Memorandum by the Tobacco Manufacturers'
Association
THE TOBACCO INDUSTRY AND THE HEALTH RISKS
OF SMOKING (TB 23)
EXECUTIVE SUMMARY
The TMA is an unincorporated trade association
representing the tobacco companies participating in the UK market.
The TMA's prime function is to represent the
UK tobacco companies in negotiations and dealings with the UK
Government and the authorities on issues of concern and interest
to its members. The TMA is a non-profit making, non-commercial
organisation; it represents the UK companies as a whole and does
not promote particular brands or products. Neither does the TMA
promote smoking in general, but it defends the freedom of adults
to smoke if they so choose.
Historically, the organisation representing
the UK tobacco companies has had a number of different functions
and, in addition to conducting dialogue with Government on behalf
of the other UK companies, it has sponsored and conducted joint
industry research to investigate questions relating to smoking
and health. This memorandum includes a summary of that research
programme. The research programme produced a large body of published
material which has contributed to the scientific knowledge of
smoking and health. This material has been available to independent
researchers, the Government and related bodies such as the Independent
Scientific Committee on Smoking and Health, as well as to TMA
member companies. No-one who was involved in the joint industry
research programme is employed by the TMA. The TMA is therefore
not able to offer any first-hand knowledge of the matters discussed.
There has been close co-operation between both
the UK tobacco companies and the Government in a number of areas
over many years. For example, the UK tobacco companies have worked
with successive Governments to agree action on product modification,
product labelling, sponsorship and advertising within the framework
of a series of voluntary agreements. This voluntary framework
has given the Government a system of regulatory control which
is flexible, speedy and effective.
Via the TMA, the UK tobacco companies have also
launched and funded, often in conjunction with other interested
parties, a number of initiatives relating to the prevention of
under-age smoking, and the issue of smoking in public places and
the workplace. These have included campaigns to educate children,
retailers and the general public about the law relating to the
prevention of sales of cigarettes to under 16s, the "CitizenCard"
proof of age scheme and an initiative to identify and promote
good practice in the accommodation of smoking and non-smoking
customers in restaurants, public houses, bars, hotels etc.
Recently, there has been a marked reduction
in the close co-operation with Government which has existed for
more than 40 years and a trend towards the exclusion of the UK
tobacco companies from dialogue concerning Government action on
tobacco and smoking issues. As the history of the UK tobacco companies'
relationship with Government shows, for more than 40 years they
have both collectively and individually been involved in a constructive
dialogue with Government involving a sharing of information and
knowledge. This dialogue has delivered significant results. It
is very much hoped that this can continue in future years.
THE TMA
1. The TMA is an unincorporated association
representing the tobacco companies participating in the UK market.
The members of the TMA include Gallaher Limited, Imperial Tobacco
Limited and British American Tobacco Company Limited, on whose
behalf this memorandum is submitted.
2. The TMA's prime function is to represent
the UK tobacco companies in negotiations and dealings with the
UK Government. For instance, it has, over the years, conducted
dialogue with representatives of the Govenment, the Department
of Health and the Chief Medical Officer on additives, taxation
and advertising, and other issues to be addressed by the Health
Committee. The TMA also provides an information service to its
members and, on request, to the public. The dialogue between the
UK tobacco companies and government has continued for over 40
years. The TMA believes that it should continue in the future.
3. The TMA was formed in 1994. There had,
however, been a number of other organisations representing the
UK tobacco companies in earlier years. The Tobacco Manufacturers'
Standing Committee (TMSC) was established in June 1956. The function
of this organisation was very different to the function of the
TMA today. It was formed by UK tobacco companies to sponsor research
into smoking and health questions and to make information available
to scientific researchers and the public. By 1963, its role had
developed and in January 1963 the TMSC became known as the Tobacco
Research Council (TRC) in recognition of its direct involvement
in smoking and health research at its laboratories at Harrogate.
4. In August 1978, the TRC was reconstituted
as the Research Committee on the Tobacco Advisory Council (TAC)
to reflect the increasing emphasis on its own research programmes
and expenditure. The TAC also absorbed the Tobacco Advisory Committee,
a body initially established in the 1940s to advise the Government
on the buying of leaf overseas but whose role had developed over
the years to become more concerned with public relations issues
and commercial matters of significance to its members.
5. In January 1994 there was a further name
change to the TMA as it was felt that the name TAC did not clearly
reflect the change of focus in its role to that of a trade association
for the UK companies, representing them in negotiations and other
dealings with government and other authorities on issues of concern
and interest to them.
JOINT INDUSTRY
FUNDED RESEARCH
The Tobacco Manufacturers' Standing Committee
6. In September 1950 Sir Richard Doll and
Professor Austin Bradford Hill published a preliminary report
which linked lung cancer with tobacco smoking based on patients
from 20 hospitals in the London region. 1 In 1951 the Government
referred the matter to their Standing Advisory Committee on Cancer
and Radiotherapy and then to a panel under the Government Actuary.
In February 1954 the then Minister of Health, the Right Honourable
Mr Iain Macleod, on the advice of the Chief Medical Officer, made
a statement in Parliament in which he accepted the Standing Committee's
view that the statistical evidence pointed to smoking as a factor
in lung cancer and he announced a research grant of £250,000
from the UK tobacco companies to the Medical Research Council
(MRC).
7. The UK tobacco companies made the grant
of £250,000 (about £4,000,000 in today's terms) to the
MRC to support a seven year research programme to enable further
investigation into smoking and health issues. The companies chose
the MRC on the advice of the Minister of Health and because they
believed that an impartial and responsible medical body should
apply the funds to such projects as it (the MRC) deemed appropriate.
The companies did not have any control over the projects selected
by the MRC for funding.
8. In 1956, the UK companies decided to
set up the TMSC whose brief 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".2
9. In 1957, in its first annual report,
the TMSC confirmed that it intended to set up a fund, in addition
to the grant to the MRC, to promote and assist research relating
to smoking and health. To assist the TMSC to determine which projects
to fund, the TMSC entered an arrangement with the British Empire
Cancer Campaign so that:
" . . . it might have the benefit of the
advice of the Scientific Advisory Committee of the Campaign on
schemes of research in the field of cancer for which the support
of the Tobacco Manufacturers' Standing Committee had been sought".3
10. The TMSC was also assisted in its decision-making
by its scientific consultants who included Sir Alfred Egerton
(Fellow of the Royal Society and Emeritus Professor of Chemical
Technology at the University of London) and Sir Ronald Fisher
(Fellow of the Royal Society and Professor of Genetics at the
University of Cambridge).
11. During the years 1958 to 1960 the TMSC
published an annual report which described the main developments
in the work of the TMSC. (Later the TRC published reviews of its
activities every couple of years or so. These summarised the research
financed by it and the work carried out at Harrogate, its own
laboratory.) Each annual report detailed the research directly
supported by the Committee and noted the research financed through
the MRC. The 1960 report also listed the TMSC research papers
that had been published to date and noted that a reference library
was available at the TMSC's offices for scientists and others
working in this field.
12. Over the years, the TMSC developed its
policy and objectives in research more precisely. These were formulated
on the recommendation of the TMSC's scientific advisers and the
main fields of research were listed in the annual report for the
year ended 31 May 1959.
13. The TMSC exercised no control over its
grantees, who were free to conduct and pubish their research as
they saw fit. In a memorandum submitted to the Expenditure Committee,
the policy of the TRC was explained (the TMSC operated by the
same policy);
"Once given these grants are free of strings.
The idea for the research comes from the grantee; he alone is
responsible for the conduct of the work and the ultimate decisions
on publication are his. Indeed the sort of research worker which
the Council supports would not come forward on any other terms."4
14. From around 1959 the TMSC gave consideration
to the implementation of a major research programme. By 1960 a
decision had been made to establish its own research laboratory
and in September 1962 a purpose-built laboratory was opened at
Harrogate. The cost of the purchase of the site and the construction
costs were equivalent to about £4 million in today's terms.
THE TOBACCO
RESEARCH COUNCIL
15. In 1962 the Royal College of Physicians
of London (RCP) published a report on Smoking in relation to Cancer
of the Lung and Other Diseases. The report concluded that cigarette
smoking was a cause of lung cancer and bronchitis, and probably
contributed to the development of coronary heart disease and various
other less common diseases. The report urged the Government to
take "decisive steps . . . to curb the present rising consumption
of tobacco, and especially of cigarettes".5
16. These events resulted in the members
of the TMSC re-assessing their contribution to research in this
area. They launched an ambitious research programme, funded and
directed jointly by the UK companies themselves. The programme
was concerned to investigate which, if any, properties of tobacco
products might be responsible for the reported health risks associated
with smoking, and how the products might be modified to reduce
such risks.
17. The TMSC adopted a working hypothesis
upon which this research programme should be based. This hypothesis
was that cigarette smoke affected the respiratory epithelium (surface
layer) by direct contact.
18. At this time, to reflect the fact that
the TMSC was to conduct its own smoking and health research programme,
it was decided that its name should be changed to the Tobacco
Research Council from January 1963. The objects of the TRC were
to conduct, promote and co-operate in and keep in touch with research
into the relationship between smoking and health.
19. In the TRC's Review of Past and Current
Activities published in 1963, the Director, G F Todd, summarised
the programme of research.
"The programme of research into the main
aspects of smoking and health, formerly financed by TMSC and now
being financed by the Tobacco Research Council on the basis of
the recommendations of medical and scientific advisers, has three
main parts, each with several sub-divisions:
Tobacco and Tobacco Smoke
(1) Chemical constituents.
(2) Physical properties.
(3) Biological effects.
(4) Pharmacological effects.
Smokers
(1) Statistics.
(2) Genetics.
(3) Psychology.
Health
(1) Epidemiological enquiries.
(2) Sub-groups susceptible to cardio-respiratory
disease.
(3) General medical research."6
20. In 1967, the TRC published a Review of its
Activities for the years 1963-66. This Review gave a comprehensive
account of the TRC's activities since 1963 and included summaries
of the research projects and experiments which the TRC had conducted
at Harrogate or supported financially. The TRC took the view that
it should obtain as much relevant information as possible about
the chemical nature of tobacco smoke. The TRC had therefore devoted
the largest part of its expenditure and effort to chemical research
and biological testing, both of which were concentrated at Harrogate:
"The bio-essay work carried out there is
primarily concerned with the possible roles of cigarette smoking
in lung cancer. Most of this work is accordingly planned on the
working hypothesis that cigarette smoke affects the respiratory
epithelium by direct contact . . .
The second line of research is concerned with
people. It comprises a series of studies of widely different kinds
to provide information about personal, environmental and other
factors in diseases associated with smoking. Information is beginning
to emerge about the characteristics of sufferers from these diseases
which may ultimately explain why only a monority of smokers and
some non-smokers contract any one of them . . .
There is a third group of projects, which is
on a smaller scale and directed at motives for smoking . . .7
The TRC also made contributions to general medical
research.
21. This bio-assay work at Harrogate was
conducted by a team of scientists under the directorship, initially,
of Dr T D Day, formerly of Leeds University. The aims of the research
were set, and the results reviewed, by committees of scientists
from the member companies as well as scientific consultants. The
main work undertaken at Harrogate was a programme of mouse skin-painting.
The aim of the mouse skin-painting programme was first to establish
the mouse skin-painting test as an adequate quantitative measure
of any biological activity in mouse skin of cigarette smoke condensate
(produced using smoking machines), and secondly, to identify any
substance in cigarette smoke responsible for biological activity.
The second objective was to be achieved by testing condensate
representing different chemical fractions of cigarette smoke.
It was hoped that the results would provide guidance for product
modification.
22. The results of this bio-assay work were
reported initially in a paper by Dr Day in the British Journal
of Cancer in March 1967, and attracted wide press coverage. It
was also reported in the TRC's Review of Activities 1963-66 which
noted:
"In practical terms an important feature
of these results seems to be that they show that in relation to
mouse skin there are stable non-volatile neutral carcinogens in
cigarette smoke condensate which are worth serious attention and
which in particular merit investigation by detailed fractionation."8
23. The results were discussed with eminent
scientists including Professor Alexander Haddow, Sir Charles Dodds
of the British Empire Cancer Campaign, Dr G F Marrian of the Imperial
Cancer Research Fund, Sir Max Rosenheim, President of the Royal
College of Physicians, and Dr C M Fletcher.
24. By 1969, the major part of the TRC's
research effort at Harrogate was concerned with the search for
compounds in cigarette smoke with potential biological activity
by fractionating the whole smoke and cigarette smoke condensate.
"The major use to which these facilties
has been put has been in support of the chemical fractionation
of cigarette smoke condensate. The objective is to discover whether
many or only relatively few of the constituents of smoke condensate
contribute to the tumorigenicity of the condensate, and to investigate
the ways in which they so contribute."9
25. This effort continued until 1970 when
the TRC re-evaluated the research programme at Harrogate. The
TRC concluded that the research could not provide any conclusive
guidance on product modification. The Review of Activities, 1967-69
stated that ". . . it may be concluded that this work [on
chemical fractionation] has been taken as far as it profitably
can." 10
26. In 1975, the TRC published a Review
of Activities for the years 1970-74. This report confirmed that
the TRC had decided "to abandon the attempt to carry the
fractionation of condensate any further. The ending of fractionation
entailed stopping the series of large-scale mouse skin-painting
experiments which had been continuously in progress since the
laboratories were set up and which had made a major contribution
to the development of this form of bio-assay".11
27. In addition to the Harrogate programme,
the TRC continued to sponsor academic research in many areas relevant
to smoking and health. An examination of the public record will
reveal more than 400 published scientific papers of projects which
received funding from the TRC.
28. By the 1970s, the Government began to
focus on product modification initiatives. In 1973 the Independent
Scientific Committee on Smoking and Health was created (see paragraph
35 et seq) and part of its terms of reference were to review research
into ". . . less dangerous smoking". The Lord Hunter
of Newington wrote in his covering letter to the Committee's Second
Report on Smoking and Health:
". . . The second, and I believe more important,
part [of the second report] outlines the progress made towards
the development of "lower risk" cigarettes." 12
This initiative encouraged the UK tobacco companies
to continue their efforts in relation to product modification,
particularly with respect to lower tar yield products, and it
was more appropriate that this research should be conducted in-house
rather than funded by the industry jointly.
29. The TRC nevertheless continued to support
independent research projects in a variety of areas.
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