CONFIDENTIAL

Dr. Giovanni Viegis links to the tobacco industry as revealed by tobacco industry documents
Pascal A. Diethelm 7 March 2006 1) At the request of Archie Turnbull, Executive Director, European Respiratory Society, I have done a search of tobacco industry documents to find possible links between Dr. Giovanni Viegi and the tobacco industry. I used the following websites: 2) Philip Morris USA Documents Site (http://www.pmdocs.com) Legacy Tobacco Documents Library (http://legacy.library.ucsf.edu/) British American Tobacco Archives (http://bat.library.ucsf.edu/)

I searched for viegi and inspected visually all the documents which matched this search criterion, and then doing snowball searches for some documents to find other related documents, using Bates number proximity or file proximity. I also used other documents from the same websites, which I had already identified and kept in my own collection. The first two topics presented below are included because they are needed to understand the context in which the facts described in this document took place. The rest of the document follows a chronological order.

3)

4)

The Center for Indoor Air Research (CIAR)

5) The Center for Indoor Air Research was created in 1988 by three US tobacco companies, Lorillard, Philip Morris and R.J. Reynolds. According to a letter from the Tobacco Institute, which coordinated the creation of CIAR, the principal purpose of the research center would be to establish mechanisms for funding and supervising industry-sponsored research on indoor air quality. CIAR operations were supervised by a Board of Directors, consisting of representatives of each company, with a representative from the Tobacco Institute serving as secretary. (Bates No. 2025858523/8525) Thomas Osdene, of Philip Morris, who was in charge of the establishment of CIAR (Bates No. 2025856205/6208), made the following description of the purpose of CIAR:
I think many of us have conceptualized the ETS issue as a battlefield in which the arena is dominated by public relations and legal issues while the ammunition which is used happens to be science. It has been the purpose of CIAR [] to provide ammunition in this fight. (Bates No. 2046594609/4613)

6)

-1-

7)

Another Philip Morris document gives further indication on CIAR:

CIAR has three classes of membership: Charter Members - tobacco companies who established the Center (PM, RJR, and Lorillard) and provide the majority of the funding; Regular and Associate Members - corporations that are interested in indoor air quality research (regular members can be represented on the Board of Directors (the Board) - none are, at present while associate members are not). The Center has an independent Science Advisory Board (SAB) which develops the research agenda for approval by the Board. The SAB recommends proposals for funding after they have been peer reviewed. Proposals can only be funded subsequent to approval by the Board. A second class of research projects Applied Studies are also funded if approved by the Board: such projects are not normally reviewed or recommended by the SAB. (emphasis added - Bates No. 2021528170)

8)

Although its bylaws included the possibility of regular and associate members, CIAR remained throughout its brief existence entirely controlled by its charter members, the tobacco companies. For example, the 1994 budget of the Center amounted to USD 5,646,078. 99,3% of this amount was shared among four tobacco companies: Philip Morris (52,8%), RJR (38,3%), Lorillard (8.9%) and Svenska Tobaks for a fixed amount of USD 150'000 dollars. CIAR budgets for 1994, 1995 et 1996 all include a line labelled Associate members, who are not identified, with a fixed amount of USD 40'000 for each year, i.e. 0.7% of the total budget. (Lorillard - Bates No.89273190/3191) It is important to note that CIAR funded two kinds of projects: regular projects were submitted to the SAB for review, while Applied Studies bypassed the peer review process and went directly to the Board of Directors, for approval by the representatives of the tobacco industry. This scheme and its consequences are well summarized in the abstract of the article by Barnes and Bero (Industry-funded research and conflict of interest: an analysis of research sponsored by the tobacco industry through the Center for Indoor Air Research. J Health Polit Policy Law. 1997 Oct;22(5):1279-93):
The Center for Indoor Air Research (CIAR) was created by three United States tobacco companies in 1988. Its stated mission is to fund high-quality, objective research related to indoor air, including studies of environmental tobacco smoke (ETS). Because CIAR is financed by the tobacco industry and funds research related to tobacco, it fosters an inherent conflict of interest. We consider whether this conflict of interest has affected the content, quality, or use of research funded by CIAR. We hypothesize that the tobacco industry might be using CIAR to develop scientific data to support its position that ETS is not harmful to health. CIAR funds two types of projects: "Peer-reviewed" projects are awarded after peer review by a group of scientists, whereas "specialreviewed" projects are awarded directly by tobacco industry executives. CIAR's special-reviewed projects are more likely than its peer-reviewed projects to be related to ETS, to support the tobacco industry position, and to be used by the industry to argue that smoking should not be regulated in public places. Our findings suggest that the tobacco industry is funding special-reviewed projects through CIAR to develop scientific data that it can use in legislative and legal settings. The industry may be

9)

-2-

financing peer-reviewed projects through CIAR to enhance its credibility, to provide good publicity, and to divert attention from ETS as an indoor air pollutant. CIAR's stated mission of funding high-quality, objective research has been compromised by conflict of interest, and at least some of CIAR's projects are being used to promote the tobacco industry's agenda.

10)

The CIAR was dissolved in 1998 by the Master Settlement Agreement, among other front organizations of the US tobacco industry, such as the Council for Tobacco Research and the Tobacco Institute. The dissolution became effective in 1999.

Confounders studies
11) Confounder studies were launched by the tobacco industry, under the leadership of Philip Morris, in the context of their strategy to mitigate the results of the IARC large epidemiological study on ETS and lung cancer, as is clearly stated in an internal presentation made in May 1994 by Steven Parrish, General Counsel and Senior Vice President, Corporate Affairs, Philip Morris Management Corporation (Bates No. 2025494471/4490). Parrishs plan includes the following objective:
SPONSOR ORIGINAL RESEARCH ON CONFOUNDERS AND EXPOSURE TO CONTRIBUTE TO THE DEBATE ON THE STUDY AND MONOGRAPH AND LOBBY ON THE SCIENCE.

12)

Richard Carchman, Manager, Bio-Chemistry Research, Philip Morris Incorporated, made a presentation to an industry group on 8 June 1994 in London (Bates No. 2028363271/3280), in which he proposed an industry response to the IARC study on lung cancer in non-smokers. His proposal comprises five points, including the following three:
2) Response plan to IARC ETS study: a) Communication with scientists at IARC and at the collaborative centers b) Execution of studies on confounders and exposure c) PR response plan 3) Proposed studies are intended for use primarily in Europe, but results can be used world-wide [] 5) Studies will be organized by and funded through CIAR.

(emphasis added) Carchman also proposes a budget of USD 2,600,000 for the confounders epidemiological studies. 13) The tobacco industry used as model for the planned European confounders study a study undertaken for CIAR by Genevieve Matanoski in the United States. The results of the Matanoski study were published in July 1995. The conclusions were, according to a internal Philip Morris presentation on CIAR (Bates No. 2043704149/4173):

-3-

NS women who were exposed to husbands who smoked were more likely to be older, have lower education, live in the city, and have other health behaviors that could increase their risk of lung cancer Many of the differences that the authors observed between the women who were exposed and non exposed to passive smoking could affect the risk of cancer.

1995-1996: the Italian pilot confounders studies

14) At the meeting of the CIAR Board of Directors of 12 April 1995, Max Eisenberg, the Executive Director of CIAR announced that he and Dr. Genevieve Matanoski would be meeting with Dr. Francesco Forastiere and Dr. Rodolfo Sarracci in Lyon at the end of April. (Bates No. 2050764815/4816) This visit to IARC was part of a plan which is detailed in an internal Philip Morris document entitled: CIAR AND IARC NEXT STEPS AND OPTIONS:
CIAR is now identifying candidates for principle [sic] investigators for the confounder (pilot and full) studies in Europe. Option: Select as principle [sic] investigator for the CIAR-sponsored confounder study(ies) scientists involved with IARC multi-center study. Eisenberg is arranging an exploratory meeting with Forestierre [sic] (Italy) premised on a discussion of matters of mutual interest []. (Bates No. 2028381588)

15)

It will be shown below that the principal investigator that CIAR was eventually able to recruit was Dr. Viegi, with Forastiere as co-investigator. This contact between CIAR representatives and WHO/IARC collaborators is described in the WHO report entitled Tobacco Company Strategies to Undermine Tobacco Control at the World Health Organization (WHO, July 2000, pp. 206-208). The WHO report adds the following:
In an interview, Boffetta [another Italian staff member of IARC] said IARC did not pursue any proposed collaboration once he became aware of CIARs industry connection. Saracci did not join CIARs Advisory Board or accept any grants for research, once IARC realized that CIAR was funded by members of the tobacco industry. One IARC collaborator (Forastiere) did, however, conduct a study for CIAR on confounders. Boffetta expressed disappointment in Forastieres decision to conduct a study for CIAR, because by then, IARC understood CIARs industrys connection. (p. 207 - emphasis added)

-4-

16)

A Philip Morris document, dated 10 October 1995 (Bates No. 2057790220/0230), suggests for the first time that the industry is considering the involvement of G. Viegi in one of its projects. This document is a paper copy of the slides of a presentation on one industry project, Determination of personal exposures to environmental tobacco smoke in Europe. At the end of this presentation, an apparently unrelated slide gives the list of potential collaborators of the European Confounders Study, and list Dr. Giovanni Viegi among three other names (Dr. Francesco Forastiere, Dr. Rodolfo Saracci and Dr. Genevieve Matanoski). On 9-10 November 1995, the CIAR Board of Directors met in Hong Kong. The Italian confounders study was discussed on both days. The notes from one participant summarizes the discussion as follows:
C.I.A.R. BOARD OF DIRECTORS MEETING Hong Kong, November 9, 1995 [] Matanoski has advised several Italian investigators re conduct of analyses of NHANESlike databases in that country. Pilot studies have been completed, and results reported (Eisenberg phone call last week) look much like the U.S. NHANES analyses. The investigator has submitted an abstract for the 1996 American Thoracic Society Meeting. That Societys newly-adopted policy on publication of tobacco-funded research is attached; it will be interesting to see whether the abstract is accepted if CIAR is acknowledged as it should be. (Bates No. 88246845/6846) C.I.A.R. FAR EAST MEETING Hong Kong, November 10, 1995 [] Dr Matanoskis role in assisting three Italian researchers in the conduct of confounder studies on NHANES-like Italian databases was described. Pilot study results from these Italian workers were available about 1 week ago; results are reportedly similar to Manatoskis findings in the U.S. One of these Italian professors has submitted an abstract describing his pilot study to the American Thoracic Societys annual meeting this summer. (Bates No. 88246838/6840)

17)

The Italian professor who has submitted the abstract is Viegi (Bates No. 2057790441). The abstract was accepted by the ATS. (Bates No. 2057790440) 18) The above strongly suggests that the Italian pilot studies on confounders were in fact projects directed by CIAR and undertaken by Viegi on behalf of CIAR. In 1995, the Scientific Advisory Board of CIAR recommended 24 proposals for approval by the Board of Directors, out of which the BoD selected 10 (Bates No. 528439146/9148 and Bates No. 83205217/5218). Among theses proposals, there is no trace of the Italian pilot studies. Neither are they included in the list of 20 project proposals recommended by the SAB in 1996 for funding in 1997. (Bates No. 566938612, 517577797/7798 and 566938773/8778). The Italian pilot studies clearly follow the track of applied studies, completely bypassing the SAB review process.

-5-

19)

The fact that the Italian pilot confounders studies are activities initiated and directed by CIAR is confirmed by several documents. In the 1994-1995 annual performance review of Dr. Max Eisenberg, the Executive Director of CIAR (dated August 1995), one of the accomplishments listed is Developing contacts with reputable researchers in Europe that is leading to a research proposal on confounders. (Bates No. 517578756/8758). One year later, the 1995-1996 performance review of Dr. Eisenberg highlights the following: Two pilot studies on confounders undertaken in Italy by Dr. Giovanni Viegi, National Research Council, and Dr. Francesco Forastiere, EPI Asssociazione per la Ricerca in Epidemiologica. Dr. Viegi presented a poster at the American Thoracic Society meeting in May 1996. (Bates No. 517578761/8762) It should be noted that the SAB reviewed projects are not singled out in Dr. Eisenbergs performance review, but are just collectively covered in one item: Receipt of a large number of research proposals, peer review of the applications, monitoring the supported projects and reporting progress, requiring financial responsibility, and ensuring completion of funded research. (ibid.) Two page highlights of the CIAR activities for 1995-1996 and for 1996-1997 also single out the Italian pilot studies undertaken by Dr. G. Viegi. (Bates No. 2063651367/1370). The Italian confounders study must have been an important responsibility of Dr. Eisenberg. Indeed, when his post description was revised in 1998 by the Board of Directors, under Scientific Responsibilities, one finds the Italian study in prominent place among the Executive Directors responsibilities:
Scientific Responsibilities: [] Confounders study in Italy by Dr. G. Viegi, National Research Council, and Dr. F. Forastiere, EPI-Associazone per la Recercia in Epidemiologia, with Dr. Sarracci of IARC and Dr. G. Matanoski, John Hopkins University, acting as consultants. (Bates No. 2063651442 and 2063651443/1446)

20)

21)

The confounders epidemiology studies

22) The pilot studies produced what the industry must have considered very promising results. Indeed, the abstract submitted by Viegi to the 1996 International Conference of the American Thoracic Society claims that women exposed to passive smoking differ markedly from the unexposed:
[]ETS exposure was significantly associated with: marital status, use of oral contraceptives, dietary regimen, type of heating, property of house, crowding index, type of job. Directions of associations were somewhat different in the two populations. In conclusions, we confirm that women exposed to ETS differ from those unexposed for several factors which should be taken into account in future studies on health effects of ETS. (Emphasis added - Bates No. 2057790441)

The conclusion does not leave much room for doubt: it is confirmed that women exposed to passive smoking are different. Interestingly, there is no mention that this

-6-

is a pilot study. This was exactly the type of result the tobacco industry was looking for, and wanted to support financially.

23)

In 1996, CIAR awarded Dr. Viegi, as principal investigator, two contracts to conduct confounders epidemiology studies aiming at evaluating whether some of the risk factors that have been associated with cardiovascular or respiratory diseases and lung cancer occur differently among women with and without exposure to ETS in three areas of Italy. (Bates No. 2063813786/3788) Contract 96-18 was for an amount of USD 853,985 and contract 96-18A for an amount of USD 878,318, totalling USD 1,232,303 (over 1.2 millions US dollars). The first contract was to end on 31 December 1997 and the second on 31 December 1998, with the possibility of a no cost extension to 31 March 1999. Again, this full-fledged confounders epidemiology project appears to have completely bypassed the SAB review process of CIAR. Indeed, this project, as was the case for Viegis pilot studies, does not appear in the list of the 20 project proposals recommended by the SAB in 1996 for funding in 1997. (Bates No. 566938612, 517577797/7798 and 566938773/8778). The project was instead placed directly under the responsibility of Dr Max Eisenberg, the Executive Director of CIAR, as is shown in his revised post description discussed above.

24)

The publication of the study results

25) Among the tobacco documents, I have found copies of three published articles in which the results of the Italian confounders study were reported: F. Forastiere, et al. (19 co-authors in total, including Viegi) Characteristics of Nonsmoking women Exposed to Spouses Who Smoke: Epidemiologic Study on Environment and Health in Women from Four Italian Areas, Environmental Health Perspectives, 109: 1171-1177, 2000 (EHP article for short) (Bates No. 3006484883/4889) S. Farchi, et al. ( 7 co-authors, including Viegi) Exposure to Environmental Tobacco Smoke Is Associated with Lower Plasma -Carotene Levels among Nonsmoking Women Married to a Smoker, Prevention Vol. 10, 907-909, August 2001 (CEBP article). (Bates No. 2067632186/2188) M. Simoni, et al. (7 co-authors, including Viegi) Characteristics of women exposed and unexposed to environmental tobacco smoke (ETS) in a general population sample of North Italy (Po River Delta epidemiological study) European Journal of Epidemiology 17:363-368, 2001 (EJE article) (Bates No. 3006440149/0153)

26)

The EHP article acknowledges funding by CIAR, although only as the last item in the acknowledgment section, saying that this work was funded in part by the Center for

-7-

Indoor Air Research (emphasis added). This declaration does not do justice to the fact that CIAR contributed over 1.2 millions US dollars to the project. One may wonder, if this was only a partial contribution, what were the amounts provided by the other financial contributors, who are not acknowledged. 27) Furthermore, there is no indication of a potential conflict of interest (this is in breach of the instruction to authors of this publications, which are very explicit and strict on this question1), while the authors could not have ignored at the time of publication (and as Viegi probably knew since the onset of the study) that the financing came from the tobacco industry, through CIAR. Perhaps the other co-authors of the article did not know, but it would be extremely surprising that it had escaped Dr. Viegis attention that CIAR had been dissolved by the MSA because it was a tobacco-related organization, considering that Viegis project was closely monitored by CIAR and that therefore Dr. Viegi must have kept in close contact with Dr. Eisenberg, who was supervising the project from January 1997 until the dissolution of CIAR. Notwithstanding the incompleteness of the conflict of interest declaration, the article appears otherwise of good quality. The results must have somehow disappointed the financial sponsor of the study, since they do not confirm Matanoskis findings, but rather tend to contradict them:
Considering that most of the variables related to a preventive behaviour were also similar between the two groups, it seems that in the Italian situation, after having
1

28)

Extract from the EHP guidelines to authors: EHP has a long-standing requirement for authors to disclose competing financial interests. Corresponding authors are required to submit with the manuscript a declaration of competing financial interests on behalf of all authors. When in doubt about the need to report, authors should always err on the side of caution and report all interests that might in any way be perceived as representing a competing financial interest. The form is available online and can be downloaded (http://ehp.niehs.nih.gov/cfi.pdf). If the article is accepted for publication, the statements are published with the article disclosing either a competing financial interest, along with a brief description, or a declaration of no competing interests. Competing financial interests may include, but are not limited to, grant support, employment (recent, present, or anticipated), patents (including pending or applied for), payment for expert testimony, and personal financial interests by the authors, immediate family members, or institutional affiliations that may gain or lose financially through publication. Increasingly, researchers are compensated through a host of financial arrangements such as travel funding, consultancies, advisory board positions, patent and royalty arrangements, stock shares, bonds, and the like. Diversified mutual funds or investment trusts do not constitute a competing financial interest. Further, authors are required to certify that their freedom to design, conduct, interpret, and publish research is not compromised by any controlling sponsor as a condition of review and publication. In order to provide full disclosure, please include a sentence in the Acknowledgments of your manuscript identifying any competing financial interests, remembering that employment can be a competing financial interest. For authors employed by a for-profit organization or an advocacy group, a simple statement of employment is adequate. Scientists are aware of the absolute necessity to maintain the personal integrity upon which science depends. It is this integrity that full disclosure of competing financial interests hopes to preserve. Therefore, it is imperative that authors and readers understand that a disclosure of a competing financial interest does not imply that the information in the article is questionable or that the conclusions are biased. Authors must also understand that the omission of a pertinent financial interest could, if later revealed, deal a severe blow to the authors' integrity and the credibility of their research. )

-8-

considered age and social class differences, women married to a smoker do not differ to a great extent from women married to a non-smoker. [] Our results also suggest that the extent of confounding from other factors, if any, is minimal. In conclusion, we found few differences in socioeconomic and dietary characteristics among non-smoking Italian women exposed and not exposed to spouses who smoke.

29)

The second article, the CEBP article, suffers from the same problem in terms of the lack of declaration of the full extent of the source of funding, acknowledging only partial funding by CIAR, without mentioning any other source of funding, and failing to declare the situation of conflict of interest arising from the link with the tobacco industry via CIAR. Although the publication policy of CEBP is not as strict as that of EHP, it still requires authors to declare their conflict of interest. However, it is possible that the authors communicated their situation of conflict of interest to the editor, who then decided not to publish it.2 As with the previous article, the result must have been slightly disappointing for the financial sponsor, since it does not fully correspond to what the tobacco industry may have expected, as it does not exonerate exposure to passive smoking from being causally associated with lung cancer, but rather provides findings that may help interpret the biological mechanisms linking ETS exposure to lung cancer and cardiovascular diseases. It should also be noted that this second article includes in its references the reference to the EHP article, as one would normally expect. The third paper, the EJE paper, is more problematic. The acknowledgement section contains what appears to be an attempt to conceal the real extent of the contribution by CIAR. Not only this contribution is mentioned as the last item, behind three other contributions, but it is labelled an educational grant from the Center of Indoor Air Research, Linthicum (MD), USA. It seems to me that this description does not correspond to reality and conceals the true nature of CIARs contribution. Nowhere in any of the documents I have seen was there any indication that the money that CIAR awarded to Viegi as principal investigator of the Italian confounders study was for educational purposes. And it seems that a grant of over 1.2 millions US dollars is quite a substantial educational grant, and one is left wondering who benefited from such a grant for his or her education. This would therefore need to be clarified.

30)

31)

32)

Extract from the CEBP guidelines to authors: Conflict of Interest. Journal policy requires that authors and reviewers reveal to the Editors-in-Chief or Senior Editors any relationships that they believe could be construed as resulting in an actual, potential, or apparent conflict of interest with regard to the manuscript submitted for review. Authors must disclose this information in the covering letter accompanying their submission. The existence of financial interests or other relationships of a commercial nature is not necessarily regarded as creating a conflict of interest. Rather, journal policy represents a recognition of the many factors that can influence judgments about research data and a desire to make as much information as possible available to those reviewing the data. If in the judgment of the Editors-in-Chief the information revealed does represent a potential conflict of interest, notification concerning the relationship may be published. If such action is deemed necessary, the authors will be informed before publication.

-9-

33)

The authors of the EJE paper do not declare any conflict of interest either, although the policy of this journal appears to be much more lax in this respect than the two preceding journals. The paper re-analyses the data of one of the areas included in the EHP article, taking the exact same sample of 1499 females, of which 867 never smoking women were selected. This figure of 867 never smoking women does not reconcile with the figure indicated in the main study of 805 who had reported never being smokers. The paper does not provide any explanation for this discrepancy. In fact, the EJE paper makes no reference at all to the EHP article. This is surprising, since it was accepted on 22 August 2001, and therefore the authors had therefore plenty of time to refer to it (as did the CEBP article). This lack of reference to a very closely related publication is not in line with good publication practice, as stated in the COPE guidelines: At the time of submission, authors should disclose details of related papers, even if in a different language, and similar papers in press. (Rule 6.4 see http://www.publicationethics.org.uk/guidelines/reports/2003/2003pdf15.pdf) The methodology used in the article is not just rudimentary, it appears to me as grossly deficient (but this is not my field of expertise my assessment needs to be cross-validated by an epidemiologist). The sample of 867 women aged 8-73 was reduced to a sample of 661 women of age 20+. This sample was then divided in two groups, the women currently exposed to passive smoking, and those unexposed. The two groups were compared by looking at the means of a number of variables, comparing percentages, and using logistic regression. However, all of this was done without controlling, as is done in the main study, for age. The study found that the exposed women were significantly younger (by 9 years) than unexposed women. This big difference can actually be easily explained. As most of the exposure is at home (74.8%), the greatest source of exposure comes from the womens husbands, who, on average, have the same age as their wives. Therefore, the likelihood of being exposed in any age group will be determined by the prevalence of smoking among men in the same age group. The average age of the exposed women will therefore tend to be close to the average age of the male smokers, and will therefore be pulled towards young age, as the smoking prevalence curves climbs rapidly from age 14 to reach a peak at or before age 25 and then continuously decreases, i.e. the curve is skewed towards zero. On the other hand, the likelihood of being unexposed will mimic the complement of the smoking prevalence distribution over age, and the average age will be pushed towards the old end of the range. But regardless of whether this explanation holds or not, all other differences observed in the paper can be assumed to derive from this age difference of 9 years between the two groups. Exposed women were found lighter (by 1.5 kg), as indeed younger women are in general, taller (by 1cm), as is indeed the new generation, not living in their own house (young people cannot yet afford to live in their own house), etc. Omitting for a moment the exposure to passive smoking, it can be hypothesized that if one took two random samples from the population of the Po River Delta area exhibiting a difference of nine years between their average ages, one would probably - 10 -

34)

35)

36)

37)

observe very similar differences with respect to all the characteristics exhibited in the paper. These results are therefore most likely not attributable to exposure. 38) The authors nevertheless make a conclusion which contradicts the findings of the main multicenter study published in EHP.
In conclusion, we have provided the distribution of ETS exposure in a general population of Italian women and we have confirmed that many life-style characteristics are associated with ETS exposure. These characteristics should be taken into account while studying the relationship between ETS and respiratory health, although it seems unlikely that these factors may obscure the relationship of ETS and health outcomes (emphasis added).

The emphasized sentence in the above quotation is the recurring motto found in the conclusions of all the confounders studies sponsored by the tobacco industry.

CIAR successor: Philip Morris External Research Program

39) CIAR ceased to operate in 1999 and was effectively dissolved. In 2000, Philip Morris replaced it with the Philip Morris Research Program, using a similar structure, with a Science Advisory Board, replacing the Board of Directors with the counterpart mechanism inside Philip Morris, the Scientific Research Review Committee (SRRC), consisting of Philip Morris staff members, and adding a group of Peer Reviewers. As of 2000, Dr Viegis name appears in the list of peer reviewers of the Philip Morris Research Program. (Bates No. 2082039342/9373) ***

- 11 -