Health Canada a mess

Sunday, April 02, 2006

Big Tobacco is getting into the game

I witnessed something today I have not seen in years.

A cigarette company commercial expressing the views of Phillip Morris International. The message “there is no safe cigarette�. Instructions to the viewer to go to the website where cigarette ingredients are not only listed but peer reviewed research showing scientific testing of all 333 possible added ingredients are available for all to see.

This will no doubt place the Tobacco industry from a moral perspective well above the anti smoker advocates who will now be scrambling to regain a credible position. The ban fans have completely disregarded their own integrity research and ventured into personal attacks against smokers claiming to be anti industry. While openly admitting a plan to make smokers lives as miserable as possible to force them to do as they are told. Bans were never about protecting anyone just a change of attack when science could not sustain their position in court as seen in the Osteen decision. Or more recently in Scotland by Judge Lord Nimmo Smith

Considering past public statements in respect to the dissertations referring to harm deriving from The mystical Tobacco plant abilities or harm derived from the added ingredients as opposed to particulate matter which is finally coming to the fore front as the real risk in smoking despite what we have been hearing for years. Now the Industry speaks from science and the ban fans speak in created political numbers. It does not take a lot of imagination to see who will win the race.

Racism regains acceptability in medical research communities. Thanks to campaigns by such groups as ASH and physicians for an Aryan nation or something similar. Coleslaw who once headed the tobacco control sales department at the WHO left in disgrace after major research failed to find what he wanted. Undaunted he created the Heather Crow saga and put the facts he had seen in the WHO study behind him. Seeding myths contradicting what he saw in the research first hand. He now sells the idea a Canadian Doctor can actually deduce a specific cause of a Lung tumor, despite the rest of medical science who cannot yet make such a claim. In his book he suggests taking over the Tobacco industry breaking the Government’s monetary chains by taking on the sales and profits personally one would assume.

100 years ago the protections of the gene pool in the Eugenics movement lobbied for the sterilization of Jews and imbeciles. 75 years ago the influence of old American money supported Hitler consistent in his endeavors to protect and establish superiority of the white Arian race, entirely consistent with the current radical views of the Arian brotherhood. Those old American money principles have returned more powerful than ever in the new HIA health intervention industry. Comparisons of race as acceptable research parameters as opposed to socioeconomic standing, which actually reveals credible realities in health outcomes. Again we draw racial lines which will likely be used to divide us according to cost of healthcare as this movement grows hatred and inspires acceptance of more punishing evaluations of those around us. The anti smoker gang along with a good deal of their recruits Government and the medical sciences community are on the verge of finding themselves on the wrong page of the balance sheet in Fascist labeling from a public perspective with little in hand to sustain a credibility rating.

Political extremist views; creation of fear through misdirection a voice gained through governments failure to support the individual’s right to informed consent. This allows an ongoing human experimentation through ingredients being added and mandated fire safe papers with no public discussions or disclosures, as risk assessments are being made for us, behind closed doors as usual.

Governments operating in such a fashion for decades, now seek “Sin Tax� compensation from the victims of those closed-door decisions. Preventable deaths and ETS exposure risk can be seen as no less than government failures resulting in human damages which should rightly be compensated by the governments who caused them not the victims as the popular media would propose. At the other partner’s offices, Tobacco settlements were added to the price of the product again assigning a duty to pay damages on the victims of a dangerous addictive product they sought to glamorize. Farmers who were lured into tobacco crops with government incentives and later were promised compensation for flue curing and regulated growing conditions to attain a safer product are now being forced off their land by a government and an industry abandoning them while ducking responsibilities they both owe in promotion of anti smoker technologies. Smoking is simply the wedge issue to take the voice of science future abusive campaigns are well underway which will affect much more than just smokers. In for a penny in for a pound, lets hope it does not take the deaths of millions to put this campaign back in check.

Change can only occur when this world grows a backbone and gets motivated to put Industry back in it’s place. The advocacy of governments to nationalize charity foundations and put the money to real charitable cause. Could act as a double edged sword as Companies who loose the ability to control will be forced to pay equitable share of taxation for a change relieving the pressures on the working poor community violence and crime will subside as a byproduct as standards of living improve. There is no higher determinant in Health outcomes than personal economy.

If this is about saving lives abdicating hatred will not improve our lot.

Currently it is becoming all too obvious numbers in the latest research simply do not bear out the test of credibility in mortality actuals in comparison to estimates unless we have finally found a need to re-examine previous perceptions and research conclusions.

If one were to investigate the hypothesis the effects of both primary and environmental cigarette smoke as a health hazard only as a percentage of a product of total particulate matter accumulation or exposure, as opposed to a separate hazard unique unto itself, it would have to be said the overall risk of Tobacco smoke is substantially overstated. In a perspective now supported by political statements being made to the public in epidemiology research, radical lobby efforts would in fact serve to increase mortality through failure of autonomy principles, and reduced need to act in total particulate matter reductions, harm to overall community and indeed the health of the individual. This would in effect allow the unnecessary; premature and causative mortality increases of thousands due to shortened life estimates in significant correlations linking PM to what are now referred to as smoking related diseases.

Although it is an ambitious endeavor to rid the planet of smoking can it be an acceptable risk to the credibility of science as a whole in the forgoing the basic rules of integrity? At any cost, is not sufficient reason to undermine the scientific reality with a political agenda. How seriously do we consider the effects of Diesel exhaust, Dioxins or Radon gases? In a political sense the scientific community has failed in raising vital concerns, which should be known to the public. Focus in favor of a tremendous global effort to protect the public from the insignificant findings in relation to ETS which in a 300 million population 3000 deaths or 30 per million are well below acceptable risk estimates. Research derives from maximum exposures to hospitality workers and expresses an equal risk to the general public who by exposure duration would be much less affected by much reduced levels of exposures. Even if the studies were found to be accurate and consistent in their findings. Simply ignoring those who find fault in ETS logic [and there are many] does not establish the findings as irrefutable as some would claim.

Recent studies [additional, additional, ] and submissions to the US EPA in regards to lowering PM acceptable levels, articles revealed a number of seemingly irrefutable facts, which could not have been obvious to researchers in the majority of ETS and primary smoking studies done to date. Submissions if seen as credible would find an acceptable standard in outdoor particulate matter annual rate of 10 micro grams per cubic meter of air. The current level at 15 micrograms M3 if reduced could amount in savings of 75,000 deaths for each microgram reduction. In total numbers this could amount to 375,000 deaths per year with the 5 Microgram reductions being requested. Those same mortality figures are currently being labeled as smoking related diseases and thought to be preventable by eliminating smoking alone. Huge reductions in smoking and ETS exposures to date have been seen to be ineffective considering the substantial increases in mortality in parallel with those reductions. Reductions in the six cities studies revealed those mortality figures dropped consistently with PM reductions which would make a much more credible case when deciding cause. The six cities study found further proof in a 26% differential in mortality between the most and least polluted cities. There has never been a smoking research study done to date revealing evidence this convincing or observations directly proportional to mortality of this magnitude of proof. In relation to the 10-year trial period and causative correlation to lung cancers as opposed to smoking habits in the past; research would seem to indicate, the causative timeline is also much shorter than previously believed. PM as a health risk would be seen to act three times as fast as smoking in creating cancers and smoking related diseases. A view more closely reflective of age in the total PM accumulation and reduced bodily function would seem to be indicated.

The six cities study;

“As Whittenberger had predicted, it was years until the Six Cities Study produced data on the health impact of air pollution. When it did, however, the results were different from what anyone had expected. First of all, the study showed that indoor air quality was far more important to overall health than outdoor air; most people simply spend much more of their time indoors, and pollutants often become concentrated inside homes and workplaces. The study also indicated a strong, positive correlation between levels of air pollution and mortality: deaths from lung cancer, pulmonary disease, and heart disease were 26 percent higher in Steubenville–a city so polluted that air-born sulfates turned lead-based house Paint black within a year–than in Portage, the cleanest city in the study.

However, rather than indicating sulfur dioxide as the culprit emission, the Six Cities Study directed attention to so-called particulate matter, now recognized as a dangerous form of air pollution. Specifically, the study highlighted the hazards of so-called pm 10 particles, which are 10 microns in diameter and smaller. This lethal relationship between particulates and cardiovascular mortality has been replicated in studies performed in cities around the world.

Following the release of the study’s results in 1993, says Dockery, the American Lung Association brought suit against the Environmental Protection Agency to update its standards on particulate matter pollution, which had not been reviewed in accordance with the Clean Air Act in well over five years.

"The quality and quantity of the data were both very impressive," says Mort Lippmann, a New York University Medical Center professor of environmental science who served on the EPA’s Clean Air Scientific Advisory Committee. "This was the largest epidemiologic study of the effect of pollution on individuals that was available. It was done very carefully over a long period of time, and it had to be taken very seriously."�

These facts should be cause for reflection and re-examination of the conclusions and peer review of those targeted smoking studies in search of integrity and agreement to the latest research and causative numbers in balancing the books of actual mortality figures. The current USA statements; 450,000 smoking deaths and 3000 ETS deaths annually need some careful consideration without which true mortality figures are seen to be exceeding actuals by a significant number. In addition the socioeconomic factors which seem to be completely ignored by researchers in smoking related research would cast incredible suspicion on the abilities or training of most of the researchers in the field to speak from an unbiased perspective in light of the wealth being driven by the anti smoker initiative. Not a typo smoker ban advocacy and the effects on health in reality bear little credibility as an attack against industry. It is well known the political strategies are to in fact make a smokers life as uncomfortable as possible in order to force them to quit. Fear and hatred through public campaigns and declarations; smokers smell like dog fescues and murder babies. Calls for child abuse charges against a parent who smokes in their own home are the height of the ignorance being promoted. In Ontario Canada a health ministry issuing a public threat quit or be punished through a website called stupid they teach our children hate and insensitivity are not only approved but recommended in learning to hate their own parents and relatives who smoke.

ASH (Arian. Something. Something.) Declares it acceptable to deny a smoker Employment, Healthcare, Housing, Opinion, Civil Rights or Security of the person. These views have no place in a civilized society or any measure of credibility regardless of who pays their wages. The outlandish accusations emitting from this group should be reflected back upon those who employ them if or when the civil and criminal cases eventually begin.

The dominant overall effect of smoker ban advocacy has been reduced trust in our institutions and increased violence in community totally without need. If inclusive solutions were considered the upheaval would never have occurred. If scientific integrity were considered the effect would have benefited all and not just the largest gang of bullies and braggarts or their ballooning bank balances.

The previous studies would have reflected the combined effect of cigarettes of all varieties seen in a single value, labeled tobacco smoke and the desolate ambient air thought to represent no substantial risk. In fact the ambient air containing levels of particulate matter PM10 above or equal to 15 micrograms per cubic meter of air would constitute an identical risk to both case and control subjects. The conclusions found in all such research have allowed us to see risk reduced with cessation of exposure in both primary and sidestream smoke. This would be consistent if we took a wider view of identical particulate in high short-term exposures and after cessation saw the effects seem to decrease with the merging over a time base with other exposures at lower but consistent levels.

If we assume the most significant risk as particulate matter and we substantiate this in physical observation as the added chemical toxins and carcinogenic contents in tobacco smoke are very minute and well below known safe levels of each toxin confirmed in mandated testing and submissions by the industry to governments for decades. [Pay particular attention to “Toxicological evaluation of glycerin as a cigarette ingredient� Found on page 5-6 of this document]

Ingredients added by country UK in comparison to other countries additives seem to remain consistent in low levels resulting in no scientific findings of added toxicity as previously shown. It should be recognized the additives would result in a completely different chemical composition after burning and considerably lower levels would be found in the contents and volume of the smoke produced. Total cigarette volume by weight would be 937 milligrams. Prior to burning. The smoke produced as indicated on the side of a package would total approximately 100 milligrams per package of 25 or about 4 milligrams per cigarette.

The particulate matter now can be safely assumed the risk we should be focusing on. The political statements of 5000 chemicals and 40-50 known carcinogens all become less of a concern when examining what we know through physical testing. Particulate matter and concentrations of exposures are directly and significantly correlated to risk directly reduced in reductions of concentrations. In follow up to the 6 cities study the March 15 submissions to American Journal of Respiratory and Critical Care Medicine. ETS Studies to date are from; http://www.forestonline.org/output/Page1.asp

Views of the unqualified, tambourine bangers in the peanut gallery.

Who now hold the proxy of scientific opinion?

One has to wonder if any level of scientific integrity survives or if it does has it simply been silenced as with the voices of the public, by those who know what is best for all of us in an industrialist old money view.

Chemicals from Second-Hand Smoke:

What a typical restaurant employee would inhale

Below is a list of the amount of selected chemicals, emitted in sidestream smoke, that a

restaurant employee, weighing approximately 65 kg (140 lbs), would directly inhale (not the total

exposure amount) over an 8-hour shift in a 300m2 area.

All chemicals marked in bold type are carcinogens (they cause cancer). All of the chemicals

below cause adverse health effects.

These calculations assume 10 smokers per 300m2 each smoking 2 cigarettes per hour, 1 totaling

160 cigarettes over the 8-hour time period, and take into account standard ventilation rates.2

Further information about these calculations can be found at: www.smokefree.ca/eng_issues/etschems2.htm


In a way of perspective if you have a 100 liter gas tank a full liter of Benzine is the acceptable standard when your tank is full.

Known safe levels of Benzene are actually one part per million the larger quantity in gasoline reflects a risk assessment by government to allow the seemingly dangerous level inhaled while gassing up your car.

The amounts of benzene listed below are for shock value only.

One UG micro gram is one millionth of a gram.

• One litre of pure water weighs approx. one kilogram 1000 grams

•1 cubic centimeter less than 1/2 an inch cubed of water weighs 1 gram.

• A steel paper clip weighs about 1 gram.

•A miligram would be equal to a cubic millimeter of water or 1000th of a gram.

•A micro gram is 1/1000 of that amount or one millionth of a gram

•A Nanogram One billionth of a gram

•A Picogram one trillionth of a gram

•Total cigarette volume by weight would be 937 milligrams. Prior to burning.

•The smoke produced as indicated on the side of a package would total approximately 100 milligrams per package of 25

•or about 4 milligrams per cigarette.

160 cigarettes in an 8 hour period would produce 640 milligrams of smoke 90% of that would consist of carbon dioxide.

The remaining 64 milligrams is refered to as RSP or PM10. Respratory particulate matter. Acording to James Repace who should know acording to his past with the EPA the level of Toxins or PPAH would be .08% of the total RSP of the possible 64 milligrams produced in a day only 51 micrograms is left to distribute 5000 chemical ingredients including the 50 carcinogens and deadly toxins being described in the list below. the numbers seem to be a little high according to what one would expect, but hey, Lobbying is about creating scary stories.

In addition to the rest of the 5000 ingredients the list is partially represented below.

The title indicates the lung capacity of each employee could exceed the norm by tens of thousands of times
and each person in the room would be able to consume the same levels of toxins
regardless if they actually exist.

Table 1: Amount of Chemicals Inhaled by A Restaurant Employee

CHEMICALamount (ug) CHEMICAL amount ug) CHEMICAL amount (ng)

carbon monoxide 5606 1,3-butadiene 25 resorcinol 123

tar 3128 hydroquinone 24 benzo[a]pyrene 18

nicotine 678 methyl ethyl ketone 23 cadmium 9.7

acetaldehyde 207 catechol 22 1-aminonaphthalene 8.5

nitric oxide 190 propionaldehyde 17 chromium 7.1

isoprene 151 cresols 15 lead 6

acetone 121 hydrogen cyanide 14 2-aminonaphtalene 5.2

toluene 66 styrene 13 nickel 4.2

formaldehyde 54 butyraldehyde 12 3-aminobiphenyl 2.4

phenol 44 acrylonitrile 11 4-aminobiphenyl 1.4

acrolein 40 crotonaldehyde 10

benzene 36 quinoline 1.3

pyridine 33 .

1 Americans for Nonsmokers’ Rights: Questions and Answers Regarding Eliminating Smoking in Restaurants. February 5, 1992.

2 ASHRAE Standard (62-1981) office ventilation rate of 10L/second per person (assuming 7 persons per

100 meters squared floor space). According to American’s for Nonsmoker’s Rights: Protecting Nonsmokers from Secondhand Smoke (fact sheet), these ventilation rates would need to be improved 270 times, a enormous cost, in order to reduce the carcinogenic risk from tobacco smoke to federal (US) accepted levels.

This would “create a virtual windstorm indoors�.


If you consider a few factors here first the amounts presented are total produced in an 8-hour period regardless of air volume applied to the room or the exchange rate which hardly represents a norm at 3 exchanges per day even 3 exchanges per hour would be a low average. If the chart represents an accounting for 3 exchanges per day tripling the amounts on the chart would reflect total contamination ratios per room volume. If they designated a 1-meter [3 foot] ceiling, as the M2 would indicate the air desolate would fit nicely with the numbers in the chart. A 3-meter ceiling [10’] would be more accurate in expressing the norm.

The volume of air mass desolate with no ventilation in the room is a 300 M2 area with an assumed 3 meter ceiling height; total air in the room would be 900 cubic meters.

Contaminant levels are expressed as amount per cubic meter of air. In this case even with the parameters shown this would amount to the numbers on the chart times 3 divided by the total meters flowing through the room in an 8 hour period. Their numbers show this to be 3 times 900 = 2700 meters so the numbers on the chart x 3 /2700 would give us the contaminant level available. Of this amount available a person could not inhale the total of the room contents.

In fact in ½ liter inhalations you would only inhale [6 inhalations per minute 360 per hour and 2880 per day] total inhalations 1440 liters or 1.5 cubic meters per day of the 2700 meters available with the hobbled ventilation system. This amount would be .00056 of total 8 hours contaminant. .06% of the figures shown on the chart. Times the amount of time you were exposed. 8 Hours in a working day would be unrealistic as no deductions were allowed for breaks or the amount of time you would normally spend outside the room ½ of the 8 hour period would be closer to reality. Total inhalations would be 4 hours or .5 of 8 hours times the contaminant level per 8 hour day the 8 hour level would be .06% [.0006] x the figures shown on the chart.

Why is the ventilation rate being fudged? The effects of normal ventilation at minimum 3 exchanges per hour would be substantial in dissipating the toxins described. From the figures above calculate for a 3 per hour exchange rate or 24 in an 8-hour day the desolate air mass becomes 21,600 as opposed to the 2700 expressed as the norm. In the next study below you will see a more motivated crushing of the numbers by an expert in scare tactics. Even he concedes a 34 exchange rate per hour is quite normal in a casino with considerably more air volume in an average room. At 30 exchanges per hour we would divide the contaminants by [240 x 900] 216,000 to attain per cubic meter contaminations per 8-hour day. In real scientific animal testing by examining the effects of tripling the additives harmful effects are seen in many cases were the normal additive amounts show no detectable harm. This is consistent with the phrase poison is in the dose and nothing including pure water and air cannot be considered toxic if taken in high dosages.

From a Health Canada audit in 1999 apparently changes were made but in contradiction to the good advice offered;

Cracks in the Foundation of the Federal House - Overarching Concerns

3.46 Exposure to toxic substances such as industrial chemicals and pesticides poses actual and potential risks to the health of Canadians and our ecosystems. Yet our understanding of the effects of toxic substances is incomplete. Many questions remain unanswered. What substances are present in our environment, homes and consumer products and at what levels? Where do they come from? What do they do to people and ecosystems? How significant are the risks? What can we do about them?

3.47 Scientific information produced through ongoing research, monitoring and assessment is used to answer these questions and is the foundation for understanding risks and making informed decisions.

3.48 Good scientific information is essential for many reasons. First, Canadians' health depends on it: unless we identify which substances pose a risk, we cannot act to reduce it. Second, together with economic, technological and social information, it supports informed decisions on how risks are to be managed. Third, after measures have been put in place to reduce risks, good scientific information can tell us whether the measures are achieving the desired result. The federal government's commitment to base its decisions on sound scientific information is reflected and repeated in legislation, departmental mandates and sustainable development strategies, and in government-wide strategies and policies.

3.49 Government failures could affect health. Our audit identified many weaknesses in the federal government's collection and use of scientific information on toxic substances. We found weaknesses in interdepartmental co-ordination of research efforts, incomplete monitoring networks, a lack of re-evaluation of pesticides, conflicting departmental agendas and priorities, and a growing gap between the demands placed on departments and the availability of resources to meet those demands. Cumulatively, we believe these cracks in the foundation threaten the federal government's ability to detect, understand and prevent the harmful effects of toxic substances on the health of Canadians and their environment.

Of the 5000 ingredients and 50 toxins Health canada appears to be concerned about by the advice they offer the public. In actual practice they are actually only concerned with 14-16 as per the information they ask for of the industry. Dioxin is not even on the list.

Another extremist who makes a good living scaring people himself presents airflow rates and typical air measurements. From a scary guy;

Reduction of the risk of secondhand smoke exposure for

Burswood Casino Staff to acceptable levels would require tornadolike

air exchange rates greater than 120,000 air changes per hour,

Or more than 3400 times the highest rates proposed by Lincolne

Scott in its ventilation technology scheme for the Burswood

Casino.

James Repace contends a safe contaminent level would be 16.4 Pico grams [Trillionths of a gram] per cubic meter of air roughly equivalent to Depleted Uranium or Dioxins. The ratio of PPAH toxic contaminents prior to a ban would be .08% the remaining particulate matter after a ban or outdoor air is seen to loose 50% of toxic content despite the fact Tobacco smoke contains 5000 ingredients outdoor air contains over 40,000 chemicals in use in Industry today with 50% of the toxic value of cigarette smoke no science is offered to substantiate this or other outrageous opinions he offers.

10,000/120,000x3400 = 283.3 exchanges per day as a proposed rate. Or 35.4 exchanges per hour. A lot different than the 3 per 8 hours exchanges above described as normal. Hurricane force winds proposed by this scary guy with a much higher desolate rate as opposed to virtual windstorms mentioned above. Although they both seem to agree the costs would be extreme and the wind force in the room needs to be increased the first estimation of a windy situation being produced by 270 exchanges per day can be seen here as below the norm, in fact discussion is surrounding the trippling of exchange rates to the level prescribed by the former study and not a mention of a breeze, until you get to the Repace huricane theories. He likes to play with toxicity fears as opposed to the fudging of air desolate numbers. Repace does not acknowlege air desolate as an issue at all as long as he can implant a fear of high contamination levels as immovable objects his numbers will keep them guessing for years. Figuring out the exchange rate would be the largest factor in increased costs apparently.

According to the extremists, risks vary with respect to whom a presentation is addressed. The Tobacco industry could not have wished for a more energetic advocate to protect their position and pass the costs of damages on to the victim. As a promonent stooge to big Tobacco Repace loves his work.

According to American’s for Nonsmoker’s Rights: Protecting Nonsmokers

from Secondhand Smoke (fact sheet), these ventilation rates would need to be improved 270 times, at

Enormous cost, in order to reduce the carcinogenic risk from tobacco smoke to federal (US) accepted levels.

This would “create a virtual windstorm indoors�.

Repace in the same evaluation presented; with multiple air exchange rates described identical risk assessments were made regardless of air desolate volumes or resulting ratios which would predict differing levels of concentrations according to how much smoking occurred in each room and the physical dimensions of the room in question each with a different rate of airflow.

For the actual measured levels, nor what the smoker density was in the casino at

that time. LS also proposes air exchange rates of 25 air changes per hour (ACH) for the

Function, VIP and existing International rooms, an increase from “the current 8 ACH.�

LS proposes an increase “from 12 ACH� to 35 ACH for Private Gaming Salons. For bar

areas within smoking-permitted rooms supply air is proposed over the bar area with

returns in the patron area to “limit� the amount of smoke exposure of bar staff. LS does

not specify the smoker density for any of the spaces. LS does not state whether these

“current� air exchange rates are the result of actual measurements or are design values for

those spaces.

In 1999, I issued an affidavit (Repace, 1999) in a legal case, Brook v. Burswood

Casino. In a table (Table 4) in that affidavit, reproduced below as Table 1 in this

Evaluation, I compared my estimates of RSP and nicotine concentrations based on

estimated smoker densities, and average air exchange rates, to actual measurements that

had been made by others. My average estimated nicotine concentration, assuming a

casino smoking prevalence of 29%, was 23 µg/m3, and average estimated RSP from SHS

was 250 µg/m3, which compared very well to actual measurements. From the preceding

paragraph we see that LS proposes to triple the air exchange rate over existing values.

Holding smoker density constant, this would reduce the average air pollution from SHS

by a factor of 3. However, if the new designated smoking-permitted rooms contain

largely smokers, the new smoker density could increase by a factor of 3, negating the

increase in ventilation. A major flaw in the LS report is that it does not specify the

current or new smoker density, and does not appear to recognize that the concentration of

SHS is directly proportional to the smoker density as well as inversely proportional to the

air exchange rate.

This statement does not mention air desolate or exchange rates simply predicted calculations and comparison to actual measurements in other venues. The air exchange rate would have tremendous bearing on the contaminant level yet Repace suggests a linear calculation would encompass all possible rates of air exchange and resulting desolate percentages. The contention of tripling the smoker density to offset tripled air exchange rates suggests a room with over 90% chain smokers a highly unlikely scenario.

The Repace cited measurements are as follows;

Table 1. Comparison of theoretical calculations for low, average, and high smoking

occupancy and average ventilation vs. environmental measurements for the

Burswood Casino from various depositions (Repace, 1999).

Est.Nicotine Conc Meas.NicotineConc. Est.Total RSPConc. Measured RSP Conc.

.(µg/m3) (µg/m3) (µg/m3) (µg/m3)

Repace LeSouef (p.252) Repace LeSouef *

Low: 3 23.8 Low: 50 200-300

Repace Langley (p.217) Repace Gordon (p.99)

Ave.: 23 26.8 Ave.: 250 216-476

Repace HBI (Brook) Repace HBI (Brook)

High: 41 15.8 High: 430 62-226

*Letter from Peter Le Souef, MD to Hon Ian Taylor dated 31 December 1996, quoting data presented b

Burswood Casino 23/11/96 to Taskforce on Passive Smoking.

“If we hold the Burswood smoker density constant, and if the air exchange rates are increased by a factor of 3, I conclude that at best, the exposure concentrations of SHS For Buswood Staff would decrease by a factor 3 to about 80 µg/m3. However, LS do not specify a smoker density, and LS’s target RSP concentration is nearly 4 times that level, at 300 µg/m3.�

An assumption is being made here the results of increased ventilation and other proposed improvements. would result in no improvements of the norms 6 years previous in 1999. In fact a concentration identical to 1999 estimates at 250 micrograms per cubic meter of air and an associated PPAH level at 163 nanograms per cubic meter of air. No representations are discussed in limiting the smokers allowed in the room per cubic meter of air. Or indeed the size of the room dictating dissolution ratios in addition to exchange rates which would calculate an inverse proportion of added pollutant desolate percentages in decline with added air mass desolate total volumes. If a room with no ventilation measured 900 cubic meters the proportions of RSP would be double a proportion in a room with double the dimensions. With ventilation each air exchange would lower by ½ a constant pollution rate entering the room in timed period. Considering Repace conclusions particulate matter remaing in the room after a ban would exceed his known safe level by 250 times even though the levels he measured with no smoking are less than average acceptable levels in outdoor air being currently challenged at 15 micrograms per cubic meter of air.

New research suggests one microgram reduction in PM10would save 75,000 lives.

In reverse of this, increases should have the same effect or worse. Measured levels expressed as normal in a smoky bar at 250 micrograms would result in annual mortality of 17,625,000 annually and in his 45 year working lifetime 793,125,000 double the US population. Over and above the current standard levels. In 1960 54% of the American population smoked and a higher tar product which would; considering few restrictions in place, have resulted in 99% of the population being exposed to ETS yet mortality figures have risen staidly alongside huge reductions in ETS exposures 75% and smoking prevalence reduced also by 66%. Perhaps Repace can explain his hurricane forced logic although I would not personally put a lot of stock in his opinions at this point.

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