Philip Morris
An Enforceable Indoor Air Quality Standard for Environmental Tobacco Smoke in the Workplace
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- Author
- Lowrey, A.H.
- Repace, J.L.
- Area
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- BIBL, BIBLIOGRAPHY
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- Named Person
- Brunnemann, K.
- Cummings, K.M.
- Fontham, E.L.
- Hammond, S.K.
- Lewtas, J.
- Parker, J.
- Wallace, L.A.
- Wells, A.J.
- Request
- Stmn/R1-072
- Stmn/R1-093
- Document File
- 2023668618/2023668781/Rhode Island Assist Meeting Materials 940125
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- Naval Research Lab
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- Naval Research Lab
- Risk Analysis
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- Master ID
- 2023668618a/8780
- 2023668618A Assist
- 2023668619-8626 Tobacco Industry Front Groups
- 2023668627 Table of Contents
- 2023668628-8631 Agenda
- 2023668632 1
- 2023668633 Project Assist Rhode Island Tobacco Facts
- 2023668634 Smoking Related Health Care Costs
- 2023668635-8636 Tobacco Fact Sheet
- 2023668637-8638 Facts About Secondhand Smoke
- 2023668639-8640 Are You Endangering Your Child's Health? Secondhand Smoke Could Be Harmful to Your Children.
- 2023668641-8643 Annotation Smoking Control in the 900000s: A National Cancer Institute Model for Change
- 2023668644 2
- 2023668645 Model Ordinance Eliminating Tobacco Advertisements on Municipal (or County) Public Transportation
- 2023668646 Model Ordinance Eliminating Tobacco Billboard Advertising in the Vicinity of Schools
- 2023668647 Model Ordinance Eliminating Tobacco Advertisements in Municipal (or County) Athletic Facilities
- 2023668648-8650 Advertising and Promotion
- 2023668651 Tobacco Advertising and Promotion
- 2023668652 Advertising Restrictions
- 2023668653-8654 Uicc Tobacco Control Fact Sheet 1 the Case for Banning Advertising and Promotion of Tobacco
- 2023668655-8656 From the Office of the General Counsel Tobacco Advertising and the First Amendment
- 2023668657 3
- 2023668658-8659 Patient Information the Fagerstrom Test for Nicotine Addiction
- 2023668660 Some Good Reasons to Stop Smoking Now
- 2023668661 930000 Money Saved by Not Smoking
- 2023668662 Smoking Cessation Programs Available in Rhode Island - 930800
- 2023668663 4
- 2023668664 Model Policy: Creating A Smoke - Free Workplace
- 2023668665 Special Report on Involuntary Smoking Legal Liability for Permitting Smoking
- 2023668666-8667 Warning to Employers: Allowing Smoking Is Hazardous to Your Health
- 2023668668-8669 Secondhand Smoke in the Workplace
- 2023668670 the Health Effects of Environmental Tobacco Smoke
- 2023668671 Implementation of Smoking Policies
- 2023668672 Strategies for Selecting Smoking Cessation Programs
- 2023668673 Costs and Benefits of Smoking Restrictions in the Workplace
- 2023668674 Smoking in the Workplace: Ventilation
- 2023668675 Smoking in the Workplace: Legal Issues
- 2023668676 Smoking Policies and the Unions
- 2023668677 Smoking Policies in Health Care Institutions
- 2023668678 Smoking and the Female Work Force
- 2023668679 Smoking and the Blue-Collar Work Force
- 2023668680-8684 Analysis and Perspective Environmental Tobacco Smoke: Implications for the Workplace
- 2023668685-8686 Smoke-Free Workplace
- 2023668687-8688 Ventilation Standards and Ashrae Smoking and Ventilation Standards
- 2023668689 Second-Hand Smoke Workplace Risks Measurable
- 2023668703 Let's Treat Secondhand Smoke As the Killer It Is
- 2023668704 State Colleges to Ban Smoking Effective 000701
- 2023668705-8708 Respiratory Health Effects of Passive Smoking Fact Sheet
- 2023668709 5
- 2023668710-8711 Executive Order No. 91-40 911028 Smoking in the Workplace
- 2023668712-8713 An Act Relating to Health and Safety - Workplace Smoking
- 2023668714-8716 Explanation by the Legislative Council of An Act Relating to Health and Safety - Workplace Smoking
- 2023668717 State Cigarette Excise Tax Rates Cents - Per - 20 - Pack As of 930901
- 2023668718-8719 Secondhand Smoke in Your Home
- 2023668720-8721 Smoke-Free Schools 'smoking Restrictions in Schools Act' Public Laws Chapter 92-230 the Facts
- 2023668722-8724 Public Health Policy Forum Editorial: Profits of Doom
- 2023668725 6
- 2023668726 Secondhand Smoke Hazardous to Restaurant Staff
- 2023668727 Health Risks of Environmental Tobacco Smoke
- 2023668728-8729 Secondhand Smoke in Restaurants
- 2023668730-8731 Smoking Bans Top the Menu at Local Eateries
- 2023668732-8734 Environmental Tobacco Smoke Concentrations in No - Smoking and Smoking Sections of Restaurants
- 2023668735-8738 Chuck E. Cheese Your Kids Will Breathe Easier at Chuck E. Cheese
- 2023668739-8742 Gio's Pasta & Grill Updated Information on Grand Opening Date Re-Release Dining Never Smelled So Good
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- 2023668745-8746 Heffie's Goes Smoke-Free Ice Cream Store Owner Loses, Gains Customers
- 2023668747 Restaurant to Feature Good Food, No Smoke
- 2023668748 7
- 2023668749-8750 Michigan Tobacco Reduction Coalition Newsletter Tobacco Free Pharmacy the Campaign
- 2023668751-8754 Pharmacists Who Choose Not to Sell Tobacco Some Pharmacists, Believing That Selling Tobacco Is at Odds with Their Ethics and Health Professional Responsibilities, Have Chosen to Take Tobacco Products Off Their Shelves
- 2023668755-8758 Pharmacy Promotion of Tobacco Use Among Children in Massachusetts. Of 100 Pharmacies Surveys, 95 Sold Tobacco, 81 Were Willing to Illegally Sell Cigarettes to Minors, and One-Half Displayed Tobacco Ads.
- 2023668759-8767 Smoking Cessation: Treatment Options and the Pharmacist's Role. The Pharmacist Can Play A Critical Role in Counseling Patients on How to Quit Smoking, and Providing Support As Well As Information on Smoking Cessation Products.
- 2023668768-8769 Tobacco Sales in Pharmacies: Mixing Good Drugs and Bad Drugs
- 2023668770-8771 Pharmacists and Tobacco: Dollars Before Duty
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Rirk Analysir, I!ol. 13. No. 4, 1993
An Enforceable Indoor' Air Quality Standard for
Environmental Tobacco Smoke in the Workplace'
James L. Repace2' and Alfred H. Lowrey'
Reedvrd Novrmber 4, 199z* irvistd March 11, 1993
:A::.i;J
F.nvitonmental tobacco smoke (ETS) has recently been determined by U.S. environmental and
occupational health authorities to be a human carcinogen. We develop a model which permits
using atmospheric nicotine measurements to estimate nonsmokers' ETS lung cancer risks in m-
dividual workplaces for the first time. We euimate-that during the 1980s, the U.S. nonsmoking
adult population's median nicotine lung exposure (homes and workplaces combined) was 143
micrograms (µg) of nicotine daily, and that most-exposed adult nonsmokers inhaled 1430 µg/day.
These exposure estimates are validated by pharmacoldnetic modeling which yields the cotrespond-
ing steady-state dose of the nicotine metabolite, cotinine. For U.S. adult nonsmokers of working
age, we estimate median coti}tine values of about 1.0 nanogram per milliliter (ng/ml) in plasma,
and 6.2 ngbml in urine; for most-exposed nonsmokers, we estimate cotinine concentrations of about
10 ng/ml in plasma and 62nghal in urine. These values arc eonsistent to within 1596 of the eotinine
values observed in contemporaneous clinical epidemiological studies. Corresponding median risk
from ETS exposure in U.S. nonsmokers during the 1980s is estimated at about two lung cancer
deaths (LCDs) per 1000 at risk, and for most-exposed nonsmokers, about two LCDs per 100.
Risks abroad appear s_im7ar. Modeling of the lung cancer mortality risk from passive smoking
suggests that de nu,umis [i.e., "acceptable'! (10-')], risk occurs at an 8-hr time-weighted-average
exposure concentration of 7.5 nanograms of ET'S nicotine per cubic meter of workplace air for a
working lifetime of 40 years. This model is based upon a linear acposurt-response relationship
validated by physical, clinical, and epidemiological data. From available data, it appears that
workplaces without effective smoking policies considerably cuxed'this de mininus risk standard.
For a substantial fraction of the 59 million nonsmoking workers in the U.S., current workplace
exposure to ETS also appears to pose risks exceeding the de marrifestia risk level above which
carcinogens are strictly regulated by the federal government.
KEY WORflS: Fnviromaental tobacco smoke; indoor air quality standard; nicotine; cotinine;
phumacokinetie
modeling; risk assessment.
1. IIVTRODUCTION
In 1991, the National Institute for Occupational
Safety and.Health (NIOSH). deciared.environmental to-
'Disclaimer. This work was perfonaed by the authors in their private
capacity. No official support or endoisement by the Environmental
Protection Agency, the Naval Researeh Labotatory, or any other, fed-
eral agency Is intended or should be inferred.
2U.S. Environmeaqt Protection Agency, Washington, D.C. 20460.
sNavsi Research Labontory, Washington. D.C. 20375.
lb whom ali correspondence should be addressed.
463
bacco smoke (E?S) to be a "potential occupational car-
cinogen," legal terminology for a substance capable of
causing human cance.r or reducing its latency period c't
Based.. upon bioiogical. plausibility and epidemiologicai
studies,tl-~ a number of risk assessments have estimated
the lung cancer mortality caused by passive smoking
among U! S. nonsmokers to be of the order of 5000 deaths
N
per year.(6) In 1992, thie American Heart Association
declared ETS to be a "major preventable cause of car-
diovascular 0
diovascular disease and death,"rn and estimated ETS- N
related mortality, from heart disease and cancer com _
oz72a33n47Aaoo4asJSOm.oaa 0,1993 Soc;ay ror NiskAnays:a M
0

464
bined, to approach 53,000 annualIy, placing passive
smoking as the third leading preventable cause of death{
after active smoking and alcohol.(8)
Workplace exposure of nonsmokers to environmen-
tal tobacco smoke is widespread, with 28.5 million non-
smoking workers in 1988 (36.5% of all nonsmoking
workers) being employed in workplaces with few or no
restrictions on smoking.0) In 1992, 25% of the adult
population were current cigarette smokers. However,
among the 100 largest U.S. industrial corporations, only
35% had banned smoking in the workplace, and of these,
many restricted the ban solely to corporate headquar-
tezs.10t
NIOSH recommends that employers ban smoking
in the workplace if possible, or "minimize" nonsmok-
ing workers' exposures if not. Because of the NIOSH
advisory, and a major report issued in 1993 by the U.S.
Environmental Protection Agency declaring ETS to be
a "known human carcinogen",(2) workplace smoking
policies to restrict nonsmokers' expostme to ETS are being
increasingly mandated by legislaturWl') considered by
regulatory agencies,03j or voluntarily adopted by busi-
ness.t'at However, workplace smoking policies shoit of
bans may reduce, but do not eliminate, nonsmokers'
exposures.0') Accordingly, there is a need for an en-
forceable indoor air quality standard for ETS, so that
regulators may quantify the risks in any indoor airshed.
With such a standard, any residual ETS exposure after
imposition of controls can be evaluated as "acceptable"
ot1 "unacceptable," relative to established regulatory ai-
teria for risk from exposure to environmental carcino-.
gens.
In 1985, Repace and Low*") proposed a health-
based indoor air quality standard based upon respirable
suspended particulate (RSP) air pollution from ETS;
however, although strongly associated with ETS, RSP
is not unique to ETS,W) and hence an ETS-RSP standard
would be difficult to enforce. Quantification of ETS ex-
posure and risk for regulatory purposes must be predi-
cated upon substances uniquely associated with tobacco
combustion, such as nicotine in workplace air.JA Newly
available data now permit development of a method to
use ETS nicotine levels as a quantitative surrogate for
the carcinogenic risk of ETS in.individuat workplaces,
and for deriving a legally enforceable health-based in-
door air quality standard for.ETS, usable by federal and .
state regulatory agencies.
2. METHODOLOGY
In creating an enforceable indoor air quality stan-
dard for the workplace carcinogen ETS, the fundamental
Repace and L6wrey '
problem to be solved' is to develop a model correlating
levels of substances uniquely associated with ETS ex-
posure (nicotine and'its metabolite, cotinine), and highiyt-
correlated with number of cigarettes smoked,tlst't ana!:,
hence with the lung cancer risk caused by ETS. To ac-
compiish this, we modify our previously developed model
relating the lung cancer risk from ETS exposure to the
nonsmoking population's exposure - to ETS-associated'
respirable suspended particulate (RSP).(61`-u'a-"- 25) By
relating atntcupheric nicotine in buildings to RSP from
ETS,tI6-2`t a nexus may be established between lung can-
cer risk and the ETS constituent, nicotine. In this man-
ner, nicotine and cotinine, which are the best available
markers for ETS exposure and dose,(2-3-5) therefore also
serve as the most suitable markers for the carcinogenic
effect of ETS, despite their own apparent lack of car-
cinogenic activity." Nicotine exposure model predic-
tions are validated by pharmacokinetic comparison with
clinical epidemiologic studies of cotinine in the body
fluids of nonsmokers. This also permits calculation of
the risk to the typical and most-exposed individuals in
the population. Current exposure levels for various classes
of workers are assessed from recent personal and area
monitoring studies of nicotine in workplace air.
3. MODELING NONSMOKERS' EXPOSURE' TO
NICOTINE
1.
Estimates of population ETS nicotine exposure may
be simply derived from earlier ETS RSP population ex
posure estimates by Repace and Lowrey,t18t using new
information- desenbing empirical relationships between
ETS RSP and nicotine concentrations.
3.L Exposure of the Nonsmoldng Population to
RSP ftvni ETS
Repace and Lowreytuas1°ast in assessing the risk
of passive smoking, developed a model to estimate the
exposure of the U.S. nonsmoking population to RSP
from ETS. This model assumed that nonsmokers' ETS
exposures (and hence lung cancer risk) are dominated
by two microenvironments, homes and workplaces, in
which time-budget studies have shown the U.S. popu-
lation averages 88% of its time.10aA-M This assumption
has been subsequently verified by ETS epidemiology in
nonsmokersa"-'0t Repace and Lowreytl"t estimated typ-
ical population exposures to RSP from ETS for U.S.
nonsmoking adults of working age by using indoor air
concentration models('9) together with time-budget stud-

Indoor Air Standard for Tobacco Smoke
ies, tables of respiration rates, standards for naturaL and
mechanical ventilation, surveys of smoking prevalence
in~ the home and workplace, and epidemiological studies
of passive smoking. Repace and l,owrey(38) estimated
the typical daily inhaled lung exposure of the U.S. non-
smoking population to RSP from ETS during the 1980s
to be Q,,, = 1.43 milligrams per day, and the lung ex-
posure of most-exposed nonsmokers was estimated to be
10-fold'~ the typical, at Q. = 14.3 milligrams per day.
3.2. Relating ETS RSP to Nicotine Using Field
Studies
There is a constant relationship between the total
amount of RSP and nicotine emitted in mainstream and
sidestream smoke.31t Since ETS RSP and nicotine differ
in decay rate, instantaneous ratios of RSP and nicotine
concentrations during growth and decay of ETS will be
variable in timeaM However, in time-averaged mea-
surements, a constant ratio of RSP to nicotine in ETS
reemerges. This is demonstrated by regression relation-
ships derived by Leaderer and Hammond,t16) and by
Miesner et aL (z) from field measurements of RSP and
nicotine in homes and workplaces, respectively. Lead-
erer and Hammond(16) have studied the relationship be-
tween nicotine and RSP from smoking in 47 homes where
cigarette consumption was reported, in the NYSERDA
Study of indoor air pollution in New York State. The
weekly average RSP concentration, R, (in units of mi-
crograms per cubic meter) measured in these homes was
regressed against the weekly average nicotine concen-
tration, N. (3z) The resulting regression relationship is given
by:
R = 9.8N + 22.9 (u.g/m') (1)
where the coefficient of determination, r2=0.64. By
comparison, Leaderer.and Hammond(16) found the RSP-
to-nicotine ratio at high smoking densities in an exper-
imental-chamber with 4 brands of commercial cigarettes
smoked by smokers to be only 30% higher,14.1 ± 1.9,
than in the NYSERDA field study. M'iesner et al tu)
studied workday average RSP and nicotine concentra-
tions in 21 commercial and institutional buildings chosen
to represent a variety of places where people. spend time
indoors other than at home. ~kesner et aL2't reported
an R-to-N ratio of 9.1 to 1 for these buildings (r2 =
0.78) in agreement with the results of Leaderer and
Hammond.(i6) Similarly, Nagda et aL (33) obtained an R-
to-N ratio of 10.3 to 1, from in fiight measurements in
the smoking sections of 61 U.S. aircraft flights. We
adopt an ETS RSP-to-nicotine ratio of 10:1.
465
3.3. Assessing Nicotine Exposure of the
Nonsmoking Population
The field-measured ETS RSP-to-nicotine ratio of
ten-to-one is now used to obtain an estimate of the non-
smoking population's nicotine exposure, E, derivative
from our ETS RSP population exposure model.'41 is
simply obtained by dividing the ETS RSP values Q,,,
and Q. by 10, yielding the values E,,, = 143 µg/day,
for the ETS nicotine exposure of the population-average
nonsmokers, and E., = 1430 µg/day, for the most-
exposed nonsmokers. In general, the average workplace
nicotine air concentration, N (in units of wg/m') is re-
lated to an individual's exposure, E (in units of µg(day),
by the expression:
E = pHN (peday) (2)
where p is the nonsmolker's respiration rate (in units of
m'!hr) during exposure, and H is the duration of that
exposure, (in units of hr/day). Respiration rates range
from about 0.4 m3/hr for resting adults, to 1 m'Ihr for
alternate sitting and light work, to 2 m'/hr for heavy
work.ta`3
4. RELATING NICOTINE EXPOSURE TO
COTMIIHE DOSE
Cotinine levels for the median and most-exposed
individuals in the population can be assessed from clin-
ical epidemiological studies. Thus, if estimated ETS ni-
cotine exposure is related to cotinine dose using
pharmacoldnetic modeling, the accuracy of these expo-
sure estimates can be assessed. Accordingly, we define
the following parameters (and their units) for'use in a
classicaIm single-compartment pharmacokinetic model
translatinj estimated nicotine axpcuttre into oortespoad-
ing estimated cotinine levels in body fluids: E, daily
nicotine lung exposure (µg,/day); a, efficiency of ab-
sotption of nicotine by the lung (diineusionIess); D, daily
absorbed nicotine dose (µg/day); F, efficiency of con-
version of nicotine to cotinine by the body (dimension-
less); P, steady state. plasma cotinine.concentration (ng(
ml); CL7, rate of cotinine clearance from plasma by he-
patic, renal, and other mechanisms (ml/min); CLR, rate
of cotiniae removal from .p)asma by renal clearance only
(mllmin); A,,, the mass of cotinine excreted into urine
daily (ng); V, daily tuine volume (ml); II, steady-state
urinary cotinine concentration (ngfml); td, number of
minutes in a day. ~
0
~
r.:
~
~
~
~
~

466
4.1. Model Development
Next, we derive a pharmacokinetic model relating
daily lung nicotine exposure, E to daily average ab-
sorbed nicotine dose, D, and to steady-state levels of
plasma cotinine concentration, P, and urinary cotinine
concentration, U. We predict the population-average and
upper extreme values for P and U for adult nonsmokers
from passive smoking corresponding to our estimates of
nicotine exposure. To assess the usefulness of this model,
we compare model predictions, valid for conditions in
the mid-1980s, to the results of several large ciinical
epidemiological studies of the levels of eotinine in the
body fluids of nonsmokers performed in the late 1980s.
That fraction of nonsmokers' daily nicotine lung
exposure E absorbed by the lung is transformed into a
plasma nicotine dose D. Plasma nicotine dose distributes
in the body rapidly, with a distribution half-life of 5-10
min, and an apparent volume of distribution of 180 LM
Nicotine is metabolized to codnine by the liver with an
efficienry F= 86%, and the remainder is partly metab-
olized to nicotine-N-oxide, or excreted unchanged in sa-
Iiva and utine.(") Elimination follows first-0rder kinetics,
with a 2-hr elimination half-life.m-')
Cotinine distributes in smokers with a half-life of
about 1.6 hr, into an apparent volume of distribution of
about 88 L.t39y Cotinine elimination also follows first-
order kinetics, and has an elimination half-life of the
order of a day in nonsmokers, and therefore yields an
index of average exposure to ETS.t'001> Measurements
of cotinine in plasma, urine, or saliva are sufficiently
sensitive and specific to identify passive smok-
ers.t`-37-39"-ut Passive smokers studied in Western Eu-
rope and North America are found to have cotinine levels
between about 0.1% and 1% of those in active smok-
ers.(a2) Recent findings suggest that nicotine and cotinine
kinetic parameters appear to be extrapolatable from
smokers to nottsmokers.('s)
Daily absorbed nicotine dose, D, is linearlyt") re-
lated to the daily average exposure; E.
, D a ctE (µ8/day) (3)
where a is the nicotine absorption efficiency. The a
value for U.S. nonsmokers from E°I'S due to U.S. cig-
arettes has not been measured. However, Iwasi et a[. (")
have measured nicotine absorption from ETS generated
by Japanese Mild Seven cigarettes in 17 nonsmoking
Japanese women. They found a nicotine absorption ef
ficiency, a= 71.3% ± 10.2%. Measured nicotine ab-
sorption efficiencies ranged from a low of 45% to a high
of 95%, and were not a function of atmospheric nicotine
concentration, which ranged from 40 to 200 µg/m3. We
Repace and Lowrey
assume the average value for the absorption efficiency
for U! S. nonsmokers from U.S. ETS is the same,
a=0.71.
In equiltbrium, the plasma cotinine concentration P(
^
(typically expressed in units of ng/ml) will be related to
the absorbed nicotine dose D by the expression <'-`-39's)
P = FD/ClA - (4)
where D/tQ is the dose rate of nicotine from passive
smoking which is assumed to be approximately constant,
and CIT is the total clearance of cotinine from plasma
(in units of mllmin) due principally to hepatic and renal
mechanisms. Aa, the total amount of urinary cotinine
excnted, is given by('5):
A = C11eFDlClr (5)
where ClR is the renal cotinine clearance (in units of mI/
min). Dividing both sides of Eq, (5) by V,,, the total
amount of urine excreted, where A, JV = U, the urine
cotinine concentration, using Eq. (4), and solving for
C1R, we arrive at an expression for the renal cotinine
clearance:
CIR = UVlPts (6A)
The total plasma cotinine clearance from Eq. (4) is then:
CIr = FD/t,P (6B)
Finally, we express U (in units of ng/mI) as a function ~
of E by substituting Eq. (4) into Eq. (6A):
U = FCIRaBICh.Y, (7)
4.2. Model Validation
Nonsmokers' renal and piasma cotinine clearance
(oral and IV dosing) have been measnred by De Schep-
per et aL Om at C1R = 7.7 mt/min and Clr = 61 mllmin
and by Curvall et aL t'0 at Cl,t a 5.48 ml/min and CIT
a 74.4 mUmia. Renal and plasma cotinine clearance
may also be estimated (based upon a 70 kg person) from
Jatvis u al t'0: Corresponding to a 5-day daily dose of
28 mg of oral nicotine in 3 nonsmokers and 2 occii.sional
smokers, the mean steady-state values P_=294 nglml and
U=1394 nghnl were measured. Assuming a daily (te =
1440 min) urine elimination V, = 1300 ml,.(`?~_we cal-.
culate the clearance values from Eqs. 6A and 6B: CIR
= 4.3 ml/min, and Clr = 57 m1/min. Averaging the
three sets of data yields for nonsmokers: C1)t = 5.9 ml/
min and Clr = 64 mUmin. (By comparison, for_smokers
(n = 28), Cla = 12.3 ± 4.8 nilLmin, and ClT = 72.2
± 13.1 ml/min).(m By contrast, if the renal-ctearance .
2023668693
)

Indoor Air Standard for Tobacco Smoke
for nonsmokers is calculated from the median values
U=5.6 ng/mll and P=1.1 ng/ml (see Table II) where
nonsmokers' cotinine levels reflect inhalation rather than
intestinal absorption, then~using Eq. (6A), C1R=(5.6 x
1300) / (1.1 x 1440) = 4.5 m!/min. Then, correspond-
ing to our estimated nonsmokers' lung exposure of E,,,
= 143 µglday, we calculate from Eq. (7), U,,, = 0.86
x 5.9 x 0.71 x 143,000 / 64 x 1300 = 6.2 ng/ml,
and for E,,. = 1430 µg/day, U,,,,x = 62 ng/ml. Sim-
ilarly, we calculate from Eq. (4) P, =. ForE/tdCi,. =
0.86 x 0.71 x 143,000 / 1440 x 64 = 0.95 ng/ml,
and P. = 9.5 ng/ml. These model predictions are
summarized in Table I, and compared to typical levels
of cotinine measured in nonsmokers' body fluids re-
ported in several clinical epidemiological studies as shown
in Table II. Our model predictions for cotinine in plasma
and urine for the typical and most-exposed individuals
are consistent to within 10-15~'o with available data for
median and peak levels of cotinine measured in the body
fluids of nonsmokers. By extension, our earlier estimates
of population exposure to RSP from ETS in the mid
1980s('") also appear to be consistent with the late 1980s
ETS population exposure as assessed by cotinine dosi-
metry.
Table L Model Predictions vs. Observations for Nicotine Lung
E;tponue and Catinine in Body Fluids for U.S. Noasmokers-
Niatroae Utinary Pluma Population
exposure, E ootinine, U ooaeine, P individual
(µB/daY) (nglml) (ng/aii) exposure
' Model predictions
143' 6.2° 0.95'
1430 62 9.5
Observational results
No data 5air 1.1
No data 55-90 10-IS
Typical
Most-ezposed
Median
Most-Uposed"
''I3e model (valid bor acposurcs determined by smoking prevalence
and workplace smoking policies in the 1980s) givea by F.qs. (4) and
(7), predicts plasma and urinary cotinine ~rtations consistent
with the results of lue 1980s clinical epidemiological studies, vati.
dating both the nicotine espostm modet, derived bae and the earlier
RSP e9osue model of Repace and Lowrey finm.vhic6 it is derived.
' Glcadated from estimatcd population average RSP lung exposure
Q_ - 1.43 mg/dryu"t osing Eq. (1).
Calcailated from E, using Eq. (7). 11% diPfereace with observed
value.
~ Cakulated from E using Eq. (4). 14% diffetvies with observed value.
It is estimated that most-exposed individuals have 10-fold the ez-
pasure of the avenge nonsmoker.a1" Modeled values are consistent
with observed ranges.
f weighted median value from Table tI.
Median value from tiaddow,Oit as reported in Table II.
" Majority of estimated matdmum cut-points diSaentiating most-ex-
posed passive smokers from tigfit smokers, from Table U.
467
Nicotine from dietary sources and from outgassing
from ETS-contaminated surfaces in buildings are poten-
tial contributing factors for cotinine in body fluids. How-
ever, their contribution to cotinine levels in body fluids
appears to be negligible by comparison to the contribu-
tion of ETS.(`8)
5. MODELING RISK FROM NICOTINE AND
COTINIIVE
We have validated our exposure model by compar-
ing observed median and peak levels of cotinine in body
fluids for nonsmokers to levels of estimated nicotine ex-
posure which we have associated with the typical and
most-exposed passive smokers in the population. We
now correspond ETS nicotine etposure with lifetime lung
cancer risk from ETS, by transforming the RSP-risk model
we developed earlier("18) into a nicotine%otinine-risk
model. A linear exposure-respottse relationship is as-
sttmed.'8)
5.1. Risk Estimation from ETS RSP
Our previously developed acptuureiesponse model
was based on modeling and field studies of nonsmokers'
exposure to RSP from ETS and the response observed
in a large cohort study of lung cancer in Seventh Day
Adventist (SDA) nonsmokers.t`9-*m SDAs, becattse of
their lifesryle, experience very little passive smoking rel-
ative to demographically comparable nonsmoking nonSDA
controls from the general population.('`9-`*) This model
predicted an ETS RSP exposure-Lung Cancer Death
(LCD) response relationship, _E=5 LCDs per 10' per-
son-years (PY) at risk per milligram of daily exposure
to ETS-derived RSP. We validated our model by pre-
dicting epidemiologically derived observational data to
within 596 P= In the American Cancxr Society cohort
studq(-u) of passive smoking in 176,739 nonsmoking
women, their observed age-adjusted meaa lung cancer
mortality rate was 13.3 LCDs/100,000 PY and the mor-
tality ratio for women exposed to spousal smoking was
1.2 relative to women with no spousal smoking. Our
exposure : response nwdel. applied - to shis cohort pre- .
dicted the values 13.8 LCDs/100,000 PY and 1.19 for
the rate and ratio respeciively." Similarly, this model
predicts exactly the misclassificadon-adjusted odds ratio
for spousal passive smoking and lung cancer derived by
the U.S. EPA in its meta-analysis of 11 U.S. epidemio-
logical studies of passive smoking and lung cancer extant
in 1992,m as well as the odds ratio found in the key

468
Table II. Cotinine in Body Fluids of Nonsmokers (Various Studies)' Repace and Lowrey
Study Micmenvironment rt Cone. (median) Comment
A. Cotinine in urine ~
Cummings(s2' New York State 227 5 Max: 60-90 ng/mi
Fontham 5 U.S. Metro Areas 728 6.2 Max: 55-99 ngjmg Cr
Fontham' 1108 5.6 nghnl
Ribolit"" 10 Countries, U.S. 1369 6 Mw. 55 ng/mg Cr
Ha1ey'T=' (males) White collar, Teus 148 6.2 ± 0.5 (mean, SD), nghttg Cr
(females) White collar, Tetas 112 8.0 = 0.8 (mean, SD), ng/mg Cr
Perez-StabletIm Southwestern U.S. 189 NR° Max 70 ng/mg Cr
Wallt" California 48 4.7 nghng Cr Wtd. Mean
48 7.3 nglmi Wtd. Mean
Haddowtlt (females)
Pottland, Maine B. Cotinine in plasma
232
1.1
Maa:10 ng/m1
Van Vunalcisnq Los Angeles 327 NR M= B-3o ng/ml
Wagenlmecht<"t Urban adults 18-30 3445 NR M= 14 ngftl
Perez-Stablet*4 Southwestern U:S. 189 NR Matc 14 ngfml
A number of studies in the late 1980s have e:omined the ttrine and plasma atxinine levels of
adult noasmokers, using radioimmunoassay and gas
chromatography. Median valuea found for utiaary ootinine are about 5-6 ng/ml (also sometimes
eatpresaed in audely eqnivaient normalized units
given by ng/mg Cteatiaine), and the atof[ used to distinguish heavy passive smokers from Gght active
smokers is of the order of 55 to 90 ng/
ml or ng/mg Cr. For plasma cotinine, the median is about I npJml, and the peak value is about 10 to
15 ng/mL
Unpublished data from Ref. 29.
` NR, Not reported.
epidemiologic study(29) upon which the U.S. EPAm re-
lied for quantitative estimates of the impact of passive
smoking on U.S. nonsmokers.
5.2. Rlsk Estimatioa from ETS Dlicotine and
Cotinine
. We now develop conversion factors relating ETS
nicotine and cotinine exposure to lung cancer risk from
ETS.
-Aanosphaic nicotine: Using the value derived for
the euposure-response 7, together with standard as-
sumptions for of5ce occupancy and ventilation, and as-
suming an average 40-year working lifetime (WLT).
Repace and Lowrey<14M estimaoed the lifetime lung cancer
death (LCD) rate for a person breathing ETS-deriVed
RSP (at a rate of 1 m3/6r) in a model workplace to be
-0-1.33-x---10-3-i,CD/(WLT µgW RSP): This rela-
tionship implies that for a nonsmoking worker, an esti-
mated lifetime risk of 1 x 10-6 is generated by breathing
an (annualized) 8-hr time-weighted average (TWA) of
75 ng of ETS RSP per cubic meter of workplace air for
a working Iifetime.(I`)
Correspondingly, by applying the approximately 10:1
RSP-to-aicotine concentration ratio found from field .
studies, as e:aempiified in Eq. (1), we derive an esd- ~.
mated risk factor -0 =100 for nicotine in the workplace:
tl~ = 1.33 x 10-'LCD//(WLT µg/m' Nicotine) (8)
In other words, a 1 x 10-6 (de minimis) working
lifetime risk is estimated to be generated by nonsmok-
ers' exposure to 7.5 nanograms of atmospheric nico-
tine from ETS per cubic meter of workplace air (ng/
m') (8-hr TWA).
Cotntirte in body fltddL- Using Eq. (2), assn++tng a
respiration p a 1 m' per houu for an 8 hr day and an
exposure to~ 11T= 7.5 ng/m' of nicotine, we assume the
corresponding estimated Iung exposure E= 60 ng of
nicotine to be delivered per 24-hr day, since our equa- -
tions are for the steady state, yielding aa estimated- de
minimis cotinine value UA6, = 2.6 x-10-a ng/ml urine
corresponding to a 1 x 10-s lifetime risk of lung cancer.
The estimated risk conversion factor; @=10-61Ujo,o,; -
relating lifetime lung cancer risk from EfS exposure to
urinary cotinine concentration is then cx;ressed as:
®_ .
4 x 10-` LCD per (WLT-ng cotininelml
urine) (9) AA
l
and similarly tlsing Pt,,,,,, =4 x 10-` ngMll,e the plasma
.
.
J

Indoor Air Standard for Tobacco Smoke
cotinine concentration corresponding to de minimis life-
time lung cancer risk, the risk conversion factor for plasma
cotinine is given by:
f2=2.5x 10-'LCD
per (WLT-ng cotinine/ml piasma) (10)
We now use the values derived for ® and S2 together
with data from clinical~ epidemiological studies of cotin-
ine in plasma and urine to estimate the risk from passive
smoking for the typical and most-exposed nonsmokers.
The weighted median urinary cotinine value estimated
for female U.S. smokers, based upon existing studies
(which are not a national probability sample), is, from
Table II, 5.6 ng/ml, with the most-exposed female non-
smokers exhibiting maximum urinary cotinine ievels about
10-15 times higher, depending upon the choice of cutoff
discriminating heavy passive smokers from light active
smokers. Most epidemiologists favor cutoffs in the range
55sU,,,,s90 ng/ml (see Table II). There are limited
data on males, with some workers reporting male non-
smoker cotinine levels somewhat lower than female 1ev-
els, and others somewhat higher. We shall assume the
exposures of males are comparable to that of females.tl8y
Using Eq. (9), and a median urinary cotinine concentra-
tion U.., = 5.6 ng/ml, the median working lifetime
lung cancer risk for U.S. nonsmokers is estimated to be
eU,,d = 2.2 x 10-', and the risk to the most-exposed
(e.g., corresponding to a bar-waitress's exposuretsl) is
estimated to be ©U,= = 2.2 x 10-=. Using IARC
cotinine studies,c30> the risks appear to be similar abroad
within factors of 2.
Simflarly, From Table IIB, median female plasma
cotinine levels P,,.d have been measured at P..d = 1.1
ng/ml, and peak levels are reported to range approxi-
mately from 10 5 P,,.d s 15 ng/m1. We shall assume
a 10=fold higher peak exposure, based upon our exposure
model.(u-'&1') Using Eq. (10), the median lung cancer
risk for U.S. nonsmokers is similarly estimated atfaPd
= 2.8 x 10-', and the risk to the most-exposed is
estimated at i2P,. = 2.8 x 10-2. These lifetime mor-
tality probabilities are associated with current levels of
exposure. The magnitude of the estimated risk will now
be placed in perspective.
6. EVALUATING ETS RISKS
6.1. Concepts of Regulatory Risk
We now consider whether the estimated' popula-
tion risks from ETS which we have modeled are "ac-
469
ceptable" by societal standards for permissible human
exposures to environmental carcinogens such as in-
dustrial chemical emissions and radionuclides in air
and water, and carcinogenic molds and pesticide res-
idues in food.
Several U.S. federal regulatory agencies promul-
gate regulations and standards to protect the public from
exposure to environmental carcinogens. It is of interest
to inquire as to what levels of population cancer risk
typically trigger regulation, what levels are beneath reg-
ulatory concern, and how consistently are they applied
among various federal agencies. Travis et 4ts't re-
viewed the use of cancer risk estimates in prevading
federal standards and in withdrawn regulatory initiatives,
to determine the relationship between risk level and reg-
ulatory action in 132 U.S. federal regulatory decisions
of record. Travis et aL (n) describe two technical risk
assessment terms: de manifestis risk and de mininus risk.
A de rnanifesris risk is literally "a risk of obvious or
evident concern," and has its roots in the legal definition
of an "obvious risk" (i.e., one recognized instantly by
a person of ordinary intelligence). De manifesris risks
are those that are so high that U.S. federal regulatory
agencies almost always acted to reduce them, and de
minimis risks are so low that agencies almost never acted
to reduce them. For various reasons, risks failing in be-
tween these exiremes were regulated in some cases but
not in othersts' ; however, residual risks after controltO
are generally de rnvuntis. Travis et aL 9M found when
the population at risk was large, as with ETS, de ntan-
ffads risk oorresponded to 3 x 10-4, and de minirnu
risk was 1 x 10-6. -
6.2. Population Risks Compared to Regulatory
Levels
How Aoes the risk from ETS compare with the fed-
eral de nianifestis risk level? Using the available data for
late 1980s cotinine concxnirations in nonsmokeis'Tody
Quids, we have estimated the aggregate population risk
from BTS at - 2 to 3 x 10-' (cMsisoent with esti-
mates(6-5`) made using other methods), an order of mag-
nitude above the de manffastis risk level.
...Another way of undcrstanding the import of such
risk probabilities is to multiply the aggregate risk by the
population at risk (in the case of lung cancer, nonsmok-
ers aged z 35 years) in gfder to estimate the annual
mortality. In 1990, there were - 50.7 millioir lifelong
nonsmokers and - 34.6 million ex-smokers in this pop-
ulation category.(55) A 2 to 3 x 10-' lifetime risk (as-
suming 40 years' exposure to the working population)

~.5.?....,
470
corresponds to a 5 to 7.5 x 10-5 annual risk, and when
applied to the nonsmoking population of 85.4 million
nonsmokers at risk produces = 4000-6000 lung cancer
deaths (LCDs) per year, consistent with the risk esti-
mates of 5000 ± 2500 LCDs per year, adjusted'to 1988,
produced by other methods.«6t By comparison, the U.S.
Environmental Protection Agency has strictly regulated
as Hazardous Air Pollutants under Section 112 of the
Clean Air Act, airborne human carcinogens involving
far lower numbers of estimated deaths, such as benzene
(< 8 cancer deaths per year) (CDslyear) arsenic (<5
CDs/year), vinyl chloride (< 27 CDs/year) (all EPA es-
timates before control and at the 95% upper confidence
limit) ~Q In contrast, de rrrinimis exposure of the entire
nonsmoking population at risk for a working lifetime of
40 years, would result in s 2 LCDs/year.
7. A WORKPLACE ETS STANDARD BASED ON
MCOTINE AND COTININE
7.1. De M'rnimis and De Manffeslis Levels of
Nicotine and Cotinine
What are the maximum concentrations of cotinine
in body fluids and the corresponding maximum airborne
nicotine concentration estimated to be consistent with a
de minimrs (10-6) lifetime population risk? From Eqs.
8, 9, and 10, the steady-state levels of cotinine in body
fluids corresponding to de minimis risk are calculated to
be Um,,;,, = 2.6 picograms of cotinine per milliliter of
urine, and' PQ,,,,,, = 0.4 picograms of cotinine per mil-
liliter of plasma, while the de nrinimis airborne nicotine
level is calculated to be Nd,,;,, = 7.5 nanograms per
cubic meter, 8 hr time-weighted-average ('I'WA). These
values represent levels corresponding to maximum per-
missible daily ETS exposure consistent with de mi,rirnis
risk. Routine detection of cotinine levels this low from
individual body fluid specimens is probably not possible
with present technology, with tadioimmunoassay and
standard gas chromatography methods having detection
limits of about 0.3 ng/ml and 0.1 nglnil, and quantitation
limits of 1 ng(ml, and 0.1 nghml, re.spectively.t"o Spe-
cialized isotope-dilution tandem mass spectrometry
methods can detect levels as low as 30 pglmi.(In How-
ever, nicotine at this level in workplace -air could be
detected at realistic sampling rates over a weekly period.
The de mmtifestis cotinine and nicotine levels are
estimated respectively at 0.8 ng/mI (steady-state urine
cotinine) 0.12 nglml (steady-state plasma cotinine), and
Repace and Lotvrey -
2.3 µg/m3 (air nicotine, 8-hr TWA). Standard methods
will detect levels of this order in body fluids or air.ta'_'1s:'a-
6°t (in order to properly assess de minintis levels of ni-
cotine in air or cotinine in body fluids, background levels(-
due, respectively, to outgassing of surfaces or dietary or nonworkplace exposures to nicotine should
be subtracted
off.)
7.2 ETS Risks in the Workplace
As Table III shows, nonsmoking workers of all cat-
egories appear to be currently reeeiving nicotine expo-
sures from ETS in offices, in industrial plants, in aircraft,
and in restaurants with lax smoking policies, which ex-
ceed the de manifestis level, sometimes by as much as
an order of magaitude. Figure 1 gives a plot of ttte es-
timated lifetime risk from breathing ETS at a rate of I
m3/hr, as a function of daily wortplace nicotine concen-
tration (8-hr TWA) at all practical levels of exposure.
Achieving de stinimis risk requires several orders of
magnitude reduction in exposure, according to measure-
ments reported in Table III. Such reductions are not pos-
stble using venti7ation or air deaning.tl`t Because of leaks
driven by pressure imbalances in buildings induced by
convection and piston effects from elevator motion, even
in large buildings, it is improb,abie that separation of
smokers and nonsmokers on different ventilation sys-.
tems will readily achieve an acceptable level of exposure (
to ETS.
In summary, based upon the available information
on current ETS nicotine exposure levels shown in Table
III, and the nicotine-risk model presented here, it ap-
pears that the risks to white collar, blue collar, and ser-
vice workers from ETS in many workplaces consider-
ably exceed the de manifertis level which triggers strict
federal regulation of carcinogens. Control of nonsmok-
ers' ET5 exposure to levels of de niinirnis risk using
methods short of complete elimination of smoking in the
workplace does not appear likely-particularly if the ad-
ditional risk of heart disease mortality from ETS is con-
sidered.
8. CONCLUSIONS
1. We have estimated that the typical' U.S. non-
smoker of working age during the 1980s ap-
peared to be exposed to a nicotine intake of ~
approximately 143 µg per day, while the most-
)

Indoor Air Standard for Tobacco Smoke
Table 111. Nicotine in Personal Air of Nonsmokers and in Building Air (Various Studies)'
Study %tic.roenvironment rt
µg/m' Comment
A. Nicotine in nonsmokers"air. Personal monitors
471
Schenker'"'
CoultasO"
Mattson'"I Railroad eierks, N:E. 40
White Collar N:M_ 15
Flight Attendants 4
(Air Canada) 6.9
20.4 = 20.6
4.7 = 4.0 Workshift median
Workshift mean = SD
4 F7ights. mean - SD
B. Nicotine in building air. Area monitors
LeadererCt"' Homes, N:Y. State 47 .2.17 = 2.43 7-day av., smoking
Hatnmondt"" Mass. Industrial
White collar 24
60
21,5 :t 40.2 9-hr workiLift av.
(uaasmoker's air,
Blue coliar 123 8.9 t 16.8 smoking allowed
Food service 51 10.3 s 12.6 on preatises)
Carsont7Oj Offices, Canada 31 11 Workday samples
Miesne&'t Wtxkplatxs, Mass. 11 6.6 = 7.6 Workweek average
0ldaker('t1 Restaurants, N.C. 33 10.5 (.1-35) 1-hr iv. (range)
leakins<'" Knoavi11e,1N'Metro
Restaurants
7
3.4 s 2.3 Z 1-hr average
Cocktail lounges 8 17.6 s 22.8
Bowling alleys 4 10.7 s 5.1
Gaming Parlors 2 10.7 = 3.0
Laundromats 3 2.0 s 0.7
Airport gates 2 6.0 = 5.5
Office 1 6.0 s 2.9
Nagda-i U~S. Aircraft
(All flights)
69
13.4 t 14.7 In-flight average
Smoking section
(Domestic) 61 0.11 i- 0.13 Nonsmaking section
(International) 8 0.33 z 0.23 Nonsmoking section
Vaughnt9jt Highrise office bldg. 1 2.0 z 0.15 Nottsm. air; 9hr av.
Measurements of workplace tticotine aoi>oeutratioas in the late 1980s using both petsottal and
area mtto:itors in workplaces where smoking is
permitted, demoasaate (from the tneans and standard deviations), a range in nicotine concentration N
of about 1 µglm' to more than 100 µghn',
indicating corrcspondiag workplace nicotine exposures E ranging from about 10 pWday to more than
1000 µg/day, using Eq. (2), assuming
workdays of the otder of 8 + hr and respiration rates of the order of 1 m'/hr. Thisis consistent
with our predicted values for the typical nonsmoker
of E,,, - 143 µg/day and E_ - 1443 µg/day, for the tlmst-eposed, which also include domestic
exposures to ETS.
exposed nonsmokers appeared to have an in-
take of about. 1430 µg per day. These values
should decline in the 1990s as U.S. smoking
prevalence decreases and restrictions on smok-
ing increase.
2. For urinary cotinine, our nlodel predicts a corre-
sponding median value of about 6.2 ng of co-
tinine per ml of urine for the typical U.S.
nonsmoker from passive smoking during the
1980s, and'a.value of about 62 ng/nil for the
most-exposed nonsmokers. For plasma cotinine,
we predict a corresponding median value of 0.95
ng of cotinine per ml of plasma for the median
nonsmoker, and 9.5 ngrtml for the most-ex-
posed. These predicted values are consistent to
within 15% of the results of late 1980s clinical
epidemiological studies relating passive smok-
ing and cotinine in body fluids.
3. We have derived a health-based standard for en-
vironmental tobacco smoke based on its sunro-
gates, atmospheric nicotine and cotinine in body
fluids of nonsmokers. For atmospheric nicotine -
in the workplace, the de ntinimis or "accepta-
ble" lifetime risk level of 1 lung cancer death
per million nonsmokers at risk occurs at 7.5 nan-
ograms per cubic meter (8-hr time-weighted av-
erage.) For cotinine,in body fluids, de minimis
risk occurs at a daily average level of 2.6 pi-_._
cograms of cotinine per milliliter of urine ex-
creted, or at a level of 0.4 picograms of plasma

472
E
:.
.::
~ 10 -7 L_
de minimis concentration
K
.001 .01 .i 1 10
ETS Nicotine Concentration (micrograms, per cubic meter)
Repace and Lowrey
too
Fig. L Emironmental tobacco smoke induced lung aneer risk vs. workplace nicotine air coocentntion (8
hr TWA). ETS Risks to workers may
be evaluated using this model on the basis of nicatine measurements in individual aaorlsites.
Workplace niaotiae mncenttations typically appear
in the range l to 100 µg/m' as shown in Table III. The de maiufestir kwel of carcinogenic risk
occurs at an exposure wnesntration of 2.3 µ®Im'
daily workshift ezposure persisting over a working lifetime. The etposune concentration
corresponding to de minvnis risk occurs at 0.0075 µgfm',
determining the level'of the standard. (1 ppb nicorine in dry air @ STP - 1.3 µg/m'j.
cotinine. De manifestis risk occurs at 2.3 micro-
grams per cubic meter of workplace air, 8-hr
time weighted average (TWA). For cotinine in
body fluids, de manifesrfr risk occurs at 0.8 nan-
ograms of cotinine per mililliter of urine, or 0.12
nanograms of cotinine per milliliter of plasma.
The exposure- and: dose-response relationships
upon which these standards are based are de-_
rived from our previously published exposure-
response model, and have been validated by
physical, clinical, and epidemiological data.
.4. We estimate the median 1980s U.S. lung cancer
population risk from passive smoking to be about
2 x 10-', and estimate that the most heavily
exposed nonsmokers have a lifetime lung cancer
risk from ETS of about 2%. IARC data on uri-
nary cotinine from 10 countries suggests that
ETS risks appear to be similar abroad. Based on
recent field studies of nicotine in workplaces, it
appears that average ETS exposure levels of U.S.
white-coilar, blue collar, and service workers
may exceed by an order of magnitude the de
manifes7fs risklevei of 3 x 10-`, beyond which
environmental carcinogens historically have beeni
strictly regulated by U.S. federal regulatory
agencies.
5. Using the information presented in this work, it
is possible for the first time to make an enforce-
able cancer-risk standard for environmental to-
bacco smoke in the workplace, using nicotine in
air, and cotinine in body fluids, based on the
concept of de minimis risk. Using this de mia-
imrs risk standard for ETS, together with newly
developed active and passive area and personal
nicotine monitors and sensitive cotinine assays,
it is now possible to monitor individual work-
places or individual workers to determine risk
from the workplace carcinogen ETS using
standard industrial hygiene techniques. This
proposed standard permits the efficacy of any,
risk management strategy (i.e., workplace
smoking policy) to be evaluated at the work-
site and compared to federal regulatory criteria
for acceptable risk for exposure to environ-
mental carcinogens. N
- . ~
N
~
