Lorillard
Environmental Tobacco Smoke: A Compendium of Technical Information Technical Review
Fields
- Author
- Ogden, M.W.
- Alias
- 88772467/88772481
- Type
- REPT, OTHER REPORT
- Area
- CROUSE,WILLIAM/BASEMENT GMP
- Litigation
- Stmn/Produced
- Characteristic
- EXTR, EXTRA
- Site
- G10
- Named Organization
- 7th Day Adventists
- Epa, Environmental Protection Agency
- Iarc
- Mormons
- OSHA, Occupational Safety & Health Administration
- Epa, Environmental Protection Agency
- Master ID
- 88772371/2597
Related Documents:- 88772371-2597 United States Environmental Protection Agency Environmental Tobacco Smoke: A Compendium of Technical Information Comments of the Tobacco Institute 900205 Reviewers' Statements
- 88772372-2379 Comments on Chapter 3
- 88772380-2396 Review of: Environmental Tobacco Smoke A Compendium of Technical Information
- 88772397-2403 Reactions to Environmental Tobacco Smoke: A Compendium of Technical Information Chapter 4: Environmental Tobacco Smoke and Cancer
- 88772404-2418 Comments on Environmental Tobacco Smoke: A Compendium of Technical Information Chapter 4: Environmental Tobacco Smoke and Cancer
- 88772419-2433 Chapter 4: Environmental Tobacco Smoke and Cancer - Environmental Tobacco Smoke: A Compendium of Technical Information
- 88772434-2442 Statement
- 88772443-2466 Critique of the Report Entitled Environmental Tobacco Smoke: A Compendium of Technical Information U.S. Environmental Protection Agency Chapters 5-8
- 88772482-2494 Review of: Environmental Tobacco Smoke A Compendium of Technical Information
- 88772495-2500 Comments by Dr. Guy B. Oldaker III on Chapter 5 Measuring Exposure to Environmental Tobacco Smoke
- 88772501-2504 Comments with References on 'measuring Exposure to Environmental Tobacco Smoke'
- 88772505-2512 Comments by Dr. Guy B. Oldaker III on Chapter 6 Exposures to Air Pollutants
- 88772513-2530 Comments by Dr. Guy B. Oldaker III on Chapter 7 Exposure Assessment in Passive Smoking
- 88772531-2533 Comments on Chapter 7: Exposure Assessment in Passive Smoking
- 88772534-2540 Review of Chapter 8 by D. Hoffmann, K.D. Brunnemann, and N. J. Haley of the Draft Compendium of Technical Information on Ets Edited by the Environmental Protection Agency
- 88772541-2553 Critique of Environmental Tobacco Smoke: A Compendium of Technical Information Chapter 9: the Effects of Passive Smoking and Day Care on Respiratory Illnesses in Children
- 88772554-2572 Evaluation of Appendix 10: Economic Justification for No Smoking Policies at the Worksite
- 88772573-2584 Economic Justification for Worksite Smoking Policies
- 88772585-2596 Review of: Environmental Tobacco Smoke A Compendium of Technical Information
- Named Person
- Brunnemann
- Ingebrethsen
- Surgeon General
- Williams
- Ingebrethsen
- Date Loaded
- 12 Feb 1999
- UCSF Legacy ID
- xfh30e00
Document Images
ENVIRONMENTAL TOBACCO SMOKE: A COMPENDIUM OF TECHNICAL INFORMATION
Technical Review - Michae). W. nrrden, Ph.^=
Chapters 5 ("Measuring Exposure to Environnu.ntal Tobacco Smoke"),
6 ("Exposures to Air Pollutants"), and 7("]sxposure Assessment in
Passive Smoking") all deal with essentia:lly the same subject
matter. Although the approaches taken represent the various
author's individual viewpoints, it would be in the best interest
of this Compendium to combine these three chapters into one
comprehensive review of "Exposure to Environmental Tobacco Smoke".
This reviewer will address each chapter individually with emphasis
on omissions, redundancies, and cnntradictio:«s. -
Chapter 5 - "Measuring Exposure to Environmontal Tobacco Sraokell
Chapter 5 is in a form which makes it 3ifficult to review
adequately. Specifically, there are numerous misspellings,
incomplete or awkward sentences, and the list of literature
references is unavailable. The subject matter of biomarkers is not
really.addressed at all. The limitations of nicotine and RSP are
not adequately portrayed. There are ways to make RSP a much more
useful marker of ETS: through the use of apportionment techniques
such a~= t::e published methods tor UVPM (ultraviolet particulate
*
matter, references" below) and solanesol ( j73 ]..and references below)
and the presented but not yet published method for FPM (fluorescent
*
particulate matter) [751. At a minimum, the pul:)lished methods must
*"[]" refers to Chaps. 5-8 Index.

6
t.
U11
be included.
p. 53 - The opening sentence is misleading. It st?*_p-- that
measuring exposure to ETS is an exact science when in fact it can
only be estimated. Replace "assessing" with "estimating".
p. 54 - The author states that "models can be developed. and
validated to predict concentration" implying that this has been
done. This reviewer knows of no adequately validated models for
this purpose, including those referenced in Chapter 7.
p. 55 - The opening sentence is misleading. It states that "(ETS)
is -a complex mix of over 4,000 air contaminantF". This is
speculation based on what is known about mainstream and sidestream
tobacco smoke. Nowhere near 4,000 tobacco smcke derived components
have ever been measured at true ETS concentrations. In fact, this
reviewer is unaware of more than 100 or so.
p. 56 - Although RSP and nicotine are widely used as markers, this
chapter (indeed, all three chapters) neads to address the
appropriateness of their use. The author states they are used
because of "their relationship to other ETS contaminants". This
reviewer is unclear as to what is meant by this statement, when in
fact,-the relationship between nicotine and PSP is highly variable
across environments.
Tb i c
section needs eiaboration with
appropriate documentation.
p. 57 - "The EPA standard is for particle mass, 10 µm." What does
2

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this mean? Ten µm is a unit of particle diameter, not mass.
The author needs to clarify what is meant by "reasonably consistent
RSP to vapor ph%~kse ratio(*:" . _`or ETS" and "nicotine, for some
applications, may vary with ETS related RSP". While nicotine and
RSP are almost always correlated in field studies (i.e., there is
a statistically significant slope), the corre].ation (i, e. , goodness
of fit) is almost always very poor. This reviewer questions how
this supports the statement that nicotine ca:ri be used to estimate
RSP attributable to ETS.
p. 58 - The author incorrectly states that there are no health
standards for exposure to nicotine. 0!SHA has one (500 µg/m3). A
further drawbac;t ot nicotine as an ETS m<<rker that should be
included is the fact that in environments w:Cthout active smoking
activity (but which have a history of smokiiig activity) there is
the very real possibility of a nicotine background due to
*
adsorption/desorption from room furnishings, etc. t74}. In these
cases, measurement of nicotine indicates expo:aure to nicotine only,
and not ETS (other less-adsorptive components have decayed to
zero). The author raises this issue at the bottom of the page and
states that "background levels of nicotine might also be indicative
of outgassing from surfaces of other volatile ETS components".
This latter statement is purely speculation <<nd should be omitted.
p. 61 - In the discussion of short-term me,==ement methods for
ETS RSP, the ultraviolet absorption method reported by Ingebrethsen
*
et al. [49] needs to be included. This UV method is the only
methodology widely-used in field surveys i.o indicate some ETS
*"[]" refers to Chaps. 5-8 Index.
3

*
apportionment of RSP [.15,70,75,92].-
rl
The author states incorrectly that "}hic tXA.D-4; method has been
evaluated for sampling periods up to one hour with...detection
limit of 0.1 µg/m3". The method has been evaluated for periods up
to 8 hours with LOD of 0.02 µg/m3. LOD for 1 hour sampling is 0.17
µg/m3 [77]*
pp. 61-62 - It is not true that particle phase nicotine can be
determined by analyzing the first filter. Particle phase nicotine
will impact the first filter but is stripped from the particles
and collected on the second filter as vapor phase nicotine. This
method cannot give separate i:.forinaiion on vapor phase and-particle
phase nicotine; it can only give total ETS nicotine if both filters
are analyzed and the results summed (i.e., the first filter
underestimates particle phase nicotine and the second filter
overestimates vapor phase nicotine).
Although passive samplers are useful in field surveys under certain
constraints, they generally show much worse ;precision than active
sampling systems and, in some cases, severely overestimate nicotine
concentrations [76]*.
p
63.- Delete the gratuitous statement that "ETS is a complex mix
of ~pveral thousand chenicals..." for the raasons outlined
comment to p. 55.
The author states that RSP and vapor phase nicotine
* "[]" refers to Chaps. 5-8 Index.
4
are

r
"reasonable" markers. How is reasonable defined? This is solely
the authors opinion and should be stated as such, if not deleted.
Chapter 6 - "Exposures to Air Po].lutants's
The title for Chapter 6 listed in the Table of Contents does not
agree with the actual chapter title. It appears the title listed
on p. 65 is more indicative of the chapter contents and implies
that this chapter was actually written for some other purpose.
This is further supported by the numerous irrelevant comments
attributable to air pollution in general. As stated previously,
this chapter should be combined with Chapters 5 and 7 for a more
comprehensive and useful review.
pp. 66-67 - What is-the relevance of the information relating to
sulfur, zinc, bromide, lead, silicon, calcium, and iron?
should be deleted.
This
The definition of mainstream smoke is circuitous and needs
revision.
This reviewer disagrees with the authors' statement that exhaled
mainstream tobacco smoke adds little to ETS. Exhaled mainstream
smoke can easily aa:' 1c? -20°s to true ETS In addition, the
chemical composition of exhaled mainstrean smoke is markedly
different from sidestream smoke due to absorption in the smoker.
5

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These authors have included the same gratuitous comments regarding
the "several thousand chemical compounds" in ETS as was included
in Chapter 5_ These c.om?aents should be del eted for the reasons
outlined previously (comments to pp. 55 & 63).
p. 68 - The authors state that the "large numibers of constituents
in ETS make it impossible to assess overall exposure based
on...each one" when in fact this is not true. The reason exposure
is not assessed on each constituent is because the vast majority
of tobacco-smoke chemicals have never been detected in ETS! In
fact, validated analytical methods exist for only a very few.
Although this may seem a trivial pursuit, the authors are implying
"ovPn::elming ccrupiexity" is the relevant issue when in realit~,
"extremely dilute concentration" is more pertinent. The authors
should strive to make a more objective presentation of the issues.
Of the possible measures of ETS, why do the authors choose RSP,
nicotine, cadmium and nitrosamines? RSP and nicotine form the
major theme of Chapters 5 and 7. Cadmium and nitrosamines are not
generally useful ETS tracers because of the ultra-trace quantities
present. (Is this a scare tactic?) Cadmium and nitrosamine
related information should be deleted and the remainder
with Chapters 5 and 7.
integrated
p. 69 - The statement is made that "each --:oker in the home raised
the mean respirable particle level by 20 lag/m3". What is the
relevance of this increase? In relation to 'the OSHA standard for
dust of 2000 Ecg/m3, this increase seems a.inuscule. The data
6

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presented in the next paragraph (0.88 and 2.11 µg/m3) are
considerably lower. This reviewer fails to see the relevance or
significance of these dat?.. M^ro information (with references)
needs to be presented or this discussion eliminated.
Because of the fact that RSP is not selective for ETS, it is
impossible to infer that the 962 µg/m3 measured (or any of the
other data) is attributable to ETS.
p. 71 - The authors contradict themselves by stating that "Indoor
cadmium levels were below the detectable limit" followed by
"cadmium levels were highly correlated with...particulate
measurements". If 7ad:uium was undetected, how could it be
correlated with anything else? The relevance of any discussion of
cadmium data is unclear and should be omitted.
The relevance of the information presented on nitrosamines is
unclear and appears to be taken out of context [9]. While true
that Brunnemann et al. detected nitrosamines, they were not
directly attributable to ETS (i.e., they were not tobacco-specific
nitrosamines). Brunnemann et al. state that "...the assessment of
traces of established animal or human carcinogens, possible thrqugh
advanced instrumentation, does not imply increased cancer risk for
man. _ The human risk can be established only through appropriate
epidemiological investigations." They go on to state =~...no
Go
epidemiological data exist linking human respiratory cancers to pp
~
volatile nitrosamines." The entire discussion of nitrosamines N
should be omitted from this chapter and left to the experts ~
rV
7

L.J
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~
~
(Hoffmann et al., Chapter 8).
What is the relersnce of the breath concen' r=* i c:: of benzene in
i! smokers? This paragraph must be deleted.
pp. 71-72 - What appear to be trivial increases in RSP (29 to 56
µg/m3) and nicotine (0.3 to 2.5 µg/m3) values; are presented. What
is the significance of these increases?
Likewise, the statement is made that "exposu::-e was increased by 20
llg/m3"
Z ~N
What is the relative magnitude and significance of this
increase?
.
The two paragraphs presented on cotinine measures are hardly
adequate. They should be deleted or covered in much greater
detail.
Summary statement #2 declares that ETS is a substantial contributor
to indoor air of benzene, acrolein, nitrusamines, pyrene, and
carbon monoxide. With the exception of bens,ene and nitrosamines,
the other compounds are not discussed within this chapter. The
data presented for benzene relate only to smokers and the
nitrosamine data are not specific to ETS. 7'his summary statement
is unfounded, unwarranted, and should be de].eted.
8

Chapter 7-O'Exposure Assessment in Passive Smoking"
The 1.Yt5!rature cita_tions for Chapter 7 are incomplete (e.g., IA.RC,
1987; Williams, 1985). The frequent use of "persortal
communication" citations is inappropriate. If this information is
not included in the scientific literature or other public domain,
it must be deleted. Considering the scope and content of Chapters
5 and 6, this reviewer sees no real need for this information to
be presented as a separate chapter. What new information is
presented here should be incorporated with Chapters 5 and 6 for a
more comprehensive and cohesive review.
p
7y - This reviewer agrees with the author that exposures tu ETs
can be assessed by personal air contaminant zaonitoring (presuming
appropriate contaminants are monitored); however, this reviewer
strongly disagrees that exposures can be assessed by modeling.
This is a common misstatement in Chapters 5, 6, and 7: assessment
implies an actual determination. Modeling can, at best, provide
an estimate, i.e., in place of an actual measurement. In reality,
modeling is still only a crude estimate and needs to be portrayed
as such.
p. 80 - It is not true that the "two most proa.ising markers for ETS
are respirable suspended particles...and nicotine". While these
are currently the most widely uscd, :aany resaarchers in the field
are actively pursuing identification of other markers specifically
to overcome the significant-limitations of-taiese two.
i 9

The author offers several unsubstantiated opinions as fact: "the
substantial emission of RSP", "ETS is the daminant contributor",
"RSP...found to be subc}antially elevated", etc. If this
Compendium is to be a scientific document, these loosely defined
qualifiers (substantial, dominant, etc.) need replaced with
quantifiers and appropriate literature citat:.ons added.
kJ
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L
L*~
U
The author states that the presence and number of smokers lacks
specificity for tobacco smoke. What does this mean? Assuming the
author means that RSP lacks specificity for tobacco smoke, this is
a true statement. However, the author continues throughout the
rest of the chapter blatantly ignoring this :aevere limitation.
Again, the author incorrectly states that "RSP is currently the
best...to represent ETS". This is opinion and should be stated as
such, if not deleted.
The author states that "nicotine and ...cotinine...derive
exclusively from tobacco products". This is incorrect. Nicotine
has been determined in a substantial number of foodstuffs including
tomato, potato, eggplant, pepper, and instant tea [13,100]* . This
reviewer agrees that tobacco smoke*is the most important source;
however, the possibility for nicotine and co-tinine in body fluids
arising from dietary sources cannot be ignored. It is unclear how
the statement "Generally, the mean concentrations c:fi -'~cotine and
cotinine in...nonsmokers exposed to ETS under natural conditions"
can be used to support the claim that "smokers are present in
nearly all environments". This section needs rewritten.
* "[]" refers to Chaps. 5-8 Index.
10

The assumption (statement) made in the last paragraph on p. 80 (and
later in the chapter) that "the averaRe...=!*cyer...emit about 22
mg of RSP per cigarette" is totally unjust:Lfied. This reviewer
must assume that the IARC reference gives an average sidestream
'tar' of 22 mg/cigt (which is not unreasonable). How is it
possible to justify the equation that 22 mg SS 'tar' = 22 mg ETS
RSP? Even the author recognizes the fact that "almost all nicotine
shifts from the particulate phase in MS and fresh SS smoke to the
vapor phase in ETS". It must be assumed thai: this same phenomenon
occurs for other tobacco-smoke constituents. The weight of ETS RSP
must be substantially less than the 22 mg predicted from SS 'tar'.
However, it is not known what the r.^latiunship is.
p. 81 - It is only correct to state that "Nonsmokers are exposed
to ETS in indoor spaces" where smoking occurs.
statement accordingly.
Please modify
p. 84 - The author states that "The utility cf Eq. 4 depends on the
assumption of an air exchange rate" when in reality Eq. 4 depends
on many more assumptions (no. of smokers, R:;P/cigt., sinks, etc.)
The appropriateness and limitations of these assumptions are never
clearly defined and they impact heavily on the usefulness of the
proposed models.
Gb
(Z
This reviewer fails to see how the example presented "illustrates -1
~
the utility of models". Having data from one experiment which are N
~
17,
then fit to a model which has been adjusted Eor variables measured -1
11

in the experiment can in no way be used as validation of the
general applicability of the model. Even i:n this case, when the
actual air exchange is used, the model predicts 130% of the RSP
actually determined. Combined with the observation that, on
*
average, RSP overestimates ETS by an additional 50% [T0;110],these
facts severely hinder the general applicability of this model.
The second example is equally flawed. The entire difference
between daytime and evening RSP concentrations is erroneously
attributed to ETS. The impact of persona]. activity other than
smoking on the daytime RSP concentration i,s completely ignored.
This so-called "pig-pen" effect (espoused pr:imarily by the authors
of C hapter 6) should be explained as a further conforndcr of these
data.
The author "implies that ETS may diffuse throughout a large office
building, exposing nonsmokers even in private offices" and offers
*
the data of Williams, 1985 [123]; as "support". The data of
Williams et al., in fact, do not support t:ais implication. The
results (Williams et al.) were miscalcu:lated and originally
published incorrectly; corrections to the calculations were made
*
and subsequently published [34]. These corrected data were
overlooked or ignored by the author and actually refute the
observation. Assuming the analytical method of Williams et al. is
sound, tneir data suppor` ey.:eedingly clean air in the office
complex surveyed.
p. 85 - The author states that from "li:mited field tests of
* "[]" refers to Chaps. 5-8 Index.
12

the...model...it is clear that both models and observations based
,r1
on...monitoring...yield consistent results". This could not be
further from the }~ ~t::- Simpl l stated, this; model has certainly
not been validated and has yet to be used in even one incidence to
provide reliable data in advance of actual air monitoring.
p. 86 - What is the relevance of the narrative concerning the
Mormons and the Seventh Day Adventists?
p. 88 - The author correctly states that "In the absence
of...data...exposures can be estimated by models or by
extrapolation from biological markers". The key word here is
~a "estimate" and it needs to be realized that the existing models
have' yet to provide any indication of -re:producible, reliable
estimates. In other words, the quality of these estimates is still
~ very much in question among scientists.
This reviewer reiterates the comment provided to p. 79. ETS
exposures can be assessed by air monitoring but only estimated by
modeling, questionnaires, and the like.
The statement "there are models in use...which can predict the
concentrations of RSP from ETS to a reasonable degree of accuracy"
is the opinion of the author and is not a generally held opinion.
p. 89 - The author (inadvertently?) providea further evidence of
the inappropriateness of calculated exposurEas- by stating "it has
been calculated that a nonsmoker would inhale volatile nitrosamines
13

equivalent to...35 filter cigarettes." What evidence exists that
this magnitude of exposure has, in fact, occu:cred? What the author
alsc fails to include is the f?^_t that "no ep;c?emiological data
exist linking human respiratory cancers to volatile nitrosamines."
*
([g]; see also comment to Chapter 6, p. 71)
The author makes further statements based on "the assumption that
formation of cotinine...and clearance from the body does not differ
substantially from smokers to nonsmokers". It is known, however,
that formation of cotinine and clearance from the body do differ
*
substantially [2,45].
What is the relevance of the :.ote ddded regarding the RSP/nicotine
ratio and the resulting calculated RSP?
RSP/nicotine ratios are
known to vary from 2:1 up to 100:1 across normal environments.
This calculation serves no useful purpose. If you want to know
RSP with any degree of confidence, you must measure it. This note
should be deleted.
p. 90 - The author presents a one-sided viewpoint ("may
substantially underestimate") on the ability :)f nicotine absorption
to predict exposure to other ETS constituents. It is at least
equally likely (and never mentioned by this author) that nicotine
absorption would overestimate exposure to other ETS constituents
k,aGFc'. on possibilities of nicotine in the di.et: (see comment to p.
80) and of a detectable nicotine background in the absence of other
ETS constituents (see comment to p. 58 [Ch. 5]).
* "[]" refers to Chaps. 5-8 Index.
14

The author attempts to support his view of the appropriateness of
RSP measurements for ETS exposure with a reference to the Surgeon
General's report: "...*_:±e relationships of RUSP mea=»rPneTt.z to ETS
are quite accurate". This comment is taken out of context and
appears to be slanted solely for the author's purpose. The actual
quotation from the Surgeon General's report is "At a practical
level, the technology for measuring nicotine levels and RSP levels
is available and accurate." The author should strive to remain
objective in presentation of the relevant issues.
p. 91 - It is not a consensus among researchers in the field that
RSP is the best atmospheric marker of ETS exposure. This is the
author's opinion.
It is incorrectly stated that the cotinine measures reflect the
actual dose of an ETS constituent. The confounding factors (diet,
background nicotine) were never presented. The statement that
cotinine measures "may substantially underestimate exposures to
other constituents of ETS" is totally unfounded. As stated
previously, it is equally likely (if not more so) that these
measures will overestimate actual ETS exposures.
It is presented as an advantage that RSP-based estimates are model-
based_ In reality, this is its second most serious drawback (the
first being that,RSP 41 ._ not specific to ETS). In discussing the GE)
Qn
drawbacks, the author fails to point out these limitations or the .~
.~
fact that RSP in nonsmokers is not absorbed in the same manner as N
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4D
it is in smokers [2]. ~-A
15
