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labeling for other ingested items such as foods or drugs, FTC 

 method test results do not accurately reflect the bioavailability 

 of the measured components. The test is, therefore, a fraud. 



Neil Benowitz and his colleagues at the University of 

 California at San Francisco have shown that nicotine yields as 

 measured with the FTC method do not significantly correlate with 

 blood levels of cotinine, the major metabolite of nicotine 

 (Benowitz et al, 1983) . This work has been confirmed by Gio Gori 

 of the Franklin Institute Policy Analysis Center and his 

 colleagues (1986) as well as by David Coultas and his colleagues 

 at the University of New Mexico School of Medicine (Coultas et 

 al, 1993). There is, however, a marked correlation between the 

 number of cigarettes smoked and cotinine levels. 



In two detailed studies, smokers ingested substantially more 

 nicotine from individual cigarettes and from an alternate 

 nicotine delivery device than predicted by the FTC test. The 

 first study, by Dr. Benowitz's group (Benowitz et al, 1991), 

 found that smokers who inhaled absorbed an average of 2.4 9 mg of 

 nicotine from a cigarette, when only 1.1 mg was predicted by the 

 machine test. This is a 127% increase over the machine-based 

 result. The second study, by the biobehavioral research group at 

 the R. J. Reynolds Tobacco Company (R. J. Reynolds, 1988a), found 

 that smokers who inhaled absorbed an average of 1 . mg of 

 nicotine from a cigarette rated at 0.66 mg (51% increase), and 

 the same subjects absorbed an average of 0.7 mg of nicotine from 



