Day 035 - 12 Oct 94 - Page 19


     
     1        A.  If I may respond to that first.  To define the words
     2        "due to", I might say a synonym might be "attributed to",
     3        or something like that; I do not have a document with me
     4        at the moment from the National Cancer Institutes to my
     5        knowledge that says that, but I would be happy to do
     6        that.
     7
     8        However, if one looks in the Surgeon General's report of
     9        1988 they do make reference to a document from the Journal
    10        of the National Cancer Institute which uses the words
    11        "proportions of cancer deaths attributed to" various
    12        factors, which, in my mind, would be a synonym for "due
    13        to".
    14
    15        In the Surgeon General's interpretation of this National
    16        Cancer Institute publication they actually give a more
    17        generous, what they call a range of acceptable limits.
    18        This is in the Surgeon General's report of 1988.
    19
    20   MR. MORRIS:  Page number?
    21
    22   THE WITNESS:  Page 180.  The first factor they list is tobacco
    23        and what they call the best estimate is 30 per cent of
    24        cancers, cancer deaths, are attributable to tobacco, but
    25        they also list -- the publication lists a range of
    26        acceptable estimates which is 25 to 40 per cent.
    27        Underneath that is alcohol which they have given 3 per
    28        cent as their best estimate and the acceptable estimates
    29        are two to four.  Under "Diet" the best estimate is 35 per
    30        cent.
    31
    32   MR. JUSTICE BELL:  What are the words used?
    33        A.  The word is only "diet".
    34
    35   Q.   It may seem pernickety and pedantic, but, although you are
    36        being asked specific questions, I have to consider a
    37        leaflet which has been published -- whether or not by the
    38        Defendants we will see -- and what it may mean.  In that
    39        context a difference between saying that something is "due
    40        to" and "it has been postulated that something is due to"
    41        or "it is believed that it is due to" or "it may be due
    42        to" may be of importance, which is why I am asking you
    43        this question.  Do you understand?
    44        A.  Yes.  If I understand the context, I was being asked
    45        to provide some documentation from my statement on the
    46        talk programme.
    47
    48   Q.   Yes.
    49        A.  Which -----
    50 
    51   Q.   What it appears to me is if you say something is due to 
    52        something that is really beyond any real debate.  It is a 
    53        matter of fact.  Whereas if you say "it is postulated
    54        that", that is hypothesis or it is being argued or some
    55        people believe that.  Do you see the difference?
    56        A.  What I had intended to say, or would have intended my
    57        language to mean, was not that beyond a shadow of a doubt
    58        diet clearly causes 35 to 50 per cent of all cancers and
    59        that these mechanisms are fully known, or anything of that
    60        nature; simply that there is very strong evidence that

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