Tobacco Documents Online

December 2, 1981 Dear I am writing to provide further information in regard to our discussion of ASHRAE Standard 62-1981 "Ventilation for Acceptable Indoor Air Quality." After further review of the Standard following our discussioniseveral weeks ago, I have grown~ stronger in my opinion that it is vulnerable to serious criticism. I would like to elaborate on several points. The requirements for outdoor air ventilation for smoking and nonsmoking areas, which appear in Table 3, lack experimental and technical support. Nowhere in the text of the Standard or in the Appendices do there appear any calculations which indicate how the many different specific ventilation require- ments were obtained. There is no technical support provided to explain why the outdoor ventilation requirements in smoking areas vary from two to five times those required of nonsmoking areas. Nor is any evidence or argument presented which!would suggest that present ventilation standards are inadequate. It is hardly sufficient for the Standard writers to state that "professional judgment" was used~when the situations considered are so varied and the relevant factors such as architectural features and occupancy characteristics so complex. :

C The Standard is also unreasonably inconsistent in that the requirements for residential areas are given without smoking being considered (as it was done in the predecessor ASHRAE Standard 62-73), while nonresidential areas are categorized into smoking and nonsmoking areas. There is no attempt to justify this discriminatory treatment on professional grounds. Although the Standard recognizes other "contaminants" in the indoor environment, it focuses solely on whether tobacco smoke might be present or absent. There are no references cited as the basis for this decision. Although references are provided in Tables 2 and 4 for other indoor air "contaminants", no references whatsoever are made to the scientific literature in regard to the constituents of tobacco smoke. In this regard several highly respected scientists have concluded that the contribution of tobacco smoke to the levels of airborne substances in the indoor air is not significant. (References cited below) Also, the Standard suggests that tobacco smoke in the air has serious health consequences to the nonsmoker; no scientific support is provided~and, in my judgment, no convincing evidence for this claim has ever appeared in the medical literature. 0 37Z5 :Z44 6 Although brief inention is made in Appendix E concerning air cleaning and recirculation, no serious consideration of this technology appears anywhere in the Standard. This represents a serious omission which is even more surprising in light of the backgrounds of several members of the Standard writing committee. i

The use of panels of lay persons to judge air quality was discussed in the Standard. However, it is unusual that this method was apparently never used by the Committee in arriving at ventilation requirements. Furthermore the subjectivity inherent 11 in such a method leaves its reliability open to serious question. I have been informed that our concern with the lack of .scientific and technical support for the Standard is shared by' ;one of ASHRAE's reviewers of the Standard. It is our understanding :that this reviewer has brought to the Committee's attention many of the same criticisms outlined above. Also, the American National Standards Institute, Inc., has been notified of these negative responses to the Standard. If you would like any further information, please don~'t hesitate to let me know. Sincerely,

Hinds, W., "The Lung and the Environment," Seminars in Respira- tory Medicine, 1(3): 197-210, January, 1980. r Hol2er, G., et al., "Gas Chromatographic-Mass Spectrometric Evaluation of Exhaled Tobacco Smoke," J Chromatography 126: 771-785, 1976. Sterling, T., Statement, U. S. Congress, House, Committee on Agriculture, Subcommittee on Tobacco, Effect of Smoking on, Nonsmokers, Hearing, 95th Cong., 2nd Sess., September 7, 1978 (Wasington: Government Printing Office 1978), pp. 41-46. Sterling, T. and D. Kobayashi, "Exposure to Pollutants in Enclosed 'Living Spaces'," Environ,Res 13: 1-35, 1977.