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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

on environmental tobacco smoke (ETS) sanctioned by a body such as the U.S. Environmental Protection Agency (EPA) concerns us in that this single-minded focus on one pollutant, unique in EPA's policies on indoor air, will give the public the impression that its removal will solve al:. indoor air problems, thus giving an entirely false sense of security. We frequently investigate build'.ngs on account of complaints from occupants with symptoms such as eye and nose irritation, fatigue, coughing, rhinitis, nausea, headaches, sore throats and general respiratory prob:.ems. It is frequently assumed by our clients that these symptoms are due to ETS. However, it is clear that identical symptoms may be found in individuals exposed to formaldehyde, sulphur oxides, ammonia, oxides of nitrogen, and ozone. :Cn addition, similar symptoms are reported by those individuals 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. Low relative humidities create similar problems and are on the increase. Surprisingly, after a detailed, scientific evaluation of these buildings, we have de-:ermined high levels of environmental tobacco smoke to be the immediate cause of indoor air pr6blems in only three percent of the 412 major U.S. buildings investigated by HBI between 1981 and 1989. This result has been corroborated. In a similar study of 203

buildings from 1978 to 1983., the National Institute for Occupational Safety and Health (NIOSH) found that only four of the buildings studied (two percent) had indoor ai-r-quality problems attributable to high concentrations of ETS. Significantly, in those few cases where we found high accumulations of ETS, we also discovered an excess of fungi and bacteria in the HVAC system. These microorganisms usually are found to be the primary causes of the complaints and acute adverse health effects reported by building occupants. Dirt in Duct Systems We have also found that HVAC systems are often poorly designed and negligently maintained. Excessive_dirt accumulations are common in ductwork, even in hospitals. Following the inspection of a number of buildings, hundreds of pounds of fungi, dust, and dirt have been removed from such ductwork. Bird, insect, and rodent carca:>ses and excess amounts of dust have been found in many buildings where employees have complained of eye irritation, headaches, fatigue, nausea, allergies, and general respiratory problems. Of course, since the ductwork is out of s'..ght, it is also invariably out of mind. Thus, it is common for the blame for these types of problems to be laid elsewhere. Energy Conservation Indeed, the complex of symptoms that we have mentioned - the "sick building syndrome" •- may result Go primarily from energy conservation efforts to seal buildings N W and reduce the infiltration/exfiltration of air.- Such efforts: N

have reduced the natural infiltration of Eresh air that previously existed in many buildings, exacerbating the often undiscovered problem of a poorl-y de-signed-or maintained HVAC system. In addition to tightening buildings and sealing windows, building managers have shut down air conditioning systems at night and on weekends in an efEort to lower energy costs. When the air conditioning is shut down in humid climates, condensation builds up and settles inside the ductwork. If dirt is present in damp ductwork, spores and microbes can flourish, only to be spread throughout the building once the HVAC system is -turned on the next mo-rning. This often results in Monday morning complaints of building odors or building sickness that disappear during the week, only to recur the following Monday morning. To save more energy, automatic temperature controllers are used to cycle fans on and off during the day. Vibrations from,the start-up of these fans can cause dirt and microbes trapped inside ductwork to be dislodged and carried into occupied areas. Another energy conservation effort that may contribute to sick building syndrome is the recirculation of indoor air, at the expense of fresh outdoor air. This may be the result of either a deliberate policy or*shortsightedness on the part of the designers. This results in the continuous redistribution of infectious microbes, allergenic dusts and spores from office to office and floor to floor. Improper ventilation can sometimes be ca-rried--to-extremes:----Typic-ally-:>

we find the fresh air dampers were.closed.completely_in over_ 35% of those buildings studied by HBI. Ore misguided engineer actually had bricked up -the fresh air vent.s -to save- energy-:- All of these buildings were operating witt, 100% recycled indoor air. The lack of an adequate frest air supply, coupled with dangerously low air exchange rates, 1-.as led to hazardous ventilation conditions in many of the buildings evaluated by HBI. Similarly, over 50%~of-the investigations conducted by NIOSH from 1978-1987 attributed the indooi air quality problems to inadequate ventilation. Poor Air Filtration Modern filter technology can easily cope with the numerous particulate matter that is routinely .carried in the indoor air. Unfortunately, however, there is far too much ignorance in this area. Frequently good filters are poorly installed allowing air bypass, but more frequently we see a move to cheaper, less efficient filters-: Many buildings attempt to clean the air with filters no better than butterfly nets. Compound this with the lack of maintenance given to the filter systems and the infrequent changes of filters and it is hardly surprising that airborne pollutants accumulate. Methodology of Dealing with Indoor Pollut'..on • Instead of a single-minded focus on specific pollutants, we believe very strongly in a generic engineering approach to deal with all pollutants at the same time. In our U.S. experience of over 80 million square feet of building studies, the major contributors to poor a.ir were threefo-ld: _-

(1) Poor Ventilation Inadequate ventilation 62% Zero fresh air intake 33% (2) Poor Filtration Inefficient air filters 43% (3) Dirt in Ventilation System; Contaminated air handlers 36% Contaminated ductwork 22% We are convinced that improving ventilation rates, upgrading filters, and cleaning up the air handling system will eliminate over 80% of indoor pollution problems. Such changes will improve worker productivity, enhance staff morale, and reduce absenteeism~owever, many managers have decided to ban smoking as an apparently cheap and easy way to solve indoor air quality problems. Unfori.unately, this simply does not work. HBI has determined that the pre:3ence of high concentrations of tobacco smoke indicates that a much more serious problem exists. Poor ventilation and improperly maintained ventilation systems are the pr.imary causes of poor indoor air. When such conditions prevail, all the invisible and odorless pollutants are also trapped. Many of these are potentially far more dangerous than ETS. Persistent indoor air quality complaints therefore can be resolved only if building managers and operators are prepared to focus on building air handling systems in an appropriate manner. High concentrations ~:)f ETS are s.5mptom, not a cause of these complaints. Its eli:nination can effect no cure.

.{ CRITIQUE OF COMPENDIUM There follows specific comments on selected chapters of this compendi.um,- either where we feel i;here are flaws or misconceptions, or where we have construci;ive contributions to make. General We feel that in many areas of this compendium the list of papers and authors referenced to i:ends to be selective; there is a broad range of research, findings and conclusions on this topic and we feel the compendium needs to reflect this breadth of information. Suggestions for additional authors are made where relevan: in each chapter. Chapter 3 Chapter 3 is entitled "The Odor and Irritation of Environmental Tobacco Smoke," by Dr. William S. Cain. Much of the premise on which this chapter is based is derived from chamber studies where visitors are asked to expose themselves to the air inside an experimental aluminum or steel space occupied by varying smoking activities in order to assess acceptability. The authors' basic conclusions are that impractically high levels of ventilation a,ould be required to provide acceptable conditions for non-smokers where smoking activity is in place, and they state "it would appear that where smoking occurs none of the recommendations of the ASHRAE (American Society of Refrigerating and Air Conditioning Engineers) standard will do for the non-smokers."

I i Unlike Dr. Cain, ASHRAE bases ii:s standards on real life feedback from architects, engineers, consumer organizations, health.officials,--medical researcher-s, bui-lding- owners and operators, and the interested public. There are significant differences in the use of real life versus chamber studies leading to very different conclusions about appropriate ventilation rates. For a number of reasons, a properly operated ventilation system works quite effectively in providing an environment not perceived as containing uncomfortable levels of ETS despite the conclusions of theoretical chamber studies. Dr. Cain justifies his reliance on chamber as opposed to real-life studies by attemptincI to portray environmental tobacco smoke (ETS) as a substance whose chemical complexity "likely exceeds that of emissions from bodies and as a consequence" analysis of EITS - containing air offers little of practical significance regarding the origin of odor or ir'ritation". This, Dr. Cain a:°gues, is because human beings perceive ETS differently thail certain other chemicals. In the case of formaldehyde, for example, Dr. Cain's own research (1) has shown that "prominen: characteristics of the sensations included growth of irritation with time for the lower concentrations and decay for the highest". In experiments (Y) on possible interaction bstween odor and OD m -3 irritation, "the odorous substance pyridiie was injected into N an environment containing 1 ppb-formaldehyde", and "the ~ Ch ~

irritation from formaldehyde decreased. :uch-sensor-y interactions may also result in environmentally realistic situations", Dr. Cain concluded. .Yet in.t:he case of ETS no-- such observations were made. Why is this: Dr. Cain does not offer an acceptable explanation. Dr. Cain also believes that "as ETS enters the atmosphere, its many chemical constituent:; react with each other and with surrounding materials both chemically and physically". Yet "irrespective of whatever chemical changes occur", Dr. Cain would have us believe th<<t "the odor of ETS behaves in the short run like a stable contaminant". Even after the source has been removed, Dr. Cain states that "ETS odor decays in a manner entirely predictable from ventilation rate" and "therefore" differs from occupany odor which has a half-life of 55 minutes presumably by slow oxidation of its chemical constituent into less odorous products" (2). Since the liquid aerosol of ETS" absorbs and so on, it becomes a source for Dr. strong].y to walls, fabrics odor Cain argues "the background odor of carries its own demands for ventilation from the typical amount of smoking in a fails to explain adequately how and why later". Consequently, the emitted products predictable in part space" (3). Dr. Cain this is so as well as how it affects the overall conclusions reyarding recommended ventilation rates. Reliance upon chamber versus real life studies also means that, as a practical matter, ASHRAE and Dr. Cain employ different definitions of acceptable indoor.--air quality:

ASHRAE Standard 62-1989 defines acceptable indoor- air- qu-ality- as "air in which there are no known contaminants at harmful concentrations as determined.by cognizant.-authorities-and_with which a substantial majority (80% or more) of the people exposed do not express dissatisfaction." Appendix C, (see page 17 of ASHRAE Standard 62-1898,) provides the "proper" or recognized definition' of acceptability to be used in establishing the 80% level, namely: "Many contaminants have odors or are irritants that may be detected by human occupants or visitors to a space. The air can be considered acceptably free of annoying contamina:nts if 80% of a panel of at least 20 untrained obse!rvers deems the air to be objectionable under representative conditions of use and occupany. An observer should enter the space in the manner of a normal visitor and should enter a judgment of acceptability within 15 seconds. Each observer should make the valuation independently of other observers and without influence from a panel leader. Users of this method are cautioned that the method is only a test for odors. Many harmful contaminants will not be detected by this test. Carbon monoxide and radon are two examples of odorless contaminants." The criteria employed by Dr. Cain in his odor and irritation tests appears far broader and nonspecific to be covered by the above, rather explicit defi.nition.(4) Dr. Cain did confirm that his own experimental findings suggested a ventilation requirement of "17.5 cfm per occupant and accordingly would meet ASHRAE visitor crii:eria", for several listed occupancies under Table 2 of ASHRAI; Standard 62-1989. Yet in returning to his climate chamber data, he continues to - argue that based on data from (his) "investigations suggests that under typical conditions of- smoking -occupany--(10$ smok=ing