Introduction

For 13 years our activities on behalf of our clients have been devoted to the study of indoor air problems. We analyze the air for fibers of textiles, asbestos, glass and mineral wools, radon, carbon monoxide, exhaust fumes, pesticides, detergents, carpet and furniture emissions, PCBs, volatile organic chemicals, bacteria, fungi and, of course, tobacco smoke. An integral part of our investigations is the study of the ventilation systems, their design, control sequences and operational policies. These experiences are all dedicated to cleaning up the indoor environment, which makes our testimony especially relevant to any debate on these issues.

Major corporations such as IBM, GTE, Digital Equipment, Union Carbide, Pepsi Cola plus government agencies including the US Department of Health and Human Services, the Social Security Administration, Housing and Urban Development, the Federal Reserve Bank and the United Nations have all retained our services to accomplish the goal of clean indoor air. These references plus over 300 other corporate clients confirm our qualifications as experts in this field.

Some of our clients have chosen to ban smoking. A number of others prefer the practice of restricted smoking areas whereas others continue with discretionary smoking. Three different philosophies yet all have expressed satisfaction with their indoor air quality programs and the resulting quality of their indoor air. How and why? Because all adopted our primary recommendations of maximizing the capacity of their ventilation systems, of improving where necessary their filtration standards and all, because of our encouragement, have paid greater attention to correct operating practices concerning their ventilation control equipment.

My testimony today is divided into two parts. Part One concerns the techniques we use to manage smoke in the indoor environment. Part Two looks at the economic impact of HR-3434.

Part One -- The Client-HBI Interface

Our advice to all our clients is not to lose sight of the long term objective -- a comfortable and productive workplace with reductions in the concentration of all pollutants, including smoke. Fortunately, smoke, from the perspective of a ventilation engineer, is a relatively easy component of the indoor air to manage. Microbes, with their incredible capacity to reproduce, coupled to their ability to lie dormant over long periods, are much harder to control. Furthermore, for every building where we have encountered tobacco smoke problems we have experienced tenfold that number of buildings with microbial contamination. These organisms positively cause allergies, certainly can cause infections and indisputably the secreted toxins from some are identified as potent carcinogens. Neither we, nor you, can afford to dismiss any indoor pollutants be they microbes, dusts, fibers or chemicals.

Carcinogens in the Workplace

Without being too melancholic, perhaps I can remind you that substances thought to be carcinogens are also widespread in the food chain. Mushrooms, nuts, corn, spinach, beets, lettuce, fish and shellfish, oranges, peppers and numerous herbs and spices contain naturally occurring chemicals that have been classed as carcinogens.
Returning to the implications of the EPA's statement. First let us recognize that the EPA has no statutory authority to regulate indoor air quality. The authorized agency is the Occupational Safety and Health Administration (OSHA). This agency is currently at the formative stage of developing rules on indoor air quality, including tobacco smoke.

OSHA has for many years been charged with the responsibility of protecting workers from exposure to many chemicals including those thought to be carcinogens. They accomplish this by ensuring that airborne concentrations of carcinogens such as benzene, arsenic, asbestos, cadmium, etc., are maintained below so-called Permissible Exposure Levels (PELs). These are usually eight hour time-weighted averages. Also, the National Institute for Occupational Safety and Health (NIOSH) publishes Recommended Exposure Limits (RELs). Perhaps of more relevance, however, are the Threshold Limit Values (TLVs). Interestingly, these TLVs are specifically set to protect worker health. Furthermore, the source of many of these TLVs, the American Conference of Gpvernmental Industrial Hygienists, state that TLVs refer to airborne concentrations of substances below which it is believed that nearly all workers may be repeatedly exposed, day after day, without adverse health affects. There is as yet no TLV for tobacco smoke.

The Role of Ventilation

Furthermore, the committee members responsible for the specification of ASHRAE 62-89 ventilation rates did not simply choose a random number for ventilation in areas of moderate smoking. Rather, their value was based on specific studies which showed 80 percent visitor acceptance at 15 cfm per person of ventilation air, with 1.1 cigarettes per hour per smoker with one-third of the population smoking (Jansen J.E., "Ventilation for Acceptable Indoor Air Quality", ASHRAE Journal, Oct. 1989, pp. 40-48). The use of 20 cfm of outdoor air per person for offices provides an adequate margin of comfort.

Smoking Areas

The smoking lounges can be designed with their own dedicated air supply and exhaust system. Or, as suggested by ASHRAE, they can be incorporated into buildings using the air supplied by the existing ventilation system. The air to the smoking lounge can be either ducted supply air or it can be "transfer air" -- i.e., air deliberately induced into the lounge from adjoining areas. So long as the designated smoking areas or its dedicated smoking lounge is maintained at a negative pressure relative to adjacent areas, the laws of physics preclude any migration of smoke from the lounge to nearby areas.

Such designs are commonly practiced in many buildings. In our experience in studying hundreds of buildings, we have found nonsmokers and smokers perfectly happy with such an arrangement.

Bars and Restaurants

Proof of the efficacy of such separation has been demonstrated by others. For example, two recent papers (1,2) report no detectable components of ETS even in air recirculated through HVAC systems from smoking areas. The first was funded by the cigarette and tobacco surtax fund of the State of California and the second was funded by the US Public Health Service Region III.

Part Two -- Economic Impact of HR-3434

"In addition, a substantial potential savings in housekeeping and manintenance expenses of buildings seems to be possible (as a result of a smoking ban) and could be in the $5 to $10 billion range".

The phrases "seems to be possible" and "could be" were perhaps included to preserve "plausible deniability." The fact is that savings of this magnitude in housekeeping and maintenance costs are more figments of the imagination than hard data. Is this obvious hyperbole simply delivered to garner support or media attention?

Why are the savings impossible? To answer this, let us review the data used by the EPA.

Housekeeping and maintenance costs were based on assuming standard times to complete specific tasks in a hypothetical 1,000 square foot unit of building. An estimate was made of the frequency of repeating such tasks. Presumptions were made such as smoking areas needing to have their carpets vacuumed 46 percent more frequently than non-smoking areas or furniture in smoking areas needing to be dusted once every three days compared with once every five days in non-smoking areas.

Using these theoretical assumptions and the assumed standard times, comparative costs between housekeeping in smoking areas and non-smoking areas were determined. Similar calculations based on presumptions and theoretical cost savings indicated that maintenance costs in non-smoking areas could save $122 per 1,000 square feet. To arrive at this figure, it was assumed that building owners would repaint smoking areas every six years and non-smoking areas could last 12 years!

Once having arrived at potential savings of $105 in housekeeping and $122 in maintenance costs per 1,000 square feet, the EPA multiplied these savings by 61 billion square feet to theorize the overall impact on the nation. They concluded that national savings would be:

Task	Theoretical Savings	Minimum Savings	Maximum Savings
Housekeeping	$6,375,000,000	$3,679,000,000	$4,906,000,000
Maintenance	$7,413,000,000	$4,278,000,000	$5,704,000,000
Total Savings	$13,788,000,000	$7,967,000,000	$10,610,000,000

Reasonableness of these Figures

Can anyone really believe that by simply eliminating the emptying of ashtrays we could save over $2.4 billion of cleaning costs? Is it possible, that by eliminating smoking we can reduce painting costs by over $4 billion per year?

These sorts of calculations are a typical example of back-room voodoo economics by persons far removed from the true facts of building service costs. I personally have discussed these issues with senior management of two major office cleaning companies. Some of the facts that emerged from those discussions are of relevance here.

The cleaning costs for government buildings from 1986 to 1993 have climbed from less than $1.0 per square foot to $1.4 per square foot (Source BOMA statistics and/or Black's Guide). In the same period we have seen a steady increase in non-smoking areas until we reach today's status in most government buildings where smoking is totally banned or severely restricted. Why were the cost savings for eliminating smoking not reflected in these figures? For comparative purposes, the average cleaning cost of commercial buildings in the USA through 1991/92, according to BOMA, is $1.08 per square foot.

The EPA's estimated cost for emptying ashtrays at $70 per 1,000 square feet represents $0.07 per square foot. Similarly, the housekeeping savings were $105 per 1,000 square feet or $0.11 per square foot. When I asked the cleaning companies if due to the elimination of smoking I could expect a reduction in cleaning costs of between 7 and 11 cents per square foot they thought I was crazy.

They point out that a typical analysis of their overall cleaning budget of $1.08 per square foot would be: Labor 70 cents, insurance and taxes 11 cents and profits at 5 cents, total $1.08. Furthermore, they point out that most of the buildings they now clean already practice restricted smoking policies. Politely, they point out that they could not pass on any significant savings whatsoever.

The savings in painting costs are also a myth. To appreciate this consider the following:

• The common areas of all major office buildings are on average, completely refurbished, including painting and re-carpeting, every four years, whether or not smoking is allowed.
• The average office lease in the USA is approximately 5 years. Thus each 5 years the offices are routinely painted, regardless of smoking policies. Larger corporations, negotiating longer leases, usually also negotiate repainting schedules schedules with the owners, or elect to cover the costs themselves. Most paint more frequently, not less frequently, than the building owners' schedules.
• The other theoretical savings can also be shown to be figments of the imagination. Discussions with building owners or their cleaning companies revealed that:
  • Venetian blinds are rarely cleaned more than once a year.
  • Frequency of vacuuming carpets is dictated by traffic patterns, not smoking policies.
  • With 13 years of experience of studying buildings we have never observed smoking policy decisions impact on the need to revise air filter replacement schedules.
• Possible Expenses Incurred by Total Smoking Bans

Lost Productivity

If 25% are smokers (150 staff), who take an average of 4 smoke breaks per day of 10 minutes duration (to leave the building, smoke a cigarette, and return to their office) then we have 150 staff x 10 mins x 4 breaks per day = 6,000 mins = 100 hours per day spent unproductively.

100 hours lost production represents 2% of the total available.

Assuming that the average worker cost $30,000 per annum in salary plus payroll associated costs the annual payroll would be, 600 staff x $30,000 = $18 Million per each 100,000 square feet.

2% productivity losses per 100,000 square feet = $360,000.

If we then used the EPA multiplier of 61 Billion sq ft couldn't we now expect to lose

Energy Costs

• Elevator Costs. If we return to our model building of 100,000 sq. ft. and assume that it is sub-divided into say 10 floors and further assume that the ground floor is a typical retail area, then the 150 smokers (25% of staff) would need to make 600 round trips, i.e., 1,200 extra elevator trips if they leave the building for 4 smoke breaks per day.
• Would an EPA researcher like to project how many multi-story buildings are present in 61 Billion sq. ft. of property to project total energy consumption expended by these smokers forced outside the building?
• Door Openings. Normally an air-conditioned building operates with an interior pressure slightly greater than the outdoor air -- on average we expect a pressure differential of 0.02" from inside to out. Every entry or exit through the doors involves a loss of conditioned air.

Since our 150 smokers per 100,000 square feet of building take a total of 600 smoke breaks per day = 1,200 door openings of say 5 seconds duration each, wouldn't we be justified in working up some energy losses based on 1,200 door openings x 5 seconds each = 100 minutes at 10,000 cfm per minute multiplied by some major fraction of 61 Billion square feet?

I am not suggesting we waste time on such interesting mathematics. The fact is that there are very tangible losses in productivity and energy related losses associated with a total smoking ban once we assume that a significant percentage of those smokers affected do indeed leave the building to smoke. Furthermore, once productivity losses are included in the equation these losses dwarf the theoretical gains claimed from reduced cleaning and /or maintenance costs.

Ladies and gentlemen, thank you for giving me a hearing today. What I have described is a small part of one of many presentations that our company makes for such recognized associations as the American Institute of Architects, ASHRAE, the Association of Energy Managers, the Gas Council, the Air Balance Council, the Building Owners and Managers Association and numerous Fortune 500 corporations. Without exception these groups compliment us on sharing the results of a decade of our research in this way. If, however, the tobacco industry asked us to make an identical presentation we are likely to be branded as apologists for that industry. We are not. We are an independent company with considerable expertise acquired over 13 years of studying buildings for a very diverse client base. Today I appear before you at the request and expense of the Tobacco Institute. However, I assure you that my findings, statements and recommendations are based on our own independent research. Indeed I challenge anyone to debate these issues with me and for anyone to point out where my statements depart from well accepted engineering principles and basic common-sense.

[signed]

Gray Robertson
March 17, 1994

Healthy Buildings International Inc.
10378 Democracy Lane
Fairfax, VA 22030