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) ,- ! ) . ! MEMORANDUM TO TSE FEDERAL TRADE COMMISSION FROM PHILIP MORRIS INCORPORATED CONCERNING BARCLAY CIGARETTES AND A PROPOSED CHANGE IN THE APPARATUS USED IN THE COMMISSION'S , LABORATORY FOR TESTING "TAR" DELIVERY ) ~ 0 0 r. ) ., Philip Morris Research Center Richmond, Virginia July 10, 1981 .t r

) I I L y ) F ! B ) , ) MEMORANDUM TO THE FEDERAL TRADE COMMISSION FROM PHILIP MORRIS INCORPORATED CONCERNING BARCLAY CIGARETTES AND A PROPOSED CHANGE IN THE APPARATUS USED IN THE COMMISSION'S LABORATORY FOR TESTING "TAR" DELIVERY Introduction This Memorandum is submitted to the Commission by Philip Morris Incorporated in response to the letter from Matthew L. Myers, dated June 11, 1981, and the accompanying request by R. J. Reynolds Tobacco Company ("Reynolds") that the CoaQaission's equipment for testing the "tar" delivery of cigarettes should be modified. In a submission made to the Commission on or about June 1, 1981, transmitted to Philip Morris by Mr. Myers, Reynolds maintained that a different cigarette holding device should be used by the Commission on its smoking machine in order to obtain reliable "tar" and nicotine delivery data for the Barclay cigarettes manufactured and sold by Brown & Williamson Tobacco Corporation. Reynolds stated to the Commission that it "strongly feels that the use of the Mk II 'Filtrona' holder will provide more accurate 'tar' and nicotine measurements „ for all cigarette brands and styles .... N .i ~ Philip Morris has conducted a series of scientific measurements and analyses of Barclay

2 r ) ! i I ! 0 r w L F. , Y cigarettes and has carefully studied the performance of Barclay cigarettes under various smoking conditions. Most of the scientific tests were conducted on the king size soft pack variety of Barclay, but the same filter construction is employed on.all Barclay varieties and the results for all varieties would be similar. On the basis of these analyses, we have reached the following conclusions: First, the principal determinant of the "tar" level of a given "low tar" cigarette is dilution -- the greater the volume of dilution, the lower the "tar" yield.. Of all cigarettes now on the market, only Barclay experiences a significant; indeed a phenomenal, difference between its dilution when smoked on the Commission's smoking machine as contrasted with its actual dilution when smoked in human lips. The dilution percentage is very high (75% to 82%) in the machine, but low (averaging 32%) when smoked in human lips. In-the case of all other cigarettes, the dilution on the smoking machine is substantially the same as the dilution experienced in a human smoker's lips. ~ Second, cond, this unique differential in dilution between smoking on the machine and smoking in the lips is the direct result of Barclay's abnormal filter

3 t , ) ! 1 I ) f ) ) construction. In all other diluted cigarettes, the filter is designed so that air can mix with the smoke with the result that regardless of the manner in which the cigarette is held in the smoker's mouth, the percentage of dilution is substantially the same. Only Barclay is constructed so that the dilution air enters and exits exclusively through isolated peripheral channels that are impermeable to mainstream smoke. When those channels are open -- as they are in the current machine's holding device or when a$arclay cigarette is smoked by a person through a plastic mouthpiece (to eliminate direct contact with the lips) the fullest level of dilution (and, therefore, the lowest level of "tar") is experienced. Bowever, when Barclay .is smoked in the mouth, the inner surfaces of the lips i grasp the perimeter of the filter and drape over some or all of the exits from the dilution channels. This conclusion by the lips results in materially less dilution and, therefore, in substantially higher actual "tar" delivery. ) 7 Third, in sum, Barclay is designed differently .. 1 •t from all other cigarettes so that, alone among all cigarettes, Barclay produces substantially greater dilution (and correspondingly lower "tar") when smoked

0 1 4 ) ) ? 0 . . 0 } / s r 0 ) ) 0 40 on the Commission's machine using the current holding device than when smoked in a person's lips. While a Barclay (KSSP) cigarette may deliver one milligram of "tar" when tested on the FTC smoking machine, it delivers many times more "tar" to actual smokers than any other brand that is ranked by the Commission's current testing procedure at one milligram. Indeed, Barclay delivers more "tar" to smokers than brands listed on the Commission's reports at seven or eight milligrams. Therefore, the present testing apparatus will not provide a valid, reliable ranking for Barclay. In short, we agree with the conclusion of R. J. Reynolds that the "tar" yield of Barclay is not accurately measured relative to other brands by existing apparatus, and we also agree that a different holding device should be prescribed by the Commission for its smoking machine. For the reasons developed below, Philip Morris does not recommend the substitution of a pressurized holding device as proposed by R. J. Reynolds, but proposes instead a simple modification of the holding device. We believe it merits emphasis that the integrity of the FTC "tar" measurement program has been seriously compromised by the introduction of Barclay. The reported

) 5 f ) 0 f ® g / I ) FTC "tar" results of all cigarette brands, along with corresponding data for nicotine and carbon monoxide, will no longer provide a basis for relative comparison among all cigarette brands. While it is well known that the FTC smoking machine is not intended to simulate human smoking, it had always been the case that cigarette brands with similar FTC "tar" deliveries delivered similar levels of particulates to any given smoker, and in particular that brands with comparatively low F'!'C "tar" deliveries delivered comparatively low levels of particulates. Barclay's claim of one miliigram "tar" by FTC method threatens to destroy those relationships. If the credibility of the FTC testing program is to be preserved, it is imperative that the holding device presently in use be modified forthwith. The Barclay Problem ! L 0 y Barclay purports to be an "ultra low tar" cigarette. In truth and in substance, it is not. The filter on Barclay is constructed differently from the filter on any othor cigarette, as Reynolds has correctly stated. Unlike any other cigarette, the Barclay filter functions one way when smoked on the smoking machine, and in a radically different way wh en smoked by a human smoker.

6 1 _ ) ! ) I 0 i ) If a Barclay cigarette is smoked by a human smoker in a normal fashion, it delivers a strong taste, and the filter is stained a deep yellow. However, when a Barclay cigarette is smoked by a human smoker through a plastic mouthpiece, the character of the product completely changes. It becomes mild in flavor, and there is much less staining of the filter. No other brand displays this kind of variation depending solely on whether a cigarette is smoked in the lips or through a plastic mouthpiece. To explain this phenomenon, it is necessary to examine the unique construction of the Barclay filter and to appreciate the relationship of dilution to "tar" yield. Barclay's Unique Dilution Channels 1 I In most cigarettes, there is some "dilution" or "ventilation" of the smoke with air taken in through the filter wrapping. The amount of dilution varies from brand to brand, and, as explained below, is a significant detcrminant -- indeed, it is the most ' significant determinant -- of a "low tar" brand's measured "tar" delivery. As shown in Exhibit 1, a typical cigarette filter is surrounded by a porous plug r

) 1 E t I 0 £ 0 I ) ) t i i t wrap, which.in turn is surrounded by tipping paper with one or more rows of ventilating perforations. When the cigarette is puffed, air is drawn through the perforations in the tipping paper, through the porous plug wrap into the filter where it mixes with the mainstream smoke. It is this mixing of air and smoke within the filter that causes the smoke's dilution. As shown in Exhibit 2, the construction of a Barclay filter is fundamentally different. The Barclay filter is surrounded with a nonporous plug wrap that prevents mixing of air with mainstream smoke in the filter. Pour peripheral dilution channels are impressed during manufacture into the nonporous plug wrapped filter. Those channels extend from the mouth end of the cigarette and terminate slightly beyond the perforations in the tipping paper, short of the tobacco rod. With Barclay, only the perforations over the channels contribute to dilutiont all the other perforations are completely functionless. The IIarclay filter is thus designed so that smoke will flow through the filter, and air vill flow through the peripheral channels, with no mixing possible in the filter. While a few other cigarettes on the market, such as Philip Morris' Multifilter brand, also

) I V : ) t i ;rj l ;-1 1 i r i 1 8 have peripheral dilution channels, the channels in those cigarettes, unlike those of Barclay, are open to the mainstream smoke at the end of the filter furthest from the mouth end of the cigarette. The result, as shown in Exhibit 3, is that dilution air is free to mix with the smoke within the filter. Barclay is the only cigarette brand that completely isolates dilution air from mainstream smoke in a set of peripheral channels. The Significance of Cigarette Dilution The principal purpose and effect of diluting cigarette smoke is to reduce deliveries of "tar," nicotine, and gas phase components of cigarette smoke. If a cigarette is highly diluted, each puff will contain a high percentage of ambient air and a correspondingly lower percentage of particulate-containing smoke. There is a clear inverse correlation between the measured dilution of cigarette brands and their measured "tar" delivery. On Exhibit 4, percentage dilution is plotted against "tar" delivery for 138 brands of cigarettes on the market. All of the brands with very low "tar" delivery have very high percentages of dilution. For example, all of the brands with measured "tar" delivery of six milligrams or less have measured N O N r N ~ ~ N

1 9 1 : ) ? ) ) g 1 ) 1 . D dilution of 50% and above, and all of the brands with measured "tar" delivery of two milligrams or less have measured dilution of 74% and above. As the exhibit shows, cigarettes with a low percentage of dilution are in the cluster of cigarettes with a higher "tar" yield. The inverse relationship between dilution and "tar" delivery can also be demonstrated for individual cigarette brands. The tipping paper of a cigarette filter can be modified to vary the degree of ventilation. Exhibits 5 and 6 show graphically the effect of such varying dilution on the "tar" delivery of a number of cigarette brands. As the•percentage of dilution is decreased, "tar" delivery is increased; conversely, as dilution is increased, "tar" yield is reduced. Barclay is no exception to this general pattern. When measured on standard testing apparatus, Barclay has a dilution of 75% to 82%, an extremely high level. It is this high level of ventilation that causes Barclay (IKSSP) to achieve a"tar" delivery by current FTC method of only one to two milligretims. The importance of dilution to Barclay's measured "tar" delivery is no secret. The Brown & Williamson Barclay patent recognizes that "[tJhe dilution of the smoke stream reduces the