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could be used without causing indoor formaldehyde concentrations that result in CEQA <br />cancer risks that substantially exceed 10 per million for occupants with continuous <br />occupancy. <br />If CARB Phase 2 compliant composite wood products are utilized in construction, then the <br />resulting indoor formaldehyde concentrations should be determined in the design phase <br />using the specific amounts of each type of composite wood product, the specific <br />formaldehyde emission rates, and the volume and outdoor air ventilation rates of the indoor <br />spaces, and all feasible mitigation measures employed to reduce this impact (e.g. use less <br />formaldehyde containing composite wood products and/or incorporate mechanical systems <br />capable of higher outdoor air ventilation rates). See the procedure described earlier (i.e., <br />Pre -Construction Building Material/Fumishing Formaldehyde Emissions Assessment) to <br />insure that the materials selected achieve acceptable cancer risks from material off gassing <br />of formaldehyde. <br />Alternatively, and perhaps a simpler approach, is to use only composite wood products (e.g. <br />hardwood plywood, medium density fiberboard, particleboard) for all interior finish <br />systems that are made with CARB approved no -added formaldehyde (NAF) resins or ultra - <br />low emitting formaldehyde (ULEF) resins. These products are now readily available and <br />many other projects such as the AC by Marriott Hotel — West San Jose Project and 2525 <br />North Main Street, Santa Ana have entered into settlement agreements stipulating the use <br />of composite wood materials only containing NAF or ULEF resins. <br />19 of 19 <br />