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APPENDIX A <br />INDOOR FORMALDEHYDE CONCENTRATIONS <br />AND THE <br />CARB FORMALDEHYDE ATCM <br />With respect to formaldehyde emissions from composite wood products, the CARB <br />ATCM regulations of formaldehyde emissions from composite wood products, do not <br />assure healthful indoor air quality. The following is the stated purpose of the CARB <br />ATCM regulation - The purpose of this airborne toxic control measure is to "reduce <br />formaldehyde emissions from composite wood products, and finished goods that contain <br />composite wood products, that are sold, offered for sale, supplied, used, or manufactured for <br />sale in California ". In other words, the CARB ATCM regulations do not "assure healthful <br />indoor air quality", but rather "reduce formaldehyde emissions from composite wood <br />products". <br />Just how much protection do the CARB ATCM regulations provide building occupants <br />from the formaldehyde emissions generated by composite wood products? Definitely <br />some, but certainly the regulations do not "assure healthful indoor air quality" when <br />CARB Phase 2 products are utilized. As shown in the Chan 2019 study of new California <br />homes, the median indoor formaldehyde concentration was of 22.4 µg/m3 (18.2 ppb), <br />which corresponds to a cancer risk of 112 per million for occupants with continuous <br />exposure, which is more than 11 times the CEQA cancer 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 <br />that 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 <br />Scenario) of the Standard Method for the Testing and Evaluation of Volatile Organic Chemical <br />Emissions for Indoor Sources Using Environmental Chambers, Version 1.1, 2017, California <br />17 of 19 <br />