Tobacco Documents Online

e June 18, 1991 MEMOR.ANDUM TO: Susan Stuntz Bob Lewis FROM: Kay Packett The revised draft of the EPA ETS Compendium (attached) is not substantially different from the draft released early last year and appears not to reflect much attention at all to the industry's extensive comments. With a few exceptions, including the Glantz/Parmley chapter on heart disease and the Repace chapter on exposure to ETS, the changes are mostly editorial. With one exception, a new section in Chapter 11 Appendix, the substantive changes that have been made are unhelpful. In addition to this review, I have requested that The Institute's scientific consultants and Covington review the new draft and provide an analysis of any changes of scientific significance, with particular focus on the chapter by Glantz and Parmley. Based on their recommendations, we will prepare to address the new draft if it moves forward at EPA or the Department of Health and Human Services. One of the editorial changes in the new draft Compendium is rearrangement of the chapters. The listing that follows is from the new draft. Chapter 1: Donald Shopland, Effects of Smoking on Smokers. The only major revision is the elimination of a discussion on the history of tobacco use. Chapter 2: John McCarthy, Elizabeth Miesner and John D. Spengler, Exposures to Indoor Particulate Air Pollutants. This chapter contains very few substantive changes. Chapter 3: Brian P. Leaderer, "Measuring Exposure to Environmental Tobacco Smoke. This chapter is missing from TI's copy of the revised draft and from the draft forwarded to Rep. Bliley. Rep. Bliley has contacted EPA to request a copy. Chapter 4: Dietrich Hoffmann, Klaus D. Brunnemann and Nancy J. ~ Absorption of Smoke Constituents by Nonsmokers Haley ~ , . ~ There are virtually no changes in this chapter, except the addition of a summary of major oints O Gn t0 p . ~. ~ a

Stuntz, Lewis Memorandum June 18, 1991 Page 2 Chapter 5: Jonathan Samet, Environmental Tobacco Smoke and Cancer. There are no changes in this chapter. Samet appears not to have revised his draft at all. Chapter 6: Stanton A. Glantz and William W. Parmley, Passive Smoking and Heart Disease. The Glantz/Parmley chapter has been revised slightly throughout, with addition or deletion of a sentence here and there and some revisions to technical discussions. Although these changes appear not to affect Glantz's central arguments, our scientific consultants will take a closer look. The one very significant change in the new Glantz chapter is a reference to and a major focus on the mortality number reported in his Circulation article. The first draft of the Glantz chapter stated merely that the number of cardiovascular deaths attributable to ETS is "ten times greater" than the lung cancer estimates. The current draft states that "ETS-induced heart disease...contributes 37,000 to the estimated 53,000 deaths annually from passive smoking." The new chapter also includes a number of new charts and graphs, one of which illustrates the number of deaths attributable to ETS from various diseases. Chapter 7: James Repace, Exposure Assessment in Passive Smoking. The major changes to this chapter include several examples of estimating ETS exposure from the Repace model and new sections on ventilation and workplace exposure. In the new ventilation section, Repace repeats the claim that 5400 cfm ventilation per occupant would be required to control for health effects of ETS. He also states that the ASHRAE standard is not designed to control for health risk, that air cleaners are as ineffective as ventilation in controlling ETS and that the only viable ETS control option is removal of the source. In the section on workplace exposure, Repace has simply added a discussion of data from several workplace studies and the conclusion that the workplace is "a significant site of exposure to ETS."

Stuntz, Lewis Memorandum June 18, 1991 Page 3 Chapter 8: William S. Cain, The Odor and Irritation of ETS. This chapter contains very few substantive changes, with the exception that Cain has added a section on applicability of chamber studies. Chapter 9: Thomas Novotny, Passive Smoking: Beliefs, Attitudes and Exposures in the United States. The information contained in the earlier draft has been rearranged. Chapter 10: Glen L. Bennett, Passive Smoking and Daycare. This chapter contains virtually no substantive changes. Chapter 11: Ruth Behrens, No Smoking Policies at the Worksite: A Look at What Companies are Doing Today and Chapter 11 Appendix: Is There Economic Justification for No Smoking Policies at the Worksite? Chapter 11 contains virtually no changes, except that reviews of a few more recent workplace smoking surveys have been added. In Chapter 11 appendix, as in the previous draft, Behrens discusses at length studies suggesting that employers will save money by banning workplace smoking and encouraging employees to quit. In the new draft, however, Behrens has added a bizarre discussion of why these studies probably are wrong, citing employer costs of developing workplace smoking control policies and increased costs of longer life. She concludes that these costs "may eliminate financial gain for the company." Please let me know if you have questions or suggestions. Attachment cc: Brennan Dawson Marty Gleason Chris Proctor John Rupp