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REVIEW OF: ENVIRONMENTAL TOBACCO SMOKE A COMPENDIUM OF TECHNICAL INFORMATION= by Simon Turner, Healthy Buildings International, Inc. L LI Introduction Healthy Buildings Internationa:l, Inc. (HBI) is a company that specializes in the study and assessment of indoor air pollution. Since we incorporated in 1981, 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 syndrome" -- and to recommend remedial s~=eps. Our building 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 Administratioi 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 rX Information" based upon our extensive experience with indoor ~ .1 air quality problems. In addition to a number of specific N ~ ~ substantive flaws contained in the document, this compendium t~

rI L on environmental tobacco-- smoke ( ETS )- --sarrc:t-ionedr-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 t:he public the impression that its removal will solve a].1 indoor air problems, thus giving an entirely false sense of security. We frequently investigate buildings on account of complaints from occupants with symptoms such as eye and nose irritation, fatigue, coughing, rhinitis, nausea, headaches, sore throats and general respiratory problems. 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. In addition, similar symptoms are reported by those individua:ls with allergies to specific fungi such as aspergillus, cladosporium, and penicillium, among others, as well as to miscellaneous bacterial aerosols. Overlapping symptom;3 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 determined high levels- of environmental tobacco smoke to be the immediate cause of indoor air problems 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-1-978 to 1983,_-the Nationa-1--Insti=tube=-for -- ~ Occupational Safety and Hea-lth- ( NIOSH} _ found that -.onl.y. four of-. the buildings studied (two percent) had indoor air 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 pounds of fungi, dust, and dirt have been removed from such ductwork. Bird, insect, and rodent carcasses and excess amounts of dust have been found in many buildings where of employees have complained of eye irritation, headaches, fatigue, nausea, allergies, and general respiratory problems. Of course, since the ductwork is out of sight, 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 primarily from energy conservation efforts to seal buildings and reduce the i-nfiltration/exfiltration of air. Such efforts

1J U, have reduced -the. natural -infiltration--of~ Eresh--air- that previously existed in:many buildings-,-exacerbating.the oftem- undiscovered problem of a poorly designed 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 effort 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 morning. 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 fr•esh 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 tc floor. Improper ventilation can sometimes be-carrit-d to extremes. Typically

we find the_ fresh.-ai-r :.damper%.:-we-re .closed-_ completely-- in- over - 35% of those buildingsd studied by. HB:I. One misguided engineer- actually had bricked up the fresh air vents to save energy. All of these buildings were operating wil:h 100% recycled indoor air. The lack of an adequate fre;3h air supply, coupled with dangerously low air exchange rates, has 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 indoor 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 Pollution 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 air were threefold:

(1) Poor Ventilation Inadequate ventilation 62% Zero fresh air intake 33% (2) Poor Filtration • Inefficient air filters 43% (3) Dirt in Ventilation Systems Conta nated air handlers 36% Contaminated ductwork 22% I We are convinced that improving ventilation rates, upgrading filters, and cleaning up the air handling system . will eliminate over 80% of indoor pollut.Lon problems.. Such' changes will improve worker productivity, enhance staff morale, and reduce absenteeism however, inany managers have decided to ban smoking as an apparently cheap and easy way to solve indoor air quality problems. Unfortunately, this simply does not work. HBI has determined that the presence of high concentrations of tobacco smoke indicates that a much more serious problem exists. Poor ventilatioz and improperly maintained ventilation systems are the primary 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 Persistent can be resolved only pr-epared to focus on appropriate manner. not a cause of these no cure. dangerous than ETS. indoor air quality complaints therefore if building managers and operators are building air handling systems in an High concentrations o.f ETS are sumptom, complaints. Its elimination can effect

r+) i c CRITIQUE.OF COMRENDIUM. There follows specific comments on selected chapters of this compendium, either where we feel there are flaws or misconceptions, or where we have constructive contributions to make. General We feel that in many areas of ttiis compendium the list of papers and authors referenced to tends 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 relevant in each chapter. Chapter 5 We do not have any major philosophical.bones of contention with this chapter, except that a better author who has published extensively in this specific field might have been Delbert Eatough, of the University of Utah. One technical point where we would take issue is the contention that 2.5 µg/m3 should be used as the cutoff point for respirable sized particles. The American Conference of Governmental Industrial Hygienists (ACGIH) clearly specify that collection devices for respirable particulate mass should have a medium cutoff size of 3.5 um. (AFpendix D, Threshold Limit Values and Biological Exposure Indices for 1989-90). Thef use of 2.5 µg/m3 instead of a commonly accepted value of 3.5 µg/m3 will artificially increase the percentage of ETS derived particulate present.in incoor RSP, since ETS

particles are almost ail.be_low-.2:5 µg/m3 in size:----There is a t t. Ii 4 . large body ofa data on indoor_RSP taken-at 3.5 um,.including Repace and Lowry's own work with piezobalances. A portion of the size fraction between 2.5 µg/m3 and 3.5 µg/m3 does indeed enter the respirator tract, and there is no evidence to suggest this size fraction is ,physiologically-significant. Of the nicotine sampling method, Healthy Buildings International (HBI) has been using the XAD-4 sorbent method for the past two years and has collected over 500 nicotine samples this way. It has proven robust, sensitive and reproducible; we support the acceptance of this method. Finally, the statement concerning the lack of health standards for controlling exposures to nicotine (p. 58) is not entirely true.' There are indeed health standards specifically meant for controlling airborne nicotine levels, published both by the ACGIH and by the British Health and Safety Executive of 500 µg/m3. Chapter 6 The paragraph on page 66 and 67 (size distribution and composition of particulates) is flawe-d -- the data they refer to on both size distribution and composition refers specifically to the outdoor case. One large area of research still to be explored in indoor air quality science is particle characterization. There is very little ].ikelihood that particle size distribution indoors is the~ same as outdoors, and even less likelihood that elemental composition of --particles indoors and• outdoors.. is. the same. For instance,

there are more sources of.-:iron, fibers-;.= aotton__dus-t:,..paper-;:. r In , mites, and organic mat-erial-s..indoors:.than outdoors.- - Specifically, Dzubay and Steven's work on particle size fractionating was primarily on outdoor air samples. ASTM are.currently exploring the possibility of developing a dust which more accurately approximates indoor particles for calibration of particle mass monitoring equipment. EPA will be asked to assess the feasibility of developing such a dust. Much of the remainder of the chapter concerns particle measurement results from different authors. Many of these samples were taken using the piezomicrobalance, and HBI has much experience using this instrument in thousands of locations,in the hundreds of buildings across the world. For instance, in 1989, in 26 office buildings in Switzerland, HBI found mean RSP values from between 26 and 63 µg/m3 (Environmental Technology Letters; in preparation). Smoking was discretionary in most of these buildings. Examining the data presented in this review, we find that in general this range is consistent with other workers' findings for this type of building. The chapter is confusing, however, because under the heading of "particulate concentraticn in offices" (in which much of the debate on control of ETS is currently centered) we find reference to Repace ard Lowry's work ten years ago in'non-smoking libraries and churches, compared to premises allowing smoking, namely bars and grilles, bowling alleys, cocktail lounges, barbecue restaurants,. all areas

-which by their nature_are-heavily-polluted.:env:ironments.--(Table' - 5). Not surprisingly,.-RSP values--measured-by the-same piezobalances tend to be an order of magnitude higher in these environments. Yet this data is presented as evidence of high levels of RSP to be found as a result of smoking i.n offices. Given recent measurements made in offices at today's levels of office smoking, it should be accepted that RSP levels, even where smoking is allowed, do not reach levels claimed by Repace et al. The selection of nicotine levels quoted in Table 7 is also not representative of most workplace environments. HBI Inc. has over the last three years been measuring nicotine in some six hundred office locations and the mean value to date approximates to 4.0 µg/m3. Overall, the chapter is selective in its choice of references; once more, Eatough's work should have been referenced in this section. Furthermore, other more recent work on measurement of ETS exposure in offices apart from our own is available which has been ignored - this includes authors such as Sterling (Theodor D. Sterling & Associates Ltd., Vancouver, Canada) who has published extensive data on ETS levels in buildings and Kirk (Imperial College, London) who has data on British ETS levels. Chapter 7 . The estimation of human exposure levels of a pollutant based either on modelling or measurements of some supposedly rep.resentative parameter depends-crucially on -the

i Vl I L, accuracy of the=original assumption..or-,the representativeness- of the measurements made.- That is why.- -measurement--methods- development for ETS is so important. Unfortunately, much of James Repace's,exposure estimations are riot based on realistic original data or assumptions. This critique will demonstrate areas of this chapter where this is the case. A prime example of this poorly conceived initial assumption is found on page 85. Repace picks measurements from 42 "smoking" buildings; a substantiaLl number of which are those bowling alleys, casinos, bars, barbecue restaurants and cocktail lounges referenced to in the previous chapter we reviewed, and compares them with twenty-one non-smoking buildings (such as churches and libraries) and concludes that about 85% of the indoor RSP is due to ETS. Reference to Eatough's work where he reviews exposure assessment methods shows he estimates about 50% of indoor RSP due to ETS. The difference is explained because Repace did not compare like buildings with similar activities in each, which generated equivalent amounts of non-ETS derived RSP. In Section D, in support of hi:; modelling assumptions, he states, "Field studies of` RSP in buildings where smoking occurs suggest that RSP from ETS contributes 80 to 90 percent of the particulate load during the period of smoking,-and that it persists for long pe!riods after smoking ends at typidal building air exchange rat:es, thus prolonging nonsmokers' exposures." Of course he is referring once more to his-unique collection=of bui-ldings., and-the statement---

, fl concerning the pers-istenc.e, of ETS -is - in--di-rect_- contrast with our -own work on the topic •of office_ environments-. - In Section C he also mentions t:hat exposures on aircraft can be considerable. This contrasts with the FAA and NIOSH findings of mean RSP levels of only 40 µg/m3, and maximum of 120 µg/m3. Measurements by Drake found a mean level of 14 µg/m3 and a maximum of 41 µgfm3. . Repace goes on to explore the concept of cigarette equivalents. This concept has to be used with care -- the basis on which such estimations are made must be carefully stated. For instance, based on his assurnptions, he estimates nicotine uptake in non-smokers to be equivalent to between 1/6 and 1/3 of a cigarette per day. However, in our previous studies of approximately 600 offices sampled on a worldwide basis where smoking was allowed, the ave::age airborne concentration of nicotine was 4.0 µg/m3. Using breathing rates as publi;3hed by ASHRAE, the average individual in an office inhales 3.6 liters of air per minute or 4.13 cubic meters of air per eight hour day. If the average nicotine content of that air was 4.0 µg/m3, each individual could inhale 16.52 micrograms of nicotine through- out the course of each day. Since the average smoker in the USA inhales 880 micrograms of nicotine per cigarette, the non- smoker exposed to 16.52 micrograms per day could inhale 0.019 QC "cigarette equivalents" per eight hour day, in contrast to ~ -IT Repace's estimates of 0.17 to 0.33 nicotine cigarette equiva- ~ lents.' ~

Finally, RSP is defined early on in this•chapter--as that portion of the particles below -2.5 um:. For reasons-_ discussed in the review of chapter 6, this figure should be 3.5 um. The piezobalance used for Repace's own work to which he refers is equipped with a size selectiv.e inlet of 3.5 um. In sui~mary, the assumptions on which exposure assessment models are based must be carefully examined since they will have such a strong influence on the outcome of such an exercise, and the policy decisions on which they are based. In our opinion, much of the data from which Repace's assumptions are derived are unrealistic, and not representative of the typical workplace environment, yet the workplace is where much of the smoking policy decision making is currently taking place.