|Received:||8/29/2008 4:10:33 PM|
|Organization:||Partnership for Prevention|
|Agency:||Federal Trade Commission|
|Rule:||Proposal to Rescind FTC Approval of the Current Cigarette Test Method|
Comments:Partnership for Prevention supports the Federal Trade Commission’s proposal to rescind its guidance relating to statements about the tar and nicotine yields of cigarettes based on testing using the Cambridge Filter Method (commonly called the FTC Test Method). The fact is that smokers’ exposure to tar, nicotine, and carbon monoxide is not meaningfully different whether they smoke low-tar, light, or regular cigarettes. More important, the risk of death or disease is the same for those who smoke regular cigarettes as for those who smoke the so called “low tar” cigarettes. Tobacco companies have long known that people who smoke lower tar cigarettes are exposed to similar amounts of dangerous toxins as other smokers. This has not prevented the companies from referring to the “FTC test method” to imply that a highly respected federal agency, i.e., the FTC, believes that “low tar” or “light” cigarettes are safer. By prohibiting tobacco companies from implying FTC endorsement of machine-based tar and nicotine yields, we are likely to see changes in consumers’ smoking behavior. Many people who might have otherwise quit smoking entirely have chosen to switch from regular to low-tar or light cigarettes believing they were making a choice that would have positive health benefits. The FTC action will make it more difficult for tobacco companies to discourage these smokers from quitting since a seemingly “safe” alternative no longer exists. Thus, fewer smokers of regular cigarettes will now switch to low-tar and light cigarettes in hopes of reducing their risk. Instead, smokers of regular cigarettes who are concerned about their health may instead attempt to quit entirely. In addition, smokers of low-tar and light cigarettes, now realizing that the cigarettes they smoke are no safer than regular cigarettes, may also make serious attempts to quit smoking. Research has shown that young people believe that “light” cigarettes are safer, less addictive, and easier to stop using. This FTC action will make it more difficult for companies to persuade people, especially young people, that there is a safe way to smoke. The proposed action by the FTC to rescind its previous guidance is an important step forward in protecting the public’s health. Partnership for Prevention strongly supports the FTC’s proposal. We appreciate the opportunity to provide comments on this important issue, and we encourage you to contact us if you need additional information. Partnership for Prevention is a nationally-recognized nonprofit membership organization of medical and health professionals, academic institutions, voluntary health associations, businesses, and government agencies dedicated to advancing scientifically-based policies and practices to prevent disease and improve health. For more information about Partnership for Prevention, please visit http://www.prevent.org.