National Association of County and City Health Officials
June 20, 2000
Donald S. Clark
Re: 16 CFR Part 307
Dear Secretary Clark:
The National Association of County and City Health (NACCHO), in partnership with the Association of State and Territorial Health Officials (ASTHO) and the National Association of Local Boards of Health (NALBOH), recently published a joint policy statement on tobacco use prevention and control. This statement calls for increased federal, state, and local regulation of tobacco products, including improvements in the current tobacco product warning labels and placement on all tobacco product packaging. NACCHO has also published a resolution on smokeless or "spit" tobacco that calls for stronger warning labels.
NACCHO recognizes that tobacco use is one of this nation's greatest public health problems and the single most preventable cause of disease, disability, and death. Many local health departments are funded to conduct comprehensive tobacco prevention and control programs, which include efforts to address the prevention use and of smokeless or "spit" tobacco, especially by adolescents. Recent focus group testing by the Centers for Disease Control and Prevention, Office on Smoking and Health revealed that many young people do not know warning labels are printed on cans of "spit" tobacco, partly because they are small, printed on one side, and often in non-contrasting colors.
While warning labels are only one element of a broad approach to preventing and controlling the use of "spit" tobacco, they are an important part of the public health effort to prevent initiation and to increase cessation. Warning label design and placement based on the same research used by spit tobacco marketers could have significant impact on reducing use of this deadly product. We applaud the Commission's efforts to examine and improve the labeling regulations for "spit" tobacco and make the following recommendations for your consideration:
NACCHO represents the leaders of the nearly 3000 local public health agencies in--cities, counties and towns--who serve on the front lines in protecting and promoting the health of their communities. Should you have any questions concerning these comments, please contact Phillip Bouton, Program Manager, Tobacco Use Prevention and Control Project, at or at 202-783-5550.
Thomas L. Milne