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formaldehyde daily dose is 65.6 µg/day <br />This is 1.64 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer risk <br />of 16.4 per million, which exceeds the CEQA cancer risk of 10 per million. This impact <br />should be analyzed in an environmental impact report ("EIR"), and the agency should <br />impose all feasible mitigation measures to reduce this impact. <br />Several feasible mitigation measures are discussed below and these and other measures <br />should be analyzed in an FIR <br />While measurements of the indoor concentrations of formaldehyde in residences built with <br />CARB Phase 2 Formaldehyde ATCM materials (Chan et. al., 2019), indicate that indoor <br />formaldehyde concentrations in buildings built with similar materials (e.g. hotels, <br />residences, offices, warehouses, schools) will pose cancer risks in excess of the CEQA <br />cancer risk of 10 per million, a determination of the cancer risk that is specific to this project <br />and the materials used to construct these buildings can and should be conducted prior to <br />completion of the environmental review. <br />Appendix A, Indoor Formaldehyde Concentrations and the CARB Formaldehyde ATOM, <br />provides analyses that show utilization of CARB Phase 2 Formaldehyde ATCM materials <br />will not ensure acceptable cancer risks with respect to formaldehyde emissions from <br />composite wood products. <br />The following describes a method that should be used prior to construction in the <br />environmental review under CEQA, for determining whether the indoor concentrations <br />resulting from the formaldehyde emissions of the specific building materials/furnishings <br />selected for the building exceed cancer and non -cancer guidelines. Such a design analyses <br />can be used to identify those materials/furnishings prior to the completion of the City's <br />CEQA review and project approval, that have formaldehyde emission rates that contribute <br />to indoor concentrations that exceed cancer and non -cancer guidelines, so that alternative <br />lower emitting materials/furnishings may be selected and/or higher minimum outdoor air <br />ventilation rates can be increased to achieve acceptable indoor concentrations and <br />5of19 <br />