The Imperial Cancer Research Fund welcomes this opportunity to submit evidence to the Select Committee on Health's inquiry into the tobacco industry's response to evidence of tobacco harms. Our mission is to contribute knowledge leading to reductions in cancer morbidity and mortality. Our research scientists have made important contributions to knowledge in key areas of tobacco research: finding out the true extent of the burden of ill health and premature death caused by cigarette smoking in the UK and worldwide; and unravelling the underlying role of nicotine in motivating smoking behaviour. It is now abundantly apparent that nicotine is a powerfully addictive drug, in many respects on a par with drugs such as heroin and cocaine, and in terms of its intractability to change perhaps the most addictive of all the drugs that are widely used in society. Nicotine addiction currently leads to the premature deaths of about 120,000 people each year in the UK, and is responsible for one in five of all deaths, and one in three deaths from cancer.

  The surest way to reduce the burden of tobacco related disease is to persuade fewer young people to take up smoking in the first place and more established smokers to give it up. We fully support policies aimed at achieving this, including year-on-year real increases in the price of cigarettes, school and public education campaigns, provision of smoking cessation treatment under the NHS, and greater restrictions on smoking in public places. However, in addition to policies targeting smoking uptake and cessation, a complementary approach is to attempt to reduce the hazards of ongoing smoking for those who cannot or will not give up. This has so far received less attention. If people smoke for nicotine, but die from the effects of tar and harmful gases, then a logical strategy would be to provide smokers with the nicotine they seek with as little of other smoke toxins as possible. From this perspective, the cigarette is viewed simply as a nicotine delivery device—one which is uniquely contaminated by carcinogens and other noxa in the tar and gas produced by combustion.

  For the past 25 years efforts to reduce the harmfulness of cigarettes have focused on lowering machine-smoked yields of tar and nicotine. Tar yields are now about half the levels they were in 1970. These reductions may have initially contributed to some lowering of risks from cigarette smoking, but it is now apparent that further reductions in nominal yields will confer no public health benefit, while actively confusing and misleading smokers.

  Cigarette yields are measured by smoking cigarettes in a machine in a conventional way. Lowered deliveries are achieved principally by diluting the smoke with air drawn in through filter ventilation holes. In some ultra-low yielding brands the extent of filter ventilation can be over 80 per cent. The underlying tobacco in low yield brands is not low yield—in fact the total nicotine content of the tobacco used in lower and higher yielding brands is very similar. This means that smokers can (and do) readily compensate for lower nicotine from low-yielding brands by manoeuvres such as increased intensity of puffing, and blocking, intentionally or otherwise, of filter ventilation holes. There is a wealth of evidence which shows that actual intakes are reduced little if at all in smokers of lower yielding brands. Compensation for nicotine is essentially complete, with the implication that tar exposures from brands of widely differing nominal yields are also similar.

  If lowered nominal tar yields do not lead to lowered dose, they certainly do serve to confuse smokers. It would not be unreasonable for cigarette consumers to infer that a cigarette listed as yielding, say, 10mg of tar should produce a tar dose 10 times higher than one yielding 1mg.

  Internal tobacco company documents show that the industry has understood for over 20 years that the reduction of machine-smoked yields offers no meaningful reduction in dose and hence no meaningful health benefits. They have nevertheless exploited low delivery cigarettes, which they term elastic or compensatible products, to provide health reassurance to smokers. In so doing they may have dissuaded some health-concerned smokers from giving up, and deflected company research efforts from developing alternative nicotine delivery devices which offer real health gains.

  It is clear that the tobacco industry cannot be relied upon to make serious moves of its own accord towards less toxic products. It is constrained both by its failure to acknowledge the reality and extent of the burden of disease caused by tobacco and by its unwillingness to openly acknowledge the underlying role of nicotine addiction. Regulatory control by government in the UK has been extremely weak. There is now scope for a fresh and more effective approach to regulation. In the United States the Federal Trade Commission has publicly recognised the misleading nature of its test for cigarette yields, and the Food and Drug Administration has asserted jurisdiction over tobacco products, thus opening the way for consumer productssuch as cigarettes to be brought under similar regulatory scrutiny to pharmaceutical nicotine delivery products such as nicotine gum and transdermal patches. The committee might well consider that there is a strong case for a similar nicotine regulatory authority in the UK, either freestanding or under the aegis of the Medicines Control Agency.

October 1999