Down the Rabbit Hole: Tobacco Control Through Radical Nicotine Reduction

June 22 marked the one-year anniversary of the Tobacco Act, which gave the FDA regulatory authority over tobacco products. Anti-tobacco extremists like Matthew Myers were delighted: “It's remarkable what the FDA has been able to accomplish in this first year.”

But the occasion was notable for another reason, the re-emergence of the most idiotic idea ever proposed by tobacco control advocates: Force smokers to quit by reducing the nicotine content of tobacco products. The Tobacco Act permits the FDA to reduce nicotine to any level above zero, thus allowing de facto nicotine prohibition.

Nicotine prohibition has been championed in the Washington Post (read it here) and elsewhere by Dr. David Kessler, former FDA commissioner and former medical school dean at the University of California/San Francisco.

This strategy was introduced in a 1994 commentary in the New England Journal of Medicine by Dr. Neal Benowitz and Dr. Jack Henningfield, tobacco opponents who now sit on the FDA tobacco products advisory panel. An ethics watchdog group has challenged their appointments based on conflicting financial interests (read it here). Their nicotine prohibition scheme, based on several highly speculative assumptions, casts doubt on their ability to provide the FDA with sound counsel.

Benowitz and Henningfield adopted, without hard evidence, the position that smokers of five or fewer cigarettes per day, are not addicted to nicotine. They even acknowledged the weakness of their assumption, commenting: “Of course, there is no sharply demarcated threshold level, and there are some people who smoke fewer than five cigarettes per day and have great difficulty in quitting and others who can smoke more than five cigarettes per day and quit with ease.”

Building on this unscientific position, Benowitz and Henningfield opined that “an absolute limit of 0.4 to 0.5 mg of nicotine per cigarette should be adequate to prevent or limit the development of addiction in most young people.” They believed that “the level of nicotine in tobacco could be reduced gradually, with a goal of reaching a target nicotine level over perhaps 10 to 15 years.”

Benowitz and Henningfield acknowledged that reducing nicotine could harm the nation’s 45 million current smokers. “Switching from higher-yield to lower-yield cigarettes has been shown to result in smoking more cigarettes or smoking more intensively [overcompensation], both of which are associated with increased exposure to carbon monoxide and other toxins.” But they were willing to make an unacceptable compromise: “Even if there is some element of overcompensation and smokers are exposed to increased levels of toxins, their short-term (10-year) risk may be offset by the long-term benefit of a greater likelihood that they will stop smoking (as cigarettes become less satisfying) and by the enormous benefit of preventing nicotine addiction in future generations.”

This radical nicotine reduction scheme would put smokers’ lives at risk, even though Benowitz and Henningfield admitted that “a threshold level for nicotine addiction is a theoretical concept.” In their commentary, they conceded that the theory “that restricting levels of nicotine would prevent addiction needs to be verified empirically,” but they reversed course in a subsequent letter to the journal: “There is no way of empirically testing the proposition that nonsmokers would be less likely to become addicted to low-nicotine cigarettes as we define them.”

Simply put, the Benowitz-Henningfield nicotine prohibition plan is to expose current smokers to increased levels of toxins over a 10-year period, in the hope that they will stop smoking in the long term, and that children might never start. They recognize that their plan needs to be tested, yet they acknowledge that testing is impossible. It is reminiscent of an Alice in Wonderland musing, “Sometimes I believe in as many as six impossible things before breakfast.”

The FDA must not follow Benowitz and Henningfield down the rabbit hole of nicotine prohibition.