Section II 
there is no benefit, and I do not think we should say that there is no benefit 
because I agree the public health argument is there. But the physician in 
me says, "Always oversell your case," because people do not change very 
much. Again, I do not care what kind of disclaimer or how it is worded, 
but there has to be, again, something about health benefits to the consumer 
in all of this. 
DR. FREEMAN; Dr. Shiftman? 
DR. SHIEFMAN; I think the two issues we have struggled with most recently 
are related. While the system as now constituted has its focus on advertising 
and on showing a single number for an FTC measure of tar and nicotine 
values, in fact there are implicit claims being made both in advertising 
proper and in brand names, which are a form of advertising that imply 
a health claim. Therefore, it seems to me we ought very strongly to 
recommend both that the use of those terms, like "light" and "ultralight," 
be regulated and that when they are used, they be accompanied in fair 
balance by a disclosure of the sort that Dr. Hughes has suggested. 
I think there is a middle ground that allows us to proceed based on what 
we know and based, I think, on regulatory authority that already exists. 
DR. FREEMAN: Yes, Dr. Zacny? 
DR. ZACNY: Based on Dr. Rickert's point about state-of-the-art 
epidemiological studies not being done at this time where you can say with 
any degree of certainty what the relationship is between nicotine dose and 
risk of disease with the brand of cigarettes we are dealing with now — the low- 
yield cigarettes and the ultralow-yield cigarettes — I disagree slightly with 
Dr. Hughes when he says that the relationship may be very shallow. As 
scientists, in any claims we make we can just say that we do not know at 
this time what the relationship is because it takes 10 or 20 years, but based 
on what we know, it would be best not to block vent holes, to take smaller 
puffs, etc. 
DR. EREEMAN: That would be an educational campaign? 
DR. ZACNY: Yes. Maybe I am wrong, but it seems that there may be a dose- 
response relationship between risk of lung cancer and how much smoke 
people take into their system, and they may realize a substantial benefit with 
the ultralow-yield cigarette. I do not think we know with certainty, and in 
the absence of that, I think the formulations that we are putting forth with 
bands and ranges are a good idea. 
DR. EREEMAN: Dr. Kozlowski? 
DR. KOZLOWSKI: I would like to draw an analogy to the FDA nutritional 
labeling. For a lot of the items on those labels, there is not persuasive 
epidemiological research to show the dose-response curves for a lot of the 
things that are listed as of interest. I think we do not want to be held to a 
higher standard. Epidemiology takes time. It has its limitations, and the 
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