APPENDIX 4
Memorandum by Mr Nigel Gray (TB 6)
THE FAILURE OF THE LOW TAR PROGRAMME AND
THE VOLUNTARY AGREEMENT IN THE UK
This was one of the few attempts to work with
the tobacco industry, yet it does not seem to have brought to
light the material I will present in the second section concerning
differing levels of nitrosamines in cigarettes.
Although it seems that the early years of the
Low Tar Programme did produce quantitative reductions of some
magnitude, and these seem to have lead to reduced mortality from
lung cancer in the seventies, there was no attempt to focus on
individual carcinogens such as Benz(A)pyrene (BaP) and the various
Tobacco Specific Nitrosamines (TSNA's).
Further, more modern studies of mortality—-the
comparison between Cancer Prevention Study 1 (CPS 1) from 1959
through 1965 and CPS 2 (1982 through 1988) in the US shows an
increase in mortality among long duration (40-49 years), one pack
a day smokers—a group who necessarily smoked progressively
lower tar cigarettes as this was all that was available (reference
1).
Further there was, during the eighties, a swing
towards adenocarcinoma, initially a much less common cancer in
the US and elsewhere, although I know of no study in UK smokers
(reference 2).
These things occurred despite the quantitative
reduction in tar—no account was taken of qualitative changes
in cigarettes, which instead of being beneficial, appear to have
been harmful.
Nitrosamines and Cancer
The International Agency for Research against
Cancer (IARC), in 1987, published a monograph (number 38) on cigarette
smoking which drew attention to the role of nitrosamines in cancer
and noted that, in particular, that 4-(methynitrosamino)-1-(3-pyridyl)-1-butanone
(NNK) is carcinogenic in several animal species, producing adenocarcinoma
of the lung regardless of route of administration. Another nitrosamine
N-Nitrosonornicotine (NNN) is an oesophageal carcinogen in similar
testing systems.
Hoffman (reference 3) has published an ongoing
analysis of a single (unnamed) US brand of cigarette which documents
a 45 per cent increase in NNK in the smoke between the late seventies
and the mid nineties, a period when BaP was stable in this brand.
Others (reference 4), in the early nineties,
published analysis showing great diversity between cigarettes
from various countries in nitrosamine yields. Nitrosamines correlate
with nitrates in tobacco, the nitrates coming from fertiliser
and other sources, and the nitrosamines being formed during the
curing and storage process. Two tables from this work show the
differences.
NITROSAMINE VS NITRATE
| |
MS | TOB
| TOB |
| Country | NNK**
| NNK** | Nitrate*
|
| France | 19-498
| 57-990 | 1.5-19.4
|
| Poland | 38-105
| 140-450 | 4.4-12.8
|
| UK | 18-103
| 92-433 | 1.4-8.0
|
| US | 41-145
| 433-733 | 6.2-13.5
|
*MG/CIG.
**NG/CIG.
FISCHER,IARC 105.
NNK=4-(N-NITROSAMINO)-1-(3-PYRIDYL)-1-BUTANONE.
|
NITROSAMINE VS NITRATE
| | MS
| TOB | TOB
|
| Country | NNN**
| NNN** | Nitrate*
|
| France | 11-1,000
| 120-6,019 | 1.5-19.4
|
| Poland | 121-345
| 870-2,760 | 4.4-12.8
|
| UK | 17-123
| 140-1,218 | 1.4-8.0
|
| US | 54-196
| 993-1,947 | 6.2-13.5
|
*MG/CIG.
**NG/CIG.
FISCHER,IARC 105.
NNN=N-NITROSONORNICOTINE.
|
In the tables, MS stands for mainstream smoke and TOB for tobacco
content.
The question arising from this data is—why, if some cigarettes
can be made with low levels of NNK and NNN, are ANY cigarettes
allowed to be made with high levels?
We (Gray, Boyle, Zatonsky-reference 5) proposed in a letter to
the Lancet in September 1998, that the market should be measured
and the median of the existing market established as an interim
upper limit for these substances. Obviously the industry CAN do
this as it is already doing it for half its products. We recommend
a similar approach to other main classes of carcinogens such as
BaP and the various heavy metal carcinogens.
We illustrated our point with the only data we could find—it
was from Poland—to exemplify the system.
ANALYSIS OF POLISH CIGARETTE BRANDS 1994
| Brand | TAR
mgm
| NNK
ng/cig |
NNN
ng/cig |
| Radomski | 16
| 240 | 1,120
|
| Mocne | 16
| 890 | 2,830
|
| Extra Mocne | 17
| 350 | 1,120
|
| Populame | 17
| 360 | 1,190
|
| Klubowe | 15
| 310 | 1,040
|
| Caro | 17 |
120 | 870
|
| Carmen | 16
| 160 | 760
|
| Stoleczne |
| 230 | 620
|
| Mars |
| 260 | 840
|
| Camel | 15
| 990 | 2,230
|
| Golden American |
| 270 | 1,330
|
| Marlboro | 14
| 580 | 2,460
|
| Median |
| 310 | 1,120
|
As you can imagine, we find this material a serious cause
for anger as the global tobacco industry, which has the necessary
technology to reduce the carcinogenic load of its products, has
not chosen to do so and, apparently, never informed the Product
Modification Programme of such data, which we believe they certainly
have.
Accordingly we arranged for the purchase and testing for
nitrosamines of Camel and Lucky Strike cigarettes from over 20
countries, as these are global brands, advertised globally, and
customers could reasonably expect them to be similar in content,
"flavour" etc.
Not so. There is a three-fold difference for NNK between
Camel bought in 20 plus countries, and a five-fold difference
between Lucky Strike similarly purchased. The range for Camel
is between 40 and 140 nanograms per cigarette and for Lucky Strike
between 50 and 250 Ng/cig.
IN SUMMARY
These findings, among the very few in the published and yet-to-be
published literature, make a powerful case for regulation of the
cigarette by governments, based on our suggestion of establishing
the median and setting it as an upper limit, repeating the process
over time until the best possible outcome is achieved.
The tobacco industry could have done this and has not.
A further point of importance is that the industry has used
as a legal defence against lawsuits, the fact that there is a
health warning on the packet. No health warning advises their
customers that carcinogen levels may vary fivefold.
September 1999
REFERENCES
1. US Department of Health and Human Services. Changes in
Cigarette Related Disease Risk and their implication for Prevention
and Control. NIH Publication No. 97-4213. Rockville, MD:US Department
of Health and Human services, Public Health Service, National
Cancer Institute, 1997; pp. 305-33).
2. El-Torkey, M, El-Zeky, F, and Hall, JC Significant changes
in the distribution of histological types of lung cancer. A review
of 4,928 cases. Cancer (Phil) 1990; 65:2361-2367.
3. Hoffmann D and Hoffmann I, The changing cigarette, 1950-1995.
J Toxicology Environ Health, 1997; 50: 307-364.
4. Fischer S, Speigelhalder B, Preussman R Tobacco specific
nitrosamines in commercial cigaretttes; possibilities for reducing
exposure. International Agency for Research on Cancer. Relevance
to human cancer of N-nitroso compounds, tobacco smoke and mycotoxins,
Monogr No 105, 1991. IARC, Lyon, 489-93.
5. Gray N, Boyle P, Zatonski W, Lancet 1998; 352: 787-88).
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