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UNITED STATES ENVIRONMENTAL PRC)TECTION AGENCY ENVIRONMENTAL TOBACCO ISMOKE: A COMPENDIUM OF TECHNICAL ]:NFORMATION COMMENTS OF THE TOBACCO ]:NSTITUTE February 5, 1990 Reviewers' Statements 1

Comments on Chapter 3 Prepared by: Dr. Deborah L. C. Kay Dr. James C. Walker Dr. Daniel B. Kurtz We have reviewed chapter 3, titled "The Odor and Irritation of Environmental Tobacco Smoke", by William S. Cain and feel that modif'.,cations in the document should be made in order for it to be scientifically credible and of optimum value for the stated audience, i.e., labor and management afficials concerned with workplace exposures, public health officials and corporate medical directors concerned with making health policy recommendations, educators, industrial hygienists and safety officers, ETS researchers, indoor air pollution investigators and legislators who are considering legislation to restrict smoking in.workplaces, restaurants, and public access buildinE;s. After reviewing the chapter, we were left with four general impressions: i. the author leads the reader to a number of conclusions regarding standards for ventilation in "real world" environments but: these conclusions rest entirely on a methodology for which the reli3vance to "real world" situations has not been demonstrated; ii. assuming this work is intended as a major review of studies in the area of odor and irritation of environmental tobacco smoke, we feel that many major and significant studies in this area were Dmitted; - iii. the chapter would be much improved if it placed ETS in some balanced prospective within the overall area of indoor air quality. iv. many statements in the paper are not clear. This first criticism is the most significant since a nuriber of these unsupported conclusions are assembled here to lead the reader to the implied conclusion that odor and irritation from ETS is a problem in real worLd environments, of such magnitude, that it requires measures more aggressive than simply adherence to recommended ventilation guidelines. We have detailed below a number of specific criticisms to illustrate our objections: 1. In paragraph 2 of the Introduction, the statemenl:s are made that "smoking has traditionally been pervasive" and "has accordingly received special• attention". We feel that these statements are simply unclear. If the intent is to "explain" the history of ETS concerns, at least two factors should be considered. These factors are: i. the tendency for buildings to be poorly ventilated consequent to the energy crisis of the mid 1970's (see e.g. Skov et al., 1987, Robertson, 1988, 1989); ii. the publication of a number of epidemiological studies (e.g. Uberla, 1988 and Hirayama, 1981, 1987) purporting to demonstrate a link between exposure to ETS and cancer. More recently, attention has been given to the ETS issue due to the report of the Surgeon General (1986).

Comments on EPA ETS compendium 2. In paragraph 3 of the Introduction, the statement is made that "a chemical analysis of ETS-containing air offers little o:` practical significance regarding the origin of its, odor or irritatiun". This statement is contrary to the recent recommendations of the Cortnnittee on Passive Smoking et al. (1986). This group pointed out that one of the key goals of future scientific research information should be a better understanding of the relationship between the chemical composition of ETS and its sensory properties. Understanding the relationship between ETS chemistry and human responses to ETS could aid air cleaner and veni:ilation system design. Finally, in the last paragraph of the Introduction, the author appears to contradict his dismissal of the importance of understanding ETS chemistry when he raises questions about the relative importance of the vapor and particulate phases of ETS for its sensory impact. 3. The second segment of the document is titled "Ventilation Requirements Based on Responses of the Visitor". This segment and the one to follow ("Responses of Occupants") need an introductory paragraph explaining to the reader the reasons for the experimental approach that investigators have taken to studying the sensory impact of ETS. In this paragraph the author could discuss the need for controlled environmental chambers and the need for a-distinction between visitors and occupants. Cain should discuss more extensively the work of other scientists who have emphasized: i. understanding the relationship between ETS cunstituents and irritation (Hugod et al., 1978, Weber-Tshopp et al., 1977a, 1977b, Marquardt e a ., 1986); 1A ii. investigating non-verbal physiological responses to ETS in an attempt to develop objective measures of the impact of ETS, e.g. Claussen et a., 1984, Muramatsu et a., 1983, Weber (or Weber-Tschopp) e al., 1976a, 1976b, 1978, 1979a, 1979b, 1982, 1984a, 1984b, Walker et a ., 1989); iii. studying the role of social factors as detezminants of the appraisal of ETS (Winneke et al., 1984). These other approaches should be discussed amply, since they address issues ::elated to the general question of the relevance of these kinds of experiments for understanding the role of ETS in indoor air quality in the real world. Equally important as an orientation of the re:ader to the methodology employed in chamber/sensory studies is a discuss::on of the ETS levels used in the sensory/chamber studies as compared to those found in the "real world". We are not aware -of any field study demonstrating significant le,vels of dissatisfaction among occupants of, or visitors to, "real world" smoking environments where proper ventilation practices are followed. If the author of this chapter is aware of such material, it should definitely be included. (We are aware of the paper by WebE:r et al.(1979a) in which laboratory studies of sensory responses to sidestream smoke (not true ETS) were related, using CO concentrations as a "bridge" marker, to sensory evaluation of ETS in a restaurant). Failing such a direct comparison between laboratory and field, the more appropri.ate approach would be to

Comments on EPA ETS compendium examine existing data concerning levels of ETS in the field in light of the levels typically employed in chamber studies. For example, a recent presentation of results of fifteen surveys of "roal world" environments, i.e., nonsmoking sections of aircraft, restaurants and offices (Oldaker, 1989) indicated that "real world" levels of nicot:Lne averaged 5Jag/m3. In a recent study (Walker et al., 1989) nicotine le-irels on the order of 140 xg/m3 were found when 8 cigarettes/hour were smoked in an 18-m3 ~ environmental chamber. This same smoking regime xesulted in CO elevations S of 3.4 ppm. These pieces of information -allow one to place the sensory/chamber studies in some "real world" pezspective. That is, one can reasonably calculate that a "ball park" estima-:e for the mean increment in CO to be expected from the rates of smoking in typical real world settings is 5/140 X 3.4 ppm - 0.12 ppm CO. This CO level is significantly lower than the 1.5 to 2 ppm ACO level which Cain proposes as a limit. Examination of Fig. 6 in the present report or, for that matter, the literature in general, demonstrates that levels this low are almost never investigated. The simple conclusion is that the:re has been little or no examination of sensory responses to ETS at concentrations that can realistically be expected in the enviro:unent. This point needs to be emphasized in this chapter. In paragraph 1 on page 30, the parenthetic sentezce is incomplete. 4. We feel that the quoted material from Yaglou, R:aey and Coggins (1936) (Note: author order not correct in Cain's chapter) on page 30, paragraph 4 does not illustrate shifting standards and i:> not relevant. In the second paragraph of the Introduction, Cain pointed out correctly that there is a great deal of subjectivity in people's responses to ETS. While individual differences and "aesthetic criteria" a-re likely to explain some of this variation, it is misleading to omit a d::scussion of the role of epidemiological reports (well-publicized by public health officials) purporting to demonstrate adverse health effects of ETS. Isn't this development the clearest determinant of the "shifting standards" that Cain describes? 5. Page 31, paragraph 1 refers to Figure 1. In thLs figure and in several other figures in the chapter the response measu:-e from subjects that is emphasized is the proportion of subjects tt•.:at are "dissatisfied". According to Figure l's caption, this result is abtained by simply asking subjects visitors "Is the air acceptable or ur.acceptable?". While we understand that this method was used to easily translate visitors' perceptions to the ASHRAE criteria, we suggest that the author discuss the many factors which influence acceptance measures. The following are a few of our particular concerns. i.- Great care must be taken when measuring and interpreting acceptance scores, such as those presented in this chapter and in Cain (1983). As demonstrated by Sheen and Drayton (1988) subjects' mental set plays a very important role in the scores. This mental set could be affected by social setting and the subjects's emotions. Therefore, one could envision different standards for bars, office buildings, bingo parlors and conference-rooms, etc.

Comments on EPA ETS compendium ii. Because the percent dissatisfied is relativel}• insensitive to changes in ventilation rate , i.e. the slope of Figure l's line for percent dissatisfied versus ventilation rate is very small, a shift of percent dissatisfaction of 10% due to lack of matching real world mental sets (i.e. if his 30% dissatisfaction level were only 10%) would reduce the ventilation requirements by at least 50% (Figure 1, p. 39a). Because acceptance scores can shift dramatically with demographic factors, a pool of respondents must be carefu.lly stratified to avoid bias. Both of these issues should be discussed by Cain. iii. One wonders, in light of the ASHRAE 20% criterion, what percentages of occupants in "real world" environments (smoking or nonsmoking) are dissatisfied. For example, what percentage of people are normally dissatisfied, in the "real world", with their environment? Are their any environments in which 100% of the occupants are consistently satisfied (Jaakkola and Heinonen, 1989; Andersson et a ., 1976)? In addition, can we expect subject's satisf,sction to ETS to be the same in a chamber as it would be to equivalent levels of ETS experienced in the "real world". 6. The author omitted a legend for the two depicted symbols in Figure 1. Figure 2 is unclear. 7. When reviewing paragraph 3 on page 31, we disagree with the use of the assumption, i.e. "10% of occupants would be would be smoking at any given time" to draw conclusions regarding the inability of current ASHRAE ventilation standards to meet the satisfaction nEeeds of nonsmokers (page 32 paragraph 2). This estimate of smoking rates is presumably based on some rather crude calculations by Repace and Lowl-ey (1980). Again, the reader would be greatly helped by the availability of "real world" smoking rate data if conclusions regarding ventilation standards are being made. The author should report the size of the chamber used in this study. 8. We were initially confused when we referred to Figure 5. This initial confusion may be eliminated by referring to the two odors in the figure's legend as "ETS" and "occupancy" as opposed to "nonsmoking" and "smoking". 9. On Page 33, paragraph 1, we share the author's isplied concerns regarding the use of CO as a marker of ETS in non-laboratory'environments, although this important point should be more explicitly stated. We disagree with the author's comments on page 33, paragraph 1 regarding the use of carbon monoxide.as the sole indicator of ETS levels. Although ETS levels within a given set of experimental conditions may possibly be related to each other by C0, use of this ETS constituent to compare ETS levels from study to study is faulty due to the different CO levels produced by various cigarette types and by different smoking condit:ions.. Data and-further

t Comments on EPA ETS compendium discussion supporting this argument is presented-by Nystrom and- Green - (1986). 10. Regarding page 34, paragraph 2, we do not understand Cain's contention that people should not be allowed to judge dissatisfaction based on perceptual irritation. 11. On page 34 in the indented section, referring to a Cain reference (year of publication missing), there is a statement "irritation would seen interpretable on grounds of health". We agreis that for some people, irritation may be a nuisance, but it has not been demonstrated that there is any health hazard related to perceived irritation of ETS. Without a demonstration of harm to the body, perceived il-ritation should only be considered a component of the subjects' percept,ial responses to the ETS stimulus. 12. On page 34, paragraph 4, the author misuses the word "Tar". "Tar" is the collection of mainstream smoke on a glass fiber filter pad. The use of the word "particles" would be more appropriate. 13. On page 34, in paragraph 5, the author should change the word "both" to "the majority of". 14. Based on the chamber data presented, we agree with Cain's statement on p. 35, paragraph 3, "ventilation has its limit3tions", but we strongly feel that Cain needs to emphasize that this conclusion has not been confirmed by analyzing real world situations where standard ventilation requirements are met. Comments regarding Cain's references: 1. Reference for Kerka (1956) is missing. 2. Reference to Cain (1986) is missing initials for co-author See. 3. Reference for Yaglou (1955) is missing.

Comments on EPA ETS compendium References Andersson, L.O., Frisk, P., and Wyon, D.P., (1976) Human Responses to Dry, Humidified and Intermittently Humidified Air in Large Office Buildings. Swedish Building Research; PB 257 903, Stockholm, Sweden. Cain, W. S., Leaderer, B. P., Isseroff, R., Bergland, L.G., Huey, R.J., Lipsitt, E.D., Perlman, D. and Dunn, J. D., (1983) Ventilation requirements in buildings - 1. Control of occupancy odor and tobacco smoke odor. Atmospheric Environment, 17, 1183-1197. Claussen, G.H., Nielsen, K.S., Sahin, F., and Fanger, P.O., (1984) Sensory irritation from exposure to environmental tobacco smoke. In: Proceedings of the 3rd International Conference o~}r Indoor i,r al t and C mate, Stockholm, Berglund, B., et a (Eds.) Swedish Council for Build:Cng Research, Stockholm, Sweden, pp. 52-56. Committee on Passive Smoking, Board on Environmental Studies and Toxicology, National Research Council (1986) Environmental Tobacco Smoke - Measurine Exposures and Assessing Health Effects, National Academ.j Press, Washington, D.C. Hirayama, T. (1981) Non-smoking wives have a higher risk of lung cancer, a study from Japan. Br. Med. J 282:183-185. Hirayama, T., (1987) Passive Smoking and Cancer: An Epidemiological Review, In: Changing Cancer Patterns and o ics in Cancer Wdemioloev. Kurihara, M., Ed., Japan Scientific Society Press, Tokyo; Plenum Press, NY, pp. 127-135 Hugod, C. Hawkins, L.H., and Astrup, P. (1978) Exposure of passive smokers to tobacco smoke constituents. Int. Arch. OccuR. Environ. Hlth. 42:21-29. Jaakkola, J.J.K., and Heinonen, O.P. (1989) Sick building syndrome, sensation of dryness and thermal comfort in relation to room t:emperature in an office building: Need for individual control of temperature. Environment. International 15:163-168. Marquardt, R., Christ, T., Blessing, A., (1986) Effect of nicotine on lacrimation and tear-film stability. Fortschr. Ophthalmol., 83:1CQ-104. Muramatsu, T., Weber, A., Muramatsu, S., and Akermann, F., (1983) An experimental study on irritation and annoyance due to passive smoking. Intl. Arch. Occu Environ. Health 51:305-317. Nystrom; C. W.nd Green, C. R. (1986), Assessing the impact of environmental tobacco smoke on indoor air quality: Current status. In: Proceedings of the ASHRAE Conference IA~ '86. Managing ndoo Air for ealth and Ener Conservation, American Society of Heating, Refrigerating and Air-Conditioning Engineers, Atlanta, GA. 0ldaker, C. B., (1989) Environmental Tobacco Smoke (ETS): How much is in the air? Presented at the_ International Tobacco_Conference!s mini-symposium on

Comments on EPA ETS compendium Environmental Tobacco Smoke and Scientific Affairs-, May 25, Winston-Salem, NC. Repace, J.L., and Lowrey, A.H., (1980) Indoor Air Pollution, Tobacco Smoke and Public Health, Science 208:464-472. Robertson, G., (1988) Source, nature and symptomology of indoor air pollutants. In: Indoor and Amb ent i~r Quality, R. Perry and P.';?. Kirk (Eds.), Selper, London. Robertson, G., (1989) Source, nature and symptomology of indoor air pollutants. Presented at the International Tobacco Conference's mini-symposium on Environmental Tobacco Smoke and Scientific Affairs, Mwr 25, Winston-Salem, NC. Sheen M..R., and Drayton, J.L. (1988) Influence of Brand Label on Sensory Perception In: Food Acceptabilitv, Thompson D.M.H. (Ed.) Elsevier Applied Science, London. Skov, P., Valbjern, 0., and DISG (1987) The "sick" building syndrome in the office environment: The Danish town hall study. Env lton. Int. 13:339-349. Uberla, K., (1988) Epidemiology: Its scope and lim:Ctations for indoor air quality. In: Indoor Air ualit , The National Acadeny of Sciences of Buenos Aires, Argentina, San Carlos de Bariloche, Argentina. - U. S. Department of Health and Human Services. 1986. 'he Hea Conseauences of Smokine. A e o of the Surgeon Ge era . DHHS Pub. No. (CDC) 87-8398. U.S. Department of Health and Human Services. Public Health Services Centers for Disease Control and Center for Health Promotion and Education. Office on Smoking and Health., Rockville, MD. Walker, J.C., Jennings, R.A., Morgan, W.T., Robinson, J.H., Griffith, D.W., and Reynolds, J.H. (1989) Sensory responses to environmental tobacco smoke from cigarettes that heat but do not burn tobacco. In: Proceedines 2f resen and Future of Indoor A_ir alit , Proceedings of the Brussels Conference 14-16 February 1989, Bieva, C.J., Courtois, Y., and Govae:rts, M., Eds., Excerpta Medica, Amsterdam. Weber-Tschopp, A., Fisher, T., Gierer, R., and Grandjean, E., (1977a) Experimentelle Reizwirkungen von Akrolein auf den Men:>chen. Int. Arch. Occuv. Environ, Hlth. 40:117-130. Weber-Tschopp, A., Fisher, T., and Grandjean, E., (1.977b) Reizwirkungen des Formaldehyds (HCHO) auf den Menschen Int. Arch. OccuR. Environ. Hlth. 39:207- 218. Weber, A., Fisher, T., and Grandjean, E. (1978) Passivrauchen unter experimentellen Bedingungen und in Feldversuchen. Sozi.ai- und Praventivmedizin 23 (4):261-262. , Weber, A., Fisher, T., and Grandjean, E., (1979a) Passive smoking in experimental and field conditions. Environ. Res. 20:205-216.

Comments on EPA ETS compendium Weber, A., Fisher, T., and Grandjean, E., (1979b) Passive smoking: Irritating effects of the total smoke and gas phase. Int. Arch. Occu Environ. Hlth. 43:183-193. Weber, A., Muramatsu, T., and Muramatsu, S., (1982) Akute und Chronische Auswirkungen des Passivrauchens. Sozia - und Preventivmed 27:262-263. Weber, A., (1984a) Acute effects of environmental tobacco smoke. European Jou Respiratory Disease 65 (Suppl. 133) 98-108. Weber, A., (1984b) Annoyance and Irritation by Passi-ie Smoking. Preventive Medicine 13:618-625. Weber-Tschopp, A., Fisher, T., and Grandjean, E., 1;1976a) Objektive und subjektive physiologische Wirkungen des Passivraucheris. Int. Arch. Occuv. Environ Hlth. 37:277- 288. Weber-Tschopp, A., Fisher, T., and Grandjean,E., (1976b) Luftverunreinigung und Belastigung durch Zigarettenrauch. Sozial- und Prevent:ivmedizin 21: 101-106. Winneke, G., Plischke, K., Roscovanu, A., and Schlipkoeter, H. (1984) Patterns and determinants if reaction to tobacco smoke in an experimental exposure setting. Proceedings of the 3rd International Conferer:ce on Indoor Air Quality and Climate, Stockholm, Indoo Air, Vol. 2. Swedis'1 Council for Building Research, Stockholm, Sweden, pp 351-356. Yaglou, C.P. (1955) Ventilation Requirements for Cigarette Smoke. Transactions Amererican Society of Heating and Air-Conditionin¢ Enzineers 61:25-32.

REVIEW OF: ENVIRONMENTAL TOBACCO SMOKE A COMPENDIUM OF TECHNICAL INFORMATION by Simon Turner, Healthy Buildings International, Inc. I Introduction Healthy Buildings International, Inc. (HBI) is a company that specializes in the study and assessment of indoor air pollution. Since we incorporated in ].981, we have studied in excess of 80 million square feet of buildings throughout the world, perhaps confirming us as the most experienced private company in that field. HBI seeks to identify the causes of indoor air quality problems -- the "sick building syndrome" -- and to recommend remedial steps. Our experiences are attracting widespread interest in the professional arena of those truly interested in indoor air quality. Clients include major banks, insurance companies, property developers, hospitals, colleges, and government agencies, including the U.S. Department of Health and Human Services, Social Security Administration, Longworth Congressional Building, Supreme Court, Government Services Administration Regional Head- quarters, United Nations Buildings in New York, Customs and Excise and Coast Guard Buildings. We were asked to comment upon the document entitled "Environmental Tobacco Smoke: A Compendium of Technical Information" based upon our extensive experience with indoor air quality problems. In addition to a number of specific substantive flaws contained in the document, this compendium