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Comments on: ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES [Draft] EPA 400/6-90/004 Response Addressing: Chapter 1: What is ETS? Section: Toxins and Irritants Chapter 3: Health Effects of ETS Section: Irritation Prepared by: Daniel B. Kurtz, Ph.D. Senior R&D Psychophysicist and James C. Walker, Ph.D. Senior R&D Behavioral Scientist R.J. Reynolds Tobacco Company October 1990

SUMMARY: The EPA draft document #EPA/400/6-90/004 dated June, 25, 1990 and titled "Environmental Tobacco Smoke: A Guide to Workplace Smoking Policies" contains a number of undocumented statements and fails to put documented statements into proper perspective. The comments below address both l.inds of statements. These comments are directed only at the statement on irritation on page 9 in Chapter 1 and at the section titled "Irritation" in Chapter 3. COMMENTARY: 1. Page 9, Paragraph 8. "Ammonia is a powerful eye and respiratory irritant." This statement does not take into account what is known about the concentration of ammonia found in ETS or what is known about the sensory properties of ammonia. The extreme upper bound of ammonia concentrations in ETS appears to be in the 5 to 10 ppm range [Fischer, 1979; Sterling, Collett, Kleven and Arundel, 1988]. In at least half of the 389 buildings studied by Sterling [Sterling, E., 1988], ammonia concentrations were below the limit of detection. A recent compilation of odor thresholds by Amoore and Hautala' (1983) lists 5.2 ppm as the ammonia odor threshold. The American Conference of Government and Industrial Hygienists (ACGIH) TWA TLV is 25 ppm and the short term exposure limit (STEL) TLV is 35 ppm. Finally, the irritation threshold has been reported as 72 mg/m' or about 104 ppm (Ruth', 1986). These considerations indicate that ammonia would only rarely be present at sufficiently high levels in ETS to be considered an odorant. Perhaps

more importantly, its concentration in ETS would be expected to remain far below the TWA or STEL TLV values and would be even further below the irritation threshold. 2. Section titled "IRRITATION;" page 15, Paragraphs 2 and 3. 2.1 The section on irritation is included under Chapter 3 titled "Health Effects of ETS." This placement implies that there is scientific evidence that ETS causes tissue damage in nonsmokers under actual smoking conditions found in the real world. All but the last sentence of this section is based on a portion of a Surgeon General's Report in which the specific page referenced contains only unreferenced statements. (It appears that citations 41 and 42 actually refer to page 231 in the Surgeon General's Report rather than page 230.) 2.2 For the "predominantly non-technical audience", this section leaves the clear but undocumented impression that typical effects of ETS on nonsmokers are: 1. "burning, itchy eyes..." which "...can become incapacitating"; 2. "a sore throat or cough"; or 3. "wheezing, headaches or nausea". 2

2.3 We suggest that the EPA clearly distinguish between the perception of ETS and purported health effects. The work by Clausen2 et al. (1987, reference #43 in the Policy Guide) deals with perceptual eye, nose and throat irritation. These authors are careful to indicate this in their work by using terminology such as "perceived intensity of throat irritation." By blurring the important distinction between these two connotations of the word "irritation," the Guide's reference to Clausen leaves the unwarranted impression that tissue damage from ETS has been observed. It has not! (The full reference should be cited for Clausen's research.) 2.2.1 Page 15, Paragraph 2, Line 5. "... for some it can become incapacitating." The claim of 'incapacitating' lacks any documentation. If such documentation exists, the frequency of this response should be noted. Also, the term 'incapacitating' should be defined. The concentration of ETS and duration of exposure necessary to produce this 'incapacitation' should also be noted along with the frequency that a nonsmoker might actually encounter this extreme stimulus. 2.2.2 Page, 15, Paragraph 3, Line 3. 'The result is generally a sore throat or ~ ~ cough." U1 3

The claim that irritation of the nose and throat results in "generally a sore throat or cough" is undocumented. Again documentation of ETS levels and exposure durations, sufficient to cause these symptoms and the frequency of these symptoms, would be necessary to support such a claim. 2.2.3 Page 15, Paragraph 3, Line 4. "Other short term effects of ETS exposure include wheezing, dizziness, headaches or nausea." Presenting extreme responses of people who are extraordinarily sensitive to ETS as though they were typical is deceptive and misleading. Again, these responses need documentation and a real world perspective. 4

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