Although the 1990 Clean Air Act (CAA) is a federal law, the states do much of the work to carry out the act. In the San Joaquin Valley of California, certain chemicals in air pollution known as volatile organic compounds (VOCs) declined for several years, but recently increased above the state's CAA State Implementation Plan (SIP). To address the nonattainment, the California Department of Pesticide Regulation (DPR) has undertaken an initiative to reduce VOCs in pesticide formulations using an unscientific approach.

Volatile Organic Compounds (VOCs) are usually made from petroleum and are a major component of gasoline. They are used as solvents in products such as paints, adhesives, inks and some consumer and commercial pesticide formulations. As these products dry, VOC solvents are emitted into the air. By far, most VOCs released to the atmosphere come from motor vehicle emissions. Significant amounts of VOCs are also released from biogenic sources such as evergreen forests.

VOC emissions per se do not appear to pose a significant public health risk. In some areas, however, when VOCs react with nitrogen oxides that are present in the air from fossil fuel combustion, ozone is formed near the ground. Ozone near the ground is the main component of smog. When ground-level ozone levels rise, hospitals see an increase in admissions as more people experience health effects from smog. Because VOCs contribute to ground-level ozone formation, they are regulated by the Clean Air Act and similar state laws.

CropLife America's Position:

  • Scientific data1 support ozone control strategies based on reactivity of individual VOCs rather than on total VOC emissions.
  • EPA and states should uniformly adopt VOC control strategies across all regulatory frameworks based only on relative reactivity.
  • VOCs in pesticide formulations have low relative reactivity and do not contribute significantly to ground-level ozone.
  • VOCs in pesticide formulations do not contribute significantly to nonattainment in the San Joaquin Valley or anywhere else, and should not be regulated in that capacity.

1 Russell, A, et al. (1995). Urban Ozone Control and Atmospheric Reactivity of Organic Gases. Science 269(5223): 491- 5