How Much is the 'Lost Pleasure' From a Cigarette Worth? (Op-Ed)	Celia Wexler  is a senior Washington Representative for the Center for Science and Democracy at the  Union of Concerned Scientists (UCS) where she focuses on food and drug safety protections for scientist whistle-blowers and government transparency and accountability.  She is the author of Out of the News: Former Journalists Discuss a Profession in Crisis (McFarland 2012).  She contributed this article to Live Science's  Expert Voices: Op-Ed & Insights.	With a halo of gray hair framing his round bespectacled bearded and mustachioed face Stanton Glantz looks kindly  almost like Santa Claus. But for decades he's been Big Tobacco's biggest nightmare.  	In 1994 Glantz received  a treasure trove of secret  documents from the tobacco industry from an anonymous whistleblower. He published the documents on the Internet proving that cigarette companies had been fully aware of the health harms of tobacco   for decades.    	Fighting tobacco has been a lifelong effort for Glantz a professor of medicine at the University of California San Francisco He has done research on both the health effects of tobacco and the efficacy of smoking-cessation programs. His official title is American Legacy Foundation Distinguished Professor in Tobacco Control at the Center for Tobacco Control Research and Education. He also has written books on statistics and minored in economics while earning his doctorate. He's no intellectual slouch when it comes to the dismal science.  	Now Glantz is on the warpath again. And this time his fight affects not only how the U.S. government protects us and our children from tobacco but also fast food alcohol and even gambling. His new foe is the notion that when figuring out the benefits of restricting tobacco use federal agencies must consider the high value a smoker places on the pleasure of smoking.   	Let's say a pack of cigarettes costs $5. A smoker might be willing to pay $25 for cigarettes if he really needs a hit of nicotine. So economic theory might then consider the real value of those cigarettes to be $25  what a smoker is willing to pay rather than what a pack costs in the marketplace.   	Glantz's crusade gets wonky but keep reading. Factoring in lost pleasure in economic analyses is not new. But what Glantz objects to is using the lost pleasure discount when discussing products that people often are addicted to. The lost pleasure factor he argues makes sense when economists are trying to figure out what a rational consumer would do in the marketplace. But an addicted consumer is not rational. Neither is a minor who may be tempted to experiment with a lot of addictive products. [Images: New Cigarette Labels Unveiled by the FDA ]	Why does this economic jargon matter? Because federal agencies when they are proposing rules often estimate their costs to the regulated industries or individuals and compare those numbers to the rule's benefits for the public at large. While this may be an elegant concept in economics it's never worked that well in the real world of public protections.	Industries are good at estimating  and often exaggerating  the monetary costs of a protective rule while agencies discuss improving public health and saving lives which are difficult to measure in dollars. How do you monetize the ability of children to play outdoors because the air is not polluted? How much is a human life worth? And then there's basic fairness to consider  is it right that while one person (or company) profits from polluting different people including workers get sick from it?	The tussle over cost-benefit analysis has persisted for years. But at the U.S. Food and Drug Administration (FDA) economists are pushing the envelope in ways that could very well tie government's hands whenever it wants to take action to curb addictive self-destructive behavior  even by minors.	In 2009 Congress gave the FDA the power to regulate tobacco. The FDA then proposed labeling rules that would include strong warnings on packages of cigarettes  warnings that Congress actually put in the text of the law The Family Smoking and Tobacco Control Act.	The FDA also proposed making those labels big and prominent. When the FDA conducted a cost-benefit analysis of the benefits of those warning labels it did something unprecedented:   The agency's economists factored in the value of lost pleasure  from smoking.	The FDA figured that lost pleasure would reduce the value of health benefits  lives saved and health improved  by 50 percent.  That's right.   The agency estimated that the value of lost pleasure to smokers was so great it would cut the benefits in better health and lives saved by half.  	Tobacco companies sued the FDA over those rules claiming it violated the tobacco industry's  First Amendment rights to promote their product and a conservative federal judge threw them out in a widely-criticized decision.  	But the FDA has not abandoned regulatory attempts even as its own economists make regulation harder to defend. Currently the FDA is proposing rules that would give it the power to regulate e-cigarettes pipe tobacco and cigars. E-cigarette makers would need to have their products approved by the FDA include warning labels and ban sales to minors although the entire process for regulatory oversight likely will take years and does not address advertising limits.  	Guess what? Not only is the FDA including the lost pleasure factor when it estimates benefits   FDA economists now believe that  lost pleasure will reduce the benefits by 70 percent. So if e-cigarette regulations produce health and productivity benefits of $1 billion by this calculation the benefits would be worth only $300 million.  	What's worse in a paper written by two FDA economists this 70 percent   or higher discount could apply to other regulatory areas such as junk food alcohol or gambling. (The paper published last February in the journal  Health Economics  includes an economist from the Office of Management and Budget as a co-author. All three write that their views are their own and not necessarily their respective agencies'. But it's not comforting to see that public servants are thinking this way.)  	Let me know if this makes sense to you: Because I'm addicted to sugar and sugar has demonstrated harmful health impacts labels letting me know how much extra sugar has been added to a food product would in some way make me unhappy as well as healthier. Just knowing about the extra sugar would deprive me of the pleasure of literally feeding my addiction.	When a Reuters reporter tried to get these economists on record to explain their reasoning they demurred but in their paper the FDA economists cite a 2002 study by MIT economist Jonathan Gruber on the lost pleasure discount. But Gruber has said that his work was misunderstood contending that the lost pleasure discount should not apply when considering behavior by consumers who likely got hooked on tobacco when they were kids and now are addicted.  	Extensive and careful scientific analysis has documented the health risks from tobacco alcohol and junk food particularly to those who are addicted to those products.  	This makes no sense in terms of science Glantz said. Economists have a role to play at federal agencies but Glantz pointed out that in this evaluation economists should not be the only voice. Behavioral psychologists pharmacologists physicians epidemiologists and biologists among others also should weigh in. Protecting our families from harm should not be trumped by invented theories about lost pleasure.  	This is just plain dumb Glantz pronounced. But it is powerfully dumb. The FDA's proposed regulation including this wacky cost-benefit calculation is  open for public comment  until August 8.  	On June 24 the FDA released changes to its proposed rule from the White House Office of Management and Budget (OMB). OMB has to approve agency rules that have significant economic costs. On initial analysis it appears the OMB heartily endorses the lost pleasure discount and may have even ratcheted it up a bit in the proposed rule.	Unless there is major pushback the FDA will continue to be guided by its misguided economists. It's time to tell the FDA that the lost pleasure concept will only create pain for the public.  	The author's most recent Op-Ed was Why Whistle-Blowers Should Watch Out for New Loophole.  The views expressed are those of the author and do not necessarily reflect the views of the publisher. This article was originally published on Live Science.