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THEODOR D STERLING AND ASSOCIATES LTD COMMENTS ON THE DRAFT REPORT BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY "ENVIRONMENTAL TOBACCO SMOKE: A GUIDE TO WORKPLACE SMOKING POLICIES" Submitted to: PROJECT OFFICER FOR ETS POLICY GUIDE Indoor Air Division (ANR 445)) Environmental Protection Agency 401 M Street, SW Washington, D.C., 20460 Prepared by: ELIA STERLING AND CHRIS COLLETT Theodor D Sterling and Associates Ltd. 20-1507 West 12th Ave. Vancouver, B.C., V6J 2E2 m ~ O? C!1 September 24, 1990 ~. ~ ~ ~ 20 • 1507 WEST 12th AVENUE, VANCOUVER. BRITISH COLUMBIA, CANADA V6J 2E2 (604) 733-2701 FAX (604) 733-9385

EXECUTIVE BUMMARY The U.S. Environmental Protection Agency released "Environmental Tobacco Smoke: A Guide to Workplace Policies" for public review on June 25, 1990. The Guide, along with a companion document "Health Effects of Passive Smoking: Assessment of Lung Cancer in Adults and Respiratory Disorders in Children," were transmitted to a Science Advisory Board (SAB) for comment. The EPA has requested reviews for technical accuracy, completeness, and effectiveness in communicating with a predominantly non-technical audience. As requested in the "Note to Reviewers," we have reviewed the EPA "Guide to Workplace Smoking Policies." Our comments are based on extensive research experience related to environmental tobacco smoke (ETS) in a variety of built environments. (See Appendix Three for resumes and publications of both authors.) Of particular relevance to this review is an examination of the issues surrounding the development and implementation of smoking policies that we conducted for Labour Canada, a department of the Canadian Federal Government, in 1987. Relevant parts of that research are attached: a User's Guide for the development and implementation of workplace smoking policy (Appendix One); and a survey of Canadian organizations which have implemented smoking policies (Appendix Two). The EPA Guide has been written to meet two objectives: 1. To help the non-expert understand the technical basis for smoking restrictions. 2. To provide guidelines for implementing smoking policies. Our review examines the EPA Guide in relation to both of these objectives. As requested in the "Note to Reviewers", we have focussed our comments upon technical accuracy, completeness and effectiveness in communicating with a predominantly non-technical audience. EPA OBJECTIVE ONE * We find that the EPA Guide contains a large number of inaccuracies resulting from a) misquoting of cited references; b) selective use of reviewed data; and c) lack of consideration of confounding factors. However, of greatest concern is the apparently intentional omission of references and data that do not agree with the premise of the Guide. * We find that the EPA Guide has been prepared under the assumption that ETS is a Group A Carcinogen. This assumption is based on the conclusions of an EPA risk

assessment that is still under public review, and has not yet been accepted. The risk assessment document is also being reviewed by the SAB. By preparing the EPA Guide prior to the final acceptance of the risk assessment, the EPA assumes that the risk assessment will be accepted "as is." The EPA appears to view both public review and SAB comment as a"rubber stamp" for proposed policy. * We find that the EPA has confused Sick Building Syndrome with Environmental Tobacco Smoke. Extensive research has shown that the most prevalent cause of occupant symptoms in sick buildings has been "inadequate ventilation." Tobacco smoke has been shown to be only a minor cause of these symptoms. EPA OBJECTIVE TWO * We find that the EPA Guide displays an appalling lack of understanding about mechanical systems in buildings and current ventilation standards. Since inadequate ventilation is the most common cause of sick buildings, it would appear that the EPA should be conversant with mechanical systems and building systems operation. At the very least, the EPA should be aware of the current ASHRAE Ventilation Standard 62-1989. * We find that the EPA Guide presents only scant information that is not sufficient to guide the practical implementation of a workplace smoking policy. Since this guide is intended for use by a non-technical audience, the lack of information makes this document of little or no use in developing and implementing workplace smoking policies. In conclusion, we find the EPA Guide to be inaccurate and incomplete with respect to the technical information. The document is, however, effective in communicating a particular viewpoint. The methods used are more common to advertising than to science. The authors of the EPA Guide, in addition to misquotes and omissions, repeat statements that are scientifically controversial in the hope that the non-technical audience will be convinced by the statements. For example, the "fact" that ETS is a Group A Carcinogen is repeated four times. Due to these questions of technical credibility and insufficient information, the EPA Guide does not fulfill its two stated objectives. Further, as there are numerous organizations that already have produced guidance documents for workplace smoking policies, this EPA Guide is of little or no use to the audience for which it is intended.

1 1.0 INTRODUCTION The U.S. Environmental Protection Agency (EPA) has prepared a document titled Environmental Tobacco Smoke: A Guide to Workplace Smoking Policies for public review. The EPA has also prepared a risk assessment of environmental tobacco smoke titled Health Effects of Passive Smoking: Assessment of Lung Cancer in Adults and Respiratory Disorders in Children for public review. Both the EPA Guide for smoking policies and the Risk Assessment are to be transmitted to a Science Advisory Board (SAB) for comment. In this document, we provide comment upon the EPA Guide to Workplace Smoking Policies. Our comments are based on extensive research experience related to environmental tobacco smoke (ETS) in a variety of built environments. For example, we conducted an examination of the issues surrounding the development and implementation of smoking policies for Labour Canada, a Federal department of the Canadian government, in 1987 (Sterling et al, 1987). We have also conducted indoor environmental evaluations of more than 350 buildings worldwide, many of which included measurement of constituents of ETS, and have organized and participated in international conferences and symposia focussing on ETS. The results of our research have also provided input into the development of standards for the measurement, assessment and control of exposure to ETS and other indoor air constituents, through committee work with organizations such as the American Society of Heating, Refrigerating and Air Conditioning Engineers

2 (ASHRAE), the American Society for Testing and Materials (ASTM), and the Canadian General Standards Board (CGSB). 2.0 APPROACH The EPA Guide has been written to meet two objectives (page 2, paragraph 6): 1. To help the non-expert understand the technical basis for smoking restrictions. 2. To provide guidelines for implementing smoking policies. This critical review examines both objectives. Specific comments regarding the first objective are more extensive than those related to Objective Two because the EPA Guide is heavily weighted towards the justification of the technical basis for smoking restriction. The first 20 pages of the EPA Guide provide the reader with information about the chemical composition of ETS, how ETS can be monitored, the health effects and the risks attributable to nonsmokers exposure to ETS. In the remaining sections of the EPA Guide, only four pages are directly devoted to providing the Itnon-eupertll* reader with information for policy development and implementation (pages 33 to 36). Additional information is presented on methods for reducing ETS exposure, workplace regulations, litigation and cost *Direct quotes from the EPA Guide are shown in bold text throughout this critical review.

3 savings. The final part of the EPA Guide presents anecdotal case studies of organizations that have instituted smoking policies. 3.0 OBJECTIVE ONE: THE TECHNICAL BASIS FOR BMORINa POLICIES Our comments on the technical basis for smoking regulation are discussed under three headings: 1. Misinformation. 2. Acceptance of the EPA Risk Assessment. 3. Relationship between ETS and the Sick Building Syndrome. 3.1 MISINFORMATION The EPA Guide contains a large number of inaccuracies resulting from (a) misquoting of cited references; (b) selective use of reviewed data; and (c) lack of consideration of confounding factors. 3.1.1 Misquoting of Cited References Chapter 2 includes a section titled "Air Monitoring Studies$' (page 12). Much of the information for the section (particularly paragraph 3) is taken from EPA reference #28: Samet et al, 1987. This article by Samet et al is a review of the health effects and sources of indoor air pollution, with a section devoted to ETS. The article does not contain original data, but is a secondary source.

4 The data reported in the EPA Guide (page 12, paragraph 3) do not agree with the data reported by either Samet et al, or the original research by Spengler et al, 1981 (EPA reference #27) from which the data were taken. The EPA Guide states that "each smoker generates 25 to 35 micrograms of R8P per cubic meter of air (µg/m3).1' However, Samet et al (in their review of Spengler et al) note that "a smoker of 1 pack of cigarettes daily contributed about 20 µg/m3 to 24-hour indoor particle concentrations." This, in turn, is different from the information contained in Spengler's original work, which states that cigarette smoke contributes approximately 20 µg/m3 to the indoor concentrations for each smoker. (Note: the number of cigarettes smoked was not quantified.) There is further contradiction within the Spengler et al report: the main text states "on the average, one smoker in the home raises the mean indoor MRP (Mass Respirable Particles) by 12 µg/m3." Clearly, the information presented in the EPA Guide is not in agreement with the original research which it (indirectly) quotes. The problem of misquoting continues when the EPA Guide states that I'Homes with two or more heavy smokers frequently exceed the federal 24-hour outdoor particle standard of 260 µg/m3,•' again citing the article by Samet et al. There are a number of errors within this one statement:

5 a) The standard referred to is a National Primary Ambient Air Quality Standard for Outdoor Air set by the EPA. However the 24-hour standard of 260 µg/m3 is for total particulate matter, not respirable particles. b) The Samet et al article from which this information is cited states that the standard of 260 µg/m3 could be exceeded, not that it is "frequently exceeded." c) The Samet et al article incorrectly reviews the original research and refers to "heavy smokers." The EPA Guide uses the same term. However, Spengler et al do not define "heavy" smokers but instead refer to homes with two or more smokers (i.e., they do not quantify the amount of smoking). d) Spengler et al do not make a comparison between 24-hour mean data and ambient standards. However, in the review by Samet et al, such comparisons are made, which are then repeated by the EPA Guide. Inaccurate quotation continues with the statement "In homes with heavy smokers, short-term particulate concentrations of S00 to 1,000 µg/m3 are not uncommon" (page 12, paragraph 3). This statement is not based on objective data. Samet et al speculate that because cigarettes are not smoked uniformly over a day, peak concentrations must occur, and suggest that "concentrations of 500 to 1000 µg/m3 are likely at the time when cigarettes are OD ~ actually smoked." Somehow, the authors of the EPA Guide have ~ ~ ~ W ,ia

6 translated this speculation into the objective fact that such levels are "not uncommon" in homes! In summary, it is apparent that many of the statements made about high RSP levels in homes are based on inaccurate review of previous research, rather than on real data. Irrespective of these inaccuracies, it is not inconceivable that there could be higher levels of RSP in the homes of smokers, for reasons other than smoking. Sterling and Weinkam (1990) have demonstrated that the patterns of smoking, occupation and social class are confounded. For instance, there is a higher prevalence of smoking among blue collar workers than among professionals. In addition, Sterling and Weinkam pointed out that blue collar workers may bring more dust home on work clothing, their homes may be located in more polluted areas, and may be smaller, less ventilated and have more occupants than other households. Therefore, it may not be unreasonable to find more dust in these homes occupied by smokers. 3 1 2 Selective Use of Information In addition to incorrect quotation to what research data actually show, the EPA Guide selectively uses information to highlight the contribution of ETS to air quality in buildings. For example, the EPA Guide states that •lThe highest RSP levels were found in designated smoking areas, where the level of RSP correlated with the number of cigarettes smoked$' (page 12). Two references are cited for this statement (EPA Reference #30: Repace and Lowrey,

7 1980 and 1982; EPA Reference #31: Miesner et al, 1988). Since Repace and Lowrey did not take RSP measurements in designated smoking areas, the above comment must relate to the work by Miesner et al (1988). This research is cited as an unpublished report to the EPA. However, the data of Miesner et al have been published elsewhere (Miesner et al, 1988a; 1989). The authors of the EPA guide have selected specific portions of data from Miesner's research to highlight (perhaps even to exaggerate) the impact of smoking on RSP levels. For example, the EPA Guide states 11One office building had RSP levels of 11 µg/m3 in its nonsmoking offices and 520 µg/m3 in a smoking lounge.$' Miesner et al also report RSP measurements in other nonsmoking areas in the study building. However, the EPA Guide only reports the lowest RSP concentration (11 µg/m3), whereas RSP levels elsewhere ranged from 12.5 to 20 µg/m3. Similarly, the EPA Guide reports only the highest RSP level measured in a smoking lounge (520 µg/m3), while the original data show RSP concentrations in other smoking lounges as low as 114 µg/m3. Interestingly, Miesner et al also measured RSP levels in nonsmoking areas, finding RSP concentrations as high as 157.3 µg/m3, showing that ETS is not the only source of RSP levels in public buildings. Further review of the data presented by Miesner et al (1988a, 1989) suggests that the elevated RSP concentrations found in the one smoking lounge (520 µg/m3) may have resulted from poor ventilation. Miesner et al note that indoor C02 levels in the