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
