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CORRESPONDENCE - 75D
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CORRESPONDENCE - 75D
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6/6/2019 12:19:02 PM
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6/4/2019 2:59:49 PM
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City Clerk
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75D
Date
6/4/2019
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Environmental Chambers", (CDPH, 2017), or other equivalent chemical emission rate <br />testing methods. Most manufacturers of building furnishings sold in the United States <br />conduct chemical emission rate tests using ANSI/BIFMA M7.1 Standard Test Method for <br />Determining VOC Emissions (BIFMA, 2018), or other equivalent chemical emission rate <br />testing methods. <br />CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a <br />material or furnishing does not create indoor chemical concentrations in excess of the <br />maximum concentrations permitted by their certification. For instance, the CDPH emission <br />rate testing requires that the measured emission rates when input into an office, school, or <br />residential model do not exceed one-half of the OEHHA Chronic Exposure Guidelines <br />(OEHHA, 2017b) for the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of <br />the CDPH test method (CDPH, 2017). These certifications themselves do not provide the <br />actual area -specific formaldehyde emission rate (i.e., µg/m2-h) of the product, but rather <br />provide data that the formaldehyde emission rates do not exceed the maximum rate allowed <br />for the certification. Thus for example, the data for a certification of a specific type of <br />flooring may be used to calculate that the area -specific emission rate of formaldehyde is <br />less than 31 µg/mz-h, but not the actual measured specific emission rate, which may be 3, <br />18, or 30 µg/m2-h. These area -specific emission rates determined from the product <br />certifications of CDPH, BIFA, and other certification programs can be used as an initial <br />estimate of the formaldehyde emission rate. <br />If the actual area -specific emission rates of a building material or furnishing is needed (i.e. <br />the initial emission rates estimates from the product certifications are higher than desired), <br />then that data can be acquired by requesting from the manufacturer the complete chemical <br />emission rate test report. For instance if the complete CDPH emission test report is <br />requested for a CDHP certified product, that report will provide the actual area -specific <br />emission rates for not only the 35 specific VOCs, including formaldehyde, listed in Table <br />4-1 of the CDPH test method (CDPH, 2017), but also all of the cancer and <br />reproductive/developmental chemicals listed in the California Proposition 65 Safe Harbor <br />Levels (OEHHA, 201.7a), all of the toxic air contaminants (TACs) in the California Air <br />Resources Board Toxic Air Contamination List (CARB, 2011), and the 10 chemicals with <br />the greatest emission rates. <br />7 <br />
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