The Response Of The Ctmc To B.c. Ministry Of Health
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A LESSON IN CHEMISTRY FOR IGNORANT HEALTH OFFICERS
THE RESPONSE OF THE CANADIAN TOBACCO MANUFACTURERS COUNCIL TO B.C. MINISTRY OF HEALTH MISINFORMATION
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|March 24, 1998
Hon. Penny Priddy, M.L.A.,
On behalf of the three major Canadian cigarette makers, I am writing in response to your Ministrys statements and intentions for tobacco and tobacco smoke constituent labelling on cigarette packages and the current advertising campaign.
The information publicly released is seriously misleading in a number of respects and factually wrong in others; your officials have been misinformed.
The facts regarding cigarettes and fine-cut tobacco manufactured by the CTMC member companies are as follows:
Canadian manufacturers do not use additives in the tobacco of non-mentholated manufactured cigarettes, which accounts for approximately 85% of total sales.
Two manufacturers use small quantities of reconstituted tobacco, a method of recovering and reusing small pieces of tobacco from the initial stages of processing and manufacturing cigarettes and fine-cut tobacco. This constitutes 8 per cent or less of the weight of tobacco in a manufactured cigarette. Naturally occurring binding agents and humectants are used in the production of reconstituted tobacco. With the agreement of Health Canada, these are not considered additives.
The remaining 15% of cigarette and cigarette tobacco sales include menthol flavoured cigarettes and cigarette tobacco, and fine-cut tobacco used in roll-your-own cigarettes. Menthol is added to the former, and moisturizing agents and preservatives to the latter. There are two possible menthol additives, three possible moisturizing agents, and two possible preservatives.
Regular reports on the few additives actually used, on a brand-by-brand basis, are required by law to be, and are, reported to Health Canada by each of the manufacturers every three months. The full list of additives used in Canada was released publicly by the industry in April, 1994. A copy of the news release is attached. Nothing is hidden. Health Canada has long been in a position to confirm to any enquiry that this list contains everything added in the manufacturing process. Under the Tobacco Act, the federal government has the authority to examine any and all steps in the manufacturing process to ensure that no additives other than those reported are being used.
Two of the twelve constituents supposedly in cigarette smoke listed by our Ministry - methoprene and turpentine - are not added or present in the smoke of Canadian cigarettes. Turpentine, a substance from pine trees, is not added to cigarette tobacco by any of the CTMC member companies. It neither occurs naturally in tobacco nor is it a byproduct of combustion of tobacco. Methoprene, non-toxic to humans, is an approved agricultural fogging agent and leave no pesticide residue. It is not used on tobacco in Canadian brand cigarettes.
Propylene glycol, another of the constituents referred to by the Ministry, is used in fine-cut tobacco for moisture retention and is an approved food additive. Taken internally, propylene glycol is harmless. As far as we know, it is not used in automobile radiator anti-freeze as shown in you Ministrys advertisement.
Not one of the constituents listed by your Ministry is unique to cigarettes or cigarette smoke. For almost all of them, a combination of a normal diet and lifestyle provides an individual with greater exposure than smoking cigarettes.
As the sophistication of organic chemical analysis has increased, the theoretical number of constituents that may be identified in tobacco smoke (or, indeed, in smoke from any organic combustion) has increased as well. Some current estimates put this number as high as then thousand. There is, however, general agreement that there are least 4,000 constituents in cigarette smoke. In the 1989 Report of the U.S. Surgeon-General only about 800 of these constituents were identified and quantified, although there is no common international set of analytical standards or agreements on measurement methodologies. Most of the constituents are in such minute quantities (billionths or even trillionths of a gram) that quantification is almost impossible and the relevance to smokers unknown.
Metals, in particular, are found in such small quantities that the 1989 U.S. Surgeon-Generals Report does not even list at least 30 metals in the smoke....because less than 1 per cent of the metals in tobacco are transferred into the smoke and constitute together only > 80 micrograms per gram. (A microgram is one-millionth of a gram)
To summarize, of the twelve constituents of cigarette smoke identified in the Ministrys press release, fact sheets and advertisement, two do not exist. One, propylene glycol, is misidentified as anti-freeze. It is a harmless approved food additive used only in roll-your-own cigarettes. The other nine either occur naturally in tobacco (and are ubiquitously present in many other agricultural products as well as in the water and the air) or are the byproducts of combustion. While this is acknowledged in the disclaimer in the advertisement, it was not acknowledged in the press releases or fact sheets.
The specifics of these nine smoke constituents mentioned in your release are as follows:
All of this information is publicly available and could have been obtained from many sources or from this office or from the CTMC member companies. It is regrettable that Ministry officials did not make such enquiries. The press conference statements and the current advertising campaign imply that many of the above are added by the manufacturers. This is not the case. A recent B.C. Health Ministry news release stated the others... are added to enhance the effect of nicotine on the brain. Again, this is not the case.
Tobacco manufacturing and sale in Canada is licensed and regulated at every step by governments, which maintain tobaccos status as a legal product. In British Columbia, the provincial government takes about eight times as much in taxes from smokers as the CTMC member companies make in after tax profits in the province.
Governments have both the legal authority and capacity to exercise regulatory oversight of every aspect of the industry.
Whatever the specific qualities and quantities of the smoke constituents of B.C. government listed, it is generally accepted that there are risks to health associated with tobacco consumption. The industry has no objection in principle to informing smokers of the presence and amounts of the constituents of tobacco smoke.
The critical question is whether such information would have any effect in persuading smokers to stop or non-smokers not to start. We know of no compelling evidence that this would be the case.
The industry itself voluntarily placed nicotine and tar levels on cigarette packages in 1975, 14 years before this was legislated. This did not appear to accelerate the already existing downward trend in smoking prevalence rates at the time.
Since warning message were legislated, two generations of larger and more strongly worded warnings have been used (those now present are among the largest in the world) and have had no measurable effect on rate of smoking prevalence. These remain essentially unchanged since 1986 according to both Health Canada and Statistics Canada.
Given this factual background and beyond the central question of efficacy, your Ministrys proposal raised a number of practical and logistical issues which we would be pleased to discuss with you. Among others these include:
1. The preparation of a comprehensive list would require a massive, multi-year study to identify and quantify the estimated 4,000 constituents of smoke from all brands of Canadian made cigarettes. One does not now exist and has never been commissioned by any government.
2. There is no Canadian nor international standard to measure the constituents in cigarette smoke such as those established by the International Standards Organization (I.S.O.) for the measurement of tar, nicotine and carbon monoxide.
3. There are practical difficulties in disclosing the information in a meaningful way. Should all constituents and their amounts be listed" If not, which ones should be omitted and why"
4. There are clear issues of the legality and fairness of mandating the listed of naturally occurring constituents for one product without doing so for others such as milk or cereal.
5. There are international trade implications raised by a separate labelling regime for one province.
6. There are potential conflicts with impending federal regulations under the Tobacco Act for the labelling of tobacco. products.
7. The process could increase cigarette prices in British Columbia and there fore have a potential impact on contraband tobacco sales in that province by increasing the price differential with other jurisdictions.
As indicated in correspondence with your predecessor, we remain available to meet with you and your officials to discuss these and other tobacco related issues.