July 20, 2000

Secretary
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, NW
Washington, DC 20680
Sent by e-mail: SMOKELESS@ftc.gov

RE: 16 CFR Part 307

Comments on the Smokeless Tobacco Warning Label Regulations

Dear Secretary:

Approximately 86,000 Oregonians use smokeless tobacco. The health hazards of smokeless tobacco are well-documented. Prevention of those illnesses is a priority for the Tobacco Prevention Program in Oregon, particularly in Eastern Oregon where use is more prevalent than in other parts of Oregon.

In addition to education and community awareness, a powerful tool to prevent people from using smokeless tobacco is the package warning label.

Canada requires larger warning labels on smokeless tobacco products, in larger type and in greater contrast to the background than we require in the US. A comparison of the US warnings to the Canadian warnings done by the Massachusetts Tobacco Control Program, shows several clear findings:

1. the size of the warnings on the package affects the ability of the user to remember that warning

2. the size of the print in the warnings affects the ability of the user to remember that warning

3. the level of contrast between the background and the warnings (black and white vs. shaded type) affects the ability of the user to remember that warning

Because greater recall correlates to greater awareness of the message, it is clear that a significant benefit could be derived from more stringent warning labels in the United States.

Therefore, it is our recommendation that the FTC do the following:

a. adopt the present Canadian smokeless tobacco warnings on smoking tobacco packages.

b. change the current requirement for smokeless tobacco warnings on advertisements so the print size is 24 point type on a black and white background, and 30 point type for a shaded background.

Thank you for your consideration of our recommendations.

Very truly yours,

Clay Parton
Manager
Tobacco Prevention and Education Department