Updated 7 September 06 Printable version:www.endsmoking.org.nz/snuffregs.pdf

Proposed snuff regulations

EXCLUDE HIGH RISK PRODUCTS: PERMIT LOW RISK SNUFFS ONLY

PRINCIPLE: 1) Some snuffs cause cancer. Others do not. Only the latter should be allowed into New Zealand.

2) Unlike cigarettes, snuff can be regulated on the basis of chemical tests before import and sale.

AIM To reduce the toxicity and addictive potential of all tobacco permitted to be sold or imported, including oral snuff imported for personal use, and warn the consumer about any remaining risk:

1) MINIMISE THE TOXICITY RISK · Using its powers at Section 31 of the Smoke-free Environments Act, Government and Ministry of Health should regulate to test tobaccos in the unburnt state and control the levels of harmful constituents in tobacco products to minimize cancer and other risk. · This should to apply to all snuffs, whether imported for sale or only permitted for personal oral use. This policy would also eliminate the import of gutkha, betel quid, pan masala, even for personal use (and if applied also to unburnt smoking products, would exclude biris (hand made) and kretek (clove) cigarettes). · As a guide for regulation writing, all tobaccos for human consumption in New Zealand (whether snuff, or for smoking tobacco products) should conform at minimum, to the levels stipulated in the current GothiaTek standard (www.gothiatek.com ) as of 2005 (Table 2 below).	2) MINIMISE THE ADDICTION RISK · The highest levels of tobacco addiction risk from snuff can be avoided if only the portion products are allowed to be imported, and not loose snuff. · The numbers addicted in the population are not increased when snuff is used only to replace smokers’ addiction to cigarettes. · In future years, the amount of nicotine permitted in snus could, if desired, be reduced gradually by law, beginning five years after cigarette sales were banned, to reduce the numbers addicted to snuff. · Smokeless tobacco can alternatively be regarded as a population-level quitting device, that can be permitted for the five years before and after a cigarette sales ban, and then withdrawn to avoid widespread nicotine addiction.
3) WARN CONSUMERS: PROPOSED PACKET WARNNG FOR SNUFFS Government can amend the Smoke-free Environments Regulations 1999 to require all packets of smokeless tobacco (snuffs) to carry the following warning: (assuming compliance with regulations of harmful constituents under Section 31 of the Act as proposed above): This tobacco product is addictive, may cause disease, but is much less harmful than cigarettes. Or This tobacco product can damage your health and is addictive
Why the policy needs updating · The New Zealand health system eventually has to pay for any cancers caused by imported snuff, whether imported privately or commercially. · Testing of the content of all unburnt tobacco, snuff or not, with regulated uniform upper limits, can control harmful constituents such as nitrosamines and heavy metals (some of which are difficult to detect in smoke). · The levels of cancer-causing nitrosamines in leading brands of unburnt tobacco sold in New Zealand vary by a factor of 66 (Table 2) and vary even more among the snuffs. (Table 1). Current government policy · The Smoke-free Environments Act bans the import, sale and advertising of oral tobacco (snuff). The ban dates from 1987. · It is legal to import snuff for personal use (NZ Customs letter to SmokeLess NZ, 2 June 06). This includes snuff from countries where snuff is known to cause cancer. · No regulation requires declarations or testing for harmful constituents whether tobacco is commercially imported for smoking, or imported as oral snuff products for personal use. Snuffs from Africa, South Asia or the United States can contain unacceptably high levels of cancer-causing nitrosamines. · No regulation bans import of high risk snuffs. The rationale for regulation · Tobacco like any plant product, contains anti-oxidants. Tobacco smoke like any smoke, contains billions of free radicals. Antioxidants in tobacco may even lower cancer risk, as may betel leaf^.1but if lit, its smoke contains free radicals, which cause cancer.^2 · Some snuffs cause mouth cancer; Swedish snuff does not: www.endsmoking.org.nz/mouthcancer.htm	Rationale for regulation continued.. However, tobacco leaves may absorb traces of cancer-causing metals from the soils of the tobacco farm. Also, if fermentation occurs before sale, cancer-causing nitrosamines may be produced in any tobacco. The level of cancer-causing nitrosamines is high in some snuffs and very low in others. Regulation is needed to require importers to disclose toxicants and nicotine content, exclude the more harmful products (including  snuff imports for private use), and monitor the others. Nitrosamines arise mainly by fermentation. Snus is not fermented, and has the lowest TSNA levels. In detail: All tobaccos: Test and set upper limits for nitrosamines. Nitrosamine levels in most New Zealand tobaccos for cigarette smoking are low, due to the use of flue-cured Virginia tobaccos. Much higher nitrosamine levels in Marlboro cigarettes – 66 times the level in Horizon brand cigarettes (Table 2) are probably due to the use of American blend tobacco. Nitrosamine levels in smoke will tend to be lower if the levels in unburnt tobacco are low. Nitrosamines are particularly expensive to test, but contribute less than one percent of the total cancer risk from smoking cigarettes. All tobaccos: Test and set upper limits for heavy metals. The metals that cause cancer are difficult to detect in smoke. Most brand reports of smoke show some cadmium and lead but do not quantify arsenic.  Smoke arsenic below detection levels in smoke would engender more confidence if confirmed by testing unburnt tobacco. ESR did this in 1996 for the leading cigarette and tobacco brands, and found appreciable traces of heavy metals. (Table 2 above)

1 Levels of nitrosamines vary by product type and country of origin.

Table 1.  Smokeless tobaccos (including snuffs)

Product type	Country of origin	Total TSNAs, 2003^2 ug/g (ppm) dry weight	Cancer risk
Betel quid, pan masala, gutkha	India, Pakistan	NNN + NNK levels up to ~100 ug/g ^1 Gutkha = areca nut, catechu, lime, betel with tobacco. A chewing tobacco. TSNAs 0.3-2.4 ug^5 In Hakim Puri (UK) 30ug.^5	Affects front of mouth.^2
Dry snuff	USA	41-1219 ug/g in two brands.	High pre-1981.^2
Moist snuff	USA	0-3.5 ug/g^5	Very low^3 4
Chewing tobacco	USA, UK	2-5 ug/g4 Leaf 0.2 ug.^5	Very low.^3 4
Moist snuff	Sweden	0.5-2 ug/g dry weight^5	Rare.^3 4

1. Stepanov I, Hecht SS, Ramkrishnan S, Gupta PC. Tobacco specific nitrosamines in smokeless tobacco products marketed

in India. Int J Cancer 2005; 116: 16-19.

2. Patel MM, Pandya AN. Indian J Pathol Microbiol 2004; 47: 19-7.

3. See www.endsmoking.org.nz/mouthcancer.htm

4. Rodu 2004. Risks based on exposure to higher levels in past decades; future risks expected to be lower.

5. McNeill A, Bedi R, Islam S, Alkhatib MN, West R. Level of toxins in oral tobacco products in the UK. Tob.Control 2006; 15: 64-7. http://tc.bmjjournals.com/cgi/content/full/15/1/64

2. Levels of harmful constituents in unburnt cigarettes vary by brand, by over 60-fold.

Table 2  Nitrosamines and heavy metal concentrations in unburnt New Zealand smoking tobaccos and in Swedish moist oral snuff; compared with the GothiaTek (Swedish smokeless industry) standard.

Ug/g dry weight (ppm)	Total TSNA*	Arsenic#	Cadmium#	Chromium#	Nickel#	Lead#
Tobacco in regular manufactured filter cigarettes
Rothmans	0.9	0.14	1.15	0.73	3.02	0.62
Dunhill	0.3	Na	Na	Na	Na	Na
Winfield	0.5	0.15	0.96	1.82	3.35	0.65
Marlboro	6.6	Na	Na	Na	Na	Na
John Brandon	0.4	Na	Na	Na	Na	Na
Longbeach	1.6	Na	Na	Na	Na	Na
Horizon	0.1	0.14	0.80	0.82	1.81	1.25
Holiday	0.3	0.16	0.93	1.39	4.19	0.75
Pall Mall	0.2	0.14	0.92	0.96	5.32	0.92
Benson & Hedges	0.6	0.17	0.92	1.53	2.22	1.06
Regular cigarette tobaccos for hand rolling
Holiday	1.2	0.18	0.22	1.36	1.74	0.64
Drum	2.5	0.11	0.46	1.44	1.91	0.58
Park Drive	1.8	0.10	0.48	1.46	1.95	0.66
Pocket edition	0.3	0.18	0.34	1.49	1.6	0.58
Port Royal	1.2	0.16	0.78	2.01	1.90	0.68
Mean all brands	1.23	0.15	0.72	1.36	2.64	0.76
Moist oral snuff
GothiaTek standard*	5	0.5	1.0	3.0	4.5	2.0
Swedish Match snus 2003^4	1^3- 2.4^4	0.14	0.4	1.0	2.0	0.4

· Rationale for Table 2: Tobacco for smoking tobacco products can also be conveniently tested in the unburnt state, and we show that the same standard required for snuff could equally apply to smoking tobaccos.  · Method. As no-one had measured tobacco-specific nitrosamines (TSNAs) in New Zealand tobaccos, Health New Zealand Ltd in 2004 requested Swedish Match to test unburnt tobacco from the ten leading cigarette brands and 5 hand-rolling tobacco brands sold in New Zealand. We include 1996 heavy metal analyses by ESR.

· Results Nitrosamines in Marlboro were 66 times the level in Horizon cigarettes. The TSNA level in snus was higher than in New Zealand-manufactured cigarettes, and lower than US-manufactured Marlboro cigarettes. · Nitrosamine levels as found in Swedish snus are very low, consistent with the absence of mouth cancer in Swedish snus users who do not smoke. · These findings from Swedish Match’s laboratory, are consistent with findings from independent laboratories. (See McNeill, ref 5 for Table 1 above)

Bhide SV, Padma PR, Amonkar AJ. Antimutagenic and anticarcinogenic effects of betel leaf extract against the tobacco specific nitrosamine NNK. IARC Sci Publ 1991; 105: 520-4. Rodu B, Jansson C. Smokeless tobacco and oral cancer: a review of their risks and determinants. Crit Rev Oral Biol Med. 2004; 15: 252-263.

Osterdahl BG, Jansson C, Paccou A. Decreased levels of tobacco-specific N-nitrosamines in moist snuff on the Swedish market. J Agric Food Chem. 2004 Aug 11;52(16):5085-8) “In the survey in 2001 and 2002, the mean level of the total TSNA content in moist snuff was 1.1 microg/g (n = 14) and 1.0 microg/g (n = 27), respectively. Wahlberg I. Swedish Match. 2004. Laboratory report to Health New Zealand Ltd. Confirmed for 2003 by reference ^2 GothiaTek standard. www.gothiatek.com

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Dr Murray Laugesen QSO chair; Prof Ross McCormick, Sir John Scott KBE, Trish Fraser MPH, Dr Marewa Glover, Trustees

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