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
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
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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
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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.
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REFERENCES
American Heart Association (1992). "Environmental tobacco smoke
and cardiovascular disease. A position paper from the Council on
Cardiopulmonary and Criticial Care, Am~rican Heart Association.:'
Circulation 86: 699-702.
American Thoracic Society (1990). "Environmental controls and lung
disease." Am. Rev. Respir. Dis. 142: 915-939.
Berglund, B. and T. Lindvall (1990). Sensory criteria for healthy
buildings. Indoor Air '90. the Fifth International Conference on
Indoor Air Quality and Climate, Ottawa, Canada,
Burge, S., ~. Hedge, et al. (1987). "Sick building syndrome: a study of
4373 office workers." Ann. Qccu_o~ Hvg. 31: 493-504.
Coultas, D. B. and W. E. Lambert (1991). Carbon monoxide. Indoor air:
a health perspective. Baltimore, MD, Johns Hopkins Uni.versity Press.
187-208.
Health Effects Institute Asbestos Research Literature Review Panel
(1991). Asbestos in public and commercial buildings. Cambridge, MA,
Health Effects Institute Asbestos Research.
Institute of Medicine. Committee on the Health Effects of Indoor
Allergens (1993). Indoor Allergens. Assessing and Controllino_
Adverse Health Effects. Washington, D.C. National Academy Press.
Marbury, M. C. and J. E. J. Woods (1991). Building-related illne~'s.
Indoor air ppll¢lion: ~ he;~lth perspective. Baltimore,MD, Johns
Hopkins University Press. 306-322.
Molhave, L. (1992). Volatile organic compounds and the sick building
syndrome. ]Environmenti~l Toxi¢~an~; Heman Expo~¢res and Their
Health Effects. New York, Van Nostrand Reinhold. 633-46.
National Asthma Education Program (1991). Guidelines for the
diagnosi.~ and management of asthma. Bethesda, MD. Department of
Health and Human Services.
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TI02321402

National Research Council. Committee on Passive Smoking (1986).
Environmental Tobacco Smoke: Measuring Exposures aud Assessin~
Heal~h Effects. Washington, DC, National Academy Press.
Samet, J. M.; W. S. Cain, et al. (1991). Environmental tobacco smoke.
Indoor air potIudon: a health perspective. Baltimore, MD, Johns
Hopkins University Press. 131-169.
Samet. J.M (1993). Indoor air pollution: a public health perspective.
Indoor Air3: 219-226.
Spengler, J. D. and J. M. Samet (199I). A perspective on indoor and
outdoor air pollution. Indoor Air Pollution. a Health Perspective.
Baltimore, MD, Johns Hopkins University Press. 1-29.
U.S. Department of Health and Human Services (1982). The health
consea_uences of smoking: cancer. A. report of the Surgeo.n General.
Washington, DC, U.S. Government Printing Office. -
U.S. Department of Health and Human Services (1983). The Health
Consequences of Smoking: Cardio.v.ascular Disease. Rockville, MD, U.S.
Govrnment Printing Office. A Report of the SUrgeon General.
U.S. Department of Health and Human Services (1984). The health
conseqoence$ of ~moking: chronic .obstructive pulmonary disease.
report of the Surgeon General. Washington, DC, U.S. Government
Printing Office.
A
U.S. Department of Health and Human Services (1986). The Health
Consea_uences of lnvolontary Smoking. a Report of the Sorgeon
General. Washington, DC, U.S. Government Printing Office.
U.S. Department of Health and Human Services (1989). Reducino_ the
heallh consequences of smoking: 25 years of progress, A report of
lhe Surgeon General. DHHS Publioati0n No. (CDC) 89-8411.
Washington, DC, U. S. Government Printing Office.
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).
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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.
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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.
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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
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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.
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