75C - PH MORTIMER MIXED USE - Laserfiche WebLink

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City of Santa Ana 4th and Mortimer Project Response 10 The commenter provides an introduction to Industrial Hygienist, Francis "Bud" Offermann, PE, CIH, and describes that, based on Mr. Offermann's findings, many composite wood products typically used in modern home construction contain formaldehyde -based glues which off -gas formaldehyde. The comment asserts that there is a fair argument that residents of the project will be exposed to a cancer risk from formaldehyde between 112 and 180 per million, above the South Coast Air Quality Management District (SCAQMD) CEQA significance threshold for airborne cancer risk of 10 per million. The commenter further asserts that, even if the project uses modern California Air Resources Board (CARB)-compliant materials, formaldehyde will create a cancer risk more than 10 times above the CEQA significance threshold and requests the implementation of mitigation measures to reduce this risk. The comment does not describe how the formaldehyde related cancer risk of between 112 and 180 per million would occur and does not identify any project -specific conditions (other than the fact that the project's construction may use wood building materials) that would lead to impacts. Current federal and State regulations limit the potential formaldehyde emissions from building materials. On June 1, 2018, the United States Toxic Substances Control Act (TSCA) Title VI was implemented, which requires that composite wood products sold, supplied, offered for sale, manufactured, or imported in the United States meet new emission standards for formaldehyde from composite wood products in order to reduce exposures to formaldehyde and avoid adverse health effects. Typical composite wood products include hardwood plywood, medium -density fiberboard, and particleboard, as well as household and other finished goods containing these products. The new emission limits include the following: Hardwood Plywood: 0.05 parts per million (ppm) Particleboard: 0.09 ppm Medium -density fibreboard: 0.11 ppm Thin Medium -density fibreboard: 0.13 ppm These emission levels were determined to be in compliance with and result in less exposure (e.g., daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 micrograms [[ig]/day), which is based on Proposition 65's risk criterion of 1 in 100,000. Therefore, products manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now required by the United States Environmental Protection Agency (USEPA) for all products manufactured or imported into the United States, would not generate formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. The CalGreen Building Code also includes similar formaldehyde limits for building products. By law, project construction materials would have to comply with these formaldehyde requirements, as all products manufactured or imported in the United States are required to meet these regulations. Furthermore, according to the United States National Library of Medicine's Hazardous Substances Database, formaldehyde is readily biodegradable and complete degradation of formaldehyde can be accomplished in less than 30 days, and formaldehyde in the air can be degraded in less than four days. Most, if not all, formaldehyde residue in furniture can be expected to be off -gassed and released shortly after it is manufactured (i.e., 30 days after manufacture), meaning that the amount of formaldehyde residue in furniture and indoor air would be expected to approach zero within 30 days. Cancer effects are produced following extensive, long-term exposures for usually more than seven years. Wood -pressed furniture would not have enough formaldehyde to off -gas for that length of time (or any length of time generally exceeding five days). 75C-290