Date: Thu, Jul 20, 2000 10:32 AM July 19, 2000 Secretary, Federal Trade Commission Re: 16 CFR Part 307 {Smokeless Tobacco Warning Labels} To the Secretary, In your recent request for "Comments Concerning Regulations Implementing the Comprehensive Smokeless Tobacco Health Education Act of 1986," I was compelled to respond with information from Alabama. In 1997, according to the results from the YRBSS (Youth Risk Behavior Surveillance Survey) 11.8% of Alabama's 9-12 Graders had used smokeless tobacco in the past month despite the fact that smokeless tobacco is not a safe alternative to smoking. Moreover, Alabama's youth have a significantly higher level of smokeless tobacco use than the national average, which is 9.3%. Smokeless tobacco causes oral and throat cancers, dental caries, increases cavity formation and leads to tooth loss. Only 4.1% of Alabama's adults (>18 years of age) use smokeless tobacco. Spit tobacco users are 50 times more likely to get oral cancer than non-users. Unfortunately, the marketing tactics used by the tobacco industry have been very successful and 11.8% of our youth experiment with smokeless tobacco, oblivious to the addictive properties of nicotine. The addictive properties of nicotine are comparable with those found in cocaine and heroin, making it extremely difficult to stop using once the vicious addictive cycle has been unleashed. Labeling requirements need to strengthened. As tobacco use becomes a global issue, it seems obvious that the warning label requirements meet the demands and inform the consumer of the all the risks. Tobacco use is the single most preventable cause of death and disease in our society. This year, over 8,000 Alabamians will die from a tobacco related illness. An estimated $1.5 billion of Alabama tax revenue is spent annually on health care productivity and income loss due to tobacco illness and early death. There are several carcinogens found in spit or smokeless tobacco: tetrafluorethylene (chemical used to make teflon), cadmium (used to make batteries), sulfuric acid (used to make fertilizers and explosives), phenolphthalein (an ingredient in laxatives).
If through adequate labeling of this dangerous product, one person is spared from the devastating effects of tobacco, then it is worth it! At least it will be an informed decision.
Sincerely, Tammy Langlois, RN
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