498 



variability among the three types of tobacco. In 1993, Burley tobacco contained 

 approximately 3.4 percent nicotine, Bright contained 2.9 percent, and Oriental contained 1.3 

 percent nicotine. The nicotine content of tobacco is tracked through recording yearly nicotine 

 trends of the various tobacco types. Also, nicotine is lost during manufacture due to 

 nicotine's volatility and water solubility. During the over-all process, approximately 25 

 percent of the nicotine content contained in the raw tobacco is lost. 



The typical cigarette contains 750 to 760 mg of tobacco. The average concentration of 

 nicotine per cigarette is 1 5 mg. There were two potential sources of added nicotine in the 

 manufacture of cigarettes, flavorings containing tobacco extract and alcohol denatured with 

 nicotine sulfate. Philip Morris stopped using flavors containing tobacco extract in domestic 

 product in 1993. When flavors containing tobacco extract were used, Merit Ultra Lights 

 Menthol was the Philip Morris product which had the highest combined use of flavors 

 containing tobacco extract and nicotine sulfate denatured alcohol. The total contribution of 

 nicotine from the flavor containing tobacco extract and the denatured alcohol was calculated 

 as 0.00544 mg per cigarette. This amount falls below standard analytical detection limits and 

 represents less than 0.04 percent of the total nicotine in a single cigarette. 



4. FINDESGS 



Based on the procedures and processes observed in the four different facilities, there is no 

 basis for the claim that Philip Morris controls or manipulates the levels of nicotine in the 

 processing of its tobacco for cigarettes. 



Processing of blended leaf and reconstituted leaf tobaccos were developed to utilize all of the 

 purchased leaf tobacco, much like any other agriculture-based industry. These processes do 

 not increase the amount of nicotine in the resultant tobaccos, rather they reduce it with no 

 processes to re-introduce or replace the lost nicotine. The frequent addition and removal of 

 water lowers the concentration of a water-soluble compound such as nicotine. Utilizing 

 components such as stems in cigarette manufacturing also lowers the nicotine level because 

 these elements have much lower concentrations of nicotine than leaf. 



The addition of flavors to tobacco does not contribute measurable nicotine to the tobacco. 

 The only exceptions in this case are for the addition of flavors containing tobacco extract and 

 the nicotine contained in the alcohol used as a vehicle for the flavors. Tobacco extract has 

 not been used by Philip Morris in cigarettes sold domestically since 1993 and is presently not 

 used in foreign exports. When flavors containing tobacco extract were used, the additional 

 nicotine content per cigarette was not detectable by standard analytical methods. 



