any
                     three month period, or

              (2)     if twenty or more odor  complaints are initiated by residents of a community, but
                     not verified by local authorities after the first day of the first occurrence in any
                     three month period, or

              (3)     if odors are detected in a community by  local authorities on more than one day
                     in any three month period (such odors shall be of sufficient intensity to  bo de-
                     tected using a Barnebey-Cheney Model 1-3  Scentometer set at 7 dilutions to
                     threshold), and

       (C)     the determination, by public attitude  surveys of randomly selected samples of adult resi-
              dents that a significantly greater proportion of respondents in the community state they
              were bothered by odors than respondents in an odor free community of similar socio-
              economic characteristics.

'These procedures may be found in the last section of the final report of the  second  phase of research.  They
 are essentially identical to those provided in the last section of this report.
                                                 -17-

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Odor Problems," which were incorporated by reference.  The remaining defini-
tions and the general provision were modeled after those  obtained by mail. The
procedural establishment of a violation was intended to be consistent with public
nuisance law.  However,  rather than to rely solely on the expressions of annoy-
ance of "any considerable number of persons, " this section was made to further
require comparative measurements of annoyance in test areas and matching con-
trol areas in order to ensure the objectivity of any results obtained.

       Extensive evaluations of this proposed regulation  were conducted by the
legal staffs of four air pollution control agencies.  The criteria used in the selec-
tion of these agencies and the substance of their evaluations are discussed in the
next chapter.
NOTES

        An excellent example of interest in a no -odor ordinance is found in a pro-
posed "Regulation VI, Control of Emissions of Odors From Stationary and Mobile
Sources, " dated September 2, 1971 . This proposed ordinance was developed by
the Air Management Services, City of Philadelphia, Department of Public Health.
The general provision stated that,  "No person shall permit, cause, suffer, or
allow the escape of odor, as defined in Section I of this Regulation, to the atmos-
phere." Odor was defined in Section I  as, "Smells or aromas which are unpleasant
to persons, or which tend to lessen human food and water intake, interfere with
sleep,  upset appetite, produce irritation of the upper respiratory tract, or create
symptoms of nausea, or which by their inherent chemical or physical nature, or
method of processing, are or may be detrimental or dangerous to health .  Odors
and smell are used herein interchangeably."  Finally, the procedural determina-
tion of an odor violation stated that, "A scent shall be a violation of this Regulation
when a certified agent of the Department senses this scent and determines it to be
an odor . "
       o
        The Third Karolinska Institute Symposium on Environmental Health,
"Methods for Measuring and Evaluating Odorous Air Pollutants at the Source and
in the Ambient Air, " Nordisk Hygienisk Tidskrift, LI (1970), 16 .
       3
        This evidence is consistent with the Symposium finding that, "In environ-
mental health the most important dimension of an odor is probably its acceptability,
e.g., what percentage of the population is annoyed by the smell."  Ibid , , 30.
            use of complaint information is criticized in the final report of the
study of the social and economic impact of odors .

        Among the most widely recognized methods for the measurement of odor
intensity from samples obtained at the source are the static  techniques of the
American Society for Testing and Materials,  Benforado et al. , Mills et al. , and
                                      -18-

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Turk and the dynamic techniques of Hemeon Associates and Sanders et al.  With
regard to the dynamic techniques,  the vapor dilution devices developed by Hemeon
Associates and Sanders et al. are  sufficiently portable to permit sensory evalua-
tions in the field.

       "The measurement of odor intensity in the ambient air has been accom -
plished on numerous occasions by  Pope, Evans and Robbins, Inc., using the
dynamic technique of Huey et al. and the odor judgment panel technique of Turk.
REFERENCES

American Society for Testing and Materials. "Standard Method for Measurement
       of Odor in Atmospheres (Dilution Method)." Designation: D 1391-57 (1957).

Benforado, D. M., Rotella, W. J., and Horton, D. L.  "Development of an  Odor
       Panel for Evaluation of Odor Control Equipment, " Journal of the Air  Pollu-
       tion Control Association, XIX,  No. 2 (February, 1969),  101-105.

Hemeon, Wesley C. L.  "Technique and Apparatus for  Quantitative Measurement
       of Odor Emissions," Journal of the Air Pollution Control Association, XVIII,
       No. 3 (March, 1968), 166-170.

Huey, Norman A., Broering, Louis C.,  Jutze, George  A., andGruber,  Charles
       W. "Objective Odor Pollution Control Investigations," Journal of the Air
       Pollution Control Association, X, No. 6 (December,  1960),  441-446.

Mills,  John L., Walsh, Robert T., Luedtke, KarlD.,  and Smith, Lewis K.
       "Quantitative Odor Measurement," Journal of the Air Pollution Control
       Association, XIII, No. 10 (October,  1963), 467-475.

Sanders, George R., Umbraco, Russell A., Twiss,  SuzAnne, and Mueller, Peter
       K.  "The Measurement of Malodor in a Community By Dynamic Olfacto -
       metry."  Paper presented at the Conference on  Methods for Measuring
       and Evaluating Odorous Air Pollutants at the Source and in the Ambient
       Air, Stockholm, June 1-5,  1970.

Turk, Amos.  "Odors," in Treatise on Analytical Chemistry, Part 3, Vol.  2
       (Analytical Chemistry in Industry). I. M.  Kolthoff, Philip J. Elving,  and
       FredJ. Stross (eds.), (New York: John Wiley & Sons, Inc., 1971),  177-
       198.

Wittes, Janet, and Turk,  Amos.  "The Selection of Judges for Odor Discrimination
       Panels," Correlation of Subjective-Objective Methods in the Study of Odors
       and Taste. Special Technical Publication No. 440, American Society for
       Testing and Materials,  1968, 49-70.
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                                 CHAPTER III
                   EVALUATION OF A MODEL ORDINANCE
       To achieve the ultimate objective of the present study, it was necessary
to select a few air pollution control agencies to appraise the usefulness of the
"Procedures for the Identification and Assessment of Community Odor Problems"
as a means for  deciding whether or not violations exist.  Because of the prelimi-
nary stage at which the tentative version of the model odor control ordinance was
supplied to these agencies and because there was insufficient time to tailor it to
the legislative customs of their respective jurisdictions, the model ordinance was
not enacted.  Neither was it nor were the results obtained from applying the pro-
cedures to actual chronic situations given to the courts for review and opinion.
Instead, the evaluations were made the responsibility of the technical and legal
staffs of the agencies themselves.

       The purpose of this chapter is to highlight these  evaluations.  The chapter
is divided into three sections. The first section describes the selection of the
agencies to participate in the study.  The second section establishes the context
from which each agency drafted its evaluation. The substance of the evaluations
is then presented.
SELECTION OF THE AGENCIES

       The following criteria were used in the selection of agencies for participa-
tion in the evaluation program:

       •  First consideration was given to geographic location. Although
          representation of different regions of the United States was
          thought important,  location in metropolitan areas having num-
          erous possible community odor problems was thought most
          important.

       •  Following this,  only agencies with known involvement in the
          study and control of community odor problems were contacted.

       •  Of those contacted,  agencies with an initial interest in the pro-
          gram were sent the requirements for participation and detailed
          work plan shown in Appendix B.  Selection was made among
          agencies  whose directors expressed willingness to complete
          these requirements.
                                     -21-

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       •  Last consideration was given to the level of government at which
          the agencies served the public.  While the procedures were meant
          to be applicable to the needs of all agencies operating at the local
          level, it was thought desirable to  ensure this applicability.

       Information obtained during the national survey of the odor problem and the
study of the social and economic impact of odors made easy the satisfaction of the
first two criteria. Fifteen agencies were contacted and acquainted with the purpose
and scope of the program.  Several agencies, although interested, declined to par-
ticipate owing to a shortage of available manpower.  Others, largely for reasons
discussed in Chapter II, had adopted the thesis that odor is not acceptable to society
and were not open to alternate proposals.

       Eight agencies were sent the requirements for participation along with copies
of the tentative form of the model ordinance and the procedures.  Four of these were
finally selected:

       •  City of Houston (Texas) Department of Public Health
       •  Hillsborough County (Florida) Environmental Protection Commission
       •  Columbia-Willamette (Oregon) Air Pollution Authority
       •  State of Maryland Bureau of Air Quality Control

It is noted that they represented progressively higher levels of government, includ-
ing a city, county, multicounty (or regional), and state authority.

       Prior to the beginning of the project related field activities,  representatives
of Copley International Corporation and Pope, Evans and Robbins, Inc., instructed
agency employees in performing such procedural tasks as the delineation of test
and control areas, analysis of public attitude survey results, proper use of the
scentometer, and training and deployment of odor judgment panelists.  Simulated
telephone interviews were used to train agency employees in preparation for con-
ducting public attitude surveys.  Transcribed examples of these interviews are
given in Appendix C.  In addition to providing instructional assistance to the agen-
cies, these meetings provided CIC and PER  with assurance that the agencies
possessed the skills necessary to complete the requirements of the program.
PERIOD AND RESULTS OF FIELD ACTIVITIES

       The field activities began in January 1972.  They were planned to continue
for a period of six months during which time each agency was to conduct a minimum
of six sets of surveys (i.e.,  six surveys in test  areas and six in matching control
areas) in accordance with the procedure for problem identification.  Source verifi-
cation was to be required for each test area in which an odor problem was identified.
However,  to compensate for an unexpected lack of odor problems during the first
few months in Oregon and Maryland and to permit four additional surveys as well
                                      -22-

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as odor judgment panel work to be conducted in Houston and Hillsborough County,
the field activities were extended to a period of eight months.

       The field activities were directed by agency officials alone.  CIC and PER
maintained advisory roles.  Questions posed by any of the agencies, along with
the responses of CIC and PER were communicated to all agencies through a series
of project letters.   During the eight months, a total of 26 questions were asked.
The frequency distribution of the questions indicated the existence of a problem
identification learning curve which, for most of the agencies, extended through
the second set of public attitude surveys.

       The results  obtained by the agencies are mainly important to the extent
that they establish the context of the subsequent evaluations.  The results are
summarized in Table 1, which compares the socioeconomic characteristics of
the test and control areas surveyed, Table 2,  which shows the survey information
obtained for problem identification purposes, and Table 3,  which shows the num-
ber of odor complaints made against the suspected sources during the field activi-
ties.

       Each of the agencies investigated many communities in search of possible
odor problems and delineated test areas in communities where the possibilities
seemed greatest. Matching control areas were then located. A total of 28 sets
of public attitude surveys were conducted in these areas.  As can be seen in
Table  2, 17 community odor problems were identified from the results of these
surveys (6 by the City of Houston, 6 by  Hillsborough County, 1 by Comumbia-
Willamette, and 4 by the State of Maryland).

       The method  of source verification was not specified in the requirements
for participation, although two sensory  techniques — one using a Barnebey-Cheney
Model 1-3 Scentometer, the  other employing an odor judgment panel trained to
evaluate an odorized environment in terms of memorized reference standards —
were described extensively in the procedure designed to assist in this undertaking.

       The complexity of investigation required to prove that a particular source
causes an odor perceptible to residents of a test area is primarily a function of
the number and types of sources situated within a few miles radius of the test
area.  Where the quality of the odor is characteristic of a particular industry  and
where only one plant of that industry is  located near the test area, the source  can
be easily pinpointed. However, when the quality of the odor is not well known or
numerous plants are clustered near the test area,  source verification can be an
extremely difficult undertaking.  All the odor problems identified by three of the
agencies were of the former type where the agencies felt that detection of the odor
followed by a brief  reconnaissance of the community was sufficient to locate the
source and provide  positive verification.  Only in Houston were the odor problems
identified in the vicinity of a number of  possible sources.
                                      -23-

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       Table 1.
to
Public Attitude
Survey Set No. T.
1 1
2 2
3 2
4
-------
able 2. Public attitude
jrposes .
jblic Attitude
No.
survey information obtained by participating agencies for problem identification
. of Interviews No . of Respondents Who
Completed Were Bothered By Odors
jrveySetNo. Test Area Control Area Test Area Control Area
Value of Normal
Deviate, z*
Odor Problem
Index
ity of Houston Department of Public Health
1
2
3
4(a)
5
6(c)
7(b)
8(d)
illsborough County
1
2
3
4
5
6
7
8
50
58
51
37
40
31
38
29
36
44
37
29
56
36
38
33
18
27
25
22
29
16
22
15
13
12
12
6
14
7
5
3
-0 01
1.98
1.56
3.15
4.61
2.79
4.07
3.69
—
3.8
--
6.1
7.2
5.7
5.7
6.9
Environmental Protection Commission
30
22
22
20
27
21
22
30
lolumbia -Willamette Air
1
2(a)
3
4
5(b)
6
31
30
30
30
30
31
tale of Maryland Bureau
Ha)
2
3
4
5
6(b)
30
30
32
31
30
30
29
25
16
30
27
29
23
30
Pollution Authority
30
30
30
30
30
30
of Air Quality Control
30
33
35
30
33
34
25
8
3
5
21
9
10
10

9
12
8
9
9
10

8
15
12
12
18
10
4
2
3
3
3
1
0
2

5
5
3
5
6
6

8
0
5
1
1
4
5.34
2.37
-0.43
1.42
4.75
3.44
3.66
2.58

1.15
2.01
1.61
1.22
0.89
1.08

0.00
4.65
2.20
3.37**
4.92
1.56
5.7
5.0
--
--
4.1
8.3
7.0
3.6

..
5.2
--
--
--
--

	
7.3
4.9
7.9-
5.8
— _
,'ote: Letters shown in parentheses after the survey set numbers refer to the initial and replicate sets of
urveys conducted in the same test and control areas.  For each of three agencies,  set b is a replicate of
et a and, for one agency, set d is a replicate of set c.
  If the value of the normal deviate, z.  equalled or exceeded 1.65,  a community odor problem was said to
  exist. '
  Values of the normal deviate and odor problem index were adjusted to exclude control area responses
  about odors from a sewer line damaged in June 1972 by hurricane Agnes.
                                                -25-

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Table 3.  Number of odor complaints to participating agencies against sources suspected by agencies of
causing odor problems in test areas (January 1972 through September 1972*).
No . of Odor Complaints

Public Attitude
Survey Set No .


Source(s) of Odor
Against
From All
Persons
Sources)
From Residents
of Test Area
City of Houston Department of Public Health
1
2
3
4(a)
5
6(c)
7(b)
8(d)
Hillsborough County
1
2
3
4
5
6
7
8
Sanitary landfill
Asphalt and pesticide manufacturing
Refineries and rubber manufacturing
Pesticides and general chemical manufacturing
Refineries and rubber manufacturing
Rubber manufacturing
Pesticides and general chemical manufacturing
Rubber manufacturing
Environmental Protection Commission
Sewage treatment plant
Fertilizer manufacturing
Barbecue restaurant
Citrus processing plants
Natural organic decomposition (Hillsborough Bay)
Asphalt manufacturing
Natural organic decomposition (Hillsborough Bay)
Natural organic decomposition (Hillsborough Bay)
2
3
88
N.A.
88
88
N.A.
88

3
9
1
N.A.
1
N.A.
1
1
2
2
35
N.A.
35
32
N.A.
32

1
5
1
N.A.
0
N.A.
0
0
Columbia -Willamette Air Pollution Authority
1
2(a)
3
4
5(b)
6
Pulp mill
Pulp mill
Animal rendering plant
Wood preserving plant
Pulp mill
Pulp mill
5
5
4
0
5
5
0
1
0
0
1
1
State of Maryland Bureau of Air Quality Control**
l(a)
2
3
4
5
6(b)
Distillery
Sewage treatment plant
Asphalt manufacturing
Coffee manufacturing
Sewage treatment plant
Distillery
2
3
2
9
0
2
0
1
2
0
0
0
Note: Letters shown in parentheses after the survey set numbers refer to the initial and replicate sets of
public attitude surveys conducted in the same test and control areas.  For each of three agencies, set b is
a replicate of set a and, for one agency, set d is a replicate of set c.
 * This was approximately the period during which the field activities were performed.
**The number of odor complaints shown for the State of Maryland include some complaints received by the
   Baltimore County and Prince Georges County Health Departments.
                                               -26-

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       Even if the agencies did not feel that it was necessary to use either of the
sensory techniques described in the procedure for source verification, they were
encouraged to apply them and, thereby, gain experience necessary for a compre-
hensive evaluation.  Their application is illustrated in the following examples.

       In Houston, all but one of the test areas were established near a vast com-
plex of oil refineries and chemical manufacturing plants situated along the Houston
Ship Channel. One of the typical test areas and the surrounding plants is shown in
Figure 3.  At different times and wind directions, the test areas received odorous
emissions from different plants. The annoyance among the residents seemed to
be caused by a virtual continuum of these emissions from the complex as a whole.
In most cases, however, a particular odor was encountered most often.  These
odors were made the object of the source investigations.

       Intensities in excess of 170 dilutions to threshold were measured on occa-
sions at various locations, and many readings greater than 7 dilutions to threshold
were obtained a high proportion  of the time in the test areas.  Despite the abundance
of odors,  however, a pattern of  peak odor intensities could not be  constructed with
sufficient precision to pinpoint the offending plants.

       Source verification was therefore attempted by use of an odor judgment
panel. The application of this technique was complicated because  of the  size of
area affected, the difficulty in distinguishing between odors of similar quality,
and the difficulty in preparing stable, non-toxic standards representative of the
various odor qualities encountered.  Again, odor distribution patterns could not
be obtained because of these complications and a lack of budgetary allowances to
find solutions.

       Because of the failure to  pinpoint the source by the construction of odor
distribution patterns, source verification was finally based on the  ability of the
agency's inspectors to recognize the quality of the predominant odors and to asso-
ciate them with particular plants and processes.  In doing so, they were sometimes
faced with only subtle differences in the quality of the various odors.  Evidence
gathered in this way is of last resort.  It depends not only on inspectors' know-
ledge of the characteristic odors of many processes, but also on their familiarity
with the industrial operations in a given community. It is hard to  document objec-
tively and can be  readily attacked as mistaken opinion.

       The scentometer and an odor judgment panel were also used in Hillsborough
County.  Twelve people, who had successfully completed triangle tests indicating
that they possessed average sensitivity to odors,  were employed as panelists.
They received odor intensity training with reference standards of tertiary dodecyl
mercaptan. The panelists were deployed in the test area affected  by emissions
from the sewage treatment plant (see Hillsborough County public attitude  survey
set no.  1 in the above tables). The test area was small and the sewage odor was
easily detectable against a background of odorless air.  As shown  in Figure 4,
                                      -27-

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Figure 3.    Location of industrial complex and test area where City of Houston
Department of Public Health conducted odor judgment panel evaluations.
                                                               Chemical
                                                                 Co.f
                                                              Chemical Co
                                                           Chemical Co.
                                   -28-

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•
to
      Figure 4.   Mean odor intensity isopleths obtained by Hillsborough County Environmental Protection Commis-
      sion by deployment of an odor judgment panel in a small test area near Tampa, Florida.	
                                                                                       Sewage Treatment Plant
             •
             o.oi
                        W. Burke
                                                        0.25

                                                                       25
                                                                                        r

                                                                           Aeration Pond
                                                                                             Primary
                                                                                             Clarifier
                                                                                  iiUiuUitiimitimuu until ^_
                                                                                            "\
                                                                      Drainage Ditch

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odor intensity isopleths were plotted from the scores obtained by the panelists.
In this case, the isopleths clearly indicated the source of the odor.

       Only the scentometer was used by the Columbia-Willamette and State of
Maryland agencies. Odor judgment panel observations were not attempted.
EVALUATION OF THE PROCEDURES AND TENTATIVE MODEL ORDINANCE

       A comprehensive evaluation form was prepared by Copley International
Corporation to assure that the evaluation data reported by each of the four agen-
cies were comparable. The answers to 48 open ended questions along with much
supporting information were requested.  A copy of the form is given in Appendix
D.  The technical and legal staffs of the agencies were asked to complete die form
and return it to CIC during what was to become the ninth month of agency partici-
pation .

       The reported data were reviewed extensively by CIC and Pope, Evans and
Robbins, Inc.  Omissions and ambiguous statements were discussed with the
appropriate agency staff members.  Similarly,  unusual findings were verified
for accuracy.

       All recommended modifications to the procedures and tentative model ordi-
nance were considered. Many involved simple  refinements and were implemented
without comment.  Others, particularly as they involved the overall utility of the
procedures or the structure and content of the tentative model ordinance, are
presented below.

Evaluation of the Procedures

       The agencies had the following comments about the design and applicability
of the procedures:

       •  Through the direct application of the  manual,  "Procedures for
          the Identification and Assessment of Community Odor Problems, "
          the manpower requirements  for the participating personnel were
          optimized. Since our agency maintains a comprehensive record
          of odor complaints, the three conditions necessary for a  "chronic
          situation" resulted in the direct application to the task of setting
          up matched test and control areas.

          The minor problems encountered in conducting the public attitude
          surveys were quickly resolved with verbal clarification by the
          Project Director. The scentometer and odor panel evaluations
          provided new interest and avenues of odor investigation and eval-
          uation previously unavailable to local enforcement agencies. 1
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The section of the manual, "Procedures for the Identification and
Assessment of Community Odor Problems, " dealing with public
attitude surveys provided all necessary information in a compre-
hensible,  concise manner.  We consider the public attitude survey
technique  as described in this procedure manual too restrictive for
use on most typical odor problem areas in Hillsborough County.
Most odor sources in this county do not affect the required number
of people for use of this method.

We think the odor judgment panel as described in the procedure is
too costly and time  consuming to be useful on the small,  isolated
odor problems in this area. A smaller panel (4-6 persons) would
be more useful for source verification in these cases.

We found the scentometer to be a useful tool for determining odor
intensity and for source verification,  and  it has the advantage of
requiring  only one person for its operation .2

The procedural manual forms the foundation for Section III of the
model ordinance by describing in detail the methods and techniques
to be employed in the selection of test and control areas, the pro-
cess of sample selection within the selected areas, the techniques
used in the public attitude survey and  the interpretation of the
survey results.  With a few minor exceptions, we have found the
procedural manual to be clear and concise, especially in the areas
of interpreting the survey results and in the survey techniques
themselves.

Although we feel that the results of the surveys do accurately
represent the attitude of the areas surveyed, we do not feel that
the results necessarily reflect the opinion of residents living
immediately adjacent to the odor source.  The reason for the dis -
agreement between  our opinion and the finding of the attitude survey
undoubtedly lies in the large area of the census tracts over which
the surveys were conducted. Application  of the survey method to
localized problem areas may provide  a more reasonable assess-
ment of the odor problems.

This agency finds that the process of test  area and control area
selection, sample selection and public attitude surveys may be
too cumbersome to  use during routine odor control enforcement
proceeding but may be of value under  unusual circumstances
where additional support to our present odor rule is required.
                            -31-

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          All of the source verification work conducted by the Staff during
          the course of the program utilized the Barnebey-Cheney Model
          1-3 Scentometer.  We found that the results obtained from using
          the scentometer did justify the efforts required to use them.
          The odor panel technique was not used during the course of the
          program and in our judgment would not be practical for routine
          field odor investigations.  Application of the scentometer in a
          moving vehicle appears to be a very effective way to provide
          rapid odor source verification. 3

       •  Our evaluation of the procedures.. .indicates (that.. .the)
          Bar nebey-Cheney Scentometer, as delivered, is not suitable for
          odor threshold determinations (and that.. .the) survey technique,
          with minor modifications and careful application,  can be a use-
          ful in-house  tool for assessing the scope of a potential odor
          problem in urban and suburban settings. ^

       It should be clear from these comments that the agencies held different
opinions about various  aspects of the applicability of the procedures.  However,
most of the agencies agreed that there are three main shortcomings to the pro-
cedures:

       (1)     The procedure for problem identification cannot be applied
              to sparsely populated communities in which only a few
              homes are affected.

       (2)     The procedure for problem identification is not applicable
              to the measurement of the undesirable effects of odor on
              commercial or industrial groups.

       (3)     Some of the tasks, particularly the delineation of test and
              control areas and the training and deployment of an odor
              judgment panel, are too cumbersome for routine applica-
              tion .

       The first point is acknowledged. It arises from the need to determine
whether or not a significant difference exists between the attitudes of residents
of a test area and those of a matching control area,  i.e., to determine,  within
a known probability of error, whether or not an odor problem exists in the test
area.  To do so, without resorting to a complex analysis of small sample sizes,
requires that residents of at least 20 (and preferably 30) homes in each area must
be successfully interviewed.

       The second point is not considered a  shortcoming. The opinions of retail
businessmen about odors in their communities were studied as part of the national
survey of the odor problem.  As a group, the businessmen were  less concerned
                                      -32-

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about odors than the residents of the same communities.  Only 8 out of 138 busi-
nessmen (6%) interviewed in test areas felt that odors had a negative  effect on
their businesses.  Of these, only 2 (less than 2%) felt that the presence of odors
had reduced the annual revenue of their  business by more than 10 percent.  Thus,
except for communities zoned entirely for commerce or industry, the procedures
are applicable to the most sensitive group.  Still, it is possible in atypical cases,
where at least 20 separately owned businesses are affected by odors and are far
removed from residences, that the public attitude survey could be directed at the
owners of those businesses.  Appropriate changes in the wording of the problem
identification questionnaire would have to be accomplished beforehand, however.
Beyond this, small commercial or industrial groups, like the residents of sparse-
ly populated communities, could seek relief through private means.

       Indeed, certain tasks  required in the application of the procedures are too
cumbersome for purposes of  routine surveillance of chronic situations. Recog-
nizing this, three conditions were written into the procedures (and the tentative
model ordinance) to limit their use (see Figure 2).  In contrast to the comments
itemized above,  most of  the agencies recommended that the limits specified by
one of these conditions be reduced and that the other conditions be left unchanged.
The effect of these recommendations is  to liberalize,  not restrict, their use.
Under the limits specified, it is felt that the costs of applying the procedures as
part of a criminal investigation are  not.excessive (estimates of the costs  are in-
cluded with the procedures).  It seems likely that a schedule of penalties  could
easily be established to permit application of the procedures to be self-supporting.

       The greatest variation of opinion among the agencies as expressed in the
reported data concerned  the use of the scentometer for purposes of both routine
surveillance and source verification.  Their comments are summarized in the
remaining paragraphs of this section.

       The City of Houston agency performed numerous measurements using the
scentometer and, out of their experiences, devised a modified system with which
the operator did not have to draw the air through the device by the function of his
lungs. In this system, as diagramed in Figure 5, a small air pump was used to
draw a fixed dilution of ambient air  through the scentometer and to deliver the
diluted sample under positive pressure to the operator's nose by means of a face
mask. By using simple mounting devices for the pump and  scentometer,  one oper-
ator was able to drive an automobile safely while perceiving a selected dilution of
ambient air continuously (the mobile technique is recommended in the procedure
for source verification).   Although designed to avoid soreness from pressure of
the bulbs against the nostrils, the system has the added advantage of eliminating
the need for both a driver and an operator when the measurements are taken by
the mobile technique.

       Although the mobile technique was used almost exclusively in Hillsborough
County, the operators felt that the reading of 7 dilutions to  threshold was too high
                                      -33-

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Figure 5.   Modified scentometer system devised by the City of Houston Department of
Public Health.	.
            Air Pump
            Assembly
                                     -34-

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for use as an indicator of possible odor problems. The agency reported identify-
ing odor problems by means of public attitude surveys in communities where it
was unable to obtain odor intensity readings at 7 dilutions to threshold.

       The Columbia-Willamette agency presently has an odor regulation based
on scentometer measurements, which has been in use for several years. The
exact method for using the device is not specified in the regulation, although
intensity measurements have been taken routinely from a stationary position.
During the field activities,  agency inspectors compared scentometer measure-
ments taken from stationary positions with those taken from an automobile.  They
reported successful use of the scentometer by both methods, but felt that the
mobile technique was more efficient in terms of area covered by one inspector.
They also reported that the scentometer bulbs were difficult to adjust to the nose
for adequate breathing.

       The agency reported failure to identify odor problems in communities
where scentometer readings of 7 dilutions to threshold were obtained.  This find-
ing is in opposition to that obtained by the Hillsborough County agency and is
thought to be due to the use of entire census tracts as test areas  — a fault of the
procedure for problem identification that has been corrected.

       Difficulty was reported by the State of Maryland agency in using the scent-
ometer as the operators experienced discomfort while taking measurements.  When
the devices were examined, it was found that the holes in the bulbs were smaller
than usual and may have contributed to the discomfort.  Despite this setback, the
agency reported appreciation that a portable dilution device which did not "depend
on the human lungs as the sample pump" would  be  a useful instrument.

Evaluation of the Tentative Model Ordinance

       The agencies had more critical comments about the structure and content
of the tentative form of the model odor control ordinance (March 1972 revision):

       •  We are always searching for ways to efficiently abate all air
          pollution sources. An effective municipal odor control ordi-
          nance is certainly the goal of this agency.  The comments
          offered by our Legal Department adequately reflect our posture
          concerning the technical aspects and problems associated with
          the model ordinance; however,  we feel that the technicalities
          can be resolved.5

       •  Our legal staff considers the need to  random sample both the
          source area and a control area under the public attitude survey
          technique to be not necessary and possibly not relevant in a
          legal proceeding.  They felt that the court would be primarily
          concerned with the effect of odors on a substantial number of
                                      -35-

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          aggrieved persons along with proof of the source.  Because of
          these reasons, our Attorney did not favor the adoption of the
          model odor control ordinance as proposed. A modified, simpler
          public attitude survey procedure could be a useful tool in assess-
          ing odor problem areas, whereas  surveys as  described in this
          procedure seem  more useful as a research tool.**

       •  The model ordinance may not be consistent with public nuisance
          law in that a public nuisance may be established by annoyance to
          a segment of the community whereas the model ordinance applies
          to a community wide problem only.  Further clarification of the
          phrase "significantly greater" which appears  in Section I of the
          ordinance is required to insure that the ordinance wording is
          clear.

          Perhaps the greatest limitation of the ordinance and the procedural
          manual which forms the foundation of Section  III of the ordinance
          lies in the definition of "community odor problem." This wording
          restricts application of the  ordinance to community residents  only,
          precluding its use on odor problems which may occur in commer-
          cial and/or industrial areas of the community which may very well
          be public nuisances.  Inasmuch as there is generally very little
          residential housing in these areas, the ordinance could not be
          applied.  This agency would not recommend adoption of the model
          ordinance in place of its present rule which limits odor strengths
          as measured by the scentometer because of the above limitation.
          The ordinance may, however,  be useful as a supplement to the
          Authority's present rule in  cases where additional support is re-
          quired to strengthen other odor control enforcement activities. ^

       •  Our evaluation of the.. .proposed ordinance indicates (that.. .the)
          ordinance contains several  legal problem areas which would be
          difficult to overcome. °

       One or more of the  agencies listed the following  as the main shortcomings
of the tentative model ordinance:

       (1)     There is a need for definitions of "community" and "signi-
              ficantly greater proportion of respondents." As stated, the
              definitions of "chronic  situation" and "community odor prob-
              lem" may lead to possible controversies.

       (2)     As a criminal law, the  ordinance is not sufficiently clear to
              advise a person of reasonable intelligence when he would be
              guilty of violating the law.
                                     -36-

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       (3)     To the extent that the violator's guilt is determined from a
              survey of the past history of his performance, the  crime is
              defined after the act and may be subject to expost facto effect.

       (4)     The ordinance is not consistent with nuisance law because it
              does not permit the protection of small portions of the popu-
              lation .

       (5)     It would have to be shown that the public attitude surveys were
              properly conducted.

       (6)     The Sixth Amendment to the United States Constitution requires
              that the accused be  confronted by his accusers.  An attempt to
              convict a person of  a crime by use of the hearsay gathered in a
              survey would appear to violate this basic right.

       (7)     Any evidence obtained from the surveys would be useless unless
              each person who was bothered by odors could be shown to have
              been bothered by odors caused by the person being prosecuted.

       (8)     The need to compare areas of "similar socioeconomic charac -
              teristics" seems to give rise to discriminatory application of
              the law among different socioeconomic classes.

       In response to the  above comments,  definitions of "community" and "signi-
ficantly greater proportion of respondents" were added to Section I of the model
ordinance, and much time was spent in considering more precise definitions of
"chronic situation" and "community odor problem." Other, simpler refinements
were made in Section II, the general provision, and in Section III, the procedural
establishment of a violation.  Beyond this, the expansion of scope of the model
ordinance, e.g.,  to permit surveys of commercial or industrial groups, or the
inclusion of additional provisions,  e.g.,  to require notification of the polluter
that he is violating, to exclude violations resulting from accident, calamity, or
act of God, or to specify a cognizant enforcement authority, is left to the liking
or customs of individual jurisdictions.

       The identification of a community odor problem would constitute the exist-
ence of a violation under the model ordinance.  Although such identification would
be based on the past history of a person's performance, there is nothing to pre-
vent the person, himself,  from conducting the necessary public attitude surveys,
measuring the effect of his emissions on neighboring communities,  and taking
appropriate action in terms of odor control before any charges are brought against
him.  The procedure for doing so is incorporated by reference in the model ordi-
nance and through enactment of the model ordinance would be a matter of public
record.
                                      -37-

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       It is felt that the more precise definition of "community odor problem,"
together with the general provisions, is now sufficiently clear to advise a person
of reasonable intelligence of what would be a wrongdoing.  This, together with the
availability of the procedure for problem identification through the public record
for use by  such a person in the  places and at the times clearly specified by the
procedure, should be  sufficient to avoid ex post facto effect.

       That the model ordinance is not applicable to small portions of the popula-
tion, i.e., to residents of less  than 20 homes,  is again acknowledged. The model
ordinance is consistent with public nuisance law if it can be agreed that "any con-
siderable number of persons" must include the  residents of at least 20 homes.  It
was not intended for the model ordinance to be applied for private means.

       It would not be difficult to show that public attitude surveys were conducted
properly.  It is assumed that agency employees would be trained by agency super-
visors before being permitted to conduct surveys that may lead to the establishment
of a violation.  The instructions for doing so are a part of the procedure for prob-
lem identification.  The results obtained by agency employees could be readily
verified by any professional survey firm as a disinterested third party. Verifica-
tion is accomplished by reinterviewing the persons contacted by the agency
employees and comparing the results obtained with those obtained by the agency
employees.

       The sixth point is acknowledged to be the main shortcoming of the proposed
approach.  Whenever  a community odor problem is identified under the model
ordinance, it may be necessary for all of the test area residents who answered
affirmatively to question 9 of the Problem Identification Questionnaire — "Would
you say that these odors have bothered you?" — to express their grievences direct-
ly to the court. This  would be necessary if the court denied the enforcement
authority from serving as the accuser, a denial which is usual in public nuisance
cases.  Since the identification  of a community  odor problem is based on group
results, refusal to appear in court or change of response to question 9 on the part
of any of the above mentioned test area residents may require a redetermination
of whether or not a significant difference still exists between the attitude of the
test area residents and those  of a matching control area.  Should a significant
difference  still exist,  the case may be permitted to continue.  Otherwise, the
case may be dismissed due to an absence of accusers.

       The difficulty of getting  many test area residents to appear in court seem-
ingly would be inversely related to the magnitude of the odor  problem in their
community. It may be partly or totally avoided by the use of a sequential sampling
technique or by adoption of the model ordinance as a statute,  rather than enact-
ment as a form of public nuisance law.  These possibilities are discussed further
in the next chapter.
                                      -38-

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       Inasmuch as persons who are bothered by odors cannot be expected to know
the source of such odors, it is left to the expertise of the cognizant enforcement
authority to determine the source. This is particularly true in cities such as
Houston where numerous industrial sources are clustered together. Fortunately,
it is not uncommon for the residents of a test area to suspect a given source. But,
still, it is left to the expertise of the cognizant enforcement authority to verify the
source.  Pertinent information concerning  the frequency, duration, intensity,  and
temporal proximity of the odors perceived by the residents of a test area and any
source that they suspect can be taken from their responses to questions 4, 6,  7,
8, and 11 of the  Problem Identification Questionnaire.

       The eighth point raises two questions.  The first is aimed at the need for a
control area at all, and the  second is aimed at the possibility of discriminatory
application of the model ordinance.  Although the use of public attitude  surveys in
legal proceedings,  whether  in a test area or  a matching control area, may be un-
precedented, the need for a control area should be of no surprise.  It serves two
purposes:

       (1)     Under  the assumption that test area and matching control
              area populations both have equal right to odor free air, it
              provides an equitable basis  for decision.

       (2)     Since what the population in the test area says about odors
              may not reflect what it actually feels about odors, it per-
              mits an estimation of true attitudes.

These purposes  are discussed at length in  Chapters III and VII of the final report
of the second phase of research.  They cannot be served by interviewing "any con-
siderable number of persons," as might be done in the more traditional establish-
ment of a public nuisance.

       The need to match a control area to a test area by reference to  the socio-
economic characteristics of the test area is only to insure that the population of
the control area would be a reasonable representation of the population of the test
area.  As a consequence, a measurement  of the attitudes of the residents of the
control area as a group would be a reasonable representation of the attitudes of
the residents of  the test  area  as a group, except for any effect on the attitudes of
the latter group  that is due to  the presence of odors in the test area. The possi-
bility that the results of  public attitude  surveys may change as a function of median
family income or any other socioeconomic characteristics is not only academic in
this context, but also doubtful.  The lack of any such relationship is also discussed
further in the next chapter.
                                      -39-

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NOTES

        Letter from Victor N. Howard, Director, Pollution Control Division,
City of Houston Department of Public Health,  Houston, Texas, October 18, 1972.
       2
        Letter from Roger P. Stewart, Director, Hillsborough County Environ-
mental Protection Commission, Tampa, Florida, October 25, 1972.
       3
        Letter from R. E. Hatchard, Program Director, Columbia-Willamette
Air Pollution Authority, Portland, Oregon, November 10, 1972.

       4Letter from George P. Ferreri,  Acting Director, Bureau of Air Quality
Control, State of Maryland Department of Health and Mental Hygiene, Baltimore,
Maryland, October 17, 1972.

       5Howard, loc.  cit.

       "Stewart, loc.  cit.

        Hatchard, loc. cit.

       °Ferreri, loc. cit.
                                    -40-

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                                 CHAPTER IV
                   CONCLUSIONS AND RECOMMENDATIONS
       The information obtained by the four participating agencies through the
applications and subsequent evaluations of the procedures for problem identifica-
tion and source verification and of the tentative form of the model odor control
ordinance was of great value not only in improving these  documents, but also in
shedding light on points of general interest in odor research.  The conclusions
derived from this information are presented first as they pertain to the procedures
and to the model ordinance and then as they may be of general interest.  A brief
statement of recommendations concludes the chapter.
CONCLUSIONS PERTAINING TO THE PROCEDURES

Procedure for Problem Identification

       Based on the experiences of all four agencies, it is concluded that the pro-
cedure for problem identification can be successfully applied to all possible odor
problems in residential areas of at least 20 homes, regardless of the source (or
sources) of the odors involved.  The procedure cannot be applied to possible odor
problems in residential areas of less than 20 homes, without resorting to a com-
plex analysis of small sample sizes, or to possible odor problems in commercial
or industrial areas,  without even further modification.  Yet,  despite these limita-
tions, it is estimated that the procedure can be successfully applied to  at least 80
percent of all possible odor problems.

       The tasks prescribed by the procedure were completed by the agencies
with little difficulty.  Their most persistent complaint was the length of time
necessary to delineate a test area and a matching control area (usually one to two
days) and to conduct a set of public attitude surveys (also one to two days).  Based
on the experiences of the Houston and Hillsborough County agencies, it is further
concluded that much time can be saved by use of a professional real estate appraiser
in the former task.  Once shown test areas of interest to the agency, a professional
appraiser with experience in the jurisdiction  of the agency can often immediately
suggest the location of closely matching control areas.

       Time savings can also be obtained by  the use of a sequential sampling tech-
nique when conducting public attitude surveys.  This requires the completion of a
minimum of three sets of public  attitude surveys (i.e., three surveys in test areas
and three in matching control areas) in accordance with the conventional survey
steps outlined in the procedure.  An  "acceptable odor level (AOL)" and "odor
                                      -41-

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problem level (OPL)" can then be calculated as described in Chapter VII of the final
report of the second phase of research. Given an AOL and OPL, a sampling plan
can be designed, against which the results obtained from surveys of future test
areas can be compared.

       The fundamental difference between sequential analysis and the conventional
survey technique is that the number of interviews completed using sequential analy-
sis is dependent upon the number of affirmative responses to question 9 of the
Problem Identification Questionnaire — "Would you say that these odors have
bothered you?" After each interview is completed, the results obtained are added
to those already obtained during the survey and compared with "decision numbers"
listed in the sampling plan.  On the basis of this  comparison, one of three decisions
can be made:

       (1)     That an odor problem is identified.

       (2)     That an odor problem does not exist.

       (3)     That the results are inconclusive  and that an additional
              interview must be completed.

       The information obtained during the field activities was used by Copley
International Corporation to design the sampling plans given in Tables 4,  5, 6,
and 7.  For each jurisdiction, an AOL was calculated from the percent of respon-
dents in a combination of all of the control areas who said they were bothered by
odors.  Thus, for each of Houston and Hillsborough County, the results obtained
in surveys of eight control areas were used in the design of the sample plans.
For each of Oregon and Maryland, the results obtained in surveys of six control
areas were used.  Had these  sample plans been available at the times the agencies
identified their first community odor problems, the amounts of time shown in
Table 8 could have been saved.

Procedure for Source Verification

       During the field activities of the present study, as in the previous phases
of research,  odor intensity measurements were performed by dilution of the
ambient air with odor free air to the odor threshold and by comparisons of the
intensities of odors in the ambient air with those of reference standards.  The
scentometer was used for the dilution to threshold measurements, while odor
judgment panels were used for the comparisons. The usefulness of these sensory
techniques was evaluated in relation to three tasks:

       (1)     The measurement of odor intensity levels at a particular
              location and at a particular time.
                                     -42-

-------
         Table 4.     Sequential sampling plan based on the proportion of residents in a
         combination of Houston control areas who stated they were bothered by odors
         (AOL = 0.233. OPL = 0.433, a  =0.05,  S  =0.05).
Co
 i
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
*
*
0
0
0
1
1
1
2
2
2
3
3
3
4
4
4
5
5
5
5
6
6
Odor
Problem
Decision No.
*
*
*
*
5
6
6
6
7
7
7
8
8
8
9
9
9
10
10
10
11
11
11
12
12
12
13
13
13
14
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
6
7
7
7
8
8
8
9
9
9
10
10
10
11
11
11
12
12
12
13
13
13
14
14
14
15
15
15
16
16
Odor
Problem
Decision No.
14
14
15
15
15
15
16
16
16
17
17
17
18
18
18
19
19
19
20
20
20
21
21
21
22
22
22
23
23
23
Table 5.     Sequential sampling plan based on the proportion of residents in a
combination of Hillsborough County control  areas who stated they were bothered
by odors  (AOL = 0.086. OPL = 0.247,  a  =0.05,  6   =0.05).
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0
0
0
0
0
0
1
1
1
1
1
1
1
2
2
Odor
Problem
Decision No.
*
*
3
3
4
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
6
7
7
7
7
7
7
8
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
6
Odor
Problem
Decision No.
8
8
8
8
8
8
9
9
9
9
9
9
10
10
10
10
10
10
10
11
11
11
11
11
11
12
12
12
12
12
           A no-odor-problem decision cannot be reached until 10 interviews have been com-
           pleted; an odor-problem decision cannot be reached until 5 interviews have been
           completed.
 A. no-odor-problem decision cannot be reached until 16 interviews have been com-
 pleted; an odor-problem decision cannot be reached until 3 interviews have been
 completed.

-------
Table 6.     Sequential sampling plan based on the proportion of residents in a
combination of Oregon control areas who stated they were bothered by odors
(AOL = 0.167, QPL = 0.353,  a  = Q.Q5,   B  =0.05).
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
Ji-
ff
*
*
0
0
0
0
1
1
1
1
2
2
2
2
3
3
3
3
4
4
4
Odor
Problem
Decision No.
*
*
&
4
5
5
5
5
6
6
6
6
7
7
7
7
8
8
8
8
9
9
9
9
10
10
10
11
11
11
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
4
5
5
5
5
6
6
6
6
7
7
7
7
8
8
8
8
9
9
9
9
10
10
10
10
11
11
11
11
12
Odor
Problem
Decision No.
11
12
12
12
12
13
13
13
13
14
14
14
14
15
15
15
15
16
16
16
16
17
17
17
17
18
18
18
18
19
Table 7.     Sequential sampling plan based on the proportion of residents in a
combination of Maryland control areas who stated they were bothered by odors
(AOL = 0.097, OPL, * 0.260, a  = 0.05,
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
%
*
*
*
*
*
*
*
*
*
*
*
*
*
0
0
0
0
0
0
1
1
1
1
1
1
2
2
2
2
Odor
Problem
Decision No.
*
*
3
4
4
4
4
4
4
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
2
2
3
3
3
3
3
3
4
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
Odor
Problem
Decision No.
8
8
9
9
9
9
9
9
10
10
10
10
10
10
11
11
11
11
11
11
12
12
12
12
12
12
13
13
13
13
  A no-odor-problem decision cannot be reached until 12 Interviews have been com-
  pleted; an odor-problem decision cannot be reached until 4 interviews have been
  completed.
* A no-odor-problem decision cannot be reached until 15 interviews have been com-
 pleted; an odor-problem decision cannot be reached until 3 interviews have been
 completed.

-------
Table 8.   Time that could have been saved by the use of a sequential sampling tech-
nique in surveying test areas in which community odor problems were identified.
                      No, of Interviews     No. of Interviews
                      Actually Completed      Necessary to     Amount of Time
                         in Test and        Complete Under    That Could Have
	Agency	Control Areas     Sequential Analysis    Been Saved*
City of Houston
Department of
Public Health
(Survey Set No.  2)
102
13
4 hrs . 27 min.
Hillsbo rough County
Environmental
Protection
Commission
(Survey Set No. 1)

Columbia -Willamette
Air Pollution Authority
(Survey Set No. 2)

State of Maryland
Bureau of Air
Quality Control
(Survey Set No. 2)
 59
 61
16
            2 hrs . 48 min.
2 hrs .  15 min.
 63
11
2 hrs.  36 min.
*It is assumed that an interview took an average of 2 minutes to complete and that
 an average of 1 minute elapsed between interviews.
                                     -45-

-------
       (2)    The documentation of odor distribution patterns throughout
              a test area and over a particular period of time.

       (3)    The location of the source of the odor in the test area by
              reference to the odor distribution patterns.

Based on these evaluations, it is concluded that the scentometer is suitable for the
first task, but the more comprehensive coverage of an odor judgment panel is pre-
ferable for the latter tasks.

       Successful application of the odor judgment panel technique can be realized
when the area affected by an odor is small enough for 12 to 16 panelists to provide
adequate coverage and when the odor caused by the source under investigation is
of such a quality that it can be positively identified even among other odors en-
countered in the area. Use of this  technique in Philadelphia during the first phase
of research, and in Hillsborough County under the present study, took place under
these ideal conditions.  The results from both studies, plotted as isopleths, clearly
pinpointed the locations of the sources as well as the areal extent of the odors at
the times the panels were used.

       The source under investigation in Los Angeles during the second phase of
research was a large  refinery.  The odor caused by the refinery affected a very
large area and was easily recognized since the refinery was well isolated from
other possible sources.  The difficulty with using the odor judgment panel tech-
nique there was simply the number of panelists that would have been required to
cover the area in sufficient depth for odor distribution patterns to be obtained.  It
is estimated that an unmanageably large number of panelists —  perhaps several
hundred — would have been required to achieve this end.

       In Philadelphia, Los Angeles, and Hillsborough County, it was possible to
select for use as reference standards stable, non-toxic odorants producing odors
similar in quality to those most frequently encountered in the test areas studied.
After brief periods of training, the  panelists had  no difficulty in recognizing the
odors in the field as being from the sources under investigation  and, consequently,
in comparing the intensities of the odors to the reference standard scales. In
Houston, however, the source under investigation was part of a  vast complex of
oil refineries and chemical manufacturing plants. The odors caused by many of
these plants were similar, although not identical, to those caused by the source
under investigation.  Selection of a  stable, non-toxic reference standard that was
representative of the source and not representative of the adjacent plants  was vir-
tually impossible.

       In situations such as these,  a reference standard scale can be prepared
from an odorant unlike any found in the complex.   For example,  Dravnieks has
found that odor judgment panelists can relate the  intensities of odors of very
                                      -46-

-------
different qualities to a reference standard scale prepared from 1-butanol with very
little loss in accuracy.

       A difficulty with using an odorant unlike those under investigation is that
odor judgment panelists must be trained not only to compare the intensities of the
odors they encounter in the field, but also to associate the qualities of the odors
with those caused by particular sources.  To accomplish this, the panelists can
be trained to recognize the odors characteristic of various sources by frequent
trips to such sources or by laboratory exposure to samples of odorous substances
typically emitted by such sources .

       To date, 17 air pollution control agencies are known to have adopted the use
of dilution devices to measure the intensities of odors from known or suspected
sources.  None have yet adopted the use of panels for comparison of the intensities
of odors in the ambient air with those of reference standards.  It is concluded that,
because of the costs  of training and deploying at least 12 panelists, enforcement
authorities feel that the odor judgment panel technique would be impractical for
routine cases of source verification. However, they appreciate the usefulness of
the technique in support of court action. For routine cases, they prefer to rely
on the  experience of their inspectors alone in locating offending plants.
CONCLUSIONS PERTAINING TO THE MODEL ORDINANCE

       From the evaluations of the four agencies and from a review of the regula-
tions summarized in Appendix A, it is concluded that a model ordinance cannot be
drafted that is compatible with the legalistic approach to controlling air pollution
preferred by every jurisdiction.  It is further concluded that emphasis in the
development of a model ordinance is best given to a conceptual framework that
would promote the most efficient solutions under the existing state of knowledge.
It is impractical to establish arbitrary limits merely because they are easy to
enforce or to devote resources in constructing as many ancillary provisions as
are felt necessary to meet all eventualities.

       The recommended form of the model odor control ordinance developed
under this  study is included as Figure 1 in the last section of this  report, "Pro-
cedures for the Identification and Assessment of Community Odor Problems."
As a no-ill-effects ordinance, it prescribes the  measurement of annoyance due
to odors which,  as discussed in Chapter II, would serve as a convenient indicator
of the existence of undesirable effects and, thus, would provide a  basis for decid-
ing whether or not a violation exists. Its adoption would tend to focus technological
controls on the annoyance threshold rather than the odor threshold and, thus,
would promote more efficient solutions in light of the societal consideration that
the added cost of control should equal the added benefit derived from  that control.
                                      -47-

-------
       An underlying dissatisfaction with the proposed approach apparent on the
part of the legal staffs of the participating agencies was that the model ordinance
is intended to be consistent with public nuisance law. No doubt this attitude was
partly due to their reflection on many unsatisfactory attempts to control the acti-
vities of financially or politically powerful entities by use of public nuisance  law
and of the greater success attained under statutes limiting such activities. Public
nuisance law was followed for two reasons:

       (1)    In the absence of relationships between the evaluation of odor
              and earlier stages of odor development (see Chapter II,
              Figure 1), only the public's evaluation can be used to decide
              whether or not an odor problem actually exists.

       (2)    Virtually all jurisdictions are presently equipped to handle
              odor cases under public nuisance law, whereas relatively
              few have adopted statutes to handle such cases.

The main shortcoming of the nuisance approach is that all of the test area residents
who, in response to the procedure for problem identification,  state that they were
bothered by odors may have to appear in court as accusers. However, the use of
a sequential sampling technique as suggested in the opening section of this chapter
would tend to minimize the number of people who would have to be involved.

       That the model ordinance is intended to be consistent with public nuisance
law should not preclude consideration of it as a statute.  Under existing and pro -
posed statutes, various limitations on odor  have been established or are recom-
mended.  Procedures for the establishment  of violations include the judgment of
one or more inspectors, the use of dilution  devices, and the presentation of diluted
stack samples to a small panel of agency employees or representatives.  By  such
procedures, decisions are dependent upon the perception of people.  Under the
model ordinance, decisions are dependent not only on the perception of people,
but,  more importantly, on their evaluations. It is concluded that, without modi-
fication, the model ordinance could serve as a statute to prohibit the emission of
odorous substances into the atmosphere that would result in a community odor
problem.

       Adoption of the model ordinance may permit the enforcement authority to
serve as the accuser.  This may require the court's acceptance of the results of
public attitude surveys in test areas and matching control areas as documentation
of the existence of an odor problem much like scentometer readings are accepted
as documentation of odor intensity levels in the community.
                                      -48-

-------
OTHER CONCLUSIONS

       Several other conclusions were derived from a review of information ob-
tained by the participating agencies during the field activities.  The first of these
casts further doubt on the usefulness of odor complaints in dealing with odor
problems.

       It was stated in Chapter VII of the final report of the  second phase of re-
search that the difficulty with using odor complaints lies in the probability that the
complainants do not represent the feelings of the community as  a whole and that
persons who volunteer complaints about a particular situation may be expected to
overstate their concern. A recent odor case in Sweden was  given as an  example
of this. It is now concluded that odor complaints are not only unreliable for the
above reasons, but also insensitive as an indicator of where odor  problems may
exist.  A comparison of the odor problem index numbers of identified community
odor problems (Table 2 of this report) with the number of  odor complaints against
sources from residents of the test areas (Table 3)  supports this conclusion. For
example, the Hillsborough  County agency calculated an odor problem index number
of 7.0 (10.0 is maximum) from one set of public attitude surveys.  Yet,  no odor
complaints were received by this agency from residents of the test area during the
entire period of the field activities.  Similar examples can be seen from the infor-
mation supplied by the other agencies. The conclusion is  further  supported by the
expectations of the agencies based on their  surveillance that odor  problems would
be identified in test areas where, in fact, they were identified and by the national
survey of the odor problem which found that while:

       .. .25 million residents in the United States could be  expected to  state
       that air pollution is a problem and that odors are a major element...
       Only one-half million residents would have  requested some authority
       or agency to take action concerning  air pollution.  The number of
       residents that would have requested action concerning odor problems
       would be a small fraction of this.

While odor complaints cannot be ignored as an indicator of where  odor problems
may exist, the conclusion points to the importance of maintaining  routine surveil-
lance as a more sensitive indicator.

       A second conclusion is in response to critics of the use of  behavioral sci-
ence techniques as a basis  for enforcing odor control regulations.  It has been
widely suspected that the propensity to complain about odors is a function of fam-
ily income in particular and socioeconomic status in general. It has been suggested
more recently that responses to public attitude surveys may be  subject to this same
function. If so, the application of a law which owes decisions to the results of such
surveys would be discriminatory.  Comparisons of median home value — an excel-
lent surrogate for both median family income and socioeconomic status — and the
percent of respondents who were bothered by odors in test areas and control areas
                                     -49-

-------
surveyed under the present study are presented in Figures 6 and 7.  The data points
do not seem to form any particular pattern.  However, quality differences in hous-
ing were not accounted for between jurisdictions, and surveys in areas of very low
median home values (below $7,750) were not attempted. Thus,  the conclusion of
this comparison must be that while the existence of such a function in connection
with public attitude surveys cannot be entirely rejected, the likelihood of its exist-
ence is doubtful.

       A final conclusion is derived from a comparison of the percentage of respon-
dents who noticed odors with the percentage of respondents who  were bothered by
odors.  The comparison given in Figure 8 is limited  to test areas in which commu-
nity odor problems were identified.  Based on the results obtained in Los Angeles
during the study of the social and economic impact of odors, a correlation as high
as that achieved during the present study (r = 0.91) was unexpected. This compar-
ison does not suggest that it is possible to identify odor problems simply by noticing
odors.  However,  should further applications of the procedure for problem identifi-
cation confirm the high correlation, it would be possible to simplify the public
attitude survey requirements of the procedure even further and, thereby,  permit
predictions of such problems with confidence.
RECOMMENDATIONS

       The overall recommendation arising from this and the previous phases of
research is that the control of odors  should be accomplished in an indirect manner,
if at all possible, through strict adherence to air quality standards governing the
emission of measurable concentrations of odorous substances into the atmosphere.
In cases where air quality standards  do not exist for the particular substances
involved or where available instrumental or wet-chemical methods are inadequate
to measure the low concentrations involved, the control of odors should be accom-
plished in a manner that takes consideration of the problem dimension of odors and
not the mere perception.  To this end, Copley International Corporation recommends
that the attached "Procedures for  the Identification and Assessment of Community
Odor Problems" should be employed to determine whether or not an odor problem
exists and, if so, the extent of such a problem relative to other odor  problems in
the jurisdiction. A mechanism for the official use of the procedures  in the estab-
lishment of a violation is found in the model odor control ordinance included as
Figure 1 in the attached procedures.

       The procedures have been developed from a comprehensive study of the
national odor problem and of the social and economic impact of odors. They are
aimed at the measurement of the problem dimension — annoyance — rather than
at arbitrary limits of odor intensity or odor quality.  Their use in connection with
the model ordinance would provide the most effective legal control of odors given
the existing state of knowledge and would yield long term benefits not available
through alternate methods to date. For example, adoption of the procedures and
                                     -50-

-------
      Figure 6.   Comparison of median home value and percent of respondents who
      were bothered by odors  in test areas surveyed by the participating agencies.
   1001	
                                                        o  City of Houston
«                                                       A  Hillsborough County
                         A                              D  Columbia-Willamette
    80
o   60
g   40
T3
OT

£
g   20

-------
 Figure 8.   Comparison of the percentage of respondents who
 noticed odors with the percentage of respondents who were
 bothered by odors in test areas surveyed by Copley International
 Corporation and the participating agencies.



CO
0
s
^^*
J2
"S
8
•5
£
g
o

!^
CO
s
0)
•a
s.
CO
0)
*o
4-1
§
o
0)
CU

100

90

80


70


60

50


40


30

20


10
n

o City of Houston
A Hillsborough County
D Columbia-Willamette
+ State of Maryland A
- x Copley International Corporation A
(during second phase of research x
in Los Angeles) °
x


+ o o
+ °°
o
A
A
"" ^
A
A
-

r = 0.91


~
1 1 1 1 II 1 I 1
0     10     20    30    40    50    60    70    80     90
            Percent of Respondents Who Noticed Odors
100
                               -52-

-------
model ordinance would tend to motivate new sources to locate outside of populated
areas, since violations would be based only on interference to such areas.  This
would be consistent with modern concepts of community planning and zoning laws
which seek to separate industry from other community groups.  As a further exam-
ple, it is expected that, under adoption, the probability that any given chronic situ-
ation would be identified as a community odor problem would automatically increase
as established sources relocate outside of populated areas or successfully apply
technological controls.  This is expected since such actions, particularly on the
part of previous offenders, would tend both to reduce the overall intensity of back-
ground odors and to focus public attention on remaining offenders. Copley Interna-
tional Corporation feels that these benefits would greatly lessen the need for
legislative refinements to the procedures or proposed law in order to deal with
any sources or chronic situations as they may arise over time.
REFERENCES

Dravnieks, Andrew.  "Odor Perception and Odorous Air Pollution," The Journal of
       the Technical Association of the Pulp and Paper Industry, LV, No. 5 (May,
       1972), 737-742. The use of 1-butanol as an odor intensity reference stan-
       dard is discussed in this and the following reference.

Dravnieks, Andrew.  "Odor Suprathreshold Intensity Experiment." A report pre-
       pared by the American Society for Testing and Materials Sensory Evaluation
       Committee E 18.  To be published.
                                      -53-

-------
                       APPENDICES
-55-

-------
                   APPENDIX A
SUMMARY OF ODOR CONTROL REGULATIONS ENFORCED BY
203 STATE AND LOCAL AIR POLLUTION CONTROL AGENCIES
                        -57-

-------
                                APPENDIX A
         SUMMARY OF ODOR CONTROL REGULATIONS ENFORCED BY
         203 STATE AND LOCAL AIR POLLUTION CONTROL AGENCIES
       In preparing the tentative form of the model odor control ordinance, it was
felt that valuable guidance could be obtained from a review of as many existing and
proposed odor control regulations as could be obtained from enforcement authorities
throughout the nation. Specifically, it was felt that such a review would not only
suggest a structure and content that would be most acceptable in all regions of the
United States, but also highlight current trends in the legal controls of odors.
COLLECTION OF INFORMATION

       To implement this review, it was first necessary to collect and summarize
any existing and proposed odor control regulations.  Thus, a letter (see below) was
sent to the director of each domestic air pollution control agency listed in the Air
Pollution Control Association "1970 Directory of Governmental Air Pollution Agen-
cies." A total of 256 agencies were contacted. Of these, 203 agencies supplied
Information  which could be  summarized.  A few others supplied information with-
out any reference to themselves, to the jurisdictions in which they served, or to
the Jurisdictions in which the regulations were applied or proposed. Obviously,
the latter information could not be summarized In the order provided below.

       Unfortunately,  it was not possible to determine from the information supplied
by some  agencies whether odors in their jurisdictions were controlled under nuisance
laws or by statutes that limit the so-called "emission of odors." Since adequate in-
formation was obtained to achieve the purpose of the initial contacts with the agencies,
no further contacts were attempted to distinguish between these possibilities.
USE OF INFORMATION

       Use of the information provided below must be made with caution. It was
collected during the Fall of 1971 and should be considered current only for that
period. (Update of the information before completion of this final report was not
within the scope of the present study.) Errors in interpretation and omissions of
pertinent conditions, prohibitions, or control requirements may exist because of
incomplete information supplied by some of the 203 agencies.  No attempt was made
to verify the accuracy of the information supplied.
                                     -1-
                                 mi
        COPLEY INTERNATIONAL  CORPORATION
            Icmomit Rrsrant, . Corporttt Pfenning . Sfllrmt Engiaaring • Mimtgtminl Smiln
                                                                                                                                                  September 28, 1971
Director
Name of Agency
Address of Agency
            Subject:  Request for Copy of Odor Control Ordinance
The Environmental Protection Agency has retained Copley International Corporation
to conduct research into the identification and assessment of community odor prob-
lems .  We are aware that state and local air pollution control agencies throughout
the United States have faced such problems for years and, consequently, that some
of these agencies have developed enforceable odor control standards. We appre-
ciate that such standards reflect considerable thought and analysis on the part of
agency officials, their personnel, and their legal advisors.

As part of our research for the EPA, we request that you send us a copy of any
ordinance presently applicable to community odor problems in your jurisdiction.
If such an ordinance does not yet exist,  but has been proposed, we request that
you send us a copy of the proposed law. Your cooperation would assist  us in iden-
tifying standards that are common to the nation as a whole or unique to certain
regions.

We have enclosed a self-addressed, stamped envelope for your convenience in
transmitting the requested information to us. If  an odor control ordinance does
not exist in your jurisdiction,  and none has been  proposed, please return this letter
to us in the enclosed envelope. Thank you for your attention to our request. We
are looking forward to hearing from you by October 15, 1971.

                                          Very sincerely yours.
                                                                                                                                                 R. David Flesh
                                                                                                                                                 Project Director
                                                                                                        RDF/leh

                                                                                                        Enclosure   7e.7 Ht.'sl
                                     iun Offices:
                                                                                                                                   TlUrHONE (;Ml 454-0391

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 LEGEND

 a.   Ordinance or nuisance law proposed, effective date not indicated
 b.   Ordinance or nuisance law proposed, approval pending
 c.   Ordinance or nuisance law proposed, effective beginning sometime in 1972
 d.   Amendment(s) to existing ordinance or nuisance law proposed, approval pending
 e.   Must be verified by agency (verification required within 2 hours in Independence
        and Kansas City, Missouri, and Clark County,  Nevada)
 f.   15% of 20 people exposed to it or living in the affected community
 g.   25% of 20 people exposed to it or living in the affected community
 h.   30% of 20 people exposed to It or living in the affected community
 i.   30% of 5 people exposed to tt or living in the affected community
 j .   30% of a sample of people exposed to it or living in the affected community
 k.   50% of 20 people exposed to It or living in the affected community
 1.   75% of sample work or reside in the  affected area, 25% of sample are from
        general public living  or working outside the affected area
m.   75% If sample Is less than 20 people
 n.   75% If sample is less than 20 but more than 4 people (and provided that these
        persons are not from the same household)
 o.   75% if sample is less than 6 people
 p.   3 persons if sample is less than 20 people
 q.   5 persons if sample is less than 20 people
 r.   If objectionable in usual places of occupancy
 s.   In residential areas
 t.   On, near, or adjacent to residential, recreational, institutional, retail sales,
        educational, and hotel premises
 u.   In commercial areas
 v.   to industrial areas or on or adjacent to industrial premises (where 2 readings
        or dilutions are given, the first indicates light industry; the second, medium
        and/or heavy industry)
 w.   to all other areas not mentioned elsewhere
 x.   When measured at or beyond property line of source
 y.   However, local air pollution control agency must be notified
 z.   Odor not specifically mentioned, but included by definition or implication stated
        elsewhere

 EXAMPLE

        A condition necessary for violation of the odor ordinance enforced by the
 Colorado Department of Health, Air Pollution Control Division due to the emission
 of odorous air contaminants  from a single source is stated below as,  "If Detectable...
              After dilution with odor free air;
               2:7vol.su,,
               aris voi.w
 Expanded, this means that a violation would exist if odor is detectable after dilution
 with 7 or more volumes of odor free air (s) to residential areas or (u) to commercial
 areas, or with 15 or more volumes of odor free air (w) in all other areas.
                                      -3-                                                                                                      -4-

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Name of Agency
(by State)
Alabama
State of Alabama
Department of Public
Health
City of Birmingham,
Department of Inspection
Services, Smoke Abate-
ment Division
City of Huntsville,
Air Pollution Control
Office
Jefferson County
Department of Health,
Bureau of Environmental
Health
Mobile County
Board of Health, Bureau
of Environmental Health
Alaska
State of Alaska
Department of Environ-
mental Conservation
Tri-Borough
Air Resources Manage-
ment District
Odor Ordinance
or Nuisance Law
Governing Odor?
No
No
Yes. Ordinance
No. 66-246,
Sec. 5; Ordi-
nance No. 69-
72. Sec. ISA.
74.
No
No
Noa
Yes. Regulation
1, Sees. 9.13
and 9. 19.
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints







If Deemed
Offensive/
Objectionable


Not specified
by whomx




Dilution
Device
Reading







If Detectable







Frequency
of Odor







Duration
of Odor







Exceptions






Farm
animals.
Upset
conditions
or break-
down of
equipment;
Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law


The emission of noxious or objectionable odors
which are detectable without instruments at or
beyond the property line will not be permitted
in the Research Park District.
It shall be unlawful for any person to permit or
cause foul or offensive odors. . .in the main-
tenance or operation of incinerators .



Effective control apparatus and measures shall
be installed and operated to reduce odor-
bearing gases or paniculate matter emitted
into the atmosphere to a reasonable minimum.
Installation or use of any device or measures to
conceal or mask an emission of an air con-
taminant shall be unlawful.

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Name of Agency
(by State)


Arizona

State of Arizona
Division of Air Pollution
Control

Maricopa County
Health Department,
Bureau of Air Pollution
Control















Arkansas

State of Arkansas
Department of Pollution
Control in Ecology

California

State of California
Air Resources Board





Bay Area
Air Pollution Control
District



Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Rules and
Regulations for
Air Pollution
Control, Regu-
lation 7-1-2. 3.

Yes. Rules and
Regulations ,
Rule 32.


















Yes. Air Code,
Sees. 10 and 13.




Yes. Health and
Safety Code,
Sec. 39077.




Noa



Condltion(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints














































If Deemed
Offensive/
Objectionable














































Dilution
Device
Reading















































If Detectable
















































Frequency
of Odor















































Duration
of Odor















































Exceptions



























Upset
conditions,
breakdown
or sched.
maint. of
equipmentv
Agricultur-
al opera-
tions and
associated
odors.










Pr ohibition( s ) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
All persons owning or responsible for any pro-
cess involving the reduction of animal and or
vegetable matter shall provide properly con-
structed facilities and install and maintain In
good working order such devices as are neces-
sary to prevent emissions of air contaminants?
No person shall emit gaseous or odorous mate-
rials from equipment, operations or premises
under his control in such quantities or concen-
trations as to cause air pollution.
No person shall operate or use any machine,
equipment or other contrivance for the treat-
ment or processing of animal or vegetable mat-
ter, separately or in combination, unless all
gases, vapors and gas -entrained effluents from
such operation, equipment or contrivance have
been: ( 1) Incinerated to destruction at > 1300°
F or processed in a manner determined to be
equally or more effective for the control of air
pollution; (2) All persons owning or responsi-
ble for any process involving the reduction of
animal and/or vegetable matter shall install.
use, and maintain such devices as are neces-
sary to prevent or control emissions of air
contaminants .
No person shall cause or permit the emission of
air contaminants, including odors. . .if the
emission of the air contaminant constitutes
air pollution.


No person shall discharge from any nonvehicular
source whatsoever such quantities of air con-
taminants or other material which cause in-
jury, detriment, nuisance or annoyance to any
considerable number of persons or to the pub-
lic or which endanger the comfort, repose,
health or safety of any persons or the public
or which cause or have a natural tendency to
cause injury or damage to business or prop-
erty.2





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Name of Agency
< by State)

Calaveras County
Air Pollution Control





Colusa County
Air Pollution Control
District
Fresno County
Public Health Department
Humboldt County
Air Pollution Control
District





Inyo County
Air Pollution Control
District
Kern County
Air Pollution Control
District

Odor Ordinance
or Nuisance Law

Yes. Regulation
IV, Rule 4.5.





No


No

Yes. Rules and
Regulations,
Rules 51 and 59.





No


No


Conditlon( s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints

























If Deemed
Offensive/
Objectionable

























Dilution
Device
Reading

























If Detectable

























Frequency
of Odor

























Duration
of Odor


























Exceptions
Odors from
agricultural
operations
in the grow-
ing of crops
or raising
of fowls or
animals .






Upset
conditions
or break-
down of
equipment











Control Requirement s)
Specified In Odor Ordinance
or Nuisance Law
A person shall not discharge from any source-
whatsoever such quantities of air contaminants
or other material which cause injury, detriment,
nuisance or annoyance to any considerable num -
her of persons or to the public or which endan-
ger the comfort, response, health or safety of
any such persons or the public or which cause
or have a natural tendency to cause injury or
damage to business or property.





A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detriment,
nuisance or annoyance to any considerable num-
ber of persons or to the public or which endan-
ger the comfort, repose, health or safety of
any such persons or the public or which cause
or have a natural tendency to cause injury or
damage to business or property. z







-------
Name of Agency
(by State)
Kings County
Air Pollution Control
District
Los Angeles County
Air Pollution Control
District
Madera County
Air Pollution Control
District
Mariposa County
Air Pollution Control
District
Merced County
Department of Public
Health
Monterey-Santa Cruz
County Unified Air
Pollution Control District
Odor Ordinance
or Nuisance Law
Governing Odor?
Yes
Yes. Rules and
Regulations,
Rule 51.
No
No
Yes
No
Condition( s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints






If Deemed
Offensive/
Objectionable






Dilution
Device
Reading






If Detectable






Frequency
of Odor






Duration
of Odor






Exceptions






Prohibition(s) and
Control Requirement( s)
Specified in Odor Ordinance
or Nuisance Law
Public nuisance law is applied to control odors.
A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury/ detri-
ment, nuisance or annoyance to any consider-
able number of persons or the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.2


Nuisance standard is applied to control odors.


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Name of Agency
(by State)

Nevada County
Air Pollution Control
District
Orange County
Air Pollution Control
District
















Placer County
Air Pollution Control
District
Plumas County
Health Department
Riverside County
Air Pollution Control
District

Odor Ordinance
or Nuisance Law
Governing Odor?
No


Yes. Rules and
Regulations,
Rules 51 and 64
















No


No

No

Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints






























If Deemed
Offensive/
Objectionable






























Dilution
Device
Reading































If Detectable
































Frequency
of Odor































Duration
of Odor






























Exceptions





Odors from
agricultural
operations
in the grow-
ing of crops
or raising
of fowls or
animals.

Equipment
used exclu-
sively for
the process
ing of food
for human
consump-
tion.










Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law



A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause Injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.
A person shall not operate or use any article,
machine, equipment or other contrivance for
the reduction of animal matter unless all gases,
vapors and gas -entrained effluents from such
an article, machine, equipment, or other con-
trivances are: (a) incinerated at temperatures
2 1200°F for i 0.3 second, or(b) processed
in a manner determined by the Air Pollution
Control Officer to be equally, or more effective
for the purpose of air pollution control than ( a)
above.2








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Name of Agency
(by State)

Sacramento County
Air Pollution Control
District





San Benito County
Air Pollution Control
Board
San Bernardino County
Air Pollution Control
District





San Diego County
Air Pollution Control
District


















Odor Ordinance
or Nuisance Law
Governing Odor?
No. Agency
applies State of
California
Health & Safety
Code, Sec. 24243,
as stated in
Prohibition( s)
column.
No


No. Agency
applies State of
California
Health & Safety
Code.Sec.24243,
as stated in
Prohibitlon( s)
column.
Yes. Rules and
Regulations,
Rules 51 and 64.
















Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints




































If Deemed
Offensive/
Objectionable




































Dilution
Device
Reading





































If Detectable






































Frequency
of Odor





































Duration
of Odor





































Exceptions




















Odors from
agricultural
operations
in the grow-
ing of crops
or raising
of fowls or
animals.

Equipment
used exclu-
sively for
the process-
ing of food
for human
consump-
tion.




Prohibition( s) and
Control Requirement(s)
Specified in Odor Ordinance
or Nuisance Law
A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.2



A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.2
A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.
A person shall not operate or use any article,
machine, equipment or other contrivance for
the reduction of animal matter unless all gases,
vapors and gas -entrained effluents from such
an article, machine, equipment, or other con-
trivances are: (a) incinerated at temperatures
il200°F for iO.3 second, or (b) processed
in a manner determined by the Air Pollution
Control Officer to be equally, or more effective
for the purpose of air pollution control than ( a)
above.2

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Name of Agency
( by State)

San Luis Obispo County
Atr Pollution Control
District
Stanislaus County
Air Pollution Control
District
Sutler County
Air Pollution Control
District






Tulare County
Air Pollution Control
District






Colorado

Colorado Department of
Health, Air Pollution
Control Division



Tri-County District
Health Department



Odor Ordinance
or Nuisance Law
Governing Odor?
No


No


Yes. Rules and
Regulations ,
Rule 4.4.






Yes. Rules and
Regulations,
Sec. 304.








Yes. Regulation
2.




No. This
agency applies
State odor
ordinance .
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints





































If Deemed
Offensive/
Objectionable





































Dilution
Device
Reading
























Scentometer
may be used












If Detectable

























After dilution with
odor free air:
>7vol.su
>15 vol.W










Frequency
of Odor
























2 meas.
within one
hour, at
least 15
minutes
x
apart








Duration
of Odor





































Exceptions








Odors from
agricultural
operations
in the grow-
ing of crops
or raising
of fowls or
animals.

Odors from
agricultural
operations
in the grow-
ing of crops
or raising
of fowls or
animals.

Mfg. or agr.
source usinj
best practi-
cal control,
unless odor
detected af-
ter dilution
with i!27
vol. o.f.a.




Prohibition( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law






A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.
A person shall not discharge from any source
whatsoever such quantities of air contaminants
or other material which cause injury, detri-
ment, nuisance or annoyance to any consider-
able number of persons or to the public or
which endanger the comfort, repose, health or
safety of any such persons or the public or
which cause or have a natural tendency to cause
injury or damage to business or property.

No person, wherever located, shall cause or
allow the emission of odorous air contaminants
from any single source such as to result in
detectable odors which are measured in excess
of established limits (see other columns) .








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Name of Agency
(by State)
Boulder City-County
Health Department

City and County of Denver
Air Pollution Control
Section

El Paso City-County
Health Department

Jefferson County
Health Department

Mesa County
Department of Public
Health

Weld County
Health Department

Odor Ordinance
or Nuisance Law
Governing Odor?
No. This
agency applies
State odor
ordinance .
No. This
agency applies
State odor
ordinance.
No. This
agency applies
State odor
ordinance .
No. This
agency applies
State odor
ordinance .
No. This
agency applies
State odor
ordinance.
No. This
agency applies
State odor
ordinance.
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints












If Deemed
Offensive/
Objectionable












Dilution
Device
Reading












If Detectable












Frequency
of Odor












Duration
of Odor












Exceptions












Prohibition( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law













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Name of Agency
( by State)

Connecticut

State of Connecticut
Department of Environ-
mental Protection, Air
Pollution Control Section





City of Bridgeport
Department of Air
Pollution Control













Falrfield Health
Department
Greenwich Health
Department



Odor Ordinance
or Nuisance Law
Governing Odor?


Yes. Statutes
and Regulations
Concerning
Clean Air,
Secs.l9-13-G29
and 19-13-G16.




Yes. Air Pollu-
tion Control
Ordinances,
Secs.l9-13-G29,
19-13-G15, and
44-14.










No

Yes . Sanitary
Code, Sec.
16.3.5.


Condltion(s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints





























If Deemed
Offensive/
Objectionable


























By persons-101


Dilution
Device
Reading






























if Detectable































Frequency
of Odor






























Duration
of Odor






























Exceptions
































Prohibition( s ) and
Control Requirement(s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer or allow to be
emitted into the open air such quantity of odor-
ous matter in such place or manner as to have
the effect, beyond his own property line, of
being detrimental to members of the public or
of interfering with the appetite, sleep or other
environmental health factors of such members.
No person shall construct, install, use or cause
to be used any incinerator \vhich will result in
odors that are either annoying or harmful to
health in any area of normal human use or
occupancy.
No person shall cause suffer or allow to be
emitted into the open air such quantity of odor-
ous matter in such place or manner as to have
the effect, beyond his own property line, of
being detrimental to members of the public or
of interfering with the appetite, sleep or other
environmental health factors of such members.
No person shall construct, install , use or cause
to be used any incinerator which will result in
odors that are either annoying or harmful to
health in any area of normal human use or
occupancy.
No person shall construct, install, use or cause
to be used any equipment or process which will
result in odors that are either annoying or
harmful to health in any area of normal human
use or occupancy.


No person shall cause, suffer, allow or permit
release of one or more air pollutants of such
quantities and such characteristics and duration
as to create objectionable odors on or near to
residential, recreational, retail sales, hotel
or educational premises.

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Name of Agency
(by State)
City of Meriden
Department of Health
City of Milford
Department of
Environmental Health
New Britain
Health Department
City of New Haven
Health Department,
Bureau of Environmental
Health
City of Norwalk
Department of Health
Delaware
State of Delaware
Air Pollution Control
Division

Odor Ordinance
or Nuisance Law
Governing Odor?
Noa
No
No
Yes. Air Pollu-
tion Control
Code, Sec. 28.
Yes. City Code,
Sec. ll-6(g).
No
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints






If Deemed
Offensive/
Objectionable




By persons)0*

Dilution
Device
Reading






If Detectable




Above threshold
levels of chemical
species as defined
by the Manufac-
turing Chemical
Association.

Frequency
of Odor






Duration
of Odor






Exceptions



Upset
conditions,
breakdown,
or sched.
maint. of
equipment:


Prohlbltion( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer or allow to be
emitted into the open air such quantity of odor-
ous matter in such place or manner as to have
the effect, beyond his own property line, of being
detrimental to members of the public or of in-
terfering with the appetite, sleep or other envi-
ronmental health factors of such members .


No person shall cause, suffer, allow or permit
release of one or more air pollutants of such
characteristics and duration as to create
objectionable odor.
No person shall cause, suffer, allow or permit
release of one or more air pollutants of such
quantities and such characteristics and duration
as to create objectionable odors on or near to
residential, recreational, retail sales, hotel
or educational premises .


-------
Name of Agency
( by State)
District of Columbia
District of Columbia
Air Pollution Division
Florida
State of Florida
Department of Pollution
Control
Broward County
Air and Water Pollution
Control Board
Hlllsborough County
Environmental Protection
Commission
Metropolitan Dade County
Pollution Control
Department
Pinellas County
Health Department
Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Air Quality
Control Regu-
lations, Sec.
8-2:715.
Yes
No
Yes. Pollution
Control Act,
Sec. 17.
Yes. County
Code, Sec. 24-
3(14).
Proposed: Sees
24-14 and 24-26
No
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints






If Deemed
Offensive/
Objectionable
By the
Director





Dilution
Device
Reading
No. 2 odor
strength





If Detectable



By a considerable
number of persons
or the public, at
or beyond the
property limits of
the premises of
the person respon-
sible for source.
By a considerable nc
of persons or the
public, at or beyonc
the property limits
of the premises of
the person respon-
sible for source.

Frequency
of Odor
2 measure
within oni
least IS i
apart



,

Duration
of Odor
nents
; hour, at
linutes





Exceptions






Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer, or allow an emis-
sion into the atmosphere of odorous or other
air contaminants from stationary sources In
sufficient quantities and of such characteristics
and duration as Is, or is likely to be, injurious
to the public welfare , to the health of human
beings, to plant or animal life, or which inter-
feres with the reasonable enjoyment of life and
property.
Odor control is accomplished through State
nuisance laws.

No person shall cause, let, permit, suffer or
allow any emission into the atmosphere or
waters of any substance which may cause
injury, detriment or public nuisance to any
person or the public which endangers the com-
fort, repose, health or safety of any person or
the public, or which causes or has a natural
tendency to cause injury or damage to business ,
vegetation or animals.2
No person shall cause, or allow to be caused,
any nuisance.
Solvent vapor or odor emissions from plant sites
or other sources, as measured, at the user's
property line, shall not exceed the established
threshold limit values for solvent vapors or
odors. Threshold limit for styrene is 10 ppm.


-------


Name of Agency
( by State)

Georgia
State of Georgia
Department of Public
Health, Air Quality
Control Branch

Fulton County
Health Department



Hawaii
State of Hawaii
Division of Environmental
Health, Air Sanitation
Branch 	

Idaho

State of Idaho
Department of Health,
Air Pollution Control
Section







Illinois
State of Illinois
Environmental Protection
Agency








Odor Ordinance
or Nuisance Law
Governing Odor?
No





Yes. Health
Regulation No.
24, Sees. 16
and 9.


No





Noa










Yes. Rules and
Regulations
Governing the
Control of Air
Pollution, Sees.
3-3.280 and
3-3.400.





Condition( s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints





































If Deemed
Offensive/
Objectionable






By the health
officer and
persons^




























Dilution
Device
Reading





























Scentometer
used








If Detectable






























After dilution with
odor free air:
8 vol.1
24 vol. v
16 vol.w








Frequency
of Odor





























2 positive
concurrent
determina-
tions by 3
trained
inspectors
in 1 hour,
at least
15 min.
apart.







Duration
of Odor






































Exceptions







Diesel en-
gines equip-
ped & oper-
ated to mini
mize objec.
odors.




Accidental
spills or
operation
upsets .









Equipment
used exclu-
sively for
processing
food for
human con-
sumption
and in food
service es-
tablishm'ts
Upset
conditions ,
breakdown
or sched.
maint. of
equipment.

Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law





No person shall permit the emission of objection-
able odors from any source under his control.
No person shall construct a new incinerator
within Fulton County unless. . . it has a secon-
dary burner for use when necessary to destroy
smoke and/or oJors.




No person shall allow, suffer, cause or permit
the emission of odorous gases, vapors, or
mists into the atmosphere in such quantities as
to cause a hazard or a nuisance.
No person shall allow, suffer, cause or permit
any plant engaged in the processing of animal,
mineral, or vegetable matter or chemical pro-
cesses utilizing animal, mineral or vegetable
matter to be operated without employing suit-
able measures for the control of odorous emis-
sions including wet scrubbers, incinerators, or
such other services as may be approved by the
Commission.
No person shall operate or use any device, ma-
chine, equipment, or other contrivance for the
inedible rendering of animal or marine matter
unless all gases , vapors and gas entrained ef-
fluents from these processes shall be controlled
in such manner as to effectively abate any ob-
jectionable odor nuisance, fa the event that th<
rendering processes of more than one company
are contributing to the objectionable odor nui-
sance, abatement shall be deemed effective
when the odor concentration from each process
is not more than 120 odor units per cubic foot.
Installation or use of any equipment to reduce or
conceal an emission which would otherwise con
stitute a violation is prohibited.


-------
Name of Agency
(by State)
Bedford Park
Air Pollution Control
Department
East St. Lcuis
Air Pollution Control
City of Evanston
Air Pollution Control
Division
Morton Grove
Air Pollution Control
Commission
Quad City Area
Regional Air Pollution
Control Agency
Indiana
Indiana State Board of
Health, Division of Air
Pollution Control
Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Ordinance
(no. unknown) ,
Sec. 7.
No
No
Yes. Air Pollu-
tion Control
Ordinance,
Sec. 22.606
2(b).
No
No
Condltlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints






If Deemed
Offensive/
Objectionable






Dilution
Device
Reading






If Detectable
•





Frequency
of Odor






Duration
of Odor






Exceptions






Prohibltlon( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
The discharge Into the outdoor atmosphere of
air contaminants so as to cause air pollution
is a violation of this Ordinance.2


Escape or emission from any source whatsoever
of. . .noxious odor. . .In such quantity or In such
manner as to be annoying to the community, or
so as to endanger or be detrimental to the
health, safety, comfort, or well-being of Its
inhabitants, Is hereby declared to be a public
nuisance and is prohibited.



-------


Name of Agency
(by State)

City of East Chicago
Department of Air
Quality Control









City of Evansvllle
Air Pollution Control
Department











City of Hammond
Department of Air
Pollution Control
City of Indianapolis,
Environmental Control
Division





Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Air Quality
Control Ordi-
nance, Sees.
6.14 through
6.16.








Yes. Air Pollu-
tion Control
Ordinance,
Sees. 941.515
through 941. 517
and941.506(c).









No


Yes. Rules,
Regulations,
and Standards,
Regulation IV.



Condltlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints
































If Deemed
Offensive/
Objectionable



























Id
By persons,
without
dilution;8
By persons,
after dilution
with 5 or 20
vol. odor
free air?

Dilution
Device
Reading

































If Detectable


































Frequency
of Odor

































Duration
of Odor

































Exceptions


Upset
conditions
or break-
down of
any process
or equip-
ment. v






Upset
conditions
or break-
down of
any process
or equip -
ment.y
















Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
It is unlawful for any person to permit or cause
the emission of such quantities of air contami-
nants from whatever source in such place or
manner as to be detrimental to any person or
to the public or to endanger the health, comfort
or safety of any person or the public, or in
such manner as to cause or have a tendency to
cause injury or damage to property or busi-
2
ness.
Installation or use of any equipment for the sole
purpose of diluting or concealing an emission
is prohibited.
No person shall permit or cause the emission of
such quantities of air contaminants from what-
ever source in such place or manner as to be
detrimental to any person or to the public or to
endanger the health, comfort, or safety of any
person or the public, or in such manner as to
cause or have a tendency to cause injury or
damage to property or business.2
Installation or use of any equipment for the pur-
pose of diluting or concealing the emission of
air contaminants is prohibited.
No incinerator shall emit or produce odorous
material arising from the installation which is
detectable beyond the premises on which the
installation is located.



No person shall cause, suffer, allow or permit
the emission of gaseous materials in such
quantities to cause an "objectionable odor":
in areas zoned residential; in industrial areas,
as shown in another column.




-------

Name of Agency
( by State)

City of Michigan City
Air Pollution Control
Division








Porter County
Health Department
St. Joseph County
Health Department,
Division of Pollution
Control
Vigo County
Health Department,
Division of Air Pollution
Control













Odor Ordinance
or Nuisance Law
Governing Odor?
Yes










No

No
Yes. Air Quality
Control Ordi-
nance, Sees.
412 and 413.












Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints






























If Deemed
Offensive/
Objectionable














By persons
"not asso-
ciated with
the problem"












Dilution
Device
Reading































If Detectable

Ml District (ltd.
mfg.): in excess
of odor threshold,
measured beyond
lot line; M2-M3
Districts ( general
mfg.): in excess
of odor threshold,
measured beyond
M2 & M3 Districts
boundary line.




















Frequency
of Odor































Duration
of Odor































Exceptions

































Proni-bition( s) 
-------


Name of Agency
(by State)

Iowa
Iowa State Department of
Health, Environmental
Engineering Service
Black Hawk County
Health Department
Linn County
Health Department
(City of Cedar Rapids)


Des Moines-Polk County
Health Department

( continued on the
next page)





















Odor Ordinance
or Nuisance Law
Governing Odor?

No


No

Yes . Ordinance
No. 81-70,
Sees. 26.11
and 26. 23.

Yes. Air Pollu-
tion Regulation,
Sees. 5-15(3),
5-16(1), 5-5(2)
B-2, 5-11, 5-12
and 5-20.


















Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints



































If Deemed
Offensive/
Objectionable






By agency,
based on
detection
criteria


























Dilution
Device
Reading






Scentometer
used



Scentometer
may be used
























If Detectable







After dilution with
odor free air:
4 vol.01
20 vol. v*
_ , WY
8 vol.1™
After dilution with
7 vol. odor free
air























Frequency
of Odor










2 separate
trials
within 1
hour, at
least 15
minutes
apart



















Duration
of Odor




































Exceptions












Equipment
used ex-
clusively
for the
processing
of food for
human
consump-
tion.

Any plant
subject to
& opera-
ting under
inspection
by the
Meat
Inspection
Division
of the
U.S.Dept.
of
Agricul-
ture.

Prohlbition( s) and
Control Requirement( s)
Specified in Odor Ordinance
or Nuisance Law






No person shall cause or permit the emission of
any objectionable odorous matter into the
ambient air.
It shall be unlawful to install a device to conceal
emissions for the purpose of circumvention of
. . .applicable Air Pollution Control Ordinances.
Any act of emission of . . .poisonous, noxious,
toxic or offensive odors from any single source
in violation or excess of the limitations estab-
lished in or pursuant to this ordinance shall be
deemed and is hereby declared to be a public
nuisance.
No person may cause, permit, or allow the
emission of odorous gases or matter in such
durations as to cause an objectionable odor.
All incinerators shall be designed and operated
so that all gases, vapors, and entrained efflu-
ents shall, while passing through the final com-
bustion chamber, be maintained at a tempera-
ture adequate to prevent the emission of
objectionable odors, provided, however, that
the Health Officer shall approve any other
method of odor control which is equally
effective.
No slaughterhouse, building or place for
slaughtering of animals shall be allowed or
permitted to emit odorous gases or matter. . .
that is injurious or dangerous to the health.
comfort or property of individuals or to the
public.

-------

Name of Agency
( by State)

(continued)

Des Moincs-Polk County
Health Department








Kansas
Kansas State Department
of Health, Division of
Environmental Health
Kentucky
Kentucky Air Pollution
Control Commission


Air Pollution Control
District of Jefferson
County
Louisiana
Louisiana State Department
of Health, Air Control
Section, Bureau of
Environmental Health

Odor Ordinance
or Nuisance Law
Governing Odor?













No



Yes. Air Pollu-
tion Control
Law, Regula-
tion No. 9.
Yes


No



Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints




























If Deemed
Offensive/
Objectionable




























Dilution
Device
Reading

















Scentometer
used










If Detectable


















After dilution with
7 vol. odor free
air









Frequency
of Odor





























Duration
of Odor





























Exceptions






























DvnhlHiHnn/ cS onH
rroniDicion^ sj ana
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
A person shall not operate or use any article.
machine, equipment or other contrivance for
the reduction of animal matter unless all non-
condensable toxic or odorous gases or matter,
effluents from such article, machine, equip-
ment or other contrivance are incinerated or
processed in such a manner as determined by
the Health Officer to be effective for the purpost
of air pollution control.
Installation or use of any equipment which con-
ceals an emission which would otherwise
constitute a violation is prohibited.









Odor control has been attained through a
"nuisance" regulation.






-------


Name of Agency
(by State)

Maine
State of Maine
Department of Environ-
mental Protection

Maryland

Maryland State Department
of Health and Mental
Hygiene, Bureau of Air
Quality








Allegany County
Health Department












Anne Arundel County
Department of Health,
Division of Environmental
Health, Air Quality
Control Section









Odor Ordinance
or Nuisance Law
Governing Odor?

No





Yes. Regulations
Governing the
Control of Air
Pollution, Sees.
43P060401
(AreaV),
43P050401
(Area IV), and
43P040406
(Area III) .


No. State
"Regulations
Governing the
Control of Air
Pollution," as
stated in the
Prohibition(s)
column, are
applied.





No. State
"Regulations
Governing the
Control of Air
Pollution," as
stated in the
Prohtt>ition( s)
column, are
applied.



Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints











































If Deemed
Offensive/
Objectionable











































Dilution
Device
Reading












































If Detectable













































Frequency
of Odor












































Duration
of Odor












































Exceptions






Any
installation
engaged
exclusively
in the
processing
of food for
human
consump-
tion.





























Pr ohibition( s ) and
Control Requirement a)
Specified in Odor Ordinance
or Nuisance Law




No person shall cause, suffer, allow or permit
any discharge of gases , vapors or odors beyonc
the property line of an installation in such a
manner that a nuisance or air pollution is
created.
No person shall cause, suffer, allow or permit
the use of any installation primarily engaged in
the reduction of offal or vegetable oil unless
all gases, vapors and gas -entrained matter
from gaid installation are: ( 1) First cooled to
i 160 F and then (2) The non-condensable
fraction is incinerated at £1400°F for i 0.4
second. (3) Alternate methods may be used If
determined by the Department to be equally or
more effective for the purpose of controlling
air pollution. Any person processing or incin-
erating gases, vapors or gas -entrained matter
as required above shall install, operate and
maintain in good working order and calibration,
continuous recording devices for indicating
temperature, or pressure or other operating
conditions. Such devices shall be approved by
the Department. . .No person shall cause, suffer
allow or permit any offal or vegetable oil to be
handled, transported or stored or to undertake
the preparation of any offal or vegetable oil
without taking reasonable precautions to pre-
vent odors from being discharged. Such rea-
sonable precautions. . . shall include. . . ( 1)
Storage of all offal or vegetable oil, prior to or
in the process of preparation, in properly en-
closed and vented equipment or areas , together
with the use of effective devices and/or methods
to prevent the discharge of odors or odor bear-
ing gases. (2) Use of covered vehicles or con-
tainers of watertight construction for the han-
dling and transporting of offal or vegetable oil.
( 3) Use of hoods and fans to enclose and vent
the storage, handling, preparation and convey-
ing of any odorous materials together with ef-
fective devices and/or methods to prevent
emissions of odors or odor bearing gases .

-------

Name of Agency
(by State)


Baltimore City Health
Department, Division
of Air Pollution Control






Baltimore County
Department of 1 lealth




Frederick County
Health Department, Air
Quality Control





Montgomery County
Health Department,
Division of Environmental
Health





Prince George's County
Health Department










Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Air Pollu-
tion Control
Ordinance, Sec.
7 A. Also, Stale
"Regulations
Governing the
Control of Air
Pollution," as
previously sta-
ted, are applied.
Noc




No. State
"Regulations
Governing the
Control of Air
Pollution," as
previously
stated, are
applied.
Yes. Ord. No.
6-40, Sec. 74-5.
Also.State'Reg-
ulations Govern-
ing the Control
of Air Pollution,"
as previously
stated, are
applied.
Yes. Air Pollu-
tion Control
Ordinance, Sec
9c, f, and g.
Also,State"Reg-
ulatlons Govern
Ing the Control
of Air Pollution,'
as previously
stated, are
applied.

Condltlon( s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints










































If Deemed
Offensive/
Objectionable










































Dilution
Device
Reading











































If Detectable












































Frequency
of Odor











































Duration
of Odor











































Exceptions
































Unusual
conditions
or mal-
function
of equip -
ment.y






P«*nhiVilfinn/ B\ anH
rruniDHion{ a) ana
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person, firm, corporation or agency oper-
ating or using, or intending to operate or use.
any equipment, process, structure or space,
indoors or outdoors, static or mobile, shall
allow such equipment, process, structure or
space, to emit any noxious acid, gas, vapor.
odor. . .in such manner as to be dangerous or
detrimental to the health or safety of the public
or to interfere unreasonably with the comfort
of the public.
No person shall cause, suffer, allow or permit
the discharge Into the atmosphere of gaaes.
vapors or odors beyond the property line in
such a manner that a nuisance or air pollution
is created.








Odor may be treated as a nuisance.
Any condition or operation which results in the
creation of odors of such intensity and charac-
ter as to be detrimental to the health and
welfare of the public or which interferes un-
reasonably with the comfort of the public shall
be removed, stopped or so modified as to
remove the odor.

No person shall cause , suffer or allow any
emissions of gases, vapors or odors beyond
the property line from which such emissions
occur, to be in sufficient quantities and of such
characteristics and duration as is or is likely
to be injurious to the public welfare, to the
health of human, plant or animal life, or to
property, or which interferes with the enjoy-
ment of life and property.
Installation or use of any equipment for the sole
purpose of diluting or concealing an emission
is prohibited.

-------


Name of Agency
(by State)


Massachusetts

City of Boston
Air Pollution Control
Commission





Metropolitan Boston
Air Pollution Control
District







Pioneer Valley
Air Pollution Control
District







Michigan

Michigan Department
of Public Health,
Division of Occupational
Health, Air Pollution
Control Section





Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Regulations
for the Control
of Atmospheric
Pollution, Reg.
2. Also, State
Regulations for
the Control of
Air Pollution,
Reg. 9, as sta-
ted below, are
locally enforced
No. State
"Regulations
for the Control
of Air Pollu-
tion," as
stated in the
Prohibition(s)
column, are
enforced
locally.
No. State
"Regulations
for the Control
of Air Pollu-
tion," as
stated in the
Prohibition(s)
column, are
enforced
locally.


Yes. Rules
R 336. 46 and
R336.48.





Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints







































If Deemed
Offensive/
Objectionable







































Dilution
Device
Reading








































If Detectable









































Frequency
of Odor








































Duration
of Odor








































Exceptions






























Abnormal
conditions
or break-
down of
equipment^






Prohibition(s) and
Control Requirement^ s)
Specified in Odor Ordinance
or Nuisance Law

No person or persons owning, leasing, or
controlling the operation of any air contamina-
tion source or sources shall willfully, negli-
gently, or through failure to provide necessary
equipment or facilities or to take necessary
precautions, permit the emission from said
air contaminant source or sources of such
quantities of air contaminants which will cause
a condition of atmospheric pollution.2

No person having control of any dust or odor
generating operations such as, but not limited
to, land clearing, construction work, dump
operation, building demolition, or agricultural
operation shall permit emissions therefrom to
the extent that such cause or contribute to a
condition of air pollution.











No person shall cause or permit the emission of
an air contaminant or water vapor, including
an air contaminant whose emission if not
otherwise prohibited by these rules, or an air
contaminant or water vapor which reacts or
may react with any other air contaminant or
natural air, and which causes or will cause
detriment to the safety, health, welfare or
comfort of any person, or which causes or will
cause damage to property or business.2

-------


Name of Agency
(by State)


City of Flint
Department of Public
Works and Utilities
















Muskegon County
Health Department,
Air Pollution Control
Section






Wayne County
Department of Health,
Air Pollution Control
Division














Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Ordinance
No. 297. Sees.
20.3 and 20.5.
















Yes. Air Pollu-
tion Control
Rules and Regu-
lations, Art.IV,
Sees. F and H.





Yes. Air Pollu-
tion Control
Regulation,
Sees. 6.5,
6.6, and 6.3F.











Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints















































If Deemed
Offensive/
Objectionable















































Dilution
Device
Reading
















































If Detectable

















































Frequency
of Odor
















































Duration
of Odor
















































Exceptions






















Abnormal
conditions
and break-
down of
equipment'




Upset
conditions
or break-
down of
equipment?













Prohibitions ) and
Control Requirement a)
Specified In Odor Ordinance
or Nuisance Law
No person shall keep, place or have on or In any
private house, place of business, lot or prem-
ises within the City of Flint, any dead carcass
... or other animal or vegetable matter or sub-
stance which may cause any unwholesome, ob-
noxious or offensive smell. Nor shall any per-
son collect or confine any horse. . .or other
domestic or undomesitcated animal. . .in pens
... or otherwise so as to create an unwhole-
some, unsightly, malodorous, obnoxious or
offensive condition.
Any cart. . . or other vehicle used for the purpose
of conveying away swill, offal, garbage or
excrement shall be perfectly tight and covered
so as to prevent the contents from leaking.
spilling or becoming offensive because of odor,
and no such cart. . .or vehicle when not actually
in use, shall be allowed In any street. . .or pub-
lic place within the limits of the City of Flint.
No person shall cause or permit the emission of
an air contaminant or water vapor, including
an air contaminant whose emission is not other-
wise prohibited by these rules, or an air con-
taminant or water vapor which reacts or may
react with any other air contaminant or natural
air, and which causes or will cause detriment
to the safety, health, welfare or comfort of any
person, or which causes or will cause damage
to property or business.2
It shall be unlawful for any person to permit or
cause the emission of such quantities of air
contaminants from whatever source in such
place or manner as to be detrimental to any
person or to the public or to endanger the
health, comfort, or safety of any person or the
public, or in such manner as to cause injury
or damage to property or business.2
When the odor of hydrogen sulfide is found to exist
beyond the property line of the source, mea-
surements shall be taken by the method set
forth In another section and if measured levels
of hydrogen sulfide are found to be in excess of
0.005 ppm by volume for a maximum period of
2 consecutive minutes, the person causing or
permitting such emissions into the atmosphere
shall be deemed in violation of this section.

-------


Name of Agency
(by State)


Minnesota

Minnesota Pollution
Control Agency,
Division of Air
Quality
















St. Cloud
Health Department




St. Louis County
Health Department













Odor Ordinance
or Nuisance Law
Governing Odor?



Yes. Air
Quality Regu-
lation, Sees.
b through f .
















Yes. Ordinance
No. 668, Sec.
6.



Yes












Conditlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints










































If Deemed
Offensive/
Objectionable










































Dilution
Device
Reading











































If Detectable












































Frequency
of Odor











































Duration
of Odor











































Exceptions


Agri-
business.

Upset
conditions
or break-
down of
equipment^




















Temporary
operational
breakdown
or cleaning
of air
pollution
control
equipment,
unless an
immed.
public
health
hazard
re suits .v

Frohibltion(s) and
Control Requirement a)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, permit or allow emission
into the ambient air of odorous air contaminants
in excess of the standards and parameters whicl
follow: ( 1) Odor sources emitting from well-
defined stacks >50 ft. above grade elevation
and with adequate dispersion characteristics as
determined by the Agency shall not emit odors
in > 150 odor concentration units. (2) Odor
sources of < 50 ft. elevation above grade or
otherwise falling to create good dispersion
conditions as determined by the Agency shall
not emit >25 odor concentration units. (3) No
odor source shall have an odor emission rate
> 1,000,000 odor concentration units /minute.
(4) No odor source shall emit air contaminants
into the ambient air which cause odor outside
the alleged polluter's property line in excess
of the following limitations: ( a) One odor unit
in areas zoned residential, recreational, insti-
tutional, retail sales, hotel or educational.
( b) Two odor units in areas zoned light Indus .
( c) Four odor units in areas zoned other than
in subsections (a) and (b) above.
The production or maintenance of Air Pollution
within the City is deemed to be a public
nuisance; it shall be unlawful for any person to
cause or maintain an air pollution nuisance in
the City.2
No person shall cause, suffer, or allow any
emissions of gases, vapors, or odors beyond
the property line from which such emissions
occur, to be in sufficient quantities and of such
characteristics and duration as is or is likely
to be injurious to the public welfare, to the
health of human, plant or animal life, or to
property, or which interferes with the enjoy-
ment of life and property.
In the absence of appropriate control measures
no person shall use products which, either by
themselves or due to additives or impurities.
result in air pollution.


-------


Name of Agency
(by State)


Mississippi

Mississippi Air and
Water Pollution
Control Commission


Missouri

Missouri Air
Conservation Commission



































Odor Ordinance
or Nuisance Law
Governing Odor?



Yes. Air
Quality Regu-
lations, Sec.
3.4.



Yes. Air
Quality Stan-
dards and Air
Pollution Con-
trol Regulations
Regulations XV
(AandB). XVI
(A2, B. andC),
andS-IV (D3
and F).

























Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints














































If Deemed
Offensive/
Objectionable









hmt
By persons;
By persons""1
after dilution
with odor
free air:
> 20 vol/
> 4 vol.





























Dilution
Device
Reading















































If Detectable
















































Frequency
of Odor















































Duration
of Odor















































Exceptions









Equipment
used
exclusive!;
for the
processing
of food for
human
consump-
tion in
food
service
establish-
ments.

Incinerators
on resides
tial prem-
ises and
used exclu-
sively to
dispose of
refuse
originating
on the same
premises,
provided
that the
total no.
of dwelling
units on
that prem-
ises does
not exceed
four.





Prohibition) s) and
Control Requirement! a)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, permit, or allow the
emission of particles, or any contaminants la
sufficient amounts or of such duration from any
process as to be injurious to humans, animals,
plants, or property, or to be a public nuisance.
or create a condition of air pollution.

No person shall emit odorous matter such as to
cause an objectionable odor: (1) on or adjacent
to residential, recreational, Institutional, re-
tail sales, hotel or educational premises; (2)on
or adjacent to industrial or other premises, as
shown in another column.
No person shall operate or use any device, ma-
chine, equipment or other contrivance for the
reduction of animal matter unless all gases,
vapors, and gas -entrained effluents from such
facility are incinerated at * 1200°F for * 0.3
second, processed in such manner as deter-
mined by the Executive Secretary to be equally
or more effective for the purpose of air pollu-
tion control. Effective devices and/or mea-
sures shall be installed and operated such that
no vent, exhaust pipe, blow-off pipe or opening
of any kind shall discharge into the outdoor air
any odorous matter, vapors, gases, or dusts
or any combination thereof which create odors
or other nuisances In the neighborhood of the
plant. Odor producing materials shall be
stored and handled in a manner such that odors
produced from such materials are confined.
Accumulation of odor producing materials re-
sulting from spillage or other escape is pro-
hibited. Odor bear ing gases, vapors, fumes,
or dust arising from materials in process
shall be confined at the point of origin so as to
prevent liberation of odorous matter.
All new incinerators shall be designed and
operated so that all gases, vapors and en-
trained effluents shall, while passing through
the final combustion chamber, be maintained
at a sufficient temperature to destroy all odor.
provided, however, that the Executive Secretary
shall approve any other method of odor control
which he determines is equally effective.

-------


Name of Agency
( by State)


Greene County-City of
Springfield Air Pollution
Control Authority





Independence
Health Department



Kansas City
Health Department














City of St. Louis
Division of Air Pollution
Control

( continued on the
next page)









Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Air Pollu-
tion Control
Standards, Sees.
2A-39, 2A-40.
and2A-47.



Yes. Ordinance
No. 1977, Sees.
11. 156 and
11.163.

Yes. Air Pollu-
tion Control
Code, Sees.
18.98, 18.88,
and 18.90(82).











Yes. Air Pollu-
tion Ordinance
54699, Sees.
22, 23, and 38
and Ordinance
50163, Sec. 15.







Condition( a) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints









One6




One,6
verified
at point
of
complaint






















If Deemed
Offensive/
Objectionable

By persons;1™1
By persons lun
after dilution
with odor
free air:
>20 vol.v
>4vol.w

































Dilution
Device
Reading









No. 2 odor
strength



No. 2 odor
strength


























If Detectable











































Frequency
of Odor









2 measurei


Duration
of Odor









nents
within one hour,
at least 15 min.
apart



2 measurements
within one hour.
at least 15 min.
apart















































Exceptions


Upset
conditions
in or break
down of
equipment-




Uncontrol-
lable force
or upset
conditions!
Uncontrol-
lable force
or upset
conditions]












Upset
conditions,
breakdown
or sched-
uled
mainte-
v
nance.'








Prohibltion(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall emit odorous matter such as to
cause an objectionable odor: (l)on or adjacent
to residential, recreational, institutional,
retail sales, hotel or educational premises;
(2) on or adjacent to Industrial or other
premises, as shown in another column.
Installation or use of any equipment for the sole
purpose of diluting or concealing an air
contaminating emission is unlawful.
No person shall cause or permit odorous
emissions so as to cause a violation (see
other columns for specifics) .

The emission into the ambient air of air con-
taminants resulting in air pollution. In violation
of any section under this article, is declared to
be and shall constitute a public nuisance, and it
shall be unlawful for any person to cause, per-
mit or maintain any such public nuisance.
No person shall cause or permit odorous emis-
sions so as to cause air pollution.
All incinerators shall be designed and operated
so that all gases, vapors and entrained effluents
shall, while passing through the final combus-
tion chamber, be maintained at a temperature
adequate to prevent the emission of objection-
able odors. Provided however, that the direc-
tor shall approve any other method of odor con1
trol which he determines is equally effective.
No person shall cause or permit the emission of
odorous matter so as to cause an odor amount-
Ing to air pollution: (1) on or adjacent to prem-
ises situated in residential, local business, or
central business districts; (2) on or adjacent to
premises located in industrial or unrestricted
districts, when diluted with 20 vol. of odor free
air; (3) on or adjacent to premises located in
the commercial districts, when diluted with
4 vol. of odor free air.
The emission or escape into the open air within
the city. . .from any source or sources whatso-
ever , of . . . odors ... in such manner or in such
amounts as are detrimental to or endanger the
health, comfort, safety or welfare of or cause

-------


Name of Agency
(by State)

(continued)

City of St. Louis
Division of Air Pollution
Control



























St. Louis County
Health Department
Division of Air Pollution
Control










Odor Ordinance
or Nuisance Law
Governing Odor?
































Yes. Air Pollu-
tion Control
Code, Regula-
tions XV and
XVI.







Conditlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints













































If Deemed
Offensive/
Objectionable
































By persons!™'
By persons hm
after dilution
with odor
free air:
> 20 vol.v
> 4 vol.w






Dilution
Device
Reading














































If Detectable















































Frequency
of Odor














































Duration
of Odor














































Exceptions


































Equipment
used
exclusively
for the
processing
of food for
human
consump-
tion in food
service
establish-
ments .

Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
severe annoyance or discomfort to, or is offen-
sive and objectionable to the public, or shall
cause injury or damage to property or inter-
fere with the normal conduct of business, is
hereby declared to be and shall constitute a
public nuisance. . .It shall be unlawful for any
person to cause, permit or maintain any such
public nuisance.
No person shall operate or use any device, ma-
chine, equipment or other contrivance for the
reduction of animal matter unless all gases.
vapors, and gas -entrained effluents from such
facility are incinerated at i!200°F for i 0.3
second, or processed In such a manner as de-
termined by the Commissioner to be equally or
more effective for the purpose of air pollution
control. Effective devices and/or measures
shall be Installed and operated such that no
vent, exhaust pipe, blow-off pipe or opening of
any kind shall discharge into the outdoor air
any odorous matter, vapors, gases, or dusts
or any combination thereof which create odors
or other nuisances in the neighborhood of the
plant. Odor producing materials shall be
stored and handled in a manner such that odors
produced from such materials are confined.
Accumulation of odor producing materials re-
sulting from spillage or other escape is pro-
hibited. Odor bearing gases, vapors, fumes.
or dust arising from materials in process
shall be confined at the point of origin so as to
prevent liberation of odorous matter.
No person shall emit odorous matter such as to
cause an objectionable odor: (1) on or adjacent
to residential, recreational, institutional, re-
tail sales, hotel or educational premises; (2)
on or adjacent to industrial or other premises.
as shown in another column.
Control requirements and prohibitions regarding
the reduction of animal matter are the same as
those stated above for the City of St. Louis ,
except that Executive Secretary is substituted
for Commissioner.


-------


Name of Agency
(by State)


Montana

Montana State
Department of Health








Billings- Laurel -
Yellowstone County
Air Pollution
Control Program







Cascade County
Air Pollution
Control Program







Missoula City-County
Health Department






Odor Ordinance
or Nuisance Law
Governing Odor?



Yes. Regula-
tion 90-009.








Yes . Regulation
No. 009.
Agency's regu-
lations are
identical with
those of the
State .





Yes. Regula-
tions, Sec. XVI.
Agency's regu-
lations are
identical with
those of the
State .



Yes. Agency's
regulations are
identical with
those of the
State .

Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints







































If Deemed
Offensive/
Objectionable







































Dilution
Device
Reading








































If Detectable









































Frequency
of Odor








































Duration
of Odor








































Exceptions


Equipment
used
exclusively
for the
processing
of food for
human
consump-
tion in food
service
establish-
ments .




















Same as
above.





Prohibition( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer, or allow any
emissions of gases, vapors, or odors beyond
the property line in such manner as to create a
public nuisance.
A person operating or using any machine, device,
equipment, or other contrivance which dis-
charges into the outdoor air any odorous matter
or vapors, gases, dusts, or any combination
thereof which create odors, shall provide,
properly install, and maintain in good working
order and in operation such devices as may be
specified by the Director.
Odor producing materials shall be so stored and
handled that odors produced thereby do not
create a public nuisance. No person shall
accumulate such quantities of such materials
as to permit spillage or other escape.
Odor bearing gases, vapors, fumes, or dusts
arising from materials in process shall be so
confined at the point of origin as to prevent
liberation of odorous matter.
No person shall operate or use any device, ma-
chine, equipment or other contrivance for the
reduction of animal matter unless all gases,
vapors, and gas -entrained effluents from such
facility are incinerated at i 1200°F for i 0.3
second, or processed in such manner as deter-
mined by the Director to be equally or more
effective for the purpose of air pollution con-
trol. A person incinerating or processing
gases, vapors or gas -entrained effluents pur-
suant to this rule shall provide, properly in-
stall and maintain, in good working order and
in operation, devices as specified by the
Director for indicating temperature, pressure,
or other operating conditions.
The following prohibition is in addition to the
control regulations stated above.
Installation or use of any device which conceals
or dilutes an emission of air contaminant
which would otherwise violate an air pollution
control regulation is prohibited.

-------


Name of Agency
(by State)


Nevada

State of Nevada
Bureau of
Environmental Health



Clark County
District Health Depart-
ment) Air Pollution
Control Section


Washoe County
District Health
Department








New Hampshire

New Hampshire Air
Pollution Control
Agency





New Jersey

New Jersey State Bureau
of Air Pollution Control,
Division of Environmental
Quality, Department of
Environmental Protection


Odor Ordinance
or Nuisance Law
Governing Odor?



Yes. Air Pollu-
tion Control
Regulation XVII



Yes. Air Pollu-
tion Control
Regulations,
Sees. 29 and
12.

No.a Proposed:
Air Pollution
Control Regu-
lations, Sees.
040.050 and
020.085.







No.a Proposed:
Regulation No.
16.







Yes. Air Pollu-
tion Control
Code, Sec. 3.4.


Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints









Onee


































If Deemed
Offensive/
Objectionable




























By an Indepen-
dent panel, ll
when diluted
with odor free
air:
2 vol. in light
Indus, areas;
W
4vol.








Dilution
Device
Reading




























Scentometer
may be
used














If Detectable


After dilution with
> 8 vol. of odor
free air





After dilution with
i 2 vol. of odor
free air



After dilution with
i 8 vol. of odor
free air



























Frequency
of Odor

2 meas.
within 1
hour, at
least 15
minutes
apart


2 meas.
within 1
hour, at
least 15
m in. apart

2 meas.
within 1
hour, at
least 15
minutes
apart
























Duration
of Odor













































Exceptions


Upset,
breakdown
or sched.
maint.y





Upset,
breakdown
or sched.
maint.y

Upset,
breakdown
or sched.
malnt.y







Malfunction
or break-
down, up to
48 hoursv.
Odors re-
sultlngfron
the normal
production
and cultura
practices
of agric.








Prohibition( s) and
Control Requirement! 8)
Specified In Odor Ordinance
or Nuisance Law
It is unlawful for any person to discharge, or
cause to be discharged from any source whatso-
ever any material or air contaminant of any kirn
or description, which is or tends to be, offen-
sive to the senses or Injurious or detrimental to
health and safety, or which in any way unduly
interferes with or prevents the comfortable en-
joyment of life or property by any considerable
number of persons or the general public.2





It is unlawful for any person to discharge, or
cause to be discharged, from any source what-
soever, any quantity of odorous or gaseous
emissions, materials, or air contaminants of
any kind or description, which is, or tends to
be offensive to the senses, or injurious or
detrimental to repose, health, and safety, or
which in any way unduly interferes with or
prevents the comfortable enjoyment of life or
property by any considerable number of
persons or the general public.

No person shall cause, suffer, allow or permit
the discharge of materials into the ambient air
which cause or contribute to an objectionable
or obnoxious odor at any location occupied by
the public as follows: (1) in areas zoned resi-
dential, recreational, institutional, retail
sales, hotel or educational;(2) in areas zoned
light industrial and in areas other than those
already described ( see other columns for
specifics) .
No person shall construct, install, use or
cause to be used any common incinerator or
any special incinerator which will result in
odors being detectable by sense of smell in
any area of human use or occupancy.



-------


Name of Agency
( by State)


City of Elizabeth
Department of Health,
Welfare and Housing,
Division of Housing and
Inspections
Suburban Air Pollution
Commission
(West Orange)

New Mexico
State of New Mexico,
Environmental Improve-
ment Agency

City of Albuquerque
Department of
Environmental Health









New York

New York State
Department of
E nvironmental
Conservation









Odor Ordinance
or Nuisance Law
Governing Odor?

Yes . Sanitary
Code, Sees.
38-247 and 38-
284(86).

Yes. Air Pollu-
tion Code, Sec.
8:13.


Yes



Yes. Animal
Control Ordi-
nance, Sec. 39.











Yes. Rules to
Prevent Air
Pollution, Sees.
186. land 187. 3;
Ambient Air

Quality Stan-
dards, Table II.



Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints






































If Deemed
Offensive/
Objectionable






































Dilution
Device
Reading







































If Detectable








































Frequency
of Odor







































Duration
of Odor







































Exceptions








































Prohibition(s) and
Control Requirement^ s)
Specified in Odor Ordinance
or Nuisance Law
No person shall create, commit, maintain or
permit to be created, committed or maintained
any nuisance.2
No person shall cause, suffer, permit or allow
any odorous matter, vapor, gases, particulates
or any combination thereof to cause air pollution
No person shall construct, install, use or cause
to be used any common incinerator or any
special incinerator which will result in odors
being detectable by sense of smell in any area
of human use or occupancy.

Odor problems handled on a nuisance basis.


Any animal or animals that habitually or contin-
uously bark, howl or otherwise disturb the
peace and quiet of the inhabitants of the City of
Albuquerque or are kept or maintained in such
a manner or in such numbers as to disturb by
noxious or offensive odors or otherwise endan-
ger the health and welfare of the inhabitants of
the City of Albuquerque are declared to be an
animal nuisance. It shall be unlawful for any
person to keep, harbor or maintain an animal
nuisance as defined above within the City of
Albuquerque.
No person shall permit or cause any air contam-
ination source to produce air pollution.2
No person shall cause, permit or allow the
emission of air contaminants from an emission
source resulting from an operation begun or
modified, after the effective date of this Part,
which exceeds the permissible emission rates

specified.
Consistent with the economic and social well-
being of the community, the ambient air shall
not contain odorous substances in such concen-
trations or of such duration as will prevent
enjoyment and use of property.

-------


Name of Agency
(by State)


Brie County
Department of Health










Monroe County
Department of Health



County of Nassau
Department of Health,
Bureau of Air Pollution
Control




City of New York
Department of Air
Resources, Environ-
mental Protection
Administration












Odor Ordinance
or Nuisance Law
Governing Odor?

Yes . Sanitary
Code, Art. XIV,
Rules 7.5, 1.3k
and 4. 4.








Yes. Sanitary
Code, Art. V,
Sec. 11.1.


Yes. Local
Law 1-1967,
Sees. 9-21.46
and 9-21. 48.




Yes. Air Pollu-
tion Control
Code, Art. 9,
Sec. 1403.2-
9.01.










Conditlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints








































If Deemed
Offensive/
Objectionable








































Dilution
Device
Reading









































If Detectable










































Frequency
of Odor









































Duration
of Odor









































Exceptions










































Prohibitlon(s) and
Control Requirement^ s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause , suffer or allow air
pollutants to escape to the open air in such
amounts as to be a nuisance . A nuisance shall
be considered to exist when air pollutants are
allowed to escape to the open air in such
amounts to affect the health, comfort, or prop-
erty of any considerable number of persons.2
No incinerator regardless of size, date of manu-
facture or date of installation shall. . .release
to the atmosphere offensive and obnoxious
odors detectable to the Commissioner or his
agents at the property line.
No person owning, operating, in charge of or in
control of any air contamination source shall
cause, permit or participate in discharging
into the atmosphere any air contaminant which
causes air pollution. z
No person shall cause or permit the emission of
an air contaminant which causes or may cause
detriment to the health, safety, welfare or
comfort of any person, or causes or may
cause damage to property or business.2
Installation or use of any device to conceal or
mask an emission of an air contaminant shall
be unlawful.
No person shall cause or permit the emission of
air contaminant, including odorous air contam-
inant, or water vapor if the air contaminant,
or water vapor causes or may cause detriment
to the health, safety, welfare or comfort of any
person, or injury to plant and animal life, or
causes or may cause damage to property or
business, or if it reacts or is likely to react
with any other air contaminant or natural air ,
or is induced to react by solar energy to pro-
duce a solid, liquid or gas or any combination
thereof which causes or may cause detriment
to the health, safety, welfare or comfort of
any person, or injury to plant and animal life,
or which causes or may cause damage to
property or business .

-------
Name of Agency
(by State)
Niagara County
Health Department,
Division of Environmental
Health Services
Onondaga County
Department of Health,
Division of Environmental
Sanitation
Rockland County
Department of Health
Suffolk County
Department of
Environmental Control
North Carolina
State of North Carolina
Department of Water
and Air Resources
Western North Carolina
Regional Air Pollution
Control Agency
Unifour Air Pollution
Control Program

Odor Ordinance
or Nuisance Law
Governing Odor?
No
No
No
No
Yes. Rules and
Regulations
Governing the
Control of Air
Pollution,
Regulation No.
5.
Yes. Rules and
Regulations
Governing the
Control of Air
Pollution, Regu-
lation No. 5.
Yes. Regulations
Governing the
Control of Air
Pollution, Regu-
lation No. 5.
Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints







If Deemed
Offensive/
Objectionable







Dilution
Device
Reading







If Detectable







Frequency
of Odor







Duration
of Odor







Exceptions







Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law




No person shall cause, suffer, allow or permit
any plant engaged in the processing of animal,
mineral, or vegetable matter to be operated
without employing suitable measures for the
control of odorous emissions including wet
scrubbers, incinerators, or such other devices
as may be approved by the Board.
No person shall cause, suffer, allow or permit
any plant engaged in the processing of animal,
mineral, or vegetable matter to be operated
without employing suitable measures for the
control of odorous emissions including wet
scrubbers, incinerators, or such other devices
as may be approved by the. . .Board.
No person shall cause, suffer, allow or permit
any plant engaged in the processing of animal,
mineral, or vegetable matter to be operated
without employing suitable measures for the
control of odorous emissions including wet
scrubbers, incinerators, or such other devices
as may be approved by the Board.

-------


Name of Agency
(by State)


County of Forsyth
Air Quality Control
Department




Gaston County
Health Department



Ohio

State of Ohio
Department of Health,
Air Pollution Control
Board











Akron -Barberton-Summ It
County Air Pollution
Control Agency













Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Regulation
No. 7.00.





No. This
agency applies
State odor
regulations.



No.a Proposed
regulation:
AP-2-07.












Yes. Air Pollu-
tion Code, Sees.
755.12,
755.08.1(7 and
10), and 755.10
(E3).
\ w*








Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints










































If Deemed
Offensive/
Objectionable










































Dilution
Device
Reading











































If Detectable












































Frequency
of Odor











































Duration
of Odor











































Exceptions












































Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer, allow or permit
any plant engaged in the processing of animal,
mineral, or vegetable matter to be operated
without employing suitable measures for the
control of odorous emissions including wet
scrubbers, incinerators, or such other devices
as may be approved by the Air Quality Control
Director.




The emission or escape Into the open air from
any source or sources whatsoever, of. . .odors
. . .in such a manner or in such amounts as to
endanger or tend to endanger the health, com-
fort, safety or welfare of the public, or is un-
reasonably offensive and objectionable to the
public, or shall cause unreasonable injury or
damage to property or Interfere with the com-
fortable enjoyment of property or normal con-
duct of business, is hereby found and declared
to be a public nuisance. It shall be unlawful
for any person to cause, permit or maintain
any such public nuisance.
Installation or use of any device or any means
which conceals or dilutes an emission of air
contaminant which would otherwise violate any
regulations of the Board is orohi^ed.
No owner , occupant or person in charge ( by
himself, his agent or employee) of any fuel-
burning equipment , internal combustion en-
gine, incinerator, railroad locomotive, vehi-
cle, premises, open fire or stack, processes
or process equipment, shall cause, suffer or
allow, the discharge, emission or release,
into the atmosphere therefrom, or from any
other source whatsoever, of any. . .air con-
taminants so as to cause a nuisance.2
It shall be unlawful for any person to permit or
cause foul or offensive odors. . .in the mainte-
nance of an incinerator. Incinerators, includ-
ing all associated equipment and grounds.
shall be designed, operated and maintained
so as to prevent the emission of odors.

-------

Name of Agency
(by State)


Canton City
Health Department,
Air Pollution Control
Division














City of Cincinnati
Department of Sewers,
Division of Air Pollution
Control




Ironton Air Pollution
Control Agency
Lake County
Combined General
Health District

Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Air Pollu-
tion Rules and
Regulations,
Art. IV, Sees.
14, 11, and 8.













Yes . Ordinance
No. 36-1969,
Sees. 2501-1.3,
and 2501-3.




No

No

Condltion(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints





























If Deemed
Offensive/
Objectionable
ehmt
By persons;
By persons6""1
after dilution
with odor
free air:
i 20 vol.v
> 4vol.w






















Dilution
Device
Reading



















> No. 8 or
equivalent
dilution;w
> No. 16 or
equivalent
dilution, in
M3, Heavy
Mfg. Dis-
txicts »










If Detectable




















If detectable at a
distance >25 feet
from the incinera-
tor chimney or at
a location of a
citizen complaint
whichever is a
greater distance.
If detectable after
dilution with o.f.a
7 vol.w
15vol. in. M3
districts.






Frequency
of Odor






























Duration
of Odor



















A period
or periods
> 15 min.
in any 8
hours.









Exceptions






























Prohibition(s) and
Control Requirement s)
Specified In Odor Ordinance
or Nuisance Law
No owner, occupant or person in charge by him-
self, his agent or employee, shall cause, suffer
or allow the emission of air contaminants into
the atmosphere so as to cause a nuisance as
determined by the Air Pollution Control Officer.
No owner, occupant or person in charge, by him-
self, his agent or employee, shall cause, suffer
or allow the emission of odorous matter into
the atmosphere such as to cause an objectional
odor, as determined by the Air Pollution Con-
trol Officer: (1) on or adjacent to residential,
recreational, institutional, retail sales, hotel
or educational premises;(2) on or adjacent to
industrial or other premises ( see other
columns for specifics) .
Installation or use of any device or any means
to conceal or mask the emission of an air con-
taminant is prohibited.
In the operation of an incinerator, no person
shall cause or permit the emission of offensive
odor. . .i.e. , any odor similar to that of burn-
ing garbage, paper, or other cellulose mate-
rial (see If Detectable column for limits) .
No person shall emit or cause the emission of
odorous substances from any source which, at
any point on the surface beyond the source
property line or at the location of a citizen
complaint beyond the source property line,
will cause the outdoor air to become odorous
air ( as specified in other columns) .
The emission of odorous substances which
cause a nuisance are also prohibited.





-------
1 	

Name of Agency
( by State)

Montgomery County
Combined General
Health District,
Department of Health
City of Portsmouth
Air Pollution Control
Authority












Steubenvllle
Air Quality Region










City of Toledo
Pollution Control
Agency






Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Regulation,
Sec. 126.0.


Yes. Air Pollu-
tion Code,
Sees. 1377.03,
1377.04,
1373.09, and
1377.10.









Yes. Regulation,
Art. VI, Sees.
2 and 3, Art.
IX, Sec. 5.









Yes . Pollution
Control Code,
Sec. 3-60-30.




Condltlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints






































If Deemed
Offensive/
Objectionable




By the
Commissioner
of Air Pollu-
tion Control 01
his authorized
representa-
tive;1 by the
above, after
dilution with
odor free air:
> 20 vol.v
> 4vol.w



By the Chief
Control
Officer or his
representa-
tive;1 by the
above , after
dilution with

odor free air;
> 20 vol.v
> 4 vol.w












Dilution
Device
Reading







































If Detectable








































Frequency
of Odor







































Duration
of Odor







































Exceptions






Breakdown
of equip-
ment . '
































Prohibition; s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, allow, or permit the
emission of any air contaminant so as to
cause air pollution.2

No owner, occupant or person In charge, by
himself, his agent, or employee, shall cause.
suffer or allow the emission of odorous matter
into the atmosphere such as to cause an objec-
tionable odor, as determined by the Commis-
sioner of Air Pollution Control or his duly
authorized representative: (1) on or adjacent to
residential, recreational, institutional, retail
sales, hotel or educational premises; (2) on or
adjacent to Industrial or other premises (see
other column for specifics) .
No person shall operate or cause to be operated
a rendering plant unless: all vents to the
atmosphere from such rendering are substan-
tially free of any odor causing air pollution;
odor producing materials are confined and
handled in such a manner that odors produced
within or outside the rendering plant from this
source can be controlled; excessive accumula-
tions of odor producing materials resulting
from spillage or escape do not occur; all
finished products , by-products, and waste
materials are either odor free or so treated as

to eliminate or prevent air pollution.
Installation or use of any equipment for the sole
purpose of diluting or concealing an emission
or distorting stack test emission results is
prohibited.
No person shall unreasonably permit the emis-
sion of any substance into the ambient air
which causes an objectionable odor, so as to
cause discomfort or endanger the public health
or welfare, or in such a manner as to cause
injury or damage to business or property; and
such air pollution is hereby found and declared
to be, and shall constitute a public nuisance.

-------


Name of Agency
(by State)


Oklahoma

Oklahoma State
Department of Health,
Air Pollution Control
Division



Oklahoma City-County
Health Department,
Air Quality Control
Division







Tulsa City-County
Health Department
Oregon
State of Oregon
Department of
Environmental Quality
( continued on the
next page)











Odor Ordinance
or Nuisance Law
Governing Odor?



No.b Proposed
Regulation No.
10.




Yes . Ordinance
12,575, Chap.
10, Sec. 9. 10. 02.








Yes

Yes. Administra
tive Rules Com-
pilation, Sees.
25-055 and 25-
325(3) .









Conditlon( s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints


































If Deemed
Offensive/
Objectionable


































Dilution
Device
Reading



































If Detectable




































Frequency
of Odor



































Duration
of Odor



































Exceptions























Equipment
used
exclusively
for the
processing
of food for
human
consump-
tion.









Prohibition(s) and
Control Requirement^ s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer, or allow any
emissions of gases, vapors, or "objectionable"
odors beyond the property line from which such
emissions occur, to be in sufficient quantities
and of such characteristics and duration as can
be shown to be injurious to the public welfare.
to the health of human, plant, or animal life,
or to property, or which interferes with the
enjoyment of life and property.
It shall be unlawful and an offense for any person,
firm or corporation to permit the emission of
any obnoxious, injurious or offensive odors. . .
from any premises, machinery, smokestacks,
boilers, chimneys, owned, operated, occupied,
controlled or leased by such person, firm or
corporation, or any such odors. . .which by
reason of the nature thereof, annoy any person
or persons, or interfere with the peaceable
enjoyment of the home, residence or premises
of any person or persons, or are a menace to
the public peace, health or safety.
The general nuisance section of the Public
Health Code can be applied to odors .
A person shall not operate or use any article,
machine, equipment or other contrivance for
the reduction of animal matter unless all gases,
vapors and gas -entrained effluents from such
an article, machine, equipment or other con-
trivance are: (1) incinerated at > 1200°F for
£ 0.3 second, or (2) processed in such a man-
ner determined by the Sanitary Authority to be
equally, or more, effective for the purpose of
air pollution control than ( 1) above. A person
incinerating or processing gases, vapors or
gas -entrained effluents pursuant to this rule
shall provide, properly install and maintain in
calibration, in good working order and in oper-
ation, devices as specified by the Sanitary
Authority, for indicating temperature, pres-
sure or other operating conditions.2

-------


Name of Agency
(by State)


( continued)

State of Oregon
Department of
Environmental Quality







Columbia-Willamette
Air Pollution
Authority





























Odor Ordinance
or Nuisance Law
Governing Odor?













Yes. Ambient
Air Standards,
Sees. 8.4,
6.2(2), 6.5,
and 6.8.



























Condltion(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints











































If Deemed
Offensive/
Objectionable











































Dilution
Device
Reading













> No. 0
or equivalent
dilution ( > 1
to < 2 d/t);su
i No. 2
or equivalent
dilution ( > 8
to < 32 d/t)w


























If Detectable













































Frequency
of Odor













2 meas.
within 1
hour, at
least 15
m in. apart
taken off
the
property
surround-
ing the
source
























Duration
of Odor












































Exceptions














Manufac-
turing
process, if
highest and
best prac-
ticable
treatment
and control
currently
available
Is used to
maintain
lowest
possible
emission
of odorous
gases.
Outdoor fires
(a) for agric
burning; (b)
for recrea-
tional pur-
poses or
cooking food
for human
consumption
(c) those set
or permitted
by any pub-
lic officials
for fire pre-
vention or
fire control
training.
D»*nVllMH fvn/ e>\ anrl
rronLoition( 8) anu
Control Requirement^ s)
Specified In Odor Ordinance
or Nuisance Law
No person shall operate any hardboard tempering
oven unless all gases and vapors emitted from
said oven are treated in a fume incinerator ca-
pable of raising the temperature of said gases
and vapors to il500°F for - 0.3 second.
Specific operating temperatures lower than
1500°F may be approved by the Department
upon application, provided that information is
supplied to show that operation at said tempera-
tures provide sufficient treatment to prevent
odors from being perceived on property not
under the ownership of the person operating
the hardboard plant.
No person shall cause or permit the emission of
odorous matter in such manner as to contribute
to a condition of air pollution, or exceed the
limits shown in other columns.
No open outdoor fire shall be allowed within the
territory which contains garbage, asphalt,
waste petroleum products, paint, paint coated
metals, wire, rubber products, plastics or
any substance which normally emits dense
smoke, noxious odors or creates a public nui-
sance.
Control apparatus and equipment shall be in-
stalled and operated to reduce to a minimum
odor-bearing gases or odor-bearing particulate
matter emitted into the atmosphere. Gas ef-
fluents from animal matter reduction or incin-
eration shall be maintained at a temperature of
1200°F for > 0.3 second, or controlled
in another manner determined by the Program
Director to be equally or more effective. The
Authority may require that buildings or equip-
ment be closed and ventilated so that all air,
gases and particulate matter are effectively
treated for removal or destruction of odorous
matter.
; Installation or use of any device or means to
conceal or mask an emission of air contami-
nants which would otherwise violate these
Rules is prohibited.






-------


Name of Agency
( by State)


Lane County
Regional Air Pollution
Authority






Mid-Willamette Valley
Air Pollution Authority






















Pennsylvania
Commonwealth of
Pennsylvania, Department
of Environmental Re-
sources , Bureau of Air
Quality and Noise Control


Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Ambient
Air Standards,
Sec. 2-7.3.






Yes. Ambient
Air Standards,
Sees. 14-020,
16-140, and
16-130.




















No




Condltion( a) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints









































If Deemed
Offensive/
Objectionable









































Dilution
Device
Reading
2 No. 0 or
equivalent
dilution in
industrial
park areas
and other
areas;8"
>No. 2 or
equivalent
dilutlonv
> No. 0 or
equivalent
dilution1;
> No. 2 or
equivalent
dilutionw


























If Detectable











































Frequency
of Odor



Duration
of Odor

2 measurements
within one hour,
at least IS min.
apart





2 measurei






nents made
within one hour.
at least 15 min.
apart, off the
property surrounding
the emission point.


















































Exceptions











































Prohibition(s) and
Control Requirement^ s)
Specified in Odor Ordinance
or Nuisance Law

No person shall cause or permit the emission of
odorous matter in such manner as to cause a
public nuisance or contribute to a condition of
air pollution or that occurs in areas used for
residential, commercial, industrial park, or
other industrial areas, as specified in other
columns.


No person shall cause or permit the emission of
odorous matter in such manner as to cause a
public nuisance or that occurs in areas used
for residential, recreational, educational.
institutional, hotel, retail sales or other simi-
lar purposes and in all other land use areas ,
as specified in other columns.
Control apparatus and equipment shall be
installed and operated to reduce to a minimum
odor bearing gases or odor bearing particulate
matter emitted into the atmosphere. Gas efflu
ent from animal matter reduction or incinera-
tion shall be maintained at a temperature of
1200°F for > 0.3 second, or controlled in
another manner determined by the Director to
be equally or more effective. The Authority
may require that building or equipment be
closed and ventilated so that all air, gases,
and particulate matter are effectively treated
for removal or destruction of odorous matter.
Installation or use of any device or means to
conceal or mask an emission of air contami-
nants which would otherwise violate these rules
is prohibited.

Odor problems are handled under the provisions
of the Air Pollution Control Act.




-------

Name of Agency
(by State)


Allegheny County
Health Department,
Bureau of Air Pollution
Control
























Air Pollution Control
Board of Greater York
Lehigh Valley
Air Pollution
Control District

(continued on the
next page)



Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Rules and
Regulations,
Sees. 1713 and
1710.
























No

Yes. Ordinance
No. 20, Sec. 3
(1, 2 and 6).





Conditlon( s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints





































If Deemed
Offensive/
Objectionable





































Dilution
Device
Reading






































If Detectable







































Frequency
of Odor






































Duration
of Odor






































Exceptions








































Prohibition( s ) and
Control Requirement s)
Specified In Odor Ordinance
or Nuisance Law
No person shall cause, suffer, or allow. . .air
contaminants. . .to escape to the open air in such
amounts as to cause annoyance or discomfort to
or be offensive and objectionable to the public
or shall cause injury or is a health hazard.2
No person shall operate or use any device, ma-
chine, equipment or other contrivance for the
reduction of animal matter unless all gases,
vapors, and gas -entrained effluents from such
facility are incinerated at a temperature of
1600°F for - 0.5 second, or processed in such
manner as determined by the Bureau Chief to be
equally or more effective for the purpose of air
pollution control. Effective devices and mea-
sures shall be installed and operated in a man-
ner such that no vent, exhaust pipe, blowoff
pipe or opening of any kind shall discharge into
the open air or atmosphere any odorous matter,
air contaminants , dusts or any combination
thereof which create odors. . . Odor-producing
materials shall be confined and handled in a
manner such that odors produced within or out-
side the plant from such materials are con-
trolled. Accumulation of odor -producing mate-
rials resulting from spillage or other means is
prohibited. Odor -bearing air contaminants
arising from materials in process shall be con-
fined at the point of origin so as to prevent
liberation of odorous matter into the workroom.


It shall be unlawful for any person to emit or
cause, suffer or allow to be emitted or to per-
mit the escape into the open air of any. . . odors
... of the quantity or character which violates
any of the provisions of this ordinance.
It shall be unlawful for any person to operate or
maintain or cause to be operated or maintained
any installation, equipment or device which by
reason of its operation or maintenance will be

-------


Name of Agency
(by State)


( continued)

Lehigh Valley
Air Pollution
Control District













Philadelphia
Department of Public
Health, Air Management
Services
Rhode Island
Rhode Island
Department of Health,
Division of Air Pollution
Control
South Carolina
South Carolina
Pollution Control
Authority


Odor Ordinance
or Nuisance Law
Governing Odor?



















No



Yes. Rules and
Regulations for
the Prevention,
Control and
Abatement and
Limitation of
Air Pollution,
Regulation 7 .

No


Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints






























If Deemed
Offensive/
Objectionable






























Dilution
Device
Reading































If Detectable
































Frequency
of Odor































Duration
of Odor































Exceptions
































Prohibition( s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
capable of emitting. . .odors. . .unless he shall
install and maintain in conjunction therewith
such control equipment as will prevent the
emission or escape into the open air of any
such. . .odors. . .of a character and in a quantity
that would violate any of the provisions of this
ordinance.
It shall be unlawful for any person to cause,
suffer or allow to be emitted into the open air
from any fuel-burning equipment, internal com-
bustion engine , process furnace, stack, prem-
ises or open fire. . .odors. . .that are a detri-
ment to the property of others or that are a
nuisance to any person not being therein or
thereupon engaged. When the Director shall
declare a nuisance as above defined to exist.it
shall be deemed to have been created and may
be summarily abated by the Director or his
duly authorized agent.
A proposed form of an odor regulation is being
considered.


No person shall emit any contaminant which
either £ilon6 or in connection with other emis~
sions, by reason of their concentration and
duration may be injurious to human, plant or
animal life, or cause damage to property or
inconvenience to property owners , or create a
disagreeable or unnatural odor or obscure
visibility or which in any way interferes with
the enjoyment of life and property.





-------

Name of Agency
(by State)


Charleston County
Health Department,
Air Pollution Control
Section






City of Spartanburg
Tennessee
Tennessee Department of
Public Health, Division
of Air Pollution Control
Chattanooga-Hamilton
County Air Pollution
Control Bureau


















Odor Ordinance
or Nuisance Law
Governing Odor?

Yes







No
No


Yes. A Regula-
tion for the
Control of Air
Pollution, Sec.
9, Rules 14.1
and 12 . 1 throug
12.3, and Sees.
14-Band 14-C.












Condition; s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints

































If Deemed
Offensive/
Objectionable













By persons P



















Dilution
Device
Reading


































If Detectable



































Frequency
of Odor


































Duration
of Odor


































Exceptions















Upset
conditions ,
breakdown
or sched.
maint.y
















Pr'rth) hif Inn/ ti\ anrl
rroniuiiion^ o) anu
Control Requirement s)
Specified In Odor Ordinance
or Nuisance Law
Odors from incineration must be reduced to such
a point as not to create an undesirable level,
I.e. , the presence in the outdoor atmosphere of
one or more air contaminants or any combina-
tion thereof in sufficient quantity and of such
duration as to be injurious to human health or
welfare, or to damage plant, animal or marine
life, to property or which unreasonably inter-
feres with enjoyment of life or use of property.
A public health nuisance law has also been
successfully employed in abating odors.




No person shall cause, suffer, allow or permit
or fail to take reasonable steps to abate or
terminate the discharge from any source what-
soever of air contaminants or other material
which shall cause injury, detriment, nuisance.
or annoyance of the public or which endanger
the comfort, repose, health or safety of the
public or which cause or have a tendency to
cause injury or damage to business or
property.
No person shall cause, suffer, allow or permit
emission such as to cause an "objectionable"
odor on or adjacent to residential, recreation-
al, institutional, retail sales, hotel or educa-
tional premises.
No person shall cause, suffer, allow or permit
emission such as to cause an "objectionable"
odor on or adjacent to premises other than
those listed above unless air containing such
odorous matter is diluted with 2 4 vol. of
odor-free air.

-------


Name of Agency
( by State)


Knox County
Department of Air
Pollution Control























City of Mem phis -Shelby
County Health Department








Metropolitan Health
Department of
Nashville and
Davidson County

(continued on the
next page)


Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Air Pollu-
tion Control
Regulations ,
Sees. 22, 14,
19(c), 25(d),
and 39.




















Yes. City Code,
Sec. 3-6.








Yes. Air Pollu-
tion Control
Ordinance,
Sec. 4-1-10.



Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints













































If Deemed
Offensive/
Objectionable

By persons
after dilution
with > 8 vol.
odor free air








































Dilution
Device
Reading














































If Detectable















































Frequency
of Odor














































Duration
of Odor














































Exceptions



Upset
conditions,
breakdown
or sched.
maint.y







































Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause, suffer, or allow any
emissions of. . . "Objectionable" odors beyond
the property line from which such emissions
occur, to be in sufficient quantities and of such
characteristics and duration as can be shown to
be injurious to the public welfare, to the health
of human, plant, or animal life, or to property.
or which unreasonably interferes with the en-
joyment of life and property.
No person owning, leasing, or controlling the
operation of any air contamination source shal
willfully, negligently, or through failure to
provide necessary equipment or facilities or to
take necessary precautions, permit the emis-
sion from said air contamination source of
such quantities of air contamination as will
tend to cause a condition of air pollution.2
Hereafter no person shall construct a new
incinerator unless it has a secondary burner
for use when necessary to destroy. . .odors.
No person shall cause, suffer, allow or permit
the emission from any motor vehicle operated
in Knox County of objectionable odors. . .that
tend to endanger the human health or safety or
prohibit the peaceful enjoyment of life and
property.
No person owning, leasing, or controlling the
operation of any air contamination sources
shall willfully, negligently, or through failure
to provide necessary equipment or facilities or
to take necessary precautions, permit the
emission from said air contamination source
or sources of such quantities of air contami-
nants as will cause, by themselves or in con-
junction with other air contaminants, a
condition of air pollution.2
The emission or discharge into the atmosphere
of odorous air contaminant from any source
whatsoever which causes injury, detriment,
nuisance or annoyance to any considerable
number of persons or to the public or which
endangers the comfort, repose, health or
safety of any such persons or the public or
which causes or has a natural tendency to

-------

Name of Agency
( by State)


( continued)

Metropolitan Health
Department of
Nashville and
Davidson County
Texas
Texas State Department of
Health, Air Pollution
Control Services

City of Dallas
Health Department







City of Fort Worth
Department of Public
Health
Galveston County
Air Control Department
City of Houston
Department of Public
Health, Pollution
Control Division

Odor Ordinance
or Nuisance Law
Governing Odor?








No



Yes. Clean Air
Ordinance ,
Sec. 5A-13(7);
Zoning Ordi-
nance. Sees.
10-430 through
10-435.


No


No
No

Conditlon( s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints




























If Deemed
Offensive/
Objectionable




























Dilution
Device
Reading





























If Detectable












If odor exceeds the
odor threshold
(2 odor units) in
heavy industrial
district after
dilution with an
equal volume of
odor free airx
If odor exceeds the
odor threshold^™








Frequency
of Odor





























Duration
of Odor




























Exceptions





























Prohobition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
cause injury or damage to business or property
will constitute a nuisance, and any person
violating any provision of this section will,
upon conviction, be subject to penalties.








No use shall be operated in any zoning district
of the City of Dallas in such a manner that the
emission of odorous matter occurs in such
quantity or volume as to produce a nuisance,
source of discomfort or hazard beyond the
bounding property lines of such use .










-------

Name of Agency
(by State)

Jefferson County
Environmental Control
Department
Laredo -Webb County
Health Department
City of Pasadena
Health Department
Utah
Utah State Division of
Health
Vermont

State of Vermont
Agency of Environmental
Conservation, Air
Pollution Control

(continued on the
next page)











Odor Ordinance
or Nuisance Law
Governing Odor?
No


No

No
No



Yes. Health
Regulations,
Sees. 5-473
and 5-474.













Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints




























If Deemed
Offensive/
Objectionable










By persons™
occupying or
frequenting
places closes
to, but beyonc
the property
line of the
source of
odors .









Dilution
Device
Reading





























If Detectable






























Frequency
of Odor





























Duration
of Odor




























Exceptions












Domestic
odors















Prohibition(s) and
Control Requirement( s)
Specified in Odor Ordinance
or Nuisance Law








No person shall operate or use any device, ma-
chine, equipment or other contrivance for the
industrial processes which as determined by
the Director, Division of Industrial Hygiene is
an odoriferous process per se, unless all
gases, vapors, and gas -entrained effluents
from such facility are incinerated at a
temperature of 1600°F for - 0.5 second, or
processed in such a manner as determined by
the Director, Division of Industrial Hygiene to
be equally or more effective for the purpose of
air pollution control.
Effective devices and measures shall be in-
stalled and operated in a manner such that no
vent, exhaust pipe, blowoff pipe or opening of
any kind shall discharge into the open air or
atmosphere any odorous matter, air contami-
nants, dusts or any combination thereof which
create odors or other nuisances .
Odor -producing materials shall be confined and

-------

Name of Agency
( by State)


( continued)

State of Vermont
Agency of Environmental
Conservation, Air
Pollution Control







Virginia
Commonwealth of Virginia
State Air Pollution
Control Board





















Odor Ordinance
or Nuisance Law
Governing Odor?















Yes. d Rules for
the Control and
Abatement of
Air Pollution,
Rules 6 and 9 .
Proposed: Rule
4.06.

















Conditionf s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints






































If Deemed
Offensive/
Objectionable















By agency on
the basis of a
review of data
obtained by
Investigation
directed by
the Board and
by holding a
public hearing
to hear com-
plaints .














Dilution
Device
Reading







































If Detectable








































Frequency
of Odor







































Duration
of Odor






































Exceptions















Accidental
or other
infrequent
emissions
of odors.
Natural
odors
resulting
from the
normal
production
and cul-
tural prac-
tices of
agriculture

Incinerators
with a
rated heat
input of
i 40
million
BTU per
hour.


Prohibition(s) and
Control Requirement( s)
Specified in Odor Ordinance
or Nuisance Law
handled in a manner such that odors produced
within or outside the plant from such materials
are controlled. Accumulation of odor-producing
materials resulting from spillage or other
means is prohibited.
Odor-bearing air contaminants arising from
materials in process shall be confined at the
point of origin so as to prevent liberation of
odorous matter into the workroom. . .
Installation or use of any equipment to reduce or
conceal an emission which otherwise would
constitute a violation of these regulations is
prohibited.
No owner shall allow the emission into the out-
door atmosphere of any odor which is deter-
mined by the Board to be objectionable to the
extent that it causes an unreasonable interfer-
ence with human life or the reasonable use of
property.
No person shall cause, suffer, allow or permit
any plant engaged in the processing of animal,
mineral, vegetable, or plant matter to be
operated without employing suitable measures.
for the control of odorous emissions including
wet scrubbers, incinerators, or such other
devices as may be approved by the Board.
No owner shall allow the operation of an incin-
erator so as to discharge into the outdoor
atmosphere. . .odor sufficient to cause a
condition of air pollution. Incinerators, in-
cluding all associated equipment and grounds ,
shall be designed, operated and maintained so
as to prevent the emission of objectionable
odors.
Installation or use of any device or means
which conceals or dilutes an emission of air
contaminant which would otherwise violate
these regulations is prohibited (this section
does not prohibit the construction of a stack
or chimney) .

-------


Name of Agency
( by State)


City of Alexandria
Health Department



















Arlington County
















Fairfax County
Health Department
Division of Environ-
mental Health

( continued on the
next page)


Odor Ordinance
or Nuisance Law
Governing Odor?

Yes.a Guide for
Odor Control,
No. 5.
Proposed: Sec.
3B-7 .
















Yes. Air Pollu-
tion Control
Ordinance,
Sec. 32-9 (b2,
cl, and e5).












Yes. Air Pollu-
tion Control
Ordinance ,
Chap. 1A-9,
Par. C.


Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints















































If Deemed
Offensive/
Objectionable

By persons ,fm
occupying or
frequenting
places close
to, but
beyond the
property line
of the source
of odors.
By agency,
after inves-
tigation
directed by
Director and
holding of a
public hear-
ing to hear
complaints ?




























Dilution
Device
Reading

Scentometer
may be
used












































If Detectable























If objectionable
odors resulting
from the burning
of refuse in fuel-
burning equipment
are detectable
beyond the prem-
ises on which the
installation is
located.
















Frequency
of Odor
















































Duration
of Odor
















































Exceptions
























Malfunction
of equip-
ment^






















Prohibition(s) and
Control Requirement(s)
Specified in Odor Ordinance
or Nuisance Law
No person or owner shall cause, permit or allow
the emissions of any odor into the outdoor at-
mosphere which results in air pollution.
No owner or person shall use or operate any
article, machine, equipment or other contriv-
ance for the reduction of animal matter by any
heated process , including rendering, cooking.
drying, dehydrating, digesting, evaporating and
protein concentrating unless odor control de-
vices and procedures acceptable to the
(Department) are provided.
No owner or person shall transport, haul or
move in any vehicle or conveyance materials
causing or giving rise to odors resulting in
air pollution.
No person shall cause, suffer, allow or permit
any source to discharge air contaminants which
cause an objectionable odor or create a nui-
sance without employing adequate measures for
the control of odorous emissions as may be
approved by the Director. a
No owner shall cause, suffer or allow any emis-
sions of gases, vapors or odors beyond the
property line from which such emissions occur.
to be in sufficient quantities and of such charac-
teristics and duration as is or is likely to be
injurious to the public welfare, to the health of
human, plant or animal life, or to property, or
which interferes with the enjoyment of life and
property.
The burning of refuse in fuel-burning equipment
is prohibited except in equipment from which
. . .no objectionable odors arising from the
installation are detectable beyond the premises
on which the installation is located.
Installation or use of any equipment for the sole
purpose of concealing an unlawful emission is
prohibited.
No owner shall cause or allow any emissions of
gases, vapors or odors beyond the property
line from which such emissions occur to be in
sufficient quantities and of such characteristics
and duration as is or is likely to result in air
pollution.
In the absence of appropriate control measures


-------
	
Name of Agency
(by State)

(continued)
Fairfax County
Health Department,
Division of Environ-
mental Health
City of Roanoke
Air Pollution
Control
Roanoke County
Health Department .
Air Pollution Control
Division












Virgin Islands
Virgin Islands Department
of Health, Division of
Environmental Health
Washington
State of Washington
Department of Ecology

Odor Ordinance
or Nuisance Law
Governing Odor?





No


Yes. Air Pollu-
tion Control
Ordinance,
Sec. 8 (C, F,
and G).












No



No

Condltlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law

No. of
Complaints






























If Deemed
Offensive/
Objectionable






























Dilution
Device
Reading































If Detectable
































Frequency
of Odor































Duration
of Odor































Exceptions










Malfunction
of equip-
ment7





















ProniDition( s) ano
Control Requirement; s)
Specified in Odor Ordinance
or Nuisance Law
no owner shall use products which, either by
themselves or due to additives or impurities,
result in air pollution .






No person shall cause, suffer, or allow any
emissions of gases, vapors, or odors beyond
the property line from which such emissions
occur, when determined by the Director to be
in sufficient quantities and of such characteris-
tics and duration as is or is likely to be injur-
ious to the public welfare; to the health of hu-
man, plant, or animal life; or to property; or
which interferes with the reasonable use of
property.
In the absence of appropriate control measures,
no person shall use products which, either by
themselves or due to additives or impurities
result in air pollution.
Installation or use of any equipment for the sole
purpose of concealing an unlawful emission is
prohibited.








-------


Name of Agency
(by State)


Northwest Air
Pollution Authority
















Olympic Air Pollution
Control Authority

















Puget Sound
Air Pollution
Control Agency

( continued on the
next page)


Odor Ordinance
or Nuisance Law
Governing Odor?

Yes

















Yes . Regulation
1. Sees. 9.11,
9.01(b5), 9.13,
and 9. 15.















Yes . Regulation
1, Sees. 9.12,
9.13, and 9. 16.



Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints













































If Deemed
Offensive/
Objectionable













































Dilution
Device
Reading














































If Detectable















































Frequency
of Odor














































Duration
of Odor














































Exceptions




















Upset
conditions
and /or
breakdown
of equip-
ment^













Upset
conditions
and/or
breakdown
of equip-
mentv


Prohibition(s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
Effective control facilities and measures shall be
installed and operated to reduce odor -bearing
gases or paniculate matter emitted into the at-
mosphere to a reasonable minimum.
The Board or Control Officer may establish rea-
sonable requirements that the building or equip
ment be closed and ventilated in such a way that
all the air, gases and particulate matter are
effectively treated for removal or destruction
of odorous matter. . .before emission into the
atmosphere.
The ambient air shall not contain odorous sub-
stances, such as (but not limited to) hydrogen
sulfide, mercaptans, organic sulfides and other
aromatic and aliphatic compounds, in such con-
centration or of such duration as will threaten
health or safety or prevent the enjoyment and
use of property.
Effective control apparatus and equipment shall
be installed and operated to reduce odor -bear-
ing gases or particulate matter emitted into the
atmosphere to a minimum, so as not to create
air pollution.
The Board may establish requirements that the
building or equipment be closed and ventilated
in such a way that all the air, gases and par-
ticulate matter are effectively treated for re-
moval or destruction of odorous matter. . .
before emission to the outdoor atmosphere.
No material containing asphalt, petroleum prod-
ucts, paints, rubber products, plastic or any
substance which normally emits dense smoku
or obnoxious odors will be burned.
Installation or use of any device or means to
conceal or mask an emission of air contaminant
which would otherwise violate these rules is
prohibited .
Effective control facilities and measures shall
be installed and operated to reduce odor-
bearing gases or particulate matter emitted
into the atmosphere to a reasonable minimum.
The Board or Control Officer may establish
reasonable requirements that the building or


-------


Name of Agency
(by State)


( continued)

Puget Sound
Air Pollution
Control Agency




Southwest Air Pollution
Authority





































Odor Ordinance
or Nuisance Law
Governing Odor?










Yes . Regulation
2, Sees. 5.03,
5.05, and 5. 07;
Regulation 1 ,
Sees. 4.01
 No. 0 or
equivalent
dilution ( > 1
to < 2 d/t);su
> No. 2 or
equivalent
dilution ( > 8
to < 32 d/t)^































If Detectable


















































Frequency
of Odor










2 meas.
within 1
hour, at
least 15
minutes
apart.
made off
the
property
surround-
ing the
air con-
taminant
source.

























Duration
of Odor

















































Exceptions











Manufactur
Ing process
if highest &
best prac-
ticable
treatment
and control
currently
available
Is used to
maintain
lowest
possible
emission
of odorous
gases.
Upset
conditions
or break-
down of
equipment )
Vehicles for
transport
of passen-
gers or
freight.
Fuel burn-
ing equip.
in dwell-
ings for not
> 4 families
Space heat-
ing equip-
ment other
than boiler.'
Internal
combustion
engines .

Prohibitionf s) and
Control Requirement s)
Specified in Odor Ordinance
or Nuisance Law
equipment be closed and ventilated in such a
way that all the air, gases and paniculate
matter are effectively treated for removal or
destruction of odorous matter. . .before emis-
sion to the atmosphere.
Installation or use of any device or means to
conceal or mask an emission of air contaminant
which would otherwise violate these rules is
prohibited.
No person shall allow, cause, let, permit or
suffer the emission of odorous gases from any
source, except as provided in this Regulation,
in such concentration as to cause a public nui-
sance or exceed limits shown in other columns.
Effective control apparatus and equipment shall
be installed and operated to reduce odor-
bearing gases or paniculate matter emitted
Into the atmosphere to a reasonable minimum,
so as not to create air pollution.
The Board may establish reasonable require-
ments that the building or equipment be closed
and ventilated in such a way that all the air ,
gases, and participate matter are effectively
treated for removal or destruction of odorous
matter., .before emission intothe ambient air.
No material containing asphalt, petroleum pro-
ducts, paints, rubber products, plastic or any
substance which normally emits dense smoke
or obnoxious odors will be burned.
Installation or use of any device or means to
conceal or mask an emission of an air contam-
inant which would otherwise be considered a
violation is prohibited.















-------

Name of Agency
( by State)


Spokane County
Air Pollution
Control Authority








Yakima County
Clean Air
Authority


















West Virginia

West Virginia
Air Pollution Control
Commission





Odor Ordinance
or Nuisance Law
Governing Odor?

Yes. Regulation
I, Sec. 6.04.









Yes. Regulation
I. Sees. 5.01,
5.04, 5.05,
and 5.06.



















Yes. Administra
live Regulations,
Sees. 2 and 6.




Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law
No. of
Complaints










































If Deemed
Offensive/
Objectionable



































By Commission
representative
based on his
investigations
or his inves-
tigations and
complaints
Dilution
Device
Reading



































Scentometer
may be
used




If Detectable











































Frequency
of Odor










































Duration
of Odor











































Exceptions












Upset
conditions
or break-
down of
equipment

Fuel -burn-
ing equip-
ment for
domestic
housing.











Internal
combustion
engines.

Agriculture
production
operations.



Prohibition( s) and
Control Requirement(s)
Specified in Odor Ordinance
or Nuisance Law
Effective control apparatus and measures shall
be installed and operated to reduce odor-
bearing gases and paniculate matter emitted
into the atmosphere to a reasonable minimum.
The Board or Control Officer may establish rea-
sonable requirements that the building or equip
ment be closed and ventilated in such a way
that all the air, gas, and particulate matter
are effectively treated for removal or destruc-
tion of odorous matter. . .before emission to
the atmosphere.
All air contaminant sources emitting odor
bearing gases and odor bearing particulate
matter shall be operated or controlled in such a
manner as to eliminate as far as practicable
noxious odors. Proven technological improve-
ments, to the extent that the same are econom-
ically feasible, shall be incorporated in such
air contaminant sources to reduce the emission
of noxious odors in the ambient air.
No person shall ignite, cause to be ignited, per-
mit to be ignited or suffer, allow or maintain
any open fire within the jurisdiction of the
Authority except as provided in another section
and no person shall burn in any open fire any
material containing asphalt, petroleum prod-
ucts, paints, rubber products, plastics or any
substance which normally emits dense smoke
or obnoxious odors.
Installation or use of any device or means to
conceal or mask an emission of air contami-
nant which would otherwise be considered a
violation is unlawful.


No person shall cause, suffer, allow or permit
the discharge of air pollutants which cause or
contribute to an objectionable odor at any
location occupied by the public.




-------


Name of Agency
(by State)

City of Wheeling
Air Pollution Control
Department














Wisconsin

State of Wisconsin
Department of Natural
Resources, Bureau of Air
Pollution Control and Solid
Waste Disposal




Eau Claire City-County
Board of Health






City of Green Bay
Department of Air
Pollution Control


Odor Ordinance
or Nuisance Law
Governing Odor?
Yes. Air Pollu-
tion Control
Ordinance,
Sees. 2 (land
g), 4. and2(h)














Yes. Air Pollu-
tion Control
Rules, NR
134.08, and
NR 154.03(5).




Yes. Air Pollu-
tion Ordinance,
Summary and
Sec. III.




No.


Condltlon(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints




.



































If Deemed
Offensive/
Objectionable
By persons?11111
By persons, hm
after dilution
with odor free
air:
20 vol. v
4vol.w

































Dilution
Device
Reading









































If Detectable










































Frequency
of Odor









































Duration
of Odor









































Exceptions


Upset
conditions
or break-
down of
equipment V



































Prohibitions ) and
Control Requlrement(s)
Specified In Odor Ordinance
or Nuisance Law
It is unlawful for any person to permit or cause
the emission of such quantities of air contami-
nants from whatever source in such place or
manner as to be detrimental to any person or ti
the public or to endanger the health, comfort 01
safety of any person or the public, or in such
manner as to cause or have a tendency to cause
Injury or damage to property or business.2
No person shall emit odorous matter such as to
cause an objectionable odor on or adjacent to
residential, recreational, institutional, retail
sales, hotel or educational premises; on or
adjacent to industrial or other premises as
shown In another column.
Installation or use of any equipment for the sole
purpose of diluting or concealing an emission
is prohibited.
No person shall emit into the ambient air mal-
odorous substances at levels which cause air
pollution.
A person shall maintain his premises , and
materials stored on his premises, so as to
minimize air pollution from. . .odors.
Materials moved on public roads, railroads,
and navigable waters shall be secured and
protected in such a manner as to minimize the
spreading of ... odor. . .
No person shall use or have under his control
any equipment or process which causes,
creates, modifies, handles, conveys, controls
discharges or comes in contact with air pollut-
ants which are subsequently discharged to the
atmosphere.2
Open burning is prohibited in any residential
areas and any areas where air pollution would
result.2




-------


Name of Agency
(by State)


Milwaukee County
Department of Air
Pollution Control






Wyoming

State of Wyoming
Department of Health
and Social Services,
Division of Health
and Medical Services































Odor Ordinance
or Nuisance Law
Governing Odor?

No. Proposed:
Air Pollution
Control Ordi-
nance, Sec. 1,
Sec. 89.11(8).






Yes. Air Qual-
ity Standards
and Regula-
tions, Sees. 5,
6, and 13.





























Condition(s) Necessary for Violation of Odor Ordinance or Nuisance Law


No. of
Complaints












One6

































If Deemed
Offensive/
Objectionable















































Dilution
Device
Reading












No. 2 odor
strength

































If Detectable














































1


Frequency
of Odor














Duration
of Odor












2 measurements
within 1 hour,
at least 15 minutes
apart































































Exceptions












Equipment
used exclu-
sively for
the pro-
cessing of
food for
human
consump-
tion in food
service
establish-
ments .

Abnormal
conditions
and equip-
ment mal-
function.^



















Prohibitions ) and
Control Requirement(s)
Specified in Odor Ordinance
or Nuisance Law
No person shall cause or allow to be emitted into
the open air from any process or control equip-
ment, internal combustion engine, premises,
or open fire, any air pollutants in a manner to
cause injury, detriment, nuisance, or annoy-
ance, or to endanger the health or safety of any
person, or to cause or have a natural tendency
to cause injury or damage to business or prop-
erty or to interfere with the reasonable use
and enjoyment of life and property.2
No person shall cause or permit odorous emis-
sions so as to cause air pollution. An odor
occurrence shall be deemed a violation under
the conditions stated in the other columns .
No person shall operate or use any device ,
machine, equipment or other contrivance for
the reduction of animal matter unless all gases
vapors, and gas -entrained effluents from such
facility are incinerated at a temperature
11200 F for a period iO.3 second, or process-
ed in such manner as determined by the Divi-
sion to be equally or more effective for the pur
pose of air pollution control. A person incin-
erating or processing gases, vapors or gas-
entrained effluents pursuant to this rule shall
provide, properly install and maintain, in good
working order and in operation, devices as
specified by the Division for indicating temper-
ature, pressure, or other operating conditions.
Effective devices and/or measures shall be in-
stalled and operated such that no vent, exhaust
pipe, blow-off pipe or opening of any kind shall
discharge into the outdoor air any odorous
matter, vapors, gases, or dusts or any com-
bination thereof which creates odors or other
nuisances in the neighborhood of the plant.
Odor producing materials shall be stored and
handled in a manner such that odors produced
from such materials are confined. Accumu-
lation of odor producing materials resulting
from spillage or other escape is prohibited.
Odor bearing gases, vapors, fumes or dusts
arising from materials in process shall be
confined at the point of origin so as to pre-
vent liberation of odorous matter.


-------
                 APPENDIX B




REQUIREMENTS FOR AGENCY PARTICIPATION
                    -111-

-------
                                 APPENDIX B
                REQUIREMENTS FOR AGENCY PARTICIPATION
PURPOSE AND SCOPE OF THE PROGRAM

       Copley International Corporation has been retained by the Environmental
Protection Agency to develop a model odor control ordinance for the purpose of
assisting state and local authorities in combating community odor problems.  This
project,  under EPA Contract No.  68-02-0095,  represents the culmination of two
and one half years of continuous odor problem  research by Copley International
Corporation for the federal government.

       The project was designed to include a comprehensive evaluation of the
model ordinance and a set of procedures developed for use in connection with the
model ordinance. The evaluation is to be conducted by four air quality enforce-
ment  agencies,  each to be selected by the following criteria:

       •  Location in a metropolitan area having numerous possible com-
          munity odor problems.

       •  Known  involvement in the study and control of community odor
          problems.

       •  Willingness to complete the requirements specified below.
PERIOD OF PARTICIPATION

       Participation of a selected agency would be for a period of seven months,
beginning January 17,  1972.  The first six months would be devoted to the applica-
tion of the enclosed "Procedures for the  Identification and Assessment of Commu-
nity Odor Problems" to actual chronic situations in the jurisdiction of the agency.
This application would be in connection with the attached "Tentative Model Odor
Control Ordinance." Although agency evaluation of the procedures and tentative
model ordinance would continue throughout the first six months and although agen-
cy comments would be accepted by Copley International Corporation at any time,
a formal statement of agency recommendations would not be required until the
seventh month.
                                     -1-
 SPECIFICS OF THE PROGRAM

 Preliminary Activities

        After agreement by the agency director to participate in the program,  repre-
 sentatives of Copley International Corporation and Pope, Evans and Robbins, Inc.
 (the project subcontractor), would travel to the agency to hold discussions with the
 agency officials.  This  would occur approximately four weeks before the beginning
 of the application and evaluation period.

        The officials would be instructed in the use of the enclosed manual.  Special
 emphasis would be placed on such complex tasks  as the delineation of test and con -
 trol areas, analysis of  public attitude survey results, proper use of the scentometer,
 and training and deployment of odor judgment panelists.  The officials would be asked
 to focus their evaluation on:

        • The complexity of the procedures versus the skills possessed by
          their personnel.

        • The costs involved.

        • The information obtained versus that needed to support effective
          odor control activities.

        • The overall utility of the procedures.

       The discussions would then be centered on the basis of the tentative model
ordinance.  Initial recommendations of the officials for changes in the structure
and content of the tentative version would be covered at that time.

Application of the Procedures (Field Work)

       Application of the procedures to actual chronic situations would be directed
by agency officials alone. Copley International Corporation and Pope,  Evans and
Robbins, Inc., would provide guidance only when  called upon to do so.  Such guid-
ance would be advisory in nature and would consist of answering specific questions.
However, all four agencies participating in the program would be informed of any
developments that would benefit the program as a  whole.

       During the first six months of agency participation, the agency would  be
required to complete a minimum of 12 public attitude surveys in accordance with
the procedure for problem identification. Six of these surveys would be conducted
in possible odor problem communities ("test areas") and six would be conducted in
matched odor free communities ("control areas"). Source verification would be
required for each test area in which an odor problem is identified.
                                                                                                                                             -2-

-------
Evaluation of the Procedures and Model Ordinance

       Representatives of Copley International Corporation and Pope,  Evans and
Robbins, Inc., would visit the selected agencies twice during the field work.  Both
visits would be for the  purpose of inspecting the progress of evaluation.  The first
visit would occur sometime in the third month of the field work.

       A comprehensive evaluation form would be prepared by Copley International
Corporation to assure that the evaluation data reported by each of the four agencies
are comparable.  The form — a series of open ended questions — would be made
available to the agency officials during the second visit, which would occur about
two weeks before the end of the field work.

       During the seventh month of agency participation, agency officials would
be required to complete the evaluation form  and submit it to Copley  International
Corporation. The evaluation data would be reviewed extensively. Omissions and
ambiguous  statements would be discussed with the appropriate officials.  Similarly,
unusual findings would  be verified for accuracy.
REPORT ON THE RESULTS

       A report on the results of the project would be prepared by Copley Interna-
tional Corporation for the Environmental Protection Agency.  A copy of the  report
would be presented to each of the agencies that participated.
REIMBURSEMENT OF ACTUAL EXPENSES

       Copley International Corporation will reimburse each agency that completes
the requirements of the program up to $6,000 for actual expenses incurred in apply-
ing the procedures to actual chronic situations.
PROCEDURE GUIDANCE

       The following individuals would be contacted for guidance related to the
application of the procedures:

       Mr. R. David Flesh                Mr. James C. Burns
       Project Director                    Senior Staff Chemist
       Copley International Corporation     Pope, Evans and Robbins, Inc.
       7817 Herschel Avenue              564 Market Street, Suite 300
       La Jolla, California  92037          San Francisco,  California  94104
       (714) 454-0391, ext. 246            (415) 981-7903
                                      -3-

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           APPENDIX C

INTERVIEW EXAMPLES USED TO TRAIN
       AGENCY PERSONNEL
              -115-

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                                APPENDIX C
                   INTERVIEW EXAMPLES USED TO TRAIN
                            AGENCY PERSONNEL
       The following are transcribed examples of simulated telephone interviews
used to train air pollution control agency personnel In preparation for conducting
the public attitude surveys described in the procedure for problem identification.
The examples were recorded on magnetic tape.  Copies of the tape were given to
the project  supervisor at each of the participating agencies.
INTERVIEW EXAMPLE NO. 1

       This example depicts an almost ideal situation in which the respondent
answers all questions with little hesitation. Although few interviews will actually
progress this smoothly, the example can be used to familiarize the trainee with
the questionnaire and the technique of telephone interviewing.  Duration of the
interview is two minutes.

Respondent:    Hello.

Interviewer:    "Hello. My name is Marian Olson.  I'm calling for a government
               agency Interested in certain community problems.  I'd like to talk
               with the lady of the house and get her opinion on a few questions.
               Are you the lady of the house?"

Respondent:    Yes, lam.

Interviewer:    "Have you lived at your present address more than  six months?"

Respondent:    Yes, I  have.

Interviewer:    "Lately, people have become very much concerned  about the en-
               vironment and various types of pollution.  Do people complain
               about any kind of pollution in your neighborhood?"

Respondent:    Yes, they do.

Interviewer:     "Do  they complain about air pollution in your neighborhood?"

Respondent:    Uh.. .yes,  they do.
                                      -1-
Interviewer:    "Water pollution in your neighborhood?"

Respondent:    No...no, not water pollution.

Interviewer:    "Airport, industrial, or traffic noise in your neighborhood?"

Respondent:    No.

Interviewer:    "Noticeable odors in your neighborhood?"

Respondent:    Yes, there are some noticeable odors in the neighborhood.

Interviewer:    "Have you noticed any odors in your neighborhood in the last three
               months?"

Respondent:    Yes, I have.

Interviewer:    "How often have you noticed these odors?"

Respondent:    Oh, about once a day.

Interviewer:    "Generally speaking, how long do these odors last?"

Respondent:    Oh.. .about half an hour or more.

Interviewer:    "How strong would you say these odors smell?"

Respondent:    Oh, quite strong.

Interviewer:    "Would you say very strong, strong.. .7"

Respondent:    Yes, very strong.

Interviewer:    "When was the last time you noticed odors in your neighborhood?"

Respondent:    Uh.. .yesterday.

Interviewer:    "Would you say these have bothered you?"

Respondent:    Yes, they do.

Interviewer:    "How much would you say they have bothered you?  Would you say
               very much, much...?"

Respondent:    Very much.


                                      -2-

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Interviewer:    "Where would you say most of these odors originate, that is, who
               or what causes them?"

Respondent:    My guess would be the oil refinery.

Interviewer:    "All  this information is strictly confidential, but we need it for
               statistical purposes.  What company do you work for?"

Respondent:    I'm a housewife.

Interviewer:    "What companies do other members of your family work for?"

Respondent:    My husband works for the Widget Company.

Interviewer:    "That completes the interview.  Thank you very much for your
               time."

Respondent:    Thank you.

Interviewer:    Bye.
INTERVIEW EXAMPLE NO. 2

       The respondent hangs up!  Occasionally, a respondent will be pressed for
time or, for various reasons, will not wish to be interviewed.  His/her coopera-
tion should be solicited, but not forcefully nor persistently.  Duration of the
incompleted interview is one minute.
Respondent:

Interviewer:




Respondent:

Interviewer:

Respondent:

Interviewer:
Hello.

"Hello.  My name is Marian Olson.  I'm calling for a government
agency interested in certain community problems.  I'd like to talk
with the lady of the house to get her opinion on a few questions.
Are you the lady of the house?"

Yes, I am.

"Have you lived at your present address more than six months?"

Yes.

"Lately, people have become very much concerned about the en-
vironment and various types of pollution. Do people complain
about any kind of pollution in your neighborhood?"
                                      -3-
Respondent:    What kind of pollution are you interested in?

Interviewer:    "Do people complain about any kind of pollution in your neighbor-
               hood?"

Respondent:    I believe you already said that.

Interviewer:    I'm sorry.  I'm allowed only to repeat the question, not to com-
               ment on it.  I'll be happy to  repeat it again.

Respondent:    Are you trying to sell me a product?

Interviewer:    No. We're asking a few questions about the environment,  and
               we'd appreciate your cooperation in answering them.

Respondent:    I think that this is going to take too much time for me.

Interviewer:    We'd appreciate your cooperation.

Respondent:    No, I'm really not interested. (Click!)


INTERVIEW EXAMPLE NO. 3

       The respondent requires prompting on several questions. The interviewer
maintains strict control by repeating the question several times. To reduce the
possibility of antagonizing the respondent,  the interviewer  could have said, "I'm
sorry.  I am not permitted to comment on  the questions, but I may repeat them if
you wish." Duration of the interview is three and a half minutes .

Respondent:    Hello.

Interviewer:    "Hello. My name is Marian Olson.  I'm calling for  a government
               agency interested in certain  community problems.  I'd like to talk
               with the lady of the house to  get her opinion on a few questions.
               Are you the lady of the house?"

Respondent:    Yes, lam.

Interviewer:    "Have you lived at your present address more than six months?"

Respondent:    Yes.
                                                                                                                                              -4-

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Interviewer:    "Lately, people have become very much concerned about the en-
               vironment and various types of pollution. Do people complain
               about any kind of pollution in your neighborhood?"

Respondent:    Well.. .uh.. .what type of pollution?

Interviewer:    "Do people complain about any kind of pollution in your neighbor-
               hood?"

Respondent:    Oh.. .yes, they do.  Are you trying to sell me a product?

Interviewer:    No, we're just asking a few questions about the environment,  and
               we'd appreciate your cooperation.

Respondent:    I see.  OK.

Interviewer:    "Do people complain  about air  pollution in your neighborhood?"

Respondent:    Yes.

Interviewer:    "Water pollution in your neighborhood?"

Respondent:    No.

Interviewer:    "Airport, industrial, or traffic noise in your neighborhood?"

Respondent:    No,  not in this neighborhood.

Interviewer:    "Noticeable odors in your neighborhood?"

Respondent:    Yes.. .noticeable odors.  I could say that.

Interviewer:    "Have you noticed any odors in your neighborhood in the last
               three months?"

Respondent:     Yes.

Interviewer:     "Have.. .how often have you noticed these odors?"

Respondent:     Urn .. .about once a week.

Interviewer:    "Generally speaking, how long do these odors last?"

Respondent:     Uh.. .you mean during the daytime or during the evening?
                                      -5-
Interviewer:    "Generally speaking, how long do these odors last?"

Respondent:    Oh.. .about a half hour altogether.

Interviewer:    "How strong would you say these odors smell?  Would you .say
               very strong, strong, moderate,  or slight?"

Respondent:    Oh.. .1 would say  strong.

Interviewer:    "When was the last time you noticed odors in your neighborhood?"

Respondent:    Well, the last time I noticed that people were complaining about
               odors.. .was last  week.

Interviewer:    "When was the last time you noticed odors in your neighborhood?"

Respondent:    Last week.

Interviewer:    "Would you say these odors have bothered you?"

Respondent:    Yes, they have.

Interviewer:    "How much would you say they have  bothered you? Would you say
               very much, much, moderately,  or little?"

Respondent:    I would say they have bothered me.. .much.

Interviewer:    "Where would you say most of these odors originate, that is, who
               or what causes them?"

Respondent:    Um.. .can you give me a few ideas?

Interviewer:    "Where would you say most of these odors originate, that is, who
               or what causes them?"

Respondent:    Uh.. .you mean specific companies,  or do you mean.. .uh.. .areas?

Interviewer:    "Where would you say most of these odors originate, that is, who
               or what causes them?"

Respondent:    Oh.. .then I couldn't tell you.  I  really don't know.

Interviewer:    "All this  information is strictly  confidential, but we need it for
               statistical purposes. What company do you  work for?"
                                                                                                                                             -6-

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Respondent:    I'm a housewife.

Interviewer:    "What companies do other members of your household work for?"

Respondent:    My husband works for the Widget Company.

Interviewer:    "That completes the interview.  Thank you very much for your
               time."

Respondent:    You're welcome.

Interviewer:    Bye.


INTERVIEW EXAMPLE NO. 4

       Interviewer leads the respondent in answering several questions.  Such a
practice should be avoided, since it usually injects unmeasurable bias into the
results of the survey. Duration of the interview is three minutes.

Respondent:    Hello.

Interviewer:    "Hello.  My name is Marian Olson.  I'm calling for a government
               agency interested in certain community problems.  I'd like to talk
               with the lady of the house to get her opinion on a few questions.
               Are you the lady of the house?"

Respondent:    Yes, lam.

Interviewer:    "Have you lived at your present address more than six months?"

Respondent:    Yes, I have.

Interviewer:    "Lately, people have become very much concerned about the en-
               vironment and various types of pollution.  Do people complain
               about any kind of pollution in your neighborhood?"

Respondent:    No, I haven't heard them complain about it.

Interviewer:    "Do people complain about air pollu..." Oh, I'm not supposed to
               ask you that question.  Just a minute; I'll have to look here and
               see what I'm supposed to do next.

Respondent:    Oh.  OK.
                                     -7-
 Interviewer:    Um.. ."Have you noticed any odors in your neighborhood in the
                last three months?"

 Respondent:     Uh.. .yes, I have.

 Interviewer:    "How often have you.. .have you noticed these odors?"

 Respondent:     Oh.. .1 really couldn't tell you that.  I don't know.

 Interviewer:    Well, I mean, like once a week., .or once a month, or...maybe
                every day?

 Respondent:     I notice it in the morning mostly.

 Interviewer:    Oh.. .uh...

 Respondent:     About an hour, maybe.

 Interviewer:    OK. Now, let's see what I'm supposed to ask you.  Um...
                "Generally speaking, how long do these odors last?" Oh!  You
                already said an hour. Uh.. .is that right?

 Respondent:     Uh.. .that's approximately right, yes.

 Interviewer:     OK.. .Um.. .Now this is a really dumb question.  I hate to have
                to ask it but.. .well, it's on here and  I have to.  "How strong
                would you say these odors smell?  Would you say very strong,
                strong, moderate, slight, don't know..."  Oh!  I'm not supposed
                to read the "don't know" part.

 Respondent:    Oh, I would say strong.. .they smell quite strong.

 Interviewer:     "When  was the last time you noticed the odors in your neighbor-
               hood?"

 Respondent:    Last week.. .no, make it this week.  This week I noticed it.

 Interviewer:    Um.. .this is another dumb question.  "Would you say these odors
               have bothered you?"

 Respondent:    Well, of course they have! If 1 noticed them,  they bothered me.

Interviewer:    "How much would you say they bothered you?"

Respondent:    Well, I thought I answered that.  Very much!

-------
Interviewer:    Oh.. .OK.. .Yes,  I guess you did answer that.  Uh..."Where
               would you say most of these odors originate, that is, who or
               what causes them?"

Respondent:    Oh, I really don't know.  I.. .1 couldn't answer that.

Interviewer:    You don't think it might he the  Widget factory in your area,  do
               you?

Respondent:    Uh.. .it could be, but I don't know for sure.

Interviewer:    Um.. .Now I gotta say another  dumb thing.  "All this information
               is strictly confidential, but we need it for statistical purposes.
               What company do you work for?"

Respondent:    I'm a housewife.

Interviewer:    Oh.  "What companies do other members of your household  work
               for?"

Respondent:    Well, my husband works for the Widget Company.

Interviewer:    Well, I guess that's about it. Um.. .it says here to say, "That
               completes the  interview," and  to thank you very much for your
               I ime.

Respondent:    Oh, you're welcome.  Thank you.

Interviewer:    Bye.
INTERVIEW EXAMPLE NO. 5

       Respondent leads the interviewer. As in Example No.  4, this situation
usually produces unmeasurable bias and, therefore, should be avoided.  Of equal
importance, the inadequate control maintained by the interviewer unnecessarily
increases the survey time and cost. Duration of the interview is six and a half
minutes.

Respondent:    Hello.

Interviewer:    "Hello.  My name is.. .is Marian Olson. I'm  calling for a govern-
               ment agency interested in certain community problems. I'd like
               to talk with the lady of the house to get her opinion of a few ques-
               tions . Are you the lady of the house?"
                                      -9-
Respondent:    Yes, lam.

Interviewer:    "Have you lived at your present address more than six months?"

Respondent:    Oh...yes.  Oh, longer than that.  Yes, much longer.

Interviewer:    Uh.. ."Lately people have become very much concerned about the
               environment and various types of pollution.  Do people complain
               about any kind of pollution in your neighborhood?"

Respondent:    Oh, all kinds. Yes, they talk about air pollution and the smog and
               water pollution and the bay, the.. .Oh, haven't  you noticed?

Interviewer:    Well, yes., .uh.. .yes.  You know, it's just all over the whole
               area. The...

Respondent:    Doesn't  it bother your eyes?

Interviewer:    Oh, yes.  Some days I can hardly  see to drive to work because the
               air pollution is so bad.

Respondent:    I know.   You know, if it weren't for my contact lenses,  I.. .I'd
               probably have  a really bad problem.

Interviewer:    Well, you know,  sometimes I arrive at work and my eyes are so
               red I look like I've been crying.  I don't  know what my boss thinks
               about that.

Respondent:    Oh, I know. You  can go through a box of Kleenex in one day.  I
               know.  It affects my sinuses.. .just everything.

Interviewer:    Oh, it sure does.  It's really bad.  Uh.. .I'm . ..The next question
               I have to ask you is, "Have you noticed any odors in your neighbor-
               hood in the last three months?"

Respondent:    Oh, yes.  I've noticed that. Oh, all kinds of odors .. .in the air-
               port, in the traffic.  I've noticed it just opening my windows.
               Sometimes I can't even do that. I've.. .Oh, everybody complains
               about the odors.   We don't know if.. .it could be the oil refinery.

Interviewer:    Yes, well.. .you  know.. .1 think they've got to do something about
               these industries that are putting all these odors  in the air. They're
               just awful!  They're just awful!

Respondent:    I know.  And it could probably affect your laundry, too.

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Interviewer:



Respondent:


Interviewer:

Respondent:

Interviewer:


Respondent:

Interviewer:

Respondent:

Interviewer:


Respondent:


Interviewer:

Respondent:

Interviewer:


Respondent:

Interviewer:

Respondent:

Interviewer:


Respondent:

Interviewer:
Yes.  Well,  you know,  I.. .I'd like to hang my clothes outside,
but I just can't anymore because they don't smell fresh when I
bring them in.

You know, I've  used that non-polluting laundry detergent and...
uh.. .1 hope I'm doing my part.

Well.. .I'm sure you  are.  I'm sure  you are.

Are you selling that?
Oh, no.  This is just a bunch of.. .of questions about.. .uh...
odors and things like that.

Oh.  Who's the study for?

Well, it's for a government agency.

Oh, which agency is that?

Well, I'm not supposed to tell you until after the interview's over.
I'll be glad to tell you when the interview's over, though.

Yes, I'd  like to know how this turns out.  You know, I want to  see
something done about this.

Well.. .I've got some more questions to ask you...

Oh...OK.  Fine. Go right ahead.

You said you noticed odors.  "How  often have you noticed these
odors?"

Oh, I'd say about once a week.. .at least.

And.. ."Generally speaking, how long do these odors last?"

Oh.. .a good part of the morning.

Um.. ."How strong would you say the odors smell? Would you
say very strong, strong,  moderate, slight...?"

Oh, they're pungent, all right.

Uh.. .well.. ."Would you  say they were very strong?"
                                     -11-
Respondent:    Um.. .very strong.. .OK. That's a good one.

Interviewer:    Uh.. ."When was the last time you noticed odors in your neighbor-
               hood?"

Respondent:    Yesterday.

Interviewer:    Did you have your laundry out then?

Respondent:    I didn't have my laundry out then.  I'm trying to gauge my washing
               with the weather.  Can you believe that? Isn't it awful?

Interviewer:    Well.. .it's awful that you have to do that.

Respondent:    Right. I just wait until it's a smoggy day or a day when there's
               odor, and then I wash the next day.

Interviewer:    Does that really work? I mean, does it usually clear the next day?

Respondent:    Yes.. .it doesn't last that long.. .quite a few hours, but it doesn't
               usually go into the  next day.

Interviewer:    I'll have to try that.  I hadn't thought of doing it  that way.

Respondent:    But you have to get a system with this kind of pollution.

Interviewer:    Yeah, I guess you're right.  Let's  see, I got another question
               here .  Um... "Would you say the odors have bothered you?"
               Well, I guess you've already said that.

Respondent:    I said that.  They sure do.

Interviewer:    And, uh, "How much would you say they bothered you?  Would
               you say...7"

Respondent:    Well, quite a bit.

Interviewer:    Uh.. .like "very much or much or moderate..."

Respondent:    Very much.  Put me down for very much.

Interviewer:    OK.  Uh.. ."Where would you say most of these odors originate,
               that is, who or what causes them?"
                                                                                                                                            -12-

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Respondent:    Oh, well,  I could take a guess.  It comes out in the traffic, the
               oil refinery, the bay, the ocean,  the trash, the garbage. Oh...

Interviewer:    Yes, I'm sure all of those things that you mentioned are.. .uh...
               arc things that cause odors.  Uh.. .Do you...?

Respondent:    You'd think if they could get a man up in the moon they'd be able
               to clean up the city a little.

Interviewer:    You sure would think so,  but I just don't know. I guess they're
               trying, but, uh.. .It's kinda hard.

Respondent:    Yes.  I'd sure like to find out how this survey  comes out.

Interviewer:    Well, uh.. .we'll.. .we'll.,.

Respondent:    Are we finished?

Interviewer:    No, I've got a couple more questions here I have to ask.

Respondent:    Oh, OK.

Interviewer:    Uh.. ."All this information is strictly confidential, but we need
               it for statistical purposes.  What company do you work for?"

Respondent:    I'm a housewife.

Interviewer:    "And what companies do other members of your household work
               for?"

Respondent:    Uh, my husband works for the Widget Company.

Interviewer:    Oh.. .Aren't they one of the companies in your area that cause
               some of the odors?

Respondent:    Yes, they  arel  I bet that's probably one of the main sources right
               in this particular area.

Interviewer:    Well, maybe...

Respondent:    I'm appalled that my husband would keep on working for the
               company...

Interviewer:    Maybe he could help the company...
                                     -13-
Respondent:    .. .but you have to have that money coming in.

Interviewer:    Maybe he could help the company do something about those awful
               odors down there.

Respondent:    Well, you have to be at the top to do something like that.  You
               know, if you're low man on the totem pole, you can't really do
               much...

Interviewer:    Yes, I...

Respondent:    .. .except maybe quit!

Interviewer:    Yes, I suppose that's right.  I suppose that's right.

Respondent:    Yes, I think so.

Interviewer:    Uh... "This completes the interview. Um .. .Thank you very much
               for your time."  I told you I would tell you what agency this is for.
               It's for the Air Pollution Control Agency in the city.

Respondent:    Air Pollution Control. Oh.. .OK.

Interviewer:    They're...

Respondent:    Is that the same one as the one who's doing all the work on the
               smog?

Interviewer:    Well.. .Yeah, that is the same one.

Respondent:    OK.

Interviewer:    Thanks very much.  Bye.
                                                                                                                                            -14-

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   APPENDIX D




EVALUATION FORM
      -123-

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                                 APPENDIX D
                             EVALUATION FORM
INTRODUCTION

       The purpose of this form is to provide each participating air pollution control
agency with a standardized format for reporting its evaluation of (1) the manual, en-
titled "Procedures for the Identification and Assessment of Community Odor Problems,
and (2) the March 1972 revision of the Tentative Model Odor Control Ordinance. The
form is designed to  promote the comparability of Information supplied by the agencies.
It is not meant to  limit the extent nor to influence the content of such information.
Indeed, each agency is encouraged to supply Information in addition to that requested
below as may be necessary to assure a complete statement of its evaluation.

       The part of the form dealing with the procedure manual should be completed
by the agency employee(s) who supervised the problem identification and source ver-
ification activities.  The part of the form involving the model ordinance should be
completed by the agency's attorney or by the agency employee who supervised the
problem Identification activities in consultation with the agency's attorney.  The
agency director should review and approve the completed form which must be sub-
mitted to Copley International Corporation on  or before October 17. 1972.

       Space is provided after each question for the agency employee's comments.
If additional space is required for a complete  statement to any question or for the
provision of supplemental Information, the blank pages at the end of the form should
be used. The back side of the pages should not be used.
EVALUATION OF THE PROCEDURE MANUAL

       A comprehensive evaluation of the manual must include a discussion of the
preliminary information leading to the use of the procedures, the procedures them-
selves, and the costs incurred from the usage. (Exception: Since use of the
"Procedure for Problem Assessment" found on page 47 of the manual was not re-
quired, discussion of this procedure is left at the option of the agency.)

Preliminary Information

       The introductory pages of the manual include: (1) a paragraph stating the
purpose of the procedures and to whom they are addressed, (2) a background infor-
mation section to describe the philosophy upon which the procedures are based,
                                     -1-
and (3) a conditional use section to list the conditions under which the procedures
should be employed.

Ql)    Do you feel that the preliminary Information adequately describes...?

       (a)     The purpose of the procedures
       (b)     The difficulties associated with using analytical equipment or com-
              plaints initiated by residents for solving community odor problems
       (c)     The proper function of complaints
       (d)     Why public attitude surveys would satisfy public nuisance law
                                                                                                               (e)    When the use of sensory techniques must be considered
       (f)     The preference for dealing with emissions of measurable
              concentrations of substances as possible infractions of air
              quality standards rather than as possible violations of odor
              regulations
                                                                                                                                             -2-

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Q2)    Two types of odor situations — "acute episodes" and "chronic situations" —
       are given.  What kind of situations do you feel "acute episodes" and "chronic
       situations" are meant to describe?
Q3)    Is it clear why such situations are distinguished under public nuisance law?
Q4)    A "chronic situation" should be considered as a possible odor problem under
       any of three given conditions.  The purpose of the conditions is to prevent
       unnecessary use of the procedures and, thus, to minimize the costs of in-
       vestigation. Based on your experience with these conditions during the field
       activities,  do you feel that they are too restrictive, not restrictive enough,
       or adequate as given? If you are not in agreement with the conditions as
       given, what changes do you suggest and why? (Please comment on each of
       the conditions separately.)
                                     -3-
Procedure for Problem Identification

       This procedure is the key part of the manual.  The results obtained from
applying the procedure determines whether or not a community odor problem exists
in the test area under investigation.  Under the provisions of the Tentative Model
Odor Control Ordinance, the source of such a problem would be in violation of law.

       The procedure contains seven sections: (1) an introductory section, (2) a
paragraph advising when to use the public  attitude surveys, (3) a section describing
the delineation of test and control areas, (4) a section on sample selection, (5) a
section on conducting interviews, (6) a result determination section, and (7) a mis-
cellaneous use section. Questions about the latter five sections are posed below.
In addition to answering these questions, please complete the following summary
information  tables.
                                                                                                          Table I.   Comparison of socioeconomic characteristics of test and control areas.
                                                                                                          (Complete parts A through H by the chronological order in which each set of public
                                                                                                          attitude surveys was performed.  Explain source of data if different from 1970
                                                                                                          U.S. Censuses of Population and Housing Census Tract Reports.)
A.
Characteristic
County name
Census tract no .
Population
Median income
Median home value
Median gross rent
Median no. of rooms
Year built (percent)
B.
Characteristic
Test Area Control Area Tolerance
±20%
±20%
±20%
±10%
±20%
Test Area Control Area Tolerance
Actual Percent
Difference
—
Actual Percent
Difference
                                                                                                          County name
                                                                                                          Census tract no.
                                                                                                          Population
                                                                                                          Median income
                                                                                                          Median home value
                                                                                                          Median gross rent
                                                                                                          Median no. of rooms
                                                                                                          Year built (percent)
                                                    ±20%
                                                    ±20%
                                                    ±20%
                                                    ±10%
                                                    + •ma.
                                                                                                                                               -4-

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c.
                                                               Actual Percent
Characteristic
County name
Census tract no .
Population
Median Income
Median home value
Median gross rent
Median no, of rooms
Year built (percent)
D.
Characteristic
County name
Census tract no .
Population
Median income
Median home value
Median gross rent
Median no. of rooms
Year built (percent)
E.
Characteristic
County name
Census tract no .
Population
Median income
Median home value
Median gross rent
Median no. of rooms
Year built (percent)
F.
Characteristic
County name
Census tract no .
Population
Median income
Median home value
Median gross rent
Median no . of rooms
Year built (percent)
Test Area Control Area Tolerance
±20%
±20%
±20%
±10%
±20%
Test Area Control Area Tolerance
±20%
+ 20%
±20%
±10%
±20%
Test Area Control Area Tolerance
±20%
±20%
±20%
±10%
±20%
Test Area Control Area Tolerance
±20%
±20%
±20%
±10%
±20%
Difference
--
Actual Percent
Difference
--
Actual Percent
Difference
--
Actual Percent
Difference
--
                                     -5-
G.  (Applicable to City of Houston, Texas, and Hillsborough County, Florida, only.)
                                                               Actual Percent
   Characteristic       Test Area   Control Area   Tolerance      Difference
County name
Census tract no.
Population
Median income
Median home value
Median gross rent
Median no . of rooms
Year built (percent)
H. (Applicable to City of Houston,
Characteristic Test Area
County name
Census tract no .
Population
Median income
Median home value
Median gross rent
Median no. of rooms
Year built (percent)
±20%
±20%
±20%
±10%
±20%
Texas, and Hillsborough County, Florida, only.)
Actual Percent
Control Area Tolerance Difference
±20%
±20%
±20%
±10%
±20%
                                                                                                        Q5)    For what reasons did you select each of the test areas?

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Q6)    How did you select each of the control areas?
Q7)    Did you establish the test and control area boundaries coincident with those
       of census tracts? If not, how did you establish the test and control area
       boundaries?
                                      -7-
Q8)    What difficulties, if any, did you encounter in setting up the test and control
       areas? What do you suggest to avoid these difficulties or to simplify the pro-
       cedure?
                                                                                                         Table II.   Summary of public attitude survey results.  (Complete parts A through
                                                                                                         H by the chronological order in which each set of public attitude surveys was per-
                                                                                                         formed.)	
                                                                                                         A.
                                                                                                                      Information Item
                                                                                                                                                             Test Area   Control Area
                                                                                                        Survey no.
                                                                                                        Date(s)  survey was conducted
                                                                                                        No. of homes in area
                                                                                                        Sampling interval used
                                                                                                        Sample  size
                                                                                                           No. of homes called, but not contacted
                                                                                                           No. of interviews refused
                                                                                                           No. of interviews completed
                                                                                                        No. of respondents bothered by odors (Q9)
                                                                                                        No. of respondents who mentioned source being
                                                                                                           investigated (Qll)
                                                                                                        Value of the normal deviate, z
                                                                                                        Odor problem index no.

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B.
             Information Item
                                                   Test Area   Control Area
Survey no.
Date(s) survey was conducted
No. of homes In area
Sampling interval used
Sample size
   No. of homes  called, but not contacted
   No. of interviews refused
   No. of interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated(Qll)
Value of the normal deviate, z
Odor problem index no.
C.
             Information Item
                                                   Test Area   Control Area
Survey no.
Date(s) survey was conducted
No. of homes in area
Sampling interval used
Sample size
   No. of homes  called, but not contacted
   No. of interviews refused
   No. of interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated (Qll)
Value of the normal deviate, z
Odor problem index no.
D.
             Information Item
                                                   Test Area   Control Area
Survey no.
Date(s) survey was conducted
No. of homes in area
Sampling interval used
Sample size
   No. of homes  called, but not contacted
   No. of interviews refused
   No. of Interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated (Qll)
Value of the normal deviate, z
Odor problem index no.
                                     -9-
                                                                                                      E.
                                                                                                                   Information Item
                                                                                                                                                         Test Area   Control Arua
 Survey no.
 Datc(s) survey was conducted
 No. of homes in area
 Sampling interval used
 Sample size
   No. of homes called, but not contacted
   No. of interviews refused
   No. of Interviews completed
 No. of respondents bothered by odors (Q9)
 No. of respondents who mentioned source being
   investigated (Qll)
 Value of the normal deviate, z
 Odor problem  index no.
                                                                                                      F.
                                                                                                                   Information Item
                                                                                                                                                        Test Area    Control Area
Survey no.
Date(s) survey was conducted
No. of homes in area
Sampling interval used
Sample size
   No. of homes called, but not contacted
   No. of interviews refused
   No. of interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated (Qll)
Value of the normal deviate,  z
Odor problem Index no.	
G.  (Applicable to City of Houston, Texas, and Hillsborough County, Florida, only.)
	Information Item	Test Area   Control Area
Survey no.
Date(s) survey was conducted
No. of homes in area
Sampling interval used
Sample size
   No. of homes called,  but not contacted
   No. of interviews refused
   No. of interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated (Qll)
Value of the normal deviate,  z
Odor problem index no.
                                                                                                                                          -10-

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H.  (Applicable to City of Houston, Texas, and Hillsborough County, Florida, only.)
              Information Item                       Test Area   Control Area
Survey no.
Date(s) survey was conducted
No. of homes in area
Sampling interval used
Sample size
   No. of homes called,  but not contacted
   No. of interviews refused
   No. of interviews completed
No. of respondents bothered by odors (Q9)
No. of respondents who mentioned source being
   investigated (Qll)
Value of the normal deviate, z
Odor problem Index no.
Q9)    What difficulties, if any, did you encounter in obtaining samples of test and
       control area homes to survey?  What do you suggest to avoid these difficulties
       or to simplify the procedure?
                                     -11-
Q10)   Which of the three conditions listed in the Introductory pages of the manual
       prompted you to conduct each set of surveys?
                                                                                                       Qll)   What percentage of telephone interviews were conducted at times other
                                                                                                              than your agency's normal working hours? (Please estimate the percent -
                                                                                                              age for each set of surveys.)
                                                                                                                                            -12-

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Q12)   Was each set of surveys conducted concurrently?  If not,  why not?
Q13)   During each set of surveys, were the interviewers switched about half way
       through the sample? If not, why not?
Q14)   Which of the surveys listed in Table II were replicates of earlier surveys?
                                      -13-
Q15)   To what extent do you attribute differences between the results obtained from
       the  replicate surveys and those obtained from the earlier surveys to...?
                                                                                                                (a)
              The manner in which the surveys were conducted
                                                                                                                (b)     Changes at the sources of odors (e.g., changes in production sched-
                                                                                                                       ules, installation of odor control equipment,  etc.)
                                                                                                                (c)     Changes in meteorological conditions
                                                                                                                (d)    Other factors (please describe in detail)
                                                                                                         Q16)   What difficulties, if any, did you encounter in conducting the surveys?  What
                                                                                                                do you suggest to avoid these difficulties or to simplify the procedure?
                                                                                                                (Please discuss in terms of pretesting,  instructing interviewers, and tabu-
                                                                                                                lating results.)
                                                                                                                                               -14-

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Q17)   What difficulties, if any, did you encounter in computing the value of the
       normal deviate,  z, and the odor problem index number?  What do you
       suggest to avoid these difficulties or to simplify the procedure?
Q18)   What is your opinion of the results obtained from each set of surveys?
                                      -15-
Q19)   Do you feel that the results justify the effort required to obtain them?
       not, why not?
                                                                                                          Q20)   Do you feel that the procedure for problem identification is applicable to
                                                                                                                 all possible community odor problems within your agency's jurisdiction?
                                                                                                                 If not, why not?
                                                                                                          Procedure for Source Verification

                                                                                                                 Whenever an odor problem has been identified, the source of the odor must
                                                                                                          be verified if the problem is to be remedied.  When the odor is not familiar or
                                                                                                          occurs downwind of more than one possible source,  the specific offender may be
                                                                                                          difficult to pinpoint.  To deal efficiently with such cases,  the use of sensory tech-
                                                                                                          niques must be considered.

                                                                                                                 This procedure is to instruct agency personnel in  the proper use of two sen-
                                                                                                          sory techniques — the scentometer and the odor judgment panel — and in the analysis
                                                                                                          of data obtained from such use. The procedure contains six sections:  (1) an intro-
                                                                                                          ductory section, (2) a section advising when to use the scentometer, (3)  a section
                                                                                                          advising when to use an odor judgment panel,  (4)  a proper use section  regarding the
                                                                                                          scentometer, (5) a proper use section  regarding the odor judgment panel, and (6) a
                                                                                                          result determination section. In addition to answering the questions posed below.
                                                                                                          please complete the following summary information  table.
                                                                                                                                               -16-

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Table III.   Summary of odor source information.  (Complete parts A through H
by the chronological order in which each set of public attitude surveys was per-
formed.  Where a complex of odor sources was involved, indicate "complex of
odor sources," but provide information only on the source of odors most frequently
detected in the test area.)       	
A.
           Information Item
                                                        Data
Name of source
Location of source (address,  if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
 No.  of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
 No.  of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
                                      -17-
                                                                                                        B.
           Information Item
                                                        Data
Name of source
Location of source (address,  if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
                                                                                                        Census tract no.  of test area affected by
                                                                                                           source
                                                                                                        Chemical name(s) of substance(s) emitted
                                                                                                           by source and  most frequently detected
                                                                                                           in test area
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
                                                                                                                                              -18-

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c.
           Information Item
                                                        Data
Name of source
Location of source (address,  if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
                                                                                                         D.
                                                                                                                    Information Item
                                                                                                                                                                 Data
Name of source
Location of source (address, if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
         1971
         1970
         1969
         1968
No. of odor complaints against source
   received by agency from residents of
   the test  area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
                                     -19-
                                                                                                                                             -20-

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E.
           Information Item
                                                        Data
Name of source
Location of source (address,  If applicable)

Age of source (if applicable)
Principal line of products (if applicable)
                                                                                                         F.
                                                                                                                   Information Item
                                                                                                                                                                 Data
Name of source
Location of source (address,  if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area  during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
                                     -21-
                                                                                                                                              -22-

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G.  (Applicable to City of Houston, Texas,  and Hillsborough County, Florida, only.)
	Information Item	Data	
Name of source
Location of source (address,  if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
Census tract no.  of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                       1971
                       1970
                       1969
                       1968
                                      -23-
H.  (Applicable to City of Houston, Texas
           Information Item
and Hillsborough County, Florida, only.)
                Data
Name of source
Location of source (address, if applicable)

Age of source (if applicable)
Principal line of products (if applicable)
Census tract no. of test area affected by
   source
Chemical name(s) of substance(s) emitted
   by source and most frequently detected
   in test area
No. of odor complaints against source
   received by agency from all parties
   during 1972 (year to date)
          1971
          1970
          1969
          1968
No. of odor complaints against source
   received by agency from residents of
   the test area during 1972 (year to date)
                      1971
                      1970
                      1969
                      1968
                                                                                                                                              -24-

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Q21)   Have any of the sources listed In Table III Installed odor control equipment
       since 1968?  If so, for each source, what type of equipment was installed
       and what was the approximate date of installation?
Q22)   Has the total number of potential odor sources in your agency's jurisdiction
       Increased, decreased, or remained about the same since 1968? On what
       facts do you base your answer?
Q23)   Has the total number of "chronic situations" in your agency's jurisdiction
       increased, decreased, or remained about the same since 1968? On what
       facts do you base your answer?
                                    -25-
Q24)   For each community odor problem that you identified, what method did you
       use to verify the source of the odor?  In each case, why did you select that
       method over other methods?

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Q25)   Did your agency compare the operation of the scentometer at fixed points
       with the operation of the device in a moving automobile?  If so, was the
       comparison made on the same date? Was the same odor  source used?
       (Please describe  the comparison in detail.)
Q26)   What difficulties, if any, did the scentometer operators encounter in using
       the scentometer? What do they suggest to overcome these difficulties or to
       simplify the procedure?
                                     -27-
Q27)   Does your agency have a particular procedure for using the scentometer?
       (If so, please describe the procedure in detail, particularly how your
       agency recommends dealing with transient odors.)
                                                                                                        Q28)   Did you use scentometer measurements to plot peak odor intensities down-
                                                                                                               wind of any of the sources listed in Table III? If so, did the pattern of
                                                                                                               intensities point toward the source?
                                                                                                        Q29)   Did your agency employ an odor judgment panel? If so, how were the
                                                                                                              panelists recruited?
                                                                                                                                           -28-

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Q30)   In your opinion, how effective were the triangle tests and odor intensity
       (reference standard) tests in training the panelists for field work?
Q31)  How many hours do you feel should be spent to adequately train an odor
       judgment panel?  How many hours were spent to train your agency's panel?
Q32)   Which of the sources listed in Table HI did you select for odor judgment
        panel evaluations?  What substance emitted by this source was most fre-
        quently detected in the test area?  What reference standard did you prepare
        to represent this substance?
 Q33)   Did you conduct any calibration tests in the field? If so, were the results
        consistent with those obtained during the odor intensity (reference standard)
        tests? If not, why not?
                                       -29-
Q34)   What difficulties, if any, did you encounter in conducting odor judgment
       panel evaluations?  What do you suggest to overcome these difficulties or
       to simplify the procedure?
 Q35)   Did you use mean odor intensities or percent of time odor was detected by
        the panelists to plot odor isopleths?  If so, did the pattern of isopleths indi-
        cate the direction of the source?
                                                                                                           Q36)   Do you feel that the results from using the scentometer or the odor evaluation
                                                                                                                  panel justify the effort required to obtain them?  If not, what other method(s)
                                                                                                                  would you consider for source verification?
                                                                                                                                                 -30-

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Costs Incurred From Using Procedures

       Estimates of the costs of services and materials necessary for problem
identification and source verification are included in the Appendix of the manual.
These estimates are based on 1971 prices  averaged for the United States as a whole.
Please complete the following actual cost table and answer the questions provided
below.
Table IV.   Actual costs incurred from using the problem identification and source
verification procedures.  (Complete parts A through C.  Indicate total costs in-
curred during the field work by cost category.)	
A.  Public Attitude Survey Costs
                                                             Actual Cost
              Cost Category
Mandays
                                                                     Dollars
Direct labor:
   Supervisory time
   Technician time
   Clerical time
      Total direct labor costs
Other direct costs (please list):
Indirect costs (please list):
         Total public attitude survey costs
                                     -31-
                                                  B.  Scentometer Measurement Costs
                                                               Cost Category
                                                                                                               Actual Cost
Mandays
                                                                                                                      Dollars
                                                  Direct labor:
                                                    Supervisory time
                                                    Technician time
                                                    Clerical
                                                        Total direct labor costs
                                                  Other direct costs (please list):
                                                  Indirect costs (please list):
                                                          Total scentometer measurement costs
                                                  C .  Odor Judgment Panel Costs
                                                                                                                       Cost Category
                                                                                                                                                                      Actual Cost
                                                                                                         Mandays
                                                                                                                                                                              Dollars
                                                  Direct labor:
                                                     Supervisory time
                                                     Technician time
                                                     Clerical time
                                                       Total direct labor costs
                                                  Other direct costs (please list):
                                                                                                         Indirect costs (please list):
                                                                                                                 Total odor judgment panel costs
                                                                                                                                              -32-

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Q37)   How many sets of public attitude surveys did you conduct during the field
       work (one set of public attitude surveys equals one survey In a test area
       and one survey in a matching control area)?  On how many separate occa-
       sions was the scentometer used?  How many odor judgment panels were
       used?
 Q38)   What percentage of total public attitude survey costs were incurred during
        ...? (Estimate as closely as possible.)

        (a)    The first set of surveys
        (b)    The second set of surveys
        (c)    The third set of  surveys
        (d)    The fourth  set of surveys
        (e)    The fifth set of surveys
        (f)    The sixth set of  surveys
        (g)    The seventh set of surveys (if applicable)
        (h)    The eighth  set of surveys (if applicable)
Q39)   Did your agency hire any full-time or part-time employees to support its
       participation in the project? If so, how many employees did your agency
       hire, and to what tasks were they assigned?
                                     -33-
Q40)   By approximately what percentages did the actual costs incurred by your
       agency differ from the estimated costs contained in the Appendix of the
       manual?  (Answer separately for each of the following activities.)

       (a)     Public attitude surveys
       (b)     Scentometer measurements
       (c)     Odor judgment panel evaluations
                                                                                                         Overall Evaluation of the Procedure Manual

                                                                                                                Please list and discuss any aspects of the manual or of the individual pro-
                                                                                                         cedures which you feel are particularly helpful in dealing with odor problems in
                                                                                                         your agency's jurisdiction.
                                                                                                                                              -34-

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EVALUATION OF THE TENTATIVE MODEL ODOR CONTROL ORDINANCE

       The procedures for problem identification and source verification were de-
veloped after several years of study to assist governmental agencies in dealing with
community odor problems caused,  particularly, by industrial operations. The pro-
cedures are offered for use in connection with public nuisance law.  The philosophy
on which they are based is discussed in the introductory pages of the manual.

       The Tentative Model Odor Control Ordinance is an advanced draft of a legal
model which, after possible refinement, would provide governmental agencies with
as scientific a vehicle for taking action  as has been yet developed against the sources
of community odor problems. To assist in the preparation of the final draft, please
answer the following questions.

Specific Questions

Q41)   Do you feel that the Tentative Model Odor Control Ordinance is consistent
       with public nuisance law? If not, why not?
                                     -35-
Q42)   In your opinion, are the definitions given in Section I sufficiently clear and
       complete to support the general provision and the procedural establishment
       of a violation? If not, what changes do you suggest?
                                                                                                                                            -36-

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Q43)   In your opinion, is the general provision stated in Section II a clear and                                Q44)   In your opinion, is the procedural establishment of a violation given in
       complete statement of what is Intended to be prohibited?  If not,  what                                         Section III sufficiently clear and complete to be understandable to the court
       changes do you suggest?                                                                                    and to all parties likely to be involved in the prosecution of an alleged vio-
                                                                                                                  lator of the general provision?  If not, what changes do you suggest?
                                      -37-                                                                                                       -38-

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Q45)
What additional or alternative sections, if any, do you recommend for
inclusion in an odor control ordinance?
                                      -39-
Q46)   Does your jurisdiction presently have an odor control ordinance?  If so,
       is it a public nuisance law, or does it limit the type,  intensity, or other
       characteristic(s) of odor?
                                                                                                           Q47)   Would the Tentative Model Odor Control Ordinance be compatible with
                                                                                                                  other air pollution control laws existing within your jurisdiction? If not,
                                                                                                                  why not?
                                                                                                                                               -40-

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Q48)   Would you favor the adoption of the Tentative Model Odor Control Ordinance
       for use In your jurisdiction?  If not, why not?
Other Information

       Please  discuss any additional aspects of the Tentative Model Odor Control
Ordinance, as you may wish.
                                    -41-
SIGNATURE OF PROJECT SUPERVISORS AND AGENCY  DIRECTOR

       Evaluation of the procedure manual was completed  by:
                                                                                                                                  Signature:

                                                                                                                             Name and Title:
                           Signature:

                     Name and Title:
                                                                                                              Evaluation of the Tentative Model Odor Control Ordinance was completed by:
                                                                                                                                  Signature:

                                                                                                                            Name and Title:




                                                                                                                                  Signature:_

                                                                                                                            Name and Title:
                                                                                                             The evaluations were reviewed and approved by:
                                                                                                                                  Signature:

                                                                                                                           Agency Director:

                                                                                                                                      Date:
                                                                                                                                           -42-

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                PROCEDURE MANUAL
-145-

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        PROCEDURES FOR THE
  IDENTIFICATION AND ASSESSMENT
   OF COMMUNITY ODOR PROBLEMS
           Prepared for the

ENVIRONMENTAL PROTECTION AGENCY
     Under Contract No. 68-02-0095
                  By
COPLEY INTERNATIONAL CORPORATION
         7817 Herschel Avenue
       La Jolla, California 92037
Contributions to this manual were made by

   POPE, EVANS AND ROBBINS,  INC.
           564 Market Street
     San Francisco, California 94104
             February 1973

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                            ACKNOWLEDGMENTS
       Copley International Corporation is grateful to the City of Houston (Texas)
Department of Public Health,  the Hillsborough County (Florida) Environmental
Protection Commission, the Columbia-Willamette (Oregon) Air Pollution Authority,
and the State of Maryland Bureau of Air Quality Control.  The technical and legal
staffs of these agencies applied and evaluated a previous version of the procedures
contained herein and a tentative form of the model odor control ordinance.  Their
evaluations were of great value in the preparation of this manual.

       Copley International Corporation acknowledges the  cooperation of many
private citizens who gave generously of their time by participating in personal
interviews.  Without their wholehearted cooperation, this manual would not have
been possible.  Copley International Corporation is especially grateful to Mr.
Richard C. Dickerson of the Environmental Protection Agency for his counsel
and assistance in the development of this document.
                               CONTRIBUTIONS
       The overall responsibility of this study was undertaken by Mr. R. David
Flesh, Director, Environmental Economics,  Copley International Corporation.
Others who contributed to this manual included:

       •  Dr. Amos Turk, Project Consultant and Professor, City College
          of the City University of New York.

       •  Mr. James C.  Burns, Senior Staff Chemist; and Mr. P.M. Conn,
          Vice President; of Pope, Evans and Robbins, Inc.

       •  Mrs.  Marian O. Doscher, Senior Industrial Economist; and Mr.
          R. Paul Weddell, Senior Economist and Statistician; of Copley
          International Corporation.
                                      -i-

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                       TABLE OF CONTENTS
ACKNOWLEDGMENTS AND CONTRIBUTIONS	    i

LIST OF TABLES	    v

LIST OF FIGURES	 . . . .  vii

FORMS	vii

IDENTIFICATION AND ASSESSMENT OF COMMUNITY ODOR
      PROBLEMS	    1

      INTRODUCTION	•	    1

      BACKGROUND INFORMATION	    1

      CONDITIONS WARRANTING USE OF THE PROCEDURES	    3

PROCEDURE FOR PROBLEM IDENTIFICATION BASED ON BRIEF
      PUBLIC ATTITUDE SURVEYS	    7

      INTRODUCTION	   7

      WHEN TO USE PUBLIC ATTITUDE SURVEYS	   8

      SETTING UP TEST AND CONTROL AREAS	   8

      OBTAINING A SAMPLE	   10

      CONDUCTING THE SURVEY	   n

      PROBLEM IDENTIFICATION	   19

      ALTERNATE MEANS  OF PROBLEM  IDENTIFICATION	   20

      OTHER USES OF SURVEY RESULTS	   25

       STATISTICAL REFERENCE SECTION	   35
                               -in-

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                   TABLE OF CONTENTS (Cont'd)
PROCEDURE FOR SOURCE VERIFICATION BASED ON SENSORY
      TECHNIQUES	  41

      INTRODUCTION	  41

      WHEN TO USE THE SCENTOMETER	  41

      WHEN TO USE AN ODOR JUDGMENT PANEL	  42

      THE SCENTOMETER	  42

      THE ODOR JUDGMENT PANEL	  45

      SOURCE VERIFICATION	  52

      OTHER DILUTION DEVICES FOR SOURCE VERIFICATION	  53

PROCEDURE FOR PROBLEM ASSESSMENT	  59

      INTRODUCTION	  59

      WHEN TO ATTEMPT PROBLEM ASSESSMENT	  59

APPENDIX	  61

      ESTIMATES OF COSTS INCURRED FROM USING
         PROCEDURES	  61

      SUGGESTED  REFERENCES	  66
                             -iv-

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                              LIST OF TABLES
Table

  1        Example comparison of possible control area with test area
                  by categories of year structure was built	    9

  2        Numbers of telephones listed for streets that are located
                  within a hypothetical test area	   10

  3        Sampling interval	   11

  4        Sequential sampling plan for deciding whether or not an
                  odor problem exists in a community being surveyed
                  (AOL =0.100, OPL = 0.263,  a = 0.05, 6=0.05)   ....   21

  5        Sequential sampling plan for deciding whether or not an
                  odor problem exists in a community being surveyed
                  (AOL =0.150, OPL = 0.333,  a =0.05, 6 =0.05)   ....   21

  6        Sequential sampling plan for deciding whether or not an
                  odor problem exists in a community being surveyed
                  (AOL =0.200, OPL = 0.393,  a = 0.05, 6 =0.05)   ....   22

  7        Sequential sampling plan for deciding whether or not an
                  odor problem exists in a community being surveyed
                  (AOL =0.250, OPL = 0.453,  a =0.05, 8 =0.05)   ....   22

  8        Sequential sampling plan for deciding whether or not an
                  odor problem exists in a community being surveyed
                  (AOL =0.300, OPL = 0.510,  a =0.05, B = 0.05)   ....   23

  9        Correction factors for use when sample size is a large
                  fraction of the total number of telephones in  the
                  area to be surveyed	   37

 10        Concentration of reference standard in odorless solvent
                  used to simulate four strengths of the odor expected
                  to be encountered in the test area	   48

 11        Recommended work schedule	   51
                                     -v-

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                            LIST OF FIGURES



Figure                                                             Page

  1       Recommended form of a model odor control ordinance .....    5

  2       Barnebey-Cheney, Model 1-3 Scentometer ............   43

  3       Example of isopleths representing mean odor intensities
                 recorded by odor judgment panelists stationed in
                 a test area at the points indicated	   54

  4       Example of isopleths representing percentages of time
                 odor was detected by odor judgment panelists
                 stationed in a test area at the points  indicated	   54



                                 FORMS



PUBLIC ATTITUDE SURVEY OF COMMUNITY ODOR PROBLEMS
      PROBLEM IDENTIFICATION QUESTIONNAIRE	   26

PUBLIC ATTITUDE SURVEY — TABULATION FORM	   30

ODOR PROBLEM IDENTIFICATION	   33

DETERMINATION OF THE ODOR PROBLEM INDEX	   34

SCENTOMETER LOG SHEET	   55

ODOR INTENSITY RATING SHEET	   56

ODOR INTENSITY RATING SUMMARY SHEET	   57
                                  -vii-

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                   IDENTIFICATION AND ASSESSMENT OF
                        COMMUNITY ODOR PROBLEMS
INTRODUCTION

       The procedures described in this manual are designed to assist governmen-
tal agencies in dealing with community odor problems caused,  particularly, by
industrial operations.  The procedures are addressed to "local" agencies, since
the investigation of community odor problems usually occurs within the public
health departments or air quality offices of local government.  They are, however,
equally applicable  to the needs of state agencies operating at the local level. A
mechanism for the official use of the procedures in the establishment of a violation
is found in the recommended form of a model odor control ordinance  given below.
BACKGROUND INFORMATION

       The contents of this manual were developed primarily from the results of
two studies — the national survey of the odor problem, conducted in 1969, and a
study of the social and economic impact of odors, conducted in 1970 and 1971.
Both were conducted by Copley International Corporation for the Environmental
Protection Agency.  Secondarily, the contents evolved from the findings of other
research done in the United States and Sweden,  and from the opinions of scientists,
jurists, and many local agency officials.  The contents were then modified in
response to the recommendations of four agencies which applied the procedures
to actual community odor problems over an eight month period in 1972.

       The difficulty with the investigation of community odor problems lies in
the lack of objective evidence that such problems exist. Analytical equipment
is available to measure low concentrations of a few odorous substances, but even
in situations involving such substances, there is no way to translate known con-
centrations into odor intensities. Equally distressing, there is no way to translate
known odor intensities into some form of an odor problem index.  Thus, for the
present at least, reliance must be placed  on the personal evaluations of those who
are exposed.

       Traditional  methods for solving community odor problems include the
presentation of subjective evidence  to the  courts for consideration under public
nuisance law which, for remedy, requires substantial and unreasonable inter-
ference to any considerable number of persons  in the community.  The most
widely used form of such evidence has been complaints initiated by residents.
On the surface, it would seem that such evidence must define the existence of
a problem.  Yet, under a literal interpretation  of public nuisance law, it may
not.  It is seldom determined from complaints whether the complainants, indi-
                                      -1-

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vidually or as a group, actually suffered interference and,  if so, whether the
interference was substantial and unreasonable.

       The procedures described in this manual are offered for use in connection
with public nuisance law in lieu of counting complaints or attempting to extract
meaningful information from complainants' remarks. Within these procedures,
complaints are relegated to a proper function of alerting local authorities to the
locations of possible odor problems.  The procedures are also offered for use in
connection with statutory law in lieu of attempting to base violations on the mere
perception of odors or on arbitrary levels of odor intensity.

Problem Identification Based on Public Attitude Surveys

       The most direct means of identifying community odor problems is an atti-
tude survey.  This stems from the personal nature of odor evaluation and the
concept that attitudes  reflect personal evaluations.  Unlike odor complaints, an
attitude survey of a randomly selected sample of residents would satisfy public
nuisance  law. The random sample would represent "any considerable number of
persons."  Attitudes expressing annoyance (typical in odor cases) would repre-
sent interference.

       To determine whether interference  is substantial and unreasonable creates
a complexity. Equity is involved.  It is unfair to find substantial and  unreasonable
interference on the basis of an arbitrary percentage  of residents who  express
annoyance.  Recent studies have found that, even in virtually odor  free areas, up
to 50 percent of the residents may express annoyance to odors.  This is due to a
variety of factors including, for example, residents  with unusual sensitivity to
background odors, feelings against nearby  industry,  and neurosis.

       The procedure for problem identification provides an equitable basis for
showing the extent of interference suffered. It is assumed that the percentage of
residents who would express annoyance to odors when odors are not present is
approximately equal in all communities of similar socioeconomic characteristics
in the agency's jurisdiction. (Once  established for communities of similar socio-
economic characteristics, the percentages must not  be applied to communities of
other characteristics  in the agency's jurisdiction or  to communities of similar
characteristics in other agencies' jurisdictions.)  This assumption is supported
by the results of the study of the social and economic impact of odors. It is also
assumed that residents of all communities have equal right to odor free air.  By
comparing the results of identical attitude surveys conducted in a suspected odor
problem community and a similar, but odor free, community, it can be statisti-
cally determined if a greater percentage of residents in the former area express
annoyance.  If so, an  odor problem is identified and  an equitable basis for show-
ing substantial and unreasonable interference is provided.
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Source Verification Based on Sensory Techniques

       Whenever an odor problem has been identified,  the source of the odors must
be found if the problem is to be remedied.  When odors are experienced in a com -
munity frequently or over long duration, it is common  for the residents to know or
at least suspect the source. Still, the source must be  verified by local authorities.

       Source verification is a straightforward endeavor when the odor is easily
recognized and only one possible source of such an odor is located near the prob-
lem community.  In such cases, a simple investigation is adequate.  However,
when the odor is not familiar or occurs downwind of more than one possible source,
the specific offender may be difficult to pinpoint. To deal efficiently with such
cases, the use of sensory techniques must be considered. The procedure for
source verification describes two of the most successful  techniques — one featur-
ing immediate availability; the other, depth of evaluation.

       The use of sensory techniques in problem identification may be possible in
the future. This alternative to the use of public attitude surveys may save time
(including the time of residents who would otherwise be interviewed) and expense
without much loss of confidence in the results.  What is needed to examine this
possibility is concurrent use of the sensory techniques and public attitude surveys
recommended by this manual on numerous Occasions over time and, based on the
results of such use, the development of appropriate dose-response relationships.

       Based on the outcome of field activities performed during the study of the
social and economic impact of odors, the scentometer  or equivalent dilution device
is recommended for indicating the locations of possible odor problems during rou -
tine surveillance.  A condition for its use in this capacity is given in a following
paragraph.

Problem Assessment

       By problem assessment is meant a determination  of the economic and social
impact of odors on a community.   Such information would support, but not replace,
the need for problem identification in odor cases.  Tentative methods  of problem
assessment have been developed, the most comprehensive of which are documented
in the final report of the  social and economic impact study.  However, because
they are not yet refined to the level of problem identification and source verifica-
tion and because they require highly specialized behavioral science  skills not
possessed by most local  agencies, they are not included in this manual.
CONDITIONS WARRANTING USE OF THE PROCEDURES

       Two types of odor situations may exist in a community. One may lead to
an odor problem; the other does not.  They are referred to as breakdown episodes
                                      -3-

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and chronic situations.  Reference to "breakdown episodes" is meant to preclude
unexpected malfunctions involving industrial processes from prompting investiga-
tions of community odor problems .  However, a limitation of one day in any three
month period is included in the following definition as incentive for industrial
operators to minimize the duration of such episodes should they occur, as well as
the possibility that such episodes can occur at all.

Breakdown Episodes

       A breakdown episode is defined as a causation of odors to persons beyond
the property limits of a source, occurring no more than once and lasting no more
than one day in any three month period.  A breakdown episode involving the emis-
sion of measurable concentrations of odorous substances into the atmosphere
should be dealt with as a possible infraction of the air quality standards governing
such substances.  A breakdown episode should not be considered as a possible
odor problem regardless of the characteristics of the odors caused.

Chronic Situations

       A chronic situation is defined as a causation of odors to persons beyond
the property limits of a source occurring more than once or lasting more than
one day in any three month period.  A chronic situation involving the  emission
of measurable concentrations of odorous substances should be dealt with as a
possible infraction of the air quality standards governing such substances.  A
chronic situation should be considered as a possible odor problem under any of
the following conditions:

       (1)     If an odor complaint is initiated by a resident of a commu-
              nity and verified by local authorities after the first day of
              the first  occurrence in any three  month period.

       (2)     If odor complaints are initiated by five or more residents
              of a community, but not verified by local authorities after
              the first  day of the first occurrence in any three month
              period.

       (3)     If odors are detected  in a community by local authorities on
              more than one day in  any three month period.  Such odors
              must be of sufficient intensity to be detected using a Barnebey-
              Cheney Model 1-3 Scentometer, or equivalent dilution device,
              set at 7 dilutions to threshold.

The existence of a chronic situation  and any of these conditions should be neces-
sary and sufficient for the employment of the following procedures.  A mechanism
for their official use in  the establishment of a violation is given in Figure 1.
                                      -4-

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Figure 1.   Recommended form of a model odor control ordinance.
SECTION I - DEFINITIONS

Chronic Situation - A causation of odors to persons beyond the property limits of a source occurring more
       than once or lasting more than one day in any three month period.

Community - A group of at least 20 houses,  apartments,  or rooms occupied as separate living quarters.

Community Odor Problem - A condition which is said to exist when it has been determined, by public attitude
       surveys of randomly selected samples of residents, that a significantly greater proportion of respon-
       dents in a community in which an odor problem is suspected state they were bothered by odors than
       respondents in an odor free community of similar socioeconomic characteristics.

Odor - Perception of smell, referring to the experience.

Odor Free Community - A community from which no odor complaints have been received by local authorities
       and in which no odors have been detected by local authorities during the past twelve months.

Odorous Substance  - A substance that stimulates the olfactory receptors and, thus, causes odor.

Person - Any person, firm, association, organization, partnership, business trust, corporation, company,
       contractor,  supplier, installer, user, or owner, or any state or local governmental agency or public
       district,  or any officer, agent, or  employee thereof.

Significantly Greater Proportion of Respondents - Determination by use of a mathematical test of statistical
       significance that the difference between the proportion of respondents in one community who gave a
       particular answer to a survey question and the proportion of respondents in another community of
       similar socioeconomic characteristics who gave the same answer to the same survey question is an
       actual difference and not the result of sampling error.

SECTION II - GENERAL PROVISION

       No person shall permit, cause, suffer, or allow the emission of odorous substances into the atmos-
phere that result in a community odor problem from any source under his control.

SECTION HI - PROCEDURAL ESTABLISHMENT OF A VIOLATION

       Violation of this ordinance shall be established by identification of a community odor problem.  Such
identification shall be undertaken by the air quality enforcement agency serving this jurisdiction in accordance
with the "Procedures for the Identification and Assessment of Community Odor Problems," prepared for the
Environmental Protection Agency under Contract No. 68-02-0095, dated March 1973.

       Identification of a community odor  problem shall require:

       (A)    the existence of a chronic situation as  defined in SECTION I of this ordinance, and

       (B)    the existence of any of the following conditions:

              (1)     if an odor complaint is initiated by a resident of a community and verified
                     by local authorities  after the first day of the first occurrence in any three
                     month period, or

              (2)     if odor complaints are initiated by five or more residents of a community,
                     but not verified by local authorities after the first day of the first occurrence
                     in any three month period, or

              (3)     if odors are detected in a community by local authorities on more than one
                     day in any three month period (such odors shall be  of sufficient intensity to
                     be detected using a Barnebey-Cheney Model 1-3 Scentometer, or equivalent
                     dilution device, set  at 7 dilutions to threshold), and

       (C)    the determination, by public attitude surveys of randomly selected samples of resi-
              dents,  that a significantly greater proportion of respondents in a community in
              which an odor problem is suspected state they were bothered by odors  than respon-
              dents in an odor free community of similar socioeconomic characteristics.

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                 PROCEDURE FOR PROBLEM IDENTIFICATION
                BASED ON BRIEF PUBLIC ATTITUDE SURVEYS
INTRODUCTION

       The following procedure is designed to allow local agencies to conduct,  with
their own personnel, public attitude surveys to identify community odor problems.
If sufficient funds are available to the local agency,  a professional interviewing
or survey firm could be engaged to perform many of the tasks described in this
procedure.  However, the additional expense is not necessary if the procedure
outlined is followed with care by local agency personnel. It is important to note
that failure to adhere to the procedure could lead to survey results that are mis-
leading or meaningless.

       Before describing the detailed steps to be undertaken in conducting a public
attitude survey, it may be helpful to  summarize the major tasks to be completed.
These tasks are described in general terms below.

       This survey is designed to compare the attitudes of people residing in a
community in which an odor problem is suspected with  attitudes of similar people
residing in an odor free community.  Attitudes of both groups are determined by
conducting interviews by telephone with residents of both communities. (Tasks
followed by an asterisk (*) could be done by an interviewing firm.)

       (1)     The first task is to define the geographic limits of the pos-
              sible odor problem community.

       (2)     Next, a matching odor free community is located.

       (3)     Utilizing a  street address (reverse order) telephone direc-
              tory, a list of telephone numbers in each community is made,
              and a sample of these  telephone numbers is selected at ran-
              dom.*

       (4)     Utilizing the questionnaire provided in this procedure, tele-
              phone interviews are conducted with the  man or lady of the
              house for each telephone number included in the sample. *

       (5)     The total number of responses to key questions asked in both
              communities is then tabulated and compared for problem
              identification.

       (6)     Finally, if an odor problem is found, an odor problem index
              number is calculated.
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WHEN TO USE PUBLIC ATTITUDE SURVEYS

       A public attitude survey should be conducted only after any of the three
conditions stated in the previous section of this procedure indicate the location
of a possible odor problem .
SETTING UP TEST AND CONTROL AREAS

       The community in which an odor problem is suspected is called the "test
area."  The first task to be undertaken is to define the geographic limits of the
test area.  This can be done by driving an automobile in a grid pattern throughout
the general area, while noting the boundaries within which the odor is perceived.
Meteorological data indicating wind patterns can also be helpful in setting these
boundaries, as can complaint patterns.

       Next, the socioeconomic characteristics of the test area must be deter-
mined.  If the boundaries of the test area are coincident with those of a  census
tract, the following characteristics of the test area should be listed by reference
to the latest U.S. Censuses of Population and Housing Census Tract  Reports
(PHC) covering the agency's jurisdiction: median income for families, median
value of owner occupied housing units,  median gross rent of renter occupied
units, median number of rooms, and year structure was built.

       An odor free community must now be located that matches the test area
as closely as possible.  This community is called the "control area." The fol-
lowing criteria should be used in choosing the control area.

       (1)     The control area should be as odor free as possible.  To
              ensure this, the local agency should not have  received any
              odor complaints from residents of the area nor detected
              any odors in the area during the past twelve months.

       (2)     The control area should be located within ten  miles of the
              test area.

       (3)     The control area should have similar access to heavily
              traveled roadways as the test area.

       (4)     The control area should be located within approximately
              the same distance from commercial or industrial estab-
              lishments as the test area.

       (5)     The median income, home value, and gross rent for the con-
              trol area should not differ from that of the test area by more
              than 20 percent. Using the above mentioned Census Tract
                                      -8-

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              Reports, note the four categories of "year structure built"
              and the corresponding number of homes listed in the census
              tract to be used as a test area. Find the modal category.
              Determine the percentage of the total number of structures
              in the test area built in this category of years.  Next,  deter-
              mine the percentage of the total number of structures  in a
              possible  control area built in the same category of years.
              The  percentage for the control area should be within 20 per -
              cent of that for the test area.

              For  example, assume the categories and numbers of structures
              are listed as in Table  1.
              Table 1.   Example comparison of possible control area with
              test area by categories of year structure was built.	
                                         Test Area        Control Area
                                       Census Tract       Census Tract
                  Category	219.01	6.01
1960 to March 1970
1950 to 1959
1940 to 1949
1939 or earlier
Total
312
1,068
321
118
1,819
203
1,926
185
197
2,511
              The modal category for census tract 219.01 is 1950 to 1959,
              at which time 1,068 structures were built. This represents
              59 percent of the total number of structures in the test area.
              During the same category of years, 1,926 structures were
              built in  census tract 6.01.  This represents 78 percent of the
              total number of structures in the possible control area.  The
              difference is 19 percent (78% - 59%), which is acceptable.

       (6)     The median  number of rooms (per housing unit) should not
              differ by more than 10 percent.

       If the community  in which an odor problem is suspected is coincident with
more than one census tract, it is preferable to use each census tract as a separate
test area.  However, if the socioeconomic characteristics of the census tracts do
not differ in excess of  the above criteria, a weighted average of characteristics
should be calculated for use in locating a control area.  The population of each
census tract should be  used as the weighting factor.

       If the boundaries of the test area are either smaller or larger than a cen-
sus tract, the agency should enlist the aid of a professional real estate appraiser

                                      -9-

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in locating a suitable control area.  An appraiser should be driven through the test
area and then asked to suggest the location of a community that would meet as many
of the above criteria as possible. To minimize the cost of such a service, the
agency may wish to request the loan of an appraiser from  the planning (or other)
department of the local government.
OBTAINING A SAMPLE

       First, list in alphabetical and/or numerical order all of the streets that are
located within the test area.  Using a street address (reverse order) telephone
directory,  which can be obtained from the telephone company, count the total num-
ber of telephones  that are listed for these streets within the test area. To do this,
the house number of the first and last house on each street that runs beyond the
test area will have to be determined. In this count do not include professional
offices, commercial establishments, government offices, or industrial facilities.
Next, using a table  of random numbers,  select one number that falls between the
number "1" and the  total number of telephones in the test area.  Determine by cu-
mulative addition the street on which the sample selection will begin.  Finally,
refer again to the street address telephone directory.  Find the street on which
the sample selection will begin, and count down to the starting point,  i.e., to the
first telephone to be used for the sample.  For example, assume the streets listed
in Table 2 are located within the test area:
Table 2 . Numbers of
hypothetical test area .

Name /Number
of Street
Adams Street
Baker Street
Charles Street
Denver Street
35th Street
36th Street
telephones listed for

No . of Telephones
on Street Within
the Test Area
32
28
32
30
12
10
streets that are located within a

Cumulative Total
No . of Telephones Within
the Test Area
32
60
92
122
134
144
Assume the random number chosen is 99.  Note from the cumulative total column
that the starting point must be the seventh telephone (within the test area) listed
on Denver Street.  Write down this address and telephone number.

       Refer to Table  3 to determine the number of telephones to be passed over
before a second telephone is chosen (the sampling interval).  Continuing the example,
since there are 144 telephones in the test area,  the sampling interval is 2.  Thus,
                                      -10-

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the ninth telephone (within the test area) listed on Denver Street would be the second
telephone to be included in the sample.  Continue in this manner until all addresses
and telephone numbers in the test area have been written down or passed over as
part of the  sampling interval.  It should be noted that, if the starting point is toward
the middle  of the streets listed (such as Denver Street), when the last street in the
test area is reached the sampling should be continued by returning to the first street
listed (such as Adams Street).

       When this procedure has been completed for the test area, the same thing
should be done for the control area.  If a multi-family dwelling such as an apart-
ment building is encountered in the test area or the control area, each family
should be counted as though they lived in a spearate house. The numerical or
alphabetical sequence of apartments is usually listed in the street address tele-
phone directory.  This sequence is convenient for purposes of selecting a sample.
If more than one telephone number is found for a single family dwelling, count
only the first number and ignore any others.  If more than one telephone number
is  found for a multi-family dwelling, count the first number for each family.
Table 3 . Sampling interval .
Number of Telephones
in the Area
1-90
91-180
181-270
271-360
361-450
451-540
541-630
631-720
721-810
811-900
901-990
991-1080
1081-1170
1171-1260
1261-1350
1351 and over
Sampling Interval
include all telephones
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
CONDUCTING THE SURVEY

       Each time interviews are conducted in the test area, they must also be
conducted in a matching control area.  This is necessary to permit the statisti-
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cal comparisons required to verify the findings of the survey.  Surveys should be
conducted concurrently in the test and control areas.  The same control area may
be used for different test areas if the residents have the same socioeconomic
characteristics as those in a second test area.

       Telephone calls to administer the questionnaire should not be made before
9:00 a.m. nor after 9:00  p.m.  To reduce the elapsed time needed to complete the
telephone calls,  the samples should be divided among two or more interviewers.
If only two interviewers are used, one  should be assigned to call the control area
sample while the other calls the test area sample.  To reduce the possibility of
interviewers biasing the results of the  survey,  it is desirable to switch the inter-
viewers about halfway through the sample; i.e., after one-half of the telephone
calls in the test area have been made by one interviewer, this person should make
calls in the control area.  The other interviewer should make the balance of the
test area calls.  A blank  copy of the questionnaire will be needed for each tele-
phone number to be called.

       If a survey in a test area or control area is not completed in one day,
simply complete the required number of interviews  between 9:00 a.m. and 9:00
p.m. of the following day.  A brief review of the first day's results may suggest
a time period  (e .g., dinner time) when it  is most likely that residents of an area
will be at home.  Concentrating the remaining calls about such a time would in-
crease the efficiency of interviewing and,  thereby, reduce survey costs.  For
optimum comparability of the test area and control area results, a like percentage
of interviews should be completed in both  areas during a given period of time.

Pretesting the Survey

       Because it is unlikely that local agency personnel are experienced in con-
ducting telephone surveys,  it will be of considerable help to pretest the survey.
However, the  pretest results should not be combined with those of the actual
survey.

       For the convenience of the agency, five simulated interview examples are
included in Appendix C of the final report, "A Study of the Social and Economic
Impact of Odors, Phase in." Arrange  for the persons who will conduct the tele-
phone interviews to review these examples and to read the "Instructions for
Interviewers" section of this procedure.   When this has been done, have each
interviewer go through the questionnaire asking the  questions aloud of another
agency employee.  Note whether the interviewer is following instructions in every
detail, and correct any errors in interviewing technique.  Then, select at random
five telephone numbers for each interviewer who will participate in the survey.
These  telephone numbers should be different from those chosen as part of either
the test or control area samples.  Have each interviewer call five numbers and
administer the questionnaire.  Again, note whether  the interviewer is following
instructions, and correct any errors.  When each interviewer is thoroughly
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familiar with the questionnaire and interviewing technique, begin calling the tele-
phone numbers in the test and control area samples.

Instructions for Interviewers

       Because people would usually like to tell you what they believe you want to
hear, it is important that the interviewer restrict what is said to the questions or
comments on the questionnaire. If the interviewer engages in pleasantries or
chats with the person answering the questions,  the responses received may be
different from those that would otherwise be obtained. The interviewer should
be particularly careful not to indicate by either comment or tone of voice any
reaction to the answers received.  It is also important for the interviewer not to
reveal the name of the agency conducting the survey nor the reason the survey is
being conducted. Some respondents may challenge the interviewer or question the
validity of the survey.  Such situations must be handled with a great deal of tact on
the part of the interviewer.  The respondent has the right to determine whether
the survey is legitimate, but if information about the agency or the survey is
given before the questions are asked, the respondent's answers  may not be valid.
Therefore, if possible, the interviewer should  agree to tell the respondent this
information after the questionnaire is completed.  If the respondent refuses to
continue the interview without this information,  the interview should be terminated.

       The respondent may suspect that the call is being made in connection with
the sale of a product.  The interviewer may assure the respondent that this is not
the case prior to asking the questions.  It may  also be necessary to tell the re-
spondent that the answers given will become a part of a statistical summary and
individual responses will not be revealed in any way.   If required, this may also
be done prior to asking the questions.

       Never suggest an answer or train of thought to the respondent. Do not
prompt in any way.  The most important job of an interviewer is to encourage the
respondent to express his or her attitudes  and to be specific in conveying these
attitudes.  Close attention to the clarity and completeness of the responses is
important. Never talk up or down to a respondent. Do not comment on the mean-
ing of any question or indicate in any way what  kind of answers are expected.

       If the respondent asks a question or fails to understand or respond to a
question,  read the question over again more slowly, using a pleasant but neutral
tone of voice.  On occasion, it may be necessary to repeat a question more than
once before obtaining a response.  Do not allow any tone of impatience to creep
into your voice. if necessary, explain that you are not permitted to discuss the
meaning of the questions.

       When asking the questions, stress only  those words that  are underlined.
Do not change the wording of any question.  These questions have been carefully
                                      -13-

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constructed to obtain the information desired.  Do not change the order of the
questions from that listed on the questionnaire.

       Before making a telephone call, the interviewer  should fill out the upper
portion of the questionnaire (a copy of the questionnaire is included at the end of
this procedure).  From the sample listing, fill in the telephone number, street
address, and city to which the call will be made.  The "File No." blank is pro-
vided for identification of the odor source under investigation.  This blank should
not be filled in until the source has been verified.  The  "Survey No." blank is
provided to allow differentiation between test and control area responses, as well
as surveys conducted at a later time. For example, before the first survey of a
suspected odor problem, "Survey No. 1A" could be assigned to the  test area and
"Survey No.  IB" could be assigned to the control area.  If the same areas are the
subject of another survey at a later date,  survey numbers 2A and 2B could be
assigned, respectively.

       The "Respondent No ." should be left blank until  tabulation of the survey
results is begun.  However, the date of the call and the time of day the  call is
made should be noted on the questionnaire before the call is made.

Interviewer Instructions for Making Calls

       Call the telephone number filled in on the questionnaire.   If there is no
answer or the line is busy,  go on to the next telephone number on the list.

       If the call is answered, read the opening statement,  saying your name in
the appropriate place.  If the person who answers  the telephone is obviously a
woman, use the feminine alternatives in the statement;  if a man,  the masculine
alternatives.  Children,  relatives,  or friends living in or visiting the household
should not be interviewed.  In addition, no person under 18 years of age should
be interviewed.  Make  sure that the person with whom you are speaking is the
man or lady of the house.  If he or she is not, try to talk with the man or lady of
the house.  If this cannot be done,  terminate the call, check that  the interview
was not completed, note the reason, and go on to the next telephone number in
the sample.

       If the man or lady of the house refuses to be interviewed at all,  note that
the interview was not completed and the reason.  "Refused" is a  sufficient expla-
nation .

       The numbered blanks in the right hand margin of the questionnaire are to
be used in tabulating the responses. Do not write  in these spaces at this time.
Every question has a list of responses after it.  Except for question 3,  only one
answer should be checked.  If the respondent gives more than one answer for a
question, ask which answer is the best answer to the question. When a question
is followed by three dots, such as  "How strong would you say these odors smell?
                                      -14-

-------
Would you say...?", read the answers provided in the order they are listed, but
do not read either the answer numbers or the response "Don't know."

       When a question is not followed by three dots, such as "When was the
last time you noticed odors in your neighborhood?",  do not read the responses.
When a question has a space provided for "Other answers," write down everything
the respondent says.  If local agency secretaries are used as interviewers, they
should use only longhand to write down "Other answers."

Interviewer Instructions for Specific  Questions

       The following instructions  should be adhered to in asking the specific ques-
tions on the questionnaire.
                                                                       IfTkT  ft
       Question 1.   Do not read the responses.  If the respondent answers "No,
read the statement following the "No" response and terminate the interview.

       Question 2 .   Do not read the responses .  If the respondent answers "Yes,
ask question 3.  If the respondent answers "No" or "Don't know, " ask question 4.

       Question 3 .   This question should be asked only of those people who
answered "Yes" to question 2. Read the responses, except for "Don't know."
Check all answers that the respondent gives to this question.
       Question 4.   Do not read the responses .  If the respondent answers "No, "
or "Don't know, " skip to question 12.  If the respondent answers "Yes, " ask ques-
tion 5.

       Question 5.   Do not read the responses.  Check the response that covers
a period most like that identified by the respondent.  Repeat the question, if neces-
sary, to obtain a response, but do not read the possible responses .

       Question 6 .   Do not read the responses .  Check the response that covers
a period most like that identified by the respondent.  Repeat the question, if neces-
sary, to obtain a response, but do not read the possible responses.

       Question 7 .   Read the responses rather slowly, pausing between each
possible response.  Do not read "Don't know."  Repeat the question and responses,
if necessary, to obtain a reply.

       Question 8 .   Do not read the responses.  Check the response that covers
a period most like that identified by the respondent.  Repeat the question, if neces-
sary, to obtain a response, but do not read the possible responses.
                                      -15-

-------
       Question 9.   Do not read the responses.  If the respondent answers "No"
or "Don't know," skip to question 11.  If the respondent answers "Yes," ask ques-
tion 10.

       Question 10.   Read the responses rather slowly, pausing between each
possible response.  Do not read "Don't know."  Repeat the question and responses,
if necessary, to obtain a reply.

       Question 11.   Do  not read the responses .  Clarify the response,  if neces-
sary, by asking the respondent to explain more fully what is meant by the answer
given. For example,  if the respondent says "Some factory," clarification might
elicit the answer, "An oil  refinery near my neighborhood." Write down any other
source(s) identified by the respondent.

       Next, read the statement preceding question 12 regarding the  confidential
nature of the information being gathered.

       Question 12.   Do  not read the responses.  Clarify the response,  if neces-
sary, as explained under question 11.  Write down the other company mentioned
by the respondent if the answer is not the source(s) under investigation.

       Question 13.   Do  not read the responses .  Clarify the response,  if neces-
sary, as explained under question 11.  Write down the other companies or employ-
ers mentioned if the answer does not include the source(s) under investigation.

Interviewer Instructions for Completing Interviews

       Read the statement at the end of the questionnaire and terminate the inter-
view.  Write your name in the space provided, and check the  space for a completed
interview on the first page of the questionnaire.  Go on to the next telephone number.

       Interviewing should be continued until all of the telephone numbers in the
sample have been dialed once.  Review the completed questionnaires, and remove
those where the answer to either question 12 or question 13 indicates a member
of the household is employed by the odor source under investigation.  This is
recommended because of potential bias the respondent may have either in favor
of or against the employer. If the source has not been verified by an agency in-
spector,  this step should be ignored.

       Next, count the number of completed questionnaires remaining for the
test area.  If there are at  least 30, the interviewing portion of the survey is com-
plete.  If not, continue to  interview, utilizing those telephone numbers where
no-answers or busy signals were received, until all no-answers or busy signals
in the sample have been called a second time.  Do the same thing for the control
area.
                                     -16-

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Tabulation

       If the local agency has access to electronic data processing equipment,
and the number of respondents in either the test or control area exceeds 90, con-
sult with those in charge of such equipment to set up procedures for tabulating the
survey. If such equipment is not available or the number of respondents in each
area is small, hand tabulating is quite  satisfactory.

       Regardless of the tabulating procedure utilized, the completed question-
naires must be edited and coded. Editing should be done by persons other than
those who conducted the interviews. The purpose of this task is to insure  that
all questions have been asked and answers recorded. Inconsistencies also can
be identified and corrected.

       On each questionnaire there should be a response to all appropriate ques-
tions . For example, if question 2 concerning people in the neighborhood com -
plaining about pollution has been answered with a "Yes," then question 3 dealing
with the kind of pollution people complain about should have  also been answered,
even if the answer is "Don't know."

       The following comments regarding each question on the questionnaire may
be used as a guide for editing.  If editing uncovers errors or omissions, it may
be necessary to call the respondent again to clarify an answer which has been
incorrectly recorded or to eliminate an inconsistency.

       Question 1.   If the response is "No, " all other questions on the question-
naire should be unanswered.

       Question 2.   If the response is "Yes," there should be an answer to ques-
tion 3.  If the response  is "No," there  should be no response to question 3.

       Question 3.   There should be no response to this  question if question 2
has a "No" reply.

       Question 4.   If the response is "No" or "Don't know," questions 4,  6, 7,
8, 9, 10,  and  11 should not contain responses.  If the answer to question 4 is
"Yes," questions 4, 6,  7, 8, 9,  and 11 must have been answered, also, even if
the answer is  "Don't know."

       Question 5.   There should be a reply to this question only if question 4
was answered "Yes." If so, there  must be a reply to this question.

       Question 6.   Same as question 5.

       Question 7.   Same as question 5.
                                      -17-

-------
       Question 8.   Same as question 5.

       Question 9.   Same as question 5.

       Question 10.   If the response to question 9 was "No" or "Don't know,"
there should be no response to this question.  If the response to both question 4
and question 9 was "Yes, " this question should have been answered,  also.

       Question 11.   Same as question  5.

       Question 12.   There should be a response to this question on all question-
naires except those where the response to question 1 was "No."

       Question 13.   Same as question  12.

       When the editing is completed, the questionnaires should be coded.  This
merely means writing the number of the  response to each question on the appro-
priate line near the right hand margin of the questionnaire.  If there  was more
than one response to question 3, the number of each type of pollution mentioned
may be written in the margin.

       When the coding is completed, each questionnaire should be numbered on
the first page in the blank following "Respondent No."  The same sequence of num-
bers may be used for the test area and the control area, since the areas will be
distinguished by the survey numbers assigned earlier.

       Tabulation may be accomplished in one of two ways.  A  form  can be de-
signed on  which to tally the number of responses of each kind to each question.
(A recommended form is provided at the end of this procedure.)  An  alternative
is to sort  the questionnaires themselves  into stacks according to the  answers to
a particular question and count the number of questionnaires in each  stack.  This
method tends to be somewhat more error free than tallying.

       Regardless of the method used, the total of all responses to each question
(except question 3) must match the total number of people asked that  question.
This provides a check on the accuracy of the tabulation. (Since question 3 is a
multiple response question,  the total number of all responses may exceed the
total number of people asked that question. Questionnaires containing more than
one response to question 3 should be separated from those having only one response.
Tabulate and total the responses on questionnaires having only one response.  Then,
tabulate separately the responses for each kind of pollution mentioned on the ques-
tionnaires with more than one response.  Finally,  add the two tabulations together
to obtain the total number of responses for each kind of pollution included in
question 3.)
                                      -18-

-------
       For purposes of odor problem identification, it is not necessary to tabu-
late the responses to all questions.  Question 1 is included in the survey to avoid
errors caused by the use of street address telephone directories that may be as
much as six months old. (Such directories are usually published at six-month
intervals.)  Questions  2  and 3 are included for introductory purposes.  Questions
4 through 10 provide odor problem definition. Question  11 permits possible iden-
tification of the odor source.  Questions 12 and 13 are included so that employees
of the source under investigation may be removed from the  sample.

       All questions may be tabulated and will yield useful information, but for
odor problem identification, tabulation should begin with question 9.  The re-
sponses to question 9 alone will indicate whether an odor problem exists.  If it
is determined that an odor problem does not exist, complete tabulation of all
questions need not be undertaken.
PROBLEM IDENTIFICATION

       The decisive step in odor problem identification is to determine whether
a significant difference exists between the proportion of respondents in the test
area who state they have been bothered by odors and the proportion of respondents
in the control  area who state they have been bothered by odors. This  is done by
using the tabulated results of question 9 from the test area and control area sur-
veys .  A form entitled "Odor Problem Identification" is included at the end of this
procedure to provide a convenient method for determining whether a significant
difference exists. A technical explanation of the method is presented  in the
"Statistical Reference" section of this procedure.

       If, after completing the "Odor Problem Identification" form, the number
in the box labeled "z" is equal to or larger than 1.65,  a significant difference
exists between the test and control areas.  If "z" is less than 1.65, no significant
difference exists. If this analysis indicates no significant difference,  then it
should be concluded  that the test area is not an odor problem area.  If a signifi-
cant difference is indicated,  then an odor problem index number should be calcu-
lated to indicate the  extent of the odor problem relative to other odor problems
identified within the  jurisdiction of the local agency.  The odor problem  index
number may be simply constructed by completing a form  entitled "Determination
of the Odor Problem Index." This form is also included below. It is based on a
formula given in the "Statistical Reference" section.

       It is important not to confuse the value of "z" with the odor problem index
number. The  value  of "z" depends upon whether or not annoyance exists in rela-
tion to the number of interviews completed in the test area and the control area.
As such, it is  used merely to decide whether or not a community odor problem
exists.  The odor problem index number, however,  takes into account the extent
                                      -19-

-------
to which odors have caused bother in each area and, therefore, is used properly
for comparative purposes.
ALTERNATE MEANS OF PROBLEM IDENTIFICATION

       An alternate means of odor problem identification — called sequential
analysis — is available to agencies that have conducted several public attitude
surveys in accordance with the above instructions.  It involves combining the
results obtained from surveys conducted in at least three control areas, selecting
a sequential sampling plan, and comparing the results  obtained in future test area
surveys with the plan selected. It should be considered for use particularly in
cases where the existence of an odor problem is very likely.

Combining Control Area Results

       The results obtained from public  attitude surveys of at least three control
areas that were conducted within the agency's jurisdiction during the past twelve
months should be combined.  This is done by simply dividing the total number of
"Yes"  responses to question 9 obtained from  these areas by the total number of
interviews completed in these  areas. The  average thus calculated is  called the
"acceptable odor level (AOL)."

Selecting a Sequential Sampling Plan

       It is estimated that the AOL for almost all jurisdictions will fall between
0.100 and 0.300.  For the convenience of local agencies,  five sequential sampling
plans are given in Tables 4,  5, 6, 7, and 8.  These  plans are for use in
jurisdictions in which the AOL is determined to be 0.100, 0.150, 0.200, 0.250,
or 0.300. They may be used in other jurisdictions as described below.  However,
more precise plans can be developed for these other jurisdictions as explained in
the "Statistical Reference" section.

       Once an AOL has been  calculated for a jurisdiction, only one sequential
sampling plan is appropriate for use in that jurisdiction.  It may be considered
to remain appropriate until such time that the agency feels a  noticeable change
in ambient odor intensities has occurred throughout the jurisdiction.

       If the AOL differs from the above five, the sequential sampling plan with
the next largest AOL should be selected.  For example, if an AOL of 0.118 is
calculated, the  plan with an AOL of 0.150 should be selected. If an AOL larger
than 0.300 is calculated, sequential analysis  should not be used.  The effect of
using a plan with the next largest AOL would be equivalent to requiring a "z"
value slightly larger than 1.65 for a community odor problem to be identified.
                                      -20-

-------
        Table 4.  Sequential sampling plan for deciding whether or not an odor problem
        exists in a community being surveyed (AOL = 0.100, OPL = 0.263, a = 0.05,
        6=0.05).
 i
to
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
*
*
*
*
*
*
*
0
0
0
0
0
0
1
1
1
1
1
1
2
2
2
2
Odor
Problem
Decision No.
*
*
*
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
7
8
8
8
8
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
2
2
3
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
6
7
7
7
7
7
Odor
Problem
Decision No.
8
9
9
9
9
9
9
10
10
10
10
10
10
11
11
11
11
11
11
12
12
12
12
12
12
13
13
13
13
13
Table 5 .  Sequential sampling plan for deciding whether or not an odor problem
exists in a community being surveyed (AOL = 0.150, OPL = 0.333, a = 0.05,
 B = 0.05).
        * A no-odor-problem decision cannot be reached until 15 interviews have been com-
         pleted; an odor-problem decision cannot be reached until 4 interviews have been
         completed.
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
*
*
*
*
*
0
0
0
0
1
1
1
1
2
2
2
2
2
3
3
3
3
4
Odor
Problem
Decision No.
*
*
*
4
4
5
5
5
5
6
6
6
6
7
7
7
7
8
8
8
8
8
9
9
9
9
10
10
10
10
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
4
4
4
5
5
5
5
6
6
6
6
6
7
7
7
7
8
8
8
8
9
9
9
9
9
10
10
10
10
11
Odor
Problem
Decision No.
11
11
11
11
11
12
12
12
12
13
13
13
13
14
14
14
14
15
15
15
15
15
16
16
16
16
17
17
17
17
' A no-odor-problem decision cannot be reached until 13 interviews have been com-
 pleted; an odor-problem decision cannot be reached until 4 interviews have been
 completed.

-------
 I
bo
to
 I
      Table 6.  Sequential sampling plan for deciding whether or not an odor problem
      exists tn a community being surveyed (AOL = 0.200,   OPL = 0.393, a = 0.05,
       6 = 0.05).
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
#
#
*
*
*
*
*
*
>f
0
0
0
0
1
1
1
2
2
2
2
3
3
3
4
4
4
5
5
5
Odor
Problem
Decision No.
*
*
*
*
5
5
6
6
6
6
7
7
7
8
8
8
9
9
9
9
10
10
10
11
11
11
11
12
12
12
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
5
6
6
6
7
7
7
7
8
8
8
9
9
9
9
10
10
10
11
11
11
11
12
12
12
13
13
13
14
14
Odor
Problem
Decision No.
13
13
13
13
14
14
14
15
15
15
15
16
16
16
17
17
17
18
18
18
18
19
19
19
20
20
20
20
21
21
Table 7.
exists  in a
8 =0.05).
Sequential sampling plan for deciding whether or not an odor problem
community being surveyed (AOL = 0.250,  OPL = 0.453, o = 0.05,
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
*
*
*
0
0
0
1
1
1
2
2
3
3
3
4
4
4
5
5
5
6
6
6
7
No Odor
Problem
Decision No.
0
*
*
*
5
6
6
7
7
7
8
8
8
9
9
9
10
10
10
11
11
11
12
12
12
13
13
13
14
14
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
7
7
8
8
8
9
9
9
10
10
10
11
11
12
12
12
13
13
13
14
14
14
15
15
15
16
16
16
17
17
Odor
Problem
Decision No.
14
15
15
16
16
16
17
17
17
18
18
18
19
19
19
20
20
20
21
21
21
22
22
22
23
23
24
24
24
25
       k A no-odor-problem decision cannot be reached until 11 interviews have been com-
        pleted; an odor-problem decision cannot be reached until 5 interviews have been
        completed.
* A no-odor-problem decision cannot be reached until 10 interviews have been com-
 pleted; an odor-problem decision cannot be reached until 5 interviews have been
 completed.

-------
       Table 8.     Sequential sampling plan for deciding whether or not an odor problem
       exists in a community being surveyed (AOL = 0.300,  OPL = 0.510,  a = 0.05,
         = 0.05).
Sample
Size
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
No Odor
Problem
Decision No.
*
*
*
*
*
*
#
*
0
0
1
1
1
2
2
3
3
3
4
4
5
5
5
6
6
7
7
7
8
8
Odor
Problem
Decision No.
*
*
*
*
*
6
7
7
7
8
8
9
9
9
10
10
11
11
11
12
12
13
13
14
14
14
15
15
16
16
Sample
Size
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
No Odor
Problem
Decision No.
9
9
10
10
10
11
11
12
12
12
13
13
14
14
14
15
15
16
16
16
17
17
18
18
18
19
19
20
20
20
Odor
Problem
Decision No.
16
17
17
18
18
18
19
19
20
20
20
21
21
22
22
22
23
23
24
24
24
25
25
26
26
26
27
27
28
28
to
CO
 I
         A no-odor-problem decision cannot be reached until  9  interviews have been com-
         pleted; an odor-problem decision cannot be reached until 6 interviews have been
         completed.

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Comparing Results From Test Area Surveys With the Plan Selected

       Once a sequential sampling plan has been selected by a local agency, the
results obtained from future test area surveys should be compared to the plan,
not to results obtained from control area surveys. In fact, except when a deci-
sion cannot be reached by using the plan or until such time that the agency feels
that a noticeable change in ambient odor intensities has occurred throughout the
jurisdiction, additional control area surveys should not be conducted.

       The results obtained from a test area survey are compared to the plan
selected by the agency as follows. Interviews are conducted with residents of the
test area in the order in which their telephone numbers were randomly selected.
At the end of each completed interview, the number of completed interviews and
the responses  to question 9 are tallied by the interviewer. The cumulative num-
ber of  "Yes" responses should be kept separate from the cumulative number of
"No" and "Don't know" responses. Reference is then made to the plan selected.

       The cumulative number of completed interviews is  shown  as the "Sample
Size." A comparison is made by simply finding the cumulative number of com-
pleted  interviews in the  "Sample Size" column and then noting the "No Odor
Problem" and  "Odor Problem" decision numbers corresponding to the cumulative
number of completed interviews.  If the cumulative number of "Yes" responses
to question 9 is equal to the "No Odor Problem Decision No.," no odor problem
exists  in the test area.  (Such a finding means that there is no significant differ-
ence between the results of the test area survey being conducted and the combined
results of the control area surveys that were used in calculating the AOL.) If the
cumulative number of "Yes" responses to question 9 is  equal to the "Odor Problem
Decision No., " an odor problem  exists in the test area. (Such a  finding means
that there is a significant difference between the results of the test area survey
being conducted and the combined results of the control area surveys that were
used in calculating the AOL.)

       Once either of these decisions has been made, the survey should not be
continued.  If, however, the cumulative number of "Yes" responses to question 9
is greater than the "No Odor Problem Decision No.," but less than the "Odor
Problem Decision No.," an additional interview must be completed.  The responses
to question 9 are again tallied and the cumulative numbers of completed interviews
and "Yes" responses are again compared to the plan selected.

       For example, assume that the plan with  an AOL of 0.150 is selected (see
Table 5 ) and that a test area has been established to investigate  a possible odor
problem.  Further assume  that after completing interviews with four residents
of the test area, the cumulative number of "Yes" responses to question 9 is also
four. By reference to Table  5,  this is sufficient for an odor problem  to be said
to exist.  (For a "Sample Size" of 4, the "Odor Problem Decision No." is 4.)
As a second example, assume that after completing interviews with 13 residents
                                     -24-

-------
of Che test area, none of the respondents stated that they were bothered by odors.
Under the same sequential sampling plan, the decision is that no odor problem
exists.  (For a "Sample Size" of 13, the  "No  Odor Problem Decision No." is 0.)

       As a final example, assume that after completing interviews with four
residents of the test area only three of the respondents were bothered by odors.
By reference to Table 5,  a decision cannot be reached.  Consequently,  an addi-
tional interview must  be completed, the responses to question 9 again tallied, and
the  cumulative  numbers of completed interviews and "Yes" responses again com-
pared to the plan  selected. If a decision cannot be reached after 60 interviews
have been completed or after the entire sample of telephone numbers in the test
area has been exhausted and all no-answers and busy signals  have been called a
second time, a matching control area should  be established.  A random sample
of telephone numbers  should be drawn and a public attitude survey should be con-
ducted in this control  area within three days following the survey conducted in the
test area.  In such a case, whether or not an odor problem exists in the test area
is decided by completing the "Odor Problem Identification" form.

       Considerable time and expense can be saved through the use of sequential
analysis in most cases.  However,  it should be remembered  that this alternate
means of problem identification does not provide an indication of the extent of an
odor problem relative to other odor problems identified within the jurisdiction of
the  local agency.
OTHER USES OF SURVEY RESULTS

       During abatement proceedings, it may be necessary to refer to the results
of the test area survey to  indicate the percentage of test area residents who re-
sponded in a particular way. For example, it may be necessary to state the per-
centage of all test area residents who noticed odors in their neighborhood during
the week of the survey.  It would be inaccurate,  however, to use directly the
percentage of test area residents who answered "This week" to question  8.  An
adjustment is required to  eliminate responses to question 8 that are actually
based on variables other than odors.

       The adjustment is  easy to accomplish. Simply subtract the percentage
response to the question in the control area from the percentage response in the
test area.  The answer is then divided by one hundred percent minus the  percent-
age response in the control area.  The resulting percentage is the true percentage
response for the test area.  Thus, if 65 percent of test  area residents and 25
percent of control area residents stated they noticed odors in their neighborhoods
"This week," then 53 percent would represent the true percentage of test area
residents who noticed odors in their neighborhood during the week of the  survey
(65% - 25%/(100% - 25%) = 53%).
                                      -25-

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     PUBLIC ATTITUDE SURVEY OF COMMUNITY ODOR PROBLEMS
             PROBLEM IDENTIFICATION QUESTIONNAIRE
Respondent:

Phone No.
Street Address_

City	
                                                 File No.

                                              Survey No.

                                          Respondent No.
Record of Call:
 Date
Time
                          Check If
                         Interview
                         Completed
  Check If
Interview Not
 Completed
  Reason If
Not Completed
                            (name)
                                  . I'm calling (long dis-
'Hello. My name is	
tance) for a government agency interested in certain community problems.
I'd like to talk with the man/lady of the house to get his/her opinion on a few
questions . Are you the man/lady of the house?" (IF NOT,  ASK: "May I talk
with him/her?")
Ql)    Have you lived at your present address more than six months?

               1. Yes
               2. No  (SAY: "I'm sorry. This survey was designed for
                      longer term residents.  Thank you for your time.")
Q2)    Lately, people have become very much concerned about the environ-
       ment and various types of pollution.  Do people complain about any
       kind of pollution in your neighborhood?

           	1. Yes (ASK Q3.)

           	2. No(ASKQ4.)

           	3. Don't know (ASK Q4.)
                                Page 1

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Q3)    Do people complain about...?

           	1. Air pollution in your neighborhood

           	2. Water pollution in your neighborhood

           	3. Airport, industrial,  or traffic noise in your neighborhood

               4. Noticeable odors in your neighborhood
           	5. Don't know (DO NOT READ THIS RESPONSE.)


Q4)    Have you noticed any odors in your neighborhood in the last three
       months?

           	1. Yes (ASK Q5.)

           	2. No (SKIP TO Q12.)
           	3. Don't know (SKIP TO Q12.)


Q5)    How often have you noticed these odors?

               1. At least once a day

           	2. At least once a week, but not every day

               3. At least once a month, but not every week

               4. Less than once a month
               5.  Don't know


Q6)    Generally speaking, how long do these odors last?

           	1.  At least one day

               2.  At least one hour, but less than one day

           	3.  At least 15 minutes, but less than one hour

               4.  Less than 15 minutes

               5.  Don't know


                                 Page 2

-------
Q7)   How strong would you say these odors smell? Would you say	?




               1.  Very strong




          	2.  Strong




               3.  Moderate
          	4.  Slight




          	5.  Don't know (DO NOT READ THIS RESPONSE .)







Q8)    When was the last time you noticed odors in your neighborhood?




          	1.  This week




               2.  Last week




          	3.  Two to four weeks ago/a month ago




          	4.  More than a month ago




          	5.  Don't know







Q9)    Would you say that these odors have  bothered you?




          	1.  Yes(ASKQ10.)




          	2.  No (SKIP TO Qll.)




          	3.  Don't know (SKIP TO Ql 1.)
Q10)   How much would you say they have bothered you?  Would you say...?




               1.  Very much




           	2.  Much




           	3.  Moderately                                                10_




               4.  Little
               5.  Don't know (DO NOT READ THIS RESPONSE .)
                                Page 3

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Qll)   Where would you say most of these odors originate, that is, who or
       what causes them?

           	1. Source(s) being investigated
               _2. Other source(s):
               3. Don't know
"All this information is strictly confidential, but we need it for statistical
purposes."
Q12)   What company do you work for?

           	1. Source(s) being investigated

           	2. Other company/none:	
                                                                              12
               3. Refused
Q13)   What companies do other members of your household work for?

           	1.  Source(s) being investigated

           	2.  Other company(ies)/none:
               3.  Refused
"That completes the interview.  Thank you very much for your time."
Interviewer's Name:
                                 Page 4

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                       PUBLIC ATTITUDE SURVEY - TABULATION FORM
                                                                          File No.
                                                                        Survey No.
Instructions.  Place a tally mark in the appropriate box to record the answer to each completed
question on the questionnaire. By tallying the fifth duplicate response with a diagonal line, count-
ing total responses is simplified ( TH1 = 5 responses).
Question 1. (Tabulate only if desired)
Response 1
Total Response 1
            Response 2
            Total Response 2
                         Total
Question 2.  (Tabulate only if desired)
Response 1
          Response 2
                   Response 3
Total Response 1
          Total Response 2
                   Total Response 3
                            Total
Question 3.  (Tally all responses given on each questionnaire, if desired)
Rl
R2
R3
R4
:RS
Total R 1
Total R2
Total R 3
Total R 4
 Total R 5
Total
Question 4.
Rl
Total R 1
R2
Total R 2
R3
Total R 3

Total |
Question 5.
Rl
Total R 1
R2
Total R2
R3
Total R 3
R4
Total R 4
R5
Total R 5


Total J
                                           Page 1

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PUBLIC ATTITUDE SURVEY - TABULATION FORM (Continued)



Question 6.
Rl
Total R 1

Question 7 .
Rl
Total R 1

Question 8.
Rl
Total R 1

Question 9.
Rl
Total R 1

Question 10.
Rl
Total R 1




R2
Total R2


R2
Total R2


R2
Total R 2


R2
Total R 2


R2
Total R 2




R3
Total R 3


R3
Total R 3


R3
Total R 3


R3
Total R 3


R3
Total R 3

S


R4
Total R 4


R4
Total R 4


R4
Total R 4


R4
Total R 4


R4
Total R 4
File No.
urvey No.


R5
Total R 5


R5
Total R 5


R5
Total R 5


R5
Total R5


R5
Total R 5





Total



Total



Total ]



Total



Total
                       Page 2

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PUBLIC ATTITUDE SURVEY - TABULATION FORM (Continued)

File No.
Survey No.

Question 11. (Tabulate only if desired)
Rl
Total R 1
R2
Total R2
R3
Total R 3

Question 12 . ( Tabulate only if desired)
Rl
Total R 1
R2
Total R2
R3
Total R 3

Question 13. (Tabulate only if desired)
Rl
Total R 1
R2
Total R 2
R3
Total R 3

Total

Total

Total
                       Page 3

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                                          ODOR PROBLEM IDENTIFICATION
Instructions
2.
3.
4.
5.
In each box labeled "A," fill in the number of interviews completed in the Control Area survey. (The number of interviews
completed = the number of problem identification questionnaires checked as completed.)
In each box labeled "B, " fill in the number of interviews completed in the Test Area survey.
In each box labeled "C," fill in the number of "Yes" responses (R 1) to Question 9 from the Test Area survey.
In each box labeled "D," fill in the number of "Yes" responses (R 1) to Question 9 from the Control Area survey.
Follow the direction of the arrows. Perform the calculations indicated.  (The square root can be easily found by referring
to a standard table of square roots and, therefore, need not be calculated.)
If the number in the box labeled "z" is 1.65 or more, an odor problem  exists.
                                             Subtract
                                                                 Divide
                 Add
                  +   B
                                                        t
                                                                                                              Find Square
                                                                                                                 Root
Multiply
A

C

A

c
*
Add
+
Add
+
Add
*
:*

D

B

D
                                                                        Multiply
                                                                                                   Divide
                                                                                      A

-------
                         DETERMINATION OF THE ODOR PROBLEM INDEX
Instructions

      Insert the total numbers of responses tabulated from the surveys in the boxes provided.  Follow the direction
of the arrows.  Perform the calculations indicated.

  Test Area Responses
       Rl      R2
                                                                      lx 1.25 =
  Q6
  Q7  [ZZ3+CZI]-
  Q8  I     14- I     I =
  Q4
                                    I
      d=>d=] = dZ]
  Q9
Control Area Responses
     Rl      R2
QS i     i+i     i= i     i+r~~i+
Q6 I     l+dZH =
Q7
   Q4
   Q10
   Q9
•en:
                                                                                  -1    1+5.00 =1
                                                         = 1     lx I     lx 1.25=1    I-
                                                                                                    OPI
                                                     A

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STATISTICAL REFERENCE SECTION

Statistically Significant Differences for Odor Problem Identification

      To determine whether there is a significant difference between the test and
control area responses to question 9 of the Problem Identification Questionnaire,
the following hypotheses must be tested:

      Hypothesis 1 (Hi):  irt =  ir

      Hypothesis 2 (H2):  ^t >  ^c  (one -tail test)

                          o =  0.05

      where:     ir^ = the true  or universe proportion of "Yes" responses
                      to question 9 in the test area

                 ir  = the true or universe proportion of "Yes" responses
                       to question 9 in the control area

                  a = the probability of concluding, on the basis of sample
                       values,  that no significant difference exists between
                       test and control areas when a significant difference
                       in universe values exists

Using the normal approximation:
                           - TTC)
                          nc
      where:     n  = the sample size, i.e., the number of interviews com-
                      pleted in the test area

                 n  = the sample size, i.e., the number of interviews com-
                      pleted in the control area

                 Jc. = the number of "Yes" responses to question 9 in the
                      test area
                 k  = the number of "Yes" responses to question 9 in the
                      control area
                                      -35-

-------
                 p  = __
                       "t
                       k
Assuming the null hypothesis (Hi) is true,  this equation becomes:


(2)   z =
                    n*   n


                A   k    k
Estimating TT by if =  *• '*'—£
                    Ilj. + Hj,

      and setting N = nt + ^

      and        K = kt + kc

      then (2) can be rewritten as:
            k   k
            _t _ _c
            n   n          n k    nk
             t    c          c t -  t c
      z = -—-—-—==——^ =  	
            K(N -K)
                                 N
If z is normal, then the probability of z £ 1 .65 = 4.95% or approximately 5%.

       It is noted that, in cases where sample size nt (or nc) is a large fraction
of the total number of telephones in the test area (or control area), the calculated
value of "z" will somewhat understate any difference  in irt and  IT £. in such cases,
marginally significant differences between ^ and ^c  may not be indicated by the
calculated value of "z" and, consequently,  marginally existent  community odor
problems may not be identified. To preclude this possibility, the value obtained
from using the  "Odor Problem Identification" form should be multiplied by one of
the following correction factors. If the resulting corrected value of "z" is equal
to or larger than 1.65, a community odor problem is said to exist.
                                      -36-

-------
Table 9,    Correction factors for use when sample size is a large fraction of the
total number of telephones in the area to be surveyed.	
    If the number of                   Multiply the value obtained from the
telephones in the area is:	"Odor Problem Identification" form by:
         1-90                     census of area,  no correction factor applied
       91-180                                      1.09
       181-270                                      1.06
       271-360                                      1.04
       361-450                                      1.03
       451-540                                      1.03
       541-630                                      1.02
       631-720                                      1.02
       721-810                                      1.02
       811-900                                      1.02
       901-990                                      1.02
       991-1080                                     l.Ol
      1081-1170                                     1.01
      1171-1260                                     1.01
      1261-1350                                     1.01
      1351 and over                  < 1% error if no correction factor applied
                                     -37-

-------
     Determination of the Odor Problem Index
           OPI =1.25
                                                                      (Rl +R2)
                                                                                          Q10
                                              (Rl)
                                                  Q4
                                                                         (Rl)
                                                                             Q9
Test Area
               - 1.25
                                                                      (Rl +R2)
                                                                                          Q10
                                               (Rl)
                                                   Q4
                                                                         (Rl)
                                                                             Q9
Control Area
               + 5.00
oo
t
where:     OPI = Odor Problem Index

           Rl  = response 1;  R2 = response 2;  etc.

           Ql  = question 1; Q2 = question 2; etc.
           The above formula is based on the Problem Identification Questionnaire.  Assuming that the control area is
     as odor free as possible (at least as free of odors as the test area), the formula will yield an index number between
     zero and 10.  The size of this number depends upon the combination of frequency (Q5), duration (Q6), intensity (Q7),
     and recentness (Q8) of odors noticed in the test area as compared to the control area.  This combination of problem-
     inducing variables is weighted by the  extent to which odors have caused bother in each area.

-------
Development of a Sequential Sampling Plan

       The first step in the development of a sequential sampling plan involves the
calculation of an acceptable odor level (AOL) as described in the procedure .  The
second step requires the calculation of an odor problem level (OPL) — by trial and
error.  To accomplish the latter step, use the  "Odor Problem Identification" form
to find the number of "Yes" responses to question 9 from a test area survey (the
boxes labeled "C") that would have had to be obtained for "z" to equal 1.65.   Fill
in the boxes labeled "D" with the number that results from multiplying the AOL
by 30 .  Fill in the boxes labeled "A" and "B" with the number 30 . The OPL is
calculated by dividing the number found for the boxes labeled "C" by 30.

       The third step requires the calculation of h^, h2, and s, where:

                               OPL
                               AOL(l-OPL)

              ,    .    1-6,.    OPL (1-AOL)
              h2 = log -s-Vlog  AOL (1 -OPL)
              s = log            OPL
                   5
                     1-OPL     AOL (1 -OPL)

              a = the probability that an odor problem decision will
                 be reached when no odor problem exists = 0.05

              6 = the probability that a no odor problem decision will
                 be reached when an odor problem exists = 0.05

              AOL = an acceptable odor level

              OPL =an odor problem level

Generation of the series of decision numbers from which the plan is developed is
accomplished by calculating c^ and C2 for  n  equal to  1 through 60, where:

              c^ =a  no odor problem decision number = -hj + sn

              G£ = an odor problem decision number = h2 + sn

               n =the sample size

       In general,  c  represents the number of respondents in the community being
surveyed who stated they have been bothered by odors . Thus ,  the series of decision
numbers generated above must be rounded to equal zero or whole numbers accord-
ing to the following rules:
                                     -39-

-------
       •  For Cp any fraction of a whole number should be rounded to the next
          lowest whole number.  Negative numbers in the series should be ig-
          nored .

       •  For C2> any fraction of a whole number should be rounded to the next
          highest whole number.  Negative numbers should not be encountered.

       As a final step, the series of rounded decision numbers should be put into
a tabular form similar to those of Tables 4 through 8 of the procedure.  It is
noted that a sequential sampling plan developed in this manner will provide the
same decision as z = 1.65 only when n equals 30 completed interviews. At less
than 30 completed interviews, decisions under such a plan would be comparable
to z  > 1.65 (the decisions, therefore, being made with somewhat greater confi-
dence). At greater than 30 completed interviews, decisions under such a plan
would be comparable to z < 1.65 (the decisions, therefore, being made with some-
what less confidence).

Adjustment to Eliminate Test Area Responses Based on Variables Other Than Odors

     The formula is a Bayesian type of correction for chance success:

           P'(S's)  = P(S|s)  - P(S|n)
                      100-P(S|n)
           where:     P'(S|s) =  the percentage of "signal" attributable
                                to the variable under study

                      P(Sls)  =  the total percentage of "noise" plus
                                "signal" measured in the test group

                      P(S)n)  =  the percentage of "noise" measured
                                in the control group
                                     -40-

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                  PROCEDURE FOR SOURCE VERIFICATION
                      BASED ON SENSORY TECHNIQUES
INTRODUCTION

       This procedure is designed to assist local agencies in source verification of
identified odor problems.  It describes the proper use of two sensory techniques —
one using a Barnebey-Cheney Model 1-3 Scentometer, the other employing an odor
judgment panel trained to evaluate an odorized environment in terms of memorized
reference standards.  As implied below,  the choice of techniques for use in a par-
ticular case depends upon the extent of information desired.

       An odor judgment panel can be used to obtain extensive information about
the quality and areal extent of odors as they vary with time.  This information
enables verification of specific sources of odors and provides detailed documen-
tation of chronic situations in test areas.  The size  of an odor panel depends on
the size of a test area.  In most  cases, one panelist per city block is essential to
provide adequate coverage.  Therefore, a considerable number of panelists are
required if the test area is large.

       A scentometer can be used to measure the intensity of ambient odors in
relation to the four ranges of dilution to threshold.  To determine the correct
range requires a minimum time  period of about one minute.  When odors are
strong and constant, scentometers can be used to obtain information similar to
odor judgment panels, but when  low intensity and transient odors are encountered,
the scentometer is more applicable for measuring maximum, rather than average,
intensities.  With strong and constant odors,  one scentometer may be  adequate to
cover a square mile or more, but with low intensity and transient odors, one
scentometer may be adequate  to  cover only a few city blocks .
WHEN TO USE THE SCENTOMETER

       The scentometer is best suited for use in routine surveillance of chronic
situations. It should be used to determine if odors can be detected at or above 7
dilutions to threshold and,  thereby, to indicate the locations of possible odor
problems.

       The scentometer can be used to assist a trained observer to verify the
source of an identified odor problem. Specifically, it can be used:

       (1)     To provide a measure of odor intensity at a particular loca-
              tion at a particular time.
                                      -41-

-------
       (2)     To establish a pattern of peak odor intensities while system-
              atically traversing the test area in an automobile, which,
              when combined with a consideration of the existing meteoro-
              logical conditions, may pinpoint the source of the odor.

       The scentometer can also serve as an odor free air chamber to refresh the
trained observer whose ability to continuously sense the odor under investigation
may otherwise be lessened due to fatigue.
WHEN TO USE AN ODOR JUDGMENT PANEL

       An odor judgment panel should be used to verify the source of an identified
odor problem if such verification cannot be established by a trained observer alone
or by a trained observer using a scentometer or equivalent dilution device.   For
source verification, an odor judgment panel can be used:

       (1)     To establish patterns of mean odor intensities and percent-
              ages of time odor was detected from concurrent evaluations
              at points throughout the test area.

       (2)     To judge the odor under investigation when odors of different
              qualities are encountered in the test area.

       Such uses are possible only after lengthy selection and training processes
necessary to ensure that the panelists can accurately relate to  the quality and
range of intensities expected to be encountered in the test area.
THE SCENTOMETER

       The scentometer (Figure 2) has been described in the literature and used
by at least twelve local air quality agencies throughout the United States.  Most of
the descriptions have focused on the physical characteristics of the device and the
principles of operation.  Emphasis in this procedure is based on experience gained
from actual use.

Preparation for Field Use

       Before going into the field, the  scentometer should be checked for  proper
function as follows:  Tapes must be placed over the four dilution orifices in such
a way that they can be  pulled clear of the orifices and replaced repeatedly.  It
should be determined that odors are effectively absorbed by the charcoal beds .
If necessary, fresh charcoal should be installed. Before each use, the scentometer
should be shaken gently in a horizontal position to distribute the charcoal  evenly
over the  beds, thereby eliminating the possibility of channeling.
                                      -42-

-------
 Figure 2.   Barnebey-Cheney, Model 1-3 Scentometer.
0
Inches
                                  -43-

-------
       The scentometer must be examined for leakage, especially around the two
bulbs which fit to the operator's nostrils. If the bulbs are applied with pressure to
the nostrils to avoid leakage, soreness can develop during constant use in the field.
If the bulbs are placed gently against the nostrils,  leakage can result.  Before and
during measurements, the operator should check that no leakage of any type is
occurring. This is done by using the scentometer in an area of strong odor after
blocking the four orifices. No odor should be discernible.

Field Measurements

       Before field measurements are attempted, the scentometer operator must
first neutralize the effects of ambient odors by inhaling odorless air through the
charcoal beds of the scentometer while keeping the four orifices blocked.  When
this is accomplished,  he should open the orifices of the scentometer in turn until
he can identify the smallest orifice through which odor can be detected.

       It is noted that, while this technique is generally successful with strong
and constant odors, very few readings may be obtained with low intensity and
transient odors. Under the latter conditions, it is advantageous to use the scent-
ometer while driving through a community. The application of this technique by
a mobile operator is fairly simple and considerably more effective.

       If odor is encountered in a community during routine surveillance, the in-
tensity should be measured with the scentometer.  Intensities detected at or above
7 dilutions to threshold would indicate the location of a possible odor problem.  Be-
fore attempting measurements, the operator should relax and breathe odor free
air.  This can be done by  using the scentometer as an odor free chamber.  How-
ever, it is more desirable to drive outside the affected area, since it is difficult
for the operator to relax with the scentometer bulbs pressed against the nostrils.

       When  the operator is suitably refreshed, the car is driven through the
affected area. Throughout this drive the operator breathes through the scento-
meter with a  selected orifice open. The route then may be retraced with a
different orifice uncovered in order to further define the odor intensity.  Each
time the route is traversed, the operator calls out the points at which negative
readings change to positive and vice versa.  These points should be plotted on a
map of the area  or recorded on a form such as the "Scentometer Log Sheet" pro-
vided at the end  of this procedure.  It is possible to have four operators and a
driver traverse  the area in one car. With a different orifice open on each scent-
ometer, a reading for any odor in the area can be quickly obtained.

       This method, while more effective than scentometer readings taken at a
fixed point, entails some problems.  The automobile must be well ventilated and
maneuverable.   There must be two to five people in each car. If there are less
than five people  in a car,  the success of the technique depends upon the constancy
                                      -44-

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of the odor, since two or more trips through the area would be required to obtain
readings through all of the orifices.

       During times when scentometer measurements are performed for prolonged
periods, some operators have reported discomfort to their nostrils or have exper-
ienced difficulty in continually drawing air through the scentometer by action of
their lungs .  To avoid this, a small air pump can be used to draw the required
dilution of ambient air through the scentometer, thereby distributing the diluted
sample under positive pressure through a face mask to the operator.  The  most
satisfactory system appears to be dependent solely on the individual operator's
preference.
THE ODOR JUDGMENT PANEL

       If a local agency wishes to perform odor judgment panel evaluations, panel
members could be recruited from among the agency employees.  This approach
could reduce the urgency of preliminary activities and lower costs considerably,
since panelist selection and training could be conducted at leisure at the agency
facilities.  It must be considered, however, that the results of evaluations by
agency employees could be criticized as being biased against the  source under
investigation.

       Regardless of this possibility,  certain preliminary activities must be
undertaken each time an odor judgment panel is to be used.  These activities in-
clude determination of the size of the panel required, location of  suitable stations
(points in the test area at which panelists would be placed), location of a panel
headquarters (if the agency facilities cannot be used),  and preparation for trans-
porting the panelists between the headquarters and the test area.

Preliminary Activities

       The community in which an odor judgment panel is to be used should be
visited to determine the areal extent of the odor to be investigated.   It should be
initially planned to provide one panelist for each city block affected by the odor.
If the test area is very large,  the size of the panel must be determined by budget-
ary constraints.  It is recommended that a minimum of twelve  panelists be  used
for source verification in any case where public nuisance law is applicable.

       The stations should be located in a  systematic manner so  that panel  mem-
bers are roughly equally spaced, with intervening distances not exceeding one
city block (approximately 100 yards).  Local odor interferences such as caused
by automotive service garages,  bakeries, or heavily traveled roadways should be
avoided when selecting stations.  Large scale maps of the test  area  should be used
                                      -45-

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to plot all stations. Such maps should be sketched if none are available from com -
mercial or governmental sources .

       In addition to selecting stations, convenient locations for performing panel
calibration tests must be found. These locations must be immediately downwind
from an odor source, at places where the presence of large panel groups will not
cause much disturbance in the neighborhood. Public parking lots, particularly for
municipal golf courses and parks, work well.

       The headquarters, which is the site used for testing, screening, training,
and assembling, should be located close to the test area.  The shorter the distance
between the locations,  the less the expense and proportion of daily schedule consumed
in travel. However, one problem with having a headquarters close  to the site is the
possibility of leakage of information to the source under investigation.  Thus, depend-
ing upon secrecy requirements, it may be necessary to locate several miles away
from the site.  Once in the test area, the presence of an  odor panel is quickly noticed
not only by residents, but possibly by employees of the facilities under investigation.
Thus,  to minimize the number of interruptions from curious outsiders and  to further
reduce the possibility of  leakage of information, it may be desirable to use the panel
for single days only or for two or more randomly chosen days.

       Transportation of the panelists to the test area can be by either cars or a bus.
If a bus is used, all panelists may be transported together and only one local agency
representative  is required to serve as driver.  However, a significant amount of
maneuvering is required in this work, and buses are not readily maneuverable.
Cars are more maneuverable but, as the entire panel cannot be  transported in one
car, additional drivers are required.  Cars are preferable as long as the area is
known and several drivers are available, while a bus is preferable to a convoy of
cars in an unfamiliar area.

       To ensure proper selection, training, and deployment of panelists,  one
agency representative  should be assigned to work with a maximum of six panelists.
If such representatives would serve as drivers, the requirement for additional
drivers is easily satisfied.  Nine passenger station wagons provide  an ideal com-
promise between buses and cars.  With vehicles of this capacity, six panelists
and their assigned agency representative can be transported together.

Recruiting Potential Panelists

       If sufficient agency employees are not available, candidates for odor panel
work must be recruited from other sources. If an odor panel is required for short
periods of one week or less, college students or temporarily unemployed people
are usually available, but for longer periods or for continuing use at regular inter-
vals,  housewives are the most available group.  It may be convenient to assign the
task of recruiting potential panelists to  an employment agency or professional
survey firm.

                                      -46-

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Initial Selection of Panelists

       After sufficient candidates have been recruited, the screening of potential
panelists should be undertaken.  Such screening is intended to exclude individuals
with particularly insensitive or irrational responses to odors.  Series of triangle
tests are used initially to screen potential panelists.  This method is quick, easy,
and inexpensive to perform.  The necessary equipment consists of a supply of
2-ounce paper cups, water, and odorous food extracts such as vanilla and winter-
green.  The prospective panel members are given three cups to sniff and are
instructed to specify the cup with the different odor.  The three  cups presented
to the panelists may be  one of the three following combinations:

       (1)     Two with the same odor, one with a different odor.
       (2)     Two with water (no odor), one with an odor.
       (3)     Two with the same odor, one with water (no odor).

       It is best to begin this test using strongly scented samples  detectable to
everyone.  The concentration of extract should be gradually decreased in water
toward threshold levels.  If the tests are conducted over several hours,  breaks
should be taken at regular intervals  to avoid sensory fatigue. The test room
should be well ventilated and odor free.  Use of an activated carbon room puri -
fier unit, such as the Barnebey-Cheney Model ABB (4,000 cfm) or  Model ADB
(10,000 cfm), may be necessary to ensure an absence  of ambient odors.

       After each test involving all panelists, the scores should be reviewed to
ascertain the percentage of correct answers.  A range of correct  answers  should
be chosen as a target, say 50% to 75%.  If, for most prospective panelists, the
actual percentage is outside this range, the concentration of odorants must be
readjusted. When 6 to 9 tests within the chosen range of correct answers have
been completed, potential panelists should be accepted or rejected on the basis
of their scores. An acceptable range of plus and minus two correct answers from
the mean of the group is recommended.

Final Selection of Panelists

       After the preliminary screening by triangle testing, training with reference
standards is begun.  A stable, non-toxic standard(s) should be chosen that  closely
matches the odor(s) to be encountered in the test area. Using various concentra-
tions of this standard, the remaining candidates (now called "panelists") are trained
to recognize the strengths of the odor with which they will be concerned. Any one
of a variety of standards may be utilized. In a study of solvent emissions, for
example, a methyl chloroform series may be used for degreasing  process  odors,
a turpentine series for thinner odors, or an amyl acetate series for lacquer solvent
odors.  A panel recruited to observe rendering plant odors can be trained with
ethanolamines.  For refinery odors, reference standard solutions of tertiary
dodecyl mercaptan are suitable.

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       If the affected area is close to an industrial complex in which a number of
chemical plants produce similar products, selection of stable, non-toxic reference
standards for each odor quality encountered is virtually impossible. In such cir-
cumstances, standards representing each odor quality may be used for identification
purposes; however, a single standard, such as 1-butanol,  should be used for inten-
sity training.

       The reference standard is dissolved in varying concentrations in an odor-
less  solvent and numbered according to strengths.  The number of strengths in a
series may vary from 4 to 12 depending upon the range of odor intensities expected
to be encountered and the  ability of the trained nose to differentiate between the
strengths  of adjacent  solutions.  As exemplified in Table 10, if the number of
strengths  in a series  is limited to  four, each solution might be four times more
concentrated than the previous solution.
Table 10.  Concentration of reference standard in odorless solvent used to simu-
late four strengths of the odor expected to be encountered in the test area.	
Odor Intensity           Concentration in Solvent
   Rating	(milliliters/liter)	Layman Assessment
      1                          0.125                        slight
      2                          0.5                           moderate
      3                          2                             strong
      4                          8                             very strong
      The reference standards should be mixed ahead of time,  although the undi-
luted odorant and solvent should be brought to the panel headquarters in case
different or additional concentrations must be prepared.

      Again, the test room should be well ventilated and odor free.  The standards
may be presented in capped, 4-ounce, polyethylene bottles with a polyethylene in-
sert to minimize the possibility of leakage caused by shaking.  Even with these
bottles, however, napkins or paper towels should be kept on hand in case of spills.
Dark bottles are preferred to prevent the panelists from noticing any color the
diluted odorant may possess.

      Panelists should be instructed to shake the bottle gently once or twice,
remove the cap, and squeeze the sides once as they hold the bottle under the nose.
After a period of memorizing the different strengths and a few  breaks to avoid
fatigue, they should be encouraged to test themselves by removing a standard
from the series at random and attempting to judge its intensity.  At  this time,
the panel instructors should circulate about the room and test the panelists with
unmarked samples. Prior to the training, a few sets of standards should be pre-
                                      -48-

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pared on which the numbers are not clearly shown but are hidden on labels attached
to the bottom of the bottles.  All panelists should be asked to sniff one of these
samples and judge the strength of the odor.  Panelists' scores  should be recorded
and combined with the results of field calibration tests (described below) before
the panel selection is finalized.

Instructions to Panelists

       When the results of the reference standard tests indicate that the panelists
are ready to go into  the field, briefing on recording procedure is necessary.  In
addition, the following points should be stressed to them:

       (1)     All evaluation materials, including clipboards,  rating sheets,
              and pencils, will be supplied by the local agency.

       (2)     A watch with a second hand and a large, easily read face is
              to be  worn by each panelist.

       (3)     Appropriate clothing,  including hats, coats, and gloves,  is
              to be  worn by each panelist if unfavorable weather is to be
              expected.  (The work involves standing on streets .  Cold
              wind and dampness, which may be present, can affect the
              efficiency of the unprepared panelist.)

       (4)     Smoking is forbidden.

       (5)     Perfume and other strongly scented toiletries are not to be
              worn.

       (6)     Gum chewing and similar diversions by panelists are dis-
              couraged .

       (7)     The recognition of transient odors requires constant atten-
              tion.  Panelists must be as alert  to the  task as possible.

       (8)     Panelists must rate odors encountered in the test area in
              accordance with the  strengths of  the reference standards
              memorized in the test room .

       All values  should be recorded on an "Odor Intensity Rating Sheet, " an
example of which is  included at the end of this procedure .  How frequently values
should be recorded depends upon the frequency, duration,  constancy, and inten-
sity of the odors.  Normally, panelists should be asked to record the highest
intensity present during each minute.  The time recorded should reflect the end
                                      -49-

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of each minute. For example: "Time:  10:40 a.m.,  Rating:  1" means that 1 was
the highest intensity perceived between 10:39 a.m. and 10:40 a.m.  Similarly,
"Time: 3:45 p.m.,  Rating: 0" means that no odor was detected between 3:44 p.m,
and 3:45 p .m.

       Determining the "quality" of the odor perceived is often a problem, i.e.,
whether or not an odor encountered is that which bothers test area residents.
Panelists should be instructed as follows:

       (1)     If the panelist is not sure whether the  odor is like that used
              during training, he must record the odor intensity as accu-
              rately as possible and make a notation regarding odor quality.

       (2)     Only if the panelist is  certain that the  odor is foreign, i.e.,
              if he can positively identify it as coming from some source
              other than that under study, should he record a zero. Even
              in such a case he should describe  the quality of the odor per-
              ceived .

Calibration Tests

       Uniformity of response among panelists must be monitored during both
the training and field phases of the work.  This is done by conducting field cali-
bration tests, i.e.,  by having all panelists record data at one  site. There should
be a distance of at least two yards between panelists  to ensure independent record-
ings .  Any panelists who consistently record values significantly different from
those of the majority should be rejected. Calibration tests actually serve two
purposes.  In addition to indicating the uniformity of  the panelists' responses and,
consequently, the reliability of the field values, they provide additional training
and experience in the field.

Work Schedule

       To get all panelists to work as a unit and, thereby, avoid those delays
which  result in reduced evaluation time  in the test area, a rigid adherence to
schedule is required.  It has been observed that about one hour is the optimum
time to leave a panelist on station.  The panelists* concentration capabilities
deteriorate significantly after working in solitude in one place for an hour.  The
type of schedule shown in Table 11 has been found to  work well.

       Panel calibration tests can be incorporated into the schedule by reducing
the 1 hour and 10 minute periods allocated to panelists at individual stations.
Normally,  one 10 minute calibration test in the morning and another of equal
duration in the afternoon is sufficient to monitor uniformity of response.
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Table 11.   Recommended work schedule.
Time
9:30 a.m
9:50 a.m
10:10 a.m
11:20 a.m
11:40 a.m
12:50 p.m
1:10 p.m
2:10 p.m
2:20 p.m
2:40 p.m
3:50 p.m
4:10 p.m
5:20 p.m
5:40 p.m




Period
. - 9:50 a.m.
. - 10:10 a.m.
. - 11:20 a.m.
. - 11:40 a.m.
. - 12:50 p.m .
. - 1:10 p.m.
. - 2:10 p.m.
. - 2:20 p.m.
. - 2:40 p.m.
. - 3:50 p.m.
. - 4:10 p.m.
. - 5:20 p.m.
. - 5:40 p.m.
. - 5:45 p.m.
Total time
Total time
Total time
Total time
Activity
Arrival of panelists , ready for departure
Travel to site, position panelists at first stations
Panelists record at first stations
Transfer to second stations
Panelists record at second stations
Return to headquarters
Lunch, restroom, etc.
Short discussion, ready for departure
Travel to site, position panelists at first stations
Panelists record at first stations
Transfer to second stations
Panelists record at second stations
Return to headquarters
Dismissal of panelists
evaluating odors 4-3/4 hours
working 7-1/4 hours
on break 1 hour
per day 8-1/4 hours
General Observations

       Based on the results of the use of odor judgment panels during the national
survey of the odor problem and the study of the social and economic impact of odors,
some observations  are offered for local agency consideration.

       (1)    Some panelists become very anxious during calibration
              runs, whereas they are relaxed when alone during actual
              field measurements.

       (2)    Some panelists have difficulty in concentrating if left
              alone for long periods and start talking to passers-by,
              listening to radios, etc.  Some discipline is required.

       (3)    Panelists should be instructed to try to avoid direct ques-
              tions from passers-by and,  if necessary, should indicate
              that  they are surveying cars or other objects unrelated to
              odors.  Some are able to be convincing without difficulty,
              while others may have trouble.

       (4)    Panelists are sometimes questioned by police. It is there-
              fore necessary to inform the local police of the field schedule
              before the  evaluations take place.
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SOURCE VERIFICATION

       The data recorded by each panelist should be in the form of a series of odor
intensity ratings against time, with one intensity value recorded each minute dur-
ing a period of evaluation. Such information should be obtained for each station in
the test area. From this, the distribution of odor over the portion of the test area
covered by the odor judgment panel can be estimated by local agency personnel.

       After each evaluation,  the intensity values recorded by each panelist should
be averaged separately. Psychologists generally prefer the use of median values
as a measure of central tendency of data generated by human evaluation. But, be-
cause of the highly skewed distribution of odor intensity ratings that are typically
obtained (particularly when odors are transient, many "no odor" ratings are listed),
the mean values recorded at each station are recommended for source verification
purposes.  Thus, averaging is performed by simply adding the intensity values
recorded and dividing the  total by the number of observations.

       In addition, the percentage of time that odor was detected by each panelist
should be determined.  This permits an estimation of odor distribution based on
whether or not odor was perceived and depends only upon  the panelists' judgment of
odor quality in relation to the reference standards. The percentage is determined
by counting the number of times odor was perceived, dividing the total by the num-
ber of observations, and multiplying this answer by 100.

       During the preliminary activities leading to the use of an odor judgment
panel, all stations should  have been plotted on a map of the test area.  Now, for
each station the mean odor intensity should be noted on the map as in Figure 3 and
the percentage of time that odor was detected should be noted on a duplicate map
as in  Figure 4.  After this, isopleths — lines of equal mean odor intensity or equal
percentage of time that odor was detected — should be constructed.  By construct-
ing such isopleths, studying recorded wind data for the periods of panel evaluation,
and noting the topographical features of the test area, the odor source usually can
be verified with confidence and patterns of odor distribution within the test area
can be established.

       During the course  of an investigation of a particular test area,  several
odor judgment panel evaluations may be completed.  (Based on the recommended
work schedule, a total of four  evaluations per day would be completed.)  The data
recorded should be summarized separately for each evaluation so that changes in
odor distribution due to variations in wind, other meteorological conditions, and
even source emissions can be  documented.  A form entitled "Odor Intensity
Rating Summary Sheet" is provided at the conclusion of this procedure for the
convenience of local agency personnel in preparing the summary information.
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OTHER DILUTION DEVICES FOR SOURCE VERIFICATION

       It is noted  that dilution devices other than the scentometer have become
available since the performance of the field activities that led to the development
of this procedure.  It is possible that these devices also can be used to obtain
measurements of ambient odor intensity for purposes of source verification.
                                       -53-

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Figure 3.   Example of isopleths representing
mean odor intensities  recorded by odor judg-
ment panelists stationed in a test area at the
points indicated.
Figure 4.  Example of isopleths representing
percentages of time odor was detected by odor
judgment panelists stationed in a test area at
the points indicated.

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File No .
Community(s) Affected




Operator 1	
Operator 2
 SCENTOMETER LOG SHEET




	   Odor Source(s)




	   Operator 3
                                                                Date
Operator 4
Points at Which
Readings Were Taken
Street
Traveled





















Cross Street
or Landmark





















Operator No . and D/T Setting
Opr:
D/T:
Opr:
D/T:
Opr:
D/T:
Opr:
D/T:
Time and Reading (+ or - )
T





















R





















T





















R





















T





















R





















T





















R





















Points at Which
Readings Were Taken
Street
Traveled





















Cross Street
or Landmark





















Operator No . and D/T Setting
Opr:
D/T:
Opr:
D/T:
Opr:
D/T:
Opr:
D/T:
Time and Reading {+ or -)
T





















R





















T





















R





















T





















R





















l





















R






















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ODOR INTENSITY RATING SHEET
NAME DATE
LOCATION

TIME









































RATING








































COMMENTS








































LOCATION

TIME









































RATING








































COMMENTS









































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ODOR INTENSITY RATING SUMMARY SHEET
Panelist
Location
(Station)




















Percent Time Detected and Mean Odor Intensity
Date :
AM
%




















M




















PM
%




















M




















Date:
AM
O7
/O




















M




















PM
%




















M




















Date:
AM
O7
/O




















M




















PM
%




















M




















Date:
AM
%




















M




















PM
%




















M




















Date:
AM
%




















M




















PM
H7
/O




















M





















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                 PROCEDURE FOR PROBLEM ASSESSMENT
INTRODUCTION

       Tentative methods of problem assessment are contained in the final re-
port,  "A Study of the Social and Economic Impact of Odors, Phase II."  The
principal economic effect of odors can be measured in terms of property value
differentials, especially residential property value differentials.  A description
of the data required and analysis employed in this aspect of problem assessment
is presented in Chapter VI.  An effects determination questionnaire was developed
to determine how residents feel odors have affected themselves, their families,
and their properties.  Property values, living patterns, and health symptoms are
covered.  A description of the questionnaire  and its use is included in Chapter VII.
WHEN TO ATTEMPT PROBLEM ASSESSMENT

       The most common effect of odors — annoyance — is readily measured
using the procedure for problem identification.  Based on results of the above
mentioned study, economic and other social effects are measurable only in an
extremely chronic  situation.  Such a situation may be presumed to exist if more
than 50 percent of the test area residents interviewed, using the problem identi-
fication questionnaire, state they have been bothered "Very much" by odors in
their community (question 10, response 1).
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                                APPENDIX
ESTIMATES OF COSTS INCURRED FROM USING PROCEDURES

       Estimates of the costs of services and materials necessary for problem
identification and source verification are listed below by task and cost category.
Where possible, these estimates are based on 1972 prices averaged for the
United States as a whole.  Consequently, they may differ somewhat from actual
costs incurred in a particular metropolitan area.

       Local agency labor requirements are listed in terms of mandays only.
Daily rates must be applied by agency officials .

Public Attitude Survey Costs

       The estimates given in this section represent the costs  of conducting iden-
tical public attitude surveys in one test area and one control area.
                                                     Estimated Cost
           Task/Category
       Unit
   Total
Task I: Select Test and Control Areas
       Supervisory time
       Clerical time
       Purchase of U. S. Census of
         Population and Housing Census
         Tract Reports (first survey
         only)
       Purchase of census tract maps
         for agency's jurisdiction (first
         survey only; necessary  only if
         maps are not included in U. S.
         Census of Population and Hous -
         ing Census Tract Reports
1 manday/area
1 manday/area
$5
$15
2 mandays
2 mandays
$5
Task II-A: Select Telephone Numbers for Samples
       Clerical time                      1 manday/area
       Rental of street address telephone
         directories (for usual six month
         period)                          $50/directory/area
$15


2 mandays


$100
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                                                     Estimated Cost
           Task/Category
       Unit
  Total
Task II-B:  Conduct Interviews
      Supervisory time (first survey
         only)
      Clerical time:
              Training (first survey
                only)
              Interviewing
      Reproduction of questionnaires
       Telephone toll charges (if appli-
         cable)
1 manday
2 mandays
2 mandays/area
120 questionnaires @
  $0.20/question-
  naire
60 calls/area @
  $0.25/call
Task II (Alternative):  Select Sample and Conduct Interviews
       Reproduction of questionnaires
       Professional survey firm charges:
              Select sample
              Conduct interviews

              Telephone toll charges
                (if applicable)

Task III: Edit Questionnaires
       Clerical time

Task IV: Code Questionnaires
       Clerical time

Task V:  Tabulate Responses
       Clerical time
       Reproduction of tabulation forms
Task VI: Evaluate Survey Results
       Supervisory time
       Clerical time
120 questionnaires @
  $0.20/question-
  naire

$50/sample/area
60 interviews/area @
  $3.50/interview
60 calls/area @
  $0.25/call
0.5 manday/area
0.5 manday/area
2 mandays/area
120 forms @ $0.15/
  form
1 manday
1 manday
1 manday
2 mandays
4 mandays
$24

$30
$24

$100

$420

$30


1 manday


1 manday


4 mandays

$18
1 manday
1 manday
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                                                    Estimated Cost
           Task/Category                        Unit               Total

Estimated Total Costs (Task II Performed By Agency)
       First set of surveys:
              Supervisory time                                    4 mandays
              Clerical time                                      17 mandays
              Services and materials                             $192
       Each additional set of surveys:
              Supervisory time                                    3 mandays
              Clerical time                                      15 mandays
              Services and materials                             $172

Estimated Total Costs (Task II Performed By Professional Survey Firm)
       First set of surveys:
              Supervisory time                                   3 mandays
              Clerical time                                      9 mandays
              Services and materials                             $612
       Each additional set of surveys:
              Supervisory time                                   3 mandays
              Clerical time                                      9 mandays
              Services and materials                             $592
Scentometer Measurement Costs

       The following estimates represent the use of a scentometer in routine
surveillance for one day.
                                                     Estimated Cost
           Task/Category                        Unit               Total

Task I: Prepare for Field Use
       Purchase of Barnebey-Cheney
         Model 1-3 Scentometer
         (first use only)                  $85                    $85

Task II:  Conduct Field Measurements
       Technician time:
              Scentometer operator       1 manday              1 manday
              Driver                     1 manday              1 manday
       Agency vehicle use                 200 miles @ $0.12/
                                           mile                 $24
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                                                     Estimated Cost
           Task/Category
       Unit
   Total
Task III: Evaluate Measurements
       Supervisory time
0.5 manday
0.5 manday
Estimated Total Costs
       First use:
              Supervisory time
              Technician  time
              Materials
       Each additional use:
              Supervisory time
              Technician  time
              Materials
                       0.5 manday
                       2 mandays
                       $109

                       0.5 manday
                       2 manday s
                       $24
Odor Judgment Panel Costs

       The estimates provided below include the costs of selecting,  training,  and
using twelve odor judgment panelists for source verification in one test area.
           Task/Category
                                                     Estimated Cost
        Unit
   Total
Task I:  Preliminary Activities^
       Supervisory time
       Agency vehicle use
1 manday               1 manday
100 miles @ $0.12/
  mile                  $12
Task II:  Screen Candidates
       Supervisory time
       Technician time
       Rental of odor free room
       Purchase of Barnebey-Cheney
         Model ABB Activated Carbon
         Room Purifier Unit (first
         use only)
       Purchase of food extracts, mix-
         ing bottles, and cups
       Payments to candidates (success-
         ful candidates only)
1 manday               1 manday
1 manday               1 manday
$25/day                 $25
$480                    $480

$10                     $10
12 candidates @ $20/
  candidate             $240
                                    -64-

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                                                     Estimated Cost
           Task/Category
       Unit
   Total
Task III: Train Panelists
       Supervisory tirre
       Technician time
       Rental of odor free room
       Purchase of odorant, solvents,
         mixing bottles, plastic bottles
       Payments to panelists
Task IV: Perform Field Evaluations
       Supervisory time
       Technician time
       Rental of station wagons
       Reproduction of rating forms

       Payments to panelists


Task V:  Summarize Field Evaluations
       Supervisory time
       Technician time
1 manday
1 manday
$25/day

$50
12 panelists @ $20/
  panelist
1 manday
1 manday
2 station wagons @
  $17/day plus
  $0.17/mile
  (200 miles)
80 forms @ $0.05/
  form
12 panelists @ $20/
  panelist
1 manday
2 mandays
1 manday
1 manday
$25

$50

$240
1 manday
1 manday
$68

$4

$240
1 manday
2 mandays
Estimated Panel Preparation Costs
       First panel:
              Supervisory time
              Technician time
              Services and materials
       Each additional panel:
              Supervisory time
              Technician time
              Services and materials

Estimated (Daily) Field Evaluation Costs
       Supervisory time
       Technician time
       Services and materials
                       3 mandays
                       2 mandays
                       $1,082

                       3 mandays
                       2 mandays
                       $602
                       2 mandays
                       3 mandays
                       $312
                                     -65-

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SUGGESTED REFERENCES

Census Tract Data

U.S. Bureau of the Census. U.S. Censuses of Population and Housing;  1970.
       Census Tracts.  Washington,  D.C.:  U. S. Government Printing Off ice,
       1972.

       Census tract data for use by each local agency are recorded in one
       of a series of reports under the above title.  The Bureau of the
       Census should be contacted to determine the report number for the
       agency's jurisdiction.  Census tract maps are included with these
       reports.

Odor Judgment Panel Information

Wittes, Janet, and Turk, Amos.  "The Selection of Judges for Odor Discrimina-
       tion Panels," Correlation of Subjective-Objective Methods in the Study
       of Odors and Taste. Special Technical Publication No. 440, American
       Society for Testing and Materials,  1968.

       This comprehensive discussion of the use and analysis of screening
       tests was co-authored by Amos Turk, the originator of the odor
       judgment panel technique.

Scentometer Information

Huey, Norman A., Broering,  Louis C., Jutze, George A., andGruber, Charles
       W.  "Objective Odor Pollution Control Investigations," Journal of the Air
       Pollution Control Association,  X, No. 6 (December, 1960), 441-446.

       This article, by the developers of the scentometer, provides  the most
       comprehensive description available of the physical characteristics of
       the device and the principles of operation.

Statistical Tables

Mathematical Tables From Handbook of Chemistry and Physics. Cleveland,
       Ohio: Chemical Rubber Publishing Company, any edition.

       Tables of square roots, needed for Odor Problem Identification (see
       page 33) and other values are included in this mathematical section
       of the widely used handbook.
                                    -66-

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The Rand Corporation.  A Million Random Digits With 100,000 Normal Deviates
       Glencoe, Illinois:  The Free Press, 1955.

       This book contains an extensive listing of 5-digit random numbers.
       These numbers can be used to select an unbiased sample of test area
       and control area telephone numbers from a street address telephone
       directory (see page 10, "Obtaining a Sample").  The first two digits of
       any of the 5-digit numbers would provide a starting point for  areas
       having zero to 99 listed telephones.  Similarly,  the first three digits
       would provide a starting point for  areas having zero to 999 listed tele-
       phones .
                                     -67-

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