Tue, May 15, 2001 9:32 AM
Subject: Cigarette and Smokeless Tobacco Reports
I am writing to comment on the use of the smokeless tobacco reports issued by the FTC. I am an associate professor and epidemiologist at the University of Florida College of Dentistry, Division of Public Health Services and Research. I regularly use the FTC reports on smokeless tobacco to monitor trends in sales and advertising for smokeless tobacco products. I have included these data have in peer-reviewed publications in scientific and professional journals, presentations at scientific conferences, and lectures to students at several universities and tobacco control workshops. I urge the FTC to continue to require this reporting from the manufacturers of tobacco products.
An additional piece of information that would make the smokeless tobacco reports far more useful would be the reporting of the number of units sold of each category of smokeless tobacco (e.g. moist snuff, loose leaf chewing tobacco), in addition to the total pounds sold. The report currently contains only the number of pounds sold, with the relatively weak justification offered that package sizes vary among manufacturers and products. In reality, the overwhelming majority of moist snuff packaging, for example, contains 1.2 oz., and the majority of loose leaf packages contain 3 oz. of product. The problem is that comparison of sales strictly by weight has led to erroneous conclusions in the press and has masked the trends in moist snuff consumption. Surely, the manufacturers can report sales in units as well as weight.
If the FTC would really like to provide useful information to the American public, it should require smokeless tobacco manufacturers to report the brand-specific contents of its products, including the nicotine concentration, pH of the product (a major determinant of the nicotine dosing characteristics of the product), tobacco-specific nitrosamine concentration, and amount of other additives. Despite evidence presented in peer-reviewed scientic publications and in testimony before the House of Representatives' Subcommittee on Health and the Environment, the major manufacturers of smokeless tobacco products have refused to provide to the American people useful information that could be used to assess the products' potential carcinogenicity and addictive potential. References supporting my statements are contained in the report issued by the FDA in reaching the conclusion that smokeless tobacco is an addictive substance and that its manufacturers are able to manipulate its physiological and psychological effects.
Smokeless tobacco manufacturers should also disclose expenditures and recipients of external research funding. Press releases from industry-sponsored researchers have been used as a form of advertising and promotion for smokeless tobacco products, and the level of activity in this area should be reported to the American people.
The FTC should consider moving the frequency of reporting to an annual report. In its current format, which I think is acceptable, there is no reason that manufacturers could not provide data on sales and advertising on an annual basis rather tha biennually. Public health surveillance works best when the information is as timely as possible, and I do consider this type of data to be one form of surveillance.
I thank you for the opportunity to comment on this issue and for your consideration.
Scott L. Tomar, DMD, DrPH