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S. HRG. 110–1118 

THE ACCURACY OF THE FTC TAR 

AND NICOTINE CIGARETTE RATING SYSTEM 

HEARING 

BEFORE THE

COMMITTEE ON COMMERCE, 

SCIENCE, AND TRANSPORTATION 

UNITED STATES SENATE 

ONE HUNDRED TENTH CONGRESS 

FIRST SESSION 

NOVEMBER 13, 2007 

Printed for the use of the Committee on Commerce, Science, and Transportation 

( 

(II) 

SENATE COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION 

ONE HUNDRED TENTH CONGRESS 

FIRST SESSION 

DANIEL K. INOUYE, Hawaii, Chairman 

JOHN D. ROCKEFELLER IV, West Virginia 

JOHN F. KERRY, Massachusetts 

BYRON L. DORGAN, North Dakota 

BARBARA BOXER, California 

BILL NELSON, Florida 

MARIA CANTWELL, Washington 

FRANK R. LAUTENBERG, New Jersey 

MARK PRYOR, Arkansas 

THOMAS R. CARPER, Delaware 

CLAIRE MCCASKILL, Missouri 

AMY KLOBUCHAR, Minnesota 

TED STEVENS, Alaska, Vice Chairman 

JOHN MCCAIN, Arizona 

TRENT LOTT, Mississippi 

KAY BAILEY HUTCHISON, Texas 

OLYMPIA J. SNOWE, Maine 

GORDON H. SMITH, Oregon 

JOHN ENSIGN, Nevada 

JOHN E. SUNUNU, New Hampshire 

JIM DEMINT, South Carolina 

DAVID VITTER, Louisiana 

JOHN THUNE, South Dakota 

MARGARET L. CUMMISKY, Democratic Staff Director and Chief Counsel 

LILA HARPER HELMS, Democratic Deputy Staff Director and Policy Director 

CHRISTINE D. KURTH, Republican Staff Director and General Counsel 

PAUL NAGLE, Republican Chief Counsel 

(III) 

C O N T E N T S 

Page 

Hearing held on November 13, 2007 ...................................................................... 1 

Statement of Senator Lautenberg .......................................................................... 1 

Statement of Senator Stevens ................................................................................ 3 

WITNESSES

Ashley, Ph.D., David L., Chief, Emergency Response and Air Toxicants 

Branch; Chief, Tobacco Laboratory, National Center for Environmental 

Health, Centers for Disease Control and Prevention (CDC), Department 

of Health and Human Services; and Chair, Tobacco Laboratory Network, 

World Health Organization ................................................................................. 15 

Prepared statement .......................................................................................... 17 

Backinger, Ph.D., Cathy L., Acting Chief, Tobacco Control Research Branch, 

National Cancer Institute, National Institutes of Health, U.S. Department 

of Health and Human Services ........................................................................... 10 

Prepared statement .......................................................................................... 11 

Goldberg, Ph.D., Marvin E., Irving & Irene Bard Professor of Marketing, 

Smeal College of Business, Penn State University ........................................... 39 

Prepared statement .......................................................................................... 40 

Henningfield, Ph.D., Jack E., Vice President, Research and Health Policy, 

Pinney Associates; Professor of Behavioral Biology, Adjunct, and Director, 

Innovators Awards Program, Department of Psychiatry and Behavioral 

Sciences, The Johns Hopkins University School of Medicine ........................... 33 

Prepared statement .......................................................................................... 35 

Kovacic, Hon. William E., Commissioner, Federal Trade Commission ............... 3 

Prepared statement .......................................................................................... 5 

Samet, M.D., M.S., Jonathan M., Professor and Chairman, Department of 

Epidemiology, Johns Hopkins Bloomberg School of Public Health .................. 25 

Prepared statement .......................................................................................... 26 

Sheller, Esq., Stephen A., Founder and Managing Partner, Sheller, P.C. ......... 50 

Prepared statement .......................................................................................... 51 

APPENDIX

Article from Pediatrics—Official Journal of the American Academy, dated 

October 2004, entitled ‘‘Adolescents’ Beliefs About the Risks Involved in 

Smoking ‘‘Light’’ Cigarettes’’ ............................................................................... 75 

Article from the American Journal of Public Health, dated December 2006, 

entitled ‘‘Effect of Televised, Tobacco Company-Funded Smoking Prevention 

Advertising on Youth Smoking-Related Beliefs, Intentions, and Behavior’’ ... 58 

Harbour, Hon. Pamela Jones, Commissioner, Federal Trade Commission, prepared statement ................................................................................................... 57 

Letter, dated May 10, 2007, to Hon. Frank R. Lautenberg from Hon. Pamela 

Jones Harbour, Commissioner, Federal Trade Commission ............................. 57 

R.J. Reynolds Tobacco Co., prepared statement ................................................... 84 

Response to written questions submitted by Hon. Daniel K. Inouye to: 

Hon. William E. Kovacic .................................................................................. 68 

Response to written questions submitted by Hon. Frank R. Lautenberg to: 

Marvin E. Goldberg, Ph.D. .............................................................................. 73 

Supplemental information submitted by Cathy L. Backinger, Ph.D. .................. 69 

(1) 

THE ACCURACY OF THE FTC TAR AND 

NICOTINE CIGARETTE RATING SYSTEM 

TUESDAY, NOVEMBER 13, 2007 

U.S. SENATE, 

COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION, 

Washington, DC. 

The Committee met, pursuant to notice, at 2:35 p.m. in room 

SR–253, Russell Senate Office Building, Hon. Frank R. Lautenberg, 

presiding. 

OPENING STATEMENT OF HON. FRANK R. LAUTENBERG, 

U.S. SENATOR FROM NEW JERSEY 

Senator LAUTENBERG. Now, we shall call the meeting to order. 

OK. 

Today’s hearing is part of our oversight of the Federal Trade 

Commission’s activities. We’re going to look closely at the FTC’s 

role in the regulation of cigarette marketing. We’re going to focus 

on the tests that the FTC has permitted tobacco companies to use 

for decades to measure the tar and nicotine levels of its cigarettes. 

Smokers have long relied on these tar and nicotine ratings to determine which cigarettes to smoke. For example, cigarettes with a low 

tar FTC rating are marketed as ‘‘light’’ cigarettes, and, as we’re 

going to learn from today’s hearing, smokers believe that when 

they switch to a light cigarette they’re turning to a safer alternative than a regular cigarette. But the National Cancer Institute 

and other studies show that switching to a light cigarette may not 

only be as bad as a regular cigarette, but often its worse for your 

health. I want to repeat that, that a light cigarette can often be 

more deadly than a regular cigarette. And addicted smokers are 

the victims of this deception. 

Now, I, too, was a smoker. But, fortunately, my 10-year-old 

daughter convinced me to stop. One day when I lit a cigarette at 

home, she said, and I’ll quote her, ‘‘Daddy, they told me at school 

that, if you smoke, that you get a black box in your throat, and I 

love you, and I don’t want you to get a black box in your throat.’’ 

And it took me a couple of days, and that was the end of smoking. 

And I know it’s not easy to give it up. As I smoked in those years, 

I kept thinking about giving it up, and never quite made it. 

The reality is that most smokers are addicted to a drug, a drug 

called nicotine. And that’s what we’re going to learn in this hearing, it’s the effect of nicotine on the brain that renders the FTC rating method inaccurate. The FTC employs the use of what some 

have called the ‘‘smoking robot machine.’’ And thanks to the CenVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
2 

ters for Disease Control, we have a short video which I’d like to 

show you now. 

Now, can the people sitting in the audience see this? It demonstrates the FTC Method and the smoking robot. 

Now, when you look at these nonaddicted machines, you don’t get 

an accurate picture as to what really is happening. The machine’s 

smoking, and the machine’s life cycle is not affected. But the smokers’ are. The reality is that smokers don’t smoke cigarettes like a 

machine; rather, our brains manipulate puffing patterns to make 

sure that a smoker takes in enough nicotine from every cigarette 

to soothe the addiction. And that’s why many who switch from 

Marlboros to Marlboro Lights wind up getting more tar, because 

they’re taking longer and deeper puffs to bring in the same amount 

of nicotine that they got from a standard Marlboro cigarette. And 

even the FTC has the knowledge that, in its testing method, that 

it doesn’t work. 

In fact, in May 2000, the FTC put out a consumer alert about 

their tar and nicotine ratings which said—I quote here—‘‘Don’t 

count on the numbers,’’ and ‘‘cigarette tar and nicotine ratings can’t 

predict the amount of tar and nicotine that you get.’’ So, the FTC 

was saying, essentially, ‘‘Don’t pay attention to our own system.’’ 

The FTC should not allow, therefore, this rating system to continue 

if it cannot stand behind it. And big tobacco should not be able to 

hide behind the FTC Method to justify the claim that light and 

low-tar cigarettes are healthier. 

In 2005, in this committee, I tried to fix this problem, and I 

brought an amendment to prohibit the tobacco companies from continuing to use the FTC Method to justify health claims about their 

cigarettes. My amendment lost on a party-line vote. And I’m hopeful that, in the wake of this hearing, that we can build momentum 

to finally tackle this problem seriously. 

The issue of tobacco control is a critical issue for our country. Tobacco-related illnesses rob more than 400,000 Americans of their 

lives each and every year. And tobacco creates $89 billion in annual healthcare costs. 

Now, just last week, the Centers for Disease Control reported 

that recent declines in smoking have stopped. Now, this is a disturbing development for America’s public health. And, as many 

know, I have a long history of trying to write sensible laws to help 

control the damage caused by tobacco use. 

Now, I wrote the law banning smoking on airplanes in 1987. 

That law changed our Nation’s culture about secondhand smoke 

and helped usher in the smoke-free revolution that we’re now seeing across the country. And I’m proud that my home state of New 

Jersey recently passed a statewide law banning smoking in restaurants, bars, and workplaces. 

I also wrote the law, in 1994, that requires that all buildings 

that house federally funded programs for children maintain a 

smoke-free environment. And now, we have another urgent tobacco 

problem to fix. 

So, I look forward to hearing the testimony from our witnesses 

today. 

3 

And I’m pleased to be sitting here with a colleague and an ally 

in this, the Vice Chairman of the Commerce Committee, Senator 

Stevens. 

STATEMENT OF HON. TED STEVENS, 

U.S. SENATOR FROM ALASKA 

Senator STEVENS. Thank you very much. 

I was trying to remember who was the author of that bill on Federal buildings, you or me, but it’s all right. 

I do thank you for holding the hearing, and I think there is a 

lot that remains to be done in this area. The FTC has used the 

same rating system to measure tar, nicotine, and carbon monoxide 

yields for 40 years yet cigarette design has not remained the same 

during this period. Concerns have been expressed to us that consumers are being misled by the cigarette rating system that’s currently in use as it relates to light and low-tar cigarettes. The test 

machine was not intended to imitate human smokers, yet that is 

how consumers are interpreting the test results. I look forward to 

hearing the witnesses today. 

And, unfortunately, I have another meeting at 3:30, but I’m 

pleased you have held this hearing, Mr. Chairman. 

Senator LAUTENBERG. Thanks very much. 

Now, I want to welcome our witnesses, but I also want to point 

out that both Altria, formerly known as Philip Morris, and R.J. 

Reynolds were asked if they would testify today, and they both refused. The Committee’s going to explore, nevertheless, what steps 

will be taken to gather information from these companies after this 

hearing. 

And, with that, I welcome our first panel. We have Mr. William 

Kovacic, a Commissioner of the Federal Trade Commission; Dr. 

Cathy Backinger, the Acting Chief of the Tobacco Control Research 

Branch of the National Cancer Institute; and Dr. David Ashley, the 

Chief of the Division of Laboratory Sciences at the Centers for Disease Control and Prevention. And I thank you for joining us. 

Mr. Kovacic, you may begin, please. And we ask you to hold your 

testimony to 5 minutes, if you will. 

STATEMENT OF HON. WILLIAM E. KOVACIC, COMMISSIONER, 

FEDERAL TRADE COMMISSION 

Mr. KOVACIC. Thank you, Vice Chairman Stevens and Senator 

Lautenberg, for the opportunity to testify about the Federal Trade 

Commission’s work concerning tar and nicotine ratings for cigarettes. 

The written statement that I submitted presents the views of the 

Commission itself, and my spoken remarks today present my own 

views, and not necessarily those of my colleagues. 

The question of how to give consumers useful information about 

the health risks of smoking has commanded the FTC’s attention for 

nearly a half century. It was the FTC’s cigarette rule in 1964, 

which required cigarette companies to place health warnings on 

packages and advertisements, that helped spur the adoption of the 

Federal Cigarette Labeling and Advertising Act. In 1967, the FTC 

began a program to provide cigarette ratings for tar and nicotine. 

Testing was done under the Cambridge Filter Test Method which 

4 

is known in the United States as the FTC Method. The program 

sought to provide smokers seeking to switch to lower-tar cigarettes 

information based on a single-standard measurement. 

For some time, the Commission has been concerned that the current test method may mislead individual consumers who rely on 

the ratings it produces to indicate the amount of tar and nicotine 

that they actually will get from their cigarettes. The current ratings tend to be relatively poor indicators of tar and nicotine exposure. Among other reasons, smokers of lower-rated cigarettes tend 

to take bigger, deeper, more frequent puffs, or otherwise alter their 

smoking behavior to obtain the dosage of nicotine they need. 

Although the limits of the test methodology were recognized 

when the program began in 1967, they became a substantially 

greater concern since the 1990s, due to changes in modern cigarette design and a better understanding of the nature and effects 

of smoking behavior. These concerns led the Commission, in 1994, 

along with Congressman Waxman, to ask the National Cancer Institute to convene a conference to address cigarette testing issues. 

The NCI convened the conference, and, in 1996, recommended 

that the cigarette testing system measure and publish information 

on the range of tar, nicotine, and carbon monoxide that most smokers would expect from the cigarettes they smoke. 

In September 1997, the Commission requested public comments 

and proposed revisions to the test method that would add a second 

tier of testing to better approximate the range of tar and nicotine 

yields and make it more apparent to consumers that the amounts 

of tar and nicotine they get from any specific cigarette depends on 

how they smoke. 

Around the same time, some public health officials warned that 

recently released studies raised serious questions about the basic 

assumption then underlying cigarette testing; namely, that cigarettes with lower machine-measured tar and nicotine ratings are 

less harmful than ones with higher ratings. An NCI report in 1997 

suggested that the reduced tar levels of modern cigarettes might 

have less benefits than previously believed. Other studies reported 

that changes in smoking behavior and cigarette design appear to 

have resulted in an increase in a specific type of cancer that occurs 

deeper in the lung. 

Citing these studies, public health agencies asked the FTC to 

postpone its proposed changes to the test method until a broader 

review of unresolved scientific issues surrounding the system could 

be addressed. 

In November 2001, the NCI reported the results of a review of 

the epidemiological and other scientific evidence on the public 

health effects of low-tar cigarettes. The panel of scientific experts 

assembled for that inquiry concluded that the existing scientific 

evidence did not demonstrate a public health benefit to smokers 

who switched to low-tar or light cigarettes. 

The 2001 NCI report also concluded that measurements of tar 

and nicotine, as measured by the FTC Method, did not offer meaningful information to consumers, and that there was an urgent 

need to develop new testing approaches. The Commission understands that this report represented, at least in part, the first step 

in an HHS response to a 1998 FTC request for assistance. When 

5 

1The written statement presents the views of the Federal Trade Commission. My oral testimony and responses to questions reflect my views, and do not necessarily reflect the views of 

the Commission or any other Commissioner. 2See infra n. 15. 

it announced the release of this report, the NCI noted the FTC’s 

previous request and indicated that it would work with other 

science-based agencies at HHS to determine how to change the 

testing method. 

The FTC understands that representatives from agencies within 

HHS are continuing to explore these issues. In addition, the World 

Health Organization has assembled a panel of experts to address 

tobacco testing issues. 

The FTC believes it is vital that there be an effective mechanism 

for implementing any recommended changes to the test method 

once these evaluations are completed. The Commission brings 

strong market-based expertise to its scrutiny of consumer protection matters, yet we lack the specialized scientific expertise needed 

to design and evaluate scientific test methods. 

When we evaluate medical or other scientific issues, the Commission often relies on other government agencies and outside experts 

with more knowledge in relevant areas. In its 1999 July report to 

the Congress, pursuant to the Cigarette Labeling and Advertising 

Act, the Commission recommended that Congress consider giving 

authority over cigarette testing to one of the Federal Government’s 

science-based public health agencies. The Commission renewed 

that recommendation in 2003 in testimony before Congress, and 

the Commission reiterates that recommendation again today. 

I thank the Committee for the opportunity to address these 

issues, and I await your questions. 

[The prepared statement of Mr. Kovacic follows:] 

PREPARED STATEMENT OF HON. WILLIAM E. KOVACIC, COMMISSIONER, 

FEDERAL TRADE COMMISSION

Chairman Inouye, Vice Chairman Stevens, Senator Lautenberg, and Members of 

the Committee, I am William E. Kovacic, a Commissioner at the Federal Trade 

Commission (‘‘FTC’’ or ‘‘Commission’’).1 The Commission is pleased to have this opportunity to provide testimony at today’s hearing. Today, I would like to discuss the 

FTC’s responsibilities and activities in the area of tobacco advertising generally, and 

then turn more specifically to a discussion of cigarette testing and the promotion 

of cigarettes based on machine-measured tar and nicotine yields. The testimony discusses concerns the FTC has with the test method, and renews the Commission’s 

previous recommendation that Congress consider giving authority over cigarette 

testing to one of the Federal Government’s science-based public health agencies. 

As the Nation’s consumer protection agency, the FTC has a broad mandate, with 

diverse responsibilities such as the prosecution and prevention of fraud in the marketing of healthcare products, deceptive financial practices in the subprime mortgage and credit repair industries, identity theft, and technology risks to consumers 

such as spam and spyware. The FTC also has responsibility over the marketing and 

promotion of tobacco products, including cigarettes, smokeless tobacco, cigars, and 

new tobacco products. One of the most challenging issues concerning cigarette advertising and promotion is the topic of today’s hearing: the advertising and promotion of cigarettes based on their tar and nicotine yields as measured by the test 

methodology commonly referred to in the United States as ‘‘the FTC Method,’’ although, as discussed below, the FTC stopped testing according to this method in 

1987.2

Cigarette testing under this test methodology began 40 years ago, in 1967, when 

the Commission approved use of the FTC Method for measuring the tar and nicotine 

6 

3When the Commission approved the test methodology, it was called the Cambridge Filter 

Method. The Cambridge Filter Method is now commonly referred in the United States as ‘‘the 

FTC Method.’’ 4When the test method was adopted, the public health community believed that ‘‘[t]he preponderance of scientific information strongly suggests that the lower the tar and nicotine content 

of cigarette smoke, the less harmful would be the effect.’’ U.S. Dept. of Health and Human Services, The Health Consequences of Smoking: The Changing Cigarette 1 (1981) (quoting a 1966 

Public Health Service statement). 5 15 U.S.C. § 45(a). 6See, e.g., Julep Tobacco Co., 27 F.T.C. 1637 (1938) (stipulation prohibiting claims that Julep 

cigarettes helped counteract irritations due to heavy smoking and never made the throat dry 

or parched). 7See Trade Regulation Rule for the Prevention of Unfair or Deceptive Advertising and Labeling of Cigarettes in Relation to the Health Hazards of Smoking, 29 Fed. Reg. 8324, 8354 (1964). 8 15 U.S.C. § 1331 et seq. Although the Commission administers the Cigarette Act, the Department of Justice enforces it. 9FTC v. Brown & Williamson Tobacco Corp., 580 F. Supp. 981 (D.D.C. 1983), aff’d. in part, 

remanded in part, 778 F.2d 35 (D.C. Cir. 1985). 10The American Tobacco Co., 119 F.T.C. 3 (1995). In another example of a Commission action 

involving unfair and deceptive cigarette advertising practices, in 1997, the Commission issued 

a complaint against the R.J. Reynolds Tobacco Co. alleging that the company’s Joe Camel advertising campaign caused or was likely to cause many young people to begin or continue to smoke, 

thereby exposing them to significant health risks. R.J. Reynolds Tobacco Co., 127 F.T.C. 49 

(1999). The Commission’s complaint was issued on May 28, 1997. On January 26, 1999, the 

Commission dismissed the complaint without prejudice because the relief sought had been 

yields of cigarettes.3 From the outset, cigarette testing under the FTC Method was 

intended to produce uniform, standardized data about the tar and nicotine yields 

of mainstream cigarette smoke, not to replicate actual human smoking. Because no 

known test could accurately replicate human smoking, the FTC believed that the 

most important objective was to ensure that cigarette companies presented tar and 

nicotine information to the public based on a standardized method. In 1967, most 

public health officials believed that reducing the amount of ‘‘tar’’ in a cigarette could 

reduce a smoker’s risk of lung cancer; therefore, it was thought that giving consumers uniform and standardized information about the tar and nicotine yields of 

cigarettes would help smokers make informed decisions about the cigarettes they 

smoked.4 In the intervening 40 years, cigarettes have changed markedly and scientific understanding of smoking behavior has improved. These changes have important implications for cigarette measurement. 

The Commission’s Responsibilities Over Tobacco Advertising and 

Promotion 

The Commission’s core responsibility over the advertising and promotion of cigarettes and other tobacco products arises from its law enforcement authority under 

Section 5 of the FTC Act, which prohibits ‘‘unfair or deceptive acts or practices in 

or affecting commerce.’’ 5 The FTC’s law enforcement activities involving cigarette 

advertising and promotion date back to the 1930s.6 In 1962, the FTC’s request for 

technical assistance from the U.S. Public Health Service was among the factors that 

led the then-Surgeon General to establish an advisory panel to undertake a comprehensive analysis of the data on smoking and health. The work of the advisory 

panel, in turn, led to the now-historic 1964 Report of the Surgeon General finding 

that cigarette smoking presented significant health risks. In that same year, the 

Commission issued a regulation requiring tobacco companies to include health 

warnings in cigarette advertisements and on packages.7 The FTC’s regulation was 

superseded in 1965, before it went into effect, by the Federal Cigarette Labeling and 

Advertising Act (‘‘Cigarette Act’’),8 which required health warnings on cigarette 

packages. 

The Commission also has used its Section 5 authority to prosecute a variety of 

unfair and deceptive cigarette advertising practices—including claims about tar and 

nicotine ratings for cigarettes. For example, in the early 1980s, the FTC filed a Federal district court lawsuit challenging claims made by Brown & Williamson Tobacco 

Corporation that its Barclay cigarettes had only 1 mg. of tar. The FTC had previously revoked the ‘‘1 mg. tar’’ rating after concluding that the FTC Method did 

not accurately measure Barclay’s tar, nicotine, and carbon monoxide due to the cigarette’s unique channel ventilation system. The court agreed with the FTC, and 

found that the ‘‘1 mg. tar’’ claim was deceptive.9 Likewise, in 1995, the Commission 

approved a consent agreement with American Tobacco Company, settling charges 

over advertisements that allegedly misused the tar and nicotine ratings by representing that smokers would get less tar by smoking 10 packs of Carlton brand 

cigarettes (which were rated at 1 mg. tar per cigarette) than by smoking a single 

pack of certain other brands of cigarettes (which were rated at 10 mg. of tar).10

7 

achieved through, inter alia, the master settlement between the major tobacco companies and 

the Attorneys General for 46 states. 11 15 U.S.C. § 4401 et seq. 12 16 C.F.R. Part 307. 13 In addition, the Commission issued a report on the advertising and promotion activities in 

the cigar industry in 1999. Federal Trade Commission Report to Congress, Report on Cigar 

Sales, Advertising, and Promotion (1999). 14 Until 1981, the Reports only provided information about the tar and nicotine yields. In 

1981, the test methodology was changed to include testing for carbon monoxide yields, and the 

Commission subsequently began reporting those yields in addition to tar and nicotine. 15 In 1967, the Commission opened its own testing laboratory to analyze the tar and nicotine 

yields of cigarettes. In 1981, the Commission laboratory began to analyze the carbon monoxide 

yields as well. The Commission operated this laboratory until April 1987, when it decided to 

close it because, inter alia, significant expenditures were needed to update and continue the laboratory, and the same information was available from the industry. See Prepared Statement of 

the Federal Trade Commission on Cigarette Tar and Nicotine Testing Before the Subcommittee 

on Transportation, Tourism, and Hazardous Materials, U.S. House of Representatives (May 7, 

1987). Since the FTC laboratory closed, the Tobacco Industry Testing Laboratory conducts the 

testing and provides the data to the individual cigarette companies; the Commission obtains the 

data from the cigarette companies pursuant to compulsory process. 16These terms are not defined by the FTC or any other government agency. The industry, 

however, has generally adopted them. The term ‘‘low’’ tar generally refers to cigarettes currently 

rated as 15 mg. tar or less and ‘‘ultra low’’ to those rated 6 mg. or less. The industry uses the 

term ‘‘full flavor’’ to describe cigarettes with tar ratings above 15 mg. The terms ‘‘light’’ and 

‘‘ultra-light’’ are used interchangeably with ‘‘low’’ tar and ‘‘ultra low’’ tar, respectively. 17 Europe and many other countries have adopted a similar machine-based test method established by the International Organization for Standardization. In those countries, the test method 

is referred to as the ‘‘ISO Method.’’ 

In addition to law enforcement actions, the Commission administers the Cigarette 

Act and administers and enforces the Comprehensive Smokeless Tobacco Health 

Education Act (‘‘Smokeless Tobacco Act’’).11 The Cigarette Act instructs the FTC to 

take certain steps to implement the mandated Surgeon General’s health warnings. 

The Smokeless Tobacco Act directs the FTC to promulgate regulations governing the 

health warnings on packaging and advertising for smokeless tobacco products. The 

Commission’s regulations specify the format, placement, and rotation of the warnings, and require companies to submit plans setting forth their rotation schedules 

to the FTC for approval.12 In addition, the FTC enforces the ban in the Smokeless 

Tobacco Act on broadcasting smokeless tobacco advertisements on radio and television. 

The Commission also publishes periodic reports on the advertising and promotion 

activities in the cigarette and smokeless tobacco industries.13 Those reports provide 

information on sales and on various categories of advertising and marketing expenditures. The Commission issued its first report for cigarettes in 1967, and on the 

smokeless tobacco industry in 1987. The Commission also published periodic reports 

showing the tar, nicotine, and carbon monoxide yields of various cigarette brands 

from 1967 through 2000.14 In light of concerns over the test method used to measure these yields, which are discussed later in this statement, these reports have not 

been published since 2000 (reporting on 1998 data). But the FTC continues to collect 

this information, and it is available to researchers on the FTC’s website. 

Finally, testing for the tar, nicotine, and carbon monoxide yields of cigarettes is 

conducted by the cigarette industry under the test methodology approved by the 

FTC in 1967.15 Cigarette companies have promoted their cigarettes based on ratings 

generated by this test methodology, and have adopted descriptors, such as ‘‘light’’ 

and ‘‘low,’’ to characterize cigarettes that have tar ratings of 15 mg. or less.16

The ‘‘FTC Test Method’’ and Its Limitations 

Cigarette ratings for tar, nicotine, and carbon monoxide are determined by machine testing conducted in accordance with the Cambridge Filter test method, commonly known in the U.S. as ‘‘the FTC Method.’’ 17 The FTC Method determines the 

relative yield of individual cigarettes by ‘‘smoking’’ them in a standardized fashion, 

according to a pre-determined protocol, on a machine. The machine is calibrated to 

take one puff of 2-second duration and 35 ml volume every minute. Cigarettes are 

smoked to a specified length, and the ratings are then calculated. In 1967, when 

it began, the intent of the tar and nicotine testing program was to provide smokers 

seeking to switch to lower tar cigarettes information based on a single, standardized 

measurement with which to choose among then-existing brands. 

Over the past 40 years that the current system has been in place, there have been 

dramatic decreases in the machine-measured tar and nicotine yields of cigarettes. 

In 1968, for example, only 2 percent of all cigarettes had machine-measured yields 

8 

18Smoking and Tobacco Control Monograph 7: The FTC Cigarette Test Method for Determining Tar, Nicotine, and Carbon Monoxide Yields of U.S. Cigarettes: Report of the NCI Expert 

Committee, National Institutes of Health, National Cancer Institute (1996). 19Smoking and Tobacco Control Monograph 8: Changes in Cigarette-Related Disease Risk and 

Their Implications for Prevention and Control, National Institutes of Health, National Cancer 

Institute (1997). 20See Thun, M.J., et al., ‘‘Cigarette Smoking and Changes in the Histopathology of Lung Cancer,’’ 89 J. of the Nat’l Cancer Inst. 1580 (1997); Ernster, V.I., ‘‘The Epidemiology of Lung Cancer 

in Women,’’ 4 Annals of Epidemiology 102 (1994); Levi, F.S., et al., ‘‘Lung Carcinoma Trends 

by Histologic Type in Vaud and Neuchatel, Switzerland, 1974–1994,’’ 79 Cancer 906 (1997). 21Letter from Donald S. Clark, Secretary, Federal Trade Commission to the Honorable Donna 

E. Shalala, Secretary, Department of Health and Human Services (Nov. 19, 1998). 

of 15 mg. or less. Today, over 83.5 percent of all cigarettes sold have machine-measured yields of 15 mg. or less. 

Despite these dramatic decreases in machine-measured yields, the Commission 

has been concerned for some time that the current test method may be misleading 

to individual consumers who rely on the ratings it produces as indicators of the 

amount of tar and nicotine they actually will get from their cigarettes. In fact, the 

current ratings tend to be relatively poor predictors of tar and nicotine exposure. 

This appears to be primarily due to compensation—or the tendency of smokers of 

lower rated cigarettes to take bigger, deeper, or more frequent puffs, or otherwise 

alter their smoking behavior in order to obtain the dosage of nicotine they need. 

Such variations in the way people smoke can have significant effects on the amount 

of tar, nicotine, and carbon monoxide they get from any particular cigarette. Smokers may incorrectly believe, for example, that they will get three times as much tar 

from a 15 mg. tar cigarette as from a 5 mg. tar cigarette. In fact, if compensation 

is sufficiently great, it is possible for smokers to get as much tar and nicotine from 

relatively low rated cigarettes as from higher rated cigarettes. Although the limitations in the test methodology were recognized when the testing program began in 

1967, they became a substantially greater concern by the 1990s as a result of 

changes in modern cigarette design and a better understanding of the nature and 

effects of compensatory smoking behavior. 

In light of these concerns, in 1994, the Commission, along with Congressman 

Henry Waxman, asked the National Cancer Institute (‘‘NCI’’) to convene a consensus conference to address cigarette testing issues. That conference took place in 

December 1994, and the NCI issued its Report of the conference in October 1996.18

The NCI Report recommended, among other things, that the cigarette testing system measure and publish information on the range of tar, nicotine, and carbon monoxide that most smokers should expect from the cigarettes they smoke. Accordingly, 

in September 1997, the Commission requested public comments on proposed revisions to the test method that would add a second tier of testing—using more rigorous smoking conditions—to better approximate a range of tar and nicotine yields 

and make it more apparent to consumers that the amount of tar and nicotine they 

get from any specific cigarette depends on how they smoke it. 

Around this same time, some public health officials expressed concerns that recently released studies raised serious questions about the basic assumption then underlying cigarette testing: that cigarettes with lower machine-measured tar and nicotine ratings are less harmful than ones with higher ratings. For example, in 1997, 

the NCI issued a Report noting that the apparent mortality risk among current 

smokers had risen in the last forty to fifty years, even though machine-measured 

tar and nicotine yields had fallen dramatically during the same period.19 In attempting to understand this phenomenon, the authors of the NCI Report suggested 

that the increased mortality risk might be due to increases in current smokers’ lifetime exposure to cigarette smoke, or that the reduced tar levels of modern cigarettes 

might have less benefits than previously believed. In addition to the NCI Report, 

a number of other studies reported that changes in smoking behavior and cigarette 

design appeared to have resulted in an increase in a specific type of cancer that occurs deeper in the lung than the type of lung cancer that was previously associated 

with smoking.20

Citing these studies, public health agencies asked the Commission to postpone its 

proposed modifications to the test method until a broader review of unresolved scientific issues surrounding the system could be addressed. The Commission responded to these comments, in 1998, by formally requesting that the Department 

of Health and Human Services (‘‘HHS’’) conduct a review of the FTC’s cigarette test 

method.21 In particular, the Commission asked HHS to provide recommendations as 

to whether the testing system should be continued, and if it should be continued, 

9 

22Smoking and Tobacco Control Monograph 13: Risks Associated with Smoking Cigarettes 

with Low Machine-Measured Yields of Tar and Nicotine, National Institutes of Health, National 

Cancer Institute (2001). 23Statement of Cathy Backinger, M.D., ‘‘Research Findings Concerning So-Called Low-Tar or 

‘Light’ Cigarettes,’’ Testimony Before the Committee on Science, Commerce, and Transportation, 

U.S. Senate (Nov. 13, 2007). See also Smoking and Tobacco Control Monograph 13: Risks Associated with Smoking Cigarettes with Low Machine-Measured Yields of Tar and Nicotine, National 

Institutes of Health, National Cancer Institute, at 146. 24Smoking and Tobacco Control Monograph 13: Risks Associated with Smoking Cigarettes 

with Low Machine-Measured Yields of Tar and Nicotine, National Institutes of Health, National 

Cancer Institute, at 34. 25 National Cancer Institute, ‘‘Low-Tar Cigarette: Evidence Does Not Indicate a Benefit to 

Public Health,’’ News from the NCI (Nov. 27, 2001). 26Prepared Statement of the Federal Trade Commission Before the Committee on Energy and 

Commerce, Subcommittee on Commerce, Trade, and Consumer Protection, U.S. House of Representatives (June 3, 2003); Prepared Statement of the Federal Trade Commission Before the 

Committee on Government Reform, U.S. House of Representatives (June 3, 2003). 

what specific changes should be made in order to correct the limitations previously 

identified by the NCI, an agency within HHS, and other public health officials. 

In November 2001, the NCI published a Report presenting the results of a review 

of the epidemiological and other scientific evidence on the public health effects of 

low-tar cigarettes.22 As noted in Dr. Backinger’s testimony prepared for today’s 

hearing, this NCI Report concluded that ‘‘there is no convincing evidence that 

changes in cigarette design . . . have resulted in an important decrease in the disease burden caused by cigarette use.’’ 23 The NCI Report also concluded that 

‘‘[v]ariations in the tar and nicotine delivery that result from the known compensatory alterations in smoking behaviors make the current U.S. cigarette tar and nicotine yields as measured by the FTC Method not useful to the smoker either for 

understanding how much tar and nicotine he or she is likely to inhale from smoking 

a given cigarette or for comparing the tar and nicotine intake that is likely to result 

from smoking different brands of cigarettes.’’ 24

The Commission understands that this Report represented, at least in part, the 

first step in the HHS response to the FTC’s 1998 request for assistance. When it 

announced the release of this Report, the NCI noted the FTC’s previous request, 

and indicated that it would work with its sister science-based agencies at HHS to 

determine what changes needed to be made to the testing method.25

The FTC understands that representatives from agencies within HHS are continuing to explore these issues. In addition, the Commission understands that an 

expert panel has been assembled by the World Health Organization to address tobacco testing issues and to make recommendations concerning such testing. 

The Commission believes that it is vital that there be an effective mechanism for 

implementing any recommended changes to the test method once the evaluations 

are completed. Although the Commission brings a strong, market-based expertise to 

its scrutiny of consumer protection matters, it does not have the specialized scientific expertise needed to design and evaluate scientific test methodologies. Indeed, 

when evaluating medical or other scientific issues, the Commission often relies on 

other government agencies and outside experts with more knowledge in the relevant 

areas. Therefore, in its July 1999 ‘‘Report to Congress for 1997, Pursuant to the Cigarette Labeling and Advertising Act,’’ the Commission recommended that Congress 

consider giving authority over cigarette testing to one of the Federal Government’s 

science-based public health agencies. The Commission renewed that recommendation in 2003 in testimony before Congress,26 and the Commission reiterates that recommendation again today. 

In conclusion, the FTC thanks the Committee for the opportunity to present testimony on this important topic. 

Senator LAUTENBERG. Thank you very much. 

Ms. Backinger? 

Dr. BACKINGER. Yes. 

Senator LAUTENBERG. We invite you to give your testimony, 

please. 

10 

STATEMENT OF CATHY L. BACKINGER, PH.D., ACTING CHIEF, 

TOBACCO CONTROL RESEARCH BRANCH, NATIONAL 

CANCER INSTITUTE, NATIONAL INSTITUTES OF HEALTH, 

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

Dr. BACKINGER. Senator Stevens and Senator Lautenberg, thank 

you for the opportunity today to testify on the National Cancer Institute’s research findings regarding the disease risk of so-called 

low-tar or ‘‘light’’ cigarettes. 

I am Dr. Cathy Backinger, Acting Chief of the National Cancer 

Institute’s Tobacco Control Research Branch. 

As is described more fully in my written testimony, there is a 

substantial long-standing body of evidence demonstrating that 

‘‘light’’ or low-tar cigarettes do not reduce smokers’ exposure to hazardous compounds or their risk of disease. Moreover, descriptions 

such as ‘‘light,’’ low tar, ‘‘ultra light,’’ and others, are aimed at conveying to consumers what NCI Monograph 13 termed ‘‘the illusion 

of risk reduction.’’ 

Additionally, the Federal Trade Commission test method does 

not offer smokers meaningful information on the amount of tar and 

nicotine they will receive from a cigarette or on the relative 

amounts of tar and nicotine exposure they are likely to receive 

from smoking different brands of cigarettes. 

Cigarette manufacturers have made changes to cigarettes over 

the last 50 years in response to concerns that the growing body of 

evidence that smoking causes disease would motivate smokers to 

quit. In the 1950s, manufacturers began the widespread promotion 

of filtered cigarettes. And in early 1970s, manufacturers introduced 

and heavily marketed new low-tar cigarette brands. Many of the 

advertisements made implicit health claims so as to reassure smokers who were concerned about their health risks. 

Over time, the market share for low-tar brands increased dramatically. In 1967, these products had only 2 percent of the market 

share. In 2005, these products held 83.5 percent of the market 

share. 

By the early 1980s, however, scientific studies had begun to show 

that when smokers switched to low-tar cigarettes, they changed the 

way they smoked by smoking greater numbers of cigarettes, increasing their depth of inhalation, taking more frequent and/or 

larger puffs, as well as holding smoke in their lungs longer. Additionally, cigarette design features allowed smokers to vary the 

amount of smoke they inhaled. Reflecting this knowledge, the 1981 

Surgeon General’s Report concluded that ‘‘the benefits [of smoking 

low-tar cigarettes] are minimal in comparison with giving up cigarettes entirely.’’ In short, more than 25 years ago, the Surgeon 

General warned that smoking low-tar cigarettes is not a substitute 

for quitting. 

NCI’s Monograph 7, published in 1996, considered the relationship between the FTC test method and actual human smoking behavior, as well as consumer perceptions of tar and nicotine ratings. 

Among the major conclusions of the monograph were: 

One, smokers who switched to lower-tar and nicotine cigarettes 

frequently changed their smoking behavior, which may negate potential health benefits; 

11 

Two, brand names and brand classifications, such as ‘‘light’’ and 

‘‘ultra light,’’ represent health claims and should be regulated and 

accompanied in fair balance with an appropriate disclaimer; and 

Three, the available data suggest that smokers misunderstand 

the FTC test data. 

NCI’s Monograph 13, published in 2001, reviewed and synthesized a vast amount of data, ranging from laboratory to population studies. Its most important finding is that ‘‘there is no convincing evidence that changes in cigarette design . . . have resulted in an important decrease in the disease burden caused by 

cigarette use.’’ The monograph also found that ‘‘advertisements of 

filtered and low-tar cigarettes were intended to reassure smokers 

[who were worried about the health risks of smoking] and were 

meant to prevent smokers from quitting based on those concerns;’’ 

additionally, that ‘‘internal tobacco company documents demonstrate that cigarette manufacturers recognize the inherent deception of advertising that offer cigarettes as light or ultra light or as 

having the lowest tar and nicotine yields.’’ 

In summary, while cigarettes have changed over the last 50 

years, the disease risks have not. Cigarette manufacturers have 

long understood that consumers would respond to the widespread 

dissemination of the grave health risks of smoking by quitting. 

Manufacturers work to reassure health conscious smokers by marketing filtered and low-tar cigarettes and heavily advertising these 

products as ways to reduce the risk of smoking. Smokers erroneously saw these products as viable alternatives to quitting, and, 

as a result, many more smokers continue to smoke who might otherwise have quit. 

Thank you for the opportunity to appear before the Committee. 

I’m happy to answer any questions. 

Thank you. 

[The prepared statement of Dr. Backinger follows:] 

PREPARED STATEMENT OF CATHY L. BACKINGER, PH.D., ACTING CHIEF, TOBACCO

CONTROL RESEARCH BRANCH, NATIONAL CANCER INSTITUTE, NATIONAL INSTITUTES

OF HEALTH, U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

Mr. Chairman, and members of the Subcommittee, thank you for the opportunity 

to testify today on the research findings of the National Cancer Institute (NCI), part 

of the National Institutes of Health (NIH), an agency of the Department of Health 

and Human Services (HHS), regarding the disease risk of so called low-tar or ‘‘light’’ 

cigarettes, and the challenges of conveying accurate information to smokers about 

the levels of tar, nicotine, and other hazardous chemicals in cigarette smoke. I am 

Dr. Cathy Backinger, Acting Chief of the National Cancer Institute’s Tobacco Control Research Branch. The Branch’s mission is to lead and collaborate on tobacco 

control and prevention research, and to disseminate evidence-based findings to prevent, treat, and control tobacco use. We envision a world free of tobacco use and 

tobacco-related cancers. 

I would like to begin by stating the NCI’s goals regarding cigarette smoking, the 

cause of an estimated 438,000 U.S. deaths annually and about one-third of all 

deaths from cancer. NCI supports, conducts, and disseminates research to prevent 

youth from ever starting to use tobacco products, to assist youth and adults who 

smoke in quitting, and to protect nonsmokers from exposure to secondhand smoke, 

a serious cause of disease and death in its own right. 

As I will describe, there is a substantial, longstanding body of evidence demonstrating that ‘‘light’’ and low-tar cigarettes do not reduce smokers’ exposure to 

hazardous compounds or their risk for disease. Moreover, descriptors such as ‘‘light,’’ 

low-tar, ‘‘ultra light,’’ and others, are aimed at conveying to consumers what NCI 

12 

1 National Cancer Institute, Smoking and Tobacco Control Monograph 13, Risks Associated 

with Smoking Cigarettes with Low Machine-Measured Yields of Tar and Nicotine, October 2001, 

page 5. 2Monograph 13, page 10. 

3 U.S. Department of Health and Human Services, Reducing the Health Consequences of 

Smoking: 25 Years of Progress. A Report of the Surgeon General, 1989, page 664. 4Low-tar cigarettes contain less than or equal to 15 mg of tar per cigarette. 

5Federal Trade Commission Cigarette Report for 2004 and 2005, issued 2007 (http:// 

www.ftc.gov/reports/tobacco/2007cigarette2004-2005.pdf). 6 U.S. Department of Health and Human Services, The Health Consequences of Smoking: The 

Changing Cigarette. A Report of the Surgeon General, 1981, page vi. 

Monograph 13 termed ‘‘the illusion of risk reduction.’’ 1 Not surprisingly, research 

has demonstrated that these terms are interpreted by many smokers to mean reduced risk. Finally, measurements of tar and nicotine yields using the Federal 

Trade Commission (FTC) test method do not offer smokers meaningful information 

on the amount of tar and nicotine they will receive from a cigarette, or on the relative amounts of tar and nicotine exposure they are likely to receive from smoking 

different brands of cigarettes.2

Cigarette manufacturers have made changes to cigarettes over the last 50 years, 

largely in response to concerns that the growing body of evidence that smoking 

causes disease would motivate smokers to quit. In the 1950s, the major manufacturers began widespread promotion of filtered cigarettes; advertisements for these cigarettes depicted filters as a technology to remove the harmful elements of smoke.3

By 1960, filtered cigarettes had become the dominant product on the market. In the 

early 1970s, manufacturers introduced new low-tar cigarette brands; by 1997, half 

of all cigarette advertising dollars were dedicated to low-tar products. Many of the 

advertisements made health claims, most implicitly, so as to reassure smokers who 

were concerned about their health risks. Over time, the market share for these 

brands increased dramatically. In 1967, low-tar cigarettes 4 constituted 2.0 percent 

of the market. By 2005, these products held 83.5 percent of market share.5

By the early 1980s, however, scientific studies had begun to show that when 

smokers switched to low-tar cigarettes, they changed the way they smoked, by 

smoking greater numbers of cigarettes, increasing their depth of inhalation, taking 

more frequent and/or larger puffs, as well as holding smoke in their lungs longer. 

Additionally, cigarette design features allowed smokers to vary the amount of smoke 

they inhaled, such as by covering ventilation holes on the filter with their fingers 

or lips. Based on this emerging evidence, the 1981 Surgeon General’s report, The 

Changing Cigarette, concluded that, ‘‘the benefits [of smoking low-tar cigarettes] are 

minimal in comparison with giving up cigarettes entirely,’’ and, ‘‘the tar and nicotine yields obtained by present testing methods do not correspond to the dosages 

that the individual smokers receive: in some cases they may seriously underestimate these dosages.’’ 6 In short, more than 25 years ago, the Surgeon General 

warned that smoking low-tar cigarettes was no substitute for quitting, and raised 

serious questions about the FTC test method. 

Our understanding of why smokers compensate when smoking ‘‘light’’ cigarettes 

was enhanced significantly by the 1988 Surgeon General’s report, The Health Consequences of Smoking: Nicotine Addiction. The major conclusions of this volume 

were that: (1) cigarettes and other forms of tobacco are addicting; (2) nicotine is the 

drug in tobacco that causes addiction; and (3) the pharmacologic and behavioral 

processes that determine tobacco addiction are similar to those that determine addiction to drugs such as heroin and cocaine. In retrospect, public health authorities 

did not fully understand that when smokers switched to a cigarette with lower machine measured tar and nicotine content they would change the way they smoked 

in order to preserve their daily intake of nicotine. This was understood much earlier 

however, by some cigarette manufacturers, as demonstrated by their internal documents. 

Tar and nicotine yields have historically been measured by a standardized machine testing regimen—the FTC test method—also known internationally as the 

ISO (for International Organization for Standardisation) machine-smoking method. 

This method, adopted in 1967, determines the yield of a cigarette by smoking it on 

a machine, in a standardized fashion, according to a predetermined protocol. The 

smoking machine is calibrated to take one puff of 2-second duration and 35 ml volume every minute; cigarettes are smoked to a butt length of 23 mm or to the length 

of the overwrap plus 3 mm, whichever is longer. These parameters were determined 

by a U.S. Department of Agriculture tobacco chemist so as to constitute an average 

of his observations of human smoking behavior. The FTC test method provided a 

uniform analytical procedure that could be replicated in different laboratories simultaneously and in the same laboratory over time. 

13 

7 National Cancer Institute, Smoking and Tobacco Control Monograph 7, The FTC Cigarette 

Test Method for Determining Tar, Nicotine, and Carbon Monoxide Yields of U.S. Cigarettes: Report of the NCI Expert Committee, August 1996, page 2. 8Monograph 7, page 4, quoting 1978 Federal Register, p. 11856. 9Monograph 13, page 146. 

10Monograph 13, page 233. 

The FTC long recognized that the machine testing did not replicate human smoking because, ‘‘No two human smokers smoke in the same way,’’ and ‘‘No individual 

smoker always smokes in the same fashion.’’ 7 Instead, the test was seen as a way 

for consumers to make valid comparisons between different brands of cigarettes. 

‘‘Thus, if the consumer smoked each different cigarette [brand] the same way, he 

would inhale ‘tar’ and nicotine in amounts proportional to the relative values of the 

FTC figures.’’ 8 However, the standardized machine measurements assumed that 

smokers would not engage in ‘‘compensatory behaviors’’ to control their intake of 

nicotine. 

In 1996, NCI’s Smoking and Tobacco Control Monograph Number 7, The FTC Cigarette Test Method for Determining Tar, Nicotine, and Carbon Monoxide Yields of 

U.S. Cigarettes: Report of the NCI Expert Committee, compiled evidence available at 

the time on the FTC test method, its relation to actual human smoking behavior, 

and consumer perceptions of tar and nicotine ratings. Among the major conclusions 

of the monograph were: (1) Actual human smoking behavior is characterized by 

wide variations in smoking patterns, which result in wide variations in tar and nicotine exposure. Smokers who switch to lower tar and nicotine cigarettes frequently 

change their smoking behavior, which may negate potential health benefits; (2) 

Brand names and brand classifications such as ‘‘light’’ and ‘‘ultra light’’ represent 

health claims and should be regulated and accompanied, in fair balance, with an 

appropriate disclaimer; and (3) The available data suggest that smokers misunderstand the FTC test data. This underscores the need for ongoing and extensive public 

education efforts. 

Lastly, in 2001, NCI’s Smoking and Tobacco Control Monograph Number 13, 

Risks Associated with Smoking Cigarettes with Low Tar Machine-Measured Yields 

of Tar and Nicotine, reviewed and synthesized what was by that time a vast amount 

of data from epidemiology, chemistry, toxicology, laboratory studies of smoking behavior, studies of risk perception and advertising, studies of product design, as well 

as previously confidential tobacco industry documents. The Monograph’s most important finding is that ‘‘there is no convincing evidence that changes in cigarette design . . . have resulted in an important decrease in the disease burden caused by 

cigarette use.’’ 9 That is, smokers who switch to low-tar cigarettes do not reduce 

their risk of disease; the only proven way to reduce the disease risks of smoking 

is to quit. The report also found that cigarette marketing and advertising for ‘‘filtered and low tar cigarettes were intended to reassure smokers (who were worried 

about the health risks of smoking) and were meant to prevent smokers from quitting based on those concerns,’’ and that, ‘‘internal tobacco company documents demonstrate that the cigarette manufacturers recognized the inherent deception of advertising that offered cigarettes as ‘‘light’’ or ‘‘ultra light,’’ or as having the lowest 

tar and nicotine yields.’’ 10 The major conclusions of Monograph 13 are the following: 

1. Epidemiological and other scientific evidence, including patterns of mortality 

from smoking-caused diseases, does not indicate a benefit to public health from 

changes in cigarette design and manufacturing over the last fifty years. 

2. Widespread adoption of lower yield cigarettes in the United States has not 

prevented the sustained increase in lung cancer among older smokers. 

3. Many smokers switch to lower yield cigarettes out of concern for their health, 

believing these cigarettes to be less risky or to be a step toward quitting. Advertising and marketing of lower yield cigarettes may promote initiation and impede cessation, more important determinants of smoking-related diseases. 

4. Measurements of tar and nicotine yields using the FTC Method do not offer 

smokers meaningful information on the amount of tar and nicotine they will receive from a cigarette. The measurements also do not offer meaningful information on the relative amounts of tar and nicotine exposure likely to be received 

from smoking different brands of cigarettes. 

The conclusion of Monograph 13 with regard to low tar cigarettes was reiterated 

by the 2004 Surgeon General’s report, The Health Consequences of Smoking, the 

most comprehensive review of the evidence on smoking and health since the 1964 

Surgeon General’s report. This report stated as one of its four major conclusions 

14 

11 U.S. Department of Health and Human Services, The Health Consequences of Smoking: A 

Report of the Surgeon General, 2004, page 25. 

that, ‘‘Smoking cigarettes with lower machine-measured yields of tar and nicotine 

provides no clear benefit to health.’’ 11

In summary, while cigarettes have changed over the last 50 years, the disease 

risks have not. Cigarette manufacturers have long understood that consumers would 

respond to the widespread dissemination of the grave health risks of smoking by 

quitting. Manufacturers worked to reassure ‘‘health conscious’’ smokers by marketing filtered and low-tar cigarettes, and heavily advertising these products as 

ways to reduce the risk of smoking. Smokers erroneously saw these products as viable alternatives to quitting, and as a result, many more smokers continued to smoke 

who might otherwise have quit. The marketing and advertising of low-tar cigarettes 

and manufacturers’ use of the FTC test method data continues today. 

A new generation of products is now being marketed by the tobacco industry with 

advertisements suggesting that they deliver lower amounts of toxic or addictive 

agents. For example, one such advertisement says, ‘‘all of the taste . . . less of the 

toxins.’’ These products—sometimes referred to as potential reduced-exposure tobacco products, or ‘‘PREPs’’—are highly engineered products which utilize new technologies to try to reduce certain harmful constituents, such as carcinogens (cancer 

causing agents) from tobacco smoke. To date, however, the scientific evidence is insufficient to evaluate whether these new products actually reduce the users’ exposure or risk for tobacco-related diseases. The 2001 Institute of Medicine report 

Clearing the Smoke concluded that currently-available data does not allow for drawing meaningful differences in toxicity or harm between tobacco products and that 

a structure for regulatory oversight would be essential to any scientific assessment 

of claims for reduced harm. 

There is a need for independent, objective, scientific research to provide guidance 

to the public about the health effects of different tobacco products. In order to address this research gap, NCI has introduced several new initiatives, including: 

• A Program Announcement titled, ‘‘Testing Tobacco Products Promoted to Reduce Harm,’’ which aims to stimulate multidisciplinary research on the characteristics of different tobacco products, methods for measuring users’ exposure to 

toxic constituents, and the impact of manufacturers’ claims on smokers’ perceptions of risk. Currently funded grants under this Program Announcement include projects studying: 

» The impact of low ignition propensity (‘‘fire-safe’’) cigarettes (Roswell Park 

Cancer Institute). 

» Mutagenicity of tobacco smoke in human cell co-cultures (New York University). 

» Clinical models for evaluating PREPs for tobacco users (Virginia Commonwealth University). 

» Laboratory based evaluation of potential reduced exposure products (Georgetown University). 

» Smoking topography and harm exposure in a new PREP (University of Pennsylvania). 

• A 5-year Research and Development contract with the Lombardi Cancer Center 

at Georgetown University to support the advancement of laboratory methods for 

tobacco product testing, taking into account human behavior. Once developed, 

these methods could be utilized to assess the potential for new products to reduce exposure in the laboratory and in human clinical trials and to assist in 

evaluating the potential impact of product design changes on individuals and 

the population as a whole. 

• Support of the University of Minnesota Transdisciplinary Tobacco Use Research 

Center (TTURC), which is conducting research on ways to reduce smokers’ exposure to tobacco smoke and its constituents. 

• Support of the Roswell Park Cancer Institute TTURC, which is studying how 

changes in cigarette design alter smokers’ actual exposures and their perceptions of the health risks of smoking. Their ongoing multi-country survey also 

collects information on smokers’ perceptions of ‘‘light’’ and ‘‘ultra light’’ cigarettes. 

• NCI is utilizing two of its ongoing national surveys—the Health Information 

National Trends Survey and the Tobacco Use Supplement to the Current PopuVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00018 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
15 

12Shiffman, S., Pillitteri, J.L., Burton, S.L., and Di Marino, M.E. Smoker and ex-smoker reactions to cigarettes claiming reduced risk. Tobacco Control 2004; 13:78–84. 13World Health Organization, ‘‘SACTob Recommendation on Health Claims Derived form ISO/ 

FTC Method to Measure Cigarette Yield’’ (January 1, 2003). Tobacco Control. WHO Tobacco 

Control Papers. Paper ISO200. http://repositories.cdlib.org/tc/whotcp/ISO200. 

lation Survey—to collect data on tobacco use and health risk perceptions related 

to new PREPs and other tobacco products. 

• Collaboration with research partners, including other NIH Institutes and Centers, HHS’s Centers for Disease Control and Prevention (CDC), and the World 

Health Organization (WHO), to identify research priorities and develop expertise related to tobacco products. NCI scientists are currently active members of 

the WHO Study Group on Tobacco Product Regulation and the Tobacco Laboratory Network, which aim to develop guidance on tobacco product testing. 

Research also suggests that there is substantial risk that smokers over-interpret 

reduced risk claims made for modified tobacco products. Exposure reduction messages associated with these products appeal to smokers who are contemplating quitting.12 Therefore, marketing of these products with messages that imply reduced exposure or harm may undermine youth prevention and adult cessation, which could 

result in an overall increase in harm to the population. 

There is an ongoing need to ensure that consumers receive accurate information 

about the health risks of smoking. The use of misleading descriptors like ‘‘light’’ and 

‘‘mild’’ and similar terms have been banned in 43 countries, including Canada, 

Brazil, and the 27 countries of the European Union. 

Tobacco smoke is extremely complex, containing thousands (over 4,800) of constituents including at least 69 known carcinogens. Because of the complexity of tobacco smoke and variations in smoking patterns, it is unlikely that any single machine test will be able to provide meaningful estimates of actual human exposure 

to harmful constituents. Instead, it is likely that a battery of tests will be needed 

to make meaningful comparisons across products. Currently, standardized machine 

measurements of tobacco smoke emissions continue to be useful in laboratory settings to understand the properties of different cigarettes. However, these measurements do not provide meaningful information about the actual exposure or risk for 

the individual smoker. A WHO expert advisory group has stated that numerical ratings for tar, nicotine, and carbon monoxide from the FTC/ISO test method are misleading and recommended that they should not be displayed in advertising or on the 

cigarette packaging.13

Since the 1964 publication of the landmark Surgeon General’s Report on Smoking 

and Health provided conclusive evidence of the health risks of smoking to the nation, education to better inform the public on smoking and health issues has been 

a crucial component of tobacco control and prevention efforts. For decades, the public has been misled by advertising implying, directly or indirectly, that low-tar cigarettes are less hazardous than other cigarettes. It is vital that the public understand 

that the only proven way to reduce the enormous burden of disease and death due 

to tobacco use is to prevent youth from beginning to smoke, and to help smokers, 

both youth and adults, to quit. 

Thank you for this opportunity to present this information to you. I would be 

happy to answer any questions you may have. 

Senator LAUTENBERG. Thank you very much. 

Dr. Ashley? 

STATEMENT OF DAVID L. ASHLEY, PH.D., CHIEF, 

EMERGENCY RESPONSE AND AIR TOXICANTS BRANCH; 

CHIEF, TOBACCO LABORATORY, NATIONAL CENTER FOR 

ENVIRONMENTAL HEALTH, CENTERS FOR DISEASE CONTROL 

AND PREVENTION (CDC), DEPARTMENT OF HEALTH AND 

HUMAN SERVICES; AND CHAIR, TOBACCO LABORATORY 

NETWORK, WORLD HEALTH ORGANIZATION 

Dr. ASHLEY. Mr. Stevens, Mr. Lautenberg, I’m Dr. David Ashley, 

Chief of the Emergency Response and Air Toxicants Branch, and 

Chief of the Tobacco Laboratory in the National Center for Environmental Health of the Centers for Disease Control and Prevention. I am also Chair of the World Health Organization’s Tobacco 

16 

Laboratory Network. I am pleased to be here today to discuss research findings from the CDC Tobacco Laboratory and provide a 

better understanding of the Federal Trade Commission Method and 

how results from the FTC Method should be interpreted. 

Our laboratory evaluates how design and contents of tobacco 

products influence emissions of toxic and addictive substances, how 

people use these products, and how these factors impact people’s 

exposure to the substances that cause disease. 

We work closely with CDC’s Office on Smoking and Health. We 

use multiple machine-smoking regimens, including the FTC smoking regimen, in our research. 

For the past 12 years, CDC has developed and applied measurements to better understand the amount of addictive and toxic substances in cigarettes, and factors that affect the delivery of those 

substances to smokers and persons exposed to secondhand smoke. 

Our smoking machines enable us to assess the influence of various 

smoking conditions on the delivery of addictive and toxic substances to smokers. In tobacco and tobacco smoke, we currently 

measure nicotine, tar, tobacco-specific nitrosamines, bio-organics, 

aldehydes, polycyclic aromatic hydrocarbons, heavy metals, and 

other chemicals. Our lab has performed studies that assess the 

smoke intake of individual smokers. In addition, for the past 20 

years we have measured components of cigarette smoke in the 

urine and blood of smokers and people exposed to secondhand 

smoke. 

The FTC Method originated in observations made in 1936 on 

how people smoked. The smoking parameters proposed, which were 

35 milliliter puffs of 2 seconds’ duration, with a puff each 60 seconds, were based on how the cigarettes which were sold at that 

time were smoked. Since then, cigarette designs have changed 

through modification of the tobacco-blend composition, ventilated 

filters, porous paper, reconstituted tobacco, and expanded tobacco. 

In carrying out a measurement using the FTC regimen, the tips 

of up to 20 cigarettes at a time are placed into holders that are attached to the smoking machine, which contains syringes or other 

devices for drawing air through the cigarettes. Holders included 

glass filter, commonly known as a Cambridge Filter pad, for collecting particulate matter, and special bags for collecting the gas 

phase. 

Cigarette manufacturers have added ventilation holes to the 

modern cigarette in the paper surrounding the filter. These holes 

are far enough from the tip of the cigarette that they’re exposed to 

room air when the cigarette is placed in the smoking machine to 

be tested using the FTC Method. As a result, room air is pulled 

into the cigarette and dilutes the smoke that is collected on the filter pad and in the collection bag, lowering the measured levels of 

nicotine, tar, and carbon monoxide. 

Other factors can also influence the delivery, including the length 

of the filter, the design of the filter, the porosity of the paper; but, 

of these, filter ventilation is the major factor. 

The way that people smoke cigarettes varies between people, and 

there are also variations in the way an individual smokes at different times. One of the more important factors in determining how 

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17 

ers are able to adjust the way they smoke by taking larger puffs, 

more frequent puffs, or blocking ventilation holes so that they can 

increase their nicotine intake when smoking cigarettes with lower 

machine-measured tar and nicotine. When individual smokers 

smoke cigarettes of different designs, they can compensate, resulting in exposure to levels of smoke that vary much less than would 

be expected based on the results from the machine smoking using 

the FTC Method. 

Studies of biomarkers in smokers have also shown that exposure 

to the toxic and addictive components to tobacco smoke are fairly 

consistent whether a smoker smokes a light, medium, or full-flavored cigarette. 

Machine smoking regimens that are more intense than the FTC 

Method are currently in use. Health Canada requires tobacco companies to report levels of chemicals in tobacco smoke using a modified method with 55-milliliter puffs taken every 30 seconds and all 

ventilation holes blocked. The State of Massachusetts has required 

reports of tobacco emissions using a regimen of 45-milliliter puffs 

taken every 30 seconds with half of the ventilation holes blocked. 

These more intense smoking regimens are aimed at better approximating how the average smoker actually smokes the cigarette. 

In summary, our laboratory has developed a broad set of capabilities to measure addictive and toxic substances in the tobacco 

product, in cigarette smoke, and in people. We’ve investigated different machine-smoking regimes, including the FTC Method, and 

how cigarette design factors can influence the delivery of toxic and 

addictive substances. We’ve found that using multiple smoking 

regimens improves our understanding of the variation in actual delivery of nicotine, tar, and carbon monoxide to the smoker, compared to using the FTC Method alone. 

Thank you for this opportunity to present this information to 

you. I would be happy to answer any questions you may have. 

[The prepared statement of Dr. Ashley follows:] 

PREPARED STATEMENT OF DAVID L. ASHLEY, PH.D., CHIEF, EMERGENCY RESPONSE

AND AIR TOXICANTS BRANCH; CHIEF, TOBACCO LABORATORY, NATIONAL CENTER

FOR ENVIRONMENTAL HEALTH, CENTERS FOR DISEASE CONTROL AND PREVENTION; 

AND CHAIR, TOBACCO LABORATORY NETWORK, WORLD HEALTH ORGANIZATION

Mr. Chairman and Members of the Committee, I am Dr. David Ashley, Chief of 

the Emergency Response and Air Toxicants Branch and Chief of the Tobacco Laboratory in the National Center for Environmental Health of the Centers for Disease 

Control and Prevention (CDC), an agency of the Department of Health and Human 

Services. I am also the Chair of the World Health Organization’s Tobacco Laboratory Network. I am pleased to be here today to discuss research findings from the 

CDC Tobacco Laboratory that provide a better understanding of the Federal Trade 

Commission (FTC) method and how results from the FTC Method should be interpreted. 

Our laboratory has five research priorities: (1) to characterize the chemical constituents and chemical additives of tobacco products; (2) to characterize the chemical 

and physical properties of tobacco products that influence delivery of nicotine and 

other harmful substances; (3) to identify the causative agents of disease in tobacco 

and tobacco smoke; (4) to assess the exposure of the U.S. population (including children, women of childbearing age, and other susceptible groups) to the harmful 

chemical constituents of tobacco smoke; and (5) to collaborate in health studies examining the relationship of secondhand smoke exposure to health outcomes, such 

as cancer. We work closely with CDC’s Office on Smoking and Health. 

Smoking causes diseases of the lungs and coronary arteries of the heart, the latter 

being the leading cause of death in the United States. Cigarette smokers are 2 to 

18 

4 times more likely to develop coronary heart disease than nonsmokers. While attempting to decrease the risk of cancer associated with smoking by reducing exposures to suspected or known carcinogens is worthwhile, it is equally important to 

recognize that the amount of small particles, called particulate matter, is inhaled 

from cigarettes by smokers at many times the levels found to be associated with significant risk for diseases of the lung and heart among persons breathing air containing these particles from other sources such as industrial pollution or fires. 

Our laboratory has developed a broad set of capabilities to measure addictive and 

toxic substances in the tobacco product, in cigarette smoke, and in people who 

smoke and are exposed to the smoke of others. We use multiple machine smoking 

regimens (i.e., specified puff volumes, puff rates, total smoking time), including the 

FTC smoking regimen, in our research. 

For the past 20 years, our lab at CDC has conducted research on assessing exposure to cigarette smoke. We developed new methods to measure cotinine, a metabolite of nicotine, in serum and saliva as a marker of tobacco smoke exposure. We 

have applied this measurement to national surveys to track over time the exposure 

of the U.S. population to tobacco smoke, both for smokers and persons exposed to 

secondhand smoke. We have documented substantial decreases in exposure to secondhand smoke in the U.S. population and identified differences in exposure between age, sex, and race/ethnic groups. 

CDC has also developed and applied measurements to better understand the 

amount of addictive and toxic substances in cigarettes and factors that affect the 

delivery of these substances to smokers and persons exposed to secondhand smoke. 

Our smoking machines enable us to assess the influence of various smoking conditions on the delivery of addictive and toxic substances to smokers. In tobacco and 

tobacco smoke, we currently measure nicotine, ‘‘tar’’ (i.e., nicotine-free dry total particulate matter), tobacco-specific nitrosamines, volatile organics, aldehydes, 

polycyclic aromatic hydrocarbons, and heavy metals. Our lab has performed studies 

that assess the smoke intake of individual smokers. In addition, we have measured 

components of cigarette smoke in the urine and blood of smokers and people exposed 

to secondhand smoke. 

The FTC Method originated in observations made by J.A. Bradford and Colleagues 1 in 1936 on how people smoked and was described again by C.L. Ogg in 

1964.2 The smoking parameters they proposed (i.e., 35 milliliter puffs of 2 seconds 

duration with a puff each 60 seconds to a butt length of 23 millimeters or to the 

length of the overwrap plus 3 millimeters, whichever is longer) were based on how 

the cigarettes which were sold at that time were smoked. Since then, cigarette designs have changed, through, for example, changes in the tobacco blend composition, 

ventilated filters, porous paper, reconstituted tobacco, and expanded tobacco.3

In carrying out a measurement using the FTC regimen, the tips of up to 20 cigarettes at a time are placed into holders that are attached to the smoking machine, 

which contains syringes or other devices for drawing air through the cigarettes. The 

holders include a glass filter commonly known as a Cambridge filter pad for collecting particulate matter. Special bags collect the gas phase which is drawn 

through the Cambridge filter pads. To measure nicotine and ‘‘tar’’, the particulate 

matter collected on the pad is extracted and analyzed by a separate analytical instrument known as a gas chromatograph. The carbon monoxide generated during 

smoking is measured by an infrared spectrometer that samples from the collection 

bags. 

Cigarette manufacturers have added ventilation holes to the modern cigarette, 

punched in the paper surrounding the filter. These holes are far enough from the 

tip of the cigarette that they are exposed to room air when the cigarette is placed 

in the smoking machine to be tested using the FTC Method. As a result, room air 

is pulled into the cigarette and dilutes the smoke that is collected on the filter pad 

and in the collection bag. This dilution using ventilation holes results in lower measured levels of nicotine, ‘‘tar’’, and carbon monoxide.3 Other factors can also influence 

the delivery of nicotine, ‘‘tar’’, and carbon monoxide including the length of the filter, the design of the filter, and the porosity of the paper; but, of these, filter ventilation is the major factor. 

The way that people smoke cigarettes varies between people and there are also 

variations in the way an individual smokes at different times. Factors that influence 

smoking patterns include nicotine level of the cigarette, the smoker’s level of stress, 

mood and the time since they smoked their last cigarette. One of the more important factors in determining how people smoke is their need for nicotine. Persons 

smoking cigarettes with a range of nicotine levels adjust the way they smoke to obtain a relatively steady amount of nicotine per cigarette.4 Unlike the machine, 

smokers are able to adjust the way they smoke by taking larger puffs, more freVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00022 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
19 

quent puffs, or blocking ventilation holes so that they can increase their nicotine 

uptake, when smoking cigarettes with lower machine-measured ‘‘tar’’ and nicotine.5

When a larger puff is taken, puffs are taken more frequently, or ventilation holes 

are blocked, cigarettes deliver much higher levels of the toxic and addictive components of tobacco smoke than is characterized using the FTC Method. When individual smokers smoke cigarettes of different designs, compensation techniques result in exposure of smokers to levels of smoke that vary much less than would be 

expected based upon results from machine smoking using the FTC Method.4

Studies of biomarkers in smokers (chemical measurements in blood and urine) 

have also shown that exposure to the toxic and addictive components of tobacco 

smoke are fairly consistent, whether a smoker uses a light, medium, or full-flavored 

cigarette.4 6 These findings are largely explained by compensation techniques used 

by the smokers. 

Machine smoking regimens that are more intense than the FTC Method are currently in use. Health Canada requires tobacco companies to report levels of chemicals in tobacco smoke using a modified method with 55 milliliter puffs taken every 

30 seconds and all ventilation holes blocked. The State of Massachusetts has required reports of tobacco emissions using a regimen of 45 milliliter puffs taken 

every 30 seconds with half of the ventilation holes blocked. These more intense 

smoking regimens are aimed at better approximating how the average smoker actually smokes the cigarette. 

In summary, our laboratory has developed a broad set of capabilities to measure 

addictive and toxic substances in the tobacco product, in cigarette smoke and in people. We have investigated different machine smoking regimens, including the FTC 

Method and how cigarette design factors can influence the delivery of toxic and addictive substances. We have found that using multiple smoking regimens improves 

our understanding of the variation in actual delivery of nicotine, ‘‘tar’’, and carbon 

monoxide to the smoker compared to using the FTC Method alone. 

Thank you for this opportunity to present this information to you. I would be 

happy to answer any questions you may have. 

References 

1 Bradford, J.A., Harlan, W.R., Hanmer, H.R. Nature of cigarette smoke: technique of experimental smoking. Industrial and Engineering Chemistry 1936; 28(7):836–839. 2Ogg, C.L. Determination of particulate matter and alkaloids (as nicotine) in cigarette smoke. 

Journal of the Association of Official Analytical Chemists 1964; 47(2):356–362. 3 Hoffmann, D., Hoffmann, I. The changing cigarette, 1950–1995. Journal of Toxicology and 

Environmental Health 1997; 50(4):307–64. 4 Jarvis, M.J., Boreham, R., Primatesta, P., Feyerabend, C., Bryant, A., Nicotine yield from 

machine-smoked cigarettes and nicotine intakes in smokers: evidence from a representative population survey. Journal of the National Cancer Institute 2001; 93(2):134–138. 5Melikian, A.A., Djordjevic, M.V., Chen, S., Richie, Jr., J., Stellman, S.D. Effcet of delivered 

dosage of cigarette smoke toxins on the levels of urinary biomarkers of exposure. Cancer Epidemiology Biomarkers and Prevention 2007b; 16(7):1408–15. 6 Hecht, S.S., Murphy, S.E., Carmella, S.G., Li S., Jensen, J., Le, C., Joseph, A.M., Hatsukami, 

D.K. Similar uptake of lung carcinogens by smokers of regular, light, and ultra light cigarettes. 

Cancer Epidemiology Biomarkers and Prevention 2005; 14(3):693–8. 

Senator LAUTENBERG. Thank you very much. 

The—thank you all—each for your testimony. And not only did 

I marvel at the detail with which you reported your findings, but 

the fact that you were all able to come very close to the time mark 

that we had set out for you, that deserves congratulations. I wish 

we could say the same for this side of the table. 

Commissioner Kovacic, I think it was fairly clear what you 

said—but just—let me verify it—that the FTC cigarette testing 

method is inaccurate at predicting the amount of tar and nicotine 

that a smoker will receive from a cigarette. 

Mr. KOVACIC. That’s correct, Senator. 

Senator LAUTENBERG. Given that the FTC is not a scientific 

agency, should your agency continue to oversee these health ratings? 

Mr. KOVACIC. We think it would be much better, Senator, that 

that task be dedicated to one of our public institutions that has the 

deeper scientific expertise. 

20 

Senator LAUTENBERG. Do you think that the ratings based on the 

FTC cigarette testing method are designed to deceive smokers into 

believing that their health is less harmed when they use tar or 

light cigarette designations? 

Mr. KOVACIC. The rating system, as it was designed, was not designed to deceive. The assumption was that it would assist smokers, who wanted to choose lower-tar cigarettes, in particular, to select cigarettes that would give them a lower dosage of tar when 

they smoked. What is impressive from the testimony of my colleagues and others, and the work that their institutions have done, 

is that those early assumptions did not take into account what’s 

called the ‘‘compensation effect.’’ And I think the key question for 

all of us whether there is any significant subset of users who do 

derive useful information from these standards and change their 

behavior in beneficial ways, or whether, as I believe I interpret Dr. 

Backinger’s findings, in particular, that those instances of benefit 

are negligible. 

Senator LAUTENBERG. Would the FTC object if Congress prohibited tobacco companies from continuing to make claims based on 

the FTC Method? 

Mr. KOVACIC. I would strongly prefer that there be a process that 

asks whether, first, there is an alternative measure or measurement that would be an improvement. But, I think, at a minimum, 

the guidance that Congress might give is first, to pursue alternatives that would be more informative. But, if, indeed, there is a 

general conclusion, assembling the science that has been done in 

this area, that the FTC Method, as it’s called, provides no benefits 

to consumers, and, indeed, has net harms, then that’s a basis for 

prohibition. 

Senator LAUTENBERG. I go back to a time, Senator Stevens, when 

we were taught to smoke by the military, our emergency rations 

had a sleeve of four cigarettes, essentially saying that tobacco is 

good for you, it calms the nerves, et cetera. It—didn’t say that we 

were creating addicts. And, at the time, I served in the European 

theater—and I know that you served in the Pacific CBI, right?— 

that all of the temporary camps that were used to receive soldiers 

in the European theater, and the same ones used to send them 

back home, were named after cigarettes. There was Lucky Strike 

and other camps there—Old Gold, et cetera. So, we learned the 

easy way. And though I’m sure it wasn’t the design of the U.S. 

Government to create this addiction, the fact is that that was the 

result. 

Dr. Backinger, does the National Cancer Institute believe that 

the FTC Method deceives smokers? You talk about the number of 

people who started originally smoking light cigarettes, and how 

much that market share has grown. Do you think that the program’s designed to deceive people into becoming smokers? 

Dr. BACKINGER. As outlined in the—in Monograph 13, the research has shown that the FTC numbers and the test method do 

not provide meaningful information to consumers. The monograph 

also found, through research analyzing tobacco industry documents, that the tobacco manufacturers knew this. 

21 

Senator LAUTENBERG. Is it appropriate to say that the continuation of the FTC Method as a basis for light and low-tar claims 

could lead more Americans to getting lung cancer? 

Dr. BACKINGER. I—the data do show, from research, that smokers who were health conscious and may have quit—otherwise have 

quit—decided to smoke what was called ‘‘light’’ or ‘‘low-tar’’ cigarettes, and, therefore, thinking they were going to have—be at reduced risk for lung cancer, as well as other diseases; however, that 

was not the case. 

Senator LAUTENBERG. In 2001, NCI found that problems with the 

FTC cigarette testing method was an urgent health issue. Has any 

government agency that you’re aware of acted upon those findings? 

Dr. BACKINGER. Since 2001, when the monograph was issued, 

NCI and other institutes at NIH have funded research to look into 

different test methods and look at laboratory methods to look at 

how smokers smoke under actual conditions. So, the answer is yes. 

Senator LAUTENBERG. Dr. Ashley, just—this is slightly repetitive, 

but I ask the question, nevertheless, to clarify it for the record. Are 

light or low-tar cigarettes as addictive as regular cigarettes, in your 

judgment? 

Dr. ASHLEY. Using the FTC Method for measuring and reporting 

nicotine, tar, carbon monoxide numbers—using that method did not 

reflect the way people actually smoke. Our research has shown 

that by using multiple methods, you get more information, you can 

get more data that tells you much more what the actual exposure 

of people is when they actually use cigarettes. And so, it’s important to be able to do that research and find out exactly what the 

levels are that people are actually exposed to, and not the way the 

machine makes that measurement. 

Senator LAUTENBERG. Have tobacco companies manipulated cigarette design to affect the FTC results? Have they moved things 

around within the cigarette itself to try and affect a less ominous 

result than we really believe is there? 

Dr. ASHLEY. I can’t really speak to the motivations of the tobacco 

industry, but I—we do know that the design of the cigarette does 

greatly influence the measurements and the results that come from 

when you use the FTC Method. 

Senator LAUTENBERG. Senator Stevens? 

Senator STEVENS. Thank you, Mr. Chairman. 

Mr. Kovacic, do you have authority to change those machines? 

Mr. KOVACIC. I think we don’t specify the test methodology itself, 

Senator. I think what we would have authority to do is to withdraw any indication that, in some sense, our agency stands behind 

the methodology, and we would certainly have the authority to convene proceedings, to work with our colleagues, to draw attention to 

the limitations of the existing methodology and suggest others. 

Senator STEVENS. But, Doctor, they’re paid for with taxpayers’ 

money, right? 

Mr. KOVACIC. I believe they’re not, Senator. The—and this is 

something I could clarify for you afterwards, but the—— 

Senator STEVENS. Who possesses them? 

Mr. KOVACIC. The testing is done by a trade association that does 

the tests. We subpoena, on a regular basis, the data, and post it 

on our website. 

22 

Senator STEVENS. Are you prohibited from testing? 

Mr. KOVACIC. We are not, Senator. We abandoned our own testing. We used to have variants of these elegant machines on the top 

floor of our building, until the mid-1980s, where the cost of maintaining them became relatively high, and we came to realize the 

limitations of our own expertise to do this work. 

Senator STEVENS. Dr. Backinger, does NCI have any testing machines? 

Dr. BACKINGER. No, we do not. 

Senator STEVENS. Dr. Ashley, do you have any testing machines? 

Dr. ASHLEY. Yes, sir, we do. 

Senator STEVENS. Where did you get them? 

Dr. ASHLEY. We purchased them as part of our program, looking 

at the impact of design of cigarettes on emissions, how people 

smoke—— 

Senator STEVENS. That’s not the question. Where did you get 

them? 

Dr. ASHLEY. We purchased them from manufacturers who make 

the machines. 

Senator STEVENS. They make them for the same testing organization that’s not Federal? 

Dr. ASHLEY. They make them for whatever consumer would purchase them. They are purchased largely by the tobacco industry. 

We got our tobacco smoking machines from the same companies 

that make them for the industry. 

Senator STEVENS. They are the same ones that Mr. Kovacic is 

talking about, right? 

Dr. ASHLEY. Yes, sir. 

Senator STEVENS. Have any of you ever asked Congress for 

money to produce your own machines? 

Dr. ASHLEY. If I can try to clarify something, the machine 

itself—— 

Senator STEVENS. I’ve really got a shortage of time, Doctor, just 

would you please answer my question. Have any of your agencies 

ever asked the Congress to give you money to replicate those machines, to build better machines? 

Dr. ASHLEY. No, sir. 

Senator STEVENS. How long have these machines been in existence? Dr. Kovacic, when were they made? 

Mr. KOVACIC. I believe, in the 1960s, the original design. 

Senator STEVENS. That even predates my presence in the Congress. That’s pretty old. You know, I just don’t understand that. 

Tell me this, have you done any studies on increasing taxes on 

cigarettes and how it affects consumers? Any of you? 

Dr. BACKINGER. The NCI has supported research, through extramural funding, to look at the increase of price on—price of cigarettes on consumption and prevalence. And we actually—one of our 

monographs addresses that. I don’t have that information with me 

specifically today. But research does show that as you increase the 

price of cigarettes, it affects both youth smoking and adult smoking. 

Senator STEVENS. Did that cover the question of bootlegging cigarettes as a result of increased taxes? 

23 

Dr. BACKINGER. I am not—I don’t know that off the top of my 

head. I would need to check back with that and get back to you 

for the—on the record. 

Senator STEVENS. Do any of your agencies have jurisdiction over 

pursuing those who bootleg cigarettes, who sell them, notwithstanding Federal laws? 

Mr. KOVACIC. We generally wouldn’t, Senator, no. We could prosecute people who misrepresent the source of the cigarettes, who advertise cigarettes as coming from one source, but receive them from 

another. But the actual policing of bootlegging, counterfeiting, 

that’s beyond our authority. 

Senator STEVENS. It’s up to the state, is that right? 

Mr. KOVACIC. Or, I would assume, Senator, Customs and Border 

Protection, those that deal with cross-border movements. 

Senator STEVENS. Did you start to say something, Dr. Ashley? 

Dr. ASHLEY. There is a Federal agency that deals with that. It’s 

not CDC. 

Senator STEVENS. Well, I’ve just one last question. As part of our 

Congressional involvement, we did require that the cigarette manufacturers do a certain amount of advertising. I’ve seen some recently, as a matter of fact, on television and over the radio, and, 

I think, even in the printed media, directed toward young people 

and trying to prevent them from smoking. Have any of you studied 

the results of those advertisements that we’ve required? 

Dr. BACKINGER. The National Cancer Institute did fund one 

study in that arena, which was published in the December 2006 

American Journal of Public Health. And I could provide that article 

for you and for the record. 

[The information referred to is contained in the Appendix.] 

Dr. BACKINGER. Just off the top of my head, the research found 

that youth that saw those ads on TV were not—did not help prevent smoking initiation. 

Senator STEVENS. Since that basic settlement that we were all 

part of, has there been an increase or a decrease in cigarette smoking by younger people? 

Dr. BACKINGER. The—for the latest years that are available—and 

I would have to look at that again—but youth smoking has increased slightly in the last 2 years for which we have data. Slightly. 

Senator STEVENS. Last irrelevant question, but my colleague has 

mentioned the fact we were all given so many free cigarettes. My 

friends and I were never seduced by those cigarettes. We didn’t 

smoke cigarettes, we smoked pipes. Have you ever made any studies of pipes and its connection to cancer, Doctor? 

Dr. ASHLEY. We have not studied pipes. 

Senator STEVENS. Dr. Backinger? 

Dr. BACKINGER. I am not aware of any NCI-funded research on 

pipes, specifically, but I could check. 

Senator STEVENS. Yes. Well, I’d be interested. 

I quit a long time ago, anyway, but I just wondered whether 

there is any connection between pipe smoking as well as the cigarette smoking. What about cigars, have you done studies of cigars? 

24 

Dr. BACKINGER. We—NCI did look at cigars, and, during the 

1990s—when there was an increase in prevalence of smoking of cigars—and we do have an NCI monograph on that subject. 

Just—the other comment, however, is, all tobacco, regardless of 

its form, is hazardous and causes a variety of cancers, as well as 

other diseases. 

Senator STEVENS. Did your monographs compare the basic results of smoking different types of substances, like pipe or tobacco 

or cigarettes? 

Dr. BACKINGER. The cigar monograph was focused solely on the 

various types of cigars that were available at the time. 

Senator STEVENS. Well, I thank you very much. 

Thank you for your testimony. I’m a little disturbed about the— 

this is the first time I’ve heard about those machines being—not— 

that our government testing was not done by other than machines 

that the industry developed. 

Thank you. 

Senator LAUTENBERG. I have a couple of questions I’d like to ask 

you. 

Dr. Ashley, last Thursday the CDC found the number of smokers 

has remained the same over the last 2 years. We know that the tobacco companies spent $13 billion in 2005 on advertising and marketing, almost double that which they spent in 1998. Do you believe that the increases in tobacco advertising is the reason that 

we’re seeing no decline in the population that is smoking? 

Dr. ASHLEY. I believe the CDC report says—concluded that fact 

that it is bottoming out and no longer decreasing is because of the 

decrease in money spent on tobacco control. 

Senator LAUTENBERG. We’re looking at testing machines, and 

seeing how reliable they might be. I think the most reliable testing 

machines are humans. And is there sufficient confirmation of the 

relationship of cancer, heart problems, and other conditions, that 

we can attribute directly to smoking? Dr. Backinger? 

Dr. BACKINGER. Yes. 

Senator LAUTENBERG. Have we seen any tests related to the difference in the incidence of cancer, et cetera, from the light, or however else they’re described, cigarettes and the regular cigarettes? Is 

there more frequent occurrence, can you say, of using either the 

regular cigarette or the light cigarettes, in terms of the people who 

use these? 

Dr. BACKINGER. The studies that were conducted are epidemiological studies, population-based. So, it’s—we don’t have data on individuals, per se. But, overall, people that smoke ‘‘light’’ or low-tar 

cigarettes did not have a decrease in any of the disease risks and 

cancers from smoking as people that smoked regular cigarettes, 

conventional cigarettes. 

Senator LAUTENBERG. Thank you all for your excellent testimony, 

and given in very clear, unequivocating fashion. I appreciate that. 

Thank you. 

And we’ll call the next panel, please, to the table. 

Senator STEVENS. I would appreciate a copy of those two monographs, Doctor. 

Dr. BACKINGER. Yes, I will follow up with that. Thank you. 

25 

Senator LAUTENBERG. I’m not really a button-pusher, as you can 

see. 

I thank the members of this panel: Dr. John Samet, the Chairman of the Department of Epidemiology at Johns Hopkins University; Jack Henningfield, Adjunct Professor at Johns Hopkins University School of Medicine; Mr. Marvin Goldberg, a Professor of 

Marketing at Penn State University; and Mr. Stephen Sheller, the 

Founder and a Managing Partner from the law firm of Sheller, P.C. 

And I thank all of you for joining us and sharing your views and 

expertise. 

And, Dr. Samet, may I ask you, please, to start. 

STATEMENT OF JONATHAN M. SAMET, M.D., M.S., PROFESSOR 

AND CHAIRMAN, DEPARTMENT OF EPIDEMIOLOGY, JOHNS 

HOPKINS BLOOMBERG SCHOOL OF PUBLIC HEALTH 

Dr. SAMET. Thank you, Senator Lautenberg, Senator Stevens. I 

appreciate the opportunity to address the Committee today on the 

matter of the accuracy of the FTC tar and nicotine rating system. 

This is an important public health issue, not only for the United 

States, but for the approximately 1.3 billion smokers in other countries. 

Let me begin with the bottom line; that is, that there is a consensus among the scientific and public health communities that a 

lower machine yield of tar and nicotine, as measured by the FTC 

protocol, has no health implications. I base this statement on the 

findings of a number of recent reviews by expert groups, including 

not only Monograph 13 of the National Cancer Institute, but a review by the Institute of Medicine published in 2001, the 2004 report of the Surgeon General, and a review of the same topic, carried out in 2002, published in 2004, by the World Health Organization’s International Agency for Research on Cancer. In my written 

testimony, I’ve summarized the key statements from these reports. 

As a major finding, the 2004 report of the Surgeon General 

states, ‘‘Smoking cigarettes with lower machine-measured yields of 

tar and nicotine provides no clear benefit to health.’’ What is the 

basis for this bottom line? Part of the basis lies in the epidemiological studies already referred to in the last panel, those studies that 

have looked at risks to smokers as they have been using these 

products and smoking them. This is a somewhat difficult area for 

epidemiologists, but we now have many studies on the question. 

To quickly summarize evidence that is included in these different 

reports, the epidemiological studies that have been carried out 

largely show no indication of lower risks associated with using 

lower-yield products. Perhaps one exception are studies that compared, early on, users of filter to the nonfilter cigarettes of the past. 

We have additional data from—comparison of how risks have 

changed over time; first, in the two large studies of 1 million Americans each, carried out by the American Cancer Society, and also 

in a 50-year study of the British doctors. We’ve seen a decline in 

the sales-weighted average of tar from above 30 milligrams per cigarette to less than 15. These studies show no indication of a parallel change in risk. In fact, comparing the findings of CPS I, the 

first study of the American Cancer Society, 1959 to 1972, with the 

findings of the second study, which began in 1980, risks for all of 

26 

the major diseases went up. The same finding was noted in the 

study of British doctors, carried out over 50 years, with no decline 

in risks for lung cancer and other diseases over time. 

Another relevant body of data involves measuring the level of tobacco-smoke components, so-called biomarkers, in body fluids of 

those who smoke. Again, if the FTC Method was giving us accurate 

information about the amounts of carcinogens and other toxins entering people, we would expect to find that levels of such markers 

in smokers paralleled those in the products—paralleled the yields 

of those in the products that they smoked. In fact, using such 

markers, we find no correlation, or limited correlation, between 

what is on the package and what is in the person. 

Recently, for example, we measured cotinine, a nicotine by-product, in saliva samples from smokers in four countries around the 

world. We found no difference in the uptake of nicotine in these 

smokers, as indicated by the cotinine level, comparing smokers of 

regular and light cigarettes. There are many other studies with 

similar findings. 

So, in summary, we now have epidemiological studies that have 

addressed the challenging question of whether changes in the product over time have altered risks. Both epidemiological studies and 

evidence from studies using biomarkers show no changes in risk for 

the major smoking-related diseases—caused diseases—that parallel 

the changes in nicotine or tar yield. All of the recent authoritative 

reports developed by multidisciplinary teams of experts have concluded that there is no indication of benefit to the health of smokers from smoking lower-yield products. 

The FTC tar and nicotine ratings provide no meaningful information about risks to smokers. The numbers provided are potentially 

misleading the smokers, as are product labels that attempt to convey messages based on yield. 

Thank you, and I’d be pleased to answer questions. 

[The prepared statement of Dr. Samet follows:] 

PREPARED STATEMENT OF JONATHAN M. SAMET, M.D., M.S., PROFESSOR AND

CHAIRMAN, DEPARTMENT OF EPIDEMIOLOGY, JOHNS HOPKINS BLOOMBERG SCHOOL

OF PUBLIC HEALTH

Introduction and Background 

Mr. Chairman, and Committee members, thank for you the opportunity to address 

the Committee on Commerce, Science, and Transportation on the matter of the accuracy of the FTC tar and nicotine rating system. This is an important public health 

issue, not only for the United States, but for the approximately 1.3 billion smokers 

in other countries. In my testimony I will speak to whether the FTC ratings and 

tobacco industry cigarette brand labels that have an implicit basis in them, e.g., 

‘‘light’’ and ‘‘ultra light’’, have any implications for the serious risks to health caused 

by cigarette smoking. 

In speaking to this topic, I draw on several decades of relevant research experience as well as my participation in developing a number of the major reports that 

have considered the FTC ratings and the implications of tar and nicotine yields for 

risks to health. My professional background and training is in internal medicine and 

the subspecialty of pulmonary diseases and in epidemiology, the scientific method 

used to study the health of populations. I have carried out research that examined 

if risks for lung diseases, including lung cancer, are associated with type of cigarette 

smoked and tar yield. My studies have also assessed whether levels of biomarkers 

of tobacco smoke exposure, particularly cotinine (the major nicotine metabolite) vary 

with the yield and type of cigarette smoked. 

Additionally, I was a contributor to Monograph 13 of the National Cancer Institute, published in 2001, which addressed the implications of lower-yield products, 

27 

as measured by machine, for human health. I was Senior Scientific Editor for the 

2004 Report of the Surgeon General on active smoking and Chair of the Working 

Group of the International Agency for Research on Cancer (IARC) of the World 

Health Organization that developed Monograph 83, Tobacco Smoke and Involuntary 

Smoking, published in 2004. These reports also considered the information about 

risks provided by cigarette yield. In the Department of Justice lawsuit against the 

tobacco industry (United States v. Philip Morris), I also testified on this topic. 

There Is Consensus That a Lower Machine Yield Has No Health Benefit 

The attached table provides the summary findings of the key recent reports on 

the topic including those prepared by the National Cancer Institute,[1] the Institute 

of Medicine,[2] the Surgeon General,[3] and the International Agency for Research on 

Cancer [4] (Table 1). Each of these reports was developed by a multidisciplinary 

group of experts who evaluated the relevant evidence. There is clear consensus in 

their findings: machine-measured yields of tar and nicotine are not informative with 

regard to risks to health of smoking cigarettes; lower yields do not imply lesser 

health risks. As a major finding, the 2004 report of the Surgeon General states (p. 

25): ‘‘Smoking cigarettes with lower machine-measured yields of tar and nicotine 

provides no clear benefit to health.’’ 

Epidemiological Studies Provide No Evidence That Lower Yields Have 

Health Benefits 

Much of the scientific evidence leading to this consensus comes from epidemiological studies. FTC reports and other information document a substantial decline since 

the 1950s in machine-measured tar and nicotine yields of cigarettes smoked in the 

United States (Figure 1). Epidemiologists have carried out research to determine 

whether this decline has had any consequences for risks to the health of smokers. 

A substantial benefit might be anticipated, of health risks tracked with machinemeasured yields. 

The relevant evidence on the risk of lower tar products has been growing, but this 

is a difficult topic for researchers. Investigating the consequences of modifications 

in cigarettes is difficult because cigarettes have been changing continually over 

time, so that comparisons cannot be made between groups that have smoked the 

same cigarettes throughout their entire lives. People who started smoking in the 

1950s then moved on to the cigarettes of the 1960s and 1970s, for example, if they 

continued to smoke. In spite of these methodological complications, epidemiological 

studies would be able to detect changes in risk of a magnitude that matched the 

changes in yields (Figure 1). 

The available epidemiological evidence comes from three sources: (1) comparisons 

of changes in mortality rates for lung cancer and other diseases over time in relation to changes in products used by smokers; (2) case-control studies comparing disease risks in smokers of different types of products; and (3) cohort studies that have 

tracked smokers over substantial periods of time, as with the study of British physicians in progress from 1951 through 2001, or that have been conducted serially, as 

with the two very large epidemiological studies carried out by the American Cancer 

Society and known as Cancer Prevention Studies I and II, or CPS I and CPS II. 

The relevant evidence is not extensive and not fully consistent across the three 

sources. There is also evidence from studies that have involved measurements of 

levels of cigarette smoke components in biological samples from smokers of different 

types of cigarettes. 

Several case-control and cohort studies have shown small reductions in risk, on 

the order of 20 percent for lung cancer, comparing smokers of filter cigarettes with 

smokers of non-filter cigarettes. These were largely early epidemiological studies, 

carried out in the 1960s and 1970s; the comparison at the time was largely between 

smokers of non-filtered and filtered cigarettes. Several reports have commented on 

these early findings (Table 1). The relevance of these findings to current cigarettes 

is uncertain. In general, epidemiological studies show that tar yield of the cigarettes 

smoked is only a weak predictor of lung cancer risk after taking account of other 

aspects of the smoking history. 

Some have interpreted the rapid decline in lung cancer mortality in younger 

males in the United Kingdom during the last decades of the 20th century as indicating a benefit of the changing cigarette. Sir Richard Peto at Oxford has proposed 

that the decline in lung cancer rates in the United Kingdom was too great to be 

explained by dropping smoking rates alone and has argued that changes in cigarettes over time also contributed to the decline. However, data from major cohort 

studies that cover the same time period—the British physicians’ study, and CPS I 

and II indicate rising relative risks of lung cancer over time in smokers generally. 

28 

If the changes in cigarette yields had any benefit we would expect these relative 

risks to be dropping. Instead, they have risen. 

Some of the most compelling evidence is from the American Cancer Society’s Cancer Prevention Studies. The data from these studies show that regardless of how 

cigarettes changed, for smokers in CPS I (1959–1972) versus those in CPS II (1980– 

1986), relative risks of lung cancer (and other diseases) went up (Table 2). Over the 

time interval separating these two studies, there was a substantial drop in the tar 

and nicotine yields of the cigarettes that were smoked in the United States (Figure 

1). In fact, in more detailed analyses of the data that have been published, the mortality rates from lung cancer tend to be higher within categories defined by the 

numbers of cigarettes smoked and the number of years of smoking, comparing the 

second study with the first.[5,6] This pattern of higher risks in CPS II suggests an 

increase in the risk of smoking over time, comparing similar groups of smokers in 

CPS I and CPS II. 

Also relevant are analyses of the data from the British Doctors’ Study which compared risks in the first and second halves of the study after 40 years of follow-up.[7]

The comparison shows that the relative risk values went up comparing the first 20 

years (1951–1971) to the second 20 years (1972–1991). The paper on the 50-year follow-up described progressively increasing risks for mortality among smokers over 

the five decades of follow-up.[8] Even looking back at the older studies that found 

small reductions in relative risks at one particular point in time, comparing filter 

to non-filter cigarette use, these studies did not track how risks changed over time 

as more and more smokers were smoking cigarettes with lower FTC tar and nicotine 

yields and the sales-weighted tar and nicotine yields declined progressively (Figure 

1). 

While the epidemiological studies have emphasized smoking and lung cancer, 

findings have been generally similar for the other major diseases caused by cigarette 

smoking. With respect to heart disease and chronic obstructive pulmonary disease 

(COPD), the evidence has also consistently shown that smokers who use lower tar 

products obtain no benefit at all in terms of reducing their risk of acquiring these 

two diseases. The findings from the comparison of CPS I and CPS II are similar 

to those for lung cancer (see Table 2). Risks for all the major diseases caused by 

smoking increased in CPS II. 

It is important to consider a possible additional risk to health posed by the use 

of low yield products: the 2004 Surgeon General’s Report noted the rise in adenocarcinoma, among the major types of lung cancer. One remarkable change in the epidemiological characteristics of lung cancer over the last 40 years approximately has 

been a shift in the predominant type of lung cancer. At the beginning of the epidemic of tobacco-caused lung cancer, the leading histologic type was squamous cell 

carcinoma, which characteristically involves the larger and more central airways of 

the lung. Since the late 1960s, there has been a shift so that adenocarcinoma is now 

the most common in both men and women. Interestingly, adenocarcinomas tend to 

occur more peripherally in the lung, arising from the smaller airways. One hypothesis is that changes in the cigarette have lead to deeper inhalation with a pattern 

of deposition of carcinogens in the lung that differed from that typically occurring 

with the older, higher-yield products.[9,10] Some have also suggested that the mix of 

carcinogens in tobacco smoke may have changed, perhaps with greater concentrations of tobacco-specific nitrosamines, which cause adenocarcinoma in exposed animals. 

Biomarker Studies Show No Association of Machine-Measured Yield With 

Levels of Smoke Components in the Bodies of Smokers 

Researchers have studied the relationship between the FTC measurements, that 

is, tar and nicotine yields as reported from the FTC Method, and the levels of tar 

components and nicotine actually entering into the bodies of smokers. Biomarker is 

a general term for compounds that can be measured in a biological material. With 

regard to cigarette smoking, we measure these biomarkers as quantitative indicators of how much a person has smoked, and of the amount of biological materials 

reaching the lungs, and then getting into the bloodstream. 

Using these methods, researchers have explored the relationship between the 

FTC-yield measurements and the levels of biomarkers in smokers. If the FTC measurements are providing meaningful information, the levels of biomarkers should 

track with the measured yields. A number of studies have used biomarkers of dose 

for specific tobacco smoke components, including carboxy-hemoglobin (hemoglobin 

bound to carbon monoxide rather than to oxygen) and cotinine (a metabolite specific 

to the breakdown of nicotine). 

In general, research using these biomarkers has indicated little, if any, correlation 

between the FTC-yield of tar or nicotine, and the levels of the biomarkers measured 

29 

in smokers. These studies have been conducted both in the population context and 

in laboratory settings. For example, in a study that my group conducted in New 

Mexico,[11] we collected saliva for the analysis of cotinine levels, and breath samples 

for measurement of carbon monoxide levels in a population survey sample of Hispanic persons. After taking account of the numbers of cigarettes smoked, the levels 

of biomarkers were not associated with the yields of tar and nicotine of the current 

brand of cigarette. Another study [12] evaluated smoking patterns and biomarkers in 

the laboratory setting, contrasting smokers of medium-yield and low-yield cigarettes. The smokers had greater puff volumes and puff frequencies than are specified in the FTC protocol and had substantially greater intakes of tar and nicotine 

than those implied by the brand yield listings. More recently, we measured the 

cotinine level in saliva samples from smokers in four countries (Brazil, China, Mexico, and Poland).[13] Cotinine concentration per cigarette smoked did not differ between smokers of light and regular cigarettes (Figure 2). Figure 2 shows the data 

for each country with two curves for country, one showing the cotinine level for 

smokers of regular cigarettes and the other for smokers of light cigarettes. The 

curves are essentially identical in each of the countries. 

These and other results suggest that there is little difference in the levels of biomarkers comparing smokers of higher yield tar/nicotine cigarettes and lower yield 

tar/nicotine cigarettes, as measured by the FTC Method. This finding implies that 

doses of carcinogens or other toxic materials that smokers inhale have little relationship, if any, to the FTC tar yield. This finding further implies that the gradual 

reduction in tar yield over the past several decades has not resulted in a reduction 

in smokers’ exposure to carcinogens and other toxic agents, and that the FTC test 

method is not informative with respect to lung cancer risk or to the risks of smoking-caused diseases generally. 

There are several explanations for this lack of correlation. First, the smoking pattern of the machine is not representative of how people smoke; in other words, the 

machine does not smoke like a person, or even the average person. It uses a pattern 

of puffing that is based on very old information. Second, the ventilation holes in the 

filter, which are not covered when the end of the cigarette is inserted into the machine, are generally covered by smokers as they hold the cigarette and puff. Third, 

smokers tend to compensate for the reduced yield of nicotine by increasing the volume of puffs (that is, the volume of smoke they pull into their mouths), the number 

of puffs per cigarette, and the number of cigarettes smoked. This compensation is 

not replicated by the test machine. In this manner, smoking cigarettes produces 

similar levels of biomarkers, regardless of whether the cigarettes smoked are labeled as ‘‘Low Tar’’ or ‘‘Low Nicotine.’’ 

Summary and Overall Conclusions 

Beginning in the 1950s, following the initial epidemiological studies showing very 

strong associations of smoking with risk for lung cancer and other diseases, the tobacco industry has continually altered cigarettes, adding filters and making other 

changes that have led to reduced yields of tar and nicotine as measured by a machine (Figure 1). Both epidemiological studies and evidence from studies using biomarkers show no parallel changes in risks for the major smoking-caused diseases. 

All recent authoritative reports, developed by multidisciplinary teams of experts, 

have concluded that there is no indication of benefit to the health of smokers from 

smoking lower yield products. The FTC tar and nicotine ratings provide no meaningful information about risks to smokers. The numbers provided are potentially 

misleading to smokers, as are product labels that attempt to convey messages based 

on yield. 

Table 1.—Summary findings of the key reports on machineMmeasured cigarette yields and health 

Report and Conclusion Page Number Year 

DNCI Smoking and Tobacco Control Monograph 13 [1] 2001 

‘‘Epidemiological and other scientific evidence, including patterns of 

mortality from smoking-caused diseases, does not indicate a benefit 

to public health fro changes in cigarette design and manufacturing 

over the last fifty years.’’ 

p. 10 

‘‘Widespread adoption of lower yield cigarettes by smokers in the 

United States has not prevented the sustained increase in lung cancer among older smokers.’’ 

p. 10 

30 

Table 1.—Summary findings of the key reports on machineMmeasured cigarette yields and health— 

Continued 

Report and Conclusion Page Number Year 

‘‘Measurements of tar and nicotine yields using the FTC Method do not 

offer smokers meaningful information on the amount of tar and nicotine they will receive from a cigarette. The measurements also do not 

offer meaningful information on the relative amounts of tar and nicotine exposure likely to be received from smoking different brands of 

cigarettes.’’ 

p. 10 

‘‘Epidemiological studies have not consistently found lesser risk of diseases, other than lung cancer, among smokers of reduced yield cigarettes. Some studies have found lesser risks of lung cancer among 

smokers of reduced yield cigarettes. Some or all of this reduction in 

lung cancer risk may reflect differing characteristics of smokers of reduced-yield compared to higher-yield cigarettes.’’ 

p. 146 

‘‘There is no convincing evidence that changes in cigarette design between 1950 and the mid 1980s have resulted in an important decrease in the disease burden caused by cigarette use either for smokers as a group or for the whole population.’’ 

p. 146 

Clearing the Smoke: Assessing the Science Base for Tobacco Harm Reduction, Institute of Medicine [2]

2001 

‘‘Most current assessments of morbidity and mortality suggest that lowyield products are associated with far less health benefit, if any, than 

would be predicted based on estimates of reduced toxic exposure 

using FTC yields.’’ 

p. 2 

‘‘The weight of the evidence indicates that lower-tar and nicotine yield 

cigarettes have not reduced the risk of disease proportional to their 

FTC yields, in part because smokers compensate to obtain more nicotine and in part because the products themselves contain higher concentrations of selected carcinogens.’’ 

p. 67 

‘‘There is no evidence of a threshold for tobacco smoking and cancer 

risk. This conclusion is consistent with the knowledge that there are 

many carcinogens in tobacco smoke, the aggregate would work to increase risk at any level. Modeling for low-dose indicates increased 

risk with less than one cigarette per day. Thus persons who initiate 

smoking with PREPS that contain tobacco would increase their risk 

for cancer, and there is unlikely to be a ‘‘safe’’ cigarette. Former 

smokers who resume smoking with such products would increase 

their risk further.’’ 

p. 431 

‘‘The available data are suggestive, but not sufficient, to conclude that 

smokers of so-called low-tar cigarettes have lower cancer risk compared to those who smoke higher tar cigarettes, with the same caveats as for filter smoking studies.’’ 

p. 432 

IARC Monograph 83, Tobacco smoke and involuntary smoking [4] 2004 

‘‘. . . after considering the limitations of the evidence, the Working 

Group concluded that changes in cigarettes since the 1950s have 

probably tended to reduce the risk for lung cancer associated with 

the smoking of particular numbers of cigarettes at particular ages.’’ 

p. 171 

‘‘The yields of tar, nicotine and carbon monoxide from cigarettes, as 

measured by standard machine-smoking tests, have fallen over recent decades in cigarettes sold in most parts of the world, but have 

remained higher in some countries. The tar and nicotine yields as 

currently measured are misleading and have only little value in the 

assessment of human exposure to carcinogens.’’ 

p. 1179 

(Summary) 

The Health Consequences of Smoking: A Report of the Surgeon General[3]

2004 

‘‘Smoking cigarettes with lower machine-measured yields of tar and 

nicotine provides no clear benefit to health.’’ 

p. 25 

[1] U.S. Department of Health and Human Services (USDHHS), National Cancer Institute. Risks associated with smoking cigarettes with low machine-measured yields of tar and nicotine. Bethesda, MD: National Institutes of Health, 2001. [2]Stratton K., Shetty P., Wallace R., Bondurant S., eds. Clearing the smoke: assessing the science base for tobacco harm reduction. Washington,D.C.: National Academy Press, 2001. [3] U.S. Department of Health and Human Services (USDHHS). The health effects of active smoking: A report of the Surgeon General. 2004. Washington, D.C., U.S. Government Printing Office. [4] International Agency for Research on Cancer (IARC). Tobacco smoke and involuntary smoking. IARC monograph 83. 2004. 

Lyon, France, International Agency for Research on Cancer. 

31 

Table 2.—Changes in cigarette-related mortality risks between Cancer Prevention Study 1 (1959 through 

1965) and Cancer Prevention Study II (1982 through 1988) and percentage of deaths attributable to active cigarette smoking. Source: 14

CPS I CPS II 

Males 

Relative 

Risk 

Percent Relative 

Risk 

Percent 

Overall Mortality 1.7 42.2 2.3 57.1 

Lung Cancer 11.9 91.6 23.2 95.7 

Coronary Heart Disease 1.7 41.5 1.9 46.2 

Chronic Obstructive Pulmonary Disease 9.3 89.2 11.7 91.4 

Stroke 1.3 21.9 1.9 46.8 

Other Smoking Related Cancers 2.7 63.4 3.5 71.2 

Females 

Overall Mortality 1.2 18.7 1.9 47.9 

Lung Cancer 2.7 63.4 12.8 92.2 

Coronary Heart Disease 1.4 27.0 1.8 45.1 

Chronic Obstructive Pulmonary Disease 6.7 85.0 12.8 92.2 

Stroke 1.2 15.2 1.8 45.7 

Other Smoking Related Cancers a 1.8 45.0 2.6 60.8 

aSites include larynx, oral cavity, esophagus, bladder, kidney, other urinary, and pancreas. 


1113same.eps
32 

Reference List 

[1] U.S. Department of Health and Human Services (USDHHS), National Cancer 

Institute. Risks associated with smoking cigarettes with low machine-measured 

yields of tar and nicotine. Bethesda, MD: National Institutes of Health, 2001. [2]Stratton, K., Shetty, P., Wallace, R., Bondurant, S., eds. Clearing the smoke: 

assessing the science base for tobacco harm reduction. Washington, D.C.: National 

Academy Press, 2001. [3] U.S. Department of Health and Human Services (USDHHS). The health effects 

of active smoking: A report of the Surgeon General. 2004. Washington, D.C., U.S. 

Government Printing Office. [4] International Agency for Research on Cancer (IARC). Tobacco smoke and involuntary smoking. IARC monograph 83. 2004. Lyon, France, International Agency for 

Research on Cancer. [5] U.S. Department of Health and Human Services (USDHHS), Public Health 

Service, National Cancer Institute (NCI). Changes in cigarette-related disease risks 

and their implication for prevention and control. Burns, D.M., Garfinkel L., Samet, 

J.M., editors. [8]. 1997. Bethesda, Maryland, U.S. Government Printing Office (NIH 

Publication No. 97–4213). Smoking and Tobacco Control Monograph. [6]Thun, M.J., Heath, C.W., Jr. Changes in mortality from smoking in two American Cancer Society prospective studies since 1959. Prev Med 1997; 26(4):422–426. [7]Doll, R., Peto, R., Wheatley, K., Gray, R., Sutherland, I. Mortality in relation 

to smoking: 40 years’ observations on male British doctors. Br Med J 1994; 

309(6959):901–911. [8]Doll, R., Peto, R., Boreham, J., Sutherland, I. Mortality in relation to smoking: 

50 years’ observations on male British doctors. Br Med J 2004; 328(7455):1519– 

1527. [9] Alberg, A.J., Ford, J.G., Samet, J.M. Epidemiology of lung cancer: ACCP evidence-based clinical practice guidelines (2nd edition). Chest 2007; 132(3 Suppl.):29S– 

55S. [10]Thun, M.J., Lally, C.A., Flannery, J.T., Calle, E.E., Flanders, W.D., Heath, 

C.W., Jr. Cigarette smoking and changes in the histopathology of lung cancer. J 

Nat’l Cancer Inst 1997; 89(21):1580–1586. [11] Coultas, D.B., Stidley, C.A., Samet, J.M. Cigarette yields of tar and nicotine 

and markers of exposure to tobacco smoke. Am Rev Respir Dis 1993; 148(2):435–440. [12]Djordjevic, M.V., Stellman, S.D., Zang, E. Doses of nicotine and lung carcinogens delivered to cigarette smokers. J Nat’l Cancer Inst 2000; 92(2):106–111. [13] Blackford, A.L., Yang, G., Hernandez-Avila, M., Przewozniak, K., Zatonski, W., 

Figueiredo, V. et al., Cotinine concentration in smokers from different countries: reVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00036 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE

1113same1.eps
33 

lationship with amount smoked and cigarette type. Cancer Epidemiol Biomarkers 

Prev 2006; 15(10):1799–1804. [14]Thun, M.J., Day-Lally, C., Myers, D.G., Calle, E.E., Flanders, W.D., Zhu, BP et al., Trends in tobacco smoking and mortality from cigarette use in Cancer Prevention Studies I (1959–1965) and II (1982–1988). In: Burns, D.M., Garfinkel, L., 

Samet, J.M., editors. Changes in Cigarette Related Disease Risks and Their Implication for Prevention and Control. Bethesda, Maryland: U.S. Government Printing Office, 1997: 305–382. 

[15] Hoffmann, D., Hoffmann, I., El Bayoumy, K. The less harmful cigarette: a 

controversial issue. a tribute to Ernest L. Wynder. Chem Res Toxicol 2001; 

14(7):767–790. 

Senator LAUTENBERG. Thank you very much. 

Dr. Henningfield, you’re next, please. 

STATEMENT OF JACK E. HENNINGFIELD, PH.D., 

VICE PRESIDENT, RESEARCH AND HEALTH POLICY, 

PINNEY ASSOCIATES; PROFESSOR OF BEHAVIORAL BIOLOGY, 

ADJUNCT, AND DIRECTOR, INNOVATORS AWARDS PROGRAM, 

DEPARTMENT OF PSYCHIATRY AND BEHAVIORAL SCIENCE, 

THE JOHNS HOPKINS UNIVERSITY SCHOOL OF MEDICINE 

Dr. HENNINGFIELD. Senator Lautenberg, thank you for the opportunity to testify. 

For three decades, I have studied drug addiction and tobacco use 

at Johns Hopkins Medical School, the National Institute on Drug 

Abuse, and Pinney Associates, and I am a consultant to 

GlaxoSmithKline on smoking cessation medicines. I also serve the 

World Health Organization in its efforts to evaluate the international equivalent of FTC, which is called the ISO [International 

Standards Organization] Cigarette Testing Method. I provide additional detail in my written submission. 

The FTC cigarette testing method does not provide accurate information about tar and nicotine exposure to cigarette smokers. It 

greatly underestimates inhaled amounts. Furthermore, the ratings 

support marketing that undermine our efforts to prevent young 

people from starting to smoke and from motivating smokers to quit. 

The problem has persisted, in part, because of the absence of public 

health-based regulatory oversight that would have been responsive 

to the warning signs over the past two decades or longer. 

How did it happen? What is the path toward resolution? Let me 

start with the problem and how it was discovered. 

I believe Americans trust product content ratings because our 

Nation leads the world in setting standards for truthful ingredient 

information for foods and drugs. This information typically communicates the maximum exposure from a product, not average exposure. When a content or delivery rating of food product or drug 

product is found to misrepresent the product, the established protocols can fix the problem. Every year, FDA acts on hundreds of 

products that are misrepresented, or, more technically, misbranded. It isn’t surprising that Americans believe the FTC rating 

bears some relationship to health effects and exposure. Consumers, 

such as my own sister, do not believe that the government would 

allow such a scam to continue. I am a scientist in this area; I was 

similarly deceived in my research efforts. 

This figure shows what many of us thought was a major success 

story in public health. In the 1960s—from the 1960s to 1980s, the 

FTC ratings of tar and nicotine plummeted, as rated by the FTC 

34 

Method. As intended, consumers flocked to cigarettes with lower 

ratings. Even scientists like me thought we could take advantage 

of what appeared to be a broad range of nicotine dosing systems 

for biological research. And then we had a hard time interpreting 

our results, because a lot of it didn’t make sense if we were really 

manipulating nicotine dose to the proportion that we thought. 

But the warning bells were sounded by human studies in the 

1980s, by NIDA and other NIH research. In 1983, Dr. Neal 

Benowitz published one of the seminal studies. His studies showed 

that light cigarettes did not deliver less nicotine. In fact, as shown 

by the solid line in this figure, actual nicotine exposure was not related to FTC ratings. The dotted line shows what scientists had expected and what companies advertised and what consumers wanted: lower levels of exposure from cigarettes with the lower ratings. 

This problem was confirmed by FDA and acknowledged by FTC in 

the 1990s. In 2001, National Cancer Institute Monograph 13 came 

to the most devastating conclusion of all, that there is no health 

benefit to cigarettes with low FTC ratings. 

How did it happen? FTC’s intentions were good, and it is not unreasonable that they expected the rating system would help smokers reduce their tar and nicotine. FTC did not anticipate the extent 

to which tobacco industry would go to design cigarettes to undermine the tests and render the rating system meaningless. Also 

under-appreciated at the time was the power of the addictive process that motivated smokers—to more intensively smoke cigarettes, 

a process that we refer to as compensatory smoking. 

The cigarette designs that you’ve already heard mentioned that 

circumvented the method were elaborate, but several are easily 

pointed out. This shows the ventilation holes which smokers cannot 

see on most cigarettes. They’re not covered by the machines, but 

smokers can easily cover them with fingers and lips. There are 

many other design features that enable smokers to get addictive 

doses of nicotine, even if it means higher levels of tar, from virtually any cigarette on the market. 

There is no simple fix that we could provide to FTC; in part, because cigarette designs continue to evolve. But, there is a path toward resolution, and that is to charge FDA to set standards for cigarette testing and labeling, and oversee the validity of the testing, 

as proposed in current legislation. FDA is the world authority in 

measuring dosing capacity and exposures produced by a broad 

range of products, including ever-changing drug delivery systems. 

For FDA, the scientific challenge is well understood. It has the capacity to not only fix the problem for currently marketed cigarettes, 

but also to prevent such a colossal and long-lasting deception to 

consumers from ever occurring again. 

Thank you for the opportunity. I’ll be pleased to do whatever I 

can to help. 

[The prepared statement of Dr. Henningfield follows:] 

35 

PREPARED STATEMENT OF JACK E. HENNINGFIELD, PH.D., VICE PRESIDENT, RE- SEARCH AND HEALTH POLICY, PINNEY ASSOCIATES; PROFESSOR OF BEHAVIORAL BI- OLOGY, ADJUNCT, AND DIRECTOR, INNOVATORS AWARDS PROGRAM, DEPARTMENT OF

PSYCHIATRY AND BEHAVIORAL SCIENCE, THE JOHNS HOPKINS UNIVERSITY SCHOOL

OF MEDICINE

Mr. Chairman, Senator Lautenberg, and other members of the subcommittee, 

thank you for the opportunity to testify. For three decades, I have studied drug addiction and tobacco use at Johns Hopkins Medical School, the National Institute on 

Drug Abuse, and Pinney Associates. I serve on the World Health Organization 

Study Group on Tobacco Product Regulation and advise its Tobacco Laboratory Network and the Conference of Parties guiding implementation of the Framework Convention (‘‘Treaty’’) on Tobacco Control on the measurement and communication of 

tobacco product contents and emissions. Through Pinney Associates I consult to 

GlaxoSmithKline on smoking cessation medications; I have a financial interest in 

a smoking cessation medicine that is under development; and, I have testified on 

these topics in litigation brought against the tobacco industry by the U.S. Department of Justice and other plaintiffs. 

My work is also supported by the Robert Wood Johnson Foundation Innovators 

Awards Program at The Johns Hopkins University School of Medicine. I speak on 

my own behalf and am not representing any of these organizations in my testimony 

today. 

My testimony is focused on the problems with the FTC Method and the science 

base for its elucidation and resolution. 

The FTC Cigarette Testing Method does not provide accurate information about 

tar and nicotine exposure to cigarette smokers and, in fact, greatly underestimates 

the inhaled amounts. Furthermore, the ratings support marketing that undermines 

our efforts to prevent young people from starting to smoke and to motivate smokers 

to quit. 

This problem has persisted in part because of the absence of public health-based 

regulatory oversight that would have been responsive to warning signs over the past 

two decades. How did it happen? What is the path toward resolution? I will start 

with the problem and how it was discovered. 

The Problem 

I believe Americans trust product content ratings because our Nation leads the 

world in setting standards for truthful ingredient information for foods and drugs. 

This information typically communicates maximum exposure from a product. When 

content or delivery ratings are found to misrepresent the product, established protocols can fix the problem. Every year, FDA acts on hundreds of products that are 

misrepresented or more technically—‘‘misbranded’’. It isn’t surprising that Americans believe the FTC rating bears some relationship to health effects and exposure. 

Consumers, such as my own sister, do not believe the government would allow a 

scam like this to go on. 


1113henn1.eps
36 

This figure shows what many of us thought was a major success story in public 

health: the 1960s to 1980s plummeting of tar and nicotine levels in cigarettes as 

rated by the FTC Method (figure modified from Hoffman and Hoffman, 1994). As 

intended, consumers flocked to cigarettes with lower ratings. Even scientists like me 

thought we could take advantage of what appeared to be the broad range of nicotine 

dosing systems for biological research. Of course, we knew the ratings did not precisely predict exposure but we expected that the ratings were meaningfully related 

to human exposure. 

The warning bells sounded in the 1980s by NIH researchers. In 1983, Dr. Neal 

Benowitz and his colleagues (1983) published one of the seminal studies. His study 

showed that light cigarettes did not deliver less nicotine. This figure (estimated from 

plasma cotinine levels) shows that nicotine exposure is directly related to number 

of cigarettes smoked. 

The second figure from the Benowitz study revealed the problem. The dotted line 

shows what scientists had expected based on FTC testing: namely that there would 

be lower levels of exposure from cigarettes with lower ratings. However, the solid 

line reveals that actual exposure was not related to FTC rating. 

Unfortunately, consumers not only reasonably believe that their exposure to tar 

and nicotine will be less from cigarettes with lower FTC Method deliveries, they beVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00040 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE

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37 

lieve that health risks of cigarettes are lower in proportion to tar and nicotine reductions. For example, Kozlowski and Pillitteri (2001) reported the results of a national telephone survey which showed that for many cigarette smokers an important 

factor in smoking light cigarettes was the belief that they could reduce the risks of 

smoking without having to quit. They also cited previously secret tobacco industry 

documents which revealed that this was the intent of the industry in their design 

and marketing approach that enabled them to ‘‘reassure smokers, to keep them in 

the franchise as long as possible.’’ Responses to survey questions about the number 

of light cigarettes that would need to be smoked to get the same amount of tar as 

from a regular cigarette indicated that about 90 percent of the respondents held 

‘‘mistaken beliefs regarding the distinctions between machine based yields of tar 

and actual tar intake.’’ 

These consumer misperceptions were further explored by Cummings and colleagues (2004) in a telephone survey of cigarette smokers. They found that only 12 

percent of smokers correctly understood that you could get as much tar from a single light cigarette as from a regular cigarette, and a third or more smokers believed 

that high tar cigarettes were twice as likely to cause disease as low tar cigarettes. 

A further complication in the accuracy and potential misapplication of FTC Method testing is that as meaningless as the results are for widely marketed ‘‘conventional’’ cigarettes, FTC has never even developed testing protocols for modified cigarettes and novel cigarette substitutes that are under development and in early 

stages of marketing. For example, Shiffman and colleagues (2003) found that one 

cigarette substitute, marketed with tar and claims based on the tobacco companies 

own modification of the FTC Method has led to serious misperceptions among smokers such as one in four believing that Eclipse is a completely safe alternative to conventional cigarettes, with highest levels of interest in people who had been contemplating quitting smoking. Even more startling was that 15 percent of young adults 

who had quit smoking for at least 2 years were interested in using Eclipse. There 

are many other modified tobacco products in various stages of marketing and development, as described by Hatsukami and colleagues (2004, 2005), and these pose 

emerging problems of even greater complexity to testing and communications than 

conventional cigarettes. 

These problems were confirmed by FDA and acknowledged by FTC in the 1990s. 

In 2001, National Cancer Institute Monograph 13 came to the most devastating conclusion of all: there is no health benefit to cigarettes marketed as ‘‘light’’ and ‘‘low 

tar’’. 

How Did it Happen? 

FTC’s intentions were good and it was probably not unreasonable for the agency 

to expect that the rating system would help smokers reduce their tar and nicotine 

exposures as advocated by the Surgeon General, and would provide incentives for 

companies to develop lower-yielding cigarettes (Wilkenfeld et al., 2000). FTC did not 

anticipate the extent to which the tobacco industry would go to design cigarettes to 

undermine the test and render the rating system meaningless with respect to actual 

intake and health effects. Also under-appreciated at the time was the power of the 

addictive process that motivated cigarette smokers to more intensively smoke cigarettes that delivered lower yields per puff (‘‘compensatory smoking’’). 

The cigarette designs that circumvented the method were elaborate, but several 

are easily pointed out. Vent holes dilute the smoke in FTC machines, but do not 

do so when covered by the fingers and lips of smokers. There are many other tricks 

employed in the deception and these include the use of various chemicals to alter 

burning properties and nicotine delivery as well as other physical design features 

that are discussed in National Cancer Institute Monographs 7 and 13. For example, 

the machine stops smoking 3 mm before reaching the overwrap connecting the filter 

to the tobacco column and so does not test all the tobacco. Not surprising, this overwrap became larger when FTC testing started. Accelerant chemicals are added so 

that the cigarette would burn faster and, therefore, the relatively slow-puffing machines would measure lower tar and nicotine. The mix of design features used to 

cheat the FTC test method varies across cigarettes and appear to be continuing to 

evolve. Until the testing is in place under authority of an agency with the experience to evaluate drug and toxin delivery and empowered to demand information 

about the designs and their consequences, scientists and consumers alike will remain in the dark with respect actual deliveries and associated health effects. 

The recent and emerging problems with respect to emerging generations of modified cigarette products, such as those involving carbon heating systems, electronic 

ignition, and novel filtration, is occurring because there is presently no regulatory 

oversight mechanism in place with expertise to develop and validate new testing 

38 

methods. In the vacuum, the tobacco companies are adopting their own variations 

on the existing FTC Method. 

Path Towards Resolution 

There is no simple fix that we could provide to FTC, in part, because, cigarette 

designs continue to evolve. But there is a path toward resolution and that is to 

charge FDA to set standards for cigarette testing and labeling and oversee the validity of the testing, as proposed in current legislation intended to give FDA authority 

over tobacco products. 

FDA is the world authority in measuring dosing capacity and exposures produced 

by a broad range of products, including ever-changing drug delivery systems. It 

would be capable of developing and validating accurate methods for testing and 

communicating the results for current cigarette products as well as for the emerging 

generations of modified cigarettes and cigarette substitutes. For FDA, this scientific 

challenge is well understood. It has the capacity to not only fix the problem with 

respect to currently marketed cigarettes but also to prevent such a colossal and 

long-lasting deception of consumers and impediment to public health from ever occurring again. 

Supporting References 

Benowitz, N.L., Hall, S.M., Herning, R.I, Jacob, P., Jones, R.T., Osman, A.L. 

Smokers of low-yield cigarettes do not consume less nicotine. New England Journal 

of Medicine, 300:139–142, 1983. 

Cummings, K.M., Hyland, A., Giovino, G.A., Hastrup, J.L., Bauer, J.E., Bansal, 

M.A. Are smokers adequately informed about the health risks of smoking and medicinal nicotine? Nicotine and Tobacco Research, 6:S333-S340, 2004. 

Hatsukami, D.K., Henningfield, J.E., Kotlyar, M. Harm reduction approaches to 

reducing tobacco-related mortality. Annual Review of Public Health, 25:377–395, 

2004. 

Hatsukami, D.K., Hecht, S. Hope or hazard: what research tells us about potentially reduced exposure tobacco products. University of Minnesota Transdisciplinary 

Tobacco Use Research Center, Minneapolis, 2005. 

Kozlowski, L.T., Pillitteri, J.L. Beliefs about ‘‘light’’ and ‘‘ultra light’’ cigarettes 

and efforts to change those beliefs: an overview of early efforts and published research. Tobacco Control, 10:i12–i16, 2001. 

Shiffman, S., Pillitteri, J.L., Burton, S.L., Di Marino, M.E. Smoker and ex-smoker 

reactions to cigarettes claiming reduce risk. Tobacco Control, 13:78–84, 2003. 

Hoffman, D., Hoffman, I. The changing cigarette, 1950–1995. Journal of Toxicology and Environmental Health, 50–307–364, 1997. 

National Cancer Institute, Smoking and Tobacco Control Monograph No. 13. 

Risks associated with smoking cigarettes with low-machine measured yields of tar 

and nicotine. National Institutes of Health, NIH Pub. No. 02–5074, 2001. 

National Cancer Institute, Smoking and Tobacco Control Monograph No. 7. The 

FTC Cigarette Test Method for Determining Tar, Nicotine, and Carbon Monoxide 


1113henn4.eps
39 

Yields of U.S. Cigarettes, Report of the NCI Expert Committee, National Institutes 

of Health, NIH Publication No. 96–4028, 1996. 

Wilkenfeld, J., Henningfield, J., Slade, J., Burns, D., Pinney, J. It’s time for a 

change: Cigarette smokers deserve meaningful information about their cigarettes. 

Journal of the National Cancer Institute, 92(2):90–92, 2000. 

Wilkenfeld, J., Henningfield, J., Slade, J., Burns, D., Pinney, J. Response to FTC’s 

Response to: It’s time for a change: Cigarette smokers deserve meaningful information about their cigarettes. Journal of the National Cancer Institute, 92(10):842–843, 

2000. 

Senator LAUTENBERG. Thank you very much. 

Dr. Goldberg? 

STATEMENT OF MARVIN E. GOLDBERG, PH.D., IRVING & IRENE 

BARD PROFESSOR OF MARKETING, SMEAL COLLEGE OF 

BUSINESS, PENN STATE UNIVERSITY 

Dr. GOLDBERG. Thank you, Senator Lautenberg, I’m pleased to 

be here to testify. 

My consideration is that of advertising and promotion. From the 

1950s, when filter tips were introduced, until 2006, the tobacco industry has spent roughly $235 billion, in 2006 dollars, on advertising and promotion for cigarettes. That’s over $10 million a day. 

In the last year, 2005, that we have data for, over $13.5 billion 

were spent. That’s over $37 million every day for that year. 

What do you get, or what does the tobacco industry get, for that? 

It gets imagery, over the decades, that is pounded into our, and especially youth’s, heads, of vital, energetic, attractive people smoking what seems to be a pretty neutral product. The images of death 

and disease are far removed. It also buys, more latterly, tremendous positioning in the stores; in particular, convenience stores, 

where 60 percent of all cigarettes are sold. Not coincidentally—for 

90 percent of the cigarette smokers that start before they’re 18 

years—not coincidentally, teenagers spend twice as much time in 

convenience stores, hanging out, as adults do. It buys positioning, 

it buys very significant advertising as the displays—colorful displays represent. The teenagers talk about what they see, and convince one another. The industry then says, ‘‘It’s not us, it’s the kids 

talking about it and convincing each other.’’ That’s what we call, 

today, ‘‘viral marketing.’’ The virus is introduced—by the industry, 

however. It’s the heavy, targeted advertising. And then the viral introducer says, ‘‘I’m not part of this. It’s kids influencing kids.’’ Well, 

viral marketing—viral marketers understand that process. 

From 1967 to 1998, when we have the data from the FTC, if you 

look at the percentage of advertising that was allocated by the companies to light cigarettes—advertising for light cigarettes—and 

compare that to the sales for light cigarettes—what percentage did 

they represent?—we see that this was push marketing. It’s not that 

the consumer sat out there and said, ‘‘I want this product,’’ it was 

pushed upon them. For example, in 1979, less than 30 percent of 

sales revenues to the tobacco industry came from light cigarettes, 

but almost 50 percent of their advertising dollars went to advertising of light cigarettes; 50 versus less than 30. They pushed this 

on the market. 

The main motivation that people have for smoking, as we’ve 

heard before, light cigarettes is the health issue. The tobacco industry recognizes that through their internal documents. When we 

40 

have done studies on this, people look to less tar, less nicotine, less 

risk. About four out of five smokers say they smoke light cigarettes 

because of health reasons. 

We tried to develop a radio message, and when we developed it, 

we talked to focus groups to set up the actual script. We couldn’t 

get people to believe that one light cigarette equaled one regular 

cigarette. We had to use a small white lie in our script. We said 

something like, ‘‘Smoking a light cigarette is sort of like jumping 

off the 15th story of a building instead of the 20th story of the 

building.’’ That little white lie, they could kind of buy. Today, people believe you need to smoke two or three light cigarettes to get 

the equivalent of a regular cigarette. 

The tobacco industry does something much better than tell you 

the cigarettes are healthier, they use a kind of syllogistic reasoning, ‘‘Tar is unhealthy, we know that. Light cigarettes have less 

tar. Ergo, light cigarettes are healthier.’’ The tobacco industry 

knows, as lawyers know, when you get the person you’re trying to 

persuade to draw the conclusion themselves, you’ve done a better 

job at persuading. They’ve persuaded themselves that it must be 

true. 

Today, the R.J. Reynolds website reads, ‘‘An individual’s level of 

risk for serious disease is significantly affected by the type of tobacco product used.’’ In other words, you can smoke a light cigarette, and you’ll still be OK. What does Philip Morris say? ‘‘There’s 

no safe cigarette.’’ If you think carefully about that, it means, logically, there can be a ‘‘safer’’ cigarette. 

I’ll stop here. 

Thank you. 

[The prepared statement of Dr. Goldberg follows:] 

PREPARED STATEMENT OF MARVIN E. GOLDBERG, PH.D., IRVING & IRENE BARD

PROFESSOR OF MARKETING, SMEAL COLLEGE OF BUSINESS, PENN STATE UNIVERSITY

The development of the market for light cigarettes was not driven by consumer demand or ‘‘pull,’’ but rather ‘‘pushed’’ by the tobacco firms’ heavy marketing and promotion outlays and enabled by the deceptive messages regarding light cigarettes’ ostensible health benefits. 

Smokers did not naturally gravitate to the experience of smoking low tar cigarettes. This was not a ‘‘pull’’ marketing phenomenon, where consumer demand drove 

sales, but rather a ‘‘push’’ phenomenon that was developed and shaped by the industry as a function of its deceptive claims for light cigarettes. Advertising and promotion for the light category drove the process with campaigns that continue to 

make the case through imagery and otherwise that smokers of light cigarettes are 

attractive, healthy and vigorous people engaging in attractive vigorous activities; 

(illness and disease are far removed from these scenes). 

From the 1950s (when the focus was on filters that ostensibly reduced tar levels) 

until 2006, the industry spent an estimated $235 billion (in 2006 dollars) on advertising and promotion for cigarettes; (data drawn from Federal Trade Commission; 

FTC 2007; figures for years prior to 1970, 1971 through 1974, and 2006 are estimates). In 2005, the last year for which figures are available, the industry spent 

over $13.5 billion—about $37 million per day—on advertising and promoting cigarettes; (FTC 2007). 

The figure below illustrates: (1) the trend with regard to the percentage of the 

tobacco industry’s advertising and promotion dollars that were allocated annually to 

light cigarettes from 1967 to 1998 the years that the FTC reported this data in their 

annual report on cigarettes (FTC 2000) and (2) the annual percentage of total cigarette sales represented by light cigarettes. As may be noted, ‘‘Light’’ cigarettes (defined as less than 15 mg. tar) came to dominate both categories. 

Also evident in the figure below—until the 1990s, the percentage of dollars allocated to advertising and promotion for the light cigarette category exceeded their 

41 

share of market. In effect, the industry was investing in and driving the growth of 

this category. Ultimately, by the 1990s, given a ‘‘ceiling effect’’ (there is only so high 

that both percentages could realistically go) the two sets of percentages became 

more closely aligned. 

As a parallel part of their advertising and promotion strategies, the tobacco industry has shaped ‘‘viral marketing’’ campaigns to ensure the success and popularity of 

light cigarettes. 

The tobacco industry has long understood how advertising and interpersonal influence combine to influence the individual smoker or potential smoker. The process 

starts with the intense advertising and promotion on the part of the industry. In 

the second step in this process, the message conveyed in the advertising is relayed 

by individuals as part of the ‘‘bandwagon’’ effect. This process has recently been labeled ‘‘virus or viral’’ marketing. 

. . . [T]he future belongs to marketers who establish a foundation and process 

where interested people can market to each other. Ignite consumer networks 

and then get out of the way and let them talk;’’ (Godin 2001, p.15; emphasis 

in the original). 

Advertising and promotion serve to initiate discussion by both ‘‘opinion leaders’’ 

and their ‘‘followers’’ who touch base with one another to assess the merits of what 

they have seen/heard. In this ‘‘multi-step flow’’ of information those around us can 

and do influence us, but this influence comes as a consequence of the advertising and 

promotion to which we are exposed (Assael 2004). While an industry like the tobacco 

industry can try and point to the interpersonal influence process (people influencing 

people) it cannot absolve itself of the ultimate responsibility for the popularity, sales 

and consumption of the products they promote. As shown in the figure above, the 

tobacco industry chose to ‘‘push market’’ light cigarettes by investing heavily in advertising and promotion to ensure the growth of this segment. With the dollars they 

spent, together with the promise of reduced health risks, they succeeded in gaining 

the smoking public’s attention for lights—and their purchase dollars. The ‘‘bandwagon’’ proved to be unstoppable, with the light cigarette category steadily increasing its share of market to the point where it currently accounts for the vast proportion of sales. 

In sum, it is important to recognize that this process, where a particular brand 

or a particular product category (such as lights) gains popularity as a function of 


1113gold.eps
42 

person-to-person influence does not stand by itself. It is not an independent and 

competing source of influence, but properly understood as an integral part of the 

tobacco industry’s global marketing process—their efforts to saturate society with 

misleading messages about cigarettes. By ‘‘igniting consumer networks’’ among 

peers, and co-opting the dynamics of person-to-person influence for their own commercial purposes, the companies need not be concerned with whether any particular 

person saw or was exposed to any particular advertisement. The tobacco companies 

understand that their massive marketing campaigns are akin to a ‘‘virus’’ where 

‘‘. . . the advertiser creates an environment in which the idea can replicate and 

spread. It’s the virus that does the work, not the marketer’’ (Godin 2001; p. 26). In 

this way, the tobacco industry’s advertising and promotion efforts are causally 

linked to smokers’ and potential smokers’ actions and choices. 

Internal corporate documents make it clear that the tobacco companies have long 

known that the health issue has been the main motivation for smokers to switch to 

lower tar/light brands. 

Consider the statements below from internal documents of Brown and 

Williamson, Philip Morris, R.J. Reynolds and Lorillard: 

Those who smoked their current brand for less than a year switched for health 

purposes—to reduce the tar and nicotine level instead of quitting (Brown & 

Williamson 1977). 

The largest group of all [brand switchers are] those who are convinced that 

smoking is dangerous to their health and who are torn between a conscience 

that urges them to quit and a hedonistic desire to continue to do something 

they enjoy. 

The very fact, then, that a smoker has decided to switch from a full-flavor cigarette to a low-delivery cigarette tells us something very important about him: 

he is concerned about his health, and he is willing to do something about it; 

(Philip Morris 1978). 

As low-yield brands become more popular among adults . . . modeling behavior 

may lead adolescents to smoke them as well. Furthermore, such brands may become considered ‘‘safer’’, thus leading teenagers to pay less attention to public 

health campaigns designed to discourage initiation; (R.J. Reynolds 1980). 

Most smokers . . . do not really understand what tar and nicotine are, or the 

difference between the two. ‘‘Tar and nicotine’’ is a term commonly used as a 

single word. . . . Those who smoke low tar and nicotine cigarettes generally 

do so because they believe such cigarettes are ‘‘better for you’’—there is less tar 

and nicotine to do long-term damage; (Lorillard 1976). 

Research has confirmed the conclusions drawn by tobacco industry executives as 

cited above: the factor leading smokers to low tar/lights is that they believe these 

cigarettes are ‘‘ ‘better for you.’ ’’ 

Research has documented the salience of health factors in guiding smokers who 

switch to light cigarettes. Below I discuss two relevant studies in which I was second author: Kozlowski et al., (1998) and Kozlowski et al., (1999). Kozlowski et al 

(1998) reported on the following question posed to those who smoked light cigarettes: ‘‘I’m going to ask you about reasons some people might give for smoking 

Light . . . cigarettes. For each one please tell me whether it is one of your reasons 

for smoking Light . . . cigarettes’’ Five options were then read to the respondent: 

one of the options, taste, was discussed above; the remaining four involved ways 

that smokers of lights might believe that their cigarette held a health-related benefit: ‘‘step to quitting,’’ ‘‘less risk,’’ ‘‘less tar,’’ ‘‘less nicotine.’’ When the last three of 

the listed risk factors (‘‘less risk,’’ ‘‘less tar,’’ ‘‘less nicotine,’’) were analyzed together, 

only 24 percent of the respondents failed to select at least one of these three options; 

in other words 76 percent answered affirmatively to at least one of the health-related benefits (as reported on p. 13). If one adds to this those who only selected the 

‘‘step to quitting,’’ the percentage would no doubt climb beyond 80 percent; (while 

many, if not most smokers, are motivated to quit by health concerns, the ‘‘quitting’’ 

response was not part of this health-related benefits analysis). 

The same logic applies to the second of the studies I worked on with Kozlowski. 

(Kozlowski et al., 1999). Smokers of light cigarettes were asked to indicate which 

of four reasons they had for smoking lights; (they could select more than one of the 

reasons). While a separate analysis was not conducted, with 52 percent citing ‘‘reduce tar/nicotine’’ and 35 percent and 38 percent citing ‘‘step toward quitting’’ and 

‘‘reduce risk’’ respectively, the percentage citing at least one of these factors would 

likely climb to 80 percent and beyond. (‘‘Taste,’’ the fourth reason is discussed fully 

below). 

43 

First hand evidence also documents how successful Philip Morris and the rest of 

the tobacco industry have been in persuading smokers of low tar/light cigarettes are 

healthier. 

It should be noted that the actual purpose of the Kozlowski et al. (1999) study 

was to develop and assess the effectiveness of a ‘‘radio’’ message informing smokers 

about the true risk associated with smoking light cigarettes. In the formative steps 

leading to the development of the ‘‘radio’’ message, earlier drafts of the script were 

presented to focus groups consisting of smokers. These drafts tried to argue that 

there was ‘‘no difference’’ between light and regular cigarettes of light cigarettes. 

While the final version still took this approach, the smokers’ reluctance to accept 

this argument led to the added statement that if there was any difference, it was 

a meaningless one; (smoking light cigarettes instead of regulars is ‘‘Kind of like 

jumping off a 15-story building instead of a 20-story building’’). This is evidence of 

how successful tobacco marketers have been in convincing smokers that there is a 

health benefit associated with lights; stating that there was no difference in the 

risks associated with smoking lights versus regulars was so contrary to the views 

expressed in the focus groups, we had to ‘‘bend’’ the truth so as to ultimately be 

able to persuade smokers of light cigarettes. 

The tobacco industry has pointed to ostensibly conflicting data, arguing that these 

data demonstrate that smokers don’t believe low tar/light cigarettes are healthier 

and they choose lights for reasons other than health concerns. 

The industry has pointed to ostensibly conflicting data, arguing that these data 

demonstrate that smokers choose lights for reasons other than health concerns; for 

example, a 1975 survey by the U.S. Department of Health, Education & Welfare 

found that 40.6 percent of current smokers believed that all cigarettes are probably 

about equally dangerous.’’ In 1975, the share of market for light cigarettes (below 

15 mg tar) was under 10 percent. As a result, the vast proportion of those defined 

as smokers in this survey would have been smokers of regular cigarettes. It is not 

at all surprising that smokers of regular cigarettes would attempt to justify their 

own smoking choice, thereby reducing the psychological discomfort/dissonance that 

would result from acknowledging that their choice (regulars) might be ‘‘wrong’’ and 

more harmful. 

Further explaining this phenomenon was the fact that when first introduced, 

Light cigarettes were considered relatively tasteless. As acknowledged by the tobacco industry as recently as April 21, 2005 (transcript of Trial Record, United 

States of America, Department of Justice, Plaintiff v. Philip Morris USA et al., Defendants) when low-tar cigarettes were introduced, the tobacco companies recognized 

that their taste was aversive—it was hardly seen as selling point for the light cigarette category. 

It took a long time for low-tar cigarettes to ever really catch on in this country. . . . [The industry believed that] these products will taste different, and 

unless the public health community gives, gives people a reason to smoke them 

[i.e., ‘‘it’s better for your health’’], I don’t think they’re going to be successful; 

(p. 19670). 

As such, they did not represent much of an alternative for smokers of regular 

cigarettes, despite the fact that held out the (false) hope of a ‘‘safer’’ cigarette; (as 

discussed below, this problem was eventually ‘‘fixed’’ with the advent of lights that 

yielded considerably more tar). Without shifting to lights as a way of reducing their 

cognitive dissonance, smokers of regular cigarettes had to take a different path to 

reduce their dissonance; to do so they developed ‘‘protective’’ attitudes. If one can’t 

change one’s behavior and there are clearly negative aspects of that behavior, then 

changing one’s attitudes toward the behavior in question is typically how one attempts to reduce the dissonance (Festinger 1957; Cohen and Kassarjian 1965). 

Given this psychological dynamic, it is not surprising that 40.6 percent responded 

that that ‘‘all cigarettes are about equally dangerous.’’ Unwilling to shift to the 

tasteless lights, yet uncomfortable in the belief that lights were in some way ‘‘better/ 

safer,’’ it is somewhat surprising that the 40.6 percent figure was not still higher. 

Evidently, the ‘‘message’’ of light cigarettes’ supposed health benefits was hard to 

ignore, for many of these regular smokers, notwithstanding the cognitive dissonance 

it generated. 

More recently, a study by Schiffman et al., (2001) sampled over 2,120 smokers in 

a national telephone survey. Of these, 816 were smokers of light cigarettes. Fully 

80 percent of the respondents believed that one had to smoke 2, 3 or more light cigarettes in order to get the same levels of tar delivery as in a regular cigarette. Since 

tar is typically regarded as a health-risk, 4 of 5 consumers conclude that the less 

44 

of it, as in a light cigarette, the safer the cigarette. The evidence I present below 

strongly disputes that mistaken view. 

As part of their extensive advertising and promotion campaign for more than a 

half-century, the tobacco industry have promoted a type of syllogistic reasoning 

that encourages smokers of light/low tar cigarettes to believe they are at less risk. 

For over half a century, smokers have been led to believe that a cigarette that 

tastes ‘‘milder’’ and is ‘‘less irritating’’ must be better for them. As one example, 67 

percent agree that ‘‘lights are smoother on the throat and chest.’’ Since smokers cannot know from simply examining a cigarette whether it is healthier than others or 

not, they need to rely on what they believe is indirect evidence (proxies); smooth 

and mild serve as such proxies. The syllogism goes: if mildness means less throat 

irritation, and less throat irritation means—in some way—a healthier cigarette, 

then mild, light cigarettes must be better for health. 

Similarly, if lights are said to have less tar/nicotine, and if it is understood that 

tar/nicotine have negative health consequences, the smoker is led syllogistically to 

the conclusion that Lights must be better for health; (less of the ‘‘bad stuff’’). The 

senior tobacco executives have engaged in these syllogisms and they believed their 

customers did as well. Consider the following responses by senior tobacco industry 

executives: 

Q. In terms of tar delivery, is there a health benefit between a twelve milligram 

cigarette and an eight milligram cigarette? 

A. My position is that less is better than more. I believe that if a person smokes 

a cigarette and receives 8 milligrams of tar, that is better than smoking a cigarette and receiving 12 milligrams of tar. 

Written Direct testimony of Susan Ivey, CEO of R.J. Reynolds, United States v. Philip Morris, 2005 (82:12–20). 

My understanding is I think, pretty common that . . . low tar is better than 

high tar . . . there have been characteristics associated with tar that are believed to be linked to health issues, and lower tar is better than higher tar. 

Deposition of Ronald Bernstein, CEO of Liggett group, (in United States v. Philip Morris, 2002 (35:4–36:9; emphasis added). 

If something is—is identified as—as being potentially harmful, having less of 

it would seemingly be better. 

Deposition of Ronald Bernstein in United States v. Philip Morris, 2002 (25:19– 

26:5). 

Q. Don’t you think that many people wanted low tar cigarettes because they 

were led to believe that low tar cigarettes were less dangerous to their health 

than high tar cigarettes? 

A. That may be a perception among some smokers . . . less is best in all kinds 

of products, product categories. 

Donald Johnston, former CEO of American Tobacco in Broin v. Philip Morris, 

1994 (62:4–13). 

Importantly, in this type of syllogistic reasoning, where the conclusion is self-generated, consumers effectively persuade themselves and this process generates more 

favorable, stronger, more actionable brand attitudes—attitudes that translate into 

actual purchase decisions. Consumers are more likely to remember the message and 

have greater confidence in the brand attitude they have developed. These brand attitudes are likely to be more resistant to counter-persuasion (Kardes 1999; 

Heimbach and Jacoby 1972; Moore et al., 1986). In sum, this indirect, syllogistic approach, is more persuasive relative to directly putting forth the (false) conclusion 

that ‘‘low tar/nicotine cigarettes are healthier for you.’’ As expressed in a report prepared for Brown and Williamson: ‘‘. . . the [advertising] copy should be ambiguous 

enough to allow the reader to fill-in his/her illogical-logic . . .’’ (Marketing and Research Counselors, Inc. 1975, pp. 12–13). 

Internal tobacco company documents further indicate that while the Barclay brand 

may have done a better job in allowing for smoker ‘‘compensation’’ than its competitors, the others in the industry also developed cigarettes that allowed for compensation; (Kozlowski 2005). 

As internal documents reveal, the tobacco industry recognized that it would be by 

allowing actual tar yields to increase that the cigarettes would come closer to tasting like regular cigarettes, and so gain in popularity. One way in which this was 

done was through ‘‘micro-vents’’ found on the filters of most cigarettes. Research has 

documented that most smokers are not aware of the micro-vents or of their effects. 

The micro-vents are inadvertently (or sometimes intentionally) covered/blocked by 

45 

the fingers/lips of smokers. This blocking has the effect of reducing the ventilation 

and increasing the levels of tar and nicotine the smoker receives. In a national survey, two-thirds (66 percent) of smokers of light cigarettes were either unaware of 

the vents or did not understand that vent blocking increased their exposure to tar. 

A carefully documented example of this type of compensation was the development of the cigarette ‘‘Barclay’’ and the reaction to it ( Kozlowski et al., 2005). In 

the design of the cigarette, not just the manufacturer of Barclay, but competitors 

as well, considered the compensation principle. In the Philip Morris documents cited 

below, the company acknowledged the compensation/tar/flavor link and also indicated that they sought to replicate the process. 

Product smokes differently in smoker’s mouth than in dental dam of smoking 

machine. Smoker’s lips close channels (grooves) between tipping paper and filter 

lowering dilution and resulting in higher tar delivery; Meyer L.F. (1980; Philip 

Morris document). 

This filter design results in some unusual delivery characteristics when smoked 

by a human that do not occur during machine smoking. . . . The dilution decrease to the [human] smoker results in substantially higher tar delivery than 

would be the case of a conventionally diluted all CA [cellulose acetate] filter 

. . . Subjective impressions by flavor development have corroborated the higher 

tar estimates . . . filter process development to either duplicate or simulate the 

Barclay effect is in progress. Houck W.G. (1980; Philip Morris Document; emphasis added). 

The tobacco industry sought to take advantage of the multiple ways in which 

smokers’ compensation alters the real tar yields for smokers as compared to machinegenerated tar yields. 

Consider the following statements in internal corporate documents from R.J. Reynolds, Lorillard and Philip Morris: 

. . . [S]ome people change their smoking habits and attempt to compensate for 

lower ‘tar’ and nicotine deliveries, for example, by taking larger puffs, more 

puffs, or smoking more cigarettes; R.J. Reynolds 1978. 

. . .[S]mokers tend to deviate more from the standard (of the FTC machine 

test] . . . with highly ventilated, low [tar/nicotine] yield brands. These kind of 

cigarettes generally . . . make it easy to expend some extra puffing effort; 

Lorillard 1981. 

The smoker data collected in this study are in agreement with results found in 

other project studies. The panelists smoked the cigarettes according to physical 

properties; i.e., the dilution and the lower RTD of Marlboro Lights caused the 

smokers to take larger puffs on that cigarette than on Marlboro 85’s. The larger 

puffs, in turn, increased the delivery of Marlboro Lights proportionally. In effect, the Marlboro 85 smokers in this study did not achieve any reduction in 

smoke intake by smoking a cigarette (Marlboro Lights) normally considered low 

in delivery; (Philip Morris 1975). 

Promoting light cigarettes as extensions of major brands and aligning them with 

the mother brand (e.g., Marlboros, Marlboro Lights), helped shaped smokers’ perceptions of their taste. 

At the same time as they developed light cigarettes that allowed for compensation, the tobacco companies learned how to boost the perceived strength of the taste, 

by using their advertising to shape the images associated with Lights. The companies viewed the taste dimension much as a ‘‘Rorschach ink blot test.’’ Light cigarette 

smokers could be induced to see/taste in the cigarettes what the companies wanted 

them to see/taste. 

. . . [I]t is almost impossible to know if the taste smokers talk about is something which they, themselves attribute to a cigarette or just a ‘‘play-back’’ of 

some advertising messages;’’ (Marketing and Research Counselors, Inc, 1975, p. 

2). 

The industry further understood that they could ‘‘borrow’’ some of the brand equity established for their primary (regular) brands such as Marlboro Reds ad Camels for the benefit of the light cigarettes. They did so by creating brand extensions— 

Marlboro Lights, Camel Lights etc. and using the same advertising themes and imagery that had been so successful to shape the imagery associated with the light 

extensions. That this strategy could affect smokers perceptions of the light cigarettes taste, is recognized in their internal documents. 

46 

. . . [O]ther free standing low tar brands such as Kent, Vantage, Carlton, etc. 

were perceived to be weaker and have less taste than the line extension low 

tars: like Marlboro Lights, Winston Lights, Camel Lights. Apparently these line 

extension low tars share the taste heritage of their parent full flavor brands; 

(Philip Morris 1990, pp. 13–14; emphasis added). 

When R.J. Reynolds sought to develop a low yield cigarette in 1976, they recognized the image problem associated with low-yield cigarettes and set out to address 

it: 

What we want is to portray the feeling and image projected by Marlboro and 

Kool advertising on a Vantage/Merit type of cigarette. In other words, put 

‘‘balls’’ (two of them) on a low ‘‘tar’’ and nicotine cigarette and position; Hind 

et al., 1976, p. 63. 

The tobacco industry has acknowledged that the taste of regular cigarettes hardly 

serves as a positive benchmark. 

One needs to question whether the ‘‘standard’’ for taste set by regular cigarettes 

is such that the taste of regular cigarettes is a positive feature? Are regular cigarettes inherently ‘‘tasty?’’ Internal documents indicate that the tobacco companies 

believed that the initial taste for (typically underage) starter smokers was aversive 

and sought to take measures to compensate for this. As early as 1959, a Philip Morris document focused on ‘‘mildness’’ as a strategy for attracting young starters: ‘‘we 

also should win more young non-smokers with mildness;’’ (memo from W.H. Danker 

to R. N. DuPuis May 28, 1959). With nearly nine in ten smokers starting before age 

18 and more than half of these smoking regularly by 18 (Lynch and Bonnie 1994; 

USDHHS 1994), it is clear that ‘‘young non-smokers’’ was referring to those under 

18. 

In 1974, R.J. Reynolds considered flavored cigarettes as a way of masking the tobacco taste. A meeting at the R.J. Reynolds offices resulted in a memo titled ‘‘New 

Products.’’ Under the authorship of J. Donati of Taitham-Laird & Rudner, an R.J. 

Reynolds advertising agency, the memo served to define a ‘‘Cigarette Designed for 

Beginning Smokers.’’ 

This cigarette would be low in irritation and possibly contain an added flavor 

to make it easier for those who have never smoked to acquire the taste for it more 

quickly; (J. Donati (1974; emphasis added)). 

After considering flavors including ‘‘citrus, apple, grape, herbs and spices, cola, 

coffee, chocolate and hickory’’ the options for further work were narrowed to cola, 

coffee and chocolate. Today R.J. Reynolds markets flavors like ‘‘Mocha Taboo’’ and 

‘‘Midnight Berry’’ through its ‘‘Kool’’ brand. This strategy would suggest that the 

company believes that the taste of tobacco is best when masked. 

The tobacco industry has advanced the ‘‘taste’’ of low tar/lights cigarettes as the 

primary reason they are chosen by smokers. When questioned about the role of this 

false and illusory dimension of low tar/light smokers’ responses are often misleading. 

When smokers are asked why they smoke light cigarettes, significant numbers 

may respond that it is because of the ‘‘taste.’’ This is understandable—they first experience the cigarette on their tongue and in their mouth—the most apparent locus 

of taste. But research tells us that ‘‘taste’’ is a good deal more than what we experience on our tongue. Twenty years ago, the Coca Cola company was concerned about 

losing market share among young cola drinkers to Pepsi Cola. Research suggested 

that younger consumers appeared to prefer the slightly sweeter taste of Pepsi. In 

response, Coca Cola developed a sweeter version of their product and proceeded to 

extensively test market it in blind taste tests across the country. Repeatedly and 

reliably in blind taste tests, consumers indicated that they preferred the sweeter 

version to the regular Coke. With that evidence in hand, Coke introduced ‘‘New 

Coke’’ with the new, sweeter formula. What happened next was shocking to Coke. 

Once the product they were drinking was labeled Coke, that knowledge impacted 

how they evaluated what they tasted—now they hated it. Within 3 months Coke 

had retreated and was pushing its original formula ‘‘Classic’’ Coke again (Fournier 

1999; rev. 2001). 

That taste is, at least in part, a function of how products are portrayed/labeled 

and advertised has been carefully researched in the context of ‘‘field’’ experiments 

with foods. In one such experiment, the same lunch meals were sold in a university 

faculty cafeteria but were labeled differently on different days. For example, on 

some days one such meal was identified as ‘‘Succulent Italian Seafood filet’’ but on 

other days merely as ‘‘Seafood Filet.’’ Those who bought and ate the foods when they 

were described in an embellished way reported that: the foods were more appealing 

47 

to the eye; they tasted significantly better; and after eating the meal they food felt 

more ‘‘comfortably full and satisfied;’’ (Wansink et al., 2004). 

Interestingly, when desserts were labeled ‘‘healthy’’ (e.g., ‘‘chocolate pudding vs. 

‘‘healthy chocolate pudding; apple crisp vs. healthy apple crisp). they were rated as 

tastier. The researchers reasoned, that as long as the dessert actually tasted good, 

consumers’ initially lower expectations regarding something labeled ‘‘healthy’’ would 

be disconfirmed; that is, they would have been surprised by the good taste. Pleasantly surprised, the unexpected contrast between their actual and expected experience would have led them to evaluate the taste of the dessert more positively than 

someone who had seen the dessert label without the adjective ‘‘healthy;’’ (Wansink 

et al., 2004b). 

Smokers of regular cigarettes who switched to what they perceived to be 

‘‘healthier,’’ light cigarettes, would have had a parallel disconfirming experience. 

These smokers would have expected light cigarettes to yield less taste (along with 

less tar). However, given the compensatory smoking behavior described above, light 

cigarettes yielded just as much tar/taste. As a result, the pleasantly surprised light 

cigarette smokers were quick to focus on the taste as the apparent motivation for 

smoking lights. 

As with the food experiments cited above, if questioned, smokers are almost certainly not going to be aware of how the label ‘‘light’’ (and hence the inference 

‘‘healthier’’) influence their perceptions of the cigarette’s taste. They revert to the 

more proximal evidence—what they believe they experience—on their tongues—and 

their answer as to why they smoke the cigarette they do smoke may reflect that 

logic. 

In two court cases where both Philip Morris and R.J. Reynolds sued Loews/ 

Lorillard, it was evident that these tobacco companies do not believe that smokers are primarily guided by taste in selecting light cigarettes. 

The plaintiff firms, Philip Morris and R.J. Reynolds argued that in a comparative 

taste test, smokers reported that the Lorillard low tar brand tasted better than the 

comparison brand only if they were first told that Lorillard’s brand had lower tar 

than either the R.J. Reynolds or the Philip Morris comparison brand. When (other) 

smokers made the same comparative taste test without being reminded of the relative tar levels, their taste preferences were very different. 

The basis of both suits was the approach taken in two parallel Lorillard surveys 

asking smokers to compare the taste of its low tar ‘‘Triumph’’ to R.J. Reynolds’ Winston Lights and to Philip Morris’ Merit. Subsequent Lorillard advertising claimed 

that the preponderance of the smokers tested appeared to prefer the taste of Triumph over Winston Lights and that it was the ‘‘National Taste Test Winner’’ over 

Merit. Both plaintiffs Philip Morris and R.J. Reynolds argued that these claims 

were deceptive inasmuch as the taste question posed in each survey had, as a preface, a reminder of the lower tar scores for Triumph relative to those for Winston 

Light and for Merit. Each of the plaintiff companies ran a test of their own, where 

the tar scores for the two brands were not revealed and the resulting taste preferences in their research were very different. 

These comparisons suggest how much of what is ostensibly labeled as ‘‘taste’’ is 

influenced by other factors; in this case, the salience of how ‘‘light’’/low tar a cigarette might be. In effect, the plaintiff firms acknowledge that where smokers are reminded of tar yields, the relative tar levels and not taste are the determining factors 

in the smokers’ evaluations of the cigarettes; (R.J. Reynolds Tobacco Company, 

Plaintiff, v. Loew’s Theatres, Inc; No. 80 Civ 4197 (RWS) United States District 

Court for the Southern District of New York; 511 F. Supp. 867; 1980 U.S. Dist. 

LEXIS 16738; 210 U.S.P.Q. (BNA) 291; October 24, 1980; Philip Morris Incorporated, Plaintiff, v. Loew’s Theatres, Inc., No. 80 Civ. 4082 (RWS) United States 

District Court for the Southern District of New York; 511 F. Supp. 855; 1980 U.S. 

Dist. LEXIS 12554 July 26, 1980). 

Of course, for decades the tobacco companies have used low tar/lightness as a critical way of selling cigarettes and have made that dimension very salient for smokers. Following the logic presented above, it is reasonable to expect that when respondents are asked, they may say that ‘‘taste’’ is the reason they prefer light/low 

tar cigarettes. Note, however, that following the logic of the two court cases discussed above, the causal sequence is, in fact, reversed. In actuality, it is because 

their cigarettes are light (and advertising and promotion continue to make that dimension salient) that smokers say they prefer the taste. They would not say so for 

the same cigarette, if its ‘‘lightness’’ was not made salient. 

48 

The tobacco industry has misleadingly used lighter colors (whites and pastels) on the 

cigarette packages and in their advertising to persuade smokers that low tar/ 

light cigarettes were purer and healthier. 

Because consumers often cannot directly judge the merits of a product claim, they 

develop heuristics or ‘‘rules of thumb’’ which involve relying on ‘‘proxies’’ for the real 

evidence they are seeking. For example, consider how difficult it is to judge how 

‘‘fresh’’ fish in a supermarket is. Supermarket executives have come to realize that 

for some consumers, fish sitting on a styrofoam tray represents a proxy conveying 

‘‘not fresh,’’ while fish sitting on ice represents a proxy conveying ‘‘fresh.’’ 

It is for the same reason that the tobacco industry has signaled the lighter, milder 

and ostensibly purer and safer features of light cigarettes, by using lighter colors 

in their advertising and on their packaging. Tobacco firms have been consistent and 

strategic in developing this tactic. Consider the following statements (as cited in the 

National Cancer Institute’s Monograph 13, p. 217) by Philip Morris and the British 

American Tobacco Co. respectively: 

. . . [W]hen Marlboro Lights was first introduced in 1971 . . . the advertising 

was dramatically different . . . first using water color executions, then big pack 

sots, a lot of white space and a small cowboy visual. (Philip Morris 1990, p. 6). 

Light-lighter-lightest were achieved by insistance [sic] on lighter presentationsproduct story imagery—white packs—pale colours—mildness dominated copy. 

(British American Tobacco Company, circa 1985, p. 13). 

A number of other examples of this strategy are cited in Chapter 7 of Monograph 

13, including the Philip Morris, Parliament campaign where models were consistently dressed in all white and placed in all white environments (National Cancer 

Instititute; Monograph 13, p. 218). As Koten (1980; cited in Monograph 13 on p. 

218) concludes: 

Red packs connote strong flavor, green packs connote coolness or menthol and 

white packs suggest that a cigarette [sic] is low-tar. White means sanitary and 

safe. And if you put a low-tar cigarette [sic] in a red package, people say it 

tastes stronger than the same cigarette [sic] packaged in white. (Koten, 1980, 

p. 22). 

More broadly, to ask people to provide reasons for their behavior; i.e., why they 

do what they do is to ask them to play the role of social scientist in explaining their 

behavior; research has shown that is a very risky endeavor. People develop ‘‘theories’’ as to why they behave as they do and use both these theories and the most 

proximal evidence in support of these theories, to explain their behavior. Sometimes 

these theories and evidence are accurate, but very often they are not. One reason 

they are often incorrect is that people tend to use evidence that is proximal and are 

less alert/sensitive to more subtle, complex and distal causes of their behavior 

(Nisbett and Ross 1980). Thus when asked about the taste of the dessert, those in 

the cafeteria focus on their taste buds and are not likely to be sensitive to the influence of the ‘‘healthy’’ label placed on the dessert on the cafeteria line and on the 

resulting effect of their positive reaction. When asked about why they smoke light 

cigarettes, smokers focus on the proximate evidence—their taste buds; they are 

much less aware of how the label ‘‘light’’ subtly influences their attitudes and behaviors, as well as their compensatory smoking behavior (as described above). 

Still today, the industry is not forthcoming about the risks of smoking light cigarettes. 

It is only recently that R.J. Reynolds has come to curtly acknowledge that ‘‘Smoking causes serious disease’’ (R.J. Reynolds website; accessed Aug. 26, 2007). However, the website goes on to provide the (would be) smoker with considerable ‘‘wiggle 

room’’ to justify (continued) smoking: 

An individual’s level of risk for serious disease is significantly affected by the 

type of tobacco product used as well as the manner and ‘‘frequency of use;’’ (R.J. 

Reynolds website; accessed August 26, 2007). 

In effect, smokers are still encouraged to search for a safer ‘‘type of tobacco product’’—most typically a ‘‘light’’ one. Alternatively, they are encouraged to alter their 

‘‘manner of . . . use.’’ The latter suggestion runs directly contrary (as discussed 

below) to the widely accepted ‘‘compensation’’ smoking behavior which smokers of 

light cigarettes use. 

The Philip Morris website is more expansive in ostensibly accepting the public 

health position regarding the risks of smoking any cigarette: 

49 

Philip Morris USA agrees with the overwhelming medical and scientific consensus that cigarette smoking causes lung cancer, heart disease, emphysema 

and other serious diseases in smokers. Smokers are far more likely to develop 

serious diseases, like lung cancer, than non-smokers. There is no safe cigarette. . . . Philip Morris USA agrees with the overwhelming medical and scientific consensus that cigarette smoking is addictive. It can be very difficult to 

quit smoking, but this should not deter smokers who want to quit from trying 

to do so; (emphasis added) Philip Morris website, accessed August 26, 2007). 

To reduce the health effects of smoking, the best thing to do is to quit; public 

health authorities do not endorse either smoking fewer cigarettes or switching 

to lower tar and nicotine brands as a satisfactory way of reducing risk. (Philip 

Morris USA website, accessed August 26, 2007). 

While Philip Morris gives voice to the public health community’s view that lower 

tar and nicotine (light) brands do not reduce the risk of smoking, the company is 

careful not to endorse that view. Further, as has been noted (Kozlowski 2005), to 

say there is ‘‘no safe cigarette’’ still allows the smoker to take false comfort in the 

mistaken belief that light cigarettes may be ‘‘safer.’’ 

References 

Assael, Henry (2004), Consumer Behavior; a Strategic Approach Boston MA: 

Houghton Mifflin Company; pp. 466–468. 

Burrows, Diane. S. (1984), ‘‘Strategic Research Report’’ R.J. Reynolds Document, 

(Feb. 29). 

Cohen, Joel and Harold Kassarjian (1965), ‘‘Cognitive Dissonance and Consumer 

Behavior,’’ California Management Review (Fall) 55–64. 

Donati, John, (1974), New Products. (June 5), Taitham-Laird & Kudner. 

Federal Trade Commission. 2000. Federal Trade Commission. Available at http:// 

www.ftc.gov/ (accessed July 7, 2004). Federal Trade Commission. 2004. Federal 

Trade Commission. Available at http://www.ftc.gov/ (accessed July 8, 2004). 

Federal Trade Commission (2007) Federal Trade Commission Cigarette Report for 

2004 and 2005. URL: http://search.ftc.gov/query.html?qt=cigarette+report+2004+ 

2005&col=hsr&col=news&col=fulll access date: June 11, 2007. 

Festinger, Leon (1957), A Theory of Cognitive Dissonance, New York: Harper & 

Row. 

Fournier, Susan (1999; Revised 2001), ‘‘Introducing New Coke,’’ Case: 9–500–067; 

Harvard Business School Publishing Boston MA. 

Heimbach, James T. and Jacob, Jacoby (1972), ‘‘The Zeigarnik Effect in Advertising,’’ Proceedings of the Third Annual Conference of the Association of Consumer 

Research, 746–758. 

Houck, W.G. (1980) Status of Barclay studies, (Philip Morris Document; September 29); Bates No. 1000785893. http://legacy.library.ucsf.edu/tid/ivu54e00. 

Kardes, Frank (1998) Consumer Behavior: Managerial Decision Making. Addison 

Wesley. 

Kozlowski, L.T., et al., (2005) An Extremely Compensatable Cigarette by Design: 

Documentary Evidence on Industry Awareness and Reactions to the Barclay Filter 

Design Cheating the Tar Testing System.’’ Tobacco Control, 14(64–70). 

————, B.Q. Edwards (2005) ‘‘Not Safe’’ is not Enough: Smokers Have a Right 

to Know More than There is No Safe Tobacco Product,’’ Tobacco Control, 14(suppl. 

II):ii3–ii7. 

————, M. Goldberg, B.A. Yost, F.M. Ahern, K.R. Aronson, C.T. Sweeney (1996), 

‘‘Smokers are unaware of the Filter Vents Now on Most Cigarettes: Results of a National Survey,’’ Tobacco Control, 5:265–270. 

Lorillard (1981), ‘‘Estimation of the Amount of smoke Obtained by Human Smokers from Different Cigarette Brands,’’ Memo from V. Norman to Dr. F.J. Shultz, 

(Aug. 31). 

Meyer L.F. (1980), Report on the Barclay Cigarette. (Sept. 15; Philip Morris document); Bates no. 2028681570/1578, http://legacy library.ucsf.edu/tid/kyo25e00. 

Moore, David J., Richard Beardon and Francis Durso (1986), ‘‘The Generation Effect in Advertising Appeals,’’ Advances in Consumer Research, (13), 117–120. 

Nisbett, Richard and Lee Ross (1980), ‘‘Human Inference: Strategies and Shortcomings of Social Judgment,’’ Chapter 9: ‘‘The Lay Scientist Self Examined,’’ 

Prentice-Hall: Englewood Cliffs, NJ. 

Philip Morris (1959) Roper Attitude Study of January 1959, Memo from W.H. 

Danker to Dr. R.N. DuPuis, (May 28, 1959). 

Philip Morris (1975), ‘‘Marlboro-Marlboro Lights Study Delivery Data,’’ Memo 

from B. Goodman to L.F. Meyer, (Sept. 17). 

50 

R.J. Reynolds (1978), ‘‘ ‘Tar’/Nicotine Control and Smoking Satisfaction,’’ Report 

authored by Donald H. Piehl, (May 9). 

Shiffman, Saul, J.L. Pilliteri, S.L. Burton, J.M. Rohay, and J.G. Gitchell (2001), 

‘‘Smokers Beliefs about ‘Light’ and ‘Ultra Light’ cigarettes,’’ Tobacco Control, 

(10)(Suppl. 1):i17–i23. 

Wansink, Brian K., Van Ittersum and J.E. Painter (2004), ‘‘How Descriptive Food 

Names Bias Sensory Perceptions in Restaurants,’’ Food Quality and Preference, in 

press, pp. 1–7. 

Wansink, Brian K., Van Ittersum and J.E. Painter (2004b), ‘‘How Diet and Health 

Labels Influence Taste and Satiation,’’ Journal of Food Science, 69 (9) s340–s346. 

Senator LAUTENBERG. Thank you very much. 

Dr. Goldberg, your testimony reflects what I think is the most 

obvious, and I asked in a couple of earlier questions, and I thank 

you. 

Mr. Sheller? 

STATEMENT OF STEPHEN A. SHELLER, ESQ., FOUNDER 

AND MANAGING PARTNER, SHELLER, P.C. 

Mr. SHELLER. Yes. Thank you, Senator Lautenberg. 

And I’m sort of sad and angry at the FTC; I’ll be frank with you. 

You know, I’ve practiced law for more than 40 years, and I’m here 

to tell you about the effects of the FTC’s failure to do its job. And 

I want to just bring to your attention two Federal judges who have 

reviewed this. 

One Federal judge once phrased it this way, ‘‘The tobacco industry may be the king of concealment and disinformation.’’ 

And Judge Kessler, in—Gladys Kessler—in U.S. v. Philip Morris, 

declared the Philip Morris companies to be racketeers. Racketeers. 

That’s a quote. She said, ‘‘Even as they engaged in a campaign to 

market and promote filtered and low-tar cigarettes as less harmful 

than conventional ones, defendants either lacked evidence to substantiate their claims or knew them to be false.’’ She goes on to 

say, ‘‘There is an overwhelming consensus in the public health and 

scientific community, both here and abroad, that low-tar cigarettes 

offer no health benefit to smokers, have not reduced the risk of 

lung cancer and heart disease, and, for smokers using them, have 

not produced any decrease in the incidence of lung cancer. Moreover, because of the misleading nature of the advertising for lowtar cigarettes, smokers who might have quit have refrained from 

doing so, in the belief that such cigarettes reduce their health risk.’’ 

She didn’t just make that up, she heard the evidence for months; 

for months. 

Now, what has happened in litigation? You know, I’ve been practicing law for some 40 years now. And, Senator Lautenberg, you recall, back in early 1998, your aide, Dan Katz, tried to do something 

about this. And I sent you the evidence I had personally collected 

from the depositions I had done that established, even within the 

company, they believed it to be a fraud; even within the companies. 

Now, what has happened today? I’ll tell you what’s happened 

today. We have 40 lawsuits that have been filed involving the lightcigarette scam in class actions in 22 different states. There are certified—meaning they’re grouped together—class actions pending in 

Massachusetts, Missouri, and New York. However, the industry 

has used the FTC’s—and I’ll call it ‘‘clear misconduct’’—they are 

like—either it’s intentional or they are like—what’s that famous 

51 

1 Haines v. Liggett Group, Inc., 140 F.R.D. 681 (D.N.J. 1992). The judge was H. Lee Sarokin. 

children’s nursery rhyme? I think it was called—I forget her name 

now—Rip Van Winkle. Rip Van Winkle. In fact, I would have 

hoped that the Director of the FTC would have been the one to testify, because I was going to call her Mrs. Rip Van Winkle. They 

have had the audacity to come before you today and told you they 

knew about this for years, but they don’t want to do anything 

about it. The reason they don’t want to do anything about it, I’ll 

tell you, because the tobacco industry is using this vehicle of their 

laziness and incompetence, on the level of a Katrina or worse, government incompetence, to give them a defense. They go into court 

and say, ‘‘Well, the FTC has been regulating us for years.’’ In fact, 

there was an even an FTC witness—his name escapes me for the 

moment, but I think it was Peter—Dr. Peterman—John 

Peterman—worked for the FTC from 1976 to 1993. He came in to 

court rooms—and I was involved, as you know, in the Illinois $10 

billion verdict. Again, a judge found them guilty of all kinds of terrible things. That got reversed by the Supreme Court of Illinois, 

based on the FTC’s supposed regulation of the industry. 

Now, they come here today with the purpose of telling you, 

‘‘We’re going to do something someday, but we want to see what 

else is better.’’ The time—the buck has stopped. You must issue a— 

legislation—because they won’t do anything—you must immediately legislate a ban on tar and nicotine levels being monitored, 

period. They’re—the tobacco industry, by the way, has machines 

which are called ‘‘human mimic smoking machines.’’ They know 

what the real numbers could be. But I add something to you today. 

All tar is not equal. There are different tars coming out of those 

cigarettes; depends on the burn level. I know the chemistry quite 

well, I’ve learned it over the years. The other element of it is—that 

is very, very important—is, they have gone into court and used 

these guys as their defense. It’s a disgrace. It shouldn’t be accepted. 

So, I ask you to move quickly and listen to what two judges— 

Federal judges—have already said. One called them the worst example—the king of disinformation. Another called them racketeers. 

What else do you need? And the FTC sits there? I think it’s time 

that you really began to take action. 

Thank you. 

[The prepared statement of Mr. Sheller follows:] 

PREPARED STATEMENT OF STEPHEN A. SHELLER, ESQ., FOUNDER

AND MANAGING PARTNER, SHELLER, P.C. 

Good afternoon. I have practiced law for more than 40 years. In that time, I have 

initiated many lawsuits involving medical malpractice, toxic torts, medical device 

and drug product and complex catastrophic personal injuries. For the past 13 years, 

I have also dedicated a substantial portion of my practice to litigation involving the 

cigarette companies. While, as one Federal judge once phrased it, ‘‘the tobacco industry may be the king of concealment and disinformation,’’ 1 the so-called light cigarette fraud is the most shameless example of outright fraud by this industry I have 

yet to encounter. 

I have researched industry practices around light cigarettes and have worked 

with a number of attorneys around the country to file consumer fraud class actions 

against the cigarette manufacturers that seek compensation for customers who 

bought these cigarettes that were sold and marketed as ‘‘light,’’ but were, in fact, 

not really lower in tar or nicotine and certainly were not any less hazardous than 

so-called ‘‘full flavor’’ brands. This is accomplished by designing the cigarette to creVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00055 Fmt 6633 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
52 

2 Nat’l Cancer Inst., Risks Associated with Smoking Cigarettes with Low Machine-Measured 

Yields of Tar and Nicotine, SMOKING AND TOBACCO CONTROL MONOGRAPH 13, NAT’L INST. OF

HEALTH (Donald Shopland, David Burns, et al., eds., 2001). 3See NCI’s ‘‘Questions and Answers on Monograph 13’’ at Question 7, viewed at http:// 

www.cancer.gov/newscenter/monograph13-QA/print?page=&keyword=. 4 U.S.C. sec. 1442(a)(1). 

5Watson, et al., v. Philip Morris Companies, Inc., 551 U.S.llThe (2007). 

ate misleading readings on puff machines using a technique for measuring tar and 

nicotine known as the FTC Method. 

The principal allegation in light cigarette lawsuits is that cigarette manufacturers 

have misled consumers by marketing light and low tar cigarettes as having less tar 

and nicotine than other brands, even though the actual exposure levels are no different. Those who smoked (and continue to smoke) light cigarettes, reasonably believing they were being exposed to less tar or nicotine, are seeking court-ordered 

damages for their losses. I believe that there have been about 40 lawsuits filed in 

22 different states on the light cigarette issue. Certified class actions are pending 

in Massachusetts, Missouri, and New York at this time. 

In fact, there is good reason to believe so called, ‘‘light, smooth, mild’’ cigarettes 

are potentially more dangerous to ones health than ‘‘full flavor’’ cigarettes. 

An important key to uncovering the light cigarette fraud was Monograph 13 released by the National Cancer Institute in 2001.2 That monograph concludes that 

‘‘cigarette manufacturers recognized the inherent deception of advertising that offered cigarettes as light [and] . . . as having the lowest tar and nicotine yields . . .’’ 

but went ahead anyway with that advertising. Shortly after the release of the monograph, it was announced that the FTC asked for guidance from DHHS to determine 

whether the FTC testing method could be improved and a working group was to 

convene in 2002, but I am unaware of any outcomes from this request for guidance.3

The FTC appears to have gone to sleep as Rip Van Winkle did in the famous children’s story and clearly needs Congress to wake them up. 

What has been happening in these lawsuits is that the cigarette companies have 

been using the lack of clarity around regulation of testing accuracy and the regulatory role of the FTC in two distinct and important ways: 

1. The cigarette companies claim that the use of the terms ‘‘light’’ and ‘‘lowered 

tar and nicotine’’ are regulated by the FTC and, therefore, state consumer protection laws’ exemption for federally regulated products defeats our state law 

claims of fraud. In the only light cigarette class action to go to trial, a verdict 

against Philip Morris for around $10 billion dollars was reversed by the Illinois 

Supreme Court in a 4–3 decision. 

That Court relied largely on a 1971 Consent Order with American Tobacco 

Company over the marketing campaign for the Pall Mall Gold 100’s and Lucky 

Filters that required American tobacco to print tar and nicotine comparisons 

with other brands for advertising that claimed these 2 brands of cigarettes were 

low, lower, or reduced in tar than other brands. This one consent order dealing 

with one company’s ad campaign hardly constitutes FTC adoption of a trade 

regulation or even a regulatory approach to the use of the terms ‘‘light’’ and 

‘‘lowered tar and nicotine’’ which are at the heart of the light cigarette fraud. 

Nonetheless, this argument is being raised repeatedly by cigarette industry defendants in ongoing litigation. 

2. The cigarette companies have, until this summer, removed light cigarette 

class action lawsuits from state to Federal courts under the ruse that the companies are acting as agents under a Federal officer and are, therefore, entitled 

to a Federal court venue under the Federal Officer Removal Statute.4 This argument, while absurd on its face, was successful in several cases and created 

expense, delay, and, most importantly, the assumption that the companies were 

simply following the regulatory requirements set down by the FTC around their 

products and should be immune to any claims of fraud. Ultimately, this argument was defeated by the U.S. Supreme Court on June 11 of this year in a 

unanimous decision 5 that echoed the conclusion of the Solicitor General that 

the FTC has not asserted control over the marketing of light cigarettes. 

Court Remedies 

The courts in many jurisdictions either refuse to certify a class, or reverse the certification of a class in the appellate courts, thereby sanctifying the tobacco industry’s 

misconduct and allowing them to continue this misconduct as we sit here. A solution 

is to consider legislation requiring that these cases be handled and certified as class 

actions, to encourage attorneys to take on what would ordinarily be a lawsuit on 

53 

6 United States v. Philip Morris USA, Inc., 449 F. Supp. 2d 1 (D.D.C. 2006) at 430. 

behalf of one individual with a very small damage claim. The tobacco industry 

knows that if a lawsuit cannot go forward as a class this will be the death knell 

of consumer claims. In addition, any money not claimed by consumers that is paid 

as part of a class action award by the tobacco industry, should be contributed to 

a cy pres fund. 

This enormous fraud on the American people must stop. Federal legislation is 

needed to protect consumers from the cigarette industry’s practices with their ‘‘light’’ 

brands and defrauded consumers should have the right to be compensated for their 

loss. I think that U.S. District Judge Gladys Kessler got it right when she ruled 

last year that the cigarette companies were racketeers in U.S. v. Philip Morris. 

About the light cigarette fraud, she said: 

‘‘Even as they engaged in a campaign to market and promote filtered and low 

tar cigarettes as less harmful than conventional ones, Defendants either lacked 

evidence to substantiate their claims or knew them to be false’’.6

She goes on to say: 

‘‘There is an overwhelming consensus in the public health and scientific community, both here and abroad, that low tar cigarettes offer no health benefit to 

smokers, have not reduced the risk of lung cancer and heart disease for smokers 

using them, and have not produced any decrease in the incidence of lung cancer. Moreover, because of the misleading nature of the advertising for low tar 

cigarettes, smokers who might have quit have refrained from doing so in the 

belief that such cigarettes reduced their health risks’’. 

Thank you for taking up this important issue. 

Senator LAUTENBERG. Thank you very much. The—I admire the 

candor that shows up here. And I don’t want to show any bias; 

that’s not Senator-like. 

[Laughter.] 

Senator LAUTENBERG. But I also don’t like the fact that somehow 

or other, over 400,000 people a year die of smoking-related disease. 

And so, when I think about the anguish and the grief that occurs 

and the impact on people’s ability to function as they live, as a result of having had a career in smoking, I’ll call it, and then the cost 

for their unhealthiness is distributed among the population and 

runs close to $89 billion a year for that. It’s a terrible thing to witness. 

Dr. Samet, I think you said that switching to light/low-tar cigarettes doesn’t cause fewer—well, let me not put words in your 

mouth. Does switching to light and low-tar cigarettes actually 

cause fewer people to quit smoking? 

Dr. SAMET. So, the concern is, the—does the availability of products that are perceived as carrying a lower risk lead to switching? 

And I think that has been demonstrated to be the case for some 

proportion of smokers. The concern is that people might move to 

a lower-yield product instead of doing what they should do, which 

is to quit. And there is some evidence to suggest that that can be 

the case. 

Senator LAUTENBERG. I think I noted, in some information, that 

people who had actually quit smoking for some time had come back 

to smoking, based on the attraction that low-tar offered, at least in 

advertising. Do we have any information, any of you, of that happening? 

Dr. HENNINGFIELD. People are constantly coming back to smoking, for a lot of reasons. The information that we do have is that, 

when there are surveys, such as national telephone-based surveys, 

54 

asking people what would attract them to smoking or coming back 

to smoking, what is attractive to people are cigarettes that appear 

to be safer. And this has been very scary, from a public health perspective, because when someone has quit, they’re on the road to 

health, and it’s terrible, the idea that they might be lured back to 

smoking, thinking that the products are substantially safer or flatout safe. 

Senator LAUTENBERG. Remind us, how long have the tobacco 

companies been aware of the smoker compensation, the period of 

time when smokers take longer, deeper puffs to compensate for 

lower amounts of nicotine? 

Dr. HENNINGFIELD. A number of us have looked at the documents. I testified in the Department of Justice trial. And, since at 

least the 1970s, if not decades before, the companies understood 

that these cigarettes delivered more than advertised. 

Mr. SHELLER. It’s—— 

Senator LAUTENBERG. Mr. Sheller, do you have—— 

Mr. SHELLER. Yes. Actually, it was before the consent decree in 

1970 that they were so happy to—no decree—voluntary agreement 

to use this deceitful trick. They were well aware of it, and they just 

decided, ‘‘Oh, it would be great,’’ as it’s now another way that 

they’ve avoided responsibility. 

But you have the documents, actually, which were given in 

1986—as the discovery we did. We—you know, they knew all about 

it. It’s in evidence. And time has—as I said, it’s no longer the FTC’s 

turn. They’ve fumbled the ball. You know, your committee has to 

have oversight of them. They had the audacity to come in here 

today and tell you, ‘‘We’ve—we may do something soon, when we 

get—we’re not expert in it, we don’t know what we’re doing. We 

need help from this one and that one.’’ That’s been their story for 

years. Put an end to it, please. 

Senator LAUTENBERG. In earlier testimony regarding smoking 

and its cost, we found out that the awareness of the tobacco companies about the lethality of the product they were selling and the addiction went back to the—I believe it was the middle 1930s when 

that information first was made available. 

Mr. SHELLER. Yes. 

Senator LAUTENBERG. And, Dr. Henningfield, when switching to 

light cigarettes, are those smokers conscious of the fact that they’re 

breathing deeper, that they’re working harder to fulfill the need 

they feel to get the nicotine in their systems? 

Dr. HENNINGFIELD. Actually, to the contrary, a lot of people believe that they are actually inhaling something less toxic, because 

it is smoother and cooler. In other words, the cigarette, which may 

be as deadly or more deadly, actually feels smoother and cooler by 

using chemicals like menthol, by using ventilation to cool the 

smoke. It’s like putting a lot of alcohol in a fruit beverage. And so 

people are deceived in many different ways; and then, with the 

marketing, of course. 

Mr. SHELLER. Yes, I’ve called it strawberry syrup on strychnine. 

Poison. 

Senator LAUTENBERG. It sounds mild, in your description. 

55 

Dr. GOLDBERG. We actually have data that two-thirds of smokers 

either don’t know about the microvents or don’t know that they 

contribute to the amount of tar that they get. 

Senator LAUTENBERG. Why are cigarettes allowed to use the 

word ‘‘light’’ without having any light benefit? Isn’t that simply deceiving consumers while the government looks the other way, Dr. 

Henningfield? 

Dr. HENNINGFIELD. Well, I think it reflects the problem—I think 

that cigarette regulation by the Federal Trade Commission is not 

their area of competence. I do not believe that the problem was intentional. But this sort of regulation is bread and butter to agencies, like the Food and Drug Administration, which set standards 

for light products. And if you look at the food rule from the early 

1990s, you see specific criteria for use of the term ‘‘light.’’ You see 

them saying, ‘‘you can’t use the term ‘ultra light,’ because it’s not 

meaningful.’’ Then there are specific standards. Most of the cigarette companies sell other products, or the major ones do, they sell 

Kraft cheese, for example, that is ‘‘light.’’ That cheese has to meet 

certain standards that are objective. 

Senator LAUTENBERG. The—my folks were able to dig out some 

packs of cigarettes I—I don’t know whether you’re—all of you are 

aware, but we were able to persuade the—Rules Committee to ban 

the sale of cigarettes throughout the Capitol. And it’s just taking 

place. And, if anything, it seemed kind of backward. Here we are, 

preaching the gospel, and downstairs they’re selling the tools for 

addiction. And so, we are—that—as of, I think, it’s the first of the 

year, that they will no longer be available. There are sales now— 

and I’m not advertising—of cigarettes at lower prices to clear out 

the inventory. 

But all of these facts—and I don’t mean to pick up out any of 

them—but the reference is, ‘‘Surgeon General’s Warning: Cigarette 

smoke contains carbon monoxide.’’ Now, wouldn’t you think that 

would scare the devil out of those people who are buying cigarettes? Carbon monoxide? Say you can get that from your car if 

you—well, if you want to end—we have different packages. This 

one is—they give it a number on this package—this is called Camel 

number 9. It is a beautiful package, but carrying almost a lethal 

message. Here, they’re more specific, ‘‘Surgeon General’s Warning: 

Smoking causes lung cancer, heart disease, emphysema, and may 

complicate pregnancies.’’ This one really—Mr. Sheller, you managed to, I think, get some justifiable anger about what we see, but 

here’s this ad. It says, ‘‘Camels, light and luscious.’’ Now—— 

Mr. SHELLER. You should see what they mail my daughter at 

home. I have a daughter who’s at Temple University, finishing up 

this year as—becoming a special-ed teacher. And, because she’s 

over 21, somehow or other they found her. She doesn’t smoke, but 

we get things in the mail—I’ve been saving them—that are mindboggling from the cigarette companies. 

Senator LAUTENBERG. Well, we’re—we’ve learned a lot, but we 

haven’t yet learned enough. And I’m hoping that we can use the 

knowledge that we’ve gained here today, with your help, to really 

do something about this. 

Dr. GOLDBERG. Senator, if I could, in response—when you say 

things like, ‘‘There are awful things like carbon monoxide,’’ et 

56 

cetera, we often think of this dispassionate person to whom the 

message is addressed. And, as you’ve said, this is—you know, there 

is a wonderful study that shows, when you show a Harvard/Yale 

football game, way back in the 1950s, to Harvard and Yale people, 

they each tell you that the other side was terrible, in terms of the 

penalties and infractions. They’re committed to a particular perspective. Well, smokers are, too. They’re very committed. They’re 

addicted. And so, we’re not talking about a reasonable person dispassionately considering the information. 

Senator LAUTENBERG. How about—we all remember when a doctor was advertised as preferring one cigarette to another. 

Mr. SHELLER. Oh, yes. With a white coat. 

Senator LAUTENBERG. I thank you all for your testimony. We’re 

going to adjourn this hearing. 

And I note, Mr. Sheller, that your admonition that Congress 

should act swiftly—— 

Mr. SHELLER. Yes. 

Senator LAUTENBERG.—to stop allowing companies to make light 

and low-tar claims based on the FTC Method, we’ll look at that 

very closely. 

Mr. SHELLER. Thank you—— 

Senator LAUTENBERG. With that—— 

Mr. SHELLER.—Senator Lautenberg. 

Senator LAUTENBERG.—this hearing is adjourned. And, once 

again, thank you all. 

[Whereupon, at 3:59 p.m., the hearing was adjourned.] 

(57) 

1This letter reflects my own views. It does not purport to represent the views of the Commission or any other Commissioner. 

A P P E N D I X 

PREPARED STATEMENT OF HON. PAMELA JONES HARBOUR, COMMISSIONER, FEDERAL

TRADE COMMISSION

Today, the Commission approves testimony to be presented on November 13, 2007 

before the Senate Committee on Commerce, Science, and Transportation concerning 

the Federal Trade Commission’s Tar and Nicotine Rating System. I concur in the 

decision to present testimony providing an overview of the FTC’s responsibilities 

and activities in the area of tobacco advertising and a discussion of cigarette testing 

and the promotion of cigarettes based on machine-measured tar and nicotine yields. 

I also concur in the Commission’s recommendation that Congress consider giving 

authority over cigarette testing to one of the Federal Government’s science-based 

public health agencies. 

However, I would also recommend that steps be taken to prohibit the use of any 

claims based on the Cambridge Filter Method—also known as ‘‘FTC Method’’—for 

testing tar and nicotine. See the attached May 10, 2007 letter to the Hon. Frank 

R. Lautenberg. The tobacco industry has known for decades that the FTC Method 

does not accurately measure the amount of tar and nicotine a person consumes from 

a cigarette. Prohibiting the use of claims based on the FTC Method would remove 

the FTC’s apparent imprimatur from cigarette labels and ads. 

FEDERAL TRADE COMMISSION

Washington, DC, May 10, 2007 

Hon. FRANK R. LAUTENBERG, 

U.S. Senate, 

Washington, DC. 

Dear Senator Lautenberg: 

I send this letter to express my support for S. 625, the Family Smoking Prevention and Tobacco Control Act.1 The bill creates a reasonable framework to oversee 

the manufacture, sale, advertising, and marketing of tobacco products. Notably, the 

bill includes several key consumer protection measures. 

First, the bill allows the Food and Drug Administration to regulate tobacco products. This is a critical starting point. The FDA has lacked adequate authority in this 

area for decades, and tobacco manufacturers have exploited the void. The bill authorizes FDA scientists to track, analyze, and regulate the components of tobacco 

products. At last, the FDA will have more effective tools to protect the public’s 

health. 

Second, the bill properly assigns—to manufacturers themselves—the burden of 

substantiating ‘‘modified risk’’ claims, such as ‘‘light,’’ ‘‘low tar.’’ and ‘‘reduced exposure.’’ Consumers’ choices are influenced by these claims. If a manufacturer says 

that its tobacco product poses a reduced risk, the manufacturer should be required 

to substantiate the claim with competent evidence that can be evaluated by scientists. This bill will compel manufacturers of tobacco products to provide scientific 

data, which will enable scientists to scrutinize modified-risk claims and determine 

whether the claims can be made responsibly. 

The bill gives the FDA authority to establish new testing procedures and disclosures about tar and nicotine. However, an additional provision is needed to ensure 

that consumers receive accurate information about tar and nicotine levels. Thus, the 

bill should prohibit the use of any claims based on the so-called ‘‘FTC Method.’’ Such 

a provision would be similar to the prohibition in your bill, S. 3872. The tobacco 

industry has known for decades that the FTC Method does not accurately measure 

the amount of tar and nicotine a person consumes from a cigarette. Since 1999, the 

58 

FTC has publicly stated its concerns about the Method’s accuracy. It distresses me 

that a small number of cigarette manufacturers still invoke the name of the FTC 

when claiming low tar and nicotine content. By prohibiting the use of claims based 

on the FTC Method, the bill would remove the FTC’s apparent imprimatur from cigarette labels and ads. 

Third, the bill appropriately preserves coordination between the FTC and the 

FDA in enforcing labeling and marketing requirements, particularly as they relate 

to children. This kind of enforcement is a core element of the FTC’ s consumer protection mission. The bill wisely preserves the FTC’s jurisdiction over unfair or deceptive cigarette advertising. I am especially pleased that advertising in violation 

of the proposed Act also will be deemed a violation of a rule promulgated under Section 18 of the FTC Act. Civil penalty authority is an important tool in the FTC’s 

enforcement arsenal. By enabling the FTC to seek civil penalties immediately when 

a violation of the proposed Act is found, the Act will further enhance the agency’s 

authority to stop misleading and youth-oriented advertising. 

I thank you for your leadership in sponsoring the bipartisan Family Smoking Prevention and Tobacco Control Act. The regulation of the manufacture, sale, advertising, and marketing of tobacco products is a tall order, but it is crucial for the 

health of our country, particularly its young people. I hope that action on the bill 

will advance the dialogue and push Federal health agencies to step up to the plate 

on this issue. 

Please contact me if I may provide any assistance to you as the bill moves forward. 

Sincerely, 

PAMELA JONES HARBOUR, 

Commissioner. 

American Journal of Public Health—December 2006, Vol. 96, No. 12 

EFFECT OF TELEVISED, TOBACCO COMPANY-FUNDED SMOKING PREVENTION

ADVERTISING ON YOUTH SMOKING-RELATED BELIEFS, INTENTIONS, AND BEHAVIOR

by Melanie Wakefield, Ph.D., Yvonne Terry-McElrath, M.S.A, Sherry Emery, Ph.D., Henry Saffer, Ph.D., Frank 

J. Chaloupka, Ph.D., Glen Szczypka, B.A., Brian Flay, Ph.D., Patrick M. O’Malley, Ph.D., Lloyd D. Johnston, 

Ph.D. 

Objective. To relate exposure to televised youth smoking prevention advertising to 

youths’ smoking beliefs, intentions, and behaviors. 

Methods. We obtained commercial television ratings data from 75 U.S. media markets, and to determine the average youth exposure to tobacco company youth-targeted and parent-targeted smoking prevention advertising. We merged these data 

with nationally representative school-based survey data (n = 103,172) gathered from 

1999 to 2002. Multivariate regression models controlled for individual, geographic, 

and tobacco policy factors, and other televised antitobacco advertising. 

Results. There was little relation between exposure to tobacco company-sponsored, 

youth-targeted advertising and youth smoking outcomes. Among youths in grades 

10 and 12, during the 4 months leading up to survey administration, each additional 

viewing of a tobacco company parent-targeted advertisement was, on average, associated with lower perceived harm of smoking (odds ratio [OR] = 0.93; confidence interval [CI] = 0.88, 0.98), stronger approval of smoking (OR = 1.11; CI = 1.03, 1.20), 

stronger intentions to smoke in the future (OR = 1.12; CI = .04, 1.21), and greater 

likelihood of having smoked in the past 30 days (OR = 1.12; CI = .04, 1.19). 

Conclusions. Exposure to tobacco company youth-targeted smoking prevention advertising generally had no beneficial outcomes for youths. Exposure to tobacco company parent-targeted advertising may have harmful effects on youth, especially 

among youths in grades 10 and 12. (Am J Public Health. 2006; 96: 2154–2160.. 

doi:10.2105/AJPH.2005.083352) 

The tobacco industry has actively attempted to remake its public image in response to evidence that it marketed products to youth and misled the public about 

smoking health risks.1 2 This effort has included public education campaigns to communicate that youths should not smoke.3 In December 1998, Philip Morris launched 

a national $100 million television campaign the company described as targeted to 

youths aged 10–14 years.4 The primary message was that youths do not need to 

smoke to fit in socially with their peers, and the campaign delivers the slogan 

‘‘Think. Don’t Smoke.’’ Although this campaign ended on U.S. television in January 

2003, the ads continue to be broadcast in other countries.5 In October 1999, and 

with a budget of around $13 million,6 Lorillard Tobacco Company also launched a 

59 

U.S.-televised youth smoking prevention campaign with the slogan, ‘‘Tobacco is 

Whacko if You’re a Teen.’’ 4

In mid-July 1999, Philip Morris launched a campaign that emphasized parental 

responsibility for talking to children about smoking; the slogan was ‘‘Talk. They’ll 

Listen.’’ 7 This parent-focused youth smoking prevention campaign has featured a 

variety of television ads and continues today. The overt message of these ads is that 

parents should talk to their children about not smoking. 

Few studies have examined the potential affect of youth-focused tobacco companysponsored advertising. Of those, most have only assessed immediate appraisals of 

the advertisements by youths,8 9 10 or the relation between ads and attitudes 

thought to be predictive of smoking behavior change,11 rather than smoking behavior itself. No studies have examined the effects of tobacco company parent-focused 

advertising on youth. Because advertising that may influence youth smoking has 

also been broadcast at various times and intensities by tobacco control programs,12

it is a complicated matter to establish the relative influence of tobacco companysponsored advertising. 

The objective of this study was to assess the relation between exposure to tobacco 

company youth smoking prevention advertising and youth smoking-related beliefs, 

intentions, and behavior in a representative sample of American secondary school 

students. The study includes youth-targeted and parent-targeted advertising. The 

study sample included the primary target age group of the youth-targeted ads 

(grade 8, mean age 14 years), as well as older youths in grades 10 and 12 (mean 

ages 16 and 18 years, respectively). We used objective media monitoring data to 

measure potential exposure of youths to different sources of advertising, as opposed 

to self-reported measures of exposure that can be correlated with openness to 

change in smoking behavior.13

Methods 

Advertising Data 

Nielsen Media Research provided data on the occurrence of all smoking-related 

advertisements that appeared on network and cable television across the largest 75 

U.S. television media market areas during 1999–2002. These 75 markets accounted 

for 78 percent of American viewing households.14 A media market is defined by a 

group of nonoverlapping counties forming a major metropolitan area. Data are on 

the basis of individual ratings of television programs obtained by monitoring household audiences across media markets. Ratings provide an estimate of the percentage 

of households with televisions that watch a program or advertisement in a media 

market over a specified time interval.15 The advertising exposure measure used in 

our study is based on Target Rating Points (TRPs) for the population aged 12–17 

years. In these analyses, TRPs were aggregated each month; 100 TRPs are equal 

to an average of 1 potential advertisement exposure per month for all youth aged 

12–17 years within a media market. TRPs represent potential average exposure; actual exposure for any given individual would vary on the basis of actual television 

viewing. In this study, all the tobacco company parent-targeted advertising was 

from Philip Morris. However, tobacco company youth-targeted advertising was 

broadcast by Philip Morris and Lorillard; Philip Morris made up 90.8 percent of the 

total TRPs in 1999, 93.0 percent in 2000, 85.2 percent in 2001, and 37.5 percent 

in 2002. 

Monthly TRP data were merged with nationally representative data collected during 1999–2002 from the Monitoring the Future school survey.16 Data were collected 

from February to June each year from samples of students in grades 8, 10, and 12, 

drawn to be representative of all students in the specified grade for the 48 contiguous states. All surveys were self-completed and group-administered in school settings. 

Dependent Variables 

Separate analyses were conducted for each of the following self-reported dependent variables: recall of antitobacco advertising at least weekly (1 = seeing 

antitobacco commercials on television or hearing them on the radio at least once a 

week in recent months); approval of smoking (1 = don’t disapprove of people smoking ≥ 1 pack a day (grades 8 and 10), or don’t disapprove of people (aged 18 years 

or older) smoking ≥ 1 pack a day (grade 12); perceived enjoyment of life by smokers 

(1 = no disagreement with the statement that smokers know how to enjoy life more 

than nonsmokers); preference for dating nonsmokers (1 = no preference for dating 

nonsmokers); perceived exaggeration of smoking harm (1 = no disagreement with 

the statement that the harmful effects of smoking have been exaggerated); perception that being a smoker reflects poor judgment (1 = do not agree that being a smoker reflects poor judgment); perception that smoking is a dirty habit (1 = do not agree 

60 

that smoking is a dirty habit); perceived harm of smoking (1 = believe people risk 

‘‘great harm’’ to themselves by smoking ≥ 1 pack of cigarettes a day); intentions to 

be smoking in 5 years time (0 = definitely will not be smoking cigarettes in 5 years; 

1 = other 17); smoking in the past 30 days (1 = any cigarette smoking in the past 

30 days); and consumption among current smokers, as measured by a 6-point scale: 

less than 1 cigarette/day (0.5), 1–5 cigarettes/day (3.0), about .5 pack/day (10), about 

1 pack/day (20), about 1.5 pack/day (30), and 2 or more packs/day (40). The natural 

log of this scale was used in all models.18

The school survey randomly allocates students to several different forms of survey 

questionnaires to maximize the number of questions asked of students. Although all 

students are asked about smoking behavior (current smoking and consumption), 

only some forms contain questions on recall of advertising, and smoking-related attitudes and intentions. For this reason, different numbers of students respond to each 

outcome measure. The total number of students included in each model is specified 

in table footnotes. 

Independent Variables 

Advertising exposure for each student was calculated to reflect the cumulative effect of repeated potential exposure to tobacco industry advertising and gave greater 

weight to more recent exposure.19-21 Thus, in analyses, individual student potential 

exposure to tobacco industry advertising was reflected by the sum of TRPs for the 

month in which the school survey was completed, plus the sum of depreciated TRPs 

from the 3 previous months. On the basis of the work of Pollay and colleagues,21

a depreciation value of 0.3 was specified as noted in the equation. 

(1) Adstockt=Adt+λAd(t¥1)+λ2Ad(t¥2)+λ3Ad(t¥3)

where Adstock is the total effective advertising, λ is set at the specified value of 0.3 

as noted above, and Ad indicates ad sponsor TRPs for time periods t, t¥1, t¥2, and 

t¥3. A range of values for λ were examined. Because results were highly similar, 

λ was set at 0.3, consistent with previously published data by Emery and colleagues 22 on the effect of state tobacco control ads. The depreciated sum was scaled 

by dividing by 100. The resulting TRP exposure value represents the depreciated 

average number of times that advertising from a particular sponsor was potentially 

seen by 100 percent of the youth aged 12–17 years in each media market over the 

4 months leading up to each specific school’s date of survey participation. Thus, students within the same media market were assigned different advertising exposures, 

depending on the month in which their school was surveyed. However, within media 

markets, students in each school were assigned the same advertising exposure values, because they completed the survey on the same date. Smoking-related outcomes 

were modeled using continuous versions of depreciated TRPs for youth-targeted and 

parent-targeted advertising. 

Statistical Analyses and Covariates 

Our analyses used survey commands in Stata (Stata Corp, College Station, Tex) 

for descriptive population estimates and multivariate regression models 

(SVYLOGISTIC for dichotomous outcomes; SVYREG for the models of cigarette consumption using the natural log of the consumption scale). The complex multistage 

sample design was accounted for by using sampling weights to adjust for differential 

selection probabilities, and by using Taylor linearization-based variance estimators 

to adjust for clustering by school and compute robust standard errors. 

Initially, for each type of tobacco company advertising, we tested several functional forms, including quadratic and threshold models, to explore whether the relations between exposure and outcomes were nonlinear. The linear models fit the data 

best, and are reported here. Thus, odds ratios refer to change in the likelihood of 

each outcome measure, on the basis of each additional advertisement viewed, on average, in the 4 months leading up to the date of survey administration. 

For tobacco company youth-targeted advertising, we first ran models for all students combined and controlled for: (1) competing advertising exposure from 2 types 

of campaigns: tobacco control (including state and national American Legacy Foundation campaigns) and tobacco company parent-targeted advertising; (2) individual 

sociodemographics: gender, race/ethnicity, average parental education, dual parent 

household, grade point average, 3 or more evenings out a week for fun/recreation, 

past-month truancy, year, region, and student-earned income; and (3) state tobacco 

policy variables: average real price per pack of cigarettes 22 and a smoke-free air 

index measuring the comprehensiveness of state smoke-free laws. The smoke-free 

air index values depended on the number, type, and level of protection for smokefree locations, and whether the state had the authority to preempt local smoke-free 

regulations.22 On the basis that the primary target group of the tobacco company 

youth-targeted advertising was youths aged 10–14 years and that middle- (grade 8, 

61 

mean age 14 years) and high-school (grades 10 and 12, mean ages 16 and 18 years, 

respectively) students are at very different developmental stages, we ran separate 

models for grade 8 versus grades 10 and 12. In the model for grades 10 and 12, a 

dummy variable for grade 12 was also included. This analysis process was repeated 

to examine the relation between tobacco company parent-targeted advertising and 

youth smoking outcomes (with the exception that competing advertising exposure 

for tobacco company youth-targeted advertising was included as a covariate). 

We conducted sensitivity analyses to explore the robustness of findings for outcomes of greatest concern. Because advertising and policy variables were correlated, 

we excluded each tobacco policy variable and tobacco control campaign exposure, to 

explore if observed relations changed in a systematic way. In addition, we were able 

to include information on student-reported frequency of television watching as a covariate in models of smoking prevalence and consumption, because these questions 

occurred on the same survey form as television watching questions for all 3 grades. 

In this set of analyses, the school survey item measured self-reported average weekday television viewing as a continuous variable (a 7-point scale ranging from 0 to 

5+ hours). 

Results 

After retaining cases that had no missing data for covariates and at least 1 of 

the specified dependent variables, 103,172 students remained in the analytic sample; 36 percent were students in grade 8 and 64 percent were students in grades 

10 and 12. Table 1 shows that 20.8 percent of the sample population had smoked 

in the last 30 days and average daily consumption for these smokers was 5.43 cigarettes. 

On average, students had been exposed to 4.77 depreciated potential viewings of 

tobacco company youth-targeted advertising and 1.13 potential viewings of tobacco 

company parent-targeted advertising in the 4-month period leading up to the survey. As expected from the diverse timing and intensity of these campaigns, there 

was variation between students, with a range of 0 to 14.51 viewings of tobacco company youth-targeted ads, and a range of 0 to 4.13 viewings of tobacco company parent-targeted ads. There was also variation in exposure to tobacco control campaigns 

(mean 6.88 viewings; for state antitobacco campaigns, mean = 1.66 [range = 0– 

19.14]; for the American Legacy Foundation, mean = 5.23 [range = 0–21.85]). 

After we controlled for covariates, increased exposure to tobacco company youthtargeted advertising among all students was generally unrelated to recall of televised anti-tobacco advertising or to smoking beliefs or behavior (Table 2). However, 

on average, each additional ad viewed was associated with a 3 percent stronger intention to smoke in the future (OR = 1.03; CI = 1.01, 1.05). When analyzed separately for middle- and high-school students, higher exposure to tobacco company 

youth-targeted advertising was unrelated to any outcome for students in grades 10 

and 12. For students in grade 8, higher exposure was associated with stronger intentions to smoke in the future (OR = 1.04; CI = 1.01, 1.08). Inclusion of self-reported frequency of television watching as a covariate did not change the finding 

that there was no relation between increased tobacco company youth-targeted advertising and smoking in the past 30 days, or consumption among smokers. (Data 

for students who smoked in the past 30 days: all students OR = 0.99; CI = 0.96, 

1.01; grade 8 OR = 0.99; CI = 0.95, 1.04; grades 10 and 12 OR = 0.99; CI = 0.96, 

1.01. Data for consumption among smokers: all students Parameter estimate = 

¥.008, P > .05; grade 8 Parameter estimate = ¥.014, P > .05; grades 10 and 12 

Parameter estimate = ¥.004, P > .05.) 

After adjusting for covariates, Table 2 shows that among all students combined, 

each additional tobacco industry parent-targeted ad was associated with a lower 

likelihood of recalling antitobacco advertising (OR = 0.87; CI = 0.82, 0.92), lower perceived harm of smoking (OR = 0.95; CI = 0.92, 1.00), stronger intentions to smoke 

in future (OR = 1.12; CI = 1.05, 1.19), and a greater likelihood of smoking in the 

past 30 days (OR = 1.10; CI = 1.03, 1.17). 

Separate models for middle- and high-school students indicated that, among students in grade 8, greater tobacco company parent-targeted advertising exposure was 

related to lower odds of recalling antitobacco advertising (OR = 0.86; CI = 0.78, 

0.94), a greater likelihood of perceiving the harms associated with smoking have 

been exaggerated (OR = 1.07; CI = 1.01, 1.13), and stronger intentions to smoke in 

the future (OR = 1.10; CI = 1.00, 1.21). Among students in grades 10 and 12, higher 

advertising exposure was also associated with less likelihood of recalling antitobacco 

advertising (OR = 0.86; CI = 0.80, 0.94), stronger approval of smoking (OR = 1.11; 

CI = 1.03, 1.20), lower perceived harm of smoking (OR = 0.93; CI = 0.88, 0.98), 

stronger intentions to smoke in future (OR = 1.12; CI = 1.04, 1.21), and a greater 

likelihood of smoking in the past 30 days (OR = 1.12; CI = 1.04, 1.19). Each addiVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00065 Fmt 6601 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
62 

tional ad exposure during the 4 months leading up to survey administration, on average, was associated with a 12 percent increase in the likelihood that students in 

grades 10 and 12 had smoked in the past 30 days. 

In sensitivity analyses among students in grades 10 and 12, where relations of 

most concern were found, exclusion of cigarette price or strength of smoke-free air 

index generally did not systematically influence the relation between increasing tobacco company parent-targeted advertising and stronger approval of smoking, lower 

perceived harm of smoking, stronger intentions to smoke in the future, or greater 

likelihood of smoking in the past 30 days (Table 3). When tobacco-control ad exposure was removed, relations persisted between increasing tobacco company parenttargeted ad exposure and stronger approval of smoking as well as smoking in the 

past 30 days, but were weakened for perceived harm of smoking and intention to 

smoke in the future. 

Table 1.—Sample Characteristics of Students in 8th, 10th, and 12th Grade: 1999–2002 

Weighted No. Percentage Mean 

Independent control variables (N = 103,172) a

Middle school (grade 8) 36.0 

High school (grades 10 and 12) 64.0 

Male 47.3 

Race/ethnicity 

White 71.6 

African American 12.0 

Hispanic 10.9 

Other 5.5 

Lives with both parents 75.0 

Regularly out ≥ 3 nights/wk 44.5 

Skipped or cut school in the past month 19.4 

Earned income, $ 1–15/wk 

(median) 

Parental education (range: 1–6) b 3.99 

Average school grade (range: 1–9) c 6.22 

Real price/pack of cigarettes, $ (range: $1.32–$2.86) 1.92 

Smoke-free air index (range: ¥22.50–51.00) 13.15 

Region 

Northeast 21.5 

Midwest 28.0 

West 18.8 

South 31.7 

Independent variables (N = 103172) a

Average tobacco industry parent-targeted exposure d

(range: 0.00– 4.13) 1.13 

Average tobacco industry youth-targeted exposure d

(range: 0.09–14.51) 4.77 

Average tobacco control exposure d (range: 0.00–23.90) 6.88 

Dependent variables e

Recall antitobacco ads on TV or radio at least weekly (1 = yes) 28,768 62.4 

Approve of others/adults smoking ≥ 1 pack per day (1 = yes)f 65,388 22.7 

Do not prefer to date nonsmokers (1 = yes) 37,645 22.6 

Feel that smokers know how to enjoy life more than nonsmokers 

(1 = yes) 37,685 16.2 

Feel the harmful effects of cigarettes have been exaggerated (1 = 

yes) 37,240 34.2 

Do not feel that being a smoker reflects poor judgment (1 = yes) 37,343 39.6 

Do not feel that smoking is a dirty habit (1 = yes) 37,320 27.5 

Perceive great harm in smoking ≥ 1 packs/day (1 = yes) 95,952 69.6 

Intend to smoke in 5 years (1 = yes) 34,047 39.1 

Smoked in the past 30 days (1 = yes) 101,720 20.8 

Consumption frequency among current smokers 

(.5, 3, 10, 20, 30,40) g 19,581 5.43 

a Number of students was obtained by retaining only cases with valid data for all independent control variables, and valid data on 

at least 1 of the specified dependent variables. bParental education was a scaled value ranging from 1 to 6, and was a combined average of mother’s and father’s highest level of

education, where 1 = grade school or less, 2 = some high school, 3 = high school completion, 4 = some college, 5 = college completion, and 6 = graduate school. c Average school grade was a 9-item scale where 1 = D and 9 = A.A mean of 6 indicates a B. 

d Exposure to specific ads during the 4 months before the school survey. Advertising exposure data reported at the student level 

and not at the media market level, because students within the same media market will have different average exposures on the 

basis of their school survey date. ePossible Ns for dependent variables varied, because not all items were asked of all students. 

fStudents in grades 8 and 10 were asked about disapproval of others’ smoking; students in grade 12 were asked about disapproval of adults’ smoking. g Consumption was measured by a 6-point scale: less than 1 cigarette/day (0.5), 1–5 cigarettes/day (3.0), about 0.5 pack/day (10), about 1 pack/day (20), about 1.5 pack/day (30), and 2 or more packs/day (40). The natural log of this scale was used in all models. 

63 

When self-reported frequency of television watching was included as a covariate, 

the relation between tobacco company parent-targeted ad exposure and current 

smoking was unchanged for students in grade 8 (OR = 1.11; CI = 0.99, 1.25, not 

significant) but was strengthened among students in grades 10 and 12 (OR = 1.14; 

CI = 1.05, 1.25, P < .01). Control for television watching did not change the previously nonsignificant results for cigarette consumption (grade 8: Parameter estimate = ¥.068, P > 0.5; grades 10 and 12: Parameter estimate= ¥.016, P > .05). 

In models of students in all three grade levels, higher cigarette price was associated with lower consumption among current smokers (Parameter estimate = ¥.002, 

SE = 0.001, P < .05), and stronger smoke-free laws were associated with a lower 

likelihood of smoking in the past 30 days (OR = 0.99; CI = 0.99, 1.00, P = .01 [data 

not shown]). In addition, consistent with previous studies,11 22 we observed expected 

relations between increasing exposure to tobacco control campaign advertising and 

higher recall of antitobacco advertising (OR = 1.04; CI = 1.03, 1.04, P < .001), more 

protective beliefs about smoking (e.g., increased perceived harm of smoking) (OR = 

1.01; CI = 1.00, 1.02, P < .01), weakened intentions to smoke in future (OR = 0.98; 

CI = 0.97, 0.99, P < .001), and a lower likelihood of smoking in the past 30 days 

(OR = 0.99; CI = 0.98, 1.00, P < .01). 

Discussion 

Overall, we found no systematic associations between increased exposure to tobacco company youth-targeted smoking prevention advertising and smoking outcomes among American youths. We found that increased exposure to tobacco company parent-targeted smoking prevention advertising was associated with lower recall of antitobacco advertising and stronger intentions to smoke in the future for all 

students. Among students in grade 8, tobacco company parent-targeted advertising 

was related to stronger beliefs that the harms associated with smoking have been 

exaggerated, and among students in grades 10 and 12, was associated with lower 

perceived harm of smoking, stronger approval of smoking, and a higher likelihood 

of having smoked in the past 30 days. Importantly, the results for smoking prevalence among students in grades 10 and 12 were not systematically influenced by correlations between price and strength of smoke-free air laws, or tobacco control advertising exposure, although some models were less robust when tobacco control ad 

exposure was removed as a covariate. 

64 

Table 2.—Odds Ratios for Each Unit Increase in Number of Ads Viewed, With 95% Confidence Intervals (CIs), for Smoking-Related Beliefs and Behavior and Tobacco Industry Smoking 

Prevention Advertising Exposure: 1999–2002 

Exposure, all students a Exposure, 8th Grade Students b Exposure, 10th and 12th Grade Students c

Youth-Targeted d Parent-Targeted e Youth-Targeted d Parent-Targeted e Youth-Targeted d Parent-Targeted e

Recall antitobacco ads on TV or radio at least 

weekly 1.00 (0.98, 1.02) 0.87*** (0.82, 0.92) 0.99 (0.96, 1.02) 0.86** (0.78, 0.94) 1.01 (0.98, 1.03) 0.86** (0.80, 0.94) 

Approve of others/adults smoking ≥ 1 pack/day f 0.98 (0.95, 1.00) 1.06 (0.99, 1.13) 0.98 (0.95, 1.01) 1.03 (0.96, 1.12) 0.98 (0.96, 1.01) 1.11** (1.03, 1.20) 

Do not prefer to date nonsmokers 1.00 (0.97, 1.02) 1.04 (0.97, 1.11) 1.00 (0.96, 1.04) 1.05 (0.94, 1.18) 0.99 (0.97, 1.02) 1.03 (0.96, 1.11) Feel that smokers know how to enjoy life more 

than nonsmokers 1.00 (0.98, 1.03) 1.00 (0.94, 1.07) 1.02 (0.98, 1.06) 1.07 (0.96, 1.19) 0.99 (0.97, 1.02) 0.94 (0.87, 1.01) 

Feel the harmful effects of cigarettes have been 

exaggerated 1.00 (0.98, 1.02) 1.03 (0.99, 1.08) 1.01 (0.98, 1.03) 1.07* (1.01, 1.13) 0.99 (0.96, 1.01) 0.99 (0.93, 1.06) 

Do not feel that being a smoker reflects poor 

judgment 0.99 (0.97, 1.01) 0.99 (0.94, 1.04) 0.98 (0.95, 1.01) 1.02 (0.95, 1.09) 0.99 (0.97, 1.02) 0.96 (0.90, 1.03) 

Do not feel that smoking is a dirty habit 1.00 (0.98, 1.02) 1.00 (0.94, 1.07) 1.00 (0.96, 1.03) 1.01 (0.92, 1.10) 1.01 (0.98, 1.03) 0.99 (0.91, 1.07) Perceive great harm in smoking ≥ 1 packs/day 0.99 (0.98, 1.01) 0.95* (0.92, 1.00) 0.99 (0.97, 1.01) 0.98 (0.93, 1.04) 1.00 (0.98, 1.02) 0.93** (0.88, 0.98) 

Intend to smoke in 5 years 1.03** (1.01, 1.05) 1.12** (1.05, 1.19) 1.04* (1.01, 1.08) 1.10* (1.00, 1.21) 1,.01 (0.99, 1.04) 1.12** (1.04, 1.21) 

Smoked in past 30 days 0.99 (0.97, 1.01) 1.10** (1.03, 1.17) 0.99 (0.95, 1.04) 1.11 (0.99, 1.25) 0.99 (0.97, 1.01) 1.12** (1.04, 1.19) Consumption frequency among current smokers,g

parameter estimate (SE) ¥.014; (.008) .019 (.025) ¥.014 (.015) .069 (.044) ¥.012 (.009) .018 (.028) 

Note. All models controlled for tobacco control advertising exposure, either tobacco company parent-targeted or youth-targeted advertising exposure, year, gender, race/ethnicity, earned income, average parental education, 

whether both parents live in the home, grade point average, evenings out, truancy, region, state cigarette price, and state smoke-free air index values. aAll students model Ns (weighted): smoked in last 30 days 101,720; perceived harm 95,952; disapproval 65 388; recall 28,768; consumption 21,138; remaining perception models range from 34,047 to 37,685. aGrade 8 model Ns (weighted): smoked in last 30 days 36,382; perceived harm 36,236; disapproval 23,305; recall 12,136; consumption 4,621; remaining perception models range from 12,287 to 16,688. cGrades 10 and 12 model Ns (weighted): smoked in last 30 days 65,338; perceived harm 59,716; disapproval 42,083; recall 16,632; consumption 16,517; remaining perception models range from 20,827 to 21,760. A dummy 

variable identifying students in grade 12 was included in these models. bTobacco company youth-targeted ads sponsored primarily by Philip Morris, and by Lorillard Tobacco Company. 

eTobacco company parent-targeted ads sponsored by Philip Morris. fStudents in grades8 and 10 asked about disapproval of others’smoking; 12th grade students asked about disapproval of adults’smoking. g Consumption measured by a 6-point scale: less than 1 cigarette/day (0.5), 1–5 cigarettes/day (3.0), about 0.5 pack/day (10), about 1 pack/day (20), about 1.5 pack/day (30), and 2 or more packs/day (40). The natural log of 

this scale was used in all models. 

*P < .05; **P < .01; ***P < .001. 

65 

Table 3.—Odds Ratios and 95% Confidence Intervals for Tobacco Company Parent-Targeted Advertising 

Exposure and Selected Smoking Outcomes Among Students in Grades 10 and 12: 1999–2002 a

Model a Weighted 

No. 

Excluding state 

cigarette price 

Excluding state 

smoke-free 

air index value 

Excluding 

tobacco control 

ad exposure 

Approve of others/adults 

smoking ≥ 1 pack/day b 42,083 1.10* (1.02, 1.18) 1.11** (1.03, 1.21) 1.10** (1.04, 1.17) 

Perceive great harm in smoking ≥ 1 packs/day 59,716 0.95 (0.90, 1.01) 0.93** (0.88, 0.98) 0.97 (0.93, 1.01) 

Intend to smoke in 5 years 21,760 1.12** (1.04, 1.20) 1.13** (1.05, 1.22) 1.04 (0.98, 1.10) 

Smoked in past 30 days 65,338 1.10** (1.03, 1.18) 1.12** (1.05, 1.20) 1.07** (1.02, 1.12) 

aTobacco company parent-targeted ads sponsored by Philip Morris. All models controlled for year, gender, race/ethnicity, earned 

income, average parental education, whether both parents live in the home, average school grade, evenings out, truancy, region, and 

dummy variable for students in grade 12. Unless specified above, models also controlled for tobacco control advertising exposure, either tobacco company parent-directed or youth-targeted advertising exposure, state cigarette price, and state smoke-free air index 

values. bStudents in grade 10 were asked about disapproval of others’ smoking; students in grade 12 were asked about disapproval of 

adults’ smoking. *P < .05; **P < .01. 

Our study did have limitations. Our use of cross-sectional survey data reduced our 

ability to make direct causal inferences about whether potential exposure to tobacco 

company parent-targeted advertising resulted in changes to youth smoking behavior, or whether an unmeasured factor may better explain the relations we observed. 

However, our ability to adjust for competing advertising exposures, our use of regional and year dummy variables, our sensitivity analyses, and the fact that we observed results for tobacco policy 23 24 and other advertising covariates 11 22 that were 

largely consistent with those found in previous studies, lead us to believe that it is 

unlikely that we are misrepresenting the relation between exposure to tobacco company youth-targeted or parent-targeted advertising and youth smoking outcomes. 

An alternate hypothesis is that tobacco companies may have purposefully purchased 

parent-targeted advertising in media markets that have higher youth smoking 

rates. This seems unlikely, however, given that the vast majority of their television 

time was bought through national network and cable channels and was not supplemented by the purchase of local media market television time. In addition, although 

the study had a large sample size, which makes differences between groups more 

likely to achieve statistical significance, the overall consistency in the pattern and 

robustness of findings leads one to conclude that the detected relations are real. 

As previously mentioned, another study limitation is that because TRPs measure 

average exposure for the overall population in a media market, individual youths 

may have more or less actual exposure, depending upon their own viewing habits. 

However, when we adjusted for self-reported television watching, the relations between tobacco company youth-targeted and parent-targeted advertising and smoking 

in the past 30 days did not change for students in grade 8 and strengthened for 

students in grades 10 and 12. Previous studies of antitobacco and antidrug advertising have found a strong correlation between advertising recall and TRP measures.22 25

Studies that use controlled exposure have indicated that tobacco company youthtargeted advertisements are less likely than those from state tobacco control programs tomake youths stop and think about smoking 10 and are of less interest to 

youths.26 In 1 national study, Philip Morris ‘‘Think. Don’t Smoke’’ advertisements 

were associated with increased intention to smoke and more favorable feelings toward the tobacco industry.6 Massachusetts youths aged 14–17 who recalled seeing 

Philip Morris’ ‘‘Think. Don’t Smoke’’ ads perceived them to be less effective than ads 

that featured the serious consequences of smoking.8 Our finding of no relation between tobacco company youth-targeted advertising and youth smoking substantiates 

these previous results. Although tobacco company youth-targeted advertising was 

withdrawn from U.S. television in early 2003, ads continue to be broadcast in other 

countries, contributing ‘‘clutter’’ to other public health-sponsored advertising efforts 12 that have been shown to be effective.11 22 27

Our finding of potentially harmful relations between tobacco company parent-targeted smoking prevention advertising and youth smoking is a source of concern. Our 

observation of adverse relations associated with parent-targeted advertising is not 

simply an artifact of our methodological approach: we have previously reported beneficial relations between exposure to state-sponsored antitobacco advertising and 

youth smoking beliefs and behavior using the same methods.22

Why might such advertising have harmful relations, especially for older teens? Although parents are the overt target group of tobacco company parent-targeted advertising, youths are exposed to them, on average, at levels almost equivalent to 

those of state-sponsored antitobacco campaigns. The overt message of the parentVerDate Nov 24 2008 08:42 Apr 23, 2012 Jkt 073848 PO 00000 Frm 00069 Fmt 6601 Sfmt 6621 S:\GPO\DOCS\73848.TXT SCOM1 PsN: JACKIE
66 

targeted campaign is that parents should talk to their children about smoking, but 

no reason beyond simply being a teenager is offered as to why youths should not 

smoke. 

Theories in developmental psychology suggest that authority messages specific to 

teenagers invite rejection by those who have migrated to a dominant peer group orientation as they make the transition to adulthood, typically between ages 15 to 17 

years.28 29 As adolescents age toward adulthood, they are more inclined to perceive 

themselves as independent and self-reliant and less likely to report that they rely 

on their parents for guidance or assistance.28 Evaluations of the U.S. National AntiDrug Media Campaign, which used messages encouraging parents to talk to their 

children about illicit drugs, have also reported unfavorable effects on adolescents.30 31 Facilitating productive interaction between parents and adolescents about 

substance use may require more intensive intervention approaches than simple encouragement through the mass media, which may do more harm than good. 

During depositions and testimony in U.S.-based tobacco trials, tobacco company 

witnesses put forward their youth smoking prevention efforts as evidence that they 

are concerned about youth smoking and that the campaigns are part of efforts to 

reduce youth smoking.32 However, during questioning at such a trial, Carolyn Levy, 

Director of Philip Morris youth smoking prevention programs, admitted that the 

aim of their programs was to delay smoking until age 18 32 This contrasts with the 

aims of public health-funded programs, which are to encourage people to never take 

up smoking. 

In summary, our analysis suggests that tobacco company youth- and parent-targeted smoking prevention advertising campaigns confer no benefit to youths, and especially for older teens, parent-targeted advertising may have harmful relations. In 

the United States, youths have the benefit of the national American Legacy Foundation antitobacco campaign, as well as state antitobacco campaigns. The Legacy 

Foundation’s budget cuts will force it to advertise less in the future, 33 and state 

antitobacco campaign advertising has begun to decline as a result of reduced state 

tobacco control funding.12 34 Many other countries of the world have limited or no 

public health-sponsored televised antitobacco advertising. Given a media environment that has fewer demonstrably beneficial advertising messages, it is conceivable 

that tobacco company smoking prevention ads could have even greater adverse effects on youth smoking behavior than suggested by this study. 

About the Authors 

Melanie Wakefield is with the Center for Behavioral Research in Cancer, The 

Cancer Council Victoria, Melbourne, Australia. Yvonne Terry-McElrath, Patrick M. 

O’Malley, and Lloyd D. Johnston are with the Institute for Social Research, University of Michigan, Ann Arbor. Sherry Emery, Frank J. Chaloupka, and Glen 

Szczypka are with the Institute for Health Research and Policy, University of Illinois, Chicago. Henry Saffer is with the Department of Economics, Kean University, 

Union, NJ. 

Requests for reprints should be sent to Melanie Wakefield, Ph.D., Center for Behavioral Research in Cancer, The Cancer Council Victoria, 1 Rathdowne Street, 

Carlton, Victoria, Australia, 3053. 

Contributors 

M. Wakefield conceived and led the study and the writing of the article. Y. TerryMcElrath conducted the analysis and assisted with writing. S. Emery, H. Saffer, F. 

Chaloupka, B. Flay, P.M. O’Malley, and L.D. Johnston contributed to conception of 

the study and the analysis and assisted with writing. G. Szczypka undertook data 

management for the study and assisted with writing. 

Acknowledgments 

The study was supported by the National Cancer Institute State and Community 

Tobacco Control Initiative (grant CA86273), the National Institute on Drug Abuse 

(grant DA01411), and The Robert Wood Johnson Foundation (grant 032 769). 

Melanie Wakefield was supported by a VicHealth Senior Research Fellowship. 

Human Participant Protection 

This study was approved by the University of Illinois, Chicago, institutional review board. Use of data from the Monitoring the Future school surveys received ethical approval by the University of Michigan Behavioral Sciences institutional review 

board. 

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RESPONSE TO WRITTEN QUESTION SUBMITTED BY HON. DANIEL K. INOUYE TO

HON. WILLIAM E. KOVACIC

Question. Are the ratings based on the FTC cigarette testing method deceiving 

smokers? 

Answer. The Commission has been concerned for some time that the current test 

method may be misleading to individual consumers who rely on the ratings it produces as indicators of the amount of tar and nicotine they actually will get from 

their cigarettes. 

As noted in the Commission’s November 13, 2007 Prepared Statement to the 

Committee, the ratings produced by the current test method tend to be relatively 

poor predictors of tar and nicotine exposure, primarily due to smoker compensation. 

If sufficiently great, compensatory smoking behavior can result in smokers getting 

as much tar and nicotine from relatively low-rated cigarettes as from higher-rated 

cigarettes. 

When the Commission approved the test method in 1967, the intent was to 

produce uniform, standardized data about the tar and nicotine yields of mainstream 

cigarette smoke, not to replicate actual human smoking. Because no known test 

could accurately replicate human smoking, the FTC believed that the most important objective was to ensure that cigarette companies presented tar and nicotine information to the public based on a standardized method. At the time, most public 

health officials believed that reducing the amount of ‘‘tar’’ in a cigarette could reduce a smoker’s risk of lung cancer; therefore, it was thought that giving consumers 

uniform and standardized information about the tar and nicotine yields of cigarettes 

would help smokers make informed decisions about the cigarettes they smoked. 

In the intervening 40 years, the limitations of the test method became a substantially greater concern as a result of changes in modern cigarette design and a better 

understanding of the nature and effects of compensatory smoking. These concerns 

have prompted the Commission to take a number of actions over the past decade. 

First, in 1994, the Commission, along with Congressman Henry Waxman, asked 

the National Cancer Institute (‘‘NCI’’) to convene a consensus conference to address 

cigarette testing issues. NCI held that conference in December 1994, and issued its 

Report in October 1996. 

The NCI Report recommended, among other things, that the cigarette testing system measure and publish information on the range of tar, nicotine, and carbon monoxide that most smokers should expect from the cigarettes they smoke. Accordingly, 

in September 1997, the Commission requested public comments on proposed revisions to the test method that would add a second tier of testing—using more rigorous smoking conditions—to generate a range of tar and nicotine yields for each 

cigarette and make it more apparent to consumers that the amount of tar and nicotine they get from any specific cigarette depends on how they smoke it. 

69 

1Federal Trade Commission Report to Congress for 1997, Pursuant to the Cigarette Labeling 

and Advertising Act, 5–6 (1999) (available at http://www.ftc.gov/os/1999/07/1997 

cigarettereport.pdf). 2Prepared Statement of the Federal Trade Commission Before the Committee on Energy and 

Commerce, Subcommittee on Commerce, Trade, and Consumer Protection, U.S. House of Representatives (June 3, 2003); Prepared Statement of the Federal Trade Commission Before the 

Committee on Government Reform, U.S. House of Representatives (June 3, 2003). 1 National Cancer Institute. Changing Adolescent Smoking Prevalence. Smoking and Tobacco 

Control Monograph No. 14. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute, NIH Pub. No. 02–5086, November 2001. 2 U.S. Department of Health and Human Services. Reducing Tobacco Use: A Report of the Surgeon General. Atlanta, Georgia: U.S. Department of Health and Human Services, Centers for 

Continued 

Ultimately, public health agencies asked the Commission to postpone its proposed 

modifications to the test method until a broader review of unresolved scientific 

issues surrounding the system could be conducted. The agency responded to these 

comments in 1998 by asking the Department of Health and Human Services 

(‘‘HHS’’) to review the test method. In particular, the Commission asked HHS to recommend whether the testing system should be continued, and if so, what specific 

changes should be made to correct the limitations previously identified by the NCI 

and others. The Commission understands that HHS continues to explore these 

issues. 

The Commission’s concerns about the current system led it to recommend in 1999 

that Congress consider giving authority over cigarette testing to one of the Federal 

Government’s science-based, public health agencies.1 The agency specifically noted 

that it does not have the specialized scientific expertise needed to design scientific 

test procedures. The Commission reiterated that request in 2003 2 and again at the 

November 13, 2007 hearings. 

Finally, the cigarette industry’s use of descriptors that are based on ratings produced by the test method—such as ‘‘light’’ and ‘‘low tar’’—is one of the issues currently before the United States Court of Appeals for the District of Columbia Circuit. The trial judge in the U.S. Department of Justice’s RICO case against the 

major cigarette manufacturers found that the manufacturers had made false and 

fraudulent statements about ‘‘light’’ and ‘‘low’’ tar cigarettes in marketing their 

products when they knew those cigarettes did not provide a clear health benefit 

compared to full-flavor cigarettes (the industry’s term for cigarettes with tar ratings 

above 15 mg.). The judge barred the companies from using the terms ‘‘light’’ and 

‘‘low’’ in marketing their products in the future. The companies have appealed that 

decision and remedy. We are monitoring that case, and believe that the court’s resolution of this issue will provide guidance and clarity on a complex issue that has 

raised troublesome questions for some time. 

SUPPLEMENTAL INFORMATION SUBMITTED BY CATHY L. BACKINGER, PH.D. 

The Impact of Cigarette Tax Increases on Cigarette Smuggling 

NCI Research Published in Monograph 14: Changing Adolescent Smoking Prevalence concluded that: 

‘‘[R]elatively little is known about the impact of large price increases on the 

growth of a black market in tobacco products and its subsequent impact on demand, particularly among youths. To the extent that organized and casual 

smuggling of tobacco products would result from large tax and price increases, 

the effects of the increases on tobacco use might be smaller than otherwise expected. The limited research in this area, however, suggests that the presence 

of a black market in tobacco products may be just as, or more, related to other 

factors—including the presence of informal distribution networks, nonexistent 

or weak policies concerning black market sales, and their lack of enforcement— 

as it is to prices (Joossens and Raw, 1995).’’ 1

The 2000 Surgeon General’s Report, Reducing Tobacco Use, concluded: 

• ‘‘Smuggling has a significant, but small, impact on cigarette demand, implying 

that a state cigarette tax increase will lead to some smuggling.’’ 

• ‘‘On average, 6 percent of state cigarette tax revenues were lost due to smuggling activities in 1995.’’ 

• ‘‘States can raise cigarette taxes and generate increased revenues, even as cigarette sales decline and interstate smuggling increases.’’ 2

70 

Disease Control and Prevention, National Center for Chronic Disease Prevention and Health 

Promotion, Office on Smoking and Health, 2000. 82–50179. 3 Cancer Prevention & Control Program, University of California—San Diego—The California 

Tobacco Control Program: A Decade of Progress, Results from the California Tobacco Survey, 

1990–1999 By the Tobacco Control Section, California Department of Health Services, December 

26, 2001. http://ssdc.ucsd.edu/ssdc/pdf/1999lFinallReport.pdf. 1 Chaloupka et al., (2002). Tax, price and cigarette smoking: evidence from the tobacco documents and implications for tobacco company marketing strategies. Tobacco Control, 11 Suppl 1: 

162–72. 2 National Cancer Institute. Changing Adolescent Smoking Prevalence. Smoking and Tobacco 

Control Monograph No. 14. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute, NIH Pub. No. 02–5086, November 2001. 

A California Department of Health survey found that soon after California’s 50- 

cent cigarette tax increase went into effect in 1999, no more than 5 percent of all 

smokers purchased cigarettes in nearby states, from Indian reservations or military 

bases, or via the Internet, or otherwise avoided the state’s cigarette tax.3

The Effect of Televised, Tobacco Company-Funded Smoking Prevention 

Advertising on Youth Smoking 

The National Cancer Institute funded a study published in the American Journal 

of Public Health in 2006 titled The Effect of Televised, Tobacco Company-Funded 

Smoking Prevention Advertising on Youth Smoking-Related Beliefs, Intentions, and 

Behavior. Below is a summary of this study: 

Recently, some tobacco companies have sought to portray themselves as interested 

in helping to prevent youth smoking, or in helping adults to quit. The sincerity and 

effectiveness of these efforts has been challenged by many in the medical and public 

health community who believe that, in reality, these activities are aimed at improving the dismal public profile of tobacco companies and at shifting attention away 

from their efforts to promote tobacco use. 

In a recently published study, Wakefield et al. confirmed that the tobacco industry’s youth-targeted smoking prevention advertising does not have beneficial outcomes for youth. In fact, it appears that exposure to tobacco company advertising 

targeted to parents may have harmful effects on youth, especially among those in 

grades 10 and 12. 

Among students in grade 8, tobacco company advertising targeted to parents was 

related to: 

• stronger beliefs that the harms associated with smoking have been exaggerated, 

• lower recall of anti-tobacco advertising (state and national American Legacy 

Foundation campaigns, such as truth), and 

• stronger intentions to smoke in the future. 

Among youths in grades 10 and 12, during the 4 months leading up to the survey 

administration, each additional viewing of a tobacco company advertisement targeted to parents was, on average, associated with: 

• lower perceived harm of smoking, 

• stronger approval of smoking, 

• greater likelihood of having smoked in the past 30 days, 

• lower recall of anti-tobacco advertising (state and national American Legacy 

Foundation campaigns, such as truth), and 

• stronger intentions to smoke in the future. 

Cigarette Taxes and Cigarette Use 

NCI-funded research has found that raising tobacco prices and implementing limits on tobacco marketing are effective in reducing and preventing tobacco use.1

• Youth are more susceptible to price increases than adults: 

» Youth: 10 percent increase in price = 5 percent reduction in prevalence. 

» Adults: 10 percent increase in price = 1–2 percent reduction in prevalence.2

CDC research has found that lower-income Americans and young adults are more 

susceptible to price increases than other Americans: 

71 

3 Centers for Disease Control and Prevention. Response to increases in cigarette prices by 

race/ethnicity, income, and age groups—United States, 1976–1993. Morbidity and Mortality 

Weekly Report 47(29):605–609, 1998. 4 U.S. Department of Health and Human Services. Reducing Tobacco Use: A Report of the Surgeon General. Atlanta, Georgia: U.S. Department of Health and Human Services, Centers for 

Disease Control and Prevention, National Center for Chronic Disease Prevention and Health 

Promotion, Office on Smoking and Health, 2000. 82–50179. 

• Lower-income Americans (family incomes at or below the national median) are 

more likely to quit smoking as a result of cigarette price increases than higherincome Americans. 

• Persons aged 18 through 24 years are more responsive to price increases than 

older smokers. 

• Hispanic smokers and non-Hispanic black smokers are more likely than white 

smokers to reduce or quit smoking in response to price increases.3

The 2000 Surgeon General’s Report, Reducing Tobacco Use, concluded: 

• ‘‘The price of tobacco has an important influence on the demand for tobacco 

products, particularly among young people.’’ 

• ‘‘Substantial increases in the excise taxes on cigarettes would have a considerable impact on the prevalence of smoking and, in the long term, reduce the adverse health effects caused by tobacco.’’ 4

Why might such advertising have harmful effects, especially for older teens? 

• Although parents are the stated audience for tobacco company advertising targeted to parents, youths are exposed to them, on average, at levels almost 

equivalent to those of state-sponsored anti-tobacco campaigns. 

• The message of the parent-targeted campaign is that parents should talk to 

their children about smoking, but no reason beyond simply being a teenager is 

offered as to why youth should not smoke. 

• Theories in developmental psychology suggest that authority messages specific 

to teenagers invite rejection by those who have migrated to a dominant peer 

group orientation as they make the transition to adulthood, typically between 

ages 15 to 17 years. 

Public health experts note that, if indeed tobacco companies wanted to make a 

positive contribution toward reducing youth tobacco use, the obvious first step would 

be to decrease or eliminate the billions of dollars the companies spend so effectively 

each year to advertise and promote tobacco use. 

Source: The Effect of Televised, Tobacco Company—Funded Smoking Prevention Advertising on Youth Smoking 

Wakefield, M., Terry-McElrath, Y., Emery, S., Saffer, H., Chaloupka, F.J., 

Szczypka, G., Flay, B., O’Malley, P.M., Johnston, L.D. (2006). ‘‘Effect of Televised, 

Tobacco Company—Funded Smoking Prevention Advertising on Youth Smoking-Related Beliefs, Intentions, and Behavior’’ American Journal of Public Health, Vol 96, 

No. 12, 2154–2160. http://www.ajph.org/cgi/content/ful1/96/12/2154. 

Disease Risks of Pipe, Cigar and Cigarette Use 

As previously stated (in Dr. Backinger’s testimony), all forms of tobacco products 

are harmful, including cigars and pipes.1 Because pipe use among Americans is 

much lower than the use of other tobacco products, there is limited research specifically on pipe smoking. Below is a summary of NCI funded research, along with information from additional studies, on how the health risks of smoking pipes or cigars, compares to that of smoking cigarettes. 

• Cigar and pipe smoking are strongly related to cancers of the mouth, 

oropharynx, hypopharynx, larynx and esophagus.234

• Cigar and pipe smoking are causally associated with lung cancer and there is 

evidence they are also causally associated with, pancreatic, stomach and urinary bladder cancer.2

• The risk of death from lung cancer is higher in pipe and cigar smokers than 

in non-smokers, but lower in pipe and cigar smokers than in cigarette smokers. 

This is because both pipe and cigar smokers typically smoke less tobacco and 

have a lower degree of inhalation.4 5

• The risk of lung cancer increases with the number of pipes or cigars smoked 

per day, and with the degree of smoke inhalation.5

72 

• Graph 1 below describes the difference in risks of dying from particular diseases 

for exclusive cigarette, pipe, and cigar smokers compared to nonsmokers. Among 

other things, the graph shows that: 

» Current pipe smokers are ∼5 times more likely to develop lung cancer than 

non-smokers while cigarette smokers are ∼20 times more likely to develop the 

disease. 

» Current pipe smokers are ∼14 times more likely to develop larynx cancer than 

non-smokers while cigarette smokers are ∼10 times more likely to develop the 

disease.6

Sources: Disease Risks of Pipe, Cigar and Cigarette Use 

1The Word Health Organization. (2006). Tobacco: Deadly in any form or disguise. Retrieved 

11/26/07 from http://www.who.int/tobacco/communications/events/wntd/2006/Tfil 

Rapport.pdf. 2The International Agency for Research on Cancer Monograph Volume 83. (2004). Tobacco 

Smoke and Involuntary Smoking. Retrieved 11/26/07 from http://monographs.iarc.fr/ENG/ 

Monographs/index.php. 3 National Cancer Institute. Cigars: Health Effects and Trends. Smoking and Tobacco Control 

Monograph No. 9. Bethesda, MD: U.S. Department of Health and Human Services, National Institutes of Health, National Cancer Institute, NIH Pub. No. 98–4302, February 1998. 4 U.S. Department of Health and Human Services. The Health Consequences of Smoking: Cancer. A Report of the Surgeon General. Washington: U.S. Department of Health and Human 

Services, Public Health Service, Office of Smoking and Health, 1982. DHHS Pub. No. (PHS) 82– 

50179. 5 U.S. Department of Health, Education, and Welfare. Smoking and Health. A Report of the 

Surgeon General. U.S. Department of Health, Education, and Welfare, Public Health service, Office of the Assistant Secretary for Health, Office on Smoking and Health, 1979. DHEW Pub. 

No. (PHS) 7950066. 6 Henley, S.J., Thun, M.J., Chao, A., Calle, E.E. (2004) Association between exclusive pipe 

smoking and mortality from cancer and other diseases. Journal of the National Cancer Institute, 

96(11). 


1113pipe.eps
73 

RESPONSE TO WRITTEN QUESTIONS SUBMITTED BY HON. FRANK R. LAUTENBERG TO

MARVIN E. GOLDBERG, PH.D. 

Question 1. The tobacco companies have claimed that smokers believe that the 

word ‘‘light’’ refers to taste. Is that true? Or is this just another device to seduce 

smokers into discarding care about their health in pursuit of their addiction? 

Answer. 

The tobacco industry has advanced the ‘‘taste’’ of low tar/lights cigarettes as the primary reason they are chosen by smokers. When questioned about the role of this 

false and illusory dimension of low tar/light smokers’ responses are often misleading. 

When smokers are asked why they smoke light cigarettes, significant numbers 

may respond that it is because of the ‘‘taste.’’ This is understandable—they first experience the cigarette on their tongue and in their mouth—the most apparent locus 

of taste. But research tells us that ‘‘taste’’ is a good deal more than what we experience on our tongue. Twenty years ago, the Coca Cola company was concerned about 

losing market share among young cola drinkers to Pepsi Cola. Research suggested 

that younger consumers appeared to prefer the slightly sweeter taste of Pepsi. In 

response, Coca Cola developed a sweeter version of their product and proceeded to 

extensively test market it in blind taste tests across the country. Repeatedly and 

reliably in blind taste tests, consumers indicated that they preferred the sweeter 

version to the regular Coke. With that evidence in hand, Coke introduced ‘‘New 

Coke’’ with the new, sweeter formula. What happened next was shocking to Coke. 

Once the product they were drinking was labeled Coke, that knowledge impacted 

how they evaluated what they tasted—now they hated it. Within 3 months Coke 

had retreated and was pushing its original formula ‘‘Classic’’ Coke again (Fournier 

1999; rev. 2001). 

That taste is, at least in part, a function of how products are portrayed/labeled 

and advertised has been carefully researched in the context of ‘‘field’’ experiments 

with foods. In one such experiment, the same lunch meals were sold in a university 

faculty cafeteria but were labeled differently on different days. For example, on 

some days one such meal was identified as ‘‘Succulent Italian Seafood filet’’ but on 

other days merely as ‘‘Seafood Filet.’’ Those who bought and ate the foods when they 

were described in an embellished way reported that: the foods were more appealing 

to the eye; they tasted significantly better; and after eating the meal they felt more 

‘‘comfortably full and satisfied.’’ (Wansink et al., 2004). 

Interestingly, when desserts were labeled ‘‘healthy’’ (e.g., chocolate pudding vs. 

healthy chocolate pudding; apple crisp vs. healthy apple crisp). they were rated as 

tastier. The researchers reasoned, that as long as the dessert actually tasted good, 

consumers’ initially lower expectations regarding something labeled ‘‘healthy’’ would 

be disconfirmed; that is, they would have been surprised by the good taste. Pleasantly surprised, the unexpected contrast between their actual and expected experience would have led them to evaluate the taste of the dessert more positively than 

someone who had seen the dessert label without the adjective ‘‘healthy;’’ (Wansink 

et al., 2004b). 

Smokers of regular cigarettes who switched to what they perceived to be 

‘‘healthier,’’ light cigarettes, would have had a parallel disconfirming experience. 

These smokers would have expected light cigarettes to yield less taste (along with 

less tar). However, given the compensatory smoking behavior described in my prepared testimony, light cigarettes yielded just as much tar/taste. As a result, the 

pleasantly surprised light cigarette smokers were quick to focus on the taste as the 

apparent motivation for smoking lights. 

As with the food experiments cited above, if questioned, smokers are almost certainly not going to be aware of how the label ‘‘light’’ (and hence the inference 

‘‘healthier’’) influence their perceptions of the cigarette’s taste. They revert to the 

more proximal evidence—what they believe they experience—on their tongues—and 

their answer as to why they smoke the cigarette they do smoke may reflect that 

logic. 

In two court cases where both Philip Morris and R.J. Reynolds sued Loews/ 

Lorillard, it was evident that these tobacco companies do not believe that smokers are primarily guided by taste in selecting light cigarettes. 

The plaintiff firms, Philip Morris and R.J. Reynolds argued that in a comparative 

taste test, smokers reported that the Lorillard low tar brand tasted better than the 

comparison brand only if they were first told that Lorillard’s brand had lower tar 

than either the R.J. Reynolds or the Philip Morris comparison brand. When (other) 

smokers made the same comparative taste test without being reminded of the relative tar levels, their taste preferences were very different. 

74 

The basis of both suits was the approach taken in two parallel Lorillard surveys 

asking smokers to compare the taste of its low tar ‘‘Triumph’’ to R.J. Reynolds’ Winston Lights and to Philip Morris’ Merit. Subsequent Lorillard advertising claimed 

that the preponderance of the smokers tested appeared to prefer the taste of Triumph over Winston Lights and that it was the ‘‘National Taste Test Winner’’ over 

Merit. Both plaintiffs Philip Morris and R.J. Reynolds argued that these claims 

were deceptive inasmuch as the taste question posed in each survey had, as a preface, a reminder of the lower tar scores for Triumph relative to those for Winston 

Light and for Merit. Each of the plaintiff companies ran a test of their own, where 

the tar scores for the two brands were not revealed and the resulting taste preferences in their research were very different. 

These comparisons suggest how much of what is ostensibly labeled as ‘‘taste’’ is 

influenced by other factors; in this case, the salience of how ‘‘light’’/low tar a cigarette might be. In effect, the plaintiff firms acknowledge that where smokers are reminded of tar yields, the relative tar levels and not taste are the determining factors 

in the smokers’ evaluations of the cigarettes; (R.J. Reynolds Tobacco Company, 

Plaintiff v. Loew’s Theatres, Inc; No. 80 Civ 4197 (RWS) United States District 

Court for the Southern District of New York; 511 F. Supp.867; 1980 U.S. Dist. 

LEXIS 16738; 210 U.S.P.Q. (BNA) 291; October 24, 1980; Philip Morris Incorporated, Plaintiff v. Loew’s Theatres, Inc.; No. 80 Civ. 4082 (RWS) United States 

District Court for the Southern District of New York; 511 F. Supp.855; 1980 U.S. 

Dist. LEXIS 12554 July 26, 1980). 

Of course, for decades the tobacco companies have used low tar/lightness as a critical way of selling cigarettes and have made that dimension very salient for smokers. Following the logic presented above, it is reasonable to expect that when respondents are asked, they may say that ‘‘taste’’ is the reason they prefer light/low 

tar cigarettes. Note, however, that following the logic of the two court cases discussed above, the causal sequence is, in fact, reversed. In actuality, it is because 

their cigarettes are light (and advertising and promotion continue to make that dimension salient) that smokers say they prefer the taste. They would not say so for 

the same cigarette, if its ‘‘lightness’’ was not made salient. 

Promoting light cigarettes as extensions of major brands and aligning them with the 

mother brand (e.g., Marlboros, Marlboro Lights), helped shaped smokers’ perceptions of their taste. 

At the same time as they developed light cigarettes that allowed for compensation, the tobacco companies learned how to boost the perceived strength of the taste, 

by using their advertising to shape the images associated with Lights. The companies viewed the taste dimension much as a ‘‘Rorschach ink blot test.’’ Light cigarette 

smokers could be induced to see/taste in the cigarettes what the companies wanted 

them to see/taste. 

. . . [I]t is almost impossible to know if the taste smokers talk about is something which they, themselves attribute to a cigarette or just a ‘‘play-back’’ of 

some advertising messages;’’ (Marketing and Research Counselors, Inc, 1975, p. 

2). 

The industry further understood that they could ‘‘borrow’’ some of the brand equity established for their primary (regular) brands such as Marlboro Reds and Camels for the benefit of the light cigarettes. They did so by creating brand extensions— 

Marlboro Lights, Camel Lights etc. and using the same advertising themes and imagery that had been so successful to shape the imagery associated with the light 

extensions. That this strategy could affect smokers perceptions of the light cigarettes taste, is recognized in their internal documents. 

. . . [O]ther free standing low tar brands such as Kent, Vantage, Carlton, etc. 

were perceived to be weaker and have less taste than the line extension low 

tars: like Marlboro Lights, Winston Lights, Camel Lights. Apparently these line 

extension low tars share the taste heritage of their parent full flavor brands; 

(Philip Morris 1990, pp. 13-14; emphasis added). 

When R.J. Reynolds sought to develop a low yield cigarette in 1976, they recognized the image problem associated with low-yield cigarettes and set out to address 

it: 

What we want is to portray the feeling and image projected by Marlboro and 

Kool advertising on a Vantage/Merit type of cigarette. In other words, put 

‘‘balls’’ (two of them) on a low ‘‘tar’’ and nicotine cigarette and position. (Hind 

et al., 1976, p. 63). 

75 

Question 2. If there were no cigarettes labeled as ‘‘light,’’ would the tobacco companies just come up with another word to send the same deceptive message to smokers? 

Answer. Forty-three countries, including Canada, Brazil, and the 27 countries of 

the European Union have banned the misleading terms such as ‘‘light’’ and ‘‘mild’’ 

(Backinger 2007). It would be useful to canvas the experiences these countries have 

had with the tobacco industry’s efforts to do an ‘‘end-run’’ around this prohibition. 

Casual observation on a trip to Canada suggests that the companies are substituting other words that will likely be used by smokers to distinguish between 

lights and regulars. If the same is true in other countries that have banned the use 

of ‘‘light’’ and ‘‘mild’’ it suggests that the advantages gained from this step are likely 

to be limited. 

One conclusion that ought to be drawn from the reasoning presented above is that 

the particular descriptors on the package are not necessarily the critical factor. 

Rather, the real issue is the question of the ultimate effect of any intended legislation. I have attached a paper by Kropp and Halpem-Fisher (2004) which I would 

like to go into the record. It indicates that, like adults, adolescents today believe 

that light cigarettes represent a reduced threat to smokers health relative to regular 

cigarettes. The goal of any legislation should be to turn this around. To this end, 

the tobacco companies should be required to develop a ‘‘corrective advertising’’ campaign advising smokers of the lack of any differences for their health between light 

and regular cigarettes. This campaign should continue as long as surveys of smokers 

show that the vast majority understand there is no difference in the risk to health 

from light versus regular cigarettes. While calling for corrective advertising may be 

more difficult legislatively, it is likely to be the most effective way to achieve the 

desired objective. 

References 

Backinger, Cathy, ‘‘Research Findings Concerning So-Called Low-Tar or ‘Light’ Cigarettes,’’ 

Presentation before the Senate Commerce, Science and Transportation Committee; U.S. Senate, 

Nov. 13, 2007, available at http://hhs.gov/asl/testify/2007/11/t20071113a.html (accessed Nov. 

24, 2007). 

Kropp, Rhonda and Bonnie, L. Halpern-Felsher (2004) ‘‘Adolescents’ Beliefs About the Risks 

Involved in Smoking ‘light’ Cigarettes,’’ Pediatrics 114(4) 445–451. 

Pediatrics—Official Journal of the American Academy—Vol. 114 No. 4, October 2004, pp. e445–e451 

ADOLESCENTS’ BELIEFS ABOUT THE RISKS INVOLVED IN SMOKING ‘‘LIGHT’’ 

CIGARETTES

By Rhonda Y. Kropp, B.S.N., M.P.H. and Bonnie L. Halpern-Felsher, Ph.D. 

ABSTRACT. Background. Light cigarettes have been marketed by the tobacco industry as being a healthier smoking choice, a safe alternative to cessation, and a 

first step toward quitting smoking altogether. Research, however, has failed to show 

a reduction in smoking-related health risks, an increase in rates of smoking cessation, a decrease in the amount of carbon monoxide or tar released, or a reduction 

in the rates of cardiovascular disease or lung cancer associated with light cigarette 

use, compared with regular cigarette use. Nevertheless, more than one-half of adolescent smokers in the United States smoke light cigarettes. This study is the first 

to investigate adolescents’ perception of the risks associated with smoking light cigarettes, as well as adolescents’ attitudes and knowledge about the delivery of tar and 

nicotine, health risks, social effects, addiction potential, and ease of cessation with 

light cigarettes, compared with regular cigarettes. 

Design. Participants were 267 adolescents (mean age: 14.0 years) who completed 

a self-administered questionnaire during class time. After reading scenarios in 

which they imagined that they smoked regular or light cigarettes, participants estimated the chances that they would personally experience 7 smoking-related health 

risks and 3 addiction risks. Participants also responded to 14 items concerning their 

attitudes and knowledge about light cigarettes versus regular cigarettes. 

Results. Participants thought that they would be significantly less likely to get 

lung cancer, have a heart attack, die from a smoking-related disease, get a bad 

cough, have trouble breathing, and get wrinkles when smoking light cigarettes, compared with regular cigarettes, for the rest of their lives. Furthermore, when participants were asked how long it would take to become addicted to the 2 cigarette 

types, they thought it would take significantly longer to become addicted to light 

versus regular cigarettes. Adolescents also thought that their chances of being able 

to quit smoking were higher with light versus regular cigarettes. Similarly, when 

participants were asked how easy it would be to quit smoking the 2 cigarette types, 

76 

they thought it would be significantly easier for them to quit smoking light cigarettes than regular cigarettes. Adolescents agreed or strongly agreed that regular 

cigarettes deliver more tar than light cigarettes and that light cigarettes deliver less 

nicotine than regular cigarettes. 

Conclusions. Overall, the results of this study show that adolescents hold 

misperceptions in both their personal risk estimates and their general attitudes 

about the health risks, addictive properties, and ease of cessation associated with 

light cigarettes. With a variety of light and ultra light cigarettes on the market, adolescents are led to think that there is a progression of safety levels to choose from 

when deciding which cigarettes to smoke. This illusion of control over health outcomes contributes to an underestimation of risks associated with smoking light cigarettes and supports these misperceptions. These results are of concern, given evidence suggesting that, if adolescents think they are less vulnerable to smoking-related health risks (i.e., lung cancer), then they are more likely to initiate smoking. 

Furthermore, there is evidence that adolescents are not fully aware of the addictive 

nature of cigarettes and therefore think that they can experiment with smoking during adolescence without becoming addicted or experiencing any health consequences. 

The data presented here support concerns regarding smoking addiction; adolescents 

might be even more inclined to smoke light cigarettes to delay addiction. Without 

correct information about light cigarettes, adolescents are unable to make informed 

decisions about their smoking behaviors. The findings presented here strongly suggest that healthcare practitioners need to talk to their adolescent clients not only 

about the overall risks of smoking but also about the specific risks associated with 

smoking light cigarettes and other tobacco varieties, including the potential for addiction and long-term health consequences. Information shared with adolescents 

about light cigarettes, both individually by healthcare practitioners and at the population level via counter-advertising campaigns, may be successful in changing current misperceptions, and ultimately light cigarette smoking patterns, among youth. 

Light cigarettes were introduced in the 1950s in response to growing public concern about the health effects of smoking. Light cigarettes have been marketed by 

the tobacco industry as being a healthier smoking choice, a safe alternative to cessation, and a first step toward quitting smoking altogether. Research, however, has 

failed to show a reduction in smoking-related health risks,1 2 an increase in rates 

of smoking cessation,3 4 a decrease in the amounts of carbon monoxide,256 or tar 2

released, or a reduction in the rates of cardiovascular disease or lung cancer 1 7 as- sociated with light cigarette use, compared with regular cigarette use. Nevertheless, 

a recent national survey of smokers found that 58.5 percent of adult smokers and 

52.8 percent of adolescent smokers reported using light cigarettes.8

Despite clear data showing that light cigarettes are not a safe alternative to 

smoking, adults in the United States harbor misperceptions about the health risks 

associated with smoking light and ultra light cigarettes,2 9–13 with a large proportion 

of adult smokers thinking that such cigarettes deliver less tar and nicotine, produce 

milder sensations, reduce the health risks associated with smoking, and assist with 

smoking cessation.10 11 No research has explored attitudes, beliefs, and perceptions 

of risk regarding light cigarettes among adolescents. If adolescents, like adults, 

think that light cigarettes are less risky to their health and are easier to quit than 

regular cigarettes, then they too may be more willing to try and to continue smoking 

these perceived ‘‘safer’’ cigarettes. This assertion is supported by theories indicating 

that perceptions of risk are related to engagement in both health-compromising and 

health-promoting behaviors.14–22

The present study addresses this gap in the literature by exploring adolescents’ 

perceptions of the risks associated with smoking light cigarettes. In addition, we assessed adolescents’ attitudes and knowledge about the delivery of tar and nicotine, 

health risks, social effects, addiction potential, and ease of cessation when smoking 

light cigarettes, compared with regular cigarettes. We hypothesized that adolescents 

would perceive light cigarettes to be less harmful to their health, to be less addictive, and to deliver less tar and nicotine than regular cigarettes. If these assertions 

are supported, than efforts to prevent adolescents’ tobacco use must include specific 

communication about the harmful nature of light cigarettes, in addition to all cigarette and tobacco varieties. 

Methods 

Participants 

Participants were 267 adolescents (mean age: 14.0 years; SD: 1.49 years) participating in a larger longitudinal study on the relationship between risk perceptions 

and tobacco use. The participants were ethnically diverse, with 56.8 percent of the 

participants describing themselves as white/non-Hispanic, 18.5 percent as Asian, 

18.5 percent as Hispanic or Latino, 2.3 percent as Pacific Islander, 1.2 percent as 

77 

African American, 1.5 percent as American Indian/Alaskan Native, and 1.2 percent 

as other. Participants’ mothers’ education, on average, was high, with 17.9 percent 

of the mothers having a professional degree, 6.1 percent having some education 

after college, 25.1 percent having a 4-year college degree, 20.5 percent having at 

least some college education, and 19.4 percent having a high school degree or less; 

9.9 percent of the participants reported that they did not know their mothers’ education. 

Participant Recruitment 

Participants in the larger study were recruited from 2 northern California public 

high schools (schools A and B), during their 9th grade year, to take part in a longitudinal study of tobacco beliefs and smoking behaviors. Participants in school A 

were recruited in autumn 2001, and those in school B were recruited in autumn 

2002. Interested participants signed the adolescent assent form, and parents signed 

the parental consent form. Of the 790 students who received consent packets (302 

from school A and 488 from school B), 418 (53 percent) returned completed consent 

forms (79.5 percent and 36.5 percent consent rate for schools A and B). Of the 790 

students who received consent packages, a total of 395 adolescents completed the 

baseline survey, for an overall response rate of 50 percent (75.5 percent response 

rate for school A and 34.2 percent response rate for school B). 

Perceptions of light cigarettes were assessed in spring 2003, which corresponded 

to the second (school B, 9th grade) and fourth (school A, 10th grade) rounds of data 

collection; therefore, only those rounds of data are reported in this article. Overall, 

200 participants from school A completed the fourth-round survey and 152 participants from school B completed the second-round survey, for a total of 352 participants (89.4 percent retention rate). Only participants who indicated that they had 

heard of light cigarettes were included in the analyses for the current report (n = 

267), accounting for 75.8 percent of the total sample. There were no significant differences between the 2 schools with respect to gender or age at the time of recruitment; however, significant differences were found with respect to ethnicity (X2 = 

57.3, df = 3, P < .001) and mother’s education (X2 = 19.7, df = 8, P < .05), with 

1 school (school B) having fewer white/non-Hispanic students and lower levels of 

mothers’ education. However, we did not find any significant differences in the results for these 2 schools or any differences based on age; therefore, data for the 2 

schools were combined. 

Procedures 

Participants completed a self-administered questionnaire during class time. The 

researchers explained the instructions for completing the survey and remained 

available to answer questions that arose during administration. Refreshments were 

provided for all participants. Participants in school A also received a movie gift certificate, whereas the administrators and teachers in school B received school supply 

money to compensate for their efforts in the study. The study received approval 

from the University’s institutional review board. 

Measures 

Demographic Features 

Participants provided information about their age, grade, gender, ethnicity, and 

mother’s level of education. 

Smoking Behaviors 

Participants were asked about the number of times they had ‘‘smoked a few puffs 

of a cigarette’’ in their entire lives, with responses being made on a 5-point scale 

(i.e., none, 1 time, 2–5 times, 6–10 times, or > 10 times).¢ 

Chance Estimates of Personally Experiencing Smoking-Related Risks 

Participants read 2 scenarios about smoking cigarettes in general (proxy for regular cigarettes) and then 2 scenarios about smoking light cigarettes. The scenarios 

were identical except for the specification of light cigarettes. The first scenario asked 

participants to imagine that they had just begun smoking cigarettes (i.e., ‘‘Imagine 

that you just began smoking. You smoke ∼2 or 3 [light] cigarettes each day. Sometimes you smoke alone, and sometimes you smoke with friends.’’). After reading this 

scenario, participants estimated the chances that they would personally experience 

5 smoking-related risks (Tables 1 and 2). 

78 

Table 1.—Comparison of Adolescents’ Estimates of Personal Risk and Benefit With Regular Versus Light 

Cigarettes: Mean-Level Analyses 

Risk estimates, mean (SD) t Value 

Regular cigarettes Light cigarettes 

Short-term cigarette use 

Risks 

Smell like an ashtray 79.81 (27.29) 79.04 (26.66) 0 .822 

Get a bad cough from smoking 71.93 (28.17) 69.97 (28.24) 1 .56 

Have trouble catching your breath 71.56 (28.59) 71.20 (27.85) 0 .325 

Have many really bad colds 58.09 (30.42) 60.07 (30.62) 1 .52 

Have bad breath 78.43 (29.61) 75.64 (29.74) 2 .16 * 

Addiction 

Become addicted to cigarettes 69.07 (30.30) 66.98 (30.13) 1 .32 

Still be smoking in 5 y 57.32 (32.42) 59.76 (31.18) 1 .45 

Be able to quit smoking 45.82 (32.98) 50.19 (32.20) 2 .53 † 

How long will it take to become 

addicted ‡ 2.98 (1.18) 3.17 (1.15) 3 .73 § 

How easy will it be for you to quit smoking || 3.64 (1.08) 3.41 (1.06) 4 .59 § 

Long-term cigarette use 

Risks 

Get lung cancer 73.04 (25.22) 70.89 (27.03) 1 .79 ¶ 

Die from lung cancer 68.80 (26.92) 68.35 (26.87) 0 .356 

Get a bad cough from smoking 75.52 (25.31) 74.06 (25.60) 1 .45 

Have trouble catching your breath 76.36 (24.16) 74.69 (26.62) 1 .50 

Have a heart attack 67.66 (25.51) 65.15 (26.35) 2 .12 * 

Get wrinkles on your face 79.74 (24.13) 78.44 (25.50) 1 .159 

Die from a smoking-related 

disease 73.13 (25.36) 70.53 (26.89) 2 .30 * 

*P < .05; † P < .01; § P < .001; ¶ P < .10. ‡ Response scale for this question: will not happen (1); ≥ 1 month (2); 1 to 6 months (3); 7 to 11 months (4); 1 to 2 years (5); 3 to 

4 years (6); ≥ 5 years (7). || Response scale for this question: very easy (1); somewhat easy (2); a little easy (3); not very easy (4); not at all easy (5). 

Table 2.—Comparison of Adolescents’ Estimates of Personal Risk and Benefit With Regular Versus Light 

Cigarettes: Individual-Level Analyses 

Percent of participants indicating 

More likely for 

regular cigarettes No difference 

More likely 

for light 

cigarettes 

Short-term cigarette use 

Risks 

Smell like an ashtray 23.9 55.7 20.5 

Get a bad cough from smoking 33.2 41.7 25.1 

Have trouble catching your breath 27.7 44.6 27.7 

Have many really bad colds 26.0 41.6 32.4 

Have bad breath 31.9 48.7 19.4 

Addiction 

Become addicted to cigarettes 34.4 37.4 28.2 

Still be smoking in 5 y 31.8 34.1 34.1 

Be able to quit smoking 23.7 38.5 37.8 

How long will it take to become 

addicted 8.4 66.2 25.5 

How easy will it be for you to quit 

smoking 31.1 60.6 8.3 

Long-term cigarette use 

Risks 

Get lung cancer 29.8 46.6 23.7 

Die from lung cancer 29.2 43.1 27.7 

Get a bad cough from smoking 33.0 45.6 21.5 

Have trouble catching your breath 29.9 46.4 23.8 

Have a heart attack 36.6 40.1 23.3 

Get wrinkles on your face 31.2 48.5 20.4 

Die from a smoking-related disease 40.6 38.3 21.1 

Next, participants were asked to imagine that they continued to smoke cigarettes 

for the rest of their lives (ie, ‘‘Now imagine that you continued to smoke ∼2 or 3 

[light] cigarettes each day for the rest of your life.’’). After reading this scenario, participants estimated the chances that they would personally experience 7 smokingrelated health risks (Tables 1 and 2). 

Participants’ chance estimates were provided as any percentage between 0 percent 

and 100 percent. The quantitative response scale (0–100 percent) was chosen over 

scales that use lexical probability terms (such as ‘‘likely’’ and ‘‘probably’’) to estimate 

79 

risk because of the great variability in meaning ascribed to these terms by adolescents.23–25

Estimates of Addiction 

After reading the scenario concerning short-term cigarette use (as described 

above), participants estimated the chances (0–100 percent scale) that they would 

personally experience 3 addiction risks (Tables 1 and 2). Participants were also 

asked about the ease of cessation (ie, ‘‘If you smoke ∼2 or 3 [light] cigarettes each 

day, how easy will it be for you to quit smoking?’’), with responses being made on 

a 5-point scale ranging from ‘‘very easy’’ to ‘‘not at all easy.’’ Finally, participants 

reported on the length of time until addiction (ie, ‘‘If you smoke ∼2 or 3 [light] cigarettes each day, how long do you think it will take until you become addicted to 

[light] cigarettes?’’), with responses being made on a 7-point scale ranging from ‘‘will 

not happen’’ to ‘‘5 or more years.’’ 

Attitudes and Knowledge About Light Cigarettes 

Participants responded to 14 items concerning their attitudes and knowledge 

about light cigarettes versus regular cigarettes in 4 categories, ie, delivery (amount 

of tar and nicotine; 2 items), health risks (5 items), perceived social outcomes (5 

items), and addiction/cessation (2 items) (Table 3). Participants responded to each 

item on a 4-point scale, ranging from ‘‘strongly agree’’ to ‘‘strongly disagree.’’ Participants also had the opportunity to indicate that they did not know how to answer 

each question. 

Table 3.—Comparison of Adolescents’ Attitudes and Knowledge Regarding Regular and Light Cigarettes 

Statement on regular versus light 

cigarettes Mean (SD) * 

Percent of participants indicating 

Strongly 

agree Agree Disagree Strongly disagree 

Don’t 

know 

Delivery 

Regular cigarettes deliver more tar 2.04 (0.77) 18.8 45.5 13.9 4.1 17.7 

Light cigarettes deliver less 

nicotine 2.54 (0.87) 6.9 33.1 23.8 11.9 24.2 

Health risks 

Regular cigarettes are more likely 

to cause a heart attack 2.60 (0.83) 6.9 28.4 33.3 10.7 20.7 

Regular cigarettes are more likely 

to cause lung cancer 2.57 (0.87) 8.4 28.7 29.9 11.5 21.5 

Regular cigarettes are more likely 

to cause a bad cough 2.66 (0.86) 5.7 29.7 28.9 14.1 21.7 

Light cigarettes are more likely to 

cause trouble catching your 

breath 2.90 (0.78) 4.6 13.4 43.5 14.9 23.7 

Regular cigarettes are less likely to 

cause wrinkles on the face 3.12 (0.83) 4.5 8.0 36.0 25.8 25.8 

Perceived social benefits 

Smoking light cigarettes looks 

cooler 3.42 (0.74) 2.7 5.4 32.2 47.7 12.0 

Smoking light cigarettes makes 

you thinner 3.04 (0.83) 4.2 8.8 33.5 20.0 33.5 

Smoking regular cigarettes is more 

likely to make you smelllike an 

ashtray 2.86 (0.89) 6.8 20.5 36.4 22.3 14.0 

Smoking a regular cigarette makes 

you feel more relaxed 2.84 (0.88) 5.7 14.1 30.9 14.9 34.4 

Smoking light cigarettes looks 

more grown-up 3.21 (0.81) 4.2 8.3 37.9 34.8 14.8 

Cessation 

It is easier to quit smoking light 

cigarettes 2.71 (0.86) 6.4 25.3 33.2 15.1 20.0 

Regular cigarettes are more 

addictive 2.69 (0.90) 6.9 28.7 28.0 17.2 19.2 

* Response scale for this question: strongly agree (1), agree (2), disagree (3), strongly disagree (4). Participants could also indicate 

if they did not know. 

Results 

Preliminary Analyses 

Before conducting the main study analyses, we conducted analyses to determine 

whether perceptions of light versus regular cigarettes varied according to smoking 

experiences. We had only 84 participants who had ever tried a cigarette, even a 

puff, and 61 adolescents who reported having ever smoked a light cigarette. Furthermore, the number of times participants had tried a cigarette varied greatly, 

80 

with 18 adolescents having tried a cigarette 1 time, 24 adolescents having tried a 

cigarette 2 to 5 times, 11 adolescents having tried a cigarette 6 to 10 times, and 

31 adolescents having smoked > 10 times. Therefore, the sample sizes with variations in smoking experiences were too small to allow a meaningful analysis according to smoking group. However, because perceptions of risk vary with the number 

of times an adolescent has smoked,21 we did examine the correlation between the 

number of times the adolescent had smoked and differences in perceptions of light 

versus regular cigarettes. None of these correlations was significant; therefore, data 

were combined across smoking experiences. 

Perceptions of Smoking-Related Risks With Light Versus Regular Cigarettes 

Paired t tests were used to examine our hypothesis that adolescents perceive less 

risk if they smoke light cigarettes, compared with regular cigarettes. Given the literature showing that adults perceive light cigarettes as less harmful and addictive 

than regular cigarettes and our directional hypothesis that adolescents would demonstrate similar if not greater bias, we used 1-tailed, directional t tests. 

As indicated in Table 1, adolescents did not perceive a significant difference in 

the chances of experiencing 4 of the risks (i.e., bad cough, trouble catching breath, 

bad colds, and smell like an ashtray) with short-term use of regular versus light 

cigarettes. Adolescents did think the risk of having bad breath was higher with regular versus light cigarettes (P = .032). Importantly, participants did think that they 

would be significantly less likely to get lung cancer (P = .075), have a heart attack 

(P = .036), and die from a smoking-related disease (P = .022) when smoking light 

cigarettes versus regular cigarettes for the rest of their lives. No differences were 

found in chance estimates of dying from lung cancer, getting a bad cough, having 

trouble breathing, or getting wrinkles with the 2 cigarette types. 

Perceived risk of becoming addicted and still smoking in 5 years did not differ significantly between regular and light cigarettes in the short-term tobacco use scenario. However, when participants were asked about their perceived ability to quit 

smoking the 2 cigarette types, they thought that their chance of being able to quit 

smoking was greater with light versus regular cigarettes (P = .012). Adolescents also 

thought it would take significantly longer to become addicted to light versus regular 

cigarettes (P < .0001) (Table 1). Similarly, when participants were asked how easy 

it would be to quit smoking the 2 cigarette types, they thought that it would be significantly easier for them to quit smoking light cigarettes than regular cigarettes 

(P < .0001) (Table 1). 

Because many of the results were not significant, we conducted a power analysis 

to confirm that we had adequate power to detect differences in perceptions of light 

versus regular cigarettes. With an α of .05 for a 1-tailed t test, we found that, with 

a sample size of 267, we had adequate power of .74 to detect small effects.26 Therefore, we do not think that the lack of significance was attributable to sample size. 

It was also important to determine the actual percentage of participants who incorrectly thought that regular cigarettes are more harmful and addictive than light 

cigarettes. Therefore, each individual was assigned a score for each outcome, corresponding to whether they thought the outcome was more likely to occur with regular cigarettes (+1) or with light cigarettes (¥1) or was equally likely to occur with 

regular or light cigarettes (0). As shown in Table 2, while > 40 percent of participants on average gave equal estimates of risk outcomes (bad cough, trouble catching 

breath, bad colds, and bad breath) for regular and light cigarettes, between 26 percent and 33 percent thought that these outcomes were more likely to occur when 

beginning to smoke regular cigarettes, compared with light cigarettes, and between 

19 percent and 32 percent viewed these outcomes as more likely with light cigarettes. 

A large proportion of the participants (between 29 percent and 41 percent) 

thought that they were more likely to experience a number of negative health outcomes (lung cancer, heart attack, death from a smoking-related disease, bad cough, 

trouble breathing, and getting wrinkles) if they smoked regular cigarettes, compared 

with light cigarettes, for the rest of their lives. Importantly, 40.6 percent thought 

that they were more likely to die of a smoking-related disease with regular cigarettes than with light cigarettes, whereas only 21.1 percent thought that the risk 

was higher for light cigarettes and 38.3 percent did not perceive a difference in risk 

between the 2 cigarette types. A large percentage of the participants thought that 

addiction was less likely with light cigarettes. For example, 34.4 percent thought 

that they were more likely to become addicted to regular cigarettes than to light 

cigarettes, and 37.8 percent thought that it would be easier for them to quit smoking light cigarettes than regular cigarettes (Table 2). 

81 

Attitudes and Knowledge About Light Cigarettes 

Participants were asked how strongly they agreed or disagreed with a series of 

14 statements comparing regular and light cigarettes in terms of the amounts of tar 

and nicotine delivered, health effects, social benefits, and addictive properties. Table 

3 shows the average scale responses for each item, as well as the proportions of participants who strongly agreed, agreed, disagreed, and strongly disagreed with each 

statement. In terms of delivery, 64.3 percent of the adolescents agreed or strongly 

agreed that regular cigarettes deliver more tar than light cigarettes and 40.0 percent thought that light cigarettes deliver less nicotine than regular cigarettes. Adolescents had similar misperceptions about the health risks associated with light 

cigarettes, with a large proportion of participants agreeing or strongly agreeing that 

smoking regular cigarettes is more likely to cause lung cancer (37.1 percent), a 

heart attack (35.3 percent), and a bad cough (35.4 percent), compared with smoking 

light cigarettes; however, between 41 percent and 44 percent of the adolescents either disagreed or strongly disagreed with these statements. The majority of adolescents disagreed or strongly disagreed that they would look cooler (79.9 percent), become thinner (53.5 percent), or look more grown-up (72.7 percent) with light cigarettes, although almost 13 percent agreed or strongly agreed with these statements. 

A significant proportion of adolescents demonstrated misperceptions about the addictive properties and ease of cessation with light cigarettes, with 35.6 percent and 

31.7 percent agreeing or strongly agreeing that regular cigarettes are more addictive 

than light cigarettes and that light cigarettes are easier to quit than regular cigarettes, respectively. Between 45 percent and 48 percent of the adolescents disagreed 

or strongly disagreed with those statements. It should be noted that, on average, 

22 percent of the participants stated that they did not know the answers to each 

of these knowledge questions. 

Discussion 

Light cigarettes, although marketed as a healthy alternative to regular cigarettes 

and as an aid to quitting smoking, in fact do not reduce the health risks associated 

with smoking 1 2 and do not increase rates of smoking cessation.3 4 Despite these 

facts, more than one-half of adolescent smokers in the United States smoke light 

cigarettes. The current study is the first to examine whether adolescents are aware 

of the true risks of smoking light cigarettes or whether their beliefs have been influenced by tobacco industry claims that light cigarettes are less harmful. Overall, the 

results of this study show that adolescents hold misperceptions in both their personal risk estimates and their general attitudes about the health risks, addictive 

properties, and ease of cessation associated with light cigarettes. These findings are 

similar to those outlined in studies with adult samples 2 9–13 and expand on those 

results by assessing perceived risk for a number of short- and long-term smoking 

outcomes in an adolescent population. 

On average, adolescents in this study thought that long-term use of light cigarettes was less likely to cause lung cancer, heart attacks, and death from a smokingrelated disease than was use of regular cigarettes. Adolescents also thought it would 

take longer to become addicted to light cigarettes and it would be easier to quit 

smoking light cigarettes, compared with regular cigarettes. Given that 64.3 percent 

and 40.0 percent of adolescents incorrectly thought that regular cigarettes deliver 

more tar and nicotine, respectively, than light cigarettes, these misperceptions about 

the health and cessation properties of light cigarettes are not surprising. With a variety of light and ultra light cigarettes on the market to choose from, adolescents 

are led to think that there is a progression of safety levels from which to choose 

when deciding which cigarettes to smoke. This illusion of control over the health 

outcomes contributes to an underestimation of risks associated with smoking light 

cigarettes and supports these misperceptions.27

Although some of the adolescents in this study were aware of the health risks and 

addictive properties associated with light cigarettes, the data clearly showed that 22 

percent of the adolescents were uncertain regarding the differences between regular 

and light cigarettes and between 25 percent and 35 percent of the adolescents 

thought that health risks were more likely with regular cigarette use than with 

light cigarette use. These results are of concern, given evidence suggesting that, if 

adolescents think they are less vulnerable to smoking-related health risks (i.e,, lung 

cancer), then they are more likely to initiate smoking.14–22 Furthermore, there is 

evidence that adolescents are not fully aware of the addictive nature of cigarettes 

and thus think that they can experiment with smoking during adolescence without 

becoming addicted or suffering any health consequences.22 27 The data presented 

here support concerns regarding smoking addiction; adolescents might be even more 

inclined to smoke light cigarettes to delay addiction. 

82 

Adolescents’ misperceptions about the health and cessation properties of light 

cigarettes mirror marketing by the tobacco industry. In fact, it has been shown that 

adolescent’ smoking intentions 28 and behavior 29 are heavily influenced by the 

multimedia smoking campaigns launched by the tobacco industry. This is supported 

in part by our results showing significant differences in risk perceptions for light 

versus regular cigarettes in smoking outcomes most countered by pro-tobacco campaigns marketing light cigarettes (e.g., healthier or a first step to cessation), whereas adolescents perceived less difference in outcomes not focused on by tobacco media 

(e.g., cough and wrinkles), although the effects of media exposure were not specifically evaluated in this study. 

Healthcare practitioners’ efforts to dispel adolescents’ inaccurate beliefs about 

light cigarettes may be informed by the success of light cigarette counter-advertising, which has been shown to be effective in changing knowledge 30–33 and intentions to quit smoking 31 33 among adults. Interestingly, a limited number of studies 

suggest that messages that focus on dispelling myths about the sensation of light 

cigarettes (‘‘feel milder,’’ ‘‘feel smoother,’’ or ‘‘less harsh’’) may be more effective than 

those providing factual information about tar and nicotine delivery, blocked vents, 

or health outcomes related to smoking light cigarettes among adults.32 33

A number of study limitations need to be discussed. First, questions concerning 

personal risk estimates did not ask specifically about regular cigarettes but instead 

asked about cigarettes in general. These general cigarette questions were juxtaposed 

with questions specifically about light cigarettes and were therefore treated as a 

proxy for questions about regular cigarettes. However, if some adolescents interpreted ‘‘cigarettes’’ as other than regular cigarettes, then they would likely have 

been considering light cigarettes when answering these questions, which would result in an underestimation rather than overestimation of perceived risk differences. 

Second, the order of the questioning about regular and light cigarettes was not 

counterbalanced. The results were consistent with the adult literature on light cigarettes and with hypotheses that adolescents perceive light cigarettes as less harmful 

and addictive. Therefore, we do not think that participants’ responses were influenced by the order of the questions, although we cannot be certain. Third, because 

of the small numbers of smokers and light cigarette smokers in this sample, we 

were unable to explore differences in attitudes and risk perceptions between smokers and nonsmokers or between light cigarette smokers and nonsmokers. Such analyses have yielded interesting results in studies of adults,11 and similar exploration 

among adolescents is needed. Last, the cross-sectional nature of this analysis did 

not allow investigation of potential links between risk perceptions, attitudes, and 

smoking initiation, cessation, or cigarette brand choices. 

Conclusions 

This study has demonstrated that adolescents harbor misperceptions about the 

health risks, addictive properties, and ease of cessation associated with light cigarettes. Such misperceptions have the potential to influence adolescents’ intentions 

to initiate and quit smoking, thereby increasing the number of adolescent smokers 

in the United States. Without correct information about light cigarettes, adolescents 

are unable to make informed decisions about their smoking behaviors. The findings 

presented here strongly suggest that healthcare practitioners need to talk to their 

adolescent clients not only about the overall risks of smoking but also about the specific risks associated with smoking light cigarettes and other tobacco varieties, including the potential for addiction and long-term health consequences. Information 

shared with adolescents about light cigarettes, both individually by healthcare practitioners and at the population level via counter-advertising campaigns, may be successful in changing current misperceptions, and ultimately light cigarette smoking 

patterns, among youths. 

Acknowledgments 

This research was supported in part by grants awarded to B.L.H-F. from the Tobacco-Related Disease Research Program, Office of the President, University of California (grant 9K–0072), the University of California, San Francisco, Academic Senate Committee on Research, and the Raschen-Tiedenann Fund from the Research 

Evaluation and Allocation Committee, School of Medicine, University of California, 

San Francisco. 

We gratefully acknowledge the contributions of Michael Biehl, Tricia Michels, Jodi 

Cornell, Holly Sigler, Eric Peterson, Dr. Jeanne Tschann, and 2 anonymous reviewers. We also thank Dr. Gary Giovino and Dr. Michael Cummings for kindly sharing 

their data on the prevalence of light cigarette use in the United States and Jun 

Yang for performing the analyses of the National Household Survey on Drug Abuse 

83 

data. We are also grateful to all of the study participants and their parents, as well 

as the schoolteachers and school administrators who contributed to this study. 

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84 

* This paper is retained in the Committee’s files. 

33Shiffman, S., Pillitteri, J.L., Surton, S.L., Rohay, J.M., Gitchell, J.G. Effect of health messages about ‘‘light’’ and ‘‘ultra light’’ cigarettes on beliefs and quitting intent. Tob Control. 2001; 

10(suppl. 1):i24–i32 

PREPARED STATEMENT OF R.J. REYNOLDS TOBACCO CO. 

R.J. Reynolds Tobacco Co. is pleased to provide comments for the Committee’s 

hearing on the accuracy of the Federal Trade Commission’s (FTC) ‘‘tar’’ and nicotine 

rating system for cigarettes. 

R.J. Reynolds, the FTC and the public health community agree that the FTC test 

does not and cannot predict the actual amount of ‘‘tar’’ and nicotine an individual 

smoker receives. It is widely accepted that machine test yields based upon a single 

smoking regime, like that prescribed by the FTC Method, do not equate to what an 

average consumer obtains from smoking. 

According to the 1967 press release announcing adoption of the FTC Method, the 

testing determines ‘‘the amount of tar and nicotine generated when a cigarette is 

smoked by a machine in accordance with the prescribed method.’’ The same FTC 

press release stated that the method was not intended to ‘‘duplicate conditions of 

actual humans smoking,’’ or gauge ‘‘the amount of smoke, or tar and nicotine, which 

the ‘average’ smoker will draw from any particular cigarette. . . .’’ 

While the fundamental limitations of the FTC Method have not changed since 

adopted some forty years ago, the relevance of machine yields to actual or average 

consumer yields has been extensively and publicly examined. Expert panels have 

been convened by the National Cancer Institute and the World Health Organization. 

A range of studies identifying the deficiencies of existing methods as well as potential alternative testing regimes have been published. A paper reviewing the recent 

advances and better understanding of these issues, authored in part by a R.J. Reynolds Tobacco Co. scientist, is attached * and made part of this testimony. (Attachment: Dixon, M. and Borgerding, M.F. (2006) Recent advances in the application 

and understanding of alternative smoking regimes. Rec. Adv. Tob. Sci. 32, 3–83.) 

While no machine-test can mimic all human behaviors, the key to progress in this 

area should be development of a standard, smoking machine-based test method for 

cigarettes that more closely models the variability of smoke yields under conditions 

of consumer use. Clearly, this should begin with the body of scientific work that has 

already been completed. As active participants in this debate and process, we would 

welcome the opportunity to participate in the Committee’s efforts to establish a robust and realistic testing standard that can be widely applied. 

R.J. Reynolds Tobacco Co. has a keen interest in advancing the testing methodology for cigarettes. We have been an active participant in the world-wide debate 

over the emerging issues. We welcome an open, scientifically-based discussion on 

these issues as part of a broader discussion of the methods of potential harm reduction of tobacco products. We believe decreasing the health risks and harm directly 

associated with the use of tobacco products is in the best interests of our society. 

Æ