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TIt-4OTHy t-~. FINNIEGAN
January 22, 1975
12t2] 765-4t00
CABL( AOOR(.~.5 KONh)AY
Dr. Robert C. Hockett
The Council for Tobacco Research -
U. S. A., Inc.
110 East 59th Street
New York, New York 10022
Dear Bob:
I am enclosing herewith the original and one
copy of your statement relating to the NCAB's proposal
to regulate cigarette smoke components, together with a
copy of the NCAB's recommendations.
I would appreciate your signing the original
statement and returning it to me. The copy is for your
files.
Sincerely,
Timothy M. Finnegsn
BY MESSENGER
P.S. Also attached is a copy of your Curriculum Vitae
which we discussed this morning.
TNF
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" STATEMENT OF DR. RCBERT C. HOCKETT
I am Robert Casad Hockett, a Ph.D. in the fields
of organic chemistry and biochemistry and Research Direc-
tor of The Council for Tobacco Research -- U. S. A., Inc.
In 1965, 1969 and 1972, I had the privilege of
presenting to various Committee~of Congress reviews of
tobacco and health research sponsored by the Council.
My
statements setting forth my background and views are
attached.
In 1972, when the regulation of "tar" and nico-
tine levels was being proposed, I stated that I could find
no ccnvincing evidence that "tar,"* nicotine or any specific
ingredient as found in cigarette smoke had been shown to
play a role in producing any human disease. Consequently,
there was no scientific basis upon which to establish max-
imum acceptable levels of "tar" or nicotine.
My remarks to Congress in 1972 may be briefly
sum2.arlzed as follows:
The 1964 Report to the Surgeon General of the
*The so-called "tars" are complex mixtures of condensed
smoke ingredients. "Tars" vary in composition with tobacco
types and treatments and with conditions of combustion,
collection and storage. Equal amounts of two different
"tars" can have vastly different biological effects in
animal experiments.
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U. S. Public Health Service concluded with respect to
nicotine: "The rapidity of de~radatlon %0 non-toxic me-
tabol~tes, the ~esults from chronic studies on animals,
and the low mortality ratios of pipe and cigar smokers
when compared with non-smokers indicate that thechronlc
toxleisy of nicotine in quantities absorbed from smoking
and other methods of tobacco use is very low and probably
does not represent a significant health problem." Since
1964, no data h~ve been published which would require a
change in that position. On the contrary, studies have
confirmed the conclusion that nicotine in the body is
rapidly converted into other substances of much lower
pharmacological activity.
It has never been scientifically established
that nicotine causes or contributes to atherosclerosls or
-- for that matter -- any other cardiovascu]ar disease.
Rather it is generally recognized that many factors may
be involved in determining the rate at which atherosclerosls
develops and also in influencing the precipitation of acute
disease events• At least twenty such factors have been
reported and some are clearly of a genetic nature, while
others are environmental. To date no one has been able
to define scientifically the predominant causal factors
or how they interact in the production of this disease.
In general, human studies on atheroscleresls still frequently
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appear confusing, inconsistent and contradictory°
Recently it has b'ecome possible to design more
systematic and better controlled animal studies to inves-
tigate what role, if any, nicotine could play in the
complex etiology of atherosclerosis. So far, such studies
have not established that nicotine can be implicated in
the production of this disease.
The pharmacological effects of nicotine in
humans have been shown to be very transient and some may
even be beneficial. While many studies have been done in
this field, none have established nicotine as contributing
to the causation, aggravation or precipitation of any
cardiovascular disease.
With regard to tobacco s~oke, over the years
numerous animal inhalation experiments have been conducted.
Nevertheless, all such studies have failed to produce the
type of lung cancer that in humans has been statistically
associated with smoking.
One experimental method that produced observable
results was the painting of smoke condensates (generally
but erroneously called "tars") on the skins of mice. My
skepticism about the relevance of such experiments to
humans is based upon the following considerations:
i. Relatively enormous doses of 'ttar" were
used in the animal skin experiments.
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2. Great differences exist between mice and
primates, including man, in susceptibility to cancer-
induclng chemicals.
3. There are many important differences between
skin and lung tissues, including various cleansing mech-
anisms.
4. There are both chemical and physical differ-
'ences between smoke condensate~or "tars" and whole, fresh,
normal smoke.
5, The role, if any, of viral agents in the
skin painting experiments is unknown.
As to carbon monoxide, it is a normal constltu-
ent of human blood produced by metabolism and can be des-
troyed by the body, though slowly. Without any exposure
at all to carbon monoxide in the air, the blood contains
from 0.2% to 1.0% of carboxyhemoglobln (the combination
formed by this gas with the red blood pigment). This level
is equivalent to that produced by constant breathing of
air cgntaining seven parts per million of the gas.
Long ago it was found that smokers, after smok-
ing and inhaling from 10 to 15 cigarettes within a period
of two hours, showed a rise in percentage saturation of
carboxyhemoglobin from 3.1% to 6.7% (average 4.3%). None
of them experienced any symptoms attributable to carbon
monoxide, which is to be expected since these levels are
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far below thbse considered acceptable in industrial ex-
posures. Further, cigarette exposure is generally inter-
mlttent as compared to the day-long exposure often
encountered in industries. As to long term exposure to
carbon monoxide, studies of men ehornlcally exposed (i0 to
18 years) in their work to relatively high carbon monoxide
levels show no earlier or more substantial circulatory ab-
normalities attributable to atherosclerosls than the
general population. In short, no one has ever scientifi-
cally shown carbon monoxide exposures from ordinary smoking
to be hazardous to humans.
Since iq72: I have follo\qed the pertinent scien-
tific literature but have not seen any data which would
change my opinion that smoking has not been scientifically
established as a "major health hazard" to humans. Nor
have I seen any studies in the medical literature which
establish "tar," nicotine or any other constituent of
tobacco smoke as disease producing in human smokers. This
is especially true with regard to the so-called epldeml-
clog!ca! or statistical studies.
It Is Kenerally conceded that the cause or
causes of disease cannot be determined by epldemlologlcal
studies alone. Such studies merely point to areas In
whlcb laboratory experiments with animals, integrated with
human clinical observations, are needed to explain and
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interpret the real ~eaning of statistical relationships
gleaned from human population studies.
Experts in the field have pointed out many un-
solved problems relating to the epldemlologieal approach.
Perhaps the most disturbing criticism of existing studies
is that in human populations, the smoker and the non-smoker
groups are self-selected to begin with instead of being
assigned at random as would be the ease in any competent
animal experiment. At present, we do not know enough
about the conscious or unconscious motivations involved
in the adoption or maintenance of cigarette smoking to
judge fully the nature and extent of the differences between
the smoking and non-smoking populations. Nor can we deter-
mine where these differences are themselves associated
with disease predispositions apart from smoking. Neverthe-
less, wherever such differences have been explored at the
levels of personality, body build, electroencephalography,
style of llfe, vocational interests, or psychological
make-up, they have been found to be real. It is important
to look for still other differences and especially, in
each case, to find out what~ if any, relationship the
differences themselves or any associated differences in
health may have to the practice of smokingJ
In v~ew of these unresolved problems, it is ob-
vious that epidemiologlcal studies have not, and cannot,
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incriminate specific components of cigarette smoke in
the causation of human disease. Neither these epldemi-
ological studies, nor animal and clinical studies, have
identified any ingredient or group of ingredients as
found in smoke as disease producing in humans.
In conclusion, it is my opinion that at the
present time there is simply no scientific basis for
regulation of levels of various cigarette smoke compon-
ents.
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