Letter to the Editor EVIDENCE OF SUPPORT FOR SMOKE-FREE PUBLIC HOUSING AMONG NEW YORK CITY RESIDENTS The high costs of secondhand smoke exposure can be measured both by negative health outcomes and economic impact, as quantified in an article by Mason et al., “The Economic Burden of Exposure to Secondhand Smoke for Child and Adult Never Smokers Residing in U.S. Public Housing,” in the May/June 2015 issue of Public Health Reports. In that article, the authors concluded that implementing smoke-free policies in all U.S. public housing would save both lives and money.1 The New York City (NYC) Department of Health and Mental Hygiene (DOHMH) agrees that smoke-free housing is important to protect health and has long supported smoke-free housing for all, including those in public housing. Since 2009, the U.S. Department of Housing and Urban Development (HUD) has repeatedly encouraged public housing authorities (PHAs) to voluntarily adopt smoke-free housing regulations for their buildings, including publishing a smoke-free housing toolkit to help both PHAs and owners/agents of subsidized or market-rate multiunit housing become smoke-free.2–5 As of July 1, 2015, more than 250 PHAs had enacted smoke-free building policies.6 Moreover, on November 12, 2015, HUD officially proposed rules that would require all PHAs to establish a smoke-free housing policy that prohibits lit tobacco products in all indoor areas of public housing.7 It is worth noting that as of October 2015, no organization that had implemented smoke-free housing had faced a legal challenge. The absence of a legal challenge is no surprise, as the law does not confer smokers, as a group, with special legal rights or privileges.8–10 Furthermore, nicotine dependence is not a disability recognized by law.11 Consequently, to survive a legal challenge, a smoke-free policy must pass a relatively easy test; it must be rationally related to a legitimate government interest (e.g., protecting the health of its residents). DOHMH is committed to improving access to smoke-free housing for all New Yorkers and has been working with the New York State Department of Health and partner organizations for many years to encourage the voluntary adoption of smoke-free housing
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among operators of multiunit housing. The federal government’s support of smoke-free housing in public housing will have a substantial impact that, as shown by Mason et al., would be measurable in health and economic terms. It is our hope that this federal action will demonstrate to housing operators that implementing smoke-free policies for all multiunit housing is an achievable goal that will lead to measurable health and economic impacts on all multiunit housing residents, regardless of income. In 2012, DOHMH, the NYC Housing Authority (NYCHA), and NYC Smoke-Free at Public Health Solutions partnered to conduct the Clean-Air Survey (CAS), a cross-sectional telephone survey of a random sample of 1,200 adult (aged $18 years) residents of NYCHA—the largest public housing authority in the United States, with more than 400,000 residents12,13 —to assess their experiences with secondhand smoke exposure, associated health outcomes, and support for smoke-free housing. In a comparison of results from the CAS with the annual NYC Community Health Survey (CHS), a cross-sectional telephone survey of about 8,500 randomly selected adults aged $18 years from NYC, residents of NYCHA reported smelling cigarette smoke in their home that came from another apartment or outside more often than New Yorkers overall (54% vs. 40%) (CHS 2013), and 84% of those NYCHA residents reported being bothered by secondhand smoke. NYCHA residents were about twice as likely to report having asthma as NYC adults (23% vs. 12%) (CHS 2013), and more than one-third (34%) of NYCHA residents reported having one or more children with asthma compared with one in eight children (13%) among New Yorkers overall (CHS 2009). Consistent with other studies, 75% of NYCHA residents preferred to live in a building where smoking was not allowed anywhere inside the building, including apartments.14–16 Additionally, 64% of NYCHA residents responded that all NYC public housing or projects should be smoke-free. Given the financial burden and health impact caused by secondhand smoke, as well as the popular support among NYCHA residents for smoke-free housing, DOHMH concurs that nationwide, increased smokefree housing, including in public housing, would be one way to begin to reduce adverse health outcomes
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and the fiscal burden associated with secondhand smoke exposure. Shannon M. Farley, DrPHa Kevin R.J. Schroth, JDa Christine Johnson Curtis, MBAa Sonia Angell, MD, MPHa New York City Department of Health and Mental Hygiene
a
REFERENCES 1. Mason J, Wheeler W, Brown MJ. The economic burden of exposure to secondhand smoke for child and adult never smokers residing in U.S. public housing. Public Health Rep 2015;130:230-44. 2. Department of Housing and Urban Development (US). Notice no. PIH-2009-21 (HA). Non-smoking policies in public housing (July 17, 2009) [cited 2015 Aug 26]. Available from: http://www.hud .gov/offices/pih/publications/notices/09/pih2009-21.pdf 3. Department of Housing and Urban Development (US). Notice no. PIH-2012-25. Smoke-free policies in public housing (May 29, 2012) [cited 2015 Aug 26]. Available from: http://portal.hud.gov /huddoc/pih2012-25.pdf 4. Department of Housing and Urban Development (US). Notice no. PIH 2012-22. Further encouragement for O/As to adopt optional smoke-free housing policies (October 26, 2012) [cited 2015 Aug 26]. Available from: http://portal.hud.gov/hudportal/documents /huddoc?id=12-22hsgn.pdf 5. Department of Housing and Urban Development (US). Smoke-free multifamily housing toolkits [cited 2015 Aug 26]. Available from: http://portal.hud.gov/hudportal/HUD?src=/smokefreetoolkits
6. Americans for Nonsmokers’ Rights. U.S. laws and policies restricting or prohibiting smoking in private units of multi-unit housing [cited 2015 Aug 26]. Available from: http://www.no-smoke.org /pdf/smokefreemuh.pdf 7. Department of Housing and Urban Development (US). Housing and Urban Development (HUD): HUD Secretary Castro announces new rule making public housing smoke-free [press release]; 2015 Nov 12 [cited 2015 Nov 30]. Available from: http://portal.hud.gov hudportal/hud?src=/press/press_releases_media_advisories/2015 /hudno_15-144 8. Fagan v. Axelrod, 550 N.Y.S.2d 552, 559 (1990). 9. People v. Broadie, 37 N.Y.S.2d 100 (1975). 10. NYC C.L.A.S.H. Inc. v. City of New York, 315 F. Supp. 2d 461, 482 (2004). 11. Brashear v. Simms, 138 F. Supp. 2d 693, 695 (2001). 12. New York City Housing Authority. Facts about NYCHA. 2015 [cited 2015 Jul 6]. Available from: http://www1.nyc.gov/assets/nycha /downloads/pdf/factsheet.pdf 13. Kimura D. Top public housing authorities. Affordable Housing Finance 2010 Apr 1 [cited 2015 Jul 7]. Available from: http://www.housingfinance.com/developments/top-public -housing-authorities_o 14. Cook NJ, Hollar L, Chavez S, Quinn DL, Phillips T, DeLucca M, et al. Support for smoke-free multi-unit housing policies among racially and ethnically diverse, low-income seniors in south Florida. J Cross Cult Gerontol 2014;29:405-15. 15. Hood NE, Ferketich AK, Klein EG, Wewers ME, Pirie P. Individual, social, and environmental factors associated with support for smokefree housing policies among subsidized multiunit housing tenants. Nicotine Tob Res 2013;15:1075-83. 16. King BA, Cummings KM, Mahoney MC, Juster HR, Hyland AJ. Multiunit housing residents’ experiences and attitudes toward smoke-free policies. Nicotine Tob Res 2010;12:598-605.
Public Health Reports / January–February 2016 / Volume 131
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among operators of multiunit housing. The federal government’s support of smoke-free housing in public housing will have a substantial impact that, as shown by Mason et al., would be measurable in health and economic terms. It is our hope that this federal action will demonstrate to housing operators that implementing smoke-free policies for all multiunit housing is an achievable goal that will lead to measurable health and economic impacts on all multiunit housing residents, regardless of income. In 2012, DOHMH, the NYC Housing Authority (NYCHA), and NYC Smoke-Free at Public Health Solutions partnered to conduct the Clean-Air Survey (CAS), a cross-sectional telephone survey of a random sample of 1,200 adult (aged $18 years) residents of NYCHA—the largest public housing authority in the United States, with more than 400,000 residents12,13 —to assess their experiences with secondhand smoke exposure, associated health outcomes, and support for smoke-free housing. In a comparison of results from the CAS with the annual NYC Community Health Survey (CHS), a cross-sectional telephone survey of about 8,500 randomly selected adults aged $18 years from NYC, residents of NYCHA reported smelling cigarette smoke in their home that came from another apartment or outside more often than New Yorkers overall (54% vs. 40%) (CHS 2013), and 84% of those NYCHA residents reported being bothered by secondhand smoke. NYCHA residents were about twice as likely to report having asthma as NYC adults (23% vs. 12%) (CHS 2013), and more than one-third (34%) of NYCHA residents reported having one or more children with asthma compared with one in eight children (13%) among New Yorkers overall (CHS 2009). Consistent with other studies, 75% of NYCHA residents preferred to live in a building where smoking was not allowed anywhere inside the building, including apartments.14–16 Additionally, 64% of NYCHA residents responded that all NYC public housing or projects should be smoke-free. Given the financial burden and health impact caused by secondhand smoke, as well as the popular support among NYCHA residents for smoke-free housing, DOHMH concurs that nationwide, increased smokefree housing, including in public housing, would be one way to begin to reduce adverse health outcomes
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Letter to the Editor 3
and the fiscal burden associated with secondhand smoke exposure. Shannon M. Farley, DrPHa Kevin R.J. Schroth, JDa Christine Johnson Curtis, MBAa Sonia Angell, MD, MPHa New York City Department of Health and Mental Hygiene
a
REFERENCES 1. Mason J, Wheeler W, Brown MJ. The economic burden of exposure to secondhand smoke for child and adult never smokers residing in U.S. public housing. Public Health Rep 2015;130:230-44. 2. Department of Housing and Urban Development (US). Notice no. PIH-2009-21 (HA). Non-smoking policies in public housing (July 17, 2009) [cited 2015 Aug 26]. Available from: http://www.hud .gov/offices/pih/publications/notices/09/pih2009-21.pdf 3. Department of Housing and Urban Development (US). Notice no. PIH-2012-25. Smoke-free policies in public housing (May 29, 2012) [cited 2015 Aug 26]. Available from: http://portal.hud.gov /huddoc/pih2012-25.pdf 4. Department of Housing and Urban Development (US). Notice no. PIH 2012-22. Further encouragement for O/As to adopt optional smoke-free housing policies (October 26, 2012) [cited 2015 Aug 26]. Available from: http://portal.hud.gov/hudportal/documents /huddoc?id=12-22hsgn.pdf 5. Department of Housing and Urban Development (US). Smoke-free multifamily housing toolkits [cited 2015 Aug 26]. Available from: http://portal.hud.gov/hudportal/HUD?src=/smokefreetoolkits
6. Americans for Nonsmokers’ Rights. U.S. laws and policies restricting or prohibiting smoking in private units of multi-unit housing [cited 2015 Aug 26]. Available from: http://www.no-smoke.org /pdf/smokefreemuh.pdf 7. Department of Housing and Urban Development (US). Housing and Urban Development (HUD): HUD Secretary Castro announces new rule making public housing smoke-free [press release]; 2015 Nov 12 [cited 2015 Nov 30]. Available from: http://portal.hud.gov hudportal/hud?src=/press/press_releases_media_advisories/2015 /hudno_15-144 8. Fagan v. Axelrod, 550 N.Y.S.2d 552, 559 (1990). 9. People v. Broadie, 37 N.Y.S.2d 100 (1975). 10. NYC C.L.A.S.H. Inc. v. City of New York, 315 F. Supp. 2d 461, 482 (2004). 11. Brashear v. Simms, 138 F. Supp. 2d 693, 695 (2001). 12. New York City Housing Authority. Facts about NYCHA. 2015 [cited 2015 Jul 6]. Available from: http://www1.nyc.gov/assets/nycha /downloads/pdf/factsheet.pdf 13. Kimura D. Top public housing authorities. Affordable Housing Finance 2010 Apr 1 [cited 2015 Jul 7]. Available from: http://www.housingfinance.com/developments/top-public -housing-authorities_o 14. Cook NJ, Hollar L, Chavez S, Quinn DL, Phillips T, DeLucca M, et al. Support for smoke-free multi-unit housing policies among racially and ethnically diverse, low-income seniors in south Florida. J Cross Cult Gerontol 2014;29:405-15. 15. Hood NE, Ferketich AK, Klein EG, Wewers ME, Pirie P. Individual, social, and environmental factors associated with support for smokefree housing policies among subsidized multiunit housing tenants. Nicotine Tob Res 2013;15:1075-83. 16. King BA, Cummings KM, Mahoney MC, Juster HR, Hyland AJ. Multiunit housing residents’ experiences and attitudes toward smoke-free policies. Nicotine Tob Res 2010;12:598-605.
Public Health Reports / January–February 2016 / Volume 131
