Tobacco Documents Online

I I I I I I I I I I I I I I I I I I people are exposed to environmental tobacco smoke, and to how much. . Even if one were to grant all the premises of the report, that there is a threshold for ETS exposure and home exposure is greater than workplace exposure, one cannot ignore the contribution of the latter to the total exposure of an individual. An evaluation of the effect of occupational exposure to environmental tobacco smoke should include an assessment of the effect of workplace exposure adding to home exposure, so that those whose home exposure is just below the postulated threshold are raised above that threshold. Note the statement on p. 39 that those who were exposed both at home and at work had over twice the exposure of those exposed only in the home. Hammond Comments Page 11

Comments on Specific Sections Overview Is the "Overview" actually an abstract or summary? If so, this should be so stated. General Issues Statements are made in this section which have not been accepted by any credible scientists; if these statements are the conclusions of CRS, they should be stated as such, and not made to appear to be accepted by the scientific community at large. This is misleading in the extreme. The Overview incorrectly implies that the EPA report is the only scientific body which has studied the full evidence and concluded that ETS causes lung cancer. The other major scientific bodies which have carefully considered all the evidence and come to the same conclusion (most prior to the deliberations of EPA) are the National Research Council of the National Academy of Sciences, the advisors to the Surgeon General, the International Agency for Research on Cancer, the National Institute for Occupational Safety and Health, and, most recently, the Occupational Safety and Health Administration. I I I I I I I I I I I I I I I I r,, / e) . -~ Oct r,) ~ - Hammond Comments Page 12 ,~ cn I

I I I I I I I I I I I I I I I I I T Similarly, it is misleading to imply that the response of the general scientific community to the EPA report was criticism. In fact, the EPA report had undergone extensive peer review over years during its preparation, and was generally well received by the scientific community, with the exception of individuals hired by the tobacco industry to criticize the report. It is also improper to characterize the disagreements as between the public health community and scientists--many members of the public health community are scientists, and many scientists who are not members of the public health community support the report. The entire discussion in the second and third paragraphs is, at best, naive in the extreme, and displays total lack of knowledge of the biology of cancer as we understand it today. Furthermore, the discussion of ETS exposures reveals ignorance of a vast body of data in the scientific literature about ETS exposure. Examples of sloppy writing: "...several reports have also claimed (italics added) that exposure to environmental tobacco smoke (ETS) may pose a significant health risk to people who have never smoked." The word "claimed" is inappropriate with reference to scientific articles. A more appropriate wording would be that "...several scientific studies report that exposure to environmental Hammond Comments Page 13

I tobacco smoke (ETS) may pose a significant health risk to people who have never smoked." Sou_r G of n. ain v Here, as well as throughout the report, the authors demonstrate their ignorance of epidemiology in their misuse of the term "confounders." Furthermore, they neglect any discussion of another serious problem with all of the epidemiological studies to date, that is, nondifferential, random misclassification of exposure status; consequently, they also neglect to discuss the effect of such misclassification on the observed odds ratio in any studies. Occupational Risk Once again, the authors of the CRS report have ignored the vast body of scientific data on ETS exposure by location, and erroneously report that residential exposure to ETS exceeds workplace exposure by a factor of 4 to 6. Biological and Chemical Issues It is'simply untrue that "...no good chemical marker exists with which to identify or quantify [the] presence [of environmental tobacco smoke)." What does a vague term such as "quite low" mean with regard to the concentration of ETS? What levels are high and what levels are low ~ 4* ~ ~ ~ Hammond Comments Page 14 ~ Lq .p v I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I depends on the biologic potency of the chemical(s) in question. "Quite low" compared to what? 1 Hammond Comments Page 15 ~ crf -0 cc I