Tuesday, September 05, 2006

In Calling for FDA Legislation to Reduce Nicotine Addiction, Anti-Smoking Organization is Full of It; And Devoid of Integrity

In response to last week's Massachusetts Department of Public Health (MDPH) report concluding that nicotine yields of most major cigarettes increased by about 10% from 1998-2004, a leading anti-smoking organization bemoaned the adverse impact of these increased nicotine levels and argued that the observed nicotine increase demonstrates the need to enact Philip Morris' FDA tobacco legislation that is currently pending in Congress.

A statement by the Campaign for Tobacco-Free Kids lamented: "The fact that the tobacco companies have been able to secretly increase nicotine levels in tobacco smoke occurred only because no federal or state agency currently has regulatory authority over cigarettes or what tobacco companies put in cigarettes. ... In light of ... the new report findings, it is critical that Congress enact legislation granting the U.S. Food and Drug Administration (FDA) authority over tobacco products that would require tobacco companies to disclose to the FDA and seek approval before making changes to their products that could make them more harmful or more addictive."

I have already commented that increased nicotine yields do not necessarily translate into increased levels of addiction and higher levels of adverse health effects. Just as smokers compensate for reduced nicotine yields by increasing puffing and smoking intensity, they may also compensate for increased nicotine delivery by reducing puffing and smoking intensity. High nicotine cigarettes have been explored by cigarette companies and public health authorities alike as a potential method for reducing the adverse health impact of cigarettes, since such a product could theoretically reduce overall cigarette consumption, decreasing tar delivery and carcinogenic risk.

Here, I argue that the Campaign for Tobacco-Free Kids' rhetoric about the disaster represented by the increased nicotine and the MDPH report demonstrating the need for Philip Morris' FDA tobacco legislation amounts to little more than hot smoke and reveals a lack of public health integrity on the part of this leading anti-smoking organization.

The Rest of the Story

Let us, for the sake of argument, accept the Campaign for Tobacco-Free Kids' implied assertion that the sale of addictive tobacco products is not acceptable, and that federal regulation is necessary to resolve this problem.

If that is the case, then what is the solution?

Mandating reductions in nicotine levels may seem intuitively to be the solution, but the truth is that reduced nicotine yield cigarettes result in a process known as compensation: smokers inhale more intensely and more rapidly and increase their cigarette consumption to make up for the reduced nicotine delivery. These changes in smoking behavior result in nearly equivalent overall nicotine intake with very low-nicotine and high-nicotine cigarettes.

For this reason, anti-smoking groups (including the Campaign for Tobacco-Free Kids itself) have blasted the cigarette companies for marketing low-nicotine cigarette products, arguing that these products give a false sense of security by implying reduced nicotine delivery when in reality, nicotine intake is essentially the same.

In fact, the cigarette companies' marketing of low-nicotine cigarettes was precisely one of the activities that led to Judge Kessler's conclusion that they were guilty of racketeering.

Requiring significant reductions in nicotine delivery of cigarettes could truly be a public health disaster. By substantially increasing the tar to nicotine ratio in cigarettes, smokers might actually suffer increased health effects because the very low nicotine levels could cause them to smoke more and thus inhale more tar. It could also give smokers a false sense of security about the addictive potential and health effects of smoking (even without fraudulent marketing by cigarette companies).

Thus, mandated reductions in nicotine levels could produce a double whammy in terms of creating a public health disaster: more direct harm due to increased cigarette consumption and indirect harm due to the false sense of security implied by the availability of lower nicotine cigarettes.

While mandating increased levels of nicotine (or increased nicotine/tar ratios) could potentially have some marginal health benefit for smokers, this approach would obviously not address the addiction problem that the Campaign for Tobacco-Free Kids alleges to be concerned about.

Therefore, there is only one solution to the addiction problem: get rid of the nicotine. Requiring the gradual reduction and then elimination of nicotine from cigarettes is the solution to the problem about which the Campaign for Tobacco-Free Kids complains.

One would naturally assume that the reason the Campaign thinks the increased nicotine yields demonstrate the need for FDA legislation is that FDA legislation would allow FDA to eventually force the elimination of nicotine from tobacco products, putting an end to the addiction problem.

However, if you read the fine print of the legislation, you'll find out that the bill does exactly the opposite: it precludes FDA from eliminating the nicotine from cigarettes. It reserves to Congress (and therefore to politics) the authority to make such a decision. Of course, that allows Big Tobacco to use its influence to ensure that such a measure will never see the light of day.

So in essence, the legislation that the Campaign for Tobacco-Free Kids suggests is so essential because of the addiction problem does exactly the opposite of what would be needed to solve that problem: it ties the FDA's hands forever, disallowing it from ever eliminating nicotine from cigarettes and potentially making this product non-addictive. It institutionalizes the addictive nature of tobacco products and makes sure that there can and will be no attempts to address this aspect of the tobacco epidemic.

In other words, the Campaign for Tobacco-Free Kids is full of it.

On the one hand, they are suggesting that cigarettes need to be regulated by FDA precisely because they are capable of producing addiction. On the other hand, they are supporting legislation that would ensure that FDA could not (now or ever) appropriately address the addictive nature of cigarettes by getting rid of the nicotine that makes the product addictive.

If the Campaign for Tobacco-Free Kids had any sincerity or integrity at all, they would demand that the proposed legislation be amended to remove this politically-motivated, definitive, and permanent obstacle to FDA regulating the nicotine content of cigarettes.

How can you with any sincerity and integrity argue that FDA needs to be able to regulate the nicotine content of cigarettes to make sure that people do not get addicted to cigarettes but then turn around and lobby for legislation that permanently bars FDA from having complete control over the nicotine levels in cigarettes?

And why is it that the Campaign refuses to demand such a revision to the legislation? The only possible reason is that the bill would lose Philip Morris' support. In other words, the Campaign has essentially agreed to this severe public health compromise in order to appease the economic interests of a company that is responsible for producing a product that kills hundreds of thousands of Americans each year.

If anyone should be attacked for acting in secrecy, it's the Campaign for Tobacco-Free Kids, not the tobacco companies. After all, the tobacco companies' actions in increasing nicotine yields are not a secret. They were reported to the government and are all over the headlines of newspapers throughout the country.

But the provisions of the FDA legislation which preclude it from eliminating nicotine from cigarettes are being kept a secret by the Campaign, and most people reading the Campaign's propaganda will make the assumption that the legislation will allow FDA to do just that. The Campaign is not fulfilling its ethical obligation to fully inform the public (and other public health and tobacco control groups) of the details of the legislation it is asking them to support.

I'll come clean with something here: the actions of the Campaign for Tobacco-Free Kids are making me extremely uncomfortable identifying with the tobacco control movement. Being a person of (I hope) some integrity, it is disappointing to wake up each morning to remember that the leading anti-smoking group is demonstrating a lack of integrity.

Before anyone misinterprets what I'm saying, I am not arguing that society should necessarily make a decision that we cannot accept the sale of a harmful product that is addictive. I am not arguing that the FDA should ban nicotine from cigarettes.

My argument is that you cannot both suggest that the sale of an addictive product is unacceptable and then support legislation that institutionalizes the addictive nature of that product.

If we are going to argue that cigarette companies should not be allowed to sell an addictive product, then we cannot with any integrity support legislation that would require forever that the product remain addictive.

If we don't feel that the addictive nature of cigarettes needs to be eliminated then that's fine, but we have no business pretending that eliminating the addictive properties of cigarettes is essential and that legislation we are supporting would do just that.

There's something I feel is a little more important to the effectiveness of the tobacco control movement right now than whether or not regulation of tobacco products is put into the tied hands of the FDA.

What's far more important is that we restore some integrity to the movement. I should be able to wake up and feel proud to be a member of the tobacco control community, not ashamed.

No comments: