Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504 #25

Submission Number:
Kevin Keenan
Roswell Park Cancer Institute
New York
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P144504
The FTC's proposed study of electronic cigarettes marketing and sales is necessary and the information gathered will be practically useful. I work to educate communities about the problem of tobacco use, including how the industry drives that use. In my community education activities, I use the information which the NYS Bureau of Tobacco Control (BTC) currently collects via the Research Triangle Institute in North Carolina about tobacco industry marketing. I have found that this data is an effective resource to inform policymakers and support the development of evidence-based policies to counter industry activities and improve public health. Specifically, information about e-cigarettes (which should include all electronic nicotine delivery systems (ENDS) and not simply the devices that look like traditional cigarettes) marketing expenditures, and various media used by product marketers is important to public health initiatives designed to counter industry activities that increase the use of addictive products detrimental to health. My work centers on the effect of point of sale marketing on tobacco use. Tobacco point of sale marketing has been an effective industry tactic to recruit new "replacement" smokers-primarily youth-and to maintain use by existing customers. Retail tobacco marketing increases the likelihood that adolescents will initiate tobacco use and thwarts cessation attempts by current users. Current ENDS marketing mimics traditional cigarette marketing of the past and may have similar effects on initiation of youth ENDS use.Expenditures on ENDS promotion has sharply increased in recent years, particularly through media no longer available to traditional tobacco products (like television)and primarily by the brands owned by large traditional tobacco companies. This advertising is effectively reaching youth--there is high awareness of ENDS advertising among youth and young adults, particularly at the point of sale.This trend is disturbing given the rising popularity of ENDS among youth.While ENDS are relatively new to the market, they are a toxic, addictive product and are yet another form of tobacco. Moreover, ENDS use is associated with increased likelihood of youth use of traditional combustible tobacco products. Thus, it is vital for residents, public health professionals and policymakers to know how marketing and sales affect the community, particularly as it pertains to rising youth use of ENDS. Our communities have too much at stake to allow a disturbing trend like youth use of e-cigarettes to continue without holding manufacturers and marketing companies socially responsible.