by Carl V Phillips
In a discussion group of scientists, policy-influencers, and other players in the world of THR (mostly e-cigarette) policy that I am a part of, there was a long discussion of mandatory “denicotinization” of cigarettes. As the discussion progressed, I ended up contributing an overview analysis of the whole matter that I think warrants a wider airing here. What appears below is the post I made there, though to protect the confidentiality of other contributors I referenced in the original I have deidentified them (following the Chatham House rule) and replaced their names with letters (W,X,Y); I am posting a note to the discussion group that those who want to claim credit for their contributions or to continue the debate here should jump in.
For those who may not know, the idea of forcing manufacturers to lower the nicotine content of cigarettes to make them less “addictive” has been kicking around from before the time there was much serious discussion about THR. The proponents of this arranged to have written into the Tobacco Control Act the provision that FDA can impose such mandatory reductions or ceilings, with the only limit being they cannot mandate complete removal of nicotine (which is really a meaningless caveat, since there is no practical difference between that and mandating a ceiling of a miniscule quantity nicotine — hey, it is not zero!).
The arguments in favor of such action are basically entirely captured in the sentence I used to describe it above: the assertion (based on no evidence or even a definition of addiction) that this will cause smokers to not be addicted, and thus reduce smoking. The main arguments against it include: 1. The response to lowered nicotine will be smokers consuming more cigarettes — and thus the constituents that actually make it harmful — in order to get the desired level of nicotine; this makes it the diametric opposite of real THR methods. 2. If regulated cigarettes are not satisfying, people will just turn to the black market for higher-quality (i.e., more desirable, though probably dirtier) products. Moreover, thanks to e-cigarettes making nicotine solutions widely available, smokers could just add the nicotine back in. 3. What right do those in power have to impose this illiberal prohibition (because that is clearly what it is, a prohibition of the variety of products people prefer, regardless of whether some somewhat-similar product remains legal) on people who choose to smoke? 4. There is no evidence whatsoever that this will accomplish its goal. The claims along the lines of “cigarettes will not be addictive if nicotine content is below…” can all be traced back to someone just making up that number from whole cloth.
In response to this last point, there has now actually been some research (which was the starting point for the discussion thread). The results were failure. Even in an artificial force-switching situation with volunteers who knew what they were getting into, subjects assigned to cigarettes with diminishing (over calendar time) nicotine content did not quit smoking. Indeed, as the nicotine content got lower many started cheating and using regular cigarettes. Another 21 comments followed in the thread, including from strong supporters of such a policy, strong opponents, and others, before I responded with the following:
The discussion of this topic never fails to captivate and astonish me — not in good ways. I am not sure how I could even catalogue my thoughts about it, but I wanted to at least throw out a few.
1. If someone were to mock-up a fake policy proposal to suggest that tobacco control is remarkably under-educated about ethics, human preferences and choices, social responsibility, history, and economics, I am not sure they could do a better job. This is the reason I bother to think about this train wreck in spite of the sentiment expressed previously about this mostly just being a dead-end waste of resources. These observations should be of as much interest to those in tobacco control as its critics, though the very characteristics that are illustrated here tend to be self-immunizing against such observations.
2. Though about 99% of the time someone says “precautionary principle”, they are talking about a policy or action to which it is not relevant, this is one of the rare cases where it applies. Someone is proposing a highly non-incremental change to the world; they are focused entirely on their own agenda, even though the intended social impacts — to say nothing of the possible unintended results — are huge; and there are very plausible arguments that it will create irreversible harms. The same people who have screamed “precaution!” about incremental and easily adjustable (even if not fully reversible) changes, such as the development of e-cigarettes, seem to not be at all bothered by proposing a radical untested policy that could have major irreversible negative consequences.
This is almost a picture-perfect precautionary principle application: The proponents’ position is basically “this is physically possible” + “this is not against the law” + “we predict that it could have some beneficial (for us) effect” + “those who warn about its major negative consequences cannot prove they will happen and we can tell stories in which no such harms happen” + “some people say this is unethical but we, personally, do not agree”. This is amazingly similar to the canonical precautionary principle applications like releasing a new organism into an ecosystem, damming a river, or opening the rainforest for resource extraction. Obviously any such principle is an ethical guideline — not universally accepted, and not a decision rule — but it is a pretty compelling about burden of proof: Before someone is allowed to blithely take the world down such a path, they should be forced to make a very compelling case that the benefits will happen and the bad-case consequences will not.
3. But it does not seem to even occur to tobacco controllers that they owe the world anything close to compelling evidence. This is a much more serious problem than the weakness of their evidence itself. As W noted, much of the “evidence” in support of this policy was just made-up from whole cloth. That says something bad about this policy proposal, but something even worse about the tobacco control enterprise.
Their research on the economics side of this consists of artificial studies of a handful of volunteers who are commanded to engage in a particular behavior. (And even though they have far more incentive to behave as dictated than do people in real life, apparently they did not do so — but we can even set that aside.) It somehow never occurs to them that no results of such studies can convincingly respond to such critical questions as, to take just one example of the many, “exactly why would anyone choose to smoke a cigarette that is designed to be unsatisfying in the first place?”
As for the prohibition being effective, we see tobacco prohibitionists worldwide responding to increasingly leaky prohibitions [e.g., smuggling to avoid taxes or “plain” packs, or the EU snus ban] by simply declaring that the black market does not exist. Not exactly the behavior of responsible people. (Hmm, lying about obvious facts in order to trick people into buying what you are selling for a few more years? It seems possible an enterprise would be vilified for the next half century if it were caught doing that.)
X cites the partial success in enforcing alcohol Prohibition as proof of concept, but things have changed a bit in the last hundred years: Since then humanity has invented big trucks, cargo planes, container shipping, and global organized crime networks with a lot of experience at smuggling. The latter received a huge boost thanks to Prohibition. (Tangential aside: This never occurred to me before, but perhaps a reason the limousine liberal politicos are so supportive of prohibitions is as an homage to the Kennedys.) Also, recipes for DIY renicotinization (un-de-nicotinization?) will be universally available in about five minutes, requiring only a solution of nicotine in propylene glycol (hmm, where are we going to find that?). The decriminalization of cannabis in a few jurisdictions is producing data that suggest the quantity of this other easily-shipped product was not hugely affected by criminalization. Oh, and there is the matter of alcohol Prohibition violations being easy to detect at the consumer and retail level, but detecting it for prohibition of normal cigarettes requires a lab test every time.
Or maybe the prohibition would simply inspire such a political backlash that Congress would just defund CTP as a result. There are countless plausible outcomes of doing something this.
But my point is not to present the list of all the practical considerations that need to be addressed; there are many more. Rather, I want to emphasize that in spite of the enormity of these points, tobacco controllers think it is sufficient to gather a bit of data that kinda sorta points in the direction of the hypothesis they would like to believe, and then declare it to be a fact that is sufficient for imposing radical policy. There are numerous important considerations that proponents of the policy would study and hash out in public if they were responsible and serious people. The lack of interest in serious concerns is a fundamental ethical failure, quite apart from all questions of the ethics of political philosophy.
4. The political philosophy is a separate and equally serious ethical problem. Y sketched the basics of why policies like this are generally not considered ethical in our society. But tobacco controllers generally dismiss such arguments as merely being a personal opinion, with the response, “and my personal opinion is different”. But while it is his personal view (and that of a large fraction of those who have ever given such matters serious thought), Y invoked by reference the many enshrined, accepted, established philosophical, legal, and constitutional bases for such a view [this included principles of autonomy, the work of J.S. Mill, and analogies to other behaviors that would be prohibited under such an ethic]. Tobacco controllers ignore this and consistently act as if “I personally think this is fine” is a valid ethical argument.
The infrequent but steady stream of tobacco controller writings on ethics, political philosophy, and the broader implications of their enterprise, generally leave me feeling like I am grading a freshman essays: “look at the really deep thoughts I have accumulated in my 17 years in the world, and notice that I am quoting from not one, but two, bits of intellectual writing that were not assigned reading, thus proving that I have thought of everything.”
X took the very rare step of offering an ethical argument with some substance rather than just saying something that translates into “I personally think this is ethical.” But what he argued [basically the standard argument that — my paraphrase — someone becomes more free, rather than less, if government force is used to prevent making a choice that is caused by some despicable thrall, instead mandating the “choice” of what everyone should really prefer] was a remarkably close paraphrase of “freedom is slavery.” Y also characterized it as Orwellian, though you could attribute that sentiment directly to Mao, Trotsky, Mussolini, and the various other authoritarian idealists Orwell was writing about. That does not make the sentiment wrong, of course. Every now and then, there is a situation where we agree that a bit of slavery actually improves people’s freedom, and it is accepted as ethical, and the immediate benefits are enough that it is worth the harms from making our society more Orwellian. But if that is the position you are arguing, you need to take it a lot more seriously than just declaring “this is one of those cases” and walking away. If your argument can also justify all manner of forced eugenics, you might still have a valid case to make, but it should be a clue that you have not given it sufficiently serious consideration. Consider the difficult ethical discussion that surrounds incarcerating people with truly serious psychological problems, something that is far easier to justify than the present proposal but that is still the subject of legitimate consternation and concern; keep in mind also how that power is inevitably abused.
If you want to invoke a relevant lesson from the 1920s, it is not the story of Prohibition, given the enormous physical changes to the world. It is the widespread embrace, by many in the same Western academic/intellectual circles that are behind tobacco control, of authoritarian utopias. This embrace continued until the lessons of c.1940 suggested that maybe it does not work out so well to replace liberty with the benevolent guiding hands of Homo superioris who just know how to make the proles better off. At least those ivory tower advocates for communism and fascism actually wrote about the big picture and tried to craft an argument for their position, rather than acting as if they were so clearly right that they did not have to.
5. Those who are just skimming this for nouns might think that I have descended into Godwin hyperbole. But this is serious analysis, not snark or chat room babbling that is the equivalent of those freshman essays. There is something wrong to the core about tobacco control’s relationship with scientific epistemology; this is not limited to cases where they are trying to lie about ecigs and such, but shows up throughout the enterprise. There is something wrong to the core about tobacco control’s relationship with political philosophy; they basically do not even seem aware that there is more to ethics than personal opinion about what ends justify what means. There is also a remarkable lack of understanding of history, real-world human behavior, and what people actually care about; this would unimportant if they were just practicing medicine, but a huge failure given that they are practicing social engineering.
These problems seem so core and so irreversible that I cannot see any room for someone to consider themselves part of tobacco control without implicitly endorsing them. When the core of an enterprise is this bad, there is really no room for a reformist wing. You can scoff at the denicotinizaton policy as if it were some wild outlier, but it seems to actually cut to the core of what tobacco control really is.
Tobacco harm reduction, anti-THR lies, and related topics 
The declining nic cig idea also has scant chance of working very well because tobacco controllers are myopic when it comes to the role of nicotine in the structure of smoking reward. They think nicotine is the supreme ruler over smokers, and if you get rid of that, problem solved. They forget about the psychoactive properties of tar that can also contribute to reward. But mostly, I suspect perhaps as much as half of the reward of smoking comes from non-nicotine influences. There’s taste, throat hit, social aspects, liking the sight of sinuous clouds of smoke, gives your hands something to do on a phone call, etc. that also play a role in reward. In lab experiments nicotine deprived smokers, in a completely unblinded condition, prefer to smoke a zero nicotine cigarette over a shot of nicotine given IV. If nicotine ruled so supreme NRT would work much better than it does. This is also why vaping is taking off as a substitute for smoking. It retains some of those non-nicotine aspects that people really like and find rewarding. So much so it’s not uncommon for many vapers to eventually go down to zero nicotine but continue to vape. If they did put this harebrained idea into practice my guess is they’ll force some smokers out of the game, but have far more people continuing to smoke zero nicotine cigarettes than they think. Put this together with the black market and being able to juice up your low nic cigs from time to time, and you wind up with a result that’s disappointing at best. Ditto for this recent nicotine eating bacteria treatment that’s in the early stages of development. You could only propose solutions like these if you’re ignorant of the complex reasons that motivate smokers to smoke, and you think it’s all about the nicotine. Just one more reason to throw on the existing pile of reasons why this is a bad idea.
Brilliant, brilliant essay. The only catch is that politicians, the same lot that enacted alcohol prohibition, keep falling for the specious arguments of tobacco controllers and additionally get to feel the warm glow of moral do-gooderism and the rush of a power trip every time they enact these cockamamie proposals. Neither ethics nor reason seem to have much to do with it. Alas.
Surely this experiment has been conducted in the EU? The limit (afaik) is 1mg in cigarettes. Many brands, before the limit was imposed, were around 1.3-1.4mg and more. Some brands disappeared and very low (<=0.5mg) appeared. What were the effects? Many people I spoke to were not even aware that their favourite brand had been reducing its nic content and wondered why they seemed to be smoking more.
The new Tobacco Products Directive limits Nicotine content in e-liquid to an arbitrary, I believe, 20mg. What effect will this have on vaping and cigarette uptake and use?
When vaping began in earnest, many may have found a way of topping up nicotine via vaping rather than smoking more cigarettes. These were and continue to be dual-users. This is in addition to the factors Brian Carter mentions. So there is evidence out there of what may happen by denicotinizing. Why not investigate? TC may not like the answers so better for them to rely on 'experts' who provide those answers regardless of ethical or scientific standards. A miracle study a day and that most unethical policy of denormalisation by whatever means. Deniconization works claims expert and has a study, complete with computer model, to prove it. Meanwhile in the real world all is not well.
Real answers may give some insight into what role nicotine does play in cigarette 'addiction'? What if nicotine was found not to be addictive as the tobacco execs testified? That would really put the cat amongst the pigeons. What of the so called 'Nicotine' hit? If Nicotine were really the most addictive substance on the planet, how come many Vapers easily reduce or eliminate it and still enjoy vaping, yet others dual-use?
Ignoring real word evidence and using arbitrary or underhand maneuvers, to achieve a Tobacco/Nicotine free future, could be seen as unethical although since they are apparently done 'for the greater good' they get a free pass (for the time being). It would appear that Post modern ethics are flexible depending on context. With Tobacco, anything to eliminate it is, it seems, ethical, other drugs not so much and there is, in some cases, even a debate.
I am much more interested in the meta-level analysis here than the particular proposal, which is difficult to imagine ever happening (making those who even bother to think about it a rather curious lot). But one quick reply: The levels of nicotine they are talking about are substantially lower than delivery of .5 mg.
I am nonplussed being somewhat at a loss as to how to respond.
In taking, for example ” [there is] something wrong to the core about tobacco control’s relationship with scientific epistemology”, is it an analysis involving a review of the literature to ascertain where and how often the break occurs while establishing what a break is, means and why it matters?
On the other hand, Is it an analysis of TCs World View (weltanschauung), how if differs from non-TC world views and what the implications of these differences have for policy? This might lead to an investigation of the psychology that leads to certain proposals, as evidenced in papers, conferences etc, with discussion possibly including death thought accessibility from terror management theory.
On the third hand maybe is it something else?
Understanding where the proposals come from and the relationship disconnects is a start. Explaining the wide adoption of the proposal or diluted proposal and the implications of the disconnects is yet another matter.
Although your analysis describes the series of disconnects, TC’s actions and proposals could be seen as purely tactical, as you say ‘a means [any means] to an end’. They found an approach that works and just use it. What I find difficult to understand is how this approach has been allowed to flourish in a seemingly ethical environment. What I am still unclear about is what the specific questions are that would help inform in a meaningful, easily understood way, being a little slow on the uptake.
I would say that you are way ahead of the curve, not slow. One of the annoyances of gaining greater understanding of something is that you end up with a longer list of things you realize you do not understand than you had back when you knew very little.
I also am at a bit of a loss of where to start on this. Yes, it could all be explained as tactics, just taking the goals as the target and treating motivation and belief as a black box. However, you cannot really get to a situation of unified tactical action by individual humans in the absence of a command structure, unless you have created a weltanschauung, or one might even say created a hive-mind. That is Cult Brainwashing 101.
The question seems to be to be whether this is more Lord of the Flies or more Islamic State. That is, you could reasonably argue that the situation is created by primitive human tendencies toward tribal polarization and warfare that just come out when a culture lacks adult supervision, as it were. Or you could argue that it is primarily a manipulation by organizers who know exactly what they are doing, taking advantage of the urge many people have to add structure to their lives by being a part of something simplistic and extremist. There is a case to be made either way (or some of each). 20 years ago, tobacco control still had a superego (just to throw in yet another soc/psych organizing metaphor :-), made up of the decent and serious people who started the whole movement. Now it is almost pure id. But there still are a few puppet masters in the mix.
On the issue of characterizing their break from valid epistemology, I cannot even fathom what it would take to do a systematic study of that. I have been doing a nonsystematic study of tobacco control and surrounding sciences for most of my career, and I have the particular skills and background to make sense of it, so I am probably closer to the question than anyone else (a scary thought). I write on this point all the time, of course. But systematizing it…? Yikes.
Some partial systematic observations permeate my writings, of course. The one I emphasized here was the tendency to use research (or “research”) entirely to try to find some thread of support for their pre-established political goals, rather than ever using it to try to find out the truth. That is, when they are not totally disconnecting their political recommendations from the research, tacking them on as completely unrelated tangents. You can drill down into this to observe that they never seek to seriously test their claims using their data, even when they can.
“Or maybe the prohibition would simply inspire such a political backlash that Congress would just defund CTP as a result.”
That would be an excellent thing! All that wasted money, re-allocated to something actually worthwhile! And non-fascist!
Basically, we need to just GET RID OF TOBACCO CONTROL ABSOLUTELY. Whatever it takes — jail, public shame and humiliation, even the death penalty for Crimes Against Humanity. They deserve ALL of that.
How do they get away with publicly calling BT deadly liars for the last time they introduced lite cigs (that time AT THE REQUEST of tobacco control) while proposing to *mandate* they repeat the performance? Why hasn’t everybody laughed them out of the room? Or lost their lunch all over their shoes?
It is quite remarkable how the tobacco controllers have gotten away with rewriting history, convincing everyone that they were not somewhere between complicit in and fully responsible for the lites fail. It is one of many examples of how they managed to convince most everyone to accept a blatant falsehood as the truth, and then move on from there to build their next falsehood. Orwell is exactly the right reference.
How many people even know what epistemology is? I use logic and set theory to spot the lies mostly, because epistemology would have me deny my personal religion and experience. And history is trivial to twist, ask any ethnic group who ever lost. But claiming that lites and ultra-lites were a horrible fraud while demanding ultra-lites be *mandated* is a contradiction my 5-1/2-year-old grandson would catch and call someone out on.
Epistemology is, of course, basically just serious thinking about how we know stuff. And how we know that we know stuff. And wondering if we really do know stuff. Stuff like that.
The real difference between those two stories is basically that lites were something consumers still liked that did not happen to have much health benefit. The denicotinized cigarettes would be something consumers don’t like that will probably not have much benefit at all. But tobacco controllers don’t like consumers, so making them unhappy is reason enough for them.
Tens of millions (perhaps a hundred million) of US taxpayer dollars by DHHS (mostly by NIH activist staffers) have been wasted studying denicotinized cigarettes and advocating a FDA regulation to denicotinize since 1994 when Big Pharma financed Benowitz and Henningfield proposed the absurd idea (to basically ban cigarettes and create a new nicotine cartel controlled by Big Pharma and regulated by FDA).
As one who was actively urging FDA Cmsnr Kessler and his Deputy Cmsnr Mitch Zeller to focus their yet-to-be-proposed FDA tobacco regulations on stopping tobacco marketing to youth, I was shocked by Benowitz and Henningfield’s proposal, and I helped convince Kessler and Zeller to prevent it from being included in their FDA tobacco regulation (that was proposed in 1995, finalized in 1996, and struck down by SCOTUS in 2000).
Unfortunately, the nicotine prohibitionists (who want mandatory denicotinized cigarettes) have had many friends at DHHS (especially since many nicotine prohibitionists are career employees at DHHS), and have given lots of money to continue studying and advocating that outrageous policy).
Would be helpful to expose how much money DHHS bureaucrats funded researchers (especially Benowitz) to study and promote that craziness (and other DHHS funded policies that were originally lobbied for by Big Pharma shills, and which were then adopted and aggressively funded by DHHS).
I thought all serious discussion about this absurd idea ended a decade ago after Vector (formerly Liggett) coopted that reduced nicotine regulatory/prohibition strategy as a big marketing plan for it Quest 1, Quest II and Quest III cigarette brand (with Quest 1 resembling a typical low tar cig, Quest II having less nicotine, and Quest III having very low nicotine). After running full page ads in newspapers (I still have them) and heavily marketing this nicotine reduction concept, Vector’s halted its six state test market, and pulled the Quest brand line from the market (because nobody bought a second pack of Quest II or Quest III, and not many bought a second pack of Quest I).
Yes, this would definitely be a good “follow the money” target. Probably not worth the effort unless someone starts seriously proposing it, though.
In fairness to the proponents of this madness, it is theoretically possible that these products would do what is claimed and intended (or claimed to be intended) in the presence of prohibition of other products. Thus the failure of Quest and even the failure of the stupid clinical trial they just did do not prove this will fail. Of course, most of us agree it would almost certainly fail — I am just saying those bits of evidence are not sufficient for that conclusion, which is mostly a based on common sense. The real key is that given how unlikely their claimed scenario seems, they are ethically obliged to produce some very strong evidence that the common sense is wrong, and they are not even attempting to do so. It does not even occur to them that they owe that to the world.
Correction on my post above. In 1994, Jack Henningfield worked at NIDA.
He didn’t begin consulting for GlaxoSmithKline (via Pinney Assoc) until after he left NIDA in the early 2000’s around the same time Mitch Zeller began lobbying for GSK (via Pinney Assoc).
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