S.JC-:.I;w
Sth Seotember 1974
NOTS ON THE CURR-MiT STATUS OF SUBSTITU`r_-_S
PLID POLICY
Q=rent trendz i33 tobacco prices gives added
incentive
to exploring further use of reconstituted tobacco
and non-toba=0
substitutes. B.A.T. policy on the use of
substitutes has bean
stated since 1962 as follows:
"We will not use substitutes unless there
-is a demonstrable advintage on healt12
grounds".
Since that time our policy has been modified in
scuze respects.
largely by the interpretation of what we mean by
"cie nmtxable
advantage". The present position is that we regard
a matexi~l
as havizg a. de natxable advantage if it gives
cigarettes with,
lower tar and lower n1cotine and with carbon
monoxide no higher
and shows no increase ijx biological activity. The
Eimtez
Committee Guidelines have now helped us to clarify
what we =earL
by biological activity: this should cover an
examinat-iort of the
chemistzy of s=okQ including materi-1-- suc-la as
benzzyrene,
nitrosamines, hydrogencyanide, etc., it should
=ver tests for
tumor igerLicity both by skin Dainting and by
inhal-at--;=, it should
also involve some general inhalation toxicology.
i~-..Lat2r, of course,
is developing his Guide1ines further to include
cli=ical azd other
hu=aa stuLes. B.A.T. could go fux-Lhar thaa
HuatQ--- in one respect:
We could take cognizance of the
initiation/promotio= h a is
ym_o th -3
and ai= to get both a reduction in total
tu=origenic--ty and La
prazation acti-jity;.
A list of substitutes and their present status is
attached. To my knowledge only two of these are
likely at
present to show a demonstrable advantaga on health
grounds
that would satisfy us: these axe CYT-'--I- and
N-14.
Presumably we wou ld only use tobacco substitutes
if
they prove to be profitable in the broadest sense,
i.e. acceptable
to the consumer, acceptable to the cigarette
manulactoxer, ..
avail-ble- at the right price, etc. One other
condition, of
coursep is t-hat the!r mmld not contravene the law
in the market
for hich the use is intended- Befoxe they axe used
in any
z)articula.r market careful considexation would
also have to ba
givan to any change in the legal position with
respect to
consumers.
In rxy view the fact that tobacco have
been accepted for sale by the German Federal
Fealt~i Ainjst=7
does not necessaxil7 constitute a demonstrable
advantage on
h2 alth grounds or provide a basis for use in any
other count--y.
'rhe tests r-axr-4ed out under the Ger=an law by
Professor Kzlle
consistz only of simple pyrolysis tests and
benz-oyrene dat2r=in-
ation, on this basis 13ATFL-UM, CYTREEL and N34
have all been cleared.
Equally although the Hunter Guidelines are very
=uch --ora 2-xtensive
it does not follow that clearance by Funterwould
be satisfactOr7
.for clearance either by B.A.T. or for use in
another cOunt=7-
Contd.
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BATCo document for Province of British Columbia 27
October 1999


2 -
TI-Li-% last rais-as impoxtan-c questions. If - as
for
pro=tion - we regard Hunter Guidelines as
inadequate should we
do ou-- ut=ost to got the Guidelines enlarged or
should vm be
gratatta for small mercies. Should we in-sist on
more st-riz9ant
requirements to satisly B.A.T. than axe required
to satisly
Huntext or for that matter Krdla--" In my view we
should get
the best legal advice we cam with regard to
potential markets
and our re sponsibi 1-i ties as manufacturers.
This advice will
almost certainly require us to act responsibly and
it may be
necessary to get independent medical advicQ.
Suggested actions are as follows:-
1. We sh-ld got legal advice on our position if we
u-
substitutes im. the United Kingdom. Perhaps simi
laxly
opinions could be sought in U.S.A., Cana"- and
Austxal-4..
2. We have pro=tsed to propose to American
Celane-se a draft
agreement for the purchase of CYTREL. This would,
if
accepted, commIt us to buying a given quantity of
C7Y=ML
contingent upon CYTRF-L In substantial quantities
in cigarettes on sale in the U-K- This zvould
cover both
consumer acceptance and any revision In. Hunter
requirements
or reversal after testing on humans.
3. We should aim to get a similax understanding
vrith !DL for
N SM.
4. We shcruld continue to press on with BAVFLA=
development
and a proposal will be put to the Tobacco Board in
this
resiDect on the 20th Seotember.
5. We should make an approach to Courtaulds to
explore the
possibility of some co-operation or a phased joint
ventura.
The main att=action here is that it is Likely that
they
could quickly engage ia large scale proch=tion.
6. We should diligently i.-iform. ourselves irith
respect to the
other materials. part-;cmla-rly Scusta which is
being t2sted
by the N.C.I. in America.
7. We will make a point olE ec-amining the Bayer
material when,
it ampeaxs in Ree=tsmals cigarettes and t.ras
becomes
*'*Ie to us, at least for la:Doratory vork.
a
va.il~
8. We should continue th2 davelop=ent Of
rZCOMSt-ztUt2d
substitutes with lo-xer biolog-kcal activity.
S.J.G;Z7--CN
Enc:
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BATCo document for Province of BritiSh Columbia 27
October 1999


APFF-?fDl-'C r
B.A.T. product based on chalk and socLiu=
carboxymethyl cellulose.
Approaclhinq.decision stage for se=.i-c rcial
plant.
Weak but useful patent position.
Probably~'i~ per 1b.
N.S.M. Product of Imperial Developments Ltd.
Full scale 20 - 30 million lbs/year plant under
construction.
Partially oxidised.ce/llulose.
Useful patent protection.
Expensive - probably over S I/lb.
C1. T-IREL Product of American Celanese
Corporation.
Full scale 10 million lbs/year plant under
construction-
Inorganic additives with cellulose bondex
probably caxboxymethyl cellulose.
Useful patent protection - not impregnable.
Price at present values about 75 Vlb.
ECUSTA Product of Ecusta.
Believed at pilot plant scale but probably no
problem in production as is essentially cellulose.
No patents.
Probably 50 d /1b.
No biological claims but under test by N.C.I.
COURTAULDS No public-information. Probably
viscose.
No patents known.
Price - not to be offered for sale but cost
is probably around 60 & /lb-
Could be produced readily.
BAYER No information but will be on test in
Germany
and samoles can then be examined.
Almost certainly cellulose based.
Batflake type product based an aluzi.=iu=
compounds.
Laboratory stage.
Vegetable reconstitution. No biological
in-formation.
May be on sale in U.S.A. in 1974.
Dfj-3NT No knowledge
S~U.W PRODUCT Presumed dead - .-;as reconstituted
veegptable wast2
but effectively flavoured.
SUTTON REESEAROi Turned down by IDL, B5W and SAT.
Patentad.
Cellulose based.
SJ(3:.qw
5.9.74
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(Z)
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BATCo document for Province of BritiSh Columbia 27
October `1999