Thanks for your reply. I had thought that perhaps my request for information had been misplaced.

The Cabaret Alliance of Manitoba's position is that a "total ban" or any increased restriction in the cabaret setting would be detrimental to the industry as experienced in other markets that have attempted to implement such an unenforceable ban. We liaison with others in the industry throughout North America on these issues. We also feel data regarding second hand smoke is inconclusive and is represented by faulty scientific procedures intended to arrive at a preconceived conclusion using smoking in general as an emotional "hot button".

Cigarette smoke is on the rise. But were you aware that its growth is specifically centered on the youth market? I would suggest that the issue is youth smoking. Are the Tobacco Ads converting kids? Or is it a reaction to all the publicity smoking is getting regarding movements to ban?

Smoking is a legal activity. It is legal regardless how this is achieved. The choice of how the smoke enters the body is one that is made by adults, as the activity of smoking is a legal activity. If the goal is a smoke free world, then ban cigarettes instead of penalizing the industry to achieve this utilitarian goal. I doubt this would happen due to the backlash of this more forthright approach. It is an interesting prohibition tactic. Buy it, it's legal. Don't smoke it anywhere. Bars, specifically are age-restricted environments where adults make decisions whether to smoke or not or whether to enter or not. Do we have a situation whereas meter readers, electricians, plumbers etc. should not enter the house of a smoker? I suggest this is getting ridiculous given the data and truths that are now emerging.

It's funny, remember the message that once mentioned that a "60 something-ish Swede is healthier than a 20 something-ish Canadian" comment that was widely publicized in the past? If Health Officials reported it, it must be true. Well, it turns out that this was not true and was intended as a message to all Canadians to get off their butts but really wasn't supported by any meaningful data... yet it got reported and accepted as true. The government has acknowledged this mistruth in the press. I suggest that there are parallel untruths that are coming to light regarding the initial data pushing the dangers of Second-Hand Smoke.

Based on a quick analysis of your reply by ourselves and associates, what stands out, is the following:

"Of these groups, the most up-to-date summary report that comprehensively documents the health risks of ETS is Monograph No.10 "Health Effects of Exposure to Environmental Tobacco Smoke", published by the National Cancer Institute.........."

Monograph 10 is a recycling of the 1997 California Environmental Protection Report, based on the EPA '93 report - vacated by Judge Thomas Osteen in July 1998. This Cal/EPA report '97 was reissued in November 1999 by the National Cancer Institute (NCI) with the addition of 5 'new' studies, which showed no statistical significance according to their own tables. The press did not pick up this 'news' - perhaps they're getting skeptical regarding the NCI. Perhaps the WCB, or their advisers, think those involved are too uninformed to be aware of this rehash. Sometimes garbage is just that - non recyclable.

"The scientific evidence that ETS causes adverse health effects is too extensive to provide you with a list." .... then goes on to refer us to a host of 'credible' sources (who will possibly be able to provide us with nothing really specific either)

" There is no credible, scientific evidence as to what constitutes a safe level of ETS exposure."...and on THIS basis zero tolerance is imposed? As none of the studies done on this issue (including WHO/IARC) produce any significant Risk Ratios. Perhaps this is just a 'Smoke Free' agenda?

"As ETS is a chemical contaminant that is typically not essential to the work process, it is practicable to eliminate it in virtually every workplace." ...completely ignoring hospitality venues (bars specifically - age restricted) which have a high percentage of smoking clientele; perhaps the answer is more important to determine what 'the safe level of ETS' is. Zero tolerance is based on the agenda to eliminate of the use of tobacco. Period. All elements of ETS (minus nicotine) are existent in "fresh" or "outside air". What is the difference between inside air and outside or "fresh" air? Where is there information that supports the difference as being harmful? I suggest this "0" level is not sensible nor reasonable and not possible even with a total ban.

"Between 5 to 10 claims are received annually, the majority of claims are related to acute exposures and aggravation of a pre-existing medical condition." ... I'm sure WCB is not paying out on any of these alleged claims, and under current scientific information regarding ETS has/would undoubtedly refuse to do so.

"With the increased knowledge and awareness of the adverse health effects associated with ETS, it is likely that the future claims experience will be significantly greater than the past claims experience."... not at the rate the psuedo-scientific studies are being shot down. See:

http://www.bmj.com/cgi/content/full/320/7232/417

BMJ 2000;320:417-418 ( 12 February/00 ) British Medical Journal Reanalysis of epidemiological evidence on lung cancer and passive smoking J B Copas, professor, J QShi, research fellow. Department of Statistics, University of Warwick, Coventry CV4 7AL

"Conclusion: A modest degree of publication bias leads to a substantial reduction in the relative risk and to a weaker level of significance, suggesting that the published estimate of the increased risk of lung cancer associated with environmental tobacco smoke needs to be interpreted with caution."

"Key messages:
a. A systematic review of epidemiological studies on passive smoking estimated the increased risk of lung cancer as 24%
b. There is clear evidence of publication bias in these studies
c. Reanalysis of the data allowing for the possibility of publication bias substantially lowers the estimate of relative risk"

FOR IMMEDIATE RELEASE: 8 FEBRUARY 2000 (8 FEBRUARY 2000 GMT) Oak Ridge National Laboratory

Exposures to second-hand smoke lower than believed, ORNL study finds "While people who work as wait staff and bartenders may generally be considered to be more highly exposed to environmental tobacco smoke, data from our study suggests that the situation is more complex," said Roger Jenkins of the Chemical and Analytical Chemistry Division.

Over the last six or seven years, more data on personal exposure to tobacco smoke has become available and the methods for measuring and analyzing the smoke have become more sophisticated. The 16-cities study, the largest of its kind ever conducted in a single country, found the highest levels of environmental tobacco smoke nicotine levels in workplaces where smoking is permitted to be between 9.41 and 14.9 micrograms per cubic meter, far lower than the numbers assumed by EPA and OSHA.

The research was funded by the Center for Indoor Air Research. ORNL is a DOE multi-program research facility managed by Lockheed Martin Energy Research Corporation

I suggest that Ventilation, Filtration, Air Exchange is the answer. Let the industry and those in the business of "Air Quality" such as Honeywell a chance to present their case. Honeywell is of major interest. We have attended three International Trade Shows involving the Hospitality Industry in Las Vegas. Paraphrasing Honeywell, "If we can protect the soldiers of Desert Storm from extremely lethal gases, ETS is manageable". They feel confident in stating "the danger posed by ETS would be 1/10th of that posed by radon gas in our homes or even Electro Magnetics in the workplace". Evolving technologies and additional entries to the marketplace will also be forthcoming.

Our position is second hand smoke cannot ever reach a dangerous level, as long as a minimum of inexpensive ventilation is provided. But, what is a dangerous level? Pressed by the ever-growing proof that the concentrations of Environmental Tobacco Smoke (ETS) are so infinitesimally small as to approach ridiculousness, this anti-smoking lobby wants us to believe that even the slightest amount of ETS can harm the body of the person exposed to it. Since this is at the basis of smoking bans - this anti-smoking lobby is so committed to the total elimination of smokers it allows and even sustains the scientific fraud concerning ETS regardless of evidence to contrary. Smoking is a hot button for many and it makes smoking bans o.k. Well, it's not O.K.!

So again, what is a dangerous level? So far, it has never been defined by anyone. Yet smoking bans are based on the concept of dangerous exposure, showing once again the schizophrenia about this issue. Here is a good starting point: outside air. Since we cannot avoid breathing, and since we circulate outside air into indoor environments, we are implicitly accepting that outside air is our most common reference point to clean air. That is why smokers are pushed outside, isn't it?

But what do you know?

SURPRISE!

Poor air quality is not healthy regardless of second hand smoke and can be treated with inexpensive, modest ventilation. If there is a problem possibly in some situations, small corrections in the ventilation, filtration, and air exchange are likely what is needed! "Outside Air" or "Fresh Air" turns out to be a very useful marker for poor air circulation. There are all the carcinogens in outside air due to automotive smoke and other environmental influences as there is from secondhand smoke minus the nicotine. Are we to believe that if any level of ETS is no good then we should all stop breathing? What level is scientifically proven as dangerous and what level is scientifically proven as safe? Again, what is the difference, in measurement between clean (outside air) and a club (supposedly dangerous) air? Now where is the data to support this difference as being the cause for concern?

I suggest, when instrumental read-outs cannot be "interpreted", and meta-analytical manipulations cannot be performed due to such low, low levels and infrared analysers and nephelometers can't support political correctness. Then any level of ETS is harmful!

Finally, I find it interesting those contradictions regarding the relative risk of ELF (Electromagnetic Fields) in comparison to ETS (Environmental Tobacco Smoke) within two separate publications from the EPA itself.

Are the rules different for tobacco smoke?

The U.S. Environmental Protection Agency (E.P.A.) says that exposure to environmental tobacco smoke causes lung cancer in non-smokers based on a relative risk of 1.19. But in a draft report on electromagnetic fields, the E.P.A. said that relative risks below 3.00 are not strong enough to support a casual relationship:

"The association between cancer occurrence and exposure to either extremely low frequency (ELF) or radio frequency (RF) fields is not strong enough to constitute a proven casual relationship, largely because the relative risks in the published reports have seldom exceeded 3.0..."(Evaluation of the Potential Carcinogenicity of Electromagnetic Fields. U.S. Environmental Protection Agency Review Draft, p. 6-2. EPA/600/6-90/005B., October 1990)

Ron Ledohowski, President
The Manitoba Cabaret Alliance