Understanding Philip Morris's pursuit of US government regulation of tobacco

Objective: To investigate Philip Morris's support of US Food and Drug Administration (FDA) regulation of tobacco products and analyse its relationship to the company's image enhancement strategies.

Data sources: Internal Philip Morris documents released as part of the Master Settlement Agreement.

Methods: Searches of the Legacy Tobacco Documents Library (http://legacy.library.ucsf.edu) beginning with such terms as "FDA" and "regulatory strategy" and expanding to include relevant new terms.

Results: Philip Morris's support for government regulation of tobacco is part of a broader effort to address its negative public image, which has a damaging impact on the company's stock price, political influence, and employee morale. Through regulation, the company seeks to enhance its legitimacy, redefine itself as socially responsible, and alter the litigation environment. Whereas health advocates frame tobacco use as a public health policy issue, Philip Morris's regulatory efforts focus on framing tobacco use as an individual choice by informed adults to use a risky product. This framing allows Philip Morris to portray itself as a reasonable and responsible manufacturer and marketer of risky products.

Conclusions: Philip Morris's ability to improve its image through support of FDA regulation may undermine tobacco control efforts aimed at delegitimising the tobacco industry. It may also create the impression that Philip Morris's products are being made safer and ultimately protect the company from litigation. While strong regulation of tobacco products and promotion remain critical public health goals, previous experiences with tobacco regulation show that caution may be warranted.

     

The Living Tomorrow Project: how Philip Morris has used a Belgian tourist attraction to promote ventilation approaches to the control of second hand smoke

Study objective: To examine the involvement of Philip Morris in Living Tomorrow 2 and determine the rationale behind its involvement.

Design: Research was conducted through a web based search of internal tobacco industry documents made publicly available through litigation.

Main results: For approximately €1 000 000 Philip Morris (now Altria) became a co-initiator of Living Tomorrow 2, a tourist complex in Belgium that aims to demonstrate how we will be living in the future. In addition to promoting the company and its grocery products, Philip Morris is using the complex and its website to promote ventilation as a means of accommodating smokers and non-smokers in the indoor environment. Particular emphasis was placed on the bar and restaurant areas. Despite the rationale for its involvement, Philip Morris fails to acknowledge its role as a cigarette manufacturer. As a form of corporate sponsorship Philip Morris thought its involvement could evade any European tobacco advertising ban.

Conclusions: Philip Morris is using a tourist attraction to promote its views on control of second hand smoke (SHS) and accommodation of smokers and non-smokers in the indoor environment. However, ventilation does not deal with the health effects of SHS. Policymakers must be cognisant of the devious tactics the industry employs to promote its own agenda, especially in relation to indoor air quality and smoking in public places. Tobacco control legislation should be continually modified and strengthened in response to the changing activities of the tobacco industry as it strives to evade existing legislation and deter the advent of new legislation.

     

How Philip Morris unlocked the Japanese cigarette market: lessons for global tobacco control

Background: The Framework Convention on Tobacco Control includes tobacco advertising restrictions that are strongly opposed by the tobacco industry. Marketing strategies used by transnational tobacco companies to open the Japanese market in the absence of such restrictions are described.

Methods: Analysis of internal company documents.

Findings: Between 1982 and 1987 transnational tobacco companies influenced the Japanese government through the US Trade Representative to open distribution networks and eliminate advertising restrictions. US cigarette exports to Japan increased 10-fold between 1985 and 1996. Television advertising was central to opening the market by projecting a popular image (despite a small actual market share) to attract existing smokers, combined with hero-centred advertisements to attract new smokers. Philip Morris's campaigns featured Hollywood movie personalities popular with young men, including James Coburn, Pierce Brosnan, Roger Moore, and Charlie Sheen. Event sponsorships allowed television access despite restrictions. When reinstatement of television restrictions was threatened in the late 1980s, Philip Morris more than doubled its television advertising budget and increased sponsorship of televised events. By adopting voluntary advertising standards, transnational companies delayed a television advertising ban for over a decade.

Conclusions: Television image advertising was important to establish a market, and it has been enhanced using Hollywood personalities. Television advertising bans are essential measures to prevent industry penetration of new markets, and are less effective without concurrent limits on sponsorship and promotion. Comprehensive advertising restrictions, as included in the Framework Convention for Tobacco Control, are vital for countries where transnational tobacco companies have yet to penetrate the market.

     

Tobacco industry strategies to undermine the 8th World Conference on Tobacco or Health

Objective: To demonstrate that Philip Morris and British American Tobacco Company attempted to initiate a wide ranging campaign to undermine the success of the 8th World Conference on Tobacco or Health held in Buenos Aires, Argentina, in 1992.

Data sources: Publicly available tobacco industry documents housed in Minneapolis, Minnesota, USA; Guilford, UK; on-line document websites; and telephone interviews with informed parties.

Study selection: Those documents determined to be relevant to the companies' campaigns against the 8th World Conference on Tobacco or Health.

Data extraction: Revision of chapter VIII of the July 2000 WHO report by a committee of experts, entitled: Tobacco company strategies to undermine tobacco control activities at the World Health Organization: report of the committee of experts on tobacco industry documents.

Data synthesis: Internal documents describe proposed media and science orientated campaigns developed by BAT, Philip Morris, and their consultants to divert attention away from the conference.

Results and conclusion: This work shows that the tobacco industry has the resources and vested interest to combat perceived threats in its regional operating markets, in this case its Latin American market. It is important for the worldwide public heath community to become aware of the numerous ways in which the tobacco industry and its front groups can work against international tobacco control meetings, even including the manipulation of or working with other public health groups to oppose tobacco control efforts. Future world conference planners and participants should be aware that the tobacco industry is likely to continue to employ such methodology. There is no reason to think that the industry is paying less attention to such conferences in the present or future. Rather, it is likely the industry will adopt and expand strategies that were successful while abandoning those that were not effective. Required disclosure of financial support by all participants at all tobacco scientific conferences is recommended. For the tobacco control community, we also recommend careful coalition building and networking with other public health groups on the ways tobacco is implicated in other public health issues.

     

The Virginia Slims identity crisis: an inside look at tobacco industry marketing to women

Objectives: Because no prior studies have comprehensively analysed previously secret tobacco industry documents describing marketing female brands, the Virginia Slims brand was studied to explore how Philip Morris and competitors develop and adapt promotional campaigns targeting women.

Methods: Analysis of previously secret tobacco industry documents. The majority of the documents used were from Philip Morris.

Results: The key to Virginia Slims advertising was creating an aspirational image which women associated with the brand. Virginia Slims co-opted women's liberation slogans to build a modern female image from 1968 through to the 1980s, and its market share grew from 0.24% to 3.16% during that time period. Ironically, the feminist image that worked very well for the brand was also the reason for its subsequent problems. Philip Morris experienced unprecedented losses in market share in the early 1990s, with a decline in market share for four consecutive years from 3.16% to 2.26%; they attributed this decline to both the fact that the brand's feminist image no longer appealed to young women aged 18–24 years, and increased competition from more contemporary and lower priced competitors. Throughout the 1990s, attempts to reacquire young women while retaining Virginia Slims loyal (now older) smokers were made using a "King Size" line extension, new slogans, and loyalty building promotions.

Conclusions: Tobacco advertisers initially created distinct female brands with aspirational images; continued appeal to young women was critical for long term growth. The need for established brands to evolve to maintain relevance to young women creates an opportunity for tobacco counter-marketing, which should undermine tobacco brand imagery and promote aspirational smoke-free lifestyle images. Young women age 18–24 are extremely valuable to the tobacco industry and should be a focus for tobacco control programmes.

     

Public health foundations and the tobacco industry: lessons from Minnesota

Objective: To investigate whether private foundations can be created in a way that will insulate them from attacks by the tobacco industry, using the Minnesota Partnership for Action Against Tobacco (MPAAT) as a case study.

Design: Information was collected from internal tobacco industry documents, court documents, newspapers, and interviews with health advocates and elected officials.

Results: The creation of MPAAT as an independent foundation did not insulate it from attacks by tobacco industry allies. During 2001–2002, MPAAT was repeatedly attacked by Attorney General Mike Hatch and major media, using standard tobacco industry rhetoric. This strategy of attack and demands for information were reminiscent of previous attacks on Minnesota's Plan for Nonsmoking and Health and the American Stop Smoking Intervention Study (ASSIST). MPAAT was ultimately forced to restructure its programme to abandon effective community norm change interventions around smoke-free policies and replace them with less effective individual cessation interventions. Neither MPAAT nor other health advocates mounted an effective public response to these attacks, instead relying on the insider strategy of responding in court.

Conclusion: It is not possible to avoid attacks by the tobacco industry or its political allies. Like programmes administered by government agencies, tobacco control foundations must be prepared for these attacks, including a proactive plan to educate the public about the principles of community based tobacco control. Public health advocates also need to be willing to take prompt action to defend these programmes and hold public officials who attack tobacco control programmes accountable for their actions.

     

Development and destruction of the first state funded anti-smoking campaign in the USA

Background: Minnesota was the first state in the USA to implement a large state funded tobacco control programme (in 1985). Despite evidence of effectiveness, it was dismantled in 1993.

Objective: To describe and analyse how and why these events transpired and identify lessons for tobacco control advocates facing similar challenges in the 21st century.

Design: Case study based on previously secret tobacco industry documents, news reports, research reports, official documents, and interviews with health advocates and state government officials.

Results: Unable to defeat funding for this campaign in 1985, the tobacco industry organised groups which eliminated it later. Despite the programme's documented effectiveness, it was dismantled based on claims of fiscal crisis. These claims were not true; the real debate was what to do with the state's surplus. Health advocates failed to challenge the claim of fiscal crisis or mobilise public support for the programme.

Conclusions: Simply quoting evidence that a tobacco control programme is effective does not ensure its continuing survival. Claims of fiscal crisis are an effective cover for tobacco industry efforts to dismantle successful programmes, particularly if health advocates accept these claims and fail to mobilise political pressure to defend the programme.

     

Tobacco industry litigation to deter local public health ordinances: the industry usually loses in court

Background: The tobacco industry uses claims of state preemption or violations of the US Constitution in litigation to overturn local tobacco control ordinances.

Methods: Collection of lawsuits filed or threatened against local governments in the USA; review of previously secret tobacco industry documents; interviews with key informants.

Results: The industry is most likely to prevail when a court holds that there is explicit preemption language by the state legislature to exclusively regulate tobacco. The industry has a much weaker record on claims of implied preemption and has lost all challenges brought under equal protection claims in the cases we located. Although the tobacco industry is willing to spend substantial amounts of money on these lawsuits, it never won on constitutional equal protection grounds and lost or dropped 60% (16/27) of the cases it brought claiming implied state preemption.

Conclusions: Municipalities should continue to pass ordinances and be prepared to defend them against claims of implied preemption or on constitutional grounds. If the ordinance is properly prepared they will likely prevail. Health advocates should be prepared to assist in this process.

     

The perimetric boycott: a tool for tobacco control advocacy

Objectives: To propose criteria to help advocates: (1) determine when tobacco related boycotts may be useful; (2) select appropriate targets; and (3) predict and measure boycott success. Methods: Analysis of tobacco focused boycotts retrieved from internal tobacco industry documents websites and other scholarship on boycotts. Results: Tobacco related boycotts may be characterised by boycott target and reason undertaken. Most boycotts targeted the industry itself and were called for political or economic reasons unrelated to tobacco disease, often resulting in settlements that gave the industry marketing and public relations advantages. Even a lengthy health focused boycott of tobacco industry food subsidiaries accomplished little, making demands the industry was unlikely to meet. In contrast, a perimetric boycott (targeting institutions at the perimeter of the core target) of an organisation that was taking tobacco money mobilised its constituency and convinced the organisation to end the practice. Conclusions: Direct boycotts of the industry have rarely advanced tobacco control. Perimetric boycotts of industry allies offer advocates a promising tool for further marginalising the industry. Successful boycotts include a focus on the public health consequences of tobacco use; an accessible point of pressure; a mutual interest between the target and the boycotters; realistic goals; and clear and measurable demands.     

A comparison of US and Norwegian regulation of coumarin in tobacco products

Objective: This paper examines policy processes regarding why the USA and Norway have not regulated coumarin in tobacco.

Design: A qualitative analysis of all tobacco industry documents regarding coumarin since the 1950s from the 1998 US Master Settlement Agreement and subsequent legal settlements. Additional data were collected from newspaper reports, general internet search engines, journal articles, scholarly reports, court cases, statutes, regulations, and informal correspondence with tobacco control experts in Norway.

Main outcome measure: An overview, summary, and analysis of all documents related to coumarin.

Results: In the USA from 1954 until 1985 when coumarin was reportedly removed from domestic cigarettes, but not from pipe tobacco until 1996, and not at all from imported Indian bidi cigarettes, regulatory efforts were stymied. In Norway, from 1973 to the present, the tobacco industry has never disclosed whether its tobacco products contain coumarin. In both the USA and Norway, the extreme delay and lack of vigorous evidence gathering and significant remedies were caused by tobacco industry assertions that revealing tobacco additives was a violation of trade secrets, and by weak regulatory authority and efforts to regulate coumarin.

Conclusion: Vigorous and expeditious regulatory investigations and remedies for harmful additives in tobacco, such as coumarin, can protect the public health. Astute insider and outsider political advocacy by health advocates is required to hold elected officials and civil servants publicly accountable for failing to enact disclosure laws and to engage in effective regulatory efforts.

     

Philip Morris'' new scientific initiative: an analysis

In the fall of 2000, Philip Morris re-initiated an external research grants programme ("Philip Morris External Research Program", or PMERP), the first since the dissolution of the Council for Tobacco Research (CTR) and the Center for Indoor Air Research (CIAR). The ostensible purpose of the programme is to help develop cigarette designs "that might reduce the health risk of smoking". Internal company documents also indicate that Philip Morris urgently seeks to restore its scientific "credibility", as part of a "new openness" in relation to the external community. The structure of the review panel--a cohort of external peer reviewers, a science advisory board, and an internal, anonymous review and approvals committee--is nearly identical to that of the CIAR. The majority of the named reviewers have had previous affiliation with the tobacco industry either as reviewers or grantees, but only a minority have done research directly on tobacco or smoking. The programmatic substance of the PMERP could be interpreted as soliciting exculpatory evidence with respect to smoking and exposure to smoke. We remain sceptical about the scientific integrity of PMERP.     

Philanthropy, politics and promotion: Philip Morris' "charitable contributions" in Thailand

The efforts of members of the tobacco industry to portray themselves as responsible corporations via ostensible commitment to improved labour practices and public philanthropy have attracted growing criticism. This is particularly true of corporate social responsibility (CSR) schemes undertaken in emerging nations that are designed to rehabilitate the tobacco industry's image among public, government and market opinions in North America and western Europe. In the case of Thailand, sponsorship of arts events and community groups has been one avenue of promoting the industry in a regulatory environment that severely curtails promotion and advertising. The Association of Southeast Asian Nations (ASEAN) Art Award, sponsored by Philip Morris (PM) has provided one such outlet for 10 years. Analysis of PM funding announcements since the end of the ASEAN art programme in Thailand reveals that recent donations to tobacco-related community organisations reinforces the extent to which seemingly generous acts are driven by corporate self-interest rather than social responsibility.     

What the public thinks about the tobacco industry and its products

Objectives: To assess public attitudes toward the tobacco industry and its products, and to identify predictors of attitudes supportive of tobacco industry denormalisation.

Design: Population based, cross sectional survey.

Setting: Ontario, Canada.

Subjects: Adult population (n = 1607).

Main outcome measures: Eight different facets of tobacco industry denormalisation were assessed. A denormalisation scale was developed to examine predictors of attitudes supportive of tobacco industry denormalisation, using bivariate and multivariate analyses.

Results: Attitudes to the eight facets of tobacco industry denormalisation varied widely. More than half of the respondents supported regulating tobacco as a hazardous product, fining the tobacco industry for earnings from underage smoking, and suing tobacco companies for health care costs caused by tobacco. Majorities also thought that the tobacco industry is dishonest and that cigarettes are too dangerous to be sold at all. Fewer than half of the respondents thought that the tobacco industry is mostly or completely responsible for the health problems smokers have because of smoking and that tobacco companies should be sued for taxes lost from smuggling. In particular, less than a quarter thought that the tobacco industry is most responsible for young people starting to smoke. Non-smoking, knowledge about health effects caused by tobacco, and support for the role of government in health promotion were independent predictors of support for tobacco industry denormalisation.

Conclusions: Although Ontarians are ambivalent toward tobacco industry denormalisation, they are supportive of some measures. Mass media programmes aimed at increasing support for tobacco industry denormalisation and continued monitoring of public attitudes toward this strategy are needed.

     

Fiscal versus social responsibility: how Philip Morris shaped the public funds divestment debate

Calls for institutional investors to divest (sell off) tobacco stocks threaten the industry's share values, publicise its bad behaviour, and label it as a politically unacceptable ally. US tobacco control advocates began urging government investment and pension funds to divest as a matter of responsible social policy in 1990. Following the initiation of Medicaid recovery lawsuits in 1994, advocates highlighted the contradictions between state justice departments suing the industry, and state health departments expanding tobacco control programmes, while state treasurers invested in tobacco companies. Philip Morris (PM), the most exposed US company, led the divestment opposition, consistently framing the issue as one of responsible fiscal policy. It insisted that funds had to be managed for the exclusive interest of beneficiaries, not the public at large, and for high share returns above all. This paper uses tobacco industry documents to show how PM sought to frame both the rhetorical contents and the legal contexts of the divestment debate. While tobacco stock divestment was eventually limited to only seven (but highly visible) states, US advocates focused public attention on the issue in at least 18 others plus various local jurisdictions. This added to ongoing, effective campaigns to denormalise and delegitimise the tobacco industry, dividing it from key allies. Divestment as a delegitimisation tool could have both advantages and disadvantages as a tobacco control strategy in other countries.     

Philip Morris's Project Sunrise: weakening tobacco control by working with it

Objective

To analyse the implications of Philip Morris USA''s (PM''s) overtures toward tobacco control and other public health organisations, 1995–2006.

Data sources

Internal PM documents made available through multi‐state US attorneys general lawsuits and other cases, and newspaper sources.

Methods

Documents were retrieved from several industry documents websites and analysed using a case study approach.

Results

PM''s Project Sunrise, initiated in 1995 and proposed to continue through 2006, was a long‐term plan to address tobacco industry delegitimisation and ensure the social acceptability of smoking and of the company itself. Project Sunrise laid out an explicit divide‐and‐conquer strategy against the tobacco control movement, proposing the establishment of relationships with PM‐identified “moderate” tobacco control individuals and organisations and the marginalisation of others. PM planned to use “carefully orchestrated efforts” to exploit existing differences of opinion within tobacco control, weakening its opponents by working with them. PM also planned to thwart tobacco industry delegitimisation by repositioning itself as “responsible”. We present evidence that these plans were implemented.

Conclusion

Sunrise exposes differences within the tobacco control movement that should be further discussed. The goal should not be consensus, but a better understanding of tensions within the movement. As the successes of the last 25 years embolden advocates to think beyond passage of the next clean indoor air policy or funding of the next cessation programme, movement philosophical differences may become more important. If tobacco control advocates are not ready to address them, Project Sunrise suggests that Philip Morris is ready to exploit them.     

Young adults' opinions of Philip Morris and its television advertising

OBJECTIVE: To determine what young people think about the tobacco company Philip Morris and how it affects their evaluations of the company's new television advertising. DESIGN: Data were gathered in the context of a controlled experiment in which participants saw four Philip Morris ads about youth smoking prevention, four Philip Morris ads about charitable works, or four Anheuser-Busch ads about preventing underage drinking (the control group). Knowledge and opinion of Philip Morris were measured before ad exposure. SETTING: A California state university in the San Francisco Bay area. SUBJECTS: A convenience sample of undergraduates (n = 218) aged 18-25 years. MAIN OUTCOME MEASURES: Advertising evaluation measured by 12 semantic differential scales. RESULTS: A little more than half of the students knew that Philip Morris is a tobacco company. Neither this knowledge nor students' smoking status was related to their opinion of the company. Philip Morris ads were rated less favourably by students who were aware that the sponsor is a tobacco company than by students who were unaware. CONCLUSIONS: Advertisements designed to discredit the tobacco industry typically avoid references to specific companies. This study suggests that such counter-advertising would benefit from teaching audiences about the industry's corporate identities.     

Tobacco control implications of the first European product liability suit

Objective: To examine tobacco control implication of the first European product liability suit in Finland.

Methods: Systematic search of internal tobacco industry documents available on the internet and at the British American Tobacco Guildford Depository.

Results: Despite legal loss, the litigation contributed to subsequent tobacco control legislation in Finland. The proceedings revealed that the industry had concealed the health hazards of its products and, despite indisputable evidence, continued to deny them. The positions taken by the industry rocked its reliability as a social actor and thus weakened its chances of influencing tobacco policy. Despite fierce opposition from the tobacco industry, tobacco products were included in the product liability legislation, tobacco was entered on the Finnish list of carcinogens, and an extensive Tobacco Act was passed in Parliament.

Conclusions: Tobacco litigation might not stand alone as a tool for public health policymaking but it may well stimulate national debate over the role of smoking in society and influence the policy agenda.

     

Tobacco industry strategy to undermine tobacco control in Finland

Objective: To identify and explain tobacco industry strategy in undermining tobacco control measures in Finland and results of these interferences in tobacco policy development during the 1980s and early 1990s.

Methods: Tobacco industry documents, which have been publicly available on the internet as a result of litigation in the USA, were analysed. Documents were sought by Finland and by names of organisations and tobacco control activists. Documents were accessed and assessed between September 2000 and November 2002. Tactics of the tobacco industry activities were categorised as presented by Saloojee and Dagli.

Results: The international tobacco companies utilised similar strategies in Finland as in other industrial markets to fight tobacco control and legislation, the health advocacy movement, and litigation. These activities slowed down the development and implementation of the Tobacco Act in Finland. However, despite the extensive pressure, the industry was not able to prevent the most progressive tobacco legislation in Europe from being passed and coming into force in Finland in 1977 and in 1995.

Conclusion: Denying the health hazards caused by tobacco—despite indisputable scientific evidence—decreased the credibility of the tobacco industry. Strategy of denial was falsely chosen, as health advocacy groups were active both in society and the parliamentary system. The strong influence of the tobacco industry may have in fact increased the visibility of tobacco control in Finland as the litigation process was also drawing attention to negative health effects of tobacco. Therefore the tobacco industry did not manage to convince public opinion. However, the tobacco industry did obtain experience in Finland in how to object to tobacco control measures.

     

How Philip Morris built Marlboro into a global brand for young adults: implications for international tobacco control

Objective: To describe Philip Morris'' global market research and international promotional strategies targeting young adults. Methods: : Analysis of previously secret tobacco industry documents. Results: Philip Morris pursued standardised market research and strategic marketing plans in different regions throughout the world using research on young adults with three principle foci: lifestyle/psychographic research, brand studies, and advertising/communication effectiveness. Philip Morris identified core similarities in the lifestyles and needs of young consumers worldwide, such as independence, hedonism, freedom, and comfort. In the early 1990s Philip Morris adopted standardised global marketing efforts, creating a central advertising production bank and guidelines for brand images and promotions, but allowing regional managers to create regionally appropriate individual advertisements. Conclusions: Values and lifestyles play a central role in the global marketing of tobacco to young adults. Worldwide counter marketing initiatives, coupled with strong, coherent global marketing policies such as the Framework Convention on Tobacco Control, are needed to break associations between young adult values and tobacco brands. As globalisation promotes the homogenisation of values and lifestyles, tobacco control messages that resonate with young adults in one part of the world may appeal to young adults in other countries. Successful tobacco control messages that appeal to young people, such as industry denormalisation, may be expanded globally with appropriate tailoring to appeal to regional values.     

A strategy for controlling the marketing of tobacco products: a regulated market model

Objective: To outline a novel strategy for controlling the tobacco market.

Arguments: More comprehensive controls over the tobacco market are essential and long overdue. Effective controls need to encourage the development of less harmful products; control commercial communication to ensure that potential harms are highlighted relative to any benefits; and provide mechanisms to move consumers away from tobacco use, or at least towards less harmful alternatives. Achieving this by regulating the existing industry is one strategy. This paper puts the case for an alternative: to have marketing controlled by an agency (called here the Tobacco Products Agency, or TPA) which tendered to manufacturers for product and which distributed to retailers in ways that reduce incentives to bend or break the law. The TPA would be backed by legislation that made tobacco a controlled substance with possession sale and use only allowed as permitted by the regulations, which in reality would be only as provided by the TPA.

Conclusions: The overall effect of such a model, which we call a "regulated market model", would be to eliminate most of the incentives and remaining opportunities for commercial promotion of tobacco and to create incentives to encourage the development of less harmful tobacco products. Such a model preserves the competition inherent in a free market, but directs it towards the challenge of reducing the harm from tobacco use.