SJG:NW
Mm .20!, 5 .5th September 1974
NOTS. ON TM CURRENT STATUS OF SUBSTI=MS
AND POLICY
Current trends in tobacco pxices gives added
incentive
to exploring further use of reconstituted tobacco
and non-tobacco
substitutes.. B.A.T. policy on the use of
substitutes has been
-stated slime 1962 as follows:
"We wil.1 not use substitutes unless there
is* a demonstrable adv"tage on health
Since that,time our policy has been modified in
some respects
largely by the interpretatIon of what we mean by
11demonstrabl*
advantageO. The present position is that we regard
a matexial
as having a demonstrable advantage if It gives
cigarettes with
lower Uz and lower -nicotine and with carbon
mon"ide no'higher
and shows no increase In biological activity. Tbe
Hunter
Committee Guidelines have now helped us to clarify
what we mean
by biological activity: tbi should cover an
examination of the
'One,
chemistry Of smoke lacludIng materials such as
benz-oyx
nitrosamines, hydrogencyanide, etc., it should
cover tests for
tumorigenicity both by skin painting and by
inhalation, it should
also involve some general imbalation toxicology.
Hunter, of course,
is developing his Guidetlines further to include
clinical and other
human - studies. B'.A.T. could go further than
HuntQz in one r2spect:
we could take cognizance of the
initiation/promotion hypothesis
and aim to get both a reduction in total
tumorigenicity and in
promotion activity.
A list'Of substitutes and their present status is
attached. TO my knowledge only two of th4se are
lik21y at
present to show a demonstrable advantaga on health
ground
that would satisfy us: these are CYTREL and NSM.
Presumably we would only use tobacco substitutes
if
they prove to be profitable in the bzoadest sense,
i.e. acceptable
to the consumer, acceptable to the cigaxette
manufacturex, ..
available at the right pricep etc. One other
condition, of
course, is that they, would not contravene the law
in the market
-for which the use-is intended. Before they are
used in any
partIculax market careful consideration would also
have to Ve
given to any change in the legal position with
respect to
consumers.
In my vLew the fact that tobacco substitutes have
been accepted for sale by the German Federal
Health Minisury'
does not necessarily constitute a demonstrable
advantage on
health grounds or.provide a basis for use in any
other country.
The test& carried out under the German law by
Professor Xrdje
.consists onlk of simple pyrolysis tests and
benzpyrene detexmin-
ation, on this basis BATFLAK3. CYT-MEL and I'M
have, all been cleared.
Equally although the H=ter Guidelines axe very
much more extensive
it does not follow that clearance by Hunter would
be satisfactory
for clearance either by B.A.T. or for use
in-another country.
Contd.
01 \
1%0
BATCo document for Province of BritiSh Columbia 27
October 1999


--2 -
This raises Important questions. If - as Xor
promotion - we regard Hunter Guidelines as
inadequate should we
do our utmost to get the Guidelines enlarged or
should we be
grateful for small Mercies. Should we insist an
more stringent
requirements to satisfy B.A.T. than are required
to satisfy
V=tex, or for that matter Krdlej, 'In my view we
should get
the best legal advice we can with regard to
potential markets
and our responsibili ties as manufacturers. This
advice will
almost certainly require us to act responsibly and
it may be
necessary to got independen medical advice.
Suggested actions are as Sollowss-
1. We should get legal advice an our position if
we use
substitutes In the United Kingdom. Perhaps
sixtilarly
opinions could be sought In U.S.A., Canada and
Australia.
2. We have, -promised to proposo to Amexicam.
Calanese a draft
agreement for the purchase of CYT2SL. This w6uld,
if
accepted, comdt us to buying a given quantity of
CYMML
contingent upon CYTREL in substantial quantities
in cigarettes on sale in the U.K. This would cover
both
consumer acceptance and any revision in Hunter
requirements.
or reversal after testing on human
3. We sbmld ala to got a. similar understanding
with IDL for
NSM.
4,,- We should continue to prpss on. with BATFLAKM
development
and a pxopd;sal vrLI-I be but to the Tobacco Board
In this
respect an the 20th Septemberi...
S. We should make an approach to Courtaulds to
exploxe the
possibility of some co-operation or a phased joint
venture.
The mai- attraction here is that it is likely that
they
could quickly engage in large sca2e production.'
6.. We should diligently inform ourselves with.
respect to the
other materials, particularly E-custa which is
being tested
by the N.C.I. in America.
7. We will make a point of examining the Bayer
material- when
it appears in Reentsma's cigarettes and thus
becomes
available to us, at least for laboratory work. -
S. We should continue the development of
reconstituted
substitutes with lower biological activity.
Rne:
Q:~
CN
BATCo document for Province of BritiSh Columbia 27
October 1999


BATFLAKR
N.S.M.
-YTRILL
SCUSTA
COURTAULDS
BAYER
B & W
HELIPM
DUPONT
SHAW PRODUCT
SUrMN RESEARCH
SJG:NW
5.9.74
APPENDIX I
B.A.T. product based on chalk and sodium
carboxymethyl cellulose. or semi-commercial
Approaching decision stagef
plant.
Weak but useful patent position.
ProbablyPid per lb.
Product of Imperial Developments Ltd.
Full scale 20 - 30 million lbs/year plant under
construction.
Partially oxidised' cellulose.
Useful patent protection.
Expensive - probably over I/lb-
Product of American Celanese Corporation.
Full scale 10 million lbs/year plant under
construction.
Inorganic additives with cellulose bonder
probably carboxymethyl cellulose.
Useful patent protection - not impregnable.
Price at present values about 75 ji/lb.
Product of Scusta.
Believed at pilot plant scale but probably no
problem in production as is essentially cellulose.
No patents.
Probably 50 g! /lb.
No biological claims but under test by N.C.I.
No public information. , Probably v1scose.
No patents known.
Price - not to be offered for sale but cosU
is probably around 60 e /lb.
Could be produced readily.
No inform ation but will be on test in Germany
and samples can then be examined.
Almost certainly cellulose based.
Batflake iype product based on aluminium
compounds.
Laboratory stage.
Vegetable reconstitution. No biological
information.
May be an sale in U.S.A. in 1974.
No knowledge
Presumed dead - was reconstituted vegetable waste
but effectively flavoured.
Turned down by IDLI B&W and SAT.
Patented.
Cellulose based.
C:>
Cl\
ON
BATCo document for Province of BritiSh Columbia 27
October 1999