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October 9, 2015
André Calantzopoulos
Chief Executive Officer
Philip Morris International, Inc.
120 Park Avenue
New York, New York 10017
Cc: Jennifer P. Goodale
Vice President, Contributions
Philip Morris International
Avenue de Rhodanie 50
1007 Lausanne, Switzerland
Re: Child labor in US tobacco farming
Dear Mr. Calantzopoulos,
We are writing today to share key findings from recent research we
conducted on child labor in tobacco farming in North Carolina in July
2015. We are encouraged by the steps taken to date to address
hazardous child labor in US tobacco farming, and we hope to continue
a constructive dialogue with Philip Morris International on this issue.
In July 2015, Human Rights Watch traveled to eastern North Carolina toinvestigate the health effects of tobacco farming on 16 and 17-year-oldchildren, a population excluded from certain protections under some
tobacco companies’ policies as well as under US law. Human Rights
Watch interviewed 33 children, ages 13 to 17, who worked on tobacco
farms in eastern North Carolina in 2015, including 26 children, ages 16or 17.
Human Rights Watch did not seek to monitor implementation of newindustry policies or conduct a comprehensive evaluation of how
conditions may have changed for child tobacco workers since HumanRights Watch conducted research on hazardous child labor in the USin 2013. We are unable to assess the implementation of any specifictobacco company’s child labor policy. However, Human Rights Watch
found children under age 16, as well as 16 and 17-year-old children,
working on tobacco farms in North Carolina in 2015.

AMSTERDAM · BEIRUT · BERLIN · BRUSSELS · CHICAGO · GENEVA · JOHANNESBURG · LONDON · LOS ANGELES · MOSCOW · NAIROBI · NEW YORK · PARIS ·SAN FRANCISCO - TOKYO · TORONTO · WASHINGTONThe children we interviewed reported working on tobacco farms in 12 counties inNorth Carolina. Most children worked for farm labor contractors or subcontractors,
and a few children worked directly for tobacco growers. Some children worked for
one employer, while others worked for more than one employer. In total, the children
we interviewed worked for at least 18 different growers or farm labor contractors ineastern North Carolina.
Many of the children could not identify the owner of the farm on which they worked,
and Human Rights Watch could not determine the companies that purchased
tobacco from the farms where children reported working.
The hazards and conditions Human Rights Watch documented in 2015 are consistent
with those documented in our 2013 research. We believe that these hazards andconditions are present on many US tobacco farms.
Working Conditions
All of the children interviewed worked as hired laborers on tobacco farms in North
Carolina; none worked on farms owned or operated by their own families. They
reported doing a range of tasks on tobacco farms in 2015, including planting
seedlings, weeding, uprooting and repositioning tobacco plants, topping, andremoving suckers.
The children interviewed for this report described working in similar conditions as
the child workers interviewed by Human Rights Watch in 2013. Most children worked
11 or 12 hours a day on tobacco farms. Some children worked six days a week, whileothers worked fewer days. Almost all children described fatigue and exhaustion afterworking long days in tobacco fields.
All children reported having opportunities to take breaks while working, usually
three times a day, including an hour break for lunch. Almost all children said they
were paid between $7.50 and $8.50 an hour, usually in cash. Very few children
reported problems with their wages.
Some children said they were asked their ages when they were hired. Other children
said they were not questioned about their age.
Health and Safety of 16 and 17-Year-Old Child Workers
Almost all of the 16 and 17-year-old children interviewed—25 out of 26—reported
feeling sick while working in tobacco farming in 2015, or after returning home fromworking in tobacco fields, with nausea, vomiting, headaches, dizziness, skinirritation, or respiratory symptoms.

Most of the children interviewed—23 out of 26—reported experiencing the sudden
onset of at least one specific symptom consistent with acute nicotine poisoning
while working in tobacco farming in 2015, or after returning home from working in
tobacco fields, including nausea, vomiting, headaches, dizziness, andlightheadedness. Some children also experienced a loss of appetite or recurrent
sleeplessness, also symptoms associated with nicotine exposure. In some cases,
the symptoms they reported could be linked to or exacerbated by pesticide exposure
or working in conditions of high heat and high humidity without sufficient rest,
shade, and hydration.
Many of the children interviewed—20 out of 26—described exposure to pesticides
while working in tobacco farming in 2015. Children reported either working in or nearfields that were being sprayed with pesticides, or re-entering fields that had beensprayed very recently. These children often said they could smell, feel, or taste thechemical spray, and 9 children reported immediate illness after coming into contact
with pesticides.
All 16 and 17-year-old children said they suffered while working in extreme heat on
tobacco farms in 2015 with little access to shade. Children did report consistentaccess to water. Many children reported pain from engaging in repetitive motions.
Children said they had inconsistent access to toilets, and many experienced
discomfort while waiting long periods of time before relieving themselves.
Most children said they had never received any health education or safety training
regarding the dangers of work in tobacco farming. Very few children were provided
with personal protective equipment by their employers, and almost no children had
access to a suitable handwashing facility with soap at their workplace.
Under international law, a child is anyone under the age of 18, and international
labor standards state that children under 18 should be prohibited from hazardous
work, defined as “work which, by its nature or the circumstances in which it iscarried out, is likely to harm the health, safety or morals of children.” Based on ourfield research, interviews with health professionals, and analysis of the public healthliterature, Human Rights Watch believes that no child under age 18 should bepermitted to work in direct contact with tobacco, due to the health risks posed by thework.
We plan to publish a report with detailed findings and recommendations this year.
The report will describe our methodology, findings, analysis of international law,
analysis of the US legal and regulatory framework regarding child labor, steps taken
by tobacco product manufacturers, tobacco leaf supply companies, and tobacco
grower associations to address child labor, gaps in protection, andrecommendations to US government, Congress, and the tobacco industry.

Human Rights Watch is committed to accurately representing the steps PMI hastaken to address child labor in tobacco farming. While we recognize that in pastcorrespondence or meetings, PMI has provided information regarding PMI’s policies
on child labor, we want to ensure that we have the most up-to-date and complete
information on PMI’s current policy.
In particular, we are interested in the following information:
1. What is PMI’s policy regarding work by children under 18 on tobacco farmssupplying PMI in the US, and globally?
2. Under PMI’s policy, what specific tasks are permissible for children under 18
to do on tobacco farms supplying PMI, and under what circumstances?
3. Does PMI prohibit “hazardous work” for children under 18, as defined byInternational Labour Organization standards? If the company prohibits
hazardous work for children under 18, what specific tasks does PMI define ashazardous?
a. Does PMI allow for any circumstances under which children under 18
can perform these types of tasks? If so, under what specificcircumstances?
4. How does PMI monitor child labor and the treatment of child workers on
farms supplying tobacco to PMI and to PMI subsidiaries and suppliers?
We would welcome a response to this letter by October 30, 2015. PMI’s response will
be reflected in our report. We will share a copy of the report with you a few days inadvance of its publication.
Thank you for your attention to these issues.
Sincerely,

Jo Becker
Advocacy Director
Children’s Rights Division

Jane Buchanan
Associate Director
Children’s Rights Division

Margaret WurthResearcher
Children’s Rights Division