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Re: Philip Morris International's view on "Existing technologies to reduce toxicants in cigarette smoke"

In their article, “Existing technologies to reduce specific toxicant emissions in cigarette smoke,” RJ O’Connor & PJ Hurley list technologies that, they propose, manufacturers could use to comply with ceilings on nine smoke constituents proposed by the WHO Study Group on Tobacco Product Regulation (TobReg).

Initially, it is important to address any conjecture that these ceilings will reduce the harm caused by cigarette smoking. Even TobReg concedes that there is no evidence – only “hope” – that its proposal will reduce the risks of smoking. Public health officials and scientists have long stated, however, that selectively reducing cigarette smoke constituents is unlikely to benefit public health.

Like TobReg, O’Connor & Hurley seem to take for granted that manufacturers can easily comply with the proposed ceilings. But their article proves the opposite. It highlights the difficulty, if not impossibility, of complying with ceilings on nine individual constituents (among thousands) in tobacco smoke, especially on a commercial scale.

Although an exhaustive treatment of each listed technology is beyond the scope of this letter, the following points illustrate pragmatic difficulties with applying these technologies in the real world.

• Using less Burley tobacco and more Bright (Virginia Flue-cured) tobacco to reduce TSNA. This would increase emissions of formaldehyde, another carcinogen in cigarette smoke.

• Using DNA from salmon sperm to reduce PAH or adding haemoglobin to reduce carbon monoxide emissions. It is difficult to envision how such options, which even the authors question, would be acceptable from a regulatory viewpoint or could be commercialized on a large scale.

• Adding ammonia compounds, including urea, to cigarettes to reduce formaldehyde. Public health authorities have alleged (although we disagree) that ammonia compounds are added to cigarettes to increase the addictive effects of nicotine.

These examples underscore the need for a science-based, rational approach to tobacco policy that applies science consistently and coherently when examining regulatory and public health proposals.

O’Connor & Hurley concede that TobReg’s proposal would force the majority of existing cigarette brands off the market. We fully agree. Viewed through this lens, the proposal is not “a conservative first step” as TobReg contends. It is a strategy to remove as many tobacco products from the market as possible.

Resources would be better spent on developing a regulatory framework that includes evidence-based standards for reduced risk assessment, rather than on promoting poorly-reasoned, speculative performance standards that are not likely to reduce the risk of tobacco-related diseases.