Tobacco Documents Online

534 Joumal of H i In addition, the ind that "more rese4 memo stated, "It spend their dolla against smoking i : The tobacco in enhance CIAR's projects will be m by funding peer-r are not related to il Implications for Whenever an indu business, a confli researcher has a r ased research and findings might aff responsibility to research that prod As many auth covertly influence (Hillman et ai.:19 Industry may be ~ produce desirable unconsciously des way that is likely t heavily on indust pressure (Hillman Several authors minimize the pote 1991; Blank 1992; proposed that ind independent third tigators. In additio should be awarde specifically state regarding study de CIAR fulfills th tion that acts as a Ith Potitics, Policy and Law . try often uses the fact that it funds research to argue is needed:' For example, a 1978 tobacco industry extremely important that the industry continue to n research to:ahow that we don't agree that the case losed" (Bloch 1994). try may`be using CIAR's peer-reviewed projects to •dibility, ao that the results of its special-reviewed likely to be accepted. The industry has little to lose ewed projects through CIAR, because most of them S. [I ustry Funding In General y funds scientific research that will directly affect its of interest arises. This conflict occurs because the " nsibility to conduct methodologically sound, unbi- ~ disseminate the findings, regardless of bow those the industry. The industry, on the other hand, has a ximize its profits, and its money is best spent on favorable data. ~have noted, industry sponsorship can overtly or ~ conduct and publication of research in various ways ; Blank 1992; Chren 1994; Witt and Gostin 1994). e likely to fund research studies that it believes will ata. In addition, investigators may consciously or i their research studies or present their findings in a e favorabld-to their sponsors. Investigators who rely unding may be particularly susceptible to industry al. 1991). ve suggested that guidelines should be ioposed -to ~ for bias. in industry-funded research (Hillman et al. ~ren 1994; %'jtt and Gostin 1994). Chren (1994) has Iry-funded research should be awarded through an ty to- irI ize contact between industry and inves- Chren suggested that all industry-funded research t ngh contracts, rather than grants, which should investig$tors will retain complete scientific freedom Fn, data "ysis, and publication of findings. iteria proposed by Chren. It is a nonprofit corpora- *rmediary between investigators and the tobacco 9

® i 528 Journal of Health Politia, Pot'rty and larr We examined these sources to identify CIAR-funded researchers who bad either testified orally or submitted written statements. When avail- able, we read both written statements and transcripts of oral testimony to determine whether they discussed CIAR-funded research, whether the researcher's relationship with the .tobacco industry was disclosed, and whether the testimony supported the. tobacco industry position on ETS (as we previously defined for concliisions of articles). We found that 28 percent (five of eighteen) of PIs on special-reviewed projects had submitted statements related to ETS, compared with 3 per- cent (one of thirty-four) of PIs on peer-reviewed projects (Fisher's exact test, p=.0154). One PI on :a special-reviewed project had testified on five separate occasions, whereas all others had testified only once. All of the statements submitted by CIAR-funded PIs supported the tobacco industry position that ETS is not harmful to health. The PI who had testified five times consistently argued that smoking can be accom- modated indoors through adequate ventilation; two PIs argued that evi- dence is insufficient to conclude that ETS causes disease; one maintained that there is a lack of biological plausibility to conclude that ETS is harmful, and that confounding variables could explain the statistical association between ETS and disease;:one argued that ETS is not a major cause of sick building syndrome and poor air quality; and one argued that workplace exposure to ETS is very low (implying that the exposure is too minimal to cause disease). f : Data from at least three oif CIAR's special-reviewed projects have been presented at hearings related.to ETS. Two special-reviewed projects were discussed at OSHA'si hearings tegarding its proposed indoor air quality standard, which recommends restricting or banning smoking in workplaces nationwide, whereas the third was discussed at hearings related to banning smoking on comttiercial airline flights. In all three cases, the data from CIAR's' special-reViewed projects were used to sup- port the tobacco industry position. One of the OSHA statements was submitted by Roger A. Jenkins, who discussed preliminary data from 'a special-reviewed project entitled "Determination of Human ExpQsure to, Environmental Tobacco Smoke" According to CIAR's tax records, Oak Ridge National Laboratory received $797,892 in 1993 to conduct this study. Jenkins disclosed in his statement-that the project had- been fuailed by CIAR; however, be stated orally that he was not appearing as awadvocate for or against OSHA's proposed standard, but "as a:scientist that's been conducting a study and Qoi7/osi

a tobacco-specific sub- :studied general indoor :o. s into the categories of Is study evaluated the iies conducted in cells, •ed exposure to a sub- posure; these included i nicotine metabolite). or exposure were clas- mple, studied whether ht or smell. of projects funded by viewed projects were teer-reviewed projects. i exposure, rather than :h related to ETS, par- r the tobacco industry projects. One of the ve smoldng is that per- :ause any serious dam- sible that the tobacco 31-reviewed projects to !idon, from a legal per- tld be much less darn- ltlSes disease; thus it is rch. ed principal investiga- CIAR, we coded the sector, or other. They :)n was a university or I with a private-sector All other affiliations •e than one affiliation affiliations of CIAR- projects had academic ; on special-reviewed zations.'Iwo special- of Healthy Buildings Table I Topics of Projects Funded by CIAR, 1988 to 1993 Topic ETS Health Effects ETS Exposure Other ETS Total ETS Non-ETS Health Effects Non-ETS Exposure Other Non-ETS Total Non-ETS r of Peer- d Projects d =40) Number of Reviewed (n =1 Special- Projects 9) 6 2 6 8 0 ; 2 1Zlo096) 12 (63%) 14 0 13 . 6 1 1 28 0096) 7 (37%) Comparison of total ETS vs. total non-ETS for peer-reviewed vs. special-reviewed projects: Fisher's Exact'itiat, D +. .02. Table 2 Affiliations of Principal Investigators (Pis) funded by CIAR' Percentage of PIs on Percentage of PIs on Peer-Reviewed Special-Reviewed Projects Projects Affiliation (n = 34) (n = 18) Academic 94 ! : 56 Private Sector 3 . 39 Other 3 6 Chi square =12.26. df = 2, p.0.002. +'IWo PIa received funding for both peer-reviewed projects and special-reviewed projects. They were cl.ssitied as PIs on special-reviewed projects throughout our analyses. However, onr results would not have been different if we had classified them as PIs on peeFreviewed projects, or if we had placed them in a separate category. International (HBI), Gray Robertson, a long-time tobacco industry con- sultant who has testified frequently on the industry's behalf (Levin 1993; U.S. House 1994a). It is therefore possible.that special-reviewed projects tend to be awarded to PIs in the private sectbr because some of them may be sympathetic to the tobacco industry position. Alternatively, academic investigators may be wary of accepting filnd,ing for special-reviewed proj- ects because they have not been subject to a formal peer-review process. We also found that three of CIAR's sp4cial-reviewed projects were awarded to PIs who are cturently meinb~ of CIAR's science advisory board. This sort of financial relationship beiween the advisory board and the tobacco industry could raise concern atoout the board's ultimate inde- Numbe Reviewe Reviewe (n tn 1~ J cn J J tn 00

® 08/09/98 ® 14:44 8 0 0 n 910 716 2186 ® t 526 Journal of Hea We also an,6lyzed ' whether articles res th Politics, Policy and Law e stated conclusions of the articles to determine lting from special-reviewed projects would be more likely than t'hose res; Table 3 s min • " of CIAR's roject-r, ing from sp~ecial-re quality char~cteristi reviewed p addition, 3 published lications. Fi ects tended funding. Table 3 al ects were m port the tob ting from peer-reviewed projects to be pro-industry. es our findings regarding the quality and conclusions lated publications. As hypothesized, articles result- iewed projects tended to be associated with poor- s. Almost one-half of articles resulting from special- jects were published in non-peer-reviewed journals. In percen were •published in symposia and 20 percent were ~ book s ctions, institutional reports, and other types of pub- ally, articles associated with CIAR's special-reviewed proj- o ackn~wledge the tobacco industry as the sole source of l o show that articles based on CIAR's special-reviewed proj- re likely than articles from its peer-reviewed projects to sup- o indistry position. These findings support evidence from previous studies su esting that industry funding is associated with pro- industry out,6omesavidson• 1986; Swaen and Meijers 1988; Lexchin 1993; Rochon et al. 1994). In addition, these findings provide further sup- port for oui hypot esis that the tobacco industry may be funding research thrqugh C R's special-reviewed projects to produce data that GO are favorable to its osition. Use of CIAR-Fundeb Research The final phapse of ou study was an ysis of the use of research funded by CIAR. We hypo esized that, alth ugh CIAR-funded research has led to publicatioits both upporting and ing the tobacco industry posi- tion, the industry vbould selectivel cite the studies that support its claims. In addition,, ve hypothesized that Pl:s on special-reviewed proj- ects would be more 1~keIy than PIs on r-reviewed projects to have tes- tified on the utdustryf s behalf. To de e how CIAR-fuaded research was being u);ed, w analyzed tes ' ony presented by CIAR-funded researchers t~t fed hearings relate to ETS. We used three sou s to identify -funded researchers who have testified or st#bmi statements on ' ues related to ETS: the list of per- sons who tesfified ore the Occupa 'onal Safety and Health Adminis- tration (OSHA) rega ding its propose indoor air quality standard (U.S. Department bf Occu ational Safety nd Health Administration 1994); the list of persons w, o submitted tec 'cal oomments to the U.S. Envi- i I ~ ® 015/031 T: Ft Pc T) So Ac ro) w1 an ide mt an. Pn inF bu: to 19! Hc Hc me

© ® ® I ® 516 Journal of Health Politics, Policy and Law Scientific evidence now strongly suggests that exposure to environmen- tal tobacco smoke (ETS) is harmful to the health of persons who do not smoke. Studies have shown that passive smoking can cause lung cancer (Hirayama 1981; Fontham et al. 1994) and heart disease (Glantz and Parmley 1991; Steenland 1992) in adults and that it increases the risk for sudden infant death syndrome (DiFranza and Lew 1995) and various res- piratory disorders in children (U.S. Environmental Protection Agency 1992). In 1986, two scientific consensus reports on the harmful effects of exposure to ETS were published independently by the National Acad- emy of Sciences (1986) and by the U.S. Surgeon General (U.S. Depart- ment of Health and Human Services 1986). And in 1992, the U.S. Envi- ronmental Protection Agency classified ETS as a known Group A human carcinogen (U.S. Environmental Protection Agency 1992). The growing awareness of the harmful effects of passive smoking has led to increased restrictions on smoking in public places to protect nonsmokers from exposure to ETS. . In contrast, a study published in 1992 in a peer-reviewed journal con- cluded that "acceptable air quality can be maintained (indoors] with moderate amounts of smoking" (Turner et al. 1992: 19). This study was funded by the Center for Indoor Air Research (CIAR), which was created by U.S. tobacco companies in 1988. CIAR's stated mission is to fund high-quality, objective research related to indoor air, including studies of ETS. Both CIAR and the tobacco industry maintain that CIAR is an independent organization. In particular, they emphasize that CIAR's proj- ects are funded in a "scientifically rigorous and objective manner" based on peer review by a group of independent scientists and that this peer review process "ensures that only high quality research ... is recom- mended for funding" (Center for Indoor Air Research 1994: 3). Whenever an industry funds research that is directly related to its product, there is concern that conflict of interest may influence the research in some way (Bond 1991; Hillman et al. 1991; Blank 1992: Rothman 1993; Chren 1994; Witt and Gostin 1994). In particular, the sponsor might apply overt or covert pressure on the investigator to pro- duce results that will be favorable (Hillman et a1.1991). For example, the sponsor could recommend that the investigator use a study design that would be more likely to favor its product. Or the sponsor could encour- age a researcher to emphasize certain conclusions in the final publication of the data. Even without any external pressure, investigators may feel consciously or subconsciously compelled to publish findings that are pleasing, or at least not damaging, to their sponsors (Hillman et al. 1991). 19 M ®

M rojects, according to ic data that could be . (Sarokin 1988; Bero d the industry to cul- x called on to testify Council for Tobacco specifically to divert t al. 1995). For exam- ition, occupation, or s attributed to smok- jects were sometimes :sults that would sup- sponsorship can influ- irch and specific evi- i control the direction arch funded by CIAR o industry argues that 9amage, and that epi- and do not prove that .ustry has an obvious :e arguments, because ) accept them if they sport prepared by the istitute noted that the ancern about passive rt stated: "The strate- issue is, as we see it, ble, medical evidence oker's health." e content, quality, and ther it is funding truly idies that appear to be hesized that, although obacco industry might position that passive Barnes and Bero  Ina C1AR's Peer-Reviewed and Special-Reviewed Projects CIAR has released several Request for App that describe its organizational structure, m (Center for Indoor Air Research 1989, 1991, these RFAs, CIAR is an independent, nonA 1988 (Center for Indoor Air Research 1994) rate members: charter, regular, and asso~ "those corporations that established the Cen ing the majority of funding;" whereas regulI "those persons or corporations that are im research but were not involved in the estab: ter for Indoor Air Research 1994: 3). Chat represented on the board of directors bu (Center for Indoor Air Research 1994). Although these types of memberships ar RFAs, the names of the members are listed M original charter members were Philip Tobacco Company, and Lorillard Corpo Research 1989); Svenska Tobaks A.B., a S pany, was added to the list of charter mem Air Research 1994). CIAR has two reguls and Mead Paper, its associate members it aging companies. Thus CIAR was create tobacco companies, and its board of direl tobacco industry representatives. C1AR's mission, as stated in its 1989- ate a focal point organization of the high and foster quality, objective research in i ronmental tobacco smoke, and to effectivi ings to the broad $cientific comrnunity" 1989: 1). This mission statement was includes a specific reference to ETS ( 1992a). CTAR states that its mission is ft entific and technical research related to i The peer-review process that CIAR ui is described in its RFA brochures as foll The research agenda of the Center fo lated by the Science Advisory Boa -Funded Research 519 bations (RFAs) brochures 6on; and funding process ~92a, 1994). According to W corporation formed in t has three types of corpo- ite. Charter members are r and are currently provid- and associate members are ested in indoor air quality zment of the Center" (Cen- - and regular members are ssociate members are not learly described in CLAR's ly in the appendix. CIAR's 's U.S.A., R. J. Reynolds on (Center for Indoor Air dish domestic tobacco com- in 1994 (Center for Indoor ~ embers: Hoechst Celanese de several paper and pack- nd nd is primarily financed by rs is composed primarily of ~ t research agenda, is "to cre- scientific caliber to sponsor oor air issues including envi-. communicate research find- ter for Indoor Air Research en ified in 1992 and no longer iter for Indoor Air Research lled primarily by funding sci- loor air. to select projects for funding s: idoor Air Research is formu- (SAB), a multi-disciplinary ® !: i

539 Journal of Health Politics, Policy and Law . 1994. Sponsored Symposia on Environmental Tobacco Smoke. Journal of the Ameriean Medical Association 271(8):612-617. Bero, L. A., and S. A. Glantz.1993: Tobacco Industry Response to a Risk Assessment of Bnvironmental Tobacco Smoke.Tobacco Connvl 2(2):103-113. • Blank, L H. 1992. Industry-Funded Dermatologic Research within Academia in the United States: Fiscal and Ethical Considerations. Journal of lm+estigative Derma- tology 98(3):265-268. Bloch, M.1994: Tobacco Industry Funding of Biomedical Research. Tobacco Control 3(4):297-298. Bond, 0. 0. 1991. Ethical Issues Relating to the Conduct and Interpretation of Epi- demiologic Research in Private Industry. Journal of Clinical Epidemiology 44(Suppl 1):29S-34S. Center for Indoor Air Research. ;1989.1989-90 Research Agenda: Request for Appli- c+ations. Linthicum, MD: Center for Indoor Air Research. 1991. 1991 Research Agenda: Request for Applications. Linthicum, MD: Center for Indoor Air Research. 1992a. 1992-93 Research Agenda: Request for Applications. Linthicum, MD: Center for Indoor Air Reacareh. 1992b: Supported Studies. Linthicum, MD: Center for Indoor Air Research. 1993a..List of projects funded by CIAR in 1993, provided by V. Christine Marquardt. I:inthicum, MD: Center forindoor Air Research, 13 October. 1993b. List of publications resulting from CIAR-funded research, provided by V. Christine Marquardt. Linthicum, MD: Center for Indoor Air Research, 13 October. 1993c. List of publications i•esulting from CIAR-funded research, provided by Paula Raimondo, Research Librarian. Linthicum, MD: Center for Indoor Air Research, 16:Novembet: 1994. 1994 Research Agenda: Request for Applications. Linthicum, MD: Center for Intlnor Air Research. •• 1995. Supported Studies and Peiblications. Linthicum, MD: Center for Indoor Air Research. Chalmers, T. C., C. S. Frsnk, and 0. Reitman. 1990. Minimizing the Three Stages of Publication Bias. Journal of dusAmerican:Medical A.rsociatton 263(10):1392-1395. Cho, M. K, and L A. Bero. Forthcoming. The Quality of Drug Studies Published in Symposium Proceedings. Chren, M. 1994. Independent Investigators and For-Profit Companies: Guidelines for Biomedical Scientists Consideaing Funding by Industry.Archives ofDermarology 130:432-437. Council for Tbbaceo Research. 1992. Report of the Council for Tobacco Research- USA, Inc. Washingto0. DC: Councii for'Ibbaeco Research. Davidson, R. 1986. Source of Funding and Outcome of Clinical Trials. Journal of General Inteinal Medicrne l i l55- 08. DiFranra, J. R.; and R. A. Lew. 1995. Effects of Maternal Cigarette Smoking on Pregnancy Complications and•Sndden Infant Death Syndrome. Journal of Family Practice 40(V85-•394. i

1 ® ® 524 Journal of Health PolPtics, Policy and Law pendence. It also suggests that the industry may reward some members of the science advisory board by providing funding for their projects. f Quality of Research Funded by CIAR " The next phase of 'our study was an evaluation of the quality of research funded through CIAR. We could not directly evaluate the quality of the projects themselves, because we did not have aocess to the proposals sub- mitted to CIAR.. As a surrogate, we evaluated the quality of publications that have resulted from C1AR-funded research. We identified articles that had resulted from CIAR-funded research by contacting CIAR and by searching MEDLINE and Current Contents for articles coauthored by CIAR-funded PIs. CIAR provided two lists that collectively identified sixty-one publications that had resulted from its funded projects (Center for Indoor Air Research 1993b, 1993c). Ten more articles that acknovtiledged CIAR as a source of funding were identified through MEDLINE and Current Contents, giving us a total of seventy- one possible articles for inclusion. Eleven of these articles (15 percent) were not contained within any of the University of California, Califor- nia State, or Stanford University libraries and therefore were not avail- able through our interlibrary loan system. We obtained five of these arti- cles by contacting the authors; another four were institutional reports, which we purchased. We could not obtain two articles (3 percent), both of which were published in symposia, and had been coauthored by a PI on a special-reviewed project (Hedge 1991; Hedge et al. 1992). Therefore we assessed the quality of sixty-nine articles that resulted from CIAR- funded research based on the criteria described in the next section. Several studies identified various factors that are associated with pub- lication quality. FQr example, peer-reviewed publications have been asso- ciated with higher quality (Barnes and Bero, unpublished data; Rochon 1994) and a more balanced presentation of information (Bero et al. 1992) compared with non-peer-reviewed publications. Similarly, articles pub- lished in symposia, which typically are not peer reviewed, have been associated with poor quality and unbalanced findings (Bero et al. 1992, 1994; Rochon 1994). In addition, review articles generally have been associated with biases based on the afi'iliations of the reviewers (Chalmers et al. 1990). Studies have also shown that publications based on industry- funded research tend to draw pro-industry conclusions (Davidson 1986; Swaen and Meijers 1988; Lexchini 1993; Rochon et al. 1994; Cho and Bero forthcoming). I ®

540 Jou~al of Health Politics, Policy and Law Marquardtj V. C., and staff scientist. 1993. Telephone interview regarding funding process for CIAIt projects. 13 October. .National Acadetay of Sciences. 1986. Enirironmental Tobacco Smoke: Measuring Exposurles and Assesstng Health Jrffects. Washington, DC: National Academy Press. ' Parish, L C.. J: A. Witkowsld, and L. E. Milh'han.1991. Conflict of Interest and Sci- entific Publications: International Journal of Dennatology 30(4):250-251. Rabin, R. 1989. Warnings Unheeded: A History of Child Lead Poisoning. American Journal of Public Health 79(12):1668-1674. Relman, A: S. - 1984. Dealing with Conflicts of Interest. New England Journal of Med- icine 31()(18):1182-1183. . 1990. New "Information for Authors"-and Readers. New England Journal of Medicnd 323:56. Rochon, P. X994.: Evaluating the Quality of Articles Published in Journal Supplements Compared with the Quality of Those Published in the Parent Journal. Journal of the Ameiiean Medical Association 272(2):108-113. Rocbon, P. A.; J. H. Qunvitz, R. W. Simms, P. R. Fortin, D. T. Felson, K. L. Minaker, and T. 6. Chalmers..I994. A Study of Manufacturer-Suppotted Trials, of Non- steroidal Anti=inflammatory Drugs in the Treatment of Arthritis. Archives ofInter- nal Mediciiu'154:157-163. Rodwin, k A.1989. Physicians' Conflicts of Interest: The Limitations of Disclosure. New En~landJournal ofMedlcine 321(20):1405-1408. Roper Otg nization. 1978. A Study of Public Attitudes towanda Cigarette Smoking and the To cco Industry in 1978. Stotm, CT: Roper Organization. Rothman, J. 1993. Conflict of Interest: The New McCarthyisrn in Science. Journal of the Ainerican MsdicalAssoeiation 269(21):2782-2784. Sarokin, H; L: 1988. Opinion, Cipollone v Liggett Group et al. 683 Federal Supple- ment 1487, NJ District Court,1988. . Southgate, hvl. T: 1987. Conflict of Interest and the Peer Review Process. Journal of the Ametiean'Medieal Association 258(10):1375. Steeniand, ~C. 1992. Passive Smoking and Risk of Heart Disease. Journal of the Amer- tcan Me;Iical Alaociation 267:94-99. Stolberg, S. 1994. R*arcbers Try to Separate Smoking Fact from Fiction. Los Ange- les Timlis, 28 May, ~. A 1. Swaen, G., knd J: Meijfrs.:1988. Influence of Design Chanacteristica on the Outcome of Retr ve CobodStudies. British Journal of Industtial Medictne 45:624-629. Taking Mo ey from the Devil (Editorial].1985. British Medical Journal 291(6511): 1743-1744. i Tobacco Ittstitute. 19d6. Tobacco Smoke and the Non-smoker: Scientific Integrity at the Crossroaats. W' ington, DC: Tobacco Institute. . Ciscr 1988. Decades of Initiatives by a Responsible Cigarette Indus- try. Wasbington, : Tobacco Institute. Todd, J. S. 1944: Leiter to Robert S. Blacklow, M.D., president and dean of North- eastern hio Univetai6es College of Medicine, 8 Novembec ~ I .~ .

0 0 i.. . 530 Journal of Health Politics, Policy shd Law ® 0 Research 1992b). Hedge's oral testimo:ny was not available for our analy- sis. However, in his written statement, Hedge (1994:2) noted that his research showed "environmental toba6co smoke plays a very minor role, if any, in eliciting sick building syn ~, ome c.omplaints." In addition, 'he stated that OSHA's proposal to requi~e separate ventilation systems in offices, that allow smoking was "unnecessarily restrictive" (Hedge 1994: 3). Thus his statement also supports the tobacco industry position that OSHA should not regulate smoking in the workplace. A third CIAR special-reviewed project was discussed at a congres- sional bearing related to banning smoking on commercial aircraft (U.S. House 1989). This study was conductea by Torbjorn Malmfors, of Malm- fors Consulting Inc., and it measured-ltvels of ETS on aircraft. Larry C. Holcoinb, of Holcomb Environmental Services, presented preliminary findings of the study and stated that be( acted as a consultant to CIAR on the project. Holcomb also noted that ; te had been asked to submit his statement by the Tobacco Institute. According to Holcomb, "the results of the CIAR study confirm that ETS levels in general are very low in pas- senger cabins" (U.S. House 1989: 369), The study was later published in a peer-reviewed journal, and it concluded that exposure to ETS on air- craft is probably not responsible for health problems in either passengers or flight attendants (Malmfors et a1. 1989). - These findings strongly suggest thai the tobacco industry is funding research through CIAR to develop scientific data that it can use in leg- islative forums to support its position. .: Concern regarding the quality of dgta resulting from CIAR special- reviewed projects has also been raised f'U.S. House 1994a; Barnes et al. 1995). A congressional subcommittee rdcently concluded that 25 percent of the data from one of CIAR's special-ieviewed projects may have been falsified or fabricated (U.S. House 1991a). The study was conducted by Gray Robertson, of HBI, and it involved an analysis of indoor air qual- ity, including measures of ETS, in 585joffice buildings. The study was published in a peer-reviewed journal er et al. 1992) and reported that ETS levels in rooms used for "ligb' smoking were similar to levels in nonsmoking rooms. The article concl.~ ded that "with good ventilation, acceptable air quality.can be maintai#ed with moderate amounts of smoking" (Turner et al. 1992: 19). I The U.S. Congress's Subcommittee n Health and the Environment (U.S. House 1994a) conducted an investi.gation of the HBI study in which it obtained that company's raw data and compared them with data sub- mitted in an interim report to CrAR. The:~ubcommittee's analysis showed W