Tobacco Documents Online

THE UNIVERSITY OF BIRMINGHAM Inulitulr .d 1/erulwtiunal II.vllll Edghaston Birmingham Bi., -?lf Lnitrd KinRdnm Trlrphone 1121 4 14 n144 1 Fax u21 s't . 20th September 1990 Project Officer for ETS Policy Guide Indoor Air Division (ANR-445) Environmental Protection Agency 401 M Street, S.W. Washington D.C. 20460 USA Re: ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES I have obtained and reviewed with interest your draft document, "Environmental Tobacco Smoke: A Guide to Workplace Smoking Policies." I have a number of comments. If one is writing, as stated, a guide for a lay audience on a scientific and social issue such as ETS in the workplace, it is imperative that a strict list of criteria be kept in mind. These criteria should include, at a minimum, the following: a. Scrupulous scientific accuracy must be observed concerning the use of facts and there must be honesty about uncertainties, even is one believes in the justness of a particular outcome or cause; b. Extrapolations from known to unknown should be clearly stated, and any limits of uncertainty arising as a result of extrapolation should be explained; c. Equal sensitivities should be shown to all persons who are the object of debate (here, smokers and non-smokers) in relation to the psycho- social aspects of the situation; d. Spurious information which is irrelevant to the debate should be avoided. Such information, to a lay audience at least, may appear to add credibility to a weak argument, because a lay audience will have to accept most "facts" at face value; e. Jargon or terminology that will not be readily understood should be avoided; f. The document should be brief without loss of clarity, and repetition an ~ irrelevant details should be avoided. ~ ..~~ C9 ~ 0~

With these criteria in mind, I have reviewed the draft document. It is unnecessarily long due to repetition, and despite the status of EPA, this document is surprising in that it has a crusading feel. This seems apparent from some of the information chosen to support the strategies that are advocated. Thus, for example, the document talks about workplaces, but in fact relies for statements about risk almost exclusively on studies that involve mainly the home situation. I am not aware that there are many studies on the effects of ETS in the workplace, and I would expect the exposure situation in the workplace to be different than the situation in the home. Thus, the policy statements made here may be based on perceptions of risk that are irrelevant to the workplace. Any extrapolation from one to the other should be made clear. The document views the workplace in a very narrow sense. It acknowledges workplaces such as offices, hospitals and schools. What about the vast numbers of workers in foundaries, shipyards, manufacturing plants, and the like? It may be that the problems of ETS, if in fact they exist in the workplace, are so small compared to other air contaminants that they are not worth mentioning with respect to such workplaces. Regardless of the science, your document is insulting in that it is geared for a white-collar audience as opposed to blue-collar workers who make up much of the work force yet it is comprehensively entitled, "a guide to workplace smoking policies". I also have a few specific points about the documents: 1. On page 2 you assert that a non-smoker may be exposed to greater amounts of smoke in 1985 than in 1955. This is based on the number of cigarettes smoked, but the composition of cigarettes has changed in that period and the smoke output may have altered. The empirical basis for the statement is not at all clear. 2. Your statements about cost-savings due to the reduction of ETS are vague and uncertain. There is little substantiation in the document. You mainly talk about the reduction of employee health insurance costs for non-smokers, but there probably is an insufficient database to permit insurers to reduce costs for non-smokers not exposed to ETS, over and above those reductions that are available for non-smokers versus smokers. This argument appears to be a make-weight argument. 3. It is nonsense to call nicotine a poison in the context of tobacco smoke. This label could be applied to many substances, regardless of whether they are in ETS, and indeed could perhaps be applied to most substances if the dose is sufficient. In the quantities found in tobacco smoke, nicotine could hardly be called a human-acute toxin, which is what the word "poison"suggests. 4. I assume other people are commenting on the larger risk assessment that accompanies this document. From what I know of the science, it appears that there is a vigorous debate about the acutual risk from ETS, and the methods used in your risk assessment are open to question. I assume others will comment on that point. If the risk assessment is wrong, then clearly this will call into question many of the statements in the workplace smoking policy guide.

3 5. Suits by smokers are mentioned. I assume that they are mentioned in order who they the to reinforce the case for employers to take stands against workers smoke, but none of these address ETS in the workplace, and thus should be omitted because they are irrelevant to the issue of ETS in workplace. 6. In Chapter 8 you refer to possible costs of smoking. This is irrelevant to ETS in the workplace, and lends a crusading feel to the document. The table on page 37 is misleading as it suggests that the figures reflect data on real costs to companies. However, the accompanying text makes clear that the data is subjective: "The executives surveyed felt that ... hardly is likely to produce data worth a figure. This document needs more work. Employees or employers who would like to adopt workplace smoking policies are entitled to a straightforward, non- advocating document. The advocacy seen here is surprising for a document produced by a government agency, and revisions should be made, pursuant to the criteria listed above, so that the document is even-handed. Yours sincerely Dr Leonard S Levy