Reasonable Marijuana Regulation in Missouri

Keep Columbia Free called and asked us to join the effort to reform marijuana laws in Missouri. To this end, we suggested that the editors of the St. Louis Post-Dispatch publish John Payne's strong op-ed and help begin the discussion statewide.

http://www.stltoday.com/news/opinion/guest-commentary-marijuana-laws-should-spare-adult-smokers/article_b69c95b5-b138-512f-aaa6-78f52d608407.html

EPA Overestimates Air Pollution Life Risk

Enstrom091611

Letter to Indiana Governor Mitch Daniels

Dear Governor Daniels,

I read online that you are considering supporting a smoking ban for Indiana. I wanted to warn you that smoking bans across the country have done grave economic harm to adult venues such as bars and casinos.

Please find attached to this e-mail a number of studies, all conducted by PhD economists, which find that smoking bans do indeed harm businesses such as bars and casinos. While I am sure the American Cancer Society has presented to you many contrary studies which find that smoking bans do no economic harm, I have to warn you that these contrary studies have been conducted almost entirely by public health professionals, not economists, and have been published in public health journals, not economic journals. As economist Dr. Jonathan Tomlin pointed out in Forbes Magazine, these amateur studies are "riddled with statistical shortcomings and... flaws."

http://www.forbes.com/2009/06/04/economic-impact-bars-restaurants-opinions-contributors-smoking-ban.html

Please allow me to suggest to you the preemptive exemption for "over 21" workplaces in the Tennessee smoking ban. Such an exemption would greatly reduce any economic harm threatened by an Indiana smoking ban. Please find the Tennessee public smoking law attached.

Governor Daniels, the latest Gallup Poll shows that while most Americans do favor a ban on smoking in restaurants, Americans also favor some sort of compromise accommodation of smokers in adult venues such as bars and casinos. Only 31 percent of Americans favor a total ban on smoking in bars and casinos. I am sure similar numbers hold true in Indiana as well.
http://www.gallup.com/poll/141809/americans-smoking-off-menu-restaurants.aspx

Bill Hannegan

Home phone: 314.367.3779 

Cell phone: 314.315.3779

 

Links to Attached Studies:

The Effect of Smoking Bans on Bars and Restaurants: An Analysis of Changes in Employment

Adams, Scott and Cotti, Chad D. (2007) "The Effect of Smoking Bans on Bars and Restaurants: An Analysis of Changes in Employment," The B.E. Journal of Economic Analysis & Policy: Vol. 7: Iss. 1 (Contributions), Article 12. 
DOI: 10.2202/1935-1682.1628

http://www.bepress.com/bejeap/vol7/iss1/art12/

The Impact of Smoking Bans on the Hospitality Industry: New Evidence from Stock Market Returns

Jonathan T. Tomlin (2009) “The Impact of Smoking Bans on the Hospitality Industry: New Evidence

from Stock Market Returns,”

The B.E. Journal of Economic Analysis & Policy: Vol. 9: Iss.

1 (Contributions), Article 13.

http://ideas.repec.org/a/bpj/bejeap/v9y2009i1n13.html

The Economic Impact of a Smoking Ban in Columbia, Missouri: An Analysis of Sales Tax Data for the First Year

Michael R. Pakko, Federal Reserve Bank of St. Louis

Regional Economic Development, 2008, 4(1), pp. 30-40.

http://65.89.18.138/publications/red/2008/01/Pakko.pdf

The Economic Impact of the New York State Smoking Ban on New York’s Bars

Ridgewood Economic Associates, Ltd., 2004

http://heartland.org/sites/all/modules/custom/heartland_migration/files/pdfs/19885.pdf

An Analysis of the Economic Effect of the Lexington-Fayette County, Kentucky Smoking Ban of 2004

Richard Thalheimer, Thalheimer Research Associates, Inc., 2005

http://kuneman.smokersclub.com/PDF/KYLexingtonThalheimerreport6_8_05.pdf

A Report on the Impacts of the City of Dallas Smoking Ban on Alcoholic Beverage Sales March 2003 to March 2004

Terry L. Clower, Ph.D. & Bernard L. Weinstein, professors of applied economics at the University of North Texas in Denton, 2004

http://www.scribd.com/doc/75958890/Dallas-Ban-Report-Full

The Revenue Performance of Casinos after a Smoking Ban: The Case of Illinois

Thomas A. Garrett, Michael R. Pakko, 2010,  Federal Reserve Bank of St. Louis

http://research.stlouisfed.org/wp/2009/2009-027.pdf

Impact of Smoking Bans on Restaurants

National Restaurant Association, 2004

http://www.minnesotansagainstsmokingbans.com/smoking_issuekit_200409.pdf

No Smoking at the Slot Machines: The Effect of a Smoke-Free Law on Delaware Gaming Revenues

Michael R. Pakko, 2005, Federal Reserve Bank of St. Louis

http://research.stlouisfed.org/wp/2005/2005-054.pdf

The Economic Losers from Smoking Bans

Michael L. Marlow, Regulation, 2010

http://www.cato.org/pubs/regulation/regv33n2/regv33n2-4.pdf

Smoking Ban Studies by PhD Economists Finding Business Loss

 Letter sent to City of Indianapolis & Marion County City-County Council December 6th:


Honorable Indianapolis & Marion County Councillors,

Please find attached to this e-mail a number of studies, all conducted by PhD economists, which find that smoking bans harm businesses such as bars and casinos. Based in part on these studies, St. Louis City and St. Louis County opted to exempt casinos and some bars from their separately enacted smoking bans. And just last week, again based in part on these studies, neighboring St. Charles County refused to enact a smoking ban unless it contained an exemption for "over 21" establishments such as bars and casinos.

Honorable Councillors, many studies have been conducted by health professionals and published in public health journals arguing that smoking bans do not hurt bars or casinos, yet as economist Jonathan Tomlin pointed out in Forbes Magazine, these amateur studies are "riddled with statistical shortcomings and... flaws."

http://www.forbes.com/2009/06/04/economic-impact-bars-restaurants-opinions-contributors-smoking-ban.html

In light of the best professional economic research concerning smoking bans, I hope Indianapolis bars, and bars all across America, will continue to enjoy freedom of choice concerning their smoking policies.

Sincerely,

Bill Hannegan

Home phone: 314.367.3779 

Cell phone: 314.315.3779

Links to Attached Studies:

The Effect of Smoking Bans on Bars and Restaurants: An Analysis of Changes in Employment

Adams, Scott and Cotti, Chad D. (2007) "The Effect of Smoking Bans on Bars and Restaurants: An Analysis of Changes in Employment," The B.E. Journal of Economic Analysis & Policy: Vol. 7: Iss. 1 (Contributions), Article 12. 
DOI: 10.2202/1935-1682.1628

http://www.bepress.com/bejeap/vol7/iss1/art12/

The Impact of Smoking Bans on the Hospitality Industry: New Evidence from Stock Market Returns

Jonathan T. Tomlin (2009) “The Impact of Smoking Bans on the Hospitality Industry: New Evidence

from Stock Market Returns,”

The B.E. Journal of Economic Analysis & Policy: Vol. 9: Iss.

1 (Contributions), Article 13.

http://ideas.repec.org/a/bpj/bejeap/v9y2009i1n13.html

The Economic Impact of a Smoking Ban in Columbia, Missouri: An Analysis of Sales Tax Data for the First Year

Michael R. Pakko, Federal Reserve Bank of St. Louis

Regional Economic Development, 2008, 4(1), pp. 30-40.

http://65.89.18.138/publications/red/2008/01/Pakko.pdf

The Economic Impact of the New York State Smoking Ban on New York’s Bars

Ridgewood Economic Associates, Ltd., 2004

http://heartland.org/sites/all/modules/custom/heartland_migration/files/pdfs/19885.pdf

An Analysis of the Economic Effect of the Lexington-Fayette County, Kentucky Smoking Ban of 2004

Richard Thalheimer, Thalheimer Research Associates, Inc., 2005

http://kuneman.smokersclub.com/PDF/KYLexingtonThalheimerreport6_8_05.pdf

A Report on the Impacts of the City of Dallas Smoking Ban on Alcoholic Beverage Sales March 2003 to March 2004

Terry L. Clower, Ph.D. & Bernard L. Weinstein, professors of applied economics at the University of North Texas in Denton, 2004

http://www.scribd.com/doc/75958890/Dallas-Ban-Report-Full

The Revenue Performance of Casinos after a Smoking Ban: The Case of Illinois

Thomas A. Garrett, Michael R. Pakko, 2010,  Federal Reserve Bank of St. Louis

http://research.stlouisfed.org/wp/2009/2009-027.pdf

Impact of Smoking Bans on Restaurants

National Restaurant Association, 2004

http://www.minnesotansagainstsmokingbans.com/smoking_issuekit_200409.pdf

No Smoking at the Slot Machines: The Effect of a Smoke-Free Law on Delaware Gaming Revenues

Michael R. Pakko, 2005, Federal Reserve Bank of St. Louis

http://research.stlouisfed.org/wp/2005/2005-054.pdf

The Economic Losers from Smoking Bans

Michael L. Marlow, Regulation, 2010

http://www.cato.org/pubs/regulation/regv33n2/regv33n2-4.pdf

Smoking Ban Debate Fails Again In St. Charles

Smoking Ban Debate Fails Again In St. Charles

Occupy St. Louis

Occupy St. Louis is right to protest that big corporations have sold out America. Indeed they have. We all know big corporations have sent so many American jobs overseas. Plus Big Box corporations and chains like Walmart and Home Depot have destroyed Main Street mom and pop stores. Real American freedom comes from small, independently owned businesses that Wall Street has no use for. Occupy St. Louis needs to stand up for the widespread distribution of the means of sales and production that is traditional Main Street America, the real source of American freedom

http://www.stltoday.com/news/local/metro/occupy-group-holds-meeting-at-galleria/article_4c19f04e-ec00-5060-a8a6-79fde0dcc66c.html#ixzz1ez1RG8jh

O'Fallon VFW Post 5077 down 30 percent due to smoking ban!

The O'Fallon smoking ban is taking its toll. I called VFW Post 5077 in O'Fallon about Monday night's smoking ban vote. They report being down 30 percent due to the O'Fallon smoking ban! They also said they would not have minded the ban if the Post had voted on it, rather than the general populace.

St. Charles County Nov. 28th Smoking Ban Flyer

FinalSt.CharlesCountyFlyerWithContactInfo _4_

Why the Pepper Spray?

My friends and I have been arrested at protests where we refused to walk. The police never had any trouble carting us off. Why the pepper spray?

Open Letter to St. Charles County Council

Dear St. Charles County Council Members:

Councilman Cronin announced on Veterans Day that he will propose that a smoking ban including bars and VFW halls be placed on the ballot. County Councilmen, St. Charles County bar owners and veterans groups have the right to allow the use of a legal product by adults on their private property if common sense ventilation and exhaust systems are in place. St. Charles County business owners are depending on you to protect their property rights by considering all the evidence and deciding under what conditions these business owners can continue to allow indoor smoking. Public health laws are almost never turned over to voters for a good reason. Most voters do not have the time, interest or information to make such an economic and public health judgement. Turning over the fate of St. Charles County bars and VFW halls to a free for all popularity contest driven by who can spend the most advertising dollars would be an irresponsible thing to do.

Furthermore, Councilman Cronin also seeks to offer voters a chance to specially exempt Ameristar Casino from the smoking ban. I must warn the Council that the Special Laws Clause of the Missouri Constitution forbids any special exemption of individual business from public health laws. It is wrong to ask St. Charles County voters to consider a constitutionally suspect measure that will likely lead to a legal challenge. Such a successful challenge was brought when Louisville Metro Council similarly exempted Churchill Downs from a smoking ban. Councilman Cronin's Ameristar exemption would likely suffer the same fate. http://www.courier-journal.com/article/20071221/NEWS01/71221014/Judge-throws-out-Louisville-s-smoking-ban

Councilman Cronin also stated on Friday that St. Charles County bars and VFW halls have no basis to worry about the economic impact of his smoking ban. But recent Missouri smoking ban experience argues otherwise.

For instance, bar owners in Springfield Missouri report revenue losses of up to 75 percent due to the smoking ban! VFW bingo is specially mentioned in this article as being hurt:

http://articles.kspr.com/2011-10-29/smoking-ordinance_30337606

A recent survey by Tobacco Free St. Louis reported losses of up to 75 percent among non-exempt St. Louis County businesses blaming the St. Louis County smoking ban.

The Clayton smoking ban has caused Clayton restaurant revenues (by law Clayton has only restaurants, no bars) to remain flat despite the reopening of Highway 40.

A study by a St. Louis Federal Reserve Bank economist found that the Columbia smoking ban cut overall restaurant revenues 3.5 percent, the revenues of restaurants that serve alcohol 6.5 percent and the revenues of bars 11 percent.

http://research.stlouisfed.org/publications/red/2008/01/RED_1_2008.pdf

Given the clear economic danger a smoking ban presents, I suggest that the St. Charles County Council continue to allow adult free choice in St. Charles County private businesses and clubs, particularly veterans groups, and instead simply forbid smoking in venues when minors are present. Ameristar Casino, St. Charles County bar owners and veterans groups would have no objection to such a common sense restriction.

Sincerely,

Bill Hannegan

Home phone: 314.367.3779
Cell phone: 314.315.3779

A Website to Nowhere

For close to a month ads have been running on KMOX. A man and a woman apparently sitting in a bar are concerned that people are smoking. After the man states that he thought there was a smoking ban, the woman explains that there are loopholes in the law. He states that it’s not fair or healthy. The narrator goes on to tell listeners to go to http://smokefreestl.org to find information on helping close the loopholes.

It’s a typical ad that is meant to drive users to the website. The ad is designed to appeal to listeners to take action. What I find baffling is if a listener actually went to the website they would find little information. The website as of 10/26/2011 has not been updated since July. Even then most recent updates have been links to newspaper articles. Anyone going to the site wouldn’t find any useable information.

The website is that of the nearly defunct Smoke-Free St Louis Organization. They were very active in 2009 helping to pass the St Louis City smoking ban. About two weeks before the Board of Alderman voted on the ban SFSTL lost its funding. I noted then that once nobody was paid to show at the aldermanic meeting all participation stopped. Over the next two years there have been only a couple of postings to the site.

When you look at the cost to write, pay voice actors and produce the ad how they could make such as simple mistake. Even worse, the ad ran many times daily for a month and no one ever thought to correct it. I can only guess to how much was spent on the campaign. It had to be tens of thousands if not hundreds of thousands. Can you imagine a private company spending its advertising budget to promote a product that didn’t exist!

I have mixed feelings on this latest use of stimulus funds. As someone who opposes smoking bans, I’m happy they are not using taxpayer money in an efficient way to reduce our freedom. As a taxpayer it really upsets me that I along with all Americans have to pay this money back.

Tony Palazzolo

Secondhand Paint Smoke

Is it plausible that burning paint with a torch outside could cause this sort of catastrophic effect described by this mom? I am very sceptical:

http://blogs.webmd.com/health-ehome/2011/10/my-children-had-lead-poisoning.html

American Cancer Society Missouri Tobacco Tax Increase Proposal

American Cancer Society Tobacco Tax

By this initiative petition, the American Cancer Society seeks to ensure for itself a permanent source of Missouri taxpayer funding for it lobbying activities.

Tobacco Free St. Louis Warning Letter

Dear Tobacco-Free St. Louis Directors and Officers,

All this year the singe focus of Tobacco Free St. Louis has been its escalating lobbying campaign meant to induce County municipalities to pass strict smoking bans, and to force the St. Louis County Council to eliminate all exemptions from St. Louis County's Indoor Clean Air Code. This lobbying campaign has culminated in an attempt by Chairwoman Fraser, detailed this week in the St. Louis Post-Dispatch, to enlist a federal agency to pressure the Council on this matter:
http://www.stltoday.com/news/local/metro/article_ababeaef-313f-51ff-85b5-433d14bacd63.html

Clearly a 501c3 educational charity such as Tobacco Free St. Louis is not allowed to devote itself to influencing legislation in this way: http://www.irs.gov/charities/article/0,,id=163392,00.html

While I do not wish to limit the speech or tactics of any group trying to influence St. Louis County government, it is wrong for any group lobbying to restrict the freedom of County businesses to enjoy the advantage of 501c3 tax-exempt status unavailable to the threatened businesses. I therefore ask that Tobacco Free St. Louis either abide by the lobbying rules governing 501c3 charities, or voluntarily give up its tax-exempt status. All I am asking for in this matter is fairness.

Sincerely,

Bill Hannegan

Home phone: 314.367.3779
Cell phone: 314.315.3779

Lets Face It

Lets Face It is the slogan for the anti-tobacco campaign for St Louis County. It comes from the 7.6 million dollar stimulus grant to St Louis County. They have run commercials over the past several months. One commercial caught my attention. It wasn't that the message was new or unique. It was what the message included. The commercial is several young people making statements. One of the statements is "smoking makes you look cool". The message is that people say all kinds of weird things that aren't true. The statement that I found odd was "One day I'll find calculus useful." Now we have a government agency making fun of a higher education. Are we now using tax dollars to dissuade people from higher learning? Now I don't believe that anyone is going to drop calculus because of this commercial. Of course I don't believe that anyone is going to quit smoking either. One idea did pop in my mind. Of course they don't like people with higher math skills. The entire anti-smoking campaign is built on the general populations lack of math skill. If you understand how to read the research you understand that the "risk" is so small that it can't be measured. You would understand that driving to a restaurant or bar is hundreds of times more risky. You would ask questions that they can't answer honestly. I'm sure this was not their intent. I don't have a problem with programs that help people stop smoking. Does it really take millions of dollars to advertise a website that regurgitated all the quit smoking strategies. Even worse it pushes people away from far more effective methods of auricular therapy, electronic cigarettes and cold turkey. The message is that the only way to do it is with pharma nicotine replacement drugs and counseling. Its really a taxpayer paid advertisement for pharmaceutical solutions. I wouldn't have a problem if it was effective. I wouldn't have a problem if it disseminated unbiased information. I wouldn't have a problem if as a taxpayer I didn't have to pay this money back. Lets Face It, they are more interested in pushing pharma products then helping people quit. Lets face it, it's a complete waste of money.


Tony Palazzolo

Councilman Steve Stenger

Back in March, Tobacco Free St. Louis head Pat Lindsey assured everyone that the elimination of exemptions was such "a done deal" by County Executive Dooley and the Health Department that she didn't even need to lobby anymore, as if an exemption free ordinance had already been written.
http://blogs.riverfronttimes.com/dailyrft/2011/03/county_smoking_ban_exemptions_st_louis.php

New Tobacco Free St. Louis head Barb Fraser recently warned the County Council that they owed the elimination of the exemptions in exchange for the $7,000,000 of Stimulus money the County Health Department got to fight smoking.
http://mogasp.wordpress.com/2011/08/01/2011-07-27-p-d-st-louis-county-council-is-urged-to-end-smoking-ban-exemptions/

I am glad to see that Councilman Stenger has resolved to do his own independent thinking on this issue. Check Jason Rosenbaum's Patch article on Stenger:

http://clayton-richmondheights.patch.com/articles/stenger-smoking-ban-changes-wont-come-immediately

Barbara Fraser and Tobacco Free St. Louis

Dear Board Members of Tobacco Free St. Louis,

An article by Brett Blume of KMOX identifies Barbara Fraser as the new head of Tobacco Free St. Louis. If this is so, I hope the Board will remind Ms. Fraser that her new position puts limits on her former ability to lobby for smoking bans. I am all for Ms. Fraser's freedom to promote specific smoking ban legislation as a private citizen or councilman, but she now can no longer do that as the head of a tax-exempt educational charity. Her statements at the July 13th press conference clearly constitute the "lobbying" or "attempts to influence legislation" in St. Louis County that is beyond the legitimate educational purpose of a 501c3 charity.
http://www.irs.gov/charities/article/0,,id=163392,00.html

I hope in the future Ms.Fraser will work to educate the St. Louis public concerning the dangers of tobacco smoke and the possible benefits of smoking bans in general, but leave the fight for specific new laws for St. Louis County to grassroots political groups who can legitimately undertake that fight.

Sincerely,

Bill Hannegan
Home phone: 314.367.3779
Cell phone: 314.315.3779

Barbara Fraser heads Tobacco Free St. Louis

I checked with reporter Brett Blume at KMOX yesterday and he confirmed that Barbara Fraser has replaced Pat Lindsey as the head of Tobacco Free St. Louis. I am not sure this was a smart move. Everyone liked Pat Lindsey, but a lot of hard feelings on County Council remain due to her handling of the smoking ban issue in 2009.

Letter to Stacy Reliford

Dear Chairman Reliford,

I was alarmed that the survey released today by the American Cancer Society is so at odds with previous research concerning St. Louis County. The latest survey by Missouri Department of Health and Senior Services found that only 30 percent of County residents favored a total ban on smoking in bars and cocktail lounges. This finding was backed up by a 2010 national Gallup Poll which found that only 30 percent of Americans favor a total ban on smoking in bars. I find the sudden change of local opinion your survey implies implausible.

I am also disappointed that the Mellman group was chosen to conduct your phone survey. In its website self-description, the Mellman group reveals itself to be more of a PR/advocacy firm than a neutral research group! They make this promise to paying clients like the American Cancer Society:

"Whether winning for you means getting more votes than your opponent, selling more product, changing public policy, raising more money or generating more activism, The Mellman Group transforms data into winning strategies."
http://www.mellmangroup.com/

I have to wonder if the "win at all costs" philosophy of the Mellman group led to some bias in the questions asked or the selection of those called. Perhaps you could release the survey in order to resolve any doubt.

Chairman Reliford, I was also surprised to learn today in the KMOX report that former County Councilman Barbara Fraser was chosen to head Tobacco Free St. Louis. This choice bodes ill for St. Louis County small bars since Ms. Fraser has privately stated that casinos are "too powerful to include in a smoking ban". I hope you and she are not working to ban smoking in all St. Louis County mom and pop bars, but exempt the "powerful" casinos! As you know, the only fair and rational exemption is an "over 21" exemption that treats all businesses equally. To exempt only casinos is just wrong.

Sincerely,

Bill Hannegan

Home phone: 314.367.3779
Cell phone: 314.315.3779

Dr. Varun Puri's Statements in Suburban Journal

Dear St. Charles County Councilmen,

In a Suburban Journal article yesterday, Dr. Varun Puri made statements in support of a St. Charles County smoking ban that need qualification. While Dr. Puri rightly suggests that no one in the scientific community contends that all secondhand smoke exposure is without ill health effects, the extent of those ill-effects is indeed still in dispute as is the ability of ventilation/filtrations systems to reduce secondhand smoke exposure to an tolerable level. As evidence of this ongoing dispute, please find attached a letter written in 2009 by Dr. Geoffrey Kabat, Senior Epidemiologist at the Albert Einstein College of Medicine, to the St. Louis County Council, which questions the extent of the life risk of second smoke and makes this statement about the use of air filtration to address the health concerns of secondhand smoke:

"Yet, since the available evidence suggests that the effects of environmental tobacco smoke, particularly for coronary heart disease, are considerably smaller than generally believed, lawmakers may therefore have greater latitude than generally believed to consider the segregation of smokers and nonsmokers and the use of air filtration as adequate and responsible ways to address the health concerns of environmental tobacco smoke in workplaces such as bars and restaurants."

Please also find attached a letter from Dr. Roger Jenkins, a scientist at the Department of Energy's Oak Ridge National Laboratory, who led the largest study ever conducted concerning the actual smoke exposure of employees in bars and restaurants in 16 US cites, as well as tests of the effectiveness of restaurant ventilation systems against secondhand smoke. St. Louis was one of the cities tested. Dr. Jenkins sums up his findings:

"Overall concentrations of ETS were fairly low: the highest concentration of particles measured in any facility were still 1/7th of the OSHA Permissible Exposure Limit...The data from the study indicated that it is possible to reduce ETS in the non‐smoking section to levels that are comparable to those encountered in similar facilities in which smoking is prohibited altogether. The findings suggested that effective segregation of smoking and non‐smoking areas in hospitality facilities is both achievable and economically viable if sufficient attention is given to overall system design, robust air exchange rates, directional airflow, and the use of appropriate heat recovery systems."

Let me further add that even Surgeon General Carmona in his 2006 report reserved judgement concerning the ability of air filtration systems to remove smoke from bar and restaurant air saying that their effectiveness needed more widespread demonstration to be accepted. Local bar employees report that such systems can indeed remove the sight and smell of smoke, and tests conducted by the casinos have found that their best air filtration systems are able to render indoor air as clean as the air outdoors despite indoor smoking. Please find this casino research attached.

Councilmen, please do not let overblown statements in the press by smoking ban advocates bully you into not considering technologies that could provide a legitimate basis for a rational smoking ban exemption such as the City of Chicago included in its ban. Though I believe OSHA's ruling concerning secondhand smoke in the workplace should be accepted as final, rational options short of a total County ban exist which can allow business owners, employees and patrons continued free choice and should be explored.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24602

Sincerely,

Bill Hannegan
314.367.3779
314.315.3779 (cell)