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                                                                                  ESTABLISHIPJG A

                                                                                  WORKPLACE
                                                                                  SMOIQNG POLICY
        1



                                  Establishing A Workplace Smoking Policy

                                  Consolidated Safety Services, Inc .

                                  Introduction

                                  Workplace smoking has in recent years been a subject of
                                  controversy. Nearly all major U.S . companies now have policies
                                  regulating smoking in the workplace . A minority have
                                  implemented smoking bans .

                                  Our experience at Consolidated Safety Services, Inc ., has shown
                                  that, in the great majority of cases, the rights and preferences of
                                  smokers and nonsmokers can be accommodated in the workplace .
                                  This kit is intended to provide assistance to managers who believe
                                  it is wise to have a policy, but who also realize total smoking bans
                                  fail to meet the needs of a significant portion of their employees .

                                  In some cases, designated smoking areas or smoking lounges are
                                  the answer. In others, managers have found it sufficient to restrict
                                  smoking to private offices or separate sections of common areas
                                  such as cafeterias . In still others, employers rely on employees to
                                  work out "informal" policies guided by courtesy and cooperation.

                                  The following information contains an overview of some of the
                                  contaminants which may be factors in indoor air quality, guidance
                                  on how to develop a workplace smoking policy, sample policies,
                                  and more.

                                  The key to establishing a successful policy is to involve your
                                  employees, get their suggestions and input, and seek their support
                                  as the policy is implemented . Then remain flexible, modifying
                                  your policy as experience shows what works best .

                                  Consolidated Safety Services, Inc ., provides assistance to
                                  employers on a variety of workplace issues, including the
                                  development and implementation of equitable smoking policies .
                                  For assistance in these matters, or any safety and occupational
                                  health issues, contact our headquarters staff at 1-800-888-4612 .

                                                            Page 1 April 1992

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                                                                                WORKPLACE
                                                                                SMOKING POLICY


                                  TABLE OF CONTENTS

                                  SECTION ONE:
                                  Indoor Air Quality : A Broad Problem
                                        Introduction
                                        Indoor Air Quality
                                        Common Indoor Air Contaminants

                                  SECTION TWO :
                                  Health Allegations about Environmental Tobacco Smoke

                                  SECTION THREE:
                                  "Social Costs of Smoking"

                                  SECTION FOUR :
                                  What Are an Employer's Legal Obligations Regarding
                                        Environmental Tobacco Smoke?
                                        State Legislation Prohibiting Lifestyle Discrimination

                                  SECTION FIVE :
                                  Negotiating a Fair Workplace Smoking Policy
                                        Element 1 : Employee Involvement
                                        Element 2 : Considering the Options
                                        Element 3 : Development of the Policy
                                        Element 4 : Implementing the Policy
                                        Sample Employee Survey To Help Establish
                                              Workplace Smoking Policies

                                  SECTION SIX :
                                  Improving the Air Quality in Company Facilities

                                  SECTION SEVEN :                                                tJ
                                                                                                 ~,
                                      Sample Smoking Policies                                    ~
                                                                                                  P
                                                                                                 t~`+
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                                                                                ESTABLISHING A

                                                                                WORKPLACE
                                                                                SMOKING POLICY


                                  SECTION ONE :

                                  Indoor Air Quality : A Broad Problem

                                  Introduction

                                  Americans may spend as much as 90 percent of their day indoors .
                                  Complaints from building occupants about indoor air quality (IAQ)
                                  have increased significantly since energy conservation measures
                                  were instituted in the 1970s .

                                  IAQ has become a significant issue for both employers and
                                  employees in the 1990s . Greater awareness among the media and
                                  the general population has escalated interest in IAQ .

                                  One element of IAQ that has received great attention in recent
                                  years is environmental tobacco smoke (ETS) . Whether it's
                                  employee complaints about ETS, occasional tension between
                                  smokers and nonsmokers, the need to abide by state or municipal
                                  smoking regulations, or for other reasons, most large companies
                                  are seeking to establish corporate smoking policies .

                                  While some employers have chosen to deal with the issue of ETS
                                  by instituting a total ban on smoking, others are interested in
                                  seeking an alternative approach that fairly addresses the concerns,
                                  morale and productivity of both smokers and nonsmokers . This kit
                                  has been developed to assist those employers who wish to consider
                                  all aspects of the issue, and offers guidelines for establishing
                                  equitable corporate smoking policies .

                                  Indoor Air Quality

                                  The phrases "indoor air quality" and "environmental tobacco
                                  smoke" are perceived by some to be closely related . Some
                                  employers believe that by adopting a strict smoking policy they




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                                   have assured good IAQ - particularly if they ban smoking in their
                                   facilities . That is usually not the case. In fact, hundreds of
                                   buildings reporting indoor air quality problems have been studied,
                                   and tobacco smoke was considered to be the major cause of those
                                   problems in only about 4 percent of them .

                                   In most offices, the amount of ETS in the air is very low . State-of-
                                   the-art technology used to estimate the amount of ETS to which
                                   nonsmokers are exposed indicates that, on average, it takes about
                                   240 hours in an office where smoking is permitted to be exposed to
                                   the nicotine equivalent of one cigarette .

                                   Yet ETS is often blamed as the sole cause of poor indoor air
                                   quality. That may be because most of us can detect very low levels
                                   of ETS in the air. We can smell it, and we can see it. However,
                                   there are many other common indoor air contaminants, and since
                                   most of these are invisible and odorless, we don't realize that they
                                   are present. Numerous investigations indicate that these other
                                   contaminants are the major causes of more than 90 percent of all
                                   indoor air quality complaints .

                                   Common Indoor Air Contaminants

                                   The indoor environment houses numerous sources that release
                                   contaminants into the air. Besides tobacco smoke, these sources
                                   can include building materials and furnishings as diverse as
                                   deteriorated insulation containing asbestos ; wet or damp carpeting ;
                                   cabinetry or furniture made of certain pressed wood products ;
                                   products for cleaning ; paper dust; adhesives ; perfumes;
                                   combustion by-products ; pest-control products ; biological
                                   organisms; and outside sources such as pollen, radon, pesticides,
                                   and auto emissions .

                                   Common indoor air pollutants and the symptoms commonly
                                   associated with them are described below :




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                                  Biological Contaminants include bacteria, mold and mildew, fungi,,
                                  viruses, dust mites, and pollen . Simple dust contains many of
                                  these organisms, as well as pieces of biological matter such as
                                  insect parts and animal dander . In addition, building occupants
                                  liberate thousands of microorganisms in the course of a day .
                                  Biological contaminants are often associated with wet or water-
                                  damaged areas, especially around air intakes, dehumidifiers and
                                  cooling coils . Symptoms reportedly associated with biological
                                  pollutants include sneezing, watery eyes, coughing, shortness of
                                  breath, dizziness, lethargy, fever and digestive problems .

                                   Carbon Monoxide is a combustion by-product . Sources of carbon
                                   monoxide include automobile exhaust, leaking chimneys and
                                   furnaces, gas stoves and heaters . Carbon monoxide can cause
                                   fatigue in healthy individuals and has been reportedly associated
                                   with chest pain in persons with heart disease . At high
                                   concentrations, it is associated with impaired vision and
                                   coordination, headaches, dizziness, confusion, and nausea .                    M

                                   Or ang ic Vapors are associated with evaporative products such as
                                   paints, paint strippers, wood preservatives, aerosol sprays, cleaners
                                   and disinfectants, insect repellents and air fresheners . In addition,
                                   copier and photographic chemicals contain high organic solvent
                                   levels. Health effects include eye, nose, and throat irritation,
                                   headaches, loss of coordination and nausea . Long-term exposure
                                   has been associated with damage to the liver, kidneys and central
                                   nervous system .

                                   Radon, a colorless gas, is generated naturally from decaying
                                   uranium and is found virtually everywhere at very low levels .
                                   Sources include earth and rock beneath buildings, well water and
                                   building materials . There are no acute health effects attributed to
                                                                                                            N
                                   radon, but exposure over a period of years has been reported to          O
                                   cause an estimated 10 percent of all lung cancer deaths .                N
                                                                                                            A
                                                                                                            N
                                   Formaldehyde is an important chemical used widely in industry to
                                   manufacture building materials and numerous household products .         CNO
                                                                                                            N
                                                                                                            CA
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                                   Sources include plywood, particleboard, fiberboard, urea-
                                   formaldehyde foam insulation, adhesives, carpet, and other
                                   textiles . In addition, carbonless paper contains formaldehyde .
                                   Immediate exposure effects include eye, nose and throat irritation,
                                   wheezing and coughing, fatigue, skin rash, and severe allergic
                                   reactions .

                                   Pesticides can be used both inside and out'side a facility . Outside
                                   lawn applications can drift or become tracked inside a building .
                                   Acute health effects include irritation to eyes, nose and throat .
                                   Long-term exposure has been associated with damage to the
                                   central nervous system .

                                   Asbestos is a mineral fiber that has been used commonly in a
                                   variety of building construction materials for insulation and as a
                                   fire-retardant. Sources include deteriorating or damaged
                                   insulation, fire-proofing, and acoustical materials . There are no
                                   acute health effects associated with asbestos . However, asbestos        M
                                   fibers can accumulate in the lungs and may eventually cause
                                   asbestosis and other diseases of the lung .

                                   Particulates associated with dust, textile fibers, and paper
                                   products are continuously liberated into the air in any occupied
                                   space . These inert materials can cause upper respiratory irritation,
                                   as well as eye, nose and throat irritation. Long-term health effects
                                   are still under investigation, although sinus infection and blockage
                                   have been frequently reported .

                                   Published data have shown that biological organisms rank the
                                   highest in contributing to indoor air pollution . In one scientific
                                   study' conducted in over 400 buildings containing 63 million
                                   square feet of office space, allergic fungi were identified as a major
                                   factor in over 30 percent of the buildings . Allergic or pathogenic
                                   bacteria were a significant factor in nearly 10 percent . In
                                   comparison, environmental tobacco smoke was a major factor in
                                   only 3 percent of the investigations .




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                                   A 1989 survey of workers in 47 district and federal government
                                   buildings in Washington, D .C.z, to assess their attitudes regarding
                                   air quality in their workplaces showed that almost three-quarters
                                   (73.3%) of the respondents indicated air quality at work was a
                                   problem, and nearly all respondents had experienced symptoms
                                   while in the workplace . Eighty-three percent indicated that poor
                                   indoor air quality was the cause of, or a contributing factor to, their
                                   symptoms . It is noteworthy, that most of the buildings in this study
                                   were owned, managed or leased by the U .S . Government. Prior to
                                   the study, in 1986, the U .S. Government had restricted smoking in
                                   all federal office buildings . This study clearly showed that
                                   building occupants complained of health problems and recognized
                                   poor indoor air quality in the absence of environmental tobacco
                                   smoke .

                                   Many buildings contain sources of gases or particulates and yet do
                                   not have occupants that complain of problems . Frequently, the true
                                   cause of poor indoor air quality is often not the air contaminants
                                   themselves . Rather, it is the inability of ventilation systems to
                                   reduce pollutants to acceptable levels . Poor ventilation and
                                   improperly maintained ventilation systems cause the buildup of not
                                   only the visible constituent ETS but also of all the invisible and
                                   odorless pollutants.

                                   Therefore, before considering a ban on smoking, or even
                                   establishing smoking policies, employers should first examine the
                                   overall indoor air quality in their workplace and try to identify all
                                   the indoor air quality problems which may exist . The result of this
                                   kind of investigation might lead to solutions that address overall
                                   indoor air quality rather than singling out one aspect of the .
                                   problem. Section 5 of this document will assist the employer in
                                   addressing indoor air quality in its entirety.
                                                                                                                                              ~
                                                                                                                                              O
                                   References:                                                                                                N

                                   1 . "Facton Affecting Employee Health & ComfoA, "Healthy Buildings Intemational Magazine, NovJDec .,1990   ~

                                   2. Safe Wa.hpiace Air Corltlion, "(ndoor Air Quality in Fedaal & D .C. Gwemoxat Birildiog.," 1989
                                                                                                                                              W


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                            REPRINTED FROM THE JULY 1991 CONSUMERS' RESEARCH

              Special Report :

                               Passive Smoking :
                             How Great A Hazard?
                                                        By Gary L. Huber, MD,
                                                       Robert E . Brockie, MD,
                                                      and Vijay K . Mahajan,, MD

                Reports from medical journals, the popular                  tions as low as one part in a billion or even~ in a
              media, and federal regulatory agencies about                  trillion~ parts of clean air, some of the highly-
              the adverse health effects of passive smoking                 diluted constit'uents in ETS are irritating to the
              have convinced many jurisdictions to ban smok-                membranes of the eyes and nose of the non-
              ing in public places . What is often missing from             smoker . Cigarette smoking is offensive to many
              such discussions is the scientific basis for the              nonsmokers and some of these highly-diluted
              health-related claims . The following article                 constituents can trigger adverse emotional
              examines the scientific data concerning the                   responses, but do these levels of exposure really
              ascertainable risk from inhalation of enuiron-                represent a legitimate health hazard?
              mental tobacco smoke . One of its authors, Dr .
                                                                                                                             L
              Gary Huber, spoke at a recent' CR symposium on
              "Science and Regulation" (see article on page                   "Cigarette smoking is offensive
              35) :-Ed.                                                       to many nonsmokers and some
                                                                              of these highly-diluted con-
                     bout 50 million or so Americans are
                                                                              stituents can trigger adverse
                     active smokers, consuming well over 500
               0 billion tobacco cigarettes each year . The                   emotional responses, but do
              "secondhand" smoke-usually called "environ-                     these levels of exposure really
              mental tobacco smoke," or more simply                           represent a legitimate health
              "ETS"-that is generated! is released into their                 hazard?"
              surroundings„ where it potentially is inhaled
              passively and retained by nonsmokers . Or is it?
                Literally thousands of ETS-related state-                      Clear answers to these questions are difficult
              ments now have appeared in the lay press or in                to find . The generation, interpretation, and use
              the scientific literature . Many of these have                of scientific and medical information about
              been~ published, and accepted as fact, without                ETS has been influenced, and probably distort-
              adequate critical questioning . Based on the                  ed, by a "social movement"' to shift the empha-
              belief that these publications are accurate,                  sis on the adverse health effects of smoking in
              numerous public policies, regulations ; and laws              the active smoker to : an implied health risk for
              have been implemented to segregate or restrict                the nonsmoker . The focus of this movement,
              active smokers, on the assertion that ETS is a                initiated by Sir George Godber of the W'orld
              health hazard to those who do not smoke .                     Health Organization 15 years ago, was and is to
                What quantity of smoke really is released into              emphasize that active cigarette smokers, injure
              the environment of the nonsmoker? What is the                 those : around! them, including their families
              chemical and! physical quality, or nature, of                 and, especially, any infants that might be
              ETS remnants in our environment? Is there a                   exposed involuntarily to ETS . .
              health risk to the nonsmoker? In concentra-                      By fostering the perception that secondhand
                                                                            smoke is unhealthy for nonsmokers, active
                                                                            smoking has become an und'esirable and an
              Drs . Huber, Brockie, and Mahajan are with ; respect-
              ively, the University of Texas Health Science Center,         antisocial behavior . The cigarette smoker has
              tliePresbyterian Hoospital of Dullas ;, and' St: Vineent "s   become ever more segregated and isolated . This
              Hospital-Medical College of Ohio ;                            ETS' social movement has been successful! in



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                reducing tobacco cigarette consumption, per-                                     health effects of ETS, it must first be appreciat-
                haps more than other measures, including                                         ed that not, all tobacco smoke is the same, and
                mandatory health warnings, advertising bans                                      thus the risk for exposure to the different kinds
                on radio and television, and innumerable other                                   of tobacco smoke must be considered indepen-
                efforts instituted by public health and medical                                  dently.l
                professional organizations . But,, has the ETS
                social: movement been based on scientific truth
                and on reproducible data and sound scientific                                    What Is ETS?
                principles?                                                                        The three most important forms of tobacco
                  At t'imes, not surprisingly,, the ETS social                                   smoke are depicted in Figure 1 . Mainstream
                movement and scientific objectivity have been                                    smoke is the tobacco smoke that is drawn
                in conflict . To start with, much of the research                                through the butt' end~ of a cigarette during
                on ETS has been shoddy and poorly conceived' .                                   active smoking ; this is the tobacco smoke that
                Editoriali board's of scientific journals have                                   the active smoker inhales into his or her lungs .
                selectively accepted or excluded contributions                                   The distribution of mainstream smoke is sum-
                not always on the basis of inherent scientific                                   marized in Table 1 (page 12) : Sidestream smoke
                merit but, in part, because of these social pres-                                is the tobacco smoke that is released in the sur-
                sures and that, in turn, has affected and biased                                 rounding environment of the burning cigarette
                the data that are available for further analyses                                 from its smoldering t'ip between active puffs .
                by professional organizations and! governmen-                                    Many publications have treated sidestream
                tal agencies . In addition, "negative"' studies,                                 smoke and ETS as if they were one : and the
                even if valid, usually are . not published, espe-                                same, but,sidestream smoke and ETS are clear-
                cially if they involve tobacco smoke, and thus                                   ly not the same thing. Sidestream smoke and
                they do not become part of the whole body of                                     ETS have different physical properties and they
                literature ultimately available for analysis .
                Negative results on ETS and health can be                                        1A burning cigarette has been described4s "a miniature chemicalfactory,"'
                found in the scientific literature, but only with                                producing numerous new components from its raw materials . When a
                                                                                                 cigarette is smoked, the burning cone has a temperature of about 860 to
                great difficulty in that they are mentioned in                                   900°C during active puffing, and smolders at 500 to 600°C between puffs .
                passing as a secondary variable in a "positive"                                  When tobacco burns at these temperatures ; the products ofipyro4yzation are
                                                                                                 all'vapors . As the :vapors cool in passage away from the burning cone, they
                study reporting some other finding unrelated to                                  condense into minute liquid droplets, initiaVly, about two ten-millionths of a
                ETS .                                                                            meter in siie: Generally ; then, all forms of smoke are mioroaerosols of very
                                                                                                 small liquid droplets of parti¢ulate : matter suspended in their surrounding
                  To evaluate critically any potential adverse                                   vapors or gases . Thus, all smoke has a :"parti¢ulate phase" and a"gas phase :"



                   Figure 1 : Particulate Phase and Gas Phase of Tobacco Smoke*


                                                                                                                                                            0

                                                                                                                                               0

                                                                           0   0   0                            0
                                                                         0   0   0
                                                                        0  0    0  0                            0
                                                                        0  0    0  0                            0
                                                                       0  00  0  0
                                                                       000          0      0      0      0      0
                   000000000000000000000                               0000
                   000000000000000000000
                                                                       0000 0 00 0 0                               0                                0
                   000000000000000000000                                                                               0
                                                                       000000 00 0 0 0
                   000000000000000000000
                                                                       0000000o00                    0    0       0
                   000000000000000000000
                   000000000000000000000                               000000000 00                                    0
                   000000000000000000000                                                                          0

                            Mainstream Smoke                                   Sidestream Smoke                              Environmental Tobacco Smoke
                                                                                                                                        (US)
                   * Schematio representat(an of the particulate phase and the gas phase of tobacco smoke . Environmentai ltobacco smoke Is not smoke in ithe conventional
                   sense, but rathef a very limited number of highly-diluted remnants or residual'constituents of mainstream smoke and sidestream smoke .




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                                                                                               measurement . In this sense, then, ETS is really
                 Table 1 : Distribution of                                                     not smoke in the conventional sense of itsAefi-
                                                                                               nition, but rather consists of only a : limited
                 Mainstream Smoke                                                              number of "remnants" or residual' constituents .
                 Total Mainstream Smoke                                             500*       present in highly dilute concentrations,
                 Wet Total Particulate Matter                                        22          Because the levels of ETS cannot~, be quanti-
                    Nicotine                                                          1 .3     fied accurately as su& in the environment,
                    Water                                                             3.7      some investigators have attempted to measure
                    "Tar"                                                            17        one or more constituent parts of ETS as, a"sub-
                 Aerosol Gas Phase                                                             stitut'e marker" for ETS' as a whole . The most
                    Water                                                           478        frequently employed such "marker" has been
                    Air Components                                                   50        nicotine or its first metabolically stable break-
                    Carbon Monoxide                                                 350        down product, cotinine. Nicotine was consid-
                    Carbon Dioxide                                                   50        ered an "ideall marker" because it is more or
                    Other Components                                                  8        less unique to tobacco, although small amounts
                 'All data expressed in milligrams for a 500 mg deliver cigarette, as deter-   can be found in some tomatoes and in other
                 mined by FederatTrade Commission criteria.                                    food sources . In the mainstream tobacco smoke
                 SOURCE: Adapted from Huber,1989 .
                                                                                               that is inhaled by the active smoker, nicotine
                                                                                               starts out almost exclusively in the tiny liquid
               have different chemical properties . Environ-                                   droplets of the particulate phase of'the smoke .
               mental tobacco smoke is usually defined as a                                    Because the smoke particles of ETS become so
               combination of highly diluted sidestream smoke                                  quickly and so highly diluted, however, nicotine
               plus a smaller amount of that residual main-                                    very rapidly vaporizes from the liquid suspend-
               streamsmoke that is exhaled and not retained                                    ed particulates and enters the surrounding gas .
               by the active smoker . What really is ETS?' In                                  In technical terms, the process by which nico-
               comparison to mainstream smoke and side-                                        tine leaves the suspended aerosol particle to
               stream smoke, ETS is so highly diluted that it                                  enter the surrounding gas phase is called
               is not even appropriate to call it smoke, in the                                "denudatiom"
               conventional sense . Indeed, the term "environ-                                   As a vapor or gas, nicotine reacts with or
               mental tobacco smoke" is a misnomer .                                           ad'sorbs onto almost everything in the : environ-
                 Why is ETS a misnomer?' Several reports on                                    ment with which it comes into contact . Thus,
               smoking and' health from the Surgeon                                            nicotine :is not a representative or even a good
               General's Office, a National Research Council                                   surrogate marker for the particulate phase, or
               review of ETS in 1986, t'he more recent                                         even the gas-vapor phase, of ETS . In fact, there
               Environmental Protection Agency's risk assess-                                  are no reliable or established markers for ETS .
               ment of ETS, and several review articles all                                    The remnant or residual constituents of ETS
               have provided a long list of chemical con-                                      each~ have their own chemical and physical
               stituents derived from, analyses of mainstream                                  behavior characteristics in the environment
               smoke and sidestream smoke,, with the iQn .plica-                               and none is present ini a concentration in our
               tion, that because they are demonstrable in                                     environment that reaches an established
               mainstream smoke and sidestream smoke these                                     threshold for toxicity.2
               same constituents must, by inference, also be
               present in ETS . No one : really knows if they are
               present or not . In fact, most are not so presentt                              Measuring Health Risks
               or, if they are, they are present only in very                                    Because the level of exposure to ETS' or the
               dilute concentrations that are well below the                                   dose of ETS' retained cannot be quantified,
               levet of detection by conventional technologies                                 under every-day, real-life cond[tions, the healthi
               available today .                                                               effect's following exposure to residual con-
                 Only 14 of'the 50 biologically active "proba
               ble constituents" of ETS listed by the Surgeon                                  2A threshold limit'value (psually expressed as milligrams of a substance per
               General, for instance, actually have been~ mea=                                 cubic meter, of airior as parts of a sutistaDee present~per million parts of res-
                                                                                               pirable clean air) is the recommended concentration of a substance as the
               sured or demonstrated at any level'I in ETS . The                               maximal level that should'.notbe exceeded to prevent occupational disease
               others are there essentially by inference, not by                               th'rough exposure in the workplace . Threshold~ liminvalues have not been
                                                                                               established for our general, every-day environment outside of industrial expo-
               actual detection or measurement . Thus, there                                   sure. Threshold limit values are determined by toxicologists, epidemiologists,
               are 36 constituents in these lists that are in-                                 and hygienists through their interpretation of literature, and usually, are sanc-
                                                                                               tioned'bythe American Conference of Governmental Ind'ustriallHygienists . No
               ferred to be present in ETS„ but their presence                                 constituent of ETS has been measuredlih our every-day envinonmentiat levels
               has not been confirmed by actual detection or                                   that exceed the threshold limit'walues permitted in the workplace .




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               stituents of ETS have been impossible to evalu-                 pared to "like ." Mainstream smoke and the
               ate directly . In broad terms ; two different                   residual constituents of ETS'represent very dif-ferent exposure conditions
               approaches have been employed in an attempt                                                                                                . Whether present in
               to assess indirectly the health risks for expo-                 mainstream smoke or in ETS, particulate phase
               sure of the nonsmoker to the environmental                      and gas phase constituents have very different
               remnants of ETS. The first of these involves a                 biological properties, as well, as different physi-
               theoretical concept that is called "linear risk                cal and chemical characteristics, and any asso-
               extrapolation ." Linear risk extrapolation has                  ciated health risks are also very different . The
               been employed extensively in attempts to deter-                concept of linear risk extrapolation for ETS' is
               mine the risk for lung cancer in nonsmokers                    based on a theory that when applied to ETS'
               exposed to ETS .3                                              incorporates unsound assumptions that are not
                  This concept of linear risk assumes that if                 valid . There is no way, as yet, to evaluate or
               there is a definable health risk for the active                compare the levels of exposure in active smok-
               smoker, then~ there also must' be a projected                  ers and nonsmokers exposed to ETS . .
               lower health risk for the nonsmoker exposed to                        The second approach used to evaluate health
               ETS . This is represented schematically in                     risks for nonsmokers exposed to ETS has
               Figure 2 : The risk has been presumed to be lin-               employed epidemiologic studies . Epidemiology
               ear from~ the active smoker to the nonsmoker                   is a branch of medical science that studies the
               exposed to ETS, based proportionately on the                   distribution of disease in human populations
               relative exposure levels and retained doses of                 and the factors determining that dist'ribution,,
               smoke ; it thus requires some measurement of                   chiefly by the use of statistics . The chief func-
               tobacco smoke exposure for both groups . This is
               fairly easy to achieve in the active smoker, in                3The concept1s based on a theoretical extrapolation of the risk for lung cancer
               part because mainstream smoke has been so                      in the active smoker to the risk for ; lung cancer in the passive smoker, on thee
                                                                              basis ofia "representative marker" for both smoke exposures . This "linear risk
               well-characterized and it is delivered directly                extrapolation" from one to the other is a model that istiased on mathematical I
               from the butt-en& of the cigarette into the                    theory and on several assumptions . The theory assumes thatithe risk applies
                                                                              to all exposure levels, even ifithey are very low. Some : advocates of the model l
               smoker . Su& is obviously not the case, howev-                 even assume a "one molecule, one hit"' mechanism, where exposures so low
               er for the nonsmoker exposed! to ETS .                         thatRhey cannoUbe detected or measured can stilllcause disease if only a sin-
                                                                              gle molecule reaches a vulnerable body tissue . The linear risk theory also
                  Most projections of linear risk for ETS-expo-               assumes that1he risk for accumulative exposure remains constant and, thus„
               sure have been based on the use of nicotine as a               that the exposed individual has no capacity to adaptor develop tolerance
                                                                              mechanisms for the exposure . Since active smokers readily and rapidty devel-
               representative marker of exposure . A few pro-                 op tolerance through a variety of defense mechanisms, iUseems illogical to
               jections have been based on carbon monoxide                    assume those repeatedly exposed to ETS would not do thesame . The linear
                                                                              risk model assumes that~ the risk fon exposure to ETS is ind@pendent of any
               levels or amounts of respirable suspended par-                 confounding factors . Finally, for this theory to be valid, it must be assumed
               ticulates in the environment, but these                        thatAhe risk is linear for duration of exposure and that it is linear for concen-
                                                                              tration ~of exposure : None of these assumptions holds true on scientific testing
               approaches are fraught with even greater error .               for comparative projections of mainstream smoke to ETS .
               Since nicotine initially is in
               the particulate phase of the
               mainstream smoke inhaled by                               Figure 2 : Linear Risk Extrapolation*
               the active smoker and it is
                                                         5 .0-r
               present primarily as a highly
                                                    a
               diluted gasrphase remnant or
               residual vapor-phase con-
                                                                      No Threshold
               stituent in the nonsmoker's                            One Molecule Theory
               environment, the concept of a
               linear health risk from the
               active smoker to the nonsmok-
               er is based on rather shaky
               scientiflc-reasoning .
                  That is to say, it is not valid
               to estimate a health risk for
               exposure : to the particulate                         r                                                                                                  T

               phase in the active smoker                                              2.0 4.0 6.0 8.0                                                                 10
               and then compare it with, the                                            Relative Enviroemental Exposure Level
               health risk for exposures to         'The concept of linear risk extrapolation In this theory ; the health response (expressed as a rela-
               the gas phase in the ETS-            tive risk) is directiy or linearly reiated to the relative envPronmental exposure level . This theory sug-
                                                    gests that there is'no "safe" threshold'below which there is no respunse, and that exposure to as
               exposed nonsmoker . Simply           little as one molecule of the environmental substance can cause an adverse response .
               stated, "like" is not being com-




http://legacy.library.ucsf.edu/tid/ayx71f00/pdf
                                                                    tion are based on the concept of some measure-
                "Of the 30 ETS-lung cancer stud-                    ment of relative risk . None of the studies actu-
                ies, 6 reported a statistically                     ally has measured exposure to ETS or to any of
                significant association . . . and                   its residual constituents directly. Relative risk
                                                                    is a relationship of the rate of the development
                24 of those studies reported no
                                                                    of a disease (such as lung cancer) within a
                statistically significant effect ."                 group of individuals exposed to some variable
                                                                    in the population studied (such as ~ ETS) divided
                                                                    by the rate of the same disease in those not
              tion of epidemiology is the identification of pop-    exposed to this variable .
              ulations at high risk for a given disease, so tliat      Relative risk is most frequently expressed as
              the cause may be identified and preventative          a "risk ratio," which is a calculated comparison
              measures implemented .                                of the rate of the disease studied in the exposed
                Epidemiologic studies are most effective            population divided by the rate of that disease in
             when they can assess a well-defined risk .             some control population not exposed to the
             Because ETS-exposure levels cannot be mea-             variable studied. The terms "risk ratio" an&
             sured or in any other way quantified directly,,        "relative risk" are often used synonymously.
             even by representative markers, epidemiolo-            Thus, the relative risk in all epidemiologic ETS
             gists have had to use indirect estimates, or sur-      studies on lung cancer is expressed as the rate
             rogates, of ETS exposure . For nonsmoking              of lung cancer in the ETS-exposed group (indi-
             adults, the number of active smokers that are          viduals married to a household smoker) divided
             present in the household has been used as a :          by the rate of lung cancer where there was no
             surrogate for ETS exposure . Usually the active        ETS exposure (no household smokers) . If thee
             smoking household member has been the non-             disease rates were exactly the same in these
             smoker's spouse . With a few limited exceptions,       two groups ; the risk ratio would! be 1 .0 .
             disease rates in~ nonsmokers exposed to a                 There have been 30 epidemiologic studies on
             spouse who smokes have been the basis for all          spousal smoking and lung cancer published in
             epidemiologic assessments .                            the scientific literature . Twenty-seven of these :
                Almost all of these studies have evaluated          epidemiological studies were case control stud-
             nonsmoking females married to a husband who            ies, where the effect of exposure to spousal
             smokes . For children„ the surrogate for ETS           smoking was evaluated retrospectively on data
             exposure has :been the number of parents in the        that had already been available for review . The
             household! who smoke . Estimates of ETS expo-          "cases" in these case-control studies were non-
             sure based on spousal or parental surrogates           smoking individuals with lung cancer married
             have been derived by various questionnaires ;          to smokers . The rate of lung cancer in these
             no study employs any direct quantification of          "cases" was compared, by the derived risk
             ETS or of ETS remnant constituents in the              ratio, to the rate of lung cancer in "control" or
             actual environment' of the nonsmoker .                 nonsmoking individuals who were married to
             Questionnaires of smoking habits are notori-           nonsmokers .
             ously lilmite& and often inaccurate, in part             Three of the studies followed cohort popula-
             because of the "social taboo" that smoking has         tions of individuals exposed to spousal smoking
             become and, in part, for other reasons related         prospectively over the course of time . A
             to the ETS social movement . Nevertheless, data        "cohort" is any designated group of people . A
             from questionnaires about smoking behavior in          "cohort study" identifies a group of people that
             spouses or in parents are the only estimates of        will be exposed to a risk and a group that will
             ETS exposure available . Rates for three dis-          not be exposed to that risk, and then follows
             eases in nonsmokers expose& (via surrogates))          these groups over time to compare the rate of
             to ETS have been assessed : lung cancer, coro-         disease development as a function of exposure
             nary heart disease, and respiratory illness in         or no exposure .
             infants and small children . Only lung cancer            The first studies were published in 1982 and
             will be discussed in this article .                    the last studies were published in 1990 . The
                                                                    studies originate broadly from different parts of
                                                                    the world and, for the most part, involve evalu-
             ETS and Lung Cancer                                    ations of lung cancer in nonsmoking females
               What is the state of evidence on ETS and             married to a smoking male partner ; eight of the
             lung cancer? Almost all of the epidemiologic           studies have limited data on nonsmoking males
             studies that are available to answer that ques-        married to smoking females . Some of the stud-




http://legacy.library.ucsf.edu/tid/ayx71f00/pdf
               ies are quite small, listing fewer than 20 sub-               the .30 epidemiologic studies on ETS and lung
               jects ; others are based on larger populat'ions,              cancer, there are 37 different total reported
               with four studies reporting between~ 129 and                  sets of risk ratios for male or female nonsmok-
               189 cancer cases . Of the 30 studies, six reported            ers . None of the studies reports a strong rela-
               a statistically significant association (identified           tive risk .
               by a positive relative risk ratio in the spousally-              Nine of the studies report risk ratios of less
               exposed to the non-exposed population) and 24                 than 1 .0 . Thus, the results, from all epidemio-
               of the studies reported no statistically signifi-
               cant effect . The : average esti-
               mated relative risk ratio for
               each, study and each sex is list-                        Table 2: Studies of ETS
               ed in Table 2, as are the confi~-
               dence intervals reported by the
                                                                        and Lung Cancer in Nonsmokers
                                                                                                                       951/0
               authors or, where not reported,                                                Number Relative Confidence
               calculated by others in pub-           Study Sex of Cases Rlsk* Intervai
               lished review artieles .41
                                                      Case Control Studies
                   Some of the .negative studies=
                                                         Chan and Fung, 1982             F      34       0 .75    (0.43, 1 .30)
               that is, some of the 24 studies
                                                         Trichopoulos et ai .,1983       F      38       2 .18** (1 .18, 3.83)
               that did not show a statistically         Correa et a11,1983              F       14      2 .07    (0.81, 5.26)
                significant association between,                                         M        2      1 .97    (0.38, 10.29)
               the development of lung, cancer           Kabat and Wynder, 1984          F       13      0 .79    (0 .25, 2 .45)
               and exposure to spousal smok-                                             M        5      1 .00    (0 .20, 5 .07) .
                ing-contained data that sug-             Buffler et al ., 1984           F       33      0 .80    (0 .34, 1 .81) .
                gested to the aut'hors or to other                                       M        5!     0 .51    (0 .15, 1 .74)
                                                         Garfinkel et a1 .,1985          F       92      1 .12    (0 .94, 1 .60)
                reviewers a "positive trendl" In
                                                         Wu et a1 .,1985                 F       29      1 .20    (0 .50, 3 .30)
                most of'science,, "trends"' do not       Akiba et a1.,1986               F       73      1 .52    (1 .00, 2 .5),
                count ; data stand as either sta-                                        M        3'     2.101    (0 .5, 5 .6)'
                tistically significant or not sta-       Lee et ai .,,1986               F       22      1 .03    (0 .37, 2 .71)
                tistically significant', with sig-                                       M        8      1 .31    (0 .38, 4 .59)
                nificance determined by specif-          Brownson .et a1 .,1987          F       19      1 .68    (0 .39, 2 .97)
                ic accepted rules of biostatis-          Gao et ai .,1987                F      189'     1 .19    (0:6, 1'.4) .
                                                         Humble et al ., 1987            F       14      1 .70    (0 .6, 5 .4)
                tics . New rules should not be
                                                         Koo et a1 .,1987                F       51      1 .55    (0.87, 3 .09)
                "made to fit" an otherwise
                                                         Lam et al ., 1987               F      115      1.65** (1 .16, 2,35)
                unproved! hypothesis, ju~st               Pershagen et al .,1987         F       33      1 .20    (0.70, 2.10)
                because the subject is tobacco           Geng et al .,,1988              F       34      2 .10 *' (1 :03, 4.53)
                and the observed results do not           Inoue and Hirayama, 1988       F       18      2.55     (0.91, 7.10)
                support the hypothesis investi-           Katada et a1 .,1988'           F       17        -        (NS;p=0 .23)
                gated .                                   Lam and Cheng ;,1988           F       37      2 .01** (1 .12, 1 .83)
                                                          Shimizu et ai1,1988            F       90       1 .10         W/A
                                                                           He,, 1990                                    F         45             0 .74          (0 .32, . 1 .68)
                                                                           Janerich et a1.,1990                         F         129            0.93           (0 .55, 1 .57)
                ETS Risk Weak                                              Kabat;1990                                   M          13            1 .20          (0.54, 2.68)
                  A relative risk is called' strong                                                                     F         35             0.90 `         (0 .46, 1 .76)
                or it is called weak, depending                             Kaiandidi et ai:,1990                       F         91             2 .11          (1 .09, 4 .08) `
                on the degree of association, or                            Sobue et a1 .,1990                          F         64             0.94           (0 .62, 1 .40)
                the magnitude of the risk ratio .                           Svensson, 1990                              F          17             1 .20         (0 .40, 2 .90)
                A strong, relative risk would be                            Wu-Wiiliams et at .,1990                    F         205             0.7           (0 .6, 0 .9)
                reflected by a risk ratio of 5 to
                                                                        Cohort Studies
                20 or greater . Weak relative                                                                           F                         1 .17         (0.85, 1 .89)
                                                                           Garfinkel, 1981                                         88
                risks, by conventional defini-                                                                                                                  (0 .77, 1 .61) '
                tion, have risk ratios in the                               Gillis et al ., 1984                        F          6              1 .00         (0 .59, 17 .85)
                range of 1 to~ 3' or so . Within                                                                        M          4              3 .25
                                                                            Hirayama, 1984b !                           F         163             1 .45         (1 .04 2 .02)
                4A confidence interval is a range of valVresth'at has                      1984a                                   7              2.28**        (1 .19 4 .22)
                a specifiedlprobability of including the true value .
                (as opposed to the estimated average value) withih      `Weak relative risks have risk ratios of between 1 and 3, or so . Any risk ratio below 1 represents a'lieya-
                that range . In the data presented in Table 2, the,     tive retationship. Note that!none of the studies sdwwa strong relative risk .
                confidence intervals are set such that there is a
                                                                        "' StatisticaHy significant'at the 5a level .
                95% probability that1he true value will falJ within
                the range of values listed .




http://legacy.library.ucsf.edu/tid/ayx71f00/pdf
               Smoke . . . .                                               "No matter how these [risk]
                                                                           data are analyzed, no one has
                                                                           reported a strong risk relation-
                logic studies consistently reveal only weak lung
                cancer risks for nonsmokers exposed to spousal             ship for exposure to spousal
                smoking, with only six of the studies reaching             smoking and lung cancer."
                statistical significance ; 24 epidemiologic studies
                report no statistically significant effect for ETS
                exposure .                                              the American Health Foundation, stated that
                  Weak relative risks, however, do not exclude          when an assessment of relative risk is weak
                causal relationships . When the relative risks          (that is,, when the odds risk ratios are in the
                are weak it is very difficult to determine if the       range of 2 to 1 or less) the possibility exists
               effect is artifactual or if it is real . Weak associa-   that the finding is artificial and a consequencee
               tions are close in magnitude to a ; level of risk        of problems in the case control! selection or is
               that is sometimes called "background noise,"             due to the presence of confounders (or con-
               and at this level of risk there are variables            founding variabl'es) and interpretation biases
               other thani the one studied that can influence           which need to be carefully considered .
               the statistical association .                            Confounding variables must be controlled in
                  When a series of epidemiologic studies                order to obtain an undistorted estimate of the
               reveals consistently weak associations that              effect of a study factor, such as spousali smok-
               sometimes individually reach statistical signifi-        ing, oni risk . This is especially true when the
               cance and sometimes do not, all of the data can          studied risk factor has a weak association .
               be pooled into a more comprehensive assess-                 At least 20 confounding factors have been
               ment to enhance : the confidence of the : assess-        identified as important to the development of
               ment . This is called a " m eta- analysis ." There       lung cancer . These include : nutrition and
               are specific rules, however, for combining data          dietary prevention, exposure to occupational
               and not every published study lend's itself to           carcinogens, exposure to various air pollution
               this kind' of assessment . The National Research         contaminants, genetic predisposition and fami-
               Council concluded, in 11986, that 13 of the then         ly prevalence, circulating beta-carotene levels
               available studies met criteria that would permit         (as well as vitamin E and vitamin A levels), his-
               a combined meta-analysis risk assessment .               tory of alcohol consumptions exposure to alpha
               When the data from these 13 studies were com-            emitting radiation (such as radon daughters),
               bined, the net relative risk from all available          geographical residence : and country of origin,
               studies was represented by a risk ratio of 1 .34 .       presence or absence of selenium and other trace
               The risk ratios as the result of other adjusted          metals, healthy versus unhealthy lifestyles,
               meta-analyses available for review vary from,            age, gender, housing conditions, race, marital
               1 .08 to 1 .42', with generally lower values             status, ethnicity, socio-economlc status, diag-
               derive& from population studies in the United            nostic crit'eria, and perhaps most importantly
               States and with somewhat higher levels of risk           of all, an enhanced clustering of risk factors .
               derived on populations outside of the United             Thus, a large number of confounding, variables
               States .                                                 are important to any consideration of spousal
                  No matter how the data from all of the epi-           smoking and lung, cancer,, and no reported!
               demiologicall studies are manipulated, recalcu-          study comes anywhere close to controlling, or
               lated, "cooked',"' or "massaged," the risk from,         even~ mentioning, half of these .
               exposure to spousal' smoking and lung cancer
               remains weak . It may be 1 .08' or it may be 1 .34
               or it may be 1 .4!2, but all of those still represent    Is ETS a Health Hazard?
               a weak relative risk . No matter how these data             Does exposure to the remnants or residuall
               are analyzed, no one has reported a strong risk          constituents of ETS' represent a legitimate
               relationship, for exposure to spousal smoking            health hazard to the nonsmoker? In consider-
               and lung cancer . Combining all the data from            ing spousal smoking, lling cancer, and the con-
               all epidemiological studies does not result in an        founding factors, Lindal Koo, at the University
               enhancement of the relative risk-the risk for            of Hong Kong, cautioned that it may not be the
               lung cancer with, exposure to spousal smoking,           hazards of tobacco smoke that are being evalu-
               is weak .                                                at'ed, but a whole range of behaviors~t'hat result
                  In addressing this problem, Ernst Wynder, of          from : having a smoking husband, which may, in




http://legacy.library.ucsf.edu/tid/ayx71f00/pdf
                                                                     ll     Has there been a "misrepresentation of sci-
                 "Unfortunately, scientific data                          ence" in the common perception of ETS today?
                 have not always been utilized                            Active tobacco smoking and environmental
                                                                          tobacco smoke are controversial, very emotion-
                 objectively by governmental
                                                                          al, and highly politicized subjects . In the quag-
                 agencies or regulatory bodies                            mire of ETS forces operative in politics, emo-
                 that have their own inherent                             tion, and science, it has been difficult to sort
                 public health or political                               out scientific fact from unsound conjecture .
                 agenda ."                                                Unfortunately, scientific data have not always
                                                                          been utilized objectively by governmental agen-
                                                                          cies or regulatory bodies that have their own
               turn, increase the risk for certain diseases               inherent public health or political agenda . Good
               among the wives and children . Indeed', con-               science ultimately must rest on established
               founding variables are always present and they             proven scientific methods, and the full results
               are so numerous and so complex that they may               generated'. by these scientific methods . When
               make it impossible ever to know the true risk              these methods are compromised, scientific
               for lung cancer in nonsmokers exposed to                   integrity is lost and society pays the price .
               spousal smoking.                                           Interpretations and judgments may vary, as a
                 Are the studies on the projections of levels of          function of an investigator's bias or to expedite
               ETS residual constituents in our environment,              one or another political, social or emotional
               and the studies on the spousal smoking and                 objective .
               lung cancer, a reflection of "bad' science?" Not             Richard Lindzen, of the Massachusetts
               necessarily, for they are the best science that i&         Institute of Technolbgy„ has emphasized that
               available today . Sir Bradford Hill of Oxford              problems will arise where we will need too
               University cautioned years ago that it is impor-           depend on scientific judgement, and' by ruining
               tant to remember that all science is subject to :          our credibility now we leave society with a
               being reinterpreted or to being changed and                resource of some importance diminished . The
               modified by advancing knowledge . As newer                 implementation of public policies must be base&
               technologies are applied to the assessment of              on good science, to the degree that it is avail-
               environmental tobacco~ smoke, clearer under-               able, and not on emotion or on political needs .
               standings will evolve .                                    Those who develop such policies must not stray
                                                                          from, soun& scientific investigations, based only
                                                                          on accepted scientific methodologies . Such has
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                                                                                  ESTABLISHING A

                                                                                  WOAAP1 aL1V.G
                                                                                  SMOKING POLICY


                                     SECTION TWO :

                                    Health Allegations about ETS

                                    Much of the concern about smoking in the workplace stems from
                                    claims that ETS causes lung cancer and other diseases in
                                    nonsmokers . Before establishing and implementing a policy that
                                    will have a significant impact on the smokers in their workforce,
                                    employers should review and evaluate these claims .

                                    Much of the recent discussion on the relationship between ETS and
                                    nonsmokers' health has been prompted by the media coverage
                                    surrounding the release of two draft documents prepared by the
                                    Environmental Protection Agency (EPA) . Using statistical
                                    methodology, the draft documents estimated that about 3,700
                                    nonsmokers die each year from lung cancer caused by exposure to
                                    ETS . To date, the reports have not been adopted as official agency
                                    policy. The EPA is therefore tasked with redrafting the ETS'
                                    documents in an effort to address some of the issues that were
                                    raised by its own scientific advisory board .

                                    The following article discusses health allegations about ETS from
                                    a perspective that rarely gets media attention . Employers should
                                    consider this information in determining whether to implement a
                                    smoking policy and, if so, what kind of policy to implement .




                                                             Page 8 April 1992



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                                                                                  ESTABLISHING A

                                                                                  WORKPLACE
                                                                                  SMOKING POLICY


                                    SECTION, THREE:

                                   "Social Costs" of Smoking

                                   There are claims that smoking imposes "social costs" on our nation
                                   and, specifically, on employers . These "costs" are based upon
                                   allegations that smokers are less productive than nonsmokers, that
                                   they have higher absenteeism rates and use health-care programs
                                   more than nonsmokers . This argument has been the basis for the
                                   imposition of excise taxes on tobacco products, higher insurance
                                   premiums for smokers and workplace smoking bans . Employers
                                   have sometimes used this theory as justification for the exclusive
                                   hiring of nonsmokers and the dismissal of employees who smoke
                                   outside the office on their own time .

                                   For a number of'reasons discussed below, the position that there
                                   are "social costs" attributable to smoking should be carefully
                                   examined before using such theories to justify smoking bans or
                                   other discriminatory treatment of smokers .

                                   • The "social cost" concept, if applied to smoking, can
                                         likewise be applied to many types of behavior . It can be
                                         argued that if employers use employment as a means to
                                         regulate employee behavior, then other lifestyle choices
                                         should also be addressed - such as obesity, hazardous leisure
                                         activities and consumption of alcohol (which have been
                                         correlated to higher health care costs) .

                                   • Claims that smokers are less productive than
                                        nonsmokers have not been substantiated ; some surveys
                                        suggest the opposite . In a survey of union representatives
                                        and government and business supervisors by the
                                          independent research firm Response Analysis Corp ., 74
                                          percent said smoking during scheduled work breaks has no
                                          significant effect on job performance . A 1984 survey of
                                          Minnesota bank executives actually found that smokers were
                                          more productive than nonsmokers .



                                                            Page 9 April 1992

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                                           It is important to carefully examine how "lost productivity"
                                           is defined . For example, if a worker retires at age 55, do the
                                           next 10 years amount to "lost productivity?" If a smoker
                                           skips a coffee break or doubles his work output during an
                                           hour so that he can go to the smoking lounge for a cigarette
                                           break, is that a net loss or gain in productivity ?

                                    • Smokers as a group have not been shown to have higher
                                         absenteeism rates as a result of their smoking than
                                         nonsmokers . A 1989 study by the National Chamber
                                         Foundation reached that conclusion . "The study found that
                                         there was no association between .. . tobacco use and work
                                         loss . The insignificance of the smoking variable was .. .
                                         surprising . Smoking has received widespread public
                                         disapproval in recent years . .. . Notwithstanding this, it had
                                        no statistically significant effect on work loss," according to
                                         the study.

                                           Other economists have criticized the theory that smoking
                                           results in absenteeism because it is simplistically used as a
                                           single criterion without correcting for job type, gender, job
                                           satisfaction and-other factors . In fact, the possibility exists
                                           that banning smoking may increase job dissatisfaction
                                           among smoking employees and may therefore increase
                                           absenteeism, rather than decrease it .

                                    • Assertions that smoking leads to increased health
                                         insurance claims have been challenged . Some insurers
                                         charge different premiums for smokers and nonsmokers, but
                                         they have done so "with little supportive actuarial
                                         experience that nonsmokers incur fewer claims," according
                                         to the 1989 Surgeon General's report .

                                           What may seem like a simple solution to the rising costs of
                                           health care - banning smoking, or not hiring smokers to
                                           begin with - may actually be precedent-setting. Since

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                                          married people tend to have higher health-care claims due to
                                          their family coverage, should only single people be hired?
                                          Since overweight people tend to have higher health-care
                                          costs, should only slender people be hired? Alcohol
                                          consumption? Family history of sickle-cell anemia?
                                          Cholesterol levels? At some point, employers will have to
                                          draw the line about delving into the private lives of their
                                          employees .

                                    • There is no reliable basis for claiming that smokers place
                                          an above-average demand on Medicare and Medicaid .
                                          Smokers as a group are very much underrepresented in their
                                          use of these programs . According to the Statistical Abstract
                                          of the United States (1987), 45 percent of Medicaid patients
                                          are children ; 15 percent of Medicaid beneficiaries and more
                                          than 90 percent of Medicare beneficiaries are over age 65 -
                                          an age group in which only 16 percent are smokers .




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                                                                                   ESTABLISHING A

                                                                                   WORKPLACE
                                                                                   SMOKING POLICY


                                   SECTTON' FOUR :

                                   What are an employer's legal obligations regarding workplace
                                   smoking?

                                   Two areas where legal issues are often raised in connection with
                                   workplace smoking are employment discrimination and liability .
                                   Employers should consult with their own legal counsel if they have
                                   questions on these, or any, legal issues related to workplace
                                   smoking.

                                   Some employers have cited the EPA's draft documents on ETS as a
                                   legal mandate that they must ban smoking or restrict it to
                                   separately ventilated lounges . It is important to note the EPA does
                                   not have the authority to regulate indoor air quality . In contrast,
                                   the Occupational Safety and Health Administration (OSHA) can
                                   set workplace limits, and has established thresholds for a variety if
                                   indoor air contaminants . To date, OSHA has not regulated
                                   workplace smoking, but it has issued a "Request information" on
                                   indoor air pollutants, including ETS, and may establish guidelines
                                   sometime in the future. Again, in all cases, employers should
                                   consult their own legal counsel to assess the impact these activities
                                   may have on their workplaces .

                                   Some trends have emerged in employers' liability regarding indoor
                                   air quality. Overviews of current legal trends in this area have
                                   been prepared . If your legal counsel would be interested in
                                   receiving some further information on this area, please indicate
                                   that on the enclosed reply card and return it to C .S .S .

                                   The American Civil Liberties Union, employee organizations, and
                                   even state legislatures have begun debating potential limits on an
                                   employer's ability to dictate an employee's legal off-hours
                                   behavior and lifestyle . Recent news reports about the advances
                                   made in the area of genetic testing are harbingers of the decisions
                                   that lie ahead for employers . How much do employers have the
                                   right to know about their employees' off-hours activities? How
                                   much control should an employer exert over those activities?

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                                   It is also important to check any municipal codes that apply to
                                   company facilities to see what local requirements exist for
                                   smoking policies . Some make no requirements at all, others
                                   require only that some form of a policy exist and be enforced, and
                                   some specify the type of policy that must be in place . Again, legal
                                   counsel should be consulted in this regard .

                                   State Legislation Prohibiting Lifestyle Discrimination

                                   For employers interested in employing only nonsmokers, there are
                                   both personnel considerations and legal limits in some states .

                                   Americans, by and large, don't like to be told what they can and
                                   cannot do in their own homes or on their own time . A 1989 survey
                                   by the National Consumers League found that more than 80
                                   percent of respondents opposed the firing of employees, or denial
                                   of employment to applicants, on the basis of legal off-work
                                   activities .

                                   As of May 1992, instances of employment discrimination against
                                   smokers have caused 40 state legislatures to consider legislation on
                                   the issue . To date, 25 have passed legislation protecting smokers
                                   from employment discrimination, most in the last two years .
                                   Following are the states with such legislation :

                                          Arizona                   New Mexico
                                          Colorado                  Nevada
                                          Connecticut               North Dakota
                                          Illinois                  Oklahoma
                                          Indiana                   Oregon
                                          Kentucky                  Rhode Island
                                          Louisiana                 South Carolina
                                          Maine                     South Dakota
                                          Minnesota                 Tennessee
                                          Mississippi               Virginia
                                          New Hampshire             West Virginia
                                          New Jersey                Wisconsin
                                                                    Wyoming

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                                   In Delaware, state government personnel policies prohibit
                                   discrimination against smokers .
                                   Typically, these state laws focus on the right to privacy . They
                                   prohibit employers from discriminating in hiring or terms of
                                   employment based on whether a person smokes off the job. Some
                                   of the laws are more broadly based, prohibiting discrimination
                                   based on any legal off-the job activity.

                                   The protections these laws afford smokers are not consistent from
                                   state to state . Some states provide exemptions for religious
                                   organizations and others that might have a conflict of interest .

                                   There is one consistency, however : These laws do not affect
                                   workplace smoking policies or employee compliance with those
                                   policies. The laws restrict only what employers may demand of
                                   employees during their non-working hours . It is important that
                                   employers contact their legal counsel for an assessment of the
                                   state's laws.

                                   Because state legislation changes quickly, you would be well
                                   advised to check whether your state has recently passed a bill
                                   prohibiting discrimination against smokers .




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                                                                                 ESTABLISHING A

                                                                                  WORKPLACE
                                                                                  SMOKING POLICY


                                   SECTION FIVE:

                                   Negotiating a Fair Workplace Smoking Policy

                                   Most individuals prefer accommodation of both smokers and
                                   nonsmokers in the workplace . A recent Gallup survey shows that
                                   69 percent of workers favored "setting aside certain areas" for
                                   smoking . Only 25 percent favored an outright ban of smoking in
                                   the workplace . Employers often overreact to employee requests
                                   for smoking restrictions by believing their only option is to ban
                                   smoking. Instead, a policy that provides designated smoking and
                                   nonsmoking areas will usually address employee concerns .

                                   Obviously, simple solutions to workplace smoking problems are
                                   the best for everyone : rearranging desks, using partitions,
                                   relocating smokers to be near exhaust vents and nonsmokers near
                                   fresh-air intake vents, opening windows, use of portable
                                   "smokeless" ashtrays and air cleaners, etc .

                                   If an employer has determined that a consistent smoking policy
                                   would help alleviate employee problems throughout the workplace,,
                                   there are several key elements that should be considered .

                                   Element 1 : Employee Involvement

                                   Most employees will accept a policy more readily if they play a
                                   role in its development . If employees' opinions have been
                                   considered, management will most likely hear fewer complaints
                                   after the implementation of the policy .

                                   Establishing a team for the development of a policy is often
                                   helpful . Such teams can be made up entirely of management
                                   representatives, but are best structured with members from both
                                   employee and management groups . The team should also
                                   represent smokers, nonsmokers, ex-smokers, and union
                                   representatives where applicable .




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                                    The first task of the team should be to gather information about the
                                    organization's needs and attitudes related to smoking in the
                                    workplace. This information should be gathered from the entire
                                    workforce, and not a select group . Often there is only a minority
                                    of nonsmokers who raise the issue of smoking in the workplace .
                                    Anti-smokers' positions should be equally balanced with those of
                                    smoking employees, as well as nonsmokers who are not totally
                                    opposed to smoking in the workplace .

                                    To gather information on employee needs and attitudes, a survey is
                                    helpful. Written, anonymous surveys are most effective, since
                                    some employees are uneasy about communicating with
                                    management. Surveys can be very brief and straightforward or
                                    very involved .

                                    It is often helpful to conduct a survey of your workforce in relation
                                    to broader issues of indoor air quality, rather than concentrating
                                    solely on smoking . This can not only help you determine .
                                    employee attitudes and preferences on smoking, but may help you
                                    identify other areas of concern as well .

                                    At the end of this section there is a sample survey . It is fairly
                                    comprehensive, and may include more information than you wish
                                    to seek .

                                    If you wish to do a survey focusing directly on smoking rather
                                    than on broader issues, we would direct your attention to questions
                                    25 through 29 . These ask for specific information on smoking .

                                    Whatever approach you take, it is, again, essential to involve
                                    employees in the policy development process, and determine as
                                    objectively as possible their attitudes and preferences .

                                    Note that question 15 on the sample survey can provide the
                                    employer with information regarding general indoor air quality
                                    problems . Should an employer find that employees indicate any
                                    problems with the quality of the workplace environment, Section
                                    Six of this kit will be beneficial .


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                                   The team may also want to enlist the help of the company's
                                   engineering staff or HVAC contractor to help assess the current air-
                                   handling system . Section Six includes a sample checklist of
                                   common HVAC evaluations .

                                   Element 2: Considering the Options

                                   There are several options to be considered when developing a
                                   workplace smoking policy . Often, employers use a combination of
                                   options to accommodate various employee populations and work
                                   areas . The key is to formulate a policy based upon options which
                                   are fair to both smokers and nonsmokers .

                                   • Open Smoking (permission to smoke an,ywhere in an office or
                                   facilit . Some companies will find that an "open policy" is fine for
                                   their operations . To them, common courtesy remains the best way to
                                   resolve issues of smoking in the workplace .

                                   The American Society of Heating, Refrigerating, and Air
                                   Conditioning Engineers (ASHRAE) Standard 62-1989 prescribes
                                   supply rates of acceptable outdoor air required for acceptable
                                   indoor air quality . "These values have been chosen to control C02
                                   and other contaminants with an adequate margin of safety and to
                                   account for health variations among people, varied activity levels,
                                   and a moderate amount of smoking ." A value of 20 cubic
                                    feet per minute has been prescribed for office spaces . This
                                   standard was developed from a consensus of engineers, architects,
                                   chemists, physiologists, product manufacturers and industry
                                   representatives .




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                                    • Separate Walled Areas for Smokers and Nonsmokers - Careful
                                      selection of the smoking areas with respect to the ventilation
                                      system ideally balances the needs of smokers and nonsmokers .
                                      Smoking can be limited to private offices or workstations, or
                                      designated areas of the facility .

                                      It is important to recognize that toilet or corridor areas designated
                                      as smoking areas may not provide efficient exhaust systems . Also,
                                      problems may arise with the designated smoking areas in a large
                                      building served by many separate air handling units . A
                                      concentration of smokers in an area served by one unit may exceed
                                      the capacity of the unit to dilute the more concentrated smoke,
                                      thereby moving more, not less, ETS to nonsmokers also served by
                                      the unit.
                                    • Separate . Unwalled Areas for Smoking and Non-smoking -
                                      Separating the workstations of smoking employees is another
                                      option that often works well . This kind of policy has
                                      the advantage of allowing smokers to stay at their workplaces and
                                      continue working as they enjoy a cigarette . It is quite convenient
                                      for nonsmokers, also, because they have easy access to their
                                      fellow employees, but are removed from cigarette smoke .

                                      Large areas such as cafeterias can provide for separate smoking
                                      and nonsmoking pafrons if the smoking area is located closest to
                                      the main ventilation return inlet .

                                    • Separate Smoking Lounges with Separate Ventilation- Some
                                      companies choose to establish smoking lounges . Under this
                                      arrangement, smoking is restricted to areas set aside specifically
                                      for smoking . The obvious advantage to this arrangement is that it
                                      ensures that nonsmokers will not be required to be around smoke .
                                      On the other hand, the success of this kind of policy frequently rests
                                      on the ready availability of the lounges, the aesthetics of the
                                      lounges themselves, and the attitude of the employee population .

                                      If a company has decided to establish a policy that allows smoking
                                      in lounges only, the employer may want to keep some
                                      considerations in mind to enhance the likelihood that the policy
                                      will be supported and accepted by employees .

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                                      Perhaps the most important factor is to make sure smoking
                                      lounges are convenient, accessible and properly ventilated .
                                      Poor selection or design of an area can result in more problems .
                                      It should be recognized that the selection of areas to be
                                      designated as smoking lounges will reflect on management's
                                      attitude toward the smoking employee . Further, if workers have
                                      to walk a great distance and be away from their regular
                                      workplace for too long, productivity may suffer .
                                      Smoking lounges should be sufficient in number, and located
                                      close enough that smokers can leave to enjoy a cigarette and
                                      return to their jobs within a reasonable period of time . It is also
                                      important that nonsmokers not have to walk too far to find a
                                      fellow employee who is in a smoking lounge.

                                      Consideration should also be given to design features that
                                      allow employees to continue working in the lounge if desired.
                                      For example, employees who have phone calls to return might
                                      do so from a smoking lounge equipped with several telephones
                                      while taking their cigarette "break ."

                                      It is also a good idea to furnish the lounge with desks or tables
                                      and chairs, and even computers, so employees can more easily
                                      work. Again, productivity will be higher, and smokers will feel
                                      better about going to the lounge, if they can continue working
                                      there .

                                      Racks of literature on your industry - trade publications and
                                      magazines, for example - might be available to smokers in the
                                      lounge so that they can stay abreast of the latest developments
                                      while smoking a cigarette . Assign one person responsibility for
                                      replacing outdated periodicals . Employers who have offered
                                      periodicals in their lounges have found racks to be helpful - they
                                      keep materials organized and avoid piles of magazines from
                                      being scattered around the room .




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                                     The decor and furnishings of the lounge say a lot to employees
                                     about the way they are perceived by management . If it is
                                     furnished with cracked, broken old furniture, it tells smokers
                                     they are not highly valued in the organization . Tasteful
                                     furnishings and decorations send quite a different message .

                                     Lighting should be equal to that of work areas . This not only
                                     makes it possible for the employees to work in the lounge, it also
                                     makes the lounge more attractive and pleasant for the
                                     employees .

                                     Ashtrays should be numerous, sturdy and of a large capacity so
                                     they will not have to be emptied too often, and so they will not
                                     spill. Glass or metal ashtrays are probably the best table-top
                                     choices, or employers may prefer to use free-standing floor
                                     ashtrays . Trash cans in the room should be metal.

                                     Maintenance is also important. Ashtrays should be emptied and
                                     the lounges cleaned daily. Pictures or other wall decorations
                                     should be covered with glass for ease of' cleaning.

                                     The location of the lounge also sends a clear message to your
                                     employees . Rather than consigning them to a dingy, small room
                                     in the basement of the building, try to find a space that is
                                     conveniently located, well-ventilated, and properly sized for the
                                     number of employees who are expected to use it . If possible,
                                     select a room that has an outside wall with a window so that
                                     fans or other ventilation can be added later if necessary.

                                     Developing a smoking lounge need not be excessively expensive
                                     or difficult . Tests have shown that conventional air distribution
                                     with an exhaust fan can be used to properly ventilate a smoking
                                     lounge . (If you are interested in receiving details on smoking
                                     lounge tests, please return the enclosed reply card to C .S .S.)

                                     Ventilation rates in tests conformed to the American Society of
                                     Heating, Refrigerating and Air Conditioning Engineers
                                     (ASHRAE) Standard 62-1989 for a smoking lounge . This


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                                    standard prescribes 60 cubic feet per minute of transfer for each
                                    occupant, all of which is exhausted to the outside of the building .

                                    The arrangement of air distribution tested which resulted in the
                                    greatest acceptance by smokers is conventional overhead air
                                    supply with air diffusers discharging toward the walls, away
                                    from the center of the room . Transfer was brought in through
                                    the ceiling on one side of the room . The exhaust rate exceeds
                                    supply, thus insuring that the room remains at a lower pressure
                                    than the surrounding areas, and not permitting smoke and odors
                                    to infiltrate the surrounding areas . This arrangement lends itself
                                    to economical retrofitting of an existing space into a smoking
                                    lounge.

                                    Again, if you would be interested in further information on how
                                    to develop a smoking lounge, or additional details on the results
                                    of smoking lounge tests, please return the enclosed reply card to
                                    C.S.S .

                                    Keeping the smoking lounge a productive part of the work
                                    environment will aid in employee morale . If nonsmoking
                                    employees perceive that smokers take more breaks than they do,
                                    resentment will follow . If smokers feel guilty over having to
                                    leave their work to go to the smoking lounge, their j ob
                                    satisfaction is likely to suffer . Following these simple, common-
                                    sense guidelines will pay big dividends in terms of employee
                                    support of a decision to provide smoking lounges .

                                  Element 3 : Development of the Policy

                                  After careful review and selection of policy options, the team
                                  should formulate a written policy .

                                  The team may want to talk to other organizations and individuals
                                  that have successfully implemented similar policies . Section
                                  Seven contains sample smoking policies already in force at other
                                  companies . These companies have reported high employee
                                  satisfaction with the policies following implementation . It is
                                  possible that a company could simply adapt one of the sample

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                                    policies which best suits its needs-saving the time of "reinventing
                                    the wheel ." Before instituting any policy, however, it is imperative
                                    that corporate legal counsel be consulted to ensure that the policy
                                    complies with applicable local and state statutes .

                                    Element 4 : Implementing the Policy

                                    The most effective policies are those which are planned and
                                    implemented in an organized manner . Policies should be clearly
                                    announced to the employee populations well before the
                                    implementation date . Give employees at least one month - and
                                    preferably longer - to become familiar with the policy . Publish the
                                    policy in an employee handbook and let future job applicants know
                                    what the company's policy is . Further, top management should
                                    openly support the policy.

                                    After the policy is implemented, keep the employees in the loop -
                                    tell them the percentages who supported the various decisions, and
                                    the procedures followed by the policy development team . When
                                    employees believe they have been part of the solution, they are
                                    more inclined to make it work for them .

                                    It is for this reason that many companies have elected to permit
                                    employees in each work area to decide what policy best meets their
                                    wishes . In such cases, management has acted in an advisory
                                    capacity - making suggestions on workstation configurations,,
                                    scheduling follow-up assessments to be sure the policy suits the
                                    employee group, etc . Once implemented, employees should be
                                    given the opportunity to express their opinions about the policy, on
                                    a regular basis, to determine if changes are necessary .




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                                                               SAMPLE SURVEY



                                    1 . What is your job title?



                                    2 . Briefly describe your primary job tasks




                                           What is the location of your workstation in the building
                                           (floor, wing, room number, etc .)?



                                    4 . What type of workstation do you have (check one)

                                                  enclosed office with a door

                                                  cubicle with full-height partitions

                                                  cubicle with mid-height partitions

                                                  open office area

                                                  industrial processing area

                                                  laboratory
                                                                                                      N
                                                  Other (please specify)
                                                                           :                     N
                                                                                                  4P
                                                                                                  N
                                                                                                  N
                                                                                                  tz
                                                                                                  ~
                                                                                                  ~
                                                                                                  IQ
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                                    5. How many persons are at your workstation?

                                                   single occupant

                                                   one additional person

                                                   two or more additional persons



                                    6 . How many hours, on average, do you spend at your

                                    workstation?



                                    7 . How many years have you been located at this workstation?




                                     8. What time do you arrive at work?

                                           What time do you leave?



                                     9 . Are any of the following located at your workstation?

                                                   portable fan

                                                   portable humidifier

                                                   portable air cleaner or negative-ion generator

                                                   portable heater

                                                   desk lamp

                                                   live plants

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                                          10. How many hours per day, on average, do you use the
                                          following?

                                                  computer

                                                  phot'ocopy machine

                                                  printing processing

                                                  glues, adhesives

                                                  cleaning products

                                                  other chemicals (please list)




                                    11 . Have there been any of the following changes in your
                                           workstation in the past year?

                                                  new carpeting

                                                  new draperies

                                                  new furniture

                                                  new office equipment

                                                  new paint




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                                    12 . Has there been any water damage to your work area over
                                           the past year?

                                                  yes

                                                  no

                                                  don't know



                                    13 . Have you ever noticed any water leaks from the ceiling,
                                           pipes, walls, or floors in your work area?

                                                  yes

                                                  no

                                                  don't know



                                    14 . In the past year, have the conditions in your work area

                                                  improved

                                                  become worse

                                                  stayed the same




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                                     15 . Please indicate how often, if at all, you have experienced
                                            each of the following symptoms while working in the
                                            building?
                                                                                              Symptom
                                                                                              goes away
                                                                                              when not
                                                     Never Rarely Sometimes Often Always at work
                                         headache
                                           nausea
                                       runny nose
                                 sinus congestion
                                         sneezing
                                        coughing
                              shortness of breath
                                   chest tightness
                                   dry/itchy eyes
                               sore/strained eyes
                                    burning eyes
                                       sore throat
                                       hoarseness
                                        dry throat
                                            chills
                                  unusual fatigue
                                      racing heart
                     problems with contact lenses
                   pain or stiffness in upper back
               pain or numbness in shoulder/neck

                                   dry/itchy skin
                       dizziness/light-headedness
                             nervousness/anxiety




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                                    16 . When do these problems occur?

                                                  morning daily

                                                  afternoon specific day(s) of the week

                                                  all day Which days?

                                                  no noticeable trend



                                    17 . Do you have any health problems or allergies which might
                                           account for any of the above symptoms?

                                                  yes

                                                  no



                                    18. Do the above symptoms appear more frequent or severe
                                         during any season or seasons?

                                                          Yes           No

                                           Winter

                                           Spring

                                           Summer
                                           Fall




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                                   19. How often do the symptoms listed earlier reduce your
                                         effectiveness on the job?




                                   20 . How often do the symptoms cause you to stay home or leave
                                          work early?




                                   21 . If you indicated having experienced any of the symptoms
                                          while at work, have they :

                                                  improved over the last year

                                                  become worse over the last year

                                                  stayed the same over the last year

                                                  not applicable


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                                     22. In the last year, how often have you noticed any of these
                                           types of odors at your workstation?

                                                             Never Rarely Sometimes Often Always
                                             body odor
                                    cosmetics/perfumes
                                           tobacco odor
                                  musty or damp smells
                                  odors from new carpet
                           odors from engine exhaust
                                 printing machine fumes
                                 cleaning product odors
                           odors from glues/adhesives
                         other


                                     23 . How often is there a problem with the following at your
                                            workstation?

                                                             Never Rarely Sometimes Often Always

                                          air movement

                                           temperature
                                              humidity
                                             noise level
                                                  lighting

                                                    odors




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                                   24. Do any of the problems vary with the seasons?

                                                           Yes      No

                                          Winter

                                          Spring

                                          Summer

                                          Fall


                                   25 . How many employees in your immediate work area smoke?
                                                   none
                                                   1-5
                                                   6-10
                                                   11-50
                                                   more than 50



                                    26 . How many employees in your immediate work area do not
                                          smoke?




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                                    27 . Which of the following best expresses your thoughts
                                           regarding smoking at work? (check one)

                                                  Employees should use common courtesy and
                                                  cooperation to decide when and where it is
                                                  appropriate to smoke .

                                                  Employees in each work area should be free to
                                                  decide their own smoking policies.

                                                  There should be a company policy that designates
                                                  smoking and nonsmoking areas .

                                                  Smoking should only be permitted in smoking
                                                  lounges .

                                                  Smoking should be completely banned in the
                                                  workplace.

                                                  Other (please specify) :



                                    28 . What should the smoking policy be in each of the following
                                           areas?
                                                         No Workers Company Total
                                                         Restric- Decide Should Ban
                                                         tions Policy Set Policy

                                       private offices
                                     open work areas
                                    conference rooms
                                            cafeterias
                                         break rooms
                                           bathrooms
                                       other (specify)


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                                   29 . How would you classify your current smoking status?

                                                  current cigarette smoker

                                                  current pipe or cigar smoker

                                                  ex-smoker

                                                  never smoked



                                   30. How many times per week do you go outdoors during work
                                        hours?



                                   31 . How many times per week do you go outdoors primarily to
                                         get some fresh air?

                                   32. How is the lighting at your workstation?

                                                  much too dim

                                                  a little too dim

                                                  comfortable

                                                  a little too bright

                                                  much too bright




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                                   33 . Is there an outside window which can be seen from your
                                          workstation?

                                                  Yes

                                                  No



                                   34 . Describe in sets of three words or less, your overall opinion
                                          of the air quality, in your workstation :




                                    35 . OPTIONAL: Your Name

                                                             Office Phone Number




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                                                                                                                                       'SX1h901_r1NG POLICY


                                   SECTION SIX :

                                   Improving the Air Quality in Company Facilities

                                  Often, the presence of visible tobacco smoke is an indication of an
                                  overall indoor air quality problem . Experience has shown that
                                  complaints about smoking are indicative of inadequate ventilation .
                                  In addition, many of the symptoms reported to be caused by
                                  tobacco smoke are often still present following the implementation
                                  of smoking bans and other policies . In such cases, the symptomss
                                  may be related to high levels of other air contaminants and poor
                                  ventilation systems.

                                  Many of the symptoms frequently attributed to "sick building
                                  syndrome" have been shown to be linked to a variety of other, non-
                                  environmental factors as well . Therefore, it is important for
                                  managers to consider all potential causes of employee complaints
                                  rather than assuming indoor air quality is a problem .

                                  Studies conducted by Dr . Alan Hedge of Cornell University have
                                  shown many, of the symptoms frequently attributed to sick building
                                  syndrome are more directly linked to job-related factors such as
                                  stress, the amount of control one has over his or her job, and job
                                  satisfaction rather than to measured contaminants in the air .

                                  In other words, the mere presence of one or more symptoms may
                                  or may not indicate sick building syndrome is the culprit . It is
                                  prudent for managers to consider all potential sources of employee
                                  complaints before deciding on a course of action to address them .

                                  In the event an employee survey, such as that included in Section
                                  Five of this kit, or other complaints alert a company to the                                                                                      N
                                  existence of indoor air quality problems, thorough investigation                                                                                  CO
                                  should be conducted . The key to conducting an investigation is to                                                                                N
                                                                                                                                                                                    ~
                                  encourage employee involvement, and to identify locations, timesf of day, and types of problems that can be selected for further                  N
                                                                                                                                                                                    N
                                                                                                                                                                                    ~
                                                                                                                                                                                    ~I.
                                                                                                                                                                                    O
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                                   investigation by in-house engineers and outside consultants . The
                                   sample survey below can serve as a guide in compiling this
                                   information .

                                   If you believe that your workplace could benefit from an analysis
                                   by a professional indoor air consultant, there may be firms in your
                                   area qualified to provide you with assistance . It is advisable to ask
                                   for references prior to contracting with any firm . In addition, local
                                   environmental health agencies may be helpful in identifying
                                   qualified persons.

                                   l . The amount of fresh air coming into your HVAC system is
                                          critical. It reduces the build-up of chemicals and bacteria
                                          created by people, equipment and building materials . In
                                         previous years' energy "crunches", some fresh-air intakes
                                         have been closed completely; so that the air in the building
                                          is totally recirculated and could contain high
                                          concentrations of indoor contaminants.

                                                  Are fresh-air dampers properly sized and operated to
                                                  allow fresh air into the building?

                                                  Is your HVAC system cleaned quarterly (or more
                                                  often, depending on occupancy) to keep it free of dust,
                                                  mold and debris?

                                          The American Society of Heating, Refrigeration, and Air
                                          Conditioning Engineers (ASHRAE) has recently
                                          established an office standard of 20 cubic feet per minute
                                          per person for indoor ventilation rates . (Up from a
                                          previous standard of 5 cfm, which many buildings were
                                          designed for. If you work in such a building, it's likely that
                                          your air exchanges are too low.)

                                          In addition, many state and city building codes specify
                                          exchange rates. Some simply reference the ASHRAE
                                          standard . Check with your city building department for

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                                           minimum requirements in your town, and have your system
                                           checked .

                                                  Building meets ASHRAE standard of 20 cubic feet per
                                                  minute per person.

                                                  Building meets local building codes of cubic feet
                                                  per minute .

                                           Suggestions from contractor on increasing air flow through
                                           existing system :




                                    3. Some air conditioning systems turn the air-supply fan on and
                                          off by a thermostat similar to home systems . If the fan starts
                                          and stops, there is no outside air ventilation from that system
                                          when the fan is off. (Restaurants often use this type of
                                          control .)

                                                  Does the fan run continuously or is it cycled?

                                                  Can it be modified to run continuously?

                                                  Spraying for pests is best done at night or on
                                                  weekends, when most employees are not in the
                                                  facility . Is the fan set to run following application of
                                                  pesticides or cleaning solutions?

                                    4. Placement of the fresh-air intake dampers outside your
                                          building can affect the quality of the air being drawn into
                                          your building . Check to be sure the intake dampers are not
                                          located near :

                                                  garages, parking facilities, loading docks or any other
                                                  location where auto or diesel exhaust would be present .


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                                                  refuse containers or dumpsters .

                                                  chemical storage areas.

                                                  the exhaust fans from stoves, furnaces or other
                                                  combustion appliances.

                                          Some buildings have uneven air distribution - some areas
                                          are cold, some offices hot and stuffy . To improve this, you
                                          may need to reconfigure interior partitions, or relocate or
                                          install additional ductwork and supply and return air grilles .
                                          To make a simple check of where the air is going, tape strips
                                          of paper or tissue to the grille on the ceiling to make sure the
                                          air is flowing and the direction of the flow .

                                                  Is the temperature consistent in each area of the facility?
                                                                                                                W.
                                                  Do some rooms or areas seem "stuffy" or "stale"?

                                                  Are there return-air grilles located in the ceiling or
                                                  walls?

                                   6 . Many HVAC systems require filters . Check with your
                                         building maintenance office to see that they are changed on
                                         the schedule recommended by the manufacturer of the
                                         system. ASHRAE recommends a minimum filtration
                                         efficiency of 40 percent . Many ventilation experts
                                         recommend a filter efficiency of 60 percent or more .

                                                  Are the filters changed or cleaned on schedule?

                                                  Do they fit snugly, so no air bypasses the filter?

                                                  When was the filter chamber last vacuumed to remove
                                                  debris?

                                                  Are the grease filters on kitchen exhaust fans washed or
                                                  replaced regularly?

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                                          Bacteria, fungi and mildew love damp, dark ventilation systems .
                                          Any moisture sources, such as humidifiers or condensate pans
                                          located under cooling coils should be scrupulously cleaned and
                                          properly drained . Biocide treatment should be used to eliminate
                                          bacteria and slime growth .

                                                When was the last time the system was drained and
                                          scrubbed?

                                                 Does the system leak fluid anyplace? (Damp or stained
                                          ceiling tiles or carpet areas often indicate a leak or a
                                          condensation problem on an uninsulated duct .)

                                                Are the drip pans of window fan coil units regularly
                                          cleaned?

                                   8. Ventilation ductwork should be checked frequently by a
                                         professional ventilation expert or industrial hygienist with
                                         expertise in examining internal ventilation ductwork . It should
                                         be cleaned of dirt, dust, fungi, microbes and debris . Believe it
                                         or not, even some new systems have been discovered to be
                                         improperly installed - ducts that lead to nowhere, valves
                                         installed incorrectly, etc.

                                                  Date of last ductwork cleaning .

                                                  Has expert confirmed that system is properly installed
                                                  and operating to efficiency guaranteed by manufacturer?

                                   9 . When new equipment, carpeting, furniture, partitions or
                                          other office fixtures are installed, ask the following;
                                                  Is the equipment installed to the specifications of the
                                                  manufacturer? Does it require special ventilation?
                                                  Can the fixtures be "aired out" in an unoccupied area
                                                   for a while to let fumes escape from the materials
                                                   before they are installed?


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                                                  Can the ventilation rate be increased for a while after
                                                  the installation of new fixtures or equipment?

                                   10. Low relative humidity in an office can cause many of the
                                         symptoms associated with sick building syndrome -
                                         scratchy throat, itchy eyes, runny or dry nasal passages, etc .
                                         You may want to consider the installation of a humidifier to
                                         the HVAC system, particularly for use through the winter
                                         months when furnaces dry the air.

                                                  Relative humidity in the office currently is percent .
                                                  Many HVAC experts recommend a level of 20 to 30
                                                  percent in winter; 40 to 50 percent in summez




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                                                                                  WORKPLACE
                                                                                  SMOKING POLICY


                                  SECTION SEVEN : SAMPLE SMOKING POLICIES

                                  Sample Smoking Policy #1

                                  Purpose

                                  To provide guidelines for addressing smoking/no-smoking issues
                                  that arise in the workplace in jurisdictions that have restrictive
                                  smoking laws and regulations .

                                  Aoolicabilitx

                                  Applies to all U .S.-based employees .

                                  Responsibilities

                                  It is the responsibility of all employees to respect the preferences
                                  of their fellow employees be they smoker or nonsmoker .
                                  Employees are to be encouraged to work out compromises among
                                  themselves when these preferences conflict . When the individual
                                  employee's efforts to work out a solution are unsuccessful, it is the
                                  responsibility of the manager(s) to make reasonable
                                  accommodations to satisfy the preferences of employees .
                                  Managers should seek assistance from their Personnel
                                  Representatives when agreement regarding accommodation cannot
                                  be reached or when extenuating, circumstances (such as a large
                                  capital expenditure) would be required .

                                  Policv

                                  When state or local ordinances require a more restrictive practice
                                  than the guidelines contained in this policy, facilities must comply
                                  with the local requirements . When there are no local restrictive
                                  laws affecting the individual facility involved, smoking restrictions
                                  are not required by this policy except to comply with local safety
                                  and fire regulations .

                                  Restricted areas (no-smoking areas)

                                  ~ There is to be no smoking in any areas in which a fire or safety
                                    hazard exists . This would include areas where flammable or
                                    hazardous substances are used or stored .


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                                   • The responsibility is left with local management for designating
                                     any other smoking and non-smoking locations (e .g., elevators
                                     or stairwells, etc .)

                                   • There shall be no smoking in areas where any food ingredients
                                     or finished product is being prepared, processed, evaluated or
                                     stored. Employees assigned to these areas will be provided
                                     access to designated smoking areas by local management .

                                   • No-smoking signs shall state "No-Smoking Area" or other
                                     language as appropriate . In New Jersey, the signs shall state
                                     "smoking permitted" and "smoking prohibited ."

                                     en ral

                                   The aforementioned policies and procedures may be changed in
                                   whole or in part by the Company at any time without prior notice .

                                   Reference

                                   Corporate Safety and Loss Control Manual .




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                                   Sample Smoking Policy #2

                                   Pur o

                                   The company has developed a policy for all employees in an effort
                                   to reasonably accommodate nonsmokers and those who choose to
                                   smoke.

                                   General Guidelines

                                   Smoking will be permitted in cafeteria smoking areas, designated
                                   office areas, lobbies and restrooms . Effective immediately,
                                   smoking will be prohibited in hallways, elevator lobbies,
                                   refreshment centers, conference rooms (with exceptions made at
                                   the discretion of the meeting leaders) and storage and file areas .

                                   Work Space Guidelines

                                   Extra efforts may be made by the department' manager to               ;9
                                   accommodate both smokers and nonsmokers such as:

                                   • Designating office space as "non-smoking" in consultation
                                      with the associate occupying the space .

                                   • Moving individuals who are in open office areas to
                                      accommodate nonsmokers and smokers. However, when
                                      smokers cannot be accommodated in open office areas, the
                                      department manager may designate those areas as non-
                                   smoking.

                                   • Employees who choose to smoke in their work areas are
                                     requested to order air purifying equipment through the
                                     Engineering Department . This equipment will be paid for by
                                     the employee's department.

                                   Please contact your Human Resources representative if you have any
                                   questions regarding this policy .




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                                   Sample Smoking Policy #3

                                   Pur ose

                                   A mutually comfortable environment for employees is dependent
                                   upon the thoughtfulness and cooperation of both smokers and
                                   nonsmokers.

                                   The company has a responsibility to provide and maintain a healthy
                                   and clean working environment . It is important to note that the
                                   company is not required to provide a "smoke-free environment" ;
                                   therefore, the company does not attempt to ban smoking entirely .
                                   Rather, we hope to promote an awareness of the concerns of nonsmokers
                                   among those who do smoke and to be responsible to the needs of those
                                   who find close proximity to smoke objectionable .

                                   The following guidelines strive to meet the needs and desires of both
                                   smokers and nonsmokers .

                                   Legal Requirements

                                   These guidelines will in no way supersede local or state law, or any
                                   existing or future regulations established for fire, health or safety
                                   reasons.

                                   Manager's Responsibilitx

                                   The following guidelines are intended as examples of actions consistent
                                   with company policy .

                                   • Designation of "no-smoking" areas with appropriate signs .
                                     These areas should include conference rooms, libraries, rest
                                     rooms and health care facilities .




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