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COMMENTS OF JACK E. PETERSON, P.E., C.I.H., Ph.D. ON ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES I hold bachelor's and master's degrees in chemical engineering and a doctorate in industrial health. I am Clinical Professor of Preventive Medicine at the Medical College of Wisconsin and Visiting Professor of Occupational and Environmental Health Sciences at the University of ' Illinois. In addition, I have an industrial hygiene consulting firm, Peterson Associates, headquartered in Brookfield, Wisconsin. My curriculum vitae is attached. At the request of The Tobacco Institute, I have reviewed the "Public Review Draft" of EPA/400/6-90/004, "ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES" dated June 25, 1990. I have a number. of comments on specific assertions contained in the draft that I find to be scientifically unwarranted or inaccurate. My comments will be directed toward chapter 5 because it addresses the subject of my special expertise. CHAPTER 5: Reducing Exposure to ETS The draft is based on the unjustified premise that all exposure to any concentration of ETS must be abolished if health is to be protected. Whether ETS in fact presents any

- 2 - risk to human health has not been established scientifically. Even if one assumes such a hypothesis for discussion purposes, however, much of the advice given about ventilating systems is faulty and shows little understanding of air handling and/or cleaning. In paragraph seven on page 22, for example, the Guide states that "[t]he smoking room should have a separate ventilation system." Even if a separate exhaust were required, however, the air supply itself probably could remain unaltered except for ensuring that there is an adequate amount. Therefore, only an exhaust fan and ductwork would have to be added, not a wholly separate ventilation system. ASHRAE Standard 62-19891/ recommends 60 cubic feet of fresh air per person (cfm/person) in smoking lounges and 15 to 20 cfm/person in offices and elsewhere whether casual smoking is allowed or not. Most commercial ventilation systems currently in place use about 5 cfm of fresh air per person because that was the amount recommended by the ASHRAE standard before 1989 (Standard 62-1981). When such systems are upgraded to the present standard, provision for smoking lounges ventilated at three times that rate should not be burdensome.?/ Nor would it be necessary to have a separate smoking room in these 1/ Janssen, John E.: Ventilation for acceptable indoor air quality, ASHRAE J- pp. 40-48 (October 1989). 2/ Eto, Joseph H. and Cecile Meyer: The HVAC costs of fresh air ventilation, ASHRAE J. pp. 31-35 (September 1989).

- 3 - circumstances. As the ASHRAE standard recognizes, 20 cfm/person is sufficient to handle a normal amount of smoking. The Guide also states that the smoking room should be negatively pressurized. The problem with this statement is that research has not shown the necessity for smoking lounges to be at a negative pressure with respect to the building (or with respect to outside air as stated here) -- or even a necessity for a separate exhaust system for lounges3/ (one of the "three requirements"). Upon what research does EPA base the requirements for separate "ventilation" systems and negative pressure? In discussing separate walled smoking and nonsmokin(I areas, the Guide states that "(als long as the two spaces share a ventilation system, their occupants will breathe the same air." This is not accurate. Air within such rooms is withdrawn, filtered, cooled or warmed and humidified or dried as necessary, diluted with fresh air and with air from elsewhere within the building and then delivered to the supply system. Even if no-fresh air were added (an omission that would likely result in sick building complaints, for reasons 3/ Sterling, Theodor D., Chris W. Collett and Elia M. Sterling: Environmental tobacco smoke and indoor air quality in modern office work environments, J. Occu . Med. 29:57-62 (1987); Sterling, T.: ETS concentrations un er different conditions of ventilation and smoking regulations, Proc. Indoor Amb. Air Qual. Conf., London, pp. 89-98 (1988); Vaughan, Wil iam M. an S. Katharine Hammond: Impact of "designated smoking area" policy on nicotine vapor and particle concentrations in a modern office building, J. Air Waste Manage. Assoc., 40:1012-1017 (1990).

- 4 - having nothing whatever to do with ETS)4/ air from a smoking area would be filtered and vastly diluted before being recirculated. Such air is not "the same air" as that in any other section of the building.5/ The discussion of separate smoking and nonsmoking areas is misleading because it is premised on the assertion that exposure to ETS must be eliminated entirely. Nowhere in this document or elsewhere in the scientific literature can be found any justification for this stance. There are simply no data available to indicate that complete elimination of ETS would do anything at all that simple reduction by means of proper ventilation would not accomplish. The fifth paragraph on page 24 states that air cleaning devices do not reduce gaseous pollutants effectively. It should be noted that many buildings are equipped with activated charcoal filters that remove various gases and vapors from circulating air. The paragraph also asserts that gases may be reemitted from air cleahers. This statement appears to generalize from uncited data on nicotine vapor. No such ETS-derived gases have been shown to be harmful in any way and they certainly have not been shown to be carcinogenic. 4/ Salisbury, Stan: Indoor Air Quality (IAQ) Investigation Procedures, Presented at: Indoor Air Quality Symposium, Atlanta, GA, February 1990. 5/ Sterling, T.D. and B. Mueller: Concentrations of nicotine, RSP, CO and CO in nonsmoking areas of offices ventilated by air recirc3lated from smoking designated areas, Am. Ind. Hyg. Assoc. J. 49:423-426 (1988).

- 5 - The discussion on p. 24 of time separation for smokers and nonsmokers also returns to the premise that all exposure to ETS must be eliminated, again without any supporting data. It also ignores the contribution of many other sources to indoor air quality problems. One study6/ indicates that the main sources of exposure to benzo[a]pyrene, one of the carcinogens found in carbonaceous smoke, can be outdoor air and food even in homes with smokers. Statements also are made that ETS particles remain in a space "several hours" after smoking has stopped. No study is cited to support this statement. If ETS particles "cling to room surfaces" as stated, then they are not available to breathe; resuspending particles from a surface is not easily done. Finally, there is no support for the statement that people "will often still be exposed to ETS particles and gases" hours after the space has been used by smokers. This occasionally may be true of trace amounts of nicotine vapor but in concentrations far too low to have even arguable health effects. CONCLUSION Chapter 5 of the Workplace Guide is premised on the unsupported assertion that ETS in the workplace must be eliminated completely to safeguard health. In addition, the 6/ Lioy, Paul L., et al.: The total human environmental ~ exposure study (THEES) to benzo(a)pyrene: Comparison of the inhalation and food pathways, Arch. Environ. Health 43:304-312CA (1988). ~ ~ m

6 Guide shows little understanding of the operation of proper ventilation systems in reducing exposure to ETS as well as other indoor air contaminants. As ASHRAE Standard 62-1989 recognizes, 20 cfm/person of fresh air is adequate to address the typical levels of smoking found in the workplace.