Proposal to Rescind FTC Approval of the Current Cigarette Test Method #536798-00027

Submission Number:
Michael Eriksen
Institute of Public Health at Georgia State University
Initiative Name:
Proposal to Rescind FTC Approval of the Current Cigarette Test Method
I am in complete support of the FTC proposal to no longer rely on the Cambridge Filter Method as a basis for making factual statements about tar and nicotine yields. Because this is the final day for public comment, I will not attempt to reiterate the science that supports the FTC's proposal to rescind its guidance, but I encourage the FTC staff and Commissioners to rely on the science that has been succinctly summarized in other submissions, such as those by the Campaign for Tobacco Free Kids and the Roswell Park Cancer Institute. Let me do add, however, on a personal note, that from my experience in tobacco control, rescinding the FTC guidance is an important first step in attempting to rectify the misunderstanding associated with machine-yield tar and nicotine values among the American public, and the purposeful abuse of these values by the tobacco industry. The shame here is that all of the "professionals" (the scientists, the regulators, the industry) know that machine-yield values are not at all a good measure of human exposure, but the humans (i.e., the smoking public) are uninformed, and worse yet, purposefully ill-informed, resulting in unprecedented harm among smokers most concerned about their health and well-being. In my capacity as the longest-serving Director of the US Government's Office on Smoking and Health, I have had extensive opportunity to see first hand the science surrounding the harm caused by smoker compensation of Light cigarettes, as well as having the opportunity of reviewing privileged tobacco industry documents on behalf of the US Department of Justice on the purpose and intent of tobacco industry development of Light products. Through this experience it is clear to me that the use of machine-yield levels of tar and nicotine using the "FTC Method" allowed for purposeful exploitation of smokers wishing to quit smoking and encouraging them to switch to Light cigarettes in an attempt to "assuage" their health concerns, resulting in untold death and suffering. This is truly one of the more unforgivable and callous travesties perpetrated on the public by the tobacco industry. The industry then blames the FTC for their behavior and the public deception. It is clearly high time for the FTC to rescind the machine-yield tar and nicotine guidance and put us on a path for more sensible regulation of the most deadly consumer product known to man.