Tobacco Documents Online

.r Statement of Hoy R. Bohanon, Jr, PE to the Occupational Safety and Health Administration ENGINEERING ALTERNATIVES FOR ENVIRONMENTAL TOBACCO SMOKE CONTROL I am Hoy Bohanon. I am a professional engineer employed by R. J. Reynolds Tobacco Company. I have studied indoor air quality for the past three years, and was involved with many aspects of building management in the ten years prior to that. Today I will talk with you about engineering solutions for good indoor air quality. I will point out that the solutions proposed by OSHA for indoor air quality should be evenly applied to all substances including environmental tobacco smoke. There is no need for singular restrictive provisions applied only to sniokers, either as workers or as customers. Specifically, I will provide details supporting the following three points: 1. There is no reason to single out environmental tobacco smoke from all other indoor air constituents. 2. Properly ventilated spaces have very low levels of indoor air contaminants 3. OSHA's proposed rules for environmental tobacco smoke are costly and unnecessary 1. There is no reason to single out environmental tobacco smoke from all other indoor air constituents. Without citing any data to indicate the effects of dilution ventilation on environmental tobacco smoke concentrations, OSHA maintains that dilution ventilation is inadequate to address environmental tobacco smoke control. Dilution ventilation, however, has long been recognized as an effective way to reduce contaminant concentrations and add to indoor comfort. The concept is very simple; if you burn your breakfast toast, you open the window and turn on the fan. There are engineering methods to do the same thing with modern HVAC systems. Engineers generally agree that dilution ventilation and filtration are acceptable methods for minimizing concentrations of substances in the indoor air. It is therefore puzzling that the Proposed Rule quickly dismisses engineering controls as a viable alternative for control of environmental tobacco smoke levels. OSHA did not investigate or discuss the many types of controls that are available. 1

It is also puzzling that OSHA dismisses dilution ventilation as an adequate environmental tobacco smoke control, but mandates it to control a host of substances such as benzene, formaldehyde and styrene, which OSHA identifies as suspected carcinogens within this same Proposed Rule. According to OSHA, these substances are emitted not only from cigarettes, but also from building materials, interior furnishings, appliances, and office equipment and suppiies. In the Proposed Rule, OSHA has developed several lists of compounds identified as Tables 11-2, III-1 and 111-2. Many of the chemicals in OSHA's list of compounds "Identified in Tobacco Smoke" are also typical compounds found in offices. In fact, 29 of the 43 compounds in tobacco smoke can also be found as emissions from building materials, interior furnishings, office equipment and supplies. Amines or alkanes can be found in adhesives, floor coverings, paints, caulking materials, ceiling tiles or particle board. How can dilution ventilation be the accepted engineering control for chemicals found building materials, furnishings, office equipment and supplies and not be acceptable for the identical chemicals found in environmental tobacco smoke?? In fact, OSHA concluded that dilution ventilation can effectively control occupational exposure to formaldehyde. OSHA's final rule for occupational exposure to formaldehyde established 8-hour time-weighted average exposure levels of 0.75 ppm or below. The rule describes the use of dilution ventilation as the primary means of control in the apparel industry to lower the exposure levels from 1.00 ppm to 0.75 ppm. In the Federal Register, the discussion on the apparel industry states: "...the workplace is treated like an office or store and air is recirculated rather than exhausted and replaced, allowing formaldehyde concentrations to build.......A relatively simple solution to this problem of air stagnation is to install roof exhaust fans." The exhaust fan specified by OSHA is a means of using dilution ventilation to lower the formaldehyde concentrations. Certainly, the primary means of contaminant control in the office is dilution ventilation. Many indoor air quality problems can be solved by designing, installing and operating HVAC equipment with proper rates of ventilation. The ANSI/ASHRAE Standard 62-1989 (ASHRAE 1989) entitled "Ventilation for Acceptable Indoor Air Quality" addresses proper ventilation in controlling indoor air problems. The standard's purpose is "to specify minimum ventilation rates and indoor air quality that will be acceptable to human occupants and are intended to minimize the potential for adverse health effects." 2

The Ventilation Rate Procedure does consider smoking activity in this procedure. Mr. John E. Janssen, an ASHRAE fellow and chairman of the committee charged with writing the ASHRAE 62-1989 Standard presented a written statement to Congress in 1991. "Research on tobacco-smoke odor at Yale's John B. Pierce Laboratory has also shown that with today's reduced smoking rate, 15 cfm of outdoor air will dilute environmental tobacco smoke to a level acceptable to 70 percent of the people entering an occupied space .... Other calculations on the tobacco-smoke perception of non-smoking occupants in a room for 15 minutes with smokers show that non-smoking occupants will register 90-percent acceptance under the assumed conditions. Thus Standard 62-1989 appears to be able to control tobacco smoke odor under minimum smoking conditions." For conditions suspected to be above minimum smoking conditions, higher ventilation rates were specified. Bars are required to have twice the ventilation rate (30 cfm/person). The rate for smoking lounges is four times the minimum (60 cfm / person). OSHA has specified dilution ventilation to be a solution to IAQ problems in the workplace. We agree. OSHA maintains that dilution ventilation will reduce the concentrations of chemicals found in the indoor air. We agree. For some unknown reason, OSHAA concludes that if the source of the chemical is tobacco smoking, ventilation will not be effective. We strongly disagree. It appears that OSHAA is not making decisions based upon scientific information, but is making a moral judgment. A.s an analogy, if we are on an elevator that has a capacity of 1200 pounds, and the current load weighs 1150 pounds, it matters not if the next person to board the elevator is a felon or a priest; the elevator is overloaded. If an indoor environment is at its capacity, you raise that capacity by ventilating, that is, changing the air - air changes. With the many assaults on the air indoors, the only way that smoking can overload the air is if the ventilation is inadequate. Evidence shows that for most cases, levels of ventilation established to handle other constituents will also handle smoking activity. There is no technical reason for making different rules for different sources of indoor chemicals. There is no reason to single out environmental tobacco smoke from all other indoor air constituents All evidence shows that: 2. Properly ventilated spaces have very low levels of indoor air contaminants. For a number of years, R. J. Reynolds has had an interest in testing the effectiveness of ventilation in real-world environments. To assist OSHA in understanding the availability and effectiveness of engineering controls, we have presented OSHA with a number of engineering papers examining concentrations of chemicals in the indoor environment. The data show that real world ~ ~ ~ 3 ~3 ~ ~

concentrations of chemicals, regardless of source, can be reduced by dilution ventilation and filtration. These controls have been shown to be effective in various types of indoor environments, and such controls can be used to effectively minimize nonsmoker exposure to environmental tobacco smoke in virtually every workplace under OSILN's jurisdiction. These papers and data are unique in three aspects: 1.. Ventilation rates were measured in addition to measuring the indoor concentrations of various chemicals. 2.. Smoking activity was assessed by counting people and cigarettes 3.. The chemicals measured were truly representative of the presence of envi.ronmental tobacco smoke in a quantitative sense. Before reviewing the results of the testing, let me elaborate on these three points. If you are to study concentrations of environmental tobacco smoke for purposes of characterizing those concentrations, factors that affect those concentrations must be measured. So the questions are: 1. Were ventilation rates measured in addition to measuring the indoor concentrations of various chemicals? In order to evaluate data from an indoor air test, for perspective, meaning, or certainly before using it to represent a typical national condition, one must know the ventilation conditions. Why do I say that? Why can't one just walk into a room, take a reading on a meter, and then generalize on the basis of that data? Because, as shown in slide 3: I`J ~ 4 LO I ~ ~ LO UO

Steady State Relationship Between Ventilation and Concentration for Constant Source Strength Ventilation SLIDE 3 Ventilation has a major effect on the concentrations of chemicals measured in an indoor space. A nonventilated area can have concentrations from identical sources that are several times higher than those observed in a ventilated space. Many occupational settings are well ventilated, and almost all have the potential to be. A properly ventilated office will have on average at least twice the air change that. a residence will have. A restaurant should be as much as 10 times that of an office. Ventilation prevents buildup of contaminants and does not act in a linear fashion, but is very dependent upon air exchange quantities. The effect of ventilation cannot be discounted or ignored in measuring concentrations in the indoor air. The second important question is: 2. Was smoking activity assessed by counting people and cigarettes? If environmental tobacco smoke is a subject of study, smoking activity must be measured. A situation where 100% of people observed are smoking 6 cigarettes an hour is extraordinary and cannot be generalized as a typical workplace exposure. Likewise, trying to measure environmental tobacco smoke where no smoking occurs is similarly misleading. The third question is: 5

3. Do the chemicals measured represent the presence of environmental tobacco _ smoke in a quantitative sense? Measures should include a particulate marker such as WPM, FPN,1 or solanesol, and the vapor phase marker 3-Ethenylpyridine. Nicotine measurements can give a qualitative indication that smoking activity has occurred, but that activity may have been days ago. It does not necessarily indicate the presence of smoke. RSP and CO have many sources in addition to tobacco smoke and are most useful quantitatively in a controlled laboratory environment. The data that OSHA has received from RJR includes 4 specific tests that I will review. All of the tests meet the criteria that I have just mentioned; ventilation rates are measured, smoking activity is quantified, and an array of environmental tobacco smoke indicators are used. The first test was conducted in 1991 and was submitted to OSHA in response to its request for information. The test was conducted in order to examine the effect of smoking activities on indoor air quality. Four buildings were selected. Two of the buildings had constant volume HVAC • systems that were approximately 35 years old. The office areas were primarily private offices. The other two were modern buildings. These newer buildings employed VAV systems and the offices areas were set-up into an open cubicle type arrangement. Two types of smoking policies were in place within the buildings. Smoking was unrestricted in two buildings and restricted to smoking lounges in the other two. 38 substances were sampled in the four buildings. Ventilation rates in the two newer systems were monitored and controlled to essentially the ASHRAE recommended minimum rate of 20 cfm/person. Comparing the results of the two new buildings ventilated at the ASHRAE minimum rate, Results of Indoor Air Quality Sampling Compound Smoking Unrestricted Smoking Restricted TLV Carbon Dioxide (ppm) 604 575 5000 10 times lower Methylene chloride <1.1 8 174,000 20,000 times lower Toluene 19 21 377,000 10,000 times lower Styrene 1.9 0.8 213,000 100,000 times lower 6

Formaldehyde (ppm) 0.034 0.033 0.75 20 times lower Compound Smoking Unrestricted Smoking Restricted TLV I Carbon monoxide (ppm) <1.0 2.4 25 10 times lower ~ Benzene 4.8 1.7 32,000 10,000 times lower Nicotine 2.3 <0.1 500 200 times lower RSP 30 5 5000 The second test submitted to the current docket was designed to evaluate the effects of ventilation rates and distance on environmental tobacco smoke exposure in a large office building; This test measured concentrations of many environmental tobacco smoke indicators in several areas on a floor in a large high rise office building where smoking is unrestricted. As a part of the test, outside air ventilation rates were varied from no mechanically delivered outside air to outside air dampers wide open. Conclusions of this test were: For open office areas on one floor of a large, modern office building with variable air volume (VAV) heating, ventilating, and air-conditioning (HVAC) technology where 31% of the occupants were smokers who each consumed, on average, 9.97 cigarettes per 7%a hour work-day: ~ Changes in ventilation rate, smoking rate, or distance from smoker were accompanied by measurable changes in environmental tobacco smoke concentration. ~ Statistical models indicated that ventilation, smoking activity, and distance from smokers are all significant factors in explaining levels of environmental tobacco smoke. The result of this study are consistent with predictions of models that are based upon fundamental physical principles. These results indicate that increased ventilation or smoker separation can reduce environmental tobacco smoke exposure. ~ Concentrations of most environmental tobacco smoke indicators varied inversely with ventilation rate and directly with smoking activity. These indicators were nicotine, 3-Ethenylpyridine (3-EP), ultraviolet particulate matter (UVPM), and fluorescent particulate matter (FPM). ~ Such behavior is consistent with predictions from physical models relating ventilation and contaminants. 7

I ~ However, RSP - one of the more commonly used indicators of exposure - did not exhibit this relation. The absence of both ventilation effect and smoking activity effect is theorized to be due to RSP originating from other sources. This result underscores the limitations associated with this indicator. The third paper presented examined the effects of ventilation and separation of smokers and nonsmokers on exposure of nonsmokers to environmental tobacco smoke in an office using personal and area monitoring techniques. Ithru 6 Designated Smoking Area Sarnpling Locatioru SlthruSlO ~ Locations where cigarettes µere smoked SLIDF 17 - 5500 Square Foot Office Space Due to the apparent lack of information regarding the relationships of dilution ventilation and ETS compound levels, R.J. Reynolds conducted a test. The results of that test clearly demonstrate the effectiveness of ventilation and separation as engineering control techniques. The term separation in these tests means establishing an area for smokers and an area for nonsmokers. It does not mean separate enclosed rooms. A 5500 square foot office area was tested. The space was served by one dedicated HVAC system. The HVAC system was a constant volume reheat system with capability to provide outside air by opening an economizer damper. 8

The test protocol was to measure iiidoor concentrations of chemicals in the space for two days with no smoking allowed. Then for eight following days, 160 cigarettes were smoked each day. For the first four days no outside air was provided by the HVAC system by keeping the damper closed. The following four days, the ventilation system damper was opened to provide outside air. For two days under each condition, smoking was restricted to a designated area located near the return air vent. This designated area is shown as shaded on slide 17. Note that the separate area was not enclosed by walls and doors. Personal monitors were used to measure nicotine and 3-EP. The results for specific markers show that all levels are low. ~ Carbon monoxide levels were not affected by smoker/non-smoker separation. Carbon monoxide levels were affected by cigarette smoking activity, outside air levels and outside air ventilation rates. Indoor carbon monoxide levels exceeded outdoor levels by approximately 2 ppm during the test days of cigarette smoking and no outside air ventilation. Carbon monoxide levels inside were not statistically different from outside levels during days of cigarette smoking with the outside air damper open. ~ Nicotine levels were most affected by smoker/non-smoker separation. Nicotine levels were slightly affected by outside air ventilation rates. Personal nicotine sampling measurements are not significantly different than work area sample measurements. ~' RSP levels were not statistically different (p< 0.05) in smoking/nonsmoking locations nor in either mode of ventilation. The average RSP levels for the test duration, were 32 µg/m3 and 29 µg/m3 for smoking and nonsmoking, respectively. In fact, RSP levels inside were not different from the outside concentrations of 30 µg/m3• ~ UVPM and FPM levels were found to be good tracers of environmental tobacco smoke particles. [SLIDE 221 These particles were found to be at essentially the same levels in the office area as the outside air during days when the outside air dampers were opened. 10 Environmental tobacco smoke RSP (based on solanesol) were affected by ventilation rates and found to be below the limit of detection on all days when the dampers were opened. The conclusions: 9

i • During days where outside air dampers were opened and smoking was restricted to the designated area; carbon dioxide, carbon monoxide, RSP, and UVPNI levels were found to be essentially the same as outdoor air levels. ~ Overall levels are low when compared to OSl-LA's estimates of environmental tobacco smoke concentrations or exposures in the workplace. 0 Under all conditions the levels are many times lower than PEL limits, and indeed even below the limits set for outdoor air. 0 By understanding these relationships and applying separation and ventilation procedures, exposure to environmental tobacco smoke can be virtually eliminated in nonsmoking areas. If ventilation can be effective in this case, then the technology is a valid engineering control, and should not be discounted by OSHA. This research was designed to test the effect of engineering controls in effectively minimizing environmental tobacco smoke concentrations. Additional research is needed to determine optimal ventilation rates and separation distances between smokers and • nonsmokers. The fourth paper deals with the effects of ventilation and filtration on reduction of exposure in restaurants. OSHA requested specific information regarding bars and restaurants. RJR has submitted data and analysis that demonstrate the effectiveness of ventilation and filtration in reducing environmental tobacco smoke components in bars and restaurants. These reductions were possible with existing standard technologies. For all areas of the restaurants, the concentrations are very low. For the nonsmoking sections, concentrations are significantly lower than the smoking sections. In order to test the effectiveness of HVAC technology in reducing environmental tobacco smoke concentrations in the real world, we sought out restaurants that served a lot of smoking patrons, and had poorly performing HVAC systems. A test and balance contractor (a contractor certified in measuring HVAC systems) evaluated and documented the performance of the existing ventilation systems. Air flow rates on kitchen exhaust hoods, make-up air units, HVAC supply air flow rates, and outside air flow rates were measured. We then made cost-effective changes projected to lead to better indoor air quality. These changes included increasing outside air ventilation rates, and in some cases, improving filtration. Air samples were taken during operating hours in both the smoking and non- smoking sections of the restaurant. Before we changed anything in the HVAC system we sampled for seven consecutive days. After we modified the HVAC system, we again sampled for seven consecutive days. 10