NYSA TI Single-Page 3
Testimony on 29 CFR Parts 1910, 1915, and 1928 Indoor Air Quality; Proposed Rule
Abstract
School of Hygiene and Public Health 615 N.
Fields
- Named Organization
- American Heart Association (Voluntary health organization that focuses on cardiac health)Voluntary health organization that focuses on cardiac health and stroke. AHA occasionally teams with tobacco retailers to engage in promotions/fund-raisers (see http://www.smokefree.net/doc-alert/messages/247136.html and http://www.rawbw.com/~jpk/stand/Pictures.html).
- American Thoracic Society (Thoracic medicine)
Organization for professionals involved in the field of thoracic (chest) medicine.- *Department of Health and Human Services
- *Department of Labor (use United States Department of Labor)
- Environmental Protection Agency (EPA)
- Government Printing Office (GPO)
- Harvard College (Harvard Collge is the undergraduate branch of Harvard Univer)
- Harvard School of Public Health
- Health Effects Institute
- Institute of Medicine
- International Agency for Research on Cancer ("IARC") (International Agency for Research on Cancer ("IRAC"))
International Agency for Research on Cancer ("IARC")- Johns Hopkins University
- National Academy Press
- National Institutes of Health
- National Research Council
- Occupational Safety and Health Administration (Held hearings in 1994 to ban smoking in workplaces)
OSHA opened hearings in September 1994 on a proposal that amounts to a virtual ban on smoking in every workplace in the nation- Occupational Safety and Health Administration (OSHA)
- Research Council
- University of New Mexico School of Medicine
- University of Rochester
- World Health Organization (Concerned with global public health)
International organization concered with public health worldwide - American Thoracic Society (Thoracic medicine)
- Named Person
- Dekker, Marcel
- Reinhold, Van Nostrand
- Samet, Jonathan M.
- Spengler, John D., Ph.D. (Public Health School, Harvard U.)
- Reinhold, Van Nostrand
- Date Loaded
- 18 Jul 2005
- Box
- 8705
Document Images
TESTIMONY ON 29 CFR PARTS 1910, 1915,
AND 1928
INDOOR AIR QUALITY; PROPOSED RULE
1926,
DEPARTMENT OF LABOR, OCCUPATIONAL SAFETY AND
HEALTH ADMINISTRATION
Jonathan M. Samet, M.D., M.S.
Professor and Chairman
Department of Epidemiology
The Johns Hopkins University
School of Hygiene and Public Health
615 N. Wolfe St., Suite 6039
Baltimore, MD 21205
Phone: (410) 955-3286
Fax: (410) 955-0863
(Version: 8112/94)
T102321389

INTRODUCTION
My name is Jonathan M. Samet. I am a medical doctor, trained-
in Internal Medicine and the subspecialty of Pulmonary Medicine. I
received an A.B. degree from Harvard College and an M.D. degree
from the University of Rochester School of Medicine and Dentistry. I
am also an epidemiologist and have received_a Master of Science in"
epidemiology from the Harvard School of Public Health. Most of my
professional career has been spent at the University of New Mexico
School of Medicine, where I most recently had the title of Professor
of Medicine and Chief of the Pulmonary and Critical Care Division of
the Department of Medicine. I recently assumed my present position
as Professor and Chair of the Department of Epidemiology of the
Johns Hopkins University School of Hygiene and Public Health.
My ~linical practice has covered the full range of pulmonary
diseases but more recently it has increasingly focused on the
diagnosis and management of patients with occupational and
environmental lung diseases. I have provided clinical care for
patients with problems stemming from indoor air pollution
exposures and for patients with the clinical syndromes referred to as
Sick Building Syndrome and Multiple Chemical Sensitivity. In New
Mexico, my research emphasized the effects of inhaled agents on
health and particularly outdoor and indoor air pollutants, including
radon, nitrogen dioxide (NO2), and environmental tobacco smoke
(ETS). This research has addressed the non-malignant and malignant
effects of ETS, nitrogen dioxide and respiratory illnesses, and radon
and lung cancer. I have also conducted studies directed at time-
activity patterns and personal exposures to pollutants and I have
studied the effects of active smoking. I have authored or co-
authored many scieniific papers on these topics and with a colleague
at the Harvard School of Public Health, John D. Spengler, Ph.D., I
edited a book, Indoor Air Pollution: A Health Perspective, which was
published by Johns Hopkins University Press in 1991. More recently,
I edited Epidemology of Lung Cancer which was published by Marcel
Dekker, Inc. in 1994.
I have served on a number of committees and advisory groups
concerned directly or indirectly with indoor air quality and health.
These include the Indoor Air Quality and Total Human Exposure
Committee of the Science Advisory Board of the Environmental
Protection Agency: the National Air Conservation Commission of the
A ~erican Lun~ Assoctauon: and SSPC 62 of the American Society of
}tcatin~. Retrtgerat~ng. and Air Cond~tionin~ Eng.~neers tASHRAE~
TI02321390

which is charged with revising the organization's Standard 62. I also
served on the Working Group on Tobacco Smoking of the
International Agency for Research on Cancer and was a Consulting
Scientific Editor for the 1986 Report of the Surgeon General on
involuntary smoking. I was subsequently the Senior Scientific Editor
for the 1990 Report of the Surgeon General on smoking cessation. I
am presently Chairman of the Biological Effects of Ionizing Radiation
(BEIR) VI .Committee of t_he National Researc__._h+~ Council. I served on
BEIR IV and was Chairman of the Panel on Dosimetdc Assumptions
Affecting the Application of BEIR IV Risk Estimates.
THE PROBLEM OF INDOOR AIR POLLUTION
Indoor air pollution is a complex societal problem. We spend
most of our time indoors and we expect that our indoor
environments will not be a cause of discomfort and disease.
Mounting evidence, however, has shown that indoor air pollution can
cause a wide range of adverse effects, ranging from discomfort and
annoyance at the least severe to death at the most severe. As we
have characterized time-activity patterns of the population, that is
the locations where people spend time and the amounts of time
spent in these locations, we have gained an understanding of the
contributions of various indoor environments to personal exposures
to pollutants. Studies of time-activity patterns and personal
exposures indicate dominant contributions from indoor environments
for exposures to many pollutants that have adverse consequences.
As would be anticipated, the workplace and the home are the
strongest contributors for most agents.
The Occupational Safety and Health Administration (OSHA) is
addressing the adverse effects of exposures received in the
workplace in its Proposed Rules. This testimony, presented in
support of the Proposed Rules, covers the adverse health effects of
indoor air pollution and the mechanisms underlying these effects and
considers the potential benefits of compliance with the rules
proposed by OSHA.
The Proposed Rules are timely. Data on the health effects of
indoor air pollution have largely been collected over the last 20
years; the evidence is now sufficient to identify some adverse effects
with certainty and the experience of the diverse professionals
concerned with indoor air pollution, documented in the submissions
~n response to OSHA's Request for Inforr~ation (56 FR 47892).
suggests that adverse effects may be increas~n~. Addtttonall.x. a
TI02321391

large number of professionals, including engineers, indusu'ial
hygienists, and others now work to solve problems of indoor air
quality in non-industrial buildings. ~ fortunately, because of the
proprietary nature of this work, there is no quantitative information
available on the numbers of buildings which have had problems of
severe enough magnitude to require evaluation and remediation.
Thus, even though there are acknowledged uncertainties in our
understanding of indoor air pollution and health, the public health
burden posed by the adverse consequences of indoor air pollutants
has become sufficient to warrant implementation of regulations by
OSHAo
However, the Proposed Rules address a problem quite different
from the regulation of a single agent that may be linked to one or
more specific health outcomes, e.g., asbestos and asbestosis,
mesothelioma, and lung cancer. Indoor air may be contaminated by
many different pollutants causing disease through diverse
mechanisms. The pollutants exist in complex mixtures and the
presence of one pollutant in the mixture may augment (synergism)
or diminish (antagonism) the effect of another pollutant.
Environmental tobacco smoke, a pollutant considered in the Proposed
Rules, is itself a complex mixture of gaseous and particulate agents
produced by tobacco combustion. Some of the approaches outlined in
the Proposed Rules are appropriately not directed at single pollutants
but at managing the problem of indoor air pollution at a more holistic
level. This type of approach is warranted rather than the presently
unworkable alternative of proposing concentration guidelines for
individual pollutants or for pollutants that might be considered as
indicators for complex mixtures.
Multiple mechanisms underlie the adverse effects of indoor air
pollution. The principal mechanisms include immediate and .delayed
hypersensitivity, infection, irritation of mucous membrane receptors,
inflammation of epithelial and alveolar surfaces, interference with
oxygen transport, and carcinogenesis, and some effects probably
have a neurophysiological basis. For some pollutants and adverse
effects, underlying pathophysiologic mechanisms have been
:ldvanced but remain to be established. For example, the Sick
Building Syndrome has been postulated to reflect irritation of
receptors in mucous membranes by volatile organic compounds
(Molhave 1992). Some effects of indoor air pollution may reflect
.~everal different mechanisms. Thus, Sick Building Syndrome has also
been linked to biological agents in addition to volatile organic
compound~ Iln.~itute of .Medicine, 1993).
T102321392

While t.hcse mechanisms arc presently considered to be the
basis for most of the adverse consequences of indoor air pollution,
the specific causal pathways remain to be established for a number
of the outcomes. Sick Building Syndrome, for example, has been
associated with inadequately maintained heating, ventilating, and
air-conditioning systems, although causal links to specific agents
have not uniformly bccn made in investigations of individual
buildings (Marbury and Woods 1991).
The spectrum of the adverse outcomes also differs from the
clinically dcfinext, effects of most regulated occupational agents; For
indoor air pollution, some adverse effects are well characterized and
represent distinct clinical entities, e.g., hypersensitivity pneumonitis
and pneumonia caused by Legionella. However, some of the most
frequent adverse consequences, discomfort, irritation, and symptoms
compatible with the Sick-Building Syndrome, arc not yet well
characterized from a clinical perspective, in spite of their prevalence
in the workforce, which is likely to be high, and their significant
impact on productivity. Even "though these symptom responses
might not bc classified as diseases, they adversely affect health when
defined broadly, as by the World Health Organization, to include
well-being. The Proposed Rules acknowledge this range of responses
and the complexities of defining some adverse consequences of
indoor air pollution without ambiguity should not dissuade OSHA
from proceeding.
Table I provides a classification of the full range of responses
to indoor air pollution, including categories for disease, impairment,
symptoms, increased risk, and perceptions (Samet 1994). This
classification is based on a plenary presentation made at Indoor Air
'93, an international congress on indoor air that is held every three
years. Each category in this classification is treated below and
examples provided. The classification serves to illustrate the range
of responses of concern with regard to indoor air pollution and the
extent of the adverse effects that OSHA needs to address.
Few quantitative estimates of the burden of disease posed by
each of these categories have been made. Risk assessment not only
requires the determination that an agent poses a hazard but also
characterization of the relationship between dose and response and
of the distribution of exposure. The requisite data are not available
for most indoor air contaminants of concern in the work place,
although risk estimates have been made for ETS and asbestos.
If appropriately catalogued, the existing data might prove
more informalive with regard to exposures to some ~ndoor air
pollutants and var~ou.~ admintstrat~ve data bases assembled for
5
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health care could provide insights into the frequency of some key
conditions and illnesses, such as pneumonia caused by Legionella
and hypersensitivity pn.eumonitis. The prevalence of symptoms
and discomfort could be determined by survey techniques. Creating
a registry of buildings where complaint, s compatible with Sick
Building SyndTome have been investigated would also be
informative. We lack information on dose-response relationships
for a number of key pollutants. Only caref~d~epidemiological and
toxic.ological research can address this gap.
Clinically Evident Dise0se: While exposures to indoor air pollutants
are universal, clinically-diagnosed eases of pollution-related disease
appear to be relatively infrequent, although most clinicians do not
actively pursue associations between disease and environmental
exposures, including indoor air pollution. In fact, a clear
relationship with indoor pollution may be clinically very difficult to
establish, because even the patient may be unaware of the relevant
exposures. In the ease of such a clinically evident disease, a link
can be established to an indoor pollutant by specific diagnostic tests
(Table 2). For example, an appropriate clinical picture and an
elevated serum precipitin titer arc sufficient to document
hypersensitivity pneumonitis due to thermophilic actinomycetes_
contaminating an air conditioning system (Weissman and Schuyler
1991). The level of carbon monoxide bound to hemoglobin
(carboxyhernoglobin) provides a marker of exposure to
concentrations of carbon monoxide associated with carbon
monoxide poisoning. Skin tests and serologic tests can provide
evidence of sensitization to antigens that produce disease through
immediate hypers.ensitivity responses.
In classifying illnesses associated with public and commercial
building environments, this category of adverse effects, e.g.,
hypersensitivity pneumonitis, has been referred to as specific
building-related illnesses or building-related illness, as in the OSHA
Proposed Rules (American Thoracic Society 1990; Marbury and
Woods 1991). However, the distinction between specific building-
related illnesses and the non-specific syndrome referred to as Sick
(or Tight) Building Syndrome rests on the establishment of a clinical
diagnosis for the former category. This group of adverse effects,
clinically evident disease, should be recognized as unified on this
basis.
Lung .cancer caused by indoor carcinogens can also be placed in
thl.,, category, although ~.t is separalely considered below under the
category. "increased r~sk of disease". Respiratory carcinogens ~n
6
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indoor air include ETS, radon, and asbestos. In the workplace, ETS is
of principal concern. The U.S. Environmental Prot~fion Agency has
re, cendy made estimates of the number of lung cancm- cases
attributable to ETS, but did not sp~cifically estimate the number of
cases attributable to involuntary exposure in the workplace (U.S.
Environmental Protection Agency 1992). Estimates have been made
for various scenarios of indoor exposure by the Review Panel of the
Health Effects I'nstitute-Asbestos Reseat.ch Cl~alth Effects Institute
Asbestos Research Literature Review Panel 1991).
Exacerbation of Established Disease: Conditions that may be
exacerbated by indoor air pollution are common in the work force.
As much as 30 to 40 l~rcent of the population is atopic, that is
allergic, and at risk for hypersensitivity responses to indoor
allergens (Institute of Medicine, 1993). Asthma, a chronic
respiratory disease characterized by hyperresponsiveness of the
lung's airways to environmental factors, affects approximately 5% of
adults (National Asthma Education Program 1991). Chronic
obstructive pulmonary disease or COPD, also a chronic respiratory
disease but characterized by permanent reduction of lung function,
affects several percent of adults (U.S. Department of Health and
Human Services 1984). Coronary heart disease becomes manifest in
middle-aged and older adults, also affecting several percent of
:tdults (U.S. Department of Health and Human Services 1990).
These. susceptible members of the work force are at greater
ri.,k frorfi a variety of indoor pollutants. Indoor exposures to animal
danders, molds, and allergens from house dust mites~and other
ta,~:cts may both cause and worsen the clinical status of persons -
~ith asthma. To date. the evidence on indoor air pollution and
a-thma primarily comes from research in the indoor environment.
I lowcver, the same exposures should have--comparable effects in
t~lher settings, including the workplace. Environmental tobacco
• ,mok¢ rll:t.v increase the non-specific responsiveness of the lung to
cnslronmental stimuli and even trigger attacks of asthma (Samet,
('aln Cl al. 1991). in managing patients with more severe asthma,
partleul:trl.v if therapy has not been effective, my clinical approach
=tt,'ludes a detailed assessment of environmental exposures at home
and :it work. ETS and. other inhaled i~tants would be anticipated
to atleer persons with COPD and individuals with coronary heart
dl,,ca,,t2.~ may be adversely impacted by carbon monoxide.
l,,rt',t-~'d Rt,I, for Digease" Many pollutants in indoor air are
.t-,.t~,'talt2d x~llh mcrea.,,ed risk for a variety of malignant and non-
T102321395

~ignant diseases (Table 3). The evidene~ suppo~ng the
relationships b~twe~n exposures to tlmse agents and increased risk
comes from epid, miological studies, short-mrm exposures of
volunteer subjects, animal studies, and in vitro toxicological studies.
The population burden of disease attributable to such agents is
often estimated using quantitative risk assessment, as has been.
done for ETS, radon, and asbestos.
Physiologic ImDairment: Exposures to indoor pollutants can impair
physiological functioning, although not to a degree necessarily
associated with disability or disease. For example, exposure to ETS
during childhood reduces the rate of lung growth and the maximum
level of lung function achieved; the averag_e, estimated ~ffect is not
anticipated to be clinically detectable nor to be associated with
reduced functional capac!.ty (Samet, Cain et al. 1991). Similarly, low
levels of chrbon mtnoxide exposure transiently impair oxygen
delivery to tissues; however, the impact on exercise capacity is
limited and likely to be manifest only during maximal activity
(Coultas and Lambert 1991). On the other hand, reduced oxygen
transport in the carbon-monoxide-exposed individual with coronary
artery disease may increase the likelihood of clinically significant
myocardial ischemia. The public health relevance of this category
of adverse effects of indoor air pollution has received little
consideration to date.
Symptom R~spon~e~;: Epidemioiogical evidence links specific indoor
air pollutants to a variety of symptoms. Environmental tobacco
smoke exposure, for example, has been causally associated with
increased risk of respiratory symptoms in children (U.S. Department
of Health and Human Services 1986), and some studies indicate
increased risk for exposed adults as well. The Sick-Building
Syndrome is a non-specific constellation of symptoms
characteristically affecting multiple occupants of a building
(American Thoracic Society 1990). However, it is very difficult for a
clinician to establish an association between symptoms and air
pollution exposure in an individual patient and the diagnosis of Sick
Building Syndrome should be made in an epidemiologic context, that
is with evidence that multiple individuals in the work place have
been afffected.
Estimates of the burden of symptoms associated with indoor
air pollutants have not been made; however, this burden is likely to
be substantial because of the high prevalence rates of exposure to
agents associated with symptoms. Surveys of the prevalence of
8
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work-related symptoms, although not conducted in random samples
of b~ildings, indicate high prevalence rates for symptoms. Burge
and coworkers (Burgc, Hedge et al. 1987) described symptom rates
in 4,373 office workers in 42 different buildings. Symptoms were
considered work related if they occurred more than twice during
the previous 12 months and improved on days away from the
office. Using this definition, the mean number of work-related
symptoms varied across the sample of buildings from
approximately 1.5 to 5. Symptoms of eye and upper airway
irritation and headaches were common (Table 4).
Perception of Unacceptable Indoor Air O_u~lity; The perception that
indoor air quality is unacceptable should be considered as distinct
from the symptoms caused by indoor air pollutants. There appears
to be a wide range of tolerance of indoor air pollution in the
population. For some, unacceptable indoor air quality reduces well-
being and for such persons, the perception of indoor air quality as
unacceptable should be classified as an adverse health effect in the
context of current concepts of health. Judgments as to the
acceptability of indoor air quality presumably integrat_e .multiple
characteristics of the air, including the presence of odor and
irritants, humidity, air movement, and temperature (Berglund and
Lindvall 1990; Spengler and Samet 1991). Undoubtedly, there is a
range of responses and expectations across the population. Physical
and psychological aspects of the environment not directly related to
indoor air quality may also influence judgments as to the
acceptability o~" indoor air quality.
The findings of a nationwide survey of U.S. office workers
suggest that dissatisfaction with the air quality in offices is common
(Woods, Drewry et ai. 1987). Of 600 workers surveyed by
telephone in 1984, 20% perceived that their work performance was
affected "often" or "sometimes". Aspects of indoor air quality that
were found to be "very serious" or "serious" by at least 50% of the
affected respondents inctuded lack of air movement (67%), being
too hot in summer (61%), stagnant or still air (55%). cigarette smoke
(54%), being too cold in winter (53%), and being too humid in
summer (50%).
Perception of Exposure to Indoor Air Pollutants: The perception of
exposure to indoor pollutants should also be regarded as an adverse
heahh effect, if this perception reduces well-being. The range of
re.,,pon.~e.,, to the perception of exposure is broad, extending from
anno.~znce because of an odor to the sometimes d~sabling symptom
9
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complex now frequemtly referred to as "multiple chemical
sensitivity". The pathogenetic mechanisms underlying multiple
chemical sensitivity remain unknown and may be multiple. The
numbers of persons who are adversely affected by the perception
of exposure "eannot be presently estimated.
i0
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ENVIRONMENTAL TOBACCO SMOKE
Environmental tobacco smoke is among the~ingle pollutants
targeted specifically for control in the Proposed Rules. This term
refers to the mixture of sidestrcam smoke and exhaled mainstream
smoke that contaminates air in spaces where smoking is taking place.
Although referre~l to as though it w~r~ a single agent, ETS is a
complex mixture of particles and gases that is known to have many
of the same toxic and carcinogenic components that are present in
the mainstream smoke inhaled by the active smoker (U.S.
Department of Health and Human Services 1986; U.S. Environmental
Protection Agency 1992). Markers of tobacco smoke can be
measured in smoking-contaminated air, e.g.., nicotine, and uptake of
ETS components by nonsmokers has been shown using cotinine and
other biomarkers.
Active smoking has diverse adverse effects including being a
cause of cancer and a number of non-malignant conditions as well.
This evidence has been comprehensively reviewed in the Reports of
the Surgeon General on smoking and health. In regard to exposures
of adult nonsmokers in the workplace to ETS, the literature on active
smoking indicates a basis for concern about risk for lung cancer and
for heart disease. Active cigarette smoking has long been established
as a cause of lung cancer, with the risk varying with the number of
cigarettes smoked per day and the duration of smoking, as well as
other aspects of smoking behavior and the type of product smoked
(U.S. Department of Health and Human Services 1982; U.S.
Department of Health and Human Services 1989). The risk for
coronary heart disease is also increased by cigarette smoking with
the risk d.ependtng most directly on being a current smoker and the
number of cigarettes smoked per day (U.S. Department of Health and
Human Services 1983; U.S. Department of Health and Human Services
1990).
In fact, a substantial epidemiologic literature indicates increased
risk for lung cancer in never smokers exposed to ETS (U.S.
Environmental Protection Agency 1992). These epidemiologic
studies are largely of the case-control design, comparing exposures of
never smokers with lung cancer to those of control never smokers
without lung cancer. The principal exposure variable assessed in
these studies has been marriage to a smoker, based on the
as.,,umption that never smokers married to smokers sustain greater
exposure at home than ne~er smokers married to never smokers.
The ~elght of the evidence ind)ca~es increased lung cancer risk for
II
T102321399

never smokers married to smokers; the causal nature of this
association is further supported by l~res~nt understanding of
respiratory carcinogenesis CU.S. Department of Health and Human
Services 1986; U.S. Environmental Protection Agency 1992). Only a
few stu~dies have addressed exposure to ETS in the workplace and a
precise estimate of the risk of workplace exposure is not available.
It would be anticipated that the risk would be variable among
workplaces, depending on the level .of contamination and the
duration of exposure. There is no r~ason to assume that an agent,
tobacco smoke, that has been shown to be a carcinogen when actively
inhaled during active smoking and passively inhaled at home, would
not be a carcinogen when involuntarily inhaled in the workplace.
For coronary heart disease, the epidemiologic evidence on
passive smoking is less abundant, but does indicate increased risk
(American Heart Association 1992). Mechanisms have been
postulated on the basis by which ETS could cause coronary heart
disease and the American Heart Association has concluded that ETS is
a cause of coronary heart disease in adults. The workplace has not
received specific investigation.
Other effects of ETS exposure have been identified and
considered to have a causal relationship to exposure (l~a~ional
Research Council and Committee on Passive Smoking 1986; U.S.
Department of Health and Human Services 1986; U.S. Environmental
Protection Agency 1993). Children exposed to ETS are at increased
risk for lower respiratory illnesses during the first years of life.
Additionally, they have increased rates of respiratory symptoms and
the lung function of exposed children increases at a lesser rate than
for unexposed children. The status of children with asthma is
adversely affected by ETS (U.S. Environmental Protection Agency
1992) and ETS is a suspect cause of asthma. ETS exposure could
plausibly exacerbate asthma in adults as well. Some studies have
indicated that exposure of adults to ETS may also adversely lung
function and produce respiratory symptoms, although the evidence
has not been judged conclusive (Samet, Cain et al. 1991).
THE POTENTIAL BENEFITS OF THE PROPOSED RULES
The Proposed Rules have two elements, a broad strategy
oriented towards achieving acceptable indoor air quality through a
compliance program designed to assure indoor air quality through
buitdin~ operation and control approache.~ directed at individual
potlutant.~ or groups of pollutants including ETS. These Proposed
12
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Rules are offm'cd at a rirnc when there arc evident gaps in our
understm~ding of indoor air quality and health. Nevertheless, the
I~oposed Rules offer approaches that build on both the scientific
evidence on indoor air pollution and health and on the field --
exl~ricnce of persons who operate buildings and evaluate buildings
with problems. Benefits for health of the workforce can reasonably
be anticipated even though any quantitative estimates of the burden
of morbidity and mortality caused by indoor air pollution in the ............
work place are subject to diverse uncertainties. For ETS, exposures
can be completely avoided by prohibiting smoking and the
alternative strategy of separate smoking areas under negative
pressure should minimize exposure of nonsmokers to ETS. OSHA can
reasonably project avoidance of the burden of morbidity and
mortality associated with ETS with implementation of the Proposed
Rules.
13
Tffi2321401

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A
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U.S. Department of Health and Human Services (1990). The Health
Benefits of Smoking Cessation; a Report of the Surgeon General. DHHS
Publicatio.n NO. (CDC) 90-g416.
U.S. Environmental Protection. Agenc.~ (1992).
t5
TI02321403

Resoiratorv Health Effects of Passive Srnokin~: Lun~ caa¢~ and Other
Disorders. EPA/600/6-90/006F. Washington, DC, U.S. EPA.
U.S. Environmental Protection Agency (1993). Respiratory Health
Effects of Passive Smoking: Lun~ Cancer and 0ther_Disorders.
Washington, D.C., National Institutes of Health.
Weissman, D. N. and M. R Schuyler (1991). Biological agents and
allergic diseases. Indoor ~ oollution. A health oerst~ective.
Baltimore, MD, Johns HoI-..ns University Pross. 285-305.
Woods, J. E., G. M. Drewry, et al. (1987). Office worker.perceptions of
indoor air quality effects on discomfort and performance. Indoor Air
"87. .Proceedings of lhe 4th International Conference on Indoor Air
and Climate. 17-21 August. Berlin (West), Institute for Water, Soil
and Air Hygiene. 464-468.
16
TI02321404

Tatlle 1 A ckts~fioation of the adverse effeots of indoor air
poat,~t~on.
C3~ly evident dises~es: Disease for which the usual methods o~
clinical evalum~ "on c~ establ~ ~ ~ link to an indoor ~
polluter.
disease is exacerbated by indoor air pollution.
Inc~ased gisk for di.gease: Diseases for which-epidemiological or other
evidence establishes increased risk in exposed individuals. However,
the usual clinical methods indicative of injury typically cannot
establish the causal link in an individual patient.
Physiological impairment: Transient or persistem effects on a measure
of physiological functioning which are of insufficient magnitude to
cause clinical disease.
Symptom responses: Subjectively reported responses which van be
linked to indoor pollutants or are attributed to indoor pollutants.
Perception of unacceptable indoor air quality: Ser~.sing of indoor air
quality as uncomfortable to an unacceptable degree.
Perception of exposure to indoor air pollutants: Awareness of exposure
to one or more pollutants with an unacceptable level of concern
about exposure.
T102321405

T~le 2 Selected ex~nl~ of clin~cally evident ~ise~se linked
to indoor air pollution.
Carbon mo~v~ide poisoning
Hemorrhagic Imeumonitis~ from high level of NO:
Hyp~rs~sitivitT pneumonitis and humidifer fever
Legionella pne~unonia
Cat- and mite-induced asthma
T102321406

Table 3 ~ ~ of exposure-disease a~ons
for indoor air pollutar~
Euvironmental Tobacco Smok~: Lung cancer, increased lower
re~iramoj illness in infants
Benzene: Leukemia
Asbestus: Lung cancer and mesothelioma.
Formaldehyde: Nasal cancer.
T102321407

Vmti~o~ Type Dry Eyes BloCked No~ Dry Thr~ ~
* ~ource: Dala from Table 5 in Burge, eta]., I987.
TI02321408
