Agriculture Canada, the tobacco industry and nicotine.
Transcription
Agriculture Canada, the tobacco industry and nicotine.
Agriculture Canada, the tobacco industry and nicotine. The cigarette companies’ recruitment of the federal agriculture ministry to boost the nicotine in Canadian tobacco, as shown by documents from the Blais-Létourneau trial. Neil Collishaw and Cynthia Callard Service d’Information sur les Procès du tabac Association pour la Santé Publique du Québec May 2015 Contents Agriculture Canada, the tobacco industry and nicotine. .............................................................................. 1 The early years of government and tobacco industry involvement in tobacco agriculture in Canada 2 1960s: Initial attempts to reconcile on health and agricultural programs. .......................................... 4 1970s: The “Less Hazardous Cigarette Programme” ............................................................................ 7 1980s: The continuation of Agriculture Canada’s “Tobacco and Health” program. .......................... 14 1990s: Concerns about nicotine spiking ............................................................................................. 19 1990s: Major changes on tobacco road .............................................................................................. 21 Related information: Agriculture Canada, tobacco growers and cigarette manufacturers ............... 24 Caution: If your Word program is set to update links when saving, you risk making the hyperlinks fail to work if the USB key is moved to another computer. To adjust your Word program, see instructions at: https://support.microsoft.com/en-us/kb/903163 1 The Canadian government has engaged in activities to discourage tobacco use from the mid 1960s, but has a much longer history of support for tobacco agriculture. Beginning in 1906 until the end of the 20th century,1 government-run tobacco agricultural research was undertaken for the benefit of the tobacco growers and tobacco manufacturers.2 That is to say, the federal government has maintained simultaneous policies of anti-smoking and pro-tobacco growing for over 50 years. The early years of government and tobacco industry involvement in tobacco agriculture in Canada It was the 1886 Experimental Farm Stations Act3 that gave the federal government an active role in agricultural research, in support of Canada’s farmers. With this enabling legislation in place, from the point of view of those interested in expanding the scope of agriculture in Canada, it was a logical extension of agricultural research for CDA to become involved in tobacco agriculture. Thus it was that in 1906, as commercial tobacco growing and a functioning system of taxation of tobacco leaf had become more firmly established, the Canadian Department of Agriculture first established a Tobacco Branch. The next logical extension of government involvement in tobacco agriculture was to establish a tobacco agriculture research station. The first such station in a tobacco-growing region was established at Harrow, in Essex County, Ontario in 1909. 4 Tobacco manufacturing in Canada expanded in the late nineteenth century. Several new tobacco manufacturing companies started up during this period.5 The American Tobacco Company of Canada (ATCC), was established in Montreal in 1895 with Mortimer Davis as its first president. He rapidly became the dominant force in the Canadian tobacco business and it was his initiative to begin the cultivation of flue-cured tobacco in Essex County, Ontario in 1900. As cigarette production expanded using Canadian-grown flue-cured tobacco, Mortimer Davis’ role expanded along with it. Several smaller companies were acquired by ATCC and the now larger ATCC was reborn as Imperial Tobacco Company of Canada Limited in 1912 with Mortimer Davis as its first president.6 From the outset in the early twentieth century, Imperial Tobacco and the federal government were partners leading the development of a flue-cured tobacco growing industry in Canada. Tobacco leaf historian Lyal Tait explained it this way: In every province and area in Canada where farmers have expressed a desire to grow tobacco, the experience and co-operation of Imperial Tobacco have been extended. In Ontario, Quebec, and the Maritimes, their fieldmen have worked hand in hand with the farmers and the government in setting up 7 the flourishing Canadian tobacco growing industry. 1 2 3 4 5 6 7 Exhibit 20789 Exhibit 21274 The Experimental Farm Stations Act. In Statutes of Canada, Chapter 57.; 1886 Exhibit 21274 Exhibit 21218 (Tait) Exhibit 21218 (Tait) Exhibit 21218 (Tait) 2 By 1948, government tobacco research had expanded to five locations — the Central Experimental Farm in Ottawa and the other experimental stations in L’Assomption, Quebec, and Harrow, Delhi and St. Thomas in Ontario. According to the 1949 report of the Dominion Experimental Farms, “Breeding and testing [of tobacco] have been carried on to meet the progressive demands of this highly specialized industry.”8 In June 1964, the House of Commons Standing Committee on Agriculture and Colonization conducted a review of the production and processing of tobacco. Witness Norman MacRae of the Canadian Department of Agriculture praised Imperial Tobacco for its assistance in tobacco agricultural research: Practically all of these committees involved a number of co-operating units. The Imperial Tobacco Company has played a great part on the three committees which I have just mentioned, and they have spent considerable sums of money, with us, in our programs relating to our attempt to devise and improve the method of curing flue-cured tobacco. They were heavily involved in our program relating to the cause and control of weather fleck, and they are still very much involved in the cigar filler program. The Imperial Tobacco Company was the only company which co-operated with us in our research problems, and I might say it was their wish to do so. They have contributed generously, and we are most 9 grateful to them for the assistance that they have given us. A few months later, in August 1964, that Committee issued their report on the study of tobacco production and processing. This report made no mention of the report that had been released 8 months earlier, in January 1964, by the US Surgeon General, which had concluded that smoking caused cancer,10 nor the conclusion of Canada’s health minister, Judy LaMarsh to the same effect in June 1963.11 Even though they had called no health scientists as witnesses, the committee voiced its confidence in agricultural research as a way to reduce the harmfulness of smoking. Your Committee heard evidence to the effect that, as yet no specific ingredient in tobacco has been positively identified as being harmful to health. Evidence received by the Committee indicates that if such an ingredient does in fact exist and can be isolated and identified it may be possible to remove the 12 hazards to health through research. Canadian parliamentary committees would not look at the health aspects of smoking until 1969.13 8 9 10 11 12 13 Exhibit 21206 Exhibit 40347.10 Exhibit 601-1964 Exhibit 20489 Exhibit 40347.107 Exhibit 729b 3 1960s: Initial attempts to reconcile on health and agricultural programs. Beginning in 1963, the health ministry launched a series of activities to respond to the “rapidly” increasing rate of lung cancer to which the “cigarette habit is an important contributory cause.”14 Among their objectives was reducing the harm of smoking to those who continued to smoke, and in 1966 this was thought by health officials to include reductions in the amount of tar and nicotine inhaled from a cigarette. The use of filters was one mechanism thought to accomplish this, and that “the way tobacco is cured and processed may affect the tar and nicotine content.” They recognized that “the Department of Agriculture might have a part to play.”15 This was followed, in 1967, with an exchange of correspondence and meetings between health and agriculture officials about ways to reduce the hazards of smoking. As the deputy minister of the Health Department16 explained to his colleague in the Agriculture Ministry, his department saw possibilities in “decreasing the number of cigarettes smoked per day, avoiding inhalation, smoking shorter cigarettes, throwing away a very long butt and good filtration.” They also saw promise in reducing the amount of tar and nicotine by .varying tobacco cultivation and curing techniques.” 17 The response within the Agriculture ministry to this memo exposes the very different concerns of the two ministries. Although it would be possible to lower the nicotine content, as an analyst concluded, it was “improbable” that farmers would want to adapt their practices and therefore the department should not “divert limited resources to breeding a variety for which there may be no demand.”18 The official did not seem impressed by other ideas proposed to reduce exposure to smoke: This is a 3-cigarette memo – standard size, medium length butt. The Department of National Health and Welfare has not yet affected my smoking habits. Continued TV ads suggest that N.H. & W. is not trying very hard: e.g. the advantages of longer and still longer cigarettes are advocated on TV, whereas Dr. Crawford recommends shorter ones. The 1967 interest by DNHW in low-yield products prompted no immediate change in tobacco agricultural research by the federal government. 1968 reports on tobacco research from the Department of Agriculture reveal that its research continued to be developed on consultation with 14 Exhibit 40116 15 Exhibit 40346.191 16 The Department of National Health and Welfare (DNHW) later renamed Health and Welfare Canada (HWC) and still later Health Canada (HC). 17 Exhibit 20581.1. page 1 18 Exhibit 20581.2. page 1 4 tobacco companies.19 Concerns for health were not identified as they were for “smoking quality” and the “economics of processing and manufacture.”20 Pressure on the Department of Agriculture to offer some nod to public health concerns increased, however, in the following two years. In November 1968, the health ministry released its first report on the tar and nicotine levels of each brand of Canadian cigarettes.21 This prompted greater interest in low-yield cigarettes, including on the part of Dr. Vickery, who was in charge of the tobacco program at Agriculture Canada. In an essay prepared on December 23, 1968 for publication in a local newspaper, he noted that because of the first “tar” tests “... one can be safe in predicting a substantial increase in requirements for the lighter types of tobacco.”22 The department still did not invite participation from health officials in developing its strategy to do this. They did, however, invite representatives of all the major Canadian manufacturers to help in departmental planning meetings in order to receive “guidance in the production of tobacco in Canada for the best interest of the trade.”23 The agriculture ministry was again prompted by events in the health ministry when health minister John Munro arranged for the Standing Committee on Health, Welfare and Social Affairs to review the possibility of legislation to control tobacco sales.24 The committee would be chaired by Dr. Gaston Isabelle. Following an early hearing, one Department of Agriculture official advised his superior that the Committee was being advised that agricultural research was required “to develop a product which is less hazardous to the consumer.” This official did not express support for the health objective. Possibly some useful public relations work could be done on behalf of the Department’s tobacco research program and on behalf of the tobacco grower by emphasizing the interest in making smoking less 25 hazardous. Hearings by the Isabelle Committee took place over much of 1969, and during this period there were more numerous discussions between health and agriculture officials. On August 7, 1969, after an “enjoyable” visit to the tobacco Research Station at Delhi, Ontario the official in charge of the tobacco program at the health ministry, Dr. Harold Colburn, shared his views on the agricultural research that was needed with his supervisor: 19 20 21 22 23 24 25 Exhibit 20597, p. 4 Exhibit 20593, p. 2 Exhibit 40316 Exhibit 20617, p. 1. Exhibits 20618, 21067, 21068, 21069 Exhibit 20068 Exhibit 40348.6 5 For my part, I believe that emphasis should be given to broad subjects such as the development of low tar, low nicotine tobaccos, the effects of different curing methods on the irritative characteristics of 26 cigarette smoke, and the possibility of developing cigarettes that smokers are less likely to inhale. He hoped that the two departments could work in a complementary fashion to make smoking less harmful. I would think that despite our cooperation, at Departmental levels, we should clearly distinguish the roles of the Departments of Health and Agriculture. The stance of this Department should, in my view, remain the non-smoking one. That of the Department of Agriculture could be, in its traditional context, to develop the tobaccos required for those who continue to smoke but would like less hazardous cigarettes. Increasing emphasis on this type of research by the Department of Agriculture would also help to solve the inconsistency of one Government Department recommending that Canadians do not smoke and 27 another providing the wherewithal for them to smoke. His view was shared by the Isabelle Committee when it made its report to Parliament on December 9, 1969. The Committee cannot agree with those who say that the Department of Agriculture should discontinue its tobacco research activities or its advice to tobacco farmers. Rather, it is to be hoped that the service will continue but give special emphasis to the production of tobacco required for the production of less hazardous cigarettes. The excellent resources of the Department of Agriculture would lend themselves admirably to collaborative research with the Department of National Health and Welfare and interested 28 universities into the broad question of less hazardous cigarettes. But when Agriculture ministry officials met with cigarette manufacturers the following January to make plans for the coming research season, there was no mention of the health goals of developing less inhalable cigarettes. Nor was there support for reduced-nicotine varieties of tobacco. These were thought to have “major drawbacks which ruled out their use.” The meeting concluded by essentially rejecting the advice of the health ministry and Isabelle Committee, and leaving to the cigarette manufacturers the responsibility for less hazardous cigarettes. The consensus is that the current varieties should be grown and that technology at the manufacturers’ level could be expected to carry out any adjustments due to changes in the domestic market in the 29 present smoking controversy. The Prime Minister’s office seemed to support this view. In response to a concern from the tobacco belt, assurance was given that although the committee had recommended that Agriculture Canada collaborate with the health department “the research program presently being carried on with the tobacco industry would be continued.”30 26 27 28 29 30 Exhibit 40249 Exhibit 40249 Exhibit 1554.4 Exhibit 20654 Exhibit 20651 6 The agriculture research program once envisioned by Harold Colburn, aimed at less palatable cigarettes with reduced nicotine, would never be realized. 1970s: The “Less Hazardous Cigarette Programme” Following release of the Isabelle Committee report, the federal government considered introducing legislation to control tobacco products, including mandatory reductions on the amount of tar and nicotine that could be delivered by cigarette. This prompted the creation of a formal interdepartmental committee with three members from each of the health and agriculture departments which became known as the Interdepartmental Committee on Production of Less Hazardous Tobacco Products.31 Maurice LeClair, the Deputy Minister of Health, set out his department’s vision of several modifications to cigarettes in a memo to the Deputy Minister of Agriculture.32 He asked his colleague to assist in the achievement “low tar, low nicotine” tobaccos. [T]here appears to be no doubt that maximum tar and nicotine levels could be reduced to some extent at an early date by changes in manufacture independent of changes in tobacco. In our view it would facilitate matters if clear objectives were established and at this time we have in mind tentative maximum levels of 15.milligrams of tar and 1 milligram of nicotine per cigarette by 1975. One of the first activities of the interdepartmental is committee was to call a meeting at which representatives from the Canadian Tobacco Manufacturers' Council (the CTMC) were invited to attend. Planning notes for this committee showed very different approaches to the task among the parties who would come together at the Tunney's Pasture complex in Ottawa on May 20, 1971. Health officials contemplated working towards a wide range of measures to reduce the amount of smoke inhaled by those who continued to smoke. Some of these were aimed at altering the behaviour of the smoker – like taking fewer puffs per cigarette or leaving a longer butt.33 Others were aimed at altering the cigarette or the tobacco within it, such as reducing the levels of both tar and nicotine in cigarettes (to a maximum of 15mg of tar and 1mg of nicotine), reducing gas phase components (carbon monoxide), and addressing pesticides and additives.34 Legislative authority for many of these measures was provided in the Cigarettes Products Act, which was then under cabinet review and would be introduced the following month.35 Agriculture officials were concerned about their role in the changing regulatory environment and "having a voice in implementing policy".36 They wanted to develop a “close liaison and working 31 32 33 34 35 36 Exhibit 40344, 20706.3. Related exhibits 20694, 21230, 40284, 20687 Exhibit 40346.272. ITL List 7, Control 00167935 Exhibit 40346.272 Exhibit 20073 Exhibit 20681.2 7 relationships with the industry” 37 and to involve the industry on "the broad objective of how we can all help to reduce the tar and nicotine levels."38 As did Health Canada, they saw a role for industry funding of this research.39 The tobacco industry representatives reviewed the government’s agenda when they met to decide on a shared position. While they agreed with the health ministry's objective to reduce tar, they did not want nicotine to be managed in the same way. They felt there was "a threshold of nicotine content that must be maintained." To maintain this nicotine level while reducing tar "requires the development of tobaccos that have the inherent property of yielding reduced tar relative to nicotine."40 The minutes that were circulated following the meeting show that while there was wide agreement on health-related research, there was disagreement between the industry and health ministry about what this meant. Whereas the health ministry had been seeking a maximum level of 1 mg of nicotine per cigarette, the industry saw this as a minimum amount required. Tar reduction In acceptable to all concerned but the CTMC representatives said that industry studies showed that for some smokers, there was a tendency to change smoking patterns to obtain a minimum daily level of nicotine when they switched to low nicotine brands ... CTMC indicated that a study in England suggested a threshold level of about 1 milligram of nicotine per 41 cigarette was required to satisfy smokers. The minutes also show that Health Canada officials challenged this view in apparent disagreement. Nonetheless, the industry's suggestion to develop new varieties of tobacco that would provide more nicotine relative to tar was noted and apparently accepted. CTMC said that consideration should be given to producing high nicotine, normal tar tobaccos with the view to reducing both by filtration.... If tar levels are to be reduced to a greater extent than nicotine, there is an urgent requirement for high 42 nicotine tobacco types which could be filtered and blended to attain the objective. Agriculture Canada’s record of the discussion shows its agreement with the CTMC's perspective. We might breed a high nicotine tobacco which could be filtered and end up with a moderate level of nicotine and low tar. This would be the ideal combination. People do not want low nicotine low tar 43 combination. Only 15% of the smokers will accept such a combination. To accomplish this, the official contemplates “new and more difficult breeding objectives” for the Delhi station. 37 38 39 40 41 42 43 Exhibit 20693 Exhibit 20704 Exhibit 40347.032 http://legacy.library.ucsf.edu/tid/afo97e00 Exhibit 20706.5 Exhibit 20706.5 Exhibit 20706.2 8 After only five months the health objective of a cigarette lower in both nicotine and tar that had been proposed by Dr. LeClair had fallen by the wayside. The Agriculture Department would adopt a research agenda aimed at altering the tar and nicotine values of cigarettes, but it was one that sought to increase the amount of nicotine relative to the amount of tar. The goal posts had been moved to the position desired by the tobacco companies. Such was Dr. Hamilton’s enthusiasm for the development of the medium nicotine, low tar products favoured by the tobacco industry, but not by DNHW, that, by July 1971, he had established “The Tobacco and Health Program” at Delhi. He neither sought nor obtained the approval of DNHW for this naming venture.44 By the end of the year, a joint research program had been developed, with roles for each department and a three-year budget of $1.5 million.45 The Cigarettes Product Act which had catalyzed this initiative was introduced to Parliament in June, but it too soon fell by the wayside. By the fall of 1971 it had lost political support and would die on the Order Paper, without ever being debated. How close is too close? Differing government relationships with the industry. Throughout the 1970s, the two departments continued to have differing views, including about how – or even whether – to work with tobacco companies on issues related to health. Following the early interdepartmental committee meeting in 1972, Agriculture officials aligned their objectives to the needs of the industry. It became clear that the two government departments and industry can have a cordial, frank discussion about matters facing the tobacco industry. It was the first time that such a meeting had been formally held between government and industry. Research is the key to the needs of industry, and to a guarantee that Canadian growers will be supplying the raw products to our manufacturers years hence. He also foresaw an alignment of financing of tobacco research. I suggested that, one day, the financing of Delhi might be a joint responsibility of the four groups. [Two government departments, growers and manufacturers.] The two company representatives were keenly interested and would welcome a discussion of the subject with CDA .....never before have the [tobacco] companies been so eager to be part of a planning body and ready to put money into the kind of research 46 we do. 44 Exhibit 40332 45 ITL List 7, Control 01435435 46 Exhibit 40339 9 By August of 1972, Dr. Hamilton had invited representatives of the tobacco growers to join the Interdepartmental Committee on Production of Less Hazardous Tobacco Products.47 What began in 1970 as an initiative of DNHW was now dominated by tobacco interests. Agriculture officials gave significant weight to the desires of the cigarette manufacturers, as illustrated in a 1973 memo from the head of tobacco research: Health officials were uncomfortable with the expanded presence of the tobacco industry, as expressed by Dr. Colburn later that summer: I have expressed my concern to Department of Agriculture officials that we have moved gradually from an inter-departmental. Committee of Agriculture and Health and Welfare—with manufacturers, growers and others as invited participants when appropriate—to a situation where there are four groups--Agriculture, Health and Welfare, growers and manufacturers--as permanent committee members. The main reason for my concern is that such a group may assume that it is, or become recognized as, the official advisory committee on less hazardous tobaccos and tobacco products with a right, including the right of veto, to 48 be the final arbiter- of recommendations to the government concerning policies and legislation. The dangers of too-close collaboration with industry was also recognized by others in the health ministry. Dr. Liston observed that “Agriculture’s goals in this program are identical to those of the tobacco industry” and later “Our own interests may, however, become diametrically opposed to those of the tobacco industry since we are primarily concerned with the health aspects...”49 Despite these misgivings, the collaboration between the two ministries deepened. Late in 1972, $240,000 was transferred from health to agriculture for the construction of a smoke analysis laboratory at Delhi.50 The news release that announced the opening of the new facility on January 22, 1973, quoted both ministers, presenting a hopeful view of making cigarettes less harmful and acknowledging a role for manufacturers in the process. Through plant breeding, Canada may be able to develop a whole plant containing a much lower percentage of tar-producing constituents and nicotine than is the case in present varieties. Thus, new types of tobacco when combined with improvements in manufacturing processes such as the production of reconstituted tobacco sheet and advancements in filter design, would enable further steps 51 to be taken in producing cigarettes that would expose smokers to fewer harmful substances. The comfort level of the health ministry with industry involvement was tested a few months after the opening of the new Delhi labs when heads of the four major tobacco companies met with the Minister of Health in April 1973 to try to get his support for a joint research program into “safer” cigarettes.52 By 47 Exhibit 40336 48 Exhibit 40238 49 Exhibit 20975 50 Exhibit 20776.2 51 Exhibit 20079 52 Exhibit 20083. See related Exhibits 942A, 20088.1, 20007.4, 40346.245, 40347.101, 40347.102, 40347.103, 20083, 20084; 20085; 40346.245; 20088.1; 21087; 21085; 40240; 40241 10 the end of the year, the minister had decided this was too close for comfort. In turning down the industry’s invitation in November 1973, he echoed the misgivings of his departmental officials: The Department's independence in providing surveillance of industry products and actions and in assessing their effects on health would, in our view, be or appear to be compromised if we were to engage in such a program. Moreover, because of the nature of cigarette smoking and the overwhelming evidence that it is a serious hazard to health, the Department must maintain and be seen to maintain its position that not smoking is the desirable goal. It would be inappropriate for us to participate in an activity that might lead Canadians to doubt that cigarette smoking is still clearly seen as a major health problem or that might falsely reassure them that a safe cigarette is on the horizon, if not already here, 53 and that they may smoke confidently without fear of possible harm. The Department of Agriculture did not share these concerns, and continued to seek advice from tobacco companies when developing its research programs. The collaboration between the companies and the federal agriculture department on the “tobacco and health” research program extended beyond ideas. As an agricultural researcher noted in 1976: “The CTMC supports part of the Delhi tobacco and health program through an annual grant signed each year.”54 Keeping government departments on the same page. The differing goals of health and agriculture ministries did not go unnoticed by parliamentarians or the media. The Ottawa Citizen reported on a meeting of the House of Commons Agriculture Committee in April 1973, in which the head of agricultural research told the committee that: Tobacco to be acceptable, needs components that make it hazardous, Dr. Migicovsky said. Cigarettes containing less tar and nicotine are not as acceptable to the public as other brands containing more. In answers to questions from Roch LaSalle (Ind-Joliette) and John Wise (PC-Elgin), Dr. Migicovsky agreed that there is a conflict between the agriculture and health department on the question of tobacco. He said the health department will continue to urge people not to smoke, but the agriculture department would continue to help tobacco farmers grow better crops as long as tobacco remained a legal crop. Such 55 is the nature of a free country, he said. If people want to die early, it’s up to them. Concerns about differing departmental approaches were expressed in the fall of 1974 by Dr. Colburn to his counterparts at the agriculture department. He wondered whether the program had drifted away from seeking outcomes beneficial to public health - “whether the current ‘tobacco and health’ program is only a search for knowledge or is a focused developmental study.” The response to these concerns by his agriculture colleagues was a request for Dr. Colburn to “write a short, crisp statement on the need for the current tobacco and health program. In this statement all H & WC reservations about the program must be identified and disposed of.”56 But such a “short, crisp statement” was not forthcoming. A lengthy rationale he provided a few months later to a health 53 Exhibit 1554.13 54 Exhibit 21098 55 ITL List 8, Control 02438206 56 Exhibit 40307 11 department colleague (in February 1975), reveals both hopes for public health benefit of this line of research, as well as ambivalence about relying on tobacco companies to achieve it. There is no doubt that we are on the verge of being able to prescribe standards for less hazardous cigarettes and ways to smoke. However, this knowledge may be potentially frustrating for us since we must depend on the manufacturers’ co-operation. This requires changes in their manufacturing technology as well as their promotional activities. By means of modifications in cigarette manufacture, the use of the industry’s advertising and complementary health promotion activities by this Department, there is no doubt that we could gradually change Canadian cigarettes (to some degree imperceptibly) and the way they are used. This could result in less smoke being taken into the average smoker’s lungs. It should also be possible to introduce tobaccos whose smoke is less likely to be taken into the lungs because of more alkaline smoke. By use of smaller packages and advertising promoting less hazardous smoking, it should also be possible to 57 encourage people to cut down, throw away long butts, reduce smoke inhalation, etc. Nonetheless, the health department maintained that the Less Hazardous Cigarette Project should aim at reducing nicotine exposure. “A less hazardous cigarette is one that when used by the smoker will result in a reduced daily or weekly intake of tar, nicotine and other constituents, and which has the lowest health impact per unit of each 58 constituent.” In its response, the agriculture department maintained that nicotine not be singled out for reduction . “Prefer less hazardous cigarette definition to read ‘... of tar and other constituents ...’. (...) The definition given might prevent the promotion of a higher nicotine – low tar and CO cigarette. Many people believe 59 this cigarette type might be truly less hazardous than currently available products.” After much delay, objectives for the collaborative Less Hazardous Cigarette Program were finally produced in the form of a “Program Protocol” in December 1976.60 1.3 The objectives of the program are; (a) to establish the feasibility of producing and marketing less and less hazardous cigarettes, (b) to influence industry marketing practices and consumer smoking patterns, (c) to develop information and sources of advice to guide policy. This protocol was the basis for two subsequent meetings of industry and government collaborators, the first in January 1977 in Simcoe, Ontario61 and the second in June 1977 in Guelph, Ontario.62 Imperial Tobacco would later report that the second meeting produced little in the way of agreement. 57 Exhibit 40347.59 58 Exhibit 40348.17, pdf 2 59 Exhibit 40348.20, pdf 1 60 Exhibit 20952.1. See also Exhibits 20803.3; 40347.071, , 61 Exhibit 20803.1 62 Exhibit 40346.236. 12 As expected the agenda was too heavy and complex and no really firm decisions emerged. The first day was basically an Information Day. The second day which included "workshop" sessions produced little 63 consensus. A more scathing account of the government’s capacity to reach its goals was given by Derick Crawford, chief scientist for RJR-MacDonald: In a nutshell, I cannot think that anything was achieved other than a clear cut case being presented to Dept of H & W that it is an enormous programme to undertake, it will take a long time and will be extremely expensive. Their whole philosophy is riddled with holes, their knowledge is extremely limited, their findings to-date are minimal and do not throw any new light on the subject. They are looking for guidance from the industry which we would give if they were prepared to embark on a realistic programme. They cannot define what they term a less hazardous cigarette. They are conversant with all the published literature; they have heard of CO, acrolein, HCN, NOx etc. , they know there should be bio testing of some form, shorter butt lengths must be a good thing (!) lower tars, etc. , etc. , but putting this 64 together in a logical, meaningful, scientific and prioritized manner is seemingly beyond them. His comments on the “Tobacco and Health” research being conducted at the Delhi Research Station were equally unflattering: Delhi: Spoke on their work related to varietal trials, high plant population/whole plant chopping/sheet process and agronomic trials. In terms of varieties they stated that nothing special had come to light (as one would expect), but that they were "hopeful of a miracle". The sheet project is by now well documented after 3 or 4 years of research. The tragedy is that there is nothing really concrete coming out of it, due to inability to test adequately through shortage of funds, and poor sample production. The agronomy side was mentioned only in so far as it could affect nicotine content of the leaf and thence T&N 65 levels in the smoke. Now, the days of the Less Hazardous Cigarette Program as a four-way collaborative effort were numbered. It would end not with a bang but a whimper. By the following year, Health and Welfare Canada was reflecting on its role in the Less Hazardous Cigarette Program. In a June 1978 memo, concerns were expressed about the financial and reputational cost of a program that had produced little and the recommendation that the only aspect of the program that should be continued was the testing work conducted by the Waterloo laboratory, Labstat. What should be our role? Our role should be to continue to pressure industry to reduce the hazards associated with smoking, monitor the industry's progress and ensure that new products brought to the marketplace are less 66 hazardous than their predecessors. To do this job, the Labstat Project, in my view, is sufficient. In 1978, the Department of National Health and Welfare was substantially reorganized. The Tobacco Program was split in two and its principals, including Harold Colburn, were assigned to other nontobacco responsibilities. The Less Hazardous Cigarette Program files were passed from its former 63 Exhibit 1557 64 Exhibit 1564 65 Exhibit 1564 66 Exhibit 40348.78 13 managers to its new managers on February 9, 1979.67 The new managers would not continue the formal collaboration with the Department of Agriculture or the University of Guelph or the University of Waterloo. The Less Hazardous Cigarette Program was at an end. Labstat of Kitchener took over the smoke measurement program from the University of Waterloo, 68 and would continue smoke measurement projects for decades to come. 1980s: The continuation of Agriculture Canada’s “Tobacco and Health” program. In April 1979, Frank Marks was the Director of the Delhi Research Station. He had observed the reorganization of tobacco control work at Health and Welfare Canada and the associated substantial downgrading of collaboration with Agriculture Canada. In a report to his superior he observed that HWC had less interest in tobacco agricultural research but that the tobacco industry looked favourably on the work of Agriculture Canada. He recommended that the “Tobacco and Health Program” at the Delhi Research Station be continued. There might be no policy input from those responsible for public health, but there could be financial input from those involved in cigarette manufacturing. 4. Tobacco and Health Research T & H research seems to be in limbo in H & W and clarification of the Ag. Canada and H & W policy on the subject is needed. The impetus for T & H research has decreased greatly in recent years in the U.S. and accordingly the interest by H & W Canada has also decreased. Nevertheless Ag. Canada should maintain an input into research on health related constituents in tobacco from the points of view of decreasing hazardous constituents and increasing favourable constituents. Manufacturers would look favourably on such an approach and would likely be willing to support such research financially —i.e. transfer some of their present input into human health aspects at universities to 69 the program at Delhi. One month later, Dr. Bray (health ministry) confirmed to Mr. Marks that his department would no longer be collaborating with Agriculture Canada on less hazardous cigarettes. Frank Marks was undeterred, and decided to continue Agriculture Canada’s “Tobacco and Health Program”. The ‘less hazardous cigarette’ concept does not appear to fit well with the policies and aims of the Bureau of Drug Abuse Control and along with cuts in funding make it highly unlikely that any further financial inputs for cooperative research (H & W and Agric. Can.) will be forthcoming from H & W Canada. Such an approach towards the ‘less hazardous cigarette’ concept is understandable since H & W could not endorse any cigarette. I think the CTMC approach is that they are already producing less-hazardous cigarettes and they would have little interest in supporting research along such lines unless there was going to be H & W endorsation of products that might be generated from the project. .... 67 Exhibit 40299 68 ITL List 8, Control 00201188, ITL List 8, Control 00203353 69 Exhibit 20828.1 14 The manufacturers have in the past supported our efforts to manipulate tobacco quality through cultural practices, plant breeding, etc. and I am sure they will continue to work with us in the future. At Delhi we view Tobacco and Health Research as part of the overall research effort to improve tobacco quality and on that basis I feel sure that we could continue to cooperate effectively with cigarette manufacturers. Consequently I am proposing to my superiors that the concept of eliminating or reducing the levels of potential carcinogenic chemicals in tobacco be continued and that it be incorporated into an overall goal 70 to improve the quality of Canadian tobacco. Less tar, more nicotine Beginning in the 1970s and continuing into the 1980s, the Delhi Research Station developed new cultivars that were especially suited to Canadian growing conditions. In addition they had higher levels of nicotine and higher nicotine/tar ratios (also expressed as lower tar/nicotine ratios). The scientist mainly responsible for this work was plant geneticist Dr. Radhey Pandeya. When Dr. Bray at the health ministry heard of this research in 1981 through a presentation made by Dr. Pandeya at a statistics conference, he wrote to Frank Marks to express his concern. I was surprised to hear Dr. Pandeya state that tobacco is purchased on the basis of nicotine content and that many desirable tobacco characteristics could be enhanced by selecting for increased nicotine content. Unfortunately, time did not permit me to question him so that I would appreciate hearing your views on this point. I had been under the impression that there were serious efforts underway to breed 71 for lower tar and am disappointed that this does not seem to be the case, at least at Delhi. Dr. Marks reply of June 4 1981, confirmed that the genetic work being done was producing strains of tobacco with higher nicotine, referred to as alkaloids. Dr. Pandeya's research programs maintain genetic strains covering wide ranges of alkaloid contents (0.1 to 6.5%). The recent emphasis on higher nicotine line has mainly been due to our concern to minimize tar delivery per unit nicotine. In this respect Dr. Pandeya has been successful in transferring high nicotine genes from Nicotiana rustica in N. tabacum without affecting tar. As a matter of fact the tar has been 72 lowered while nicotine increased (in our newly released cultivars like Nordel, Delgold and Newdel). Dr. Marks also indicated that export buyers had a preference for upper leaves that were higher in nicotine. It is true that cured leaf quality of tobacco is better with ascending plant position, which also brings a better price. The total alkaloids also increase [Total alkaloids is a marker for nicotine.] with the ascending plant position. It is also true that export buyers do buy on the basis of nicotine content indirectly by 73 selecting upper primings. In the departmental tobacco newsletter that spring, Dr. Frank Marks reported: 70 Exhibit 40348.87 71 Exhibit 20862 72 Exhibit 20863 73 Exhibit 20863 15 ... our new varieties with higher nicotine content provide for even better tar/nicotine ratios. (...) We have proceeded in this direction because of the increased consumer demand for light cigarettes. The primary methods manufacturers use to produce medium and light cigarettes are filtration and paper. The relatively low tar/nicotine ratio of Canadian tobacco offers manufacturers greater flexibility in producing 74 lighter cigarettes and still maintain sufficient nicotine and flavour to satisfy consumer demands. In a 1982 document, Dr. Radhey Pandeya emphasized the importance of choosing a suitable variety of tobacco plant: Choice of a suitable cultivar precedes all cultural and management practices in maximizing crop returns…. Genetic breeding studies at Delhi were geared towards developing low TPM, low tar and low tar/nicotine ratio cultivars with higher nicotine content.” … ...it has been established that all new cultivars are higher in nicotine and lower in tar and tar/nicotine 75 ratio irrespective of nitrogen levels and topping heights. Out of the lab and into the fields The higher nicotine tobacco plants developed by Agriculture Canada were popular with both tobacco farmers and tobacco manufacturers. Growers shifted quickly to the new varieties and tobacco manufacturers eagerly purchased them. By the 1980s, the tobacco farms of Southern Ontario were producing tobacco using cultivars developed by Agriculture Canada. Surveys were regularly conducted to determine the percentage of total alkaloids (nicotine is the major alkaloid in tobacco). The following chart compares percent total alkaloids in 1984 to the same figure for the 1970s, before Canadian cultivars were used.76 74 Exhibit 40347.87, pdf 6. 75 Exhibit 40348.170 76 Exhibit 30099. Table based on values on page 1 and 11 16 Alkaloids (nicotine) in Canadian tobacco (%) 4 3.5 3 1978-79 1984 2.5 2 1.5 1 0.5 0 Sand leaves Cutter leaves Body leaves Under-tip leaves 1984 Sand leaves Cutter leaves Body leaves Under-tip leaves Tip leaves 1.80 1.96 2.53 3.45 3.79 Tip leaves Total Alkaloids % 1970-79 average 1.82 1.79 2.32 2.95 3.18 Much to the advantage of the tobacco industry, the percentage of total alkaloids, and thus percent nicotine, increased for leaves at every stalk position, with the exception of sand leaves, which stayed about the same. These leaves were not often used in the production of cigarettes, according to Frank Marks, former Director of the Delhi Research Station: And actually, quite often, the growers themselves wouldn't bother harvesting the sands because they 77 were so low in value that it wasn't worth the cost of harvesting. The Delhi Research Station prepared cigarettes and did smoke analysis in 1986, comparing the results of new cultivars (Newdel, Delgold, Candel and Nordel) to the older ones (Delhi 76, Virginia 115). In experiment 91, without exception, the newer varieties had more nicotine per cigarette and lower tar/nicotine ratios than the older varieties.78 Genetic research at Delhi produced several new cultivars with relatively higher amounts of nicotine, and lower tar/nicotine ratios. These were very attractive to the tobacco farmers and to the manufacturers who purchased their tobacco. The rate of uptake of the new varieties by tobacco farmers was very fast. 77 Trial Transcript. December 3, 2013, pdf. 120 78 Reference 30105, pdf 6. 17 In 1979, only 15% of tobacco farms grew tobacco of varieties developed at the Delhi Research Station. Just three years later in 1982, this percentage had increased to 88%.79 Differing views on health Health Canada continued to have misgivings about the high-nicotine, low tar/nicotine cultivars that were being developed. These misgivings were expressed several times, but meekly so, in internal documents that would not change the policy. In 1982, Dr. Bray of DNHW wrote: I am inclined to believe that the weight of scientific evidence favours the latter position [opposition to the introduction of low-tar, high-nicotine cigarettes] and that it would be imprudent to support the 80 manufacture of medium-nicotine, low-tar cigarettes at this time. In 1983 a draft Cabinet discussion paper was prepared by Health and Welfare found little support for tobacco control objectives in the approach of Agriculture Canada: Very little of the current work of Agriculture Canada is consistent with the objectives of protecting people 81 from the hazards of tobacco and discouraging the further spread of tobacco use. On behalf of the Health Ministry, Labstat tested the levels of toxic substances in the blood of smokers who switched from regular cigarettes to those which were made with higher-nicotine lower-tar tobacco. The results, published in 1984, found little improvement, and the study’s conclusions called into question the low-tar, medium-nicotine hypothesis.82 In this same period, Agriculture ministry officials considered that their work helped protect the health of Canadian smokers, as they outlined in a 1985 summary of achievements and “rationale for continued and sustained support”: In regards to domestic consumption, 31% of Canadians (5.9 million) smoke and therefore active R & D must be maintained to ensure product quality and safety. As an example, Canadian tobacco manufacturers can not produce cigarettes from raw materials of non-Canadian origin without compromising very seriously the current product safety standards and adding additional health risk 83 factors to the Canadian consumers. In terms of staff investment, in the mid-1980s agriculture research on tobacco was in the ascendancy among government programs; health research on tobacco was not. A staff photo of Delhi Research Station personnel in a summer 1983 Agriculture Canada report showed 57 persons; one was absent.84 At 79 Exhibit 30162 80 Exhibit 40348.103 81 Exhibit 20983A, pdf 19. 82 Exhibit 40348.62 83 Exhibit 30104 84 Exhibit 40346.246 18 the same time, the Bureau of Tobacco Control at Health and Welfare Canada was operating with 4 person-years.85 The differing policy approaches did not go unnoticed, as recorded in a report of a CBC Radio interview. The general thrust of the interviewer was to suggest that National Health and Welfare and Agriculture Canada were working at cross purposes regarding tobacco control and to document the size of the budget for tobacco control. Dr. Bray took the position that the two Departments simply have different mandates. National Health and Welfare to protect the health of Canadians, Agriculture to ensure that Canadian growers remain economically competitive on the world market. He acknowledged Agriculture’s objective of producing 86 safe food and suggested tobacco was not a safe crop, rather a twilight crop. In his testimony, Health Canada official Denis Choinière confirmed that Health Department officials had no influence on research or on cultivar development at Agriculture Canada.87 1990s: Concerns about nicotine spiking In 1994 and 1995, Canadian media were reporting on recently-discovered practices of the American tobacco industry. US tobacco company Brown & Williamson was deliberately increasing nicotine in cigarettes using super-high-nicotine tobacco, Y-1, grown in Brazil, and surreptitiously imported into the United States. This was brought to public attention by the February 1994 broadcast of this information on the ABC network program Day One. Day One was widely viewed in Canada.88 As so often happens, new developments in the United States in any sphere of activity prompt the question on all Canadian lips ‘Is the same thing happening in Canada?’ In response to media inquiries in early March, Health Canada officials revealed to the media that the question was already under review. M. Kaiserman a declaré au cours d’une interview que son ministère s’intéresse à la question depuis un an environ, parce que les niveaux de nicotine des cigarettes canadiennes n’ont pas décliné au même rythme que les niveaux de goudron. Normalement, a-t-il dit, les mesures adoptées pour réduire le taux de goudron devraient faire baisser le taux de nicotine dans des proportion semblables. “ La nicotine ne paraît pas baisser en relation directe (avec le goudron) et il semble qu’on ait ajouté de la 89 nicotine. “ Before the results of Health Canada’s study were available, the tobacco companies provided the public with reassurance that Canadian cigarettes were not spiked with nicotine. 85 List 7, Exhibit 00632094 86 List 7, Exhibit 00632094 87 Trial Transcript, June 11 2013, p. 255 88 Exhibit 20065.8838 89 Exhibit 20065.8838, see also 40346.266 19 On April 21, 1994, the CTMC issued a news release declaring: None of the manufacturers adds nicotine to any of its products to enhance nicotine levels. Nicotine occurs naturally in tobacco, but in widely varying quantities, depending on the grade of tobacco. Different grades 90 are used to produce specific blends. On the same day, Imperial Tobacco released a list of the ingredients, and emphasized that these did not include nicotine: Imperial Tobacco does not add nicotine to any of its products to enhance their nicotine levels. The nicotine content of cigarettes and fine cut tobacco products is exclusively determined by the blends of 91 tobacco in the product. July 15, 1994, Rothmans International, on behalf of its operations in all countries, issued a statement declaring that “Rothmans International has never genetically engineered tobacco to increase nicotine,” and “Rothmans International does not add ammonia to tobacco.”92 In none of these releases did the companies acknowledge that genetic engineering had been done on behalf of the companies by Agriculture Canada, or that this engineering was for the purpose of increasing the levels of nicotine and the nicotine/tar ratios in the Canadian tobacco they used to make their cigarettes. The following year, the results of the research project conducted for Health Canada were released. The study by Labstat had benefited from the collection made by the laboratory during its decades of cigarette testing done for the government. In June 1995, Health Canada released A Historical Study of Nicotine Yields of Canadian Cigarettes in Relation to the Composition and Nicotine Content of Cigarette Tobacco (1968 – 1995): Final Report (March 31, 1995).93 It confirmed that the nicotine content of the lamina portion of unburned tobacco leaf steadily increased from 1978 to 1995, and that over the same period there was a clear downward trend in the tar/nicotine ratio from 1978 to 1993. 90 Exhibit 40017 91 Exhibit 40017 92 Exhibit 1332 93 Exhibit 40346.400 20 The Canadian tobacco industry took great interest in this study in advance of its release,94 and prepared a document outlining their position that despite “slight” increase in nicotine content of leaf tobacco, “nicotine and "tar" yields in Canadian cigarettes have gone down over the past many years in keeping with the objectives of Health and Welfare Canada and the preferences of the Canadian tobacco consumer.”95 The health and agriculture ministries also prepared for the release of this report.96 The news release eventually issued by Health Canada on June 28, 1995 reported not at all on trends in tar/nicotine ratios97 Nor did it draw attention to the involvement of government in the development of higher-nicotine varieties, although this history had been identified in its internal briefing notes.98 Health Canada's message in media interviews also deflected attention from the role of government or industry in any changes to the nicotine levels in tobacco. "The data that is there suggests that in fact there is no manipulation of nicotine content in Canadian cigarettes in the processing."99 Canadian tobacco companies did not dose their tobacco with ammonia; they did not use Y-1 tobacco from Brazil. They did not need to. They had cultivars of tobacco developed at the Delhi Research Station with public money and grown on Canadian tobacco farms with more nicotine per unit of tar. 1990s: Major changes on tobacco road In 1986, the federal government was looking afresh at possible legislation to control tobacco products. This precipitated a review of government policies that supported the tobacco industry and Agriculture 94 Exhibits 883A, 883B, 883C, 883D, 883E, 883F, 883G, List 7 00979374. 95 Exhibit 808 96 Exhibits 40348.143, 40348.145, 40347.98, 40348.032, 40348.033, 40193, 40346.388, 40193, 40346.388, 40347.097, 40348.144, 40348.145, 40346.146 97 Exhibit 40193 98 Exhibit 40348.144, 40346.266 99 http://legacy.library.ucsf.edu/tid/boh01d00 21 Canada officials found themselves isolated after “All other departments had responded favourably to the Cabinet decision regarding changes in programs and regulations under their jurisdiction.”100 Pressure continued to be applied, including letters from Health Minister Jake Epp to Agriculture Minister John Wise that urged the coordinated announcement of tobacco legislation with a re-direction of Agriculture Canada’s efforts on behalf of tobacco farming: I am aware that your Department is developing programs to provide incentives and financial assistance to tobacco farmers wishing to turn from tobacco growing to alternative economic activities. I am fully supportive of your efforts in this area, and I would ask you to give consideration to making a public announcement concerning your intentions in this regard in the very near future. If you were able to make such an announcement, the Government would be seen to have a truly comprehensive approach to the 101 tobacco problem. Mr. Wise obliged by creating the Alternative Enterprise Initiative (AEI) in February 1987 and the Tobacco Transition Adjustment Initiative (TTAI) in April 1987. The former, with $15 million in funding, sought to subsidize tobacco farmers to establish other enterprises, whether in farming or not. The latter, with $30 million in initial funding (later increased to $69.5 million) was intended to permanently retire tobacco quota, while maintaining some farmers in tobacco growing. 102 (The success of these initiatives was highly qualified, according to a report of the Pan American Health Organization.103) In developing its “Action Plan” to respond to these policy changes, agriculture officials noted the health concerns, yet decided to continue research to support tobacco growing. The antismoking organizations (and Health and Welfare Canada) perceive the Agriculture Canada's tobacco R&D activities at direct odds with the objectives of another government department which 104 wishes to protect public health from the hazards of smoking. ... Above all considerations, as long as 6 million Canadians continue to smoke and consider .smoking as socially acceptable behaviour, and the political expediency remains unchanged, the Research Branch has an obligation to conduct research and development in tobacco in order to help produce and provide a quality consumer product in tobacco, similar to any other crop, and to protect the interests and welfare of 105 Canadian tobacco producers who depend on tobacco for their livelihood. The preservation of expertise and continued cooperation with the industry was promised by the Minister to the head of Imperial Tobacco. 100 List 8 03824996. 101 Exhibit 40348.114 102 Exhibit 40347.90 103 Exhibit 601-1992, p. 95 104 Exhibit 40348.31, pdf 22 105 Exhibit 40348.31, pdf 23 22 Agriculture Canada has always enjoyed a very close cooperative relationship with the Canadian Tobacco Manufacturers' Council and I want that to continue. Let me assure you also that professional positions will 106 be staffed at the Delhi Research Station and that core research programs in tobacco will be maintained. New ways would be developed to coordinate that cooperation. In 1986, a new research advisory committee, Ontario Tobacco Research Advisory Committee (ONTRAC) had been set up to give voice to the perspectives of producers, manufacturers, and provincial and federal governments (but not to health ministry representatives).107 (This was in addition to the coordination of research the Delhi Engineering and Research Group, which was funded by the tobacco growers and companies (in a 35% 65% split), but which operated within the Delhi Research Station. 108) Formal agreements were entered into between Imperial Tobacco and Agriculture Canada. In 1986 a two-year Research Agreement was reached between Imperial Tobacco and Her Majesty the Queen in Right of Canada,109 with an option to extend up to 5 years. In addition to a fixed cost of $90,000, an annual payment of $63,500 would be given to Agriculture Canada In 1992, a two-year agreement110 allowed for Imperial Tobacco to provide $165,300 to the Delhi Research Station. In 1994, a one-year agreement111 governed a contribution of $231,000 in kind and $97,500 in cash from the CTMC. Imperial Tobacco On April 13, 1994, Gary Whitfield of Agriculture and Agri-Food Canada (AAFC)wrote down the terms of a verbal agreement that had been reached on December 10, 1993 for ongoing funding of tobacco agricultural research by AAFC, an agreement that would have provided up to $6.5 million over 10 years.112 . This agreement would not come into place. Agriculture Canada was changing its policy and those working on the file recognized that “Tobacco research is a very touchy subject within Ag Can.” 113 So much so that they understated the research time spent on tobacco. Actual professional PY's for tobacco are currently at 4.7, however, records kept for the Government show 114 only 2.5 PY's (don't want to raise a red flag). In 1995, the Canadian Tobacco Research Foundation (CTRF) was established by the tobacco industry. It too was a cooperative endeavour: 106 Exhibit 30312 107 Exhibit 30111 108 Exhibit 30111; Exhibit 40346.246, pdf 21 (same as Exhibit 21274) 109 Exhibit 20244.3 110 Exhibit 20247 111 Exhibit 21301 112 Exhibit 21304 113 Exhibit 30279 114 Exhibit 30279 23 “a partnership among the Federal government, growers and manufacturers … with the mandate to operate a scientific research foundation for the purposes of facilitating and promoting agricultural 115 scientific research and development related to tobacco production in the interest of its members.” The tobacco research capacity retained by Agriculture Canada was now funded by the tobacco industry through the CTRF.116 Formal collaborative agreements between the foundation and Agriculture Canada were entered into for 1996/1997.117 The Tobacco Advisory Committee assumed the role of coordinating input from federal and provincial agriculture ministries.118 However, Agriculture Canada’s active involvement in tobacco research came to an end in 2000, when a decision was reached that “No AAFC research is being allowed to work on tobacco.”119 Related information: Agriculture Canada, tobacco growers and cigarette manufacturers Recent trends in tobacco agriculture in Canada Physicians for a Smoke-Free Canada, 2008 Backgrounder: Tobacco Transition Program Physicians for a Smoke-Free Canada, 2011 Tobacco is still being grown in Ontario Physicians for a Smoke-Free Canada, 2009 115 Exhibit 989.72 116 Exhibit 20891 117 List 8. 023228278 118 List 8, x01243918 119 Exhibit 20789 24