12 November 1980

Mr. Leroy J. Pletten
8401 18 Mile # 29
Sterling Heights, MI 48078

Dear Mr. Pletten:

In response to your letter of 30 October 1980 in which you request technical criteria defining "smoke-free" air. I would like to state that in my opinion, a practical definition of "smoke-free" air would be air which contains respirable particulates of [not more than] mass median aerodynamic diameter in the range 0.01 to 3.5 micrometers as measured by a TSI model 3500 piezobalance, in a concentration not exceeding 20 micrograms per cubic meter, averaged over 8 hours. Shorter averaging times may be used if the samples are taken over a one hour period during the middle of the morning or afternoon workday.

I have reviewed the Memorandum of Mr. E. F. Braun, [TACOM] Industrial Hygienist, concerning medical policy - Determining Air Flow Rates in Building to Determine Smoking Control Program. Mr. Braun states that "a possible nuisance condition from smoking may exist but such a condition does not constitute a health hazard." This statement is incorrect. Small airways dysfunction has been reported in nonsmokers from passive [forced, involuntary] smoking in the office environment. Acute symptoms from passive smoking have been reported in persons with cardiovascular or respiratory disease; Mr. Pletten reports that he is [become] an [tobacco-caused] asthmatic [caused by TACOM's job hazard]. Tobacco smoke is a proven human carcinogen; there is strong evidence that increased exposure to carcinogens increases the risk of cancer. Moreover, the "nuisance" factor from passive smoking has been shown, in a study of 10,000 nonsmoking federal employees, to cause interference with work productivity.

As my own research has shown, tobacco smoke cannot be controlled to within the levels of the National Ambient Air Quality Standard for Total Suspended particulates at any ventilation rate designed for a particular occupancy. Nonsmokers should not be exposed to the increased risk of cancer and respiratory disease attendant upon passive [forced, involuntary] smoking [behavior/conduct]. Employers should provide smoke-free areas for nonsmokers, and should conduct active campaigns to discourage smoking among their employees.

/s/James L. Repace
James L. Repace
Assistant Director for Administration
Environmental Protection Specialist
Office of Policy Analysis

Ed. Note: The E. F. Braun above-cited in fact knew of TACOM's job hazard, and so testified. His cited memo had taken the criminally false 'TACOM is safe' party line under pressure of TACOM management and legal office, which insisted on his presenting a good story in writing, regardless of truth. Cross-examination brought out Braun's real view point, and that of his supervisor, the TACOM physician, F. J. Holt, M.D.
The latter verified the bad TACOM ventilation system, “. . . mechanical failures happen all the time [p 25 line 16],” resulting in “hazardous to them [TACOM employees p 42]”. Braun had recommended “over and over and over again” solving the hazard as pertinent ventilation equipment was “outmoded” so air became “stagnant” [p 17 line 25] and “hell” [p 18 line 2].
Rather than solve the hazard, TACOM ousted Pletten in reprisal for his having blown the whistle on the hazard to “all [p 42 line 14].”