rubentito/OCR-IDL huggingface dataset:
C. Smoking Bans Do Not Effectively Address Indoor Air Quality Problems The Guide creates the false impression that smoking bans will eliminate a wide variety of potentially toxic compounds from indoor air when, in fact, ETS is only one aspect of indoor air quality. Many pollutants other than ETS, e.g., asbestos, formaldehyde, ozone, volatile organic compounds, cotton fibers, fungi, bacteria, and dust mite excreta, have a significant impact on indoor air quality [Molina, 1989; Robertson, 1990]. Virtually everything used in the interior of a building, including building materials, furnishings, equipment and supplies, is a source of airborne particles and/or gases [Kirk, 1988; Robertson, 1990; Wanner, 1984]. Some particles and gases are released quickly, while others are released at a slow rate for years. Office supplies and equipment, especially generators, duplicators, copiers and ovens have been found to release potentially hazardous chemicals. Formaldehyde is released from bulk paper supplies. The human body is also a major contributor to indoor air pollution. Each person sheds literally millions of particles, primarily skin scales, per minute. Many of these scales carry microbes; the bulk of which are short-lived and harmless. Some persist, however, and contribute to the particulate burden in an indoor environment. As stated by Kirk: There are many sources of indoor air pollutants (both gaseous and particulate) including the use of gas stoves and fires, coal, coke and wood fires, house plants, cooking, cleaning, painting, and the adoption of a variety of household and office products including cleaning agents, glues, correction fluids, plastics, and varnishes. In addition, the simple act of movement resuspends particulate matter whilst building materials and furnishings, especially when new, may release a variety of organic materials into the indoor atmosphere. Release of formaldehyde from cavity wall insulation, furniture and fabrics are all examples of such indoor air pollutants and are of considerable public concern [Kirk, 1988, p. 99]. 41
Although cleaning processes such as sweeping, vacuming, and dusting normally remove the larger particles, they often increase the airborne concentrations of the smaller particles [Robertson, 1990]. Low relative humidity causes complaints similar to those ascribed to ETS [Jaakkola, 1990; Reinikainen, 1990]. Temperature, noise, poor lighting, and stress can also result in similar complaints [Molina, 1989]. Indoor air quality complaints are referred to as sick building syndrome12 (SBS). Investigators of building-related complaints have found multiple causes of SBS and have reported ETS to be a negligible source of complaints about indoor air quality [Collett, 1989; Melius, 1985; Robertson, 1990]. For example, from 1981 through 1987, one company studied indoor air quality in 223 different buildings, accounting for over 39 million square feet of property, and found that ETS was a significant concern in only 10, or 4%, of the buildings [Robertson, 1989]. In another SBS database, smoking was implicated as a major contributor to complaints in only 12 of 408 (<3%) of the buildings surveyed [Collett, 1989]. The National Institute for Occupational Safety and Health (NIOSH) investigated more than 200 "sick" buildings and found that tobacco smoke was the source of claimed discomfort in only 2% of the buildings investigated. Ventilation problems caused half the complaints; outdoor air was considered a bigger problem than ETS [Melius, 1985]. Other investigators 12 Sick building syndrome comprises a group of symptoms which are reported by people working predominantly in air conditioned buildings [Molina, 1989]. Typical symptoms are eye and nose irritation, fatigue, coughing, rhinitis, nausea, headaches, sore throats and general respiratory problems [Robertson, 1988]. 42
concluded that bacterial and fungal contamination is a major source of indoor air problems [Collett, 1989; Nevalainen, 1990; Robertson, 1990, Strom, 1990]. Inadequate ventilation exacerbates all indoor air quality problems. Ignoring the broader issue of indoor air quality, the Guide recommends only extreme solutions. The implication that banning smoking or establishing smoking policies will make indoor air "safe" is not justified. Crawford concluded: "The prohibition of smoking in the workplace will not reduce the adverse health effects of industrial processes. It will remove the telltale signs of inadequate ventilation" [Crawford, 1988, p. 203]. Similarly, Robertson confirmed that ETS is blamed for poor indoor air quality because it can be seen and smelled: In reality, ETS is merely a symptom of an invisible problem, not a cause. Without question, the leading cause of sick buildings is inadequate ventilation. If visible pollutants like smoke accumulate inside a building, so too do pollutants that are invisible. The symptoms often wrongly attributed to ETS can be caused by a veritable garden of contaminants. Scores of nontobacco pollutants such as formaldehyde, carbon monoxide, oxides of nitrogen, ozone, fungal and bacterial spores, cotton fibers and fiberglass fragments -- coupled with poor ventilation - - are generally found on investigation to be the real cause of the problems reported by building occupants. The Surgeon General's 1986 report on "involuntary smoking' questioned the effectiveness of ventilation as a mitigation strategy for ETS. We have found, however, that proper ventilation quickly dissipates ETS. Indeed, ventilation experts frequently gauge the operational efficiency of ventilation systems by using smoke tests. If smoke persists, it is a clue that a serious ventilation problem exists. Once the underlying problem of poor air circulation is corrected, so too is the high level of ETS [Robertson, 1990, pp. 333-334]. 43
It is ironic that the Guide disregards the role of ventilation. An EPA headquarters building itself was "the subject of significant occupant complaints of inadequate ventilation and poor indoor air quality" [USEPA, 1989b, p. 23]. In fact, "[alpproximately six EPA employees have been advised by their physicians not to reenter the building. Some of these employees exhibit signs of a heightened sensitivity to the air pollutants present in the complex" [USEPA, 1989b, p. 23]. Smoking was not permitted in the building. The Agency's own experience shows that smoking bans do not effectively address indoor air quality problems. D. The Guide Should Objectively Discuss The Entire Range Of Possible Workplace Policies, Not Just Extreme Options The EPA has stated that it intends, in the Guide, "to describe the range of technical and policy options for instituting effective smoking policies" [Federal Register, 1990]. The Guide identifies seven policy options, but summarily dismisses all but two: outright prohibition of smoking in the workplace or separately ventilated smoking rooms. Since the latter option will be prohibitively expensive for many employers, only the former option -- total smoking bans -- is likely to be considered. As currently written, the Guide could appropriately be titled: "Guide to Workplace Smoking Prohibition." The rationale for these two options depends upon the EPA's conclusion in the Health Assessment that ETS is a proven Group A carcinogen. As previously discussed, the data do not support that conclusion. Consequently, the rationale for including only two extreme policies fails. The Agency must appropriately evaluate additional alternatives. Simple accommodation, emphasizing flexibility, common courtesy and interactive management has 44
proven viable [BNA, 1987]. Studies indicate that ETS levels in offices where smoking is permitted are low [Carson, 1988; Proctor, 1989]. Other studies show that ETS does not significantly recirculate between smoking and nonsmoking areas of buildings. Even in the same room, smoking and nonsmoking sections effectively mitigate nonsmoker exposure to ETS [Kim, 1990]. Not surprisingly, therefore, separating smokers and nonsmokers also has proven viable [Hedge, 1990; Sterling, 1989]. The Guide fails to include even one case study on these less extreme alternatives. The authors also fail to consider effective ventilation as an alternative. Improved ventilation will not only reduce nonsmoker exposure to ETS, but will also improve the overall quality of indoor air. In this regard, the Agency should not ignore the experience of the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) in formulating a national ventilation standard. In 1973, ASHRAE published its original ventilation standard. Standard 62-73 incorporated two criteria: a minimum ventilation rate (typically 5 cfm per person) to accommodate energy conservation and a recommended rate for comfort (typically 15 cfm per person) [Burroughs, 1988]. In 1981, ASHRAE published a revised standard (Standard 62-1981) that required a dual ventilation standard of 5 cfm of fresh air per person in a smoke-free environment and 25 cfm in a smoking environment. In addition to "no smoking," other criteria, such as air cleaners, were required for designing a system utilizing 5 cfm [Burroughs, 1988, p. 532]. ASHRAE revised the standard in 1989 to provide for a single, standard ventilation rate of 20 cfm per person in offices with 15 cfm as a minimum. The new standard 45
recognizes that the 1981 standard's 5 cfm rate for nonsmoking areas was inadequate to ensure an acceptable degree of comfort in light of the many other -- imperceptible -- sources of indoor air contamination. A ventilation rate of 20 cfm is sufficient to deal with normal smoking activities as well as the full range of contaminants in buildings [Burroughs, 1988]. Perceptible ETS is a symptom of poor indoor air quality rather than a cause. Smoking bans do nothing to address the overall causes of poor indoor air quality. Thus, a manager who bans smoking in the belief that such a ban will resolve indoor air quality problems undertakes a false economy. Those businesses that adopt the Guide's recommendation to ban smoking, but fail to improve ventilation, will eliminate only a visible symptom of an indoor air quality problem without doing anything to mitigate the problem itself. One example illustrates vividly the magnitude of the Guide's omission in its discussion of appropriate policy alternates. In 1987, The Bureau of National Affairs (BNA) published a special report which was designed to provide information on workplace smoking issues to private sector decision-makers [BNA, 1987]. BNA polled 623 employers and reported that 54 percent had smoking policies in effect and that another 21 percent were considering such policies. Of the employers with smoking policies in effect, only 12 percent had instituted complete smoking bans. Like the Guide, the BNA report included a number of case studies. Unlike the Guide, the BNA report included nine case studies to cover a range of alternate policies -- from a flexible policy emphasizing accommodation (IBM) to a smoking ban also included in the Guide (Pacific Northwest Bell). The BNA report stands in stark contrast to the 46
Guide, which completely fails to include examples of more moderate policy options. When compared with the BNA report, the Guide is embarrassingly incomplete. E. Discussion Of Litigation, Economics And Public Opinion Is Extraneous And One-Sided The Guide includes one-sided treatments of public attitudes about ETS, the economic costs of workplace smoking, and the threat of private litigation. These sections generate heat but no light on an important and potentially far-reaching public policy statement. The section on litigation [The Guide, pp. 28-31] merits special attention because it illustrates the insidious approach taken by the Policy Guide. Supposedly, the Policy Guide is designed to disseminate relevant information on ETS to government and private-sector decision-makers. RJRT questions the propriety of including a section on litigation in an EPA policy guide. Moreover, the Guide's discussion is particularly unbalanced and inevitably leads the reader to conclude that employers will get sued if workplace smoking bans are not instituted. The section leaves the impression that such lawsuits will generally prevail. This is not surprising, because the authors essentially present an advocate's brief, not an objective discussion of the regulatory and legal issues surrounding workplace smoking (i.e., the merits of the case). Here, the EPA is advocate, judge and jury in its effort to stimulate smoking bans. The EPA has no authority to require smoking bans. By providing such an unbalanced treatment, the Agency strays far from its mission and statutory authority. The section, "Cost Savings Related to ETS Reduction" is similarly inappropriate. The Guide suggests with undue certainty that smoking increases business costs. The cost data presented by the EPA are based on anecdotal opinion surveys, not on objective facts. Indeed, the Guide notes: "There has been relatively little research in this area and most of 47
the studies that have been conducted only minimally document the direct and indirect costs of ETS" [The Guide, p. 37]. This begs the question whether the documentation is minimal or whether documented costs are minimal. Whether smoking in the workplace raises -- or lowers -- business costs is a subject of much debate but little evidence. Despite this uncertainty, the Guide presents the issue as proven. The EPA should not rely on opinion and guesswork to justify its policy recommendations. Claims that nonsmoker exposure to ETS in the workplace increases business operating costs must be quantified and verified. Without such objective information, the public cannot adequately assess this issue and is left with the impression that workplace smoking automatically raises the costs of doing business. The section, "Public Attitudes Towards ETS" [The Guide, p. 41] attempts to validate the Guide's contentions regarding the health effects of ETS and the need for workplace smoking bans by citing public opinion surveys. This is sophistry of the highest order. The fact that people may believe ETS to be harmful does not make it so. Public opinion surveys are not pertinent to an objective analysis of the issues. Rigorous scientific investigation frequently demonstrates public opinion to be misinformed. Popular belief does not relieve the EPA of its obligation to provide an accurate and objective scientific foundation for its policy recommendations regarding ETS in the workplace. Moreover, dissemination of accurate scientific information can often result in a better informed public. That should be the EPA's objective. 48
F. The Policy Guide Should Be Based On Substantial Evidence The Policy Guide should be objective and based on substantial, relevant evidence. Public policy and proper administrative procedure require nothing less. The Guide's inadequate review of ETS science and its frequent inclusion of extraneous issues to justify policy recommendations raise serious questions about its objectivity. As discussed below, the Guide's historical development, coupled with the bias and interests of its principal authors, raises similar questions about the EPA's motivations. Perhaps the most provocative aspect of the Policy Guide is its relation to the Health Assessment and the EPA's still-unfinished Technical Compendium on Environmental Tobacco Smoke [USEPA, 1989c]. The Policy Guide was intended to be a simplified version of the Technical Compendium [Axelrad, 1989]. Curiously, the Technical Compendium has not been released for public comment and review by the Agency's Science Advisory Board. Instead, the draft Policy Guide has been released first for public comment. In other words, the Policy Guide has been developed and released in advance of the originally intended support document. Moreover, the Guide now relies extensively on a document of far more limited scientific scope, the draft Health Assessment. As a consequence, several serious questions regarding procedural regularity, objectivity and utility of the Policy Guide are raised. In short, the Policy Guide represents a conclusion -- based largely on the predilections of the authors -- in search of a rationale. The scientific rationale chosen by the authors of the Guide may fit the policies recommended by those authors, but it does not reflect an accurate summary of the science relating to ETS. Science should not be forced to fit the 49 2318
policies set forth in the Guide; the opposite should be true -- policy recommendations should follow from the science. In these circumstances, the EPA should return to the predicate task -- a complete and objective review of ETS science -- before issuing policy recommendations. G. The Policy Guide Is An Inappropriate Exercise Of Authority By EPA In 1986, Congress enacted Title IV of the Superfund Amendments and Reauthorization Act (SARA) to establish a research effort to characterize the extent of indoor air quality and evaluate potential mitigation strategies [SARA, 1986]. Title IV of the Radon Gas and Indoor Air Quality Research Act authorized EPA to investigate indoor air quality. Section 403 of SARA Title IV ("Title IV" or the "Title") directs EPA to: 1. Research all aspects of indoor air quality and its impact on health; 2. Coordinate federal, state, local and private research and development, and disseminate information related to improving indoor air quality, and; 3. Assess potential mitigation strategies at the federal level. The EPA's ETS-related activities have sprung from this directive. Section 404 of Title IV, however, states expressly that the Title is not to be construed to authorize any regulatory programs or activities other than research, development, coordination and information dissemination. Notwithstanding this express restriction, the EPA has engaged in de facto regulation in developing this Guide. The EPA has selectively reviewed existing research, combined science with policy considerations and issued recommendations tantamount to workplace smoking regulations. 50
The Agency's activities are precisely those that one would expect if the Agency had regulatory authority. The Guide is clearly designed to promote workplace smoking bans in lieu of regulation because the EPA lacks authority to regulate the workplace. In other words, the EPA is hoping to accomplish extralegally what it is has not been granted the authority to do by Congress. Further, the statute authorizes the EPA to study overall indoor air quality. Yet the EPA singled out one component of indoor air -- ETS -- and condemned it through an unacceptable review of the science. Significantly, the Guide purports to analyze the issue of ETS in the workplace, but instead relies primarily on selective data on ETS in homes. Furthermore, the EPA has relied on authors who will benefit financially from workplace smoking restrictions. There is no substantial, relevant, scientific evidence to justify the Guide's policy recommendations. Absent substantial scientific evidence and a more objective evaluation, the EPA should not issue the Policy Guide. The Policy Guide, therefore, represents an abuse of discretion by the EPA. Finally, the need for the Guide must be questioned. OSHA is required by statute to regulate workplace health hazards. On September 1, 1989, OSHA denied a petition by Action on Smoking and Health to ban or limit workplace smoking. The Agency concluded that the data do not establish a "grave danger" from tobacco smoke at workplace exposure levels [OSHA, 1990]. On July 9, 1990, OSHA committed to study the issue of environmental 51
tobacco smoke in the workplace [OSHA, 1990]. Therefore, the EPA should refrain from promulgating the Policy Guide. To do otherwise constitutes an improper exercise of administrative power, an abuse of Agency authority, and a waste of taxpayers' money. III. CONCLUSION The EP. A has exceeded its statutory authority, abused its discretion, and compromised its scientific integrity by developing this Guide. RJRT submits that the Guide is irreparably flawed in its presentation of ETS science. In the absence of a scientific basis and legislative authority, the authors present irrelevant and misleading information in a transparent attempt to stimulate workplace smoking bans. Assuming that any action is required, the Guide fails to consider all viable policy options. For these reasons, the Agency's development of the Guide should be terminated. The public would be better served if the EPA adheres to its primary charge -- to research all aspects of indoor air quality and its impact on health. Exercises in creative writing, such as this Guide, will then be superfluous. 52
REFERENCES ACGIH, "Threshold Limit Values and Biological Exposure Indices for 1987-1988," in Threshold Limit Values for Chemical Substances in the Work Environment Adopted by ACGIH, 1987. Adlkofer, F., Scherer, G., Von Meyerinck, L., Von Maltzan, C., Jarczyk, L., "Exposure to ETS and its Biological Effects: A Review," in C.J. Bieva, Y., Courtois and M. Govaerts (eds.) Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 183-196. Ames, B.N., Gold, L.S., "Too Many Rodent Carcinogens: Mitogenesis Increases Mutagenesis," Science, Vol. 249, 1990, pp. 970-971. Arfi, C., Kaloustian, J., Pauli, A.M., Pastor, J., Grimaldi, F., Gouezo, F., Viala, A., "Nicotine and Indoor Air Pollution," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 173-176. Ashby, J., de Serres, F.J., Draper, M., Ishidate, Jr., M., Margolin, B.H., Matter, B., Shelby, M.D. (eds.), "Overview and Conclusions of the IPCS Collaborative Study on In Vitro Assay Systems," Progress in Mutation Research, Vol. 5, Elsevier Science Publishers, Amsterdam, 1985, pp. 118-174. ASHRAE Standard 62 (1989). Ventilation for Acceptable Indoor Air Quality, American Society of Heating, Refrigerating and Air-Conditioning Engineers, Atlanta (discussed in Grimsrud, D.T., "Future Directions for Ventilation Standards," in Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, Vol. 5, pp. 365-377). Axelrad, R., Director of Indoor Air Division, Environmental Protection Agency, Letter to Mr. Robert Lewis, Senior Vice President for Federal Relations at the Tobacco Institute, dated November 27,1989. Baker, R.R., Proctor, C.J., "The Origins and Properties of Environmental Tobacco Smoke," Environment International, Vol. 16, 1990, pp. 231-245. Baker, R.R., "The Formation of Environmental Tobacco Smoke," Tobacco International, pp. 1-10, May 25, 1989. Ball, M., Intorp, M., Schilling, B., "Analysis of Environmental Tobacco Smoke (ETS) Constituents in Indoor Air Under Real Life Conditions," Paper presented at the International Experimental Toxicology Symposium on Passive Smoking, Essen University, Essen, Federal Republic Of Germany, October 23-25, 1986. 53
Biber, A., Scherer, G., Hoepfner, I., Adlkofer, F., Heller, W-D., Haddow, J.E., Knight, G.J., "Determination of Nicotine and Cotinine in Human Serum and Urine: An Interlaboratory Study," Toxicology Letters, Vol. 35, 1987, pp. 45-52. BNA, "Where There's Smoke: Problems and Policies Concerning Smoking in the Workplace," Bureau of National Affairs, A BNA Special Report (2nd Edition), 1987. Burroughs, H.E.B., "ASHRAE: Addressing the Indoor Air Quality Challenge With Energy Conscious Design," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 530-535. Carson, J.R., Erikson, C.A., "Results from Survey of Environmental Tobacco Smoke in Offices in Ottawa, Ontario," Environmental Technology Letters, Vol. 9, No. 6, June 1988, pp. 501-508. Castro, A., Monji, N., "Dietary Nicotine and its Significance in Studies on Tobacco Smoking," Biochemical Archives, Vol. 2, 1986, pp. 91-97. Collett, C., Sterling, E., Sterling, T., Weinkam, J., "A Database of Problem Buildings: Learning by Past Mistakes," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 413-419. Coultas, D.B., Peake, G.T., Samet, J.M., "Questionnaire Assessment of Lifetime and Recent Exposure to Environmental Tobacco Smoke," American Journal of Epidemiology, Vol. 130, No. 2, 1989, pp. 338-347. Crawford, W.A., "Health Effects of Passive Smoking in the Workplace," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 203-210. Crouse, W.E., Ireland, M.S., Striegal, Jr., R.S., Williard, C.S., DeLuca, T.C., "Results From a Survey of Nicotine in Supermarkets," EPA/Air and Waste Management Association International Symposium, Proceedings of Air Pollution Control Association Meeting, May 1989. Crouse, W.E., Ireland, M.S., Johnson, J.M., Striegel, Jr., R.M., Williard, C.S., DePinto, R.M., Oldaker, G.B., McBride, R.L., "Results From a Survey of Environmental Tobacco Smoke (ETS) in Restaurants," in J.P. Harper (ed.), Combustion Processes and the Quality of the Indoor Environment, 1990, pp. 214-222. Cummings, K.M., Markello, S.J., Mahoney, M., Bhargava, A.K., McElroy, P.D., Marshall, J.R., "Measurement of Current Exposure to Environmental Tobacco Smoke," Archives of Environmental Health, Vol. 45, No. 2, 1990, pp. 74-79. 54
Curvall, M., Vala, E.K., Englund, G., Enzell, C.R., "Urinary Excretion of Nicotine and Its Major Metabolites," 43rd Annual Tobacco Chemists' Research Conference, Richmond, VA, 1989. DiNardi, S.R., "Conceptual Considerations for Monitoring Exposure to Environmental Tobacco Smoke," Proceedings of the ASHRAE Conference, Indoor Air Quality '86, Managing Indoor Air for Health and Energy Conservation, April 20-23, 1986, pp. 89-96. Estill, J., Seattle Smoking Foe Cited by Koop, Associated Press, November 30, 1988. Eudy, L.W., Thome, F.A., Heavner, D.L., Green, C.R. and Ingebrethsen, B.J., "Studies on the Vapor-Particulate Phase Distribution of Environmental Nicotine by Selective Trapping and Detection Methods," Presentation at the 79th Annual Meeting of the Air Pollution Control Association, Minneapolis, Minnesota, June 22-27, 1986, pp. 2-14. Federal Register, Vol. 54, No. 12, January 19, 1989, pp. 2450-2451, 2560, 2651-2652, 2928, 2946, 2949, 2959. Federal Register, Vol. 55 June 25, 1990, pp. 25874-01. Fischer, T., Weber, A., Grandjean, E., "Luftverunreinigung durch Tabakrauch in Gaststatten," International Archives of Occupational Environmental Health, Vol. 41, 1978, pp. 267-280. Garfinkel, L., Auerbach, O., Joubert, L., "Involuntary Smoking and Lung Cancer: A Case- Control Study," Journal of the National Cancer Institute, Vol. 75, No. 3, 1985, pp. 463-469. Gori, G.B., "A Summary Appraisal," in G.B. Gori and F.G. Bock (eds.), Banbury Report 3: A Safe Cigarette?, Cold Spring Harbor Laboratory, New York, 1980, pp. 353-359. Greene, M.S., Nonsmoking Business Can Mean Money in Bank, Washington Post, October 6, 1985. Haley, 1990 Annual Winter Toxicology Forum, February 19-21, 1990, pp. 170-183. Hammer, J, "The Kick-the-Habit Business," Newsweek, August 29, 1988, pp. 42-43. Harke, H.P., "Air Pollution in Smoke-Filled Rooms," Reviews on Environmental Health, Vol. I, No. 4, 1974, pp. 305-326. 55
Hedge, A., Erickson, W.A., Rubin, G., "Building Ventilation and Smoking Policy Effects on Indoor Air Quality and Employee Comfort and Health," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, Canada, July 29 - August 3, 1990, pp. 739-744. Hoffmann, D., Brunnemann, K.D., Adams, J.D., Rivenson, A., Hecht, S.S., "N-Nitrosamines in Tobacco Carcinogenesis," in P.N. Magee (ed.), Banbury Report 12: Nitrosamines and Human Cancer, Cold Spring Harbor Laboratory, New York, 1982, pp. 211-225. Hoffmann, D., Brunnemann, K.D., Hoffmann, I., "Significance of Benzene in Tobacco Carcinogenesis," in M.A. Mehlmon (ed.), Benzene: Occupational and Environmental Hazards -- Scientific Update, Preventive Science Publication, New Jersey, 1990, pp. 99-112. Hoffmann, D., Haley, N.J., Adams, J.D., Brunnemann, K.D., "Tobacco Sidestream Smoke: Uptake by Nonsmokers," Preventive Medicine, Vol. 13, 1984, pp. 608-617. Horstman, R.H., "Predicting Velocity and Contamination Distribution in Ventilated Volumes Using Navier-Stokes Equations," Engineering Solutions to Indoor Air Problems," Proceedings of the ASHRAE Conference, IAQ '88, Atlanta, Georgia, April 11-13, 1988. Horvath, S.M., Bedi, J.F., "Alteration in Carboxyhemoglobin Concentrations During Exposure to 9 ppm Carbon Monoxide for 8 Hours at Sea Level and 2134 m Altitude in a Hypobaric Chamber," Journal of Air Pollution Control Association, Vol. 39, No. 10, 1989, pp. 1323-1327. Hulka, B.S., "The Health Consequences of Environmental Tobacco Smoke," Environmental Technology Letters, Vol. 9, 1988, pp. 531-538. Idle, J.R., "Titrating Exposure to Tobacco Smoke Using Cotinine--A Minefield of Misunderstandings," Journal of Clinical Epidemiology, Vol. 43, No. 4, 1990, pp. 313-317. Ingebrethsen, B.J., Sears, S.B., "Particle Evaporation of Sidestream Tobacco Smoke in a Stirred Tank," Journal of Colloid and Interface Science, Vol. 131, No. 2, 1989, pp. 526-536. Jaakkola, J.J.K., Miettinen, O.S., Komulainen, K., Tuomaala, P., Seppanen, O., "The Effect of Air Recirculation on Symptoms and Environmental Complaints in Office Workers. A Double-Blind, Four Period Cross-Over Study," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 281-286. Jarvis, M.J., Russell, M.A.H., "Measurement and Estimation of Smoke Dosage to Non- Smokers From Environmental Tobacco Smoke," European Respiratory Journal, (Suppl.) 133, 1984, pp. 68-75. 56
Kabat, G.C., Wynder, E.L., "Lung Cancer in Nonsmokers," Cancer, Vol. 53, 1984, pp. 1214- 1221. Kay, D.L.C., Heavner, D.L., Nelson, P.R., Jennings, R.A., Eaker, D.W., Robinson, J.H., DeLuca, P.O., Risner, C.H., Brockschmidt, J.K., "Effects of Relative Humidity on Nonsmoker Response to Environmental Tobacco Smoke," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 275-280. Kim, S-D., Yamamoto, T., Ensor, D.S., Sparks, L.E., "Three-Dimensional Contaminant Distribution in an Office Space," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 139- 144. Kirk, P.W., Hunter, M., Baek, S.O., Lester, J.N., Perry, R., "Environmental Tobacco Smoke in Indoor Air," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 99-112. Klaassen, C.D., Amdur, M.O., Doull, J. (eds.), "The Basic Science of Poisons," Casarett and Doull's Toxicology, McMillan Publishing Company, New York, 1986. Klus, H., Begutter, H., Nowak, A., Pinterits, G., Ultsch, I., Wihlidal, H., "Analysis of Environmental Tobacco Smoke (ETS) Constituents in Indoor Air Under Controlled Conditions," Proceedings of CORESTA Symposium, Vol. II, Taormina, Italy, October 27, 1986, pp. 1-16. Koo, L. C., "Environmental Tobacco Smoke and Lung Cancer: Is It The Smoke Or The Diet?," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 65-75. Layard, M.W., "Environmental Tobacco Smoke and Cancer: The Epidemiologic Evidence," in D.J. Ecobichon and J.M. Wu (eds.), Environmental Tobacco Smoke: Proceedings of the International Symposium at McGill University 1989, Lexington Books, Lexington, Mass., 1990, pp. 99-115. Lee, P.N., "Passive Smoking and Lung Cancer Association: A Result of Bias?" Human Toxicology, Vol. 6, 1987, pp. 517-524. Lee, P.N., Chamberlain, J., Alderson, M.R., "Relationship of Passive Smoking to Risk of Lung Cancer and Other Smoking-Associated Diseases," British Journal of Cancer, Vol. 54, 1986, pp. 97-105. 57
Letzel, H., Blumner, E., Uberla, K., "Meta-Analyses on Passive Smoking and Lung Cancer Effects of Study Selection and Misclassification of Exposure," Environmental Technology Letters, Vol. 9, No. 6, June 1988, pp. 491-500. Lofroth, G., Burton, R.M., Forehand, L., Hammond, S.K., Seila, R.L., Zweiddlinger, R.B., Lewtas, J., "Characterization of Environmental Tobacco Smoke," Environmental Science Technology, Vol. 23, No. 5, 1989, pp. 610-614. Machacek, D.A., Jiang, N-S., "Quantification of Cotinine in Plasma and Saliva by Liquid Chromatography," Clinical Chemistry, Vol. 32, No. 6, 1986, pp. 979-982. Mahajan, V.K., Huber, G.L., "Health Effects of Involuntary Smoking: Impact on Tobacco Use, Smoking Cessation, and Public Policies," Seminars in Respiratory Medicine, Vol. 11, No. 1, January 1990, pp.87-114. Martin, M.J., Fehrenbach, A., Rosner, R., "Ban on Smoking In Industry,' New England Journal of Medicine, Vol. 315, No. 10, 1986, pp. 647-648. Matsunga, S.K., Plezia, P.M., Karol, M.D., Katz, M.D., Camilli, A.E., Benowitz, N.L., "Effects of Passive Smoking on Theophylline Clearance," Clinical Pharmacology Therapeutics, Vol. 46, No. 4, 1989, pp. 399-407. Melius, J., Wallingford, K., Keenlyside, R., Carpenter, J., "Indoor Air Quality -- the NIOSH Experience," Paper Presented at a Meeting of the American Society of Heating, Refrigeration and Air Conditioning Engineers, Atlanta, George, 1985, pp. 1-17. Molina, C., "Sick Building Syndrome - Clinical Aspects and Prevention," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 15-21. NIEHS, National Institute of Environmental Health Sciences, U.S. Department of Health and Human Services, Fifth Annual Report on Carcinogens, NTP-89-239, 1989, pp. 15-17. NRC, National Research Council, Environmental Tobacco Smoke: Measuring Exposures and Assessing Health Effects, National Academy Press, Washington, D.C., 1986. NRC, National Research Council, Complex Mixtures: Methods for In Vivo Toxicity Testing, National Academy Press, Washington, D.C., 1988. Nelson, P.R., Heavner, D.L., Oldaker, G.B., "Problems With the Use of Nicotine as a Predictive Environmental Tobacco Smoke Marker," Proceedings of the 1990 EPA International Symposium on Toxic and Related Air Pollutants, to appear Fall, 1990b. Nelson, P.R., Ogden, M.W., Maiolo, K.C., Heavner, D.L., Collie, B.B., "Predictive Value of 58
Nicotine as an Environmental Tobacco Smoker Marker," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990a, pp. 367-372. Nevalainen, A., Kotimaa, M., Pasanen, A.L., Pellikka, M., Niininen, M., Reponen, T., Kalliokoski, P., "Mesophilic Actinomycetes - The Real Indoor Air Problem?, Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 203-206. Oates, S., "Who Tells Smokers to Put It Out," Washington Post, July 28, 1985. Ogden, M.W., Maiolo, K.C., Oldaker, G.B., Conrad, F.W., "Evaluation of Methods for Estimating the Contribution of ETS to Respirable Suspended Particles," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 415-420. Ogden, M.W., Maiolo, K.C., "Collection and Analysis of Solanesol as a Tracer of Environmental Tobacco Smoke (ETS)," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 77-88. Oldaker, G.B., "Environmental Tobacco Smoke (ETS): How Much is in the Air?,' Tobacco International, pp. 1-10, May 25, 1989. Oldaker, G.B., Perfetti, P.F., Conrad, Jr., F.C., Conner, J.M., McBride, R.L., "Results From Surveys of Environmental Tobacco Smoke in Offices and Restaurants," in H. Kasuga (ed.), Indoor Air Quality, Springer-Verlag, Berlin Heidelberg, 1990a, pp. 99-104. Oldaker, G.B., Ogden, M.W., Maiolo, K.C., Conner, J.M., Conrad, F.W., DeLuca, P.O., "Results From Surveys of Environmental Tobacco Smoke in Restaurants in Winston-Salem, North Carolina," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990b, pp. 281-285. Oldaker, G.B., Conrad, Jr., F.W., "The Effect of Environmental Tobacco Smoke (ETS) on the Air Quality Within Aircraft Cabins," Submitted to National Academy of Sciences, April 10, 1986. OSHA, "Occupational Safety and Health Reporter (BNA) 279 (July 25, 1990). Proctor, C.J., "The Analysis of the Contribution of ETS to Indoor Air," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 57-66. Proctor, C.J., Warren, N.D., Bevan, M.A.J., "Measurements of Environmental Tobacco Smoke in an Air-Conditioned Office Building," Environmental Technology Letters, Vol. 10, 1989, pp. 1003-1018. 59
Reasor, M.J., "Biological Markers in Assessing Exposure to Environmental Tobacco Smoke," in D.J. Ecobichon and J.M. Wu (eds.), Environmental Tobacco Smoke: Proceedings of the International Symposium at McGill University 1989, Lexington Books, Lexington, Mass., 1990, pp. 69-77. Reasor, M.J., "The Composition and Dynamics of Environmental Tobacco Smoke," Journal of Environmental Health, Vol. 50, No. 1, 1987, pp. 20-24. Reinikainen, L.M., Jaakkola, J.J.K., Helenius, T., Seppanen, O., "The Effect of Air Humidification on Symptoms and Environmental Complaints in Office Workers: A Six Period Cross-Over Study," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 775-780. Reist, P.C., "Brownian Motion and Simple Diffusion," Introduction to Aerosol Science, McMillan Publishing Company, New York, 1984, pp. 108-120. Repace, J.L., Lowrey, A.H., "Tobacco Smoke, Ventilation, and Indoor Air Quality," ASHRAE Transactions 88, 1982, pp. 895-909. Reynolds, B., "More and More Firms Adopt Smoking Policies," USA Today, June 26, 1990. Robertson, G., "Ventilation, Health and Energy Conservation -- A Workable Compromise," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air quality, Excerpta Medica, Amsterdam, 1989, pp. 293-300. Robertson, G., "Indoor Pollution: Sources, Effects and Mitigation Strategies," in D.J. Ecobichon and J.M. Wu (eds.), Environmental Tobacco Smoke: Proceedings of the International Symposium at McGill University 1989, Lexington Books, Lexington, Mass., 1990, pp. 333-355. Ruth, J.H., "Odor Thresholds and Irritation Levels of Several Chemical Substances: A Review," American Industrial Hygiene Association Journal, Vol. 47, 1986, pp. A-142-A151. Ryan, P.B., Spengler, J.D., Halfpenny, P.F., "Sequential Box Models for Indoor Air Quality: Application to Airliner Cabin Air Quality," Atmospheric Environment, Vol. 22, No. 6, 1988, pp. 1031-1038. SARA, "Radon Gas and Indoor Air Quality Research Act of 1986, Publication L. 99-499, Title IV, 100 Stat. 1758 (42 U.S.C.A. § 7401 note (West Supp. 1990)). Schepers, G., Walk, R-A., "Cotinine Determination by Immunoassays May Be Influenced by Other Nicotine Metabolites," Archives of Toxicology, Vol. 62, 1988, pp. 395-397. Sheen, S.J., "Detection of Nicotine in Foods and Plant Materials," Journal of Food Science, 58776 60
Vol. 53, No. 5, 1988, pp. 1572-1573. Sheps, D.S., Adams, K.F., Bromberg, P.A., Goldstein, G.M., O'Neil, J.J., Horstman, D., "Lack of Effect of Low Levels of Carboxyhemoglobin on Cardiovascular Function in Patients with Ischemic Heart Disease," Archives of Environmental Health, Vol. 42, No. 2, 1987, pp. 108-116. Shimizu, H., Morishita, M., Mizuno, K., Masuda, T., Ogura, Y., Santo, M., Nishimura, M., Kunishima, K., Karasawa, K., Nishiwaki, K., Yamamoto, M., Hisamichi, S., Tominaga, S., "A Case-Control Study of Lung Cancer in Nonsmoking Women," Tohoku Journal of Experimental Medicine, Vol. 154, 1988, pp. 389-397. Spengler, J.D., Dockery, D.W., Turner, W.A., Wolfson, J.M., Ferris, B.G., "Long-Term Measurements of Respirable Sulfates and Particles Inside and Outside Homes," Atmospheric Environment, Vol. 15, 1981, pp. 23-30. Sterling, E.M., Collett, C.W., Kleven, S., Arundel, A., "Typical Pollutant Concentrations in Public Buildings," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 399-404. Sterling, T., "ETS Concentrations Under Different Conditions of Ventilation and Smoking Regulation," in R. Perry and P.W. Kirk (eds.), Indoor And Ambient Air Quality, Selper Ltd., London, 1988, pp. 89-98. Sterling, T., "Exposure to Environmental Tobacco Smoke in the Non Industrial Workplace Under Different Conditions of Ventilation and Smoking Regulation," in C.J. Bieva, Y. Courtois and M. Govaerts (eds.), Present and Future of Indoor Air Quality, Excerpta Medica, Amsterdam, 1989, pp. 111-118. Strom, G., Palmgren, U., Wessen, B., Hellstrom, B., Kumlin, A., "The Sick Building Syndrome: An Effect of Microbial Growth in Building Constructions?," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 173-178. Thornton, R.E., "Environmental Tobacco Smoke," Tobacco International, May 25, 1989. Thuan, N.T.L., Migueres, M.L., Roche, D., Roussel, G., Mahuzier, G., Chretien, J., Ekindjian, O.G., "Elimination of Caffeine Interference in HPLC Determination of Urinary Nicotine and Cotinine," Clinical Chemistry, Vol. 35, No. 7, 1989, pp. 1456-1459. Uberla, K., "Epidemiology: Its Scope and Limitations for Indoor Air Quality,' Indoor Air Quality Symposium, San Carlos de Bariloche, Argentina, December 6-7, 1988, pp. 45-60. 61
Uberla, K., "Lung Cancer from Passive Smoking: Hypothesis or Convincing Evidence?," International Archives Occupational Environmental Health, Vol. 59, 1987, pp. 421-437. USEPA, "Hydrogen Cyanide Health Effects," Environmental Protection Agency, EPA-460/3- 81-026, Final Task 2 Report, September 11, 1981. USEPA 1990, "Report to Congress on Indoor Air Quality: Executive Summary and Recommendations, EPA/400/1-89/0011A, U.S. Environmental Protection Agency, August 1989a. USEPA 1990 "Report to Congress on Indoor Air Quality. Vol. 1: Federal Programs Addressing Indoor Air Quality," U.S. Environmental Protection Agency, EPA/400/1-89/001B, August 1989b. USEPA, Environmental Tobacco Smoke: A Compendium of Technical Information (Draft), Indoor Air Division, Office of Atmospheric and Indoor Air Programs, Office of Air and Radiation, U.S. Environmental Protection Agency, Washington, D.C., 1989c. USPHS, U. S. Surgeon General's Report. The Health Consequences of Involuntary Smoking. U. S. Department of Health and Human Services, Public Health Service, (1986). Varela, L.R., "Assessment of the Association Between Passive Smoking and Lung Cancer," A Dissertation Presented to the Faculty of the Graduate School of Yale University in Candidacy for the Degree of Doctor of Philosophy, May 1987, pp. 1-176. Wanner, H., Kuhn, M., "Indoor Air Pollution by Building Materials," in B. Berglund, T. Lindvall and J. Sundell (eds.), Proceedings of the Third International Conference on Indoor Air Quality and Climate, Vol. 3: Sensory and Hyperreactivity Reactions to Sick Building, Stockholm, August 20-24, 1984, pp. 35-40. Watts, R.R., Langone, J.J., Knight, G.J., Lewtas, J., "Cotinine Analytical Workshop Report: Consideration of Analytical Methods for Determining Cotinine in Human Body Fluids as a Measure of Passive Exposure to Tobacco Smoke," Environmental Health Perspectives, Vol. 84, 1990, pp. 173-182. Winneke, G., Plischke, K., Roscovanu, A., Schlipkoeter, H-W., "Patterns and Determinants of Reaction to Tobacco Smoke in an Experimental Exposure Setting," in B. Berglund, T. Lindvall and J. Sundell (eds.), Proceedings of the 3rd International Conference on Indoor Air Quality and Climate, Vol. 2: Radon, Passive Smoking, Particulates and Housing Epidemiology, Stockholm, August 20-24, 1984, pp. 351-356. Wu, A.H., Henderson, B.E., Pike, M.C., Yu, M.C., "Smoking and Other Risk Factors for Lung Cancer in Women," Journal of National Cancer Institute, Vol. 74, No. 4, 1985, pp. 747- 751. 62
Wynder, E.L., Kabat, G.C., "Environmental Tobacco Smoke and Lung Cancer: A Critical Assessment," in H. Kasuga (ed.), Indoor Air Quality, Springer-Verlag, Berlin Heidelberg, 1990, pp. 5-15. Yamamoto, T., Kim, S-D., Ensor, D.S., Sparks, L.E., "Characteristics of Two-Dimensional Particle Eddy Diffusion in Office Space," Indoor Air '90, Proceedings of The Fifth International Conference on Indoor Air Quality and Climate, Toronto, July 29 - August 3, 1990, pp. 243-248. 63
NYC (PM767) - 4/18 RC# 296 2047589387 NYC - 5/17 RC# 297 (Follow up calls (DM 774-)
SYNERGY VOLUMES-BRAZILJARGENTINA AND COLOMBIA BRAZIL TYPE 1996 1997 FC STRIPS 30,172 37,253 FC BY PRODUCTS 5,733 7,078 TOTAL 35,905 44,331 NO 40' CONTS 880 1,087 BURLEY STRIPS 28,179 22,948 BURLEY BY PRODUCTS 8,172 6,655 TOTAL 36,351 29,603 NO 40' CONTS 891 726 TOTAL TOB. NORTH-40' 1,771 1,812 TOTAL TOB. NORTH-TEU 3,542 3,624 COFFEE NORTH-JAX-40' COFFEE NORTH-JAX-20 TOTAL COFFEE NORTH-JAX-TEU - COFFEE NORTH-HOUSTON-40' COFFEE NORTH-HOUSTON-20' TOTAL COFFEE NORTH-HOUSTON-TEU - - TOTAL COFFEE TEU 2,000 SHEET TO BRAZIL 8,800 8,800 NO 40' CONTS SOUTH 262 262 NO 40' CONTS SOUTH-TEU 524 524 TOTAL TEU NORTH 5,542 3,624 TOTAL TEU SOUTH 524 524 TOTAL TEU BRAZIL/ARGENTINA 6,066 4,148 TOTAL TEU(COFFEE) COLOMBIA 750 Beer <50 BR TEU through 7/96 +264 Paragray 614
SYNERGY VOLUMES-AFRICA ZIMBABWE TYPE 1996 1997 FC STRIPS 1,526 1,820 FC BY PRODUCTS 290 346 TOTAL 1,816 2,166 NO 40 CONTS 45 53 MALAWI BURLEY STRIPS 17,714 14,512 BURLEY BY PRODUCTS 5,137 4,208 TOTAL 22,851 18,720 NO 40' CONTS 560 459 TOTAL 40' CONTS 605 512 TOTAL TEU 1,209 1,024
mic. E.mken EXACT COPY January 21, 1980 Mr. W. D. Hobbs Mr. E. A. Horrigan, Jr. Mr. G. H. Long Mr. C. G. Tompson Mr. G. B. Whitaker Mr. J. T. Wilson Re: ANALYSIS OF CIGARETTE PRICE - UPDATE In March, 1979, we published a report titled, "Analysis of Cigarette Price." The report was prepared by Dr. John McCann (currently a professor at Duke University and previously a .consultant with Data Resources, Inc.) Since the publication of the report, Field Sales performed several National Pricing Surveys. These data have been incorporated into this report, which was expanded to show the trend of cigarette pricing at different outlets in the five areas of the United States. Complete retail pricing backup data are available at the state, total U. S., and RJR Division and Region levels. Highlights Cigarette retail prices continue to climb, more than doubling since 1964. However, when adjusted for inflation in the economy, cigarette retail prices have continued the decline begun in 1971. Manufacturers' price increases over the last year have been taken at a rate lower than cost of living increases; thus, inflation adjusted manufacturers' prices are declining as they did in the period 1964 - 1974. Manufacturers prices continue to increase the percentage they hold of the retail price. State taxes have begun to climb but still not at the rate of inflation. They continue to make up about a quarter of the retail price. Trade margins have also continued to climb but in "real" dollars have not kept up with the cost of living. Increases in this price component have been lower than the others so that its percentage of the retail price has begun to decline.
January 21, 1980 Page Two It appears that margin levels are not related to state tax levels (and thus cost to retailer) . Geographically, price and state tax are highest in the North Atlantic Area and lowest in the South Atlantic Area. However, trade margins are highest in Mid-Continent and lowest in North Central Areas. State tax does appear to determine levels of retail pricing, since those states with high tax rates (Connecticut, Florida, Massachusetts) have the highest retail prices, and those with the low taxes (South Carolina, Kentucky, North Carolina) have the lowest retail prices. Convenience stores continue to have the highest retail prices, while super stores and discount stores remain consistently lowest in pricing. Uziel Frydman Marketing Research Department UF:gj Attachment CC: Mr. R. A. Emken Mr. N. W. Glover Mr. D. W. Grout Mr. G. R. Gunzenhauser Mr. J. F. Hind Mr. C. A. Martin Mr. C. C. Standen Mr. J. B. Stuart Mr. C. A. Tucker