Select Committee on Health Minutes of Evidence


Memorandum by Imperial Tobacco Group PLC

THE TOBACCO INDUSTRY AND THE HEALTH RISKS OF SMOKING (TB 13)

Summary

  Imperial Tobacco Group PLC ("Imperial") is a UK company which has always acted as a responsible manufacturer of tobacco products.

  Since the publication in the early 1950s of human population studies reporting that lung cancer occurred more frequently in cigarette smokers than in non-smokers, an enormous amount of scientific research has been carried out on cigarette smoking and diseases associated with it. In consultation with leading scientists and by working closely with Government-appointed independent scientific advisers, Imperial has contributed substantially to that research both through its own research and through its funding of independent research.

  Despite that research, there remain many unanswered questions. Imperial accepts that human population studies have established a statistical association between cigarette smoking and lung cancer and other diseases and that smoking should be recognised as a risk factor for certain diseases, including lung cancer. However, scientists generally agree that a statistical association alone does not establish a cause and effect relationship. Also, the mechanisms by which the diseases associated with smoking develop and any role which smoking might play remain unknown. Nevertheless, Imperial accepts that cigarette smoking may be a cause of lung cancer and other diseases and it has conducted its business for over 30 years on this basis.

  Public health bodies have for some time pursued a strategy of reducing the tar[141] yield of cigarettes. However, scientists are still debating whether a reduction is beneficial. Imperial has co-operated with Government and its advisers in their strategy from the early 1970s of lowering tar yields in cigarettes. Imperial has implemented a very large number of modifications to its products to reduce tar and nicotine yields and has committed massive resources to the development and marketing of a tobacco substitute.

  For more than 40 years, Imperial worked alongside Government to address smoking and health issues. Government has, since the late 1950s, implemented a consistent public health policy against smoking, and Imperial has never challenged that policy or the public messages that Government has delivered. The co-operation between Government and Imperial developed into a unique regime of voluntary agreements. Imperial entered into those agreements willingly and has been committed to complying not only with the letter of those agreements but also with their spirit. These agreements have enabled Government to achieve one of the most advanced, comprehensive and effective systems of regulation of the sale of tobacco products in the world and substantial reductions in tar and nicotine yields and in total cigarette consumption in the UK. In other countries, which do not have a similar regime of voluntary agreements, Imperial also markets and sells its products in a responsible manner.

  Government and public health bodies have consistently advised against smoking and millions of smokers in the United Kingdom and elsewhere have stopped. While some smokers might have difficulty in stopping, Imperial believes that smokers are able to stop smoking if they choose to do so.

  From the 1950s, the Government, public health authorities and the media have informed the public about the risks associated with smoking. Those adult smokers who choose to start or continue smoking do so with knowledge of this information.

  Imperial considers that smoking is a matter for informed adult choice. It produces tobacco products to meet the demands of adults who choose to smoke with knowledge of the risks associated with smoking. Imperial does not encourage or want children to smoke. Imperial has agreed with Government, and has participated in, many initiatives to prevent under-age smoking.

  Government's policy to prevent sales of tobacco products to children is, however, undermined by its conflicting policy on tobacco taxation. UK tobacco duty is the highest in the world and, as a result, legitimate total market sales of cigarettes and roll your own tobacco have declined rapidly in recent years. Government taxation policy has, however, led to a corresponding rise in the market for bootlegged and smuggled tobacco products and non-UK duty paid sales. Children have free access to smuggled tobacco, which bypasses retailer controls and is much cheaper than legitimate retailed product.

  Imperial regrets that the constructive and fruitful relationship between the UK tobacco companies and the Government, which enabled the Government to achieve so much, has broken down. It strongly recommends the re-establishment of constructive dialogue.

  Imperial encourages the Health Select Committee to recommend to Government that it:

    (a)  re-establishes a constructive and effective dialogue between all relevant Government departments and the UK tobacco companies;

    (b)  continues to adopt and enforce measures to prevent smoking by children;

    (c)  adopts effective measures to prevent the smuggling of tobacco goods; and

    (d)  continues to allow adults who choose to smoke to have access to a range of products and information about them.

Introduction

  This memorandum is submitted by Imperial in response to a request from the Health Committee of the House of Commons. It details Imperial's actions over the half century since researchers raised the possible relationship between smoking and chronic diseases, such as lung cancer. It demonstrates that, throughout this period, Imperial acted as a responsible tobacco manufacturer.

IMPERIAL'S BUSINESS

  The tobacco business conducted by Imperial has a long established history, dating back to 1901 when it was formed by the merger of 13 independent British tobacco companies. Imperial has been an independent company throughout the period since 1901 except for the period 1986-1996 when it was a wholly owned subsidiary of Hanson PLC. Today Imperial is an integrated, international tobacco company manufacturing and distributing a range of cigarettes, cigars, roll your own and pipe tobacco, snuff and cigarette papers to over 70 countries worldwide. The Company, which has its registered office and head office functions in Bristol, is divided into seven business units each headed by a managing director.

  Imperial has 4,600 employees worldwide, of whom 2,700 are employed in the UK. The Company has 12 factories, four of which are located in the UK in Nottingham (cigarettes), Bristol (cigars), Liverpool (pipe tobacco, snuff and roll your own tobacco), and Treforest (cigarette papers).

  Imperial continues to make a significant investment in technological innovations to improve productivity and reduce costs. In excess of £80 million has been invested in its UK factories over the last five years and productivity has risen by 35 per cent in the same period. The Company is now established as one of the world's lowest cost producers of high quality tobacco products. In the 1998 financial year, Imperial's international business comprised £300 million of turnover excluding duty with its exports from the UK contributing £68 million to the balance of payments.

  In 1998, Imperial's UK turnover was £3,521 million of which £2,873 million (81.6 per cent) was paid to the Government in duty. UK tobacco duty is the highest in the world and as a result legitimate total market sales of cigarettes and roll your own tobacco have declined rapidly in recent years to 70.5 billion and 1,800 tonnes respectively in 1998. There has, however, been a corresponding rise in the market for bootlegged and smuggled tobacco products and non-UK duty paid sales.

SCIENTIFIC RESEARCH INTO SMOKING AND HEALTH

  1.  Since the publication in the early 1950s of human population studies reporting that lung cancer occurred more frequently in cigarette smokers than in non-smokers, a vast amount of scientific research has been carried out into cigarette smoking and its relationship to certain diseases and into the causes and mechanisms of the diseases themselves.

  2.  From the early 1950s, Imperial monitored developments in the field of smoking and health and actively contributed to research:

    —  by carrying out its own research;

    —  by funding and assisting independent researchers;

    —  through research carried out by TRC/TMSC of which it was the principal member;

    —  by making available the results of research; and

    —  by regularly consulting distinguished scientists for their views about the state of scientific knowledge and about Imperial's proposed actions.

EARLY RESEARCH BY IMPERIAL

  3.  In the early 1950s, very little was known about the chemical constituents of either tobacco or tobacco smoke and, after consulting independent scientists, Imperial concentrated its research in this important area. Imperial took the lead by initiating a programme of chemical research into the constituents of tobacco and tobacco smoke.

  4.  The research required the construction of a new laboratory at Raleigh Road, Bristol in 1953 and 1954 and the development of new equipment and techniques to analyse the minute quantities of compounds within tobacco leaf and smoke. The equipment to undertake this research did not previously exist and Imperial played a leading role in its development. A considerable amount of work was necessary to develop an automatic smoking machine which would resemble the conditions of human cigarette smoking. This machine was developed by Imperial during 1954 and 1955 and information about it was promptly shared with other UK tobacco companies, independent scientific research institutions and the scientific press. In addition, Imperial was the major supplier of material (including cigarettes, cigarette smoke condensate and cigarette smoke condensate fractions) required by independent researchers who were carrying out both chemical and biological research.

  5.  An enormous amount of research was carried out to identify the compounds present in tobacco smoke which was found to be a highly complex mixture. By the late 1960s, hundreds of compounds had been identified in the smoke of a typical UK cigarette.

GRANT TO THE MRC

  6.  In 1953 Imperial, together with other UK tobacco companies, consulted with the Minister of Health and on his advice decided in 1954 to place £250,000 (about £4 million in today's terms) at the disposal of the Medical Research Council ("MRC") to enable it to fund independent research into the cause or causes of lung cancer. Imperial provided half of this sum.

  7.  Projects funded included research to identify compounds in tobacco smoke and research into the possible biological effects of those compounds. This latter research mainly used cigarette smoke condensate which was painted in large amounts on the skin of individual animals, particularly mice.

TMSC/TRC RESEARCH

  8.  A significant further expansion of the research effort occurred in June 1956 with the establishment of the Tobacco Manufacturers' Standing Committee ("TMSC"). This was jointly funded by the UK tobacco companies. Imperial was a founding and principal member in that it supplied the largest share of the funding. The TMSC's objective was to "assist research into smoking and health questions, to keep in touch with scientists and others working on this subject in the UK and abroad, and to make information available to scientific workers and the public."[142]


  9.  The TMSC set up a new fund to promote and assist research into any question relating to smoking and health. From 1958, the Scientific Advisory Committee of the British Empire Cancer Campaign ("BECC") advised the TMSC on what research should be funded. The TMSC also liaised with the MRC and gathered and distributed information about smoking and health. The basic objective was to find out more about the nature of tobacco smoke and its possible effects upon smokers, the motives for smoking and the factors associated with lung cancer and other diseases. The research commissioned by the TMSC included epidemiological studies and chemical and biological research. All grantees were independent from the TMSC and had total freedom to decide what research to carry out and whether to publish the results of that research.

  10.  The role of the TMSC progressively expanded particularly with the decision to set up a purpose-built research facility at Harrogate in Yorkshire to conduct research relating to smoking and health. This decision was taken by the TMSC in 1960 after consultation with external independent scientists including Dr G F Marrian of the MRC and the Imperial Cancer Research Fund and Sir Charles Dodds of the BECC and the Royal College of Physicians ("RCP"). The construction of the Harrogate laboratories took almost two years and was a major commitment of resource by Imperial and the other UK tobacco companies. Research began at Harrogate in September 1962.

  11.  From 1 January 1963, the name of the TMSC was changed to the Tobacco Research Council ("TRC") to reflect its increased direct involvement in research.

  12.  The research at Harrogate concentrated on the chemistry of tobacco smoke and biological testing and was primarily directed at the possible role of cigarette smoking in lung cancer. This research was carried out on the working hypothesis that cigarette smoke might cause or contribute to the development of lung cancer and mainly consisted of a programme of mouse skin painting under the direction of Dr T D Day (previously of the Department of Experimental Pathology and Cancer Research, School of Medicine, Leeds University). The broad objective of this research was to develop acceptable and quantitatively reliable tests for measuring any biological activity of tobacco smoke condensate in animals and to identify any potentially harmful constituents in tobacco smoke and, if possible, remove them.

  13.  The mouse skin painting research undertaken at Harrogate was discussed with the Minister of Health and with Professor Sir Alexander Haddow (Chester Beatty Institute, Institute of Cancer Research at the Royal Cancer Hospital), Sir Charles Dodds, Dr G F Marrian, Sir Max Rosenheim (President of the RCP), Professor H S B Atkins (President of the Royal College of Surgeons) and Dr C M Fletcher (Postgraduate Medical School of London). In 1967, the studies were published in the British Journal of Cancer.[143]

  14.  The mouse skin painting research was also directed at identifying potentially biologically active compounds in cigarette smoke by fractionating whole smoke and cigarette smoke condensate. However, by the 1970s, it became apparent that the search had been taken as far as it reasonably could and the decision was taken to discontinue the fractionation research and the large-scale mouse skin painting experiments which had been continuously in progress since the laboratories were set up in 1962.

  15.  In addition to chemical and biological research, the TRC also carried out pharmacological research at Harrogate under the direction of Dr A K Armitage, as well as research into the reasons why people smoke. This research was also published.

  16.  In 1974, the laboratories at Harrogate were sold to Hazleton Laboratories and from then on the TRC research programme at Harrogate continued under contracts with Hazleton. Research included inhalation and cardiovascular studies and basic cell and tissue culture research. Grant-aided research by independent workers also continued on a substantial scale.

CONSULTATION WITH EXTERNAL INDEPENDENT SCIENTISTS

  17.  Imperial and the TMSC/TRC consulted and took advice from leading scientists on the direction of research carried out and the interpretation of the results of research. These scientists included:

    —  Sir Charles Dodds (President of the RCP Committee of Air Pollution; Chairman of the Scientific Committee of the British Heart Foundation, Courtauld Institute of Biochemistry at Middlesex Hospital Medical School);

    —  Sir Ronald Fisher FRS (Professor of Genetics, University of Cambridge);

    —  Sir John Richardson (President of the Royal Society of Medicine);

    —  Lord Todd (Professor of Organic Chemistry at Cambridge University);

    —  Professors Sir Alexander Haddow, R D Passey and E Boyland (Chester Beatty Institute of Cancer Research at the Royal Cancer Hospital, London);

    —  Professors Sir Ernest Kennaway and J W S Blacklock (St Bartholomew's Hospital);

    —  Dr C M Fletcher (Co-author of the 1962 RCP Report on Smoking and Health); and

    —  Dr J W Cook and W Carruthers (MRC Carcinogenic Substances Research Unit, University of Exeter).

PUBLICATION OF RESEARCH

  18.  The TMSC published annual reports of its activities for each year from 1957 to 1960. These reports outlined the TMSC's objectives and summarised the research funded during the year (including that administered by the MRC) and reported other developments in the field of smoking and health. Between 1963 and 1975, the TRC published four reviews of its research activities, each covering a number of years. The reviews summarised the research funded by the TRC and listed the scientific papers published by TRC staff and grantees.

  19.  These TMSC annual reports and TRC reviews of activities describe a comprehensive research programme which was planned and implemented by highly-qualified scientists. It included:

    —  mouse skin studies;

    —  inhalation studies;

    —  pharmacological research;

    —  in vivo and in vitro tests;

    —  cardiovascular studies;

    —  epidemiological studies;

    —  product modification research;

    —  human smoking behaviour research.

  20.  TMSC/TRC scientists and independent researchers funded by the TMSC/TRC published in excess of 400 papers in prestigious scientific journals. The many articles published covered the broad range of research funded by Imperial and the other UK tobacco companies.

FURTHER RESEARCH BY IMPERIAL

  21.  In addition to the research carried out at Harrogate and funded through the TRC, Imperial's own Research Department continued throughout the 1960s and 1970s to undertake both chemical research and research into product modification in the following broad areas:

    —  development and application of methods for the analysis of tobacco smoke;

    —  studies of tobaccos from different countries of origin;

    —  the mechanism of filtration of the particulate and vapour phases of smoke;

    —  studies of selective filtration and of ventilated filters;

    —  studies of the constituents of smoke which contribute to flavour and aroma;

    —  human smoking characteristics by direct and indirect measurement and observation;

    —  work on standardisation of measurement of tar and nicotine yields; and

    —  testing of consumer acceptability of experimental cigarettes.

  22.  Vast amounts were expended by Imperial on product modification research and the development of a tobacco substitute called New Smoking Material ("NSM"). Imperial employed one of the largest contract research laboratories in the world, Huntingdon Research Centre ("HRC"), to carry out research into product modification and a bioassay test system which would assist quantitative comparison of modified and unmodified cigarettes. HRC and Imperial's Research Department also conducted research relating to the development of NSM and research recommended by the Independent Scientific Committee on Smoking and Health ("ISCSH"). The ISCSH had been established by the Government in 1973 "to provide unbiased and objective advice to health ministers (who appointed the members) and, where appropriate, to the tobacco companies, on the health aspects of smoking tobacco".[144] Imperial's co-operation with the ISCSH is detailed below.

  23.  From 1980, Imperial and the other UK tobacco companies provided the ISCSH with £1 million per annum for three years for "independent monitoring of research proposed by the ISCSH into the effects on health of product modification".[145]

TOBACCO PRODUCTS RESEARCH TRUST

  24.  In 1982, after consultation between the ISCSH, the Government and the UK tobacco companies, the Tobacco Products Research Trust ("TPRT") was established as a charitable trust to administer funds made available by Imperial and the other UK tobacco companies through the Tobacco Advisory Council ("TAC"). The TAC had replaced the TRC in 1978.

  25.  The TPRT operated from 1982 to 1996. The objective of the TPRT was to promote independent research into the possible health effects of modifications to tobacco products. Under the TPRT, 36 projects were completed and over 100 articles were published in scientific journals. Over £8 million was committed by the UK tobacco companies (45 per cent of which was provided by Imperial) to research funded by the TPRT. In addition, three international symposia were held, two of which were organised and funded jointly with the Department of Health. The Chairman of the TPRT was Sir Peter Froggatt who, in 1996, wrote:

    "The sole monies available to the Trust were the principal sums from the tobacco industry through the Tobacco Advisory Council and the interest earned on these in the hands of the Trust and, for a time before that, in those of the ISCSH. Without these funds there would have been no research programme and no Trust! The industry, especially though not exclusively the companies' scientific research staff, took a healthy interest in the progress and results of the research programme, and in all ways relationships between the Trustees and the industry were amicable and constructive. This contributed greatly to the success of the research programme. I like to think that also in a wider sense both parties benefited. I certainly did and I believe the others did as well.".[146]

  26.  The UK tobacco companies funded a second independent charitable research trust, the Health Promotion Research Trust chaired by Sir John (later Lord) Butterfield. This was established in 1984 under a voluntary agreement with the Government. The UK tobacco companies provided £11 million over a three and a half year period to sponsor research into "health promotion in fields other than smoking".[147]

CONCLUSION

  27.  Since the early 1950s, Imperial has made a very substantial contribution to scientific research into smoking and health and the causes of diseases associated with smoking.

  28.  Initially, Imperial's research concentrated on identifying potentially harmful constituents of cigarette smoke with a view, if possible, to removing them. This line of enquiry was taken as far as it reasonably could and, after many years and a massive research effort by Imperial and others, it was discontinued. The focus of interest then moved to tar yield reduction and Imperial's research effort increasingly addressed product modification and the development of tobacco substitutes.

  29.  Imperial consulted leading scientists on the direction of its research and the interpretation of the results of research into smoking and health. It also worked closely with Government appointed independent scientific advisors and public bodies such as the ISCSH and TPRT.


141   Tobacco smoke consists of a particulate phase and a vapour phase. "Tar" is the total particulate matter in cigarette smoke less water and nicotine. Back

142   TMSC First Annual Report for the year ended 31 May 1957. Back

143   BR J Cancer 21, 1, 56-81. Back

144   C Swann and P Froggatt: TPRT, 1996: Preface, page 1. Back

145   C Swann and P Froggatt: TPRT, 1996: page 9. Back

146   C Swann and P Froggatt: TPRT, 1996: Preface, page 2. Back

147   Hansard 1982-3a. Back


 
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