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) • - 10 - ) 3 1 ) ) 1 quantity of smoke particulates as well as gas phase components which are delivered to the mouth of the smoker," and expressly represents that the Barclay "invention further provides a cigarette filter for lowering tar predominantly by ventilation instead of filtration." U.S. Pat. No. 4,256,122 at 1 (March 17, 1981). When Barclay is tested on the FTC machine, its full dilution potential is realized since the current holding device leaves all four peripheral dilution channel exits fully open. Therefore, it tests with very high dilution and concomitantly low "tar." However, as described below in detail, when actually smoked in human lips, the channel exits are partially or.completely occluded. This results in less dilution (since the only avenues available for dilution air in Barclay are those dilution channels which are open) and therefore more "tar." The same result does not occur in any other cigarette since; in all other brands, dilution air is not physically segregated from the smoke and is drawn in through the filter rod regardless of the drape of the lips over the end of the filter.

) I I ) ) I Dilution Experienced by Barclay Smokers It is possible to measure the dilution of cigarettes smoked by human smokers. A schematic diagram of the equipment employed is shown in Exhibit 7. When a cigarette is puffed by a human smoker,-the measuring equipment calculates and compares the volume drawn through the cigarette rod and the volume of ventilating air drawn through the perforations around the filter. The ratio of the volume of ventilating air to the combined volume, expressed as a percentage, is defined as the percentage dilution. While measurements of cigarette dilution have traditionally been made on unlit cigarettes, the dilution measuring equipment can be used with either unlit or lit cigarettes. Using a group of 45 test subjects, Philip Morris has measured the dilution experienced by human smokers for a large number of cigarette brands, including Barclay. The test subjects were regular smokers, and included both men and women of varying ages. Measurements using the identical procedure were conducted on a number of different days, at various times, and under varying atmospheric conditions. In every case, care was taken that the test-subject not observe the results calculated by the dilution measuring equipment.

ti ) T ) 1 ) ) , The results of these dilution measurements are clear, dramatic and reproducible. The data are displayed in Exhibit 8. In the case of every cigarette brand exce Barclay, the measured dilution for human smokers (1) was very close to the measured dilution in a standard smoking machine utilizing the current holding device, and (2) remained essentially the same whether the cigarette was held directly in the smoker's lips or in a plastic mouthpiece. The results for Barclay, however, are strikingly different. When a Barclay cigarette was held in the lips as in normal smoking, no person experienced a dilution even close to the 75$ dilution encountered by the smoking machine using the current holding device. The variance from smoker to smoker was very large, ranging from a low of 12% dilution to a high of 55% dilution. The average, 32$ dilution, was less than half the dilution encountered by the smoking machine. When a Barclay cigarette was puffed by smokers through a plastic mouthpiece to prevent lip contact with the filter, the results were different. With a plastic mouthpiece, the measured dilution of Barclay was slightly lower than, but very close to, the dilution encountered by the FTC smoking machine with the current

) ) ) 3 holding device. The dilution measuring equipment thus confirms and quantifies the subjective observation that a Barclay becomes a very different cigarette when puffed through a plastic mouthpiece. These measurements establish beyond any doubt that the Barclay filter acts very differently in a smoker's mouth than in the current FTC holding device. We understand that Reynolds has hypothesized that this difference is caused by the collapse of the four peripheral channels under pressure exerted by a human smoker. Our observations show that the lips of a human smoker tend to occlude fully or partially the Barclay peripheral channels, blocking the dilution air. This effect has been confirmed by Philip Morris through observation of a Barclay filter from inside a smoker's mouth using a fiber optic instrument (a borescope), and has been recorded on a videotape which we are prepared to make available to the Commission. "Tar" Delivery Measurements at Smoker Dilution As noted above, a series of measurements made on dilution measuring equipsnent confirms that the dilution of cigarettes of any brand -- except Barclay -- is essentially the same whether the cigarette is smoked N O N r CA ~ ~ ~ ~ CA

) - 14 - i .! ) I by a human smoker or by an FTC smoking machine. Accordingly, for all cigarette brands other than Barclay, the FTC tests, as currently conducted, measure "tar" at approximately the same dilution experienced by smokers. The situation is very different with regard to Barclay, however. The average dilution experienced by test subjects holding a Barclay cigarette in their lips was less than half the dilution encountered by an FTC smoking machine utilizing the current holding device. As noted above, it is possible to measure Barclay "tar" delivery at different dilutions. When Barclay is measured at the 32% average dilution of the test subjects, the "tar" delivery is about nine milligrams. In other words, the level of particulate matter delivered by a Barclay cigarette to a human smoker is similar to that of a brand measuring about nine milligrams "tar" by FTC method. These data are set forth in Exhibits 9 and 10. In an attempt to corroborate these data, we hava also measured and analyzed the nicotine retained in Barclay filters after smoking. While it is sometimes possible to estimate "tar" delivery on the basis of retained nicotine, such analyses are not a rigorous

} t l 3 i method for measuring "tar," because of the large number of variables involved: puff volume, flow rate, nicotine to "tar" ratio at measured dilution and flow rate, and filter efficiency at measured dilution and flow rate. A retained nicotine analysis that fails to take account of these variables (particularly the impact of changing flow rate on filter efficiency) is of no scientific value. When the entire analyais is properly performed, nicotine retention studies confirm that the particulate delivery of a Barclay cigarette smoked in an FTC smoking machine with the current holding device is comparable to a cigarette measuring one to two milligrams of "tar," whereas the particulate delivery of a Barclay cigarette smoked in the mouth by a human smoker is comparable to a cigarette measuring about nine milligrams of "tar." A Proposed Modified Cigarette Holding Device As shown above, by measuring the "tar" delivery of a Barclay cigarette in a smoking machine at a dilution level comparable to that experienced by a human smoker, it is possible to obtain "tar" delivery data for Barclay that may fairly be compared with those for other cigarette brands. This comparability can be achieved by modifying the cigarette holding device used on the

) - 16 - I ? ). 1. FTC smoking machine to reflect the occlusion caused by the lips of a human smoker. Philip Morris has designed such a modified holding device, shown in cross-section in Exhibit 11. The interposition of an annular ring in the holding device so as to abut the mouth end of the cigarette affects the dilution achieved by the Barclay filter in a manner similar to that of a smoker's lips. Tests conducted on the modified holding device indicate that there is no substantial change in the dilution of any cigarette other than Barclay, and therefore no substantial change in the measured FTC "tar" delivery of any cigarette other than Barclay. The modified holding device does, however, reduce the dilution of a Barclay cigarette to approximate the level experienced by smokers. The modified holding device thus yields "tar" delivery data for Barclay that may fairly be compared with those for other brands. These data are set forth in Exhibit 12. Use of the modified holding device proposed by Philip Morris would require only a slight alteration of the Commission's testing equipment, and no change at all in test procedures. 'The modified holding device

1 ) ) ) ) is easily installed, may be readily obtained, and requires no auxiliary apparatus. Conclusion Philip Morris recoAanends to the Coaanission that the modified holding device described above be substituted forthwith for the holding device currently employed on the F'RfC's smoking machine. With the use of such a modified holding device, the dilution of cigarettes smoked on the machine will closely approximate the dilution experienced by human smokers. By testing cigarettes at that dilution level, it will be possible to preserve the validity of the FTC "tar" rankings as a basis for comparison among brands. ~

) I Index of Exhibits 1. Diagram of Dil ution Mechanism of Typical Diluted Cigarette ) 2. Diagram of Dilution Mechanism of Barclay Cigarette . Diagram of Dilution Mechanism of Multifilter Cigarette V 4. FTC "Tar" Versas Dilution for 138 Market Cigarettes 5. FTC "Tar" Versus Dilution for Barclay and Cambridge Cigarettes 6. FTC "Tar" Versus Dilution for Barclay and Carlton Cigarettes ) 7. Schematic Diagram of Instrument to Measure Dilution 8. Dilution Experienced by Smokers of Various Cigarette Brands ) 9. FTC "Tar" of Various Cigarette Brands at Average Dilution 10. FTC "Tar" Versus Dilution for Barclay, Showing "Tar" and Dilution Experienced by Smokers ) 11. Diagram of Proposed Modified Cigarette Holding Device 12. FTC "Tar" of Various Cigarette Brands at Average Dilution and When Measured with Modified Holding Device 0 I

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