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Kimley)>)Horn <br />To: Ali Pezeshkpour, City of Santa Ana <br />From: Ace Malisos <br />Kimley-Horn and Associates, Inc. <br />Date: June 4, 2019 <br />Subject: MainPlace— Response to Comments by Francis J. Offermann, PE, CIH Regarding <br />Indoor Air Quality <br />Kimley-Horn has reviewed the May 31, 2019 memorandum prepared by Francis J. Offermann, PE, CIH <br />on indoor air quality associated with the MainPlace Project ("Project"), located in Santa Ana, <br />California. For the reasons set forth below, there is no merit to the claim that the Project would create <br />a significant health risk by exposing future residents of the Project to formaldehyde. <br />Health Risk from Indoor Air Concentrations of Formaldehyde <br />Potential formaldehyde emissions from building materials are the subject of extensive regulation at <br />both the federal and state level. On June 1, 2018, new provisions of the US Toxic Substances Control <br />Act (TSCA) Title VI were enacted, requiring composite wood products sold, supplied, offered for sale, <br />manufactured, or imported into the US to meet new emissions standards for formaldehyde in order <br />to reduce exposures to formaldehyde and avoid adverse health effects. These new emission limits <br />include: <br />• Hardwood plywood: 0.05 parts per million <br />• Particleboard: 0.09 ppm <br />• Thin medium -density fiberboard: 0.13 ppm <br />The California Air Resources Board (GARB) identifies that these standards will lead to a reduction in <br />statewide formaldehyde emissions of 500 tons per year and a reduced cancer risk of 40% when <br />compared to the emissions levels permitted before these limits were enacted in 2018. This project, <br />like all projects in the City, will be implemented pursuant to these formaldehyde requirements, as all <br />produced manufactured or imported into the US must meet these levels. <br />Further, according to the US National Library of Medicine's Hazardous Substances Database, <br />formaldehyde is readily biodegradable and complete degradation of formaldehyde can be <br />accomplished in less than 30 days, and formaldehyde in the air can be degraded in less than 4 days. <br />Thus, most, if not all, formaldehyde residue in furniture, fixtures, and floors can be expected to be off <br />a <br />