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REVIEW OF: ENVIRONMENTAL TOBACCO SMOKE A COMPENDIUM OF TECHNICAL INFORMATION by Simon Turner, Healthy Buildings International, Inc. Introduction Healthy Buildings Internatioaal, Inc. (HBI) is a company that specializes in the study 3nd 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 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 Compe!ndium 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

4 4 14 # ~ IN w A rn .n 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 all 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 individuals with allergies to specific fungi such as aspergillus, cla3osporium, 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 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 1978 to-1983; the Naticnal Institute-for Occupational Safety and Health (NIOSH) found that only four_ of the buildings studied (two percent) hz.d indoor air quality problems attributable to high concentrations of ETS. significantly, in those few cases where we found high accumulations of ETS, we also discovei-ed an excess of fungi and bacteria in the HVAC system. The:ae 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 carcasses 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 sight, it is also invariably out of mind. Thus, it is common for the blame for these types of problems to be laid e7.sewhere. Energy Conservation Indeed,.the complex of symptoms that we have mentioned - the "sick building syndrome" - may result primarily from energy conservation e.Eforts to seal buildings and reduce the.infiltration/exfiltration of air. Such efforts

i is a- . go Am p have reduced the natural infiltration of fresh air that previously-existed in many buildings, exacerbating the often 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 micrcbes 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 oL.tdoor air. This may be the result of either a deliberate policy or shortsightedness on the part of the designers. This re!sults in the continuous redistribution of infectious microbes, allergenic dusts and spores from office to office and floor to floor. Improper ventilation can..sometimes be carried t.o extr.emes._ Typically

*4 A R4 IN L:~ W4 we find the fresh air dampers were-closed completely-in over 35% of those buildings studied by HBI. One misgu-ided engineer- actually had bricked up the fresh air vents to save energy. All of these buildings were operating with 100% recycled indoor air. The lack of an adequate fresh 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 pollLitants 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 pol-lutants at the same-time. In our U.S. experience of over 80 million square feet of building studies,-the major contr-ibutors to poor air were threefold:

I" A (1) Poor Ventilation Inadequate ventilation 62% Zero fresh air intake 33% (2) Poor Filtration Inefficient air filters 43% (3) Dirt in Ventilation Systems Contaminated air handlers 36% Contaminated ductwork 22% We are convinced that improvirg ventilation rates, w 14 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 however, many 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 ventilation and improperly maintained ventilation systems are the primary causes of poor indoor air. When such conditions prevaLl, 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 of ETS are sumptom, not a cause of these complaints. Its elimination can effect no cure.

of this CRITIQUE OF COMPENDIUM There follows specific comments on selected chapters compendium, either where we feel there are flaws or misconceptions, or where we have construetive contributions to make. General We feel that in many areas of this 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 10 This entire chapter, by its title, examines "no smoking policies" at the work site. It is obvious, however, that there are many options which will deal with the issue of smoking in the workplace. In our opinion, smoking can comfortably be tolerated in offices employing the ventilation rates as defined in ASHRAE Standard 62-• 1989. In the event that dedicated smoking lounges are specified, we again draw attention to RSHRAE's ventilation rates for these areas and suggest that all such lounges should be equipped with local area exhaust capability. Policies For Dealing with Smoking in the Workplace Attempts to solve a tobacco smoke problem alone without dealing with ventilation as a whole could leave - signif_icant =env-i=ronmental-.pr-oblems unsolved. Evidence of this

is shown in work by NIOSH and our-own published--work--which- found 2% - 4% of bui-ldings-investigated for indoor air quality problems respectively had ETS as their major pollutant source. An example of a potentially misplaced smoking ban was shown in a building owned by a majoi bank with indoor air quality complaints recently. An occupant questionnaire commissioned by the management resulted in a proposed smoking ban. On investigation of the subject building, however, the .HVAC system was found to be operating on 100% recycled air, with the outdoor air dampers closed. Even when they were open, the system was capable of deliver;.ng only 2 to 5 cfm outdoor air per occupant. The filters were found to be inefficient, and excessive fungal growths were found inside the ductwork with correspondingly high numbers of their spores in the air of the office area. Once ventilation, filtration, and hygiene were improved, complaints were reduced and the proposed smoking ban was subsequently found to be unnecessary. Designated Smoking Areas are often a practical political solution which balances the objectives of non-smokers with the smokers' wishes. laith some thoughtfulness in the selection of the smoking areas with respect to prevailing ventilation conditions, the policy of designating smoking areas works very satisfactorily. However, problems with designated smoking areas have frequently been found in indoor air quality investigations due to careless- ness. Cafeteria areas are often designated as smoking areas by management, despite ventilation systems there which are

i I I- ~i 1, clearly-unable to cope. A fundamental p.itfall of the.desig- nated smoking area concept, as-a.whole, is that in a large building served by many air handling uni-=s, it concentrates all the smokers into an area served by oaly one unit. The capacity of this unit to dilute this more concentrated smoke load is now often exceeded, delivering more, not less, ETS to non-smokers also served by this unit. If there is a requirement to establish non-smoking areas within a building, we recommend the designation of many small smoking areas throughout the building ensuring that no individual air handling unit is required to cope with more smokers than it has the capacity to handle. Air Cleaning equipment marketed specifically for removal of ETS components from room air is another option. These include electrostatic precipitators, activated charcoal filters and HEPA filter units. All three have their place in removing respirable dust from the air. Dnly activated charcoal systems will deal with odor, however. We have found that all types of retrofitted air cleaning equipment frequently are left unserviced and dirty, resulting in poor or no air cleaning capacity. The most effective devices for removal of perceived signs (both olfactory and visual) of ETS appear to be a combination of good quality filters, such as HEPA, or equivalent, followed by chemical sorption of odorous gases with activated charcoal or other proprietary media. "Dilution Ventilation" is another solution. This term refers to "-dilution of contaminated air with

- uncontaminated air- in a general ar.ea,-room-, or building-, for the purpose of health hazard or nuisance control." Those who feel that dilution v.antilation is an inadequate-solution to ETS exposure include Repace and Lowry. They maintain that for adequate protection from lung cancer, a standard of 0.75 µg/m3 RSP from ETS should be adopted in the office workplace environment. They then calculate that this would require as much as 5,400 cubic foot per minute per person of fresh air brought into the building to dilute ETS generated particulates to this level. Our data shows this figure of 0.75 µg/m3 to be an unrealistic goal. This will be I the case even in non-smoking offices. Since even dry outside air might have an RSP value of between 10 and 60 µg/m3, any attempt to attain a 0.75 µg/m3 standard when outdoor air is at these levels is clearly impractical. ASHRAE base their ventilation standard on achieving control of moderate amounts of smoking. The most practical long term solution to eliminating most ETS related problems, along with a wide range of other commonly found indoor pollutants, is to ventilate office buildings, whether or not smoking is allowed, to this standard of 20 cfm per person of outdoor air in office areas. Finally, Exhaust Ventilation offers another workable approach. This policy involves the designation of smoking areas in buildings and the retrofitting of exhaust systems to those areas. When properly installed, the advantages to this ~ -system are clear - no -reentrainment of ETS into-the return