Tobacco Documents Online

.•• Exhibit 3 * 471 AFFIDAVIT OF BEA J. VAN DEN BERG The undersigned, Bea J. van den Berg, M.D., deposes and states as follows: 1. I am director of Child Health and Development Studies, a research unit of the University of California School of Public Health and, until July 1990, Adjunct Professor of Maternal and Child Health at the University of California School of Public Health, Berkeley, California. 2. I received my medical degree in the Netherlands. In 1965, I joined the research staff of the Child Health and Development Studies, a research project which was designed and directed by the late Dr. J. Yerushalmy, Professor of Biostatistics at the University of California at Berkeley. My -Curriculum Vitae is attached. 3. I have conducted research involving several areas of smoking and health. ~ ~ 4. In March 1983 I gave the attached evidence in the -United States Congress, House of Representatives, Committee on :Energy and Commerce, Subcommittee on Health and the Environment. VThis evidence related to my study of pregnancy outcome in women who smoked during pregnancy. 5. I offered that evidence because at that time there ~existed a controversy over the existence of an increased risk of 1~ spontaneous abortion and stillbirths among women who smoked during pregnancy. My research did not support the existence of

6. For almost two- _ "'"„~ . Development studies, we studied pregnancy outcomes o women wno smoked cigarettes during pregnancy,`'in comparison to women°W . pregnancy. These studies were based on interviews"early in their` never smoked or stopped smoking before, or ear7y in tlieir pregnancies. 7. Our statistical studies, comparing the risk of fetal death for smoking and non-smoking pregnan find a difference between the two groups`: .. evidence that smoking during pregnancy does not rais`e the r'isk~or } womenI ''''f ai1ed "'to on the pregnancy outcome of 15,0d0 pregnant women, provide spontaneous abortion and stillbirth nor did our observatlons . .: . . s - .. support the allegation that cigarette smoking by`pregnant women' may result in severe birth defects:-J- 8. These studies were prospective'and observationa1 11 smoking groups. The cigarette smokers have` already# chosen Subjects are of course not randomly assigned to smoking or riot-' ` Data were gathered before the event such as pregriancy`"outcome: themselves. Our approach in these studies wasG'to try to distinguish between characteristics o smoking habit. 9. ' ' ` self-selection a the nd From data derived from a study'which included 1,000 young women, we examined the relationship between smocing and characteristics which could not possibly be caused by smoking, such as age at first pregnancy and the tendency to obtain an induced abortion. N U'! O f-+ ~ 2 © W ~ C,3

Ir• 10. Smokers experienced their first pregnancy at earlier ages on average. For example, among the white women who were smokers, 21% experienced a pregnancy before they were 19 years old. Among the non-smokers only 4% became pregnant before age 19. 11. The most probable explanation for the lower age of first pregnancy and the higher rate of induced abortion observed among smokers compared to non-smokers, is that they reflect considerable difference in life-style, and concepts of health habits and risk taking. 12. We also examined adolescent smoking and early respiratory disease. (See Adolescent Smoking and Early Respiratory Disease: A Longitudinal study 59 Annals of Alwlergy 135 (1987) Oechsli, Seltzer, and van den Berg). 13. Other studies had identified a greater risk of respiratory disease among smokers than non-smokers. Our study sought to identify the temporal relation between the*onset of disease and commencement of the smoking habit. 14. In the 2,000 adolescent subjects, although, respiratory illness showed a statistically significant association with smoking, the disease preceded commencement of smoking in 90.5% of the smokers with asthma, and 60% of the smokers with bronchitis. 15. These data suggest that smokers may possess a constitutional or (genetic) predisposition to the onset of 3 4s

childhood asthma unrelated to any direct effect of cigarette c t smoking. 16. The hypothesis that the association between smoking and a health outcome may reflect a constitutional difference between smokers and non-smokers is not new. In the 1960's and 70's, I participated in studies conducted by Professor Yerushalmy. Those studies were the basis of the work we are continuing. Thorough analysis of those studies between smoking and certain health conditions led Professor Yerushalmy to the hypothesis that there were biological differences between smokers and non-smokers. 17. We had observed, for example, that smoking mothers had a greater likelihood of having twins and that the age of menarche of smokers (which occurred before they began smoking) was younger in women who later became smokers. Similarly, we observed that, before they began smoking, women who later became smokers had a greater frequency of low birth weight babies than women who did not smoke. Ex-smokers had lower rates of low birth weight babies than smokers during the period before they began smoking. N Ln 0 ~ 0 -4 0 CA) -0 Ln 4

18. In conclusion, I believe, and have observed, that there has been a controversy within the scientific community with respect to the causal significance of the association between cigarette smoking and certain aspects of health. Subscribed and sworn to be before me this ;.6 day of ,Vor.,.bw, 1990. NOTARY PUBLIC WCHAE. F. S. OrAHOSa[+1 ~Y Na1-il5~'ll~~wUbrlc Co~io~n 5