Tue, May 15, 2001 3:55 PM
Subject: Cigarette and Smokeless Tobacco Reports
As a public health researcher specializing in the field of adolescent tobacco use, I find the data published in the Federal Trade Commission's (FTC) annual reports on cigarettes, smokeless tobacco, and cigars invaluable.
I absolutely agree that the FTC should continue to collect and publish data regarding cigarette and smokeless tobacco sales, advertising, and promotion. The FTC is currently the only reliable source of this type of data. This is a historic time in tobacco control, with the recent Master Settlement Agreement (MSA), the Engle trial in Florida, the pending Department of Justice lawsuit, pending legislation for the regulation of tobacco by the Food and Drug Administration, and the pending U.S. Supreme Court case concerning the State of Massachusetts's ban on tobacco advertising near schools. The increased public awareness about tobacco industry marketing practices makes access to these data important for concerned citizens. Currently, there is a question as to whether or not the MSA is truly effecting industry marketing efforts toward youth. Several state Attorneys General are suing the tobacco industry, alleging violations of the MSA. The FTC reports are one of the only resources with which to monitor the effect of the Master Settlement Agreement on tobacco industry practices. Because this data is provided by the FTC, the integrity of the data is not questioned. Without FTC annual reports, the public must rely on the tobacco industry and tobacco control advocates to produce or uncover such data, which will introduce substantial bias and make valid conclusions impossible.
Annual reports are the best way to monitor trends over time in tobacco advertising and marketing expenditures. It also allows the effect of major events, such as the MSA, to be studied in a timely fashion. Changing to a biennual format would be very restrictive in terms of the quality of conclusions able to be drawn from the data.
The current format of the reports presents a succinct, yet comprehensive picture of industry expenditures. It is best to have a consistant format for presenting data that is followed longitudinally. Changing the current format will make future research more difficult. Over time, certain categories have been expanded or condensed and this has been clearly noted in the text of the tables. This type of enhancement, which provides further clarification of categories, is quite helpful. State by state expenditures would be very helpful in order to better understand the relationship between marketing expenditures and youth smoking rates. As state legislatures continue to face tobacco-related issues, this information could be helpful. For instance, if a legislature is considering increasing restrictions on youth access to tobacco, it would be helpful to know the extent of retail marketing expenditures statewide. However, this would require a much more extensive operation of data collection and publication. If the FTC is thinking of eliminating the reports altogether, this is not very likely to be feasible.
Although it may not fall under the provisions of the FTC, annual reporting of state cigarette tax levels would also be helpful. The Tobacco Institute used to publish this data. However, the MSA required the disbandment of tobacco industry trade groups. Organizations such as the Tobacco Institute collected and published data that was helpful to both the tobacco industry, tobacco control advocates, and tobacco issue researchers. The elimination of these organizations heightens the need for FTC reporting.
I am worried that the issue of whether or not to continue issuing these reports is due to a decrease in requests for them. Now that the FTC reports are easily accessible on-line, there is no need to go directly through the FTC to obtain this information. It is very important to continue to publish this information and provide ready access to the public. In my personal dealings with tobacco specialists at the FTC, it is extremely difficult to gather any information over the telephone or find a person willing to take the time to send information. Therefore, merely collecting data and not publishing it, may be a waste of resources.
Thank you for your consideration.
Laurie Fisher, SM