Date: Wed, Jul 19, 2000 6:45 PM Secretary, Federal Trade Commission Re: 16 CFR Part 307 To the Secretary: This letter is in response to your Request for Comments Concerning Regulations Implementing the Comprehensive Smokeless Tobacco Health Education Act of 1986. Smokeless tobacco is a serious public health problem in Arkansas. Clearly consumers are not receiving sufficient warnings about the health risks associated with smokeless tobacco use. At the very least, the labels on smokeless tobacco products should cover at least 50% of the package's main and side panels and be required as a package insert as well. Additionally, warnings should be printed in a larger type than is presently used on cigarettes. Precise requirements should be specified by the FTC. Additionally, the FTC should specify in regulations the format and colors of the warning. Research and evidence from other countries suggest that black type on a white background is most effective. Citizens of this country deserve at least as much protection as is mandated by law and regulation in Canada and Australia. The warnings should be rotated often to maintain their effectiveness. These messages should give the consumer important and graphic information about the addictive properties of smokeless tobacco, the immediate and long-term, disease specific health effects of smokeless tobacco use, and all ingredients, or at the very least, the hazardous ones, included in the product. The FTC should be allowed to pursue these stronger labeling requirements to adequately protect the current users of smokeless tobacco and the potential users of the product, who are mostly minors. It is important that this product be labeled with warnings that are more likely to be seen, understood, and incorporated into decisions by consumers about whether or not to use it. Thank you for considering these comments. I look forward to seeing the FTC take action on this important health issue. Sincerely, Patty McLean, Tobacco Prevention and Education Program Director |