This is a comment that I’ve just submitted to the FDA asking them to enforce their own regulations and conduct appropriate testing, which has not been done to date, to determine whether all current IQOS applications are in compliance with regard to pesticide residues as required by this rule, and then to determine the impact of any discovered pesticide residues on the manufacturer’s many and deceptive “Modified Risk” claims.
You can support a moveon petition to Congress demanding that FDA investigate by clicking on the cute little hummingbird choking on clouds of vaporized pesticides.
(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.
FDA Comment Submission
I am concerned that
The presence of pesticide residues in the Tobacco component of IQOS has not been discussed or referenced in any of Philip Morris’s FDA multiple IQOS applications.
While the IQOS applications offer extensively documented comparisons between toxic substances in the IQOS vapor stream and toxic substances in the smoke stream of combusted Tobacco (reference Cigarettes only, not commercial cigarettes), after performing a keyword search through the submitted IQOS documentation I can find no mention of any comparison of pesticide residues in the IQOS vapor stream with those in a reference cigarette smoke stream in support of the IQOS claim of “modified risk”.
The public record does not show that FDA has yet requested that Philip Morris demonstrate compliance with Special Rule 907(a)(1)(B) with regard to any of its IQOS applications.
To grant any application related to IQOS without first establishing that IQOS can and will comply with Special Rule 907(a)(1)(B) would seriously jeopardize public health in that without demonstrated compliance and published results, the public will not have an opportunity to make a fair and complete comparison of the relative risks the pesticide residue contaminants of the IQOS product vs combustible Tobacco products.
To grant any application related to IQOS that claims “harm reduction” without first comparing the relative harm of inhaling the intact pesticide burden in the IQOS vapor stream to the harm of inhaling the partially combusted, altered and degraded pesticides in a conventional Tobacco smoke stream, would not serve the public’s interest in having full and fair disclosure of all relevant risks associated with the use of IQOS.
Discussion
Because the Tobacco materials, along with any pesticide residues, in the Tobacco component of IQOS will be vaporized well below the point of pyrolytic degradation, and none of any pesticide residues contained in the Tobacco component will be destroyed by combustion, therefore it is reasonable to project that a greater proportion of the original pesticide residue burden on the Tobacco component of IQOS will survive and retain bioactivity in the vapor stream compared with the proportion of surviving and bioactive pesticide residues in a smoke stream that would be generated by combusting that same Tobacco component; and
Because in making its case for “modified risk” Philip Morris, by comparing the toxicant properties of an IQOS vapor stream with the toxicant properties of a Reference Cigarette smoke stream, either by oversight or by design fails to address the differences in potential for harm between (1) delivery of the full original pesticide residue burden in the IQOS vapor stream compared with (2) delivery of a reduced portion of the original pesticide residue burden, of which a portion has been destroyed by combustion, and some or all of the remainder of which has been dry-distilled into altered compounds and/or partially degraded by pyrolytic processes; and,
Because Special Rule 907(a)(1)(B) requires that manufacturers “shall not use” tobacco of any origin containing pesticide residues “at a greater level” than “any tolerance” specified under Federal law; and
Because in addition to pesticides registered for use on Tobacco with established tolerance levels, Federal law also specifies certain pesticides that are banned for use on Tobacco; in the context of US Special Rule 907(a)(1)(B) this requires that manufacturers shall not use any Tobacco containing those banned pesticides “at a greater level” than zero; and
Because current Tobacco industry documentation shows that certain pesticides not registered for use on Tobacco in the United States are present in the world Tobacco supply, and certain pesticides banned in the US are also present in the world Tobacco supply (https://www.coresta.org/agrochemical-guidance-residue-levels-grls-29205.html ); and
Because Philip Morris is a large importer of Tobacco stem and waste materials from Brazil, a Tobacco exporter with documented heavy use of pesticides on Tobacco crops; (https://www.zauba.com/Buyers-of-tobacco-stems) and
Because imported Brazilian Tobacco stems and waste that are likely to be contaminated with pesticides residues, some of which may violate the “greater level” condition of Special Rule 907(a)(1)(B), are used in large quantities (millions of kilograms/year) by Philip Morris in its Tobacco product manufacturing in the US and are therefore, in the absence of any statement by the manufacturer to the contrary, likely used in its IQOS manufacturing processes; however, without testing for the presence and concentration of pesticide residues in the IQOS Tobacco component there can be no demonstration of IQOS compliance with Special Rule 907(a)(1)(B) regarding any such “imported tobacco”; and
Because Brazilian Tobacco pesticide use includes the documented use of pesticides for which US EPA and USDA have established that there are no safe levels, and that are either not registered or banned for use on Tobacco in the US ( https://www.hindawi.com/journals/omcl/2018/7017423/); therefore,
I am requesting that FDA suspend further consideration of the Philip Morris MRTP application, and any other Philip Morris application that can result in approval by the FDA for sale of IQOS in the US, until the issues I raise here are addressed under the FDA’s 907(a)(1)(B) authority and any other applicable enabling authorities.
This MoveOn.org petition urges Congress to intervene and order the FDA to suspend all IQOS applications while conducting an investigation of a previously-unrecognized public health threat represented by the IQOS system.
Please click on the happy little hummingbird hovering in all that harmless IQOS vapor, sign the petition, and help stop this sinister fraud.
The Petition Is Simple
“We ask that Congress act with urgency to direct and enable FDA to immediately conduct testing for residues of toxic and banned pesticides on the Tobacco component of IQOS before any further consideration of any of the pending IQOS applications.
And It’s Important
The pesticides in IQOS Tobacco won’t be burned – they’ll be vaporized with full bioactivity intact. There will be much higher concentrations of these toxic substances in Tobacco vapor than in Tobacco smoke.
Teens and younger children whose neurological and reproductive development is still highly vulnerable to the xenobiotic activity of these chemicals will be inhaling a concentrated pesticide vapor, including vapors of pesticides banned for use anywhere in the world.
In its applications for IQOS Philip Morris never mentions pesticides. Accidental oversight or deliberate omission? Philip Morris is well aware of the presence of these toxic substances in the world Tobacco supply yet they appear nowhere in the list of substances being avoided by IQOS users in comparison to smokers.
(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.
Congress has to act now, before IQOS can begin vaporizing millions of American lives. And not incidentally, that’s why the 24 countries where IQOS is already vaporizing lives need to investigate and act with even more urgency than the US Congress.
This is a list of pesticide residues from an internal industry document that reveals the 100+ pesticide residues in the world Tobacco supply. That means any or all of these could be in any given Tobacco product in any country. IQOS uses Tobacco to produce its vapor. There is enough authoritative published evidence that these pesticide residues will be present in IQOS Tobacco vapor for Congress to order the FDA to investigate and if necessary act to prevent the chronic exposure of potentially millions of Americans to these 100% avoidable toxic substances.
Why avoidable? Because the industry knows how to produce organic Tobacco products. But they choose not to. That’s an purely financial decision, disregarding the health consequences, that could only be made safely if they believed that the fix was firmly in and working smoothly.
For the past few years I’ve been hoping that somebody who has actually grown Coca in a greenhouse would write a little guide for growers, but probably for some very good reasons it looks like nobody is going to take that chance. So I thought I would do the best job possible working mainly with historical data. Also just for fun I’ve also priced it the same as my first Cultivators Handbook of Marijuana in 1969 – three bucks. I hope that makes it easy to own and read, and I hope the ideas in this Handbook can help bring about the liberation of Mama Coca the way the original “Cultivators” helped move things along a little in the early days of the Cannabis revolution.
Even though I’ve been researching Coca history and traditions for a long time by exploring Coca literature from the 1700’s and 1800’s, I never really appreciated how much practical growing advice was scattered throughout this fascinating long-lost literary history. Lost knowledge is a tool waiting to be picked up and used once again, and it has been fun doing just that with the incredible Coca literature of the 1700’s and 1800’s. Not that there aren’t web resources that cover the basics of Coca growing, but it’s another thing altogether to hear voices from hundreds of years ago speaking with passion and authority on every little aspect of their exciting new discovery – the Coca plant and it’s incredible leaf.
Of course what’s missing at this point in Handbook, other than an excellent section by Angelo Mariani on his Paris Coca greenhouses, is any good current information on greenhouse Coca cultivation of the kind that Cannabis growers have gotten very good at. There is no question at all that Coca can be grown indoors with exactly the same technology as Cannabis, and I hope that is already happening in some very private places. Maybe I can help things along a little with some of the information here and then perhaps someone more knowledgeable than me will share what they know too.
As just mentioned, in the Handbook we look at the classic 1880’s Coca greenhouses of Angelo Mariani outside Paris, and explore his advice on growing the very highest quality Coca leaf under glass. Mariani was without doubt the first true connoisseur of Coca Leaf itself and had barely
A handful of magic beans
disguised contempt for the Cocaine craze of his time. His Bordeaux wine-based “Vin Mariani” was celebrated worldwide and set the standard for Coca wine, and he knew more about high-quality Coca Leaf production than any other European or American of his time or probably since. He maintained two first-class Coca plantations in Bolivia and greenhouses in several cities in France, and his advice is simple but definitely gold standard.
So here’s a list of what you’ll find in this first edition, and feel free to click on any of the images in this post to go to Amazon and read inside the book.
Finally – do you know something you want to share about Coca? I’m calling on readers, growers, botanists and other Friends of Mama Coca to communicate with me and help expand and evolve this resource. Just click HERE to send me a message.
The bean is ready!
Summary Of Coca Cultivation Techniques
Coca Cultivation Over The Centuries
Coca’s Natural Home Environment
Botany of the Coca Plant: Part One
Botany of the Coca Plant: Part Two
Traditional Andean Coca-Growing Regions
Ideal Coca-Growing Conditions
The Exquisite Coca Flower
The Importance Of Humidity
Coca Soils Of The Montaña
It’s all good!
Best Kinds of Earth For Coca Cultivation
How To Select Viable Seeds
Protecting Seeds & Seedlings
Planting Out & Cultivating Coca
Daily Life Of A Coca Grower
High Quality vs. Inferior Coca Leaf
Peruvian vs. Bolivian Leaf – A Comparison
Ensuring High Quality Coca Leaves
Harvesting & Curing Coca Leaf: Part One
Traditional Harvesting Techniques: Part Two
Natural Enemies Of Coca
Commentaries On Coca
Happy leaves
Searching For Wild Coca
Angelo Mariani – Master Coca Grower
Coca & Its Therapeutic Properties
Proper Cultivation Techniques
Harvesting For Maximum Purity & Potency
Preparation of the Coca Leaves
Coca Leaf – A Better Medicine
Natural Medicinal Preparations Of Coca Leaf
Your Keys To This Ancient Knowledge
I especially hope that you enjoy reading and exploring the “Keys To Knowledge” hyperlinked bibliography at the end of this little Handbook as much as I enjoyed putting it together for you.
Brief Explanation: This is a proposal for addressing protein energy malnutrition in rural communities that my friends Peter, Luis and I (we called ourselves AF&T) created a few years back as part of another, bioenergy-related project. The people we submitted the proposal to weren’t responsive, but I still believe that it is such a high-potential approach to empowering rural women to feed themselves and their families with enough high-quality protein to thrive that I am posting it for anyone in the community who can use it. My friends and I would, of course, be happy to help if needed.
Proposal Summary
AF&T’s proposal seeks to interrupt the protein energy malnutrition (PEM) cycle in women from childhood through child-bearing age. Maternal PEM is the direct cause of both fetal malnourishment and low birth weight children and the low or absent capacity of the mother to provide breast milk for her newborn and infant children. AF&T will demonstrate that palatable, nutritious plant leaf protein, extracted from specific high protein plants using appropriate village-scale technology, can be produced at the local level in almost any environment and can address the primary obstacle to controlling and potentially eradicating PEM, which is that most people living in rural villages have inadequate access to high quality protein both for themselves and for their animals. All actions required to implement this proposal at the village level are consistent with the normal role of women in rural settings worldwide.
Proposal Narrative
Inadequate access to protein means, for much of the rural underdeveloped world, inadequate access to animal protein. Women and children in developing countries frequently bear the principal responsibility for accompanying domestic animals on their search for widely dispersed and low quality forage. In many cases this search burns more calories than the forage that is found provides. Thus, both the animals and the people run permanent and increasing caloric deficits. Pregnant women are not exempt from accompanying the animals, resulting in gradual progressive starvation of both the mother and the unborn child. Women who run a caloric deficit before and during pregnancy, and more specifically a protein energy deficit, not only more frequently give birth to low birth-weight and otherwise health-compromised newborns, their breast milk production is also compromised.
It is a vicious cycle, resulting in permanent developmental damage to children, vulnerability of the newborn and infant to disease, injury, and infection and all too frequently in death before the age of two. In turn, this results in more frequent pregnancies, and the accompanying progressive drain on the woman’s nutritional resources, as well as the loss of the protective effect of breast-feeding against pregnancy. AF&T proposes to develop and demonstrate a village-scale appropriate technology that can be used to extract high quality plant protein from purpose grown drought-tolerant crops that can be used to provide adequate high protein feed for domestic animals with little expenditure of caloric energy in search of forage. In turn, this appropriate technology will mean greater access to milk, meat, eggs and other forms of animal protein using only local resources and labor, requiring no external resources or support once installed.
The rationale for developing an appropriate technology that can be used to extract plant proteins for use as animal feed, rather than simply using the whole plant as feed, is that by separating the proteins from the rest of the plant materials those plant materials can be used for other purposes, including the production of biogas in household digesters which are ubiquitous in much of the rural underdeveloped world, and for other purposes including animal bedding and household heating and cooking fuel, while preserving the high value proteins as animal feed.
In a parallel phase of our proposed program, recognizing that a significant part of the rural underdeveloped world is vegetarian on the basis of religious beliefs, AF&T will take the protein extracted from purpose-grown high protein plants using the village-level appropriate technology referred to above, and will develop a high protein plant extract that is both palatable and nutritious using a process developed over thousands of years to make high protein vegetarian Miso from a wide variety of plant materials including soy, barley, chickpea and other plant proteins. We expect that this process will eliminate the primary obstacle to acceptance of plant leaf protein extracts in the past, which has been that, untreated, it has a bitter and unacceptable “green taste”. By applying the principles and techniques for the production of tasty and nourishing Miso from plant materials to the protein extracted using a variation on already established methods such as the well-known “Lucerne” method, we plan to develop a nutritious palatable high protein paste that can be eaten by itself or mixed into virtually any other food, or consumed as a broth, as is the case with traditional Miso.
The “Lucerne” method consists of macerating plant materials in water to create a slurry – Alfalfa is the plant material typically used in the case of the “Lucerne” method – and then slowly raising the temperature of the slurry until the plant proteins coagulate and rise to the surface, where they are skimmed off, then dried and ground into a high protein powder. As noted, while this material is indeed high in proteins, it is also rich in oils and pigments, accounting for its unacceptably bitter “green taste”. We will demonstrate that by applying the traditional Miso fermentation process to this extract, this bitterness and green taste will be removed, resulting in a highly nutritious, high protein food that is stable without refrigeration.
After a comprehensive review of many leaf protein resources worldwide, we have identified Pennisetum purpurem as the best candidate for leaf protein extraction. We propose to build upon known leaf protein extraction technologies to develop a methodology that can turn purpose-grown high protein Pennisetum purpurem (and other leafy non-food plants) into both (A) a nutritious, and palatable source of human food-grade protein and (B) a nutritious, abundant source of high quality animal feed that does not require foraging.
The basis for AF&T’s selection of Pennisetum purpurem as our plant choice for leaf protein is supported by over 30 years of experience in ranch and livestock management on the part of one of our partners, and by a body of science that affirms the quality and palatability of Pennisetum purpurem as animal feed. There is also solid supporting scientific evidence that simple extraction methods using village-scale appropriate technology can be effectively used for extracting protein from herbaceous plants. Further, there are both scientific studies and voluminous anecdotal evidence that leaf protein can be an effective intervention in cases of childhood Protein Energy Malnutrition (PEM) and disease, and that leaf protein is also an effective animal feed, whether found in nature as forage or provided as feed.
Recognizing that, however desirable it may be as a leaf protein resource, Pennisetum purpurem is not a one-size-fits-all source of plant protein. AF&T has researched other common high leaf protein indigenous plant species capturing data on growing and climate conditions, fertilizer needs and application rates, best cultivation practices, and leaf protein levels. These species include: (1) Amaranthus tricolor ( African/Chinese spinach, Tampala, Bledo); (2) Cnidoscolus chayamansa (Chaya, Tree spinach,Chaya col, Kikilchay, Chaykeken); (3) Crotolaraia longirostrata (Chipilin; also Sunnhemp); (4) Medicago sativa (alfalfa, Lucerne); and (5) Vigna unguiculata (cowpeas, Caupi, Frijol de Vaca, Frijo Mica, Feijao de Corda).
AF&T’s Phase I experimental plan has three main components. 1) produce a Miso-like leaf protein paste that is can be added to any food base or consumed by itself without a strong “green taste”; 2) test and compare several extraction methods and technologies establishing extraction and flavoring protocols; and 3) conduct a series of leaf protein palatability tests..
Upon a successful Phase I, we plan to move from small scale trials designed to identify the optimum extraction methods to moving those extraction methods to full village scale capable of supporting a model village of 500 people with 50 domestic animals, and initiating overseas leaf protein production trials. We plan to partner with a well-networked NGO to begin the familiarization process, and provide various forms of leaf protein foods to selected groups in developing countries and generate data on key indicators of improved maternal, fetal, newborn and infant nutrition including birth weight, ratio of live births, newborn and infant weight gain, and incidence and duration of successful breast feeding. AF&T’s primary partner, MMC, through its global online network will engage the local medical, scientific and analytical resources and capacities needed to monitor and evaluate the impact of these foods on human nutrition. AF&T will also generate U.S. data for leaf protein extraction residue used as animal feed, including weight gain, milk and egg production, fiber quality, fertility and reproduction.
Working with collaborators, AF&T will use our protein extraction experience and protocols to design and build a prototype protein extraction technology using essentially “off-the-shelf” components and placing a small number of prototypes in developing country communities. After prototype development and testing, we intend to model our dissemination of this technology following the “Heifer Project” model. Just as the Heifer Project puts animals, which are essentially meat and milk protein machines, into the hands of village-level entrepreneurs (mostly women), after a training program, AF&T’s vision is to put increasing numbers of Leaf Protein extraction units into similar hands after training. We will utilize the global village-level reach of MMC and other NGO partners to identify, qualify, train and support these food entrepreneurs and help them establish their local biomass grower networks. They will be able to produce culturally acceptable, nutritionally and clinically potent protein food products with high nutritive values that will gradually become a part of peoples’ volitional diets, with the residues of the process to be used as a high value animal feed that we believe will provide a community nutritional level solution to the human toll now wrought by Protein Energy Malnutrition.
APPENDIX – FOOD-GRADE PROTEIN & BIOENERGY PRODUCTION
Energy Cane (Pennisetum pupura) Concentrate Process
This process was developed for use with energy cane used as a substrate for a bioenergy project. It is based on a similar process used in the EU to extract leaf protein from Alfalfa for use as both human and animal feed. This same process can be directly scaled down for use with appropriate low-technology at the village level.
Animal feed values for Pennisetum p. are shown in this table.
If Pennisetum p. energy cane in excess of the bioenergy installation requirements is produced, that portion of excess cane can be taken through the process described below to extract additional co-product value.
In this way a crop of energy cane can generate three distinct revenue streams: (1) as a source of high value protein curd extracted from the macerated whole plant (2) as Brown Juice plus the fibrous pulp from which the Green Juice has originally been extracted, utilized as a biogas production booster when combined with animal manure and other substrates and (3) as a source of enhanced animal feed production when excess cane is produced but not used in the AD processes.
1. Pulping and pressing of energy cane
Immediately after cutting, the cane is pulped and pressed forcefully to separate a large part of the nutritional factors from the indigestible fiber. Done rapidly, this stage also limits hydrolysis of cellular proteins by proteases. The nutritional elements, consisting principally of chloroplastic and cytoplasmic proteins, pigments and vitamins, are recovered in the green juice expressed.
The co-product of this green juice production, the ligneous and cellulosic fibers of the stalk and leaves, is dried and used as fodder, as it remains an excellent source of high quantity animal feed. Its overall nutritive value, moreover, is improved because of the shattering of the stalk fibers (the nutrients are freed and the fibers themselves more easily digested by the cellulytic ferment in the rumen).
2. Heat coagulation of protein
The green juice, adjusted to pH 8.5 utilizing acetic acid to slow down the action of phenyloxydase and to improve the structure of the coagulum, is pre-heated and then brought to 85-90* C by steam injection. This causes coagulation without degradation of almost all the proteins which are within the pigments; fat-soluble vitamins, lipids and minerals.
3. Separation of the coagulum
Next, the coagulum (moist green curd containing the majority of the nutrients) is centrifuged from the rest of the solution (designated brown juice from this point on in the process).
This curd contains more than 50 % of crude protein, of which 80 % is true protein, accompanied by some free amino-acids or peptides. Heat coagulation extracts on average 8 % of the original DM of the crop and 20 – 25 % of its protein.
4. Drying and storage
The curd, as paste, having been mechanically separated from most of the brown juice is dried on a heated belt utilizing process heat from the generator unit of the AD facility. So far, the making of concentrates for animal or human consumption is the same.
Then, the concentrate is pelletized and stored in sealed silos’ cells under inert gas, awaiting distribution.
For human feeding, the energy cane concentrate is ground. This meal (on average with moisture content of 8 %) must be kept dry, away from air, heat and light. Thus, it is bagged hermetically immediately.
To protect pigments and vitamins an antioxidant is added
– For animal feed: Ethoxyquin (150 mg/kg)
– For human feed : Ascorbic acid (500 mg/kg).
5. By-product usage
The brown juice, still containing 13 – 15 % of the original dry matter (DM) is mainly soluble Nitrogen mineral salts and sugars It is mixed with the fibrous residue. This mixture is dried in high temperature air in a rotating drum. The by-product thus obtained is ground, pelletized and stocked for marketing. It contains 16-20 % protein, 25-30 % cellulose and 100-150 mg carotene/kg. It is excellent fodder for cattle and rabbits.
For the profitability of this industry, the realization of the value of the two products (protein extract and co-product representing- respectively 8 % and 92 % original DM) is essential.
6. Homogeneity of energy cane concentrate (ECC)
The protein content of ECC varies slightly, from 50 – 60 %, although the protein content of energy cane as cut varies from 15 – 25 %, according to the timing of the cut and vegetative stage of the crop. Thus the variation in quality of the vegetation processed results in a quantity of ECC between 6 and 12 % of original DM with an average of 8%
Highwaymen in the Middle Ages gave travelers a choice – they could hand over their cash and all their possessions, or they could hand over their life. At least those criminals gave their victims a choice.
Big tobacco wants both. “They just keep lining up for a smoke, so we grab ’em, drain ’em, and toss ’em aside – there’s plenty more coming down the highway. “
This post offers you an inside look at how Big Tobacco spreads its money around to buy scientists and regulators in order to create meaningless tobacco regulations based on purposely faked science so they can say “See, we’re playing by the rules, so you can’t touch us.”
Well, I do believe that Big Tobacco has outsmarted itself with its attempt to move smokers away from smoking and into vaporizing. That’s because in order to accomplish this massive feat of social engineering Big Tobacco has inadvertently revealed some things about their industrial practices that will, when clearly understood, point directly to their massive corporate crimes.
This post is an excerpt from a World Health Organization internal document titled: “Tobacco Company Strategies to Undermine Tobacco Control Activities at the World Health Organization”. This 250 page report reveals the extent of Big Tobacco’s subversion, corruption, intimidation and seduction of scientists, regulators, institutions, and anti-tobacco efforts worldwide. WHO estimates that by 2050 Big Tobacco will have killed 1 Billion people in its rampage, and this is a detailed look at how it has managed to accomplish the miracle of killing millions of people for profit and never being held criminally accountable.
This courageous and powerful report reveals in great detail the remarkable efforts Big Tobacco makes to cover its tracks, and it seems pretty clear that the only reason it would go to that enormous trouble and expense would be if they knew that if the truth about what they are really up to were to get out there, and if the truth could break through all that very expensive social engineering they’ve been doing for decades, they would all be doing the CNN perpwalk.
The reason this is relevant to a blog on Coca and Cannabis is that if you look closely at the methods Big Tobacco has used to systematically subvert scientists and government agencies worldwide to protect itself and pursue its goals, you can explain a lot of otherwise puzzling and inconsistent things about the American “War on Drugs”. After you read the following excerpt, and maybe the whole WHO report, see if you don’t agree with me that the “War on Drugs” has had the smell of Big Tobacco all over it since the 1970’s.
THE REPORT, Section Seven: “Subverting Science And Health”
Distorting WHO Research
Tobacco companies have a long history of distorting science to oppose restrictions on tobacco. Some of the tactics the tobacco companies have used for decades to manipulate the scientific and public debate include:
1. Secretly Funding Speakers at WHO Conferences
Tobacco companies have attempted to influence the tone and content of WHO- sponsored scientific conferences by paying “independent” scientists to attend and present papers. For example, Japan Tobacco Inc. (JTI) planned to pay 40 scientists to “present ‘neutral’ papers” at the 6th World Health Conference on Smoking or Health held in Japan in 1987.117 JTI calculated that the 40 scientists they would plant at the conference would exert significant influence:
“J.T.I. is trying to change the very nature and tone of the conference through these efforts.”118
INFOTAB, too, planned to encourage the submission of papers favorable to tobacco companies to the 6th WCToH.119
JTI also planned to get a scientific foundation controlled by tobacco companies (SRFS) involved as a member of the Academic Committee for the conference, to permit JTI to participate in the screening of papers for the conference:
“If the SRFS can send members to this committee, ‘neutral’ papers could be submitted to the conference.”120
2. Holding Scientific Symposia to Promote Pro-Industry Positions, with Tobacco Companies’ Role Concealed
As part of its campaign to undermine the IARC ETS study, tobacco companies arranged for several symposia on ETS at which speakers chosen for views consistent with the tobacco companies’ position would present papers. Tobacco company sponsorship of some of these symposia was concealed or minimized. Some of these conferences were primarily sponsored by tobacco company front organizations, such as Healthy Buildings International and CIAR.121 The views expressed at the symposia were disseminated by tobacco companies as “independent” scientific viewpoints.122
3. Misrepresenting Tobacco Company Work as WHO- Supported
In an apparent attempt to enhance the credibility of a tobacco company-sponsored ETS conference, industry officials widely misrepresented the conference as WHO- sponsored, based on the attendance at the conference of a single WHO official.123
4. Using “Independent” Consultants with Concealed Tobacco Company Ties to Lobby WHO Scientists
Echoing its use of front organizations as surrogates, tobacco companies have used outside scientists with concealed tobacco company ties to approach and lobby WHO on scientific questions related to tobacco.
5. Contacting WHO Study Scientists to Influence Study Results
As part of their plan to undermine the IARC ETS study, tobacco companies set out to establish contacts with the study investigators and collaborators.124 With some exceptions,125 the tobacco companies arranged to have contacts made through outside scientists acting as tobacco company consultants.126 The tobacco company affiliation of the consultants who contacted the IARC investigators was frequently concealed.127 These contacts with IARC scientists were to be used to gather “the best information about the status and likely findings of the study,”128 convince study investigators of the weaknesses of the IARC study,129 and, ultimately, achieve “the objective of no report or a report which draws mild conclusions from its data.”130
Through their contacts with IARC investigators and collaborators the tobacco companies were successful in gaining a large amount of information about the design and conduct of the study. More importantly, they were able to gain confidential information about preliminary study results and about how the study was likely to be interpreted. The tobacco companies were not able to influence the outcome of the study, however.
6. Presenting Tobacco Company Arguments Through “Independent” Scientists with Concealed Tobacco Company Ties
Tobacco companies’ scientific consultants have also lobbied WHO on scientific issues without revealing their tobacco company ties. For example, Peter Lee, a tobacco company consultant, wrote to the Director-General of WHO,131 apparently at BAT’s request, providing a lengthy criticism of a WHO study of mortality from tobacco use. In his letter, Lee described himself as “an independent statistician/epidemiologist who has followed the literature on smoking and health very closely for over 20 years.” He did not disclose any tobacco industry affiliations.132
7. Compromising Independence and Credibility of WHO Studies by Involving Investigators in Tobacco Company Research or Activities
Tobacco companies, through their front organization CIAR, attempted to involve IARC and its investigators in collaborative ventures. These ventures included (1) using IARC investigators to conduct studies on ETS confounders that could be used by tobacco companies to challenge the IARC study, (2) offering research grants to IARC investigators, and (3) offering to put an IARC investigator on CIAR’s advisory board.133
According to the study coordinator, IARC itself did not pursue any proposed collaboration once IARC became aware of CIAR’s tobacco company connections.134 One IARC collaborator did, however, conduct a study for CIAR on confounders. The tobacco companies’ purpose in using an IARC collaborator was almost certainly to undermine the IARC study results by attempting to produce evidence, under the name of one of IARC’s own investigators, that would undercut the study.
Tobacco companies conducted and publicly promoted a large number of studies, conferences, and literature reviews on ETS that were designed to challenge the validity of the IARC ETS study. These activities were generally carried out through third parties to create the appearance that the data and opinions were independent of tobacco industry influence.
The data from these studies were used successfully by industry officials when the IARC study results were released to cast doubt on the study. For example, the Sunday Telegraph cited the tobacco company-financed studies as evidence that:
“Passive smokers inhale the equivalent of just six cigarettes a year from other people’s smoke, according to the largest ever study of actual exposure levels of non-smokers. The figure, which undermines previous warnings about the dangers of passive smoking, is a thousand times lower than that faced by direct smokers, and so tiny that it could not be measured statistically.”135
8. Creating an Ostensibly Independent Coalition of Scientists
Tobacco companies sought to create an ostensibly independent coalition of scientists in Europe to help criticize the IARC study and other scientific studies used to support tobacco control policies.136 Like The Advancement of Sound Science Coalition (TASSC) created by Philip Morris and a public relations firm in the US, the European group would appear to be independent but would be initiated and funded by tobacco companies and by other industries.137
The committee of experts was unable to determine the success of this plan. Ong and Glantz have reported, however, that the likely outcome of this initiative was the European Science and Environment Forum (ESEF),138 although ESEF claims to receive little or no tobacco industry funding.139 ESEF has listed on its website at least two working papers criticizing the IARC ETS study, and the methods used in ETS epidemiological studies.140 Lorraine Moody, ESEF’s “key contact,”141 wrote an opinion piece in the Wall Street Journal claiming that the IARC study showed a possibly “trivial or nonexistent” risk of lung cancer from ETS, demonstrating that the health risks of ETS are overstated.142
9. Misrepresenting Scientific Studies to the Media and Regulators
The results of the IARC ETS study, released in 1998, showed that non-smoking spouses of smokers have an estimated 16% increased risk of developing lung cancer and that non-smokers exposed to ETS in the workplace have an estimated 17% increased risk of developing lung cancer.143 IARC’s reported results were consistent with the results of other ETS studies, showing an increased risk of lung cancer for nonsmokers exposed to ETS by a spouse or in the workplace.144 However, there were not enough subjects in the study for the increased risk to reach “statistical significance,” using common statistical methods (i.e., at the 95% confidence level).145
Shortly after the results of the IARC ETS study were released, BAT issued a press release stating: “New scientific research from the World Health Organization has shown the risk of lung cancer from environmental tobacco smoke to be either non-existent or too small to be measured at a meaningful level.”146 Thus, BAT claimed that the lack of statistical significance was equivalent to a finding that there was no relationship between ETS and lung cancer. These claims were picked up first by the Sunday Telegraph and then by other news outlets.
Despite subsequent clarifying statements from IARC and WHO about the study results, the misrepresentation of the study results in the BAT news release was repeated in media accounts around the world. Tobacco companies may also have distorted the IARC study results when addressing regulatory authorities.
10. Staging Media Events or Other Diversions to Discredit or Distract Attention from WHO Tobacco Control Activities
Tobacco companies planned a series of distractions from the 8th World Conference on Tobacco OR Health. These plans, at least some of which were carried out, included a media campaign just before the 8th WCToH, emphasizing the need for childhood immunizations; a major soccer game to distract attention from Jimmy Carter’s arrival; training journalists to disrupt a press conference held by the conference organizers; and embarrassing US Senator Ted Kennedy by planting journalists to ask questions about drinking and sexual harassment allegations.
One unattributed BAT document with the handwritten title “Dietrich/WHO” on the title page also planned an event, called the “Global Children’s Health Conference,” to “distract the media from extensive coverage of the May 31, 1990 International Anti- Smoking Day and the 1990 theme of Smoking and Children.”147 According to the document, through the Institute for IIHD, run by Paul Dietrich (see Chapter VI), BAT would hold a conference for business and government leaders and launch a longer- term strategy to increase private funding for children’s health issue. In describing the program strategy, the BAT document states:
“ The event will be staged to pre-empt monitored WHO meetings and conferences“,150 had confidential WHO contacts,151 and obtained confidential documents and information.152 Examples of clandestine surveillance activities are described in several of the case studies.
“The conference can facilitate the development of a long-term initiative to counteract the WHO’s anti- smoking campaign
“At no time during the event will the issue of smoking be addressed…
“…Design the Conference to address primary health needs of children underscoring the ‘real crisis’. Develop an oblique critique of WHO’s anti- smoking campaign which identifies it as trivial when the global infants’ and children’s crisis is evaluated.
“Introduce alternative solutions which, in the long-term, could successfully undermine the WHO’s overall mandate.”148
It appears that BAT did not carry through with this conference.
11. Conducting Systematic Surveillance of WHO Activities
Tobacco companies have carried out intensive monitoring of WHO and its Regional Offices to gather intelligence about its tobacco control programs.149
Some of the industry’s intelligence-gathering has been conducted openly, through attendance at open meetings and conferences and through open contacts with WHO and other UN officials.
There is also evidence, however, that tobacco companies have secretly monitored conferences,150 had confidential WHO contacts,151 and obtained confidential documents and information.152
Examples of clandestine surveillance activities are described in several of the case studies.
This ends the excerpt. You can read and download the full 250 page UN Report in PDF format here:
If you are inclined to look at references, here they are – just for this section. The entire report contains thousands of similarly damning references that put the moral degradation and greed of this industry on full display. And they really don’t care, because they have convinced themselves that they are untouchable. They would do well to remember – Al Capone was brought down by a simple little tax violation and not by any of his vast criminal conspiracies and crimes.
I think that the industry’s attempt to engineer a shift from smoking to vaporizing is going to reveal the tobacco industry’s equivalent of a simple little tax evasion crime that will be enough, when all the evidence is brought to bear, for the initiation of a crimes against humanity trial in the World Court that will ultimately result in worldwide government and civil seizure of tobacco industry assets.
Notes & References
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Hauser N. Trip Report-RomeIFAO November 26-29, 1984. November 26, 1984. Philip Morris
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The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2501442889–2897. www.pmdocs.com. UQ 5.
Lojacono G. Research Group Informal Meeting On: Health Effects of ETS in Europe-Paris-P. Broussell Hospital (Ville}uif 13I14 March, 1991). March 1991est. Philip Morris Companies Inc. 2501356073–6076. www.pmdocs.com. UQ 33534.
JMH–possibly Hartogh J. Action Plan proposed by ICOSI Task Force 4th World Conference on Smoking & Health. January 29, 1979. Philip Morris Companies Inc. 2501015212–5215. www.pmdocs.com. UQ 33549.
The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2834. www.pmdocs.com. UQ 5.
Tully R. 8th WCTH. January 29, 1992. British American Tobacco Company. 300504241– 4252. Guildford Document Depository. UQ 33334.
The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2889– 2890. www.pmdocs.com. UQ 5.
Informal Meeting of the IARC Research Group on ETS and Human Cancer. Philip Morris Companies Inc. 2501349504–9507. http://www.pmdocs.com. UQ 33636.
47th WHO World Assembly: Informal meeting of some members of the IARC study group “ETS and the Lung Cancer”. Geneva May 3-6, 1994. Philip Morris Companies Inc. May 5, 1994.
Wilhelmus J. WHO. April 18, 1995. Philip Morris Companies Inc. 2063625254. www.pmdocs.com. UQ 33541.
CECCM. IARC Study. April 4, 1995. British American Tobacco Company. 500804531– 4537. Guildford Document Depository. UQ 33774.
Cerioli A. Report on my attendance to the Conference “Conoscenze Scientifiche, Seperi Popolari e Socita Umana alle Soglie del Duemile. Attualite del Pensiero di A. Maccacaro.” January 27, 1997. Philip Morris
Menchaca. January 25, 1990. British American Tobacco Company. 502587287. Guildford Document Depository. UQ 33237.
Lojacono G. Research Group Informal Meeting On: Health Effects of ETS in Europe-Paris-P. Broussell Hospital (Ville}uif 13I14 March, 1991). March 14, 1991est. Philip Morris
Pages R. [Forwarding note from H. Reif: IARC Study]. July 19, 1993. Philip Morris Companies Inc. 2025470098. www.pmdocs.com. UQ 32800.
Dietrich P. [Letter to Sharon Boyse, Enclosing Memo of Visit to Thailand and Philippines]. January 29, 1992. British American Tobacco Company. 300516024–37. Guildford Document Depository. UQ 33682.
WHOIIOCUIUICC: Strategies and Tactics. January 31, 1989. Philip Morris Companies Inc. 2501045143–5147 at 5143. www.pmdocs.com. UQ 32846.
Appendix I, INFOTAB January 1989 Discussion Paper. January 30, 1989. Philip Morris Companies Inc. 2501045258–5268 at 5262. pmdocs.com. UQ 33561.
World Watch: Protecting our Global ‘Next Generation’-A Proposed Conference on Children’s Health Issues. October 1989. 300516227–6285 at 6235. Guildford Document Depository. UQ
WHOIIOCUIUICC: Strategies and Tactics. January 31, 1989. Philip Morris Companies Inc. 2501045143–5147 at 5143. pmdocs.com. UQ 32846.
Hartogh JM. To all members of the ICOSI task force 4th world conference on smoking and health. [Memo by E. Brueckner.] June 26, 1979. British American Tobacco Company. 100433043–3047 at 3046. Guildford Document Depository. UQ
WHOIIOCUIUICC: Strategies and Tactics. January 31, 1989. Philip Morris Companies Inc. 2501045143–5147 at 5146. pmdocs.com. UQ 32846.
Appendix I, INFOTAB January 1989 Discussion Paper. January 30, 1989. Philip Morris Companies Inc. 2501045258–5268. pmdocs.com. UQ 33561.
PMI Corporate Affairs Action Plan 1990. November 2, 1989est. Philip Morris Companies Inc. 2500019979–9999 at 9980–9982. pmdocs.com. UQ 33558.
Sullivan J. IARC Study. September 2, 1993. Philip Morris Companies Inc. 2501117793– 7797 at 7795. pmdocs.com. UQ 33603
Egawa E. April 25, 1986. Philip Morris Companies Inc. 2021654119–4123. pmdocs.com. UQ 66.
Bloxidge JA. International Tobacco Growers’ Association (ITGA). October 11, 1988. British American Tobacco Company. 502555415–5417 at 5417. Guildford Document Depository. UQ 33284.
Boyse S. 8th World Conference on Tobacco and Health. August 28, 1991. British American Tobacco Company. 202019292–9293 at 9292. Guildford Document Depository. UQ
Bible G. Corporate Affairs Conference I Action Plan. December 13, 1986. Philip Morris Companies Inc. 2021596422–6432 at 6429. pmdocs.com. UQ 32834.
Appendix I, INFOTAB January 1989 Discussion Paper. January 30, 1989. Philip Morris Companies Inc. 2501045258–5268. pmdocs.com. UQ 33561.
Interview with Alan Lopez, Coordinator, Epidemiology and Burden of Disease, World Health Organization, May 4,
Oldman M. [Letter to G Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5363. Guildford Document Depository. UQ
Agro-Tobacco Services-Programme Review No1. British American Tobacco Company. 502552606–2611 at 2609. Guildford Document Depository. UQ 33290.
Interview with Alan Lopez, May 4,
Lee PN. Helmut Schievelbein. August 9, 1979. Philip Morris Companies Inc. 2501159889–9891 at 9889. www.pmdocs.com. UQ 33717.
Minutes of the Meeting of the Working Group of the E.E.C. Tobacco Manufacturers’ Associations, Held in Luxemburg on 4th and 5th October 1979. November 11, 1979. Philip Morris Companies Inc. 2501015083–5096 at 5088. pmdocs.com. UQ 33716.
Belcher P. Scientific Committee on Tobacco and Health (SCTH). February 9, 1994. Rothmans International. Philip Morris Companies Inc. 2024188905–8907 at 8905. pmdocs.com. UQ 33715.
Independent Scientific Review of the Toxic Substances Board Report, May 1989, Summary, Commissioned by the Tobacco Institute of New Zealand. 1989est. Philip Morris Companies Inc. 2504203558–3559. pmdocs.com. UQ 33535.
Collett C. Memo to Ted Sterling re: International Symposium on Environmental Tobacco Smoke, November 3-4, 1989.
November 1989est. Philip Morris Companies Inc. 2062856942. www.pmdocs.com. UQ 33536.
Rothman’s International Tobacco ETS Workshop. May 1992est. Philip Morris Companies Inc. 2501237099. pmdocs.com. UQ 33532.
25 . Pen Pictures of Guest Speakers. May 1992est. Philip Morris Companies Inc. 2501237101– 7103 at 7101. www.pmdocs.com. UQ 33531.
S&H. Re: Dr. Furst-Review of Non-Smoker Problem CTR Special Pro}ect. 1976est. Lorillard Tobacco Company. 03747419. TDO Supersite at tobaccodocuments.org. UQ 33714.
From the record before Congress, the Case for Defeat of S. 772. 1983est. Tobacco Institute. TIMN 0353310–3320 at 3312. TDO Supersite at tobaccodocuments.org/. UQ 33729.
Purvis A, Johnson J. Privileged and confidential attorneyIclient connumications. Trial Report, SummaryITestimonyIPro}ection. April 21, 1988. Philip Morris Companies Inc. 2025880540– 0543. Bliley Documents at tobaccodocuments.org. UQ 33730.
Tobacco Institute Newsletter. March 12, 1982. Philip Morris Companies Inc. 515841024. Bliley Documents at tobaccodocuments.org. UQ 98.
Hoel D. Confidential-For counsel only. July 10, 1979. Philip Morris Companies Inc. 6267450002. Bliley Documents at www.tobaccodocuments.org. UQ 99.
Tobacco Institute Newsletter. March 12, 1982. Philip Morris Companies Inc. 515841024. Bliley Documents at tobaccodocuments.org. UQ 98.
Lyberopoulos H. ARISE 1994-95 Activities and Funding. Philip Morris Companies Inc. 2024208096–8099. pmdocs.com. UQ 33779.
Information on Associates for Research in Substance En}oyment Meeting in Venice. R.J. Reynolds Tobacco Company. 508300651–0667 at 0652. http://www.rjrtdocs UQ 33749.
Wilhelmus J. WHO. April 18, 1995. Philip Morris Companies Inc. 2063625254. pmdocs.com. UQ 33541.
Luik J, Snel J, Warburton D. ARISE (Associates for Research into the Science of En}oyment): A Summary of the Workshop Held in April 1995. April 1995est. R.J. Reynolds Tobacco Company. 511818234–8241. rjrtdocs.com. UQ 33731.
The World Health Organization. December 1985est. Philip Morris Companies Inc. 2023267436. pmdocs.com. UQ 46.
36 . Reif H. Continuation of the Vettorazzi Pro}ect. March 25, 1992. Philip Morris Companies Inc. PM 2025594741–4743 at 4742. http://www.pmdocs.com. UQ 33466.
Consultant to ICOSI on International Organisations. August 1980est. Philip Morris Companies Inc. 2025049734. pmdocs.com. UQ 37.
Developing Countries Group (DCG). Progress report covering events since the ICOSI board of directors meeting October 5I8th, 1980. February 1981est. Philip Morris Companies Inc. 2025049364–9374 at 9365. pmdocs.com. UQ 40.
Hauser. [Letter to AG Leeks]. April 20, 1983. Philip Morris Companies Inc. 2023273908– 3909. www.pmdocs.com. UQ 42.
Secretariat Interim Report. December 28,1984. Philip Morris Companies Inc. 2023272512– 2617 at 2514. www.pmdocs.com. UQ 43.
January 11, 1991. British American Tobacco Company. 300557237–7259 at 7241. Guildford Document Depository. UQ 33350.
January 11, 1991. British American Tobacco Company. 300557237–7259 at 7240. Guildford Document Depository. UQ 33350.
January 11, 1991. British American Tobacco Company. 300557237–7259 at 7256. Guildford Document Depository. UQ 33350.
Interviews with Neil Collishaw, Leanne Riley, and Barbara Zolty, all former employees of the WHO’s Tobacco or Health Program, Feb. 4, 2000.
Boca Raton Action Plan: WHOIIOCUIUICC: Strategies and Tactics. Philip Morris Companies Inc. 2501045143–5147 at 5146. pmdocs.com. UQ 32846.
E–mail communication from Neil Collishaw. March 29,
Interviews with Neil Collishaw, Barbara Zolty, and Leanne Riley, February 4,
E–mail communication from Barbara Zolty, March 2,
Sullivan J. IARC Study. September 2, 1993. Philip Morris Companies Inc. 2501117793– 7797 at 7795. pmdocs.com. UQ 33603.
Von Maerestetten C. IARC. July 26, 1993. Philip Morris Companies Inc. 2025493295. pmdocs.com. UQ 33776.
IARC Study. Philip Morris Companies Inc. 2501347168–7173 at 7172. pmdocs.com. UQ 33595.
Pages R. Update 2: IARC study of ETS and lung cancer. August 2, 1993. Philip Morris Companies Inc. 20232999819. http://www.pmdocs.com. UQ 33733.
Memo on vaccines for world health organization. October 25, 1971. Philip Morris Companies Inc. 2012581044. pmdocs.com. UQ 4.
Boca Raton Action Plan: WHOIIOCUIUICC: Strategies and Tactics. Philip Morris Companies Inc. 2501045143–5147 at 5146. pmdocs.com. UQ 32846.
Flavor and Extract Manufacturers Association. Invoice. August 17, 1995. Philip Morris Companies Inc. 2050761274. pmdocs.com. UQ 33546.
Schrankel K. Final Report to Contributors of Anethole Research Fund. August 25, 1998. Philip Morris Companies Inc. 2063597040. pmdocs.com. UQ 33548.
Minutes of Anethole Task Force. May 2, 1996. Philip Morris Companies Inc. 2063616600. pmdocs.com. UQ 33547.
Minutes of Anethole Task Force. May 2, 1996. Philip Morris Companies Inc. 2063616600. pmdocs.com. UQ 33547.
Schrankel. Final Report to Contributors of Anethole Research Fund. August 25, 1998. Philip Morris Companies Inc. 2063597040. www.pmdocs.com. UQ 33548 TIMN270055–0059 at 0058. http://www.tobaccoinstitute.com. UQ 32904.
Hartogh JM. To all members of the ICOSI task force 4th world conference on smoking and health. [Memo by E. Brueckner.] June 26, 1979. British American Tobacco Company. 100433043–3047. Guildford Document Depository. UQ 33162.
Oldman M. [Letter to G Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5358. Guildford Document Depository. UQ 33278.
Action Plan proposed by ICOSI Task Force on 4th World Conference On Smoking & Health Stockholm, June 18-22,1979. January 30, 1979. Council for Tobacco Research. 10395689–5695.
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Observations on the Fifth World Conference on Smoking and Health by a Consultant, Winnipeg, July 1983. July 1983est. Philip Morris Companies Inc. 2501021685–1709 at 1685. www.pmdocs.com. UQ 32890.
Corti A. Director of Information Services, INFOTAB. Latin American Meetings-
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GenevaIRome, March 9-15, 1987. January 15,
Developing Countries Ad Hoc Group (DCG). Progress Report Covering Events Since the ICOSI Board of Directors Meeting on 19th February, 1980. August 1980est. Philip Morris 1987. British American Tobacco Company. 301760973–0979 at 0979. Guildford Document Depository. UQ 33254
Appendix I, INFOTAB January 1989, Discussion Paper. January 30, 1989. Philip Morris Companies Inc. 2501045258–5268 at 5262. Minnesota Document Depository. UQ 33561.
Pro}ect Report Covering Pro}ects and Action Plans Since the Board of Directors Meeting on March 30, 1981. 1981est. Philip Morris Companies Inc. 2025048077–8088 at 8077. pmdocs.com. UQ 41.
Pro}ect Report Covering Pro}ects and Action Plans Since the Board of Directors Meeting on March 30, 1981. Philip Morris Companies Inc. 2025048077–8088 at 8082. www.pmdocs.com. UQ 41.
Verkerk H. Fifth World Conference on Smoking and Health-Winnepeg. Philip Morris Companies Inc. 2501021564–1586 at 1577. pmdocs.com. UQ 32888.
Secretariat Interim Report. December 28, 1984. Philip Morris Companies Inc. 2023272512– 2617 at 2594. pmdocs.com. UQ 43.
INFOTAB Board of Director’s (BOD) Meeting-March 30, 1981. April 6, 1981. 502741855. Bliley Documents at www.tobaccodocuments.org. UQ 60.
Witt S. International Committee on Smoking Issues Lausanne-November 10-12, 1977.
Schlosser A, Mine K (Chadbourne, Parke). Representative Compilation of Literature Describing the Benefits of Tobacco. April 29, 1986. Brown & Williamson Company.
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Oldman M. [Letter to D. Bacon, enclosing “Agro-Tobacco Services (ATS), Proposal for a Consultancy Agreement”]. January 7, 1992. British American Tobacco Company. 502552644–2654 at 2650. Guildford Document Depository. UQ
Oldman M. [Letter to D. Bacon, enclosing “Agro-Tobacco Services (ATS), Proposal for a Consultancy Agreement”]. January 7, 1992. British American Tobacco Company. 502552644–2654 at 2647. Guildford Document Depository. UQ
Oldman M. [Letter to G. Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5361. Guildford Document Depository. UQ
Oldman M. [Letter to G. Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5358. Guildford Document Depository. UQ
Oldman M. [Letter to G. Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5361. Guildford Document Depository. UQ
Oldman M. [Letter to D Bacon enclosing Agro- tobacco Activity Report for January 1993]. February 10, 1993. British American Tobacco Company. 502552508–2513 at 2512–2513. Guildford Document Depository. UQ
Oldman M. Paper for ITGA General Meeting, 1994. British American Tobacco
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Opukah S. ECOSOCIFAO Positions on Tobacco. August 18, 1994. British American
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Brady B. March 3, 1992. British American
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Hartley R. [Note to Mr. B.D. Bramley].June 28, 1993. British American Tobacco Company.
Oldman M. Paper for ITGA General Meeting, 1994. 1994est. British American Tobacco
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Bacon D. Development Aid, Progress. November 28, 1991. British American Tobacco Company. 202049931–9932 at 9931. Guildford Document Depository. UQ
Bacon D. Development Aid, Progress. November 28, 1991. British American Tobacco Company. 202049931–9932 at 9932. Guildford Document Depository. UQ
Interview with Neil Collishaw, Feb. 4,
Bible G. Corporate Affairs Conference I Action Plan. December 13, 1988. Philip Morris Companies Inc. 2021596422–6432 at 6429. pmdocs.com. UQ 32834.
Boca Raton Action Plan: Status Report for the Period Ending January 31, 1989. January 31, 1989. Philip Morris Companies Inc.2500103969–4056 at 3989. www.pmdocs.com.
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Boyse S. [Letter to Peter Hazel, David Bacon, and JJ Mostyn]. August 8, 1991. British American Tobacco Company. 304004032. Guildford Document Depository. UQ 33184
Dietrich P. WHO spends money on what? The Wall Street Journal, May 9, 1989. UQ
Oldman M. [Letter to D. Bacon enclosing Activity Report, September/October 1993]. November 1, 1993. British American Tobacco Company. 502555329–5331 at 5331. UQ 33276.
Boca Raton Action Plan: Status Report for the Period Ending May 31, 1989. May 31, 1989. Philip Morris Companies Inc. 2021592752– 2764 at 2752. www.pmdocs.com. UQ 32859.
Boca Raton Action Plan: Status Report Ending July 31, 1989. July 31, 1989. Philip Morris Companies Inc. 2023547120–7135 at 7121. pmdocs.com. UQ 32860.
Boca Raton Action Plan Summary Report December 3, 1988-October 30, 1989. October 30, 1989. Philip Morris Companies Inc. 2503005015–5050. pmdocs.com. UQ 32862.
Oldman M. [Letter to D. Bacon enclosing Activity Report, September/October 1993]. November 1, 1993. British American Tobacco Company. 502555329–5331 at 5331. UQ 33276
Ntaba H. Letter to the Editor, International Health and Development, Vol. 1, No. 2, Summer, p. 31. UQ
Boca Raton Action Plan: Status Report for the Period Ending September 30, 1989. September 30, 1989. Philip Morris Companies Inc. 2501204997–5021 at 4998. pmdocs.com. UQ 32861.
Boyse S. [Letter to Paul Dietrich]. August 7, 1991. British American Tobacco Company. 300516113. Guildford Document Depository. UQ
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Bacon D. Who Benefits from WHO? November 24, 1993. British American Tobacco Company.
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Agenda: “Primer Encuentro de Periodistas Y la Industria Del Tabaco.” June 1991est. British American Tobacco Company. 300565679– 5681. Guildford Document Depository. UQ 33675.
BAT Smoking Issues Briefing, Taiwan. September 6–8, 1992. British American
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Oldman M. [Letter to G. Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5359. Guildford Document Depository. UQ
Bloxidge JA. International Tobacco Growers’ Association (ITGA). October 11, 1988. British American Tobacco Company. 502555415– 5417. Guildford Document Depository. UQ 33284.
Oldman M. [Letter to G. Pedlow]. March 13, 1991. British American Tobacco Company. 502555357–5363 at 5360. Guildford Document Depository. UQ
Oldman M. Agro-Tobacco Services (ATS), Proposed Plan. November 1991. British American Tobacco Company. 502552655–2667 at 2659. Guildford Document Depository. UQ 33303.
INFOTAB International Workshop, Brussels, October 13-16, 1986. October 16, 1986. Philip Morris Companies Inc. 2501446636–7080 at 6723–6724. pmdocs.com UQ 33566.
Boca Raton Action Plan: Appendix A, WHOIIOCUIUICC: Strategies and Tactics. January 31, 1989. Philip Morris Companies Inc. 2501045143–5147.pmdocs.com UQ 32846.
Wells JK. INFOTAB Advisory Council Meeting July 14 and 15, 1982. July 21, 1982. Brown &Williamson Company. 680002301–2307.
Bible G. Corporate Affairs Conference I Action Plan. December 13, 1988. Philip Morris Companies Inc. 2021596422–6432 at 6429. pmdocs.com. UQ 32834.
Egawa E. April 25, 1986. Philip Morris Companies Inc. 2021654119–4123 at 4121. pmdocs.com. UQ 66.
Egawa E. April 25, 1986. Philip Morris Companies Inc. 2021654119–4123 at 4121. pmdocs.com. UQ 66.
INFOTAB International Workshop, Brussels, October 13-16, 1986. October 16, 1986. Philip Morris Companies Inc. 2501446636–7080 at 6677. pmdocs.com UQ 33566.
Egawa E. April 25, 1986. Philip Morris Companies Inc. 2021654119–4123 at 4120. pmdocs.com. UQ 66.
Whitley C. Statement of Charles O. Whitley on behalf of the Tobacco Institute before the Subcommittee on Health and the Environment, Committee on Energy and Commerce, US House of Representatives [Draft]. July 9, 1990. Tobacco Institute TIMN 0032095–2141 at 2118. Bliley Documents. tobaccodocuments.org. UQ 32912.
Zhang M. [Attaching Press article in the China Daily on the CIAR’s GEP workshop in Guangzhou.] September 9, 1997. Philip Morris Companies Inc. 2063608546–8547. http://www.pmdocs.com. UQ 33752.
Whitley C. Statement of Charles O. Whitley on behalf of the Tobacco Institute before the Subcommittee on Health and the Environment, Committee on Energy and Commerce, US House of Representatives [Draft]. July 9, 1990. Tobacco Institute TIMN 0032095–0032141 at 2118. Bliley Documents. tobaccodocuments.org. UQ 32912.
Press release by the organizers of the expert discussion of the “Physician’s View of Passive Smoking”: Health Danger through Passive Smoking Not Proven. April 1984. Philip Morris Companies. 1002965608–6509. pmdocs.com. UQ 33770.
Masironi R. [Letter to W. Kloepfer]. December 2, 1986. Philip Morris Companies Inc. 2025816621–6624. www.pmdocs.com. UQ 33771.
Greenberg D. September 15, 1993. Philip Morris Companies Inc. 2021184116–4121 at 4119. www.pmdocs.com. UQ 33590.
Walk, R.A. IARC Multi-Center Case Control Study of ETS and Lung Cancer, Your memo dated 21 May 93. July 13, 1993. Philip Morris Companies Inc. 2025493287. pmdocs.com. UQ 33616.
IARC Study. 1994est. Philip Morris Companies Inc. 2501347168–7173 at 7169. pmdocs.com. UQ 33595.
Pages R. IARC Study of ETS and Lung Cancer. May 21, 1993. Philip Morris Companies Inc. 2500015757. www.pmdocs.com. UQ 33617.
Walk, R.A. IARC Multi-Center Case Control Study of ETS and Lung Cancer: Update of information. July 30, 1993. Philip Morris Companies Inc. 2029041838–1839. http://www.pmdocs.com. UQ 33618.
Interview with Paolo Boffetta, April 17, 2000.
Greenberg D. September 15, 1993. Philip Morris Companies Inc. 2021184116–4121 at 4119. www.pmdocs.com. UQ 33590.
IARC Study. Philip Morris Companies Inc. 2501347168–7173 at 7169. www.pmdocs.com. UQ 33595.
Greenberg D. September 15, 1993. Philip Morris Companies Inc. 2021184116–4121 at 4118. www.pmdocs.com. UQ 33590.
Boyse S. [Letter to Ron Tully.] April 18, 1990. British American Tobacco Company. 400099555. Guildford Document Depository. UQ
Boyse S. [Letter to PN Lee.] December 19, 1989. British American Tobacco Company. 400099679. Guildford Document Depository. UQ 33509.
Lee P. May 8, 1990. British American Tobacco Company. 502587275–7284 at 7275. Guildford Document Depository. UQ
Winokur M. [FAX to H. Reif attaching “CIAR and IARC, Next Steps and Options.”] December 19, 1994. Philip Morris Companies Inc. 2028381587–1588 at 1588. pmdocs.com. UQ 33746.
Interview with Paulo Boffetta, April 17,
Matthews R, MacDonald V. Passive smokers inhale six cigarettes a year. Sunday Telegraph. August 16,
Lyberopoulos, H. Presentation on IARC [enclosing overheads]. April 19, 1994. Philip Morris Companies Inc. 2501355931–5944 at 5942. pmdocs.com. UQ 33604.
Hockaday T, Cohen N. Thoughts on TASSC Europe. March 25, 1994. Philip Morris
Lindheim J. Presentation on Scientist Pro}ect. May 5, 1994. Philip Morris Companies Inc. 2025493201–3207 at 3205–3206. pmdocs.com. UQ 33708.
Ong E, Glantz S. Tobacco industry efforts subverting International Agency for Research on Cancer’s second–hand smoke study. The Lancet. 2000; 355: 1253–59.
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Hirayama T. Non–smoking wives of heavy smokers have a higher risk of lung cancer: A study from Japan. BMJ 1981; 282:183–85.
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US Environmental Protection Agency. Health effects of passive smoking: Assessment of lung cancer in adults and respiratory disorders in children. Office of Research and Development, Office of Health and Environmental Assessment. EPA/600/6–90/006F, 1992b.
Boffetta P, Agudo A, Ahrens W, et al. Multicenter case–control study of exposure to environmental tobacco smoke and lung cancer in Europe. J Natl Cancer Inst 1998; 90: 1440–50.
British American Tobacco. [ News release]. March 5, 1998. Philip Morris Companies Inc. 2063594010–4240 at 4018. pmdocs.com. UQ 33750.
World Watch: Protecting our Global ‘Next Generation’-A Proposed Conference on Children’s Health Issues. October 1989. 300516227–6285 at 6235. Guildford Document Depository. UQ
World Watch: Protecting our Global ‘Next Generation’-A Proposed Conference on Children’s Health Issues. October 1989. British American Tobacco Company. 300516227–6285 at 6236. Guildford Document Depository. UQ 33691.
INFOTAB . Item 2 Report From The Secretary General . January 1, 1982est. Philip Morris Companies Inc. 2021594826–4836. pmdocs.com. UQ 32.
Background to the Structure and Operations of the Activist Movement. November 15, 1994.
Philip Morris Companies Inc. 2501110753– 0775. www.pmdocs.com. UQ 68.
Seymour M. 6 September 1996 IARC European Response Plan Workshop. August 8, 1996.
Philip Morris Companies Inc. 2063604476– 4498. www.pmdocs.com. UQ 71.
Hauser N. Trip Report-RomeIFAO November 26-29, 1984. November 26, 1984. Philip Morris
Hartogh J. Report by Task Force 5th World Conference on Smoking and Health, Winnipeg, Canada, July 1983. February 26, 1981. Philip Morris Companies Inc. 2025049376–9377. www.pmdocs.com. UQ 33514.
The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2501442889–2897. pmdocs.com. UQ 5.
Lojacono G. Research Group Informal Meeting On: Health Effects of ETS in Europe-Paris-P. Broussell Hospital (Ville}uif 13I14 March, 1991). March 1991est. Philip Morris Companies Inc. 2501356073–6076. www.pmdocs.com. UQ 33534.
JMH–possibly Hartogh J. Action Plan proposed by ICOSI Task Force 4th World Conference on Smoking & Health. January 29, 1979. Philip Morris Companies Inc. 2501015212–5215. www.pmdocs.com. UQ 33549.
The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2834. pmdocs.com. UQ 5.
Tully R. 8th WCTH. January 29, 1992. British American Tobacco Company. 300504241– 4252. Guildford Document Depository. UQ 33334.
The World Health Organization (WHO): Its Work Related to the Activities of the International Tobacco Industry. Philip Morris Companies Inc. 2501442830–2897 at 2889– 2890. pmdocs.com. UQ 5.
Informal Meeting of the IARC Research Group on ETS and Human Cancer. Philip Morris Companies Inc. 2501349504–9507.
47th WHO World Assembly: Informal meeting of some members of the IARC study group “ETS and the Lung Cancer”. Geneva May 3-6, 1994. Philip Morris Companies Inc. May 5, 1994.
Wilhelmus J. WHO. April 18, 1995. Philip Morris Companies Inc. 2063625254. www.pmdocs.com. UQ 33541.
CECCM. IARC Study. April 4, 1995. British American Tobacco Company. 500804531– 4537. Guildford Document Depository. UQ 33774.
Cerioli A. Report on my attendance to the Conference “Conoscenze Scientifiche, Seperi Popolari e Socita Umana alle Soglie del Duemile. Attualite del Pensiero di A. Maccacaro.” January 27, 1997. Philip Morris
Menchaca. January 25, 1990. British American Tobacco Company. 502587287. Guildford Document Depository. UQ 33237.
Lojacono G. Research Group Informal Meeting On: Health Effects of ETS in Europe-Paris-P. Broussell Hospital (Ville}uif 13I14 March, 1991). March 14, 1991est. Philip Morris
Pages R. [Forwarding note from H. Reif: IARC Study]. July 19, 1993. Philip Morris Companies Inc. 2025470098. www.pmdocs.com. UQ 32800.
Dietrich P. [Letter to Sharon Boyse, Enclosing Memo of Visit to Thailand and Philippines]. January 29, 1992. British American Tobacco Company. 300516024–37. Guildford Document Depository. UQ 33682.
Banned Pesticides In Tobacco Products – Background
The tobacco industry is extremely careful not to allow (more on that later) studies of pesticide residues on its cigarette products in any country but particularly in the US. The industry is exquisitely aware that if the extent of this chemical contamination were known, particularly the presence of multiple banned organochlorine pesticides in their products, then especially at the state and county levels public health officials and regulators would have no choice but to call an end to industry’s game.
And then there would also be a brand new basis for some hefty civil lawsuits as well as domestic and international criminal charges for everything from negligence to genocide.
About time too, don’t you think?
So here’s an outline of the issue and why I think it represents a new broad area for regulatory control of the harm being done by Tobacco products. I would love to hear from organizations with a Tobacco product control agenda who would like help in crafting a local strategy of pesticide residue identification – we have fully certified high-level labs here in Oregon with experience in Tobacco testing that are ready to help.
European regulators in several countries, notably Germany, and acting through the EU Commission as a whole, are already way ahead of the US in identifying and regulating the public health threat caused by pesticide residues in Tobacco products. But, because of the tight control that the Tobacco industry has over the US media, Americans who are casually consuming “the news” will NEVER hear about these controls on pesticide contamination. And because of the control that the Tobacco industry has over the US scientific and medical communities, you will NEVER find that anyone in the entire anti-tobacco movement has ever spent a few hundred bucks and tested some off-the-shelf Tobacco products for pesticide residues. Go ahead – Google away. It’s just not there.
Does that strike anyone other than me as a bit odd?
That tight grip on public knowledge, by the way, comes from clandestine financial controls, domination of advertising, hidden ownership of important media, and co-opted journalists at every level of every important media player. To the Tobacco industry, this is all a game-planned process.
That may sound like a cold-blooded way to refer to the slaughter of untold millions of people across generations of smokers and their families, but you can be certain that as far as the tobacco industry is concerned it’s a game, and when it comes to money they are definitely cold-blooded, and they’re playing for keeps.
The Smoking Gun
As you read this please keep in mind that all it took to bring down Al Capone was one small tax evasion charge that the feds could make stick.
So. There has only been one small study of pesticides in actual commercial cigarettes since the 1970’s, but if that study is at all representative of the state of the 2018 commercial cigarette market (parenthetical comment – it is, as you’ll see documented later) then regulators worldwide ought to be pulling cigarettes from shelves and running them through pesticide testing. Don’t you think?
I can hear the Tobacco science flacks now. “Well, that data is from 2003. That was 15 years ago. And besides those pesticides aren’t permitted on tobacco anymore.”
Oh, really?
So, you would think that if nasty old Endosulfan, Heptachlor and 4,4-DDE, and a whole lot more organochlorine and organophosphate pesticides weren’t being used on tobacco anymore then the tobacco industry scientific organization CORESTA wouldn’t be publishing “good practice” guidelines updated June 2018 that lists acceptable limits on them – right?
Well, just because the tobacco industry chooses to publish good practice limits on those banned pesticides, that doesn’t mean they are still being used – right? When you read the document it is absolutely clear – these pesticide residues are being detected in Tobacco and Tobacco products worldwide and the industry is worried enough to publish “good practice” and “stewardship” guidelines, including guidelines for dozens of pesticides that are banned because chronic exposure in any amount is hazardous – like through a few hundred puffs of Tobacco product smoke or vapor a day.
Also if you open that CORESTA link above, please notice their innocent little qualifying remark:
“The GRLs are applicable to cured tobacco leaf while focusing on processed tobacco leaf which is predominantly used for the production of traditional cigarette tobaccos and the GAPs associated with the cultivation of these tobacco types.”
In other words we are just going to ignore the issue of pesticide residues on Tobacco stems and trash, which we know are present in higher concentrations than on the leaf, because we don’t want to raise that particular issue.
How We Know Brazilian Tobacco Is Widely Contaminated
With that hidden public health issue in mind, let’s look at pesticide use on tobacco in Brazil – as good a place to start as any. We could look at dozens of other countries, but Brazil is the biggest exporter of tobacco to the US.
First, note that Brazilian tobacco uses twice as much pesticide per hectare as the next biggest user, cotton, and three times as much as soybeans. That is significant – it means that Brazilian Tobacco plants are drenched with these chemicals.
That’s how we know beyond reasonable doubt that Brazilian Tobacco waste exports to the US are contaminated, and probably very heavily contaminated. That doesn’t worry the US Tobacco companies because nobody is watching what they do except for their own people, a few corrupt officials, and some piss-ant regulations that aren’t enforced and don’t matter.
Well, OK. So tobacco uses a lot of pesticides. That doesn’t necessarily mean they are using banned pesticides, or pesticides known to be dangerous if inhaled even in small doses on a chronic basis.
That link is a pretty detailed research piece that looks at the health impact of pesticides on tobacco farmers in Brazil, and in the process it talks in detail about the pesticides they are exposed to. Of course, these are the same pesticides whose residues wind up on Brazilian tobacco. Check it out.
So, it’s clear that a great many pesticides being used on tobacco in Brazil. This isn’t the only piece of evidence, by far. When you look at all the evidence, it is clear that banned organochlorine and organophosphate pesticides are being used intensively on Brazilian tobacco as recently as early 2018.
The reason that’s important is that all of the trash from the Brazilian tobacco industry – not the tobacco leaf, but the stems and waste from the factory floors – winds up being shipped to the US for manufacturing into American cigarettes. That tobacco trash and stems is if anything more heavily contaminated with pesticides than the tobacco leaf (because it includes systemic pesticides), which is kept in Brazil and Argentina for making cigarettes out of real leaf tobacco – the kind demanded by smokers in Latin America.
The contaminated tobacco trash is sent to the US, and look who’s bringing it in. (We’ll get to why in a minute.)
That’s a whole lot of tobacco trash, isn’t it? Well, those are only the records of two shipments of toxic waste brought to the US by Big Tobacco. There are plenty more. Now, let’s talk about why they are bringing in all those tobacco stems from Brazil and other waste dumps on the planet.
How Brazilian Nerve Poisons Get Into Those Marlboros, Camels etc.
It’s really pretty simple. The tobacco industry figured out years ago that American smokers didn’t really care what they were smoking, and since the tobacco companies could sell the actual leaf to Europeans and Latin Americans who cared, why not use all those stalks and stems and trash that they were just throwing away and figure out how to make cigarettes out of it?
Here’s a short video by Philip Morris showing in detail how they take tobacco waste and turn it into cigarettes. They treat this process as though it is a miraculous achievement. While you watch how this cigarette giant makes fake tobacco for American smokers, remember those pesticide residues on those millions of pounds of Brazilian tobacco waste they’re grinding up and bragging about.
There is major deception at @ 2:11-20. Can you can spot it now that you know about the pesticide residues in that trash they’re turning into cigarettes?
At this point you may be asking what contaminated Brazilian tobacco trash has to do with where we started – banned pesticides in commercial cigarettes in Europe, including two prominent American brands.
The relevance is that the banned pesticides in those 2003 EU cigarettes got into them exactly the same way that banned pesticides are getting into every US cigarette manufactured with Brazilian tobacco stems and trash in 2018.
The tobacco stems and trash that are being exported from Brazil ( and other countries, but Brazil is the biggest US supplier) to Europe and to America are used for the same thing – to make fake tobacco cigarettes chock full of invisible poisons on that waste Tobacco just like in the Philip Morris video above. Philip Morris, RJR and the others know for a fact that their manufacturing materials are contaminated with banned toxic substances, and they may even quietly test for some of these poisons, but they have never issued a recall for a single batch of Tobacco products which they would have a positive duty to do if banned pesticide residues were detected.
So What Can Be Done?
Quite a bit, actually. In a coming post I’ll link you to peer-reviewed journal research that demonstrates the level of public health threat presented by these hidden toxic substances, and I’ll share with you the results of a little public health effort here in Portland to test off-the-shelf Tobacco products being sold locally whose origins can be traced to imported Brazilian Tobacco waste. Stay tuned for what I expect to be some interesting results.
Meanwhile if you like what I’m trying to do here, please hit that little donate button below and drop a thank you on me. I would appreciate knowing that you care about the work I’m doing.
If you want a new way to control the damage that Tobacco products do to your community, then this may interest you.
This post offers credible tobacco industry data showing all of the pesticides that contaminate Tobacco products worldwide. It is published by CORESTA, the tobacco industry’s captive science & research institute. This information alone can empower local initiatives by offering credible evidence that banned toxic substances may be contaminating locally-sold Tobacco products.
If your local health department has regulations that allow it to investigate whether a product being sold in your community is contaminated with banned pesticide residues, then this list will give them probable cause to sample locally-sold Tobacco products and test for the presence of banned pesticide chemicals.
It is important for you to keep in mind, when making such a request, that (1) it doesn’t matter that the products are Tobacco – they are just like pesticide contaminated candles, air fresheners or incense – and (2) these contaminants are present because of negligence by the manufacturer and lack of regulatory oversight by any superior authority, so the local authorities have to act in the interest of public health and safety.
So this is it – the official (but highly confidential) June, 2018 tobacco industry guide to the pesticide chemicals used on tobacco worldwide. It’s an industry list cautioning manufacturers to ‘watch out’ for these chemicals that remain on Tobacco from the fields, which means that it’s a list of what the industry knows is potentially present in any Tobacco product anywhere.
Many of these pesticides are damaging to human health at very low levels of chronic exposure – just like a smoker gets 100-200 times a day, 365 days a year puffing away and inhaling the pesticide residues invisibly contaminating the tobacco in their cigarette. (Except that it isn’t really tobacco, but that’s another post.)
But the really severe public health threat created by pesticides on Tobacco lies in the industry’s attempt to pivot toward vaporizing. Imagine that instead of being at least partially destroyed by combustion and smoking, all those pesticides are now being gently vaporized and delivered full-strength to your lungs as IQOS Tobacco vapor.
While the tobacco industry publishes pesticide standards for its members, it makes clear that nobody actually has to follow this industry guidance. The tobacco companies are safe from accountability because there is no testing of commercial cigarettes in the United States for the presence of any of these chemicals, and what little testing the FDA, EPA and USDA do perform almost seems deliberately designed to shield the tobacco industry from investigation. It’s not as if the FDA doesn’t have the authority to demand that Tobacco companies at least keep the contamination down a little.
907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act:
(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.
Please keep that language in mind as you browse the list below. Chronic low-dose exposure to any one of the pesticides on this list, just by itself, is enough to cause serious damage to human adults, children and babies. The US government, along with the health authorities of every state, seem collectively uninterested in knowing what dozens of these violent chemicals, all being either burned or heated, smoked or vaporized and then inhaled actively or passively are doing to smokers or vapers, their families and everybody else downwind every day of their lives.
One last thing – notice that there are a lot of banned pesticides on the list. That’s because the Tobacco industry recognizes that large stores of these chemicals still exist and farmers still use them for one simple reason – they kill bugs. It might also be that these chemicals are still being made in black factories in India and China.
Whether using banned pesticides or not, most small farmers in the Third World can’t even read the labels, if there are any, so all they care about is killing bugs and fungus. Every pound of tobacco that bugs eat and fungus destroys is one less pound the farmer has to sell to feed his family, which doesn’t mean that the kids just go without a snack for a day or two.
So of course hundreds of thousands of small tobacco farmers worldwide are going to use triple-witching stuff like Endrin, Heptachlor, Aldrin, and Dieldrin whenever they can get it or whenever they are told to use it. Because while manufacturing of these incredibly toxic chemicals is banned almost everywhere, ‘black’ factories in China and India are churning out the oldies but goodies by the ton and selling them in countries where 50% of all pesticides are used on just one crop – tobacco.
But of course regulatory authorities in the ‘advanced’ countries like the US don’t test for these banned pesticides in anything anymore, much less in tobacco products like cigarettes, because “nobody uses them anymore and all the old stores have been used up or destroyed long ago”.
This is not a list of recommended CPAs (Crop Protection Agents) for tobacco. That is a matter for official and/or industry bodies in each country.
GRLs have not yet been set for all CPAs registered for tobacco. Setting GRLs is an ongoing process based on a list of priorities decided by frequency of use and importance to leaf production.
The presence of a compound does not imply endorsement by CORESTA
The entries in the list do not replace MRLs (Maximum Residue Levels) set by the authorities. Compliance with MRLs is a legal requirement for countries that have set them for
No.
CPA
GRL
(ppm)
Residue definition
Notes
1
2,4,5-T
0.05
2,4,5-T
2
2,4-D
0.2
2,4-D
3
Acephate
0.1
Acephate
4
Acetamiprid
3
Acetamiprid
5
Acibenzolar-S-methyl
5
Acibenzolar-S-methyl
6
Alachlor
0.1
Alachlor
7
Aldicarb (S)
0.5
sum of Aldicarb, Aldicarb sulfoxide and Aldicarb sulfone, expressed as Aldicarb
In countries where fungal diseases such as blue mould are a persistent problem in the field throughout the growing season, the use of dithio- carbamates (DTC) fungicides may be an essential part of the season-long disease management strategy and in keeping with GAP as a means of ensuring crop quality and economic viability for the producer. Under high disease pressure residues of dithio- carbamates (DTC) fungicides slightly in excess of the specified GRL may be observed. In countries where there is not a field fungal disease problem the use of fungicides is not necessary, and there should be no residues detected. Consistent with GAP, dithiocarbamates (DTC) fungicides must be used only according to label instructions to combat fungal diseases in the seedbed and in the field.
No.
CPA
GRL
(ppm)
Residue definition
Notes
47
Endosulfans (S)
1
sum of alpha- and beta-isomers and Endosulfan-sulphate expressed as Endosulfan
48
Endrin
0.05
Endrin
49
Ethoprophos
0.1
Ethoprophos
50
Famoxadone
5
Famoxadone
51
Fenamiphos (S)
0.5
sum of Fenamiphos, Fenamiphos sulfoxide and Fenamiphos sulfone expressed as Fenamiphos
52
Fenitrothion
0.1
Fenitrothion
53
Fenthion (S)
0.1
sum of Fenthion, Fenthion sulfoxide and Fenthion sulfone expressed as Fenthion
54
Fenvalerate (S)
1
Fenvalerate (sum of all isomers including Esfenvalerate)
sum of Heptachlor and two Heptachlor epoxides (cis- and trans-) expressed as Heptachlor
62
Hexachlorobenzene
0.02
Hexachlorobenzene
63
Imidacloprid
5
Imidacloprid
64
Indoxacarb (S)
15
Sum of S isomer + R isomer
65
Iprodione (S)
0.5
sum of Iprodione and N-3,5- dichlorophenyl-3-isopropyl-2,4- dioxoimidazolyzin-1-carboxamide expressed as Iprodione
66
Malathion
0.5
Malathion
67
Maleic hydrazide
80
Maleic hydrazide (free and bounded form)
In some instances, where GAP is implemented and label recom- mendations with regard to application rates and timing are strictly adhered to, residue levels may exceed the current GRL of 80 ppm as a result of extreme weather conditions and the current technology available for application. However, as with all CPAs, all efforts should be made to strictly follow label application rates, and use should be no more than necessary to achieve the desired effect.
68
Metalaxyl (S)
2
sum of all isomers including Metalaxyl-M / Mefenoxam
69
Methamidophos
1
Methamidophos
70
Methidathion
0.1
Methidathion
71
Methiocarb (S)
0.2
sum of Methiocarb, Methiocarb sulfoxide, and Methiocarb sulfone expressed as Methiocarb
sum of Dichlorvos, Naled, and Trichlorfon expressed as Dichlorvos
see Dichlorvos
107
Trifluralin
0.1
Trifluralin
Carbendazim is the degradation product of Benomyl and Thiophanate-methyl. In the case the same sample contains residues of both Carbendazim and/or Benomyl/Thiophanate-methyl, the sum of the residues should not exceed 2
Deltamethrin is the degradation product of Tralomethrin. In the case the same sample contains residues of both Deltamethrin and Tralomethrin, the sum of the two residues should not exceed 1
Dichlorvos is the degradation product of Naled and In the case the same sample contains residues of both Dichlorvos and/or Naled/Trichlorfon, the sum of the residues should not exceed 0.1 ppm.
Omethoate is the degradation product of Dimethoate. In the case the same sample contains residues of both Dimethoate and Omethoate, the sum of the two residues should not exceed 0.5
The Dithiocarbamates Group includes the EBDCs: Mancozeb, Maneb, Metiram, Nabam and Zineb – as well as Amobam, Ferbam, Policarbamate, Propineb, Thiram and
Methomyl is the degradation product of Thiodicarb. In the case the same sample contains residues of both Methomyl and Thiodicarb, the sum of the two residues should not exceed 1
Fluopyram added to GRL list June
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This is a comment that I’ve just submitted to the FDA asking them to enforce their own regulations and conduct appropriate testing, which has not been done to date, to determine whether all current IQOS applications are in compliance with regard to pesticide residues as required by this rule, and then to determine the impact of any discovered pesticide residues on the manufacturer’s many and deceptive “Modified Risk” claims. 
