Tuesday, July 20, 2010

If You're Banning Chocolate and Banana in Cigarettes, Then Why Not Licorice, Brown Sugar, Caramel, Lemon Oil, Lime Oil, and Scotch Spearmint Oil?

Yesterday, I argued that the TPSAC, in being asked to evaluate whether or not it made sense to exempt menthol from the ban on cigarette flavorings, must consider the central question of whether menthol enhances the taste, and therefore the appeal of cigarettes, especially to youth. Today, I extend that reasoning by arguing that menthol is not unique and that there are more than a hundred similar flavorings added to cigarettes that enhance the taste and appeal of the product. Based on the reasoning used to ban cigarette flavorings like chocolate, vanilla, and strawberry, each of these other flavorings must also be banned.

R.J. Reynolds, for example, acknowledges that each of the following 130 additives is used as a flavoring agent in some of its cigarette brands to enhance the taste and therefore the appeal of the product.

  • Acetic Acid
  • Acetoin
  • Acetophenone
  • 2-Acetylpyrazine
  • 3-Acetylpyridine
  • Amyl Butyrate
  • Amyl Octanoate
  • Amyris Oil
  • trans-Anethole
  • Anisic Aldehyde
  • Ascorbic Acid
  • Balsams, Peru
  • Beeswax Resinoid
  • Benzaldehyde
  • Benzaldehyde Glyceryl Acetal
  • Benzoic Acid
  • Benzyl Alcohol
  • Benzyl Benzoate
  • Benzyl Cinnamate
  • Bornyl Acetate
  • Brown Sugar
  • Butanoic Acid, 3-Methyl-, 4-Methylphenyl Ester
  • Butanol, 3-Methyl-, Benzoate, 1-
  • Butyl Alcohol
  • n-Butyl Isovalerate
  • Butyric Acid
  • Caramel Color
  • Caramel (Plain)
  • Cardamon Oil
  • Carob Bean Extract
  • Carrot Seed Oil
  • l-Carvone
  • Caryophyllene
  • Caryophyllene Oxide
  • Celery Seed Oil
  • Chicory Extract
  • Cinnamaldehyde
  • Cinnamon Bark Oil
  • Citral
  • Citric Acid
  • Citronella Oil
  • Clary Sage Oil
  • Cocoa (Extract, Powder, Extractive, Tincture, Distillate, Absolute)
  • Coffee Beans, Ground
  • Coriander Oil
  • Corn Syrup
  • Damascenone
  • Davana Oil
  • delta-Decalactone
  • gamma-Decalactone
  • Decanoic Acid
  • Dextrose
  • Diammonium Phosphate
  • Diethyl Malonate
  • 2,6-Dimethoxyphenol
  • Dimethyl Benzyl Carbinol Butyrate
  • Dimethyl Sulfide
  • 3,4-Dimethyl-1,2-Cyclopentadione
  • 4,5-Dimethyl-3-Hydroxy-2,5-Dihydrofuran-2-one
  • 2,5-Dimethylpyrazine
  • Dodecahydro-3A,6,6,9A-Tetramethylnaptho-(2,1-b)-Furan
  • delta-Dodecalactone
  • gamma-Dodecalactone
  • Ethyl Acetate
  • Ethyl Benzoate
  • Ethyl Butyrate
  • Ethyl Caproate
  • Ethyl Cyclotene
  • Ethyl Decanoate
  • Ethyl Heptanoate
  • Ethyl Levulinate
  • Ethyl Maltol
  • Ethyl Methyl Phenyl Glycidate
  • Ethyl Myristate
  • Ethyl Nonanoate
  • Ethyl Octanoate
  • Ethyl Pentanoate
  • Ethyl Phenylacetate
  • 3-Ethyl Pyridine
  • Ethyl Vanillin
  • 4-Ethyl-2-Methoxy-Phenol
  • Ethyl-2-Methylbutyrate
  • 2-Ethyl-3,5(or 6)-Dimethylpyrazine
  • 5-Ethyl-3-Hydroxy-4-Methyl-2(5H)-Furanone
  • 2-Ethyl-3-Methylpyrazine
  • Eucalyptol
  • Fenugreek Absolute/Extract
  • Fenugreek Seed
  • Furaneol
  • Geraniol
  • Geranium Bourbon Oil
  • Geranyl Acetone
  • Glycerides, mixed decanoyl and octanoyl
  • Guaiacol
  • Helichrysum Absolute
  • gamma-Heptalactone
  • Heptanoic Acid
  • omega-6-Hexadecenlactone
  • gamma-Hexalactone
  • Hexanal
  • Hexanoic Acid
  • 3-Hexanoic Acid
  • 1-Hexanol
  • 2-Hexen-1-ol
  • cis-3-Hexen-1-yl Acetate
  • cis-3-Hexenol
  • Hexyl Acetate
  • Hexyl Phenylacetate
  • Hydroxyphenyl)-Butan-2-one, 4-(para-
  • Invert Sugar
  • alpha-Ionone
  • beta-Ionone
  • alpha-Irone
  • Isoamyl Acetate
  • Isoamyl Butyrate
  • Isoamyl Isovalerate
  • Isobutyl Phenylacetate
  • 2-Isobutyl-3-Methoxy Pyrazine
  • Isobutyraldehyde
  • Isovaleraldehyde
  • Isovaleric Acid
  • Jasmine Absolute
  • Labdanum Absolute
  • Lactic Acid
  • Lauric Acid
  • Lemon Oil
  • Lemongrass Oil
  • Levulinic Acid
  • Licorice
  • Licorice Extract Powder
  • Lime Oil
  • Linalool
  • Linalool Oxide
  • Linalyl Acetate
  • Linoleic Acid
  • Lovage Root
  • Maltol
  • Mate Extract
  • para-Mentha-8-Thiol-3-one
  • Menthol
  • l-Menthone
  • 2-Methoxy-3-Methyl-Pyrazine
  • 2-Methoxy-4-Methylphenol
  • Methyl Dihydrojasmonate
  • Methyl Linoleate/Methyl Linolenate
  • 2-Methyl Pentanoic Acid
  • Methyl Salicylate
  • trans-2-Methyl-2-Butenoic Acid
  • Methyl-2-Furoate
  • Methyl-2-Pyrrolyl Ketone
  • 2-Methyl-3((5 or 6)Furfurylthio)pyrazine
  • 6-Methyl-3,5-Heptadien-2-one
  • 6-Methyl-5-Hepten-2-one
  • 4-Methylacetophenone
  • 2-Methylbutyric Acid
  • Methylcyclopentenolone
  • 2-Methylpyrazine
  • 5-Methylquinoxaline
  • 3-Methylvaleric Acid
  • Myristic Acid
  • Myrrh Absolute
  • Myrrh Extract
  • Myrrh Oil
  • Nerol
  • Neroli Bigarade Oil
  • Nerolidol
  • 2,6-Nonadien-1-ol
  • gamma-Nonalactone
  • Nonanoic Acid
  • gamma-Octalactone
  • Octanal
  • Octanoic Acid
  • 1-Octen-3-ol
  • 2-Octenal, (E)-
  • Olibanum Oil
  • Orange Oil
  • Orange Oil Terpenes
  • Orange Sweet Terpeneless Oil
  • Orris Root Extract
  • Palmitic Acid
  • Patchouli Oil
  • Patchouly Absolute
  • omega-Pentadecalactone
  • 2,3-Pentanedione
  • Pepper Oil, Black
  • Peppermint Oil, Terpeneless
  • Peru Balsam Oil
  • Phenyl-2-Propenoic Acid Ethyl Ester, 3-
  • Phenyl-2-Propenoic Acid, 3-
  • Phenylacetaldehyde
  • Phenyl Acetic Acid
  • Phenethyl Acetate
  • Phenethyl Alcohol
  • alpha-Pinene
  • Piperonal
  • Potassium Carbonate
  • Potassium Sorbate
  • Propyl Acetate
  • Rose Oil (Turkish)
  • Rosemary Oil
  • Salicylic Aldehyde
  • Sandalwood Oil, Yellow
  • Sodium Citrate
  • Scotch Spearmint Oil
  • Sucrose
  • alpha-Terpineol
  • alpha-Terpinyl Acetate
  • 5,6,7,8-Tetrahydroquinoxaline
  • 2,3,5,6-Tetramethylpyrazine
  • Thymol
  • para-Tolualdehyde
  • Triethyl Citrate
  • 3,5,5-Trimethyl-1,2-Cyclohexanedione
  • 2,6,6-Trimethyl-2-Cyclohexene-1, 4-Dione
  • 4-(2,6,6-Trimethylcyclohex-1-enyl) but-2-en-4-one
  • 2,3,5-Trimethylpyrazine
  • delta-Undecalactone
  • gamma-Undecalactone
  • 2-Undecanone
  • Urea
  • Valerian Root Oil
  • gamma-Valerolactone
  • Vanilla Oleoresin
  • Vanillin
  • Veratraldehyde
  • Vetiver Oil
  • Violet Leaves Absolute

  • If you look at Camel cigarettes in particular, you'll note that the following flavorings are added to enhance the taste and appeal of the product -- the first four are present in nearly all Camel sub-brands and the remainder are present in certain sub-brands:
    • Brown sugar
    • High fructose corn syrup
    • Cocoa
    • Licorice
    • Honey
    • Sucrose
    • Menthol
    How can it make any sense for the federal government to ban chocolate, vanilla, strawberry, pineapple, coconut, and banana flavorings -- which are almost never used in cigarettes -- but to allow cigarette companies to put sugar, cocoa, licorice, and honey in cigarettes to improve their taste and enhance their appeal to children?

    Certainly, if you're not going to allow banana, then you shouldn't allow honey. If you're not going to allow pineapple, then you shouldn't allow sugar. If you're not going to allow mint, then you sure as heck shouldn't allow licorice. And if you're not going to allow chocolate, then you shouldn't allow brown sugar.

    To be clear, I'm not stating that I agree with the original decision to ban flavorings; however, the regulatory framework set up by the anti-smoking groups essentially asks the FDA to regulate the ingredients in cigarettes that enhance its appeal to youth. Thus, the FDA seems to have little choice but to ban all the additives in cigarettes. After all, there is no way the FDA can justify a ban on pineapple but allow lemon and lime oil, caramel, brown sugar, peppermint oil, vanillin, licorice extract powder, and scotch spearmint oil to be added to cigarettes to improve their taste and enhance their appeal among potential youth smokers.

    Perhaps more potently, a failure to ban lemon, lime, spearmint, and peppermint oil, vanillin, brown sugar, cocoa powder, caramel, and licorice would be completely inconsistent with the public statements made by the FDA and by prominent HHS officials.

    For example, the FDA itself has boasted that: "The Tobacco Control Act prohibits the manufacture, distribution, and sale of those cigarettes [flavored cigarettes] in order to protect our kids...". Well, if a prohibition on flavored cigarettes is necessary to protect kids, then it looks like the FDA has no justification for failing to also ban a host of other flavorings -- particularly since these are flavorings which the cigarette companies actually use.

    Furthermore, the FDA Commissioner stated that: "These flavored cigarettes are a gateway for many children and young adults to become regular smokers." So if flavored cigarettes are a gateway for children to become regular smokers, wouldn't the FDA want to ensure that lemon, lime, spearmint, peppermint, brown sugar, caramel, cocoa, and licorice aren't also added to cigarettes to give them a taste that is more likely to appeal to kids?

    And the icing on the cake is that the Assistant Secretary for Health and Human Services stated: "Flavored cigarettes attract and allure kids into lifetime addiction. FDA's ban on these cigarettes will break that cycle for the more than 3,600 young people who start smoking daily." If flavorings in cigarettes are what attract and allure kids into a lifetime of addiction and breaking that cycle will stop 3,600 young people from smoking every day, then it seems imperative that the FDA ban all flavorings from cigarettes, not just the ones which are not ever used.

    I don't believe for a minute that the Assistant Secretary of HHS, FDA Commissioner, or anyone at FDA is going to recommend a ban on all of these flavorings. Why? Because I don't believe that they are actually sincere about their desire to stop 3,600 kids a day from smoking. I think their statements were a purely political stunt that was not based in reality.

    We'll see. Let's see whether the same policy makers who made those statements about the dire need to get flavors out of cigarettes actually follow through by getting the flavors out of cigarettes. In the mean time, I stand by my statement. I truly believe this is all about politics, and not about science, nor about actually improving the public's health by preventing 3,600 young people every day from starting to smoke. The Family Smoking Prevention and Tobacco Control Act is all about protecting and institutionalizing cigarette smoking, not reducing it.

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