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applicability and use of early -life exposure adjustments for projects subject to CEQA, it was reported that3: "The Proposed Amended Rules are separate from the CEQA significance thresholds. The SCAQMD staff is currently evaluating how to implement the Revised OEHHA Guidelines under CEQA. The SCAQMD staff will evaluate a variety of options on how to evaluate health risks under the Revised OEHHA Guidelines under CEQA. The SCAQMD staff will conduct public workshops to gather input before bringing recommendations to the Governing Board. In the interim, staff will continue to use the previous guidelines for CEQA determinations." To date, the SCAQMD, as a commenting agency, has not conducted public workshops nor developed policy relating to the application of early -life exposure adjustments utilizing the OEHHA Guidance Manual for projects prepared by other public/lead agencies subject to CEQA. As a result, it is our recommendation that health risk assessments rely upon U.S. EPA documentation when evaluating the use of early life exposure adjustment factors (Supplemental Guidance for Assessing Susceptibility from Early -Life Exposure to Carcinogens, EPA/630/R-003F) wherein adjustment factors are only considered when carcinogens act "through the mutagenic mode of action." A mutagen is a physical or chemical agent that changes genetic material, such as DNA, increasing the frequency of mutations to produce carcinogenic effects. The use of adjustment factors is recommended to account for the susceptibility of producing adverse health effects during early life stages from exposure to these mutagenic compounds. In 2006, U.S. EPA published a memorandum which provides guidance regarding the preparation of health risk assessments should carcinogenic compounds elicit a mutagenic mode of action (USEPA, 20064). As presented in the technical memorandum, numerous compounds were identified as having a mutagenic mode of action. For diesel particulates, polycyclic aromatic hydrocarbons (PAHs) and their derivatives, which are known to exhibit a mutagenic mode of action, comprise < 1 % of the exhaust particulate mass. To date, the U.S. Environmental Protection Agency reports that whole diesel engine exhaust has not been shown to elicit a mutagenic mode of action (USEPA, 20185). Additionally, the California Department of Toxic Substances Control (DTSC) which is charged with protecting individuals and the environment from the effects of toxic substances and responsible for assessing, investigating and evaluating sensitive receptor populations to ensure that properties are free of contamination or that health protective remediation levels are achieved has adopted the U.S. EPA's policy in the application of early -life exposure adjustments which is consistent with the methodology considered herein. As such, incorporation of early -life exposure adjustments for exposures to DPM emissions in the quantification of carcinogenic risk for construction of the proposed project is not warranted. Given that there is no available guidance that has been adopted by SCAQMD for CEQA purposes and the fact that the Project does not emit any pollutants that elicit a primary mutagenic mode of action, the use of the OEHHA guidelines to determine potential construction health risks would not be appropriate and therefore is not recommended by the City at this time. The EIR correctly evaluates potential impacts and no further evaluation is technically required. 9 See Response to Comment #1 3, Page A-7 and A-8 of the June 5, 2015 board meeting Agenda No. 28. http://www.aqmd.gov/docs/defoult. source/Agendas/Governing-Board/2015/2015-lun1-028 ° United States Environmental Protection Agency, 2006. Memorandum — Implementation of the Cancer Guidelines and Accompanying Supplemental Guidance - Science Policy Council Cancer Guidelines Implementation Workgroup Communication II: Performing Risk Assessments that include Carcinogens Described in the Supplemental Guidance as having a Mutagenic Mode of Action. 5 United States Environmental Protection Agency, National Center for Environmental Assessment, 2018. Integrated Risk Information System (IRIS). Diesel Engine Exhaust. 75C-197