CI-2009 IEQp2: Environmental Tobacco Smoke (ETS) Control Required

Yes, electronic cigarettes are considered a form of smoking for the purposes of both the interior and exterior smoking provisions of the LEED Prerequisite Environmental Tobacco Smoke Control. As recommended in the December 2013 report[1] prepared for the World Health Organization, “e-cigarettes should be prohibited anywhere where the use of conventional cigarettes is prohibited”. The indoor air quality impacts from electronic cigarettes are not fully characterized, but there is sufficient evidence that electronic cigarettes produce emissions in fine aerosol form that can expose building occupants. For example, according to the report, “several chemicals that have been found in e-cigarette aerosol and e-liquid are on California’s official list of known human carcinogens or reproductive toxicants, including nicotine, acetaldehyde, formaldehyde, nickel, lead, toluene(1)”.
[1] Background Paper on E-cigarettes (Electronic Nicotine Delivery Systems); Grana, R.; Benowitz, N.; Glantz, SA; December 2013; University of California

The CIR is inquiring whether proof of future compliance would be acceptable to meet the prerequisite and whether prohibiting smoking within 15 feet from entrances would meet the intent of the credit. Future compliance for this prerequisite would not meet the intent, which is to prevent or minimize exposure of tenant space occupants, indoor surfaces, and systems to Environmental Tobacco Smoke (ETS). If smoking in a space is allowed for an extended period of time, this extends the timeframe over which occupants, systems, and surfaces within these spaces will be exposed to ETS. Materials which absorb ETS will off-gas after the smoking itself ceases, further extending the exposure timeframe. Limiting smoking to 15 feet from entrances instead of 25 feet would not meet the credit requirement. The project should prohibit smoking within 25 feet from building entrances, to the extent possible, in order to meet the credit requirements. If the applicant does not have the authority to prohibit smoking within 25 feet of the entrance, signage should be posted requesting that people do not smoke within 25 feet of the entrance. Applicable Internationally.

The prerequisite requires, "Zero exposure of nonsmokers to ETS by prohibition of smoking in the building, OR, provide a designated smoking room designed to effectively contain, capture and remove ETS from the building". The CIR narrative implies that the entire restaurant is being treated as a smoking room. While this approach will prevent building occupants in other spaces within the building from tobacco smoke exposure, it does not protect non-smoking restaurant patrons from smoke within the space. If smoking cannot be prohibited in the restaurant, the project team and owner may wish to consider creating a fully contained smoking section within the facility that meets the requirements set forth under the prerequisite. Applicable Internationally.

Yes, smoking of cannabis is considered a form of smoking for the purposes of both the interior and exterior smoking provisions of the LEED Prerequisite Environmental Tobacco Smoke Control.
Secondhand cannabis smoke has been shown to contain many of the same chemicals and carcinogens as secondhand tobacco smoke [1].
[1] Moir D, Rickert WS, Levasseur G, et al. A Comparison of Mainstream and Sidestream Marijuana and Tobacco Cigarette Smoke Produced under Two Machine Smoking Conditions. American Chemical Society. 2008;21:494-502.

Any potential smoking outdoors must be addressed in regards to secondhand smoke exposure. Balconies are automatically considered smoking areas unless smoking on them is prohibited (by the building manager in the case of a leased apartment; by the initial HOA Rules and Regulations in the case of a condominium). For any compliance path, if a balcony does not comply with the requirements for exterior smoking areas (at least 25 feet away from entries, operable windows and outdoor air intakes), smoking must be prohibited on the balcony. LEED projects registered before September 4, 2006, will not be held to this interpretation, but are encouraged to do so. This ruling reflects the original intent of the IEQ Technical Advisory Group and is considered consistent with the non-residential compliance paths and with the mission of green building. The ruling is also considered reasonable because eighty percent of the U.S. population does not smoke.

The project is requesting an alternative compliance pathway for EQp2: ETS Control, by using indoor smoking cabins with in situ filtration. While air cleaning and dilution ventilation have been found to be helpful in improving visibility and reducing irritation in rooms with tobacco smoking, neither air cleaning nor dilution ventilation have been shown to provide acceptable indoor air quality from a health perspective (e.g. lung cancer, cardiovascular disease etc.). For these reasons, this approach does not meet the intent of the prerequisite and will not be accepted. Applicable Internationally; Germany.