Smoking and Tobacco Control Monograph No. 7 
hazards of the many different varieties of cigarettes on the 
market is currently feasible [580 F. Supp. at 985]. 
The comments ultimately submitted in response to the Commission's 
questions about compensatory smoking reflected sharply disparate views. 
On the one hand, the American Heart Association (AHA), American Lung 
Association (ALA), and American Cancer Society (ACS) identified problems 
with the existing methodology, expressed concern over the impact of 
compensatory smoking behavior, and suggested extensive research to 
improve the current testing and reporting procedures.^® 
On the other hand, Philip Morris, R.J. Reynolds Tobacco Company, 
and American Brands asserted that compensatory smoking behavior was 
not relevant to the testing methodology and that devising a protocol that 
accounted for compensatory smoking would require establishing a profile of 
the average smoker, something the Commission had previously declined to 
do because of the impossibility of accounting for all the relevant variables. 
Lorillard stated that data on compensatory smoking were very limited and 
therefore recommended that the existing system be kept intact. Liggett & 
Myers suggested that perhaps all cigarette testing should be abolished because 
smoking behavior could seriously affect tar and nicotine yields and smokers 
could not be taught to change their behavior. 
In response to the Commission's question about possible implementation 
of a "banding" system for its tar and nicotine ratings, B&W (which had 
just had Barclay's rating revoked) argued that the current system caused 
manufacturers to emphasize small differences that might not exist, given 
the realities of compensatory smoking, and that it should be replaced with 
a system that would group products into high-tar, medium-tar, low-tar, and 
ultralow-tar "bands." Philip Morris and American Brands argued that banding 
would lead to a concentration of brands at the upper limit of each category 
(in contrast to the existing system, which encouraged reductions across the 
board). American Brands also contended that banding would confuse 
consumers, whereas Philip Morris noted that it would substitute the 
Government's judgment about the significance of differences in tar ratings 
for that of the individual consumer. 
the ALA stated that given the reality of compensatory smoking, lov^-tar cigarettes might not be as safe as 
some consumers were being led to believe and that the Commission's testing and reporting procedures were 
contributing to questionable advertisements for "safe" cigarettes. The ACS stated that the Commission's test 
method should be modified to reflect current understanding of compensatory smoking behavior. The AHA 
expressed its view that the Commission's testing and reporting procedures fostered the belief among 
consumers that low-tar cigarettes were safer than high-tar brands. However, epidemiological evidence 
showing a correlation between the risk of coronary heart disease and the number of cigarettes smoked 
per day, but not a reduced rate of such disease among low-tar smokers, suggested that smokers of those 
cigarettes might be engaging in compensatory smoking. 
I he ALA and ACS recommended that research be conducted to determine how actual intake of tar and 
other smoke constituents by smokers related to the Fl'C's ratings; following completion of this research, 
the Commission should test each cigarette under a range of conditions replicating actual smoking behavior 
and report those results with a warning that individual yield depends on individual smoking patterns. 
6 
