Comment Submissions - Notice of Public Comment Period and Workshops on a Draft Cancer Inhalation Unit Risk for Ethylene Oxide

Without question, we should regulate the large ethylene oxide (EtO) sterilizers. Their EtO usage is higher than smaller facilities, often by orders of magnitude. However, if attempting to reduce total levels of airborne EtO to the levels of parts per trillion, the state of California would have greater success by banning tobacco products rather than overly regulating small- to medium-sized commercial sterilizers. Statewide emissions from cigarettes alone can contribute 200 times more EtO than all the commercial sterilizers combined. In California, cigarettes emit up to 180,000 pounds EtO per year, while 40 sterilization facilities in the year 2019 emitted a combined total of 793 pounds. After regulating the large EtO sterilizers, if California wishes to better control total airborne EtO levels down to the parts per trillion, air quality would benefit far more by banning tobacco products that contribute little to society, rather than overly regulating small- to medium-sized commercial sterilizers that provide valuable infection-prevention services to the healthcare industry. Calculations and assumptions: 1. Cigarettes are responsible for 7 mg EtO per cigarette (IARC, 2012). 2. Annual per-capita consumption by Californians is 15 packs (Orzechowski and Walker. The Tax Burden on Tobacco, 2021). 3. At 20 cigarettes per pack, the average Californian consumes 300 cigarettes per year. 4. At 7 mg EtO per cigarette, the average Californian could generate up to 2.1 g EtO through cigarette usage. 5. Using a state population of 39 million people, cigarette usage would therefore contribute up to 82 thousand kilograms, or 180 thousand pounds, of EtO. 6. In the pre-pandemic year 2019, 40 sterilization facilities emitted a combined total of 793 pounds (CARB, 2022). 7. For eight out of ten years, 2011-2020, most of the ethylene oxide came from a single source (CARB, 2022).