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Can ventilation control secondhand smoke in the hospitality industry?

Can Ventilation Control Secondhand Smoke
in the Hospitality Industry?
An Analysis of the Document “Proceedings of the
Workshop on Ventilation Engineering Controls
for Environmental Tobacco Smoke in the
Hospitality Industry”, sponsored by the Federal
Occupational Safety and Health Administration
and the American Conference of Governmental
Industrial Hygienists.

June 2000
OSHA Ventilation Workshop Analysis Can Ventilation Control Secondhand Smoke
in the Hospitality Industry?
An Analysis of the Document “Proceedings of the Workshop on Ventilation Engineering Controls for
Environmental Tobacco Smoke in the Hospitality Industry”, sponsored by the Federal Occupational Safety and
Health Administration and the American Conference of Governmental Industrial Hygienists.

Abstract
A panel of ventilation experts assembled by OSHA and ACGIH concluded that dilutionventilation, used in virtually all mechanically ventilated buildings, will not control secondhandsmoke in the hospitality industry (e.g., restaurants, bars, casinos). The panelists asserted that anew and unproved technology, displacement ventilation, offered the potential for up to 90%reductions in ETS levels relative to dilution technology. However, this assertion was notsubstantiated by any supporting data. Air cleaning was judged to be somewhere betweendilution and displacement ventilation in efficacy, depending on the level of maintenance. Thepanel also failed to quantify the ETS exposure or risk for workers or patrons either before or afterthe application of the new technology. Panelists observed that building ventilation codes are notroutinely enforced. They also noted the lack of recognized standards for acceptable ETSexposure as well as the lack of information on typical exposure levels. However, indoor airquality standards for ETS have been proposed in the scientific literature, and reliablemathematical models exist for predicting pollutant concentrations from indoor smoking. Theseproposed standards and models permit application of an indoor air quality procedure fordetermining ventilation rates as set forth in ASHRAE Standard 62. Using this procedure, it isclear that dilution ventilation, air cleaning, or displacement ventilation technology even undermoderate smoking conditions cannot control ETS risk to de minimis levels for workers or patronsin hospitality venues without massively impractical increases in ventilation. Although there is ascientific consensus that ETS is a known cause of cancers, cardiovascular diseases, andrespiratory diseases, although ETS contains 5 regulated hazardous air pollutants, 47 regulatedhazardous wastes, 60 known or suspected carcinogens, and more than 100 chemical poisons, thetobacco industry denies the risks of exposure, opposes smoking bans, promotes ventilation as apanacea for ETS control, and works for a return to laissez-faire concerning smoking in thehospitality industry. Smoking bans remain the only viable control measure to ensure thatworkers and patrons of the hospitality industry are protected from exposure to the toxic wastesfrom tobacco combustion.
OSHA Ventilation Workshop Analysis Table of Contents
Executive Summary
• ETS and Ventilation: Health Risk Assessment Summary Summary of issues raised in OSHA/ACGIH Ventilation Workshop
• General Categories of Proposed Solutions • Condensed Workshop Summary
Environmental tobacco smoke
• Modeled ETS Exposure in Hospitality Venues • Risk Modeling, Dilution Ventilation (RACT) • Risk Modeling, Displacement Ventilation (BACT) • Conclusions on ETS Risks under RACT and BACT Tobacco Industry and Ventilation
• ETS, Ventilation, and the Hospitality Industry Conclusions
Appendices
• Appendix A: 103 Poisons in Tobacco Smoke
• Appendix B: Equivalency of Repace and Ott models of ETS-RSP • Appendix C: 47 Chemicals in ETS classified as hazardous waste • Appendix D: Documents from tobacco industry websites References
List of Figures
• Figure 1. Nicotine levels in 10 Vancouver, British Columbia, Pubs
• Figure 2. Estimated ETS risks for restaurant workers • Figure 3. California economics and smoke-free ordinances.
• Figure 4. Active and passive smoking and breast cancer List of Tables
• Table 1: Equations for exposure & dose estimation
• Table 2. Comparison of model with measurements of ETS markers • Table 3. Smoker density & Air Exchange for hospitality venues • Table 4. Estimated RSP and Nicotine for cigarette smoking • Table 5. ETS-RSP and disease for hospitality industry workers • Table 6. Mortality for ETS and Hazardous Air Pollutants • Table 7: Wells’s Mortality Estimates for ETS • Table C-1. Carcinogens in tobacco smoke OSHA Ventilation Workshop Analysis Executive Summary
1. OSHA-ACGIH Ventilation Workshop Summary
A panel of 14 experts on ventilation engineering and ventilation practices in
the hospitality industry was charged with determining technically andeconomically feasible engineering controls for ETS in restaurants, bars, andcasinos, assuming that total elimination of ETS was not an option. The panelrecognized that there was a lack of information on typical ETS exposure levels insuch venues, as well as a lack of recognized standards for acceptable exposure.
Panelists concluded that well-mixed dilution ventilation, the overwhelmingmajority of current installations, was unsatisfactory for controlling workerexposure to ETS in hospitality venues. Local area exhaust ventilation, smokelessashtrays, air cleaning, and displacement ventilation were identified as potentiallymore effective. Of these, displacement ventilation was viewed as the mostpromising, with estimated 90% reductions under the most favorable conditions.
These estimates were based on professional judgment rather than on measureddata. Moreover, the panel raised several concerns about displacement technology,including lack of familiarity by many ventilation engineers, difficulty withretrofitting existing installations, and potential aesthetic problems.
Ventilated ashtrays as currently available did not appear to be effective, although panelists felt the technology could be made 40% to 50% efficient,provided smokers could be persuaded to use them, a significant potential problemin areas where foreign tourists are frequent customers. These conclusions wereprofessional judgments as opposed to data-based analysis. Although air filters arecapable of high capture efficiencies, they also require high airflow to be effective,and needed regular effective maintenance to remain effective. Costs are a majorconsideration in the restaurant industry, which limits the implementation of hightechnology solutions such as 100% outside air 1-pass systems. Costs are not alimiting factor in the casino industry for the large casinos, although they are forthe small ones. Large fluctuations (e.g., factors of 3) in the smoking population ofthese venues may occur. A further significant problem is that some building codesdo not require that the ventilation system actually be operated, especially in thesmall non-chain establishments.
In brief, The OSHA/ACGIH workshop concluded that presently available ventilation technology (well-mixed dilution ventilation) was unsatisfactory forcontrolling worker exposure to ETS. It also concluded that air cleaning wassimilarly problematic. Of proposed new technology, displacement ventilation was OSHA Ventilation Workshop Analysis viewed as having the potential for 90% reductions in ETS levels, although thisview was not supported by performance data. Other major problems included thelack of familiarity of most ventilation engineers with the new technology, and thedifficulty in retrofitting existing installations. Panelists viewed the lack ofenforcement of ventilation rates by local building codes and the use of naturalventilation as further problems. However, it should be noted that in California,Cal-OSHA requires employers to ventilate workspaces during working hours.
2. ETS and Ventilation: Health Risk Assessment Summary
Using U.S. average smoking prevalence, ASHRAE Standard 62-1999 and 62-1989 default occupancy levels, and recommended makeup air supply rates,models show that for dilution ventilation supplied in recommended amounts,estimated ETS RSP levels for hospitality industry venues will be between 100 and200 µg/m3, and air nicotine levels from 10 to 20 µg/m3. Predicted levels aresignificantly lower than observations, suggesting lower ventilation rates or highersmoker densities than expected. This is not surprising since smoker density is notregulated and ventilation rates are not enforced.
Assuming ideal dilution ventilation, i.e., reasonably achievable control technology (RACT), model-estimated ETS risk levels for lung cancer and heartdisease combined ranged from 15 to 25 per 1000 workers, which is 15 to 25 timesOSHA’s significant risk level, and 15,000 to 25,000 times the de minimis or“acceptable risk” level for federally regulated hazardous air pollutants. Thissupports the conclusion of the OSHA/ACGIH ventilation panel that dilutionventilation (better than 99% of current installations) is not a viable control forETS.
Assuming ideal displacement ventilation, i.e., best achievable control technology (BACT), based on the professional judgment of the OSHA/ACGIHpanel, estimated ETS risk levels for lung cancer and heart disease combined wouldbe reduced by 90%. This places estimated ETS risks between 1.5 to 2.5 per 1000workers, which is 1.5 to 2.5 times OSHA’s Significant Risk level, and 1,500 to2,500 times the de minimis or “acceptable risk” level for federally regulatedhazardous air pollutants. Even a 90% reduction in ETS exposure yields massivelyunacceptable risk.
Moreover, the panel’s estimates of 90% reductions in ETS concentrations are not supported by measured data. ETS concentrations experienced by workersin smoking areas may actually be increased due to low air flows employed by thistechnology, and the confinement of smokers to designated smoking areas with afraction of the volume of the entire building.
OSHA Ventilation Workshop Analysis All cognizant health and scientific authorities in the U.S., including the US Environmental Protection Agency, the National Institute for Occupational Safetyand Health, OSHA, the Surgeon General, the National Academy of Sciences, theNational Cancer Institute, the National Toxicology Program and the AmericanMedical Association, have concluded that ETS exposure causes morbidity andmortality. This consensus has been accepted by ASHRAE in ASHRAE Standard62-1999 and codified in Addendum 62-e.
While indoor pollutants are not regulated under the Clean Air Act, the control technologies utilized are appropriate for the discussion of indoor pollutantssuch as ETS. Under Section 112 of the federal Clean Air Act, pollutants may bedesignated as “hazardous air pollutants” (HAPS) if they can cause seriousmorbidity or mortality, as ETS does. These ETS-like chemicals are regulated byNESHAPS, which are far more stringent than either the “reasonably achievablecontrol technology” (RACT) for existing sources or “best available controltechnology” (BACT) required for new sources of outdoor air pollution. RACTand BACT are designed to control ordinary non-hazardous air pollutants.
NESHAPS regulate HAPS to levels of de miminis risk with an adequate margin ofsafety. ETS actually contains 5 HAPS pollutants, more than 100 poisonouschemicals, and 47 chemicals classified as hazardous waste under RCRA. ETSemitted into the outdoor air from a smokestack industry would qualify forregulation as a HAP mixture, like coke-oven emissions.
While no official ETS indoor air quality (IAQ) standards have been adopted in the U.S., proposed NESHAPS-style ETS IAQ standards have been published,and are based on limiting ETS lung cancer and heart disease risk to de minimislevels. Application of these putative standards to restaurants, bars, and casinosshows that tornado-like levels of ventilation would be required to control ETS.
Moreover, enforcement of an official ETS-ventilation standard would requireestablishment of costly new regulatory bureaucracies. Even if official standardsfor ETS were adopted for lung cancer and heart disease, protecting against theemerging risks of ETS-induced breast cancer, stroke, nasal sinus cancer,respiratory diseases, etc. would remain a formidable obstacle.
The tobacco industry does not concede that ETS poses health risks to nonsmokers. Its goal, as stated on its websites, is to promote ventilationtechnology as one possible option among many for hospitality business owners,and the industry argues for letting the marketplace decide how to control ETS.
Smoking bans represent the most cost-effective, easiest-to-enforce, and lowest risk alternative for ETS control. They appear profitable for business, andare also the only control measure known which is capable of yielding zero risk.
OSHA Ventilation Workshop Analysis I. The following is a summary of issues raised in the 176 page document Proceedings of theWorkshop on Ventilation Engineering Controls for Environmental Tobacco Smoke in theHospitality Industry, sponsored by the U.S. Dept. of Labor, Occupational Safety and HealthAdministration (OSHA), and the American Conference of Governmental Industrial Hygienists(ACGIH). This discussion includes the available (dilution ventilation and air cleaning) andproposed (displacement ventilation) technology, and summarizes the constrasting views ofventilation engineers present at the workshop.
SUMMARY OF PROCEEDINGS OF THE WORKSHOP ON
VENTILATION ENGINEERING CONTROLS FOR ENVIRONMENTAL
TOBACCO SMOKE IN THE HOSPITALITY INDUSTRY, JUNE 7-9, 1998,
FT. MITCHELL, KY
CO-SPONSORED BY THE
U.S. DEPT. OF LABOR, OCCUPATIONAL SAFETY & HEALTH ADMINISTRATION
(OSHA) AND THE AMERICAN CONFERENCE
OF GOVERNMENTAL INDUSTRIAL HYGIENISTS (ACGIH)
Summary: In June 1998, OSHA sponsored a Technical Workshop on Ventilation
Engineering Controls for Environmental Tobacco Smoke Exposure in the
Hospitality Industry. The 3-day workshop, held in Ft. Mitchell, Kentucky, was
coordinated by ACGIH. A panel of 14 experts was assembled to provide more
information on ETS exposures and to discuss ventilation engineering controls for
reducing exposures in restaurants, bars, and casinos. The panelists were either
experienced ventilation engineers or facility managers from the hospitality
industry.
The workshop was an outgrowth of OSHA’s Notice of Proposed Rulemaking on Indoor Air Quality (59 FR 15968) which required control of pointsources of pollutants, and specified conditions under which smoking could beallowed in the workplace. Employers were required to establish designatedsmoking areas, permit smoking only in such areas, and ensure that those areaswere enclosed and exhausted directly outdoors, and maintained under negativepressure sufficient to contain tobacco smoke. Employees could not be required toenter the designated smoking areas as part of their normal work. However, whilethe ETS provisions were feasible for many employers, “it became apparent toOSHA that in businesses where there is substantial contact between customerswho smoke and workers (e.g. food, beverage and gaming industries, collectivelyknown as the ‘hospitality industry’) this provision was not easily applied as OSHA Ventilation Workshop Analysis written. During the public hearing on OSHA’s proposed standard on indoor airquality, representatives of the hospitality industry supplied very little informationon engineering and administrative controls that could be used to protect workers.
The purpose of the 1998 Workshop was “to obtain much needed information on feasible engineering and work practice controls for the hospitalityindustry (i.e., bars, restaurants and gambling facilities) that could potentiallyreduce ETS exposure, from the point of view of ventilation engineers and facilitymanagement personnel. A Mission Statement was delivered to the panelists byDr. Steven Guffey, Workshop Chair, and ACGIH Industrial VentilationCommittee Member, University of Washington. Dr. Guffey stated that “theworkshop mission was to come up with feasible controls for environmentaltobacco smoke (ETS), particularly in the hospitality and restaurant business.” Heasserted that the workshop’s primary aim was to achieve reductions in ETS levels.
Dr. Guffey stated that the workshop focus included, but was not limited to, “theunique occupational exposures in the hospitality sector due to the interfacebetween workers and smoking customers. ETS is a contaminant in bars,restaurants and gambling facilities. We will consider engineering controls, such aslocal source capture ventilation, that control the contaminant at its point ofgeneration; controls that are technically and economically feasible. We can alsoconsider other ventilation engineering controls employed in general industry, suchas makeup air islands, and displacement ventilation.” Ventilation was defined (R. Hughes Presentation) as an application of controlled airflow for the purpose of providing comfort and to provide forcontaminant control. The two basic types of ventilation are local exhaustventilation and dilution or general ventilation. Local exhaust captures thecontaminant right at the source. Local exhaust ventilation can be significant inreducing worker exposure, because the contaminant is captured at or near thesource and is prevented from reaching the worker. Local exhaust is primarily forpoint source contamination. It is very effective for high contaminant levels, andrequires low airflow. Dilution ventilation dilutes the contaminant by mixing thelarge quantities of air with it to lower the concentration level. It does not preventworker exposure because the contaminant stays in the area. It is usually better fordiffuse sources of contamination. Its application is better with low levels ofcontaminant or low toxicity contaminants. A disadvantage (in addition to the poorexposure control) is that it can require extremely large amounts of airflow.
The major source of information for ventilation design in the commercial or indoor environment is the ASHRAE Handbook of Fundamentals. Information inthe ASHRAE Fundamentals focuses primarily on comfort although they do have OSHA Ventilation Workshop Analysis information on industrial ventilation. ASHRAE does provide some of thetheoretical aspects of ventilation. Industrial ventilation does have applicability forthe control of the commercial environment, and while most of the past efforts havebeen directed to the industrial environment these ventilation techniques are readilyadaptable. ACGIH’s Industrial Ventilation focuses primarily on the industrialenvironment. It discusses in great detail local and general ventilation, providinginformation on system components, discussing the construction of exhaust hoods,fans, and duct design.
During the workshop, each panelist presented for 15 minutes on topics including local source capture vs. general dilution ventilation, supply air islands,ventilation performance monitoring, displacement ventilation systems, particulateand gas phase air cleaners, and current practice for designing heating, ventilating,and air conditioning (HVAC) systems. The panel then explored the technologicaland economic feasibility of applying current prudent practice for application ofHVAC controls to the hospitality sector. Finally, the panel maderecommendations of the most promising options.
The Executive Summary of the Workshop Proceedings, authored by Dr.
Guffey, synopsized the issues involved in “engineering solutions to ETSexposures.” Panelists discussed several possible engineering solutions for avariety of ETS exposure conditions in restaurants, bars, and the gaming industry.
Displacement ventilation was deemed to have the greatest chance of producingsubstantial reductions, and could be less costly over time than the dilutionmethods now in common use. However, a major problem is that displacementventilation is unfamiliar to most heating, ventilating, and air conditioning (HVAC)engineers, and presents challenges in duct placement, especially in retrofittingexisting facilities. Another problem is that displacement ventilation is relativelynew and practical applications too recent and sparse to state with confidence that itwould apply to larger casinos or to cases where turbulent mixing is not well-controlled. Likewise it may be difficult to use ventilated ashtrays on gamingtables because they would obscure some hand movements, a security issue incasinos. In general, ventilated ashtrays were thought to have less potential toachieve dramatic reductions in exposures, but would reduce the quantity of ETSreleased into occupied spaces, while using low levels of exhaust air. A drawbackis that they would require cooperation of smokers and occupy counter or tablespace. A combination of displacement ventilation and ventilated ashtrays mightbe used together, in restaurants and bars.
Although the mission of the group was to develop engineering solutions to ETS exposures, it was recognized that a major complication was “the lack of a
OSHA Ventilation Workshop Analysis recognized standard for acceptable exposure levels, and the lack of important
information on typical levels of exposure.”
It was not clear to Panelists what the
typical levels of exposures to workers in restaurants, bars, and gaming
establishments would be if current ventilation strategies were well executed.
Furthermore, for most ventilation interventions, it was difficult to predict the
reduction in exposures that would result because in part efficacy depends on many
factors beyond the control of the designer. Factors cited included sources of
exposure, mechanisms of exposure, constraints imposed by material handling
(e.g., serving of food or drinks or dealing cards), work practices such as standing
within arm’s reach and avoiding a hurried or unfriendly appearance), competing
air motions (e.g. jets from diffusers, convection) and source strength, location, and
mobility. Despite these unknowns, the panel believed it could propose measures
which “will substantially reduce ETS emissions, and thus exposure to workers.”
The actual magnitude of reductions would have to be experimentally determined.
The sufficiency of the reductions would have to be ascertained when ACGIH or
others set a standard of acceptable exposure.
The panel considered such factors as identification of major issues, vital information that is missing or incomplete, smoking locations, sources of smoke,smoker behaviors important to source control, ETS monitoring, importantconstraints on solutions, general categories of possible solutions, and finally,proposed general control measures for bars, restaurants, and casinos: dilutionventilation, displacement ventilation, and ventilated ashtrays. Estimated percentreductions were made, apparently based on professional judgment rather than dataor models. Total elimination of ETS was not an option for consideration.
Panel discussion of major issues:
1. Vital information missing or incomplete: missing information on upward velocity of cigarette and cigar smoke (pipes apparently not considered) atdifferent heights above the source, crucial for downdraft control. Panelconcluded velocities too great for downdraft to work. Will increasing airflowincrease burn rate, discouraging smokers from cooperation in holdingcigarettes under small hoods between puffs? Uncertainty about buildup of tarson ducts. Effective filters may require excessive pressures, and may be poorlymaintained. Optimal filters and placement -- in the hood or near the fan? Canfiltered exhaust air be recirculated or must it be exhausted outdoors?Smokeless ashtray filters are poor on removal efficiency. Restaurant industrypanelists complained of the difficulty of adequate maintenance and detrimentaleffects of increased fan pressures on equipment if filters added to existing OSHA Ventilation Workshop Analysis systems. Panelists were unaware of published data on these issues, but thoughtit could be obtained by future research.
2. Smoking locations: Engineering controls need to be discussed in terms of location of activity rather than type of establishment, e.g., tables and booths,bars, gaming tables, slots, and video games, designated smoking lounges wherecustomers are served, stationary workers in service areas, change booths, orcashiers.
3. Smoking sources: Exhaled mainstream smoke diffuses over large area, unless the smoker directs it into a receptacle; smokers in motion are a diffuse sourceof both exhaled mainstream and sidestream smoke. Point source controlstrategies may not work. It is doubtful that if smokers blow smoke at workersthat any kind of ventilation can control it. Velocity and direction is important.
Designing systems for mobile source control very difficult. How long doessmoker hold cigarette, and how long is it down? Differences between cigarsand cigarettes? Pipe smoking was held to be rare, and dismissed as source.
ETS generation rates are not well characterized.
4. Reduction in ETS that must be obtained? No guidance provided.
5. Necessary smoker behavior for solution success: Smoking behaviors differ in restaurants, bars, and casinos. Restaurant smoking is leisurely, casino smokingis intense.
6. Assumptions about smoker behavior, and likelihood of adoption of requested behavior necessary for substantial reduction:: Can smoking take place only indesignated areas, leaving cigarettes in ashtrays as much as possible, blowingsmoke toward ventilated points? In the panelists’ experience, compliance withposted rules is high for locations, directional exhaling is possible, especiallyvertically. Smokers’ attitudes toward leaving cigarettes in ashtrays when not inuse is unknown, but compliance is judged likely.
7. Monitoring of ETS: Best indicators thought to be personal monitoring of airborne nicotine and UV or fluorescent particulate; literature suggests thatrespirable suspended particles poorly correlated to more specific measures.
Body fluid or hair cotinine possible but affected by individual variability.
Stationary monitors may be better than personal monitors for short periods dueto individual variability.
OSHA Ventilation Workshop Analysis 8. Important constraints on solutions: Acceptable solutions should require minimal effort by smokers and should not make them feel conspicuous orpunished. Acceptable solutions must stay within airflow capacity of currentequipment except perhaps for large casinos.
9. Likely attainable ETS reduction for each method: Varies among methods.
10. Cost factors and limitations: Cost of additional exhaust ventilation was $1-$2 per cubic foot per minute per year ($1-$2/cfm-y).
General Categories of Proposed Solutions
• Smoking bans
• Smoking lounges, including self-serve dining areas where employees do not go • Local source capture and control using hoods Since the mission of the workshop was to explore solutions that would allowsmoking while “substantially reducing exposure to employees,” bans, limitationsand non-service smoking lounge options were dismissed. Panelists concluded,furthermore, that while well-mixed dilution ventilation is currently widely used, itappears that it is not a satisfactorily efficient or effective method of controllingETS exposures to workers in restaurants, bars, and gaming establishments.
Especially given the absence of a prescribed quantitative level of acceptablecontrol and measured data demonstrating that control. Thus the workshopfocused on the remaining alternatives: displacement ventilation and local exhaustventilation of ETS sources.
Displacement Ventilation
Displacement ventilation is a dilution design strategy that eschews the turbulencemixing necessary to traditional “well-mixed” designs. Displacement ventilationrequires that supply air released in a room be 5 to 10 degrees cooler than the airalready in the room. Released at the floor level, it will travel horizontally acrossopen spaces. Since people, mechanical and electrical devices are generally muchwarmer than this supply air, the convection currents from them carry warmcontaminated air to the ceiling area where it can be removed by return air grilles.
The rising plume of ETS being warm is helpful, and both sidestream and exhaledmainstream should rise. If the ceiling exceeds 8 feet, then the contaminants near OSHA Ventilation Workshop Analysis the ceiling should be well above the breathing zone. This strategy contrasts withwell mixed dilution ventilation, which attempts to mix floor and ceiling air usingjets from the ceiling diffusers to provide the necessary kinetic energy. To besuccessful, displacement ventilation requires that there be relatively littledisturbance to the air by moving objects (e.g., Casablanca fans), jets of air, etc. (inother words, it is a low-flow technique). It works best when the supply air can bedelivered very close to the floor, requiring ducts and supply air grilles to beinstalled at or near the floor. If tobacco smoke is exhaled downward, this runscounter to this strategy. Also, restaurant industry panelists objected to theconstraints on layout and esthetics imposed by locating large diffusers near thefloor. Experimental verification of efficacy is lacking if diffusers are located inthe ceiling near walls and directed downward. The panelists concluded that ifconditions are suitable, displacement ventilation has the potential to remove bothsidestream and mainstream smoke, and may be used in conjunction with ventilatedashtrays, ventilated booths, and other local exhaust strategies.
Panelists estimated that total ETS reductions were likely to be around
90% or more for good conditions. However, they noted that poor conditions,
especially those due to the introduction of turbulence and large eddies, could
sharply lower the reductions.

The panelists observed the following concerns: • Displacement technology is unfamiliar to many HVAC engineers • Supply air diffusers take up significant wall space • Ducting of air to floor level can be difficult, especially in existing facilities • The technology is sensitive to errors in supply air temperature, affecting • Low ceilings can lead to stratified temperatures (warm heads, cold feet) • Concentrations of ETS at ceiling height are dense; workers at elevated stations (as in casinos) could experience increased exposures unless additionalmeasures are taken Ventilated Ashtrays
Ventilated ashtrays (“smokeless” ashtrays), according to the panelists, in principlecould be highly effective in reducing sidestream smoke, but commercial modelstested were largely ineffective, although experimental ones built by some panelistshave worked much better. In addition, for any ductless unit to remain effective,filters have to extremely well maintained. Panelists felt maintenance would likelybe a continuing problem for the hospitality industry. Operational problemsrelating to scarcity of space on bar tops and tables and potential problems with OSHA Ventilation Workshop Analysis cleaning the units and the surfaces they obstruct may limit their usefulness.
Panelists had reservations about whether enclosed ventilated ashtrays would be
accepted by restaurants and patrons. Panelists assumed that 50% to 70% of ETS
came from sidestream smoke, and assumed that properly maintained devices could
collect 95% of the effluent while the cigarette was resident, which they assumed
would be 80% of the time, yielding a net estimated collection efficiency of 38%
to 53% of ETS.

Advantages:
• Reduce total room ETS burden, including room surfaces Disadvantages:
• Must be ducted to outside unless posessing self-contained filter and fan • Frequent cleaning of hoods and ducts necessary if not filtered at hood • Internal hood filters must be frequently cleaned • For units without internal filters, duct plugging may occur Canopy Hoods For Tables
Panelists stated reductions in ETS for canopy hoods would depend on airflow levels, but did not estimate likely reductions because minimum airflowswere impracticably high, in the neighborhood of >300 cfm/hood.
Condensed Workshop Summary:
A panel of 14 experts on ventilation engineering and ventilation practices in the hospitality industry was charged with determining technically andeconomically feasible engineering controls for ETS in restaurants, bars, andcasinos, assuming that total elimination of ETS was not an option. The panelrecognized that there was a lack of information on typical ETS exposure levels insuch venues, as well as a lack of recognized standards for acceptable exposure.
Panelists concluded that well-mixed dilution ventilation, the overwhelmingmajority of current installations, was unsatisfactory for controlling workerexposure to ETS in hospitality venues. Local area exhaust ventilation, smokelessashtrays, air cleaning, and displacement ventilation were identified as potentiallymore effective. Of these, displacement ventilation was viewed as the most OSHA Ventilation Workshop Analysis promising, with estimated 90% reductions under the most favorable conditions.
Concerns about this technology included lack of familiarity by many ventilationengineers, difficulty with retrofitting existing installations, and potential aestheticproblems.
Ventilated ashtrays as currently available did not appear to be effective, although panelists felt the technology could be made 40% to 50% efficient,provided smokers could be persuaded to use them, a significant potential problemin areas where foreign tourists are frequent customers. Although air filters arecapable of high capture efficiencies, they also require high airflow to be effective,and needed regular effective maintenance to remain effective. Costs are a majorconsideration in the restaurant industry, which limits the implementation of hightechnology solutions such as 100% outside air 1-pass systems. Costs are not alimiting factor in the casino industry for the large casinos, although they are forthe small ones. Large fluctuations (e.g., factors of 3) in the smoking population ofthese venues may occur. A further significant problem noted by the participants isthat some building codes do not require that the ventilation system actually beoperated, especially in the small non-chain establishments. However, it should benoted that in California, Cal-OSHA requires employers to ventilated workspacesduring working hours, under (CCR Title 8, 5142).
Comment: Despite the wealth of ETS data in the literature compiled in
more than 1/2 dozen reports, plus the fact that indoor air quality models have beenunder development for more than 40 years, the panel did not use either models ordata to characterize existing ETS exposures in hospitality venues. The panel didnot apply the indoor air quality procedure in ASHRAE 62, section 6.2, whichprovides a direct solution to the problem by restricting the concentration of ETS tosome specified acceptable level. No data were presented to substantiate thepanelists’ belief that 90% reductions in ETS concentrations were obtainable undereither controlled studies or in the field, especially in view of the caveats raisedabout placement of supply air ducts, turbulent flows, and blowing smoke down ortoward the workers (as often happens in casinos). Moreover, in view of OSHA’sestimates of more than 13,000 workers’ deaths per year from ETS exposure, thepanel’s attitude that only a 90% reduction is sufficient for ETS control to protectworkers seems cavalier. The panels’ confidence in displacement ventilation is notwell founded. In addition, the panels’ conclusion on ETS-RSP being poorlycorrelated to more specific measures is not supported (e.g. see EHP, 107, suppl. 2,pp 225-388 (May 1999). Individual variability in cotinine levels does notcompromise assessment of ETS dose (Repace et al., 1998).
OSHA Ventilation Workshop Analysis Environmental tobacco smoke (ETS)
This following demonstrates application of the indoor air quality procedure specified in ASHRAE Standards 62-1981, 62-1989, and 62-1999 to ETS,providing the “direct solution” to the ventilation rates necessary for control.
Hazard Assessment. Environmental tobacco smoke (ETS) is the smoke emitted
into the air from the burning end of a cigarette, pipe or cigar, as well as exhaled
smoke from the smoker. The breathing of ETS is known as involuntary smoking
or passive smoking. A body of evidence on the health risks of ETS has
accumulated during the past two decades, connecting exposure to ETS to
premature death. The most recent report on ETS from the United Kingdom, the
SCOTH Report (1998), concluded that passive smoking is a cause of lung cancer
and ischemic heart disease. The SCOTH report concludes that restrictions on
smoking in public places and work places are necessary to protect nonsmokers
(SCOTH, 1998). The U.S. National Toxicology Program has include ETS on its
list of known human carcinogens (NTP, 2000), and the Finnish Parliament
similarly voted to list tobacco smoke on its national list of carcinogenic substances
(CanFin, 1999).
In the USA, in 1997, the Environmental Protection Agency of the State of California (CalEPA, 1997), in a scientific report which considered publiccomments from individuals from federal, state, and local government agencies,universities, and various research organizations, as well as from the tobaccoindustry, concluded that in adult nonsmokers, ETS exposure causes lung cancerand nasal sinus cancer, heart disease mortality, acute and chronic coronary heartdisease morbidity, and impairs fetal growth in pregnant women as well asinflicting acute eye and nasal irritation. The California EPA(1997) estimated thatU.S. ETS exposure caused 3000 lung cancer deaths (LCDs) annually, from 35,000to 62,000 heart disease deaths (HDDs) from ischemic heart disease per year, andcaused an indeterminate number of cases of retardation of fetal growth.
In 1994, The U.S. Occupational Safety and Health Administration (OSHA, 1994), asserted that “employees working in indoor environments face a significantrisk of material impairment of their health due to poor indoor air quality.” Insupport of that determination, OSHA cited the risk of heart and lung fatality tononsmoking U.S. workers from passive smoking, estimated to range as high as722 annual cases of fatal lung cancer, and 13,000 deaths from heart disease peryear, and that these deaths would be avoided by elimination of nonsmokers’exposure to ETS in the workplace. OSHA(1994) proposed a rule to eliminatenonsmokers’ ETS exposures in the workplace. In 1992, the U.S. Environmental OSHA Ventilation Workshop Analysis Protection Agency (EPA, 1992) declared ETS to be a “known human lungcarcinogen,” causing conservatively 3000 LCDs annually.
In 1992, the American Heart Association (AHA, 1992) declared ETS to be a "major preventable cause of cardiovascular disease and death," and estimatedETS-related mortality, from heart disease and cancer combined, to approach50,000 annually, placing passive smoking as the third leading preventable cause ofdeath, after active smoking and alcohol. In 1991, the U.S. National Institute forOccupational Safety and Health (NIOSH, 1991) declared environmental tobaccosmoke (ETS) to be a "potential occupational carcinogen," legal terminology for asubstance capable of causing human cancer or reducing its latency period. Basedupon biological plausibility and epidemiological studies, a number of riskassessments have estimated the lung cancer mortality caused by passive smokingamong U.S. nonsmokers to be of the order of 5000 deaths per year (Repace &Lowrey, 1985; 1990). Wigle et al. (1987) estimated that 330 Canadians die oflung cancer from passive smoking annually.
In 1986 The U.S. Surgeon General concluded that "involuntary smoking is a cause of disease, including lung cancer, in healthy nonsmokers." Also in 1986,The National Research Council (NRC, 1986) of the U.S. National Academy ofSciences, a congressionally chartered private body established to further scientificknowledge and to advise the federal government on scientific issues, stated that"Considering the evidence as a whole, exposure to ETS increases the incidence oflung cancer in nonsmokers." The body of evidence from spousal smoking studies suggests that the average excess risk of lung cancer from passive smoking is 24% (95% CI: 13% to36%) [Hackshaw et al., 1997]. However, for nonsmokers exposed to the smoke ofa pack of cigarettes per day or more, the risk increase can be considerably greater;the EPA summarized 12 studies that assessed the increase at these higher levels ofsmoking. For 9 studies in 5 countries, the excess ETS risk in this category rangedfrom 57% to 220%; 3 other studies in 2 countries reported risks in the 10% to 20%range (U.S. EPA, 1992, Table 5-11). In the U.S. in 1980, the average smokersmoked 32 cigarettes per day (Repace and Lowrey, 1980). Law et al. (1997)reviewed the evidence from 19 published studies of passive smoking and heartdisease; they reported that the average excess risk of ischemic heart disease frompassive smoking epidemiological studies is 23% (95% CI:14% to 33%), andconcluded that platelet aggregation provides a plausible explanation for themechanism and magnitude of the effect. Kawachi, et al. (1997) studied coronaryheart disease (CHD) in 32,000 female U.S. nurses aged 31 to 61 yr., fornonsmoking women exposed only at work, observed a dose-response for passivesmoking and CHD. Adjusted relative risks of CHD were 1.00 [for no exposure], OSHA Ventilation Workshop Analysis 1.58 (95% CI, 0.93-2.68) [occasional exposure], and 1.91 (95% CI, 1.11-3.28)[regular exposure]. In this study, regular exposure to SHS at work caused a 91%increase in CHD.
Johnson and Repace (in press) observed that the epidemiological studies of passive smoking and disease are flawed where other exposure is common (e.g., inchildhood, in social situations, or in the workplace). In such cases lung cancer andother disease risks may be seriously underestimated. Spouses of non-smokersexposed in other circumstances will be misclassified as nonexposed,contaminating the referent group, and attenuating the risk estimate. For example,Hackshaw et al.(1997) estimate that the odds ratio for lung cancer and passivesmoking would have been 1.42 (1.21- 1.66) if those with spousal exposure alonewere compared with those who were truly unexposed. By comparison, in a recentmeta-analysis of risk associated with workplace exposure, Wells (1997) found anestimated relative risk of 1.39 (95% confidence interval 1.15-1.68) for the fivestudies meeting basic study quality standards. Repace and Lowrey (1985) foundthat when both workplace exposure and an unexposed referent group were takeninto account in the American Cancer Society study of passive smoking and lungcancer, a population relative risk of 1.2 increased to 1.7.
In fact, Repace and Lowrey modeled the risk of workplace exposure, estimating the average relative risk at 2.0 for U.S. office workers in the 1980’s.5This result is consistent with a value reported by Reynolds et al. (1996). forwomen with 30 or more years of workplace exposure, i.e. at ages at which lungcancer mortality begins to become significant. Moreover, all of these analysesfocus on average risk. Repace et al. estimated that individuals at the 95thpercentile (e.g., those experiencing high smoker density and low air exchange)have exposure -- and risk -- as much as four times as high as those at the median.
This result is commensurate with observations of dose and risk (Johnson andRepace, in press). In general, the degree of ETS disease risk depends criticallyupon the average ratio of the smoker density to the air exchange rate in theexposure venues a person frequents during life; e.g., workplace smoker densitiesare often far higher than in homes, while air exchange rates may be comparable(Repace and Lowrey, 1985; 1993; Repace et al., 1998).
Hazardous Chemicals in ETS
What chemicals in ETS are responsible for these diseases? ETS is a complex mixture of 5000 chemicals (NRC, 1986), many of which remain to becharacterized. Listed in Appendix A are 103 chemicals in tobacco smoke whichare identified as hazardous. Although OSHA TLVs exist for many of these OSHA Ventilation Workshop Analysis chemicals, the effects of exposure to all of them simultaneously, with the multiplepossibility of additivity, synergism or antagonism of effect, is not known. Thereare 60 known or suspected carcinogens in ETS (Repace and Lowrey, 1985).
Markers for ETS:
Nicotine and its primary metabolite cotinine are the best indicators of ETS exposure and dose in nonsmokers. Airborne nicotine has beenfound to be highly correlated to the number of cigarettes smoked in the presenceof nonsmokers and to urinary cotinine in those nonsmokers. During passivesmoking, nonsmokers inhale nicotine proportionally to the product ofconcentration, exposure duration, and respiration rate. Inhaled nicotine isabsorbed into the bloodstream through the lung, and is rapidly and extensivelymetabolized with a half-life of the order of 2 hrs by the liver into cotinine andnicotine N-oxide. The intake of nicotine reflects exposure to other constituents ofETS. In nonsmokers, cotinine has a half-life in plasma on the order of 17 hrs andthus is an indicator of the integrated exposure to ETS over the previous 1 to 2days. Cotinine in body fluids provides a valid quantitative measure of recentintegrated ETS nicotine exposure (Repace et al., 1993; 1998; Benowitz, 1999;Samet, et al., 1999). Cotinine appears in all body fluids and on average is excretedin fixed relationships from plasma (i.e., serum) into saliva and urine. Althoughnicotine is present in trace amounts in certain vegetables, dietary sources arenegligible compared to passive smoking as a contribution to body fluid cotinine.
Air nicotine can be used to predict ETS-RSP (Leaderer and Hammond, 1991;Repace and Lowrey, 1993; Daisey, 1999). ETS is the major source of exposure ofthe population to indoor fine particles (Repace and Lowrey, 1980; Wallace, 1996).
The set of equations given in Table 1 permit calculation of one ETS atmosphericor biomarker from another with reasonable accuracy (Repace & Lowrey, 1993;Repace et al., 1998). For example, the estimated daily average population averageETS-RSP exposure during the mid 1980’s (U.S. smoking prevalence about 33%)according to Repace and Lowrey (1985) was Q = 1.43 milligrams of ETS-RSP,and at a respiration rate of 24 m3 per day, corresponds to a daily average ETS-RSPconcentration of R = 60 µg/m3. The equations in Table 1 below permit the corresponding mean nicotine and cotinine levels to be calculated: N = R/10 = 6 µg/m3. The corresponding estimated daily average population salivary cotininelevel is then S = (0.0071)(24)(6) = 1 ng/ml. The estimated daily average population serum cotinine level is then P = (1 ng/ml/ 1.16) = 0.88 ng/ml, and the estimated daily average population urinary cotinine level is given by U = (6.5)( 0.88 ng/ml) • 6 ng/ml. Repace and Lowrey (1980, 1985) estimated that most-exposed nonsmokers had exposures ten times average, yielding maximum exposedindividuals with the following: R = 600 µg/m3; N = 60 µg/m3; S = 10 ng/ml; OSHA Ventilation Workshop Analysis The only national probability sample of any ETS marker is that of serum cotinine, performed in the NHANES III study (Pirkle et al., 1996), with data taken
between 1988 and 1991 (U.S. smoking prevalence about 29%). NHANES III
reported that adults > 17 years who reported work exposure only > 3 hr/day had
geometric mean serum cotinine levels of 0.6 ng/ml, home exposure only was 0.7
ng/ml, both home and work exposure, 0.9 ng/ml. A bimodal distribution was
observed, with a separation between 10 to 15 ng/ml, the region between heavy
passive smoking and light active smoking. Despite the uncertainty introduced by
comparing geometric means to arithmetic means and the 12% lower smoking
prevalence (see CalEPA, 1997, fig. 2.6), the Table 1 model estimates are close to
NHANES III observations. The Table 1 model predictions can be compared to
data reported in the literature, with general agreement as shown in Table 2 below.
[Repace & Lowrey, RISK ANALYSIS, 13:463-475 (1993)]. [Repace,Jinot, Bayard, et al, RISK ANALYSIS, 18: 71-83 (1998)]. OSHA Ventilation Workshop Analysis Table 2. Comparison of model with reported measurements of ETS markers
Marker

Modeled Results
Observations
Reference
CalEPA (1997):
Nicotine
Saliva Cotinine
Serum Cotinine
Urine Cotinine
Analysis:
General dilution ventilation, [which I will characterize as “reasonably achievable control technology,” (RACT) on the basis of the panels’ statement thatit constitutes more than 99% of current HVAC installations], was judged to beinadequate by the panelists for ETS control. RACT, as applied to pollutionsources in outdoor air pollution control, is the lowest limit that a particular sourceis capable of meeting by the application of control technology that is reasonablyavailable considering technological and economic feasibility (EPA, 1983).
Displacement ventilation possibly coupled with ventilated ashtrays in someinstallations (but impractical for all), which I will describe as “best availablecontrol technology,” or BACT, was judged to be the best potential controlmeasure by the panelists. BACT, again as applied to pollution sources in outdoorair pollution control, refers to the maximum degree of air pollution reductionattainable by a source considering energy, environmental and economic impacts,through the application of available systems, methods and techniques (EPA,1983). In outdoor air pollution control, BACT does not permit the source topollute in excess of any requirements imposed by Section 112 of the Clean AirAct, which regulates hazardous air pollutants.
The panelists’ conclusions on ETS controls were reached on the basis of professional judgment, which they identified as being hindered by two majorproblems. The first problem identified by the panelists was the lack ofinformation on existing exposure levels, and the second one was the lack of OSHA Ventilation Workshop Analysis recognized standards of acceptable ETS exposure, so that even if displacementtechnology were to be universally adopted in the hospitality industry, and 90%exposure reductions could be routinely achieved in practice, there is no guaranteethat the residual exposure would yield an acceptable risk for hospitality workers.
A further problem which emerged in the discussion is that since some buildingcodes do not require operation of the HVAC systems, these codes would have tobe changed. Also, some establishments may have only natural ventilation.
Finally, even assuming that recognized standards limiting ETS exposure areadopted an enforcement apparatus would be required to ensure that the standardsare being met.
Outdoor air pollution regulation and control has long been guided by atmospheric models for plume dispersion (Turner, 1970). However, it has notgenerally been recognized that indoor air pollution, particularly from ETS, can bemodeled with far greater accuracy than stationary source outdoor air pollution(Wadden and Scheff, 1983; NRC, 1986; Repace, 1987; Ott, 1999). ETSconcentrations predicted by models agree well with measured values in realsettings, both on a minute-by-minute basis and for longer time averages, and themodels are especially useful for determining the ventilation required to meetsuggested indoor air quality standards (e.g., the National Ambient Air QualityStandard for fine particles (currently 15 µg/m3 annual ave. PM ) for given smoking activity levels (Ott, 1999). In particular, the panelists did not applyexisting models to estimate current exposure. Further, the U.S. EnvironmentalProtection Agency has declared ETS to be a human carcinogen, a conclusionendorsed by the National Cancer Institute (NCI, 1993) and the NationalToxicology Program (1999). Panelists also did not consider whether the residualexposure of workers to ETS after application of BACT would yield an acceptablerisk.
Comment: I will now employ published models of ETS exposure and risk
to the hospitality workplace to evaluate the current hazard for workers and patronswith dilution ventilation, and estimate the risk under both RACT and BACT. Iobserve that the panelist’s conclusions that RACT will not control ETS and thatBACT will achieve a putative 90% reduction in exposure are not supported bydata or by models. Accordingly, below I will apply models to estimate currentexposure, compare the model results with data for an accepted ETS atmosphericmarker, and employ a dose-response relationship to estimate worker risk underRACT and BACT, and compare the estimated risk with established federalregulatory risk criteria.
OSHA Ventilation Workshop Analysis Modeled ETS Exposure and Risk in Restaurants, Bars, Casinos .
Introduction
Repace et al.(1998), Repace and Lowrey (1993), Repace (1987), Repace and Lowrey (1985), and Repace (1984) developed models for ETS exposure, dose, andrisk which agree well with observations. It is important to note that these ETSmodels have gained widespread acceptance in the scientific community: The National Research Council (1986) observed that the most extensive use of the mass-balance equation for assessing ETS in occupied spaces was by Repaceand Lowrey (1980), and observed that the model “predicted ETS-Respirablesuspended particle (RSP) levels reasonably well over a wide range of values ofinput parameters.” The model was also favorably reviewed in the 1986 SurgeonGeneral’s Report on Involuntary Smoking. Ott et al. (1992) derived and validateda general equation for the mean concentration of ETS in an indoor space andconcluded that it was structurally equivalent to the model of Repace (1987). TheMonte Carlo model of Repace et al. (1998) for predicting ETS exposures wasfavorably reviewed by Spengler (1999).
Weiss (1986) commented “on the association between passive smoking and lung cancer and the biological and mathematical assumptions underlying Repaceand Lowrey’s (1985) assessment of risk.” Weiss concluded, in part: “Despite thesimplifying assumptions of the risk estimates and the flaws in the epidemiologicdata from which they are derived, Repace and Lowrey’s figures remain the bestcurrent estimates of lung cancer deaths from passive smoking.” Kawachi et al.
(1989) estimated the “relative risk for lung cancer death from exposure to passivesmoking in the workplace . via an exposure response relationship derived byRepace and Lowrey [1985; 1987].” Wigle et al. (1987) used the methods ofRepace & Lowrey (1985) to assess lung cancer risk in Canadians. Nagda et al.
(1989) assessed the lung cancer risks of passive smoking for flight attendants andpassengers on U.S. carriers in part using the risk assessment model of Repace andLowrey (1985). The U.S. EPA (NCI, 1993) described the risk assessmentapproach of Repace and Lowrey (1985) for lung cancer as “a novel approach thatcontributes to the variety of evidence for evaluation [of lung cancer risk] andprovides a new perspective on the topic.” Tancrede et al. (1987) used the riskassessment model of Repace (1984) to estimate a mean lifetime risk for lungcancer for U.S. nonsmokers from passive smoking of about 5 per thousand, with a98th percentile of 3.8%. Finally, Samet and Wang (2000) have observed that thecalculations made possible by the exposure, dose, and risk models of Repace et al.
(1998) for estimating worker risk of lung cancer illustrate that passive smoking OSHA Ventilation Workshop Analysis must be considered as an important cause of lung cancer death from a publichealth perspective, since exposure is involuntary and not subject to control.
Exposure Modeling
Ott (1999) in the OSHA-sponsored Workshop on Environmental Tobacco Smoke Exposure Assessment, observed that much progress has been made overfour decades in developing, testing, and evaluating the performance ofmathematical models for predicting pollutant concentrations from smoking inindoor settings. Ott (1999) further commented that although largely overlookedby the regulatory community, these models provide regulators and risk assessorswith practical tools for the quantitative estimation of ETS exposures. In the sameworkshop, Spengler (1999) observed that generally the highest ETS exposures areoccurring in bars, restaurants, and nightclubs, and using the techniques developedby Repace et al. (1998) reasonable estimates may be made of ETS exposures inoffices, restaurants and bars. Repace et al. (1998) have shown that ETS exposureis directly proportional to the smoker density D , (in units of habitual smokers per 100 m3), and inversely proportional to the air exchange rate φ (in units of air changes per hour: h-1), where a habitual smoker is assumed to smoke at thenational average rate of 2 cigarettes per hour, where the smoker density D = 100 n /V, and where n is the number of habitual smokers and V is the volume of the space in cubic meters. ASHRAE Standard 62-1989, Ventilation for AcceptableIndoor Air Quality (now supplanted by ASHRAE Standard 62-1999) specifiesdesign ventilation rates based on design occupancy, i.e., 10 L/s per designoccupant, and so many occupants per 100 m2 (100 m2 is ~1000 ft2) this becomes avolumetric measure when a ceiling height is assumed. Therefore, for a givensmoking prevalence, the design occupancy determines both the smoker densityand the air exchange rate.
Repace(1987) derived an equation for the calculation of ETS-RSP levels in units of micrograms per cubic meter (µg/m3) for a workplace as a function of thehabitual smoker density D (units HS/100m3) in the building and the building’s air where φ (fi-vee) is the air exchange rate due to dilution ventilation. The equation incorporates a 20% removal rate for ETS-RSP deposition on surfaces, andassumes an emission rate of 14 mg of ETS-RSP per cigarette and a smoking rateof 2 cigarettes per smoker per hour. If there is additional air cleaning, φ would be OSHA Ventilation Workshop Analysis increased by the air exchange rate due to the air cleaning. ETS nicotine levelsmay be estimated by dividing Equation 1 by ten (Repace et al., 1993, 1998).
ASHRAE Standard 62-1999 (values were the same for the predecessor Standard 62-1989) specifies the following occupancies, in persons per 100 m2 offloor area (Table 3) for the given hospitality venues: If a smoking prevalence of25% is assumed, then the number of expected smokers and the smoker density (inunits of habitual smokers per 100 m3) may be estimated, assuming a 4 meterceiling height multiplied by the unit space area for the number of occupants. Theproduct of smoking prevalence and occupancy (number of persons per 100 m2)yields the estimated number of smokers. The corresponding air exchange rate forpollutant removal, in units of air changes per hour (ACH) may be calculated, asfollows.
Table 3. Smoker density and Air Exchange Rate (dilution ventilation) at full
occupancy for various hospitality venues for a ceiling height of 4 m under ASHRAE
Standard 62-1999 per 100 m2 of floor area, and a smoking prevalence of 25%. (US
smoking prevalence in 1993 = 24%.)
Hospitality
The air exchange rate ACH = (Occupancy, Persons)(Vent Rate Lps/P)(1m3/1000L)(3600 s/hr) / (space volume, m3). For example, for a Dining Room, anoccupancy Occ = 70 persons per 100 m2 of floor area, or per 400 m3 of spacevolume, assuming a 4 m ceiling. For a smoking prevalence of 25%, the number ofhabitual smokers n = (0.25)(70) = 18, the habitual smoker density D = (.25)(70)/(400) = 4.5 smokers per 100 m3. The air exchange rate is φ = (70 occ x 10 Lps/occ x 1 m3/1000 L)(3600 s/h) / (400 m3) = 6.25 h-1. [Because there is noenforcement of operational ventilation rates, there is an economic incentive forbuilding owners to supply less.] OSHA Ventilation Workshop Analysis Table 4. Estimated RSP and Nicotine Concentrations Based on Equations 1
& 2, for cigarette smoking.
Hospitality
The RSP and nicotine concentrations, estimated in Table 4 for the RACT case ofdilution ventilation are liberal in that they assume full occupancy, but areconservative in other respects: (a) since nonsmokers are known to avoid smokyrestaurants and bars (Biener et al., 1999), the number of smokers will likely begreater than their prevalence in the population; (b) the air exchange rates are likelyto be less than design because to provide design rates of ventilation costs money,and there is no enforcement of operational rates; (c) in bars, nightclubs, andcasinos, smoking is likely to be more intensive than the national average of 2cigarettes per hour (chain smokers smoke up to 6 cigarettes per hour); (d) cigarsmake more pollution than cigarettes (Repace et al., 1998); (e) if smokers arerestricted to designated areas, hospitality workers will work in environmentswhere almost everyone is a smoker, increasing the number of smokers by as muchas a factor of 4. For restaurants, cutting back on ventilation might mean airexchange rates closer to 1 air change per hour rather than 6. Nevertheless, Table 4levels can be compared with the range of observations reported by EPA (1992):for restaurants average RSP values (ch. 3, fig. 3-8) ranged from 40 to 1000 µg/m3,and nicotine in restaurants (not necessarily in the same ones) from 6 to 18 µg/m3,consistent with the predictions in Table 4, and the caveats in this paragraph.
In table 4, for habitual smoker densities D ranging from 4.5 to 6.25 habitual smokers per hundred cubic meters, the estimated nicotine levels rangefrom 10 to 20 µg/m3. By comparison, Lockhart (1995) has expressed the nicotineconcentration in pubs as a function of active smoker density (the active smoker OSHA Ventilation Workshop Analysis density D is the average number of burning cigarettes per hundred cubic meters (D = 1/3 D ) was measured in Canada in 1995. Figure 1 below shows measured levels in ten Vancouver British Columbia (BC) restaurants and pubs with smokingand nonsmoking sections in 1995 (Lockhart, 1995). The smoking prevalence inBC is 23% (Gallup, 1996). It is seen that nicotine levels ranged as high as 40µg/m3 in the smoking sections and as high as 30 µg/m3 in the nonsmokingsections, and that the differences between the smoking and nonsmoking sectionswere slight, due to “well-mixed” dilution ventilation. This corresponds toestimated RSP levels above background of 300 to 400 µg/m3, comparable to thelevels measured by Repace and Lowrey (1980). Thus the values predicted in table4 correspond to active smoker densities of from 1.5 to 2.0 active smokers perhundred cubic meters, and to measured nicotine concentrations (interpolatingbetween the smoking and nonsmoking section curves) ranging from about 15 to 30µg/m3, higher than predictions.
Presumably, these restaurants and pubs should have been ventilated according to ASHRAE Standard 62, which (for both the 1989 and 1999 versions)specifies 15 Lps per occupant for pubs and 10 Lps per occupant for restaurantdining rooms. As shown above, this corresponds to design air exchange rates ofthe order of 15 hr-1, and should have resulted in nicotine concentrations of theorder of 10 µg/m3 (an active smoker density of 2 burning cigarettes per 100 m3corresponds to a habitual smoker density of 6 habitual smokers per 100 m3). Thatlevels as much as 50% higher than predicted were observed suggests that eitherthe actual ventilation rates were lower than the level mandated by the ASHRAEStandard, or that the smoking rates were higher, or some combination of the two.
In either case, this suggests that the estimates in Table 4 are conservative.
Although panelists were sanguine about the prospects of displacement ventilation, I emphasize that no data was presented to support its efficacy on ETS.
Its usual application is a one-pass system with 100% outside air introduced into adesignated nonsmoking section, with positive air flow directed through an openpassageway into a negatively-pressurized smoking section.
OSHA Ventilation Workshop Analysis ETS, SMOKING VS. NONSMOKING SECTIONS
ne Concentrati
Active Smokers per 100 m 3
Figure 1. Nicotine levels measured in 10 Vancouver, British Columbia Pubs for the Heart
and Stroke Foundation of BC and Yukon (Lockhart, 1995). The active smoker density Ds
(the average instantaneous density of burning cigarettes) is 1/3 of the habitual smoker
density D of the habitual smoker model of Repace (1987).

Regulatory Risk Levels
Involuntarily imposed worker risks from ETS can be compared to societal standards for permissible human exposures to environmental carcinogens such asindustrial chemical emissions and radionuclides in air and water, andcarcinogenic molds and pesticide residues in food. Several U.S. federal regulatoryagencies promulgate regulations and standards to protect the public from exposureto environmental carcinogens. It is of interest to inquire as to what levels ofpopulation cancer risk typically trigger regulation, what levels are beneathregulatory concern, and how consistently are they applied among various federalagencies. Travis et al.(1990) reviewed the use of cancer risk estimates inprevailing U.S. federal standards and in withdrawn regulatory initiatives, todetermine the relationship between risk level and regulatory action in 132 U.S.
federal regulatory decisions of record concerning lifetime risk of mortality.
Travis et al. describe two technical risk assessment terms: de manifestis risk and de minimis risk. A de manifestis risk is literally "a risk of obvious or evident OSHA Ventilation Workshop Analysis 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 manifestis 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 falling in between these extremes were
regulated in some cases but not in others; however, residual risks after control
are generally de minimis
. Travis et al. found when the population at risk was
large, as with ETS, de manifestis risk corresponded to a lifetime risk of mortality
of 3 per ten thousand (3 x 10-4), and de minimis risk was one per million (1 x 10-6). The U.S. Occupational Safety and Health Administration has defined aworking lifetime (45 yr.) risk level of 1 death per 1000 workers at risk ascorresponding to a “significant risk of material impairment of health” (U.S. DOL,1994).
Risk Modeling, Dilution Ventilation (RACT-Case)
ETS risks are estimated based on the ETS-RSP levels from Table 4, using the exposure-response models of Repace and Lowrey (1985b), Repace andLowrey (1993) and Repace et al. (1998). Under these models, a time-weighted 8-hr average exposure for 260 days/yr over a 40 year working lifetime to an ETS-RSP level of 75 µg/m3 corresponds to a working lifetime risk of 1 per 1000 forlung cancer mortality, and 1 per 100 for heart disease mortality. These exposureand risk assessment models may be used to assess the fatal lung cancer and heartdisease risk to hospitality workers from ETS exposure at work. This modeling issummarized in Table 5 for five hospitality venues. Under dilution ventilation andoccupancy as specified by ASHRAE Standard 62-1999, and with a typical U.S.
average smoking prevalence, the combined estimated lung cancer and heartdisease mortality risks to hospitality workers range from 15 to 30 per 1000,exceeding all applicable environmental and occupational regulatory levels. A riskof 20 per 1000 is twenty thousand times the de minimis risk level. The riskscalculated in Table 5 are likely to be underestimated relative to real-worldsituations, because of two factors: first, since there is no enforcement ofoperational ventilation rates, and since it costs money to treat outdoor air which iscold or hot and humid, operational rates will be less than design -- it is a simplematter of turning a dial to close down outside air dampers. Second, smokyrestaurants, bars, and casinos are likely to have far less nonsmokers and far moresmokers than national prevalence figures suggest, because nonsmokers are knownto avoid such establishments (Biener et al., 1999); in fact during 1995, based ondata provided by Biener et al., the number of Massachusetts nonsmokers who saidthey avoided smoky restaurants and bars was 80,000 more the total number ofMassachusetts smokers.
OSHA Ventilation Workshop Analysis Table 5. Estimated ETS-RSP concentration and associatedc lung cancer, heart
disease and combined risk for hospitality industry workers using dilution ventilation,
assuming a smoking prevalence of 25%, (approx. the U.S. average), and compliance
with the ASHRAE Standard 62 1999.

Smoking Area
Estimated
Est. Excess
Est. Excess
Est. Total
Lung Cancer
Heart Disease
(PM ), µg/m3
Mortality per
Mortality per
Mortality per
1000 workers
1000 workers
1000 workers
Risk Level
†: assumes workers serve in lounge; a: lung cancer death; b: heart disease death . c: assumes worker exposure for 8 hours per day, 260 days/yr; 40 yr Working Lifetime (WLT)(NB: Since OSHA assumes a 45-year WLT Sig. Risk occurs at a slightly lower concentrationthan shown (40/45)(75) or 67 µg/m3 for lung cancer and 6.7 µg/m3 for heart disease.
Based on Table 5, assuming regular patrons have an exposure duration of about 10% of the workers, or 4 hrs per week, the combined lung cancer and heartdisease mortality risks to the patrons also exceeds all environmental andoccupational regulatory risk levels.
Such increases in RSP levels (over a typical non-ETS background of ~20 µg/m3) would also be expected to result in the denial of access to the workplaceand public places of accommodation for both workers and patrons who areasthmatics or who suffer from other cardio-respiratory diseases. Dockery andPope (1994) found that total daily mortality associated with particulate airpollution shows an approximately 1% increase per 10 µg/m3 daily increase inparticulate matter below 10 microns in aerodynamic diameter (PM ). They also found that particulate air pollution is even more strongly associated withcardiovascular mortality, with a dose-response showing a 1.4% increase per 10 OSHA Ventilation Workshop Analysis µg/m3 increase in PM . The U.S. National Ambient Air Quality Standard (NAAQS) for PM protects against health effects such as premature death, increased hospital admissions and emergency room visits (primarily the elderlyand individuals with cardiopulmonary disease); increased respiratory symptomsand disease (children and individuals with cardiopulmonary disease such asasthma); decreased lung function (particularly in children and individuals withasthma); and against alterations in lung tissue and structure and in respiratory tractdefense mechanisms. The level of 15 µg/m3 of the annual standard is an annualaverage which defines clean air. The supplemental 24-hr standard of 65 µg/m3 isintended to prevent short-term peaks from impacting public health (Fed. Reg.,1997).
In fact, Eisner et al.(1998) studied the association between ETS exposure and respiratory symptoms in a cohort of 53 bartenders before and afterCalifornia’s prohibition on smoking in all bars and taverns in 1998. 74% of thebartenders initially reported respiratory symptoms; of those symptomatic atbaseline, 59% no longer had symptoms at follow-up. 77% initially reportedsensory irritation symptoms; at follow-up, 78% of these had symptom resolution.
After ETS exposure completely ceased, objective measures of pulmonary functionshowed a marked 5% to 7% improvement after only one month of smoke-free air.
Eisner et al. (1998) concluded that establishment of smoke-free bars and tavernswas associated with improvement of respiratory health.
As discussed above, Spengler (1999) has observed that ETS exposures in restaurants can be modeled using the techniques of Repace et al. (1998). Sametand Wang (2000) have observed that the risk models of Repace et al. (1998) areuseful for estimating worker risk. Figure 2 combines these models to estimateETS risk as a function of ventilation rate in a restaurant at a smoking prevalence of29%, equivalent to 2 smokers per 1000 ft2 or per ~100 m2 of floor area. It is seenthat for RACT, or ordinary dilution ventilation to reduce the ETS risk to restaurantworkers to de minimis levels would require ventilation rates in excess of 100,000Lps/occ, levels which are impractical by more than 4 orders of magnitude (10,000-fold). At a smoking prevalence of 25%, as used above, ETS risks are reduced onlyslightly compared to the risks shown in Fig. 2. If one assumes that BACT, ordisplacement ventilation, can reduce ETS risks to 1/10, equivalent to a ten-foldincrease in ventilation efficiency, the risks still remain unacceptable by threeorders of magnitude (1,000-fold). This is discussed in further detail below.
OSHA Ventilation Workshop Analysis ETS RISK AND VENTILATION: RESTAURANT WORKERS
29% Smoking Prevalence; 70 Persons per 100 m HEART DISEASE
LUNG CANCER
VENTILATION RATE (Liters per second per occupant)
Figure 2. Estimated excess risks of lung cancer and heart disease for hospitality workers
for a smoking prevalence of 29%, a restaurant occupancy of 70 persons per 100 m2, as a
function of ventilation rate supplied per occupant. The ASHRAE Standard
recommendation of 10 Lps/occ (20 cfm/occ) is shown (Risks are estimated based on the
models of Repace and Lowrey, 1985; 1993; Repace et al., 1998). Risks to workers in bars
and casinos would likely be greater, due to higher actual smoker prevalence and closer
proximity of bartenders and casino dealers to smoking. Note that ASHRAE Standard 62-
1999 has identical occupancy and ventilation requirements.

Siegel(1993), in a review of the literature, found that restaurant waitresses had a 50% to 100% higher risk of lung cancer compared to the general population.
EPA(1992, p. 187) estimated that the annual risk of lung cancer for U.S.
nonsmoking women from the general population from all causes was 15 per100,000, corresponding to a 70 year lifetime risk of 10 per 1000, with 1/3 of thatrisk from passive smoking, for an estimated lifetime risk from passive smoking atabout 3 per 1000 above a non-ETS background of 7 per 1000. By comparison, theestimated excess ETS risk for lung cancer for restaurant workers in Figure 2 frompassive smoking in a restaurant workplace in compliance with the ASHRAEStandard is about 3 per 1000, which when added to the general populationbackground, would constitute a 100% increase. Thus, the estimated lung cancerrisk from Figure 2 is in good agreement with the results of EPA and Siegel.
OSHA Ventilation Workshop Analysis Risk Modeling, Displacement Ventilation (BACT)
As discussed above, the OSHA Ventilation Workshop Panelists concluded that displacement ventilation had the potential to achieve 90% reductions in ETSconcentrations, although no data on real hospitality facilities taken for actualworkers was presented to support this contention. Nevertheless, for the purposesof this analysis, I will presume that this can be accomplished, and that thetechnology will work as designed and be properly operated and maintained over aworking lifetime. Using dilution ventilation, the hospitality venues of Table 4using perfectly designed and properly operated HVAC systems would have totalworking lifetime risks for workers of from 15 to 30 per 1000. I will assume that90% reductions on this ideal level (and not the realistic levels shown in Figure 1)can be achieved using displacement technology or BACT. This would yieldestimated combined lifetime risks for workers of from 1.5 to 3 per 1000, whichstill exceed all environmental and occupational regulatory levels. A risk of 2 per1000 is two thousand times the de minimis risk level. There is a third concept inoutdoor air pollution control known as LAER, or lowest achievable emissionsreductions (USEPA, 1983). This is the most stringent level of reduction which iscontained by any source or category of sources. BACT clearly will not achieveLAER. This level of reduction, however, is easily achieved by smoking bans suchas in the State of California. Smoking bans reduce the risk from ETS exposure tozero.
Airborne carcinogens, are not regulated using RACT or BACT. They fall under Section 112 of the Clean Air Act, which governs hazardous air pollutants(HAPS), i.e., pollutants which “may reasonably be anticipated to result in anincrease in mortality or an increase in serious irreversible, or incapacitatingirreversible, illness” (CAA, 1977). Hazardous air pollutants are regulated under aNational Emission Standard for Hazardous Air Pollutants, or NESHAPS. HAPSare regulated after a risk assessment. Severe emissions limitations are imposedHAP sources. The emissions limitations are designed to reduce the aggregate orpopulation risk to de minimis levels. This is accomplished by estimating dose-response relationships, estimating population exposure, and requiring reduction ofthe source emissions to limit the downwind concentration to de minimis risklevels. This means less than 1 estimated death per lifetime for the population atrisk, irrespective of the costs of containment, since Section 112 is exempt fromeconomics tests.
Table 6 below shows the risks before control for various hazardous air pollutants regulated by the US EPA, compared with ETS. In the case of arsenic,the only copper smelter in the U.S. to emit arsenic (an impurity in the ore) closeddown because it could not meet the NESHAPS requirement economically. Note OSHA Ventilation Workshop Analysis that with the exception of asbestos, all the remaining HAPS pollutants are
themselves also constituents of ETS (Repace and Lowrey, 1985; 1990). Risk
assessments have been performed for ETS by the U.S. EPA (1992), by Repace and
Lowrey (1985), and by others (Repace and Lowrey, 1990) and average 5000 +
2500 LCDs/year. Unlike the other ETS risk assessments which have been
performed, Repace and Lowrey (1985) derived a dose-response relationship.
Clearly, based on the number of deaths, ETS falls in the category of a hazardous
air pollutant. Note that NESHAPS requirements override both BACT and RACT.
If regulated under a NESHAPS, ETS deaths would have to be less than 1 death per
year, nationally. NESHAPS are also set such that risks to the most-exposed
individual are controlled to acceptable levels. Note that unlike ETS, which is a
best-estimate risk, the remaining pollutants are generally estimates at the 95%
upper confidence interval of a maximum likelihood estimate.
:
Table 6. U.S. EPA-Estimated mortality for Hazardous Outdoor Air Pollutants Regulated
under the Clean Air Act compared to those estimated for ETS (US EPA, 1992; Repace and
Lowrey, 1990), which is not federally regulated.
Hazardous Air Pollutant

Estimated Annual Cancer Mortality
*Regulated under Section 112 of the Clean Air Act ETS itself contains 5 HAPs, vinyl chloride, radionuclides (e.g. Po210), coke-ovenlike chemicals (e.g. polycyclic aromatic hydrocarbons), benzene, and arsenic.
Cigarettes have been manufactured with asbestos filters. In addition, 47 chemicalsin ETS have been classified as “hazardous waste” under RCRA (Appendix C).
However, alone among well-known toxic and carcinogenic chemicals, ETS is notsubject to a NESHAPS, OSHA TLV, or air quality standard. In addition,Congress has exempted regulation of tobacco products under TSCA. AlthoughEPA classified ETS as a “known human carcinogen” in 1992, EPA has noauthority to set indoor air quality standards, is explicitly forbidden by Congressfrom regulating indoor air quality, and EPA’s ETS research program wasabandoned in 1990. While OSHA proposed (1994) to regulate ETS in workplaces,work on its proposed rule ceased in 1995. In the absence of any official safe levelfor ETS, it is foolish to make -- or accept -- vague claims that ventilation can OSHA Ventilation Workshop Analysis control ETS. The only prudent approach is a smoking ban. Smoking bans willachieve de minimis risk without any engineering controls.
Although smoking bans have been widely opposed by the hospitality industry,their opposition been founded in a misguided belief in business losses that havefailed to materialize in any part of the U.S. Although many in the hospitalityindustry worry about loss of smoking customers, few seem to realize they havealready lost a substantial amount of nonsmoking trade. It might be expected thatsince many nonsmokers avoid smoky places (Biener et al., 1999; Glantz, 1999),and since adult nonsmokers outnumber adult smokers by more than 3:1 nationally,that there would be no economic penalties. In fact, as Figure 3 shows, smokingbans have had no discernible adverse economic impact in California.
California Restaurant and Bar Sales
Before and After Smoke-free Laws
First Quarter Taxable Sales Figures for Restaurants & Bars, State of California ’92-’99 Source: California Dept. of Health; California Board of Equalization Food - No Alcohol
Food &/or All Alcohol
Food &/or Beer\Wine
Smoke-Free
Smoke-Free
Restaurants
SALES IN BILLIONS OF DOLLARS
Figure 3. Data from California food and beverage industry tax receipts shows no economic
impact from smoke-free restaurant or bar ordinances.

OSHA Ventilation Workshop Analysis Conclusions on ETS Risks under RACT and BACT
The best that current dilution engineering technology (RACT) can provide is estimated worker risks of the order of 20 thousand times the de minimis level.
Similarly, the best that future displacement engineering technology (BACT) canprovide is estimated worker risks of the order of 2 thousand times the de minimislevel. Smoking bans (LAER) provide risks thousands of times lower (actuallyzero) at no discernible cost to the industry as a whole, while providing obvioussignificant public and worker health benefits.
The Tobacco Industry and Ventilation
Background. In 1973, ASHRAE Standard 62-73 Section 6.2, specified from 30
cubic feet per minute per occupant (cfm/occ) (15 Lps/occ) to 50 cfm/occ of
outdoor makeup ventilation air for bars and cocktail lounges and 10 to 20 cfm/occ
for restaurant dining rooms. In 1981, ASHRAE Standard 62-1981, in order to
save energy, specified different ventilation rates for smoking and nonsmoking in
Section 6, Table 3: smoking restaurants 35 cfm/occ, nonsmoking 7 cfm/occ.
Smoking bars and cocktail lounges, 50 cfm/occ, nonsmoking 10 cfm/occ. These
rates were recommended by a committee of ventilation engineers from industry in
a consensus process. ASHRAE 62-1981 also added a new “indoor air quality
procedure” which would bring contaminants to some specified acceptable levels
(similar to the procedure I have employed above in Figure 2). It further
recommended that “best available control technology be employed for toxic
indoor contaminants such as asbestos, radon, and formaldehyde, but stated that for
other contaminants such as tobacco smoke, precise quantitative treatment can be
difficult.”
The tobacco industry’s response to these new two-tiered rates, which imposed a penalty on smoking establishments, was to disrupt the committee’sfunctioning using parliamentary maneuvers (Repace, 1991) and ultimately tothreaten ASHRAE with litigation. The net result, incorporated into ASHRAEStandard 1989, was abolition of the differential rates for smoking and nonsmokingestablishments. The new rates for restaurants were a blanket 20 cfm/occindependent of smoking status, and for bars, 30 cfm/occ. However, in a furthercapitulation to the tobacco industry, a footnote to the standard stated: “Table 2prescribes rates of . outdoor air required for acceptable indoor air quality. Thesevalues have been chosen to control CO and other contaminants with an adequate margin of safety and to account for health variations among people, varied activitylevels, and a moderate amount of smoking.” In the foreword to the Standard, thefollowing opaque disclaimer appeared: “. with respect to tobacco smoke and OSHA Ventilation Workshop Analysis other contaminants, this standard does not, and cannot ensure the avoidance of allpossible adverse health effects, but it reflects recognized consensus criteria andguidance.” The tobacco industry widely touted ASHRAE 62-1989 in support of its contention that tobacco smoke could be controlled by ventilation, and thatsmoking bans were not needed. Confidential “draft” tobacco industry strategydocuments from a Settlement Agreement Website observed that because ETS wasperceived to be a health risk and annoyance, and smoking bans were proliferating.
The ASHRAE Standard 62-1989 revision was identified as a major issue: “Theproposed revised standard . would preclude any building where ETS is presentfrom being classified as having acceptable indoor air quality. For new buildingsdesigned to adhere to this standard the result could be the same de factoprohibition of smoking contemplated by the OSHA [Indoor Air Quality]proposal.” The strategy document’s listed Goal: “Perpetuate the substance ofStandard 62-1989, which provides for smoking, as the accepted standard andamend the terms of the revision to accommodate smoking.” Litigation optionswere among the actions considered to further this goal. The hospitality industrywas singled out as a major target for “accommodation,” with hotels, restaurants,pubs and taverns specifically mentioned. [pmdocs.com, Worldwide Strategy andPlan, pp 2-4, Bates # 2060577486, -87, -88; -502, -522], see appendix D below.
However, despite numerous attempts at amending the standard and several appeals to both ASHRAE and ANSI, the industry failed. After a decade, a newversion of the standard was issued which reflected the general medical/scientificconsensus on ETS: ASHRAE Standard 62-1999 contained an addendum 62e,which repealed the statement that the ventilation rates in Table 2 “accommodate amoderate amount of smoking.” The Foreword to Standard 62-1999 noted: “Sincethe last publication of this standard in 1989, numerous cognizant authorities havedetermined that environmental tobacco smoke is harmful to human health. [A listof authorities was given, including the US EPA, WHO, AMA, ALA, NIOSH,NAS, OSHA, and the Surgeon General.] This addendum does not prohibitsmoking or any other activity in buildings, but rather removes the statement thatthe recommended ventilation rates are intended to accommodate a moderateamount of smoking.” The indoor air quality procedure continued to be listed as analternative performance method to the Ventilation rates prescribed in Table 2.
Current Tobacco Industry Statements on ETS, Ventilation, and the
Hospitality Industry

The major tobacco companies, Philip Morris (PM), RJ Reynolds (RJR), and British American Tobacco (BAT) [BAT’s U.S. subsidiary is Brown & OSHA Ventilation Workshop Analysis Williamson] maintain corporate websites {PhilipMorris.com; RJReynolds.com;BAT.com} which discuss inter alia, ETS health and ventilation issues, and thehospitality industry. The relevant documents are given in Appendix D below.
Philip Morris (PM), the largest U.S. tobacco company, maintains the most extensive ETS information (see website headings titled: Secondhand Smoke;Options Program; Accommodation; Ventilation: PM states that while itrecognizes that ETS can be annoying to nonsmokers, there are options to“minimize” ETS, and a “sizable segment of the population continues to support‘accommodation’ of smoking. PM has an “Accommodation Program” whichtargets business owners in the hospitality industry by offering access toinformation on the latest ventilation technology. Ventilation, says PM, plays animportant role in accommodation. However, PM asserts that “owners ofrestaurants, bars, casinos and other hospitality venues should be permitted tochoose what kind of smoking polices to adopt for their establishments.
“Designated areas, separate rooms, smoking lounges, and sometimes, noseparation at all, are ways that business owners choose to accommodate the‘preferences’ of nonsmokers and smokers,” says PM. PM cites the Courtesy ofChoice program sponsored by the International Hotel and Restaurant Association.
The program is supported by local hospitality associations, Philip MorrisInternational, and other tobacco sponsors in some 47 countries and is available inalmost 8000 individual hospitality outlets.” PM acknowledges that “manyscientists and regulators have concluded that ETS poses a health risk tononsmokers, but that “we do not agree with many of their conclusions.” PhilipMorris states that “So long as unwanted exposure is minimized, . concernsregarding ETS can be addressed without banning smoking.” (Appendix D).
RJ Reynolds states on its website under “Secondhand Smoke,” that although “many people find secondhand smoke annoying, and that some . believe itpresents a risk to their health . There are many ways to allow smokers andnonsmokers to ‘peacefully coexist’ in public places without resorting to smokingbans: Common courtesy . -- coupled with adequate ventilation and filtration, anddesignated smoking areas . .” RJR also “does not believe that the scientificevidence concerning secondhand smoke establishes it as a risk factor for lungcancer, heart disease, or any other disease in adult nonsmokers.” “. businessowners know best how to satisfy their customers, and they should be allowed todecide whether they want to allow, restrict or ban smoking in theirestablishments.” (Appendix D).
BAT also recognizes {website headings Environmental tobacco smoke; ETS -- accommodating both smokers and non-smokers] that ETS “is a significant OSHA Ventilation Workshop Analysis annoyance” and that “there have been claims that ETS is a cause of disease . “however . we do not believe that exposure to ETS is a risk factor for chronicdisease in adults.” “We support sensible accommodation of . smokers andnonsmokers . through good ventilation.” “We also support the Courtesy ofChoice campaign run by the International Hotel and Restaurant Association. Itaims to help the hospitality industry to accommodate all its customers inrestaurants, convention centres, cafes, bars, clubs and hotels, and involvestechnical analysis of ventilation and owners allocating flexible smoking and non-smoking areas.” “. we do not believe that public smoking bans are needed toprotect nonsmokers from diseases linked with smoking.” (Appendix D).
Summary: Thus, the big three tobacco companies state that they all
believe that ETS is just an annoyance -- not a serious health threat, despite allthose authoritative government reports to the contrary -- and that ventilation whichminimizes smoke is the cure, not smoking bans, especially in the hospitalityindustry. In other words, the tobacco industry is saying that the hospitalityindustry should make the final decision on ETS controls: using RACT, BACT, ordoing nothing. No mention is made of enforcement, or of acceptable levels ofexposure or risk.
OSHA Ventilation Workshop Analysis Discussion:
Mainstream medical and scientific opinion has reached a consensus that passive smoking causes lung cancer and heart disease, as well asmany other serious health effects. In addition, it is a major annoyance due to eye,nose, and throat irritation. Although every major medical and scientific group inthe U.S. is in unanimous agreement that ETS is hazardous, the tobacco industryrefuses to accept this consensus. Instead, the industry promotes “accommodation”of smokers, particularly in the hospitality industry. Accommodation involvesusing ventilation as a control measure, which leaves workers and nonsmokingpatrons exposed to ETS. This promotion of ventilation as a “solution” to passivesmoking has several flaws. Ventilation is not tied to risk. Instead, the industryconfines itself to stating that “exposures are low.” As proof, the industry cites theOak Ridge Study (Jenkins and Counts, 1999), which it funded under contract(Glantz et al., 1996). However this study is not representative (Hammond, 1999).
Public health authorities cannot accept on faith that the risks will be trivial or non-existent, and promote ventilation to provide comfort for building occupantsexposed to ETS. However, even if a limited goal of “comfort” is examined, asSpengler (1999) has observed, the goal of ASHRAE Standard 62-1989 --providing air of quality that satisfies the comfort of 80% of occupants cannot bemet at the current specifications of the standard. In fact ASHRAE Standard 61-1999’s Addendum 62-e repeals that goal due to the carcinogenicity of ETS.
Indoor air quality standards for ETS have been proposed by Repace and Lowrey (1985b) based on ETS-RSP and Repace and Lowrey (1993) for nicotineand plasma (serum) and urinary cotinine, and extended to saliva cotinine byRepace et al. (1998). These standards are premised on an exposure-responserelationship with the numerator based on lung cancer rate differences between twoCalifornia cohorts of lifelong nonsmokers-- one presumed to be unexposed to ETS(California Seventh Day Adventists) and the other exposed to ETS (Non-SDAsfrom the general California population). The denominator of the exposure-response relationship underlying the standard was based on assessing the averagepopulation exposure to ETS-RSP (Repace and Lowrey, 1985). Later, ETS-RSPwas translated into airborne nicotine and body fluid cotinine equivalents using theequations in Table 1. Estimates of average population exposure to ETS-RSP werevalidated by predicting serum cotinine levels in good agreement with a nationalprobability sample measured in NHANES III. These atmospheric and body fluidcotinine measures were traced back to the primary determinants of ETS exposure:smoker density and air exchange rate; air exchange rates were those based onASHRAE Standard 62 (Repace et al., 1998). And the risk model was extended toheart disease mortality (Repace et al., 1998). As Figure 2 shows, contrary to thetobacco industry’s vague claims about the efficacy of ventilation, risks cannot becontrolled to an acceptable level for both workers and regular restaurant patronsusing even the best possible displacement ventilation technology.
OSHA Ventilation Workshop Analysis Even if a way could be found by some as-yet undiscovered ventilation or air cleaning technology to reduce ETS exposures by 4 orders of magnitude, aregulatory bureaucracy would be required to issue permits for the new technology,which would have to be retrofitted into all existing establishments, and designedinto all new establishments. Then an enforcement squad would have to beassembled, trained, and fielded to handle complaints. Measuring either ETSconcentrations or ventilation rates is difficult, time-consuming, and expensive.
Although ETS-RSP can be measured in real-time, RSP is non-specific for ETS.
While ETS nicotine is specific, it cannot be measured in real-time. Ventilationrates also cannot be measured in real-time. Since most ventilation engineers arefamiliar only with dilution technology, they would have to be trained to install thenew technology, and building inspectors would have to be retrained to approvethose plans. Because there are tens of thousands of establishments in a State thesize of California, this would rapidly become an enforcement nightmare.
However, smoking bans will achieve zero risk, and currently appear to be easilyenforceable.
A final problem concerns new and emerging ETS risks which have not been quantified and for which no dose-response relationships exist. Other studies havelinked ETS to mortality from SIDS, and nasal sinus cancer, and possibly cervicalcancer and respiratory disease (CalEPA, 1997). New studies have linked ETS tobreast cancer, and stroke. The risk of ETS-induced breast cancer appears to behighly non-linear, as shown in Figure 4, suggesting that developing an ETS-IAQstandard for breast cancer would be problematic. Another largely unrecognizedissue is that ETS particles are re-emitted again from room surfaces where theyhave been deposited, indicating that room surfaces act as secondary sources ofETS particles (Johannson et al., 1993). Gases are also likely to be absorbed onand re-emitted from surfaces. This means that buildings where smoking ispermitted become highly contaminated with toxic waste from ETS, massivesurface sources of PAHs and other carcinogenic and toxic substances to whichnonsmokers can be exposed even when there is no smoking taking place. Toappreciate the magnitude of the problem, consider a restaurant with an occupancyof 70 persons per 1000 ft2, with a smoker prevalence of 29%, for an area smokeroccupancy of 2 smokers per 1000 ft2. Each smoker smokes 2 cigarettes per hour.
Assuming smoking occurs in the restaurant for 8 hours daily, and that eachcigarette liberates 14 mg of tar, 20% of which deposits on room surfaces. Thus(2.8 mg/cigarette) (2 smokers/1000ft2)(2 cigarettes/smoker-hour)(8 hours/day)(300days/year) = 27 grams per year of tobacco tar deposited on room surfaces --including the HVAC system -- per 1000 ft2 of floor area. For a 10,000 ft2restaurant, this is 270 g/year or ~ 1 kg of toxic waste every 4 years.

Source: http://passivrauchen.mibet.de/FedOHSHAets.pdf

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