Hong Kong

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CAN THE PROPOSED CONTROL YIELD. ACCEPTABLE .... BAR B. 6:15 pm. 11:45 pm. 9:15 pm fine-particle air pollution particle-bound carcinogens. BAR C.
CONTROLLING TOBACCO SMOKE POLLUTION: VENTILATION, SMOKING ROOMS, SMOKING BANS -WHAT WORKS AND WHAT DOESN’T? J.L. Repace, MSc., Biophysicist Repace Associates, Inc. Secondhand Smoke Consultants! www.repace.com! 24 October 2005. Invited Testimony, concerning the inability of ventilation to control secondhand smoke and the hazards of smoking rooms to smokers, and Debate with Dr. Chris Proctor, Head of Science & Regulatory Affairs, British American Tobacco, before the Hong Kong Legislative Council on Smoking (Public Health) (Amendment) Bill 2005. Hong Kong Special Administrative Region (SAR), China.

Controlling Tobacco Smoke Pollution: Questions to be asked and answered.

•! WHAT ARE THE RISKS TO BE CONTROLLED? •! WHAT ARE THE VARIABLES THAT DETERMINE RISK? •! HOW BIG IS THE EXISTING RISK? •! WHAT IS THE REQUIRED LEVEL OF CONTROL FOR ACCEPTABLE RISK? •! CAN THE PROPOSED CONTROL YIELD ACCEPTABLE RISK TO WORKERS? •! CAN ENFORCEMENT BE ACHIEVED AT ACCEPTABLE COST?

WHAT ARE THE RISKS TO BE CONTROLLED?

WHAT ARE THE VARIABLES THAT DETERMINE RISK?

VARIABLES DETERMINING SECONDHAND SMOKE (SHS) POLLUTION LEVELS : •! •! •! •! •!

NUMBER OF SMOKERS SMOKING RATES CIGARETTE, PIPE, CIGAR EMISSIONS SIZE OF ROOM VENTILATION RATE CONTROLLABLE VARIABLES ARE SMOKING POLICIES AND DESIGN VENTILATION RATES. !

HOW BIG IS THE EXISTING RISK?

3 in 100 HONG KONG CATERING WORKERS ESTIMATED TO DIE FROM PASSIVE SMOKINGDILUTION Over a Working Lifetime,FAILS or 150TO deaths per year; VENTILATION PROTECT RISK TO MOST-EXPOSED IS 20 per 100. SMOKE CATERING WORKERS FROM SECONDHAND 100

May 2001!Hong Kong Council on Smoking & Health Report No. 8 Second-hand smoke exposures and passive smoking in non-smoking catering workers in Hong Kong: the combined risks for heart disease and cancer. AJ Hedley, SM McGhee, J Repace, et al.

Urine Cotinine (ng/ml)

100

10 Average Worker

10

1

1

U.S. OSHA SIGNIFICANT RISK LEVEL

0.1

VERY LARGE RISKS BY U.S. REGULATORY STANDARDS 0.1

.01

.1

1

5

10

20 30

50

70 80

90

95

99

99.9

FROM LUNG CANCER & HEART DISEASE COMBINED

1000

LIFETIME PROBABILITY OF DEATH FROM PASSIVE SMOKING, %

104 Hong Kong Catering Workers Exposed Only at Work

99.99

CUMULATIVE FREQUENCY, % Estimated Dose-Response = 1.44 Heart & Lung Deaths per 1000 workers per nanogram of cotinine per milliliter of urine per 45-year Working Lifetime

Estimated Cost Per Life Lost from Passive Smoking •! Cost of passive-smoking mortality among 200,000 catering workers (64% of them nonsmokers), (150 deaths per year) times (US $4.5 million per life lost from pollution) * = US $675 million/year. Assuming a life in Hong Kong is valued the same as a life in the U.S., this is an estimated (US $675 million/year) times (7.75 Hong Kong dollars/ U.S. dollar) = HK $5.2 billion/year. •!

*(U.S. Environmental Protection Agency, Washington, DC, 1997. The Benefits and Costs of the Clean Air Act: 1970-1990. EPA Report 410R-97-002.)

•! Such estimates must be balanced against any estimated losses to industry from a smoking ban.

WHAT IS THE REQUIRED LEVEL OF CONTROL FOR ACCEPTABLE RISK? •! DE MINIMIS (ACCEPTABLE RISK) LEVEL USED BY U.S. REGULATORY AGENCIES IS 1 DEATH PER MILLION PERSONS PER LIFETIME. (Repace JL et al. Risk Analysis 18: 71-83,1998).

•! RISK FROM PASSIVE SMOKING TO AVERAGE WORKERS OVER A WORKING LIFETIME IS 3 PER 100, RISK TO MOST-EXPOSED WORKERS IS 20 PER 100, BASED ON MEASURED DOSES TO HONG KONG WORKERS (Hedley AJ, et al. Hong Kong COSH Report #8, May 2001). •! ANY VALID CONTROL MEASURE FOR PASSIVE SMOKING MUST REDUCE RISK TO ACCEPTABLE LEVELS. •! REQUIRED RISK REDUCTION IS A FACTOR OF (20/100) / (1/1,000,000) = 200,000 FOR THE MOSTEXPOSED, AND (3/100)/(1/1,000,000) = 30,000 FOR AVERAGE WORKERS

How Much Ventilation Would be Required to Control Tobacco Smoke Pollution In Hong Kong? •! •! •! •! •! •!

HK ventilation rate is 4.5 litres/second-occupant HK restaurant seating is 67 persons/100 m2 Assuming a 4 metre ceiling: 2.7 air changes/hour Average worker has 3,000/100,000 lifetime risk De minimis risk level is 1 death/1,000,000 persons To attain de minimis risk, ventilation must be increased by 30,000 times, to 81,000 air changes/ hr, or 135,000 litres/second per occupant •! Is it possible to deliver such rates of air exchange?

CAN THE PROPOSED CONTROL YIELD ACCEPTABLE RISK? Repace JL, Controlling Tobacco smoke pollution. ASHRAE IAQ Applications 6 (#3): 11-15 (2005)

TORNADO-like rates of air flow are necessary to attain acceptable risk from secondhand smoke

ARE TORNADO-LIKE VENTILATION RATES REALLY REQUIRED? •! U.S. OSHA: “The carcinogenicity of ETS [secondhand smoke] discounts the use of general [dilution] ventilation as an engineering control of this contamininant.” (Federal Register, Tuesday, April 5, 1994, Part II Department of Labor - Occupational Safety and Health Administration 29CFR Parts 1910, 1915, 1926 and 1928, Indoor Air Quality; Proposed Rule.)

•! ASHRAE: “The minimum ventilation rate table … [applies] only to no-smoking spaces … for smoking -permitted spaces, additional (but unspecified) ventilation … is required.” (ASHRAE Standard 62.1-2004, Ventilation for Acceptable Indoor Air Quality. American Society of Heating, Refrigerating and AirConditioning Engineers, Inc., 2004).

CAN ENFORCEMENT BE ACHIEVED AT ACCEPTABLE COST? •! Ventilation or Air-cleaning: estimated Cost of ventilation in U.S.: $1/ft2-year at ASHRAE-recommended ventilation rates. For tornadostrength ventilation to achieve acceptable risk in Hong Kong: US $30,000/ft2-year, or HK $2.5 million/ m2-year. •! Smoking Bans: estimated HK$1 per establishment for No Smoking signage on front door.

AIR QUALITY MONITORS FOR SECONDHAND SMOKE STUDIES Ecochem PAS 2000 CE PPAH Monitors!

MIE pDR 1200 RSP Monitors

Monitors for SHS!

ToC, RH%, CO, CO2 Monitors

INDOOR AIR POLLUTION FROM SMOKING IN 8 HOSPITALITY VENUES USING DILUTION VENTILATION: VERY HEAVY COMPARED TO OUTDOORS Delaware Hospitality Industry Secondhand Smoke Survey: Real-time RSP & PPAH, Friday Nov. 15, 2002 1200

1200

1100

PPAH ng/m3

particle-bound carcinogens

900

900

800

800

700

700

outdoors

600

SMOKING

BAR B

600

500

500

BAR G

400

400

CASINO A

300

300

BAR F

BAR E

200

200

BAR D

100 0

1000

100

BAR C

0

6:15 pm

30

60

90

120

150

180

9:15 pm

Elapsed Time (minutes)

210

240

270

300

330

11:45 pm

0

PPAH, nanograms per cubic meter (ng/m3)

POOL HALL H

RSP µ g / m3

1000

RSP, micrograms per cubic meter (µ µg/m3)

1100

fine-particle air pollution

INDOOR AIR POLLUTION IN 8 HOSPITALITY VENUES AFTER A SMOKING BAN: COMPARABLE TO OUTDOOR LEVELS Delaware Hospitality Industry Secondhand Smoke Survey: Real-time RSP & PPAH After The Smoking Ban 1200

1200

1100

1100

fine-particle air pollution

1000

PPAH ng/m3

900

900

particle-bound carcinogens

800

800

PPAH ng/m3

RSP µg/m3

1000

RSP µg/m3

700

outdoors

600

SMOKE-FREE

500 400

600 500 400

300

BAR B

CASINO A

200

BAR C

BAR D

BAR F

BAR E

BAR G

300

POOL HALL H

200

100 0

700

100

0

6:15 PM

30

60

90

120

150

180

9:15 PM

210

Elapsed Time (minutes)

240

270

300

330

11:45 PM

360

0

INDOOR SMOKE POLLUTION BURDEN GREATLY EXCEEDS OUTDOOR AIR 8 DELAWARE HOSPITALITY VENUES VERSUS OUTDOOR AIR 5

U.S. ANNUAL AMBIENT AIR QUALITY STANDARD FOR PM2.5

4

RELATIVE LEVEL

5

ANNUAL AVERAGE BURDEN OF FINE PARTICLE AIR POLLUTION

4

DAILY AVERAGE BURDEN OF CARCINOGEN AIR POLLUTION

3

3

2

2

1

1

0

0

WORKERS IN 8 VENUES

OUTDOORS

WORKERS IN 8 VENUES

OUTDOORS

SMOKE-FREE LAW CLEARS THE AIR CARCINOGEN (PPAH) LEVELS DROP BY 95% 150

100

50

0

BEFORE

Nov 15, 2002

AFTER

Jan 24, 2003

FINE PARTICLE AIR POLLUTION (RSP) LEVELS DROP BY 90% RSP, micrograms per cubic meter

PPAH, nanograms per cubic meter

Repace JL, JOEM 46:887-905 (2004)

!

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BEFORE

Nov 15, 2002

AFTER

Jan 24, 2003

8 Delaware Hospitality Venues: Casino, 6 Bars, & Pool Hall !

Baltimore Highway toll-booth PPAH Carcinogen range: 9 -200 ng/m3 Wilmington Hospitality Venue PPAH Carcinogen range: 43 -234 ng/m3 (Repace JL, JOEM 46:887-905, 2004)!

Secondhand Smoke Pollution in the Hospitality Industry is Worse than Working at an Interstate Highway Toll Booth

PUBWORKERS’ RISK BEFORE AND AFTER SMOKE-FREE IRELAND

ESTIMATED URINE COTININE, nanograms per millilitre

BARWORKER SECONDHAND SMOKE DOSE FALLS 80% POST-SMOKING BAN 35

BAR WORKERS' URINE COTININE ESTIMATED FROM SALIVA COTININE 35 n = 111; P