Tar & Nicotine Numbers - Philip Morris USA

The Commission directed that the test cover approximately 50 of the major brands and types (many brands are sold as regular, and king size, or filter, etc.) and all brands for which any tar or nicotine statement appears on the label or in the advertising. With respect to the latter, one purpose of the test will be to determine the accuracy of such statement. Cigarettes for testing will be purchased on the open market in 50 localities throughout the United States.

In determining the foregoing procedures, the Commission relied substantially upon a record including written presentation by interested persons and oral testimony offered at a public hearing on November 30, 1966, which was held "to assist the Commission in determining what action, if any, should be taken in the public interest with respect to modifying or amplifying the Cambridge Filter Method...and the form in which test results should be expressed." At the hearing the Commission received numerous submissions reflecting a variety of modifications of the Cambridge Filter Method that have been adopted by different groups engaged in testing cigarettes. No test can precisely duplicate conditions of actual human smoking and, within fairly wide limits, no one method can be said to be either "right" or "wrong." The Commission considers it most important that the test results be based on a reasonable standardized method and that they be capable of being presented to the public based on a uniform method used by all laboratories. Use of more than one testing method would produce different results which would only serve to confuse or mislead the public.

In determining the testing method, the Commission has not attempted to gauge the test to the amount of smoke, or tar and nicotine, which the "average" smoker will draw from any particular cigarette.

No two human smokers smoke in the same way. No individual smoker always smokes in the same fashion. The speed at which one smokes varies both among smokers, and usually also varies with the same individual under different circumstances even within the same day. Some take long puffs (or draws), some take short puffs. That variation affects the tar and nicotine quantity in the smoke generated.

Even with the same type of cigarette, individual smokers take a different number of puffs per cigarette depending upon the circumstances. When concentrating, or talking, the number of puffs is usually less. When listening, or required to listen to another person talking, the number of puffs per cigarette, as well as the duration of each puff, usually increases. Smoking rates while reading a book may differ from smoking rates while viewing a television program. The number of puffs and puff duration (as well as butt length) will vary according to emotional state. Some smokers customarily put their cigarettes down in an ashtray where they burn between puffs; other smokers constantly hold cigarettes in their mouths; others hold them between their fingers.

The Cambridge Filter Method does not and cannot measure these many variations in human smoking habits. It does not measure tar or nicotine in the smoke generated while the cigarette is not being puffed. It does not measure all of the tar and nicotine in any cigarette, but only that in the smoke drawn in the standardized machine smoking according to the prescribed method. Thus, the purpose of testing is not to determine the amount of tar and nicotine inhaled by any human smoker, but rather to determine the amount of tar and nicotine generated when a cigarette is smoked by a machine in accordance with the prescribed method.

Accordingly, the testing method should not be considered defective because it does not rely on "averages." There are too many variables as to both smokers and smoking conditions for any average to be meaningful. Test results phrased in terms of an "average" smoker could be misleading to the public, because a smoker has no way of knowing how closely his smoking habits conform to those of the purportedly "average" smoker. It should be emphasized that the Cambridge Filter Method itself did not purport to duplicate an "average" smoker. Rather, it was an amalgam of many choices - some of them arbitrary. For example, the temperature and humidity specified in that Method were not determined by reference to the "average" temperature or the "average" humidity at which people smoke cigarettes. There is no human smoker who smokes, and no cigarette that is smoked, under conditions that precisely duplicate either the Cambridge Filter Method in its original form or as modified by the Commission. Thus, to reiterate, the uniform method determined by the Commission has as its purpose measurement of the tar and nicotine generated by cigarettes when smoked according to that procedure.

There has been a wide variation among testing groups on the question of how many cigarettes of each brand to test. Recommendations were made to the Commission to test as few as 60 cigarettes per brand and as many as 200. After studying the record and its laboratory's preliminary test results, the Commission has determined that testing 100 cigarettes per brand will provide valid and reliable results. However, the Commission intends to continue evaluating its test results, and on that basis may determine in the future to change the number of cigarettes tested or any other testing procedures as may be found necessary.

Chairman Dixon dissents from that part of the majority's direction on testing procedures with respect to butt length and has filed a separate statement which is attached.

Commissioner MacIntyre did not participate in the Commission's vote on this matter for the reason that he did not consider that the Commission's cigarette testing laboratory had satisfactorily completed its trial test so as to sufficiently and adequately advise the Commission regarding what is required in this respect.