Tobacco Documents Online

ENVIRONMENTAL TOBACCO SMOKE A CRITIQUE OF A PROPOSED SMOKING BAN Palm Springs, California September 1990 Healthy Buildings International, Inc. 10378 Democracy Lane Fairfax, Virginia 22030 3EF ;; 4 1990 HHealthy Buildings International, Inc. (HBI), formerly ACVA Atlantic, has specialized in the study and assessment of indoor air quality in commercial buildings since 1981. Since then, we have diagnosed problems and specified solutions in over 70 million square feet of space entirely representative of the workplaces in which decisions concerning smoking policies are taking place. We consequently have amassed a very large database on those factors that most influence air quality in these buildings. Environmental tobacco smoke is frequently raised as an issue during the course of our building inspections. We therefore have become very familiar with levels of ETS in these environments, as well as with the various control options and policies being considered by workplace occupants. Thus we feel well qualified to comment on the proposed smoking restriction bill from a perspective of both the technical and political issues. Firstly, the EPA policy is based on their stated belief that ETS is one of the most widespread and harmful indoor air pollutants and is a major contributor to indoor air pollution. This statement is not supported by any specific references. In fact, there are very few credible databases of knowledge where consistent methodology has been used to identify, rank, and characterize the building contaminant sources that actually are the cause of occupant problems. Those of which we are aware either mention ETS as a minor (less than 5%) contributor, or fail to mention it at all. Our own findings after examining 412 commercial buildings from 1981 to 1988 show ETS to have been the major contribution to indoor air quality problems in only 3% of the buildings studied. One of the papers most frequently used to support claims that ETS is a major contributor to particulate indoor air pollution is a 1980 paper in Science by Repace and Lowrey. In our opinion, this paper should no longer be used because the data therein is insufficient, outdated and entirely irrelevant to office environments. For example, let us look more closely at some of the measurements that were chosen to be reported by Repace and Lowery since this data is the very backbone of much of the current risk assessment work on which today's decisions on smoking policies are based. in this ten-year-old paper, the only in-office measurements which were made were under experimental conditions in a small, 500 square foot room where artificially high levels of ETS were generated by a relar of seven smokers consuming 32 cigarettes in 49 minutes, giving RSP values as high as 500 pg/m . The only comparison of smoking and non-smoking environments was by ' contrasting RSP levels in the following locations: 1 TI DN 0003088

a SMOKING NON-SMOKING Unventilated room (cocktail party) Church Sunday service Lodge hall Sandwich restaurant A, non-smoking section Bar and grill Fast food restaurant Firehouse bingo game Sandwich restaurant B, non-smoking section Pizzeria Church bingo game Inn Bowling alley Hospitall waiting room Shopping plaza restaurant (2 samples) Barbecue restaurant Sandwich restaurant A, smoking section Fast food restaurant Neighborhood restaurant/bar Hotel bar Sandwich restaurant B, smoking section Roadside restaurant Note how office environments are conspicuous by their absence. And yet the proposed bill is very much orientated away from restaurants, churches, bars, grilles, bingo parlors, etc. Why then is the data available from more recent workplace environments not used in the current risk assessment data? For example, our own measurements in 1988/89 in 331 office environments where smoking was designated and/or discretionary showed mean RSP values of 46 µg/ms -- well below the values used by Repace as representing typical smoking environments. Another published survey of 230 office environments found mean RSP levels of 37 µg/ms in smoking permitted areas. Indeed, one of the papers referred to in the EPA document (E.A. Miesner of the Harvard School of Public Health)- reported a mean RSP concentration of 33.8 µg/ras, but this was omitted from the EPA risk assessment analysis. Ventilation Of course one of the constant statements made by Repace/EPA is that ventilation itself cannot deal with tobacco smoke. This statement ignores a fundamental part of the ASHRAE 62-89 standard on ventilation rates which clearly states that ventilation rates of 20 cfm per person in areas where smoking is discretionary will deal adequately with'moderate amounts of smoking." This standard was adopted by consensus after careful consideration by a large professional body of architects, engineers, health officials, consumer organizations, medical researchers, and building owners and operators. We 2 TI DN 0003089

r t are at a loss to understand why no mention was made of this since it is so germane to the issue at hand. Although the 20 cfm standard should be used primarily as a practical comfort standard, the standard does state that it "reflecu recognized consensus criteria and guidance' with respect to health effects. Our experience corroborates the experience and conclusions of ASHRAE. In 70 million square feet of indoor air quality studies, complaints of comfort problems associated with ETS are extremely uncommon at 20 cfm per person outside air (O/A), where it is found. Before the ASHRAE standard is junked because of claimed health effects of moderate ETS generation diluted by 20 cfm O/A per person, we need better evidence; either risk assessments based on actual exposure measurements, or epidemiological evidence from modern day offices ventilated to 20 cfm per person. By contrast, the health risk assumptions used in the EPA policy guide for spaces ventilated at 20 cfm are based on theoretical calculations, not on practical measurements of exposure to ETS in modern office environments ventilated to 20 cfm per person. Both occupant comfort and ETS health risks, if any, are likely to be improved considerably if efforts first are made to comply with the ASHRAE standard to ensure the reduction of all airborne contaminants in buildings. We have found that 62% of buildings investigated to date are not complying with this standard, compared with NIOSH findings of approximately 50%. In our opinion, compliance with the ASHRAE standard is the single most important and practical step building owners, employers and policy makers can take to reduce exposure to ETS. What Precioitates Smokin4 Bans? Many proposed smoking bans originate with building occupants who attribute irritation to ETS. Unfortunately, virtually every other common indoor pollutant -- including ozone, formaldehyde, oxides of nitrogen, aeroallergens, fungi and bacteria -- give precisely the same uritative effects as high levels of ETS, but of all these, only ETS is visible. Thus, focusing on ETS alone, while paying no attention to ventilation or other aspects of building hygiene, is to miss the entire forest for a single tree. Attempts to solve a tobacco smoke problem alone without dealing with ventilation as a whole could leave significant environmental problems unsolved. An example of an entirely misplaced smoking ban is provided by a major bank headquarters building studied by HBI. An occupant questionnaire commissioned by the management discovered many indoor air quality complaints and led to a proposed smoking ban. On investigation of the building, however, the HVAC system was found to be operating on 100% recycled air, with the fresh air dampers closed. Even with the dampers open, the system was capable of delivering only 2 to 5 cfm fresh air per occupant. The filters were found to be inefficient and excessive fungal growths were found inside the ductwork with correspondingly high numbers of their spores in the air of the office area. Once ventilation, filtration and hygiene were improved, complaints were reduced and the proposed smoking ban was found to be unnecessary. Ironically, the ban would have hidden the only visible evidence of the true causes of indoor air problems in this building. Conclusions We are seeing a proliferation of so-called "Clean Indoor Air Acts" throughout this country. Unfortunately, virtually all of these acts are simply bans or restrictions on smoking. This is a result of a single-minded focus on environmental tobacco smoke -- the only visible indoor air pollutant. However, experience quickly shows that simply removing tobacco smoke is certainly no way of guaranteeing clean air. 3 TI DN 0003090

HBI has determined that the presence of high concentrations of tobacco smoke indicate a much more serious problem. Poor ventilation and improperly maintained ventilation systems are the primary causes of poor indoor air. When such conditions prevail, all the invisible and odorless pollutants are also trapped and many of these are potentially far more dangerous than ETS. Persistent indoor air quality complaints can be resolved only if building managers and operators are prepared to focus on these air handling systems in an appropriate manner. Medicine teaches us that one should not exclusively treat symptoms, the correct goal is to eliminate the cause. Gray Robertson September 1990 4 TI DN 0003091