California Environmental Protection
Agency
Air Resources
Board
Alan C. Lloyd, Ph.D.
Chairman
1001 I Street - P.O. Box 2815 - Sacramento, California
95812 -
www.arb.ca.gov
June
11, 2001
Dear Sir or Madam:
Request for Information Regarding Environmental Tobacco
Smoke
I am writing to request information on the
atmospheric chemistry, sources, total exposure to, and the adverse
health effects of exposure to environmental tobacco smoke (ETS). The
Air Resources Board (ARB) is requesting this information as part of
our toxic air contaminant program. This request is the first step in
the process to review and assess ETS as a toxic air contaminant.
This program is established by state law (California Health and
Safety Code section 39650 et seq.) and is summarized in Enclosure
1.
In February 1992, the ARB and the Office of
Environmental Health Hazard Assessment (OEHHA), with assistance from
the Department of Health Services (DHS), undertook a thorough
assessment of the health risks associated with exposure to ETS. This
assessment was done to ensure a comprehensive review of scientific
data, to obtain public input through public comment periods and
workshops, and to secure an independent review by the state's
mandated scientific peer group, the Scientific Review Panel (SRP).
In June 1997, the SRP approved a scientific report that presented
the assessment performed jointly by OEHHA, DHS, and the ARB. The SRP
also developed specific findings regarding the health effects
resulting from exposure to ETS. The final report was released to the
public in September 1997, and was approved by the ARB at its October
23, 1997 meeting. However, since 1997, new legislation has been
enacted which requires an evaluation of the effects of candidate
toxic air contaminants (i.e. ETS) on children's
health.
Under the Children's Environmental Health
Protection Act (Health & Safety Code section
39660(c)(1)(A)-(D)), the report prepared to identify a compound as a
toxic air contaminant must now include the following (to the extent
information is available):
1. exposure patterns among
infants and children that are likely to result in disproportionately
high exposure to ambient air pollutants in comparison to the general
population;
2. special susceptibility of infants and
children to ambient air pollution in comparison to the general
population;
3. the effects on infants and children of
exposure to toxic air contaminants and other substances that have a
common mechanism of toxicity; and
4. the
interaction of multiple air pollutants on infants and children,
including the interaction between criteria air pollutants and toxic
air contaminants.
Some of the work to update
the previous ETS report will focus on meeting these new
requirements. In addition, the OEHHA must conduct a quantitative
risk assessment. In cases where there is no threshold of significant
adverse health effects, existing law requires that OEHHA determine
the range of risk to humans resulting from current or anticipated
exposure to the substance. A range of risk was not calculated or
presented in the previous ETS report.
We now request
additional, pertinent information for ETS exposure, including any
material on children's exposure to ETS and any material that may not
be available to the public or that is not included in the enclosed
bibliography from the joint ARB/OEHHA 1997 report on ETS (Enclosure
2). We are also requesting information relevant to human exposure to
ETS and its constituents in California through media other than
outdoor ambient air. Specifically, we are requesting information
concerning total exposure to ETS through inhalation, ingestion, and
skin absorption, with special emphasis on inhalation exposure in the
indoor air environment. This includes ETS and its constituent
concentrations in various media, consumption information,
bioabsorption rates, body burden studies, etc.
There is
no need to submit information that you submitted in response to
ARB's previous requests for information about ETS. The information
that you provide will be considered as part of an evaluation of ETS
as a candidate toxic air contaminant. This information, with the
exception of trade secrets, may be released to the public.
Therefore, if you believe that any of the information you are
providing is a trade secret, or is otherwise exempt from disclosure
under any other provisions of law, you should identify it as such at
the time of submission. The ARB's procedure for handling information
claimed to be trade secret is explained in Enclosure 3.
We would
appreciate receiving by September 4, 2001, any relevant information
you wish to submit. Your help in carrying out our review is greatly
appreciated. Please send the information to the attention
of:
Ms. Janette Brooks, Chief
Air Quality Measures Branch
Re: Environmental Tobacco
Smoke
California Air Resources
Board
P.O. Box 2815
Sacramento,
California 95812
If you are not
the person to whom this request should be addressed, please forward
it to the appropriate person in your organization. Also, please let
us know whether you would like to continue to receive information
inquiries for other candidate substances, and if not, if there is
anyone in your organization to whom such requests should be sent.
For other questions regarding the public information request, please
contact Mr. Jim M. Aguilar, Manager, Substance Evaluation Section,
at (916) 322-8283.
Sincerely,
Peter D. Venturini, Chief
Stationary Source
Division
Enclosure 1
State of
California
Air Resources
Board
Toxic Air Contaminant: Program Statutory Basis and
Process
California's toxic air contaminant program is
established by Health and Safety Code sections 39650-39674. This law
sets forth the process for:
1. assessing the risk posed by
substances;
2. identifying by regulation
substances determined to be toxic air contaminants;
and
3. managing the risk by adopting
control measures for the identified toxic air
contaminant.
The law
defines a toxic air contaminant as an air pollutant which may cause
or contribute to an increase in mortality or an increase in serious
illness, or which may pose a present or potential hazard to human
health.
Two reports are prepared during this risk
assessment and risk management process. The first report, which is
prepared by the California Environmental Protection Agency's Air
Resources Board (ARB) and Office of Environmental Health Hazard
Assessment (OEHHA) staffs, contains information on the exposure and
health effects of the substance. This report is used to determine
whether a substance should be identified as a toxic air contaminant.
The second report, which is prepared by the ARB staff after a
substance is identified as a toxic air contaminant, is on the need
for regulation of that substance. Both reports are developed using
an open, public process.
Before the ARB can formally
identify a substance as a toxic air contaminant, several steps must
be taken. First, the ARB must make a formal request to the OEHHA to
evaluate the health effects of the candidate substance. Second, the
ARB staff must prepare the risk assessment report, including the
health effects evaluation and an estimate of exposure levels and/or
unit risk (with a special emphasis on children's exposure), and then
submit the report to the Scientific Review Panel on Toxic Air
Contaminants (SRP) for its review. The report submitted to the SRP
will be made available to the public. Information submitted by
interested parties will be considered in the report to the SRP. The
SRP reviews the sufficiency of the information, methods, and data
used by the OEHHA in its evaluation and prepare findings. The
report, with the written findings of the SRP, will be considered by
the ARB and will be the basis for any regulatory action to identify
a substance as a toxic air
contaminant.
The attached information
request is the first step in preparing the risk assessment report
and is usually done before a formal request is made to OEHHA for
preparation of a health assessment. Before either the ARB or OEHHA
begin their analysis of a substance, the ARB provides an opportunity
for interested parties to submit information on the atmospheric
chemistry, sources, exposure to, and the adverse effects on health
of exposure to that substance. You are encouraged to submit any
information that you believe would be important in ARB's and OEHHA's
evaluation, but there is no need to submit information you submitted
to us previously.