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Comments by Dr. Guy B. Oldake^ III on CHAPTER 5 MEASURING EXPOSURE TO ENVIRONMENTAL 1'OBACCO SMOKE INTRODUCTION 0 U U Ii General Comments Chapter 5 "Measuring Exposure to Environmental Tcbacco Smoke" (ETS) in its present form is an incomplete rough draft which cannot be expected to address adequately the needs of decision makers, public health officials, corporate medical directors, etc. in their efforts to malce well-informed decisions regarding the assessment of exposure to ETS. Because of the chapter's limited ;;.opa a.:d i;egl ect of a l arge amount of publ i shed 1 iterature, i t i s~^c;:,:~ ~~teni with thp theme of a compendium of technical information. The autnui., may wi~;h to consider using as a guide the document produced by Nagda and Rector ("Guidelines for Monitoring Indoor Air Quality," I:PA-600/4-83-046, September 1983) as they pursue revisions. This document provides a wealth of technical information regarding the measurement of indoor air cuality as well as a thorough review of available methods and instruments for assessing indoor air quality. The copy available to this reviewer lacked a listing of literature citations; consequently, the extent of review is severely limiti2d. Without such citations, the chapter has inadequate technical support. This reviewer recommends that additional drafts submitted contain the necessary references to facilitate adequate review. Specific Comments The Introduction, which is inordinately lengthy and reaches the point only at its very end, presents the Chapter's objectives: ~ GD ~ ~ ~ ~ 1 CD C!T

"This chapter will present a discussion of' the issues to be considered in air sampling for ETS with emphasis on air sampling in enclosed spaces rather than on personal monitoring. Selection of ETS contaminants to be monitored, available methods of sample collection and analysis, operating principles for each method, relative advantages and disadvantages of each mathod and sources for purchase of sampling equipment will be covered." Although adequately identified, these objectives are not met by the chapter in its present form.- This set of topic sentences is probably best placed at the beginning of the Introduction. In this place, it would offer the author a guide for the-revision of the Introduction, which contains much information that is not germane to the discussion. SELECTION OF ETS CONTAMINANTS FOR NIONITORING , The author on p. 55 states that ETS contains over 4,000 compounds in the particulate and vapor phases. This statement is apt to confuse most users of the document bec?use 'It suggests that these compounds have been measured in ETS, which is not tne case. The author should note that this statement derives from information on mainstream and sidestream smoke and i3 assumed to extend to ETS. Although the author lists many of ETS markers which have been used or proposed, the author fails to list several which provide apportionment for RSP and which have found wide use for assessing exposure to ETS. Thus, the author neglects to identify ultraviolet particulate matter (UVPM, a measure providing an upper estimate of exposure to ETS respirable suspended par-:icles (RSP) (Ingebrethsen, 1988, Carson, 1988; Conner, 1990; Proctor, Environ. Technol. Lett., 1989), solanesol (which provides a direct measure of ETS RSP (Ogden, Environ. Sci. Technol., 1988; Ogden, TCRC 1989)), 3-vinylpyridine (which provides a measure of exposure to the gas phase of ETS (Ogden, TCRC 1989), and fluorescent particulate matter (which complements UVPM (Ogden, "CRC 1989)). The author's discussion of ETS indicators on page E6 is misleading because it fails to distinguish between practical indicators z.nd impractical indicators. In addition, the author's reference to tables in Chapter 6 is imprecise, and therefore, also misleading. On page 56 the author :;tates: QD Co ~ .1< N 2 rA CD a~

l.: k "Carbon monoxide, nitrogen oxides, acroleir, benzene, toluene, tobacco specific nitrosamines, vapor and particle phase nicotine, isoprene, pyridine, particle phase nicotine and cotinine, respirable suspended particles, polonium-210 and benzo[a:lpyrene are among the many air contaminants that have been used or proposed for use as indicators of the presence of ETS. Tables in chapter 6 show the range of concentrations measured in a number of indoor environments were [sic] smoking occurred." Most of the substances listed are either impractical or unreliable because they occur at trace levels and because they originate from sources other than ETS. Tables in Chapter 6 suamarize data for sidestrean to mainstream ratios of various substances and results from surveys of nicotine and total suspended particles (TSP) in indoor environments under realistic conditions. Of these tables, only those presenting nicotine and RSP results are germane- to the discussion; however, these present information available in previously published documents and represent but a small portion of the data now available. The author should revise this paragraph to address practical ETS indicators. (This recommendation is consistent with thp author's statemsnt: "This chapter will focus on the use of RSP and nicotine os markers for ETS ...." The authors of Chapters 5 and 6 should coordinate their efforts to ensure that literature citations are accurate and up to date. On page 56 the author states that tobacco combustioi has a major impact on the mass of RSP, and that ETS RSP is detectable above background levels in occupied environments even under conditions of low smoking rates. These statements are ambiguous, unsupported, and to some extent, inaccurate. Because RSP is not specific for ETS, an RSP measurement in itself provides an ambiguous result for ETS'RSP without some means of apportionment. Although tobacco consumption can have a major impact on the mass of RSP, such is not typically the situation; if this were the situation, there would be no interest in the development of methods to apportion RSP. (This concern speaks also to item 2, of page 56.) The ongoing efforts to develop methods for apportioring RSP respond directly to the first of the five criteria the author lists on page 55 (for example see Ogden, Environ. Sci. Technol., 1988). The author should define "low smoking , rates," because detection of ETS RSP depends strongly on this parameter. Detection also depends on the method employed and tFe circumstances under which ~ it is employed, as is the case for integrated methods of sampling where J N 3 CD ~

{J f-' r detection is greatly affected by sampling time and therefore sample volume. Indeed, the author recognizes this limitation in Table I. Some of the methods referenced by the author will not detect ETS RSP urder typical circumstances; the author should identify these. Also on page 56, the author states: "... methods are available to accurately and inexpensively measure RSP levels ...." Accuracy needs to be addressed more fully and quantitatively within the body of the chapter, if this subject is be raised, as it should. At the end of page 56 and continuing to page 57, the author notes that "there are outdoor particle health standards established by the U.S. EPA which provide a frame of reference in interpreting measured RSP levels associated with ETS." This statement should be omitted from the text, because the "frame of reference" assumes that the reader will understand and appreciate the numerous attending assumptions that must be understood for making informed, intelligent interpretation. If this "frame of reference" is to be offered, the author should inform the reader of the technical, politica'I, institutional, economic, :nd regulatory issues which affected promulgation of the Nat'.;,,all Ambient Air Qii?l ity Standards (NAAQS) . At a minimum, the author must aaor a.s tnr imrort?nca of averaging time for interpretation. To be complete, the author should identify the standards of the Occupational Safety and Health Administration for RSP and nicotine, 2 mg/m3 and 500 µg/m3, respectively. On page 57 the author states: Some recent'field studies have found a reasonably consistent RSP to vapor phase ration [sic] between for ETS in the. residential and non- industrial occupational environments (11, 12) [references unavailable], suggesting that vapor phase nicotine, for some applications, may vary with ETS related RSP and thus be used to estimate the RSP attributable to ETS." Results from the greater number of field studies, including offices, restaurants, and passenger cabins of commercial aircraft, discount the broad applicability of this "suggestion" (Oldaker, Excerpta Medica International Congress Series 1989). Nonetheless, it might be that these results are not covered by the qualifier "some applications." The author of Chapter 5 should 4 i_

provide the reader with specific examples of situations where the suggested relation might hold and be useful. P L fl On page 57 the author states that nicotine provides a link between air concentrations of ETS and internal dose. Because the relations between nicotine and ETS constituents have not been characterized, this statement is speculation and should be either revised or omitted. On page 58 the author states that there are no health standards controlling exposures to nicotine. This'statement is false; the OSHA standard is 500 µg/m3. MEASUREMENT OF RSP AND NICOTINE IN AIR The author states correctly that concentrations of RSP, nicotine, and other ETS constituents in an enclosed space can exhibit a pronounced spatial and temporal distribution. This statement directly contradicts the fundamental assumptions made by the author of Chapter 7 for the equilibrium RSP model. The authors of the respective chapters should address and resolve this contradiction. The aut.i,G:' t.ur r-cck'?y rer.ogaizes several of disadvantages associated with use of RSP for assessing exposure to ETS. These disadvantages need to be integrated with Chapter 7 by Mr. Repace who uses RSP in his arguments to support (invalidated) models. The fundamental, unstatel issue is that RSP will overestimate exposure to ETS RSP. The question the author of Chapter 5 must address is: to what extent and under what circumstances will RSP overestimate ETS RSP? The importance of nicotine outgassing is not adequately stressed at page 58; this issue is critical to current interpretation of determinations of nicotine exposure and dose. Most investigators assume that the outgassing does not contribute significantly to measures of exposure and dose as inferred by nicotine. Results reported by Eudy (1987) and RSP to nicotine ratios reported by Oldaker (Excerpta Medica International Congress Series 1989) indicate that such background levels caused by outgassing can represent a substantial portion of the nicotine actually measured in the air, and tierefore presumably, in body fluids. 00 U) .~ ~ 5 ~ c.o

MEASUREMENT METHODS FOR RSP The author defines RSP to include particles ranging below 2.5 Am; however, a11 the measurement methods listed in the table have cut points greater than this. How can use of such methods be supported? This reviewer questions whether some of the methods should be included. In addition, the concentration ranges of the methods are shown to depend on sampling time. For the integrated methods, sampling time is only one limitation. The author shuuld provide the reader with information on detectionn as controlled by the sensitivity of the balances available-for the integrated methods employing gravimetry. The author fails to recognize the availability of the portable air sampling system (PASS), which has been used to determine levels of RSP, UVPM, carbon monoxide, and nicotine in indoor environments as part of field surveys (McConnell, 1988; Carson, 1988; Drake, 1988; Proct3r, Environ. Technol. Lett. 1989; Crouse, 1988, 1989). In addressing the "detailed comparative study" (Ingebrethsen, 1988), the author neglects to mention the methotf-for dei:erodning ultraviolet particulate matter (UVPM), whi ch al so• vras d-i scua:;cd i n the ttud,.7 The UVPM method shoul d be addressed to ensure completeness. MEASUREMENT METHODS FOR NICOTINE The author provides but scant information on the XAD-4 based method, which has been used to provide the greatest amount of inforination on exposures to ETS nicotine. In addition, the author fails to recognize use of Tenax for collecting nicotine (Jenkins, 1988; Thompson, 1989). The author should omit the discussion dealing with "small annular denuder systems," because papers on this subject have not been published. GD Qn J ~ lU 6 p O