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I_\ U» 62101 I_1 <br />INDOOR FORMALDEHYDE CONCENTRATIONS <br />AND THE <br />GARB FORMALDEHYDE ATCM <br />With respect to formaldehyde emissions from composite wood products, the CARB ATOM <br />regulations of formaldehyde emissions from composite wood products, do not assure <br />healthful indoor air quality. The following is the stated purpose of the CARB ATCM <br />regulation - The purpose of this airborne toxic control measure is to "reduce formaldehyde <br />emissions from composite wood products, and finished goods that contain composite wood <br />products, that are sold, offered for sale, supplied, used, or manufactured for sale in <br />California". In other words, the CARB ATCM regulations do not "assure healthful indoor <br />air quality", but rather "reduce formaldehyde emissions from composite wood products". <br />Just how much protection do the CARB ATOM regulations provide building occupants <br />from the formaldehyde emissions generated by composite wood products ? Definitely some, <br />but certainly the regulations do not "assure healthful indoor air quality" when CARB Phase <br />2 products are utilized. As shown in the Chan 2019 study of new California homes, the <br />median indoor formaldehyde concentration was of 22.4 µg/m3 (18.2 ppb), which <br />corresponds to a cancer risk of 112 per million for occupants with continuous exposure, <br />which is more than 11 times the Bay Area Air Quality Management District CEQA cancer <br />risk of 10 per million. <br />Another way of looking at how much protection the CARB ATCM regulations provide <br />building occupants from the formaldehyde emissions generated by composite wood <br />products is to calculate the maximum number of square feet of composite wood product that <br />can be in a residence without exceeding the CEQA cancer risk of 10 per million for <br />occupants with continuous occupancy. <br />For this calculation I utilized the floor area (2,272 ft), the ceiling height (8.5 ft), and the <br />number of bedrooms (4) as defined in Appendix B (New Single -Family Residence Scenario) <br />of the Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor <br />17 of 19 <br />