B&W's Policy On Testing Additives

In 1967 Dr. R. B. Griffith, director of research at B&W, informed a group of USDA scientists and other officials that they must test combustion products of residues in tobacco to be assured of their safety {1302.01, p. 2}. By the 1980s this sensibility is no longer evident in the documents. Rather, concern about the toxicology of combustion products is termed "unscientific" and is projected onto critics and potential regulators.

Dr. J. G. Esterle, manager of smoking and health affairs at B&W, wrote a memo to Dr. R. A. Sanford, vice president for R&D, on September 11, 1981, about a "suggested program for testing biological activity of our cigarette additives" {1314.01}. The proposed program first takes note of B&W's additive policy and a criticism this policy has received.

B&W's policy on cigarette casing and flavoring ingredients is:

"To be used as a casing or flavoring in any of our cigarette products, an ingredient added to tobacco shall meet one of the following criteria:

Adherence to this policy provides B&W with a very favorable position in defense of our usage of flavors and casings. Yet, the regulatory and antismoking agencies have identified, at least from a PR standpoint, a weakness. This is that the additives are potentially altered during smoking which may provide a new health risk to the smoker. However unscientific this attack may be, we should be prepared to respond. The program, described here, is designed to provide that response [emphasis added]. {1314.02, p. 1}

These criteria permitted B&W to use any current additive, since only one of the criteria need be met and the first one essentially grandfathered all existing additives regardless of possible dangers. Moreover, the concerns expressed in the 1960s by a company scientist about the need to examine the combustion products of pesticides for toxicity are now instead attributed to outside, anti-tobacco critics.

The proposed solution was to conduct Ames testing of cigarette smoke from cigarettes, with the test additives added at ten to twenty times the

normal level {1314.02}. The Ames test is a test of mutagenicity which has been used as a screening test to predict carcinogenicity. Other screening tests were considered but discarded as inappropriate. The concern seems to have been focused exclusively on the possible carcinogenicity of pyrolysis products of additives. Esterle suggests that each flavor formula for each brand be systematically tested. The initial wave of testing was to be completed by July 1982. The tone of this proposal is purely defensive. The impression one gets is that the purpose of the test is not to determine whether there might be real problems but simply to obtain data that might be used if the company were forced to describe the toxicology of its additives in connection with a lawsuit or if the federal government were able to require the disclosure of additives.