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reconstituted tobacco. When the cigarette is burned, the 



reconstituted tobacco serves as a source of ammonia in smoke. 



The amount of reconstituted tobacco can be as high as 25 percent 



of the tobacco in the cigarette. And we've seen ammonia compound 



levels as high as 10 percent in the reconstituted tobacco. Thus, 



as the company handbook goes on to state, the benefits of the 



reconstituted tobacco: 



"come from being an ammonia source, as well as incorporating 

 sugar-ammonia reactions. As a low alkaloid blend component, 

 it also absorbs nicotine from higher alkaloid-containing 

 components. [It thus becomes]... a positive blend 

 contributor rather than merely a filler." 



The handbook also says that ammonia can be applied directly to 



the tobacco' that goes into cigarettes. 



How much additional nicotine does this technology impart? 



It is our understanding, based on smoke analysis described in the 



company handbook, that an experimental cigarette made of 

 reconstituted tobacco treated with ammonia has almost double the 

 nicotine transfer efficiency of tobacco. 



How widespread is ammonia use in the industry? The company 

 handbook states that many U.S. tobacco companies use ammonia 

 technologies. Until we have access to similar documents from 

 other companies, we will not know whether other companies use it 

 directly to affect nicotine levels. 



To determine how well nicotine content is controlled in 

 cigarettes, FDA laboratories compared the content uniformity of 

 drugs in either tablets or capsules to the content uniformity of 

 nicotine in cigarettes. What is striking is how little the 

 nicotine content varies from cigarette to cigarette, suggesting 

 tight and precise control of the amount of nicotine in 

 cigarettes. In fact, as this chart shows, the nicotine 

 content uniformity of the cigarettes tested meets drug content 

 uniformity standards set by the U.S. Pharmacopeia. (Chart 19) 



Mr. Chairman, 1 have presented information on the control 

 and manipulation of nicotine because I believe it raises certain 

 important questions — questions that are even more important in 

 light of the repeated assertions of the cigarette industry that 



