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i ; i _: For the_ sake o£-balance-,--the-_aul;.hor-s..-should--discuss._ the published studies indicating that ETS does not appear to make a major contr-ibution-to indoor~air pollution.: In studies in the United States and Canada, Sterling et al., (1987-) and Sterling and Mueller, (1988) concluded that ETS does not make a significant contribution to either indoor air quality or health and comfort symptoms associ-ated with the "sick building syndrome." Since 1978, NIOSH has conducted numerous investigations of buildings with health and comfort complaints. Nearly half of the complaints were associated with-,;i-nadequate,ventilation (Mehlius et al., 1984). Only 2% of the complaints involved ETS. _ Another problem area is the sec:ion in which the authors present data on levels of RSP in homes [p.68-69]. What conclusions are to be drawn from the results of these studies? In the article by Spengler et aL., (1981), the actual amount of smoking was not reported, thus the reader has no way of assessing the limitations of the conclusions regarding levels of RSP per smoker. It would be appropriate for the authors to discuss problems in interpreting such data, and to indicate how particular levels relate to health effects. Certain conclusions in the Summary section are not supported by information presented in the text or in the literature. For example, the statement that "Environmental ~ tobacco smoke is the primary contaminant causing elevated RSP C?~ ~ levels in enclosed spaces.°- is too-absolute-:- A more-accu-rate- .F _tV ~ U1 W

~1d statement would_be "In enclosed spac.es--in which smoking occurs,. ETS may be a major cause of elevated RSP levels." Certainly, there are many enclosed spaces in which ETS makes- no contribution to RSP because smoking is not occurring. Even where smoking does occur, not all studies have been properly controlled to permit such an absolute statement. For example, in the study by Weber and Fisher (1980) cited by the authors, baseline values of particles were determined at a time when the rooms were unoccupied. These values ;aere subtracted from values obtained when the rooms were occupied and smoking was occurring. -To control for particles generated by occupancy, the proper condition to establish the baseline is wherL the only variable is the occurrence of smoking. Occupancy and other human activity should be the same during the baseline and experimental conditions. In summary statement #2, the authors are in conflict with the conclusions of Dr. Leaderer in Chapter 5[p.56]. Evidence has•not been provided which allows this statement to be made. In fact, it is well established that carbon monoxide levels do not change very much due to ETS (Carson and Erikson, 1988; Hugod, 1985; Proctor, 1988; Sterling and Mueller, 1988). None of the other chemicals mentioned in the statement have been•studied thoroughly enough to support this conclusion. If the authors have references in support of these statements, they should be provided. Generally, the authors should te more comprehensive in citings references for statemen.ts- they make- throughout- the; -

LJ chapter. Further.,. there -are several point:s.-.on_ whi-ch_ .the - authors have presented inappropriate information, not . thoroughly referenced- statements, or have.-cited --studies -thart are not contemporary and omitted those that are contemporary. For example, inclusion of the work by Wallace et al. (1987), [p.71], is inappropriate, since that study's conclusion that cigarettes are a major source of benzene is relevant only to active smoking and not e:cposure to ETS. Another example is the citation to Dzubay and Stevens, 1975, as support for the statement that at leasi: 75$ of the sulfur, zinc,-bromide-and lead are •found •in the s:.ze range of <2.5 um. [p.66]. Based on one reference from that long.ago, it_ is not valid to make such a definitive statement. It is not clear that the data collected in 1981 and presented in Figure 3 are an accurate ref:lection of present exposure conditions [p.68]. Since this document deals with. technical information, it would be an app::opriate place to discuss the proper experimental design fo:- studies measuring the contribution of ETS to RSP or any other constituent of indoor air. For example, as mentioned ea:lier, the proper controls in such studies should be measurements in the same environment with the same number of peopl,2 and the same level of activity, but with no smoking occurring. It is appropriate to critique the studies of Weber and Fiscler, (1980) [p.69], Quant et al.,'(1982) [p.69], and others on the basis of design flaws, and to question the conclusions that can be drawn if proper experimental design is not utilize3-.-

,J A number. of articles more recent -than those- cited--in - Tables 5 and 6 have been reported where particulates and nicotine have been measured under--realist_i::-conditions: For- example: Sterling et al., 1987; Mattson et al, 1989; Henderson et al., 1989; Sterling and Mueller, 1988. These articles should be cited and reviewed. Comments on future directions that should be taken in this area would be appropriate. REFERENCES L .Benner CL,.--Bayona JM, Caka FM, Tang H, Lewis L, Crawford J, Lamb JD, Lee ML, Lewis EA, Hansen LD, and Eatough DJ: Chemical composition of environmental tobacco smoke. 2. Particulate-phase compounds. Environ. Sci. Technol. 23, 688-698, 1989. - Carson JR and Erikson CA: Results from survey of environ- mental tobacco smoke in offices in Ottawa, Ontario. Environ. Tech. Lett. 9: 501-508, 1988. Eatough DJ, Hansen LD, and Lewis EA: The chemical characterization of environmental tobacco smoke in Environmental Tobacco Smoke, Proceedings of the International Symposium at McGill University 1989, Ecobichon DJ and Wu JM, editors, Lexington Books, DC Heath and Co., Lexington, Mass. pp. 3-50, 1990. Henderson FW, Reid HF, Morris R, Wang O-L, Hu Pc, Helms RW, Forehand L, Mumford J, Lewtas J, Haley NJ, and Hammond SK: Home air nicotine levels and urinary cotinine excretion in preschool children. Am. Rev. Resp. Dis. 140: 197-201, 1989. Hugod C: Exposure to smoke constituents by passive smoking. Tokai. J. Exp. Med. 10: 401-405, 1985. Mattson ME, Boyd G, Byar D, Brown C, Callahan JF, Corle D, Cullen JW, Greenblatt J, Haley NJ, Hammond SK, Lewtas J, and Reves.W: Passive smoking on commercial airline flights. JAMA 261: 867-872, 1989. Mehlius J, Walingford R, Keenlyside R, et. al.: Indoor air quality; the NIOSH experience.- Meeting-of -the-=American-= - Congress of Government Hygienists, 1984.

Muramatsu M, Umemura S,.Fukui_J-, Arai T, and-Kira S: Estimation of personal exposure to ambient nicotine in daily environment. Int. Arch. Occup. Environ. Health 59: 545-550, 1987. Pritchard JN, Black A, and McAughey JJ: The physical behavior of sidestream tobacco smoke under ambient conditions. Environ. Tech. Lett. 9: 545-552, 1988. Spengler JD and Sexton K: Indoor air pollution: A public health perspective. Science 221: 9-17, 1983. Sterling TD, Collet CW and Sterling EM: Environmental tobacco smoke and indoor air quality in modern office work environments, J. Occup. Med. 57-62, 1987. Sterling TD and Mueller B: Concentrations of nicotine, RSP, CO and CO in nonsmoking areas of offices ventilated by air recirgulated from smoking designated areas. Am. Ind. Eya. Assoc. J. 49: 423-426, 1988. Vu Duc TV and Huynh CK: Deposition rates of sidestream smoke particles in an experimental chamber. Toxicol. Lett. 35: 59, 1987.

Chapter 7 Exposure Assessment in Passive! Smoking James L. Repace---- {1 In this Chapter, the author relies extensively on modeling to assess exposure to ETS. While modeling may be useful under appropriate circumstances, the author's approach to it here oversimplifies a complex exposure problem. For the presentation to be balanced, it should be pointed out that there are limitations to modeling, such as the heavy reliance on published data and the need to make nurierous assumptions that might not be valid. The lack of qua:.ifications gives the reader a misleading impression of the nature of such an approach. In many instances, the author has relied on reviews of the literature, such as the reports by the Surgeon General, the National Research Council and IARC. ~'he primary literature sources, rather than these rev::ews, should be cited. The statement is made that ETS :Ls the dominant contributor to indoor levels of RSP [p.801. What is the evidence to support that statement? A mo:-e correct statement would be "that in certain indoor environments, ETS may be the dominant contributor to RSP levels." A strong case can be made that RSP is not the best measure of air contamination due to ETS []?.80], principally due to its lack of specificity for ETS. Nicotine may be a better marker because of its tobacco-specificity and ease of measurement (Eatough et al., 1990). However, because of its U

r Lii rapid decay during ag.ing,_ severe limitationsn exist. in the.use_= of nicotine as a surrogate for ETS (Eatoucih et al., 1990). It is-not clear that the author is correct in assuming that it is almost impossible for nonsmokers to avoid some exposure to ETS, [p.80). This is too strong of a generalization. While there may be some data to support this statement, it is clear that many nonsmokers can avoid exposure to ETS, particularly with all of the present smoking restric- tions. For a balanced presentation, the ZLuthor should cite and discuss other work that indicates that, ETS may not contribute significantly to indoor RSP (Sterling et al., 1987). In places, the author relies on data that were obtained as long as 20 years ago. For exzimple, the author cites a 1970 reference to support an assertion about the number of homes containing children and smokers [p.86]. There is no reason to-believe that these figures are accurate, particularly•with the decline in cigarette! smoking. The author should cite more contemporary research in this area or qualify his statements. The same comments apply to the data in Table 10. A number of publications have ai:tempted to quantitatively compare exposure to ETS wit:h that of active smoking through the use of "cigarette equ:.valents." While alluding to the limitations of using such a value, the author should comment more thoroughly on the ovel-a11 validity of this concept in order-to have a balanced presentation-of the -

r subject [p.89].. Cons.ideri-ng-the-chemical complexity and.. dynamics of ETS, the concept of cigarette equivalents has little util.ity. This is particularly true when-.values are based upon a single component of ETS such as nicotine or cotinine levels in biological fluids. The presentation contains a numter of misleading statements, assumptions, and omissions. For example, in contrast to what the author claims [p.89], there is evidence that nicotine is cleared from the body at different rates in smokers and nonsmokers (Kyerematen et al., 1982). Further, in addressing:the use of-nicotine as a marker for ETS exposure [p.89], the author states that "it has been calculated- that a nonsmoker would inhale volatile nitrosamires equivalent to 10 nonfilter cigarettes or 35 filter cigaretts." The term "calculated" implies that there is no question of the validity of the data from which the calculations were made. The term "estimated" would be more accurate here since the data being relied on are only estimates to begin with. It is also inappropriate for the author to use the term "typical nonsmoker" in making generalizations about: body burden nicotine [p. 91-92]. A more accurate typology would be "nonsmokers who work with smokers." Another example is the author's use of the term "ETS carcinogens" [p.92]. This statement assumes that ETS is carcinogenic, but this has not been proven. Finally, the citation for Kuller et al., (1986) [p.90] should be provided.

It would- als-o- be useful. to incLx,de:-a sect.i.on.-on- future needs in this area. REFERENCES Eatough DJ, Hansen LD, and Lewis EA: The chemical characterization of environmental tobacco smoke in Environmental Tobacco Smoke, Proceedings of the International Symposium at McGill University 1989, Ecobichon DJ and Wu JM, editors, Lexington Books, DC Heath and Co., Lexington, Mass. pp. 3-50, 1990. Kyetematen GA, Damiano MD, Dvorchik BHT, and Vessell ES: Smoking-induced changes in nicotine disposition: Application of a new HPLC assay for nicotine and its metabolites. Clin. Pharmacol. Ther. 32: 769-780, 1982. Sterling TD, Collet CW and Sterling EM: F,nvironmental tobacco smoke -and -indoor air quality in modern office work environments, J. Occup. Med. 57--62, 1987. - t

E rl Chapter 8 Absorption of Smoke Constituents by Nonsmokers Dietrich Hoffmann, Klaus- D. Brunnemann; and:=Nancy J. Haley The authors have presented a reasonably balanced discussion of the use of biological marke::s in the assessment of exposure to ETS. Several points should be expanded upon or clarified in order to more completely evaluate the authors' statements. These will be addressed in the following para- graphs. The authors have not provided a citation in support of their statement that exhaled mainstream smoke makes few contribution to ETS [p. 95]. In fact, there are little quantitative data on which to base any co-iclusions on this question. For example, the more frequent the puffs and the more shallow the inhalation (the less deposition), the larger the contribution of exhaled mainstream smoke to ETS. Additionally, the type of tobacco being s:noked will influence the contributions of each. The authors snould acknowledge the fact that little information exists in this area. The authors should more fully discuss the problems associated with interlaboratory comparisons of nicotine and cotinine in human serum and urine as presented in the ref-erence by Biber et al. [p.98]. These investigators found that absolute_,values for these parameters show large CZ) CD interlaboratory variations which are particularly high in the -.1 samples from subjects exposed to ETS. In addition, in another C~ study (Letzel et al., 1987), it was reported that estimating N