Date: Thu, Jul 20, 2000 4:23 PM
Subject: tobacco warning labels Secretary, Federal Trade Commission

re: 16 CFR Part 307

To the Secretary;

I am writing today in response to your request for comments regarding the Regulations Implementing the Comprehensive Tobacco Health Education Act of 1986.

In Kansas, smokeless tobacco is a rights of passage. All young men, and some young women use smokeless tobacco as a status symbol. Smokeless tobacco is a problem. I moved to Kansas from Tennessee and do not remember a smokeless tobacco problem like I noted here.

In reviewing the small print and the content of the warning labels, it is clear that consumers are not receiving sufficient warnings about the health risks of smokeless tobacco. One example being my brother- in - law who stated that by using smokeless tobacco he was" not hurting his family". I was appalled! The nicotine levels in smokeless tobacco and other carcinogens lead to financially and emotionally devastated family. We are seriously misleading our consumers about this product!

I appeal to you to consider making the labels on smokeless tobacco more obvious, they should cover at least 50 percent of the package 's main and side panels, or add a package insert outlining the concerns. It may also be advisable to print the warnings in a larger font and contrasting color to the rest of the package. It is crucial that the present safe harbor approach to compliance be abandoned and that details of the warning labels - such as type size, color, and placement be mandated by regulations and not left to the manufacturers of this product. The tobacco industry has a proven track record of pushing the regulatory envelope, so, it is clearly noted that the FTC provide the parameters. Australia and Canada have some impressive label regulations and would certainly be an excellent resource in which to model or even standardize labels. Australia 's labels are especially of interest as they provide the consumer important and graphic information about the addictive properties of tobacco, and Canada has recently updated their labels to be visually graphic.

I support the FTC's desire for stronger labeling. The people of the United States deserve that as a minimum. The Commission should be allowed to pursue these stronger labeling requirements to adequately protect the current users of smokeless tobacco and the potential users of this product, who are most likely to be minors.

Thank you for considering my concerns regarding tobacco labeling. I look forward to hearing on the news that the FTC has taken action on this important health issue.

Sincerely,

Kathy Gilmartin