~a~ ~0
AUGUST 20, 1985
PROJECT EMN
P H A S E I
A. CONCEPT - NOT MARKETING ORJEN7ED
- NO FINANCIAL'RESTRICTIONS
B. THEIR DEFINITION OF THE PROBLEMS
SURGEON GENERAL
ROYAL COLLEGE OF PHYSICIANS
C. DEFINITION TO INCLUDE RELATIVE VALUES OF
SPECIFIC
TOXIC COMPONENTS IN DIFFERENT SOURCES
I.E. SOIL, AIR# WATER AND FOOD
P.J. DUNN
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D. TOXIC AGENTS - 6AS PHASE AND PARTICULATE MATTER
IDENTIFICATION By CATEGORY
AND.
IDENTIFICATION OF SOURCE
S.R. HASSEY
E. EVOLUTION OF THE SMOKING AND HEALTH ISSUE
MECHANISM OF MEDICAL METHODOLOGY
MECHANISM OF THE AMES TEST
BENCH MARKS OF EVOLUTION
M. BILIMORIA
F. EVOLUTION OF THE PRODUCT
GROSS REDUCTION
SELECTIVE REDUCTION OF SPECIFIC
SMOKE COMPONENTS
6. WHAT WOULD BE ACCEPTABLE AS A SAFER CIGARETTE
LITERATURE REVIEW
C. WARREN
BATCo document for Province of British Columbia 28
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R E V I E W
1 9 6 2
REPRESENTATION OF
AMERICAN CANCER SOCIETY
AMERICAN COLLEGE OF CHEST PHYSICIANS
AMERICAN HEART ASSOCIATION
AMERICAN MEDICAL ASSOCIATION
TOBACCO INSTITUTE INC.
FOOD AND DRUG ADMINISTRATION
NATIONAL TUBERCULOSIS ASSOCIATION
FEDERAL TRADE COMMISSION
PRESIDENTS OFFICE OF SCIENCE & TECHNOLOGY
MET WITH THE SURGEON GENERAL TO ESTA.BLISH THE
WORK OF AN
EXPERT COMMITTEE AND TO AGR.EE ON A LIST OF S014E
150 SCIENTISTS
AND PHYSICIANS QUALIFIED TO EVALUATE DATA ON THE
RELATIONSHIP
BETWEEN TOBACCO USE AND HEALTH.
THE SURGEON GENERAL SELECTED 10 FROM THE LIST AND,
THUS, THE SURGEON GENERAL'S ADVISORY COMMITTEE ON
SMOKING
AND HEALTH WAS LAUNCHED AT ITS FIRST MEETING OF
NOVEMBER 9, 1962.
THE JUDGMENTS OF THE ADVISORY COMMITTEE LED TO A
SERIES
OF CONCLUSIONS RELEASED IN 1964 IN THE 'REPORT OF
THE ADVISORY
COMMITTEE TO THE SURGEON GENERAL OF THE PUBLIC
HEALTH SERVICE
ON SMOKING AND HEALTH.'
THE COMMITTEE CONCLUDED!
"CIGARETTE SMOKI NG IS A HEALT"HAZARD
OF SUFFICIENT IMPORTANCE IN THE UNITED
STATES TO WARRANT APPROPRIATE REMEDIAL
ACTION.'
c::)
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9 7 9
FIFTEE-N YEARS AFTER THE INITIAL 'SURGEON
GENERAL'S
REPORT' THE U.S. DEPARTMENT OF HEALTH, EDUCATION
AND WELFARE
PUBLISHED
a SMOKING AND HEALTH A REPORT OF THE
SURGEON GENERAL'
THIS REPORT IS A COMPENDIUM OF NEW DATA FROM MANY
SOURCES INCLUDING THE- OFFICE ON SMOKING & HEALTH
AND THEIR
REPORT ON THE EXPERT PANEL CLASSIFICATION OF
COMPOUNDS
IN CIGARETTE SMOKE.
Toxic and Carcinogenic Agents
Compounds in cigarette smoke have been classified
by an expert panel
into:
1. Those judged most likely to contribute to the
health hazards of
smoking.
(a) Carbon monoxide (gas phase).
(b) Nicotine and "tar" (particulate phase).
2. Those judged as probable contributors to the
health hazards of
smoking.
(a) Gas phase: acrolein, hydrocyanic acid, nitric
oxide and nitrogen
dioxide.
(b) Particulate phase: cresols and phenol.
S. Those judged as suspected contributors to the
health hazards of
smoking.
(a) Gas phase: acetaldehyde, acetone,
acetenitrile. acrylonitrile,
ammonia, benzene, 2-3 butadione, carbon dioxide,
crotononitrile,
ethylamine, formaldehyde, hydrogen sulfide,
metbacrolein, meth-
yl alcohol, and methylamine.
(b) Particulate phase: butylamine, dimethylamine,
DDT, endrin,
furfural, hydroquinone, nickel compounds,
pyridine.
These cornpound3 have been so designated not only
because of their
harrrLful actions but also because of their
concentrations in tob
smoke. Although other constituents are considered
toxic, they are not
present in concentrations deemed a health hazard.
A number of tumor initiators, co-carcinogens, and
organ-speaic
carcinogens have been isolated and identified. The
majority of Co.-
carcinogens remain to be identified. The increased
risk ci1rAmtte
smokers have for cancer of the esophagus, kidney,
and urinary bladder
suggests the possibility that cigarette smoke
contains unidentified
organ-5pecific carcinogens besides the known trace
arnounta of
carcinogenic aromatic and N-nitrosamines.
SMOKING Z HEALTH A REPORT OF THE SURGEON GENERAL
INTRODUCTION 9 SUMMARY
OFFICE ON SMOKING & HEALTH 1-30
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IN THE PREFACE TO THE 1979 'SURGEON GENERAL-S*
REPORT.
THE SURGEON GENERAL REFERS TO A 1966 PUBLIC HEALTH
SERVICE
REPORT THAT STATEDII
THE PREPONDERANCE OF SCIENTIFIC EVIDENCE
STRONGLY SUGGESTS THAT THE LOWER THE
'TAR' AND NICOTINE CONTENT OF CIGARETTE
SMOKE, THE LESS HARMFUL WOULD BE THE
EFFECT 9
PREFACE XII
THIS WAS FOLLOWED BY THE DECISION OF THE FEDERAL
TRADE
C014MISSION TO BEGIN MEASURING THE 'TAR' AND
NICOTINE YIELDS
OF CIGARETTES AND TO PERMIT MANUFACTURERS TO BEGIN
USING
THIS INFORMATION IN THEIR ADVERTISING.
THIS IN TURN TRIGGERED:
CHANGES IN CIGARETTE PRODUCTION TECHNOLOGY
DEVELOPMENT OF RECONSTITUTED TOBACCO
REFINEMENT OF CIGARETTE FILTERS AND PAPER
MEN TOBACCO STRAINS
TO MENTION A FEW.
THE OBJECTIVE WAS TO REDUCE THE 'TAR' AND NICOTINE
OF CIGARETTE SMOKE.
THE IMPACT OF THESE CHANGES IS NOTED IN THE
FOREWORD
OF THE 1982 REPORT.
'THE HEALTH CONSEQUENCES OF SMOKING'
A REPORT OF, THF SURGEON GENERAL
Lower Tar Cigarettes
This report also notes that smokers who use
filtered or lower tar
cigarettes have statistically lower death rates
from lung cancer than
do cigarette smokers who use nonfiltered or higher
tar brands. This
reduced risk was also noted ror laryngeal cancer.
However, cancer
death rates for smokem or lower tar cigarettes
were still significantly
higher than those noted for nonsmokem.
Edward N. Brandt. Jr.. M.D.
Assistant Secretary for Health
(-n
CD
~_n
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-4-
IN THE 1979 'SMOKING AND HEALTH A REPORT OF THE
SURGEON
GENERAL', JULIUS B. RICHMOND, M.D. STATES
Adhering to this spirit of inquiry and rewg-nizing
the magnitude of
the public health problem, we must ask: What is
our current
knowledge about "appropriate remedial action?"
What scientific,
economic, and behavioral facts are important for
the design of public
policy toward cigarette smoking? What have we
learned so far, and
where do we go from here?. To answer these
questions, we must
confront three central facts: Individuals vary in
their health risks
associated with cigarette smoking. Individuals
vary in their cigarette-
smoking behavior. The cigarette product itself is
changing.
vii
PREFACE VIJ
T14E LAST SENTENCE 'THE CIGARETTE PRODUCT ITSELF
IS CHANGING'
LEADS TO THE THEME OF THIS PROJECT I E. NOW DO. WE
DESIGN
AND MANAGE FUTURE PRODUCT CHANGES?
THE NATIONAL CANCER INSTITUTE PORTION OF THE
'SMOKING
AND HEALTH A REPORT OF THE SURGEON GENERAL"
CONTAINS THEIR
THOUGHTS RELATIVE TO PRODUCT CHAkGE.
In this chapter we sill consider the tobacco as a
raw material, how it
is made into cigarettes, the cigarette smoke
generation proce-'s, the
composition of cigarette smoke, physiological
responses to cigarette
smoke, the pharmacology of nicotine as a component
of cigarette
smoke, and efforts to define less hazardous
cig-drettes through
cigarette smoke modification. Also, consideration
will be given to the
effects of smoke characteristics on smoking
behavior and, therefore, on
the dose inhaled by man and ex&rimental animals.
14-9
THESE THOUGHTS WILL BE AMPLIFIED IN THE FOLLOWING
PARTS OF THIS REORT.
C:D
<ZD
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A PARALLEL ACTIVITY IN THE FIELD OF SMOKING AND
HEALTH
WAS TAKING PLACE IN GREAT BRITAIN.
1 9 5 9
THE ROYAL COLLEGE OF PHYSICIANS OF LONDON SET UP A
COMMITTEE TO:
aREPORT ON THE QUESTION OF SMOKING
AND ATMOSPHERIC POLLUTION IN RELATION
TO CARCINOMA OF THE LUNG AND OTHER
ILLNESSES'
AND HAD DIFFICULTY IN WORKING WITH TWO VARIABLES
SO THAT
IN:
1 9 6 2
THE FIRST REPORT 'SMOKJN6 AND HEALTH' WAS
PUBLISHED.
1 9 7 1
THE SECOND REPORT BY. THE ROYAL COLLEGE' OF
PHYSICIANS
OF LONDON 'SMOKING AND HEALTH NOW' WAS PUBLISHED.'
CHAPTER 3 OF THAT REPORT 'THE CHE141STRY AND
PHARMACOLOGY
OF TOBACCO SMOKER IDENTIFIES THE SUBSTANCES OF
MEDICAL
IMPORTANCE AND GROUPS THEM INTO FOUR MAIN GROUPS.
C_-
C-_
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-6-
a Known cancer-producing substances. These are of
two kinds:
carcinogens or cancer initiators, which have been
shown
by themselves to induce cancer in experimental
animals,
and co-carcinogens or cancer promoters, which do
not
themselves produce cancer but accelerate its
production
by cancer initiators.
6 Irritani jub.0ances. Ilese may stimulate
secretion or mucus
in the bronchial tubes and bihibit the action of
the cilie
fining them. some orthese irritants are also
co-carcinogens.
c Vicolint. IlLis has a wide range of
pharmacological actions
on tissues throughout the body, especially on the
nervous
system.
d Carbon monoxide and other gaits. Carbon monoxide
interferes
with the blood's capacity to carry oxygen or with
the use
ofoxygen in the tissues. There are other
chemically active
gases, including oxides of nitrogen and hydrogen
cyanide,
the effects ofwhich in the low concentrations
occurring in
tobacco smoke are uncertain.
36 Stnoking and Hedth Now
1 9 7 7
THE THIRD REPORT BY. THE ROYAL COLLEGE OF
PHYSICIANS
OF LONDON 'SMOKING, OR HEALTH WAS PUBLISHED.
c::>
C-7:>
tl-n
c0
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PAGES 25 AMP 26 OF THIS REPORT CONTAIN THE
FOLLOWING:
Less Harmful Smoking Habits
The tobacco manufacturers have been steadily
reducing the tat and nicotine
delivery of their cigarettes in recent years by
changing the tobacco leaf
used. and by increasing the efficiency of filters.
Forty years ago. one of
the most popular cigarettes had far and nicotine
yields of 36 and 3.3 rns
respectively (30). If these figures were typical
for that period. average
yields were skeady considered lower in 1965 when
regular analyses were
started (Table 11). Since then, owing especially
to the large rwitch from
plain to r0ter-tipped brands of cigarettes, them
has been a further striking
fall in the average amount of tar and nicotine to
which British smokers
expose themselves (Table 12).
Table 1.2
Saks-weigh ted Avenge Tar and Nicotine Yields of
Cigan ties Sold in the UK I %S to 197S
raw Mean Tar Afean Nicotine
Yield (nW Yield (OW)
1965 31.4 2.08
1967 26.0 1.92
1969 23.9 1.67
1971 21.3 I.S1
1973 18.7 1.44
1975 17.9 1.3S
Change 1965-75 -13.5 -0.73
% Change -43 -35
Figures supplied by the TRC
PAGE 121, UNDER THE HEADING OF 'LESS HARMFUL
SMOKING,'
CONTAINS THE FOLLOWING;
Iteducing the hamful constituents of cigarette
smoke. Since we do not
know precisely which of the many hundreds of
chemical compounds in
ithe smoke of cigirettes are responsible for
cancers, bronchitis, emphysema,
or damage to the heart and blood vessels, we
cannot specify exactly what
constituents in the smoke should be reduced to
lessen the risk. But most
smoking-Telated cancer% are probably caused by
carcinogenic substances
in the 'tar' fraction of the smoke, and it has
been shown that American
smokers who for at least ten years have smoked
only filter-tipped cigar.
ettes (which lave a lower tar delivery than plain
cigarettes) have their
dsk of getting lung cancer almost halved (46). A
mote recent, larger study
indicates that the tisk is reduced by only sortie
20 per cent (I 5s).
BATCo document for Province of British Columbia 28
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a HEALTH OR SMOKING.'a FOLLOW-UP REPORT OF THE
ROYAL COLLEGE
OF PHYSICIANS
CHAPTER THREE PAGE 23
TABLE ).I. Changes in England and Wales male lunS
cancer death rates in early
middle age since tar deliveries have been reduced
Age at time Death rates pet million men from
cancers, of
ofobservation the respiratory tract. excluding
larynx
Men born in about Men born in about
1910, and observed 1930-1950, and Ratio
In 1940-1960 observed in 1980
30-34 39.. 13 0.3
33-39 98.. 45 0.3
40-44 253- 134 0.5
4"9 597** 379, 0.6
High mean tar intake ordy in first decade or so of
smoking history
High mean tar intake throughout smoking history
CHAPTER NINE PAGE 87
Len dangerous lonns ofamoking? 87
0 urnzes in national lung cancer deaths
As pointed out earlier (Figure 3.1) there has been
an important down-
ward trend in lung cancer mortality in men or all
ages fin the United
Kingdom. In women this trend has been seen only in
the youngest age
groups. In seeking an explanation for these trends
the influence of
smoking habits 20-30 years earlier has been shown
to be of paramount
importance (the 'generation effect').
There is no obvious explanation for these falls in
national lung cancer
death rates other than the changes in the tar
delivery or cigarettes.
Cigarette consumption per head did not begin to
fall in men until very
recently (see Figure 11.2). If the IaU in lung
cancer deaths is due to
smoking lower tar/nicotine cigarettes, complete
compensation for the
lower nicotine by increasing total smoke intake
cannot have becn wide-
spread. Declining air pollution is unlikely to
have contributed much to
this effect since air pollution appears to have
little if any effect on lung
cancer incidence 1131, and moreover simday
decreases have been
observed in unpolluted Finland 1131.
C:)
QYI
c::)
C~0
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CHAPTER FIVE OF 'HEALTH OR SMOKING' IS ENTITLED
'SUSCEPTIBILITY TO SMOKING HAZARD' AND SOME OTHER
CONSIDERATIONS ARE BROUGHT INTO THE PICTURE.
GENETIC PREDISPOSITION
GENETIC FACTORS THAT MIGHT INFLUENCE
SUSCEPTIBILITY
TO SMOKING.
DIET
FOR CANCER OF THE LUNG, THE EVIDENCE SO FAR
AVAILABLE SUGGESTS THAT LOW INTAKE OF VITAMIN A
INCREASES THE CHANCE THAT SMOKING WILL CAUSE
THIS CANCER. STUDIES TO SEE WHETHER INCREASING
THE DIETARY INTAKE OF VITAMIN A CAN DECREASE
THE CARCINOGENIC EFFECTS OF CIGARETTE SMOKING
ARE NOW UNDER WAY.'
THESE TWO POINTS ARE INDICATIVE OF THE INCREASING
AWARENESS OF THE INTER-RELATIONSHIP OF LIFESTYLE,
DIET,
ENVIRONMENT, AND HEALTH.
CIGARETTE SMOKING IS ONE FACTOR AND
DONE TO IDENTIFY TOXIC SMOKE COMPONENTS.
REDUCED THE QUANTITY PER CIGARETTE THROUGH A
PROGRAM. THE VALUE OF THIS CHANGE WAS IDENT~IFIED
MUCH HAS BEEN
INDUSTRY HAS
'TAR' REDUCTION
EARLIER.
CONTINUED GROSS REDUCTION OF 'TAR' TO BRING ABOUT
REDUCTION OF TOXIC COMPONENTS MAY LEAD TO AN
APPRECIABLE
ALTERATION OF THE ORGANOLEPTIC PROFILE AND
CONSEQUENTLY
TO CONSUMER REJECTION.
WHAT APPEARS TO BE A REASONABLE COURSE OF ACTION.
IS
THE SELECTIVE REDUCTION OF SPECIFIC SMOKE
COMPONENTS TO
REDUCE THE SPECIFIC TOXICITY OF CIGARETTE SMOKE.
Cx)
C. WARREN SEPTEMBER 9. 1985
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THERE HAVE BEEN EXPRESSIONS OF CONCERN BY LAWYERS
THAT IF WE OVERTLY STATE THAT WE ARE ATTEMPTING TO
REMOVE
TOXIC AGENTS IN THE GAS PHASE AND PARTICULATE
MATTER OF
CIGARETTE SMOKE THAT WE ARE ADMITTING GUILT IN THE
SMOKING
AND HEALTH CONTROVERSY.
THIS IS NOT NECESSARILY SO. THE PROGRESSION FROM
TOXIC AGENT TO BIOLOGIC ACTIVITY IS DONE BY THE
SURGEON
GENERAL, WITH VARYING DEGREES OF CERTAINTY. FOR
EXAMPLE,
IN THE 1981 PUBLICATION
'THE HEALTH CONSEQUENCES OF SMOKING
THE CHANGING C16ARETTE
A REPORT OF THE SURGEON GENERAL'
ON PAGE 24, "RESEARCH NEEDS ON LOW-YIELD
CIGARETTES," THERE
IS A LIST OF RESEARCH RECOMMENDATIONS AMONG WHICH
IS
0 Another research need is routine, frequent
surveillance of
current and future lower "tar" and nicotine
cigarettes for
specific chemical constituents and biological
activity. In addition
to "tar," nicotine, and carbon monoxide yield,
ne%v types of
cigarettes should be monitored regularly for
delivery of other
potentially harmful constituents, such as
benzo[a]pyrene, phe-
nols, catechols, nitrosamines, nitrogen oxides,
volatile aldehydes,
and radionuclides. More frequently updated ratings
of "tar,"
nicotine, and carbon monoxide content would permit
more
accurate studies on the potential impact of
cigarette components
on health.
~Jn
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-2-
IT WOULD BE REASONABLE FOR US TO SAY THAT WE DO
NOT
DEBATE THE BIOLOGICAL AND HENCE MEDICAL
INTERPRETATION
OF THE SPECIFIC CHEMICAL CONSTITUENTS, BUT THAT WE
ARE
WORKING TOWARD REDUCING OR REMOVING THE TOXIC
AGENTSo AND
LET THE SURGEON GENERAL OR THE ROYAL COLLEGE OF
PHYSICIANS
DETERMINE WHATo IF ANY, ARE THE MEDICAL
IMPLICATIONS.
THIS, THEY HAVE ALREADY DONEo E.G. WHEN THEY LINK
REDUCED
'TAR' CONTENT OF CIGARETTE SMOKE AND DECLINING
INCIDENCE
OF LUNG CANCER.
THE APPROACH THAT WE REMOVE THE TOXIC AGENTS
IDENTIFIED
BY OTHERS IS COMMON PRACTICE E.G. WHEN THE F.D.A.
MAKES
A JUDGMENT IN THE AREAS OF
FOOD
PHARMACEUTICAL
BEVERAGE
I.E. REMOVES SOME COMPONENT FROM THE G.R.A.S.
LIST, THE
RESPONSE IN INDUSTRY IS AUTOMATIC.
WE COULD ASSUME THE SAME IMPLIED DIRECTIVE BY
TAKING
TABLE I AND TABLE 11 FROM THE 1981 SURGEON
GENERAL'S REPORT
OTHE CHANGING CIGARETTE.'
C=)
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TABLE I.-b1mjePr toxic ajo-tits In the sas Phaw of
elgarette
smoke (unaged)*
Biologic Coceotrabowcip"tte
Agat
wd,itr R-P Ua
reported dg%?tVA9`
Di-thyl.itr-ine C I-no 06 IS All
Ll.byl-thyloil,rco.m. C 0.1-10 ag IJ aff
Di,thyl.itm-usize C me IS as
Nitroeopyrrolidime C It 11 g
OLh.r Diu-.,!- C ag
(4 coo,pubclo)
Hydmd. C 24-0 og g
Vie,Y1 chloride C 1-16 .8 12 g
U,.U- TI 10-416 g 90 Ng
Fw.W&by& CT, C40C 2D-90 pff 3D ps
Bydroge. ey-We M. T WMD pg 210 Pff
Acrolein CT 25-140 pg 70 pg
A.LW&byde Cr 19- 1.400 PC Sao og
Nitrogen oid" (NO.~ T 10-ft pg SW Pg
Ammonis TV IOL-150 Pg OD Pg
pl~ TV " PC 10 PC
Carka amoxWc T " mg 17 mg
-CW-u- q W_ _&_ .6 -6 i&W cerbo"L od pa"I hlori-wl
.W Ww..kr-
-C denow. TI. %.- Witiwr; C.C. Cr. clliwie moet: W
T. t..k agost.
-IS - dg-ne eith-t AJU, dp. b.At - the p.. ."
078-IM
-MG. >06% NO; - NO.
MK ..k 1. _.k. of hkodw Us dpretu. b- pH <U. .4
th~wd- p7"- - p-t
1. P-L-.d r-
SOURC& Wyoler _d Roff- (tw~
TABLE 2.-Major toik agen ts In the particulate
matter of
cigarette smoke (unaged)o
Ag-t Biologic coacentradoo/cigaretto
Se"ty. RLOP us
reported dgrruco.
Beftlg.byrew TI 9-W me 2D ag
&ldcth7lchrM.* T1 0.5-2 vg 0.6 mg
Beato[j)nuorwitbew T1 "eg to off
Bcnz(&)LnLhracco~ T1 640 @a 40 as
Other polloodear mr-tie bydm
cwb.. (>M -Puo&) TI I ?
Dibc.goj).~ TI 3-10g I as
Dibeos(~.b*ri&m TI I ?
Dibee.o[c&)w~ TI 0.7W 0.146
c4 c 50-we cc 150 ag
then* C.C W250 me 170 39
B.osoczAik-71.6. C.C so as
Other polpocksr womode byd-
cubow (>10 campov.&) c4c
X.PhUSLI.Dow C-C 1-10 PC 9 Pff
1.11*07H.&IN coc 0.3-0.9 pg 03 Pg
S-Mothlicubuoks C40C 0-0W" pg ILI Fg
Other neubvi eompou.& C4cC ? I
C.techol coac 40-~ pC PC
3- A "ethylexteebols coc "rg a F4
Other caleebols (>4 ampwn&) w T
Uaknown phemb and m6& coc ?
W-Nitronownicodw C 100450 eg 250 mg
Othw wo,olatile C ? T
0-NaothyWaift DC 6-26 of a at
Other arocati. ..w Dc I
Unk...8 BUM cmpwm& Bc r
P.lonivwno C 0.03-13 pCI
Nickel compm.& C 10400 ag
C.dwium w"D& C 940 a#
A-.iL C 1-20 pg
Nlootim T MI-10 wc 1.5 tog
Mina tobem Wkski& T 0.01-0.2 wS 0.1 tog
ph-1 CT 10-2w PC U PC
Crewle (I compouada) Cr to,450 Pg TO PC 4h.
I I-Pl." "
Ic donewe cordsoven. M wame, -%ee. Tt. "'ooe,
leltle6w. car. w-oloollow Cr. du ?Ad. Meet; aw T.
Sed..P.L
b IS " d4oreet. wilb.4 filter dp be"bt . tW W -6a
IM IM
IOURM. wrd..w sdr"_(jj4
BATCo document for Province of l3ritiSh Columbia
28 October 1999


-3-
IN THIS CASE,, WE WOULD USE ONLY TNE 'AGENT'
COLUMN
SINCE THE 'BIOLOGIC ACTIVITY' BELONGS TO THE
SURGEON GENERAL.
THE STATED OBJECTIVE COULD BE:
CIGARETTE AND SMOKE, CHEMISTRY MODIFICATION
C. WARREN
SEPTEMBER 12, 1985
co
BATCo document for Province of British Columbia 28
October 1999