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06/15/93 12:32 '8`202 637 1505 I.'HILIP MORRIS CO CM006/'028 THE IGNITION TEST METNOD PROPOSED 9Y NIST IS NOT A VAUO OR RELfASLE PqEDICTOR OF CIGARET7E IGNITICNS IN'. REAI,-WORLD CIRCUMSTANCES A. Irttroduction "ne iaoo(atory resuwts cotaineo cy N8S unoer the 1~984 legislation were based on a mocxuo test wnichiinciuded trree commercially purchased fabrics and two paddings.' The TSG recognizea in rts Final Report, however, that aRhougllitne mockup tests were 'reasonable indicators of performance on fuli-scale furnrture made of the same materials.' development of a standard test method that would be valid and reliable snould proceed as soon as possibte. Following publication of the TSG Final Report., RJR and other members of the tobacco industry began to worx cooperatively in oraer to share inlomtaaon on test method development eejng generated by individual campanies ana to build on the TSG woric. Work on test method devsiopment was forrnalized througn two tobacco organuations: t) CORESTA, an international' scienufic organization of tobacco companies and reiated organizations', and 2) the Industry Joint Venture, a legal entity organized to work on test method development co+npnsing the six U.S. cigarette manuf acturers. The following discussion refers to a number of studies that have been completed or are in progress. This information has also been shared with the organizations charged wrtn researcn tasks or oversight or advisofy responsibilities under the 1990 Act Wtten relevant, information was presented to tne TAG: in other cas.s, presentatiortis wefe made to CPSC andlor to NIST. Some of me studies haw aJso been presented at otfw technical meetings or pubii,sl9ea in peer-reviewed journals. Every effoR has been made to hew this technical information availsble for due consideration by persons and or+paNzador+s cnarge0 with respoflsibility for cartymg out the legislation. ' Oann, R.G., R.H. Hut* Jr., J.F. Krasrt)r, Fi.s. Levltw, H.B. IMIfMtW and T. J. Ohlemiilller. The Erfect of ClaanRe Characteristics qo tfu 1qnRlon of Son Fufn 1~1 , Nf3S TeCMicat Neie 1241. 1984. ' Refsed organizatlons include both commercial suppfiers to tfle indtxtty such as paper ana ritter manufacturers as well as univeratties that conduct tobacco research. 4 2021302'721

06/15/93 12:J3 $`202 637 1505 k'HILIP MORRIS CO Q007/028 in the work completed under the 1984 legislation, 32 experimental prototype cigarettes were ranked by adding the number of ignrtions observed on each of the three mockup types.' The TSG concluded that there were cigarette construct,on parameters important to reduced ignition propens,rl, ;ow packing density. low paper permeao,itry. reduced c;rcumference. iin that order) and perhaps. removaliot cttrate (useo as a metnod to ensure uniformity of burn rate) in cigarette paper. The 'reductionr potential was enhanced when tnese constructton parameters were used in combination. 7he three fabrics were cnosen because they were able to discriminate among cigarettes. Neither the N8S nor the TSG investigated whether those fabric and padding combinations were best for ranking cigarectes. The primary task was to determine technical feasibility of developing cigarettes wrth a reduced propensity to ignite soft furnishings. Thus, no effort was made to oetermine the representativeness of'those fabrics to those used on, upholstered furniture. It was known, at the nme of course, that tne ignrtabiltty of cigarettes was highly substrate-dependent. Most fabncs will eatner always ignite when in contact with a burning cigarette or never ignite, regardless of the cigarette construction parameters: relativey few fabrics will display varied ignition capabilities depending on now tne cigarette is constructed. Since 1987, Industry work has shown tnat the rankin of cigarettes according to ignition propensity is dependent upon the substrate which is tested. lh other words. a different ranking of cigarettes and cigarette charaCcterl5t{CS can be achieved through a diferent choice of fabncs and paddirgs. In additlon, the environment surrounding the tfst sRe can also inNuence not ony the magnitude, but tM ordering of cigaretn igniHon rankirA ' The 32 cigaratta were sp.claly martufxwrea to repreve aN Combirtations of twv variables of each d fNe factors• packing dertieity, paper perrnesbility, ciraxn(eAnce. PreS&M40 Of ablild'"Ce of cafm on paper, and tobacco typw Td the axieftt posaiM , pO factor wU tWed = two extreme values For example, the vaiues for tobseco typ. were a1 burley v!, ali !hW curea: the values for tooacco density wM represerxe?4 by usa af 100% expen0e0 tobioco vs. 0% expanded tobaaco. in most caSY, tMse values are beyond the limits of curreRt commerctalty acceptabte cigarettss. 5 2021302'722

06/Y5/9J 12:33 '8`202 637 1505 ~'HILIP MORRIS CO Z008/028 g, Rather Tf1an Investioate Or Taks Account Of FA-CIoM TThat Affect Actual Furnrture F:res N1 T Has Fiefied Undufy On The Prior TSG Ignition Testina To Validate Currern Proposed Test Methods T1ie 1990 Act charges NIST with test metnod development. NISTs approach has been ;o seek arn lgnmon test trat wouid c:.rre+ate to. i e._ repeat as ciosey as possible, the resutcs of rts eamer work for the TSG.' 'wh,le !"e industry nas attempted to point out Guring technicaldiscussions w1tn !be TAG. NIST„ and CPSC that discrepancies exist in the earlier work due to the influence of substrates and environment, NIST has proceeded without due consideration of the Ihaustry finaings, NIST has stated that the ranking established by the TSG is'yasid,' because of ignition tests run on !u:~F scale fWmiture that showed a*strong, but not petiect' correlation to the bencn-scale tests.' This reasoning is difficult to uncerstand when one considers that the full-scale tests themsefves were Iimlted in scope. The full-scale tests were not correlated to tne tests of 32 cigarettes on 3 substrates usea to determine the TSG •ranking.' They were correlated instead to a bench•scaie test of two of tne three substrates wrth 5 cigarettes (only 3 of which were included in tne 'ranking'),, and to addRionaJ bench-scale tests with three other fabrics wtlich showod a nigfl proportion of resuits that were erther 0 or 100% (over one-hatf of all results were at 0).' The high number of results at either end of the scale would tend to give any test a high correiation. Even with the two fabrics which showed some discrimination, tne full-scaie test was merely a 'scale-up' test, and, as stated in the 1987 TSG Final Report: 'T'he mockup measurements are a reasonable indicator of the performance of full-scale fumiturn m mat .' This limited scale-up test does not lead to ttte conclusion thac thoee dgareaa woukd perforrtt the same ''TTtis rttetfloa r.omes diroctty to the general approach of the Technical StuQy Group (TSG1 in tneir 19f3S-87 rMNICtt and re(Ip on the reistive rankings of cigarettes obtaine0 in tnat work to select the alpt?ropfof aM fabriCS 9ftd te3i condRioni.l AnntM R to ConCreSS - AcIiyitllrs of tt'e Cia ett. Fire 9 Proiect. 1992 at 2 ' Oeppa. R.W. Loa of Meetina (CPSC): Fir"af! Crlaaratesi. CP C/IndustrvlbIIST Techrncal Mwti% Marctt 30 & 31. 1992, at " ' The otflK 29 CigBreRss lrom ttte 32 TSG cigereRfa set weA not tested o11 thM tMN additional fabriCS, in eitfler the bench-scalr or fult-scaie testi. 6 2021302723

06/15/93 12:34 '$202 637 1505 k1HILIP MORRIS CO _ Q009/028 way in the real world under the vanety of Conditions and on the vanety of substrates that e:ist, Reliance on these previous resutts for development of a valid and reliable standardized test is reliance on a thin reed indeed. Earry in rts work under tne 1990 Act, NIST tested TSG cigarettes tnat nad been in freezer storage since the completion of tne TSG work ana repeated tne bencn-scaie mockup tests with eignt of the 32 onginal prototypes to determine wnether cigarette inregrrty was intaa.' The earfier rankings were not futty reproduced. however, in fact, there were some shiRs in relative posrticn of the cigarettes, particulany in the mid-range of ignition propensity. NIST initialty attributed the differences to aging of one of the fabrics, out tests of the fabric by an Industry lab disproved this theory.' These re-tests at NIST were run in a aifferent laboratory by a different operatorr the re-test demonstrates trie sensrtivity' of test outcome to test conditions. Nevertheless. NIST proceeded to develop a new test that would correlate to the 1987 ranking. NIST has also cRed as verification of its previous ranking the test results of another Ilboratory -The California Bureau of Home Furnishings-that were run as paR of the 1987 study.'0 In the CBHF test. however, only 8 cigarettes and1wo substrates were tested Interestingly, the denim substrate that showed the greatest discrepancies in the NIST retest was not tested by CBHF. Other work shared with NIST and CPSC (in June, 1991) regarding ranking of cigarettes included a study by AJR whicrt examined the independent effea of one of the TSG variables on ignttk,m propeflsity." The TSQ had concluded that the cotrbinstbn d sortw variables was most effective in reducing i9nitlon pfopeiyhy, but those variaDles were rlot studied individualy. RJA maae 'Harris, fLH., Jr., M. Nava.*ro, R.Ci. Garnn, and KA. Ebertlardt. 'Aeevaluation of Expenmental Cigarottes Usad h tttis Cigame Safosy Act of 1984,' NIST Aaoort FA 3984. 1,991. ' Notmart, V. M.morandum to A. Spoars. 'Char9cc.rizatfon d NSSINIST Denim FaDnc,' March 19, 1992 SubmiRSd to Catsumer Produt;t Safety CommistiorL Marctt 1992. 'O Oanwt QN., JA McConnack. and 9. Ctaire. Tests d Srno/0erha IQnitlon of Ctlairs an_d ReducedScaie Madc!um by Various Ctaarertei Tecfvtical SKdy Cittwp, Volume 7, October 1987. " Lewia, LS. Pnsentation aa NISTMdustry Technicat Meedng, f3aithersburQ, Md, June 4,1991. 7 2021302724

06/15/93 12:35 '8`202 637 1505 k'HILIP MQRRIS CO 0011/028 ,After controlling for atl smoker cnaractensttcs anQ city, logistic regleSSion modeling snowed four cigarette characteristics to be significant • tifter, filter length. porosSy, and pack rype."' Densrry;, the charaaenstiC that the TSG had identRied as the paramount parameter affecting ignition propensitv «as not found to have a sign,ficant relationship to tnese aauat fires. In addition, nerther circumference nor addivon of citrate was found to be related to the incidence of fires." These reported results are further evidence that reliance on the onginal TSG results as a basis for calibrating: the proposed NIST tests is unwarranted. NIST has provided two test approaches as potential candidates for a standardized test. The first, the Mockup Ignition Test Method, is designated as a primary test method: one that measures the perforrnance of cigarettes on •moCkup assemblies [thatj Closey represent furniture constructlon.'" The mockup assemolles are of three types: No. 1,0 COnon duck over 32 tigRT13 potyurethane foam: No. 6 cotton duck over the same polyurethane foam: and No. 4 Cotton duck over 6 mil polyethylene film over the same poyuretmane foam. All materials are 8' by 8'. and ~ the foam is 2' thick. Aft tests are run in the flat (as opposed to crerice) corlflguration. Tests are run inside a pleYiglass box vented at the top by a 6' diameter chimney. Room conditions are specified to be 23 = 3°C and 55 x 5% relative humidity. Five (remade) TSG cigarettes were tested by this method in an irnertaDoratory study completed at the end of 1992. The second approach provtded by MST, the CigarRte Extinction Test Method. is a seconaary or indlrea rttetttod that relies on a•surrogate• for a fabriGpadding sub3trate." A lit cigarette is placed on a stack of 3. 10, or 15 pieces of 02 titter paper, and results are r.cordad as a total bum '° The prwerlCe of a fiRec and the lertgth of thft futer wen not evaluated by the TSc3M nor was tne type of pack. The htx tha this study identifled cigarettas in a soR pack as being more retated to tires than those in a hard pack wu desafbed try tne irnestpators as `unLisuat.' !SL at 29. AJR knows of no reason why the type of pack should t)Nt any relat/onship to cfganRe ignitlon propenswy. t. 17 l.awsort, R. NIST PresentetzJon to Technioal Advisoty Group, January 28, 199Cl. Ld. 9 2021302726