Tobacco Documents Online

Appendix C Comments on the proposed WHO Resolution EB77/22 Add. 2 dated 11 January, 1986 The proposed Resolution makes a number of statements which are inconsistent with several expert studies and, if not shelved, the Resolution could at least be amended based on the argumen- tation below. I Re. item 1(2), part one : "that the presence of carcinogens and other toxic substances in tobacco smoke and other tobacco products is a known fact". I I I Comment These so-called carcinogens and toxic substances occur in minute auantities in tobacco smoke. None of these substances as found in tobacco smoke have proven to be the cause of any human disease. Furthermore, the same or similar substances can be found in natural foodstuffs, in the air we breathe, in water we drink, in cooked or stored foodstuffs, as well as in a wide variety of consumer goods such as detergents, dyes, cosmetics, solvents, fabrics and so on.

2 II Re. item 1 (2), part two : "and that the direct causaZ Zink between tobacco and a range of fataZ and disabling diseases has been scientifically proven". Suggested theme of amendment : A DIRECT CAUSAL LINK BETWEEN TOBACCO SMOKE AND DISEASE HAS NOT BEEN SCIENTIFICALLY PROVEN, MORE RESEARCH IS NEEDED TO EXPLAIN THE MANY INCONSISTENCIES IN THE DATA TO SUPPORT THE CAUSAL HYPOTHESIS. Comment (a) Inconsistencies There are many unexplained inconsistencies in the studies on this subject such as: Why is. it that the vast majority of "heavy" smokers never develop so-called "smoking- related" diseases? Why do Chinese women in Hong Kong have one of the highest rates of lung cancer in the world, when 45 percent of those contracting the disease have never smoked tobacco in any form? Why do Japanese males, who have one of the highest incidences of smoking in the world, have one of the lowest incidences of lung cancer? Why can one not explain the substantial differences in alleged "smoking-related" disease rates between Caucasian and Asian races, sexes, urban and rural groups?

i I I I L 3 (b) Cause and effect relationship The data suggesting a causal relationship is neither consistent, definitive nor conclusive. Despite this statistical data, no one has yet established the basic causal mechanisms for such diseases as lung cancer and heart disease. Those diseases generally statistically associated with smoking have also been statistically associated with many other suspected risk factors such as dietary practices, stress, workplace exposures, familial disposition, viral or other infections, air and water pollution and so on. Many eminent epidemiologists, statisticians and other scientists have challenged the association claimed from the epidemiology surveys on which the "smoking causes disease" theory is based. If the case against smoking were proven, why are scores of researchers around the world requesting more funds each year to investigate what role, if any, smoking may play in the development of disease? Despite 40 years of intensive scientific research, thousands of published reports, millions of research dollars (much of it provided by the tobacco industry) and CONTRARY TO WHAT THE WHO HAS STATED, THE CASE IS NOT CLOSED. MORE RESEARCH IS NEEDED.

4 III Re. Item 1 (3) : "that passive, enforced or involuntary smoking violates the right to health of non-smokers, who must be protected against this noxious form of environmental pollution". Suggested theme of amendment : IT IS CLAIMED THAT ENVIRONMENTAL TOBACCO SMOKE (ETS) IS A MAJOR CONTRIBUTOR TO THE QUALITY OF INDOOR AIR, AND THAT ETS MAY AFFECT THE HEALTH OF NON-SMOKERS. HOWEVER, THE SCIENTIFIC LITERATURE SHOWS THAT THESE CLAIMS ARE UNWARRANTED. Comment Although exposure to environmental tobacco smoke under extreme conditions may provoke complaints of irritation and annoyance, the claim that non-smokers are subjected to a health hazard when they are exposed to other people's tobacco smoke is not warranted by the scientific evidence. In April 1984, researchers from USA, Europe and Japan met in Vienna and their review of scientific evidence on environmental tobacco smoke and health resulted in a press release concluding that: "Should lawmakers wish to take legislative measures with regard to "passive" smoking, they will, for the present, not be able to base their efforts on a demonstrated health hazard from "passive" smoking". Also in 1984, German researchers reported, in a study of 1,351 office workers, that non-smokers exposed to environ- c mental mental tobacco smoke showed essentially no decrease pulmonary function. in

5 I . , i I L In 1983, a US Department of Health and Human Services report of current research on possible respiratory effects of exposure to environmental tobacco smoke concluded that such effects, if any, range from "negligible to quite small". Furthermore, a report from a workshop on Effects and Exposure Levels of Environmental Tobacco Smoke held in Geneva in March 1983, contained the following observation: "An overall evaluation based upon available scientific data leads to the conclusion that an increased risk (of lung cancer) for non-smokers from ETS exposure has not been established." (Dr. R. Rylander - "Workshop Perspectives", page 144 from above report) In summary, there is no justification for legal restric- tions on smoking in public or at the workplace on the basis of alleged health hazards from environmental tobacco smoke. Singling out environmental tobacco smoke as the only or major element in pollution of the workplace, severely distorts the pollution problem and would greatly restrict research into workplace hazards. Commonsense must dictate that there is a need for increased courtesy and mutual tolerance throughout the world. e

6 IV Re. Item 3 : ...... deplores direct and indirect practices which attempt to promote the use of tobacco, as this product is addictive and dangerous even when used as promoted. " Suggested theme of amendment : The words "as this product is addictive and dangerous even when used as promoted" should be eliminated as there is no scientific agreement to support these allegations. (See also under Section II) Comment I I (a) Several authoritative studies have shown that advertising has not been established as a significant factor for changes in total cigarette consumption. It aims to attract smokers to a particular brand instead of a competing one. (b) The term "addiction" is widely misused and leads to severe misunderstandings. There are numerous definitions of "addiction" and the labelling of tobacco use as an "addiction" is misleading and directly contradicts WHO's International Classifi- cation of Disease which defines many products as dependence-producing, but not tobacco. Many smokers have been reported to stop smoking for practical, safety or religious reasons and to do so without apparent discomfort. Such behaviour does not fit the conventional view of "addiction". The decline in smoking documented in Britain, Con- tinental Europe and North America is not consistent with the notion that tobacco is "addictive" nor with the observation that some 95% of those Americans who quit smoking did so without the aid of organized smoking cessation programmes. s

7 V Re. Item 4 (2) : "measures to promote abstention from the use of tobacco so as to protect children and young people from becoming addicted." Suggested theme of amendment : "TO PREVENT CHILDREN AND YOUNG PEOPLE FROM TAKING UP SMOKING." Comment As argued in section IV, the term "addicted" should be eliminated from the Resolution. I I I The tobacco industry holds the view that smoking is an adult custom and is concerned that where a law exists relating to cigarette sales to under-age purchasers, this law is not contravened. On a number of occasions, the industry has taken direct and active steps to encourage the observance of the law by retailers.

8 VI Re Item 4 (8) : "the promotion of viable economic aZternatives to tobacco production and trade" Suggested theme of amendment : "THE PROMOTION OF VIABLE CASH CROPS WHICH COMPLEMENT TOBACCO PRODUCTION." r ( { t I Comment Studies undertaken by the Economist Intelligence Unit, the University of Reading (U.K.) and the FAO during 1981-1983 have shown that in nearly every tobacco producing country, tobacco is one of the most valuable crops grown, yielding net returns which may be several times higher than those obtained from crops of staple foodstuffs. In its issue of March-April 1983, "CERES", a bi-monthly magazine published by the FAO, carried a review of the 1983 FAO Report "The Economic Significance of Tobacco" under the title "Tobacco is too profitable to curb growing". Here follow some extracts: "Tobacco is, in fact, one commodity in which even smaller developing countries can find immediate tangible social and economic benefits. ?ts growing generates the employment of largely rural populations and it provides a ready source of cash for small- holders who would otherwise have to rely on subsis- tence farming or on less remunerative crops. Tobacco leaf, the unmanufactured product, is an important source of foreign exchange for exporting countries. Tobacco manufacturing creates extensive employment opportunities, particularly in developing countries where manual methods of production are still the most common. Finall_v, tobacco products are a very important and easily tapped source of tax revenue for governments in both developing and developed countries."

9 The review continues: "As one of the most widely grown non-food crops - it occupies seventh place after wheat, rice, maize, soybeans, cotton and coffee - tobacco is produced in about 120 countries and territories while requiring a mere 0.3 percent of the world's arable land, against 16.3 percent occupied by wheat, 2.3 by cotton and 0.7 by coffee. Thus, even in countries where aggregate cash receipts from tobacco are relatively small, their contribution to total agricultural incomes can be considerable." I And it ends by stating: "As an important source of employment and cash income in all the countries where it is grown, tobacco not only provides a livelihood for the growers, but also for other workers; it provides rural work, industrial employment and national income. It is a lot more than just smoke in the economy of many countries." It is often alleged by anti-tobacco campaigners that food shortages are caused because tobacco is grown on land that might otherwise be used for the production of food crops. However, studies undertaken by the Economist Intelligence Unit in the early 1980's have shown that land which can be used for the growing of tobacco is often unsuitable for growing other crops and that, where this is not the case, yields of food crops which have been planted after tobacco are higher than they would otherwise have been. The main findings can be summarized as follows: I Tobacco accounts for only a small proportion of land under arable and permanent crops. N 0 ~ ~ It occupies that land for only part of the crop year. ~ N ~ N L i

L 10 Grown after tobacco, food and cash crops generally achieve much higher yields from the benefit of the residual tobacco fertilizer. - The growing of tobacco greatly improves agricultural knowledge and skills. - Tobacco is one of the most stable commodities, least subject to price variations. Most important of all, tobacco is a high value cash crop producing a good and stable return for the farmer. He invests and spends that income, both on his farm and on other products and so generates greater economic activity and prosperity. It is therefore not in the least surprising that virtually every independent research organisation and specialist, who has investigated the impact of the growing of tobacco in the developing world, has concluded that it complements and benefits food production. Finally, it is worth considering what might happen in many developing countries if governments were persuaded to eradicate established tobacco farms in their countries. In many of these countries there exist, and have existed for centuries, small unregistered plots where air-cured tobacco is grown for the use of the grower, and his family, and sometimes also for sale or barter to his neighbours. It would be logical to assume that in the wake of a ban on planting "regulated" tobacco crops, there would be a proliferation of unregistered tobacco plots without the benefit of controls extending to agronomic practices, fumigants, sprays, herbicides and pesticides. This would have obvious adverse economic implications for both farmers and governments, and possibly for consumers of such unregulated products. N tn 0 ~ ~ ~ N OD N v I