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Thoughts On Coca, Cannabis, Opium & Tobacco – Gifts Of The Great Spirit


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Little Cigars And High Liver Cancer Rates In Marginalized Communities

As I continue to mine the data from our December 2018 tests of off-the-shelf tobacco products for pesticide residues I keep running across small surprises that have big implications. Here’s a good example – the data has just shown me a likely connection between little cigar use and the puzzling high rates of liver cancer in Hispanic, Black and Native American communities.

The connection may lie in two of the pesticide contaminants just found in Swisher Sweets – check the carbendazim and cypermethrin in the right-hand data column below. Exposure to either of these chemicals is strongly linked to liver disease; exposure to the two chemicals together appears to have much greater impact than just the simple sum of their effects. They are more than merely additive and they are synergistic. (many additional citations below)

Basic Clin Pharmacol Toxicol. 2012 May;110(5):433-40

“Carbendazim impends hepatic necrosis when combined with imazalil or cypermethrin.”

“Low doses of carbendazim in combination with low doses of imazalil or cypermethrin caused very pronounced hepatic necrosis, more than any of the three individually applied pesticides or combination of imazalil and cypermethrin.”

Community Tobacco Control Partners Test Results 12/18

This study, like the others cited below, is an experiment to see what happens when you combine these two liver toxins. They use mice and rats. They aren’t saying that in the real world you would ever find people exposed to levels of carbendazim and cypermethrin like this at the same time. That would never happen. Except …

If you’re a super-cool young Latino dude smoking Swisher Sweets and fantasizing Carly B, or maybe a young Black mother smoking them because she’s heard they’re less harmful than cigarettes. They’re going to get the full load of carbendazim and cypermethrin together, over and over with every puff. 

Hum Exp Toxicol. 2012 May;31(5):492-505

“Carbendazim combined with imazalil or cypermethrin potentiate DNA damage in hepatocytes of mice.”

“In combination with carbendazim clastogen, properties of imazalils and cypermethrins were potentiated compared to all other treatments and control.

Higher long tail nuclei (LTN) in females indicate that certain cells in females were especially prone to total nucleus disintegration. ‘

Due to synergistic effects, low environmentally present concentrations of imazalil and cypermethrin in food, and especially their mixtures with carbendazim have genotoxic potential that could be particularly dangerous over prolonged exposure in mammalian organism.”

There’s not a single study anywhere that looks at individual pesticides in tobacco products and their impact on human health as inhaled toxins, much less when they are inhaled together day after day in a supertoxic cocktail. I suppose you could call this a simple oversight on the part of thousands of highly trained, highly paid scientists, doctors and regulators. I suppose you could say that.

But that’s exactly what millions of Latino, Black and Native people throughout the Americas are doing – inhaling that carbendazim/cypermethrin cocktail 20-40-60 times a day every day. That’s their only option too, because their only choices are the cheapest most contaminated brands of tobacco products, not the relatively cleaner high-end cigarettes smoked in economically privileged White communities. 

Young Latino, Black and Native American little cigar smokers are also inhaling at least 16 other pesticides in combination with the carbendazim/cypermethrin. No studies exist on what that incredible level of toxic synergy may be doing, but the studies on just the carbenzadim/cypermethrin combination are certainly suggestive. How about if you just add a little DDT to the mix? Done.

Both carbendazim and cypermethrin (and DDT) are potent high-tech Endocrine Disruptors, and they are present here in very significant concentrations, not traces, although endocrine disruptors have been conclusively shown to operate independently of concentration. This characteristic is known as a non-monotonic dose response, and is a much-needed refinement of the standard approach to determining a pesticide’s hazardous levels of exposure. This is especially true with the ED pesticides like Carbendazim and Cypermethrin that appear to have no safe level of exposure at all.

Extraordinarily important work by Dr. Laura Vandenberg of Massachusetts Public Health has shown that the classic way of looking at pesticide toxicity is not only wrong but dangerous in an age of designer pesticides that no longer rely on the brute force of chemical poison. http://dose-response.org/wp-content/uploads/2014/06/Vandenberg-2013-dose-response.pdf

According to Dr. Vandenberg, and these are my words, there is a strong belief among regulators, and way too many scientists, that once you establish a level at which a pesticide does measurable damage you can simply project backwards in a straight line to lower doses and estimate a level where it can’t possibly do any harm.

That makes regulators happy – they have a number. That means they have a full-time job monitoring that number. Above that number – we have a problem and we get to enforce our rules. Below that number – you’re good to go and we’ve done our job protecting the public. Next!

That approach worked great with the first pesticides, which were all heavy-duty poisons. The more poison you use, the more bugs you kill. When bugs develop resistance, use more. If the first spray doesn’t get them all, spray again. But regulators keep people “safe” by limiting the amount that can be used per acre. If you’re a farmer and you reach that amount and the bugs keep eating your crop you yell at the chemical companies and they come up with a newer, stronger, different kind of poison using the same process.

What dose of this new shit kills all the rats? OK, that’s too much. How about a lower dose? Hmmm – still kills a bunch and now it seems to cause tumors. How about this teeny weeny dose? Hey, that seems to work. Look – no bugs, and the rats are alive. Well, most of them. We’re good to go! Off to the tobacco fields! Better living through chemistry.

But then all the poisons stopped working. Well, not entirely, but you had to keep piling them on and it got to the point where all those organochlorine pesticides were causing some alarm. Some may remember Rachel Carson’s “Silent Spring”. The tobacco industry, from the very beginning the world’s heaviest users of these poisons because bugs love tobacco leaves more than any other plant, realized that they needed something better. Not safer, just better. They already owned all the regulators and were in the process of owning the scientific community so nobody was looking at pesticides in tobacco products, even though cancer was beginning to explode and everybody knew it was “smoking-related”. Nobody ever asked “smoking what?” because “everybody knew” it was tobacco. The fact that the tobacco pesticides were beginning to be identified as super-toxic environmental carcinogens somehow escaped attention, and gave the chemical industry time to develop other kinds of “Crop Protection Agents”.

Endocrine disruptors break out of the old poison/dose relationship completely, but regulators haven’t even thought of keeping up. Endocrine disruptors are the ag industry’s answer to poison fatigue. You don’t have to keep using more and more, and the numbers don’t set off any regulatory alarms because you’re using stuff that nobody understands. All we know is that it takes care of our bug problem.

ED’s are designed to work at any level – in the latest ones all it takes is a couple of molecules at the right place at the right time and – voila – no baby insects or, more commonly, “non-viable offspring”. The bugs have babies but they don’t survive to eat those valuable cops like tobacco – their fave in the whole world.

A Swisher Sweets smoker, whether they are smoking the little cigar intact or just using the wrapper as a blunt, is inhaling a blend of carbendazim and cypermethrin with every puff. Since smoking patterns vary, let’s just say that little cigar smokers are exposed through inhalation multiple times a day every day. Since these chemicals operate independently of dose, their concentration matters for other reasons but not to explain what they so to the smoker’s liver. What they are likely to do to smokers when they are inhaled together seems pretty clear, even though these studies are only on rats and the rats are eating the cancerous combo, not smoking it.

Here are a few of the studies that seem to make the connection – what do you think? There are lots of related refs – but how many do we need to begin asking questions about the safety of some of these tobacco products?

Int J Exp Pathol. 2012 Oct;93(5):361-9

“Effect of cypermethrin, carbendazim and their combination on male albino rat serum”

Alpha-cypermethrin and carbendazim are synthetic; α-cypermethrin belongs to a class of synthetic pyrethroids and carbendazim belongs to the class of carbamate fungicides. The current study was carried out to evaluate the low-dose exposure of individual and mixed forms of cypermethrin and carbendazim.

The experimental results indicate that even low-dose use of the synthetic pyrethroid carbamate and their combined form results in consequential negative effects on cell function.

Toxicol Sci. 2015 Sep;147(1):116-26.

“Oral Exposure of Mice to Carbendazim Induces Hepatic Lipid Metabolism Disorder and Gut Microbiota Dysbiosis”

Carbendazim (CBZ) has been considered as an endocrine disruptor that caused mammalian toxicity in different endpoints. Here, we revealed that oral administrations with CBZ at 100 and 500 mg/kg body weight for 28 days induced hepatic lipid metabolism disorder which was characterized by significant increases of hepatic lipid accumulation and triglyceride (TG) levels in mice.

The serum cholesterol (TC), high-density lipoprotein, and low-density lipoprotein levels also increased after CBZ exposure.

Correspondingly, the relative mRNA levels of some key genes related to lipogenesis and TG synthesis increased significantly both in the liver and fat.

Moreover, the increase in serum IL-1β and IL-6 levels by the treatment of CBZ indicated the occurring of inflammation.

Furthermore, the levels of bioaccumulation of CBZ in the liver and gut were very low as compared in the feces, indicating that most of CBZ stayed in gastrointestinal tract and interacted with gut microbiota until excreted.

At phylum level, the amounts of the Bacteroidetes decreased significantly in the feces after 5 days CBZ exposure. High throughput sequencing of the 16S rRNA gene V3-V4 region revealed a significant reduction in richness and diversity of gut microbiota in the cecum of CBZ-treated mice. UniFrac principal coordinates analysis observed a marked shift of the gut microbiota structure in CBZ-treated mice away from that of the controls.

More deeply, operational taxonomic units’ analysis identified that a total of 361 gut microbes were significant changed. In CBZ-treated groups, the relative abundance of Firmicutes, Proteobacteria, and Actinobacteria increased and that of Bacteroidetes decreased.

Our findings suggested that CBZ could lead to hepatic lipid metabolism disorder and gut microbiota dysbiosis in mice

Toxicol In Vitro. 2014 Dec;28(8):1507-20. 

“Potential involvement of chemicals in liver cancer progression: an alternative toxicological approach combining biomarkers and innovative technologies.”

Pesticides as well as many other environmental pollutants are considered as risk factors for the initiation and the progression of cancer. In order to evaluate the in vitro effects of chemicals present in the diet, we began by combining viability, real-time cellular impedance and high throughput screening data to identify a concentration “zone of interest” for the six xenobiotics selected: endosulfan, dioxin, carbaryl, carbendazim, p’p’DDE and hydroquinone.

Endosulfan, was able to strongly modulate all the studied cellular processes in HepG2 cells, followed by dioxin, then carbendazim.

Our in vitro data indicate that these xenobiotics may contribute to the evolution and worsening of hepatocarcinoma, whether via the induction of the EMT process and/or via the deregulation of liver key processes such as cell cycle and resistance to apoptosis.


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Sweet Cheap Poison At The Bodega

We’ve just finished testing off-the-shelf tobacco products from local mini-marts in Portland, Oregon and among the 20+ hidden, unregulated xenobiotic contaminants that we were able to identify (see below) we found extremely high concentrations of Carbendazim. This contamination occurred in a little cigar brand that is #1 in Latino communities and high in popularity in African-American, Native American and other marginalized & low-income communities where tobacco product choices are restricted to the cheapest, and now we know the most contaminated brands.

Carbendazim has been banned in the EU since 2014. It attacks and destroys the reproductive and immune systems of young people, particularly young Latinos, African-Americans, and Native Americans whose genetic materials are known to be more vulnerable to Carbendazim than youth of European ancestry.  As you can see in the data, Carbendazim is only one many previously hidden, unregulated contaminants we found, each with it’s own health impact. But for the moment let’s focus just on the Carbendazim 0.843 mg/kg that’s being inhaled 20-40-60 times a day by @ 850,000 young people in the US right now today.

Carbendazim contamination disproportionately impacts marginalized young people who fall victim to tobacco products and who, because of poverty and carefully targeted marketing, have few choices available to them other than the cheapest and most contaminated brands. Please notice the relationship between price and contamination in the data below. 

(from): Summary of Science Behind 2014 EU Ban on Carbendazim “Independent literature shows that the pesticide Carbendazim is a very dangerous toxin, capable of causing malformations in the foetus at very low doses and it’s still uncertain if a safe level exists at all. Carbendazim is also capable of disrupting chromosome unfolding, can cause infertility of men and cancer.”   

Community Tobacco Control Partners Test Results 12/18

As you can see, Carbendazim shows up in our first-ever data on pesticide contaminants of tobacco products (right hand column third row). This brand, Swisher Sweets, is #1 in popularity among young smokers, who are also right in the middle of their reproductive years. It is heavily marketed to youth, and is designed with sweet flavors and heavy social media advertising to be part of a cool lifestyle.

Here is a detailed study of how the most toxic brands, with Swisher Sweets the “most toxic”, are marketed in low-income, Latino, Black, and Native American communiities.

This means that these young people, in the middle of their reproductive years, are at the highest possible risk for suffering the known consequences of Carbendazim exposure. (And all the other pesticides you see there, each of which deserves it’s own discussion.) This is made more serious by the route of exposure, because inhalation exposure is far more toxic than eating or skin exposure, and the frequency, because smokers (and fetus and child) are exposed to the pesticides with every puff.

The bottom line is that 0.843 mg/kg is an extraordinary level of Carbendazim to find in any consumer product, but especially in an off-the-shelf tobacco product being marketed heavily to kids, considering that it has been totally banned in much of the world since 2014, is strictly regulated in the US, and is totally illegal on tobacco. Imagine the response of health authorities if this were found on school lunches, slurpees at the 7/11, beer at the mini-mart or granola at Whole Foods?

The problem isn’t just that the Carbendazim is present. For there to be that much Carbendazim residue, it had to have been sprayed on the tobacco deliberately, heavily and recently. There is full knowledge of the EU ban, and the reasons for it. All tobacco manufacturers have notified by their own scientific authority CORESTA. The manufacturers know, or have every reason to know, that they are committing serious race-based crimes against humanity. I can only assume that they have been at this for so long that they actually don’t realize what they are doing to so many people.

Here are just a few of the peer-reviewed research data links that throw light on this hidden relationship

1. Regul Toxicol Pharmacol. 2014 Aug;69(3):476-86. Reproductive and possible hormonal effects of carbendazim.

“The literature review indicates that CBZ induces reproductive and developmental toxicity through alteration of many key events which are important to spermatogenesis. It seems that this fungicide may influence the hypothalamus-pituitary-gonad axis in addition to being a testicular toxicant.”

“2,5-Hexanedione (2,5-HD), a taxol-like promoter of microtubule assembly, and carbendazim (CBZ), a colchicine-like inhibitor of microtubule assembly, are two environmental testicular toxicants that target and disrupt microtubule function in Sertoli cells.”

3. Toxicol Ind Health. 2014 Apr;30(3):259-67. Carbendazim-induced testicular damage and oxidative stress in albino rats: ameliorative effect of licorice aqueous extract

“Administration of carbendazim induced significant decrease in testis weight, diameter, and germinal epithelial height of the seminiferous tubules. Histological results revealed degeneration of seminiferous tubules, loss of spermatogenic cells, and apoptosis. Moreover, carbendazim caused elevation of testicular malondialdehyde (MDA), marker of lipid peroxidation, and reduced the activity of the antioxidant enzymes, superoxide dismutase (SOD) and catalase (CAT).”

4. Toxicol Pathol. 2007 Aug;35(5):719-27. “Dose-dependent effects of sertoli cell toxicants 2,5-hexanedione, carbendazim, and mono-(2-ethylhexyl) phthalate in adult rat testicles.

“Sertoli cells are the primary cellular target for a number of pharmaceutical and environmental testicular toxicants, including 2,5-hexanedione, carbendazim, and mono-(2-ethylhexyl) phthalate. Exposure to these individual compounds can result in impaired Sertoli cell function and subsequent germ cell loss. The loss of testicular function is marked by histopathological changes in seminiferous tubule diameter, seminiferous epithelial sloughing, vacuolization, spermatid head retention, germ cell apoptosis, and altered microtubule assembly.”

5.  Environmental Chemistry Letters 14(3) · June 2016 “Toxicity, monitoring and biodegradation of the fungicide carbendazim” 

“We found that carbendazim causes embryotoxicity, apoptosis, teratogenicity, infertility, hepatocellular dysfunction, endocrine-disrupting effects, disruption of haematological functions, mitotic spindle abnormalities, mutagenic and aneugenic effect.”

And the issue isn’t just Carbendazim as you can see looking back in the data. Most of the individual contaminants are concerning by themselves, but they are additive and synergistic in effect and their impact on human health in that regard is absolutely unknown. What is known now, and IMO it ought to be enough, is that young smokers are inhaling a toxic cocktail of chemicals each designed to operate in different ways at the nano-level to disrupt basic life processes.  The dosage of the most advanced pesticides doesn’t matter – they don’t need a “critical mass” to work. A couple of molecules, well below the level of detection, is enough for them to do what they were designed to do to the reproductive systems and genetic materials of bugs, and human teens are simply unfortunate collateral damage in the tobacco industry’s search for increased profits through chemistry.


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Do You Want To Make Little Cigars Illegal In Your Community?

I’ll skip the long, long back story and get right to the point. If you’ve been looking for a way that individuals and small groups of people acting on their own initiative can control dangerous tobacco products at the local level, this is it. Here’s wishing you a successful 2019.

I recently had a number of off-the-shelf tobacco brands tested for pesticide residues. This was the first time this has been done in the US, in spite of the massive amounts of tax and private money spent every year on so-called “tobacco control and prevention”.

In this post I’m including hard evidence showing the concentration of illegal, totally banned DDT I found on the most popular brand of sweet & fruity little cigars, Swisher Sweets – the top choice among low-income, Black and Hispanic teens. They are also arguably the most toxic piece of shit in the whole pile of toxic shit that this rat pack of corporate criminals sells to kids. Don’t get me wrong – I found extreme pesticide contamination on many of the brands I tested – it’s just that the little cigars stood way out at the top of the contamination chart.

Don’t just take my word for the toxicity of little cigars – the University of North Carolina conducted an extensive study in 2016 comparing the toxicity of little cigar smoke, including swisher Sweets, compared with cigarette smoke. This study was also the first of its kind, just like my pesticide residue study. The North Carolina researchers found detailed hard evidence that little cigars are extremely toxic and are particularly dangerous to young, Black, and Latino smokers compared with cigarettes. (This study, combined with the hard evidence I’m sharing in this post, will blow your mind if you care about mass poisoning of innocent children.)

The one area that this North Carolina study missed was the key role that pesticide residues play in tobacco product toxicity. Like every other scientific and medical study before them, these researchers totally failed to account for pesticide contamination in the tobacco products they tested, and so they were understandably puzzled by the extreme levels of toxicity they found.

However, once you factor in pesticide contamination, the whole picture emerges clearly. The North Carolina data makes sense. It’s the differences in the pesticide burdens of different types of tobacco products that account for the differences in toxicity among types of tobacco products. That’s why it’s so important for local communities to understand the nature of this hidden threat to their children.

I found actionable levels of many different pesticide residues in all the tobacco products I just tested, including several cigarette brands popular with kids. But the overall pesticide contamination of Tobacco products, which regulators manage to ignore, isn’t the key point here. The key point for tobacco product control at the local level is that these little cigar/DDT results are not only grim news for smokers but flat out violate the law.

It is illegal to sell any product contaminated with this level of DDT anywhere in the US. and much of the world. Only soil or water-residual DDT is allowed in any food, beverage, cosmetic or other consumer product, and there is no way that the level I found could occur as a residual from soil or water – it was sprayed on the tobacco used to make this product, and it was sprayed recently. (See commentary below the data.)

The DDT concentration shown below is 700+ times the highest level found anywhere in the entire US food chain from lingering soil or water contamination, and I will guarantee that a sampling of 100 such products will yield similarly shocking results. 

So here’s my suggestion. Take this data on your phone to your health department. Show them the DDT levels. Tell them that the same little cigar products are being sold at the mini-mart. (They are.) 

And then ask them what the law says they have to do. Tell them that the investigator behind this data will send them the full, certified lab report naming the specific brands we tested and the full results. I almost guarantee that they will try to wiggle out of it – “we don’t regulate tobacco products”, or “we don’t regulate pesticides in tobacco products” or, their favorite excuse – “well, tobacco is so bad anyway that we don’t care about a few pesticides”.

But here’s the beauty of the hard evidence I’m offering. It doesn’t matter if your local health officials think they can regulate tobacco products specifically or not. It doesn’t matter if they think have the authority to regulate tobacco products or not. Unless they are somehow forbidden to investigate and take action in cases of toxic substance contamination in consumer products being sold to children in your county, they do have the authority to act. You may have to make them act by going to the School Board, the District Attorney, and your local media, but they do have the authority to act locally and independently on high-level DDT contamination of anything in your community – period.

These contaminated tobacco products are illegal not because they are tobacco products; they are illegal because they are consumer products contaminated with hazardous concentrations of extremely hazardous, totally banned pesticide chemicals that will be emitted when they are used as intended by the manufacturer.

If you enjoy a sweet irony, I can guarantee that when all the testing is done, most of the premium cigars that the 1% love will turn out to be the most highly contaminated of all. Although some premium cigar tobacco growers still use traditional methods, and grow tobacco without industrial chemicals, I’m quite certain that most premium cigars will prove to be far more contaminated than the cheap little cigars the busboys out behind that five-star restaurant have to smoke. 

                   Pesticide Residue Test Sample #1                                  Multnomah County, Oregon                       Received 12/13/2018

billdrake4470@gmail.com

Oregon Cannabis Pesticide Residue Action Levels (PPM)
Analyte Results/Units na = not a listed or regulated pesticide
Exceeds ORS Action Levels √
Unregistered Tobacco EPA/Oregon √√
Banned/Zero Tolerance √√√

Swisher Sweets

Acetamiprid 0.146 mg/kg 0.2
Azoxystrobin 0.198 mg/kg 0.2
Carbendazim √√√ 0.843 mg/kg Carcinogen: WHO
Cypermethrin 0.443 mg/kg 1.0
DDT, p,p-  √√√ 0.816 mg/kg** 0.0 – banned
Dimethomorph √√ 0.0380 mg/kg na
Fenamidone √√ 0.0370 mg/kg na
Imidacloprid 0.169 mg/kg 0.2
Indoxacarb √√ 0.0790 mg/kg na
Mandipropamid √√ 0.0770 mg/kg na
Pendimethalin √√ 0.0910 mg/kg na
Propamocarb √√ 0.0910 mg/kg na
Pyraclostrobin √√ 0.0210 mg/kg na
Chlorantraniliprole Trace 0.2
Ethofenprox Trace 0.4
MGK Trace 0.2
Permethrin Trace 0.2
Thiacloprid Trace 0.2

** Relevant to risk assessment for these “Little Cigars”; the highest levels of DDT p, p- in all foods tested by FDA in their comprehensive “Total Diet Reports” for 2017, were for catfish filets and for frozen potato fries. The 2.17 ng/g potatoes and 2.3 ng/g levels expressed in the FDA “Total Diet Study” are the equivalents of 0.00217 mg/kg for potatoes and 0.0023 mg/kg for catfish. compared with 0.816 mg/kg in the single little cigar sample tested. Based on my knowledge of tobacco industry practices, additional testing will show serious levels of OCP and other classes of pesticide contamination particularly on tobacco products in the “discount” and low-price market segments and, as we will see, in the premium cigar market segment as well.

I know for certain that as we test other tobacco products, especially the cheap ones, we’ll find stuff that makes DDT look like a hint of mint. However, this data is right now, and approximately 800,000 children between 11-15 are smoking this particular brand of little cigar every day and inhaling every one of the pesticides listed.

But even if the only contaminant were the 0.816 mg/kg (or 816 mcg/kg) DDT ….

Average adult intakes of DDT were estimated to be 62 µg/person/day (1000 micrograms = 1 milligram) in 1965 and 240 µg/person/day in 1970, before the DDT ban was instituted. The FDA Total Diet Studies show that the daily intakes have fallen since the ban, with daily intakes (for a 16-year-old, 70 kg male) averaging 6.51, 2.38, 1.49, and 0.97 µg/person/day for 1978–1979, 1979–1980, 1984–1986, and 1986–1991, respectively.https://ntp.niehs.nih.gov/ntp/htdocs/chem_background/exsumpdf/ddt_508.pdf

“Based on all of the evidence available, the Department of Health and Human Services has determined that DDT is reasonably anticipated to be a human carcinogen. Similarly, the International Agency for Research on Cancer (IARC) has determined that DDT is possibly carcinogenic to humans. EPA has determined that DDT, DDE, and DDD are probable human carcinogens.”

https://www.atsdr.cdc.gov/phs/phs.asp?id=79&tid=20

Here is a first-class study of the toxicity of cigarette smoke compared to little cigar smoke. It’s clear from this data and analysis that little cigars, including Swisher Sweets which were one of the brands tested, are far more toxic than cigarettes. Interestingly, the researchers were puzzled about where those huge differences in toxicity came from. ‘

It was at least partly from the hidden and unaccounted-for pesticides, which were overlooked in this study as they have been overlooked in virtually every American scientific and medical study of “tobacco” smoke. Little cigars are far more contaminated with far more toxic “crop protection agents” than cigarettes because of differences in how the tobacco is raised, and in how much highly contaminated tobacco manufacturing waste is used in making the product.