Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504 #22

Submission Number:
22
Commenter:
Sharon Fischer
State:
New York
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504
The Federal Trade Commission's (FTC's) proposed study of electronic cigarette marketing and sales is critical to more clearly understand the impact of these new products in our society. I work at the county level as a tobacco control program coordinator and currently use the information provided by the FTC that documents tobacco industry marketing activity. This information is shared with local elected officials and key stakeholders. The elected officials and community members in our community are keenly aware of the relationship between tobacco industry marketing and youth initiation, as exemplified by the results of professional surveys we have conducted. Due to their desire to protect youth from the ravages of tobacco use and their understanding of the influence of pervasive tobacco marketing at the point of sale, the City of Binghamton, NY considered a law in the spring of 2014 prohibiting new tobacco retailers from locating near schools. Due to their concern about the increasing use of e-cigarettes among youth, city council members chose to include retailers of e-cigarettes in the law. Therefore, a law prohibiting new tobacco and e-cigarette retailers from locating near schools passed unanimously and became effective immediately in April of 2014. The use of electronic nicotine delivery systems (ENDS) among youth has been increasing exponentially, tripling among middle and high school youth from 2013 to 2014. This is a troubling trend since almost all ENDS contain nicotine, a very addictive substance, and recent research has found that youth who use ENDS are more likely to smoke conventional cigarettes. In addition, studies have determined the flavoring used in ENDS produces toxins and carcinogens when heated as part of the vaping process. Due to the toxic nature of these products and the fact that youth are increasingly using them, it is very important that good data is available regarding the marketing of these products. We know that current ENDS marketing tactics mimic the way traditional cigarettes were marketed effectively for years. The Surgeon General concluded that tobacco marketing causes tobacco use. Thus it is vital that community members, health professionals and elected officials have reliable data on marketing and sales of ENDs to help stem the tide of youth use. The information that will be gathered should include all ENDS products, not simply the early devices that look like combustible cigarettes. This category of devices is evolving rapidly and it is important to capture data for all product types including but not limited to e-cigarettes, vape pens, e-hookah, etc. It will also be useful to differentiate by manufacturer type (exclusively ENDS producers vs. ENDS and other tobacco product producers) and by product type (disposable, refillable, flavored, unflavored, nicotine containing, non-nicotine containing, etc.) In summary, the FTC's gathering of data related to the marketing and sales of ENDS is imperative to help inform parents, community members, and elected officials that work to protect youth and others from the addictive and toxic effects of yet another tobacco derived product.