Sometime soon, on the basis of two years of exhaustive investigation and legal analysis, Food and Drug Administration Commissioner David Kessler is likely to make a formal finding that tobacco products, cigarettes, and smokeless tobacco are drug delivery devices within his agency's jurisdiction. He will likely find that tobacco companies target teenagers in their marketing strategies and deliberately manipulate nicotine levels in their products to create and sustain nicotine addiction. And, he will probably conclude, since 90 percent of smokers become addicted before the age of 21, nicotine addiction is a pediatric disease.