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Because these commercial spaces will be constructed with CARB Phase 2 Formaldehyde <br />ATCM materials, and be ventilated with the minimum code required amount of outdoor <br />air, the indoor formaldehyde concentrations are likely similar to those concentrations <br />observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which <br />is a median of 22.4 µg/m3 (Chan et. al., 2019) <br />Assuming that the commercial spaces employees work 8 hours per day and inhale 20 m3 <br />of air per day, the formaldehyde dose per work -day at the offices is 149 µg/day. <br />Assuming that these employees work 5 days per week and 50 weeks per year for 45 years <br />(start at age 20 and retire at age 65) the average 70-year lifetime formaldehyde daily dose <br />is 65.8 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. Several feasible mitigation <br />measures are discussed below and these and other measures should be analyzed in an EIR. <br />The residential occupants will potentially have continuous exposure (e.g., 24 hours per day, <br />52 weeks per year) to formaldehyde released by the building materials and furnishing <br />commonly found in residential construction. These exposures to formaldehyde are <br />anticipated to result in significant cancer risks. <br />Because these residences will be constructed with CARB Phase 2 Formaldehyde ATCM <br />materials and ventilated with the minimum code required amount of outdoor air, the indoor <br />residential formaldehyde concentrations are likely similar to those concentrations observed <br />in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median <br />of 22.4 µg/m3 (Chan et. al., 2019) <br />Assuming that the residential occupants inhale 20 m3 of air per day, the average 70-year <br />796119 <br />