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HHI-L)-1 li ) , -ii Da,mn( r,at % L,tnr f,jirtav Air;;rnia ??O3U • IBI Healthy Buildings IntemaoonaLlnc. A CRITIQUE OF THE PUBLIC REVIEW DRAFT "ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES" ISSUED BY THE INDOOR AIR DIVISION OF THE OFFICE OF AIR AND RADIATION, U.S. ENVIRONMENTAL PROTECTION AGENCY Healthy Buildings International, Inc. 10378 Democracy Lane Fairfax, Virginia 22030 Healthy Buildings International, Inc. (HBI), formerly ACVA Atlantic, has specialized in the study and assessment of indoor air quality in commercial buildings since 1981. Since then, we have diagnosed problems and specified solutions in over 63 million square feet of space entirely representative of the workplaces in which decisions concerning smoking policies ar •3king place. We consequently have amassed a very large database on those factors that most influLace air quality in these buildings. Environmental tobacco smoke is frequently raised as an issue during the course of our building inspections. We therefore have become very familiar with levels of ETS in these environments, as well as with the various control options and policies being considered by workplace occupants. We feel well qualified, then, to comment on some aspects of the draft EPA policy guide, in particular on levels of ETS as measured in typical workplace environments (Chapters 1 and 2, Part I) and on technical and political issues connected with smoking policies (Parts II and II1). We will not comment extensively on the health issues raised in the current draft (Chapters 3 and 4, Part I) beyond noting a very serious concern with respect to the acute effects that the draft erroneously attributes to ETS. Introduction The first paragraph in the Guide's Introduction states that "field studies, controlled experiments and mathematical models have shown that ETS is one of the most widespread and harmful indoor air pollutants and is a major contributor to particulate indoor air pollution." This statement is not supported by any specific references. In fact, there are very few credible databases of knowledge where consistent methodology has been used to identify, rank and characterize the building contaminant sources that actually are the cause of occupant problems. Those of which we are aware either mention ETS as a minor (less than 5%) contributorl,=, or fail to mention it at alls.4. Our own findings after examining 412 commercial buildings from 1981 to 1988 show ETS to have been the major contribution to indoor air quality problems in only 3% of the buildings studied. See Figure 1. One of the papers most frequently used to support claims that ETS is a major contributor to particulate indoor air pollution is a 1980 paper in Science by Repace and Lowreyj. This paper should no longer be used because the data are insufficient, outdated and entirely irrelevant to office environments. We will discuss the more recent and relevant data later in this review. l (703) 352-0102 (703) 352-0151 (tax)

HBI ahM &uiJuk,~ Ink~r.ttr 4 t' , . Figure 1. HBI Experience 1980-1988 Major Factors Found Database: 412 Buildings, 63 Million Square Feet Fon9I Atrbor.• Dust Low RH Bacterta HCHO ExhauatTobaceo Fum.• Contaminants VOCS High Fibrous Osono RH 01..• Simply measuring the relative percentage levels of various building contaminants, however, is not the most effective way of addressing indoor pollution problems. In our experience, a "pollutant by pollutant" approach to indoor air quality is inefficient, ineffective and naive. There is a strong, but relatively recent, movement within the EPA which corroborates this view: the concept of Total Human Exposure (THE). Forward-thinking scientists at EPA have been developing the concept based on the understanding that all pollutants to which human beings are exposed must be prioritized properly and that we must develop an understanding of the true risks to human health from W1 sources. We are seeing a proliferation of so-called "Clean Indoor Air Acts" throughout this country. Unfortunately, virtually all of these acts are simply bans or restrictions on smoking. This is a result of a single-minded focus on ETS -- the only visible component of indoor air. To quote from a recent article by Dr. Ott on the THE concepte: "If we do not know whether the right sources (or other contributors to exposure and risk) are being controlled, or whether they are being controlled by the correct amount, then our regulatory programs can be ineffective and inefficient in reducing risks." Experience certainly has shown us that simply removing tobacco smoke is no way to reduce health risks to or ensure the comfort of the building occupant; it certainly does not guarantee clean air. On many occasions, we have found that the presence of high concentrations of tobacco smoke indicate a much more serious problem. Poor ventilation and improperly maintained ventilation systems are 2

HBI Hrahfr fiuiWnr_!, IrncYi,ttr r.o the primary causes of poor quality indoor air1,2 s. When such conditions prevail, all the invisible and odorless pollutants, including those that are acknowledged to be harmful, are trapped in the indoor environment. Persistent indoor air quality complaints can be resolved only if building owners and operators are prepared to focus on air handling systems in an appropriate manner. Medicine teaches us that we should not exclusively treat symptoms; the proper approach is to eliminate the cause. The EPA document paints a nightmarish picture of just one component of indoor air. This reflects the efforts of a small number of highly motivated and well-placed individuals at the Indoor Air Division of the U.S. EPA dedicated to the elimination of tobacco smoke alone. These efforts could eclipse the vital role EPA has to play in encouraging building owners and managers to control all forms of indoor pollution by proper operation of their buildings. Good, generic engineering practices clearly are much more effective and easier to apply than wholesale human behavior modification. Part I, Chapters I and 2 What Is ETS, and MeasurinQ ETS in the Air and Body The "notes to reviewers" page of the draft policy guide requests comments on the draft's "effectiveness in communicating with a predominantly non-technical audience." In our judgement, the very first chapter of the policy guide -- like many of those that follow -- oversimplify the relevant facts to the point of inaccuracy while ignoring much of the relevant literature. As a result, the overall impression that is created is seriously misleading, particularly to the non-technical audience to which the document is supposed to communicate. The definition of sidestream smoke (SS) offered in Chapter I provides an example of this. It completely fails to mention that, once released into an indoor environment, sidestream smoke is drastically and rapidly diluted, cooled and oxidized by the atmosphere. Nobody is exposed, therefore, to sidestream smoke per se, yet much of this chapter details the results of laboratory measurements of pure SS to identify its chemical constituents and compare their concentrations with those found in mainstream smoke. This is an academic exercise. How do these measurements relate to actual human exposure to these compounds? Obviously, they relate rather indirectly if at all. It is actual human exposure to ETS (and consequent assessment of dose leading from this exposure) that is important. Indeed, there remains a real need for more data on ETS exposure. EPA scientists specifically are calling for more work on ETS in office buildings (amongst other THE micro- environmental research needs). To quote Dr. Ott once more6: "without accurate knowledge of human exposure or dose, often it is impossible to determine which sources should be controlled and by how much. Filling this critical gap in the complete risk model is necessary to implement a 'risk-based' approach to environmental management. Completing the risk model requires determining if traditional source control efforts actually are reducing the risks to health in the manner intended and to the extent needed " The second chapter examines actual exposure by discussing some but not all of the pertinent monitoring studies to date. The selection of monitoring studies the authors have made, however, reflects serious shortcomings. They mention that approximately 50 studies of ETS in buildings have been conducted. In addition, the document by its own terms is focused exclusively on smoking in the workplace. It therefore is puzzling that the studies the authors chose to mention were performed almost exclusively in the home. The only measurements referred to in the document that were not taken in the home were done in bars, restaurants, bus stations, airplanes and office smoking lounges. This is both irresponsible and misleading. Hundreds of much more recent measurements of RSP, nicotine, and other constituents of ETS have been made in office environments that are the subject 3

H& hkealtlr Bwiunht, In4r,.mMc;, of this document. Very few of these measurements show RSP in areas where smoking is discretionary at the levels described in this document. Our own measurements in different office environments, for instance, show mean RSP levels in both designated and discretionary smoking areas of 46 µg/ms in 331 offices and levels of 20.1 µg/ms in 254 non-smoking areas. These measurements were taken in a total of 585 office environments using identical methodology in each. At each site detailed information was collected which included the following: Room size Number of occupants Number of cigarettes smoking per hour (if any) Carbon dioxide concentrations (integrated over one hour) Carbon monoxide concentrations (integrated over one hour) Respirable suspended particulates (integrated over one hour) Nicotine (integrated over one hour) With such a large sample, this information is allowing us to conduct a detailed statistical examination of the relationships.between smoker density and RSP, nicotine and carbon monoxide. The spread of smoker densities obtained is allowing us to go further than just classifying areas as "smoking observed" and "no smoking observed", but to provide statistically valid data on the ability of real office ventilation systems to deal with varying smoking loads. Some of the initial findings are as follows: a) There is a strong relationship between RSP and nicotine. b) There is a relationship between RSP, nicotine and smoker density, although levels of RSP and nicotine do not rise substantially out of the "no smoking observed" data set until relatively high smoker densities are observed. c) There is a very slight increase in carbon monoxide concentration with smoker density, but even in the heaviest smoking areas, carbon monoxide levels do not breach the EPA ambient maximum limit of 9 ppm. In fact, they rarely rise above 4 ppm. d) There appears to be a weak relationship between room size and presence of smoking. Rooms in which smoking occurs tend to be smaller than rooms in which no smoking is observed. Overall, this leads us to the not surprising conclusion that levels of carbon monoxide, RSP and nicotine rise significantly above background "no smoking" levels primarily in cramped rooms used for heavy smoking. Another published survey of office environments found mean RSP levels of 37 µg/ms in smoking- permitted areas7. No reason is given in the draft policy guide for EPA's ignoring reports such as these, and none is apparent to us. In fact, Miesner's paper8 (reference #29 and 31), which is cited, describes five office measurements where smoking was discretionary, producing results that are both consistent with our and other workplace monitoring studies and inconsistent with the largely irrelevant or outdated reports that are cited in the policy guide. RSP in the offices studied by Meisner varied from 16.2 µg/ms (smoking in nearby offices) to 80.0 µg/ms, with a mean of 33.8 µ8/ms• The measurements the draft policy guide has chosen to report appear to refkct bias on the part of the authors. Repace and Lowery's 1980 study, "Indoor Air Pollution, Tobacco Smoke and Public Health"a, serves to a large extent as the backbone of the policy guide. In this ten-year-old paper, the only in- office measurements which were made were under experimental conditions in a 113 m3 room where 4

ti& FkahM Bwk1u,_, Intcr „t, .. artificially high levels of ETS were generated by a relay of seven smokers consuming 32 cigarettes in 49 minutes, giving RSP values as high as 500 µg/ms (using the same instrumentation as used in our surveys, incidentally). The only comparison of smoking and non-smoking environments was by contrasting RSP levels in the following locations: SMOKING 7 NON-SMOKING Unventilated room (cocktail party) Church Sunday service Lodge hall Sandwich restaurant A, non-smoking section Bar and grill Fast food restaurant Firehouse bingo game Sandwich restaurant B, non-smoking section Pizzeria Church bingo game Inn Bowling alley Hospital waiting room Shopping plaza restaurant (2 samples) Barbecue restaurant Sandwich restaurant A, smoking section Fast food restaurant Neighborhood restaurant/bar Hotel bar Sandwich restaurant B, smoking section Roadside restaurant Obviously, the Repace and Lowrey paper involves no carefully controlled situations permitting smoking and non-smoking areas to be compared in a way that is meaningful. Indeed, the paper offers no guarantees at all of similar production of non-ETS derived RSP between the smoking and non- smoking areas. The references most suitable in an impartial review document would be measurements taken in modern offices where typical levels of RSP in smoking-permitted areas can be compared with levels of RSP in non-smoking areas. Clearly, such measurements are available. ETS levels in airlines also are briefly touched upon in the draft policy guide. Since the Department of Transportation has just released, at great expense, a comprehensive study on airline air quality°, it would make sense to utilize this data as the primary reference. The DOT study found RSP levels in smoking sections of aircraft to be less than a fifth of that claimed in the reference currently cited. Furthermore, levels of carbon dioxide, which were used as in indicator of ventilation, averaged 1,500 ppm, clearly showing the need for better ventilation in passenger aircraft. Scott Baker, one of the 5

HBI Healttr BwkLrka Ii:k ;L~u g,, authors of this study, presented the work at the Brookings Institution Society for Risk Analysis recently, with the comment that "the risks from exposures to ETS are not terribly significant."to Baker's results are consistent with those of other studies.tt,ts,ts In summary, based on our own sampling of workplace environments and on our awareness of current literature on indoor air sampling for ETS, we think the section on air monitoring studies should be revamped with newer, more relevant studies to better reflect the levels of ETS found in typical U.S. office spaces. Chanters 3 and 4 Health Effects of ETS, and How BiQ is the Risk from ETS? Acute Effects Our role in the indoor air quality field focuses on building diagnostics, remedies and consulting on proactive maintenance with building operators and owners. We have much experience with occupants complaining of acute respiratory problems. Such symptoms as eye and nose irritation, fatigue, coughing, rhinitis, nausea, headaches, sore throats and general respiratory problems are typical. Our clients frequently assume that these symptoms are due to ETS. Identical symptoms can be found, however, in individuals exposed to formaldehyde, sulphur ox: . s. ammonia, oxides of nitrogen, and ozone. In addition similar symptoms are reported by individuais with allergies to specific fungi such as aspergillus, cladosporium, and penicillium, among others, as well as to miscellaneous bacterial aerosols. Overlapping symptoms also can be caused by exposure to household dusts, cotton fibers, fiberglass fragments, etc. In addition, similar problems are encountered due to low relative humidities. Unfortunately, of all these factors, only ETS is visible, and public perception as to the true causes of these acute symptoms is often warped as a result. Parts II and III ETS: The Solutions, and Case Studies The ASHRAE 62-8914 standard on ventilation rates clearly states that an air exchange of 20 cfm per person in areas where smoking is discretionary will deal adequately with "moderate amounts of smoking." The draft policy guide completely ignores this component of the ASHRAE standard, even though the standard was adopted by consensus after careful consideration by a large professional body of architects, engineers, health officials, consumer organizations, medical researchers, and building owners and operators. We are at a loss to understand why no mention was made of this since it is so germane to the issue at hand. Although the 20 cfm standard should be used primarily as a practical comfort standard, the standard does state that it "reflects recognized consensus criteria and guidance" with respect to health effects. Our experience corroborates the experience and conclusions of ASHRAE. In 63 million square feet of indoor air quality studies, complaints of comfort problems associated with ETS are extremely uncommon at 20 cfm per person outside air (O/A), where it is found. Before the ASHRAE standard is junked because of claimed health effects of moderate ETS generation diluted by 20 cfm O/A per person, we need better evidence; either risk assessments based on actual exposure measurements, or epidemiological evidence from modern day offices ventilated to 20 cfm per person. By contrast, the health risk assumptions used in the EPA policy guide for spaces ventilated at 20 cfm are based on theoretical calculations, not on practical measurements of exposure to ETS in modern office environments ventilated to 20 cfm per person. 6

HBI Ht21dn fiwlt7uh httc, .rtxw:• Both occupant comfort and ETS health risks, if any, are likely to be improved considerably if efforts first are made to comply with the ASHRAE standard to ensure the reduction of all airborne contaminants in buildings. Unfortunately, the draft policy guides places no emphasis on ASHRAE standards and their value in maintaining good indoor air quality. Yet we have found that 62% of buildings investigated to date are not complying with this standard, compared with NIOSH findings of approximately 50%. Chapter 5 of the EPA document is titled, "Reducing Exposure to ETS." We think compliance with the ASHRAE standard is the single most important and practical step building owners, employers and policy makers can take to reduce exposure to ETS. The chapter continues with a review of other methods of ETS control. We will briefly comment on each one. ProhibitinQ Smokina Indoors Many proposed smoking bans originate with building occupants who attribute irritation to ETS. Unfortunately, as we have mentioned, virtually every other common indoor pollutant -- including ozone, formaldehyde, oxides of nitrogen, aeroallergens, fungi and bacteria -- give precisely the same irritative effects as high levels of ETS, but of all these, only ETS is visible. Thus, focusing on ETS alone, while paying no attention to ventilation or other aspects of building hygiene, is to miss the entire forest for a single tree. Attempts to solve a tobacco smoke problem alone without dealing with ventilation as a whole could leave significant environmental problems unsolved. An example of an entirely misplaced smoking ban is provided by a major bank headquarters building studied by HBI. An occupant questionnaire commissioned by the management discovered many indoor air quality complaints and led to a proposed smoking ban. On investigation of the building, however, the HVAC system was found to be operating on 100% recycled air, with the fresh air dampers closed. Even with the dampers open, the system was capable of delivering only 2 to 5 cfm fresh air per occupant. The filters were found to be inefficient and excessive fungal growths were found inside the ductwork with correspondingly high numbers of their spores in the air of the office area. Once ventilation, filtration and hygiene were improved, complaints were reduced and the proposed smoking ban was found to be unnecessary. Ironically, the ban would have hidden the only visible evidence of the true causes of indoor air problems in this building. Senarate Smoking Lounges with Separate Ventilation This involves the designation of smoking areas in buildings and the retrofitting of exhaust systems to those areas. When properly installed, the advantages to this system are clear. No re-entrainment of ETS into the return system of the building is permitted and minimum overall air movement is required. The key is careful design. Poor design can create, of course, serious problems, such as over-pressurized ceiling voids, unbalancing of the main air handling system and short-circuiting of the exhaust outlet into fresh air intakes. The comments made in the draft policy guide inadequately anticipate these kind of problems, although we agree that the appropriate ventilation rate for such smoking lounges should be 60 cfm per person. The inference which follows, however, that in ordinary office areas (not designated for smoking). 20 cfm per person is "inadequate to effectively reduce the level of ETS when smokers are present" should be removed. This flies in the face of all the accepted work ASHRAE's Standards Committee have done on this topic. It also is inconsistent with the substantial air quality monitoring literature that exists. 7

HBI Hc21th. Bwklirrti InlrnLU, 4.,, ; Senarate Walled Areas for Smokers and Non-smokers with a Shared Ventilation System This is often a politically practical solution that balances the wishes of both non-smokers and smokers. With some thoughtfulness in the selection of the smoking areas, and by taking prevailing ventilation conditions into account, the policy of designating smoking areas works very satisfactorily. The only problems we have found with designated smoking areas, even without separation by walls or partitions, have been due to carelessness. Toilet or corridor areas are sometimes designated as smoking areas by management despite ventilation systems not designed to be used in such a manner. In a properly ventilated building, however, designated smoking areas may not be necessary or desirable. In a large building served by many air handling units, such policies concentrate all the smokers into an area served by only one unit. The capacity of this unit to dilute this more concentrated smoke load can be exceeded, delivering more, not less, ETS to non-smokers also served by this unit. Under those circumstances there may be evidence of ETS in non-smoking areas. HBI has measured nicotine levels in hundreds of buildings across the U.S. Where smoking is evenly distributed through -a building, nicotine levels in non-smoking areas very rarely are above the detection limit of the method used. Our work shows, for example, that permitting smoking only in individual offices as well as in selected common areas usually results in negligible exposure to ETS in non-smoking areas. Evidence of this can be found in the paper by Williams et a11b, referred to in the draft policy guide (reference 73). They use a method with an apparently very low detection limit to measure a maximum nicotine level of approximately 0.3 µg/ms in non-smoking areas close to smoking areas. The pap.:r goes on to measure a claimed 0.013 µg/ms of nicotine in an office originally containing smokers seven days after a smoking ban. The ETS represented by this minuscule amount of nicotine is very unlikely to be sensed by building occupants, let alone be responsible for any health effects. To put this measurement in perspective, this value is approximately one half of the lowest detection limit (eight hours sampling) of EPA's own standard method IP-2A16 for determining nicotine in indoor air using XAD-4 absorbent tubes. Separate. Unwalled Areas for Smoking and Non-smokinst Since many buildings are not being operated at proper ventilation rates, the policy of grouping smokers together in one portion of a room actually may further increase levels of ETS in that room as the ventilation system struggles to deal with the uneven smoking load. The problem is further exacerbated by policies that are based on political instead of practical considerations. The management of a building may decide to designate one portion of a cafeteria for smoking, not understanding the design or operation of the air supply and return system in that space. HBI has found that ETS exposure in non-smoking areas of cafeterias that share smoking zones is kept to a minimum if the smoking area is located closest to the main return inlet, even when this is located above an evenly perforated false ceiling. We also note a paragraph on page 24 which speculates that time-separating smokers and non-smokers will not sufficiently reduce ETS concentrations. No published work is referenced to support this speculation, nor does our experience support it. As is the case where smokers and non-smokers share a common ventilation system, some components of ETS will only be measurable with the most sensitive instrumentation, and we are not aware of any convincing evidence of health or comfort problems at such minuscule ETS levels. One of the most disappointing aspects of the draft policy guide is relegation of the heading "Examining Your Ventilation System" to a self-confessed "sidebar " As we have insisted over some nine years, proper examination and maintenance of a building's HVAC system are absolute prerequisites if good indoor air quality is to be achieved. Major flaws in HVAC system operation and 8

HBI Hc2hfn &nklur_tiln~c~n~w.;. maintenance should be corrected before indulging in occupant shuffling, smoking bans, questionnaire exercises or a myriad of other "social engineering" practices. These practices often do nothing beyond attempting to mask the true causes of poor air quality, which are usually inadequate ventilation, inefficient filtration, and poor hygiene. This section should be rewritten, expanded and given much greater prominence in this document, since it is the key to reducing public exposure to all forms of indoor pollution, not just those that are visible. In summary, we are deeply disappointed by the draft policy guide. Many other EPA publications, such as those issued on radon, asbestos and lead in water, contain carefully written, balanced discussions of the pertinent issues with options for mitigation laid out in a manner clear both to the scientific and consulting community, as well as the public at large. Unfortunately, it appears that this document was conceived at the outset simply as an opportunity to present a case for outright banning of smoking from indoor work environments. As a consulting company, we were hoping for a more balanced product that we could use in guiding our clients towards solutions to indoor air quality problems as a whole, and ETS mitigation in particular, that suits their particular concerns, needs and circumstances. We hope that the next draft of this document will pursue that goal. 9

HBI Hcahtn &uklu ~ InLL, ,:u ~. , REFERENCES 1. Melius, J., Wallingford, K., Keenlyside, R., Carpenter, J. (1984) Indoor Air Quality -- The NIOSH Experience. Ann Am. Conf. Gov. Ind. Hyg., Vol. 10. 2. Robertson, G. Source, Nature and Symptomology of Indoor Air Pollutants (1988). Indoor and Ambient Air Quality, Selper, London, pp 311-319. 3. Rask, D.R., Lane, C.A., Bosmon, T.A., Putnam, V.L. Environmental Stressors and System Deficiencies Identified in Problem Office Buildings (1990) AWMA 83rd Ann. Conf. June 24-29, Pittsburgh. 4. NIOSH (1989) Evaluating Building Ventilation for Indoor Air Quality Investigations, National Institute for Occupational Safety and Health, Cincinnati, Ohio. - 5. Repace, J.L., Lowrey, A.H., (1980) Indoor Air Pollution, Tobacco Smoke and Public Health. Science, Vol. 208, pp. 464-472. 6. Ott, W.R. (1990) Total Human Exposure: Basic Concepts, EPA Field Studies, and Future Research Needs. J. Air Waste Manage Assoc. Vol. 40 No. 7 pp. 966-975. 7. Sterling, T.D., Collett, C.W., Sterling, E.M. (1987) Environmental Tobacco Smoke and Indoor Quality in Modern Office Work Environments. J. Occupational Medicine, Vol. 29, No. 1, pp. 57-62. 8. Miesner, E.A., et. al. (1988) Report to the U.S. Environmental Protection Agency, Cooperative Agreement No. CR813526-01-0, Harvard School of Public Health. Also, JAPCA Vol. 39, pp. 1577-1582 (1989). 9. Nagda, N.L., Fortmann, R.C., Koontz, M.D., Baker, S.R., Ginevan, M.E. (1989) Airliner Cabin Environment Contaminant Measurements, Health Risks, and Mitigating Options. Report to U.S. Dept. of Transportation No. DOT-P-I 5-89-5. 10. Baker, S.R: (1990) Health Risks to Airliner Occupants: Exposure to Environmental Tobacco Smoke and Other Pollutants. Presentation to ILSI Risk Science Institute, Brookings Institution Society for Risk Analysis, June 14, 1990. 11. Malmfors, T., D. Thorburn and A. Westlin (1989) Air quality in passenger cabins of DC-9 and MD-80 aircraft, Environ. Technol. Letters 10: 613-628. 12. Holcomb, L.C. (1988) Impact of environmental tobacco smoke on airline cabin air quality, Environ. Technol. Letters 9: 509-514. 13. Muramatsu, M., S. Umemura, J. Fukui, T. Arai, and S. Kira (1987) Estimation of effect of environmental tobacco smoke on air quality within passenger cabins of commercial aircraft, Int. Arch. Occup. Environ. Health 59: 545-550. 10