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Coalition on Smoking OR Health 

 February 25, 1994 

 Page 2 



intend cigarettes to be used for this purpose, because some 

 people smoke for reasons other than the drug effect. See Action 

 on Smoking and He alth v. Harris . 655 F.2d 236, 239 (D.C. Cir. 

 1980) . 



Evidence brought to our attention is accumulating that 

 suggests that cigarette manufacturers may intend that their 

 products contain nicotine to satisfy an addiction on the part of 

 some of their customers. The possible inference that cigarette 

 vendors intend cigarettes to achieve drug effects in some smokers 

 is based on mounting evidence we have received that: (1) the 

 nicotine ingredient in cigarettes is a powerfully addictive agent 

 and (2) cigarette vendors control the levels of nicotine that 

 satisfy this addiction. 



The Coalition is well aware of the large body of scientific 

 evidence documenting the highly addictive nature of nicotine. 

 Most of this evidence is summarized in the 1988 Surgeon General's 

 Report and in the Department of Health and Human Services' 1991 

 "Triennial Report to Congress on Drug Abuse and Drug Abuse 

 Research." The evidence demonstrates that cigarettes cause an 

 addiction. The current evidence suggests that nicotine, when 

 delivered by cigarettes, produces physiological dependence 

 resulting in withdrawal symptoms when smokers are deprived of 

 nicotine. It also appears that cigarettes enjoy a market that 

 is based in part on the need of smokers to satisfy that 

 addiction. A Canadian survey suggests that 80 percent of smokers 

 believe they are addicted to cigarettes. Other data suggest that 

 a comparable percentage of smokers are, in fact, addicted. 



Moreover, the public knows that cigarettes are harmful and 

 many smokers desire to quit. Research has revealed that 77 

 percent of smokers desire to quit but cannot primarily because of 

 nicotine addiction. At FDA we have approved a number of 

 pharmaceutical therapies for treating nicotine addiction and many 

 more are under development. These therapies, which include 

 nicotine patches and nicotine gum, are essentially, nicotine- 

 delivery systems. There is a growing market for these, as well 

 as non-pharmaceutical, behavioral therapies. 



Although technology was developed years ago to remove 

 nicotine from cigarettes and to control with precision the amount 

 of nicotine in cigarettes, cigarettes are still marketed with 

 levels of nicotine that are sufficient to produce and sustain 

 addiction. In fact, it is our understanding that manufacturers 

 commonly add nicotine to cigarettes to deliver specific amounts 

 of nicotine. There is also evidence discovered in recent 

 litigation that some individuals involved in the manufacture of 

 cigarettes in the 1970s regarded their products as nicotine- 

 delivery systems. 



