The Air Quality Division of the Department of Environmental Quality (DEQ) of the State of Oregon has recently released a proposal for an Odor Nuisance Strategy Report. and is asking for feedback about it. This proposal is based on several parameters, the so-called "Nuisance Factors" which are the tools used by the Environmental officers to deal with odor complaints.
DEQ last updated its nuisance rules as part of a process improvement effort in 2001. At this time DEQ is proposing a strategy to implement the existing rules. The Oregon Administrative rule on nuisance (OAR 340-208-0310) (Appendix A) describes multiple factors for DEQ to consider when determining if a nuisance exists.
The Nuisance factors are the following:
- Frequency of the emission;
- Duration of the emission;
- Strength or intensity of the emissions, odors or other offending properties;
- Number of people impacted;
- The suitability of each party's use to the character of the locality in which it is conducted;
- Extent and character of the harm to complainants
- The source's ability to prevent or avoid harm.
No olfactometric technique is mentioned in this proposal, which is based just on a non-calibrated officer expert judgment.
Tellingly, nor odor units nor dynamic olfactometry are mentioned in this work either, therefore no source-oriented approach has been taken to deal with odor complaints in this State, paving the way to subject-driven complaints with no use of repeatable and reproducible techniques.
For more information please click here.
The Nuisance Odor Strategy Report was finally released. No mention of the word olfactometry appears in the whole document. We missed the chance to help to manage the odour emission in Oregon with the best available techniques. Several proposal were sent by several groups, such as the people of St Croix Sensory Inc, or the people of IDES Canada. These approaches were based on dinamic olfactometry but they were plainly dismissed.
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