House of Commons - Health - Minutes of Evidence

Select Committee on Health Minutes of Evidence

Memorandum by British American Tobacco

THE TOBACCO INDUSTRY AND THE HEALTH RISKS OF SMOKING (TB 28)

1. British American Tobacco is pleased to contribute to the House of Commons Health Committee's inquiry into the action the tobacco industry has taken in response to the scientific knowledge of the harmful effects of smoking and the addictive nature of nicotine. We are also pleased to be asked to provide our view on the role of Government in providing consumer protection.

2. The tobacco operations of British American Tobacco and Rothmans merged on 7 June 1999. This memorandum addresses their response to the issue of smoking and health including their participation in research funded jointly by the UK tobacco companies. Whilst before the merger British American Tobacco's presence in the UK cigarette market was limited, as a UK based manufacturer of cigarettes, it has had a significant involvement in research jointly funded by the UK tobacco industry and in the co-operative relationship between the industry and the Government and its advisers. A brief corporate profile of the British American Tobacco group of companies can be found in paragraphs 58-62 of this memorandum.

3. Because the scope of the inquiry is so broad, and the actions taken by British American Tobacco and Rothmans extend over many years, we are providing a memorandum to the Committee that, whilst still only a brief summary of the actions taken, is quite lengthy. To assist the Committee, this executive summary highlights some of the key points made in our memorandum, but should be read alongside the full submission.

4. It is our view that the issue of smoking and health, both the science and the related public policy, should be dealt with openly and transparently. We expect this inquiry to consider the full history of the tobacco companies' contribution to smoking and health research and their co-operation with the Government on a range of matters, most particularly product modification.

5. We would also expect the inquiry to consider, in relation to smoking, the issue of the freedom of adults, who are aware of the nature of the risks, to choose a particular lawful lifestyle activity, and the basis for and proportionality of any government regulation of that activity.

6. Whilst this memorandum considers actions taken over many years, it is perhaps helpful to the Committee to start, as we have done in our Annual Report, by stating clearly British American Tobacco's view on smoking.

Smoking—our view

7. Along with the pleasures of cigarette smoking come real risks of serious diseases such as lung cancer, respiratory disease and heart disease. We also recognise that, for many people, smoking is difficult to quit.

8. It is for these reasons that we have long considered that the choice to smoke or not is one exclusively for adults. We do not want children to smoke and we actively support programmes to prevent and reduce under-age smoking.

9. Public health authorities have been successful over decades in publicising their conclusions that smoking is a cause of disease and encouraging smokers to quit. Every pack of cigarettes we manufacture world-wide carries a health warning.

10. Some argue that smoking, whilst lawful, must be the result of a lack of information about the risks, an "addiction" or the power of cigarette advertising. However, there are ample surveys from around the world that demonstrate a remarkably high awareness of smoking risks, and there is nothing so powerful about the pleasure of smoking that prevents a smoker from reaching and carrying out a decision to quit, as hundreds of millions of former smokers demonstrate. Moreover, the cigarette market is mature, so advertising promotes a choice between brands for those who have already decided to smoke. Social factors, not cigarette advertising, are the principal reasons why people start smoking.

11. The statistics that demonstrate the real increased risks of smoking also show that these risks are lower in groups of people who smoke less, start smoking later, quit earlier and smoke fewer cigarettes. The statistics have not demonstrated a risk free level of smoking, nor that a particular individual smoker will avoid an associated disease by smoking less. Statistics are unable to predict what will happen to an individual and science is still to determine which smokers will get a smoking related disease and which will not. We continue to support relevant research.

12. There are some people who will argue that leaving the choice to individuals ignores the claimed health risks to others posed by environmental tobacco smoke. However, statistics do not demonstrate environmental tobacco smoke is even a risk factor associated with the development of any long-term health effects or disease. We agree with public health authorities that it is proper not to smoke for prolonged periods around young children, but public smoking is a social issue, which can be resolved by having sensible regard for other people.

13. In our view, an informed decision to enjoy the pleasures of smoking while balancing those pleasures against the risks is no more for criticism than many other lifestyle choices we all make. Most of us are content to leave these choices to the individual. Smoking is just such a lifestyle choice for individuals.

14. We will continue to support the right of informed adults to choose to smoke.

Co-operation with the Government

15. We seek to co-operate with the Government and public health authorities to the fullest extent reasonably possible. The reason for this is simple. We take the view that the most effective way of developing rational smoking and health policies is for the industry, the Government and public health bodies to work with each other and to engage in a free and frank exchange of views. Each party involved in this open dialogue brings its own particular expertise. For example, in relation to product modifications aimed at reducing the risks of smoking, tobacco companies manufacture cigarettes and understand best the parameters of cigarette design that will be acceptable to smokers; public health bodies advise on the general directions of product modifications and how to evaluate whether any product modifications might be of benefit from a public health perspective; and democratic governments concern themselves with the welfare and freedoms of their citizens, ensuring that ways forward benefit society as a whole.

16. The history of the actions taken by British American Tobacco and Rothmans, detailed in this memorandum, can be clearly characterised as an approach of proper co-operation with the Government which resulted in a practical programme which brought together the interests of all parties as the state of scientific knowledge developed.

17. It has, however, over the past few years become far more difficult for the tobacco companies to maintain proper dialogue with the Government and its public health authorities and to work with it in developing rational smoking and health policies based on a proper understanding of the science and the lessons to be drawn from the past. This comes in part from attempts by some to misrepresent the motives and actions of tobacco companies. British American Tobacco, for example, has been falsely accused of hiding the risks of smoking and trying to sell cigarettes to children. We expect the Government to consult with other parties, as well as with ourselves, in the development of smoking and health policies, but consultation must be open and transparent and fairly balanced. The development of policy should have primary regard to the science, rather than highly publicised but misleading distortions by persons advocating nothing less than the prohibition or elimination of smoking.

Past actions taken in response to scientific knowledge

18. The view that smoking can be harmful to health is by no means new. Even before formal scientific studies on smoking and health were published, cigarettes were commonly referred to as "coffin nails". However, it was the work of Sir Richard Doll in the early 1950s that provided the scientific hypothesis that the rise in lung cancer incidence at that time was related to cigarette smoking (eg Doll R and Bradford Hill A, "Smoking and Carcinoma of the Lung", British Medical Journal, 2, p 739, 1950; "A study of the Aetiology of Carcinoma of the Lung", British Medical Journal, 2, p 4797, 1952). The Government and the UK industry took Sir Richard's work seriously. The Government asked its Standing Advisory Committee on Cancer and Radiotherapy to consider the science, whilst tobacco manufacturers entered into discussion with public health authorities and provided significant funds, on the advice of the Minister of Health, to the Medical Research Council for additional research aimed at evaluating the hypothesis (Hansard, 523, col 174, 1953-4; 585, col 89, 1957-8).

19. Research into smoking and health has been undertaken in many institutions and in many countries. Over the period since the early 1950s there has been an enormous amount of research published on the subject with, in the last two decades, thousands of academic papers being published each year. In responding to this information we have considered product design possibilities in light of the changing and expanding scientific knowledge.

20. Although throughout the 1950s there were differing views among scientists on the role of smoking in the development of lung cancer, the view that the role was causal was actively promoted by the Government and the public health authorities and by the media. Warning by public health authorities is their proper function. By 1956 the Minister of Health, Mr R H Turton, announced that there was an incontrovertible association between smoking and the incidence of lung cancer (Hansard, Vol. 552, col 803, 1956). This, and reports by the Royal College of Physicians, were widely publicised such that by 1959 a survey in Edinburgh reported that 98 per cent of those questioned had heard of the relationship between smoking and lung cancer (Cartwright A, Martin F M, Thomson J G, "Health Hazards of Cigarette Smoking, Current Popular Beliefs", British Journal Prev Soc Med, 14, p 160, 1960). Over the last 40 years or more, the public health authorities have created a truly pervasive environment with warnings on products and advertising, public education, research, quitting campaigns and smoking restrictions.

21. British American Tobacco promptly recognised the need both to understand the relationship between smoking and disease, newly identified by epidemiology, and to consider whether it was possible to modify products in response to concerns about this important new information. In 1956 it set up a research laboratory in Southampton, having recruited a senior scientific advisor, Sir Charles Ellis, who had been an advisor to Government during the Second World War, to determine a research programme. For over 40 years this research centre has attempted to find product modifications that would be accepted as providing a "safer" cigarette. This effort continues today.

22. The research effort at Southampton was undertaken in conjunction with a much broader UK tobacco industry initiative to find ways forward, very much in collaboration with the public health community. British American Tobacco and Rothmans contributed through both funds and expertise to the Tobacco Manufacturers' Standing Committee ("TMSC"). Notably the TMSC constructed purpose built bio-assay research laboratories in Harrogate, Yorkshire, to contribute to the development of acceptable and quantitatively reliable tests for measuring the biological effects of tobacco smoke.

23. This laboratory took as a working hypothesis the notion that tobacco smoke affects the respiratory epithelium (the surface of the lung) by direct contact, producing changes which in some smokers led eventually to lung cancer. The aim was to identify the chemical compounds giving rise to the biological activity of tobacco smoke and investigate cigarette design characteristics which could reduce such activity.

24. To reflect this research effort, the TMSC, in 1963, changed its name to the Tobacco Research Council ("TRC") and the research results produced at Harrogate were published by means of TRC Reviews of Activities as well as in articles published in prestigious scientific journals.

25. The Harrogate laboratories also investigated the pharmacological activity of nicotine, with the research being published in journals such as Nature and the British Journal of Pharmacology.

26. British American Tobacco's research was guided by this joint effort and by developments in the wider scientific arena. This work, over many years, with increasing degrees of sophistication as science developed, considered product modifications that would produce a cigarette with lower biological activity, the selective removal or reduction of specific constituents of cigarette smoke, the development of alternative and innovative products and the development of lower tar products. This effort is detailed in the full memorandum.

27. In 1971, the UK tobacco companies and the Department of Health and Social Security ("DHSS") formed a joint committee, the Standing Scientific Liaison Committee ("SSLC"). The purpose of the Committee was to advise the Secretary of State on scientific aspects of smoking and health, particularly on the significance to health of tar and nicotine, the constituents of tobacco smoke, research into less dangerous smoking and methods to test the health effects of cigarette smoking. (DHSS, "Report of the Standing Scientific Liaison Committee", DHSS, 1972). From 1972 the DHSS began publishing tables which ranked brands by tar yields and assigned them to High, Middle or Low tar bands.

28. In 1973 the SSLC was disbanded, and the DHSS created the Independent Scientific Committee on Smoking and Health ("ISCSH"), a group of scientists from a range of disciplines acting with complete professional independence. The role of the ISCSH was, inter alia, to advise both the Government and tobacco companies on product modifications related to less hazardous cigarette smoking. (ISCSH, Fourth Report, 1988).

29. One key initiative of the Committee was to encourage the companies to develop cigarettes containing tobacco substitutes to replace a proportion of the natural tobacco in cigarettes. The Committee also devised a testing regime to evaluate products incorporating such substitutes whilst maintaining that systematic long term epidemiological studies would be needed to properly test the effects of the products on human health (ISCSH, First Report, 1975). Thus, the cigarettes launched on the UK market containing tobacco substitutes could not be guaranteed to reduce the risk associated with smoking. In any event, these products, including Rothmans' Peer brand, proved unacceptable to the consumer, and thus a commercial failure.

30. Faced with this, the ISCSH focused on the further reductions in the tar yield of conventional cigarettes, encouraging the manufacturers to invest in ways to produce cigarettes acceptable to consumers but with lower tar levels. The ISCSH recommended that the Secretary of State obtain the manufacturers' co-operation for the achievement of further substantial reductions in tar (ISCSH, Second Report, 1979). The companies agreed and entered into a voluntary agreement with the Government in 1981 to reduce the sales-weighted average tar levels to 15mg by the end of 1983. This target was achieved. A further target of 13mg tar was set to be achieved by the end of 1987. In 1988 the fourth and last report of the ISCSH recommended reduction to 12mg tar by the end of 1991, and while no formal agreement was concluded on this target, the target was met. (ISCSH, Fourth Report, 1988). These targets were met through a combination of factors including the provision of information to smokers about the availability of lower tar brands and the industry's agreement to commit its advertising to such brands. The positive role that advertising to smokers played in this respect is probably not sufficiently appreciated today.

31. Throughout these years the companies maintained open dialogue, and worked with the ISCSH on issues of concern. In addition, the companies provided funding for the Tobacco Products Research Trust which sponsored research efforts to assess the effectiveness of the policies being set.

32. One particular concern the ISCSH had about the programme arose from the fact that reducing tar yields tends also to reduce nicotine yields. On the hypothesis that smokers smoked primarily for nicotine, it was feared that smokers switching to lower tar (and hence lower nicotine) cigarette brands would compensate (ie smoke more intensively) to achieve their accustomed nicotine yields, thereby increasing their tar intake also and defeating the purpose of the switch. British American Tobacco played its part in investigating this phenomenon, including holding a scientific conference in 1977. The papers from the proceedings were published in a book—Thornton R E, "Smoking Behaviour", Churchill Livingstone, Edinburgh, 1978.

33. The ISCSH concluded that whilst a certain amount of compensation occurred, it was generally partial, and thus did not negate the presumed benefits of switching to lower tar. However, in order to address this potential problem, they advocated product modification strategies to reduce nicotine proportionately less than tar (ISCSH, Fourth Report, 1988).

34. In response to suggestions such as these, British American Tobacco investigated various means of developing cigarettes with reduced tar to nicotine ratios. One initiative was the development of a cigarette in collaboration with Dr Russell of the Addiction Research Unit at the Maudsley Hospital. Another was the funding in the US of the development, through cross-breeding, of a strain of tobacco called Y-1.

35. However, smokers do not accept cigarettes with low tar and medium nicotine yields, finding such products unbalanced and harsh. The fact that many smokers now choose very low tar and very low nicotine cigarettes, and do not typically smoke more of these cigarettes per day, suggests that the hypothesis that smokers needed to maintain a certain nicotine intake was overly simplistic.

36. Epidemiological studies have repeatedly reported that the health risks associated with smoking are dose-related. This is the fundamental basis of the low-tar initiative determined by the Government: that, in groups of people, less smoke over a lifetime seems to be related to less risk. The principal components of the risk are the number of years spent smoking and the number of cigarettes smoked per day. Epidemiological studies also report that groups of people smoking filtered cigarettes (with tar yields of the order of 15mg or less) had lower risks than groups smoking unfiltered cigarettes (with tar yields of the order of 30mg).

37. Whilst the Government and public health authorities have encouraged smokers who did not wish to quit to switch to cigarettes of lower tar yield, British American Tobacco has never made health claims about smoking low tar cigarettes. Given that the epidemiology reports dose-response relationships, it might be thought logical that less smoke from lower tar cigarettes would be associated with less risk than more smoke from higher tar cigarettes. However, the science is not sufficiently developed to demonstrate whether or not this is true for very low tar cigarettes. Because very low tar products are relatively new, there is no epidemiology to properly assess the health risks related to a lifetime smoking of such cigarettes. Moreover, whilst epidemiological studies indicate lower risks in groups of people who smoke less, these studies can not provide any assurance to an individual. Despite this, the only product modification that has been given any support by public health authorities is the development of lower tar products, and we have done our best to manufacture products lower in tar that are acceptable to consumers.

38. Some advocates are currently suggesting that very low tar cigarettes "offer no meaningful benefits to smokers and may even be more harmful" (ASH press release, 18 March 1999) and are suggesting that taste descriptors such as "Lights" be prohibited. In the absence of definitive science one way or the other, but with the logical thought that less smoke is most probably associated with less risk, we do not think it wise to undermine the market's acceptance of low tar cigarettes. Taken overall, the limited data that does exist suggests that smokers of low tar cigarettes do take less tar than smokers of high tar cigarettes.

39. It will be apparent to the Health Committee that in addition to the scientific work referred to above (and more fully below), the area of smoking and health has been the subject of intensive study in many institutions and by many bodies in many countries over many, many years. Further, scientific techniques have developed to a revolutionary degree. All this work has informed our scientists and researchers and those with whom we have consulted externally.

Actions continue today

40. We continue to investigate product modifictions that might be regarded as presenting a reduced risk. We support the development of tests that might become accepted as a basis for evaluating the potential health effects of such product modifications, recognising, just as the ISCSH did in the 1970s, that long-term epidemiological studies will be needed to properly test the potential effect. We continue to undertake, and support externally, scientific research that will provide guidance on the development of "safer" cigarettes, including research on biological mechanisms and research on smoking behaviour.

41. Our ability to support scientific research in the UK has been recently limited by efforts of organisations such as The Wellcome Trust to ensure that scientific institutions do not accept funds from tobacco manufacturers. Our policy is that the scientists involved with all independent research funded by British American Tobacco should publish and interpret the research entirely independently. We think that further research is needed and remain willing to provide funds for worthwhile research on this basis. If scientific and academic institutions in this country are unwilling to accept our support, we will look to fund research overseas. We hope that the academic community will come to see that our offer is genuine and that their interests and ours are best served if high quality independent research is undertaken. We fear that in the interests of being seen to be politically correct, some scientific institutions are reducing their effectiveness.

42. We continue not to make health claims about our products and will comply with all regulations. We expect that the Government will wish to consult and draw upon our substantial expertise on all issues surrounding smoking and to include us and other tobacco manufacturers in their deliberations in the future. We expect deliberations to be open and transparent, and proposals to be fairly based and proportionate.

Smoking is an adult choice

43. British American Tobacco takes the view that adults, who are aware of the nature of the risks should be allowed to choose to smoke. We believe that in these circumstances it is practical to define adult as being over 18, though accept that some governments define adult at an even older age. We do not want children to smoke and we actively support programmes to prevent and reduce under-age smoking. Indeed, for several years we have called upon the UK Government to raise the legal age for sale of tobacco products to 18, and hope that this inquiry will consider this as one initiative that would help in the effort to reduce smoking by children. We also hope the UK Government will support proof-of-age schemes, such as CitizenCard, that assist retailers in complying with legislation.

The question of addiction

44. Most people in the UK believe that smoking is addictive. This is entirely understandable since it has been long known that smoking can be hard to quit and the term "addictive" is used quite loosely in everyday speech. British American Tobacco recognises that, by current popular concepts of addiction, smoking can be seen to be addictive.

45. Scientifically speaking, there is nothing in cigarette smoke that prevents someone from reaching and carrying out a decision to quit. Indeed, there are about as many ex-smokers as smokers in the UK, the great majority of whom stopped without any medical intervention. Nicotine does have mild pharmacological properties and does play an important role in smoking. Nicotine is thought to assist the smoker to concentrate and relax and smokers do not choose cigarettes without nicotine. But while nicotine is important there are many other characteristics of the entire smoking experience that people appreciate and which encourage them to continue to smoke. There is no well defined withdrawal syndrome from smoking in comparison to those associated with many substances traditionally labelled addictive and, even manufacturers of nicotine replacement therapies aimed at assisting smokers to quit, warn their customers that their products, which contain nicotine, will not work without the will power and determination to quit. We take the view that public health policy should be based on sound science.

46. Many people find it hard to quit, but given the motivation people can do so. We hope that the Committee will consider whether public health authorities and the Government should use the term "addiction" in relation to smoking and, in particular, consider the impact of labelling smoking "addictive" on the motivation of those who have decided to give up.

Environmental tobacco smoke

47. The Government's view that exposure to environmental tobacco smoke ("ETS") is a cause of lung cancer and heart disease cannot be justified on the basis of the existing science. We have an expectation that the science of ETS be treated, in public health terms, in the same manner as the science on any other topic. There are strong indications that this has not been the case. Misstatements on ETS lead smokers to believe that they are responsible for causing chronic disease in others. We take the view that it is wrong to make a large proportion of UK citizens feel guilty since the science does not support the claims often made. The ultimate example of the guilt being wrongly laid at the feet of smokers is a recent Government survey that reported that a large proportion of people in the UK believe that ETS causes diabetes. (Department of Health, Statistical Bulletin, 1998/25, July 1998). No scientist has made such a claim, yet the nature of some anti-smoking initiatives has led the public to this false belief. The Department of Health stated: "Therefore, the responses to the questions about the effects of smoking on health should generally be taken as an overestimate of the real level of knowledge for both smokers and non-smokers" (ibid, p 9). Such examples bring science and the health authorities into disrepute and leave them less able to tackle other public health issues.

48. British American Tobacco's view is that it is right that parents and other adults be particularly sensitive to the needs of young children, especially infants, for a clean, comfortable environment. It makes sense not to smoke around infants, especially in poorly ventilated environments, and not to smoke around young children for long periods.

49. We do believe that smoking in public places is annoying to many non-smokers. However, society should react to such annoyance in the manner that it has done successfully over the past years, acting without government intervention, by people accommodating each other, showing common courtesy to each other and adopting practical solutions for smokers and non-smokers.

The role of the Government in consumer protection

50. The UK Government has, since 1956, believed that smoking can be a cause of certain diseases. The Government and the public health authorities, have rightly warned the British public of this for more than 40 years. Successive UK Governments have, presumably, also decided that tobacco products should continue to be legal, and have decided to collect excise duties on all tobacco products sold in the UK. Currently the Government collects around £10 billion in excise duties annually as a result of the sale of tobacco products in the UK.

51. There can be no other product that has received such public attention related to health risks, and it is most unlikely that anyone in the UK has not heard it said authoritatively that smoking is a cause of disease. Given such a widespread awareness of the risks involved in smoking, the question is what approach should the Government take to issues of smoking and health. The alternatives range from a laissez faire approach (ie, given the level of available information, leave it to the market to sort out) to a social engineering approach (where the Government intervenes in the personal lawful lifestyle choices of its citizens and drives them to make lifestyle choices that the Government believes are worthy). British American Tobacco does not believe that such "nannyism" is the proper role of the Government; however, neither do we believe that Government should have no role and leave it to the market alone. A scientifically based, soundly supported and proportionate response by Government is fundamental in a democratic society where what is at issue is the restriction of the freedom of individual citizens to choose a particular lifestyle activity or the freedom of corporate citizens to conduct their lawful business.

52. We believe that the Government should continue in its role of ensuring proper public education on all material health risks, including important ones such as smoking. This is particularly important in schools. It is also appropriate that the Government provides smokers with accurate information, which might, for example, include the fact that whilst epidemiological studies have found no safe level of smoking, groups of people who smoke fewer cigarettes for fewer years have lower health risks than those who smoke more.

53. We do not believe it is appropriate to ban cigarette advertising in response to concerns about the health risks of smoking. Advertising does not cause people to smoke nor does it increase overall consumption, but it is important to cigarette companies wanting to compete with each other. A comparison of the consumption trends in countries with or without advertising bans does not indicate that there is a correlation between tobacco advertising and consumption. The suggestion that the cigarette industry aims, through its advertising, to replace the smokers who stop smoking is misconceived and wrong, and demonstrates a failure to understand the role of advertising, in a mature market for products such as cigarettes and washing powder. We also believe that the Government should recognise that a ban on advertising may restrict its ability to encourage smokers to use products which it regards as "safer" through advertising, as happened when the industry agreed to commit its advertising to lower tar brands as part of the Government's product modification programme.

54. We strongly believe that public health information should be scientifically accurate. In this regard, we are concerned by some of the recent activities of Action on Smoking and Health ("ASH"), a charity which has pledged itself "to hound the tobacco industry out of business by every means at our disposal" (ASH Press Release, 15 July 1996). ASH has made a series of smoking policy recommendations directed at the Government based on false scientific assumptions. Some of these statements are referred to in this memorandum. The role of the charity ASH, and its relationship with the Department of Health has been increasingly unclear over the last several years and we encourage the Committee to consider this. In recent years, ASH has received most of its funding from the Department of Health, the Welsh Office and regional health authorities and this money has then apparently been used to lobby Government Departments, including the Department of Health itself, for the introduction of government restrictions on smoking and to persuade the public of the need for such restrictions.

55. It is the responsibility of both manufacturers and non-government organisations to provide accurate information and not inflammatory and sometimes knowingly erroneous information. We expect, of course, that bodies with different perspectives from ours will be included in government consultation and, indeed, we welcome a thoughtful engagement of all.

56. We also take the view that any regulations aimed at consumer protection should be formulated in a transparent manner, should be fairly based in the science, should be proportionate to the risk and demonstrably be reasonably capable of achieving the stated aim of the regulation. For example, in light of the plain evidence on the subject, we do not believe that a ban on cigarette advertising will have any effect on consumption of cigarettes by those under-age (or by others).

57. We support open government and are willing to play our proper role in discussing with the Government matters on which we have expertise and experience. We look forward to contributing fully to the Committee's inquiry.



© Parliamentary copyright 2000	Prepared 28 February 2000