D ecide F or Y ourself .
PASSIVE REPORTING ON
PASSIVE
SM OKE
by Jacob Sullum
L ast F ebruary the administrator of the
Environmental Protection Agency told a House
subcommittee that Congress should ban smok­
ing in places of business. Testifying in favor of
the Smoke-Free Environment Act. which
would forbid smoking in buildings open to the
public, Carol Browner relied heavily on the
EPA report that declared environmental tobac­
co smoke (ETS) to be "a known human lung
carcinogen."
Since it was released in January 1993, this
510-page document has become a favorite
prop of the anti-smoking movement. It has
helped justify smoking bans in government
agencies— including the Department ot
Defense—in cities such as Los Angeles and
San Francisco, and in states such as Maryland
and Washington. Because the EPA s prelimi­
nary conclusions about ETS were first publi­
cized in 1990, the report had an impact even
before it appeared in its final form. "Hundreds
of local ordinances have been passed or intro­
duced in virtually every area of the country
since 1991," Browner testified. "In the year
since publication of the EPA report...we have
seen a rapid acceleration ot measures to protect
non-smokers in a variety ot settings And in
March, the U S. Occupational Safety and
Health Administration (OSHA) proposed a ban
on smoking in indoor workplaces, including
bars and restaurants.
In light of the legislation and policy changes
it has generated, the EPA s Respiratory Health
Effects o f Passive Smoking: Lung Cancer and
Other Disorders may be the most influential
report ever issued by the agency. As one might
expect, it has received extensive coverage from
major newspapers. Between May 1990 and
February 1994, the New York Times. Los
Angeles Times. The Wall Street Journal and
The Washington Post ran more than 100 news
stories about ETS. ot which about 45 focused
on the EPA report. Yet almost without excep­
tion, the coverage has been one-sided, credu­
lous and superficial. Even before the EPA
released its report, journalists were quick to
accept the claim that secondhand smoke kills.
And despite serious questions about the
report’s assertion that ETS causes lung cancer
and the process by which the EPA reached that
conclusion, leading U.S. newspapers have
treated this assertion as scientific fact. In so
doing, not only have they exaggerated what is
known about the effects ot ETS, but they have
missed an important story about the corruption
of science by the political crusade against
smoking.
To uncover the facts would not have required
a lot of digging. They were repeatedly outlined
by representatives of the tobacco industry tor
anyone who would listen. Indeed, that was a
big part of the problem. "The tobacco industry
has established a reputation for disseminating
misinformation," says Michael Fumento. one
of the few journalists who took a critical look
at the science behind the EPA s report. "At the
very least. |the industry | has been known to
put a twist on material that isn’t warranted. In a
MEDIACRITIC
I
r.
J
Faced with evidence that was weak, incon­ That impression is supported by the fact that
sistent and ambiguous, the EPA finessed some the EPA put together a "policy guide" for
important points and gave the data a vigorous reducing workplace exposure to ETS well
massage to arrive at the conclusion that ETS before it had officially decided that ETS was a
causes lung cancer. To begin with, the EPA hazard. The first draft of the guide was
used an unconventional definition of statisti­ released in June 1990, three-and-a-half years
before the EPA released the final version of
cal significance. In previous risk assessments
the EPA had always used the traditional stan­ its risk assessment. William Reilly, then
administrator of the EPA. told The Wall Street
dard. But in the case of ETS, the agency
abandoned the usual definition of statistical Journal in January 1993 that he delayed
release of the policy guide in its final torm
significance and called a result significant it
the probability that it occurred by chance was because he didn't want it to "look like we're
trying to torque the science."
10 percent or less—a change
r r o c-
j
Reilly had reason to be con-
that in effect doubles the odds
1 DC E P A [ m e s s e d cerned about that perception.
of being wrong.
In March 1992, an expert
Even according to the
panel that he convened had
b ro a d e r d e fin itio n , only
is s u e d a r e p o r t c a lle d
one of the 11 U.S. studies that
Safeguarding the Future:
the report analyzes found a
Credible Science. Credible
statistically significant link
between ETS and lung cancer c a u s e s l u n o C O IlC e r. D ecisions. Among other
things, the panel concluded
And according to the usual
that "EPA science is of
definition, none of them did.
uneven quality, and the agency's policies and
In order to bolster the evidence, the EPA
departed from its usual risk-assessment proce­ regulations are frequently perceived as lack­
dure by combining the results from these 11 ing a strong scientific foundation ' It cau­
studies in a "meta-analysis." This technique is tioned that "science should never be adjusted
appropriate only when the underlying studies to fit policy, either consciously or uncon­
sciously."
are comparable in method and structure.
Enstrom says using meta-analysis for stud­
espite these and other warning signs,
ies such as those examined by the EPA “is not
the coverage by the major newspapers
a particularly meaningful exercise," since the
was generally unskeptical of the
studies are apt to differ in the way they define
agency's conclusions and dismissive ot the
sm okers, the types of lung cancer they
tobacco industry's criticism. The typical story
include, the confounding variables they take
into account and so on. "It's just fraught with opened with the government's claims, elabo­
dangers." In any event, the result of the EPA's rated on them for several paragraphs, quoted
anti-smoking activists who agreed with the
meta-analysis is significant only under the
EPA and described the tobacco industry s
weak definition adopted especially for these
data. By the conventional standard, the meta­ response in a paragraph or two. The tobacco
industry’s comments usually amounted to lit­
analysis does not support the claim that ETS
causes lung cancer Furthermore, had the EPA tle more than denial, and no independent
sources were provided to back them up. News
included in its meta-analysis a large U.S.
study published in 1992, the result might not consumers were left with the impression that,
aside from industry representatives, no one
have been significant even by the revised
had doubts about the EPA's position on the
standard.
health effects of ETS.
The contrivances employed by the EPA,
But as Michael Fumento showed in his
which a July 31, 1992 Science article
described as “fancy statistical footwork," indi­ January 28, 1993 story for Investor's Business
Daily, this was clearly not true. "Some scien­
cate that the agency was determined to reach
tists and policy analysts who say they couldn't
the conclusion that ETS kills non-smokers.
some key points
to conclude that
passive smoke
D
MEDIACRITIC
sense, it was the boy who didn't cry wolf—the
guy who year after year saw a wolf and
claimed there was no wolf there. When he
says, 'Look, there's no wolf there,- the media
are not going to be quick to believe that."
In fact, most reporters were so disinclined to
believe the tobacco industry that they simply
assumed there was a wolf, without attempting
to verify its existence. On January 6, 1993, Los
Angeles Times writer Rudy Abramson report­
ed: “The most bitter resistance to the EPA's
move to link secondary smoke and lung cancer
has been waged by Philip Morris Co., a lead­
ing cigarette manufacturer, and by the Tobacco
Institute, the industry’s chief lobbying organi­
zation. Some 30 years after the landmark sur­
geon general's report on smoking and health,
the industry continues to argue that there is no
scientific proof of a link between cancer and
smoking.”
The message of this juxtaposition is clear:
Since the tobacco industry has refused to
acknowledge that smoking causes lung cancer,
people should not give credence to their claims
about ETS and lung cancer. This argument,
which showed up repeatedly in coverage of the
EPA report, seeks to simultaneously discredit
criticism of the agency’s position and bolster
the case against ETS. It implies not only that
the tobacco industry is lying, but that the evi­
dence of a link between ETS and lung cancer
is just as strong as the evidence of a link
between smoking and lung cancer. This analo­
gy is very misleading.
James Enstrom, a professor of epidemiology
at UCLA, notes that thousands of studies have
examined the link between smoking and lung
cancer. Virtually all of them have found posi­
tive associations, statistically significant in the
vast majority of cases.
This is an important point. In any study that
tries to measure the association between a sus­
pected risk factor and disease rates, there is
always the possibility that an observed differ­
ence between the exposed group and the con­
trol group occurred simply by chance and had
nothing to do with the risk factor. Researchers
do statistical tests to account for this possibili­
ty. By convention, epidemiologists call a result
significant if the possibility that it occurred by
chance is five percent or less. The associations
between smoking and lung cancer are sizable
as well as statistically significant: Recent stud­
ies indicate that the average male smoker is 20
times more likely to develop lung cancer than
a male non-smoker, while the risk ratio tor
women is about 10 to one. The figures are
even higher for heavy smokers.
These errors in stories about the EPA
report reflect a general tendency in cover­
age of the ETS controversy to exaggerate
evidence and m inim ize criticism . An
example is a May 29, 1990 New York
Times story by Lawrence K. Altman.
U nder the h ead lin e, “The E vidence
Mounts on Passive Smoking,” Altman
described a growing scientific consensus
that ETS is a health hazard. He quoted
one scientist who said "the links between
passive smoking and health problems are
now as solid as any finding in epidemiol­
ogy,’’ and another who claimed “there’s
no question” that ETS causes heart dis­
ease. Both assertions are controversial, to
say the least, but Altman did not offer
specific rebuttals from anyone. In the 44-
paragraph article, he devoted only three
paragraphs to skeptics, both identified
with the tobacco industry.
And Altman himself exaggerated what
the evidence tells us. In the second para­
graph, he asserted that “the studies show”
ETS “causes death not only by lung can­
cer, but even more by heart attack." Thus,
he declared at the outset of the story that
the case was closed on ETS. "The EPA
reviewed 24 epidemiological studies of
passive sm oking and lung cancer, 11
m ore than in the Surgeon G en eral's
Report in 1986,” he wrote, describing an
early version of the risk assessment. "The
newer studies confirm [the results] in the
first 13 studies." The reader is not likely
to guess from this summary that the vast
majority of these studies failed to find a
significant link between ETS and lung
cancer.
Altman is not alone in failing to discuss
statistical significance. Consider Jane E.
Brody’s January 8, 1992 New York Times
story about a study directed by Elizabeth
Fontham of Louisiana State University
Medical Center. The headline read: “New
Study Strongly Links Passive Smoking
and C an ce r.” B rody rep o rted : “The
study, the largest of its kind, found a 30
percent higher risk of lung cancer if the
women's husbands smoked, a risk that
y contrast, the EPA report was based on
30 epidemiological studies that looked
for a link between ETS and lung cancer,
mainly by comparing disease rates among
non-smoking women living with smokers to
disease rates among women living with non-
smokers. Most of the studies found positive
associations, but they were statistically signifi­
cant in only six studies. (Nine found that living
with a smoker was associated with a reduced
risk of lung cancer, but these results were not
statistically significant.) And all ot the positive
associations were weak by epidemiological
standards, typically yielding risk ratios of less
than three to one. The EPA estimated that a
woman who lives with a smoker is 1.19 times
as likely to develop lung cancer as a woman
who lives with a non-smoker. "Comparing that
to a 10 to one ratio, you can see it's minute."
Enstrom says. “It’s at least one order of magni­
tude different from the active smoking data.
With risk ratios this small, it's difficult to
rule out confounding variables, such as diet
and other sources of pollution, that might
account for an observed association. "At least
20 confounding factors have been identified as
important to the development of lung cancer,”
wrote Gary L. Huber, a professor of medicine
at the University of Texas Health Science
Center, and two colleagues in the July 1991
issue of Consumers' Research. “No reported
study comes anywhere close to controlling, or
even mentioning, half of these."
Enstrom is not optimistic that future research
will clarify the issue. "You're talking about
ratios that are so close to 1.0 that it’s really
beyond the realm of epidemiology," he says.
"You could do more studies, and you could
probably arrive at more precise ratios, but as to
whether those ratios would mean any thing, I
doubt it....You're basically down in a noise-
level situation, and whether you can really see
a true signal above the noise is doubtful'
B
rose with the number of cigarettes and
years of exposure.” Brody failed to note
that this overall association was not sta­
tistically significant (that is, the probabili­
ty that the result occurred purely by
chance was greater than five percent).
Although Fontham et al reported statisti­
cally sig n ific a n t asso c ia tio n s for a
few subgroups, the risk ratios were all
under 2.5, so it is wrong to say that the
study “strongly links passive smoking
and cancer.”
nother common error involves con­
fusing correlation with causation.
In 1991, for exam ple, the U.S.
Centers for Disease Control (CDC) did a
survey that, among other things, asked
parents to assess their children’s health.
The CDC reported that 4.1 percent of the
children who lived in households with
sm okers were said to be in “ fa ir” or
“poor” health, compared to 2.4 percent of
the children who lived in households
without smokers. From this information it
is im p o ssib le to co n clu d e anything
about the effects of ETS, since the study
did not control for variables that might
account for the difference in reported
health. Poverty is the most obvious exam­
ple. Research shows that people with lower
incomes are both more likely to smoke and
more likely to be in poor health.
Yet on June 19, 1991, the New York
Times, The Wall S treet Journal, Los
Angeles Times and The Washington Post
all ran stories under headlines asserting
that the study had found that smoking in
the home harms children. Only the New
York Times and The Washington Post
noted that the study did not control for
incom e, and only the Post m ade the
importance of this fact clear.
The errors that appear in these and
other stories about ETS are not random,
of course. They consistently weigh in
favor of the view that ETS is a serious
health hazard. Reporters are receptive to
that view for a number of reasons. Even if
they d o n ’t p erso n ally d isap p ro v e of
A
MEDIACRITIC
When reporters choose sides on the basis
smoking, they are well aware of its dan­
gers. If a lot o f tobacco sm oke hurts of trust, they fail to make independent
smokers, it seems plausible that a little assessments of the arguments of both sides.
would hurt non-smokers, though not as So readers of stories about ETS might wish
to keep in mind the following points:
much.
Since most jo u rnalists do not have □ The Im portance of S tatistical
backgrounds in statistics or epidemiolo­ Significance. When researchers do not come
gy, they rely on other people to assess the up with statistically significant results, (hey
issue. The most conspicuous sources for tend to underplay this fact, for obvious rea­
stories about ETS work for the tobacco sons. Stories should be examined to see
in d u stry , the g o v ern m e n t and a n ti­ whether they disclose, as a good report
smoking groups. Reporters don’t trust the should, whether a result is statistically sig­
nificant. Epidem iological
tobacco com panies. But
studies include “confidence
in contrast to the skepti­
When someone intervals” that indicate there
cism th ey b rin g to the
pronouncem ents of other cites a “pattern ” is a 95 percent probability
that the true risk ratio lies
government agencies and
two numbers. If the
s p e c ia l-in te re st gro u p s,
or “trend in the between
lower number is 1.0 or less,
they do tend to trust pub­
lic health authorities such data’
, ’ it’s time to the result is not significant,
even if the authors of the
as th e EPA and a n ti­
sm oking o rg a n iz a tio n s look more closely. paper play it up in the
abstract.
su ch as th e A m e ric a n
When researchers don’t get significant
Cancer Society. The governing assump­
tion seems to be that the tobacco compa­ results overall, they sometimes slice up the
nies are trying to maintain profits, while data into subgroups, seeing if they can find a
the government and anti-smoking groups significant association at certain levels of
are interested in promoting public health exposure, for certain kinds of cancer and so
on. But the more such comparisons they do,
and getting out the facts.
the less likely it is that any association they
ut sometimes these two missions find will be meaningful, since there is a five-
conflict. Public health officials may percent chance of being wrong each time.
be inclined to shade the truth a bit if Furthermore, the subgroup data for ETS and
lung cancer are often contradictory: One
it helps to discourage smoking by making
it less acceptable. In her testimony last study will find a significant result for adeno­
February, EPA Adm inistrator Browner carcinoma lung cancer but not for other
said the main benefit of the Smoke-Free types of cancer, or for spousal smoking but
Environment Act would be its impact on not for childhood exposure, while another
smokers. “The reduction in smoker mor­ study will find the opposite.
tality due to smokers who quit, cut back or □ The P itfalls of C o rrelatio n versus
do not start is estimated to range from C ausation. Even a statistically significant
about 33,000 to 99,000 lives per year,” association between A and B does not prove
she said. And six former surgeons general, that A causes B. A and B could both be
the New York Times reported, “echoed the associated with another factor or set of fac­
theme that this simple measure could do tors. An article in the July 28, 1993 Journal
more for the public health than any other o f the American Medical Association report­
bill in years.” So, just as the tobacco com­ ed that, allowing for differences in smoking
panies have an interest in minimizing the rates, restaurant workers are 50 percent more
dangers of ETS, the government and the likely to get lung cancer than people in other
anti-smoking groups have an interest in occupations. The study controlled for smok­
ing but not for a wide range of other factors
maximizing them.
B
MEDIACRITIC
MEDIACRITIC
care less about tobacco company profits or
even the rights of smokers are worrying aloud
that the EPA report is paving the way for jus­
tifying new health-based government regula­
tions and programs without any real science
behind them," he wrote. The story quoted a
series of credible sources, including epidemi­
ologists and statisticians, who questioned the
quality of the evidence linking ETS to lung
cancer and took the EPA to task for manipu­
lating the data to make its case. Fumento cited
a 1992 article from Toxicologic Pathology
in which Alvan Feinstein,
an epidem iologist at Yale
University, reported a com­
ment by a leading public-
health researcher: "Yes, it's
rotten science, but it’s in
a worthy cause, It will help
us get rid o f c ig a r e tte s
and become a smoke-free
society."
It's difficult to understand
why virtually no one followed Fumento's
lead, especially since similar questions about
the report were raised that summer in con­
gressional hearings and in a tobacco industry
law suit challenging the EPA's findings.
During the year after Fum ento’s piece
appeared, only one story in a major newspa­
per dealt with the issues he raised in a less
than perfunctory way. In a July 28, 1993 arti­
cle about the tobacco industry’s lawsuit. Wall
Street Journal reporter Jerry E. Bishop made
it clear that questions about statistical signifi­
cance and confounding variables are legiti­
mate and not easily dismissed. Although he
did not quote any critics of the report who
were not affiliated with the tobacco industry,
he at least showed that statisticians disagree
about the quality of the EPA's work.
By contrast, a June 23, 1993 story by
Journal reporter F.ben Shapiro unfairly and
erroneously attacked one of the industry’s
major claims, that the EPA excluded from its
meta-analysis a large U.S. study, published in
the November 1992 issue of the American
Journal o f Public Health, that would have
changed the report's conclusions. Shapiro
wrote that the study, which was included in a
tobacco industry press package about the law-
that could affect lung cancer rates. Yet cov­
erage in The Washington Post, the New York
Times and Los Angeles Times supported the
author’s conclusion that the higher incidence
of lung cancer should be blamed on higher
levels of tobacco smoke in restaurants.
The concern about confounding variables
is especially important when risk ratios are
small. Epidemiologists generally consider an
association "w eak" when the ratios are
between 1.0 and 3.0. In the restaurant study,
the risk ratio emphasized by the author was
about 1.5. “Anything with a risk ratio of less
than 3.0. I don't trust," Fumento says. “It’s
like measuring the width of a hair with a
standard 12-inch ruler. You can’t do it. The
little markings are tot) big. So it is with epi­
demiology. It’s a blunt tool.
□ Weasel Words. Readers should be alert
to q u a lifie rs and hedging; so should
reporters. In the restaurant study, tor exam­
ple, the author wrote: “The epidemiologic
evidence suggested that there may be a 50
percent increase in lung cancer risk among
food-service workers that is in part attribut­
able to tobacco smoke exposure in the work­
place." (Emphasis added.) The 1991 report
of the CDC survey of children’s health said
the results “show an apparent pattern sug­
gesting that, fo r most children, fair or poor
health appears to be associated with various
exposures to cigarette smoke. (Emphasis
added.) When someone cites a “ pattern" or
a "trend in the data." it’s time to look more
closely. In rigorous science, close doesn't
count.
J Discrepancies. When two versions of a
verifiable fact diverge sharply, readers
should reserve judgment. For instance, an
Associated Press story that appeared in the
New York Times on June II, 1992, quoted a
physician who appeared at an American
Heart Association (AHA) press conference
as saying that "thousands of studies have
shown that secondary smoke increases the
risk of heart and lung disease." The Tobacco
Institute, on the other hand, "insisted that
fewer than 100 studies had been done on the
effects of secondary smoke." In fact, about a
dozen studies had found a significant link
between ETS and lung cancer or heart dis­
suit, “actually appears to support the EPA's
decision. The report...concludes that there is
'a small but consistent elevation in the risk of
lung cancer in non-smokers due to passive
smoking.’” Thus Shapiro implied that the
results of the study supported the claim that
ETS causes lung cancer. But the sentence
from which he quoted actually says that “our
study and others conducted during the past
decade suggest a small but consistent eleva­
tion in the risk of lung cancer.” (Emphasis
added.) In fact, the study itself did not find a
statistically significant associ­
ation between ETS and lung
cancer. That is why the tobac­
co com panies argued that
it would have underm ined
the E PA 's c a se . S h a p iro
a lso sm u g ly q u o te d the
researchers' opinion that "the
proliferation of federal, state
and local regulations that
restrict smoking in public
places and work sites is well-founded." This
editorial comment does not change the data.
Many other stories raised false doubts about
the arguments of the EPA’s critics. In the July
22, 1993 New York Times, for example, Philip
J Hilts reported that Representatives Thomas
J. Bliley, Jr. (R-VA) and Alex McMillan
(R-NC) “suggested that the EPA’s study of
several studies, or ‘meta-analysis,’ used a
lower standard of statistical proof than nor­
mally used in assessing danger scientifically."
Despite the implication of the word suggest­
ed, this is not an arguable point, although the
report's detractors and supporters disagree
about its importance. Hilts also stated that
“about 30 studies were reviewed, of which 24
showed that secondhand smoke was a risk"—
just the opposite was true. And he had the
congressmen conceding the very point they
were disputing: "The biggest study, the two
lawmakers noted, found statistical proof that
secondhand smoke caused cancer with cer­
tainty only in those people subjected to the
most smoke." No study has ever found "statis­
tical proof that secondhand smoke caused
cancer with certainty." (In fact, it is impossi­
ble for an epidemiological study to provide
such proof.)
Reporters don’t
trust the tobacco
companies.
But they do trust
the EPA.
ease. In this case, the reporter misunderstood
his source, and a phone call to the AHA
would have cleared up the matter. In other
cases, it might be necessary to consult an
independent authority fam iliar with the
research.
Reporters will soon have an opportunity to
do better. In testimony last February. EPA
Administrator Carol Browner predicted that
the Smoke-Free Environment Act would
save the lives of 5,000 to 9.000 non-smokers
each year. Dave Mudarri of the EPA’s Indoor
Air Division says fewer than 2,200 of these
represent lung-cancer cases; the rest are
heart-disease deaths. Yet the evidence of a
link between ETS and heart disease is even
weaker than the evidence of a link between
ETS and lung cancer, and the EPA has never
done a risk assessm ent in this area. The
agency’s full report on the impact of the
Smoke-Free Environment Act was sched­
uled to be released in the spring.
If reporters want to get at the truth, they
cannot continue to act as if only one side in
this debate has an ax to grind. They need to
be just as skeptical about the EPA and the
Coalition on Smoking or Health as they
are about Philip Morris. “I treat sources like
lawyers, like advocates in a court of law, ’
Fumento says. In a court of law the jurors
take for granted that each side has an agen­
da, but that does not stop them from weigh­
ing the argum ents. Sim ilarly, reporters
should not dism iss a statem ent sim ply
because it comes from the Tobacco Institute.
Writing in Toxicologic Pathology. Yale
epidemiologist Alvan Feinstein cautioned
his fellow scientists against automatically
believing everything the “good guys” say
and rejecting everything the “bad guys" say.
His message applies to journalists as well as
scientists: “If public health and epidemiolo­
gy want to avoid becoming a branch of poli­
tics rather than science, the key issues are
methods and process, not the ‘goodness’ of
the goals or investigators. In science even
more than law. the ‘bad guy’...should always
have the right to state his case, and a well-
stated case has the right to be heard, regard­
less of who pays for it."*
Jacob Sullum is managing editor of Reason magazine.
O 1994 Forbes MediaCrMtc Reprinted with permission
MEDIACRITIC
S econdhand S moke :
C onsider T he F acts , T hen D ecide .
In January 1993, the EPA issued its report declaring that
secondhand smoke is harmful to non-smokers.
Since that time, this report, accepted in large part without question,
has caused considerable concern among smokers and non-smokers
alike. And while these concerns grew, the flaws in the EPA’s use
of science remained largely unpublicized.
Finally, these flaws are being publicly discussed.
In this meticulously researched article in the current issue of
Forbes MediaCritic, Jacob Sullum, Managing Editor of Reason
magazine explains why the public never got the full story about the
EPA report. He also details exactly how the EPA disregarded
established methods of statistical analysis to arrive at a politically
motivated conclusion about secondhand smoke.
Since the EPA’s report has been the basis for a flurry of smoking
restrictions, we believe that smokers and non-smokers need
to have both sides of the story in order to make up their own
minds. After all, recent polls show that most Americans prefer
accommodation and common courtesy to more smoking regula­
tions and outright bans.
For a full copy of this article and more information,
please call 1 800 852-5325.
PHILIP MORRIS U.S.A.
I n A ny C ontroversy , F acts M ust M atter .
> I
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© 1994
JcS
Philip Morris Inc.
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