The Fire Safe Cigarette Act of 1990 (Pub. L. 101-352; 104 Stat. 405)
responds directly to those recommendations. It directed the Commission and the
National Institute of Standards and Technology (NIST) to complete the research
recommended by the Technical Study Group and to assess the practicability of
developing a performance standard to reduce cigarette ignition propensity. {A
copy of the Act is included at Appendix B.) The following tasks were assigned:

To be Completed by the National Institute of Standards and Technology:

° develop a standard test method to determine cigarette ignition
propensity,

° compile performance data for cigarettes using this test method, and

° conduct laboratory studies on and computer modeling of ignition physics to
develop valid, user-friendly predictive capability.

To be Completed by the Commission:

° design and implement a study to collect baseline and follow-up data about
the characteristics of cigarettes, products, and smokers involved in fires,

o develop information on societal costs of cigarette fires, and

° develop information on changes in the toxicity of smoke and resultant health
effects from cigarette prototypes {in consultation with the Secretary of
Health and Human Services, and at a cost of not more than $50,000).

The Fire Safe Cigarette Act also established a Technical Advisory Group
(TAG) to advise and assist the Commission and NIST in carrying out their work.
The membership of the TAG consisted primarily of the same members who had
served on the earlier Technical Study Group. The TAG met regularly throughout
the course of the Act, actively participated in assessing the progress of the various
tasks, and prepared a final advisory report that appears separately at Appendix A.

This is the third and final report required by the Fire Safe Cigarette Act. It
describes the work undertaken to complete the tasks set forth above and assesses
the practicability of developing a performance standard to reduce cigarette ignition
propensity. Separate volumes provide additional details about the technical work
on each task.


IV. Technical Advisory Group

The Fire Safe Cigarette Act established a Technical Advisory Group (TAG) to
advise and work with the Consumer Product Safety Commission and NIST on the
implementation of the Act. The members were, in general, the same individuals
who served on the Technical Study Group (TSG) for the Cigarette Safety Act of
1984.

The Technical Advisory Group met regularly and discussed every aspect of
the work in progress. Both NIST and Commission staff made regular presentations
about the progress of the work. In addition, several members of the TAG
representing cigarette manufacturers or their designated representatives presented
the results of research independently undertaken. Most of the industry
presentations were intended to raise doubts about the validity of the NIST test
method. In addition to the questions about air flow and fabric selection, which
have been discussed earlier in this report, the presentations were intended to
contradict some of the statistical conclusions from the earlier report of the
Technical Study Group in 1987.

The TAG issued a final advisory opinion about the research Pursued under
the Act and an assessment of the practicability of developing a performance
standard. The majority of the TAG supported the research findings. A minority,
almost always members representing the cigarette manufacturers, disagreed,
questioning primarily the adequacy of the test method developed by NIST. In
support of their opinion, the manufacturers introduced a large volume of oral and
written testimony. The TAG’s final advisory opinion includes a summary of both
majority and minority positions; they appear at Appendix A of this report.

23


F. Societal Cost of Cigarette Fires

Introduction

The Fire Safe Cigarette Act directed the Commission to “develop information
on the societal costs of cigarette-ignited fires." Volume 6 of this report presents a
summary of the latest available data on the estimated economic costs of deaths,
injuries and property damage resulting from structural fires started with smoking
materials. These are the costs most likely to be significantly affected by action to
reduce the ignition propensity of commercial cigarettes. The estimates do not
include other costs to the public associated with fires and fire safety but less
directly related to cigarette-ignited fires.

A substantial amount of new information regarding the cost of injuries was
accumulated for this task. Greatly improved estimates of costs associated with
fatal and non-fatal burn, anoxia and other injuries were developed, including
estimated medical costs, transport costs, productivity losses, pain and suffering,
and legal and health insurance administrative costs. The estimates, presented in
summary below, are reasonably applicable to injuries resulting from cigarette-
ignited fires. Estimates for the numbers of fatalities and non-fatal injuries and for
property damage are from CPSC’s Directorate for Epidemiology, the U.S. Fire
Administration, and the National Fire Protection Association.

Estimated Societal Costs

During 1990 the total cost of cigarette-ignited fire deaths, injuries and
property damage was estimated at approximately $4.0 billion (in 1992 dollars,
excluding costs associated with public expenditures on fire protection, firefighting
services, and other costs less directly associated with or affected by cigarette-
ignited fires). This comprises over 1,200 deaths and nearly 7,000 treated civilian
and firefighter injuries in residential and non-residential smoking fires (99 percent of
total estimated injury costs -- and virtually all deaths -- involve civilian casualties)
as well as nearly $0.5 billion in property damage. Fatal injuries account for about
$2.5 billion (60 percent) of this total; hospitalized, non-fatal injuries -- chiefly
thermal burns and anoxia -- account for over $1.0 billion. Estimated total annual
costs for all injuries are shown in Table 1; detailed cost components on a per-case
average basis are estimated in Table 2.

19


comprehensive four-tiered sequential series of tests and a more practical first-step
alternative. A limited number of cigarettes were tested using the first step
alternative series.

The Commission finds that the panel of health experts established the
framework for a reasonable evaluation of the toxicity of low ignition potential
cigarettes. Candidate prototypes could be compared with the brand they would
replace in the marketplace or with a standard reference cigarette. However,
additional technical work is necessary to establish the most reasonable series of
tests and to set appropriate acceptance criteria.

The importance of pairing a performance test for cigarette ignitability with a
corresponding assurance of no increased adverse health effects requires emphasis.
Toxicity testing is a necessary component of the development of a performance
standard for a reduced ignition potential cigarette. This aspect of developing a
performance standard will require more work than any other. Although cigarette
manufacturers face no current restrictions on the manufacture of cigarettes sold to
the public, if modifications to current cigarettes were required to make them less
likely to start fires, there would be an equal obligation to ensure that no increased
adverse health effects result.

4. Commercial Feasibility

Economic research pursued under the Cigarette Safety Act of 1984
established the technical feasibility of modifying cigarettes to increase ignition
resistance. Some of the changes were estimated to be achievable with only small
changes in the cost of producing cigarettes. The research did not examine the
acceptability of such cigarettes to smokers.

The current Act required no additional work on commercial feasibility, and
the legislative history makes it plain that none was intended. At meetings of the
TAG, several manufacturers have described several smoker acceptability tests that
they conducted using prototype ignition-resistant cigarettes. The results indicated
a low degree of smoker acceptability.

However, both the fire incident study and the NIST tests of commercial
cigarettes provide evidence that some cigarettes with a reduced ignition potential
are already in the marketplace. A degree of consumer acceptability has therefore
already been established.

5. Cost/Benefit

The Commission has made no estimates of the cost to the public of a
performance standard to reduce cigarette ignitability. The maximum benefits,

28




IL. ASSESSMENT OF THE PRACTICABILITY OF DEVELOPING A PERFORMANCE
STANDARD TO REDUCE CIGARETTE IGNITION PROPENSITY

The TAG has spent considerable time discussing how to provide you with technical advice on this
topic. We realize that, under the Consumer Product Safety Act (P-L. 92-573), tobacco and tobacco
products are specifically not included as consumer products. However, under the Fire Safe Cigarette
Act of 1990 (BL. 101-352), the Congress requires such an assessment. The TAG presumes that there
are some technical elements likely to be common to any regulatory process and that these are similar
to those used by the CPSC. CPSC staff have provided us with such a list, and these elements are
addressed below.

A. TEST METHOD TO CHARACTERIZE PRODUCT PERFORMANCE

Eleven members of the TAG recommend the use of the Mock-up Ignition Test Method for use in
a product performance standard for the reasons given under Task 1, above. While routine measure-
ment of the relative ignition propensity of cigarettes is feasible using either of the two methods, this
method is preferred over the Cigarette Extinction Method because it demonstrated better distinction
among both the commercial and experimental cigarettes. The NIST report contains all the necessary
materials for initiating the adoption of either method as a voluntary consensus standard by either
ASTM or the National Fire Protection Association (NFPA).

These members also find that use of the test method is likely to potentiate reduced fire losses. The
current best-selling cigarettes produce consistent ignitions of all substrates in the two test methods.
New cigarette designs intended to produce fewer fires and fire deaths will need to demonstrate a
significant reduction in test ignitions, compared to the current best-sellers. There are no data
indicating the converse, namely that cigarettes that produce fewer ignitions in the test methods will
produce greater fire losses.

As noted in the above discussion of the test methods (see Task 1), the four cigarette industry TAG
members believe that these are not predictive of real-world cigarette ignition propensity. They have
found in their studies that ignitions of commercial fabrics under likely real-world environmental
conditions may be increased by adoption of a performance standard based on the proposed NIST test
methods. In addition, the predicted short-term reproducibility of the proposed test methods (40%)
makes them unsuitable for use in product development or in establishing a performance standard.
Longer term reproducibility has not been examined and may even be more limited in view of the
reported charactéristics of the cotton duck fabric relied on by NIST Thus, at this state of develop-
ment, neither of the proposed test methods should be adopted as a basis for measuring the ignition
propensity of cigarettes. They assert the methods are not predictive of real-world fire risk and could
be counterproductive.

B. ACCEPTANCE CRITERION
The TAG believes that the setting of acceptability criteria is in the domain of the regulator. The
NIST report does provide some assistance, however. The interlaboratory evaluation of the method
showed that individual test labs could differ by about 40 percent, defining the limit of resolution for

use in any future regulations. There are also data to “calibrate” the method at the high and low ends

A8


a narrow range of tobacco density, which was a pronounced factor identified in the TSG research.
In addition, the cigarette industry uses additives other than citrates to the paper. It is thus
noteworthy that two factors were identified as affecting ignition propensity in both this and the TSG
studies: presence of a filter and paper porosity.

Eleven members of the TAG find that this study shows that cigarettes currently on the market differ
significantly in their risk of starting a fire, even after controlling for smoker characteristics. The
eleven members realize that the particular characteristics shown to be significant may be surrogates
for some other cigarette properties and smoker characteristics, unknown at this time. Despite only
eight cities participating, the eleven members feel that it is unlikely that brand preferences peculiar
to these localities may have influenced the results, or that a larger sample size would have yielded
major differences in the principal conclusions.

By contrast, the four cigarette industry representatives note that this study did not find a statistically-
significant association between reduced tobacco density (or reduced amount of tobacco), reduced
cigarette circumference, or the presence of citrate in cigarette paper and the incidence of fires.
These factors are three of the four cigarette design parameters that were reported in the TSG
laboratory experiments to affect ignition propensity. The four assert that the presence of a filter was
not reported in the 1984-87 research conducted by NIST to be a significant variable affecting ignition
propensity and was not studied further by NIST under the current legislation. It is also noteworthy
that demographic variations among smokers were found to be associated with fire incidence to a far
greater extent than cigarette design characteristics. The field study findings raise serious questions
concerning the real-world predictive value of the Mock-up Ignition Test and the Extinction Test. The
cigarette design and packaging characteristics for which statistical significance was reported in the
field study are based on analyses of main and first-order interaction terms. Limitations on sample size
have been reported by CPSC to preclude examination of higher-order interactions for the variables
that were reported to have statistical significance. The CPSC field study should be interpreted in
light of this limitation.

5. Develop information on societal costs of cigarette-ignited fires. The TAG has received a rough

draft and heard a presentation of estimates of the costs of smoking fire injuries by the National Public
Services Research Institute, a contractor to CPSC. Based on 1990 estimates of (civilian and fire
fighter) fatalities and injuries resulting from cigarette-initiated fires in structures, the annual cost to
society is estimated to be $3.6 billion, with direct property damage estimated to cost an additional $0.4
billion. These estimates are based on a combination of new research, a comprehensive review of
existing literature, and the latest cost estimation techniques. The TAG has received a next draft, but
did not have sufficient time to evaluate it prior to transmitting this report.

Eleven members of the TAG find the presented work to be quite thorough. Significant benefits
would accrue should cigarettes of reduced IP acquire an increased share of the market.

The four TAG cigarette industry members believe that the CPSC and its contractor used questionable
assumptions and inappropriate data to arrive at a hugely inflated cost estimate. Moreover, other
studies show substantial declines in careless smoking-related fires (58%) and fire deaths (45%) from
1980 through 1991.

A6






The eleven members also find that the nine-laboratory study showed that the two methods are of
useful reproducibility. The lab-to-lab variation in the proportion of ignitions is comparable to other
fire test methods currently being used to regulate materials which may be involved in unwanted fires.

By contrast, the four cigarette industry members are sharply critical of the NIST research and the
resulting methods. They assert the report contains conjecture on selections and assumptions made
in developing the proposed test method. They further make the following assertions. Many of the
explanations are contrary to research results at NIST and elsewhere. The proposed method employs
substrates rarely, if ever, used in upholstered furniture or mattresses. One of the criteria used by
NIST to select the cotton duck fabrics was that they would show large fractions of ignitions by
popular commercial cigarettes; similar criteria were used in the design of the Extinction Method as
well. The fabrics’ chemical and physical properties are not representative of furniture or mattresses.
They show inverse relationships between ignitions and fabric weight compared to commonly-used
commercial fabrics. Extensive cigarette industry research data indicate an interaction between
substrate and cigarette characteristics resulting in the conclusion that cigarette ignition propensity
rankings are substrate dependent. The proposed tests were subjected to interlaboratory studies that
made use of a limited, non-random selection of experimental cigarettes. Studies by NIST and other
laboratories with the duck fabrics also indicate that the crevice configuration, which was excluded
from the proposed NIST test method and is of concern in real-world fire settings, produces results
that are inconsistent with commercial fabrics, e.g., the crevice configuration is a less severe test than
the flat configuration with the duck fabrics. With little consideration of commercial substrate
characteristics, or data that relates the test method substrate to real-world substrates, the proposed
test method has no obvious real-world connectivity. Effects of real-world environmental air flow on
cigarettes were not investigated, even though cigarette industry data indicate that it can reverse the
apparent ignition propensities of cigarettes. Similar effects which have not been investigated by NIST
may result from humidity changes. During the NIST studies, certain cigarette characteristics were
found to correlate with reduced ignition propensity. Little correlation was found between these
characteristics and those found in the CPSC field study of cigarette fires (Task 4), further indicating
the lack of a real-world relationship between the proposed test method and fires. Finally, they assert
that other issues not adequately addressed or resolved by NIST include unacceptable short- and long-
term reproducibility of the test method.

. Cor formance data for ial) cigarett ing the standard test method. NIST has
completed the testing of 20 commercial cigarettes. Fourteen of these are the best selling packings,
comprising nearly 40% of total sales. The test results show that these consistently ignite the most
difficult-to-ignite substrate in the Mock-up Ignition Test and burn their full length in the Cigarette
Extinction Test Method. The remaining six packings tested have one or more physical properties
suggesting their being less ignition prone. All of these packings showed reduced ignition propensity
in the Mock-Up Ignition Test Method. Four of these packings rarely ignited the most difficult-to-
ignite substrate; the other two ignited it in 40-70% of the tests. Three of the four packings showed
reduced IP on the middle substrate as well. While the Cigarette Extinction Test Method is less
sensitive to changes in IP, three of the packings showed markedly fewer full-length burns. All these
differentiations are outside the variability of the test methods. In the combined test results of
commercial and experimental cigarettes using both methods, there is one inconsistency in the results
of testing of one commercial cigarette on one substrate using the Mock-Up Ignition Method.

The TAG thus observes that there are multiple brands of commercial cigarettes currently being sold
that are of reduced ignition propensity, as measured by the NIST test methods.

A-4






Volume 1. Overview

Table of Contents

Acknowledgements .............ceccssccceesersscenecceccneeneseesensenteateeeneeteanens

I. Executive Summary

U. Introduction ..........ccescsseeeseeceeeeseeensseerasersenecneseceenesseeesaaseanesen

lll. Summary of Research

. Test Method Development ..
Testing of Commercial Cigarettes.
Ignition Physics/Computer Modeling .
Fire Incident Study ...
Toxicity Testing Plan ...
Societal Cost of Cigarette Fires ...

TMMOOMD

IV. Technical Advisory Group ...........:.cccesesensesseeceseteeeessecnenceseeaneesee

V. Practicability of Developing a Performance Standard ............csess00

Appendix A: Advisory Opinion of Technical Advisory Group ...............

Appendix B: Copy of Fire Safe Cigarette Act of 1990............c..c:cceeeeee

25

Al

Bt


Health Effects Assessment Plan

After consideration of the testing proposed by the expert panei, and in
consultation with DHHS, the Commission developed the following performance-
based plan. Four sequential tiers of testing are proposed:

Tier 1: chemical analyses of smoke: acidity and reduction/oxidation
potential, carbon monoxide, hydrogen cyanide, and nitrogen oxides, aldehydes,
volatile hydrocarbons, volatile nitrosamines, particulate matter (tar), catechols,
nicotine, phenols, polynuclear aromatic hydrocarbons, and tobacco-specific
nitrosamines.

Tier II: in vitro tests: Salmonella mutagenicity (Ames’ assay) and mouse
embryo fibroblast cell transformation assay.

Tier It: indicators of human smoking behavior: levels of cotinine and carbon
monoxide in human subjects, smoker topography (puff volume, frequency, and
draw velocity).

Tier IV: in vivo tests: mouse inflammatory lung response, hamster
respiratory tract carcinogenicity, and mouse skin painting carcinogenicity.

Satisfactory performance at one tier would be required before proceeding to
the next. The toxicities of the prototypes should be compared with marketed
types intended for replacement or comparable marketed types, and standard
reference cigarettes. However, the definition of acceptable levels of performance at
any tier is beyond the scope of this plan. Moreover, it is beyond the direction
given by the Act.

The FTC method is the basis for the mechanical generation of smoke
constituents for the tests described in Tier |. However, the test protocol,
especially in terms of puff volume, frequency, and draw velocity, may need to be
revised based on actual smoking behavior as measured in Tier ill. Uniess
consistent correlation of testing results of mainstream and sidestream smokes can
be shown, both must be separately collected and tested.

Additives in the prototypes exceeding the current levels of use or new additives
must be disclosed to determine whether additional testing is needed.
improvements in toxicity testing and risk evaluation may occur in the future and
should be considered during possible revisions of the plan.

17


Ili. Summary of Research

A. Test Method Development

The Fire Safe Cigarette Act directed NIST to develop a standard test method
to determine cigarette ignition propensity. The work was a follow-on to research
described in the final report of the Technical Study Group in 1987.

In that report, NIST described several characteristics of cigarettes that were
found to be related to their ignition propensity, based on tests conducted on a
specially made series of experimental cigarettes. Those tests were performed
using several different combinations of fabrics and upholstery filling materials
(substrates) to represent and model the ignition performance of soft furnishings.
The characteristics that affected the risk of ignition were tobacco density, cigarette
circumference, paper porosity, presence of a filter, and, to a lesser extent, the
addition of citrate to the wrapping paper.

Because the original experimental cigarettes were no longer available in
sufficient quantity to complete the work, a new series of experimental cigarettes
was provided by the cigarette manufacturers, intended to repeat the range of
characteristics of the original. Five of the remade experimental cigarettes were
selected to serve as calibration for the test method under development.

Mockup Ignition Method: The ignition of furniture or bedding by a cigarette
is a highly interactive process; that is, properties of the substrate and of the
cigarette play equally critical roles in determining whether or not ignition will occur.
In order to develop a reliable test that could be used repeatedly over many years
with the expectation that it will yield consistent results, particular care was needed
to select the appropriate test materials.

A mockup consisting of a single layer of raw cotton duck fabric over
polyurethane foam was selected. Cotton duck, which is commonly known as
canvas, was chosen for several reasons. It is used in large quantities by the
military and there are military specifications for its construction. These facts help
to assure that it will be available indefinitely, and that its properties will remain
consistent. Cotton duck also has ignition characteristics that allow discrimination
among cigarettes within the ignition propensity range of both the experimental
cigarettes and current commercial cigarettes. This point is crucial to the reliability
and validity of the test method. Some fabrics will be ignited by all cigarettes;
others will not be ignited by any cigarette. Such fabrics are of no use to
discriminate among various cigarettes.


C. Ignition Physics and Computer Modeling

The Fire Safe Cigarette Act directed NIST to conduct laboratory studies on
and computer modeling of ignition physics to develop valid, user-friendly predictive
capability. The plan intended at the outset has been modified somewhat by the
complexity of the mathematical modeling and by the exigencies of the test method
development project. However, NIST has developed computer models of a multi-
layer cushion (substrate) subjected to a stationary heat source, a model of a
burning cigarette lying on a substrate, and a protocol to use the two together. A
description appears in Volume 3 of this report, "A Computer Model of the
Smoldering Ignition of Furniture.”


because it provides better discrimination among cigarettes at the higher range of
ignition propensity.

The development of the two test methods constitutes the most important
task under the Fire Safe Cigarette Act of 1990. Much of the discussion during the
Technical Advisory Group meetings, and a significant amount of correspondence,
concerned this work. Throughout the process of developing the tests, many
decisions and selections had to be made. The information underlying these
selections, and the bases for the decisions made, were the subject of considerable
attention and controversy.

Members of the TAG representing cigarette manufacturers have introduced
considerable data disputing the validity of the test conditions as representative of
real life conditions, particularly with regard to fabric selection and air flow
conditions. In one series of tests, a variety of upholstery fabrics purchased at
retail was substituted for the cotton duck fabrics and purportedly tested according
to the NIST protocol, using five experimental cigarettes of varying ignition
propensity according to the 1987 NIST research. This research suggested that
with some of the fabrics there was a reversal of ranking from the NIST tests; that
is, cigarettes that performed well on the NIST tests had many ignitions, while
cigarettes that performed badly had few ignitions. However, there was no
evidence that in the aggregate the rankings were reversed.

One cigarette manufacturer also commissioned a study by the Battelle
Memorial institute of cigarette ignition tests conducted under a variety of air flow
conditions. These data, introduced nearly at the end of the 3 year research period,
also purported to indicate that the introduction of air flow into the test chamber,
even at a rate of 0.1 ft./min., showed reversals of ranking from the results that
would have been obtained from the NIST test. Although NIST is confident that its
test method reasonably reflects what happens in the real world, it acknowledges
that if data emerge to establish that changes are needed, the test methods could
be modified.

Conclusiens: NIST has developed two separate methods for measuring the
propensity of cigarettes to ignite soft furnishings. The test methods are repeatable
and reproducible within reasonable limits. Further, based on research conducted
for the Technical Study Group during 1984 to 1987, they adequately reflect what
happens in the real world when cigarettes are dropped on furnishings. The mock-
up ignition method is more suitable for use in a performance standard.

A complete description of the test method development research is at
Volume 2 of this report, "Test Methods for Quantifying the Propensity of
Cigarettes to ignite Soft Furnishings."


First implementation step

Completion of all four testing tiers is costly relative to the presemt level of
testing required by FTC ($330,000 in direct costs for Tiers I, Il, and IV ).
Therefore, a stepwise implementation of the plan is suggested.

A practical subset of recommended tests should comprise, as a minimum,
limited testing from Tiers | and Il. (Subsequent steps should consider the more
comprehensive recommended test plan.) The estimated direct cost of this first
step was $6,900 per cigarette type tested, although the Commission was able to
contract for the work for somewhat less. The tests included: from Tier |, tests for
nicotine, tar (FTC), carbon monoxide, whole smoke pH, benzo(a)pyrene, and
tobacco-specific nitrosamines; from Tier II, the Salmonella mutagenicity ("Ames")
assay. Smoke and condensate were generated by machine according to the FTC
protocol.

The Commission contracted with two laboratories to conduct this limited
test protocol on five cigarettes-- two commercial brands, two low ignition-
potential prototypes, and a standard reference cigarette. The results indicate that
the plan will provide data that can distinguish differences in toxicities among
cigarette types. The demonstration also shows that the cost estimates are
reasonable and the implementation of limited tests from Tiers | and t! is feasible.

A complete review of the toxicity findings is at Volume 5, Toxicity Testing
Plan.

18



Finally, the Commission notes that both laboratory and field studies indicate
that some lower ignition propensity cigarettes already exist in the marketplace.
Characteristics that have been associated with improved performance, in one or
both of these studies, include lower paper porosity, smaller circumference, shorter
filter, and lower tobacco density.


104 STAT. 406

PUBLIC LAW 101-352—AUG. 10, 1990

The Commission shal! make such request not later than the expira-
tion of 30 days after the date of the enactment of this Act.
(>) Commassion.—The Consumer Product Safety Commission

(a) design and implement a study to collect baseline and
followup data about the characteristics of cigarettes, products

ited, and smokers involved in fires, and
develop information on societal costs of cigarette-ignited

Human Services, shall develop information on changes in the tox-
Sy aoe ae ee Ee eS
ion more 8

such information.
SEC. 3. ADVISORY GROUP.

Safe
Commission and National Institute for Standards and Technology's




E. Toxicity Testing Plan

The Fire-Safe Cigarette Act directed the Commission, in consultation with
the Secretary of the Department of Health and Human Services (DHHS), to develop
information on changes in the toxicity of smoke and resultant health effects of
cigarettes with a reduced probability of starting fires.

The reasons for considering the health implications of ignition-resistant
cigarettes are compelling. There are about 50 million smokers in the U.S., of
whom an estimated 434,000 die annually from adverse health effects associated
with smoking. According to the Department of Health and Human Services, the
societal cost of smoking in the U.S. is estimated at $68 billion per year in direct
and indirect costs. Thus, even a small increase in the risk of an adverse health
effect due to new cigarette types could result in a great increase in human and
economic costs. If this occurs, it could counter the benefits achieved from the
reduction of fires by new cigarette types.

The Act imposed a limit of $50,000 for evaluating health effects. Both the
Commission and the TAG agreed that the spending limit precluded any significant
amount of actual testing of cigarette prototypes, especially since the nature and
extent of required testing had not been established. In consultation with Donald
Shopland, MD, of the DHHS, and with the concurrence of the TAG, the
Commission decided to convene a panel of health experts who would develop a
toxicological testing plan. The experts would define the significant issues and
recommend the tests necessary for a comprehensive assessment of health effects
of low-ignition potential cigarette smoke.

The experts were selected from a list proposed by the TAG, the DHHS, and
the Commission. Each prepared specific chapters of the final report:

JEFFREY E. HARRIS, MD, PHD, PROVIDED AN OVERVIEW OF THE ISSUES
RELATED TO DEVELOPMENT OF A PLAN AND THE MAJOR HEALTH EFFECTS OF
TOBACCO SMOKE.

HaROLD C. PILLSBURY, JR., DESCRIBED THE SMOKING MACHINE AND
PROTOCOL FOR THE COLLECTION OF GASES AND PARTICULATE MATTER FROM
CIGARETTE SMOKE.

Davip M. BuRNS, MD, DISCUSSED THE EFFECT OF SMOKING TOPOGRAPHY
{INHALATION PROFILE) AND BIOLOGICAL INDICATORS OF TOBACCO SMOKE IN
HUMANS.

15


Data obtained from Manufacturers

Research carried out during 1984-87 identified several physical
characteristics of cigarettes that significantly affected their risk of igniting
upholstery materials in laboratory tests. The characteristics included tobacco
density, circumference, paper porosity, the amount of citrate additive, and the
presence of a filter. Since many of these characteristics cannot be determined
from physical inspection, the Commission solicited these specifications from
manufacturers, who submitted the requested data about the cigarettes that they
currently manufacture.

Results

The data were analyzed using a statistical procedure known as logistic
regression. This is a rigorous method of analysis by which many different
demographic and cigarette characteristics can be analyzed simultaneously to
determine the strength of their respective associations with the risk of fire.
Interactions between demographic and cigarette characteristics can also be
examined.

The demographic variables included in the analysis were household income,
education, gender, race, age, and city of residence. One demographic variable, the
number of cigarettes smoked daily, was collected but discarded from the analysis
because of coding discrepancies between the fire and smoker groups.

Cigarette characteristics included in the analysis were tobacco column length, filter
length, circumference, tobacco density, amount of tobacco, menthol, paper
porosity, citrate additive (to the wrapping paper), and pack type (soft pack or box).

After controlling for all smoker characteristics, several cigarette
characteristics were found to have a significant effect on the risk of fire: (a) the
presence and length of a filter, (b) wrapping paper Porosity, and
(c) pack type. Specifically, a higher fire risk was observed for unfiltered cigarettes,
for cigarettes with a short rather than a long filter, for cigarettes with higher paper
Porosity, and for cigarettes from a soft pack rather than a box. Significant
interactions of household income with both education and race were found, and a
significant interaction between pack type and gender. (The excess fire risk for soft
Pack cigarettes was only statistically significant among male smokers.)

The smoker characteristics that were found to be significant were:
(a) income, {b) education, and (c) gender. Income had a more profound effect on
risk than any other smoker or cigarette characteristic. Families with an income of
less than $10,000 a year were six times as likely to have a fire as families with an
annual income of $20,000 or more.

12


UniTED STATES
CoNSUMER Propuct SAFETY COMMISSION
WasuIncTon, D.C. 20207

The Chairman

August 9, 1993

The Honorable Albert Gore
President of the Senate
Washington, D.C. 20510

Dear Mr. President:

In accordance with the provisions of the Fire Safe Cigarette Act of 1990 (Public Law
101-352), I am transmitting to the Congress the final report describing the research
prescribed by the Act. The Commission and the National Institute of Standards and
Technology have completed all of their assigned tasks. The findings are described in detail
in the report transmitted with this letter.

While the Commission concludes that it is practicable to develop a performance
standard to reduce cigarette ignition propensity, the effort to achieve such an objective is
beyond both the jurisdiction and the technical capability of the agency. It would therefore be
prudent for Congress, if it determines that pursuing this objective is in the national interest,
to identify and delegate to a more appropriate agency the task of working with industry to
develop a performance standard to reduce cigarette ignition propensity.

Sincerely,

Jacqueline Jones-Smith




ll. Introduction

The United States has the dubious distinction of being among the world
leaders in fire death rates. On a per capita basis, about 50 percent more U.S.
residents die in fires as in Europe or Japan. In 1990 the toll was almost 5,200
deaths, mostly in fires in residential structures; about 1,200 of these deaths
occurred in fires started by cigarettes.

Cigarettes are not the leading cause of fires in this country, but they are by
far the leading cause of fire fatalities. In spite of a significant decline during the
last decade, cigarette fires accounted for 25 percent of alt residential fire deaths
during 1990, the most recent year for which data are available. In that year,
cigarettes ignited an estimated 44,000 structural fires that caused about 1,200
deaths, 3,360 civilian injuries, and $400 million in direct property loss.

Nine years ago Congress enacted the Cigarette Safety Act of 1984 (Pub.L.
98-567, 98 Stat. 2925). That legislation created a Technical Study Group on
Cigarette and Littie Cigar Safety to study the technical and commercial feasibility,
economic impact, and other consequences of developing cigarettes with a
minimum likelihood to ignite upholstered furniture or mattresses. The Technical
Study Group consisted of 15 members appointed to represent government,
industry, fire service organizations, and medical and public health groups.

Several physical characteristics of cigarettes were proposed as possibly
affecting ignition potential. These characteristics were systematically examined in
laboratory work performed at the National Bureau of Standards, now NIST, using
prototype cigarettes specially prepared by cigarette manufacturers. The tests
identified tobacco density, cigarette circumference, paper porosity, the amount of
citrate, and {in separate tests) the presence of a filter as affecting the risk of
ignition. Economic impact analyses and estimates of changes in fire loss from an
ignition-resistant cigarette were prepared, as well as a study of the feasibility of
Collecting field gata about cigarette-ignited fires.

In October 1987, the Technical Study Group issued its final report. The
major findings were that, ” it is technically feasible and may be commercially
feasible to develop cigarettes with a reduced propensity to ignite upholstered
furniture and mattresses." However, the group also made specific
recommendations for additional research in the area of cigarette fire safety.


UNITED STATES
CoNSUMER PRODUCT SAFETY COMMISSION
Wasnincton, D.C. 20207

The Chairman

August 9, 1993

The Honorable Thomas S. Foley
Speaker of the House

U.S. House of Representatives
Washington, D.C. 20515

Dear Mr. Speaker:

In accordance with the provisions of the Fire Safe Cigarette Act of 1990 (Public Law
101-352), I am transmitting to the Congress the final report describing the research
prescribed by the Act. The Commission and the National Institute of Standards and
Technology have completed all of their assigned tasks. The findings are described in detail
in the report transmitted with this letter.

While the Commission concludes that it is practicable to develop a performance
standard to reduce cigarette ignition propensity, the effort to achieve such an objective is
beyond both the jurisdiction and the technical capability of the agency. It would therefore be
prudent for Congress, if it determines that pursuing this objective is in the national interest,
to identify and delegate to a more appropriate agency the task of working with industry to
develop a performance standard to reduce cigarette ignition propensity.

Sincerely,

Jacqueline Jones-Smith


B. Testing of Commercial Cigarettes

in accordance with the directives of the Fire Safe Cigarette Act, NIST
compiled performance data on a limited number of commercial cigarettes, using
both test methods. The 20 cigarettes tested were selected from among more than
500 "packings” available on the commercial market at the time of testing. NIST
selected 14 cigarettes that represent a significant proportion of the market in terms
of sales figures, and 6 others that were expected to yield reduced ignition
propensity because of their physical characteristics.

Because it was anticipated that many of the cigarette types would exhibit
high ignition propensity, an abbreviated protocol was employed. This was based
upon the assumption that if a cigarette displayed 100 percent ignitions on the
most ignition-resistant substrate, the number of replicates could be reduced for the
remaining substrates.

With one minor exception, all of the 14 best selling cigarettes ignited the
test fabrics in all tests. Of the six cigarettes expected to display reduced
propensity, almost all showed fewer ignitions on the hardest-to-ignite fabric, and
at least one differentiated at the intermediate level. Similar results were obtained
using the cigarette extinction method.

The testing of commercial cigarettes has provided a limited baseline of data
for comparison purposes. In addition, it has demonstrated the high ignition
propensity of commercial cigarettes in general compared to the experimental
cigarettes. It has shown that some cigarettes on the market have a lower ignition
propensity when tested in accordance with the test method developed by NIST. A
detailed report of the test results is included in Appendix G of Volume 2.


Practicability of Developing a Performance Standard

to Reduce Cigarette Ignit

1

U.S. Consumer Propuct Sarery
Commission
JACQUELINE JONES-SmuTH, CHAIRMAN

Ausust 1993



Summary of Practicability

In summary, the Commission concludes that it is practicable to develop a
standard to reduce cigarette ignition propensity. However, the Commission notes
that, in order to more fully address issues raised by other interests, additional work
is needed. The Commission also concludes that such an effort is beyond both the
jurisdiction and the technical capability of the agency. Therefore, the Commission
respectfully suggests that should it be determined that pursuing the development
of this standard is in the national interest, the Congress should identify and
delegate to a more appropriate agency the task of working with industry to
develop the desired performance standard.

30


Finally, the Commission offers special thanks to the members of the
Technical Advisory Group, who spent many hours attending meetings and
reviewing the work of NIST and the Commission. Every member added to our
store of knowledge:

Current Members

Ms. Jean Adams
Federal Emergency Management Agency

Mr. Charles M. Carey
American Furniture Manufacturers Association

Dr. Richard Gann
National Institute of Standards & Technology

Mr. John C. Gerard
National Fire Protection Association

Mr. James F. Hoebel
U.S. Consumer Product Safety Commission

Mr. Michael D. McGibeny
Internationa! Association of Fire Chiefs

Mr. Andrew McGuire
American Burn Association

Dr. Dallas O. Pinion
The Tobacco Institute

Dr. Edward Press
American Public Health Association

Dr. Donald Shopland
National Cancer Institute

Dr. Alexander W. Spears, Ill
The Tobacco Institute

Dr. David Townsend
The Tobacco Institute



Acknowledgements
Many persons both in and out of government made important coritributions
to the technical work described in this report. The Commission acknowledges their
efforts.

Consumer Product Safety Commission:

Allen F. Brauninger Terry Kissinger

Roy W. Deppa Brian C. Lee

Linda Fansier Lakshmi C. Mishra

Bea Harwood Dale R. Ray

James F. Hoebel Gail A. Stafford

Kathy Kaplan William W. Zamula
National Institute of Standards and Technology

Emil Braun J. Randall Lawson

Keith R. Eberhardt Henri E. Mitler

Richard G. Gann Thomas J. Ohiemiller

Richard H. Harris, Jr. Kay M. Villa
George N. Walton

National Fire Protection Association
Rita F. Fahy Michael J. Karter, Jr.
John R. Hall Jr. Alison Miller

Mathematica Policy Research, Inc.
Donna Eisenhower John Hall
Peter Forbes

Tobacco Company Representatives/Contractors

Sarah Debanne Leslie Lewis
Fred Clarke Vello Norman
Ron Flack Steve Spivack

Hugh Honeycutt

Toxicity Consultants
David M. Burns, University of California at San Diego
C. Gary Gairola, Tobacco and Health Research Inst., Univ. of Kentucky
Jeffrey E. Harris, Internal Medicine Assoc., Mass. General Hospital
Dietrich Hoffman, American Health Foundation
Harold C. Pillsbury, Jr.

iti


PUBLIC LAW 101-352—AUG. 10, 1990 104 STAT. 405

Fublic Law 101-352
‘ist Congress
An Act

To direct the completion of the research recommended by the Technical Study Group
oa Cigarete and Lite Cigar Fire Safety and to provide for an amearment of the
practicality of a cigarette fire safety performance mandard.

Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,

SECTION 1. SHORT TITLE; FINDINGS.

(a) Suort Trmz—This Act’ may be cited as the “Fire Safe
Act of 1990".

») Farpincs.—'
mee reteiguied Tres are the ending cute of Sire deaths
ni

ae in 1987, there were 1,492 deaths from cigarette-ignited
fires, 3,809 serious injuries, and $395,000,000 in property
damage caused by such

(8) the final report of the Technical Study Group on on 1 Cigarette
and Little Cigar Fire Safety under the Cigarette Safety Act of
1984 determined that (A) it is technically feasible ‘and t may be
commercially feasible to develop a cigarette that will have a
significantly reduced propensity to ignite funiture and mat-
tresses, and (B) the overall impact on other other expects of the
United States society and economy momy may be minimal,

(4) the final report of the Ts ly Group on Cigarette
and Little Cigar Fire Safety peerea the Cigarette Safety Act of
1984 further ed that the value of a cigarette with leas
of a likelihood to jgnite furniture and, mattresses qhich Fould
prevent property damage and pe: injury oes is

sconamially incaleulable, a by law th

it is appropriate for e Congress to require yy law the
completion of the research described in the final ort Ae the
Technica] Study Group on Cigarette and Little Cigar Fi
and an assessment of the practicability of developing a re Sofety
ance standard to reduce cigarette ignition propensity, and

(6) it is appropriate for the Consumer Product ety Commis-
sion to utilize its expertise to complete the recommendations for
further work and report to Congress in a timely fashion.

SEC. 2, COMPLETION OF FIRE SAFETY RESEARCH.
(a) CENTER For Fire Researcu.—At the request of the Consumer
Product Safety Commission, the National Institute for Standards

and Technology's Center for Fire Research shall—
ignition propensity Ts “ett method to determine cigarette

a 2) eo) coca pet ne emance data for cigarettes using the stand-

test method developed under paragraph (1), and
__(8) conduct sarmenires Maire studies on and computer modeling of
valid, user-friendly predictive

BL

Aug. 10. 1990
GR. 233)

Fire Safe
sm Act of

15 USC 2054
note.

15 USC 2054
nate.


air flow conditions, while the reverse was true for cigarettes with a demonstrated
high ignition potential in the NIST test. In other words, a reversal of the expected
rankings was observed.

Some of the data presented by industry (e.g., a report about air flow
prepared by the Battelle Memorial Institute and data from testing fabrics commonly
used in uphoistered furniture) was introduced at too late a date to be thoroughly
considered for this report. While NIST is confident that its test method reasonably
reflects what happens in the real world, it acknowledges that if data emerge to
establish that changes are needed, the test methods could be modified.

The Commission also notes that it is not necessary for the test method to
discriminate adequately among low and high ignition propensity cigarettes on all
fabrics and under all air flow conditions. It is only necessary that it do so in the
aggregate. Few test methods or remedial strategies are effective under all possible
circumstances.

The accurate and reproducible representation of a real-life process involving
fire in a controlled laboratory environment is never easy because of the large
number of variables involved. It is not possible in one test, or even a limited series
of tests, to reproduce all real life conditions under which a cigarette may start a
fire. Insofar as possible, a test must narrow the range of variables to allow
examination of the performance characteristic of interest.

It is not unusual for standardized tests to employ materials and test
conditions that do not exist or rarely exist in real life. The need to simulate real life
must be balanced against the need to use standardized materials that will provide
reliabie results. If the materials and conditions chosen for a test adequately serve
as surrogates for the variety of substrates and conditions found in real life, then
their use is acceptable. In this case, prior research under the TSG established the
ignition performance of experimental cigarettes using several different fabric and
cushion combinations. Experimental cigarettes with those same characteristics
were used in developing the present test method.

Cigarette manufacturers have implicitly approved the use of surrogates in
their research. Repeatedly they have used fabrics treated with different levels of
smolder promoters such as sodium or potassium ions as a surrogate for fabrics
with varying levels of ignitability. The fabric selected by NIST, an as-received,
undyed cotton duck, was chosen because of the stability of its specifications and
performance over time. The three weights used represent varying levels of
ignitability and provide flexibility in setting acceptance criteria.

26




£1 Fe,
ra Me, NIST UNITED STATES DEPARTMENT OF COMMERCE
é * National Institute of Standards and Technology
. : Gaithersburg, Maryland 20889,
% g
% ¢
° stares of *
July 8, 1993

The Honorable Jacqueline Jones-Smith
Chairman

Consumer Product Safety Commission
Washington, DC 20207

Dear Chairman Jones-Smith:

1 am pleased to provide you with the Technical Advisory Group's (TAG) final appraisal of the tasks
being carried out under the Fire-Safe Cigarette Act of 1990 (PL. 101-352). After summarizing our
activities, we present our views on the six tasks being performed by the Consumer Product Safety
Commission (CPSC) and the National Institute of Standards and Technology (NIST) and our
assessment of the practicability of developing a performance standard to reduce cigarette ignition
propensity (IP). This letter is timed to provide input to your August 10, 1993 final report to the
Congress, and most of our comments are based on interim versions of the task products.
Nonetheless, we feel our assessment is valid and germane to your needs.

The chronology of our activity under the Act is as follows. Public Law 101-352 was enacted on
August 10, 1990. The initial appropriation was received by CPSC on November 29, and the first
funding was transferred to NIST on December 17. You appointed the TAG members by December
26. As under the Cigarette Safety Act of 1984, the membership represent:

Federal agencies (5 members),

cigarette manufacturing (4 members),
public health organizations (2 members),
fire safety organizations (2 members), and
furniture manufacturing (2 members).

eoevee

Eleven TAG meetings have been held on February 1, 1991, March 21, 1991, June 3, 1991, October
31, 1991, January 24, 1992, April 16, 1992, June 15, 1992, September 1, 1992, January 28-29, 1993,
April 29-30, 1993, and June 11, 1993. A notice of each meeting was published in the Federal
Register. The public audience at the meetings has been almost exclusively by technical and legal staff
of the member organizations. We repeat our appreciation for the support of CPSC project staff in
organizing the TAG meetings and distributing the materials needed to perform our functions.

The meetings have focused on reviews of project directions and results, both of work performed
directly under the Act and also under the sponsorship of the tobacco industry. Discussion of
technical and programmatic issues has been vigorous. The TAG membership is sharply divided in
many facets of its assessment of the work performed under the Act. In general, where there are two

A-1


Various sensitivity tests were conducted to determine how dependent the
logistic regression modeling was on certain aspects of the data. Areas of
investigation included: the sensitivity of the regression modeling to the -low fire
reporting rate in Columbus, OH; to the use of self vs. proxy reporting {i.e.,
obtaining information directly from the smoker vs. from another household
member); to the cluster sampling of the smoking households in the smoker survey;
and to the effect of excluding cases where data on income or education were not
available. The sensitivity tests indicated that the results described above were not
significantly affected by any of these issues.

Discussion

Some of these epidemiological findings confirmed laboratory findings, some
did not. Paper porosity was found to be significant in both laboratory and field
studies. Tobacco density and cigarette circumference were significant in
laboratory tests but not in the field study. It should be noted, however, that while
the range of these characteristics in the field study included a few values at either
end of the spectrum of characteristics examined in experimental cigarettes, most
of the values for density and circumference among currently manufactured
cigarettes were distributed closely around the mean. The fact that no significant
differences were found may merely reflect the small sample size at either end of
the range.

Results from a single epidemiological study cannot be determined to be
definitive. By nature field studies are less rigorous than those conducted in a
laboratory, where extraneous variables can be more rigidly controlled. The
possibility cannot be ruled out that some of the characteristics shown to be
significant may be surrogates for other cigarette characteristics unknown at this
time. Only a few have been examined.

On the other hand, field studies have the advantage of relating directly to
real life situations. The observed high risk for unfiltered cigarettes and cigarettes
with a high paper porosity has been confirmed in laboratory studies. The effect of
filter length, though not suggested previously, is a logical extension of that finding.

In summary, the results suggest that cigarettes currently on the market
differ significantly in their risk of starting a fire, even after controlling for smoker
characteristics.

A detailed analysis of the fire incident study and the smoker survey is at
Volume 4 of this report.

13




Cotton duck fabric is manufactured in several weights of varying
susceptibility to ignition by a cigarette. The test procedure includes performing the
test on three different weights of cotton duck (and in one case, an added layer of
polyethylene film between the fabric and foam), with 48 replicates per test. The
tests allow for the examination of cigarettes across a broad range of ignition
propensity performance.

The ignition process is a subtle one, and it is readily affected by air
movement. In actual fire situations, cigarettes may lie in various positions on and
within furnishings, and air movement in the vicinity is thought to encompass a
range from essentially zero upward. While actual air flows are not quantified, air
flow velocities are likely to be variable, randomly oriented with respect to the
cigarette, and low. For the test, NIST chose to use a slightly-modified version of
the test chamber developed by the cigarette industry. This chamber is a closed
plastic box that has a prominent "chimney" at the top to allow smoke to exit and
an equal amount of air to flow back in. Conditions within the box are essentially
still; what air movement exists is caused by the rising smoke and replacement air
flow. NIST chose this condition because it is within the range of actual conditions,
and it requires minimal effort to obtain a repeatable test environment.

Cigarette Extinction Test Method: NIST also investigated the feasibility of a
test method that could discriminate over a wide range of cigarette ignition
propensities with more easily standardized materials. The substrate materials
finally selected were 3, 10, and 15 jayers of standard cellulosic filter paper that
effectively provide varying thermal absorption. Thus, as more layers are added,
more of the heat of the cigarette is drawn away, and the more likely the cigarette
is to self-extinguish. !t should thus take more layers of paper to cause a more
ignition-prone cigarette to self-extinguish in the test.

interlaboratory Study: A major element of the development of both test
methods was the "round robin” series of tests to demonstrate the reproducibility of
the method. NIST arranged the participation of nine laboratories, including Federal
and state government laboratories, cigarette industry laboratories, and a
commercial testing laboratory. Each lab tested five prototype cigarettes, selected
from remakes of the original set of experimental cigarettes, using both the mockup
ignition method and the cigarette extinction method. The labs were provided with
a written protocol for conducting the tests and all of the necessary test materials,
including the experimental cigarettes.

The results of the interlaboratory tests indicate that the test methods are
repeatable and reproducible within acceptable limits. While NIST believes either
method is appropriate for routine use in measuring cigarette performance, the
Mockup Ignition Test Method is more suitable for use in a performance standard


I. CONCLUSION

In conclusion, the Technical Advisory Group, by a vote of 11 to 4, believes that sufficient technology
and information is available to deem practical the development of a performance standard to reduce
cigarette ignition propensity.

Sincerely,

(LAME

Richard G. Gann, Ph.D.
Chairman, Technical Advisory Group
Fire-Safe Cigarette Act of 1990
and
Chief, Fire Science Division
Building and Fire Research Laboratory

cc: Members, Technical Advisory Group

A-i1




Medical costs were derived from an exhaustive review of data from a variety
of medical data bases, with detailed corroboration and cross-checking. Estimates
for productivity losses, litigation costs, and emergency transport are drawn from
existing and newly-generated data. Pain and suffering estimates, which comprise
a substantial proportion of total costs, are largely based on a thorough analysis of
jury verdicts in fire injury cases. Each of the cost components is based on
averages of observed ranges and represents a conservative approach to estimating
costs.

Conference on Fire-related Injuries

A national conference of leading burn care experts was held to discuss
trends in treatments, costs and outcomes of fire-related injuries. The conferees
noted the substantial reduction in the mortality rates for hospitalized burn patients
over the past two decades led to an increase in the proportion of resources
devoted to extremely severe burn cases. This emphasis on badly burned victims
may tend to increase total costs, especially since treatments being developed for
the most severe burn and anoxia cases are likely to be very expensive. Thus,
costs can be expected to continue to be very high for fire-related injuries. On the
other hand, functional and cosmetic outcomes for less severe burns have improved
dramatically in recent years, and increasing outpatient management of burn injuries
in lieu of hospitalization may tend to curb potential cost increases.

Potential Benefits of Lower Ignition Propensity Cigarettes

The Act does not call for an analysis of the benefits - or costs - of any
specific set of performance or other requirements for cigarette fire safety. The
1987 TSG final report contained analyses of potential benefits and costs
associated with a variety of possible cigarette modifications, but no specific test
method or performance requirements were presented or analyzed. The range of
potential benefits would depend on the nature, technical and commercial
feasibility, and projected effectiveness of any possible requirements. The available
data suggest, however, that substantial fire safety benefits could accompany
reductions in the ignition propensity of commercial cigarettes. While some
currently-marketed commercial cigarettes may have lower ignition propensity,
uncertainty about the commercial feasibility of lower ignition propensity cigarettes
remains. Similarly, the potential net benefits (i.e., net of economic costs) are
unknown, and may be especially sensitive to any possible health effects of altering
the chemical composition of cigarette smoke.

21


Although the societal cost estimates may be conservative, not ali smoking
fires are addressable by widespread use of lower ignition propensity cigarettes.
Therefore, the cost estimates may overstate the likely level of benefits of
mandatory or other action to reduce cigarette ignition propensity. Any future
analysis of the economic efficiency of lower ignition propensity cigarettes would,
however, involve estimating the likely benefits (and costs) to the public of a
reasoned set of alternatives aimed at improved cigarette fire safety.

22



§,_Develop information on changes in the toxicity of smoke and resultant health effects from
Cigarette prototypes: This task reflects the concern that a small increase, due to new cigarette types,
in the serious health risk that, in the view of eleven members of the TAG, already causes over
400,000 smoking-related deaths annually could overbalance the benefits that would be achieved from
the reduction of fires. Since the Act limits spending to $50,000, the TAG agreed with CPSC staff
that any significant amount of actual testing of prototypes was precluded and that the preparation
of a recommended testing protocol would be of high value. CPSC staff, in consultation with the
Department of Health and Human Services (DHHS) and with nominations from the TAG, composed
a panel of five eminent scientists in the field of cigarette smoke toxicity, supported by CPSC and
DHHS representatives, to assist in developing such a plan.

Based on scientific information developed by the expert panel, the CPSC/DHHS recommended and
the TAG concurred that a four-tier, performance-based test protocol be utilized for assessing possible
changes in toxicity of new, low IP cigarettes. A performance-based test was judged scientifically
appropriate due to the significant number of possible design variations of low IP cigarette prototypes.
The protocol comprises: (1) analysis of specific chemical constituents in cigarette smoke incorporating
the FTC protocol, (2) in vitro testing, (3) examination of changes in human smoking behavior of low
TP cigarettes that might change smoke dose and exposure, and (4) in vivo (animal) testing. Each of
the tiers (except number 3) contains specific tests that use currently-accepted and currently-used
scientific technology that may be employed to demonstrate the health and/or safety for products in
the U.S. marketplace and for Federal regulation of consumable products. However, not all health
effects of serious concern are addressed at this time because of the impracticability or non-existence
of adequate tests, high costs, or long periods needed for testing. Definition of acceptable levels of
performance was deemed to be beyond the scope of the Act. Estimated costs for conducting all but
the third tier (for which no estimates are available) are about $330,000 per prototype.

Conducting a selected subset of tests represents a practical first step in implementing the plan. With
input from the experts and the TAG, CPSC/DHHS recommended the measurement of tar, nicotine,
carbon monoxide, pH, benzo(a)pyrene, and tobacco-specific nitrosamines from tier I, and a salmonella
mutagenicity assay from Tier I]. The estimated direct cost for this first step is $6,900. CPSC directed
testing of five cigarette types to demonstrate the practicability of this first step testing. The data
indicate that cigarette types can be distinguished by these toxicological parameters and that the cost
estimates in the plan are reasonable.

Eleven members of the TAG recognize the Toxicity Testing Plan as a substantial contribution to
evaluating the changes in toxicity associated with low ignition-potential cigarettes and finds that it is
a reasonable approach, especially considering the constraints imposed on the expert panel (funding,
time, complexity).

The four cigarette industry representatives agree that changes in smoke chemistry may be expected
to result from large modifications in cigarette design and that careful study of potential health effects
that may be associated with such changes is appropriate. They note, however, that the plan has
limitations as a guidance document and that issues of experimental design and the interpretation of
results will require more detailed assessment than was permitted under the constraints imposed by
the Act. Definition of acceptable performance for modified cigarettes also is critical. The proposed
toxicity plan raises serious questions, but provides few answers at this stage of development.

A-7





in a commercially feasible cigarette without increasing smoke toxicity (assuming that toxicity is repre-
sented by these three yields).

The four TAG members representing the cigarette industry dispute this, citing shortcomings of the
methods used, as noted in the above sections on the two Tasks. They also note that assessment of
the economic and commercial feasibility of low IP cigarettes was not included in the Act. Further,
the six commercial brand styles tested under Task 2 have a minimal market share, indicating
unacceptability to the overwhelming majority of smokers. Consumer testing (by the industry) of
prototype cigarettes incorporating the low-IP features identified in the TSG study has found that they
are not acceptable to smokers.

E. BENEFIT/COST ANALYSIS OF LOW IGNITION PROPENSITY CIGARETTES

Eleven members of the TAG find that a net benefit to the nation can be derived from the
introduction of low ignition propensity cigarettes into commerce, assuming the incremental adverse
health effects do not outweigh the fire safety benefits. This is based on three observations. First,
in appraising the NIST model of economic impact in its Final Report, the TSG concluded that the
cost of modified cigarettes need not be large:

“The overall effects of the cigarette modifications considered may result in only small changes
in the price of cigarettes, unemployment, health care costs, life expectancy, and the financial
status of the affected industries and professions.”

Second, as noted under "Economic and Commercial Feasibility,” cigarettes of reduced ignition
propensity are already being marketed in the same price range of the most popular brands.

Third, there are likely to be significant benefits from low IP cigarettes. The TSG correlation of
mock-up results with chair tests and the current NIST test method report indicate that positive test
Tesults can be expected to be indicative of reduced ignitions for significant portions of the real-world
furnishings population, at least for coarse changes in test performance.

The four TAG members representing the cigarette industry disagree. They assert that cost/benefit
analysis was not authorized or addressed in the current legislation and cannot begin to be conducted
until a reproducible and predictive standard test method has been developed and proposed
performance standards or acceptance criteria have been advanced. A wide range of critical economic
considerations also were identified in the 1984-87 TSG studies as critical inputs to any assessment of
the costs versus benefits of reduced ignition propensity cigarettes. It was found that a cost/benefit
conclusion could not be reached on the data then available, and there has been no further study of
these issues. Cigarette industry data also indicate that a performance standard based on the NIST
methods may increase the propensity of cigarettes to ignite commonly-used cigarette fabrics in real-
world conditions and thereby produce detriments rather than benefits. The four assert that
cost/benefit analysis also should include consideration of alternate approaches to improved fire safety.
They contend that California upholstered furniture flammability standards have proven feasible and
effective in reducing fires and fire deaths beyond any known or realistic prediction of the impact of
modification in cigarette design.

4-10




however, can be derived from estimates of the current societal cost of cigarette
fires as described above. It is unlikely that any performance standard will prevent
all cigarette fires. The estimated level of effectiveness would depend on factors
such as the stringency of the test (where the acceptance criteria are set) and its
precision in accurately predicting ignitability on the range of materials found in U.S.
homes.

Although the Commission concludes that the test method developed by
NIST bears a reasonable relationship with real life conditions, it notes that
additional tests of the kind carried out by industry would be necessary to make the
cost/benefit findings that might be required to promulgate a standard.

29


The choice of air flow conditions presents a similar problem. It is not
practical to represent all air flow conditions, and strict control of managed air flow
can be difficult. The actual location and position of fire-causing cigarettes is not
fully known, but epidemiological evidence suggests that the most typical furniture
location is within a crevice formed by cushions. Air flow rates and air availability
under such conditions are probably random, variable, and typically low. The
negligible air flow rate used in the NIST tests seems fair and reasonable, and has
not been persuasively refuted by industry research.

2. Acceptance Criteria

In order to translate a test method into a performance standard, one must
set an appropriate acceptance (pass/fail) criterion or criteria. How many ignitions,
if any, are acceptable for a prescribed number of tests? The ideal level of
acceptability is one that achieves the maximum benefits in safety at the least cost,
and allows for the known variability in flammability test results.

The Fire Safe Cigarette Act did not direct the Commission or NIST to
establish an appropriate acceptance criterion. However, the Commission has no
reason to believe that an appropriate acceptance level could not be established for
the present test. Some additional lab work might be required to establish the
optimal cut-off point for the number of ignitions allowed.

NIST’s tests were conducted on three different weights of cotton duck,
representing differing levels of ignitability, with 48 replicates per fabric. The
results for the cigarettes tested suggest that acceptable differentiation might be
achieved using only two of these cotton duck fabrics, and possibly fewer
replicates. Test results for specific cigarettes on specific fabrics tended to be
dichotomous - no or few ignitions as opposed to all or nearly all ignitions, a finding
that might facilitate setting an appropriate acceptance criterion.

3. Health Effects

In addition to being a major cause of fire deaths, cigarettes are the single,
major cause of premature mortality in the United States, directly responsible for an
estimated 400,000 to 500,000 deaths annually. It is therefore essential to ensure
that changes in the physical properties of cigarettes for the purpose of achieving
reduced ignition potential do not result in additional adverse health effects. Even a
small increase in human toxicity could outweigh the beneficial effects of fewer
fires.

The $50,000 spending limit to develop information on the toxicity of

ignition-resistant cigarettes precluded any significant amount of testing. Instead, a
panel of health experts drew up a plan for such an assessment, including both a

27


|. Executive Summary

The Fire Safe Cigarette Act of 1990 directed the U.S. Consumer Product
Safety Commission (Commission) and the National Institute of Standards and
Technology (NIST) to carry out research designed to provide an assessment of the
practicability of developing a performance standard to reduce cigarette ignition
propensity, that is, the likelihood that a cigarette will act as an ignition source for
mattresses, upholstered furniture, and similar items. This report describes the
results of that research.

Practicability of Developing a Performance Standard

While the Commission concludes that it is practicable to develop a
performance standard to reduce cigarette ignition propensity, it is unclear that such
a standard will effectively address the number of cigarette-ignited fires. Further,
the effort to achieve such an objective is beyond both the jurisdiction and the
technical capability of the agency. It would, therefore, be prudent for Congress, if
it determines that pursuing this objective is in the national interest, to identify and
delegate to a more appropriate agency the task of working with industry to
develop a performance standard to reduce cigarette ignition propensity.

To this end, broad parameters have been identified through the research
specified in the Fire Safe Cigarette Act. The actual development of a standard
would require the following:

{A) setting appropriate acceptance criteria for the ignition test method;

{B) establishing the appropriate series of tests for toxicity and setting
acceptance criteria for each of those tests;

{C) estimating the safety benefits to be derived from the imposition of such
tests; and

{D) determining the costs to cigarette manufacturers, consumers, and others
of such a standard. The Commission emphasizes the importance of including
toxicity tests in a standard, since even a small increase in toxicity could outweigh
the beneficial effect of fewer fires.

The Fire Safe Cigarette Act directed the completion of several specific tasks,
some of which were to be carried out by NIST, others by the Commission.

vii


of the ignition propensity scale: the commercial cigarette test data (Task 2) establish an indication
of performance for the cigarettes associated with current fire losses; some experimental cigarettes
never or rarely ignited a variety of substrates.

The four cigarette industry representatives believe that consideration of acceptance criteria
presupposes that a reproducible and predictive test method has been developed. At this state, they
contend that neither condition has been met.

c HEALTH EFFECTS

Eleven members of the TAG support use of the CPSC toxicity testing plan in the development of
a performance-based requirement for low ignition-potential cigarettes entering the market. The plan
is a reasonable approach to collect data needed to evaluate major health risks. It could be adopted
as guidance or incorporated into mandatory or voluntary consensus standards. The TAG also
recognizes that improvements in toxicity testing and risk evaluation may occur and should be consid-
ered during possible future revisions of the plan.

These eleven members of the TAG believe that the primary responsibility for the safety of cigarette
products belongs to the cigarette manufacturers. No agency currently has regulatory authority over
cigarettes. They believe that new products should not increase the risk of adverse health effects to
the public above the existing risks resulting from currently-marketed cigarettes, unless such increased
tisk is outweighed by the reduced number of deaths and injuries from the fires prevented. The
toxicity of a candidate low IP cigarette should be compared to a) the specific marketed brand/type
intended for replacement or comparable marketed brands/types for a non-replacement candidate,
and/or b) standard reference cigarettes. Toxicity criteria remain to be set.

The four representatives of the cigarette industry, as noted under Task 6, contend that the plan is
insufficient for guiding regulation. They do agree that careful study of potential health effects is
appropriate.

D. ECONOMIC AND COMMERCIAL FEASIBILITY OF LOW IGNITION
PROPENSITY CIGARETTES

Eleven members of the TAG have considered the extensive series of studies conducted and sponsored
by the cigarette industry subsequent to the TSG’s final report in October, 1987. They conclude that
these studies are not persuasive in changing the TSG’s findings that "it is technically feasible ... to
develop cigarettes that will have a significantly reduced propensity to ignite upholstered furniture or
mattresses."

Indeed, the eleven members of the TAG find that cigarettes of reduced ignition propensity are
already being marketed, presumably at a profit. This is based on the results of the CPSC field study
(Task 4) and the NIST commercial cigarette tests (Task 2). Thus, these members conclude that some
manufacturers have found it commercially feasible to produce and sell cigarettes of reduced ignition
propensity. In addition, the TAG notes that these reduced IP current commercial cigarettes also
show yields of tar, nicotine and carbon monoxide that are no different in the aggregate from the best-
selling cigarettes. Thus, the eleven conclude that it is possible to achieve reduced ignition propensity

AS


PUBLIC LAW 101-852—AUG. 10, 1990

no person assigned to or consulting with the Center for Fire Re
search, the Consumer Product Safety Commission, or the Technical
Advisory Group, shall disclose any such information to any person
‘who is not a member or employee of, assigned to, or consulting with,
the Center for Fire Research, Consumer Product Safety Commission,

committee or committee of the Congress, that if a subcommit-
tee or committee of the Congress requests Consumer Product

fety Commission, the National Institute for Standards and Tech-
nology’s Center for Fire Research, or the Technical Advisory Group
to provide such information, the Commission, the Center for Fire
Research, or Technical Advisory Group shall notify the person who
provided the information of such a request in writing.

Approved August 10, 1990.

LEGISLATIVE HISTORY: H.R. 298:

CONGRESSIONAL RECORD, Vol. 196 (1990):
‘July 30, considered and pessed House and Senste.

B-

104 STAT. 407


Develop Information on the Societal Cost of Cigarette Fires

The Commission estimates that in 1990 the total direct cost of cigarette-
ignited fire deaths, injuries, and property damage was approximately $4.0 billion (in
1992 dollars). The estimated cost of fatal and non-fatal injuries, which comprises
a substantial portion of the total, includes estimates for medical and transport
costs, productivity loss, pain and suffering, and legal and insurance costs. Fatal
injuries, estimated at 1200 in 1990, account for about $2.5 billion of this total;
hospitalized non-fatal injuries, chiefly thermal burns and smoke inhalation, account
for more than $1.0 billion. Direct property damage from cigarette fires comes to
about $500 million annually.

Develop Information on Toxicity and Health Effects (in consultation
with the Secretary of Health and Human Services)

A panel of cigarette smoke toxicity experts developed a plan for testing low
ignition-potential cigarettes. The purpose of the tests is to assure that whatever
changes are made to achieve ignition resistance do not result in increased toxicity
and adverse health effects beyond those that currently exist. Since the
comprehensive set of proposed tests would cost about $330,000 per cigarette
type, a reduced number of tests estimated at $6,900 per cigarette type was
recommended as a practical first step implementation. Five cigarette types,
including two prototype ignition-resistant cigarettes, two commercial brands, and a
standard reference cigarette, were tested according to this reduced protocol. The
results demonstrated that such an approach is practical and that the tests can
distinguish differences among cigarette types.

Technical Advisory Group

The Act named a Technical Advisory Group (TAG) of 15 members
representing the cigarette industry, government, the fire services, and health
groups to advise the Commission and NIST on their work. The TAG met regularly
during the course of this research, offering valuable comments at each stage.
Several members of the TAG representing cigarette manufacturers gave or
sponsored presentations of research that had been independently pursued,
primarily related to the effect of air flow and fabric selection on the ignition
propensity of cigarettes. The majority of the TAG supports the findings described
above; a minority, almost always members representing cigarette manufacturers,
disagrees, questioning primarily the validity of the test methods developed by
NIST. They contend that the test methods have not sufficiently been shown to
represent the way cigarettes ignite furnishings in real life. (The National
Association of State Fire Marshals, although not represented on the TAG, agrees
with this position.) Both majority and minority opinions are described in the TAG’s
final advisory report to the Commission, which appears at Appendix A.


OVERVIEW

Practicability of Developing a Performance Standard

to Reduce Cigarette Ignition Propensity

U.S. Consumer Product Safety Commission
Jacqueline Jones-Smith, Chairman

Beatrice Harwood, Project Manager

August 1993



Table 1
Societal Costs of Cigarette-Ignited Fire-related Injuries
{$ million, 1992 dollars)

Cost Estimated
Component Cost_ —s-_ Percent
Medical 76 2.1
Transport 1 <0.1
Productivity Loss 705 19.7
Pain & Suffering 2,763 77.1
Legal 35 1.0
Insurance/Admin 5 0.1
TOTAL $ 3,585 100.0

Source: Miller, et al, National Public Services Research Institute

Detailed breakdowns of injury cost components on a per-case average basis
are estimated for burns and anoxia (the major injury categories) in Table 2.

Table 2
Estimated Average Per-case Cost Components
for Cigarette-Ignited Burn and Anoxia Injuries
(1992 dollars)

Burns Anoxia
itali Hospitalized
Non- ER Non- ER
Fatal Fatal Only Fatal Fatal Only
Medical 11,199 50,963 698 10,860 4,434 617
Transport 453 211 26 416 253 111

Productivity 530,000 34,000 2,750 530,000 11,000 2,750
Pain & Suff. 1,470,000 785,000 10,700 1,470,000 105,000 9,500
Legal 19,000 8,500 {¢) 19,000 1,500 i?)
Ins./Admin. 816 3,582 51 789 328 51

TOTAL 2,000,000 875,000 14,000 2,000,000 125,000 13,000

Source: NPSRI. Estimates are based on breakdowns for civilian injuries

20




Fire Safe Cig. tte Act of 1990

Under the Cigarette Safety Act of 1984 (P.L. 98-567), the Technical Study Group on Cigarette and Little
Cigar Fire Safety (TSG) found that it is technically feasible and may be commercially feasible to develop
a cigarette that will have a significantly reduced propensity to ignite furniture and mattresses. Further-
more, they found that the overall impact of such a cigarette on other aspects of the United States
society and economy may be minimal.

Recognizing that cigarette-ignited fires continue to be the leading cause of fire deaths in the United
States, the Fire Safe Cigarette Act of 1990 (P.L. 101-352) was passed by the 101st Congress and signed
into law on August 10, 1990. The Act deemed it appropriate for the U.S. Consumer Product Safety
Commission to complete the research recommended by the TSG and provide, by August 10, 1993, an
assessment of the practicality of a cigarette fire safety performance standard.

Three particular tasks were assigned to the National Institute of Standards and Technology’s Building
and Fire Research Laboratory:

* develop a standard test method to determine cigarette ignition propensity,

* compile performance data for cigarettes using the standard test method, and

* conduct laboratory studies on and computer modeling of ignition physics to develop valid,
user-friendly predictive capability.

Three tasks were assigned to the Consumer Product Safety Commission:

+ design and implement a study to collect baseline and follow-up data about the characteristics of
cigarettes, products ignited, and smokers involved in fires,

* develop information on societal costs of cigarette-ignited fires, and

* in consultation with the Secretary of Health and Human Services, develop information on changes
in the toxicity of smoke and resultant health effects from cigarette prototypes.

The Act also established a Technical Advisory Group to advise and work with the two agencies.
This report is one of six describing the research performed and the results obtained. Copies of

these reports may be obtained from the U.S. Consumer Product Safety Commission,
Washington, DC 20207.


disparate views reflected in this report, the four cigarette industry representatives comprise the
minority.

A-2



DIETRICH HOFFMANN, PHD, PROPOSED TESTS FOR THE ANALYSIS OF TOXIC
SMOKE CONSTITUENTS AND IN VIVO BIOASSAYS FOR CARCINOGENICITY.

Gary GAIROLA, PHD, SUGGESTED SHORT-TERM TESTS FOR THE EVALUATION
OF TOXICITY.

Panel Findings

Adverse health effects that determine the nature of required toxicity tests
include the following: lung and throat cancer, chronic obstructive lung disease,
heart and vessel disease, male and female reproductive effects, fetal growth
retardation, and psychophysiological addiction. Not all of these health effects can
be addressed at this time because of the impracticality or non-existence of
adequate tests, high costs, or long periods of time needed for testing.

Other major issues surrounding the testing included evaluation of sidestream
smoke, analytical vs. in vitro vs. in vivo testing, machine reflection of human
smoking behavior, performance vs. design-based testing, screening models, and
disclosure of new additives or increased levels of existing additives.

A smoking machine protocol for measuring nicotine, carbon monoxide, and
particulate matter (tar) was developed by the Federal Trade Commission. It is the
only required toxicity testing for cigarettes in the U.S., and it prescribes no limits
of acceptability. However, cigarette smoke contains more than 3,500 chemicals.
The panel agreed that present knowledge on the adverse health effects and toxic
constituents of cigarette smoke dictated further testing beyond the FTC
requirements.

Since low ignition-potential cigarettes might cause changes in smoking
behaviors and therefore modify the toxicity, altered human behavior may become a
significant factor in exposure. Analysis of selected chemicals known to be
associated with adverse health effects may not be sufficient to predict the net
toxicity of the smoke. /n vitro and in vivo testing are needed.

16



V. Practicability of Developing a Performance Standard

The research described above is relevant to the final and most critical of the
directives of the Fire Safe Cigarette Act - an assessment of the practicability of
developing a performance standard to address cigarette ignition propensity. There
are at least five aspects to such an assessment:

1. development of an acceptable test method

2. appropriate acceptance criteria for such a test
3. possible adverse health effects

4. economic feasibility

5. cost/benefit determinations

A

discussion of each of these aspects follows.
1. Development of an acceptable test method

The first requirement for a performance standard is the development of a
valid and reliable test method for measuring cigarette ignition performance. (A
valid test is one that measures what it is intended to measure, in this case the
likelihood that a cigarette will start a fire under real life conditions. A reliable test
is one that produces similar results when repeated by operators at the same or
other laboratories, assuming reasonable diligence in following the test protocol.)
NIST’s test method research was the single most important task specified in the
Act.

The Commission shares NIST‘s and the TAG’s conclusion that the research
during the present study, together with research undertaken from 1984 to 1987,
establishes the validity and reliability of their test methods within reasonable limits.

Members of the TAG who represent cigarette manufacturers, as well as
representatives of the National Association of State Fire Marshals, claim that the
test methods developed by NIST are inadequate. Their primary contention is that
the test method developed by NIST is not sufficiently related to real life conditions,
particularly in terms of the test fabrics and air flow conditions in the test chamber.
They have introduced considerable testimony to this effect at TAG meetings and
have submitted a large quantity of written materials.

Representatives of cigarette manufacturers have introduced data indicating
that under some air flow conditions and with some fabrics, there is a reversal of
ignition propensity ranking from the NIST tests; that is, cigarettes that showed few
ignitions using the fabrics and air flow conditions specified in the NIST test method
showed many ignitions when tested on certain other fabrics or under certain other

25


D. Cigarette Fire Incident Study

The Fire Safe Cigarette Act directed the Commission to collect data about
the characteristics of cigarettes, smokers, and materials ignited in cigarette fires.
Using two independent contractors, the Commission conducted a field study of
cigarette fires and a survey of smokers in the communities where the fires
occurred. The primary purpose of the study was to determine whether any
physical characteristics of currently manufactured cigarettes were significantly
associated with the risk of fire, after controlling for other cigarette and smoker
characteristics.

Data Collection on Fire Incidents

The National Fire Protection Association was the contractor for the field
study. With the cooperation of fire departments in Baltimore, MD; Cleveland, OH;
Columbus, OH; Dallas, TX; Denver, CO; Houston TX; Philadelphia, PA; and
Portiand, OR, the contractor collected data over a 13 month period, from
December 1991 through December 1992. During that time, 564 fires were
reported for which the attending fire department could determine the identity of
the smoker and the brand of cigarette believed to have started the fire.

Data Collection on Smokers

Mathematica Policy Research, Inc., the Commission’s contractor for the
comparison group of smokers, collected demographic and cigarette preference data
from a sample of smokers in the same geographical areas served by the eight
participating fire departments. The sample was drawn by random digit dialing from
telephone exchanges within the fire department service areas. Information was
collected on ail smokers in a given household, as reported by one adult member of
the household. After the elimination of data from households not located within
the fire department service areas and from households where fires had occurred
within the last year, 1,611 smokers comprised the sample that served as a
comparison for the fire incident group.

11


Members of the Technical Advisory Group (Continued)

Dr. Jerry F. Whidby
The Tobacco Institute

Ms. Judith P. Wilkenfeid
Federal Trade Commission

Mr. James M. Williams, Sr.
Business and Institutional Furniture Manufacturers Association
Former Members

Dr. James Charles
The Tobacco Institute

Mr. Roger Lanahan
Federal Emergency Management Agency




L APPRAISAL OF TASKS UNDER "COMPLETION OF FIRE SAFETY RESEARCH"

With one month remaining in the lifetime of the Act, the TAG is confident that CPSC and NIST
staff will complete all six of the mandated tasks. Eleven of the members of the TAG find that the
work performed under the Fire Safe Cigarette Act of 1990 meets both the specific directives of the
Act and responds to the overall intent. The four cigarette industry representatives, supported by
industry-supported or -generated data and analyses, have expressed strong criticism of the quality and
suitability of many of those products. Their assertions have generally been found non-persuasive by
the other eleven members. Specific manifestations of both these positions appear under the
discussion of the individual tasks.

A. NIST Tasks:

1. Develop a standard test method to determine cigarette ignition propensity. The TAG feels that
this is the most important of the tasks and, as such, it has received the most attention. The TAG

members have reviewed near-final documentation of the test method development.

Conducting new research and building on research performed under the direction of the Technical
Study Group (TSG) under the Cigarette Safety Act of 1984 and related work performed by the
cigarette industry, NIST has developed two test methods:

. The Mock-up Ignition Test Method uses three types of simulated upholstery cushions, each
with a different cigarette ignition susceptibility. Each assembly (substrate) consists of a top
layer of one of three weights of cotton duck fabric; a cushion of a polyurethane foam; and,
in the least susceptible substrate, a thin layer of thermoplastic film in between. The perfor-
mance measure is whether or not the mock-up is ignited by the cigarette placed on it.

: The Cigarette Extinction Test Method replaces the more complex substrate with 3, 10, or 15
layers of standard cellulosic filter paper. The performance measure is whether the cigarette
extinguishes before burning its full length, ie., whether the substrate absorbs enough heat
from the cigarette coal to extinguish the cigarette.

Eleven members of the TAG have accepted the two methods and commend them as successful
completion of this task, believing that both methods have valid links (comparable to many current
fire test methods) to real-world fire scenarios of concern. NIST has incorporated most of the
relevant physics and chemistry of such ignitions, while replicating the real-world hazard to sufficient,
but differing extents. Both tests offer the use of a graded measure of performance, where a range
of acceptable levels can be set by the regulator, although neither NIST nor the TAG have addressed
specific regulatory criteria. Ignition propensity measurements using the two tests are consistent with
each other and with other IP data. These TAG members also accept the provided basis for using
only flat substrates, conducting all testing without externally-imposed air flow, and use of the selected
substrate materials. The test materials are deemed likely to be available, with long-term consistency,
in the foreseeable future. In general, the eleven are not persuaded by the cigarette industry
representatives’ assertions that the test methods are inaccurate or inappropriate.

A3


3._Conduct laboratory studies on and computer modeling of ignition physics to develop valid, “user-
friendly" predictive capability. In September, 1992, NIST published a personal-computer-based model
of a multi-layer substrate subjected to a stationary heat source with computer graphics and full
technical documentation. The model, an upgrade of the version developed under the prior Act,
shows promise in replicating limited experimental data on ignition by a stationary heat source. The
intent is to use the model in conjunction with a model of a burning cigarette (to be completed in
June, 1993) to simulate the cigarette ignition process. The TAG acknowledges the first report as
completion of this part of the task. The TAG has not yet received the final report containing the
cigarette burning model and the protocol for using the two models together.

‘Two of the cigarette companies have recently requested copies of the software. In a preliminary
review, one has noted that the program executes in a relatively short time, has improved numerics
compared to the original version, and is easier to use if all the input parameters are known.
However, the model is limited in use because of the absence of the partner cigarette burning model
and poor handling of oxygen diffusion. Use of the model would be promoted by having a catalogue
of the thermal and kinetic properties required by the model for different fabrics and foams.

NIST has performed several examinations of aspects of the physics of the ignition process in
developing both the test methods and the computer models. These have been tightly related to the
development of the test methods and the computer models. They include: chemical kinetic profiles
(via thermogravimetry) of fabric decomposition in air, analysis of cigarette-to-substrate heat transfer,
analysis of oxygen transport to the ignition site, development of a small heat source to simulate the
energy flux from the cigarette coal, generation of ignition delay time and ignition temperature data
(as functions of the oxygen level, weight of substrate fabric, padding, and applied heat flux) for model
verification, and measurement of ignition environment by infrared thermography.

B. CPSC TASKS:

4, Design and implement a study to collect baseline and follow-up data about the characteristics of
cigarettes, products ignited, and smokers involved in fires. The aim of this study was to examine
whether any physical characteristics of currently-manufactured cigarettes affected the risk of fire, after
controlling for all other known smoker and cigarette characteristics. Working with the fire depart-
ments in eight cities, the National Fire Protection Association (NFPA), under contract to CPSC, has
obtained data on 564 smokers (and their cigarettes) involved in fires. A second contractor,
Mathematica, obtained telephone data about 1611 smokers who did not have fires. The TAG has
teviewed a draft report from NFPA.

Using a logistic regression model, and after controlling for all other variables, four cigarette
characteristics were found to have a statistically significant effect on the risk of a fire: the presence
and length of a filter, paper porosity, and pack type (soft pack or box). The last was more
pronounced among men than among women. Education level, gender, and especially income level
were significant smoker characteristics.

The systematic, wide variation of certain composition factors (e.g., tobacco density, circumference,
paper porosity, and citrate in the paper) of the experimental cigarettes in the TSG research enabled
analysis of their impact on ignition propensity. Commercial cigarettes do not necessarily lend
themselves to similar analysis. For instance, most of the commercial cigarettes in this study were in

AS


Research to be Completed by NIST:
Develop a Standard Test Method

This was the most important of the tasks specified by Congress: to develop
a standard test method for measuring cigarette ignition propensity. NIST
developed two test methods. One, the mockup ignition test method, measures the
number of ignitions when cigarettes are placed on three types of simulated
upholstery cushions with differing levels of ignition susceptibility. The second, the
cigarette extinction test method, substitutes differing layers of filter paper for the
furniture mock-ups and provides a more indirect measure of cigarette ignitability.
Of these, the mock-up test is more suitable for use in a performance standard
because it appears capable of providing better discrimination among cigarettes of
high or moderate ignition propensity.

Test Commercial Cigarettes

NIST tested 20 selected brands of commercial cigarettes using the test
methods described above. Several cigarettes performed significantly better than
others on these tests, indicating that commercially marketed cigarettes differ in
their probability of igniting soft furnishings, as measured by the mock-up test.

Conduct Laboratory Studies and Computer Modeling

NIST has developed a computer model of a multi-layer material (substrate)
subjected to a stationary heat source with clear computer graphics and full
technical documentation.

Research to be Completed by the Commission:
Implement a Fire incident Study

The Commission conducted a study of the "characteristics of cigarettes,
products ignited and smokers involved in fires." Through the services of
contractors and local fire departments, it collected data on cigarette fires in eight
U.S. cities and data from a companion survey of smokers in those same areas.
Statistical analysis of the results indicated that, after adjusting for smoker
characteristics and other cigarette specifications, the following cigarette
characteristics significantly affected the risk of having a fire: filter presence and
length, wrapping paper porosity, and whether the cigarette was packed in a soft
pack or a box. Smoker characteristics that affected risk were gender, education,
and (especially) family income.

These findings also suggest that cigarettes already in the marketplace differ
in their likelihood of starting a fire.

viii