[Senate Hearing 110-1118]
[From the U.S. Government Publishing Office]
S. Hrg. 110-1118
THE ACCURACY OF THE FTC TAR
AND NICOTINE CIGARETTE RATING SYSTEM
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HEARING
before the
COMMITTEE ON COMMERCE,
SCIENCE, AND TRANSPORTATION
UNITED STATES SENATE
ONE HUNDRED TENTH CONGRESS
FIRST SESSION
__________
NOVEMBER 13, 2007
__________
Printed for the use of the Committee on Commerce, Science, and
Transportation
U.S. GOVERNMENT PRINTING OFFICE
73-848 WASHINGTON : 2012
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SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION
ONE HUNDRED TENTH CONGRESS
FIRST SESSION
DANIEL K. INOUYE, Hawaii, Chairman
JOHN D. ROCKEFELLER IV, West TED STEVENS, Alaska, Vice Chairman
Virginia JOHN McCAIN, Arizona
JOHN F. KERRY, Massachusetts TRENT LOTT, Mississippi
BYRON L. DORGAN, North Dakota KAY BAILEY HUTCHISON, Texas
BARBARA BOXER, California OLYMPIA J. SNOWE, Maine
BILL NELSON, Florida GORDON H. SMITH, Oregon
MARIA CANTWELL, Washington JOHN ENSIGN, Nevada
FRANK R. LAUTENBERG, New Jersey JOHN E. SUNUNU, New Hampshire
MARK PRYOR, Arkansas JIM DeMINT, South Carolina
THOMAS R. CARPER, Delaware DAVID VITTER, Louisiana
CLAIRE McCASKILL, Missouri JOHN THUNE, South Dakota
AMY KLOBUCHAR, Minnesota
Margaret L. Cummisky, Democratic Staff Director and Chief Counsel
Lila Harper Helms, Democratic Deputy Staff Director and Policy Director
Christine D. Kurth, Republican Staff Director and General Counsel
Paul Nagle, Republican Chief Counsel
C O N T E N T S
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Page
Hearing held on November 13, 2007................................ 1
Statement of Senator Lautenberg.................................. 1
Statement of Senator Stevens..................................... 3
Witnesses
Ashley, Ph.D., David L., Chief, Emergency Response and Air
Toxicants Branch; Chief, Tobacco Laboratory, National Center
for Environmental Health, Centers for Disease Control and
Prevention (CDC), Department of Health and Human Services; and
Chair, Tobacco Laboratory Network, World Health Organization... 15
Prepared statement........................................... 17
Backinger, Ph.D., Cathy L., Acting Chief, Tobacco Control
Research Branch, National Cancer Institute, National Institutes
of Health, U.S. Department of Health and Human Services........ 10
Prepared statement........................................... 11
Goldberg, Ph.D., Marvin E., Irving & Irene Bard Professor of
Marketing, Smeal College of Business, Penn State University.... 39
Prepared statement........................................... 40
Henningfield, Ph.D., Jack E., Vice President, Research and Health
Policy, Pinney Associates; Professor of Behavioral Biology,
Adjunct, and Director, Innovators Awards Program, Department of
Psychiatry and Behavioral Sciences, The Johns Hopkins
University School of Medicine.................................. 33
Prepared statement........................................... 35
Kovacic, Hon. William E., Commissioner, Federal Trade Commission. 3
Prepared statement........................................... 5
Samet, M.D., M.S., Jonathan M., Professor and Chairman,
Department of Epidemiology, Johns Hopkins Bloomberg School of
Public Health.................................................. 25
Prepared statement........................................... 26
Sheller, Esq., Stephen A., Founder and Managing Partner, Sheller,
P.C............................................................ 50
Prepared statement........................................... 51
Appendix
Article from Pediatrics--Official Journal of the American
Academy, dated October 2004, entitled ``Adolescents' Beliefs
About the Risks Involved in Smoking ``Light'' Cigarettes''..... 75
Article from the American Journal of Public Health, dated
December 2006, entitled ``Effect of Televised, Tobacco Company-
Funded Smoking Prevention Advertising on Youth Smoking-Related
Beliefs, Intentions, and Behavior''............................ 58
Harbour, Hon. Pamela Jones, Commissioner, Federal Trade
Commission, prepared statement................................. 57
Letter, dated May 10, 2007, to Hon. Frank R. Lautenberg from Hon.
Pamela Jones Harbour, Commissioner, Federal Trade Commission... 57
R.J. Reynolds Tobacco Co., prepared statement.................... 84
Response to written questions submitted by Hon. Daniel K. Inouye
to:
Hon. William E. Kovacic...................................... 68
Response to written questions submitted by Hon. Frank R.
Lautenberg to:
Marvin E. Goldberg, Ph.D..................................... 73
Supplemental information submitted by Cathy L. Backinger, Ph.D... 69
THE ACCURACY OF THE FTC TAR AND NICOTINE CIGARETTE RATING SYSTEM
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TUESDAY, NOVEMBER 13, 2007
U.S. Senate,
Committee on Commerce, Science, and Transportation,
Washington, DC.
The Committee met, pursuant to notice, at 2:35 p.m. in room
SR-253, Russell Senate Office Building, Hon. Frank R.
Lautenberg, presiding.
OPENING STATEMENT OF HON. FRANK R. LAUTENBERG,
U.S. SENATOR FROM NEW JERSEY
Senator Lautenberg. Now, we shall call the meeting to
order. OK.
Today's hearing is part of our oversight of the Federal
Trade Commission's activities. We're going to look closely at
the FTC's role in the regulation of cigarette marketing. We're
going to focus on the tests that the FTC has permitted tobacco
companies to use for decades to measure the tar and nicotine
levels of its cigarettes. Smokers have long relied on these tar
and nicotine ratings to determine which cigarettes to smoke.
For example, cigarettes with a low tar FTC rating are marketed
as ``light'' cigarettes, and, as we're going to learn from
today's hearing, smokers believe that when they switch to a
light cigarette they're turning to a safer alternative than a
regular cigarette. But the National Cancer Institute and other
studies show that switching to a light cigarette may not only
be as bad as a regular cigarette, but often its worse for your
health. I want to repeat that, that a light cigarette can often
be more deadly than a regular cigarette. And addicted smokers
are the victims of this deception.
Now, I, too, was a smoker. But, fortunately, my 10-year-old
daughter convinced me to stop. One day when I lit a cigarette
at home, she said, and I'll quote her, ``Daddy, they told me at
school that, if you smoke, that you get a black box in your
throat, and I love you, and I don't want you to get a black box
in your throat.'' And it took me a couple of days, and that was
the end of smoking. And I know it's not easy to give it up. As
I smoked in those years, I kept thinking about giving it up,
and never quite made it.
The reality is that most smokers are addicted to a drug, a
drug called nicotine. And that's what we're going to learn in
this hearing, it's the effect of nicotine on the brain that
renders the FTC rating method inaccurate. The FTC employs the
use of what some have called the ``smoking robot machine.'' And
thanks to the Centers for Disease Control, we have a short
video which I'd like to show you now.
Now, can the people sitting in the audience see this? It
demonstrates the FTC Method and the smoking robot.
Now, when you look at these nonaddicted machines, you don't
get an accurate picture as to what really is happening. The
machine's smoking, and the machine's life cycle is not
affected. But the smokers' are. The reality is that smokers
don't smoke cigarettes like a machine; rather, our brains
manipulate puffing patterns to make sure that a smoker takes in
enough nicotine from every cigarette to soothe the addiction.
And that's why many who switch from Marlboros to Marlboro
Lights wind up getting more tar, because they're taking longer
and deeper puffs to bring in the same amount of nicotine that
they got from a standard Marlboro cigarette. And even the FTC
has the knowledge that, in its testing method, that it doesn't
work.
In fact, in May 2000, the FTC put out a consumer alert
about their tar and nicotine ratings which said--I quote here--
``Don't count on the numbers,'' and ``cigarette tar and
nicotine ratings can't predict the amount of tar and nicotine
that you get.'' So, the FTC was saying, essentially, ``Don't
pay attention to our own system.'' The FTC should not allow,
therefore, this rating system to continue if it cannot stand
behind it. And big tobacco should not be able to hide behind
the FTC Method to justify the claim that light and low-tar
cigarettes are healthier.
In 2005, in this committee, I tried to fix this problem,
and I brought an amendment to prohibit the tobacco companies
from continuing to use the FTC Method to justify health claims
about their cigarettes. My amendment lost on a party-line vote.
And I'm hopeful that, in the wake of this hearing, that we can
build momentum to finally tackle this problem seriously.
The issue of tobacco control is a critical issue for our
country. Tobacco-related illnesses rob more than 400,000
Americans of their lives each and every year. And tobacco
creates $89 billion in annual healthcare costs.
Now, just last week, the Centers for Disease Control
reported that recent declines in smoking have stopped. Now,
this is a disturbing development for America's public health.
And, as many know, I have a long history of trying to write
sensible laws to help control the damage caused by tobacco use.
Now, I wrote the law banning smoking on airplanes in 1987.
That law changed our Nation's culture about secondhand smoke
and helped usher in the smoke-free revolution that we're now
seeing across the country. And I'm proud that my home state of
New Jersey recently passed a statewide law banning smoking in
restaurants, bars, and workplaces.
I also wrote the law, in 1994, that requires that all
buildings that house federally funded programs for children
maintain a smoke-free environment. And now, we have another
urgent tobacco problem to fix.
So, I look forward to hearing the testimony from our
witnesses today.
And I'm pleased to be sitting here with a colleague and an
ally in this, the Vice Chairman of the Commerce Committee,
Senator Stevens.
STATEMENT OF HON. TED STEVENS,
U.S. SENATOR FROM ALASKA
Senator Stevens. Thank you very much.
I was trying to remember who was the author of that bill on
Federal buildings, you or me, but it's all right.
I do thank you for holding the hearing, and I think there
is a lot that remains to be done in this area. The FTC has used
the same rating system to measure tar, nicotine, and carbon
monoxide yields for 40 years yet cigarette design has not
remained the same during this period. Concerns have been
expressed to us that consumers are being misled by the
cigarette rating system that's currently in use as it relates
to light and low-tar cigarettes. The test machine was not
intended to imitate human smokers, yet that is how consumers
are interpreting the test results. I look forward to hearing
the witnesses today.
And, unfortunately, I have another meeting at 3:30, but I'm
pleased you have held this hearing, Mr. Chairman.
Senator Lautenberg. Thanks very much.
Now, I want to welcome our witnesses, but I also want to
point out that both Altria, formerly known as Philip Morris,
and R.J. Reynolds were asked if they would testify today, and
they both refused. The Committee's going to explore,
nevertheless, what steps will be taken to gather information
from these companies after this hearing.
And, with that, I welcome our first panel. We have Mr.
William Kovacic, a Commissioner of the Federal Trade
Commission; Dr. Cathy Backinger, the Acting Chief of the
Tobacco Control Research Branch of the National Cancer
Institute; and Dr. David Ashley, the Chief of the Division of
Laboratory Sciences at the Centers for Disease Control and
Prevention. And I thank you for joining us.
Mr. Kovacic, you may begin, please. And we ask you to hold
your testimony to 5 minutes, if you will.
STATEMENT OF HON. WILLIAM E. KOVACIC, COMMISSIONER, FEDERAL
TRADE COMMISSION
Mr. Kovacic. Thank you, Vice Chairman Stevens and Senator
Lautenberg, for the opportunity to testify about the Federal
Trade Commission's work concerning tar and nicotine ratings for
cigarettes.
The written statement that I submitted presents the views
of the Commission itself, and my spoken remarks today present
my own views, and not necessarily those of my colleagues.
The question of how to give consumers useful information
about the health risks of smoking has commanded the FTC's
attention for nearly a half century. It was the FTC's cigarette
rule in 1964, which required cigarette companies to place
health warnings on packages and advertisements, that helped
spur the adoption of the Federal Cigarette Labeling and
Advertising Act. In 1967, the FTC began a program to provide
cigarette ratings for tar and nicotine. Testing was done under
the Cambridge Filter Test Method which is known in the United
States as the FTC Method. The program sought to provide smokers
seeking to switch to lower-tar cigarettes information based on
a single-standard measurement.
For some time, the Commission has been concerned that the
current test method may mislead individual consumers who rely
on the ratings it produces to indicate the amount of tar and
nicotine that they actually will get from their cigarettes. The
current ratings tend to be relatively poor indicators of tar
and nicotine exposure. Among other reasons, smokers of lower-
rated cigarettes tend to take bigger, deeper, more frequent
puffs, or otherwise alter their smoking behavior to obtain the
dosage of nicotine they need.
Although the limits of the test methodology were recognized
when the program began in 1967, they became a substantially
greater concern since the 1990s, due to changes in modern
cigarette design and a better understanding of the nature and
effects of smoking behavior. These concerns led the Commission,
in 1994, along with Congressman Waxman, to ask the National
Cancer Institute to convene a conference to address cigarette
testing issues.
The NCI convened the conference, and, in 1996, recommended
that the cigarette testing system measure and publish
information on the range of tar, nicotine, and carbon monoxide
that most smokers would expect from the cigarettes they smoke.
In September 1997, the Commission requested public comments
and proposed revisions to the test method that would add a
second tier of testing to better approximate the range of tar
and nicotine yields and make it more apparent to consumers that
the amounts of tar and nicotine they get from any specific
cigarette depends on how they smoke.
Around the same time, some public health officials warned
that recently released studies raised serious questions about
the basic assumption then underlying cigarette testing; namely,
that cigarettes with lower machine-measured tar and nicotine
ratings are less harmful than ones with higher ratings. An NCI
report in 1997 suggested that the reduced tar levels of modern
cigarettes might have less benefits than previously believed.
Other studies reported that changes in smoking behavior and
cigarette design appear to have resulted in an increase in a
specific type of cancer that occurs deeper in the lung.
Citing these studies, public health agencies asked the FTC
to postpone its proposed changes to the test method until a
broader review of unresolved scientific issues surrounding the
system could be addressed.
In November 2001, the NCI reported the results of a review
of the epidemiological and other scientific evidence on the
public health effects of low-tar cigarettes. The panel of
scientific experts assembled for that inquiry concluded that
the existing scientific evidence did not demonstrate a public
health benefit to smokers who switched to low-tar or light
cigarettes.
The 2001 NCI report also concluded that measurements of tar
and nicotine, as measured by the FTC Method, did not offer
meaningful information to consumers, and that there was an
urgent need to develop new testing approaches. The Commission
understands that this report represented, at least in part, the
first step in an HHS response to a 1998 FTC request for
assistance. When it announced the release of this report, the
NCI noted the FTC's previous request and indicated that it
would work with other science-based agencies at HHS to
determine how to change the testing method.
The FTC understands that representatives from agencies
within HHS are continuing to explore these issues. In addition,
the World Health Organization has assembled a panel of experts
to address tobacco testing issues.
The FTC believes it is vital that there be an effective
mechanism for implementing any recommended changes to the test
method once these evaluations are completed. The Commission
brings strong market-based expertise to its scrutiny of
consumer protection matters, yet we lack the specialized
scientific expertise needed to design and evaluate scientific
test methods.
When we evaluate medical or other scientific issues, the
Commission often relies on other government agencies and
outside experts with more knowledge in relevant areas. In its
1999 July report to the Congress, pursuant to the Cigarette
Labeling and Advertising Act, the Commission recommended that
Congress consider giving authority over cigarette testing to
one of the Federal Government's science-based public health
agencies. The Commission renewed that recommendation in 2003 in
testimony before Congress, and the Commission reiterates that
recommendation again today.
I thank the Committee for the opportunity to address these
issues, and I await your questions.
[The prepared statement of Mr. Kovacic follows:]
Prepared Statement of Hon. William E. Kovacic, Commissioner,
Federal Trade Commission
Chairman Inouye, Vice Chairman Stevens, Senator Lautenberg, and
Members of the Committee, I am William E. Kovacic, a Commissioner at
the Federal Trade Commission (``FTC'' or ``Commission'').\1\ The
Commission is pleased to have this opportunity to provide testimony at
today's hearing. Today, I would like to discuss the FTC's
responsibilities and activities in the area of tobacco advertising
generally, and then turn more specifically to a discussion of cigarette
testing and the promotion of cigarettes based on machine-measured tar
and nicotine yields. The testimony discusses concerns the FTC has with
the test method, and renews the Commission's previous recommendation
that Congress consider giving authority over cigarette testing to one
of the Federal Government's science-based public health agencies.
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\1\ The written statement presents the views of the Federal Trade
Commission. My oral testimony and responses to questions reflect my
views, and do not necessarily reflect the views of the Commission or
any other Commissioner.
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As the Nation's consumer protection agency, the FTC has a broad
mandate, with diverse responsibilities such as the prosecution and
prevention of fraud in the marketing of healthcare products, deceptive
financial practices in the subprime mortgage and credit repair
industries, identity theft, and technology risks to consumers such as
spam and spyware. The FTC also has responsibility over the marketing
and promotion of tobacco products, including cigarettes, smokeless
tobacco, cigars, and new tobacco products. One of the most challenging
issues concerning cigarette advertising and promotion is the topic of
today's hearing: the advertising and promotion of cigarettes based on
their tar and nicotine yields as measured by the test methodology
commonly referred to in the United States as ``the FTC Method,''
although, as discussed below, the FTC stopped testing according to this
method in 1987.\2\
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\2\ See infra n. 15.
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Cigarette testing under this test methodology began 40 years ago,
in 1967, when the Commission approved use of the FTC Method for
measuring the tar and nicotine yields of cigarettes.\3\ From the
outset, cigarette testing under the FTC Method was intended to produce
uniform, standardized data about the tar and nicotine yields of
mainstream cigarette smoke, not to replicate actual human smoking.
Because no known test could accurately replicate human smoking, the FTC
believed that the most important objective was to ensure that cigarette
companies presented tar and nicotine information to the public based on
a standardized method. In 1967, most public health officials believed
that reducing the amount of ``tar'' in a cigarette could reduce a
smoker's risk of lung cancer; therefore, it was thought that giving
consumers uniform and standardized information about the tar and
nicotine yields of cigarettes would help smokers make informed
decisions about the cigarettes they smoked.\4\ In the intervening 40
years, cigarettes have changed markedly and scientific understanding of
smoking behavior has improved. These changes have important
implications for cigarette measurement.
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\3\ When the Commission approved the test methodology, it was
called the Cambridge Filter Method. The Cambridge Filter Method is now
commonly referred in the United States as ``the FTC Method.''
\4\ When the test method was adopted, the public health community
believed that ``[t]he preponderance of scientific information strongly
suggests that the lower the tar and nicotine content of cigarette
smoke, the less harmful would be the effect.'' U.S. Dept. of Health and
Human Services, The Health Consequences of Smoking: The Changing
Cigarette 1 (1981) (quoting a 1966 Public Health Service statement).
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The Commission's Responsibilities Over Tobacco Advertising and
Promotion
The Commission's core responsibility over the advertising and
promotion of cigarettes and other tobacco products arises from its law
enforcement authority under Section 5 of the FTC Act, which prohibits
``unfair or deceptive acts or practices in or affecting commerce.'' \5\
The FTC's law enforcement activities involving cigarette advertising
and promotion date back to the 1930s.\6\ In 1962, the FTC's request for
technical assistance from the U.S. Public Health Service was among the
factors that led the then-Surgeon General to establish an advisory
panel to undertake a comprehensive analysis of the data on smoking and
health. The work of the advisory panel, in turn, led to the now-
historic 1964 Report of the Surgeon General finding that cigarette
smoking presented significant health risks. In that same year, the
Commission issued a regulation requiring tobacco companies to include
health warnings in cigarette advertisements and on packages.\7\ The
FTC's regulation was superseded in 1965, before it went into effect, by
the Federal Cigarette Labeling and Advertising Act (``Cigarette
Act''),\8\ which required health warnings on cigarette packages.
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\5\ 15 U.S.C. 45(a).
\6\ See, e.g., Julep Tobacco Co., 27 F.T.C. 1637 (1938)
(stipulation prohibiting claims that Julep cigarettes helped counteract
irritations due to heavy smoking and never made the throat dry or
parched).
\7\ See Trade Regulation Rule for the Prevention of Unfair or
Deceptive Advertising and Labeling of Cigarettes in Relation to the
Health Hazards of Smoking, 29 Fed. Reg. 8324, 8354 (1964).
\8\ 15 U.S.C. 1331 et seq. Although the Commission administers
the Cigarette Act, the Department of Justice enforces it.
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The Commission also has used its Section 5 authority to prosecute a
variety of unfair and deceptive cigarette advertising practices--
including claims about tar and nicotine ratings for cigarettes. For
example, in the early 1980s, the FTC filed a Federal district court
lawsuit challenging claims made by Brown & Williamson Tobacco
Corporation that its Barclay cigarettes had only 1 mg. of tar. The FTC
had previously revoked the ``1 mg. tar'' rating after concluding that
the FTC Method did not accurately measure Barclay's tar, nicotine, and
carbon monoxide due to the cigarette's unique channel ventilation
system. The court agreed with the FTC, and found that the ``1 mg. tar''
claim was deceptive.\9\ Likewise, in 1995, the Commission approved a
consent agreement with American Tobacco Company, settling charges over
advertisements that allegedly misused the tar and nicotine ratings by
representing that smokers would get less tar by smoking 10 packs of
Carlton brand cigarettes (which were rated at 1 mg. tar per cigarette)
than by smoking a single pack of certain other brands of cigarettes
(which were rated at 10 mg. of tar).\10\
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\9\ FTC v. Brown & Williamson Tobacco Corp., 580 F. Supp. 981
(D.D.C. 1983), aff'd. in part, remanded in part, 778 F.2d 35 (D.C. Cir.
1985).
\10\ The American Tobacco Co., 119 F.T.C. 3 (1995). In another
example of a Commission action involving unfair and deceptive cigarette
advertising practices, in 1997, the Commission issued a complaint
against the R.J. Reynolds Tobacco Co. alleging that the company's Joe
Camel advertising campaign caused or was likely to cause many young
people to begin or continue to smoke, thereby exposing them to
significant health risks. R.J. Reynolds Tobacco Co., 127 F.T.C. 49
(1999). The Commission's complaint was issued on May 28, 1997. On
January 26, 1999, the Commission dismissed the complaint without
prejudice because the relief sought had been achieved through, inter
alia, the master settlement between the major tobacco companies and the
Attorneys General for 46 states.
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In addition to law enforcement actions, the Commission administers
the Cigarette Act and administers and enforces the Comprehensive
Smokeless Tobacco Health Education Act (``Smokeless Tobacco Act'').\11\
The Cigarette Act instructs the FTC to take certain steps to implement
the mandated Surgeon General's health warnings. The Smokeless Tobacco
Act directs the FTC to promulgate regulations governing the health
warnings on packaging and advertising for smokeless tobacco products.
The Commission's regulations specify the format, placement, and
rotation of the warnings, and require companies to submit plans setting
forth their rotation schedules to the FTC for approval.\12\ In
addition, the FTC enforces the ban in the Smokeless Tobacco Act on
broadcasting smokeless tobacco advertisements on radio and television.
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\11\ 15 U.S.C. 4401 et seq.
\12\ 16 C.F.R. Part 307.
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The Commission also publishes periodic reports on the advertising
and promotion activities in the cigarette and smokeless tobacco
industries.\13\ Those reports provide information on sales and on
various categories of advertising and marketing expenditures. The
Commission issued its first report for cigarettes in 1967, and on the
smokeless tobacco industry in 1987. The Commission also published
periodic reports showing the tar, nicotine, and carbon monoxide yields
of various cigarette brands from 1967 through 2000.\14\ In light of
concerns over the test method used to measure these yields, which are
discussed later in this statement, these reports have not been
published since 2000 (reporting on 1998 data). But the FTC continues to
collect this information, and it is available to researchers on the
FTC's website.
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\13\ In addition, the Commission issued a report on the advertising
and promotion activities in the cigar industry in 1999. Federal Trade
Commission Report to Congress, Report on Cigar Sales, Advertising, and
Promotion (1999).
\14\ Until 1981, the Reports only provided information about the
tar and nicotine yields. In 1981, the test methodology was changed to
include testing for carbon monoxide yields, and the Commission
subsequently began reporting those yields in addition to tar and
nicotine.
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Finally, testing for the tar, nicotine, and carbon monoxide yields
of cigarettes is conducted by the cigarette industry under the test
methodology approved by the FTC in 1967.\15\ Cigarette companies have
promoted their cigarettes based on ratings generated by this test
methodology, and have adopted descriptors, such as ``light'' and
``low,'' to characterize cigarettes that have tar ratings of 15 mg. or
less.\16\
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\15\ In 1967, the Commission opened its own testing laboratory to
analyze the tar and nicotine yields of cigarettes. In 1981, the
Commission laboratory began to analyze the carbon monoxide yields as
well. The Commission operated this laboratory until April 1987, when it
decided to close it because, inter alia, significant expenditures were
needed to update and continue the laboratory, and the same information
was available from the industry. See Prepared Statement of the Federal
Trade Commission on Cigarette Tar and Nicotine Testing Before the
Subcommittee on Transportation, Tourism, and Hazardous Materials, U.S.
House of Representatives (May 7, 1987). Since the FTC laboratory
closed, the Tobacco Industry Testing Laboratory conducts the testing
and provides the data to the individual cigarette companies; the
Commission obtains the data from the cigarette companies pursuant to
compulsory process.
\16\ These terms are not defined by the FTC or any other government
agency. The industry, however, has generally adopted them. The term
``low'' tar generally refers to cigarettes currently rated as 15 mg.
tar or less and ``ultra low'' to those rated 6 mg. or less. The
industry uses the term ``full flavor'' to describe cigarettes with tar
ratings above 15 mg. The terms ``light'' and ``ultra-light'' are used
interchangeably with ``low'' tar and ``ultra low'' tar, respectively.
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The ``FTC Test Method'' and Its Limitations
Cigarette ratings for tar, nicotine, and carbon monoxide are
determined by machine testing conducted in accordance with the
Cambridge Filter test method, commonly known in the U.S. as ``the FTC
Method.'' \17\ The FTC Method determines the relative yield of
individual cigarettes by ``smoking'' them in a standardized fashion,
according to a pre-determined protocol, on a machine. The machine is
calibrated to take one puff of 2-second duration and 35 ml volume every
minute. Cigarettes are smoked to a specified length, and the ratings
are then calculated. In 1967, when it began, the intent of the tar and
nicotine testing program was to provide smokers seeking to switch to
lower tar cigarettes information based on a single, standardized
measurement with which to choose among then-existing brands.
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\17\ Europe and many other countries have adopted a similar
machine-based test method established by the International Organization
for Standardization. In those countries, the test method is referred to
as the ``ISO Method.''
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Over the past 40 years that the current system has been in place,
there have been dramatic decreases in the machine-measured tar and
nicotine yields of cigarettes. In 1968, for example, only 2 percent of
all cigarettes had machine-measured yields of 15 mg. or less. Today,
over 83.5 percent of all cigarettes sold have machine-measured yields
of 15 mg. or less.
Despite these dramatic decreases in machine-measured yields, the
Commission has been concerned for some time that the current test
method may be misleading to individual consumers who rely on the
ratings it produces as indicators of the amount of tar and nicotine
they actually will get from their cigarettes. In fact, the current
ratings tend to be relatively poor predictors of tar and nicotine
exposure. This appears to be primarily due to compensation--or the
tendency of smokers of lower rated cigarettes to take bigger, deeper,
or more frequent puffs, or otherwise alter their smoking behavior in
order to obtain the dosage of nicotine they need. Such variations in
the way people smoke can have significant effects on the amount of tar,
nicotine, and carbon monoxide they get from any particular cigarette.
Smokers may incorrectly believe, for example, that they will get three
times as much tar from a 15 mg. tar cigarette as from a 5 mg. tar
cigarette. In fact, if compensation is sufficiently great, it is
possible for smokers to get as much tar and nicotine from relatively
low rated cigarettes as from higher rated cigarettes. Although the
limitations in the test methodology were recognized when the testing
program began in 1967, they became a substantially greater concern by
the 1990s as a result of changes in modern cigarette design and a
better understanding of the nature and effects of compensatory smoking
behavior.
In light of these concerns, in 1994, the Commission, along with
Congressman Henry Waxman, asked the National Cancer Institute (``NCI'')
to convene a consensus conference to address cigarette testing issues.
That conference took place in December 1994, and the NCI issued its
Report of the conference in October 1996.\18\ The NCI Report
recommended, among other things, that the cigarette testing system
measure and publish information on the range of tar, nicotine, and
carbon monoxide that most smokers should expect from the cigarettes
they smoke. Accordingly, in September 1997, the Commission requested
public comments on proposed revisions to the test method that would add
a second tier of testing--using more rigorous smoking conditions--to
better approximate a range of tar and nicotine yields and make it more
apparent to consumers that the amount of tar and nicotine they get from
any specific cigarette depends on how they smoke it.
---------------------------------------------------------------------------
\18\ Smoking and Tobacco Control Monograph 7: The FTC Cigarette
Test Method for Determining Tar, Nicotine, and Carbon Monoxide Yields
of U.S. Cigarettes: Report of the NCI Expert Committee, National
Institutes of Health, National Cancer Institute (1996).
---------------------------------------------------------------------------
Around this same time, some public health officials expressed
concerns that recently released studies raised serious questions about
the basic assumption then underlying cigarette testing: that cigarettes
with lower machine-measured tar and nicotine ratings are less harmful
than ones with higher ratings. For example, in 1997, the NCI issued a
Report noting that the apparent mortality risk among current smokers
had risen in the last forty to fifty years, even though machine-
measured tar and nicotine yields had fallen dramatically during the
same period.\19\ In attempting to understand this phenomenon, the
authors of the NCI Report suggested that the increased mortality risk
might be due to increases in current smokers' lifetime exposure to
cigarette smoke, or that the reduced tar levels of modern cigarettes
might have less benefits than previously believed. In addition to the
NCI Report, a number of other studies reported that changes in smoking
behavior and cigarette design appeared to have resulted in an increase
in a specific type of cancer that occurs deeper in the lung than the
type of lung cancer that was previously associated with smoking.\20\
---------------------------------------------------------------------------
\19\ Smoking and Tobacco Control Monograph 8: Changes in Cigarette-
Related Disease Risk and Their Implications for Prevention and Control,
National Institutes of Health, National Cancer Institute (1997).
\20\ See Thun, M.J., et al., ``Cigarette Smoking and Changes in the
Histopathology of Lung Cancer,'' 89 J. of the Nat'l Cancer Inst. 1580
(1997); Ernster, V.I., ``The Epidemiology of Lung Cancer in Women,'' 4
Annals of Epidemiology 102 (1994); Levi, F.S., et al., ``Lung Carcinoma
Trends by Histologic Type in Vaud and Neuchatel, Switzerland, 1974-
1994,'' 79 Cancer 906 (1997).
---------------------------------------------------------------------------
Citing these studies, public health agencies asked the Commission
to postpone its proposed modifications to the test method until a
broader review of unresolved scientific issues surrounding the system
could be addressed. The Commission responded to these comments, in
1998, by formally requesting that the Department of Health and Human
Services (``HHS'') conduct a review of the FTC's cigarette test
method.\21\ In particular, the Commission asked HHS to provide
recommendations as to whether the testing system should be continued,
and if it should be continued, what specific changes should be made in
order to correct the limitations previously identified by the NCI, an
agency within HHS, and other public health officials.
---------------------------------------------------------------------------
\21\ Letter from Donald S. Clark, Secretary, Federal Trade
Commission to the Honorable Donna E. Shalala, Secretary, Department of
Health and Human Services (Nov. 19, 1998).
---------------------------------------------------------------------------
In November 2001, the NCI published a Report presenting the results
of a review of the epidemiological and other scientific evidence on the
public health effects of low-tar cigarettes.\22\ As noted in Dr.
Backinger's testimony prepared for today's hearing, this NCI Report
concluded that ``there is no convincing evidence that changes in
cigarette design . . . have resulted in an important decrease in the
disease burden caused by cigarette use.'' \23\ The NCI Report also
concluded that ``[v]ariations in the tar and nicotine delivery that
result from the known compensatory alterations in smoking behaviors
make the current U.S. cigarette tar and nicotine yields as measured by
the FTC Method not useful to the smoker either for understanding how
much tar and nicotine he or she is likely to inhale from smoking a
given cigarette or for comparing the tar and nicotine intake that is
likely to result from smoking different brands of cigarettes.'' \24\
---------------------------------------------------------------------------
\22\ Smoking and Tobacco Control Monograph 13: Risks Associated
with Smoking Cigarettes with Low Machine-Measured Yields of Tar and
Nicotine, National Institutes of Health, National Cancer Institute
(2001).
\23\ Statement of Cathy Backinger, M.D., ``Research Findings
Concerning So-Called Low-Tar or `Light' Cigarettes,'' Testimony Before
the Committee on Science, Commerce, and Transportation, U.S. Senate
(Nov. 13, 2007). See also Smoking and Tobacco Control Monograph 13:
Risks Associated with Smoking Cigarettes with Low Machine-Measured
Yields of Tar and Nicotine, National Institutes of Health, National
Cancer Institute, at 146.
\24\ Smoking and Tobacco Control Monograph 13: Risks Associated
with Smoking Cigarettes with Low Machine-Measured Yields of Tar and
Nicotine, National Institutes of Health, National Cancer Institute, at
34.
---------------------------------------------------------------------------
The Commission understands that this Report represented, at least
in part, the first step in the HHS response to the FTC's 1998 request
for assistance. When it announced the release of this Report, the NCI
noted the FTC's previous request, and indicated that it would work with
its sister science-based agencies at HHS to determine what changes
needed to be made to the testing method.\25\
---------------------------------------------------------------------------
\25\ National Cancer Institute, ``Low-Tar Cigarette: Evidence Does
Not Indicate a Benefit to Public Health,'' News from the NCI (Nov. 27,
2001).
---------------------------------------------------------------------------
The FTC understands that representatives from agencies within HHS
are continuing to explore these issues. In addition, the Commission
understands that an expert panel has been assembled by the World Health
Organization to address tobacco testing issues and to make
recommendations concerning such testing.
The Commission believes that it is vital that there be an effective
mechanism for implementing any recommended changes to the test method
once the evaluations are completed. Although the Commission brings a
strong, market-based expertise to its scrutiny of consumer protection
matters, it does not have the specialized scientific expertise needed
to design and evaluate scientific test methodologies. Indeed, when
evaluating medical or other scientific issues, the Commission often
relies on other government agencies and outside experts with more
knowledge in the relevant areas. Therefore, in its July 1999 ``Report
to Congress for 1997, Pursuant to the Cigarette Labeling and
Advertising Act,'' the Commission recommended that Congress consider
giving authority over cigarette testing to one of the Federal
Government's science-based public health agencies. The Commission
renewed that recommendation in 2003 in testimony before Congress,\26\
and the Commission reiterates that recommendation again today.
---------------------------------------------------------------------------
\26\ Prepared Statement of the Federal Trade Commission Before the
Committee on Energy and Commerce, Subcommittee on Commerce, Trade, and
Consumer Protection, U.S. House of Representatives (June 3, 2003);
Prepared Statement of the Federal Trade Commission Before the Committee
on Government Reform, U.S. House of Representatives (June 3, 2003).
---------------------------------------------------------------------------
In conclusion, the FTC thanks the Committee for the opportunity to
present testimony on this important topic.
Senator Lautenberg. Thank you very much.
Ms. Backinger?
Dr. Backinger. Yes.
Senator Lautenberg. We invite you to give your testimony,
please.
STATEMENT OF CATHY L. BACKINGER, Ph.D., ACTING CHIEF,
TOBACCO CONTROL RESEARCH BRANCH, NATIONAL
CANCER INSTITUTE, NATIONAL INSTITUTES OF HEALTH,
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Dr. Backinger. Senator Stevens and Senator Lautenberg,
thank you for the opportunity today to testify on the National
Cancer Institute's research findings regarding the disease risk
of so-called low-tar or ``light'' cigarettes.
I am Dr. Cathy Backinger, Acting Chief of the National
Cancer Institute's Tobacco Control Research Branch.
As is described more fully in my written testimony, there
is a substantial long-standing body of evidence demonstrating
that ``light'' or low-tar cigarettes do not reduce smokers'
exposure to hazardous compounds or their risk of disease.
Moreover, descriptions such as ``light,'' low tar, ``ultra
light,'' and others, are aimed at conveying to consumers what
NCI Monograph 13 termed ``the illusion of risk reduction.''
Additionally, the Federal Trade Commission test method does
not offer smokers meaningful information on the amount of tar
and nicotine they will receive from a cigarette or on the
relative amounts of tar and nicotine exposure they are likely
to receive from smoking different brands of cigarettes.
Cigarette manufacturers have made changes to cigarettes
over the last 50 years in response to concerns that the growing
body of evidence that smoking causes disease would motivate
smokers to quit. In the 1950s, manufacturers began the
widespread promotion of filtered cigarettes. And in early
1970s, manufacturers introduced and heavily marketed new low-
tar cigarette brands. Many of the advertisements made implicit
health claims so as to reassure smokers who were concerned
about their health risks.
Over time, the market share for low-tar brands increased
dramatically. In 1967, these products had only 2 percent of the
market share. In 2005, these products held 83.5 percent of the
market share.
By the early 1980s, however, scientific studies had begun
to show that when smokers switched to low-tar cigarettes, they
changed the way they smoked by smoking greater numbers of
cigarettes, increasing their depth of inhalation, taking more
frequent and/or larger puffs, as well as holding smoke in their
lungs longer. Additionally, cigarette design features allowed
smokers to vary the amount of smoke they inhaled. Reflecting
this knowledge, the 1981 Surgeon General's Report concluded
that ``the benefits [of smoking low-tar cigarettes] are minimal
in comparison with giving up cigarettes entirely.'' In short,
more than 25 years ago, the Surgeon General warned that smoking
low-tar cigarettes is not a substitute for quitting.
NCI's Monograph 7, published in 1996, considered the
relationship between the FTC test method and actual human
smoking behavior, as well as consumer perceptions of tar and
nicotine ratings. Among the major conclusions of the monograph
were:
One, smokers who switched to lower-tar and nicotine
cigarettes frequently changed their smoking behavior, which may
negate potential health benefits;
Two, brand names and brand classifications, such as
``light'' and ``ultra light,'' represent health claims and
should be regulated and accompanied in fair balance with an
appropriate disclaimer; and
Three, the available data suggest that smokers
misunderstand the FTC test data.
NCI's Monograph 13, published in 2001, reviewed and
synthesized a vast amount of data, ranging from laboratory to
population studies. Its most important finding is that ``there
is no convincing evidence that changes in cigarette design . .
. have resulted in an important decrease in the disease burden
caused by cigarette use.'' The monograph also found that
``advertisements of filtered and low-tar cigarettes were
intended to reassure smokers [who were worried about the health
risks of smoking] and were meant to prevent smokers from
quitting based on those concerns;'' additionally, that
``internal tobacco company documents demonstrate that cigarette
manufacturers recognize the inherent deception of advertising
that offer cigarettes as light or ultra light or as having the
lowest tar and nicotine yields.''
In summary, while cigarettes have changed over the last 50
years, the disease risks have not. Cigarette manufacturers have
long understood that consumers would respond to the widespread
dissemination of the grave health risks of smoking by quitting.
Manufacturers work to reassure health conscious smokers by
marketing filtered and low-tar cigarettes and heavily
advertising these products as ways to reduce the risk of
smoking. Smokers erroneously saw these products as viable
alternatives to quitting, and, as a result, many more smokers
continue to smoke who might otherwise have quit.
Thank you for the opportunity to appear before the
Committee. I'm happy to answer any questions.
Thank you.
[The prepared statement of Dr. Backinger follows:]
Prepared Statement of Cathy L. Backinger, Ph.D., Acting Chief, Tobacco
Control Research Branch, National Cancer Institute, National Institutes
of Health, U.S. Department of Health and Human Services
Mr. Chairman, and members of the Subcommittee, thank you for the
opportunity to testify today on the research findings of the National
Cancer Institute (NCI), part of the National Institutes of Health
(NIH), an agency of the Department of Health and Human Services (HHS),
regarding the disease risk of so called low-tar or ``light''
cigarettes, and the challenges of conveying accurate information to
smokers about the levels of tar, nicotine, and other hazardous
chemicals in cigarette smoke. I am Dr. Cathy Backinger, Acting Chief of
the National Cancer Institute's Tobacco Control Research Branch. The
Branch's mission is to lead and collaborate on tobacco control and
prevention research, and to disseminate evidence-based findings to
prevent, treat, and control tobacco use. We envision a world free of
tobacco use and tobacco-related cancers.
I would like to begin by stating the NCI's goals regarding
cigarette smoking, the cause of an estimated 438,000 U.S. deaths
annually and about one-third of all deaths from cancer. NCI supports,
conducts, and disseminates research to prevent youth from ever starting
to use tobacco products, to assist youth and adults who smoke in
quitting, and to protect nonsmokers from exposure to secondhand smoke,
a serious cause of disease and death in its own right.
As I will describe, there is a substantial, longstanding body of
evidence demonstrating that ``light'' and low-tar cigarettes do not
reduce smokers' exposure to hazardous compounds or their risk for
disease. Moreover, descriptors such as ``light,'' low-tar, ``ultra
light,'' and others, are aimed at conveying to consumers what NCI
Monograph 13 termed ``the illusion of risk reduction.'' \1\ Not
surprisingly, research has demonstrated that these terms are
interpreted by many smokers to mean reduced risk. Finally, measurements
of tar and nicotine yields using the Federal Trade Commission (FTC)
test method do not offer smokers meaningful information on the amount
of tar and nicotine they will receive from a cigarette, or on the
relative amounts of tar and nicotine exposure they are likely to
receive from smoking different brands of cigarettes.\2\
---------------------------------------------------------------------------
\1\ National Cancer Institute, Smoking and Tobacco Control
Monograph 13, Risks Associated with Smoking Cigarettes with Low
Machine-Measured Yields of Tar and Nicotine, October 2001, page 5.
\2\ Monograph 13, page 10.
---------------------------------------------------------------------------
Cigarette manufacturers have made changes to cigarettes over the
last 50 years, largely in response to concerns that the growing body of
evidence that smoking causes disease would motivate smokers to quit. In
the 1950s, the major manufacturers began widespread promotion of
filtered cigarettes; advertisements for these cigarettes depicted
filters as a technology to remove the harmful elements of smoke.\3\ By
1960, filtered cigarettes had become the dominant product on the
market. In the early 1970s, manufacturers introduced new low-tar
cigarette brands; by 1997, half of all cigarette advertising dollars
were dedicated to low-tar products. Many of the advertisements made
health claims, most implicitly, so as to reassure smokers who were
concerned about their health risks. Over time, the market share for
these brands increased dramatically. In 1967, low-tar cigarettes \4\
constituted 2.0 percent of the market. By 2005, these products held
83.5 percent of market share.\5\
---------------------------------------------------------------------------
\3\ U.S. Department of Health and Human Services, Reducing the
Health Consequences of Smoking: 25 Years of Progress. A Report of the
Surgeon General, 1989, page 664.
\4\ Low-tar cigarettes contain less than or equal to 15 mg of tar
per cigarette.
\5\ Federal Trade Commission Cigarette Report for 2004 and 2005,
issued 2007 (http://www.ftc.gov/reports/tobacco/2007cigarette2004-
2005.pdf).
---------------------------------------------------------------------------
By the early 1980s, however, scientific studies had begun to show
that when smokers switched to low-tar cigarettes, they changed the way
they smoked, by smoking greater numbers of cigarettes, increasing their
depth of inhalation, taking more frequent and/or larger puffs, as well
as holding smoke in their lungs longer. Additionally, cigarette design
features allowed smokers to vary the amount of smoke they inhaled, such
as by covering ventilation holes on the filter with their fingers or
lips. Based on this emerging evidence, the 1981 Surgeon General's
report, The Changing Cigarette, concluded that, ``the benefits [of
smoking low-tar cigarettes] are minimal in comparison with giving up
cigarettes entirely,'' and, ``the tar and nicotine yields obtained by
present testing methods do not correspond to the dosages that the
individual smokers receive: in some cases they may seriously
underestimate these dosages.'' \6\ In short, more than 25 years ago,
the Surgeon General warned that smoking low-tar cigarettes was no
substitute for quitting, and raised serious questions about the FTC
test method.
---------------------------------------------------------------------------
\6\ U.S. Department of Health and Human Services, The Health
Consequences of Smoking: The Changing Cigarette. A Report of the
Surgeon General, 1981, page vi.
---------------------------------------------------------------------------
Our understanding of why smokers compensate when smoking ``light''
cigarettes was enhanced significantly by the 1988 Surgeon General's
report, The Health Consequences of Smoking: Nicotine Addiction. The
major conclusions of this volume were that: (1) cigarettes and other
forms of tobacco are addicting; (2) nicotine is the drug in tobacco
that causes addiction; and (3) the pharmacologic and behavioral
processes that determine tobacco addiction are similar to those that
determine addiction to drugs such as heroin and cocaine. In retrospect,
public health authorities did not fully understand that when smokers
switched to a cigarette with lower machine measured tar and nicotine
content they would change the way they smoked in order to preserve
their daily intake of nicotine. This was understood much earlier
however, by some cigarette manufacturers, as demonstrated by their
internal documents.
Tar and nicotine yields have historically been measured by a
standardized machine testing regimen--the FTC test method--also known
internationally as the ISO (for International Organization for
Standardisation) machine-smoking method. This method, adopted in 1967,
determines the yield of a cigarette by smoking it on a machine, in a
standardized fashion, according to a predetermined protocol. The
smoking machine is calibrated to take one puff of 2-second duration and
35 ml volume every minute; cigarettes are smoked to a butt length of 23
mm or to the length of the overwrap plus 3 mm, whichever is longer.
These parameters were determined by a U.S. Department of Agriculture
tobacco chemist so as to constitute an average of his observations of
human smoking behavior. The FTC test method provided a uniform
analytical procedure that could be replicated in different laboratories
simultaneously and in the same laboratory over time.
The FTC long recognized that the machine testing did not replicate
human smoking because, ``No two human smokers smoke in the same way,''
and ``No individual smoker always smokes in the same fashion.'' \7\
Instead, the test was seen as a way for consumers to make valid
comparisons between different brands of cigarettes. ``Thus, if the
consumer smoked each different cigarette [brand] the same way, he would
inhale `tar' and nicotine in amounts proportional to the relative
values of the FTC figures.'' \8\ However, the standardized machine
measurements assumed that smokers would not engage in ``compensatory
behaviors'' to control their intake of nicotine.
---------------------------------------------------------------------------
\7\ National Cancer Institute, Smoking and Tobacco Control
Monograph 7, The FTC Cigarette Test Method for Determining Tar,
Nicotine, and Carbon Monoxide Yields of U.S. Cigarettes: Report of the
NCI Expert Committee, August 1996, page 2.
\8\ Monograph 7, page 4, quoting 1978 Federal Register, p. 11856.
---------------------------------------------------------------------------
In 1996, NCI's Smoking and Tobacco Control Monograph Number 7, The
FTC Cigarette Test Method for Determining Tar, Nicotine, and Carbon
Monoxide Yields of U.S. Cigarettes: Report of the NCI Expert Committee,
compiled evidence available at the time on the FTC test method, its
relation to actual human smoking behavior, and consumer perceptions of
tar and nicotine ratings. Among the major conclusions of the monograph
were: (1) Actual human smoking behavior is characterized by wide
variations in smoking patterns, which result in wide variations in tar
and nicotine exposure. Smokers who switch to lower tar and nicotine
cigarettes frequently change their smoking behavior, which may negate
potential health benefits; (2) Brand names and brand classifications
such as ``light'' and ``ultra light'' represent health claims and
should be regulated and accompanied, in fair balance, with an
appropriate disclaimer; and (3) The available data suggest that smokers
misunderstand the FTC test data. This underscores the need for ongoing
and extensive public education efforts.
Lastly, in 2001, NCI's Smoking and Tobacco Control Monograph Number
13, Risks Associated with Smoking Cigarettes with Low Tar Machine-
Measured Yields of Tar and Nicotine, reviewed and synthesized what was
by that time a vast amount of data from epidemiology, chemistry,
toxicology, laboratory studies of smoking behavior, studies of risk
perception and advertising, studies of product design, as well as
previously confidential tobacco industry documents. The Monograph's
most important finding is that ``there is no convincing evidence that
changes in cigarette design . . . have resulted in an important
decrease in the disease burden caused by cigarette use.'' \9\ That is,
smokers who switch to low-tar cigarettes do not reduce their risk of
disease; the only proven way to reduce the disease risks of smoking is
to quit. The report also found that cigarette marketing and advertising
for ``filtered and low tar cigarettes were intended to reassure smokers
(who were worried about the health risks of smoking) and were meant to
prevent smokers from quitting based on those concerns,'' and that,
``internal tobacco company documents demonstrate that the cigarette
manufacturers recognized the inherent deception of advertising that
offered cigarettes as ``light'' or ``ultra light,'' or as having the
lowest tar and nicotine yields.'' \10\ The major conclusions of
Monograph 13 are the following:
---------------------------------------------------------------------------
\9\ Monograph 13, page 146.
\10\ Monograph 13, page 233.
1. Epidemiological and other scientific evidence, including
patterns of mortality from smoking-caused diseases, does not
indicate a benefit to public health from changes in cigarette
---------------------------------------------------------------------------
design and manufacturing over the last fifty years.
2. Widespread adoption of lower yield cigarettes in the United
States has not prevented the sustained increase in lung cancer
among older smokers.
3. Many smokers switch to lower yield cigarettes out of concern
for their health, believing these cigarettes to be less risky
or to be a step toward quitting. Advertising and marketing of
lower yield cigarettes may promote initiation and impede
cessation, more important determinants of smoking-related
diseases.
4. Measurements of tar and nicotine yields using the FTC Method
do not offer smokers meaningful information on the amount of
tar and nicotine they will receive from a cigarette. The
measurements also do not offer meaningful information on the
relative amounts of tar and nicotine exposure likely to be
received from smoking different brands of cigarettes.
The conclusion of Monograph 13 with regard to low tar cigarettes
was reiterated by the 2004 Surgeon General's report, The Health
Consequences of Smoking, the most comprehensive review of the evidence
on smoking and health since the 1964 Surgeon General's report. This
report stated as one of its four major conclusions that, ``Smoking
cigarettes with lower machine-measured yields of tar and nicotine
provides no clear benefit to health.'' \11\
---------------------------------------------------------------------------
\11\ U.S. Department of Health and Human Services, The Health
Consequences of Smoking: A Report of the Surgeon General, 2004, page
25.
---------------------------------------------------------------------------
In summary, while cigarettes have changed over the last 50 years,
the disease risks have not. Cigarette manufacturers have long
understood that consumers would respond to the widespread dissemination
of the grave health risks of smoking by quitting. Manufacturers worked
to reassure ``health conscious'' smokers by marketing filtered and low-
tar cigarettes, and heavily advertising these products as ways to
reduce the risk of smoking. Smokers erroneously saw these products as
viable alternatives to quitting, and as a result, many more smokers
continued to smoke who might otherwise have quit. The marketing and
advertising of low-tar cigarettes and manufacturers' use of the FTC
test method data continues today.
A new generation of products is now being marketed by the tobacco
industry with advertisements suggesting that they deliver lower amounts
of toxic or addictive agents. For example, one such advertisement says,
``all of the taste . . . less of the toxins.'' These products--
sometimes referred to as potential reduced-exposure tobacco products,
or ``PREPs''--are highly engineered products which utilize new
technologies to try to reduce certain harmful constituents, such as
carcinogens (cancer causing agents) from tobacco smoke. To date,
however, the scientific evidence is insufficient to evaluate whether
these new products actually reduce the users' exposure or risk for
tobacco-related diseases. The 2001 Institute of Medicine report
Clearing the Smoke concluded that currently-available data does not
allow for drawing meaningful differences in toxicity or harm between
tobacco products and that a structure for regulatory oversight would be
essential to any scientific assessment of claims for reduced harm.
There is a need for independent, objective, scientific research to
provide guidance to the public about the health effects of different
tobacco products. In order to address this research gap, NCI has
introduced several new initiatives, including:
A Program Announcement titled, ``Testing Tobacco Products
Promoted to Reduce Harm,'' which aims to stimulate
multidisciplinary research on the characteristics of different
tobacco products, methods for measuring users' exposure to
toxic constituents, and the impact of manufacturers' claims on
smokers' perceptions of risk. Currently funded grants under
this Program Announcement include projects studying:
The impact of low ignition propensity (``fire-safe'')
cigarettes (Roswell Park Cancer Institute).
Mutagenicity of tobacco smoke in human cell co-cultures
(New York University).
Clinical models for evaluating PREPs for tobacco users
(Virginia Commonwealth University).
Laboratory based evaluation of potential reduced
exposure products (Georgetown University).
Smoking topography and harm exposure in a new PREP
(University of Pennsylvania).
A 5-year Research and Development contract with the Lombardi
Cancer Center at Georgetown University to support the
advancement of laboratory methods for tobacco product testing,
taking into account human behavior. Once developed, these
methods could be utilized to assess the potential for new
products to reduce exposure in the laboratory and in human
clinical trials and to assist in evaluating the potential
impact of product design changes on individuals and the
population as a whole.
Support of the University of Minnesota Transdisciplinary
Tobacco Use Research Center (TTURC), which is conducting
research on ways to reduce smokers' exposure to tobacco smoke
and its constituents.
Support of the Roswell Park Cancer Institute TTURC, which is
studying how changes in cigarette design alter smokers' actual
exposures and their perceptions of the health risks of smoking.
Their ongoing multi-country survey also collects information on
smokers' perceptions of ``light'' and ``ultra light''
cigarettes.
NCI is utilizing two of its ongoing national surveys--the
Health Information National Trends Survey and the Tobacco Use
Supplement to the Current Population Survey--to collect data on
tobacco use and health risk perceptions related to new PREPs
and other tobacco products.
Collaboration with research partners, including other NIH
Institutes and Centers, HHS's Centers for Disease Control and
Prevention (CDC), and the World Health Organization (WHO), to
identify research priorities and develop expertise related to
tobacco products. NCI scientists are currently active members
of the WHO Study Group on Tobacco Product Regulation and the
Tobacco Laboratory Network, which aim to develop guidance on
tobacco product testing.
Research also suggests that there is substantial risk that smokers
over-interpret reduced risk claims made for modified tobacco products.
Exposure reduction messages associated with these products appeal to
smokers who are contemplating quitting.\12\ Therefore, marketing of
these products with messages that imply reduced exposure or harm may
undermine youth prevention and adult cessation, which could result in
an overall increase in harm to the population.
---------------------------------------------------------------------------
\12\ Shiffman, S., Pillitteri, J.L., Burton, S.L., and Di Marino,
M.E. Smoker and ex-smoker reactions to cigarettes claiming reduced
risk. Tobacco Control 2004; 13:78-84.
---------------------------------------------------------------------------
There is an ongoing need to ensure that consumers receive accurate
information about the health risks of smoking. The use of misleading
descriptors like ``light'' and ``mild'' and similar terms have been
banned in 43 countries, including Canada, Brazil, and the 27 countries
of the European Union.
Tobacco smoke is extremely complex, containing thousands (over
4,800) of constituents including at least 69 known carcinogens. Because
of the complexity of tobacco smoke and variations in smoking patterns,
it is unlikely that any single machine test will be able to provide
meaningful estimates of actual human exposure to harmful constituents.
Instead, it is likely that a battery of tests will be needed to make
meaningful comparisons across products. Currently, standardized machine
measurements of tobacco smoke emissions continue to be useful in
laboratory settings to understand the properties of different
cigarettes. However, these measurements do not provide meaningful
information about the actual exposure or risk for the individual
smoker. A WHO expert advisory group has stated that numerical ratings
for tar, nicotine, and carbon monoxide from the FTC/ISO test method are
misleading and recommended that they should not be displayed in
advertising or on the cigarette packaging.\13\
---------------------------------------------------------------------------
\13\ World Health Organization, ``SACTob Recommendation on Health
Claims Derived form ISO/FTC Method to Measure Cigarette Yield''
(January 1, 2003). Tobacco Control. WHO Tobacco Control Papers. Paper
ISO200. http://repositories.cdlib.org/tc/whotcp/ISO200.
---------------------------------------------------------------------------
Since the 1964 publication of the landmark Surgeon General's Report
on Smoking and Health provided conclusive evidence of the health risks
of smoking to the nation, education to better inform the public on
smoking and health issues has been a crucial component of tobacco
control and prevention efforts. For decades, the public has been misled
by advertising implying, directly or indirectly, that low-tar
cigarettes are less hazardous than other cigarettes. It is vital that
the public understand that the only proven way to reduce the enormous
burden of disease and death due to tobacco use is to prevent youth from
beginning to smoke, and to help smokers, both youth and adults, to
quit.
Thank you for this opportunity to present this information to you.
I would be happy to answer any questions you may have.
Senator Lautenberg. Thank you very much.
Dr. Ashley?
STATEMENT OF DAVID L. ASHLEY, Ph.D., CHIEF,
EMERGENCY RESPONSE AND AIR TOXICANTS BRANCH;
CHIEF, TOBACCO LABORATORY, NATIONAL CENTER FOR
ENVIRONMENTAL HEALTH, CENTERS FOR DISEASE CONTROL
AND PREVENTION (CDC), DEPARTMENT OF HEALTH AND
HUMAN SERVICES; AND CHAIR, TOBACCO LABORATORY
NETWORK, WORLD HEALTH ORGANIZATION
Dr. Ashley. Mr. Stevens, Mr. Lautenberg, I'm Dr. David
Ashley, Chief of the Emergency Response and Air Toxicants
Branch, and Chief of the Tobacco Laboratory in the National
Center for Environmental Health of the Centers for Disease
Control and Prevention. I am also Chair of the World Health
Organization's Tobacco Laboratory Network. I am pleased to be
here today to discuss research findings from the CDC Tobacco
Laboratory and provide a better understanding of the Federal
Trade Commission Method and how results from the FTC Method
should be interpreted.
Our laboratory evaluates how design and contents of tobacco
products influence emissions of toxic and addictive substances,
how people use these products, and how these factors impact
people's exposure to the substances that cause disease.
We work closely with CDC's Office on Smoking and Health. We
use multiple machine-smoking regimens, including the FTC
smoking regimen, in our research.
For the past 12 years, CDC has developed and applied
measurements to better understand the amount of addictive and
toxic substances in cigarettes, and factors that affect the
delivery of those substances to smokers and persons exposed to
secondhand smoke. Our smoking machines enable us to assess the
influence of various smoking conditions on the delivery of
addictive and toxic substances to smokers. In tobacco and
tobacco smoke, we currently measure nicotine, tar, tobacco-
specific nitrosamines, bio-organics, aldehydes, polycyclic
aromatic hydrocarbons, heavy metals, and other chemicals. Our
lab has performed studies that assess the smoke intake of
individual smokers. In addition, for the past 20 years we have
measured components of cigarette smoke in the urine and blood
of smokers and people exposed to secondhand smoke.
The FTC Method originated in observations made in 1936 on
how people smoked. The smoking parameters proposed, which were
35 milliliter puffs of 2 seconds' duration, with a puff each 60
seconds, were based on how the cigarettes which were sold at
that time were smoked. Since then, cigarette designs have
changed through modification of the tobacco-blend composition,
ventilated filters, porous paper, reconstituted tobacco, and
expanded tobacco.
In carrying out a measurement using the FTC regimen, the
tips of up to 20 cigarettes at a time are placed into holders
that are attached to the smoking machine, which contains
syringes or other devices for drawing air through the
cigarettes. Holders included glass filter, commonly known as a
Cambridge Filter pad, for collecting particulate matter, and
special bags for collecting the gas phase.
Cigarette manufacturers have added ventilation holes to the
modern cigarette in the paper surrounding the filter. These
holes are far enough from the tip of the cigarette that they're
exposed to room air when the cigarette is placed in the smoking
machine to be tested using the FTC Method. As a result, room
air is pulled into the cigarette and dilutes the smoke that is
collected on the filter pad and in the collection bag, lowering
the measured levels of nicotine, tar, and carbon monoxide.
Other factors can also influence the delivery, including
the length of the filter, the design of the filter, the
porosity of the paper; but, of these, filter ventilation is the
major factor.
The way that people smoke cigarettes varies between people,
and there are also variations in the way an individual smokes
at different times. One of the more important factors in
determining how people smoke is their need for nicotine. Unlike
the machine, smokers are able to adjust the way they smoke by
taking larger puffs, more frequent puffs, or blocking
ventilation holes so that they can increase their nicotine
intake when smoking cigarettes with lower machine-measured tar
and nicotine. When individual smokers smoke cigarettes of
different designs, they can compensate, resulting in exposure
to levels of smoke that vary much less than would be expected
based on the results from the machine smoking using the FTC
Method.
Studies of biomarkers in smokers have also shown that
exposure to the toxic and addictive components to tobacco smoke
are fairly consistent whether a smoker smokes a light, medium,
or full-flavored cigarette.
Machine smoking regimens that are more intense than the FTC
Method are currently in use. Health Canada requires tobacco
companies to report levels of chemicals in tobacco smoke using
a modified method with 55-milliliter puffs taken every 30
seconds and all ventilation holes blocked. The State of
Massachusetts has required reports of tobacco emissions using a
regimen of 45-milliliter puffs taken every 30 seconds with half
of the ventilation holes blocked. These more intense smoking
regimens are aimed at better approximating how the average
smoker actually smokes the cigarette.
In summary, our laboratory has developed a broad set of
capabilities to measure addictive and toxic substances in the
tobacco product, in cigarette smoke, and in people. We've
investigated different machine-smoking regimes, including the
FTC Method, and how cigarette design factors can influence the
delivery of toxic and addictive substances. We've found that
using multiple smoking regimens improves our understanding of
the variation in actual delivery of nicotine, tar, and carbon
monoxide to the smoker, compared to using the FTC Method alone.
Thank you for this opportunity to present this information
to you. I would be happy to answer any questions you may have.
[The prepared statement of Dr. Ashley follows:]
Prepared Statement of David L. Ashley, Ph.D., Chief, Emergency Response
and Air Toxicants Branch; Chief, Tobacco Laboratory, National Center
for Environmental Health, Centers for Disease Control and Prevention;
and Chair, Tobacco Laboratory Network, World Health Organization
Mr. Chairman and Members of the Committee, I am Dr. David Ashley,
Chief of the Emergency Response and Air Toxicants Branch and Chief of
the Tobacco Laboratory in the National Center for Environmental Health
of the Centers for Disease Control and Prevention (CDC), an agency of
the Department of Health and Human Services. I am also the Chair of the
World Health Organization's Tobacco Laboratory Network. I am pleased to
be here today to discuss research findings from the CDC Tobacco
Laboratory that provide a better understanding of the Federal Trade
Commission (FTC) method and how results from the FTC Method should be
interpreted.
Our laboratory has five research priorities: (1) to characterize
the chemical constituents and chemical additives of tobacco products;
(2) to characterize the chemical and physical properties of tobacco
products that influence delivery of nicotine and other harmful
substances; (3) to identify the causative agents of disease in tobacco
and tobacco smoke; (4) to assess the exposure of the U.S. population
(including children, women of childbearing age, and other susceptible
groups) to the harmful chemical constituents of tobacco smoke; and (5)
to collaborate in health studies examining the relationship of
secondhand smoke exposure to health outcomes, such as cancer. We work
closely with CDC's Office on Smoking and Health.
Smoking causes diseases of the lungs and coronary arteries of the
heart, the latter being the leading cause of death in the United
States. Cigarette smokers are 2 to 4 times more likely to develop
coronary heart disease than nonsmokers. While attempting to decrease
the risk of cancer associated with smoking by reducing exposures to
suspected or known carcinogens is worthwhile, it is equally important
to recognize that the amount of small particles, called particulate
matter, is inhaled from cigarettes by smokers at many times the levels
found to be associated with significant risk for diseases of the lung
and heart among persons breathing air containing these particles from
other sources such as industrial pollution or fires.
Our laboratory has developed a broad set of capabilities to measure
addictive and toxic substances in the tobacco product, in cigarette
smoke, and in people who smoke and are exposed to the smoke of others.
We use multiple machine smoking regimens (i.e., specified puff volumes,
puff rates, total smoking time), including the FTC smoking regimen, in
our research.
For the past 20 years, our lab at CDC has conducted research on
assessing exposure to cigarette smoke. We developed new methods to
measure cotinine, a metabolite of nicotine, in serum and saliva as a
marker of tobacco smoke exposure. We have applied this measurement to
national surveys to track over time the exposure of the U.S. population
to tobacco smoke, both for smokers and persons exposed to secondhand
smoke. We have documented substantial decreases in exposure to
secondhand smoke in the U.S. population and identified differences in
exposure between age, sex, and race/ethnic groups.
CDC has also developed and applied measurements to better
understand the amount of addictive and toxic substances in cigarettes
and factors that affect the delivery of these substances to smokers and
persons exposed to secondhand smoke. Our smoking machines enable us to
assess the influence of various smoking conditions on the delivery of
addictive and toxic substances to smokers. In tobacco and tobacco
smoke, we currently measure nicotine, ``tar'' (i.e., nicotine-free dry
total particulate matter), tobacco-specific nitrosamines, volatile
organics, aldehydes, polycyclic aromatic hydrocarbons, and heavy
metals. Our lab has performed studies that assess the smoke intake of
individual smokers. In addition, we have measured components of
cigarette smoke in the urine and blood of smokers and people exposed to
secondhand smoke.
The FTC Method originated in observations made by J.A. Bradford and
Colleagues \1\ in 1936 on how people smoked and was described again by
C.L. Ogg in 1964.\2\ The smoking parameters they proposed (i.e., 35
milliliter puffs of 2 seconds duration with a puff each 60 seconds to a
butt length of 23 millimeters or to the length of the overwrap plus 3
millimeters, whichever is longer) were based on how the cigarettes
which were sold at that time were smoked. Since then, cigarette designs
have changed, through, for example, changes in the tobacco blend
composition, ventilated filters, porous paper, reconstituted tobacco,
and expanded tobacco.\3\
In carrying out a measurement using the FTC regimen, the tips of up
to 20 cigarettes at a time are placed into holders that are attached to
the smoking machine, which contains syringes or other devices for
drawing air through the cigarettes. The holders include a glass filter
commonly known as a Cambridge filter pad for collecting particulate
matter. Special bags collect the gas phase which is drawn through the
Cambridge filter pads. To measure nicotine and ``tar'', the particulate
matter collected on the pad is extracted and analyzed by a separate
analytical instrument known as a gas chromatograph. The carbon monoxide
generated during smoking is measured by an infrared spectrometer that
samples from the collection bags.
Cigarette manufacturers have added ventilation holes to the modern
cigarette, punched in the paper surrounding the filter. These holes are
far enough from the tip of the cigarette that they are exposed to room
air when the cigarette is placed in the smoking machine to be tested
using the FTC Method. As a result, room air is pulled into the
cigarette and dilutes the smoke that is collected on the filter pad and
in the collection bag. This dilution using ventilation holes results in
lower measured levels of nicotine, ``tar'', and carbon monoxide.\3\
Other factors can also influence the delivery of nicotine, ``tar'', and
carbon monoxide including the length of the filter, the design of the
filter, and the porosity of the paper; but, of these, filter
ventilation is the major factor.
The way that people smoke cigarettes varies between people and
there are also variations in the way an individual smokes at different
times. Factors that influence smoking patterns include nicotine level
of the cigarette, the smoker's level of stress, mood and the time since
they smoked their last cigarette. One of the more important factors in
determining how people smoke is their need for nicotine. Persons
smoking cigarettes with a range of nicotine levels adjust the way they
smoke to obtain a relatively steady amount of nicotine per
cigarette.\4\ Unlike the machine, smokers are able to adjust the way
they smoke by taking larger puffs, more frequent puffs, or blocking
ventilation holes so that they can increase their nicotine uptake, when
smoking cigarettes with lower machine-measured ``tar'' and nicotine.\5\
When a larger puff is taken, puffs are taken more frequently, or
ventilation holes are blocked, cigarettes deliver much higher levels of
the toxic and addictive components of tobacco smoke than is
characterized using the FTC Method. When individual smokers smoke
cigarettes of different designs, compensation techniques result in
exposure of smokers to levels of smoke that vary much less than would
be expected based upon results from machine smoking using the FTC
Method.\4\
Studies of biomarkers in smokers (chemical measurements in blood
and urine) have also shown that exposure to the toxic and addictive
components of tobacco smoke are fairly consistent, whether a smoker
uses a light, medium, or full-flavored cigarette.\4\ \6\ These findings
are largely explained by compensation techniques used by the smokers.
Machine smoking regimens that are more intense than the FTC Method
are currently in use. Health Canada requires tobacco companies to
report levels of chemicals in tobacco smoke using a modified method
with 55 milliliter puffs taken every 30 seconds and all ventilation
holes blocked. The State of Massachusetts has required reports of
tobacco emissions using a regimen of 45 milliliter puffs taken every 30
seconds with half of the ventilation holes blocked. These more intense
smoking regimens are aimed at better approximating how the average
smoker actually smokes the cigarette.
In summary, our laboratory has developed a broad set of
capabilities to measure addictive and toxic substances in the tobacco
product, in cigarette smoke and in people. We have investigated
different machine smoking regimens, including the FTC Method and how
cigarette design factors can influence the delivery of toxic and
addictive substances. We have found that using multiple smoking
regimens improves our understanding of the variation in actual delivery
of nicotine, ``tar'', and carbon monoxide to the smoker compared to
using the FTC Method alone.
Thank you for this opportunity to present this information to you.
I would be happy to answer any questions you may have.
References
\1\ Bradford, J.A., Harlan, W.R., Hanmer, H.R. Nature of cigarette
smoke: technique of experimental smoking. Industrial and Engineering
Chemistry 1936; 28(7):836-839.
\2\ Ogg, C.L. Determination of particulate matter and alkaloids (as
nicotine) in cigarette smoke. Journal of the Association of Official
Analytical Chemists 1964; 47(2):356-362.
\3\ Hoffmann, D., Hoffmann, I. The changing cigarette, 1950-1995.
Journal of Toxicology and Environmental Health 1997; 50(4):307-64.
\4\ Jarvis, M.J., Boreham, R., Primatesta, P., Feyerabend, C.,
Bryant, A., Nicotine yield from machine-smoked cigarettes and nicotine
intakes in smokers: evidence from a representative population survey.
Journal of the National Cancer Institute 2001; 93(2):134-138.
\5\ Melikian, A.A., Djordjevic, M.V., Chen, S., Richie, Jr., J.,
Stellman, S.D. Effcet of delivered dosage of cigarette smoke toxins on
the levels of urinary biomarkers of exposure. Cancer Epidemiology
Biomarkers and Prevention 2007b; 16(7):1408-15.
\6\ Hecht, S.S., Murphy, S.E., Carmella, S.G., Li S., Jensen, J.,
Le, C., Joseph, A.M., Hatsukami, D.K. Similar uptake of lung
carcinogens by smokers of regular, light, and ultra light cigarettes.
Cancer Epidemiology Biomarkers and Prevention 2005; 14(3):693-8.
Senator Lautenberg. Thank you very much.
The--thank you all--each for your testimony. And not only
did I marvel at the detail with which you reported your
findings, but the fact that you were all able to come very
close to the time mark that we had set out for you, that
deserves congratulations. I wish we could say the same for this
side of the table.
Commissioner Kovacic, I think it was fairly clear what you
said--but just--let me verify it--that the FTC cigarette
testing method is inaccurate at predicting the amount of tar
and nicotine that a smoker will receive from a cigarette.
Mr. Kovacic. That's correct, Senator.
Senator Lautenberg. Given that the FTC is not a scientific
agency, should your agency continue to oversee these health
ratings?
Mr. Kovacic. We think it would be much better, Senator,
that that task be dedicated to one of our public institutions
that has the deeper scientific expertise.
Senator Lautenberg. Do you think that the ratings based on
the FTC cigarette testing method are designed to deceive
smokers into believing that their health is less harmed when
they use tar or light cigarette designations?
Mr. Kovacic. The rating system, as it was designed, was not
designed to deceive. The assumption was that it would assist
smokers, who wanted to choose lower-tar cigarettes, in
particular, to select cigarettes that would give them a lower
dosage of tar when they smoked. What is impressive from the
testimony of my colleagues and others, and the work that their
institutions have done, is that those early assumptions did not
take into account what's called the ``compensation effect.''
And I think the key question for all of us whether there is any
significant subset of users who do derive useful information
from these standards and change their behavior in beneficial
ways, or whether, as I believe I interpret Dr. Backinger's
findings, in particular, that those instances of benefit are
negligible.
Senator Lautenberg. Would the FTC object if Congress
prohibited tobacco companies from continuing to make claims
based on the FTC Method?
Mr. Kovacic. I would strongly prefer that there be a
process that asks whether, first, there is an alternative
measure or measurement that would be an improvement. But, I
think, at a minimum, the guidance that Congress might give is
first, to pursue alternatives that would be more informative.
But, if, indeed, there is a general conclusion, assembling the
science that has been done in this area, that the FTC Method,
as it's called, provides no benefits to consumers, and, indeed,
has net harms, then that's a basis for prohibition.
Senator Lautenberg. I go back to a time, Senator Stevens,
when we were taught to smoke by the military, our emergency
rations had a sleeve of four cigarettes, essentially saying
that tobacco is good for you, it calms the nerves, et cetera.
It--didn't say that we were creating addicts. And, at the time,
I served in the European theater--and I know that you served in
the Pacific CBI, right?--that all of the temporary camps that
were used to receive soldiers in the European theater, and the
same ones used to send them back home, were named after
cigarettes. There was Lucky Strike and other camps there--Old
Gold, et cetera. So, we learned the easy way. And though I'm
sure it wasn't the design of the U.S. Government to create this
addiction, the fact is that that was the result.
Dr. Backinger, does the National Cancer Institute believe
that the FTC Method deceives smokers? You talk about the number
of people who started originally smoking light cigarettes, and
how much that market share has grown. Do you think that the
program's designed to deceive people into becoming smokers?
Dr. Backinger. As outlined in the--in Monograph 13, the
research has shown that the FTC numbers and the test method do
not provide meaningful information to consumers. The monograph
also found, through research analyzing tobacco industry
documents, that the tobacco manufacturers knew this.
Senator Lautenberg. Is it appropriate to say that the
continuation of the FTC Method as a basis for light and low-tar
claims could lead more Americans to getting lung cancer?
Dr. Backinger. I--the data do show, from research, that
smokers who were health conscious and may have quit--otherwise
have quit--decided to smoke what was called ``light'' or ``low-
tar'' cigarettes, and, therefore, thinking they were going to
have--be at reduced risk for lung cancer, as well as other
diseases; however, that was not the case.
Senator Lautenberg. In 2001, NCI found that problems with
the FTC cigarette testing method was an urgent health issue.
Has any government agency that you're aware of acted upon those
findings?
Dr. Backinger. Since 2001, when the monograph was issued,
NCI and other institutes at NIH have funded research to look
into different test methods and look at laboratory methods to
look at how smokers smoke under actual conditions. So, the
answer is yes.
Senator Lautenberg. Dr. Ashley, just--this is slightly
repetitive, but I ask the question, nevertheless, to clarify it
for the record. Are light or low-tar cigarettes as addictive as
regular cigarettes, in your judgment?
Dr. Ashley. Using the FTC Method for measuring and
reporting nicotine, tar, carbon monoxide numbers--using that
method did not reflect the way people actually smoke. Our
research has shown that by using multiple methods, you get more
information, you can get more data that tells you much more
what the actual exposure of people is when they actually use
cigarettes. And so, it's important to be able to do that
research and find out exactly what the levels are that people
are actually exposed to, and not the way the machine makes that
measurement.
Senator Lautenberg. Have tobacco companies manipulated
cigarette design to affect the FTC results? Have they moved
things around within the cigarette itself to try and affect a
less ominous result than we really believe is there?
Dr. Ashley. I can't really speak to the motivations of the
tobacco industry, but I--we do know that the design of the
cigarette does greatly influence the measurements and the
results that come from when you use the FTC Method.
Senator Lautenberg. Senator Stevens?
Senator Stevens. Thank you, Mr. Chairman.
Mr. Kovacic, do you have authority to change those
machines?
Mr. Kovacic. I think we don't specify the test methodology
itself, Senator. I think what we would have authority to do is
to withdraw any indication that, in some sense, our agency
stands behind the methodology, and we would certainly have the
authority to convene proceedings, to work with our colleagues,
to draw attention to the limitations of the existing
methodology and suggest others.
Senator Stevens. But, Doctor, they're paid for with
taxpayers' money, right?
Mr. Kovacic. I believe they're not, Senator. The--and this
is something I could clarify for you afterwards, but the----
Senator Stevens. Who possesses them?
Mr. Kovacic. The testing is done by a trade association
that does the tests. We subpoena, on a regular basis, the data,
and post it on our website.
Senator Stevens. Are you prohibited from testing?
Mr. Kovacic. We are not, Senator. We abandoned our own
testing. We used to have variants of these elegant machines on
the top floor of our building, until the mid-1980s, where the
cost of maintaining them became relatively high, and we came to
realize the limitations of our own expertise to do this work.
Senator Stevens. Dr. Backinger, does NCI have any testing
machines?
Dr. Backinger. No, we do not.
Senator Stevens. Dr. Ashley, do you have any testing
machines?
Dr. Ashley. Yes, sir, we do.
Senator Stevens. Where did you get them?
Dr. Ashley. We purchased them as part of our program,
looking at the impact of design of cigarettes on emissions, how
people smoke----
Senator Stevens. That's not the question. Where did you get
them?
Dr. Ashley. We purchased them from manufacturers who make
the machines.
Senator Stevens. They make them for the same testing
organization that's not Federal?
Dr. Ashley. They make them for whatever consumer would
purchase them. They are purchased largely by the tobacco
industry. We got our tobacco smoking machines from the same
companies that make them for the industry.
Senator Stevens. They are the same ones that Mr. Kovacic is
talking about, right?
Dr. Ashley. Yes, sir.
Senator Stevens. Have any of you ever asked Congress for
money to produce your own machines?
Dr. Ashley. If I can try to clarify something, the machine
itself----
Senator Stevens. I've really got a shortage of time,
Doctor, just would you please answer my question. Have any of
your agencies ever asked the Congress to give you money to
replicate those machines, to build better machines?
Dr. Ashley. No, sir.
Senator Stevens. How long have these machines been in
existence? Dr. Kovacic, when were they made?
Mr. Kovacic. I believe, in the 1960s, the original design.
Senator Stevens. That even predates my presence in the
Congress. That's pretty old. You know, I just don't understand
that.
Tell me this, have you done any studies on increasing taxes
on cigarettes and how it affects consumers? Any of you?
Dr. Backinger. The NCI has supported research, through
extramural funding, to look at the increase of price on--price
of cigarettes on consumption and prevalence. And we actually--
one of our monographs addresses that. I don't have that
information with me specifically today. But research does show
that as you increase the price of cigarettes, it affects both
youth smoking and adult smoking.
Senator Stevens. Did that cover the question of bootlegging
cigarettes as a result of increased taxes?
Dr. Backinger. I am not--I don't know that off the top of
my head. I would need to check back with that and get back to
you for the--on the record.
Senator Stevens. Do any of your agencies have jurisdiction
over pursuing those who bootleg cigarettes, who sell them,
notwithstanding Federal laws?
Mr. Kovacic. We generally wouldn't, Senator, no. We could
prosecute people who misrepresent the source of the cigarettes,
who advertise cigarettes as coming from one source, but receive
them from another. But the actual policing of bootlegging,
counterfeiting, that's beyond our authority.
Senator Stevens. It's up to the state, is that right?
Mr. Kovacic. Or, I would assume, Senator, Customs and
Border Protection, those that deal with cross-border movements.
Senator Stevens. Did you start to say something, Dr.
Ashley?
Dr. Ashley. There is a Federal agency that deals with that.
It's not CDC.
Senator Stevens. Well, I've just one last question. As part
of our Congressional involvement, we did require that the
cigarette manufacturers do a certain amount of advertising.
I've seen some recently, as a matter of fact, on television and
over the radio, and, I think, even in the printed media,
directed toward young people and trying to prevent them from
smoking. Have any of you studied the results of those
advertisements that we've required?
Dr. Backinger. The National Cancer Institute did fund one
study in that arena, which was published in the December 2006
American Journal of Public Health. And I could provide that
article for you and for the record.
[The information referred to is contained in the Appendix.]
Dr. Backinger. Just off the top of my head, the research
found that youth that saw those ads on TV were not--did not
help prevent smoking initiation.
Senator Stevens. Since that basic settlement that we were
all part of, has there been an increase or a decrease in
cigarette smoking by younger people?
Dr. Backinger. The--for the latest years that are
available--and I would have to look at that again--but youth
smoking has increased slightly in the last 2 years for which we
have data. Slightly.
Senator Stevens. Last irrelevant question, but my colleague
has mentioned the fact we were all given so many free
cigarettes. My friends and I were never seduced by those
cigarettes. We didn't smoke cigarettes, we smoked pipes. Have
you ever made any studies of pipes and its connection to
cancer, Doctor?
Dr. Ashley. We have not studied pipes.
Senator Stevens. Dr. Backinger?
Dr. Backinger. I am not aware of any NCI-funded research on
pipes, specifically, but I could check.
Senator Stevens. Yes. Well, I'd be interested.
I quit a long time ago, anyway, but I just wondered whether
there is any connection between pipe smoking as well as the
cigarette smoking. What about cigars, have you done studies of
cigars?
Dr. Backinger. We--NCI did look at cigars, and, during the
1990s--when there was an increase in prevalence of smoking of
cigars--and we do have an NCI monograph on that subject.
Just--the other comment, however, is, all tobacco,
regardless of its form, is hazardous and causes a variety of
cancers, as well as other diseases.
Senator Stevens. Did your monographs compare the basic
results of smoking different types of substances, like pipe or
tobacco or cigarettes?
Dr. Backinger. The cigar monograph was focused solely on
the various types of cigars that were available at the time.
Senator Stevens. Well, I thank you very much.
Thank you for your testimony. I'm a little disturbed about
the--this is the first time I've heard about those machines
being--not--that our government testing was not done by other
than machines that the industry developed.
Thank you.
Senator Lautenberg. I have a couple of questions I'd like
to ask you.
Dr. Ashley, last Thursday the CDC found the number of
smokers has remained the same over the last 2 years. We know
that the tobacco companies spent $13 billion in 2005 on
advertising and marketing, almost double that which they spent
in 1998. Do you believe that the increases in tobacco
advertising is the reason that we're seeing no decline in the
population that is smoking?
Dr. Ashley. I believe the CDC report says--concluded that
fact that it is bottoming out and no longer decreasing is
because of the decrease in money spent on tobacco control.
Senator Lautenberg. We're looking at testing machines, and
seeing how reliable they might be. I think the most reliable
testing machines are humans. And is there sufficient
confirmation of the relationship of cancer, heart problems, and
other conditions, that we can attribute directly to smoking?
Dr. Backinger?
Dr. Backinger. Yes.
Senator Lautenberg. Have we seen any tests related to the
difference in the incidence of cancer, et cetera, from the
light, or however else they're described, cigarettes and the
regular cigarettes? Is there more frequent occurrence, can you
say, of using either the regular cigarette or the light
cigarettes, in terms of the people who use these?
Dr. Backinger. The studies that were conducted are
epidemiological studies, population-based. So, it's--we don't
have data on individuals, per se. But, overall, people that
smoke ``light'' or low-tar cigarettes did not have a decrease
in any of the disease risks and cancers from smoking as people
that smoked regular cigarettes, conventional cigarettes.
Senator Lautenberg. Thank you all for your excellent
testimony, and given in very clear, unequivocating fashion. I
appreciate that. Thank you.
And we'll call the next panel, please, to the table.
Senator Stevens. I would appreciate a copy of those two
monographs, Doctor.
Dr. Backinger. Yes, I will follow up with that. Thank you.
Senator Lautenberg. I'm not really a button-pusher, as you
can see.
I thank the members of this panel: Dr. John Samet, the
Chairman of the Department of Epidemiology at Johns Hopkins
University; Jack Henningfield, Adjunct Professor at Johns
Hopkins University School of Medicine; Mr. Marvin Goldberg, a
Professor of Marketing at Penn State University; and Mr.
Stephen Sheller, the Founder and a Managing Partner from the
law firm of Sheller, P.C. And I thank all of you for joining us
and sharing your views and expertise.
And, Dr. Samet, may I ask you, please, to start.
STATEMENT OF JONATHAN M. SAMET, M.D., M.S., PROFESSOR AND
CHAIRMAN, DEPARTMENT OF EPIDEMIOLOGY, JOHNS HOPKINS BLOOMBERG
SCHOOL OF PUBLIC HEALTH
Dr. Samet. Thank you, Senator Lautenberg, Senator Stevens.
I appreciate the opportunity to address the Committee today on
the matter of the accuracy of the FTC tar and nicotine rating
system. This is an important public health issue, not only for
the United States, but for the approximately 1.3 billion
smokers in other countries.
Let me begin with the bottom line; that is, that there is a
consensus among the scientific and public health communities
that a lower machine yield of tar and nicotine, as measured by
the FTC protocol, has no health implications. I base this
statement on the findings of a number of recent reviews by
expert groups, including not only Monograph 13 of the National
Cancer Institute, but a review by the Institute of Medicine
published in 2001, the 2004 report of the Surgeon General, and
a review of the same topic, carried out in 2002, published in
2004, by the World Health Organization's International Agency
for Research on Cancer. In my written testimony, I've
summarized the key statements from these reports.
As a major finding, the 2004 report of the Surgeon General
states, ``Smoking cigarettes with lower machine-measured yields
of tar and nicotine provides no clear benefit to health.'' What
is the basis for this bottom line? Part of the basis lies in
the epidemiological studies already referred to in the last
panel, those studies that have looked at risks to smokers as
they have been using these products and smoking them. This is a
somewhat difficult area for epidemiologists, but we now have
many studies on the question.
To quickly summarize evidence that is included in these
different reports, the epidemiological studies that have been
carried out largely show no indication of lower risks
associated with using lower-yield products. Perhaps one
exception are studies that compared, early on, users of filter
to the nonfilter cigarettes of the past.
We have additional data from--comparison of how risks have
changed over time; first, in the two large studies of 1 million
Americans each, carried out by the American Cancer Society, and
also in a 50-year study of the British doctors. We've seen a
decline in the sales-weighted average of tar from above 30
milligrams per cigarette to less than 15. These studies show no
indication of a parallel change in risk. In fact, comparing the
findings of CPS I, the first study of the American Cancer
Society, 1959 to 1972, with the findings of the second study,
which began in 1980, risks for all of the major diseases went
up. The same finding was noted in the study of British doctors,
carried out over 50 years, with no decline in risks for lung
cancer and other diseases over time.
Another relevant body of data involves measuring the level
of tobacco-smoke components, so-called biomarkers, in body
fluids of those who smoke. Again, if the FTC Method was giving
us accurate information about the amounts of carcinogens and
other toxins entering people, we would expect to find that
levels of such markers in smokers paralleled those in the
products--paralleled the yields of those in the products that
they smoked. In fact, using such markers, we find no
correlation, or limited correlation, between what is on the
package and what is in the person.
Recently, for example, we measured cotinine, a nicotine by-
product, in saliva samples from smokers in four countries
around the world. We found no difference in the uptake of
nicotine in these smokers, as indicated by the cotinine level,
comparing smokers of regular and light cigarettes. There are
many other studies with similar findings.
So, in summary, we now have epidemiological studies that
have addressed the challenging question of whether changes in
the product over time have altered risks. Both epidemiological
studies and evidence from studies using biomarkers show no
changes in risk for the major smoking-related diseases--caused
diseases--that parallel the changes in nicotine or tar yield.
All of the recent authoritative reports developed by
multidisciplinary teams of experts have concluded that there is
no indication of benefit to the health of smokers from smoking
lower-yield products.
The FTC tar and nicotine ratings provide no meaningful
information about risks to smokers. The numbers provided are
potentially misleading the smokers, as are product labels that
attempt to convey messages based on yield.
Thank you, and I'd be pleased to answer questions.
[The prepared statement of Dr. Samet follows:]
Prepared Statement of Jonathan M. Samet, M.D., M.S., Professor and
Chairman, Department of Epidemiology, Johns Hopkins Bloomberg School of
Public Health
Introduction and Background
Mr. Chairman, and Committee members, thank for you the opportunity
to address the Committee on Commerce, Science, and Transportation on
the matter of the accuracy of the FTC tar and nicotine rating system.
This is an important public health issue, not only for the United
States, but for the approximately 1.3 billion smokers in other
countries. In my testimony I will speak to whether the FTC ratings and
tobacco industry cigarette brand labels that have an implicit basis in
them, e.g., ``light'' and ``ultra light'', have any implications for
the serious risks to health caused by cigarette smoking.
In speaking to this topic, I draw on several decades of relevant
research experience as well as my participation in developing a number
of the major reports that have considered the FTC ratings and the
implications of tar and nicotine yields for risks to health. My
professional background and training is in internal medicine and the
subspecialty of pulmonary diseases and in epidemiology, the scientific
method used to study the health of populations. I have carried out
research that examined if risks for lung diseases, including lung
cancer, are associated with type of cigarette smoked and tar yield. My
studies have also assessed whether levels of biomarkers of tobacco
smoke exposure, particularly cotinine (the major nicotine metabolite)
vary with the yield and type of cigarette smoked.
Additionally, I was a contributor to Monograph 13 of the National
Cancer Institute, published in 2001, which addressed the implications
of lower-yield products, as measured by machine, for human health. I
was Senior Scientific Editor for the 2004 Report of the Surgeon General
on active smoking and Chair of the Working Group of the International
Agency for Research on Cancer (IARC) of the World Health Organization
that developed Monograph 83, Tobacco Smoke and Involuntary Smoking,
published in 2004. These reports also considered the information about
risks provided by cigarette yield. In the Department of Justice lawsuit
against the tobacco industry (United States v. Philip Morris), I also
testified on this topic.
There Is Consensus That a Lower Machine Yield Has No Health Benefit
The attached table provides the summary findings of the key recent
reports on the topic including those prepared by the National Cancer
Institute,[1] the Institute of Medicine,[2] the
Surgeon General,[3] and the International Agency for
Research on Cancer [4] (Table 1). Each of these reports was
developed by a multidisciplinary group of experts who evaluated the
relevant evidence. There is clear consensus in their findings: machine-
measured yields of tar and nicotine are not informative with regard to
risks to health of smoking cigarettes; lower yields do not imply lesser
health risks. As a major finding, the 2004 report of the Surgeon
General states (p. 25): ``Smoking cigarettes with lower machine-
measured yields of tar and nicotine provides no clear benefit to
health.''
Epidemiological Studies Provide No Evidence That Lower Yields Have
Health Benefits
Much of the scientific evidence leading to this consensus comes
from epidemiological studies. FTC reports and other information
document a substantial decline since the 1950s in machine-measured tar
and nicotine yields of cigarettes smoked in the United States (Figure
1). Epidemiologists have carried out research to determine whether this
decline has had any consequences for risks to the health of smokers. A
substantial benefit might be anticipated, of health risks tracked with
machine-measured yields.
The relevant evidence on the risk of lower tar products has been
growing, but this is a difficult topic for researchers. Investigating
the consequences of modifications in cigarettes is difficult because
cigarettes have been changing continually over time, so that
comparisons cannot be made between groups that have smoked the same
cigarettes throughout their entire lives. People who started smoking in
the 1950s then moved on to the cigarettes of the 1960s and 1970s, for
example, if they continued to smoke. In spite of these methodological
complications, epidemiological studies would be able to detect changes
in risk of a magnitude that matched the changes in yields (Figure 1).
The available epidemiological evidence comes from three sources:
(1) comparisons of changes in mortality rates for lung cancer and other
diseases over time in relation to changes in products used by smokers;
(2) case-control studies comparing disease risks in smokers of
different types of products; and (3) cohort studies that have tracked
smokers over substantial periods of time, as with the study of British
physicians in progress from 1951 through 2001, or that have been
conducted serially, as with the two very large epidemiological studies
carried out by the American Cancer Society and known as Cancer
Prevention Studies I and II, or CPS I and CPS II. The relevant evidence
is not extensive and not fully consistent across the three sources.
There is also evidence from studies that have involved measurements of
levels of cigarette smoke components in biological samples from smokers
of different types of cigarettes.
Several case-control and cohort studies have shown small reductions
in risk, on the order of 20 percent for lung cancer, comparing smokers
of filter cigarettes with smokers of non-filter cigarettes. These were
largely early epidemiological studies, carried out in the 1960s and
1970s; the comparison at the time was largely between smokers of non-
filtered and filtered cigarettes. Several reports have commented on
these early findings (Table 1). The relevance of these findings to
current cigarettes is uncertain. In general, epidemiological studies
show that tar yield of the cigarettes smoked is only a weak predictor
of lung cancer risk after taking account of other aspects of the
smoking history.
Some have interpreted the rapid decline in lung cancer mortality in
younger males in the United Kingdom during the last decades of the 20th
century as indicating a benefit of the changing cigarette. Sir Richard
Peto at Oxford has proposed that the decline in lung cancer rates in
the United Kingdom was too great to be explained by dropping smoking
rates alone and has argued that changes in cigarettes over time also
contributed to the decline. However, data from major cohort studies
that cover the same time period--the British physicians' study, and CPS
I and II indicate rising relative risks of lung cancer over time in
smokers generally. If the changes in cigarette yields had any benefit
we would expect these relative risks to be dropping. Instead, they have
risen.
Some of the most compelling evidence is from the American Cancer
Society's Cancer Prevention Studies. The data from these studies show
that regardless of how cigarettes changed, for smokers in CPS I (1959-
1972) versus those in CPS II (1980-1986), relative risks of lung cancer
(and other diseases) went up (Table 2). Over the time interval
separating these two studies, there was a substantial drop in the tar
and nicotine yields of the cigarettes that were smoked in the United
States (Figure 1). In fact, in more detailed analyses of the data that
have been published, the mortality rates from lung cancer tend to be
higher within categories defined by the numbers of cigarettes smoked
and the number of years of smoking, comparing the second study with the
first.[5,6] This pattern of higher risks in CPS II suggests
an increase in the risk of smoking over time, comparing similar groups
of smokers in CPS I and CPS II.
Also relevant are analyses of the data from the British Doctors'
Study which compared risks in the first and second halves of the study
after 40 years of follow-up.[7] The comparison shows that
the relative risk values went up comparing the first 20 years (1951-
1971) to the second 20 years (1972-1991). The paper on the 50-year
follow-up described progressively increasing risks for mortality among
smokers over the five decades of follow-up.[8] Even looking
back at the older studies that found small reductions in relative risks
at one particular point in time, comparing filter to non-filter
cigarette use, these studies did not track how risks changed over time
as more and more smokers were smoking cigarettes with lower FTC tar and
nicotine yields and the sales-weighted tar and nicotine yields declined
progressively (Figure 1).
While the epidemiological studies have emphasized smoking and lung
cancer, findings have been generally similar for the other major
diseases caused by cigarette smoking. With respect to heart disease and
chronic obstructive pulmonary disease (COPD), the evidence has also
consistently shown that smokers who use lower tar products obtain no
benefit at all in terms of reducing their risk of acquiring these two
diseases. The findings from the comparison of CPS I and CPS II are
similar to those for lung cancer (see Table 2). Risks for all the major
diseases caused by smoking increased in CPS II.
It is important to consider a possible additional risk to health
posed by the use of low yield products: the 2004 Surgeon General's
Report noted the rise in adenocarcinoma, among the major types of lung
cancer. One remarkable change in the epidemiological characteristics of
lung cancer over the last 40 years approximately has been a shift in
the predominant type of lung cancer. At the beginning of the epidemic
of tobacco-caused lung cancer, the leading histologic type was squamous
cell carcinoma, which characteristically involves the larger and more
central airways of the lung. Since the late 1960s, there has been a
shift so that adenocarcinoma is now the most common in both men and
women. Interestingly, adenocarcinomas tend to occur more peripherally
in the lung, arising from the smaller airways. One hypothesis is that
changes in the cigarette have lead to deeper inhalation with a pattern
of deposition of carcinogens in the lung that differed from that
typically occurring with the older, higher-yield
products.[9,10] Some have also suggested that the mix of
carcinogens in tobacco smoke may have changed, perhaps with greater
concentrations of tobacco-specific nitrosamines, which cause
adenocarcinoma in exposed animals.
Biomarker Studies Show No Association of Machine-Measured Yield With
Levels of Smoke Components in the Bodies of Smokers
Researchers have studied the relationship between the FTC
measurements, that is, tar and nicotine yields as reported from the FTC
Method, and the levels of tar components and nicotine actually entering
into the bodies of smokers. Biomarker is a general term for compounds
that can be measured in a biological material. With regard to cigarette
smoking, we measure these biomarkers as quantitative indicators of how
much a person has smoked, and of the amount of biological materials
reaching the lungs, and then getting into the bloodstream.
Using these methods, researchers have explored the relationship
between the FTC-yield measurements and the levels of biomarkers in
smokers. If the FTC measurements are providing meaningful information,
the levels of biomarkers should track with the measured yields. A
number of studies have used biomarkers of dose for specific tobacco
smoke components, including carboxy-hemoglobin (hemoglobin bound to
carbon monoxide rather than to oxygen) and cotinine (a metabolite
specific to the breakdown of nicotine).
In general, research using these biomarkers has indicated little,
if any, correlation between the FTC-yield of tar or nicotine, and the
levels of the biomarkers measured in smokers. These studies have been
conducted both in the population context and in laboratory settings.
For example, in a study that my group conducted in New
Mexico,[11] we collected saliva for the analysis of cotinine
levels, and breath samples for measurement of carbon monoxide levels in
a population survey sample of Hispanic persons. After taking account of
the numbers of cigarettes smoked, the levels of biomarkers were not
associated with the yields of tar and nicotine of the current brand of
cigarette. Another study [12] evaluated smoking patterns and
biomarkers in the laboratory setting, contrasting smokers of medium-
yield and low-yield cigarettes. The smokers had greater puff volumes
and puff frequencies than are specified in the FTC protocol and had
substantially greater intakes of tar and nicotine than those implied by
the brand yield listings. More recently, we measured the cotinine level
in saliva samples from smokers in four countries (Brazil, China,
Mexico, and Poland).[13] Cotinine concentration per
cigarette smoked did not differ between smokers of light and regular
cigarettes (Figure 2). Figure 2 shows the data for each country with
two curves for country, one showing the cotinine level for smokers of
regular cigarettes and the other for smokers of light cigarettes. The
curves are essentially identical in each of the countries.
These and other results suggest that there is little difference in
the levels of biomarkers comparing smokers of higher yield tar/nicotine
cigarettes and lower yield tar/nicotine cigarettes, as measured by the
FTC Method. This finding implies that doses of carcinogens or other
toxic materials that smokers inhale have little relationship, if any,
to the FTC tar yield. This finding further implies that the gradual
reduction in tar yield over the past several decades has not resulted
in a reduction in smokers' exposure to carcinogens and other toxic
agents, and that the FTC test method is not informative with respect to
lung cancer risk or to the risks of smoking-caused diseases generally.
There are several explanations for this lack of correlation. First,
the smoking pattern of the machine is not representative of how people
smoke; in other words, the machine does not smoke like a person, or
even the average person. It uses a pattern of puffing that is based on
very old information. Second, the ventilation holes in the filter,
which are not covered when the end of the cigarette is inserted into
the machine, are generally covered by smokers as they hold the
cigarette and puff. Third, smokers tend to compensate for the reduced
yield of nicotine by increasing the volume of puffs (that is, the
volume of smoke they pull into their mouths), the number of puffs per
cigarette, and the number of cigarettes smoked. This compensation is
not replicated by the test machine. In this manner, smoking cigarettes
produces similar levels of biomarkers, regardless of whether the
cigarettes smoked are labeled as ``Low Tar'' or ``Low Nicotine.''
Summary and Overall Conclusions
Beginning in the 1950s, following the initial epidemiological
studies showing very strong associations of smoking with risk for lung
cancer and other diseases, the tobacco industry has continually altered
cigarettes, adding filters and making other changes that have led to
reduced yields of tar and nicotine as measured by a machine (Figure 1).
Both epidemiological studies and evidence from studies using biomarkers
show no parallel changes in risks for the major smoking-caused
diseases. All recent authoritative reports, developed by
multidisciplinary teams of experts, have concluded that there is no
indication of benefit to the health of smokers from smoking lower yield
products. The FTC tar and nicotine ratings provide no meaningful
information about risks to smokers. The numbers provided are
potentially misleading to smokers, as are product labels that attempt
to convey messages based on yield.
Table 1.--Summary findings of the key reports on machine-measured
cigarette yields and health
------------------------------------------------------------------------
Report and Conclusion Page Number Year
------------------------------------------------------------------------
DNCI Smoking and Tobacco Control 2001
Monograph 13 [1]
``Epidemiological and other p. 10
scientific evidence, including
patterns of mortality from
smoking-caused diseases, does
not indicate a benefit to public
health fro changes in cigarette
design and manufacturing over
the last fifty years.''
``Widespread adoption of lower p. 10
yield cigarettes by smokers in
the United States has not
prevented the sustained increase
in lung cancer among older
smokers.''
``Measurements of tar and p. 10
nicotine yields using the FTC
Method do not offer smokers
meaningful information on the
amount of tar and nicotine they
will receive from a cigarette.
The measurements also do not
offer meaningful information on
the relative amounts of tar and
nicotine exposure likely to be
received from smoking different
brands of cigarettes.''
``Epidemiological studies have p. 146
not consistently found lesser
risk of diseases, other than
lung cancer, among smokers of
reduced yield cigarettes. Some
studies have found lesser risks
of lung cancer among smokers of
reduced yield cigarettes. Some
or all of this reduction in lung
cancer risk may reflect
differing characteristics of
smokers of reduced-yield
compared to higher-yield
cigarettes.''
``There is no convincing evidence p. 146
that changes in cigarette design
between 1950 and the mid 1980s
have resulted in an important
decrease in the disease burden
caused by cigarette use either
for smokers as a group or for
the whole population.''
Clearing the Smoke: Assessing the 2001
Science Base for Tobacco Harm
Reduction, Institute of Medicine
[2]
``Most current assessments of p. 2
morbidity and mortality suggest
that low-yield products are
associated with far less health
benefit, if any, than would be
predicted based on estimates of
reduced toxic exposure using FTC
yields.''
``The weight of the evidence p. 67
indicates that lower-tar and
nicotine yield cigarettes have
not reduced the risk of disease
proportional to their FTC
yields, in part because smokers
compensate to obtain more
nicotine and in part because the
products themselves contain
higher concentrations of
selected carcinogens.''
``There is no evidence of a p. 431
threshold for tobacco smoking
and cancer risk. This conclusion
is consistent with the knowledge
that there are many carcinogens
in tobacco smoke, the aggregate
would work to increase risk at
any level. Modeling for low-dose
indicates increased risk with
less than one cigarette per day.
Thus persons who initiate
smoking with PREPS that contain
tobacco would increase their
risk for cancer, and there is
unlikely to be a ``safe''
cigarette. Former smokers who
resume smoking with such
products would increase their
risk further.''
``The available data are p. 432
suggestive, but not sufficient,
to conclude that smokers of so-
called low-tar cigarettes have
lower cancer risk compared to
those who smoke higher tar
cigarettes, with the same
caveats as for filter smoking
studies.''
IARC Monograph 83, Tobacco smoke 2004
and involuntary smoking [4]
``. . . after considering the p. 171
limitations of the evidence, the
Working Group concluded that
changes in cigarettes since the
1950s have probably tended to
reduce the risk for lung cancer
associated with the smoking of
particular numbers of cigarettes
at particular ages.''
``The yields of tar, nicotine and p. 1179
carbon monoxide from cigarettes, (Summary)
as measured by standard machine-
smoking tests, have fallen over
recent decades in cigarettes
sold in most parts of the world,
but have remained higher in some
countries. The tar and nicotine
yields as currently measured are
misleading and have only little
value in the assessment of human
exposure to carcinogens.''
The Health Consequences of 2004
Smoking: A Report of the Surgeon
General [3]
``Smoking cigarettes with lower p. 25
machine-measured yields of tar
and nicotine provides no clear
benefit to health.''
------------------------------------------------------------------------
[1] U.S. Department of Health and Human Services (USDHHS), National
Cancer Institute. Risks associated with smoking cigarettes with low
machine-measured yields of tar and nicotine. Bethesda, MD: National
Institutes of Health, 2001.
[2] Stratton K., Shetty P., Wallace R., Bondurant S., eds. Clearing the
smoke: assessing the science base for tobacco harm reduction.
Washington,D.C.: National Academy Press, 2001.
[3] U.S. Department of Health and Human Services (USDHHS). The health
effects of active smoking: A report of the Surgeon General. 2004.
Washington, D.C., U.S. Government Printing Office.
[4] International Agency for Research on Cancer (IARC). Tobacco smoke
and involuntary smoking. IARC monograph 83. 2004. Lyon, France,
International Agency for Research on Cancer.
Table 2.--Changes in cigarette-related mortality risks between Cancer
Prevention Study 1 (1959 through 1965) and Cancer Prevention Study II
(1982 through 1988) and percentage of deaths attributable to active
cigarette smoking. Source: \14\
CPS I CPS II
Males
Relative Percent Relative Percent
Risk Risk
Overall Mortality 1.7 42.2 2.3 57.1
Lung Cancer 11.9 91.6 23.2 95.7
Coronary Heart 1.7 41.5 1.9 46.2
Disease
Chronic Obstructive 9.3 89.2 11.7 91.4
Pulmonary Disease
Stroke 1.3 21.9 1.9 46.8
Other Smoking 2.7 63.4 3.5 71.2
Related Cancers
Females
Overall Mortality 1.2 18.7 1.9 47.9
Lung Cancer 2.7 63.4 12.8 92.2
Coronary Heart 1.4 27.0 1.8 45.1
Disease
Chronic Obstructive 6.7 85.0 12.8 92.2
Pulmonary Disease
Stroke 1.2 15.2 1.8 45.7
Other Smoking 1.8 45.0 2.6 60.8
Related Cancers a
a Sites include larynx, oral cavity, esophagus, bladder, kidney, other
urinary, and pancreas.
Reference List
[1] U.S. Department of Health and Human Services
(USDHHS), National Cancer Institute. Risks associated with smoking
cigarettes with low machine-measured yields of tar and nicotine.
Bethesda, MD: National Institutes of Health, 2001.
[2] Stratton, K., Shetty, P., Wallace, R., Bondurant,
S., eds. Clearing the smoke: assessing the science base for tobacco
harm reduction. Washington, D.C.: National Academy Press, 2001.
[3] U.S. Department of Health and Human Services
(USDHHS). The health effects of active smoking: A report of the Surgeon
General. 2004. Washington, D.C., U.S. Government Printing Office.
[4] International Agency for Research on Cancer (IARC).
Tobacco smoke and involuntary smoking. IARC monograph 83. 2004. Lyon,
France, International Agency for Research on Cancer.
[5] U.S. Department of Health and Human Services
(USDHHS), Public Health Service, National Cancer Institute (NCI).
Changes in cigarette-related disease risks and their implication for
prevention and control. Burns, D.M., Garfinkel L., Samet, J.M.,
editors. [8]. 1997. Bethesda, Maryland, U.S. Government Printing Office
(NIH Publication No. 97-4213). Smoking and Tobacco Control Monograph.
[6] Thun, M.J., Heath, C.W., Jr. Changes in mortality
from smoking in two American Cancer Society prospective studies since
1959. Prev Med 1997; 26(4):422-426.
[7] Doll, R., Peto, R., Wheatley, K., Gray, R.,
Sutherland, I. Mortality in relation to smoking: 40 years' observations
on male British doctors. Br Med J 1994; 309(6959):901-911.
[8] Doll, R., Peto, R., Boreham, J., Sutherland, I.
Mortality in relation to smoking: 50 years' observations on male
British doctors. Br Med J 2004; 328(7455):1519-1527.
[9] Alberg, A.J., Ford, J.G., Samet, J.M. Epidemiology
of lung cancer: ACCP evidence-based clinical practice guidelines (2nd
edition). Chest 2007; 132(3 Suppl.):29S-55S.
[10] Thun, M.J., Lally, C.A., Flannery, J.T., Calle,
E.E., Flanders, W.D., Heath, C.W., Jr. Cigarette smoking and changes in
the histopathology of lung cancer. J Nat'l Cancer Inst 1997;
89(21):1580-1586.
[11] Coultas, D.B., Stidley, C.A., Samet, J.M. Cigarette
yields of tar and nicotine and markers of exposure to tobacco smoke. Am
Rev Respir Dis 1993; 148(2):435-440.
[12] Djordjevic, M.V., Stellman, S.D., Zang, E. Doses of
nicotine and lung carcinogens delivered to cigarette smokers. J Nat'l
Cancer Inst 2000; 92(2):106-111.
[13] Blackford, A.L., Yang, G., Hernandez-Avila, M.,
Przewozniak, K., Zatonski, W., Figueiredo, V. et al., Cotinine
concentration in smokers from different countries: relationship with
amount smoked and cigarette type. Cancer Epidemiol Biomarkers Prev
2006; 15(10):1799-1804.
[14] Thun, M.J., Day-Lally, C., Myers, D.G., Calle,
E.E., Flanders, W.D., Zhu, B-P et al., Trends in tobacco smoking and
mortality from cigarette use in Cancer Prevention Studies I (1959-1965)
and II (1982-1988). In: Burns, D.M., Garfinkel, L., Samet, J.M.,
editors. Changes in Cigarette Related Disease Risks and Their
Implication for Prevention and Control. Bethesda, Maryland: U.S.
Government Printing Office, 1997: 305-382.
[15] Hoffmann, D., Hoffmann, I., El Bayoumy, K. The less harmful
cigarette: a controversial issue. a tribute to Ernest L. Wynder. Chem
Res Toxicol 2001; 14(7):767-790.
Senator Lautenberg. Thank you very much.
Dr. Henningfield, you're next, please.
STATEMENT OF JACK E. HENNINGFIELD, Ph.D.,
VICE PRESIDENT, RESEARCH AND HEALTH POLICY,
PINNEY ASSOCIATES; PROFESSOR OF BEHAVIORAL BIOLOGY,
ADJUNCT, AND DIRECTOR, INNOVATORS AWARDS PROGRAM,
DEPARTMENT OF PSYCHIATRY AND BEHAVIORAL SCIENCE,
THE JOHNS HOPKINS UNIVERSITY SCHOOL OF MEDICINE
Dr. Henningfield. Senator Lautenberg, thank you for the
opportunity to testify.
For three decades, I have studied drug addiction and
tobacco use at Johns Hopkins Medical School, the National
Institute on Drug Abuse, and Pinney Associates, and I am a
consultant to GlaxoSmithKline on smoking cessation medicines. I
also serve the World Health Organization in its efforts to
evaluate the international equivalent of FTC, which is called
the ISO [International Standards Organization] Cigarette
Testing Method. I provide additional detail in my written
submission.
The FTC cigarette testing method does not provide accurate
information about tar and nicotine exposure to cigarette
smokers. It greatly underestimates inhaled amounts.
Furthermore, the ratings support marketing that undermine our
efforts to prevent young people from starting to smoke and from
motivating smokers to quit. The problem has persisted, in part,
because of the absence of public health-based regulatory
oversight that would have been responsive to the warning signs
over the past two decades or longer.
How did it happen? What is the path toward resolution? Let
me start with the problem and how it was discovered.
I believe Americans trust product content ratings because
our Nation leads the world in setting standards for truthful
ingredient information for foods and drugs. This information
typically communicates the maximum exposure from a product, not
average exposure. When a content or delivery rating of food
product or drug product is found to misrepresent the product,
the established protocols can fix the problem. Every year, FDA
acts on hundreds of products that are misrepresented, or, more
technically, misbranded. It isn't surprising that Americans
believe the FTC rating bears some relationship to health
effects and exposure. Consumers, such as my own sister, do not
believe that the government would allow such a scam to
continue. I am a scientist in this area; I was similarly
deceived in my research efforts.
This figure shows what many of us thought was a major
success story in public health. In the 1960s--from the 1960s to
1980s, the FTC ratings of tar and nicotine plummeted, as rated
by the FTC Method. As intended, consumers flocked to cigarettes
with lower ratings. Even scientists like me thought we could
take advantage of what appeared to be a broad range of nicotine
dosing systems for biological research. And then we had a hard
time interpreting our results, because a lot of it didn't make
sense if we were really manipulating nicotine dose to the
proportion that we thought.
But the warning bells were sounded by human studies in the
1980s, by NIDA and other NIH research. In 1983, Dr. Neal
Benowitz published one of the seminal studies. His studies
showed that light cigarettes did not deliver less nicotine. In
fact, as shown by the solid line in this figure, actual
nicotine exposure was not related to FTC ratings. The dotted
line shows what scientists had expected and what companies
advertised and what consumers wanted: lower levels of exposure
from cigarettes with the lower ratings. This problem was
confirmed by FDA and acknowledged by FTC in the 1990s. In 2001,
National Cancer Institute Monograph 13 came to the most
devastating conclusion of all, that there is no health benefit
to cigarettes with low FTC ratings.
How did it happen? FTC's intentions were good, and it is
not unreasonable that they expected the rating system would
help smokers reduce their tar and nicotine. FTC did not
anticipate the extent to which tobacco industry would go to
design cigarettes to undermine the tests and render the rating
system meaningless. Also under-appreciated at the time was the
power of the addictive process that motivated smokers--to more
intensively smoke cigarettes, a process that we refer to as
compensatory smoking.
The cigarette designs that you've already heard mentioned
that circumvented the method were elaborate, but several are
easily pointed out. This shows the ventilation holes which
smokers cannot see on most cigarettes. They're not covered by
the machines, but smokers can easily cover them with fingers
and lips. There are many other design features that enable
smokers to get addictive doses of nicotine, even if it means
higher levels of tar, from virtually any cigarette on the
market.
There is no simple fix that we could provide to FTC; in
part, because cigarette designs continue to evolve. But, there
is a path toward resolution, and that is to charge FDA to set
standards for cigarette testing and labeling, and oversee the
validity of the testing, as proposed in current legislation.
FDA is the world authority in measuring dosing capacity and
exposures produced by a broad range of products, including
ever-changing drug delivery systems. For FDA, the scientific
challenge is well understood. It has the capacity to not only
fix the problem for currently marketed cigarettes, but also to
prevent such a colossal and long-lasting deception to consumers
from ever occurring again.
Thank you for the opportunity. I'll be pleased to do
whatever I can to help.
[The prepared statement of Dr. Henningfield follows:]
Prepared Statement of Jack E. Henningfield, Ph.D., Vice President,
Research and Health Policy, Pinney Associates; Professor of Behavioral
Biology, Adjunct, and Director, Innovators Awards Program, Department
of Psychiatry and Behavioral Science, The Johns Hopkins University
School of Medicine
Mr. Chairman, Senator Lautenberg, and other members of the
subcommittee, thank you for the opportunity to testify. For three
decades, I have studied drug addiction and tobacco use at Johns Hopkins
Medical School, the National Institute on Drug Abuse, and Pinney
Associates. I serve on the World Health Organization Study Group on
Tobacco Product Regulation and advise its Tobacco Laboratory Network
and the Conference of Parties guiding implementation of the Framework
Convention (``Treaty'') on Tobacco Control on the measurement and
communication of tobacco product contents and emissions. Through Pinney
Associates I consult to GlaxoSmithKline on smoking cessation
medications; I have a financial interest in a smoking cessation
medicine that is under development; and, I have testified on these
topics in litigation brought against the tobacco industry by the U.S.
Department of Justice and other plaintiffs.
My work is also supported by the Robert Wood Johnson Foundation
Innovators Awards Program at The Johns Hopkins University School of
Medicine. I speak on my own behalf and am not representing any of these
organizations in my testimony today.
My testimony is focused on the problems with the FTC Method and the
science base for its elucidation and resolution.
The FTC Cigarette Testing Method does not provide accurate
information about tar and nicotine exposure to cigarette smokers and,
in fact, greatly underestimates the inhaled amounts. Furthermore, the
ratings support marketing that undermines our efforts to prevent young
people from starting to smoke and to motivate smokers to quit.
This problem has persisted in part because of the absence of public
health-based regulatory oversight that would have been responsive to
warning signs over the past two decades. How did it happen? What is the
path toward resolution? I will start with the problem and how it was
discovered.
The Problem
I believe Americans trust product content ratings because our
Nation leads the world in setting standards for truthful ingredient
information for foods and drugs. This information typically
communicates maximum exposure from a product. When content or delivery
ratings are found to misrepresent the product, established protocols
can fix the problem. Every year, FDA acts on hundreds of products that
are misrepresented or more technically--``misbranded''. It isn't
surprising that Americans believe the FTC rating bears some
relationship to health effects and exposure. Consumers, such as my own
sister, do not believe the government would allow a scam like this to
go on.
This figure shows what many of us thought was a major success story
in public health: the 1960s to 1980s plummeting of tar and nicotine
levels in cigarettes as rated by the FTC Method (figure modified from
Hoffman and Hoffman, 1994). As intended, consumers flocked to
cigarettes with lower ratings. Even scientists like me thought we could
take advantage of what appeared to be the broad range of nicotine
dosing systems for biological research. Of course, we knew the ratings
did not precisely predict exposure but we expected that the ratings
were meaningfully related to human exposure.
The warning bells sounded in the 1980s by NIH researchers. In 1983,
Dr. Neal Benowitz and his colleagues (1983) published one of the
seminal studies. His study showed that light cigarettes did not deliver
less nicotine. This figure (estimated from plasma cotinine levels)
shows that nicotine exposure is directly related to number of
cigarettes smoked.
The second figure from the Benowitz study revealed the problem. The
dotted line shows what scientists had expected based on FTC testing:
namely that there would be lower levels of exposure from cigarettes
with lower ratings. However, the solid line reveals that actual
exposure was not related to FTC rating.
Unfortunately, consumers not only reasonably believe that their
exposure to tar and nicotine will be less from cigarettes with lower
FTC Method deliveries, they believe that health risks of cigarettes are
lower in proportion to tar and nicotine reductions. For example,
Kozlowski and Pillitteri (2001) reported the results of a national
telephone survey which showed that for many cigarette smokers an
important factor in smoking light cigarettes was the belief that they
could reduce the risks of smoking without having to quit. They also
cited previously secret tobacco industry documents which revealed that
this was the intent of the industry in their design and marketing
approach that enabled them to ``reassure smokers, to keep them in the
franchise as long as possible.'' Responses to survey questions about
the number of light cigarettes that would need to be smoked to get the
same amount of tar as from a regular cigarette indicated that about 90
percent of the respondents held ``mistaken beliefs regarding the
distinctions between machine based yields of tar and actual tar
intake.''
These consumer misperceptions were further explored by Cummings and
colleagues (2004) in a telephone survey of cigarette smokers. They
found that only 12 percent of smokers correctly understood that you
could get as much tar from a single light cigarette as from a regular
cigarette, and a third or more smokers believed that high tar
cigarettes were twice as likely to cause disease as low tar cigarettes.
A further complication in the accuracy and potential misapplication
of FTC Method testing is that as meaningless as the results are for
widely marketed ``conventional'' cigarettes, FTC has never even
developed testing protocols for modified cigarettes and novel cigarette
substitutes that are under development and in early stages of
marketing. For example, Shiffman and colleagues (2003) found that one
cigarette substitute, marketed with tar and claims based on the tobacco
companies own modification of the FTC Method has led to serious
misperceptions among smokers such as one in four believing that Eclipse
is a completely safe alternative to conventional cigarettes, with
highest levels of interest in people who had been contemplating
quitting smoking. Even more startling was that 15 percent of young
adults who had quit smoking for at least 2 years were interested in
using Eclipse. There are many other modified tobacco products in
various stages of marketing and development, as described by Hatsukami
and colleagues (2004, 2005), and these pose emerging problems of even
greater complexity to testing and communications than conventional
cigarettes.
These problems were confirmed by FDA and acknowledged by FTC in the
1990s. In 2001, National Cancer Institute Monograph 13 came to the most
devastating conclusion of all: there is no health benefit to cigarettes
marketed as ``light'' and ``low tar''.
How Did it Happen?
FTC's intentions were good and it was probably not unreasonable for
the agency to expect that the rating system would help smokers reduce
their tar and nicotine exposures as advocated by the Surgeon General,
and would provide incentives for companies to develop lower-yielding
cigarettes (Wilkenfeld et al., 2000). FTC did not anticipate the extent
to which the tobacco industry would go to design cigarettes to
undermine the test and render the rating system meaningless with
respect to actual intake and health effects. Also under-appreciated at
the time was the power of the addictive process that motivated
cigarette smokers to more intensively smoke cigarettes that delivered
lower yields per puff (``compensatory smoking'').
The cigarette designs that circumvented the method were elaborate,
but several are easily pointed out. Vent holes dilute the smoke in FTC
machines, but do not do so when covered by the fingers and lips of
smokers. There are many other tricks employed in the deception and
these include the use of various chemicals to alter burning properties
and nicotine delivery as well as other physical design features that
are discussed in National Cancer Institute Monographs 7 and 13. For
example, the machine stops smoking 3 mm before reaching the overwrap
connecting the filter to the tobacco column and so does not test all
the tobacco. Not surprising, this overwrap became larger when FTC
testing started. Accelerant chemicals are added so that the cigarette
would burn faster and, therefore, the relatively slow-puffing machines
would measure lower tar and nicotine. The mix of design features used
to cheat the FTC test method varies across cigarettes and appear to be
continuing to evolve. Until the testing is in place under authority of
an agency with the experience to evaluate drug and toxin delivery and
empowered to demand information about the designs and their
consequences, scientists and consumers alike will remain in the dark
with respect actual deliveries and associated health effects.
The recent and emerging problems with respect to emerging
generations of modified cigarette products, such as those involving
carbon heating systems, electronic ignition, and novel filtration, is
occurring because there is presently no regulatory oversight mechanism
in place with expertise to develop and validate new testing methods. In
the vacuum, the tobacco companies are adopting their own variations on
the existing FTC Method.
Path Towards Resolution
There is no simple fix that we could provide to FTC, in part,
because, cigarette designs continue to evolve. But there is a path
toward resolution and that is to charge FDA to set standards for
cigarette testing and labeling and oversee the validity of the testing,
as proposed in current legislation intended to give FDA authority over
tobacco products.
FDA is the world authority in measuring dosing capacity and
exposures produced by a broad range of products, including ever-
changing drug delivery systems. It would be capable of developing and
validating accurate methods for testing and communicating the results
for current cigarette products as well as for the emerging generations
of modified cigarettes and cigarette substitutes. For FDA, this
scientific challenge is well understood. It has the capacity to not
only fix the problem with respect to currently marketed cigarettes but
also to prevent such a colossal and long-lasting deception of consumers
and impediment to public health from ever occurring again.
Supporting References
Benowitz, N.L., Hall, S.M., Herning, R.I, Jacob, P., Jones, R.T.,
Osman, A.L. Smokers of low-yield cigarettes do not consume less
nicotine. New England Journal of Medicine, 300:139-142, 1983.
Cummings, K.M., Hyland, A., Giovino, G.A., Hastrup, J.L., Bauer,
J.E., Bansal, M.A. Are smokers adequately informed about the health
risks of smoking and medicinal nicotine? Nicotine and Tobacco Research,
6:S333-S340, 2004.
Hatsukami, D.K., Henningfield, J.E., Kotlyar, M. Harm reduction
approaches to reducing tobacco-related mortality. Annual Review of
Public Health, 25:377-395, 2004.
Hatsukami, D.K., Hecht, S. Hope or hazard: what research tells us
about potentially reduced exposure tobacco products. University of
Minnesota Transdisciplinary Tobacco Use Research Center, Minneapolis,
2005.
Kozlowski, L.T., Pillitteri, J.L. Beliefs about ``light'' and
``ultra light'' cigarettes and efforts to change those beliefs: an
overview of early efforts and published research. Tobacco Control,
10:i12-i16, 2001.
Shiffman, S., Pillitteri, J.L., Burton, S.L., Di Marino, M.E.
Smoker and ex-smoker reactions to cigarettes claiming reduce risk.
Tobacco Control, 13:78-84, 2003.
Hoffman, D., Hoffman, I. The changing cigarette, 1950-1995. Journal
of Toxicology and Environmental Health, 50-307-364, 1997.
National Cancer Institute, Smoking and Tobacco Control Monograph
No. 13. Risks associated with smoking cigarettes with low-machine
measured yields of tar and nicotine. National Institutes of Health, NIH
Pub. No. 02-5074, 2001.
National Cancer Institute, Smoking and Tobacco Control Monograph
No. 7. The FTC Cigarette Test Method for Determining Tar, Nicotine, and
Carbon Monoxide Yields of U.S. Cigarettes, Report of the NCI Expert
Committee, National Institutes of Health, NIH Publication No. 96-4028,
1996.
Wilkenfeld, J., Henningfield, J., Slade, J., Burns, D., Pinney, J.
It's time for a change: Cigarette smokers deserve meaningful
information about their cigarettes. Journal of the National Cancer
Institute, 92(2):90-92, 2000.
Wilkenfeld, J., Henningfield, J., Slade, J., Burns, D., Pinney, J.
Response to FTC's Response to: It's time for a change: Cigarette
smokers deserve meaningful information about their cigarettes. Journal
of the National Cancer Institute, 92(10):842-843, 2000.
Senator Lautenberg. Thank you very much.
Dr. Goldberg?
STATEMENT OF MARVIN E. GOLDBERG, Ph.D., IRVING & IRENE BARD
PROFESSOR OF MARKETING, SMEAL COLLEGE OF BUSINESS, PENN STATE
UNIVERSITY
Dr. Goldberg. Thank you, Senator Lautenberg, I'm pleased to
be here to testify.
My consideration is that of advertising and promotion. From
the 1950s, when filter tips were introduced, until 2006, the
tobacco industry has spent roughly $235 billion, in 2006
dollars, on advertising and promotion for cigarettes. That's
over $10 million a day. In the last year, 2005, that we have
data for, over $13.5 billion were spent. That's over $37
million every day for that year.
What do you get, or what does the tobacco industry get, for
that? It gets imagery, over the decades, that is pounded into
our, and especially youth's, heads, of vital, energetic,
attractive people smoking what seems to be a pretty neutral
product. The images of death and disease are far removed. It
also buys, more latterly, tremendous positioning in the stores;
in particular, convenience stores, where 60 percent of all
cigarettes are sold. Not coincidentally--for 90 percent of the
cigarette smokers that start before they're 18 years--not
coincidentally, teenagers spend twice as much time in
convenience stores, hanging out, as adults do. It buys
positioning, it buys very significant advertising as the
displays--colorful displays represent. The teenagers talk about
what they see, and convince one another. The industry then
says, ``It's not us, it's the kids talking about it and
convincing each other.'' That's what we call, today, ``viral
marketing.'' The virus is introduced--by the industry, however.
It's the heavy, targeted advertising. And then the viral
introducer says, ``I'm not part of this. It's kids influencing
kids.'' Well, viral marketing--viral marketers understand that
process.
From 1967 to 1998, when we have the data from the FTC, if
you look at the percentage of advertising that was allocated by
the companies to light cigarettes--advertising for light
cigarettes--and compare that to the sales for light
cigarettes--what percentage did they represent?--we see that
this was push marketing. It's not that the consumer sat out
there and said, ``I want this product,'' it was pushed upon
them. For example, in 1979, less than 30 percent of sales
revenues to the tobacco industry came from light cigarettes,
but almost 50 percent of their advertising dollars went to
advertising of light cigarettes; 50 versus less than 30. They
pushed this on the market.
The main motivation that people have for smoking, as we've
heard before, light cigarettes is the health issue. The tobacco
industry recognizes that through their internal documents. When
we have done studies on this, people look to less tar, less
nicotine, less risk. About four out of five smokers say they
smoke light cigarettes because of health reasons.
We tried to develop a radio message, and when we developed
it, we talked to focus groups to set up the actual script. We
couldn't get people to believe that one light cigarette equaled
one regular cigarette. We had to use a small white lie in our
script. We said something like, ``Smoking a light cigarette is
sort of like jumping off the 15th story of a building instead
of the 20th story of the building.'' That little white lie,
they could kind of buy. Today, people believe you need to smoke
two or three light cigarettes to get the equivalent of a
regular cigarette.
The tobacco industry does something much better than tell
you the cigarettes are healthier, they use a kind of
syllogistic reasoning, ``Tar is unhealthy, we know that. Light
cigarettes have less tar. Ergo, light cigarettes are
healthier.'' The tobacco industry knows, as lawyers know, when
you get the person you're trying to persuade to draw the
conclusion themselves, you've done a better job at persuading.
They've persuaded themselves that it must be true.
Today, the R.J. Reynolds website reads, ``An individual's
level of risk for serious disease is significantly affected by
the type of tobacco product used.'' In other words, you can
smoke a light cigarette, and you'll still be OK. What does
Philip Morris say? ``There's no safe cigarette.'' If you think
carefully about that, it means, logically, there can be a
``safer'' cigarette.
I'll stop here.
Thank you.
[The prepared statement of Dr. Goldberg follows:]
Prepared Statement of Marvin E. Goldberg, Ph.D., Irving & Irene Bard
Professor of Marketing, Smeal College of Business, Penn State
University
The development of the market for light cigarettes was not driven
by consumer demand or ``pull,'' but rather ``pushed'' by the tobacco
firms' heavy marketing and promotion outlays and enabled by the
deceptive messages regarding light cigarettes' ostensible health
benefits.
Smokers did not naturally gravitate to the experience of smoking
low tar cigarettes. This was not a ``pull'' marketing phenomenon, where
consumer demand drove sales, but rather a ``push'' phenomenon that was
developed and shaped by the industry as a function of its deceptive
claims for light cigarettes. Advertising and promotion for the light
category drove the process with campaigns that continue to make the
case through imagery and otherwise that smokers of light cigarettes are
attractive, healthy and vigorous people engaging in attractive vigorous
activities; (illness and disease are far removed from these scenes).
From the 1950s (when the focus was on filters that ostensibly
reduced tar levels) until 2006, the industry spent an estimated $235
billion (in 2006 dollars) on advertising and promotion for cigarettes;
(data drawn from Federal Trade Commission; FTC 2007; figures for years
prior to 1970, 1971 through 1974, and 2006 are estimates). In 2005, the
last year for which figures are available, the industry spent over
$13.5 billion--about $37 million per day--on advertising and promoting
cigarettes; (FTC 2007).
The figure below illustrates: (1) the trend with regard to the
percentage of the tobacco industry's advertising and promotion dollars
that were allocated annually to light cigarettes from 1967 to 1998 the
years that the FTC reported this data in their annual report on
cigarettes (FTC 2000) and (2) the annual percentage of total cigarette
sales represented by light cigarettes. As may be noted, ``Light''
cigarettes (defined as less than 15 mg. tar) came to dominate both
categories.
Also evident in the figure below--until the 1990s, the percentage
of dollars allocated to advertising and promotion for the light
cigarette category exceeded their share of market. In effect, the
industry was investing in and driving the growth of this category.
Ultimately, by the 1990s, given a ``ceiling effect'' (there is only so
high that both percentages could realistically go) the two sets of
percentages became more closely aligned.
As a parallel part of their advertising and promotion strategies,
the tobacco industry has shaped ``viral marketing'' campaigns to ensure
the success and popularity of light cigarettes.
The tobacco industry has long understood how advertising and
interpersonal influence combine to influence the individual smoker or
potential smoker. The process starts with the intense advertising and
promotion on the part of the industry. In the second step in this
process, the message conveyed in the advertising is relayed by
individuals as part of the ``bandwagon'' effect. This process has
recently been labeled ``virus or viral'' marketing.
. . . [T]he future belongs to marketers who establish a
foundation and process where interested people can market to
each other. Ignite consumer networks and then get out of the
way and let them talk;'' (Godin 2001, p.15; emphasis in the
original).
Advertising and promotion serve to initiate discussion by both
``opinion leaders'' and their ``followers'' who touch base with one
another to assess the merits of what they have seen/heard. In this
``multi-step flow'' of information those around us can and do influence
us, but this influence comes as a consequence of the advertising and
promotion to which we are exposed (Assael 2004). While an industry like
the tobacco industry can try and point to the interpersonal influence
process (people influencing people) it cannot absolve itself of the
ultimate responsibility for the popularity, sales and consumption of
the products they promote. As shown in the figure above, the tobacco
industry chose to ``push market'' light cigarettes by investing heavily
in advertising and promotion to ensure the growth of this segment. With
the dollars they spent, together with the promise of reduced health
risks, they succeeded in gaining the smoking public's attention for
lights--and their purchase dollars. The ``bandwagon'' proved to be
unstoppable, with the light cigarette category steadily increasing its
share of market to the point where it currently accounts for the vast
proportion of sales.
In sum, it is important to recognize that this process, where a
particular brand or a particular product category (such as lights)
gains popularity as a function of person-to-person influence does not
stand by itself. It is not an independent and competing source of
influence, but properly understood as an integral part of the tobacco
industry's global marketing process--their efforts to saturate society
with misleading messages about cigarettes. By ``igniting consumer
networks'' among peers, and co-opting the dynamics of person-to-person
influence for their own commercial purposes, the companies need not be
concerned with whether any particular person saw or was exposed to any
particular advertisement. The tobacco companies understand that their
massive marketing campaigns are akin to a ``virus'' where ``. . . the
advertiser creates an environment in which the idea can replicate and
spread. It's the virus that does the work, not the marketer'' (Godin
2001; p. 26). In this way, the tobacco industry's advertising and
promotion efforts are causally linked to smokers' and potential
smokers' actions and choices.
Internal corporate documents make it clear that the tobacco
companies have long known that the health issue has been the main
motivation for smokers to switch to lower tar/light brands.
Consider the statements below from internal documents of Brown and
Williamson, Philip Morris, R.J. Reynolds and Lorillard:
Those who smoked their current brand for less than a year
switched for health purposes--to reduce the tar and nicotine
level instead of quitting (Brown & Williamson 1977).
The largest group of all [brand switchers are] those who are
convinced that smoking is dangerous to their health and who are
torn between a conscience that urges them to quit and a
hedonistic desire to continue to do something they enjoy.
The very fact, then, that a smoker has decided to switch from a
full-flavor cigarette to a low-delivery cigarette tells us
something very important about him: he is concerned about his
health, and he is willing to do something about it; (Philip
Morris 1978).
As low-yield brands become more popular among adults . . .
modeling behavior may lead adolescents to smoke them as well.
Furthermore, such brands may become considered ``safer'', thus
leading teenagers to pay less attention to public health
campaigns designed to discourage initiation; (R.J. Reynolds
1980).
Most smokers . . . do not really understand what tar and
nicotine are, or the difference between the two. ``Tar and
nicotine'' is a term commonly used as a single word. . . .
Those who smoke low tar and nicotine cigarettes generally do so
because they believe such cigarettes are ``better for you''--
there is less tar and nicotine to do long-term damage;
(Lorillard 1976).
Research has confirmed the conclusions drawn by tobacco industry
executives as cited above: the factor leading smokers to low tar/lights
is that they believe these cigarettes are `` `better for you.' ''
Research has documented the salience of health factors in guiding
smokers who switch to light cigarettes. Below I discuss two relevant
studies in which I was second author: Kozlowski et al., (1998) and
Kozlowski et al., (1999). Kozlowski et al (1998) reported on the
following question posed to those who smoked light cigarettes: ``I'm
going to ask you about reasons some people might give for smoking Light
. . . cigarettes. For each one please tell me whether it is one of your
reasons for smoking Light . . . cigarettes'' Five options were then
read to the respondent: one of the options, taste, was discussed above;
the remaining four involved ways that smokers of lights might believe
that their cigarette held a health-related benefit: ``step to
quitting,'' ``less risk,'' ``less tar,'' ``less nicotine.'' When the
last three of the listed risk factors (``less risk,'' ``less tar,''
``less nicotine,'') were analyzed together, only 24 percent of the
respondents failed to select at least one of these three options; in
other words 76 percent answered affirmatively to at least one of the
health-related benefits (as reported on p. 13). If one adds to this
those who only selected the ``step to quitting,'' the percentage would
no doubt climb beyond 80 percent; (while many, if not most smokers, are
motivated to quit by health concerns, the ``quitting'' response was not
part of this health-related benefits analysis).
The same logic applies to the second of the studies I worked on
with Kozlowski. (Kozlowski et al., 1999). Smokers of light cigarettes
were asked to indicate which of four reasons they had for smoking
lights; (they could select more than one of the reasons). While a
separate analysis was not conducted, with 52 percent citing ``reduce
tar/nicotine'' and 35 percent and 38 percent citing ``step toward
quitting'' and ``reduce risk'' respectively, the percentage citing at
least one of these factors would likely climb to 80 percent and beyond.
(``Taste,'' the fourth reason is discussed fully below).
First hand evidence also documents how successful Philip Morris and
the rest of the tobacco industry have been in persuading smokers of low
tar/light cigarettes are healthier.
It should be noted that the actual purpose of the Kozlowski et al.
(1999) study was to develop and assess the effectiveness of a ``radio''
message informing smokers about the true risk associated with smoking
light cigarettes. In the formative steps leading to the development of
the ``radio'' message, earlier drafts of the script were presented to
focus groups consisting of smokers. These drafts tried to argue that
there was ``no difference'' between light and regular cigarettes of
light cigarettes. While the final version still took this approach, the
smokers' reluctance to accept this argument led to the added statement
that if there was any difference, it was a meaningless one; (smoking
light cigarettes instead of regulars is ``Kind of like jumping off a
15-story building instead of a 20-story building''). This is evidence
of how successful tobacco marketers have been in convincing smokers
that there is a health benefit associated with lights; stating that
there was no difference in the risks associated with smoking lights
versus regulars was so contrary to the views expressed in the focus
groups, we had to ``bend'' the truth so as to ultimately be able to
persuade smokers of light cigarettes.
The tobacco industry has pointed to ostensibly conflicting data,
arguing that these data demonstrate that smokers don't believe low tar/
light cigarettes are healthier and they choose lights for reasons other
than health concerns.
The industry has pointed to ostensibly conflicting data, arguing
that these data demonstrate that smokers choose lights for reasons
other than health concerns; for example, a 1975 survey by the U.S.
Department of Health, Education & Welfare found that 40.6 percent of
current smokers believed that all cigarettes are probably about equally
dangerous.'' In 1975, the share of market for light cigarettes (below
15 mg tar) was under 10 percent. As a result, the vast proportion of
those defined as smokers in this survey would have been smokers of
regular cigarettes. It is not at all surprising that smokers of regular
cigarettes would attempt to justify their own smoking choice, thereby
reducing the psychological discomfort/dissonance that would result from
acknowledging that their choice (regulars) might be ``wrong'' and more
harmful.
Further explaining this phenomenon was the fact that when first
introduced, Light cigarettes were considered relatively tasteless. As
acknowledged by the tobacco industry as recently as April 21, 2005
(transcript of Trial Record, United States of America, Department of
Justice, Plaintiff v. Philip Morris USA et al., Defendants) when low-
tar cigarettes were introduced, the tobacco companies recognized that
their taste was aversive--it was hardly seen as selling point for the
light cigarette category.
It took a long time for low-tar cigarettes to ever really catch
on in this country. . . . [The industry believed that] these
products will taste different, and unless the public health
community gives, gives people a reason to smoke them [i.e.,
``it's better for your health''], I don't think they're going
to be successful; (p. 19670).
As such, they did not represent much of an alternative for smokers
of regular cigarettes, despite the fact that held out the (false) hope
of a ``safer'' cigarette; (as discussed below, this problem was
eventually ``fixed'' with the advent of lights that yielded
considerably more tar). Without shifting to lights as a way of reducing
their cognitive dissonance, smokers of regular cigarettes had to take a
different path to reduce their dissonance; to do so they developed
``protective'' attitudes. If one can't change one's behavior and there
are clearly negative aspects of that behavior, then changing one's
attitudes toward the behavior in question is typically how one attempts
to reduce the dissonance (Festinger 1957; Cohen and Kassarjian 1965).
Given this psychological dynamic, it is not surprising that 40.6
percent responded that that ``all cigarettes are about equally
dangerous.'' Unwilling to shift to the tasteless lights, yet
uncomfortable in the belief that lights were in some way ``better/
safer,'' it is somewhat surprising that the 40.6 percent figure was not
still higher. Evidently, the ``message'' of light cigarettes' supposed
health benefits was hard to ignore, for many of these regular smokers,
notwithstanding the cognitive dissonance it generated.
More recently, a study by Schiffman et al., (2001) sampled over
2,120 smokers in a national telephone survey. Of these, 816 were
smokers of light cigarettes. Fully 80 percent of the respondents
believed that one had to smoke 2, 3 or more light cigarettes in order
to get the same levels of tar delivery as in a regular cigarette. Since
tar is typically regarded as a health-risk, 4 of 5 consumers conclude
that the less of it, as in a light cigarette, the safer the cigarette.
The evidence I present below strongly disputes that mistaken view.
As part of their extensive advertising and promotion campaign for
more than a half-century, the tobacco industry have promoted a type of
syllogistic reasoning that encourages smokers of light/low tar
cigarettes to believe they are at less risk.
For over half a century, smokers have been led to believe that a
cigarette that tastes ``milder'' and is ``less irritating'' must be
better for them. As one example, 67 percent agree that ``lights are
smoother on the throat and chest.'' Since smokers cannot know from
simply examining a cigarette whether it is healthier than others or
not, they need to rely on what they believe is indirect evidence
(proxies); smooth and mild serve as such proxies. The syllogism goes:
if mildness means less throat irritation, and less throat irritation
means--in some way--a healthier cigarette, then mild, light cigarettes
must be better for health.
Similarly, if lights are said to have less tar/nicotine, and if it
is understood that tar/nicotine have negative health consequences, the
smoker is led syllogistically to the conclusion that Lights must be
better for health; (less of the ``bad stuff''). The senior tobacco
executives have engaged in these syllogisms and they believed their
customers did as well. Consider the following responses by senior
tobacco industry executives:
Q. In terms of tar delivery, is there a health benefit between
a twelve milligram cigarette and an eight milligram cigarette?
A. My position is that less is better than more. I believe that
if a person smokes a cigarette and receives 8 milligrams of
tar, that is better than smoking a cigarette and receiving 12
milligrams of tar.
Written Direct testimony of Susan Ivey, CEO of R.J. Reynolds,
United States v. Philip Morris, 2005 (82:12-20).
My understanding is I think, pretty common that . . . low tar
is better than high tar . . . there have been characteristics
associated with tar that are believed to be linked to health
issues, and lower tar is better than higher tar.
Deposition of Ronald Bernstein, CEO of Liggett group, (in
United States v. Philip Morris, 2002 (35:4-36:9; emphasis
added).
If something is--is identified as--as being potentially
harmful, having less of it would seemingly be better.
Deposition of Ronald Bernstein in United States v. Philip
Morris, 2002 (25:19-26:5).
Q. Don't you think that many people wanted low tar cigarettes
because they were led to believe that low tar cigarettes were
less dangerous to their health than high tar cigarettes?
A. That may be a perception among some smokers . . . less is
best in all kinds of products, product categories.
Donald Johnston, former CEO of American Tobacco in Broin v.
Philip Morris, 1994 (62:4-13).
Importantly, in this type of syllogistic reasoning, where the
conclusion is self-generated, consumers effectively persuade themselves
and this process generates more favorable, stronger, more actionable
brand attitudes--attitudes that translate into actual purchase
decisions. Consumers are more likely to remember the message and have
greater confidence in the brand attitude they have developed. These
brand attitudes are likely to be more resistant to counter-persuasion
(Kardes 1999; Heimbach and Jacoby 1972; Moore et al., 1986). In sum,
this indirect, syllogistic approach, is more persuasive relative to
directly putting forth the (false) conclusion that ``low tar/nicotine
cigarettes are healthier for you.'' As expressed in a report prepared
for Brown and Williamson: ``. . . the [advertising] copy should be
ambiguous enough to allow the reader to fill-in his/her illogical-logic
. . .'' (Marketing and Research Counselors, Inc. 1975, pp. 12-13).
Internal tobacco company documents further indicate that while the
Barclay brand may have done a better job in allowing for smoker
``compensation'' than its competitors, the others in the industry also
developed cigarettes that allowed for compensation; (Kozlowski 2005).
As internal documents reveal, the tobacco industry recognized that
it would be by allowing actual tar yields to increase that the
cigarettes would come closer to tasting like regular cigarettes, and so
gain in popularity. One way in which this was done was through ``micro-
vents'' found on the filters of most cigarettes. Research has
documented that most smokers are not aware of the micro-vents or of
their effects. The micro-vents are inadvertently (or sometimes
intentionally) covered/blocked by the fingers/lips of smokers. This
blocking has the effect of reducing the ventilation and increasing the
levels of tar and nicotine the smoker receives. In a national survey,
two-thirds (66 percent) of smokers of light cigarettes were either
unaware of the vents or did not understand that vent blocking increased
their exposure to tar.
A carefully documented example of this type of compensation was the
development of the cigarette ``Barclay'' and the reaction to it (
Kozlowski et al., 2005). In the design of the cigarette, not just the
manufacturer of Barclay, but competitors as well, considered the
compensation principle. In the Philip Morris documents cited below, the
company acknowledged the compensation/tar/flavor link and also
indicated that they sought to replicate the process.
Product smokes differently in smoker's mouth than in dental dam
of smoking machine. Smoker's lips close channels (grooves)
between tipping paper and filter lowering dilution and
resulting in higher tar delivery; Meyer L.F. (1980; Philip
Morris document).
This filter design results in some unusual delivery
characteristics when smoked by a human that do not occur during
machine smoking. . . . The dilution decrease to the [human]
smoker results in substantially higher tar delivery than would
be the case of a conventionally diluted all CA [cellulose
acetate] filter . . . Subjective impressions by flavor
development have corroborated the higher tar estimates . . .
filter process development to either duplicate or simulate the
Barclay effect is in progress. Houck W.G. (1980; Philip Morris
Document; emphasis added).
The tobacco industry sought to take advantage of the multiple ways
in which smokers' compensation alters the real tar yields for smokers
as compared to machine-generated tar yields.
Consider the following statements in internal corporate documents
from R.J. Reynolds, Lorillard and Philip Morris:
. . . [S]ome people change their smoking habits and attempt to
compensate for lower `tar' and nicotine deliveries, for
example, by taking larger puffs, more puffs, or smoking more
cigarettes; R.J. Reynolds 1978.
. . .[S]mokers tend to deviate more from the standard (of the
FTC machine test] . . . with highly ventilated, low [tar/
nicotine] yield brands. These kind of cigarettes generally . .
. make it easy to expend some extra puffing effort; Lorillard
1981.
The smoker data collected in this study are in agreement with
results found in other project studies. The panelists smoked
the cigarettes according to physical properties; i.e., the
dilution and the lower RTD of Marlboro Lights caused the
smokers to take larger puffs on that cigarette than on Marlboro
85's. The larger puffs, in turn, increased the delivery of
Marlboro Lights proportionally. In effect, the Marlboro 85
smokers in this study did not achieve any reduction in smoke
intake by smoking a cigarette (Marlboro Lights) normally
considered low in delivery; (Philip Morris 1975).
Promoting light cigarettes as extensions of major brands and
aligning them with the mother brand (e.g., Marlboros, Marlboro Lights),
helped shaped smokers' perceptions of their taste.
At the same time as they developed light cigarettes that allowed
for compensation, the tobacco companies learned how to boost the
perceived strength of the taste, by using their advertising to shape
the images associated with Lights. The companies viewed the taste
dimension much as a ``Rorschach ink blot test.'' Light cigarette
smokers could be induced to see/taste in the cigarettes what the
companies wanted them to see/taste.
. . . [I]t is almost impossible to know if the taste smokers
talk about is something which they, themselves attribute to a
cigarette or just a ``play-back'' of some advertising
messages;'' (Marketing and Research Counselors, Inc, 1975, p.
2).
The industry further understood that they could ``borrow'' some of
the brand equity established for their primary (regular) brands such as
Marlboro Reds ad Camels for the benefit of the light cigarettes. They
did so by creating brand extensions--Marlboro Lights, Camel Lights etc.
and using the same advertising themes and imagery that had been so
successful to shape the imagery associated with the light extensions.
That this strategy could affect smokers perceptions of the light
cigarettes taste, is recognized in their internal documents.
. . . [O]ther free standing low tar brands such as Kent,
Vantage, Carlton, etc. were perceived to be weaker and have
less taste than the line extension low tars: like Marlboro
Lights, Winston Lights, Camel Lights. Apparently these line
extension low tars share the taste heritage of their parent
full flavor brands; (Philip Morris 1990, pp. 13-14; emphasis
added).
When R.J. Reynolds sought to develop a low yield cigarette in 1976,
they recognized the image problem associated with low-yield cigarettes
and set out to address it:
What we want is to portray the feeling and image projected by
Marlboro and Kool advertising on a Vantage/Merit type of
cigarette. In other words, put ``balls'' (two of them) on a low
``tar'' and nicotine cigarette and position; Hind et al., 1976,
p. 63.
The tobacco industry has acknowledged that the taste of regular
cigarettes hardly serves as a positive benchmark.
One needs to question whether the ``standard'' for taste set by
regular cigarettes is such that the taste of regular cigarettes is a
positive feature? Are regular cigarettes inherently ``tasty?'' Internal
documents indicate that the tobacco companies believed that the initial
taste for (typically underage) starter smokers was aversive and sought
to take measures to compensate for this. As early as 1959, a Philip
Morris document focused on ``mildness'' as a strategy for attracting
young starters: ``we also should win more young non-smokers with
mildness;'' (memo from W.H. Danker to R. N. DuPuis May 28, 1959). With
nearly nine in ten smokers starting before age 18 and more than half of
these smoking regularly by 18 (Lynch and Bonnie 1994; USDHHS 1994), it
is clear that ``young non-smokers'' was referring to those under 18.
In 1974, R.J. Reynolds considered flavored cigarettes as a way of
masking the tobacco taste. A meeting at the R.J. Reynolds offices
resulted in a memo titled ``New Products.'' Under the authorship of J.
Donati of Taitham-Laird & Rudner, an R.J. Reynolds advertising agency,
the memo served to define a ``Cigarette Designed for Beginning
Smokers.''
This cigarette would be low in irritation and possibly contain
an added flavor to make it easier for those who have never
smoked to acquire the taste for it more quickly; (J. Donati
(1974; emphasis added)).
After considering flavors including ``citrus, apple, grape, herbs
and spices, cola, coffee, chocolate and hickory'' the options for
further work were narrowed to cola, coffee and chocolate. Today R.J.
Reynolds markets flavors like ``Mocha Taboo'' and ``Midnight Berry''
through its ``Kool'' brand. This strategy would suggest that the
company believes that the taste of tobacco is best when masked.
The tobacco industry has advanced the ``taste'' of low tar/lights
cigarettes as the primary reason they are chosen by smokers. When
questioned about the role of this false and illusory dimension of low
tar/light smokers' responses are often misleading.
When smokers are asked why they smoke light cigarettes, significant
numbers may respond that it is because of the ``taste.'' This is
understandable--they first experience the cigarette on their tongue and
in their mouth--the most apparent locus of taste. But research tells us
that ``taste'' is a good deal more than what we experience on our
tongue. Twenty years ago, the Coca Cola company was concerned about
losing market share among young cola drinkers to Pepsi Cola. Research
suggested that younger consumers appeared to prefer the slightly
sweeter taste of Pepsi. In response, Coca Cola developed a sweeter
version of their product and proceeded to extensively test market it in
blind taste tests across the country. Repeatedly and reliably in blind
taste tests, consumers indicated that they preferred the sweeter
version to the regular Coke. With that evidence in hand, Coke
introduced ``New Coke'' with the new, sweeter formula. What happened
next was shocking to Coke. Once the product they were drinking was
labeled Coke, that knowledge impacted how they evaluated what they
tasted--now they hated it. Within 3 months Coke had retreated and was
pushing its original formula ``Classic'' Coke again (Fournier 1999;
rev. 2001).
That taste is, at least in part, a function of how products are
portrayed/labeled and advertised has been carefully researched in the
context of ``field'' experiments with foods. In one such experiment,
the same lunch meals were sold in a university faculty cafeteria but
were labeled differently on different days. For example, on some days
one such meal was identified as ``Succulent Italian Seafood filet'' but
on other days merely as ``Seafood Filet.'' Those who bought and ate the
foods when they were described in an embellished way reported that: the
foods were more appealing to the eye; they tasted significantly better;
and after eating the meal they food felt more ``comfortably full and
satisfied;'' (Wansink et al., 2004).
Interestingly, when desserts were labeled ``healthy'' (e.g.,
``chocolate pudding vs. ``healthy chocolate pudding; apple crisp vs.
healthy apple crisp). they were rated as tastier. The researchers
reasoned, that as long as the dessert actually tasted good, consumers'
initially lower expectations regarding something labeled ``healthy''
would be disconfirmed; that is, they would have been surprised by the
good taste. Pleasantly surprised, the unexpected contrast between their
actual and expected experience would have led them to evaluate the
taste of the dessert more positively than someone who had seen the
dessert label without the adjective ``healthy;'' (Wansink et al.,
2004b).
Smokers of regular cigarettes who switched to what they perceived
to be ``healthier,'' light cigarettes, would have had a parallel
disconfirming experience. These smokers would have expected light
cigarettes to yield less taste (along with less tar). However, given
the compensatory smoking behavior described above, light cigarettes
yielded just as much tar/taste. As a result, the pleasantly surprised
light cigarette smokers were quick to focus on the taste as the
apparent motivation for smoking lights.
As with the food experiments cited above, if questioned, smokers
are almost certainly not going to be aware of how the label ``light''
(and hence the inference ``healthier'') influence their perceptions of
the cigarette's taste. They revert to the more proximal evidence--what
they believe they experience--on their tongues--and their answer as to
why they smoke the cigarette they do smoke may reflect that logic.
In two court cases where both Philip Morris and R.J. Reynolds sued
Loews/ Lorillard, it was evident that these tobacco companies
do not believe that smokers are primarily guided by taste in
selecting light cigarettes.
The plaintiff firms, Philip Morris and R.J. Reynolds argued that in
a comparative taste test, smokers reported that the Lorillard low tar
brand tasted better than the comparison brand only if they were first
told that Lorillard's brand had lower tar than either the R.J. Reynolds
or the Philip Morris comparison brand. When (other) smokers made the
same comparative taste test without being reminded of the relative tar
levels, their taste preferences were very different.
The basis of both suits was the approach taken in two parallel
Lorillard surveys asking smokers to compare the taste of its low tar
``Triumph'' to R.J. Reynolds' Winston Lights and to Philip Morris'
Merit. Subsequent Lorillard advertising claimed that the preponderance
of the smokers tested appeared to prefer the taste of Triumph over
Winston Lights and that it was the ``National Taste Test Winner'' over
Merit. Both plaintiffs Philip Morris and R.J. Reynolds argued that
these claims were deceptive inasmuch as the taste question posed in
each survey had, as a preface, a reminder of the lower tar scores for
Triumph relative to those for Winston Light and for Merit. Each of the
plaintiff companies ran a test of their own, where the tar scores for
the two brands were not revealed and the resulting taste preferences in
their research were very different.
These comparisons suggest how much of what is ostensibly labeled as
``taste'' is influenced by other factors; in this case, the salience of
how ``light''/low tar a cigarette might be. In effect, the plaintiff
firms acknowledge that where smokers are reminded of tar yields, the
relative tar levels and not taste are the determining factors in the
smokers' evaluations of the cigarettes; (R.J. Reynolds Tobacco Company,
Plaintiff, v. Loew's Theatres, Inc; No. 80 Civ 4197 (RWS) United States
District Court for the Southern District of New York; 511 F. Supp. 867;
1980 U.S. Dist. LEXIS 16738; 210 U.S.P.Q. (BNA) 291; October 24, 1980;
Philip Morris Incorporated, Plaintiff, v. Loew's Theatres, Inc., No. 80
Civ. 4082 (RWS) United States District Court for the Southern District
of New York; 511 F. Supp. 855; 1980 U.S. Dist. LEXIS 12554 July 26,
1980).
Of course, for decades the tobacco companies have used low tar/
lightness as a critical way of selling cigarettes and have made that
dimension very salient for smokers. Following the logic presented
above, it is reasonable to expect that when respondents are asked, they
may say that ``taste'' is the reason they prefer light/low tar
cigarettes. Note, however, that following the logic of the two court
cases discussed above, the causal sequence is, in fact, reversed. In
actuality, it is because their cigarettes are light (and advertising
and promotion continue to make that dimension salient) that smokers say
they prefer the taste. They would not say so for the same cigarette, if
its ``lightness'' was not made salient.
The tobacco industry has misleadingly used lighter colors (whites and
pastels) on the cigarette packages and in their advertising to
persuade smokers that low tar/light cigarettes were purer and
healthier.
Because consumers often cannot directly judge the merits of a
product claim, they develop heuristics or ``rules of thumb'' which
involve relying on ``proxies'' for the real evidence they are seeking.
For example, consider how difficult it is to judge how ``fresh'' fish
in a supermarket is. Supermarket executives have come to realize that
for some consumers, fish sitting on a styrofoam tray represents a proxy
conveying ``not fresh,'' while fish sitting on ice represents a proxy
conveying ``fresh.''
It is for the same reason that the tobacco industry has signaled
the lighter, milder and ostensibly purer and safer features of light
cigarettes, by using lighter colors in their advertising and on their
packaging. Tobacco firms have been consistent and strategic in
developing this tactic. Consider the following statements (as cited in
the National Cancer Institute's Monograph 13, p. 217) by Philip Morris
and the British American Tobacco Co. respectively:
. . . [W]hen Marlboro Lights was first introduced in 1971 . . .
the advertising was dramatically different . . . first using
water color executions, then big pack sots, a lot of white
space and a small cowboy visual. (Philip Morris 1990, p. 6).
Light-lighter-lightest were achieved by insistance [sic] on
lighter presentations-product story imagery--white packs--pale
colours--mildness dominated copy. (British American Tobacco
Company, circa 1985, p. 13).
A number of other examples of this strategy are cited in Chapter 7
of Monograph 13, including the Philip Morris, Parliament campaign where
models were consistently dressed in all white and placed in all white
environments (National Cancer Instititute; Monograph 13, p. 218). As
Koten (1980; cited in Monograph 13 on p. 218) concludes:
Red packs connote strong flavor, green packs connote coolness
or menthol and white packs suggest that a cigarette [sic] is
low-tar. White means sanitary and safe. And if you put a low-
tar cigarette [sic] in a red package, people say it tastes
stronger than the same cigarette [sic] packaged in white.
(Koten, 1980, p. 22).
More broadly, to ask people to provide reasons for their behavior;
i.e., why they do what they do is to ask them to play the role of
social scientist in explaining their behavior; research has shown that
is a very risky endeavor. People develop ``theories'' as to why they
behave as they do and use both these theories and the most proximal
evidence in support of these theories, to explain their behavior.
Sometimes these theories and evidence are accurate, but very often they
are not. One reason they are often incorrect is that people tend to use
evidence that is proximal and are less alert/sensitive to more subtle,
complex and distal causes of their behavior (Nisbett and Ross 1980).
Thus when asked about the taste of the dessert, those in the cafeteria
focus on their taste buds and are not likely to be sensitive to the
influence of the ``healthy'' label placed on the dessert on the
cafeteria line and on the resulting effect of their positive reaction.
When asked about why they smoke light cigarettes, smokers focus on the
proximate evidence--their taste buds; they are much less aware of how
the label ``light'' subtly influences their attitudes and behaviors, as
well as their compensatory smoking behavior (as described above).
Still today, the industry is not forthcoming about the risks of
smoking light cigarettes.
It is only recently that R.J. Reynolds has come to curtly
acknowledge that ``Smoking causes serious disease'' (R.J. Reynolds
website; accessed Aug. 26, 2007). However, the website goes on to
provide the (would be) smoker with considerable ``wiggle room'' to
justify (continued) smoking:
An individual's level of risk for serious disease is
significantly affected by the type of tobacco product used as
well as the manner and ``frequency of use;'' (R.J. Reynolds
website; accessed August 26, 2007).
In effect, smokers are still encouraged to search for a safer
``type of tobacco product''--most typically a ``light'' one.
Alternatively, they are encouraged to alter their ``manner of . . .
use.'' The latter suggestion runs directly contrary (as discussed
below) to the widely accepted ``compensation'' smoking behavior which
smokers of light cigarettes use.
The Philip Morris website is more expansive in ostensibly accepting
the public health position regarding the risks of smoking any
cigarette:
Philip Morris USA agrees with the overwhelming medical and
scientific consensus that cigarette smoking causes lung cancer,
heart disease, emphysema and other serious diseases in smokers.
Smokers are far more likely to develop serious diseases, like
lung cancer, than non-smokers. There is no safe cigarette. . .
. Philip Morris USA agrees with the overwhelming medical and
scientific consensus that cigarette smoking is addictive. It
can be very difficult to quit smoking, but this should not
deter smokers who want to quit from trying to do so; (emphasis
added) Philip Morris website, accessed August 26, 2007).
To reduce the health effects of smoking, the best thing to do
is to quit; public health authorities do not endorse either
smoking fewer cigarettes or switching to lower tar and nicotine
brands as a satisfactory way of reducing risk. (Philip Morris
USA website, accessed August 26, 2007).
While Philip Morris gives voice to the public health community's
view that lower tar and nicotine (light) brands do not reduce the risk
of smoking, the company is careful not to endorse that view. Further,
as has been noted (Kozlowski 2005), to say there is ``no safe
cigarette'' still allows the smoker to take false comfort in the
mistaken belief that light cigarettes may be ``safer.''
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Senator Lautenberg. Thank you very much.
Dr. Goldberg, your testimony reflects what I think is the
most obvious, and I asked in a couple of earlier questions, and
I thank you.
Mr. Sheller?
STATEMENT OF STEPHEN A. SHELLER, ESQ., FOUNDER
AND MANAGING PARTNER, SHELLER, P.C.
Mr. Sheller. Yes. Thank you, Senator Lautenberg.
And I'm sort of sad and angry at the FTC; I'll be frank
with you. You know, I've practiced law for more than 40 years,
and I'm here to tell you about the effects of the FTC's failure
to do its job. And I want to just bring to your attention two
Federal judges who have reviewed this.
One Federal judge once phrased it this way, ``The tobacco
industry may be the king of concealment and disinformation.''
And Judge Kessler, in--Gladys Kessler--in U.S. v. Philip
Morris, declared the Philip Morris companies to be racketeers.
Racketeers. That's a quote. She said, ``Even as they engaged in
a campaign to market and promote filtered and low-tar
cigarettes as less harmful than conventional ones, defendants
either lacked evidence to substantiate their claims or knew
them to be false.'' She goes on to say, ``There is an
overwhelming consensus in the public health and scientific
community, both here and abroad, that low-tar cigarettes offer
no health benefit to smokers, have not reduced the risk of lung
cancer and heart disease, and, for smokers using them, have not
produced any decrease in the incidence of lung cancer.
Moreover, because of the misleading nature of the advertising
for low-tar cigarettes, smokers who might have quit have
refrained from doing so, in the belief that such cigarettes
reduce their health risk.'' She didn't just make that up, she
heard the evidence for months; for months.
Now, what has happened in litigation? You know, I've been
practicing law for some 40 years now. And, Senator Lautenberg,
you recall, back in early 1998, your aide, Dan Katz, tried to
do something about this. And I sent you the evidence I had
personally collected from the depositions I had done that
established, even within the company, they believed it to be a
fraud; even within the companies.
Now, what has happened today? I'll tell you what's happened
today. We have 40 lawsuits that have been filed involving the
light-cigarette scam in class actions in 22 different states.
There are certified--meaning they're grouped together--class
actions pending in Massachusetts, Missouri, and New York.
However, the industry has used the FTC's--and I'll call it
``clear misconduct''--they are like--either it's intentional or
they are like--what's that famous children's nursery rhyme? I
think it was called--I forget her name now--Rip Van Winkle. Rip
Van Winkle. In fact, I would have hoped that the Director of
the FTC would have been the one to testify, because I was going
to call her Mrs. Rip Van Winkle. They have had the audacity to
come before you today and told you they knew about this for
years, but they don't want to do anything about it. The reason
they don't want to do anything about it, I'll tell you, because
the tobacco industry is using this vehicle of their laziness
and incompetence, on the level of a Katrina or worse,
government incompetence, to give them a defense. They go into
court and say, ``Well, the FTC has been regulating us for
years.'' In fact, there was an even an FTC witness--his name
escapes me for the moment, but I think it was Peter--Dr.
Peterman--John Peterman--worked for the FTC from 1976 to 1993.
He came in to court rooms--and I was involved, as you know, in
the Illinois $10 billion verdict. Again, a judge found them
guilty of all kinds of terrible things. That got reversed by
the Supreme Court of Illinois, based on the FTC's supposed
regulation of the industry.
Now, they come here today with the purpose of telling you,
``We're going to do something someday, but we want to see what
else is better.'' The time--the buck has stopped. You must
issue a--legislation--because they won't do anything--you must
immediately legislate a ban on tar and nicotine levels being
monitored, period. They're--the tobacco industry, by the way,
has machines which are called ``human mimic smoking machines.''
They know what the real numbers could be. But I add something
to you today. All tar is not equal. There are different tars
coming out of those cigarettes; depends on the burn level. I
know the chemistry quite well, I've learned it over the years.
The other element of it is--that is very, very important--is,
they have gone into court and used these guys as their defense.
It's a disgrace. It shouldn't be accepted.
So, I ask you to move quickly and listen to what two
judges--Federal judges--have already said. One called them the
worst example--the king of disinformation. Another called them
racketeers. What else do you need? And the FTC sits there? I
think it's time that you really began to take action.
Thank you.
[The prepared statement of Mr. Sheller follows:]
Prepared Statement of Stephen A. Sheller, Esq., Founder
and Managing Partner, Sheller, P.C.
Good afternoon. I have practiced law for more than 40 years. In
that time, I have initiated many lawsuits involving medical
malpractice, toxic torts, medical device and drug product and complex
catastrophic personal injuries. For the past 13 years, I have also
dedicated a substantial portion of my practice to litigation involving
the cigarette companies. While, as one Federal judge once phrased it,
``the tobacco industry may be the king of concealment and
disinformation,'' \1\ the so-called light cigarette fraud is the most
shameless example of outright fraud by this industry I have yet to
encounter.
---------------------------------------------------------------------------
\1\ Haines v. Liggett Group, Inc., 140 F.R.D. 681 (D.N.J. 1992).
The judge was H. Lee Sarokin.
---------------------------------------------------------------------------
I have researched industry practices around light cigarettes and
have worked with a number of attorneys around the country to file
consumer fraud class actions against the cigarette manufacturers that
seek compensation for customers who bought these cigarettes that were
sold and marketed as ``light,'' but were, in fact, not really lower in
tar or nicotine and certainly were not any less hazardous than so-
called ``full flavor'' brands. This is accomplished by designing the
cigarette to create misleading readings on puff machines using a
technique for measuring tar and nicotine known as the FTC Method.
The principal allegation in light cigarette lawsuits is that
cigarette manufacturers have misled consumers by marketing light and
low tar cigarettes as having less tar and nicotine than other brands,
even though the actual exposure levels are no different. Those who
smoked (and continue to smoke) light cigarettes, reasonably believing
they were being exposed to less tar or nicotine, are seeking court-
ordered damages for their losses. I believe that there have been about
40 lawsuits filed in 22 different states on the light cigarette issue.
Certified class actions are pending in Massachusetts, Missouri, and New
York at this time.
In fact, there is good reason to believe so called, ``light,
smooth, mild'' cigarettes are potentially more dangerous to ones health
than ``full flavor'' cigarettes.
An important key to uncovering the light cigarette fraud was
Monograph 13 released by the National Cancer Institute in 2001.\2\ That
monograph concludes that ``cigarette manufacturers recognized the
inherent deception of advertising that offered cigarettes as light
[and] . . . as having the lowest tar and nicotine yields . . .'' but
went ahead anyway with that advertising. Shortly after the release of
the monograph, it was announced that the FTC asked for guidance from
DHHS to determine whether the FTC testing method could be improved and
a working group was to convene in 2002, but I am unaware of any
outcomes from this request for guidance.\3\ The FTC appears to have
gone to sleep as Rip Van Winkle did in the famous children's story and
clearly needs Congress to wake them up.
---------------------------------------------------------------------------
\2\ Nat'l Cancer Inst., Risks Associated with Smoking Cigarettes
with Low Machine-Measured Yields of Tar and Nicotine, Smoking and
Tobacco Control Monograph 13, Nat'l Inst. of Health (Donald Shopland,
David Burns, et al., eds., 2001).
\3\ See NCI's ``Questions and Answers on Monograph 13'' at Question
7, viewed at http://www.cancer.gov/newscenter/monograph13-QA/
print?page=&keyword=.
---------------------------------------------------------------------------
What has been happening in these lawsuits is that the cigarette
companies have been using the lack of clarity around regulation of
testing accuracy and the regulatory role of the FTC in two distinct and
important ways:
1. The cigarette companies claim that the use of the terms
``light'' and ``lowered tar and nicotine'' are regulated by the
FTC and, therefore, state consumer protection laws' exemption
for federally regulated products defeats our state law claims
of fraud. In the only light cigarette class action to go to
trial, a verdict against Philip Morris for around $10 billion
dollars was reversed by the Illinois Supreme Court in a 4-3
decision.
That Court relied largely on a 1971 Consent Order with American
Tobacco Company over the marketing campaign for the Pall Mall
Gold 100's and Lucky Filters that required American tobacco to
print tar and nicotine comparisons with other brands for
advertising that claimed these 2 brands of cigarettes were low,
lower, or reduced in tar than other brands. This one consent
order dealing with one company's ad campaign hardly constitutes
FTC adoption of a trade regulation or even a regulatory
approach to the use of the terms ``light'' and ``lowered tar
and nicotine'' which are at the heart of the light cigarette
fraud. Nonetheless, this argument is being raised repeatedly by
cigarette industry defendants in ongoing litigation.
2. The cigarette companies have, until this summer, removed
light cigarette class action lawsuits from state to Federal
courts under the ruse that the companies are acting as agents
under a Federal officer and are, therefore, entitled to a
Federal court venue under the Federal Officer Removal
Statute.\4\ This argument, while absurd on its face, was
successful in several cases and created expense, delay, and,
most importantly, the assumption that the companies were simply
following the regulatory requirements set down by the FTC
around their products and should be immune to any claims of
fraud. Ultimately, this argument was defeated by the U.S.
Supreme Court on June 11 of this year in a unanimous decision
\5\ that echoed the conclusion of the Solicitor General that
the FTC has not asserted control over the marketing of light
cigarettes.
---------------------------------------------------------------------------
\4\ U.S.C. sec. 1442(a)(1).
\5\ Watson, et al., v. Philip Morris Companies, Inc., 551 U.S.__The
(2007).
---------------------------------------------------------------------------
Court Remedies
The courts in many jurisdictions either refuse to certify a class,
or reverse the certification of a class in the appellate courts,
thereby sanctifying the tobacco industry's misconduct and allowing them
to continue this misconduct as we sit here. A solution is to consider
legislation requiring that these cases be handled and certified as
class actions, to encourage attorneys to take on what would ordinarily
be a lawsuit on behalf of one individual with a very small damage
claim. The tobacco industry knows that if a lawsuit cannot go forward
as a class this will be the death knell of consumer claims. In
addition, any money not claimed by consumers that is paid as part of a
class action award by the tobacco industry, should be contributed to a
cy pres fund.
This enormous fraud on the American people must stop. Federal
legislation is needed to protect consumers from the cigarette
industry's practices with their ``light'' brands and defrauded
consumers should have the right to be compensated for their loss. I
think that U.S. District Judge Gladys Kessler got it right when she
ruled last year that the cigarette companies were racketeers in U.S. v.
Philip Morris. About the light cigarette fraud, she said:
``Even as they engaged in a campaign to market and promote
filtered and low tar cigarettes as less harmful than
conventional ones, Defendants either lacked evidence to
substantiate their claims or knew them to be false''.\6\
---------------------------------------------------------------------------
\6\ United States v. Philip Morris USA, Inc., 449 F. Supp. 2d 1
(D.D.C. 2006) at 430.
---------------------------------------------------------------------------
She goes on to say:
``There is an overwhelming consensus in the public health and
scientific community, both here and abroad, that low tar
cigarettes offer no health benefit to smokers, have not reduced
the risk of lung cancer and heart disease for smokers using
them, and have not produced any decrease in the incidence of
lung cancer. Moreover, because of the misleading nature of the
advertising for low tar cigarettes, smokers who might have quit
have refrained from doing so in the belief that such cigarettes
reduced their health risks''.
Thank you for taking up this important issue.
Senator Lautenberg. Thank you very much. The--I admire the
candor that shows up here. And I don't want to show any bias;
that's not Senator-like.
[Laughter.]
Senator Lautenberg. But I also don't like the fact that
somehow or other, over 400,000 people a year die of smoking-
related disease. And so, when I think about the anguish and the
grief that occurs and the impact on people's ability to
function as they live, as a result of having had a career in
smoking, I'll call it, and then the cost for their
unhealthiness is distributed among the population and runs
close to $89 billion a year for that. It's a terrible thing to
witness.
Dr. Samet, I think you said that switching to light/low-tar
cigarettes doesn't cause fewer--well, let me not put words in
your mouth. Does switching to light and low-tar cigarettes
actually cause fewer people to quit smoking?
Dr. Samet. So, the concern is, the--does the availability
of products that are perceived as carrying a lower risk lead to
switching? And I think that has been demonstrated to be the
case for some proportion of smokers. The concern is that people
might move to a lower-yield product instead of doing what they
should do, which is to quit. And there is some evidence to
suggest that that can be the case.
Senator Lautenberg. I think I noted, in some information,
that people who had actually quit smoking for some time had
come back to smoking, based on the attraction that low-tar
offered, at least in advertising. Do we have any information,
any of you, of that happening?
Dr. Henningfield. People are constantly coming back to
smoking, for a lot of reasons. The information that we do have
is that, when there are surveys, such as national telephone-
based surveys, asking people what would attract them to smoking
or coming back to smoking, what is attractive to people are
cigarettes that appear to be safer. And this has been very
scary, from a public health perspective, because when someone
has quit, they're on the road to health, and it's terrible, the
idea that they might be lured back to smoking, thinking that
the products are substantially safer or flat-out safe.
Senator Lautenberg. Remind us, how long have the tobacco
companies been aware of the smoker compensation, the period of
time when smokers take longer, deeper puffs to compensate for
lower amounts of nicotine?
Dr. Henningfield. A number of us have looked at the
documents. I testified in the Department of Justice trial. And,
since at least the 1970s, if not decades before, the companies
understood that these cigarettes delivered more than
advertised.
Mr. Sheller. It's----
Senator Lautenberg. Mr. Sheller, do you have----
Mr. Sheller. Yes. Actually, it was before the consent
decree in 1970 that they were so happy to--no decree--voluntary
agreement to use this deceitful trick. They were well aware of
it, and they just decided, ``Oh, it would be great,'' as it's
now another way that they've avoided responsibility.
But you have the documents, actually, which were given in
1986--as the discovery we did. We--you know, they knew all
about it. It's in evidence. And time has--as I said, it's no
longer the FTC's turn. They've fumbled the ball. You know, your
committee has to have oversight of them. They had the audacity
to come in here today and tell you, ``We've--we may do
something soon, when we get--we're not expert in it, we don't
know what we're doing. We need help from this one and that
one.'' That's been their story for years. Put an end to it,
please.
Senator Lautenberg. In earlier testimony regarding smoking
and its cost, we found out that the awareness of the tobacco
companies about the lethality of the product they were selling
and the addiction went back to the--I believe it was the middle
1930s when that information first was made available.
Mr. Sheller. Yes.
Senator Lautenberg. And, Dr. Henningfield, when switching
to light cigarettes, are those smokers conscious of the fact
that they're breathing deeper, that they're working harder to
fulfill the need they feel to get the nicotine in their
systems?
Dr. Henningfield. Actually, to the contrary, a lot of
people believe that they are actually inhaling something less
toxic, because it is smoother and cooler. In other words, the
cigarette, which may be as deadly or more deadly, actually
feels smoother and cooler by using chemicals like menthol, by
using ventilation to cool the smoke. It's like putting a lot of
alcohol in a fruit beverage. And so people are deceived in many
different ways; and then, with the marketing, of course.
Mr. Sheller. Yes, I've called it strawberry syrup on
strychnine. Poison.
Senator Lautenberg. It sounds mild, in your description.
Dr. Goldberg. We actually have data that two-thirds of
smokers either don't know about the microvents or don't know
that they contribute to the amount of tar that they get.
Senator Lautenberg. Why are cigarettes allowed to use the
word ``light'' without having any light benefit? Isn't that
simply deceiving consumers while the government looks the other
way, Dr. Henningfield?
Dr. Henningfield. Well, I think it reflects the problem--I
think that cigarette regulation by the Federal Trade Commission
is not their area of competence. I do not believe that the
problem was intentional. But this sort of regulation is bread
and butter to agencies, like the Food and Drug Administration,
which set standards for light products. And if you look at the
food rule from the early 1990s, you see specific criteria for
use of the term ``light.'' You see them saying, ``you can't use
the term `ultra light,' because it's not meaningful.'' Then
there are specific standards. Most of the cigarette companies
sell other products, or the major ones do, they sell Kraft
cheese, for example, that is ``light.'' That cheese has to meet
certain standards that are objective.
Senator Lautenberg. The--my folks were able to dig out some
packs of cigarettes I--I don't know whether you're--all of you
are aware, but we were able to persuade the--Rules Committee to
ban the sale of cigarettes throughout the Capitol. And it's
just taking place. And, if anything, it seemed kind of
backward. Here we are, preaching the gospel, and downstairs
they're selling the tools for addiction. And so, we are--that--
as of, I think, it's the first of the year, that they will no
longer be available. There are sales now--and I'm not
advertising--of cigarettes at lower prices to clear out the
inventory.
But all of these facts--and I don't mean to pick up out any
of them--but the reference is, ``Surgeon General's Warning:
Cigarette smoke contains carbon monoxide.'' Now, wouldn't you
think that would scare the devil out of those people who are
buying cigarettes? Carbon monoxide? Say you can get that from
your car if you--well, if you want to end--we have different
packages. This one is--they give it a number on this package--
this is called Camel number 9. It is a beautiful package, but
carrying almost a lethal message. Here, they're more specific,
``Surgeon General's Warning: Smoking causes lung cancer, heart
disease, emphysema, and may complicate pregnancies.'' This one
really--Mr. Sheller, you managed to, I think, get some
justifiable anger about what we see, but here's this ad. It
says, ``Camels, light and luscious.'' Now----
Mr. Sheller. You should see what they mail my daughter at
home. I have a daughter who's at Temple University, finishing
up this year as--becoming a special-ed teacher. And, because
she's over 21, somehow or other they found her. She doesn't
smoke, but we get things in the mail--I've been saving them--
that are mind-boggling from the cigarette companies.
Senator Lautenberg. Well, we're--we've learned a lot, but
we haven't yet learned enough. And I'm hoping that we can use
the knowledge that we've gained here today, with your help, to
really do something about this.
Dr. Goldberg. Senator, if I could, in response--when you
say things like, ``There are awful things like carbon
monoxide,'' et cetera, we often think of this dispassionate
person to whom the message is addressed. And, as you've said,
this is--you know, there is a wonderful study that shows, when
you show a Harvard/Yale football game, way back in the 1950s,
to Harvard and Yale people, they each tell you that the other
side was terrible, in terms of the penalties and infractions.
They're committed to a particular perspective. Well, smokers
are, too. They're very committed. They're addicted. And so,
we're not talking about a reasonable person dispassionately
considering the information.
Senator Lautenberg. How about--we all remember when a
doctor was advertised as preferring one cigarette to another.
Mr. Sheller. Oh, yes. With a white coat.
Senator Lautenberg. I thank you all for your testimony.
We're going to adjourn this hearing.
And I note, Mr. Sheller, that your admonition that Congress
should act swiftly----
Mr. Sheller. Yes.
Senator Lautenberg.--to stop allowing companies to make
light and low-tar claims based on the FTC Method, we'll look at
that very closely.
Mr. Sheller. Thank you----
Senator Lautenberg. With that----
Mr. Sheller.--Senator Lautenberg.
Senator Lautenberg.--this hearing is adjourned. And, once
again, thank you all.
[Whereupon, at 3:59 p.m., the hearing was adjourned.]
A P P E N D I X
Prepared Statement of Hon. Pamela Jones Harbour, Commissioner, Federal
Trade Commission
Today, the Commission approves testimony to be presented on
November 13, 2007 before the Senate Committee on Commerce, Science, and
Transportation concerning the Federal Trade Commission's Tar and
Nicotine Rating System. I concur in the decision to present testimony
providing an overview of the FTC's responsibilities and activities in
the area of tobacco advertising and a discussion of cigarette testing
and the promotion of cigarettes based on machine-measured tar and
nicotine yields. I also concur in the Commission's recommendation that
Congress consider giving authority over cigarette testing to one of the
Federal Government's science-based public health agencies.
However, I would also recommend that steps be taken to prohibit the
use of any claims based on the Cambridge Filter Method--also known as
``FTC Method''--for testing tar and nicotine. See the attached May 10,
2007 letter to the Hon. Frank R. Lautenberg. The tobacco industry has
known for decades that the FTC Method does not accurately measure the
amount of tar and nicotine a person consumes from a cigarette.
Prohibiting the use of claims based on the FTC Method would remove the
FTC's apparent imprimatur from cigarette labels and ads.
______
Federal Trade Commission
Washington, DC, May 10, 2007
Hon. Frank R. Lautenberg,
U.S. Senate,
Washington, DC.
Dear Senator Lautenberg:
I send this letter to express my support for S. 625, the Family
Smoking Prevention and Tobacco Control Act.\1\ The bill creates a
reasonable framework to oversee the manufacture, sale, advertising, and
marketing of tobacco products. Notably, the bill includes several key
consumer protection measures.
---------------------------------------------------------------------------
\1\ This letter reflects my own views. It does not purport to
represent the views of the Commission or any other Commissioner.
---------------------------------------------------------------------------
First, the bill allows the Food and Drug Administration to regulate
tobacco products. This is a critical starting point. The FDA has lacked
adequate authority in this area for decades, and tobacco manufacturers
have exploited the void. The bill authorizes FDA scientists to track,
analyze, and regulate the components of tobacco products. At last, the
FDA will have more effective tools to protect the public's health.
Second, the bill properly assigns--to manufacturers themselves--the
burden of substantiating ``modified risk'' claims, such as ``light,''
``low tar.'' and ``reduced exposure.'' Consumers' choices are
influenced by these claims. If a manufacturer says that its tobacco
product poses a reduced risk, the manufacturer should be required to
substantiate the claim with competent evidence that can be evaluated by
scientists. This bill will compel manufacturers of tobacco products to
provide scientific data, which will enable scientists to scrutinize
modified-risk claims and determine whether the claims can be made
responsibly.
The bill gives the FDA authority to establish new testing
procedures and disclosures about tar and nicotine. However, an
additional provision is needed to ensure that consumers receive
accurate information about tar and nicotine levels. Thus, the bill
should prohibit the use of any claims based on the so-called ``FTC
Method.'' Such a provision would be similar to the prohibition in your
bill, S. 3872. The tobacco industry has known for decades that the FTC
Method does not accurately measure the amount of tar and nicotine a
person consumes from a cigarette. Since 1999, the FTC has publicly
stated its concerns about the Method's accuracy. It distresses me that
a small number of cigarette manufacturers still invoke the name of the
FTC when claiming low tar and nicotine content. By prohibiting the use
of claims based on the FTC Method, the bill would remove the FTC's
apparent imprimatur from cigarette labels and ads.
Third, the bill appropriately preserves coordination between the
FTC and the FDA in enforcing labeling and marketing requirements,
particularly as they relate to children. This kind of enforcement is a
core element of the FTC' s consumer protection mission. The bill wisely
preserves the FTC's jurisdiction over unfair or deceptive cigarette
advertising. I am especially pleased that advertising in violation of
the proposed Act also will be deemed a violation of a rule promulgated
under Section 18 of the FTC Act. Civil penalty authority is an
important tool in the FTC's enforcement arsenal. By enabling the FTC to
seek civil penalties immediately when a violation of the proposed Act
is found, the Act will further enhance the agency's authority to stop
misleading and youth-oriented advertising.
I thank you for your leadership in sponsoring the bipartisan Family
Smoking Prevention and Tobacco Control Act. The regulation of the
manufacture, sale, advertising, and marketing of tobacco products is a
tall order, but it is crucial for the health of our country,
particularly its young people. I hope that action on the bill will
advance the dialogue and push Federal health agencies to step up to the
plate on this issue.
Please contact me if I may provide any assistance to you as the
bill moves forward.
Sincerely,
Pamela Jones Harbour,
Commissioner.
______
American Journal of Public Health--December 2006, Vol. 96, No. 12
Effect of Televised, Tobacco Company-Funded Smoking Prevention
Advertising on Youth Smoking-Related Beliefs, Intentions, and Behavior
by Melanie Wakefield, Ph.D., Yvonne Terry-McElrath, M.S.A, Sherry
Emery, Ph.D., Henry Saffer, Ph.D., Frank J. Chaloupka, Ph.D., Glen
Szczypka, B.A., Brian Flay, Ph.D., Patrick M. O'Malley, Ph.D., Lloyd D.
Johnston, Ph.D.
Objective. To relate exposure to televised youth smoking prevention
advertising to youths' smoking beliefs, intentions, and behaviors.
Methods. We obtained commercial television ratings data from 75
U.S. media markets, and to determine the average youth exposure to
tobacco company youth-targeted and parent-targeted smoking prevention
advertising. We merged these data with nationally representative
school-based survey data (n = 103,172) gathered from 1999 to 2002.
Multivariate regression models controlled for individual, geographic,
and tobacco policy factors, and other televised antitobacco
advertising.
Results. There was little relation between exposure to tobacco
company-sponsored, youth-targeted advertising and youth smoking
outcomes. Among youths in grades 10 and 12, during the 4 months leading
up to survey administration, each additional viewing of a tobacco
company parent-targeted advertisement was, on average, associated with
lower perceived harm of smoking (odds ratio [OR] = 0.93; confidence
interval [CI] = 0.88, 0.98), stronger approval of smoking (OR = 1.11;
CI = 1.03, 1.20), stronger intentions to smoke in the future (OR =
1.12; CI = .04, 1.21), and greater likelihood of having smoked in the
past 30 days (OR = 1.12; CI = .04, 1.19).
Conclusions. Exposure to tobacco company youth-targeted smoking
prevention advertising generally had no beneficial outcomes for youths.
Exposure to tobacco company parent-targeted advertising may have
harmful effects on youth, especially among youths in grades 10 and 12.
(Am J Public Health. 2006; 96: 2154-2160.. doi:10.2105/
AJPH.2005.083352)
The tobacco industry has actively attempted to remake its public
image in response to evidence that it marketed products to youth and
misled the public about smoking health risks.\1\ \2\ This effort has
included public education campaigns to communicate that youths should
not smoke.\3\ In December 1998, Philip Morris launched a national $100
million television campaign the company described as targeted to youths
aged 10-14 years.\4\ The primary message was that youths do not need to
smoke to fit in socially with their peers, and the campaign delivers
the slogan ``Think. Don't Smoke.'' Although this campaign ended on U.S.
television in January 2003, the ads continue to be broadcast in other
countries.\5\ In October 1999, and with a budget of around $13
million,\6\ Lorillard Tobacco Company also launched a U.S.-televised
youth smoking prevention campaign with the slogan, ``Tobacco is Whacko
if You're a Teen.'' \4\
In mid-July 1999, Philip Morris launched a campaign that emphasized
parental responsibility for talking to children about smoking; the
slogan was ``Talk. They'll Listen.'' \7\ This parent-focused youth
smoking prevention campaign has featured a variety of television ads
and continues today. The overt message of these ads is that parents
should talk to their children about not smoking.
Few studies have examined the potential affect of youth-focused
tobacco company-sponsored advertising. Of those, most have only
assessed immediate appraisals of the advertisements by youths,\8\ \9\
\10\ or the relation between ads and attitudes thought to be predictive
of smoking behavior change,\11\ rather than smoking behavior itself. No
studies have examined the effects of tobacco company parent-focused
advertising on youth. Because advertising that may influence youth
smoking has also been broadcast at various times and intensities by
tobacco control programs,\12\ it is a complicated matter to establish
the relative influence of tobacco company-sponsored advertising.
The objective of this study was to assess the relation between
exposure to tobacco company youth smoking prevention advertising and
youth smoking-related beliefs, intentions, and behavior in a
representative sample of American secondary school students. The study
includes youth-targeted and parent-targeted advertising. The study
sample included the primary target age group of the youth-targeted ads
(grade 8, mean age 14 years), as well as older youths in grades 10 and
12 (mean ages 16 and 18 years, respectively). We used objective media
monitoring data to measure potential exposure of youths to different
sources of advertising, as opposed to self-reported measures of
exposure that can be correlated with openness to change in smoking
behavior.\13\
Methods
Advertising Data
Nielsen Media Research provided data on the occurrence of all
smoking-related advertisements that appeared on network and cable
television across the largest 75 U.S. television media market areas
during 1999-2002. These 75 markets accounted for 78 percent of American
viewing households.\14\ A media market is defined by a group of
nonoverlapping counties forming a major metropolitan area. Data are on
the basis of individual ratings of television programs obtained by
monitoring household audiences across media markets. Ratings provide an
estimate of the percentage of households with televisions that watch a
program or advertisement in a media market over a specified time
interval.\15\ The advertising exposure measure used in our study is
based on Target Rating Points (TRPs) for the population aged 12-17
years. In these analyses, TRPs were aggregated each month; 100 TRPs are
equal to an average of 1 potential advertisement exposure per month for
all youth aged 12-17 years within a media market. TRPs represent
potential average exposure; actual exposure for any given individual
would vary on the basis of actual television viewing. In this study,
all the tobacco company parent-targeted advertising was from Philip
Morris. However, tobacco company youth-targeted advertising was
broadcast by Philip Morris and Lorillard; Philip Morris made up 90.8
percent of the total TRPs in 1999, 93.0 percent in 2000, 85.2 percent
in 2001, and 37.5 percent in 2002.
Monthly TRP data were merged with nationally representative data
collected during 1999-2002 from the Monitoring the Future school
survey.\16\ Data were collected from February to June each year from
samples of students in grades 8, 10, and 12, drawn to be representative
of all students in the specified grade for the 48 contiguous states.
All surveys were self-completed and group-administered in school
settings.
Dependent Variables
Separate analyses were conducted for each of the following self-
reported dependent variables: recall of antitobacco advertising at
least weekly (1 = seeing antitobacco commercials on television or
hearing them on the radio at least once a week in recent months);
approval of smoking (1 = don't disapprove of people smoking * 1 pack a
day (grades 8 and 10), or don't disapprove of people (aged 18 years or
older) smoking * 1 pack a day (grade 12); perceived enjoyment of life
by smokers (1 = no disagreement with the statement that smokers know
how to enjoy life more than nonsmokers); preference for dating
nonsmokers (1 = no preference for dating nonsmokers); perceived
exaggeration of smoking harm (1 = no disagreement with the statement
that the harmful effects of smoking have been exaggerated); perception
that being a smoker reflects poor judgment (1 = do not agree that being
a smoker reflects poor judgment); perception that smoking is a dirty
habit (1 = do not agree that smoking is a dirty habit); perceived harm
of smoking (1 = believe people risk ``great harm'' to themselves by
smoking * 1 pack of cigarettes a day); intentions to be smoking in 5
years time (0 = definitely will not be smoking cigarettes in 5 years; 1
= other \17\); smoking in the past 30 days (1 = any cigarette smoking
in the past 30 days); and consumption among current smokers, as
measured by a 6-point scale: less than 1 cigarette/day (0.5), 1-5
cigarettes/day (3.0), about .5 pack/day (10), about 1 pack/day (20),
about 1.5 pack/day (30), and 2 or more packs/day (40). The natural log
of this scale was used in all models.\18\
The school survey randomly allocates students to several different
forms of survey questionnaires to maximize the number of questions
asked of students. Although all students are asked about smoking
behavior (current smoking and consumption), only some forms contain
questions on recall of advertising, and smoking-related attitudes and
intentions. For this reason, different numbers of students respond to
each outcome measure. The total number of students included in each
model is specified in table footnotes.
Independent Variables
Advertising exposure for each student was calculated to reflect the
cumulative effect of repeated potential exposure to tobacco industry
advertising and gave greater weight to more recent
exposure.19-21 Thus, in analyses, individual student
potential exposure to tobacco industry advertising was reflected by the
sum of TRPs for the month in which the school survey was completed,
plus the sum of depreciated TRPs from the 3 previous months. On the
basis of the work of Pollay and colleagues,\21\ a depreciation value of
0.3 was specified as noted in the equation.
(1)
Adstockt=Adt+lAd(t-1)+l
2Ad(t-2)+l3Ad(t-3)
where Adstock is the total effective advertising, l is set at the
specified value of 0.3 as noted above, and Ad indicates ad sponsor TRPs
for time periods t, t-1, t-2, and t-3. A range of values for l were
examined. Because results were highly similar, l was set at 0.3,
consistent with previously published data by Emery and colleagues \22\
on the effect of state tobacco control ads. The depreciated sum was
scaled by dividing by 100. The resulting TRP exposure value represents
the depreciated average number of times that advertising from a
particular sponsor was potentially seen by 100 percent of the youth
aged 12-17 years in each media market over the 4 months leading up to
each specific school's date of survey participation. Thus, students
within the same media market were assigned different advertising
exposures, depending on the month in which their school was surveyed.
However, within media markets, students in each school were assigned
the same advertising exposure values, because they completed the survey
on the same date. Smoking-related outcomes were modeled using
continuous versions of depreciated TRPs for youth-targeted and parent-
targeted advertising.
Statistical Analyses and Covariates
Our analyses used survey commands in Stata (Stata Corp, College
Station, Tex) for descriptive population estimates and multivariate
regression models (SVYLOGISTIC for dichotomous outcomes; SVYREG for the
models of cigarette consumption using the natural log of the
consumption scale). The complex multistage sample design was accounted
for by using sampling weights to adjust for differential selection
probabilities, and by using Taylor linearization-based variance
estimators to adjust for clustering by school and compute robust
standard errors.
Initially, for each type of tobacco company advertising, we tested
several functional forms, including quadratic and threshold models, to
explore whether the relations between exposure and outcomes were
nonlinear. The linear models fit the data best, and are reported here.
Thus, odds ratios refer to change in the likelihood of each outcome
measure, on the basis of each additional advertisement viewed, on
average, in the 4 months leading up to the date of survey
administration.
For tobacco company youth-targeted advertising, we first ran models
for all students combined and controlled for: (1) competing advertising
exposure from 2 types of campaigns: tobacco control (including state
and national American Legacy Foundation campaigns) and tobacco company
parent-targeted advertising; (2) individual sociodemographics: gender,
race/ethnicity, average parental education, dual parent household,
grade point average, 3 or more evenings out a week for fun/recreation,
past-month truancy, year, region, and student-earned income; and (3)
state tobacco policy variables: average real price per pack of
cigarettes \22\ and a smoke-free air index measuring the
comprehensiveness of state smoke-free laws. The smoke-free air index
values depended on the number, type, and level of protection for smoke-
free locations, and whether the state had the authority to preempt
local smoke-free regulations.\22\ On the basis that the primary target
group of the tobacco company youth-targeted advertising was youths aged
10-14 years and that middle- (grade 8, mean age 14 years) and high-
school (grades 10 and 12, mean ages 16 and 18 years, respectively)
students are at very different developmental stages, we ran separate
models for grade 8 versus grades 10 and 12. In the model for grades 10
and 12, a dummy variable for grade 12 was also included. This analysis
process was repeated to examine the relation between tobacco company
parent-targeted advertising and youth smoking outcomes (with the
exception that competing advertising exposure for tobacco company
youth-targeted advertising was included as a covariate).
We conducted sensitivity analyses to explore the robustness of
findings for outcomes of greatest concern. Because advertising and
policy variables were correlated, we excluded each tobacco policy
variable and tobacco control campaign exposure, to explore if observed
relations changed in a systematic way. In addition, we were able to
include information on student-reported frequency of television
watching as a covariate in models of smoking prevalence and
consumption, because these questions occurred on the same survey form
as television watching questions for all 3 grades. In this set of
analyses, the school survey item measured self-reported average weekday
television viewing as a continuous variable (a 7-point scale ranging
from 0 to 5+ hours).
Results
After retaining cases that had no missing data for covariates and
at least 1 of the specified dependent variables, 103,172 students
remained in the analytic sample; 36 percent were students in grade 8
and 64 percent were students in grades 10 and 12. Table 1 shows that
20.8 percent of the sample population had smoked in the last 30 days
and average daily consumption for these smokers was 5.43 cigarettes.
On average, students had been exposed to 4.77 depreciated potential
viewings of tobacco company youth-targeted advertising and 1.13
potential viewings of tobacco company parent-targeted advertising in
the 4-month period leading up to the survey. As expected from the
diverse timing and intensity of these campaigns, there was variation
between students, with a range of 0 to 14.51 viewings of tobacco
company youth-targeted ads, and a range of 0 to 4.13 viewings of
tobacco company parent-targeted ads. There was also variation in
exposure to tobacco control campaigns (mean 6.88 viewings; for state
antitobacco campaigns, mean = 1.66 [range = 0-19.14]; for the American
Legacy Foundation, mean = 5.23 [range = 0-21.85]).
After we controlled for covariates, increased exposure to tobacco
company youth-targeted advertising among all students was generally
unrelated to recall of televised anti-tobacco advertising or to smoking
beliefs or behavior (Table 2). However, on average, each additional ad
viewed was associated with a 3 percent stronger intention to smoke in
the future (OR = 1.03; CI = 1.01, 1.05). When analyzed separately for
middle- and high-school students, higher exposure to tobacco company
youth-targeted advertising was unrelated to any outcome for students in
grades 10 and 12. For students in grade 8, higher exposure was
associated with stronger intentions to smoke in the future (OR = 1.04;
CI = 1.01, 1.08). Inclusion of self-reported frequency of television
watching as a covariate did not change the finding that there was no
relation between increased tobacco company youth-targeted advertising
and smoking in the past 30 days, or consumption among smokers. (Data
for students who smoked in the past 30 days: all students OR = 0.99; CI
= 0.96, 1.01; grade 8 OR = 0.99; CI = 0.95, 1.04; grades 10 and 12 OR =
0.99; CI = 0.96, 1.01. Data for consumption among smokers: all students
Parameter estimate = -.008, P > .05; grade 8 Parameter estimate =
-.014, P > .05; grades 10 and 12 Parameter estimate = -.004, P > .05.)
After adjusting for covariates, Table 2 shows that among all
students combined, each additional tobacco industry parent-targeted ad
was associated with a lower likelihood of recalling antitobacco
advertising (OR = 0.87; CI = 0.82, 0.92), lower perceived harm of
smoking (OR = 0.95; CI = 0.92, 1.00), stronger intentions to smoke in
future (OR = 1.12; CI = 1.05, 1.19), and a greater likelihood of
smoking in the past 30 days (OR = 1.10; CI = 1.03, 1.17).
Separate models for middle- and high-school students indicated
that, among students in grade 8, greater tobacco company parent-
targeted advertising exposure was related to lower odds of recalling
antitobacco advertising (OR = 0.86; CI = 0.78, 0.94), a greater
likelihood of perceiving the harms associated with smoking have been
exaggerated (OR = 1.07; CI = 1.01, 1.13), and stronger intentions to
smoke in the future (OR = 1.10; CI = 1.00, 1.21). Among students in
grades 10 and 12, higher advertising exposure was also associated with
less likelihood of recalling antitobacco advertising (OR = 0.86; CI =
0.80, 0.94), stronger approval of smoking (OR = 1.11; CI = 1.03, 1.20),
lower perceived harm of smoking (OR = 0.93; CI = 0.88, 0.98), stronger
intentions to smoke in future (OR = 1.12; CI = 1.04, 1.21), and a
greater likelihood of smoking in the past 30 days (OR = 1.12; CI =
1.04, 1.19). Each additional ad exposure during the 4 months leading up
to survey administration, on average, was associated with a 12 percent
increase in the likelihood that students in grades 10 and 12 had smoked
in the past 30 days.
In sensitivity analyses among students in grades 10 and 12, where
relations of most concern were found, exclusion of cigarette price or
strength of smoke-free air index generally did not systematically
influence the relation between increasing tobacco company parent-
targeted advertising and stronger approval of smoking, lower perceived
harm of smoking, stronger intentions to smoke in the future, or greater
likelihood of smoking in the past 30 days (Table 3). When tobacco-
control ad exposure was removed, relations persisted between increasing
tobacco company parent-targeted ad exposure and stronger approval of
smoking as well as smoking in the past 30 days, but were weakened for
perceived harm of smoking and intention to smoke in the future.
Table 1.--Sample Characteristics of Students in 8th, 10th, and 12th
Grade: 1999-2002
------------------------------------------------------------------------
Weighted No. Percentage Mean
------------------------------------------------------------------------
Independent control variables (N = 103,172) a
Middle school (grade 8) 36.0
High school (grades 10 and 64.0
12)
Male 47.3
Race/ethnicity
White 71.6
African American 12.0
Hispanic 10.9
Other 5.5
Lives with both parents 75.0
Regularly out 3 nights/wk 44.5
Skipped or cut school in the 19.4
past month
Earned income, $ 1-15/wk
(median)
Parental education (range: 1- 3.99
6) b
Average school grade (range: 6.22
1-9) c
Real price/pack of 1.92
cigarettes, $ (range: $1.32-
$2.86)
Smoke-free air index (range: - 13.15
22.50-51.00)
Region
Northeast 21.5
Midwest 28.0
West 18.8
South 31.7
Independent variables (N = 103172) a
Average tobacco industry 1.13
parent-targeted exposure d
(range: 0.00- 4.13)
Average tobacco industry 4.77
youth-targeted exposure d
(range: 0.09-14.51)
Average tobacco control 6.88
exposure d (range: 0.00-
23.90)
Dependent variables e
Recall antitobacco ads on TV 28,768 62.4
or radio at least weekly (1
= yes)
Approve of others/adults 65,388 22.7
smoking 1 pack per day (1 =
yes) f
Do not prefer to date 37,645 22.6
nonsmokers (1 = yes)
Feel that smokers know how to 37,685 16.2
enjoy life more than
nonsmokers (1 = yes)
Feel the harmful effects of 37,240 34.2
cigarettes have been
exaggerated (1 = yes)
Do not feel that being a 37,343 39.6
smoker reflects poor
judgment (1 = yes)
Do not feel that smoking is a 37,320 27.5
dirty habit (1 = yes)
Perceive great harm in 95,952 69.6
smoking 1 packs/day (1 =
yes)
Intend to smoke in 5 years (1 34,047 39.1
= yes)
Smoked in the past 30 days (1 101,720 20.8
= yes)
Consumption frequency among 19,581 5.43
current smokers
(.5, 3, 10, 20, 30,40) g
------------------------------------------------------------------------
a Number of students was obtained by retaining only cases with valid
data for all independent control variables, and valid data on at least
1 of the specified dependent variables.
b Parental education was a scaled value ranging from 1 to 6, and was a
combined average of mother's and father's highest level of education,
where 1 = grade school or less, 2 = some high school, 3 = high school
completion, 4 = some college, 5 = college completion, and 6 = graduate
school.
c Average school grade was a 9-item scale where 1 = D and 9 = A.A mean
of 6 indicates a B.
d Exposure to specific ads during the 4 months before the school survey.
Advertising exposure data reported at the student level and not at the
media market level, because students within the same media market will
have different average exposures on the basis of their school survey
date.
e Possible Ns for dependent variables varied, because not all items were
asked of all students.
f Students in grades 8 and 10 were asked about disapproval of others'
smoking; students in grade 12 were asked about disapproval of adults'
smoking.
g Consumption was measured by a 6-point scale: less than 1 cigarette/day
(0.5), 1-5 cigarettes/day (3.0), about 0.5 pack/day (10), about 1 pack/
day (20), about 1.5 pack/day (30), and 2 or more packs/day (40). The
natural log of this scale was used in all models.
When self-reported frequency of television watching was included as
a covariate, the relation between tobacco company parent-targeted ad
exposure and current smoking was unchanged for students in grade 8 (OR
= 1.11; CI = 0.99, 1.25, not significant) but was strengthened among
students in grades 10 and 12 (OR = 1.14; CI = 1.05, 1.25, P < .01).
Control for television watching did not change the previously
nonsignificant results for cigarette consumption (grade 8: Parameter
estimate = -.068, P > 0.5; grades 10 and 12: Parameter estimate= -.016,
P > .05).
In models of students in all three grade levels, higher cigarette
price was associated with lower consumption among current smokers
(Parameter estimate = -.002, SE = 0.001, P < .05), and stronger smoke-
free laws were associated with a lower likelihood of smoking in the
past 30 days (OR = 0.99; CI = 0.99, 1.00, P = .01 [data not shown]). In
addition, consistent with previous studies,\11\ \22\ we observed
expected relations between increasing exposure to tobacco control
campaign advertising and higher recall of antitobacco advertising (OR =
1.04; CI = 1.03, 1.04, P < .001), more protective beliefs about smoking
(e.g., increased perceived harm of smoking) (OR = 1.01; CI = 1.00,
1.02, P < .01), weakened intentions to smoke in future (OR = 0.98; CI =
0.97, 0.99, P < .001), and a lower likelihood of smoking in the past 30
days (OR = 0.99; CI = 0.98, 1.00, P < .01).
Discussion
Overall, we found no systematic associations between increased
exposure to tobacco company youth-targeted smoking prevention
advertising and smoking outcomes among American youths. We found that
increased exposure to tobacco company parent-targeted smoking
prevention advertising was associated with lower recall of antitobacco
advertising and stronger intentions to smoke in the future for all
students. Among students in grade 8, tobacco company parent-targeted
advertising was related to stronger beliefs that the harms associated
with smoking have been exaggerated, and among students in grades 10 and
12, was associated with lower perceived harm of smoking, stronger
approval of smoking, and a higher likelihood of having smoked in the
past 30 days. Importantly, the results for smoking prevalence among
students in grades 10 and 12 were not systematically influenced by
correlations between price and strength of smoke-free air laws, or
tobacco control advertising exposure, although some models were less
robust when tobacco control ad exposure was removed as a covariate.
Table 2.--Odds Ratios for Each Unit Increase in Number of Ads Viewed, With 95% Confidence Intervals (CIs), for Smoking-Related Beliefs and Behavior and
Tobacco Industry Smoking Prevention Advertising Exposure: 1999-2002
--------------------------------------------------------------------------------------------------------------------------------------------------------
Exposure, all students a Exposure, 8th Grade Students b Exposure, 10th and 12th Grade Students c
-----------------------------------------------------------------------------------------------------------------------------------
Youth-Targeted d Parent-Targeted e Youth-Targeted d Parent-Targeted e Youth-Targeted d Parent-Targeted e
--------------------------------------------------------------------------------------------------------------------------------------------------------
Recall antitobacco 1.00 (0.98, 1.02) 0.87*** (0.82, 0.92) 0.99 (0.96, 1.02) 0.86** (0.78, 0.94) 1.01 (0.98, 1.03) 0.86** (0.80, 0.94)
ads on TV or radio
at least weekly
Approve of others/ 0.98 (0.95, 1.00) 1.06 (0.99, 1.13) 0.98 (0.95, 1.01) 1.03 (0.96, 1.12) 0.98 (0.96, 1.01) 1.11** (1.03, 1.20)
adults smoking 1
pack/day f
Do not prefer to 1.00 (0.97, 1.02) 1.04 (0.97, 1.11) 1.00 (0.96, 1.04) 1.05 (0.94, 1.18) 0.99 (0.97, 1.02) 1.03 (0.96, 1.11)
date nonsmokers
Feel that smokers 1.00 (0.98, 1.03) 1.00 (0.94, 1.07) 1.02 (0.98, 1.06) 1.07 (0.96, 1.19) 0.99 (0.97, 1.02) 0.94 (0.87, 1.01)
know how to enjoy
life more than
nonsmokers
Feel the harmful 1.00 (0.98, 1.02) 1.03 (0.99, 1.08) 1.01 (0.98, 1.03) 1.07* (1.01, 1.13) 0.99 (0.96, 1.01) 0.99 (0.93, 1.06)
effects of
cigarettes have
been exaggerated
Do not feel that 0.99 (0.97, 1.01) 0.99 (0.94, 1.04) 0.98 (0.95, 1.01) 1.02 (0.95, 1.09) 0.99 (0.97, 1.02) 0.96 (0.90, 1.03)
being a smoker
reflects poor
judgment
Do not feel that 1.00 (0.98, 1.02) 1.00 (0.94, 1.07) 1.00 (0.96, 1.03) 1.01 (0.92, 1.10) 1.01 (0.98, 1.03) 0.99 (0.91, 1.07)
smoking is a dirty
habit
Perceive great harm 0.99 (0.98, 1.01) 0.95* (0.92, 1.00) 0.99 (0.97, 1.01) 0.98 (0.93, 1.04) 1.00 (0.98, 1.02) 0.93** (0.88, 0.98)
in smoking 1 packs/
day
Intend to smoke in 5 1.03** (1.01, 1.05) 1.12** (1.05, 1.19) 1.04* (1.01, 1.08) 1.10* (1.00, 1.21) 1,.01 (0.99, 1.04) 1.12** (1.04, 1.21)
years
Smoked in past 30 0.99 (0.97, 1.01) 1.10** (1.03, 1.17) 0.99 (0.95, 1.04) 1.11 (0.99, 1.25) 0.99 (0.97, 1.01) 1.12** (1.04, 1.19)
days
Consumption -.014; (.008) .019 (.025) -.014 (.015) .069 (.044) -.012 (.009) .018 (.028)
frequency among
current smokers,g
parameter estimate
(SE)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note. All models controlled for tobacco control advertising exposure, either tobacco company parent-targeted or youth-targeted advertising exposure,
year, gender, race/ethnicity, earned income, average parental education, whether both parents live in the home, grade point average, evenings out,
truancy, region, state cigarette price, and state smoke-free air index values. aAll students model Ns (weighted): smoked in last 30 days 101,720;
perceived harm 95,952; disapproval 65 388; recall 28,768; consumption 21,138; remaining perception models range from 34,047 to 37,685.
a Grade 8 model Ns (weighted): smoked in last 30 days 36,382; perceived harm 36,236; disapproval 23,305; recall 12,136; consumption 4,621; remaining
perception models range from 12,287 to 16,688.
c Grades 10 and 12 model Ns (weighted): smoked in last 30 days 65,338; perceived harm 59,716; disapproval 42,083; recall 16,632; consumption 16,517;
remaining perception models range from 20,827 to 21,760. A dummy variable identifying students in grade 12 was included in these models.
b Tobacco company youth-targeted ads sponsored primarily by Philip Morris, and by Lorillard Tobacco Company.
e Tobacco company parent-targeted ads sponsored by Philip Morris.
f Students in grades8 and 10 asked about disapproval of others'smoking; 12th grade students asked about disapproval of adults'smoking.
g Consumption measured by a 6-point scale: less than 1 cigarette/day (0.5), 1-5 cigarettes/day (3.0), about 0.5 pack/day (10), about 1 pack/day (20),
about 1.5 pack/day (30), and 2 or more packs/day (40). The natural log of this scale was used in all models.
*P < .05; **P < .01; ***P < .001.
Table 3.--Odds Ratios and 95% Confidence Intervals for Tobacco Company Parent-Targeted Advertising Exposure and
Selected Smoking Outcomes Among Students in Grades 10 and 12: 1999-2002 a
----------------------------------------------------------------------------------------------------------------
Excluding state
Model a Weighted Excluding state smoke-free air Excluding tobacco
No. cigarette price index value control ad exposure
----------------------------------------------------------------------------------------------------------------
Approve of others/adults smoking 42,083 1.10* (1.02, 1.18) 1.11** (1.03, 1.21) 1.10** (1.04, 1.17)
1 pack/day b
Perceive great harm in smoking 1 59,716 0.95 (0.90, 1.01) 0.93** (0.88, 0.98) 0.97 (0.93, 1.01)
packs/day
Intend to smoke in 5 years 21,760 1.12** (1.04, 1.20) 1.13** (1.05, 1.22) 1.04 (0.98, 1.10)
Smoked in past 30 days 65,338 1.10** (1.03, 1.18) 1.12** (1.05, 1.20) 1.07** (1.02, 1.12)
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
a Tobacco company parent-targeted ads sponsored by Philip Morris. All models controlled for year, gender, race/
ethnicity, earned income, average parental education, whether both parents live in the home, average school
grade, evenings out, truancy, region, and dummy variable for students in grade 12. Unless specified above,
models also controlled for tobacco control advertising exposure, either tobacco company parent-directed or
youth-targeted advertising exposure, state cigarette price, and state smoke-free air index values.
b Students in grade 10 were asked about disapproval of others' smoking; students in grade 12 were asked about
disapproval of adults' smoking.
*P < .05; **P < .01.
Our study did have limitations. Our use of cross-sectional survey
data reduced our ability to make direct causal inferences about whether
potential exposure to tobacco company parent-targeted advertising
resulted in changes to youth smoking behavior, or whether an unmeasured
factor may better explain the relations we observed. However, our
ability to adjust for competing advertising exposures, our use of
regional and year dummy variables, our sensitivity analyses, and the
fact that we observed results for tobacco policy \23\ \24\ and other
advertising covariates \11\ \22\ that were largely consistent with
those found in previous studies, lead us to believe that it is unlikely
that we are misrepresenting the relation between exposure to tobacco
company youth-targeted or parent-targeted advertising and youth smoking
outcomes. An alternate hypothesis is that tobacco companies may have
purposefully purchased parent-targeted advertising in media markets
that have higher youth smoking rates. This seems unlikely, however,
given that the vast majority of their television time was bought
through national network and cable channels and was not supplemented by
the purchase of local media market television time. In addition,
although the study had a large sample size, which makes differences
between groups more likely to achieve statistical significance, the
overall consistency in the pattern and robustness of findings leads one
to conclude that the detected relations are real.
As previously mentioned, another study limitation is that because
TRPs measure average exposure for the overall population in a media
market, individual youths may have more or less actual exposure,
depending upon their own viewing habits. However, when we adjusted for
self-reported television watching, the relations between tobacco
company youth-targeted and parent-targeted advertising and smoking in
the past 30 days did not change for students in grade 8 and
strengthened for students in grades 10 and 12. Previous studies of
antitobacco and antidrug advertising have found a strong correlation
between advertising recall and TRP measures.\22\ \25\
Studies that use controlled exposure have indicated that tobacco
company youth-targeted advertisements are less likely than those from
state tobacco control programs tomake youths stop and think about
smoking \10\ and are of less interest to youths.\26\ In 1 national
study, Philip Morris ``Think. Don't Smoke'' advertisements were
associated with increased intention to smoke and more favorable
feelings toward the tobacco industry.\6\ Massachusetts youths aged 14-
17 who recalled seeing Philip Morris' ``Think. Don't Smoke'' ads
perceived them to be less effective than ads that featured the serious
consequences of smoking.\8\ Our finding of no relation between tobacco
company youth-targeted advertising and youth smoking substantiates
these previous results. Although tobacco company youth-targeted
advertising was withdrawn from U.S. television in early 2003, ads
continue to be broadcast in other countries, contributing ``clutter''
to other public health-sponsored advertising efforts \12\ that have
been shown to be effective.\11\ \22\ \27\
Our finding of potentially harmful relations between tobacco
company parent-targeted smoking prevention advertising and youth
smoking is a source of concern. Our observation of adverse relations
associated with parent-targeted advertising is not simply an artifact
of our methodological approach: we have previously reported beneficial
relations between exposure to state-sponsored antitobacco advertising
and youth smoking beliefs and behavior using the same methods.\22\
Why might such advertising have harmful relations, especially for
older teens? Although parents are the overt target group of tobacco
company parent-targeted advertising, youths are exposed to them, on
average, at levels almost equivalent to those of state-sponsored
antitobacco campaigns. The overt message of the parent-targeted
campaign is that parents should talk to their children about smoking,
but no reason beyond simply being a teenager is offered as to why
youths should not smoke.
Theories in developmental psychology suggest that authority
messages specific to teenagers invite rejection by those who have
migrated to a dominant peer group orientation as they make the
transition to adulthood, typically between ages 15 to 17 years.\28\
\29\ As adolescents age toward adulthood, they are more inclined to
perceive themselves as independent and self-reliant and less likely to
report that they rely on their parents for guidance or assistance.\28\
Evaluations of the U.S. National Anti-Drug Media Campaign, which used
messages encouraging parents to talk to their children about illicit
drugs, have also reported unfavorable effects on adolescents.\30\ \31\
Facilitating productive interaction between parents and adolescents
about substance use may require more intensive intervention approaches
than simple encouragement through the mass media, which may do more
harm than good.
During depositions and testimony in U.S.-based tobacco trials,
tobacco company witnesses put forward their youth smoking prevention
efforts as evidence that they are concerned about youth smoking and
that the campaigns are part of efforts to reduce youth smoking.\32\
However, during questioning at such a trial, Carolyn Levy, Director of
Philip Morris youth smoking prevention programs, admitted that the aim
of their programs was to delay smoking until age 18 \32\ This contrasts
with the aims of public health-funded programs, which are to encourage
people to never take up smoking.
In summary, our analysis suggests that tobacco company youth- and
parent-targeted smoking prevention advertising campaigns confer no
benefit to youths, and especially for older teens, parent-targeted
advertising may have harmful relations. In the United States, youths
have the benefit of the national American Legacy Foundation antitobacco
campaign, as well as state antitobacco campaigns. The Legacy
Foundation's budget cuts will force it to advertise less in the future,
\33\ and state antitobacco campaign advertising has begun to decline as
a result of reduced state tobacco control funding.\12\ \34\ Many other
countries of the world have limited or no public health-sponsored
televised antitobacco advertising. Given a media environment that has
fewer demonstrably beneficial advertising messages, it is conceivable
that tobacco company smoking prevention ads could have even greater
adverse effects on youth smoking behavior than suggested by this study.
About the Authors
Melanie Wakefield is with the Center for Behavioral Research in
Cancer, The Cancer Council Victoria, Melbourne, Australia. Yvonne
Terry-McElrath, Patrick M. O'Malley, and Lloyd D. Johnston are with the
Institute for Social Research, University of Michigan, Ann Arbor.
Sherry Emery, Frank J. Chaloupka, and Glen Szczypka are with the
Institute for Health Research and Policy, University of Illinois,
Chicago. Henry Saffer is with the Department of Economics, Kean
University, Union, NJ.
Requests for reprints should be sent to Melanie Wakefield, Ph.D.,
Center for Behavioral Research in Cancer, The Cancer Council Victoria,
1 Rathdowne Street, Carlton, Victoria, Australia, 3053.
Contributors
M. Wakefield conceived and led the study and the writing of the
article. Y. Terry-McElrath conducted the analysis and assisted with
writing. S. Emery, H. Saffer, F. Chaloupka, B. Flay, P.M. O'Malley, and
L.D. Johnston contributed to conception of the study and the analysis
and assisted with writing. G. Szczypka undertook data management for
the study and assisted with writing.
Acknowledgments
The study was supported by the National Cancer Institute State and
Community Tobacco Control Initiative (grant CA86273), the National
Institute on Drug Abuse (grant DA01411), and The Robert Wood Johnson
Foundation (grant 032 769). Melanie Wakefield was supported by a
VicHealth Senior Research Fellowship.
Human Participant Protection
This study was approved by the University of Illinois, Chicago,
institutional review board. Use of data from the Monitoring the Future
school surveys received ethical approval by the University of Michigan
Behavioral Sciences institutional review board.
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\10\ Terry-McElrath, Y., Wakefield, M., Ruel, E., et al., The
effect of anti-smoking advertisement executional characteristics on
youth appraisal and engagement. J Health Commun. 2005; 10:127-143.
\11\ Farrelly, M.C., Healton, C.G., Davis, K.C., Messeri, P.,
Haviland, M.H. Getting to the truth: evaluating national tobacco
countermarketing campaigns. Am J Public Health. 2002; 92:901-907.
\12\ Wakefield, M., Szczypka, G., Terry-McElrath, Y., et al., Mixed
messages on tobacco: comparative exposure to public health, tobacco
company and pharmaceutical company sponsored tobacco-related television
campaigns in the United States, 1999-2003. Addiction. 2005; 100:1875-
1883.
\13\ Borland, R., Balmford, J. Understanding how mass media
campaigns impact on smokers. Tobacco Control. 2003; 12 (Suppl. 2):ii45-
52.
\14\ Nielsen Media Research. DMA market and demographic rank:
September 2001. New York: Nielsen Media Research; 2002.
\15\ Szczypka, G., Emery, S., Wakefield, M., Chaloupka, F. The
adaption and use of Nielsen Media Research commercial ratings data to
measure potential exposure to televised smoking-related advertisements.
Available at: http://www. impacteen.org/ab_RPNo29_2003.htm. Accessed
August 15, 2006.
\16\ Johnston, L.D., O'Malley, P.M., Bachman, J.G. Monitoring the
Future: national survey results on drug use, 1975-2003. Volume 1:
Secondary school students. Bethesda, MD: National Institute on Drug
Abuse;2004. NIH Publication No. 04-5507.
\17\ Wakefield, M., Kloska, D.D., O'Malley, P.M., et al., The role
of smoking intentions in predicting future smoking among youth:
findings from Monitoring the Future data. Addiction. 2004; 99(7):914-
922.
\18\ Duan, N.M.W., Morris, C.N., Newhouse, J.P. Choosing between
the sample selection model and the multi-part model. J Business Econ
Stat. 1984; 2:283-289.
\19\ Berndt, E. The practice of econometrics: classic and
contemporary. Reading, MA: Addison-Wesley Publishing Company; 1991.
\20\ Koyck, L.M. Distributed lags and investment analysis.
Amsterdam: North Holland Publishers; 1959.
\21\ Pollay, R., Siddarth, S., Segal, M., et al., The last straw?
Cigarette advertising and realized market shares among youths and
adults, 1979-1993. J Marketing. 1996; 60(2):1-16.
\22\ Emery, S., Wakefield, M.A., Terry-McElrath, Y., et al.,
Televised state-sponsored anti-tobacco advertising and youth smoking
beliefs and behavior in the United States, 1999-2000. Arch Paediatr
Adolesc Med. 2005; 159:639-645.
\23\ Chaloupka, F., Warner, K. The economics of smoking. In:
Newhouse JP, Cuyler AJ, eds. The Handbook of Health Economics. New
York: North Holland; 2001:1539-1627.
\24\ Wakefield, M.A., Chaloupka, F.J., Kaufman, N.J., Orleans,
C.T., Barker, D.C., Ruel, E.E. Effect of restrictions on smoking at
home, at school, and in public places on teenage smoking: cross
sectional study. Br Med J. 2000; 321(7257):333-337.
\25\ Southwell, B.G., Barmada, C.H., Hornik, R.C., Maklan, D.M. Can
we measure encoded exposure? Validation evidence from a national
campaign. J Health Commun. 2002; 7(5):445-453.
\26\ Wakefield, M., Balch, G.I., Ruel, E.E., et al., Youth
responses to anti-smoking advertisements from tobacco control agencies,
tobacco companies and pharmaceutical companies. J Appl Soc Psychl.
2005; 35:1894-1911.
\27\ Farrelly, M.C., Davis, K.C., Haviland, M.L., Messeri, P.,
Healton, C.G. Evidence of a dose-response relationship between
``truth'' antismoking ads and youth smoking prevalence. Am J Public
Health. 2005; 95(3):425-431.
\28\ Crockett, L.J., Petersen, A.C. Adolescent development: Health
risks and opportunities for health promotion. In: Millstein, S.G.,
Petersen, C., Nightingale, E.O., eds. Promoting the Health of
Adolescents: New Directions for theTwenty-First Century, 1993, New
York: Oxford University Press; 1993:3-37.
\29\ Ingra, V., Irwin, C.E. Theories of adolescent risk taking
behavior. In: Di Clemente, R.J., Hansen, W.B., and Ponton, L.E., eds.
Handbook of Adolescent Health Risk Behavior, New York: Plenum Press;
1996.
\30\ Hornik, R., Maklan, D., Cadell, D., et al., Evaluation of the
national youth anti-drug media campaign: fifth semiannual report of
findings. Available at: http://www.nida. nih.gov/DESPR/Westat/#reports.
Accessed September 19, 2005.
\31\ Hornik, R., Maklan, D., Cadell, D., et al., Evaluation of the
national youth antidrug media campaign: 2003 report of findings.
Available at: http://www.nida.nih.gov/DESPR/ Westat/#reports. Accessed
September 19, 2005.
\32\ Wakefield, M., Mcleod, K., Perry, C.L. ``Stay away from them
until you're old enough to make a decision'': Tobacco company testimony
about youth smoking initiation. Tobacco Control. In press.
\33\ Schroeder, S.A. Tobacco control in the wake of the 1998 Master
Settlement Agreement. New Eng J Med. 2004; 350:293-301.
\34\ Szczypka, G., Wakefield, M., Emery, S., et al., Estimated
exposure of adolescents to state-funded anti-tobacco television
advertisements--37 states and the District of Columbia, 1999-2003.
MMWR. 2005; 54(42):1077-1080.
______
Response to Written Question Submitted by Hon. Daniel K. Inouye to
Hon. William E. Kovacic
Question. Are the ratings based on the FTC cigarette testing method
deceiving smokers?
Answer. The Commission has been concerned for some time that the
current test method may be misleading to individual consumers who rely
on the ratings it produces as indicators of the amount of tar and
nicotine they actually will get from their cigarettes.
As noted in the Commission's November 13, 2007 Prepared Statement
to the Committee, the ratings produced by the current test method tend
to be relatively poor predictors of tar and nicotine exposure,
primarily due to smoker compensation. If sufficiently great,
compensatory smoking behavior can result in smokers getting as much tar
and nicotine from relatively low-rated cigarettes as from higher-rated
cigarettes.
When the Commission approved the test method in 1967, the intent
was to produce uniform, standardized data about the tar and nicotine
yields of mainstream cigarette smoke, not to replicate actual human
smoking. Because no known test could accurately replicate human
smoking, the FTC believed that the most important objective was to
ensure that cigarette companies presented tar and nicotine information
to the public based on a standardized method. At the time, most public
health officials believed that reducing the amount of ``tar'' in a
cigarette could reduce a smoker's risk of lung cancer; therefore, it
was thought that giving consumers uniform and standardized information
about the tar and nicotine yields of cigarettes would help smokers make
informed decisions about the cigarettes they smoked.
In the intervening 40 years, the limitations of the test method
became a substantially greater concern as a result of changes in modern
cigarette design and a better understanding of the nature and effects
of compensatory smoking. These concerns have prompted the Commission to
take a number of actions over the past decade.
First, in 1994, the Commission, along with Congressman Henry
Waxman, asked the National Cancer Institute (``NCI'') to convene a
consensus conference to address cigarette testing issues. NCI held that
conference in December 1994, and issued its Report in October 1996.
The NCI Report recommended, among other things, that the cigarette
testing system measure and publish information on the range of tar,
nicotine, and carbon monoxide that most smokers should expect from the
cigarettes they smoke. Accordingly, in September 1997, the Commission
requested public comments on proposed revisions to the test method that
would add a second tier of testing--using more rigorous smoking
conditions--to generate a range of tar and nicotine yields for each
cigarette and make it more apparent to consumers that the amount of tar
and nicotine they get from any specific cigarette depends on how they
smoke it.
Ultimately, public health agencies asked the Commission to postpone
its proposed modifications to the test method until a broader review of
unresolved scientific issues surrounding the system could be conducted.
The agency responded to these comments in 1998 by asking the Department
of Health and Human Services (``HHS'') to review the test method. In
particular, the Commission asked HHS to recommend whether the testing
system should be continued, and if so, what specific changes should be
made to correct the limitations previously identified by the NCI and
others. The Commission understands that HHS continues to explore these
issues.
The Commission's concerns about the current system led it to
recommend in 1999 that Congress consider giving authority over
cigarette testing to one of the Federal Government's science-based,
public health agencies.\1\ The agency specifically noted that it does
not have the specialized scientific expertise needed to design
scientific test procedures. The Commission reiterated that request in
2003 \2\ and again at the November 13, 2007 hearings.
---------------------------------------------------------------------------
\1\ Federal Trade Commission Report to Congress for 1997, Pursuant
to the Cigarette Labeling and Advertising Act, 5-6 (1999) (available at
http://www.ftc.gov/os/1999/07/1997
cigarettereport.pdf).
\2\ Prepared Statement of the Federal Trade Commission Before the
Committee on Energy and Commerce, Subcommittee on Commerce, Trade, and
Consumer Protection, U.S. House of Representatives (June 3, 2003);
Prepared Statement of the Federal Trade Commission Before the Committee
on Government Reform, U.S. House of Representatives (June 3, 2003).
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Finally, the cigarette industry's use of descriptors that are based
on ratings produced by the test method--such as ``light'' and ``low
tar''--is one of the issues currently before the United States Court of
Appeals for the District of Columbia Circuit. The trial judge in the
U.S. Department of Justice's RICO case against the major cigarette
manufacturers found that the manufacturers had made false and
fraudulent statements about ``light'' and ``low'' tar cigarettes in
marketing their products when they knew those cigarettes did not
provide a clear health benefit compared to full-flavor cigarettes (the
industry's term for cigarettes with tar ratings above 15 mg.). The
judge barred the companies from using the terms ``light'' and ``low''
in marketing their products in the future. The companies have appealed
that decision and remedy. We are monitoring that case, and believe that
the court's resolution of this issue will provide guidance and clarity
on a complex issue that has raised troublesome questions for some time.
______
Supplemental Information Submitted by Cathy L. Backinger, Ph.D.
The Impact of Cigarette Tax Increases on Cigarette Smuggling
NCI Research Published in Monograph 14: Changing Adolescent Smoking
Prevalence concluded that:
``[R]elatively little is known about the impact of large price
increases on the growth of a black market in tobacco products
and its subsequent impact on demand, particularly among youths.
To the extent that organized and casual smuggling of tobacco
products would result from large tax and price increases, the
effects of the increases on tobacco use might be smaller than
otherwise expected. The limited research in this area, however,
suggests that the presence of a black market in tobacco
products may be just as, or more, related to other factors--
including the presence of informal distribution networks,
nonexistent or weak policies concerning black market sales, and
their lack of enforcement--as it is to prices (Joossens and
Raw, 1995).'' \1\
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\1\ National Cancer Institute. Changing Adolescent Smoking
Prevalence. Smoking and Tobacco Control Monograph No. 14. Bethesda, MD:
U.S. Department of Health and Human Services, National Institutes of
Health, National Cancer Institute, NIH Pub. No. 02-5086, November 2001.
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The 2000 Surgeon General's Report, Reducing Tobacco Use, concluded:
``Smuggling has a significant, but small, impact on
cigarette demand, implying that a state cigarette tax increase
will lead to some smuggling.''
``On average, 6 percent of state cigarette tax revenues were
lost due to smuggling activities in 1995.''
``States can raise cigarette taxes and generate increased
revenues, even as cigarette sales decline and interstate
smuggling increases.'' \2\
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\2\ U.S. Department of Health and Human Services. Reducing Tobacco
Use: A Report of the Surgeon General. Atlanta, Georgia: U.S. Department
of Health and Human Services, Centers for Disease Control and
Prevention, National Center for Chronic Disease Prevention and Health
Promotion, Office on Smoking and Health, 2000. 82-50179.
A California Department of Health survey found that soon after
California's 50-cent cigarette tax increase went into effect in 1999,
no more than 5 percent of all smokers purchased cigarettes in nearby
states, from Indian reservations or military bases, or via the
Internet, or otherwise avoided the state's cigarette tax.\3\
---------------------------------------------------------------------------
\3\ Cancer Prevention & Control Program, University of California--
San Diego--The California Tobacco Control Program: A Decade of
Progress, Results from the California Tobacco Survey, 1990-1999 By the
Tobacco Control Section, California Department of Health Services,
December 26, 2001. http://ssdc.ucsd.edu/ssdc/pdf/1999_Final_Report.pdf.
---------------------------------------------------------------------------
______
The Effect of Televised, Tobacco Company-Funded Smoking Prevention
Advertising on Youth Smoking
The National Cancer Institute funded a study published in the
American Journal of Public Health in 2006 titled The Effect of
Televised, Tobacco Company-Funded Smoking Prevention Advertising on
Youth Smoking-Related Beliefs, Intentions, and Behavior. Below is a
summary of this study:
Recently, some tobacco companies have sought to portray themselves
as interested in helping to prevent youth smoking, or in helping adults
to quit. The sincerity and effectiveness of these efforts has been
challenged by many in the medical and public health community who
believe that, in reality, these activities are aimed at improving the
dismal public profile of tobacco companies and at shifting attention
away from their efforts to promote tobacco use.
In a recently published study, Wakefield et al. confirmed that the
tobacco industry's youth-targeted smoking prevention advertising does
not have beneficial outcomes for youth. In fact, it appears that
exposure to tobacco company advertising targeted to parents may have
harmful effects on youth, especially among those in grades 10 and 12.
Among students in grade 8, tobacco company advertising targeted to
parents was related to:
stronger beliefs that the harms associated with smoking have
been exaggerated,
lower recall of anti-tobacco advertising (state and national
American Legacy Foundation campaigns, such as
truth'), and
stronger intentions to smoke in the future.
Among youths in grades 10 and 12, during the 4 months leading up to
the survey administration, each additional viewing of a tobacco company
advertisement targeted to parents was, on average, associated with:
lower perceived harm of smoking,
stronger approval of smoking,
greater likelihood of having smoked in the past 30 days,
lower recall of anti-tobacco advertising (state and national
American Legacy Foundation campaigns, such as
truth'), and
stronger intentions to smoke in the future.
______
Cigarette Taxes and Cigarette Use
NCI-funded research has found that raising tobacco prices and
implementing limits on tobacco marketing are effective in reducing and
preventing tobacco use.\1\
---------------------------------------------------------------------------
\1\ Chaloupka et al., (2002). Tax, price and cigarette smoking:
evidence from the tobacco documents and implications for tobacco
company marketing strategies. Tobacco Control, 11 Suppl 1: 162-72.
---------------------------------------------------------------------------
Youth are more susceptible to price increases than adults:
Youth: 10 percent increase in price = 5 percent
reduction in prevalence.
Adults: 10 percent increase in price = 1-2 percent
reduction in prevalence.\2\
---------------------------------------------------------------------------
\2\ National Cancer Institute. Changing Adolescent Smoking
Prevalence. Smoking and Tobacco Control Monograph No. 14. Bethesda, MD:
U.S. Department of Health and Human Services, National Institutes of
Health, National Cancer Institute, NIH Pub. No. 02-5086, November 2001.
CDC research has found that lower-income Americans and young adults
---------------------------------------------------------------------------
are more susceptible to price increases than other Americans:
Lower-income Americans (family incomes at or below the
national median) are more likely to quit smoking as a result of
cigarette price increases than higher-income Americans.
Persons aged 18 through 24 years are more responsive to
price increases than older smokers.
Hispanic smokers and non-Hispanic black smokers are more
likely than white smokers to reduce or quit smoking in response
to price increases.\3\
---------------------------------------------------------------------------
\3\ Centers for Disease Control and Prevention. Response to
increases in cigarette prices by race/ethnicity, income, and age
groups--United States, 1976-1993. Morbidity and Mortality Weekly Report
47(29):605-609, 1998.
---------------------------------------------------------------------------
The 2000 Surgeon General's Report, Reducing Tobacco Use, concluded:
``The price of tobacco has an important influence on the
demand for tobacco products, particularly among young people.''
``Substantial increases in the excise taxes on cigarettes
would have a considerable impact on the prevalence of smoking
and, in the long term, reduce the adverse health effects caused
by tobacco.'' \4\
---------------------------------------------------------------------------
\4\ U.S. Department of Health and Human Services. Reducing Tobacco
Use: A Report of the Surgeon General. Atlanta, Georgia: U.S. Department
of Health and Human Services, Centers for Disease Control and
Prevention, National Center for Chronic Disease Prevention and Health
Promotion, Office on Smoking and Health, 2000. 82-50179.
---------------------------------------------------------------------------
Why might such advertising have harmful effects, especially for
older teens?
Although parents are the stated audience for tobacco company
advertising targeted to parents, youths are exposed to them, on
average, at levels almost equivalent to those of state-
sponsored anti-tobacco campaigns.
The message of the parent-targeted campaign is that parents
should talk to their children about smoking, but no reason
beyond simply being a teenager is offered as to why youth
should not smoke.
Theories in developmental psychology suggest that authority
messages specific to teenagers invite rejection by those who
have migrated to a dominant peer group orientation as they make
the transition to adulthood, typically between ages 15 to 17
years.
Public health experts note that, if indeed tobacco companies wanted
to make a positive contribution toward reducing youth tobacco use, the
obvious first step would be to decrease or eliminate the billions of
dollars the companies spend so effectively each year to advertise and
promote tobacco use.
Source: The Effect of Televised, Tobacco Company--Funded Smoking
Prevention Advertising on Youth Smoking
Wakefield, M., Terry-McElrath, Y., Emery, S., Saffer, H.,
Chaloupka, F.J., Szczypka, G., Flay, B., O'Malley, P.M., Johnston, L.D.
(2006). ``Effect of Televised, Tobacco Company--Funded Smoking
Prevention Advertising on Youth Smoking-Related Beliefs, Intentions,
and Behavior'' American Journal of Public Health, Vol 96, No. 12, 2154-
2160. http://www.ajph.org/cgi/content/ful1/96/12/2154.
______
Disease Risks of Pipe, Cigar and Cigarette Use
As previously stated (in Dr. Backinger's testimony), all forms of
tobacco products are harmful, including cigars and pipes.\1\ Because
pipe use among Americans is much lower than the use of other tobacco
products, there is limited research specifically on pipe smoking. Below
is a summary of NCI funded research, along with information from
additional studies, on how the health risks of smoking pipes or cigars,
compares to that of smoking cigarettes.
Cigar and pipe smoking are strongly related to cancers of
the mouth, oropharynx, hypopharynx, larynx and esophagus.\2\
\3\ \4\
Cigar and pipe smoking are causally associated with lung
cancer and there is evidence they are also causally associated
with, pancreatic, stomach and urinary bladder cancer.\2\
The risk of death from lung cancer is higher in pipe and
cigar smokers than in non-smokers, but lower in pipe and cigar
smokers than in cigarette smokers. This is because both pipe
and cigar smokers typically smoke less tobacco and have a lower
degree of inhalation.\4\ \5\
The risk of lung cancer increases with the number of pipes
or cigars smoked per day, and with the degree of smoke
inhalation.\5\
Graph 1 below describes the difference in risks of dying
from particular diseases for exclusive cigarette, pipe, and
cigar smokers compared to nonsmokers. Among other things, the
graph shows that:
Current pipe smokers are 5 times more likely to
develop lung cancer than non-smokers while cigarette
smokers are 20 times more likely to develop the disease.
Current pipe smokers are 14 times more likely to
develop larynx cancer than non-smokers while cigarette
smokers are 10 times more likely to develop the
disease.\6\
Sources: Disease Risks of Pipe, Cigar and Cigarette Use
\1\ The Word Health Organization. (2006). Tobacco: Deadly in any
form or disguise. Retrieved 11/26/07 from http://www.who.int/tobacco/
communications/events/wntd/2006/Tfi_
Rapport.pdf.
\2\ The International Agency for Research on Cancer Monograph
Volume 83. (2004). Tobacco Smoke and Involuntary Smoking. Retrieved 11/
26/07 from http://monographs.iarc.fr/ENG/Monographs/index.php.
\3\ National Cancer Institute. Cigars: Health Effects and Trends.
Smoking and Tobacco Control Monograph No. 9. Bethesda, MD: U.S.
Department of Health and Human Services, National Institutes of Health,
National Cancer Institute, NIH Pub. No. 98-4302, February 1998.
\4\ U.S. Department of Health and Human Services. The Health
Consequences of Smoking: Cancer. A Report of the Surgeon General.
Washington: U.S. Department of Health and Human Services, Public Health
Service, Office of Smoking and Health, 1982. DHHS Pub. No. (PHS) 82-
50179.
\5\ U.S. Department of Health, Education, and Welfare. Smoking and
Health. A Report of the Surgeon General. U.S. Department of Health,
Education, and Welfare, Public Health service, Office of the Assistant
Secretary for Health, Office on Smoking and Health, 1979. DHEW Pub. No.
(PHS) 7950066.
\6\ Henley, S.J., Thun, M.J., Chao, A., Calle, E.E. (2004)
Association between exclusive pipe smoking and mortality from cancer
and other diseases. Journal of the National Cancer Institute, 96(11).
______
Response to Written Questions Submitted by Hon. Frank R. Lautenberg to
Marvin E. Goldberg, Ph.D.
Question 1. The tobacco companies have claimed that smokers believe
that the word ``light'' refers to taste. Is that true? Or is this just
another device to seduce smokers into discarding care about their
health in pursuit of their addiction?
Answer.
The tobacco industry has advanced the ``taste'' of low tar/lights
cigarettes as the primary reason they are chosen by smokers.
When questioned about the role of this false and illusory
dimension of low tar/light smokers' responses are often
misleading.
When smokers are asked why they smoke light cigarettes, significant
numbers may respond that it is because of the ``taste.'' This is
understandable--they first experience the cigarette on their tongue and
in their mouth--the most apparent locus of taste. But research tells us
that ``taste'' is a good deal more than what we experience on our
tongue. Twenty years ago, the Coca Cola company was concerned about
losing market share among young cola drinkers to Pepsi Cola. Research
suggested that younger consumers appeared to prefer the slightly
sweeter taste of Pepsi. In response, Coca Cola developed a sweeter
version of their product and proceeded to extensively test market it in
blind taste tests across the country. Repeatedly and reliably in blind
taste tests, consumers indicated that they preferred the sweeter
version to the regular Coke. With that evidence in hand, Coke
introduced ``New Coke'' with the new, sweeter formula. What happened
next was shocking to Coke. Once the product they were drinking was
labeled Coke, that knowledge impacted how they evaluated what they
tasted--now they hated it. Within 3 months Coke had retreated and was
pushing its original formula ``Classic'' Coke again (Fournier 1999;
rev. 2001).
That taste is, at least in part, a function of how products are
portrayed/labeled and advertised has been carefully researched in the
context of ``field'' experiments with foods. In one such experiment,
the same lunch meals were sold in a university faculty cafeteria but
were labeled differently on different days. For example, on some days
one such meal was identified as ``Succulent Italian Seafood filet'' but
on other days merely as ``Seafood Filet.'' Those who bought and ate the
foods when they were described in an embellished way reported that: the
foods were more appealing to the eye; they tasted significantly better;
and after eating the meal they felt more ``comfortably full and
satisfied.'' (Wansink et al., 2004).
Interestingly, when desserts were labeled ``healthy'' (e.g.,
chocolate pudding vs. healthy chocolate pudding; apple crisp vs.
healthy apple crisp). they were rated as tastier. The researchers
reasoned, that as long as the dessert actually tasted good, consumers'
initially lower expectations regarding something labeled ``healthy''
would be disconfirmed; that is, they would have been surprised by the
good taste. Pleasantly surprised, the unexpected contrast between their
actual and expected experience would have led them to evaluate the
taste of the dessert more positively than someone who had seen the
dessert label without the adjective ``healthy;'' (Wansink et al.,
2004b).
Smokers of regular cigarettes who switched to what they perceived
to be ``healthier,'' light cigarettes, would have had a parallel
disconfirming experience. These smokers would have expected light
cigarettes to yield less taste (along with less tar). However, given
the compensatory smoking behavior described in my prepared testimony,
light cigarettes yielded just as much tar/taste. As a result, the
pleasantly surprised light cigarette smokers were quick to focus on the
taste as the apparent motivation for smoking lights.
As with the food experiments cited above, if questioned, smokers
are almost certainly not going to be aware of how the label ``light''
(and hence the inference ``healthier'') influence their perceptions of
the cigarette's taste. They revert to the more proximal evidence--what
they believe they experience--on their tongues--and their answer as to
why they smoke the cigarette they do smoke may reflect that logic.
In two court cases where both Philip Morris and R.J. Reynolds sued
Loews/Lorillard, it was evident that these tobacco companies do
not believe that smokers are primarily guided by taste in
selecting light cigarettes.
The plaintiff firms, Philip Morris and R.J. Reynolds argued that in
a comparative taste test, smokers reported that the Lorillard low tar
brand tasted better than the comparison brand only if they were first
told that Lorillard's brand had lower tar than either the R.J. Reynolds
or the Philip Morris comparison brand. When (other) smokers made the
same comparative taste test without being reminded of the relative tar
levels, their taste preferences were very different.
The basis of both suits was the approach taken in two parallel
Lorillard surveys asking smokers to compare the taste of its low tar
``Triumph'' to R.J. Reynolds' Winston Lights and to Philip Morris'
Merit. Subsequent Lorillard advertising claimed that the preponderance
of the smokers tested appeared to prefer the taste of Triumph over
Winston Lights and that it was the ``National Taste Test Winner'' over
Merit. Both plaintiffs Philip Morris and R.J. Reynolds argued that
these claims were deceptive inasmuch as the taste question posed in
each survey had, as a preface, a reminder of the lower tar scores for
Triumph relative to those for Winston Light and for Merit. Each of the
plaintiff companies ran a test of their own, where the tar scores for
the two brands were not revealed and the resulting taste preferences in
their research were very different.
These comparisons suggest how much of what is ostensibly labeled as
``taste'' is influenced by other factors; in this case, the salience of
how ``light''/low tar a cigarette might be. In effect, the plaintiff
firms acknowledge that where smokers are reminded of tar yields, the
relative tar levels and not taste are the determining factors in the
smokers' evaluations of the cigarettes; (R.J. Reynolds Tobacco Company,
Plaintiff v. Loew's Theatres, Inc; No. 80 Civ 4197 (RWS) United States
District Court for the Southern District of New York; 511 F. Supp.867;
1980 U.S. Dist. LEXIS 16738; 210 U.S.P.Q. (BNA) 291; October 24, 1980;
Philip Morris Incorporated, Plaintiff v. Loew's Theatres, Inc.; No. 80
Civ. 4082 (RWS) United States District Court for the Southern District
of New York; 511 F. Supp.855; 1980 U.S. Dist. LEXIS 12554 July 26,
1980).
Of course, for decades the tobacco companies have used low tar/
lightness as a critical way of selling cigarettes and have made that
dimension very salient for smokers. Following the logic presented
above, it is reasonable to expect that when respondents are asked, they
may say that ``taste'' is the reason they prefer light/low tar
cigarettes. Note, however, that following the logic of the two court
cases discussed above, the causal sequence is, in fact, reversed. In
actuality, it is because their cigarettes are light (and advertising
and promotion continue to make that dimension salient) that smokers say
they prefer the taste. They would not say so for the same cigarette, if
its ``lightness'' was not made salient.
Promoting light cigarettes as extensions of major brands and aligning
them with the mother brand (e.g., Marlboros, Marlboro Lights),
helped shaped smokers' perceptions of their taste.
At the same time as they developed light cigarettes that allowed
for compensation, the tobacco companies learned how to boost the
perceived strength of the taste, by using their advertising to shape
the images associated with Lights. The companies viewed the taste
dimension much as a ``Rorschach ink blot test.'' Light cigarette
smokers could be induced to see/taste in the cigarettes what the
companies wanted them to see/taste.
. . . [I]t is almost impossible to know if the taste smokers
talk about is something which they, themselves attribute to a
cigarette or just a ``play-back'' of some advertising
messages;'' (Marketing and Research Counselors, Inc, 1975, p.
2).
The industry further understood that they could ``borrow'' some of
the brand equity established for their primary (regular) brands such as
Marlboro Reds and Camels for the benefit of the light cigarettes. They
did so by creating brand extensions--Marlboro Lights, Camel Lights etc.
and using the same advertising themes and imagery that had been so
successful to shape the imagery associated with the light extensions.
That this strategy could affect smokers perceptions of the light
cigarettes taste, is recognized in their internal documents.
. . . [O]ther free standing low tar brands such as Kent,
Vantage, Carlton, etc. were perceived to be weaker and have
less taste than the line extension low tars: like Marlboro
Lights, Winston Lights, Camel Lights. Apparently these line
extension low tars share the taste heritage of their parent
full flavor brands; (Philip Morris 1990, pp. 13-14; emphasis
added).
When R.J. Reynolds sought to develop a low yield cigarette in 1976,
they recognized the image problem associated with low-yield cigarettes
and set out to address it:
What we want is to portray the feeling and image projected by
Marlboro and Kool advertising on a Vantage/Merit type of
cigarette. In other words, put ``balls'' (two of them) on a low
``tar'' and nicotine cigarette and position. (Hind et al.,
1976, p. 63).
Question 2. If there were no cigarettes labeled as ``light,'' would
the tobacco companies just come up with another word to send the same
deceptive message to smokers?
Answer. Forty-three countries, including Canada, Brazil, and the 27
countries of the European Union have banned the misleading terms such
as ``light'' and ``mild'' (Backinger 2007). It would be useful to
canvas the experiences these countries have had with the tobacco
industry's efforts to do an ``end-run'' around this prohibition. Casual
observation on a trip to Canada suggests that the companies are
substituting other words that will likely be used by smokers to
distinguish between lights and regulars. If the same is true in other
countries that have banned the use of ``light'' and ``mild'' it
suggests that the advantages gained from this step are likely to be
limited.
One conclusion that ought to be drawn from the reasoning presented
above is that the particular descriptors on the package are not
necessarily the critical factor. Rather, the real issue is the question
of the ultimate effect of any intended legislation. I have attached a
paper by Kropp and Halpem-Fisher (2004) which I would like to go into
the record. It indicates that, like adults, adolescents today believe
that light cigarettes represent a reduced threat to smokers health
relative to regular cigarettes. The goal of any legislation should be
to turn this around. To this end, the tobacco companies should be
required to develop a ``corrective advertising'' campaign advising
smokers of the lack of any differences for their health between light
and regular cigarettes. This campaign should continue as long as
surveys of smokers show that the vast majority understand there is no
difference in the risk to health from light versus regular cigarettes.
While calling for corrective advertising may be more difficult
legislatively, it is likely to be the most effective way to achieve the
desired objective.
References
Backinger, Cathy, ``Research Findings Concerning So-Called Low-Tar
or `Light' Cigarettes,'' Presentation before the Senate Commerce,
Science and Transportation Committee; U.S. Senate, Nov. 13, 2007,
available at http://hhs.gov/asl/testify/2007/11/t20071113a.html
(accessed Nov. 24, 2007).
Kropp, Rhonda and Bonnie, L. Halpern-Felsher (2004) ``Adolescents'
Beliefs About the Risks Involved in Smoking `light' Cigarettes,''
Pediatrics 114(4) 445-451.
______
Pediatrics--Official Journal of the American Academy--Vol. 114 No. 4,
October 2004, pp. e445-e451
Adolescents' Beliefs About the Risks Involved in Smoking ``Light''
Cigarettes
By Rhonda Y. Kropp, B.S.N., M.P.H. and Bonnie L. Halpern-Felsher, Ph.D.
ABSTRACT. Background. Light cigarettes have been marketed by the
tobacco industry as being a healthier smoking choice, a safe
alternative to cessation, and a first step toward quitting smoking
altogether. Research, however, has failed to show a reduction in
smoking-related health risks, an increase in rates of smoking
cessation, a decrease in the amount of carbon monoxide or tar released,
or a reduction in the rates of cardiovascular disease or lung cancer
associated with light cigarette use, compared with regular cigarette
use. Nevertheless, more than one-half of adolescent smokers in the
United States smoke light cigarettes. This study is the first to
investigate adolescents' perception of the risks associated with
smoking light cigarettes, as well as adolescents' attitudes and
knowledge about the delivery of tar and nicotine, health risks, social
effects, addiction potential, and ease of cessation with light
cigarettes, compared with regular cigarettes.
Design. Participants were 267 adolescents (mean age: 14.0 years)
who completed a self-administered questionnaire during class time.
After reading scenarios in which they imagined that they smoked regular
or light cigarettes, participants estimated the chances that they would
personally experience 7 smoking-related health risks and 3 addiction
risks. Participants also responded to 14 items concerning their
attitudes and knowledge about light cigarettes versus regular
cigarettes.
Results. Participants thought that they would be significantly less
likely to get lung cancer, have a heart attack, die from a smoking-
related disease, get a bad cough, have trouble breathing, and get
wrinkles when smoking light cigarettes, compared with regular
cigarettes, for the rest of their lives. Furthermore, when participants
were asked how long it would take to become addicted to the 2 cigarette
types, they thought it would take significantly longer to become
addicted to light versus regular cigarettes. Adolescents also thought
that their chances of being able to quit smoking were higher with light
versus regular cigarettes. Similarly, when participants were asked how
easy it would be to quit smoking the 2 cigarette types, they thought it
would be significantly easier for them to quit smoking light cigarettes
than regular cigarettes. Adolescents agreed or strongly agreed that
regular cigarettes deliver more tar than light cigarettes and that
light cigarettes deliver less nicotine than regular cigarettes.
Conclusions. Overall, the results of this study show that
adolescents hold misperceptions in both their personal risk estimates
and their general attitudes about the health risks, addictive
properties, and ease of cessation associated with light cigarettes.
With a variety of light and ultra light cigarettes on the market,
adolescents are led to think that there is a progression of safety
levels to choose from when deciding which cigarettes to smoke. This
illusion of control over health outcomes contributes to an
underestimation of risks associated with smoking light cigarettes and
supports these misperceptions. These results are of concern, given
evidence suggesting that, if adolescents think they are less vulnerable
to smoking-related health risks (i.e., lung cancer), then they are more
likely to initiate smoking. Furthermore, there is evidence that
adolescents are not fully aware of the addictive nature of cigarettes
and therefore think that they can experiment with smoking during
adolescence without becoming addicted or experiencing any health
consequences. The data presented here support concerns regarding
smoking addiction; adolescents might be even more inclined to smoke
light cigarettes to delay addiction. Without correct information about
light cigarettes, adolescents are unable to make informed decisions
about their smoking behaviors. The findings presented here strongly
suggest that healthcare practitioners need to talk to their adolescent
clients not only about the overall risks of smoking but also about the
specific risks associated with smoking light cigarettes and other
tobacco varieties, including the potential for addiction and long-term
health consequences. Information shared with adolescents about light
cigarettes, both individually by healthcare practitioners and at the
population level via counter-advertising campaigns, may be successful
in changing current misperceptions, and ultimately light cigarette
smoking patterns, among youth.
Light cigarettes were introduced in the 1950s in response to
growing public concern about the health effects of smoking. Light
cigarettes have been marketed by the tobacco industry as being a
healthier smoking choice, a safe alternative to cessation, and a first
step toward quitting smoking altogether. Research, however, has failed
to show a reduction in smoking-related health risks,\1\ \2\ an increase
in rates of smoking cessation,\3\ \4\ a decrease in the amounts of
carbon monoxide,\2\ \5\ \6\ or tar \2\ released, or a reduction in the
rates of cardiovascular disease or lung cancer \1\ \7\ associated with
light cigarette use, compared with regular cigarette use. Nevertheless,
a recent national survey of smokers found that 58.5 percent of adult
smokers and 52.8 percent of adolescent smokers reported using light
cigarettes.\8\
Despite clear data showing that light cigarettes are not a safe
alternative to smoking, adults in the United States harbor
misperceptions about the health risks associated with smoking light and
ultra light cigarettes,\2\ \9\-\13\ with a large proportion
of adult smokers thinking that such cigarettes deliver less tar and
nicotine, produce milder sensations, reduce the health risks associated
with smoking, and assist with smoking cessation.\10\ \11\ No research
has explored attitudes, beliefs, and perceptions of risk regarding
light cigarettes among adolescents. If adolescents, like adults, think
that light cigarettes are less risky to their health and are easier to
quit than regular cigarettes, then they too may be more willing to try
and to continue smoking these perceived ``safer'' cigarettes. This
assertion is supported by theories indicating that perceptions of risk
are related to engagement in both health-compromising and health-
promoting behaviors.\14\-\22\
The present study addresses this gap in the literature by exploring
adolescents' perceptions of the risks associated with smoking light
cigarettes. In addition, we assessed adolescents' attitudes and
knowledge about the delivery of tar and nicotine, health risks, social
effects, addiction potential, and ease of cessation when smoking light
cigarettes, compared with regular cigarettes. We hypothesized that
adolescents would perceive light cigarettes to be less harmful to their
health, to be less addictive, and to deliver less tar and nicotine than
regular cigarettes. If these assertions are supported, than efforts to
prevent adolescents' tobacco use must include specific communication
about the harmful nature of light cigarettes, in addition to all
cigarette and tobacco varieties.
Methods
Participants
Participants were 267 adolescents (mean age: 14.0 years; SD: 1.49
years) participating in a larger longitudinal study on the relationship
between risk perceptions and tobacco use. The participants were
ethnically diverse, with 56.8 percent of the participants describing
themselves as white/non-Hispanic, 18.5 percent as Asian, 18.5 percent
as Hispanic or Latino, 2.3 percent as Pacific Islander, 1.2 percent as
African American, 1.5 percent as American Indian/Alaskan Native, and
1.2 percent as other. Participants' mothers' education, on average, was
high, with 17.9 percent of the mothers having a professional degree,
6.1 percent having some education after college, 25.1 percent having a
4-year college degree, 20.5 percent having at least some college
education, and 19.4 percent having a high school degree or less; 9.9
percent of the participants reported that they did not know their
mothers' education.
Participant Recruitment
Participants in the larger study were recruited from 2 northern
California public high schools (schools A and B), during their 9th
grade year, to take part in a longitudinal study of tobacco beliefs and
smoking behaviors. Participants in school A were recruited in autumn
2001, and those in school B were recruited in autumn 2002. Interested
participants signed the adolescent assent form, and parents signed the
parental consent form. Of the 790 students who received consent packets
(302 from school A and 488 from school B), 418 (53 percent) returned
completed consent forms (79.5 percent and 36.5 percent consent rate for
schools A and B). Of the 790 students who received consent packages, a
total of 395 adolescents completed the baseline survey, for an overall
response rate of 50 percent (75.5 percent response rate for school A
and 34.2 percent response rate for school B).
Perceptions of light cigarettes were assessed in spring 2003, which
corresponded to the second (school B, 9th grade) and fourth (school A,
10th grade) rounds of data collection; therefore, only those rounds of
data are reported in this article. Overall, 200 participants from
school A completed the fourth-round survey and 152 participants from
school B completed the second-round survey, for a total of 352
participants (89.4 percent retention rate). Only participants who
indicated that they had heard of light cigarettes were included in the
analyses for the current report (n = 267), accounting for 75.8 percent
of the total sample. There were no significant differences between the
2 schools with respect to gender or age at the time of recruitment;
however, significant differences were found with respect to ethnicity
(X2 = 57.3, df = 3, P < .001) and mother's education (X2 =
19.7, df = 8, P < .05), with 1 school (school B) having fewer white/
non-Hispanic students and lower levels of mothers' education. However,
we did not find any significant differences in the results for these 2
schools or any differences based on age; therefore, data for the 2
schools were combined.
Procedures
Participants completed a self-administered questionnaire during
class time. The researchers explained the instructions for completing
the survey and remained available to answer questions that arose during
administration. Refreshments were provided for all participants.
Participants in school A also received a movie gift certificate,
whereas the administrators and teachers in school B received school
supply money to compensate for their efforts in the study. The study
received approval from the University's institutional review board.
Measures
Demographic Features
Participants provided information about their age, grade, gender,
ethnicity, and mother's level of education.
Smoking Behaviors
Participants were asked about the number of times they had ``smoked
a few puffs of a cigarette'' in their entire lives, with responses
being made on a 5-point scale (i.e., none, 1 time, 2-5 times, 6-10
times, or > 10 times). cents
Chance Estimates of Personally Experiencing Smoking-Related Risks
Participants read 2 scenarios about smoking cigarettes in general
(proxy for regular cigarettes) and then 2 scenarios about smoking light
cigarettes. The scenarios were identical except for the specification
of light cigarettes. The first scenario asked participants to imagine
that they had just begun smoking cigarettes (i.e., ``Imagine that you
just began smoking. You smoke 2 or 3 [light] cigarettes each day.
Sometimes you smoke alone, and sometimes you smoke with friends.'').
After reading this scenario, participants estimated the chances that
they would personally experience 5 smoking-related risks (Tables 1 and
2).
Table 1.--Comparison of Adolescents' Estimates of Personal Risk and
Benefit With Regular Versus Light Cigarettes: Mean-Level Analyses
------------------------------------------------------------------------
Risk estimates, mean (SD) t Value
-------------------------------------------------
Regular
cigarettes Light cigarettes
------------------------------------------------------------------------
Short-term cigarette
use
Risks
Smell like an 79.81 (27.29) 79.04 (26.66) 0.822
ashtray
Get a bad 71.93 (28.17) 69.97 (28.24) 1.56
cough from
smoking
Have trouble 71.56 (28.59) 71.20 (27.85) 0.325
catching your
breath
Have many 58.09 (30.42) 60.07 (30.62) 1.52
really bad
colds
Have bad 78.43 (29.61) 75.64 (29.74) 2.16 *
breath
Addiction
Become 69.07 (30.30) 66.98 (30.13) 1.32
addicted to
cigarettes
Still be 57.32 (32.42) 59.76 (31.18) 1.45
smoking in 5
y
Be able to 45.82 (32.98) 50.19 (32.20) 2.53
How long will 2.98 (1.18) 3.17 (1.15) 3.73
it take to
become
addicted
How easy will 3.64 (1.08) 3.41 (1.06) 4.59
it be for you
to quit
smoking ||
Long-term cigarette
use
Risks
Get lung 73.04 (25.22) 70.89 (27.03) 1.79
cancer
Die from lung 68.80 (26.92) 68.35 (26.87) 0.356
cancer
Get a bad 75.52 (25.31) 74.06 (25.60) 1.45
cough from
smoking
Have trouble 76.36 (24.16) 74.69 (26.62) 1.50
catching your
breath
Have a heart 67.66 (25.51) 65.15 (26.35) 2.12 *
attack
Get wrinkles 79.74 (24.13) 78.44 (25.50) 1.159
on your face
Die from a 73.13 (25.36) 70.53 (26.89) 2.30 *
smoking-
related
disease
------------------------------------------------------------------------
*P < .05; P < .01; P < .001; P < .10.
Response scale for this question: will not happen (1); 1 month (2); 1
to 6 months (3); 7 to 11 months (4); 1 to 2 years (5); 3 to 4 years
(6); 5 years (7).
|| Response scale for this question: very easy (1); somewhat easy (2); a
little easy (3); not very easy (4); not at all easy (5).
Table 2.--Comparison of Adolescents' Estimates of Personal Risk and
Benefit With Regular Versus Light Cigarettes: Individual-Level Analyses
------------------------------------------------------------------------
Percent of participants indicating
---------------------------------------------------
More likely for More likely
regular No difference for light
cigarettes cigarettes
------------------------------------------------------------------------
Short-term cigarette
use
Risks
Smell like 23.9 55.7 20.5
an ashtray
Get a bad 33.2 41.7 25.1
cough from
smoking
Have trouble 27.7 44.6 27.7
catching
your breath
Have many 26.0 41.6 32.4
really bad
colds
Have bad 31.9 48.7 19.4
breath
Addiction
Become 34.4 37.4 28.2
addicted to
cigarettes
Still be 31.8 34.1 34.1
smoking in
5 y
Be able to 23.7 38.5 37.8
quit
smoking
How long 8.4 66.2 25.5
will it
take to
become
addicted
How easy 31.1 60.6 8.3
will it be
for you to
quit
smoking
Long-term cigarette
use
Risks
Get lung 29.8 46.6 23.7
cancer
Die from 29.2 43.1 27.7
lung cancer
Get a bad 33.0 45.6 21.5
cough from
smoking
Have trouble 29.9 46.4 23.8
catching
your breath
Have a heart 36.6 40.1 23.3
attack
Get wrinkles 31.2 48.5 20.4
on your
face
Die from a 40.6 38.3 21.1
smoking-
related
disease
------------------------------------------------------------------------
Next, participants were asked to imagine that they continued to
smoke cigarettes for the rest of their lives (ie, ``Now imagine that
you continued to smoke 2 or 3 [light] cigarettes each day for the rest
of your life.''). After reading this scenario, participants estimated
the chances that they would personally experience 7 smoking-related
health risks (Tables 1 and 2).
Participants' chance estimates were provided as any percentage
between 0 percent and 100 percent. The quantitative response scale (0-
100 percent) was chosen over scales that use lexical probability terms
(such as ``likely'' and ``probably'') to estimate risk because of the
great variability in meaning ascribed to these terms by
adolescents.\23\-\25\
Estimates of Addiction
After reading the scenario concerning short-term cigarette use (as
described above), participants estimated the chances (0-100 percent
scale) that they would personally experience 3 addiction risks (Tables
1 and 2). Participants were also asked about the ease of cessation (ie,
``If you smoke 2 or 3 [light] cigarettes each day, how easy will it be
for you to quit smoking?''), with responses being made on a 5-point
scale ranging from ``very easy'' to ``not at all easy.'' Finally,
participants reported on the length of time until addiction (ie, ``If
you smoke 2 or 3 [light] cigarettes each day, how long do you think it
will take until you become addicted to [light] cigarettes?''), with
responses being made on a 7-point scale ranging from ``will not
happen'' to ``5 or more years.''
Attitudes and Knowledge About Light Cigarettes
Participants responded to 14 items concerning their attitudes and
knowledge about light cigarettes versus regular cigarettes in 4
categories, ie, delivery (amount of tar and nicotine; 2 items), health
risks (5 items), perceived social outcomes (5 items), and addiction/
cessation (2 items) (Table 3). Participants responded to each item on a
4-point scale, ranging from ``strongly agree'' to ``strongly
disagree.'' Participants also had the opportunity to indicate that they
did not know how to answer each question.
Table 3.--Comparison of Adolescents' Attitudes and Knowledge Regarding Regular and Light Cigarettes
----------------------------------------------------------------------------------------------------------------
Percent of participants indicating
Statement on regular versus light ---------------------------------------------------------
cigarettes Mean (SD) * Strongly Strongly Don't
agree Agree Disagree disagree know
----------------------------------------------------------------------------------------------------------------
Delivery
Regular cigarettes deliver more 2.04 (0.77) 18.8 45.5 13.9 4.1 17.7
tar
Light cigarettes deliver less 2.54 (0.87) 6.9 33.1 23.8 11.9 24.2
nicotine
Health risks
Regular cigarettes are more 2.60 (0.83) 6.9 28.4 33.3 10.7 20.7
likely to cause a heart attack
Regular cigarettes are more 2.57 (0.87) 8.4 28.7 29.9 11.5 21.5
likely to cause lung cancer
Regular cigarettes are more 2.66 (0.86) 5.7 29.7 28.9 14.1 21.7
likely to cause a bad cough
Light cigarettes are more likely 2.90 (0.78) 4.6 13.4 43.5 14.9 23.7
to cause trouble catching your
breath
Regular cigarettes are less 3.12 (0.83) 4.5 8.0 36.0 25.8 25.8
likely to cause wrinkles on the
face
Perceived social benefits
Smoking light cigarettes looks 3.42 (0.74) 2.7 5.4 32.2 47.7 12.0
cooler
Smoking light cigarettes makes 3.04 (0.83) 4.2 8.8 33.5 20.0 33.5
you thinner
Smoking regular cigarettes is 2.86 (0.89) 6.8 20.5 36.4 22.3 14.0
more likely to make you
smelllike an ashtray
Smoking a regular cigarette makes 2.84 (0.88) 5.7 14.1 30.9 14.9 34.4
you feel more relaxed
Smoking light cigarettes looks 3.21 (0.81) 4.2 8.3 37.9 34.8 14.8
more grown-up
Cessation
It is easier to quit smoking 2.71 (0.86) 6.4 25.3 33.2 15.1 20.0
light cigarettes
Regular cigarettes are more 2.69 (0.90) 6.9 28.7 28.0 17.2 19.2
addictive
----------------------------------------------------------------------------------------------------------------
* Response scale for this question: strongly agree (1), agree (2), disagree (3), strongly disagree (4).
Participants could also indicate if they did not know.
Results
Preliminary Analyses
Before conducting the main study analyses, we conducted analyses to
determine whether perceptions of light versus regular cigarettes varied
according to smoking experiences. We had only 84 participants who had
ever tried a cigarette, even a puff, and 61 adolescents who reported
having ever smoked a light cigarette. Furthermore, the number of times
participants had tried a cigarette varied greatly, with 18 adolescents
having tried a cigarette 1 time, 24 adolescents having tried a
cigarette 2 to 5 times, 11 adolescents having tried a cigarette 6 to 10
times, and 31 adolescents having smoked > 10 times. Therefore, the
sample sizes with variations in smoking experiences were too small to
allow a meaningful analysis according to smoking group. However,
because perceptions of risk vary with the number of times an adolescent
has smoked,\21\ we did examine the correlation between the number of
times the adolescent had smoked and differences in perceptions of light
versus regular cigarettes. None of these correlations was significant;
therefore, data were combined across smoking experiences.
Perceptions of Smoking-Related Risks With Light Versus Regular
Cigarettes
Paired t tests were used to examine our hypothesis that adolescents
perceive less risk if they smoke light cigarettes, compared with
regular cigarettes. Given the literature showing that adults perceive
light cigarettes as less harmful and addictive than regular cigarettes
and our directional hypothesis that adolescents would demonstrate
similar if not greater bias, we used 1-tailed, directional t tests.
As indicated in Table 1, adolescents did not perceive a significant
difference in the chances of experiencing 4 of the risks (i.e., bad
cough, trouble catching breath, bad colds, and smell like an ashtray)
with short-term use of regular versus light cigarettes. Adolescents did
think the risk of having bad breath was higher with regular versus
light cigarettes (P = .032). Importantly, participants did think that
they would be significantly less likely to get lung cancer (P = .075),
have a heart attack (P = .036), and die from a smoking-related disease
(P = .022) when smoking light cigarettes versus regular cigarettes for
the rest of their lives. No differences were found in chance estimates
of dying from lung cancer, getting a bad cough, having trouble
breathing, or getting wrinkles with the 2 cigarette types.
Perceived risk of becoming addicted and still smoking in 5 years
did not differ significantly between regular and light cigarettes in
the short-term tobacco use scenario. However, when participants were
asked about their perceived ability to quit smoking the 2 cigarette
types, they thought that their chance of being able to quit smoking was
greater with light versus regular cigarettes (P = .012). Adolescents
also thought it would take significantly longer to become addicted to
light versus regular cigarettes (P < .0001) (Table 1). Similarly, when
participants were asked how easy it would be to quit smoking the 2
cigarette types, they thought that it would be significantly easier for
them to quit smoking light cigarettes than regular cigarettes (P <
.0001) (Table 1).
Because many of the results were not significant, we conducted a
power analysis to confirm that we had adequate power to detect
differences in perceptions of light versus regular cigarettes. With an
a of .05 for a 1-tailed t test, we found that, with a sample size of
267, we had adequate power of .74 to detect small effects.\26\
Therefore, we do not think that the lack of significance was
attributable to sample size.
It was also important to determine the actual percentage of
participants who incorrectly thought that regular cigarettes are more
harmful and addictive than light cigarettes. Therefore, each individual
was assigned a score for each outcome, corresponding to whether they
thought the outcome was more likely to occur with regular cigarettes
(+1) or with light cigarettes (-1) or was equally likely to occur with
regular or light cigarettes (0). As shown in Table 2, while > 40
percent of participants on average gave equal estimates of risk
outcomes (bad cough, trouble catching breath, bad colds, and bad
breath) for regular and light cigarettes, between 26 percent and 33
percent thought that these outcomes were more likely to occur when
beginning to smoke regular cigarettes, compared with light cigarettes,
and between 19 percent and 32 percent viewed these outcomes as more
likely with light cigarettes.
A large proportion of the participants (between 29 percent and 41
percent) thought that they were more likely to experience a number of
negative health outcomes (lung cancer, heart attack, death from a
smoking-related disease, bad cough, trouble breathing, and getting
wrinkles) if they smoked regular cigarettes, compared with light
cigarettes, for the rest of their lives. Importantly, 40.6 percent
thought that they were more likely to die of a smoking-related disease
with regular cigarettes than with light cigarettes, whereas only 21.1
percent thought that the risk was higher for light cigarettes and 38.3
percent did not perceive a difference in risk between the 2 cigarette
types. A large percentage of the participants thought that addiction
was less likely with light cigarettes. For example, 34.4 percent
thought that they were more likely to become addicted to regular
cigarettes than to light cigarettes, and 37.8 percent thought that it
would be easier for them to quit smoking light cigarettes than regular
cigarettes (Table 2).
Attitudes and Knowledge About Light Cigarettes
Participants were asked how strongly they agreed or disagreed with
a series of 14 statements comparing regular and light cigarettes in
terms of the amounts of tar and nicotine delivered, health effects,
social benefits, and addictive properties. Table 3 shows the average
scale responses for each item, as well as the proportions of
participants who strongly agreed, agreed, disagreed, and strongly
disagreed with each statement. In terms of delivery, 64.3 percent of
the adolescents agreed or strongly agreed that regular cigarettes
deliver more tar than light cigarettes and 40.0 percent thought that
light cigarettes deliver less nicotine than regular cigarettes.
Adolescents had similar misperceptions about the health risks
associated with light cigarettes, with a large proportion of
participants agreeing or strongly agreeing that smoking regular
cigarettes is more likely to cause lung cancer (37.1 percent), a heart
attack (35.3 percent), and a bad cough (35.4 percent), compared with
smoking light cigarettes; however, between 41 percent and 44 percent of
the adolescents either disagreed or strongly disagreed with these
statements. The majority of adolescents disagreed or strongly disagreed
that they would look cooler (79.9 percent), become thinner (53.5
percent), or look more grown-up (72.7 percent) with light cigarettes,
although almost 13 percent agreed or strongly agreed with these
statements. A significant proportion of adolescents demonstrated
misperceptions about the addictive properties and ease of cessation
with light cigarettes, with 35.6 percent and 31.7 percent agreeing or
strongly agreeing that regular cigarettes are more addictive than light
cigarettes and that light cigarettes are easier to quit than regular
cigarettes, respectively. Between 45 percent and 48 percent of the
adolescents disagreed or strongly disagreed with those statements. It
should be noted that, on average, 22 percent of the participants stated
that they did not know the answers to each of these knowledge
questions.
Discussion
Light cigarettes, although marketed as a healthy alternative to
regular cigarettes and as an aid to quitting smoking, in fact do not
reduce the health risks associated with smoking \1\ \2\ and do not
increase rates of smoking cessation.\3\ \4\ Despite these facts, more
than one-half of adolescent smokers in the United States smoke light
cigarettes. The current study is the first to examine whether
adolescents are aware of the true risks of smoking light cigarettes or
whether their beliefs have been influenced by tobacco industry claims
that light cigarettes are less harmful. Overall, the results of this
study show that adolescents hold misperceptions in both their personal
risk estimates and their general attitudes about the health risks,
addictive properties, and ease of cessation associated with light
cigarettes. These findings are similar to those outlined in studies
with adult samples \2\ \9\-\13\ and expand on those results
by assessing perceived risk for a number of short- and long-term
smoking outcomes in an adolescent population.
On average, adolescents in this study thought that long-term use of
light cigarettes was less likely to cause lung cancer, heart attacks,
and death from a smoking-related disease than was use of regular
cigarettes. Adolescents also thought it would take longer to become
addicted to light cigarettes and it would be easier to quit smoking
light cigarettes, compared with regular cigarettes. Given that 64.3
percent and 40.0 percent of adolescents incorrectly thought that
regular cigarettes deliver more tar and nicotine, respectively, than
light cigarettes, these misperceptions about the health and cessation
properties of light cigarettes are not surprising. With a variety of
light and ultra light cigarettes on the market to choose from,
adolescents are led to think that there is a progression of safety
levels from which to choose when deciding which cigarettes to smoke.
This illusion of control over the health outcomes contributes to an
underestimation of risks associated with smoking light cigarettes and
supports these misperceptions.\27\
Although some of the adolescents in this study were aware of the
health risks and addictive properties associated with light cigarettes,
the data clearly showed that 22 percent of the adolescents were
uncertain regarding the differences between regular and light
cigarettes and between 25 percent and 35 percent of the adolescents
thought that health risks were more likely with regular cigarette use
than with light cigarette use. These results are of concern, given
evidence suggesting that, if adolescents think they are less vulnerable
to smoking-related health risks (i.e,, lung cancer), then they are more
likely to initiate smoking.\14\-\22\ Furthermore, there is
evidence that adolescents are not fully aware of the addictive nature
of cigarettes and thus think that they can experiment with smoking
during adolescence without becoming addicted or suffering any health
consequences.\22\ \27\ The data presented here support concerns
regarding smoking addiction; adolescents might be even more inclined to
smoke light cigarettes to delay addiction.
Adolescents' misperceptions about the health and cessation
properties of light cigarettes mirror marketing by the tobacco
industry. In fact, it has been shown that adolescent' smoking
intentions \28\ and behavior \29\ are heavily influenced by the
multimedia smoking campaigns launched by the tobacco industry. This is
supported in part by our results showing significant differences in
risk perceptions for light versus regular cigarettes in smoking
outcomes most countered by pro-tobacco campaigns marketing light
cigarettes (e.g., healthier or a first step to cessation), whereas
adolescents perceived less difference in outcomes not focused on by
tobacco media (e.g., cough and wrinkles), although the effects of media
exposure were not specifically evaluated in this study.
Healthcare practitioners' efforts to dispel adolescents' inaccurate
beliefs about light cigarettes may be informed by the success of light
cigarette counter-advertising, which has been shown to be effective in
changing knowledge \30\-\33\ and intentions to quit smoking
\31\ \33\ among adults. Interestingly, a limited number of studies
suggest that messages that focus on dispelling myths about the
sensation of light cigarettes (``feel milder,'' ``feel smoother,'' or
``less harsh'') may be more effective than those providing factual
information about tar and nicotine delivery, blocked vents, or health
outcomes related to smoking light cigarettes among adults.\32\ \33\
A number of study limitations need to be discussed. First,
questions concerning personal risk estimates did not ask specifically
about regular cigarettes but instead asked about cigarettes in general.
These general cigarette questions were juxtaposed with questions
specifically about light cigarettes and were therefore treated as a
proxy for questions about regular cigarettes. However, if some
adolescents interpreted ``cigarettes'' as other than regular
cigarettes, then they would likely have been considering light
cigarettes when answering these questions, which would result in an
underestimation rather than overestimation of perceived risk
differences. Second, the order of the questioning about regular and
light cigarettes was not counterbalanced. The results were consistent
with the adult literature on light cigarettes and with hypotheses that
adolescents perceive light cigarettes as less harmful and addictive.
Therefore, we do not think that participants' responses were influenced
by the order of the questions, although we cannot be certain. Third,
because of the small numbers of smokers and light cigarette smokers in
this sample, we were unable to explore differences in attitudes and
risk perceptions between smokers and nonsmokers or between light
cigarette smokers and nonsmokers. Such analyses have yielded
interesting results in studies of adults,\11\ and similar exploration
among adolescents is needed. Last, the cross-sectional nature of this
analysis did not allow investigation of potential links between risk
perceptions, attitudes, and smoking initiation, cessation, or cigarette
brand choices.
Conclusions
This study has demonstrated that adolescents harbor misperceptions
about the health risks, addictive properties, and ease of cessation
associated with light cigarettes. Such misperceptions have the
potential to influence adolescents' intentions to initiate and quit
smoking, thereby increasing the number of adolescent smokers in the
United States. Without correct information about light cigarettes,
adolescents are unable to make informed decisions about their smoking
behaviors. The findings presented here strongly suggest that healthcare
practitioners need to talk to their adolescent clients not only about
the overall risks of smoking but also about the specific risks
associated with smoking light cigarettes and other tobacco varieties,
including the potential for addiction and long-term health
consequences. Information shared with adolescents about light
cigarettes, both individually by healthcare practitioners and at the
population level via counter-advertising campaigns, may be successful
in changing current misperceptions, and ultimately light cigarette
smoking patterns, among youths.
Acknowledgments
This research was supported in part by grants awarded to B.L.H-F.
from the Tobacco-Related Disease Research Program, Office of the
President, University of California (grant 9K-0072), the University of
California, San Francisco, Academic Senate Committee on Research, and
the Raschen-Tiedenann Fund from the Research Evaluation and Allocation
Committee, School of Medicine, University of California, San Francisco.
We gratefully acknowledge the contributions of Michael Biehl,
Tricia Michels, Jodi Cornell, Holly Sigler, Eric Peterson, Dr. Jeanne
Tschann, and 2 anonymous reviewers. We also thank Dr. Gary Giovino and
Dr. Michael Cummings for kindly sharing their data on the prevalence of
light cigarette use in the United States and Jun Yang for performing
the analyses of the National Household Survey on Drug Abuse data. We
are also grateful to all of the study participants and their parents,
as well as the schoolteachers and school administrators who contributed
to this study.
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______
Prepared Statement of R.J. Reynolds Tobacco Co.
R.J. Reynolds Tobacco Co. is pleased to provide comments for the
Committee's hearing on the accuracy of the Federal Trade Commission's
(FTC) ``tar'' and nicotine rating system for cigarettes.
R.J. Reynolds, the FTC and the public health community agree that
the FTC test does not and cannot predict the actual amount of ``tar''
and nicotine an individual smoker receives. It is widely accepted that
machine test yields based upon a single smoking regime, like that
prescribed by the FTC Method, do not equate to what an average consumer
obtains from smoking.
According to the 1967 press release announcing adoption of the FTC
Method, the testing determines ``the amount of tar and nicotine
generated when a cigarette is smoked by a machine in accordance with
the prescribed method.'' The same FTC press release stated that the
method was not intended to ``duplicate conditions of actual humans
smoking,'' or gauge ``the amount of smoke, or tar and nicotine, which
the `average' smoker will draw from any particular cigarette. . . .''
While the fundamental limitations of the FTC Method have not
changed since adopted some forty years ago, the relevance of machine
yields to actual or average consumer yields has been extensively and
publicly examined. Expert panels have been convened by the National
Cancer Institute and the World Health Organization. A range of studies
identifying the deficiencies of existing methods as well as potential
alternative testing regimes have been published. A paper reviewing the
recent advances and better understanding of these issues, authored in
part by a R.J. Reynolds Tobacco Co. scientist, is attached * and made
part of this testimony. (Attachment: Dixon, M. and Borgerding, M.F.
(2006) Recent advances in the application and understanding of
alternative smoking regimes. Rec. Adv. Tob. Sci. 32, 3-83.)
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* This paper is retained in the Committee's files.
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While no machine-test can mimic all human behaviors, the key to
progress in this area should be development of a standard, smoking
machine-based test method for cigarettes that more closely models the
variability of smoke yields under conditions of consumer use. Clearly,
this should begin with the body of scientific work that has already
been completed. As active participants in this debate and process, we
would welcome the opportunity to participate in the Committee's efforts
to establish a robust and realistic testing standard that can be widely
applied.
R.J. Reynolds Tobacco Co. has a keen interest in advancing the
testing methodology for cigarettes. We have been an active participant
in the world-wide debate over the emerging issues. We welcome an open,
scientifically-based discussion on these issues as part of a broader
discussion of the methods of potential harm reduction of tobacco
products. We believe decreasing the health risks and harm directly
associated with the use of tobacco products is in the best interests of
our society.