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Acting Now Is Urgent: Commentary on Zeller by Robert Proctor

Zeller is right that most smoking today is not a free choice1; it is more like the robbery of choice. Cigarette makers have long recognized this in their internal communications, acknowledging privately that “We can’t defend continued smoking as ‘free choice’ if the person was ‘addicted’.”2 Zeller is also correct in talking about a continuum of risk: addiction is not like being pregnant; there are degrees of addiction, and we are not likely to find some bright line threshold of rod content nicotine below which there is no risk of addiction.

Zeller is also right to stress that nicotine doesn’t directly cause most of the diseases traced to smoking. Nicotine doesn’t cause cancer, the same way that alcohol doesn’t cause traffic accidents. The causation is indirect. Nicotine stokes the fires that drive the train. That’s what gives the lie to Michael Russell’s mantra that people smoke for the nicotine but die from the tar. Historians have shown that the idea originates not with Russell, but rather with the intrepid researchers at BAT and Battelle, who recognized this already in the early 1960s, as part of their efforts to create a heat-not-burn nicotine delivery device.3 The idea behind BAT’s Project Ariel was to make a space-age cigarette that would deliver nicotine “satisfaction” without the “unattractive side effects” of cancer and emphysema.4

The FDA is to be praised for seeking a product standard that would require the nicotine in cigarettes not to exceed some maximum level. We are talking here about nicotine in the rod—which has nothing to do with those old FTC or ISO “tar and nicotine” delivery numbers now recognized as fraudulent or at least misleading. The new standard will have to be a by-weight percentage of alkaloid in the rod—with careful attention to smoke pH so that the standard can’t be gamed by freebasing. A standard will have to specify both alkaloid in the rod and the pH of the resulting smoke.

“Minimally addictive” are words carefully chosen by Zeller because it could well be that nicotine may be slightly addictive, even at very low doses.5 But, that is not really the point. The FDA’s mandate is not to eliminate all risk but rather to specify a standard that will improve what Zeller calls “net public health,” and the stakes are huge. Zeller notes that FDA action could save 33 million Americans from becoming regular smokers, preventing an estimated 8 million deaths. That’s like stopping 3000 Twin Towers from collapsing or saving every life lost in all American wars. And lest we forget, these are real people with names and faces and families, some of whom are not yet even born.