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Comments on: ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES [Draft] EPA/400/6-90/004 Response Addressing: Chapter 5: Reducing Exposure to ETS Prepared by: Patricia O. DeLuca Associate R&D Chemist and Guy B. Oldaker III, Ph.D. Senior Staff R&D Chemist R.J. Reynolds Tobacco Company October 1990

The EPA has failed to inform users of the Guide that the rate at which ETS spreads - "disperses" is the appropriate word - is determined primarily by environmental factors specific to each microenvironment. Such factors include room geometry, relative locations of smokers and nonsmokers, general ventilation characteristics of the room (eg., number, location, and air-tightness of windows and doors), and the design and performance of heating ventilating and air conditioning (HVAC) systems. That these factors are the main determinants of ETS dispersion rate is supported by studies which show the effectiveness of smoker segregation as a means of reducing exposure of nonsmokers to ETS. For example, a recent U.S. Department of Transportation study found that ETS was not ubiquitous in passenger cabins of commercial aircraft where smoking occurred [1]. The EPA also has failed to contrast the dispersion rates of the particulate and gas phases of ETS. Thus, based upon simple physical principles, gas-phase components of ETS have an inherent tendency (i.e, diffusion) to disperse more quickly than the particulate phase (viz., ETS RSP). This information is important because it explains to the user why detection of gas-phase components of ETS in a room does not unambiguously indicate the possibility for exposure to ETS RSP. The sentence implies that ETS - dispersed, diluted, and "virtually ubiquitous" - exists at significant concentrations. Thus, viewed within the context of the Guide, the sentence implies that ETS levels representing concerns to public health are virtually ubiquitous in spaces where smoking is permitted. Because this statement is made without qualification, it admits the interpretation that virtually anywhere smoking occurs, ETS must be present at levels of concern, regardless of whether or not its presence can be detected analytically. The term "virtual ubiquity" requires quantification reflecting either analytical chemistry concepts or regulatory concepts such as a de minimis level. 3 -1

Not having a literature citation to support the position that the ability to spread quickly results in virtual ubiquity, these reviewers must assume that the EPA's reasoning derives from two assumptions, neither of which can be adequately supported. First, the sentence could be assuming that the quick spreading of ETS is not accompanied by significant dilution, where a significant dilution would cause ETS levels to fall below either limits of detection or de minimis levels. The literature on exposure assessment contains numerous examples where ETS indicators could not be detected in areas where smoking occurred; thus, this assumption is false [1, Z 3, 4J. Second, the sentence could be assuming that cotinine in body fluids is a reliable indicator of exposure to the components of ETS associated with health concerns. Indeed, several studies have concluded that ETS is ubiquitous based upon determinations of cotinine, a nicotine metabolite, in body fluids. However, the work of Nelson et aL [5] has raised serious questions about the reliability of cotinine measures as an indication of exposure to ETS, in general, and ETS RSP, in particular. These researchers found that nicotine levels can falsely indicate exposure to ETS. This finding is important because most scientists assume that ETS RSP (as distinguished from gas phase ETS) is the phase associated with health alleged concerns. This opening sentence presents a strong position regarding the ubiquity of ETS. An equally strong citation of the supporting literature (and treatment of the wealth of literature referred to) is required to ensure completeness. Os ~ ~ cut A CJt N 4 ~

2. Under CHAPTER 5: Reducing Exposure to ETS, in the first paragraph, the fourth Sentence reads: The effectiveness of each of these techniques in reducing ETS varies. The Guide fails to define or reference both the word "effectiveness" and the general concept of "effective." Additionally, throughout Chapter 5 the EPA uses "effective" in connection with several different concepts thus making the interpretation of the word all the more confusing. For the Guide to be useful, the EPA must provide the following: (a) criteria for assessing whether a smoking policy is effective; (b) criteria for assessing the relative effectiveness of techniques offered to reduce ETS exposure; and (b) criteria addressing the relative performance of the generic air cleaning devices described. 5

3. In the section titled Prohibiting Smoking Indoors, first paragraph, the first sentence states: The most effective way to eliminate ETS exposure for nonsmokers is to prohibit smoking indoors. This statement does not communicate effectively. The statement implies that prohibition can totally eliminate nonsmokers' exposure to ETS. Prohibiting smoking indoors, however, cannot eliminate ETS exposure for nonsmokers since exposure can occur in outdoor settings. Additionally, even indoor ETS exposure cannot be eliminated since smoking cannot (currently) be regulated in all indoor environments; e.g., private residences. If this statement is to convey a precise meaning, consistent with the subject of the chapter, its object must be constrained to reduction rather than elimination. Otherwise, the focus of the sentence should be narrowed to specific microenvironments. Without some definition of "effective" this statement is meaningless. Users of this Guide require criteria for evaluating the relative effectiveness of the techniques presented in Chapter 5. In the absence of such criteria, government and private sector decision makers will be unable to implement informed, technically sound policies. m ~ ~ ~ ~ N 6 p

4. In the section titled Prohibit Smoking Indoors, first paragraph, the second sentence states: This [viz., prohibition of smoking indoors] is also, generally, the least expensive method of eliminating ETS from indoor air because it doesn't require changes to the existing ventilation system and may also reduce long term energy costs. The statement requires a cost analysis to support the position that this technique is "generally the least expensive method." For example, what generally are the costs relative to productivity? The EPA appears to be neglecting this cost issue; such neglect is supported by the subsequent sentence appearing in the Guide: However, a smoking prohibition may be inconvenient to those smokers who continue to smoke and must leave the building to do so. The statement also shows that the EPA is speculating on the matter of energy costs. No evidence exists to support the position that prohibiting smoking by itself can reduce long term energy costs. By raising the issue of reducing such costs, the EPA implies that a cause-and-effect relationship exists between the prohibition of smoking and energy usage. Such a cause-and-effect relationship might occur if intentional changes were made to building HVAC systems subsequent to a smoking prohibition; eg., a building owner or operator could reduce ventilation, an action which would probably result in reduced energy costs. Such reduced ventilation rates would be technically justified if they conformed with applicable building codes; ag., specifications of the American Society of Heating, Refrigerating, Ventilating and Air- conditioning Engineers (ASHRAE). However, if ventilation were reduced below applicable (and presumably, adequate) specifications, the result would be unacceptable indoor air quality, or, stated another way, an "unhealthy" environment. ~ Although a strong technical argument can be made that reduced ventilation will W .D~ C1t 7 N M+

reduce energy costs, an equally strong argument can be made that these energy savings from energy will be overwhelmed by the costs associated with health care owed to the effects of diminished indoor air quality [6]. To ensure that users of the Guide are not misled by this sentence, the EPA must clearly state that conformance with applicable specifications will determine whether ventilation may be reduced, which in turn could reduce energy costs. The statement also implies that there are cases where the prohibition of smoking indoors is not the least expensive method for eliminating ETS from indoor air. The EPA should provide users with examples. Providing examples would remove the ambiguity associated with the word "generally." 5. In the section titled Creating Separate Smoking Lounges with Separate Ventilation, the second paragraph states: To be properly ventilated, a smoking room should meet three requirements: The fourth paragraph provides one of these requirements: The room should have at least 60 cubic feet per minute (cfm) of outdoor air per smoker to control ETS odors. This statement is incomplete without some technical support for the ventilation requirement of 60 cfm per smoker. These reviewers suspect that the requirement applies to the air of the smoking room and derives from experiments involving ~ nonsmoking subjects. If this assumption is true, the requirement is inapplicable ~ ~ ~ tn 8 N

because it is based on nonrepresentative experimental subjects and irrelevant experimental hypotheses and measures. 6. In the section titled Creating Separate Smoking Lounges with Separate Ventilation, the second and third paragraphs state: To be properly ventilated, a smoking room should meet three requirements: The smoking room should have a separate ventilation system. This means that air from the room should be immediately exhausted outside rather than being recirculated through the building. The average building recirculates the vast majority of its air supply. The EPA uses flawed logic to support the requirement for a separate ventilation system. They assume that because the average building recirculates the vast majority of its air supply, all buildings must do so, and therefore, all smoking areas should be separately ventilated. Even the assumption itself admits the possibility that the average building has some areas (i.e., what could be termed "the vast minority") where air is not recirculated. Assuming that the creation of a smoking room is warranted, common sense first would have the ventilation system characterized to determine whether a separate ventilation system is necessary. Clearly, the need for separate ventilation is best determined on a case-by-case basis. The SIDEBAR EXAMINING YOUR VENTILATION SYSTEM touches upon this approach; however, the main text of Chapter 5 fails to identify the SIDEBAR. 9

7. In the section titled Create Separate, Walled Areas for Smokers and Nonsmokers with a Shared Ventilation System the first paragraph states: A common mitigation strategy is to create separate areas for smokers and nonsmokers, each walled off from the other. This may reduce nonsmokers' ETS exposure. However, it does not eliminate ETS pollution. As long as the two spaces share a ventilation system, their occupants will breathe the same air. Polluted air from the smoking rooms will be recirculated to nonsmoking areas. T7ds pacsqge is t7logical and self contradictory. In what is apparently an eJfort to support srnoAong prohibition at all costs, the EPA argues both sides of an issue at once. Reading this pa&sage, informed users of the Guide can conclude that it is either the work of a neophyte or propqgandq and poorly composed propaganda at tlwx Ample literature demonstrates what common experience tells us: Smoker segregation reduces ETS exposure for nonsmokers. The statement: 'This may reduce nonsmokers' exposure " is false; the fact is: This will reduce nonsmokers' exposure. Even if one were to assume that the word "may" is accurate, the illogic remains. Thus, if nonsmokers' exposure is reduced, then the occupants of smoking and nonsmoking areas cannot breathe the same air. The Guide correctly recognizes that this mitigation strategy is common; it fails, however, to reveal why. The most logical and straightforward answer is that this strategy is commonly observed because it is effective. The EPA should address why this strategy is commonly observed. The same holds for the strategy Create Separate, Unwalled Areas for Smokers and. Nonsmokers, which according to the Guide is the most common strategy. The term "ETS pollution" is vague, emotionally loaded, and easily misinterpreted. If the Guide is to use this term, it must provide an objective definition to ensure 10

effective communication. Plternatively, the word "pollution" should be omitted. The latter option is simpler. 8. In the section titled Create Separate, Walled Areas for Smokers and Nonsmokers with a Shared Ventilation System the second paragraph states: A second problem with this strategy is that ETS diffuses easily through doorways and windows. Therefore the smoke will not remain in the room, but will seep into neighboring nonsmoking spaces.74 Reference number 73 (Williams et aL, 1985 [7]) which is the support offered for the position that "smoke will seep into neighboring nonsmoking spaces" has been discredited. Green et aL [8] found that this work contained arithmetic errors. When corrections are made, reference number 73 supports the opposite conclusion: essentially no smoke seeps into neighboring nonsmoking sections. However, this opposite conclusion assumes that the method used by Williams et aL to determine nicotine provided quality results. (RSP, the Guide's ETS surrogate of choice, was not measured.) This assumption is probably incorrect. Unlike the other methods used by investigators to determine ETS nicotine, the method of Williams et aL has not been validated. Either a reliable reference should be provided or the sentence associated with reference number 74 should be deleted. Failure to recognize that this work was discredited indicates that the Guide, in general, and this section, in particular, are incomplete because the applicable literature has not been adequately reviewed. 11