Problems with the Tobacco Products Scientific Advisory Committee (TPSAC) List of Harmful or Potentially Harmful Tobacco and/or Tobacco Smoke Components

The draft initial list of harmful or potentially harmful tobacco and/or smoke components prepared by the Constituent Subcommittee of the Tobacco Products Scientific Advisory Committee (TPSAC) differs significantly from the similar lists prepared by Hoffmann and colleagues who had over four decades of experience and knowledge in tobacco and/or tobacco smoke components and their chemical and biological properties. The draft list comprises 106 components, 60 of which were included in the recent Hoffmann et al. lists but does not include nine of the Hoffmann-listed components. All of the 106 components appear in a list by Rodgman and Green of 162 tobacco and/or tobacco smoke components, each of which was defined as biologically adverse at one time or another over the previous years by one or more investigators. As with the Hoffmann et al. lists, the list by the TPSAC Constituent Subcommittee contains numerous anomalies.

· Three harmful components (dibenz[a, j]acridine, dibenz[a, h]acridine, 7H-dibenzo[c, g]carbazole) first reported in tobacco smoke in the 1960s that were not confirmed over the next forty years by many talented investigators in Japan, Germany, and the USA, including several at the U.S. Department of Agriculture (USDA).

· Two harmful components (arsenic, N-nitrosodiethanolamine) the levels of which have decreased significantly because their precursors have not been used in tobacco agronomy for over three decades.

· The many water-soluble components that reach the lung at a much reduced level to exert their ciliastasis.

· A component (chrysene) that the International Agency for Research on Cancer (IARC) has removed from its tumorigenicity listing, a decision accepted by Hoffmann et al. who removed chrysene from their more recent tobacco/tobacco smoke listings of adverse components.

TPSAC gives no indication of the following:

· The relationship between the per cigarette delivery of some of the harmful components and their level of permissibility by Occupational Safety & Health Administration (OSHA).

· The components on its list that significantly offset the adverse biological activity of several others of its listed components.

· Many components in tobacco and/or tobacco smoke not listed by TPSAC have been reported to significantly reduce the adverse biological effect of several components on the TPSAC list plus several others.