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Anti-smoking law: government should respect public initiatives

This is the submitted (un-editted) version of the article. It was published in The Jakarta Post (20-04-2006) as:
Government regulation should support smoke-free buildings

Earlier this month, the Jakarta government started to enforce the anti-smoking law. Not only the smokers in the prohibited areas who will start to get punishment, but also the building management who fails to provide special areas for smoking.

Strangely enough, though, the building management will still face possible charges for failing to provide the smoking room even if the building is already declared as a smoke-free building. This article shows that this policy not only creates misleading perception to the general public about the direction of the anti-smoking regulations, but also lacks of technological basis.

The smoking room

A smoking room is a part of the building where smoking is allowed. The very existence of the smoking room within the smoke-free building assumes that the tobacco smoke, along its poisonous and cancerous contents, can be contained within the smoking room to be eventually exhausted to the outside air. The question remains: is it realistic to assume that the smoke will not spread out of the smoking room?

There are two main issues in answering the above question. Firstly, what is it that we want to contain within the smoking room? Secondly, is it technologically feasible to contain tobacco smoke so it will not spread out of the smoking room?

To answer the first question, if our concern is about the health of every occupant in the building, especially the non-smokers, then the materials that we want to contain is the poisonous and cancerous substances that are generated during the burning of tobacco. It has been widely accepted – except of course by the tobacco industry – that tobacco smoke contain thousands of substances, and many of them are dangerous to our health. Some of these substances have been identified as carcinogenic.

Moving to the second question, if our concern is to ensure the health of all occupants in the building, then the second question becomes is it technologically feasible to contain the smoke so that the dangerous materials do not spread out of the room? The answer is yes.

Hospitals and laboratories have isolated areas where dangerous gases (or even viruses) may not spread out of the isolated areas. The technology used in the hospitals and laboratories is of course expensive. But they are very effective in ensuring the containment of the dangerous materials within the isolation areas. From the ventilation point of view, containing the dangerous materials in isolation areas of the hospitals is technologically the same with containing the tobacco smoke and its dangerous content in the smoking room.

My problem with these so called smoking rooms is that they do not use the same technology as the isolation areas in the hospitals. This will raise the logical questions: what do these smoking rooms contain? For sure, they do not contain the dangerous substances as these substances are of the same size with the dangerous materials in the hospitals while the technology used in the smoking room is less reliable.

Of course my objection above can be counter-argued with concentration argument. The counter argument will say that even if the smoking room cannot 100% contain the dangerous substances, the one that spreads out is actually so little that the concentration is very minimum to raise the alarm.

Well, I also have a problem with this line of argument. If we talk about low concentration, then how low is the safety limit? Nobody actually dares to set the safety limit.

There are institutions in the world (e.g. the OSHA in the US) that set the TLV (threshold limit value) of dangerous materials. The TLV is actually the maximum concentration of the dangerous materials allowed in the occupied space. But tobacco smoke is special in a way that it contains so many dangerous materials, some of which are carcinogenic. For these substances, there is no institution in the world who dares to set the safe concentration level. That is why the concentration argument is irrelevant for tobacco smoke.

Ventilation standard

We only need to quote the Standard 62-2005 on “Ventilation for acceptable indoor air quality” published by ASHRAE (American Society for Heating Refrigerating and Air Conditioning Engineers) to understand the position of the smoking room. This standard has been adopted as the American standard by ANSI, and is the de-facto ventilation standard in the world.

Standard 62 explicitly states that the good indoor air quality can only be achieved in the building where smoking is not allowed. Only smoke-free building can guarantee that the building is free from the dangerous substances produced by the burning tobacco.

This means that the ventilation standard indirectly says that there is no ventilation technology that can be used to guarantee the isolation of tobacco smoke and all its dangerous components. Providing the special smoking room cannot guarantee that the non-smokers outside the smoking room will be free from the effect of the tobacco smoke.

It is true that the Standard 62 has a special section that provides guidelines on how to design ventilation system in the buildings where smoking is allowed. But this section is put on the appendix of the Standard, and it is clearly stated that the guideline in the appendix only deals with the odor problem caused by the tobacco smoke, and has nothing to do with the health effect of the tobacco smoke.

Setting the priority

From the above discussions, there are two important conclusions that we can draw. Firstly, there is no expanation in the regulation for what reasons smoking rooms are provided. If the reason is to guarantee the health of the occupants of the building, then the above discussion shows that providing smoking rooms cannot be the solution.

It seems to me that the reason to provide smoking rooms is more sociological then technical. The smoking rooms are provided simply so that the smokers are not felt victimized by the regulation. But if this is the case, it is no where to be found in the regulation.

The government must explain this in the regulation, at least in the explanatory notes of the regulation.

The second conclusion is that the initiative from the public (the building managements) to set smoke-free rules for their buildings is actually the ideal condition for the anti-smoking regulation, especially from the ventilation technology point of view. Smoke-free building is the future of the anti-smoking regulation.

With that in mind, the government should respect the smoke-free initiative by exempting the smoke-free building from providing the smoking room. Instead of punishing the building management of the smoke-free building for failing to provide the smoking room, the government should give commendations for them as examples of good public initiative.