OSMC Table 403.3 for

"For nail salons, each nail station shall be provided with a source capture system capable of exhausting not less than 50 cfm per station".

The proposed alternate method is a downdraft source capture system that ventilates air and removes contaminants at the surface of the table, with the ventilation located in the center of the surface, directly between the nail technician and the customer. The ventilation mechanism utilizes an activated carbon-capture filtration system that captures contaminants at the source. The name of this system is the Valentino Beauty Pure GEN3S, and while the manufacturer advertises its typical air flow at 293 CFM, it has been tested in accordance with AMCA 210-07, to the result of just over 87 cfm. *Please see enclosed Valentino Test Certificate.

Prior to receiving notification from the inspector of the requirement for source capture systems that exhaust directly outside, the tenant purchased a non-returnable shipment of downdraft manicure tables that remove contaminants at the surface of the table and filters contaminants, dust, and odors. She made this purchase to protect the health of her employees and customers - which is the intent of the OSMC requirement for exhausting a minimum of 50 cfm.

The tenant was unaware of these requirements as she researched this business by visiting other Portland nail salons and speaking with owners and nail technicians in and around Portland. In those discussions and visits, there was no evidence of source capture systems that vented directly to the exterior.

She found only one salon that had source capture systems at their manicure tables, but had no evidence that these exhausted at a minimum of 50cfm. *Please see enclosed list of salons in the area, registered within the past 10 years, that do/may not meet this code requirement.

The tenant states the financial cost of providing a ventilation system which connects each manicure table directly to the exterior, along with the cost of retrofitting the non-refundable carbon-capture tables that have already been delivered, will put this salon at a competitive disadvantage to other nail salons in inner southeast and northeast Portland as the majority do not have direct ventilation systems.

OSMC Table 403.3 for

Mechanical exhaust required and the recirculation of air from such spaces is prohibited.

The proposed alternate method is to ventilate contamination by utilizing activated carbon filters to capture dust, odors, and other contaminants at the source without exhausting those contaminants to the adjacent restaurants' fresh air intakes or polluting the air of the surrounding neighborhood. The filters are replaceable and are suggested by the manufacturer to replace every 1-2 weeks.

The name of this system is the Valentino Beauty Pure GEN3S, and while the manufacturer advertises its typical air flow at 293 CFM, it has been tested in accordance with AMCA 210-07, to the result of just over 87 cfm.

While this carbon-capture method does not exhaust directly to the exterior but allows recirculation of air within the salon, it filters contaminants from the air and so addresses the intent of the Oregon Specialty Mechanical Code providing a healthier work environment for employees and healthier atmosphere for customers. Carbon-capture is identified in at least one other western state as an alternative to exhausting directly to the exterior. This system was purchased, in good faith, by our client for the benefit of employees and customers.

*Please see enclosed Description of Filtration that was issued by the manufacturer when the State of Utah began requiring filtration or exhaustion. Also enclosed is a copy of 2014 Utah state bill 143 with applicable verbiage highlighted, lines 48-57. Additional identification of the manufacturer addressing Utah SB143 requirements can be found in the enclosed 2017- Product Consumer-Guide-US.

Prior to receiving notification from the inspector of the requirement for source capture systems that exhaust directly outside, the tenant purchased a non-returnable shipment of downdraft manicure tables that remove contaminants at the surface of the table and filters contaminants, dust, and odors. She made this purchase to protect the health of her employees and customers - which is the intent of the OSMC requirement for exhausting contaminants to the exterior and not recirculating air from within the space.

The tenant was unaware of these requirements as she researched this business by visiting other Portland nail salons and speaking with owners and nail technicians in and around Portland. In those discussions and visits, there was no evidence of source capture systems that vented directly to the exterior.

The tenant found only one salon that had source capture systems at their manicure tables, but these recirculate air within the space (possibly through a filter). *Please see enclosed list of salons in the area, registered within the past 10 years, that do not meet this code requirement.

The tenant states the financial cost of providing a ventilation system which connects each manicure table directly to the exterior, along with the cost of retrofitting the non-refundable carbon-capture tables that have already been delivered, will put this salon at a competitive disadvantage to other nail salons in inner southeast and northeast Portland as the majority do not have direct ventilation systems.

OSMC Section 403.2.1, item 3.

Where mechanical exhaust is required by footnote b in Table 403.3, recirculation of air from such spaces shall be prohibited. All air supplied to such spaces shall be exhausted, including any air in excess of that required by Table 403.3

The proposed alternate method is to ventilate contamination by utilizing activated carbon filters to capture dust, odors, and other contaminants at the source without exhausting those contaminants to the adjacent restaurants' fresh air intakes or polluting the air of the surrounding neighborhood. The filters are replaceable and are suggested by the manufacturer to replace every 1-2 weeks.

The name of this system is the Valentino Beauty Pure GEN3S, and while the manufacturer advertises its typical air flow at 293 CFM, it has been tested in accordance with AMCA 210-07, to the result of just over 87 cfm.

While this carbon-capture method does not exhaust directly to the exterior and allows recirculation of air within the salon, it filters contaminants from the air and so addresses the intent of the Oregon Specialty Mechanical Code providing a healthier work environment for employees and healthier atmosphere for customers. Carbon-capture is identified in at least one other western state as an alternative to exhausting directly to the exterior. This system was purchased, in good faith, by our client for the benefit of employees and customers.

*Please see enclosed Description of Filtration that was issued by the manufacturer when the State of Utah began requiring filtration or exhaustion. Also enclosed is a copy of 2014 Utah state bill 143 with applicable verbiage highlighted, lines 48-57. Additional identification of the manufacturer addressing Utah SB143 requirements can be found in the enclosed 2017- Product Consumer-Guide-US.

Prior to receiving notification from the inspector of the requirement for source capture systems that exhaust directly outside, the tenant purchased a non-returnable shipment of downdraft manicure tables that remove contaminants at the surface of the table and filters contaminants, dust, and odors. She made this purchase to protect the health of her employees and customers -which is the intent of the OSMC requirement for exhausting contaminants to the exterior and not recirculating air from within the space.

The tenant was unaware of these requirements as she researched this business by visiting other Portland nail salons and speaking with owners and nail technicians in and around Portland. In those discussions and visits, there was no evidence of source capture systems that vented directly to the exterior.

The tenant found only one salon that had source capture systems at their manicure tables, but these recirculate air within the space (possibly through a filter). *Please see enclosed list of salons in the area, registered within the past 10 years, that do not meet this code requirement.

The tenant states the financial cost of providing a ventilation system which connects each manicure table directly to the exterior, along with the cost of retrofitting the non-refundable carbon-capture tables that have already been delivered, will put this salon at a competitive disadvantage to other nail salons in inner southeast and northeast Portland as the majority do not have direct ventilation systems.