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.
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.
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. 
