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1, 3 I a CA6L[:"ARIOPO" TG.ECOPICR: (202) 672-6720 TCLDt:69-ZFl3 ARNOLD & PORTER 1200 NEW NAMP51-1iRE AVENUE. N. W. WASMINGTON. D. C.20035 1660. 1ANCOl.N STREET 0 E"KR... COCO /1A00 6026s (303) 632-2900 (202) 872-0700 ) t Re: Investigation of Barclay Filter Dear Mr. Myers: Enclosed are a number of technical materials from the Philip Morris Research Center responding to questions raised at our meeting on July 10, 1981: Chart 1 sets forth in full the "tar," total particulate matter, nicotine, and water delivery data and puff counts for the Barclay, Cambridge, and Carl- ton cigarettes measured in Exhibits 5 and 6 of our earlier submission. It also includes information on the cigarette wrapper porosity of those three brands. Chart 2 sets forth similar data for all the brands of cigarettes displayed on Exhibit 9 of our submission, when measured by the current FTC method and at average smoker dilution. Chart 3 provides similar data for measurements N made on Philip Morris' proposed modified cigarette O holding device. ~ JEROME F. CMAPMAN 0(RECT UNG (202) 672-6750 July 17, 1981 Matthew L. Myers, Esquire Division of Advertising Practices Bureau of Consumer Protection Federal Trade Commission 414 - llth Street, N.W. Room 6113 Washington, D.C. 20580

i 0 P :t 0 a 0 r bRNOLD & PORTER Matthew L. Myers, Esquire July 17, 1981 Page Two / Chart 4 sets forth the resistance-to-draw of Multifilter cigarettes with the flutes in the filter. open and occluded. It will be noted that with the flute openings closed, the resistance-to-draw is increased from the low to the moderate range. This is because smoke, which otherwise would bypass the cellulose acetate filter and flow through the flutes, is diverted through the filter when the flutes are closed. Chart.5 is an engineering drawing of'Philip Morris' proposed modified cigarette holding device, showing relevant dimensions and tare weight. Chart 6 is a short discussion of the differ- ence between the slope of the Barclay line.and the Cambridge and Carlton lines in Exhibits 5 and 6 of Philip Morris' earlier submission, a matter inquired about at our-meeting last week. We are enclosing also, as you requested last week, copies of all the published articles that Philip Morris has been able to locate thus far deal- ing with efforts to analyze nicotine or other smoke components in exhaled breath, or in the blood or other body fluids of smokers. In each case, Philip Morris personnel have attempted to highlight what appear to be the principal conclusions of the author. These articles, including some prepared by represen- tatives of BAT Industries, Ltd., all appear to be critical of biological experiments of the sort you mentioned last week, and the articles indicate that such experiments are not reliable methods for measur- ing a cigarette's actual delivery of particulate matter.

ARNOLD & PORTER 0 Matthew L. Myers, Esquire July 17, 1981 Page Three ) I ) ) , One additional area about which you inquired at our meeting was the possibility of estimating "tar" delivery by analyzing the retained nicotine in the butts of smoked cigarettes. As we mentioned last week, Philip Morris has conducted studies in that area relating to Barclay cigarettes which sup- port our more direct observations and conclusions regarding the Barclay filter. Due to the complexity of nicotine-retention technology, we require some additional time to produce a complete written analy- sis that is both clear and comprehensive. We expect this report to be available next week. As we mentioned previously, nicotine reten- tion studies are at best a rough and approximate method forr estimrtting "tar" delivery, and are fairly remote from the principal.issues raised by the Bar- clay matter. Accordingly, we strongly urge that the Commission sbould not hold up circulation of the material submitted by Philip Morris and others pend- ing receipt of our retained nicotine report. The process of reviewing these submittals should begin as soon as possible. The ultimate receipt of responses will be greatly expedited by circulating the material in hand today, supplemented later by our follow-on submittal. Enclosures

I INDEX ) 1. TAR, TPM, NICOTINE-AND WATER DELIVERIES OF DATA USED IN EXHIBITS 5 AND 6. ~ 2. TAR, TPM, NICOTINE AND WATER DELIVERIES OF DATA USED IN EXHIBIT 9. 3. DELIVERIES ON MODIFIED CAMBRIDGE FILTER HOLDER ~ USING FTC TAR METHODOLOGY PRESENTED IN EXHIBIT 12. 4. S. RESISTANCE TO DRAW (RTD) OF B&H MULTIFILTER CIGARETTES: WITH AND WITHOUT FLUTES OCCLUDED. MODIFIED CAMBRIDGE FILTER HOLDER. 6. EXPLANATION OF SLOPE OF DELIVERY LINES (EXHIBITS 5 AND 6).

i I 1. TAR, TPM, NICOTINE AND WATER DELIVERIES OF DATA USED IN EXHIBITS 5 AND 6 TAR TPM NIC. H.0 PC BRAND IIILUTIONI ) BARCLAY2 0t 12.2 14.7 1.06 1.41 6.3 154 10.9 13.0 1.02 1.11 6.7 301 9.2 10.8 0.86 0.71 6.8 I 50l 7.2 8.4 0.71 0.54 7.5 75t 2.8 3.2 0.30 0.12 8.4 85t 1.2 1.4 0.12 0.13 8.6 ~ CAMBRIDGE3 0t 6.6 7.9 0.61 0.70 5.9 15t 6.1 7.3 0.58 0 ..59 6.3 30t 4.9 5.8 0.50 0.39 6.6 ~ 50t 3.7 4.4 0.41 0.27 6.9 75t 1.6 1.9 0.17 0.11 7.3 8St . 0.6 0.7 0.07 0.03 8.1 CARLTON4 0% 5.9 7.0 0.48 0.61 5.3 15t 5.3 6.3 0.46 0.50 5.4 30t 4.6 5.3 0.40 0.35 5.8 50t 3.3 3.8 0.34 0.20 6.4 75% 1.2 1.4 0.13 0.05 6.9 85% 0.4 0.5 0.05 0.05 7.4 , 2Cigarette wrapper porosity 3Cigarette wrapper porosity .4Cigarette wrapper porosity 1Various dilution levels were achieved by applying glue to the perforations in the filter. N 0 for Barclay KSSP is 15 seconds (Greiner). N N for Cambridge KSSP is 13 seconds CGreiner). CA ~ for Carlton KSSP is 13 seconds CGreiner). Q ~

2. TAR, TPM, NICOTINE AND WATER DELIVERIES OF DATA USED IN EXHIBIT 9. a. TAR BY FTC METHOD BRAND TAR TPM NIC. H20 PC ) BARCLAY 2. 1 2.6 0.28 0.20 8.0 I CAMBRIDGE 1. 3 1.6 0.17 0.12 7.0 CARLTON 0. 9 1.4 0.18 0.30 7.4 MARLBORO LIGHTS 12. 2 14.1 0.77 1.18 8.2 ) MERIT 7. 1 8.5 0.60 0.85 8.0 i B$H MULTIFILTER 11. 9 14.4 0.86 1.60 7.6 VANTAGE ULTRA LIGHTS 6. 6. 7.8 0.54 0.63* 7.4 WINSTON LIGHTS 12. 3 14.2 0.81 1.10 8.1

t, t , b. TAR AT AVERAGE SMOKER DILUTION. BRAND TAR TPM NIC. H20~ PC ) BARCLAY 9.3 10.9 0.89 0.75 7.1 CAMBRIDGE 1.8 2.1 0.22 0.11 7.5 ~ CARLTON 1.8 2.1 0.21 0.09 6.8 MARLBORO LIGHTS 12.2 14.1 0.77 1.18 8.2 ) MERIT 7.1 8.5 0.60 0.85 8.0 B€rH MULTIFILTER 11.9 14.4 0.86 •1.60, 7.6 ~ VANTAGE ULTRA-LIGHTS 6.3 7.7 0.58 . 0.80 7.5 WINSTON LIGHTS 12.8. 14.2 0.81 1.10 8.1

I r 3. DELIVERIES ON MODIFIED CAMBRIDGE FILTER HOLDER USING FTC TAR METHOD LO PRE EN ED 12 ) TAR TPM NICOTINE H,0 P.C. ..1 BARCLAY KSSP 9.4 11.8 1.12 1.26 6.8 CAMBRIDGE KSSP 1.4 1.6 0.17 0.07 7.0 ) CARLTON KSSP 1.0 1.4 0.16 0.22 7.2 MARLBORO LIGHTS KSSP 11.8 13.8 0.77 1.24 8.7 j MERIT KSSP 7.0 8.5 0.59 0.92 8.2 B & H MULTI*- FILTER 11.5 14.2 0.83 1.89 8.7 VANTAGE ULTRA LIGHTS 6.4 7.S 0.50 0.57 7.6 i WINSTON LIGHTS 12.2 14.4 0.83 . 1.41 8.4 I

# 4!. RESISTANCE TO DRAW (RTD) OF B&H MULTIFILTER CIGARETTES: WITH AND WITHOUT FLUTES OCCLUDED ) FLUTES NOT OCCLUDED FLUTES OCCLUDED RTD, IN OF HZ0 1 DIL. RTD IN OF H20 ~ DIL.* I AVG. 3.2 27 6.1 25 ~ j SD 0.3 4 0.2 5

i ) - 37.ZL - MILllMaSERS 5. MODIFIED CAMBRIDGE FILTER HOLDER TARE WEIGHT = 42.86 GRAMS