sample="rhetorical" bates="2056136171" isource="pm" decade="1990" class="ui" date="19951018 " DRAFT STATEMENT OF AMMONIA October 18, 1995 The supporters of the FDA's plan to unlawfully regulate cigarettes have attempted to rehash old news about ammonia into a front page story in the Wall Street Journal, perhaps motivated by the overwhelming negative public reaction to the rule making underway. In fact, public comments are running overwhelmingly against the FDA's unlawful plan. These are the facts. Ammonia is naturally present in tobacco. Several ammonia compounds also are used in the cigarette manufacturing process as processing aid es and flavorants. For example, Philip Morris U.S.A. uses diammonium phosphate (DAP), an ammonia-related compound, to hold tobacco pieces together when making one type of reconstituted tobacco sheet. Reconstituted tobacco has been used for over 25 years as part of the tobacco blend in a cigarette. Philip Morris U.S.A. also uses several ammonia compounds to give a flavor or sensationsimilar to what one feels in the throat from the carbonation of a soft drink, the "hot" in chili peppers, or the "cool feeling" of mint. Such use of ammonia flavorants is not unique to Philip Morris U.S.A. or the cigarette industry. Ammonia compounds are used in a variety of consumer products including beverages, ice cream, ices, gelatin, puddings, and baked goods. Philip Morris U.S.A.'s use of ammonia compounds has been public knowledge for many years. Those manufacturing processes that utilize ammonia compounds have been described in published articles and patents which were filed with the government. Further, the tobacco industry list of ingredients submitted to the Department of Health and Human Services since 1986 includes the ammonia compounds used by Philip Morris. Contrary to the FDA's assertions in its report supporting its rule making and contrary to speculation in the Wall Street Journal, Philip Morris U.S.A. does not use ammonia in the cigarette manufacturing process to increase the amount of nicotine inhaled by the smoker or to "affect the rate of absorption of nicotine in to the bloodstream of the smoker," or to "increase the potency of the nicotine a smoker actually inhales." If, as the Wall Street Journal asserts, Philip Morris U.S.A. were using ammonia to increase nicotine deliveries of lower tar cigarettes, one would expect that as tar and nicotine deliveries of Marlboro have fallen over the past twenty five years, ammonia levels would have increased. But that is simply not the case.