Correspondence - #18 - Laserfiche WebLink

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Based on his "corrected" 24.1 pg/m3 figure, Mr. Offermann claims that "the median lifetime cancer risk is still 120 per million for homes built with CARB-compliant composite wood products." This is despite the fact that the original 22.4 pg/m3 figure is based in part on sample homes that were built prior to CARB Phase 2 ATCM rules going into effect, and the "corrected" 24.1 pg/m3 utilized by Mr. Offermann has no evidentiary basis. Mr. Offermann expands on his analysis when discussing the alleged impact on the Project's future residents. He starts by stating that "residential occupants will potentially have continuous exposure (e.g., 24 hours per day, 52 weeks per year)." In other words, Mr. Offermann assumes that a Project resident will spend every hour of every day within their apartment. This is clearly an inaccurate assumption, and Mr. Offermann offers no evidence to support it, nor does he acknowledge that his assumption directly contradicts existing guidance offered by OEHHA regarding "fraction of time at home" or FAH.2 By ignoring this guidance, Mr. Offermann's continuous exposure assumptions for residential occupants are not tenable. Mr. Offermann then launches a flurry of speculation, claiming that because the Project "will be constructed with CARB Phase 2 Formaldehyde ATCM materials, and be ventilated with the minimum code required amount of outdoor air, the indoor residential formaldehyde concentrations are likely similar to those concentrations observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median of 24.1 pg/m3." Mr. Offerman cites the paper by Singer et al. in support of this statement. As explained earlier, Singer et al. concedes a lack of evidence surrounding whether low air velocities were ever a factor during the HENGH study's passive sampling of indoor formaldehyde levels, and the paper's published findings report a 18.2 ppb figure which correlates with Mr. Offermann's non -"corrected" 22.4 pg/m3 figure. The application of a 7.5% "correction" that correlates with Mr. Offermann's 24.1 pg/m3 figure is not evident in the paper by Singer et al., and Mr. Offermann's citation referencing Singer et al. is therefore questionable. Furthermore, and as also explained earlier, the HENGH study addressed by Singer et al. sampled homes that were constructed several years prior to the full rollout of CARB Phase 2 Formaldehyde emission standards. Singer et al. neither explicitly states nor infers that sample homes were built with CARB Phase 2 compliant materials, nor does it suggest that its formaldehyde findings should be interpreted in the manner that Mr. Offermann has undertaken. Therefore, Mr. Offermann's reasoning that the Project would contain similar indoor residential formaldehyde concentrations as HENGH study sample homes is both inaccurate and unfounded, and Mr. Offermann's citation referencing Singer et al. in support of this reasoning is once again questionable. Mr. Offermann speculates further when he states that the Project's indoor residential formaldehyde concentrations would be "likely similar" to concentrations observed by the HENGH study because the Project 11 will ... be ventilated with the minimum code required amount of outdoor air." Mr. Offermann demonstrates no understanding of what the "minimum code required amount of outdoor air" would be for the Project, nor does he support his claim that the Project's ventilation would be no greater than "minimum code" requirements with any evidence. Moreover, Mr. Offermann demonstrates no understanding of what ventilation the HENGH study sample homes achieved. He fails to substantiate why the Project would have any similarity in ventilation to the 70 detached single-family homes constructed between 2011 and 2017 that were sampled as part of the HENGH study, and he fails to establish why presumably similar ventilation would even contribute to presumably similar indoor residential formaldehyde concentrations in future Project 2 Note that the OEHHA's recommended FAH value for adult receptors between 16 and 70 years of age is 0.73, or 73% of time spent at home. See OEHHA, The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, February 2015. Page 4